ULNRC-05235, Commitment Statue for NRC Bulletin 2003-01, Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized-Water Reactors.

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Commitment Statue for NRC Bulletin 2003-01, Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized-Water Reactors.
ML053540259
Person / Time
Site: Callaway Ameren icon.png
Issue date: 12/12/2005
From: Keith Young
AmerenUE
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BL-03-001, ULNRC-05235
Download: ML053540259 (5)


Text

A Union Electric PO Box 620 Callaway Plant Fulton, MO 65251 December 12, 2005 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 Ladies and Gentlemen: ULNRC-05235 DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 A t.UNION ELECTRIC CO.

WAmeren FACILITY OPERATING LICENSE NPF-30 COMMITMENT STATUS FOR NRC BULLETIN 2003-01, UF "POTENTIAL IMPACT OF DEBRIS BLOCKAGE ON EMERGENCY SUMP RECIRCULATION AT PRESSURIZED-WATER REACTORS" Ref: 1. ULNRC-048 84, dated August 8, 2003

2. ULNRC-04966, dated March 25, 2004
3. ULNRC-05026, dated July 9,2004
4. ULNRC-05205, dated September 13, 2005
5. NRC letter dated November 16, 2005 from Jack Donohew to Charles Naslund Reference 1 through 4 transmitted the Union Electric Company (AmerenUE) responses to NRC Bulletin 2003-01, "Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized Water Reactor," dated June 9, 2003.

Reference 5 provided NRC closeout of NRC Bulletin 2003-01 for the Callaway Plant.

During the review of the NRC closeout letter, several discrepancies were identified.

On November 30, 2005, a teleconference was held between the NRC Project Manager, and AmerenUE personnel to discuss these concerns. As a result of the teleconference, the NRC Project Manager requested additional information on the status of the commitments made in the references above. Enclosure 1 to this letter provides AmerenUE response to the request for additional information.

In addition, in Reference 5 the reason for not implementing candidate operator actions (COA) 10 - "Termination of one train of HPSI prior to recirculation" at Callaway is not correct. In Reference 3 AmerenUE explained that this action was not implemented due to unacceptable core damage consequences demonstrated by single failure analysis as described in WCAP 16204. B 10 3 This letter does not contain new commitments.

asubsidiary of Ameren Corporsaton

ULNRC-05235 December 12,2005 Page 2 If you have any questions concerning this matter, please contact Dave Shafer at (314) 554-3104.

Sincerely, Keith D. Young Manager - Regulatory Affairs BFH/jdg . Commitment Status Report

ULNRC-05235 December 12, 2005 Page 3 cc: Mr. Bruce S. Mallett Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Jack N. Donohew (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 7E1 Washington, DC 20555-2738 Missouri Public Service Commission Governor Office Building 200 Madison Street PO Box 360 Jefferson City, MO 65102-0360 Mr. Ron Reynolds Director Missouri State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102

i ULNRC-05235 Enclosure 1 Page 1 of 2 STATUS OF COMMITMENTS The following table identifies those actions committed to by AmerenUE in response to NRC Bulletin 2003-01 and their current status.

COMMITMENT SOURCE STATUS DOC. / DATE Procedure OSP-SA-00004, "'Visual Inspection of ULNRC-04884 Completed on Containment for Loose Debris", will be revised as August 8, 2003 10/17/2003.

follows:

  • add a step to verify refueling pool drain pipe screens are not blocked with debris
  • add a step to verify that the radiation barrier gates at the four secondary shield wall entrances are not blocked with debris The work document associated with installation of the ULNRC-04884 Completed on refueling pool drain pipe screens will be revised to ensure August 8, 2003 07/24/2003.

an inspection is performed to ensure no debris or blockage exists in the refueling pool drain pipe.

Callaway Plant will conduct Licensed Operator ULNRC-04884 Completed Continuing Training on indications of and responses to August 8, 2003 The sump sump clogging. The training will include a simulator issues was scenario. taught in LOCT cycle 03-5 Simulator Scenario #4 Callaway Plant will develop and conduct training for the ULNRC-04884 Completed on Technical Support Center engineering staff of the August 8, 2003 03/18/2004.

Emergency Response Organization to provide guidance on the parameters which would indicate that recirculation sump screen blockage may be developing and what mitigating actions should be considered.

Callaway Plant will develop and conduct training for ULNRC-04884 Completed on contractor and plant personnel with unescorted access to August 8, 2003 04/02/2004.

the RCA to increase awareness of the issues related to containment sump screen blockage and the importance of containment cleanliness.

Callaway Plant will conduct training for the engineering ULNRC-04884 Completed on staff to raise awareness of more aggressive containment August 8, 2003 02/23/2004.

cleanliness requirements, the potential for recirculation sump blockage, and actions being taken to address Bulletin 2003-01 concerns.

ULNRC Page 2 of 2 A work document will be planned and performed to ULNRC-04884 Completed on accomplish additional inspections and cleaning, as August 8, 2003 09/05/2003.

required, on targeted horizontal surfaces that are not usually accessed.

Procedural controls will be developed to maintain a more ULNRC-04884 Completed on aggressive cleaning strategy for subsequent refuel outages August 8, 2003 12/17/2004.

(for refuel outages after refuel 13).

Accessible sump screen surfaces will be inspected to ULNRC-04966 Completed on confirm that the sump enclosure boundaries formed by the March 25, 2004 05/13/2004.

middle screens, gratings, and miscellaneous structural steel have no openings that are larger than 1/2 +/- 1/8 inch, or for boundaries formed by the inner screens, gratings, and miscellaneous structural steel that there are no openings larger than 1/8 +/- 1/16 inch. Inspection findings will be evaluated using acceptance criteria contained in plant design documents and any deficiencies identified will be entered into the plant work control and corrective action program to report and resolve the identified deficiency.

Implementation of the following WOG candidate operator ULNRC-05026 Completed on actions at the Callaway Plant as part of the overall July 9, 2004 04/29/2005.

Emergency Operating Procedure (EOP's) upgrade effort.

  • COA 1A - Operator action to secure one spray pump before recirculation alignment
  • COA 5 - Refill of RWST

. COA 8 - Provide Guidance on Symptoms and Identification of CTMT sump blockage

  • COA 9 - Develop contingency actions to be taken in response to CTMT sump blockage

Text

A Union Electric PO Box 620 Callaway Plant Fulton, MO 65251 December 12, 2005 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 Ladies and Gentlemen: ULNRC-05235 DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 A t.UNION ELECTRIC CO.

WAmeren FACILITY OPERATING LICENSE NPF-30 COMMITMENT STATUS FOR NRC BULLETIN 2003-01, UF "POTENTIAL IMPACT OF DEBRIS BLOCKAGE ON EMERGENCY SUMP RECIRCULATION AT PRESSURIZED-WATER REACTORS" Ref: 1. ULNRC-048 84, dated August 8, 2003

2. ULNRC-04966, dated March 25, 2004
3. ULNRC-05026, dated July 9,2004
4. ULNRC-05205, dated September 13, 2005
5. NRC letter dated November 16, 2005 from Jack Donohew to Charles Naslund Reference 1 through 4 transmitted the Union Electric Company (AmerenUE) responses to NRC Bulletin 2003-01, "Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized Water Reactor," dated June 9, 2003.

Reference 5 provided NRC closeout of NRC Bulletin 2003-01 for the Callaway Plant.

During the review of the NRC closeout letter, several discrepancies were identified.

On November 30, 2005, a teleconference was held between the NRC Project Manager, and AmerenUE personnel to discuss these concerns. As a result of the teleconference, the NRC Project Manager requested additional information on the status of the commitments made in the references above. Enclosure 1 to this letter provides AmerenUE response to the request for additional information.

In addition, in Reference 5 the reason for not implementing candidate operator actions (COA) 10 - "Termination of one train of HPSI prior to recirculation" at Callaway is not correct. In Reference 3 AmerenUE explained that this action was not implemented due to unacceptable core damage consequences demonstrated by single failure analysis as described in WCAP 16204. B 10 3 This letter does not contain new commitments.

asubsidiary of Ameren Corporsaton

ULNRC-05235 December 12,2005 Page 2 If you have any questions concerning this matter, please contact Dave Shafer at (314) 554-3104.

Sincerely, Keith D. Young Manager - Regulatory Affairs BFH/jdg . Commitment Status Report

ULNRC-05235 December 12, 2005 Page 3 cc: Mr. Bruce S. Mallett Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Jack N. Donohew (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 7E1 Washington, DC 20555-2738 Missouri Public Service Commission Governor Office Building 200 Madison Street PO Box 360 Jefferson City, MO 65102-0360 Mr. Ron Reynolds Director Missouri State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102

i ULNRC-05235 Enclosure 1 Page 1 of 2 STATUS OF COMMITMENTS The following table identifies those actions committed to by AmerenUE in response to NRC Bulletin 2003-01 and their current status.

COMMITMENT SOURCE STATUS DOC. / DATE Procedure OSP-SA-00004, "'Visual Inspection of ULNRC-04884 Completed on Containment for Loose Debris", will be revised as August 8, 2003 10/17/2003.

follows:

  • add a step to verify refueling pool drain pipe screens are not blocked with debris
  • add a step to verify that the radiation barrier gates at the four secondary shield wall entrances are not blocked with debris The work document associated with installation of the ULNRC-04884 Completed on refueling pool drain pipe screens will be revised to ensure August 8, 2003 07/24/2003.

an inspection is performed to ensure no debris or blockage exists in the refueling pool drain pipe.

Callaway Plant will conduct Licensed Operator ULNRC-04884 Completed Continuing Training on indications of and responses to August 8, 2003 The sump sump clogging. The training will include a simulator issues was scenario. taught in LOCT cycle 03-5 Simulator Scenario #4 Callaway Plant will develop and conduct training for the ULNRC-04884 Completed on Technical Support Center engineering staff of the August 8, 2003 03/18/2004.

Emergency Response Organization to provide guidance on the parameters which would indicate that recirculation sump screen blockage may be developing and what mitigating actions should be considered.

Callaway Plant will develop and conduct training for ULNRC-04884 Completed on contractor and plant personnel with unescorted access to August 8, 2003 04/02/2004.

the RCA to increase awareness of the issues related to containment sump screen blockage and the importance of containment cleanliness.

Callaway Plant will conduct training for the engineering ULNRC-04884 Completed on staff to raise awareness of more aggressive containment August 8, 2003 02/23/2004.

cleanliness requirements, the potential for recirculation sump blockage, and actions being taken to address Bulletin 2003-01 concerns.

ULNRC Page 2 of 2 A work document will be planned and performed to ULNRC-04884 Completed on accomplish additional inspections and cleaning, as August 8, 2003 09/05/2003.

required, on targeted horizontal surfaces that are not usually accessed.

Procedural controls will be developed to maintain a more ULNRC-04884 Completed on aggressive cleaning strategy for subsequent refuel outages August 8, 2003 12/17/2004.

(for refuel outages after refuel 13).

Accessible sump screen surfaces will be inspected to ULNRC-04966 Completed on confirm that the sump enclosure boundaries formed by the March 25, 2004 05/13/2004.

middle screens, gratings, and miscellaneous structural steel have no openings that are larger than 1/2 +/- 1/8 inch, or for boundaries formed by the inner screens, gratings, and miscellaneous structural steel that there are no openings larger than 1/8 +/- 1/16 inch. Inspection findings will be evaluated using acceptance criteria contained in plant design documents and any deficiencies identified will be entered into the plant work control and corrective action program to report and resolve the identified deficiency.

Implementation of the following WOG candidate operator ULNRC-05026 Completed on actions at the Callaway Plant as part of the overall July 9, 2004 04/29/2005.

Emergency Operating Procedure (EOP's) upgrade effort.

  • COA 1A - Operator action to secure one spray pump before recirculation alignment
  • COA 5 - Refill of RWST

. COA 8 - Provide Guidance on Symptoms and Identification of CTMT sump blockage

  • COA 9 - Develop contingency actions to be taken in response to CTMT sump blockage