ULNRC-06092, Relief Request 13R-16 for Temporary Non-Code Repair of the Train a Component Cooling Water Heat Exchanger

Relief Request 13R-16 for Temporary Non-Code Repair of the Train a Component Cooling Water Heat Exchanger

ML14079A531
Person / Time
Site:	Callaway
Issue date:	03/19/2014
From:	Maglio S Ameren Missouri, STARS Alliance
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ULNRC-06092
Download: ML14079A531 (4)

Text

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WAmeren Callaway Plant MISSOURI March 19, 2014 ULNRC-06092 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 50.55a Ladies and Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

FACILITY OPERATING LICENSE NPF-30 RELIEF REQUEST 13R-16 FOR TEMPORARY NON-CODE REPAIR OF THE TRAIN A COMPONENT COOLING WATER HEAT EXCHANGER Pursuant to 10 CFR 50.55a(a)(3)(ii), Union Electric Company (Ameren Missouri) hereby requests NRC approval of the attached relief request 13R-16. The requested relief is intended for the third 10-year inservice inspection interval of Callaway's Inservice Inspection (lSI) Program. With regard to the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, i.e.,Section XI, "Rules and Inservice Inspection of Nuclear Power Plant Components," the Code Edition and Addenda applicable to Callaway's third 10-year lSI interval is the 1998 Edition with 2000 Addenda.

Per the attached relief request, Ameren Missouri proposes to implement alternative requirements in lieu of requirements contained in ASME Section XI IWA-4000, "Repair/Replacement Activities,"

subject to the NRC staff interpretation provided in Appendix C.12 of Inspection Manual Chapter (IMC) 0326, "Operability Determinations & Functionality Assessments for Conditions Adverse to Quality or Safety," regarding through-wall conditions in Class 3 components. The scope of the request is limited to the train A Component Cooling Water Heat Exchanger (EEG01A), which has developed a pinhole through-wall defect that has resulted in leakage of essential service water (ESW) from the component.

A mid-cycle shutdown to restore the affected component to its design condition in accordance with IWA-4000 would represent a hardship or unusual difficulty without a compensating increase in level of quality or safety. In lieu of the IWA-4000 requirements, Ameren Missouri proposes to apply provisions of IWA -413 3, "Mechanical Clamping Devices used as Piping Pressure Boundary," and Mandatory Appendix IX, "Mechanical Clamping Devices for Class 2 and 3 Piping Pressure Boundaries," for installation of a temporary non-code repair to control ESW leakage.

PO Box 620 Fulton, MO 65251 AmerenMissouri.com STARS* Alliance

ULNRC-06092 March 19, 2014 Page 2 Installation of the mechanical clamping device to provide a credited pressure boundary in the area of the flaw will allow recovery of available margin of stored water volume in the ultimate heat sink (UHS) that exceeds the volume credited in safety analyses.

In accordance with ASME Code Case N-705, which has been accepted by the NRC and incorporated into Revision 16 of Regulatory Guide 1.147, "Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1," Ameren Missouri has performed an evaluation that determined adequate structural integrity of the affected component will be maintained with or without the mechanical clamping device being installed.

To satisfy the requirements of ASME Code Case N-705, Mandatory Appendix IX and NRC Inspection Manual Chapter 0326 Appendix C.12, a permanent internal weld repair that will restore the affected component to full compliance with IWA-4000 is scheduled to be performed in the next refueling outage for Callaway, i.e., Refuel20, which is scheduled to begin in October 2014. Installation of the mechanical clamping device is planned for the week of March 24, 2014. Please be advised, therefore, that Ameren Missouri expects to promptly request verbal approval of the enclosed relief request following submittal of this written request (i.e., prior to March 21, 2014.)

Supporting information and essential details, including justification, is provided in the attached relief request.

This letter does not contain new commitments.

If there are any questions, please contact J. A. Doughty at 573-220-5145.

Sincerely,

-<Jtut{ A. VV\)

Scott A. Maglio,/

Manager, Regulatory Affairs JPKI

Enclosure:

1. 10 CFR 50.55a Request Number BR-16

2. Attachment A: CAR 2012307879 -A CCW HX Pinhole Leak Evaluation

3. Attachment B: Engineering Disposition- EEG01A Temporary Non-Code Leak Repair Page 2

ULNRC-06092 March 19, 2014 Page 3 cc: Mr. Marc L. Dapas Regional Administrator U.S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Fred Lyon Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-881 Washington, DC 20555-2738

ULNRC-06092 March 19, 2014 Page4 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4150 International Plaza Suite 820 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)

Electronic distribution for the following can be made via Other Situations ULNRC Distribution:

F. M. Diya C. 0. Reasoner III D. W. Neterer L. H. Graessle B.L.Cox S. A. Maglio T. B. Elwood Corporate Communications NSRB Secretary STARS Regulatory Affairs Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)

Missouri Public Service Commission