View source for ML18164A028

{{Adams
| number = ML18164A028
| issue date = 06/07/2018
| title = LER 2018-002-00 for Calvert Cliffs, Unit 1, Items Non-Conforming to Design for Tornado Missile Protection
| author name = Tierney T A
| author affiliation = Exelon Generation Co, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000317, 05000318
| license number = DPR-053, DPR-069
| contact person = 
| document report number = LER 2018-002-00
| document type = Letter, Licensee Event Report (LER)
| page count = 5
}}

=Text=
{{#Wiki_filter:Exelon Generation June 7, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Calvert Cliffs Nuclear Power Plant, Units No. 1 and 2 Todd A. Tierney Plant Manager Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657 410 495 5205 Office 484-459-0142 Mobile www.exeloncorp.com todd.tierney@exeloncorp.com 10 CFR 50.73 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 

==Subject:==
Licensee Event Report 2018-002, Revision 00 Items Non-Conforming to Design for Tornado Missile Protection The attached report is being sent to you as required by 1 O CFR 50.73. There are no regulatory commitments contained in this correspondence.
Should you have questions regarding this report, please contact Mr. Larry D. Smith at (410) 495-5219. Respectfully, QC~ for Todd A. Tierney Plant Manager TAT/PSF/bjm 

==Attachment:==
As stated cc: NRC Project Manager, Calvert Cliffs NRC Regional Administrator, Region I NRC Resident Inspector, Calvert Cliffs S. Gray, MD-DNR  
.. NRC FORM366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY 0MB: NO. 3150-0104 EXPIRES: 03/31/2020 (04-2018) Estimated burden per response to comply with this mandatory collection request: 80 hours. r)-vP.AEGt,~ LICENSEE EVENT REPORT (LER) Reported lessons learned are incorporated into the licensing process and fed back to ~.:> >-o industry. Send comments regarding burden estimate to the Information Seivices Branch 0, (See Page 2 for required num~er of digits/characters for each block) (T-2 F43), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e-mail to I! <> lnfocollects.Resource@nrc.gov, and to the Desk Officer, Office of Information and Regulatory .. 0 \j; "' Affairs, NEOB-10202, (3150-0104), Office of Management and Budget, Washington, DC 20503. J (See NUREG-1022, R.3 for instruction and guidance for completing this form If a means used to impose an information collection does not ~.,.., ~&'d httQ://www.nre.gov/reading-rm/doc-coll ections/nu regs/staff/sr1 022/r3/) disp~y a currently valid 0MB control number, the NRC may not conduct or sponsor, and a person Jt, ........ is not required to respond to, the information collection. 1. Facility Name 2. Docket Number 3.Page Calvert Cliffs Nuclear Power Plant, Unit 1 05000317 1 OF 4 4. Title Items Non-Conforming to Design for Tornado Missile Protection 5. Event Date 6. LEA Number 7. Report Date 8. Other Facilities Involved I Sequential I Rev Facility Name Docket Number Month Day Year Year Number No. Month Day Year Calvert Cliffs Nuclear Power Plant Unit 2 05000 318 Facility Name Docket Number 05 14 2018 2018 -002 -00 06 07 2018 05000 9. Operating Mode 11. This Report is Submitted Pursuant to the Requirements of 1 O CFR &sect;: (Check all that apply) D 20.2201(b) D 20.2203(a)(3)(i)
D 50.73(a)(2)(ii)(A)
D 50.73(a)(2)(viii)(A)
D 20.2201 (d) D 20.2203(a)(3)(i1) 
[8J 50.73(a)(2)(ii)(B)
D 50.73(a)(2)(viii)(B) 1 D 20.2203(a)(1) () 20.2203(a)(4) D so.73(a)(2)(iii)
D 50.73(a)(2)(ix)(A)
D 20.2203(a)(2)(i)
D 50.36(c)(1)(i)(A)
D 50.73(a)(2)(iv)(A)
D 50.73(a)(2)(x) 10. Power Level D 20.2203(a)(2)(ii)
D 50.36(c)(1)(ii)(A)
D 50.73(a)(2)(v)(A)
D 73.71(a)(4) D 20.2203(a)(2)(iii)
D so.36(c)(2) D 50.73(a)(2)(v)(B)
D 73.71(a)(s) D 20.2203(a)(2)(iv)
D so.46(a)(3)(ii)
D 50.73(a)(2)(v)(C)
D 73.77(a)(1) 100 D 20.2203(a)(2)(v)
D 50.73(a)(2)(i)(A) l8J 50.73(a)(2)(v)(D)
D 73.77(a)(2)(i) D 20.2203(a)(2)(vi) l8J 50.73(a)(2)(i)(B) l8J 50.73(a)(2)(vii)
D 73.77(a)(2)(ii) 
" .. D D Other (Specify in Abstract below or in NRG Form 366A) " ,. 50.73(a)(2)(i)(C) 
: 12. Licensee Contact for this LEA Licensee Contact relephone Number (Include Area Code) Patricia Furio, Principal Regulatory Engineer 41 0-495-437 4 13. Complete One Line for each Component Failure Described in this Report Cause System Component Manufacturer Reportable to ICES Cause System Component Manufacturer Reportable to ICES NIA NIA 14. Supplemental Report Expected Month Day Year D Yes (If yes, complete 15. Expected Submission Date) [8J No 15. Expected Submission Date Abstract (Limit to 1400 spaces, i.e., approximately 14 single-spaced typewritten lines) On May 14, 2018, Calvert Cliffs Nuclear Power Plant determined that the Saltwater subsystems on both Units 1 and 2 do not conform with the licensing basis for protection against a tornado generated missile. The Saltwater system header is vulnerable to a tornado missile that enters the Intake Structure through the watertight door, IS-2. An extent of condition review did not identify any additional items that are non-conforming to the design basis for a tornado missile. Upon determination of the initial non-conformance for the Saltwater system subsystems, both Saltwater subsystems were declared inoperable for both Units. Compensatory measures were put in place and verified. Therefore, in accordance with the NRC Enforcement Guidance Memorandum EGM 15-002, both Saltwater system subsystems were returned to operable but non-conforming status and an 8-hour ENS Notification was made to the NRC. This condition has been in existence since original licensing of the plant. It is not known if it was overlooked or considered acceptable at the time of the original licensing process. There are no actual consequences as a result of the non-conforming condition. NRC FORM 366 (04-2018)
NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY 0MB: NO. 3150-0104 EXPIRES: 03/31/2020 (04-2018) +~,;,'-V,'R Rl:cc,,1_.0 Estimated burden per response to comply with this mandatory collection request: 80 hours. Reported &sect; ''l LICENSEE EVENT REPORT (LER) lessons learned are incorporated into the licensing process and fed back to industry. Send comments ; regarding burden estimate to the Information Services Branch (T-2 F43), U.S. Nuclear Regulatory 0 ' ~,.,' '~ CONTINUATION SHEET Commission, Washington, DC 20555-0001, or by e-mail to lnfocollects.Resource@nrc.gov, and to .,,,., ~Q ,, ........ the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, (3150-0104), Office of Management and Budget, Washington, DC 20503. If a means used to impose an information collection (See NUREG-1022, R.3 for instruction and guidance for completing this form does not display a currently valid 0MB control number, the NRG may not conduct or ht!Q://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1022/r3/)
sponsor, and a person is not required to respond to, the information collection. 1. FACILITY NAME 2. DOCKET NUMBER 3. LEA NUMBER YEAR SEQUENTIAL REV Calvert Cliffs Nuclear Power Plant Unit 1 05000317 NUMBER NO. 2018 -002 -NARRATIVE PLANT AND SYSTEM IDENTIFICATION Calvert Cliffs Nuclear Power Plant, Units 1 and 2, are Combustion Engineering Pressurized Water Reactors with a licensed maximum power level of 2737 megawatts thermal. The Energy Industry Identification System codes used in the text are identified as [XX]. A. CONDITION PRIOR TO EVENT Units 1/2 Date: May 14, 2018 Power level: 100 percent/100 percent Mode: 1/1 There were no structures, systems, or components (SSCs) out-of-service that contributed to this event. B. DESCRIPTION OF EVENT On May 14, 2018 during evaluation of protection for Technical Specification equipment from the damaging effects of a tornado generated missile, it was determined that a non-conforming condition exists with the Saltwater [BS] System subsystem piping [PSP] with respect to tornado missile protection. Specifically, since a tornado generated missile could strike Saltwater system subsystem piping on either Unit, the design does not meet the licensing basis and a conforming condition exists. This condition was entered into the corrective action program (separate entries for each Unit) and the NRG was notified via Event Notification 53401 on May 14, 2018. This event is reportable in accordance with 1 O CFR 50. 73(a)(2)(i)(B) as a condition prohibited by Technical Specification; 1 O CFR 50. 73(a)(2)(ii)(B) as an event or condition that resulted in the nuclear power plant being in an unanalyzed condition that significantly degraded plant safety; 1 O CFR 50.73(a)(2)(v)(D) as an event or condition that could have prevented the fulfilment of the safety function of SSCs that are needed to mitigate the consequences of an accident, and 10 CFR 50.73(a)(2)(vii) as an event where a single cause or condition caused two independent trains to become inoperable in a single system. C. CAUSE OF EVENT This condition was part of the original plant design and has existed since the initial construction and licensing of the plant. Calvert Cliffs Unit 1 received its initial operating license on July 31, 1974 and Calvert Cliffs Unit 2 received its initial operating license on August 13, 1976, based in part on the design as described in the Final Safety Analysis Report (FSAR). The cause of the conforming condition is a legacy design issue that was identified as part of the response to Regulatory Information Summary 2015-06, "Tornado Missile Protection." 00 NRG FORM 366A (04-2018) Page _2_ of ...+/-....
NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY 0MB: NO. 3150-0104 EXPIRES: 03/31/2020 (04-2018) ~c..._v,.fl.ftl;Gu1..,"'o Estimated burden per response to comply with this mandatory collection request: 80 hours. Reported . .. LICENSEE EVENT REPORT (LER) lessons learned are incorporated into the licensing process and fed back to industry. Send comments i regarding burden estimate to the lnlormation Services Branch (T-2 F43), U.S. Nuclear Regulatory ... ~I) '~rt[ CONTINUATION SHEET Commission, Washington, DC 20555-0001, or by e-mail to lnfocollects.Resource@nrc.gov, and to ......... the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, (3150-0104), Office of Management and Budget, Washington, DC 20503. If a means used to impose an inlormation collection (See NUREG-1022, R.3 for instruction and guidance for completing this form does not display a currently valid 0MB contra\* number, the NRG may not conduct or htt12://www.nrc.gov/reading-nn/doc-co\lections/nuregs/staff/sr1022/r3D sponsor, and a person is not required to respond to, the inlormation collection. 1. FACILITY NAME 2. DOCKET NUMBER 3. LER NUMBER YEAR SEQUENTIAL REV Calvert Cliffs Nuclear Power Plant Unit 1 05000317 NUMBER NO. 2018 -002 NARRATIVE D. SAFETY ANALYSIS There are no actual consequences resulting from this identified non-conforming condition. A tornado that could produce the design basis missile is highly unlikely in the mid-Atlantic region. The probability of a design basis missile striking the Saltwater System subsystem piping in a fashion to render the SSC inoperable is also very low. The FSAR described characteristics of the design basis tornado wind hazard and tornado generated missile hazard. These design requirements are stated as: -* "Differential bursting pressure between the inside and outside of the containment structure is assumed to be 3 pounds per square inch positive pressure.
* Lateral force is assumed as the force caused be a tornado funnel having a peripheral tangential velocity of 300 mph and a forward progression of 60 mph. The provisions for gust factors and variation of wind velocity with height do not apply.
* A tornado driven missile equivalent to a 4000 pound automobile flying through the air at 50 mph and at not more than 25 feet above the ground or a 4 inch by 12 inch by 12 foot long piece of wood traveling end-on at 300 mph at any height." NRG Enforcement Guidance Memorandum, EGM 15-002, Revision 1, provides for the application of NRG enforcement discretion which allows the identified non-conforming conditions on each Unit to be returned to an operable status based on the application of compensatory measures which are intended to reduce the likelihood that th*e tornado event would result in a failure of the Saltwater system subsystem on either Unit. Calvert Cliffs has applied the guidance in EGM 15-002, Revision 1 and NRG DSS-ISG-2016-01, Revision 1, Appendix A to determine the acceptable initial compensatory measures necessary to ensure that the identified non-conforming condition could be treated by the NRG with enforcement discretion. E. CORRECTIVE ACTIONS Compensatory measures were implemented in accordance with NRG guidance contained in EGM 15-002 (revision 1) and DSS-ISG-2016-01 (revision 1) as described earlier. Enforcement discretion provided by EGM 15-002 remains in effect until June 10, 2020 for Calvert Cliffs, at which time modifications, analysis, license amendments, or other actions must be implemented to fully resolve the issue. F. PREVIOUS OCCURRENCES No previous similar events have occurred at the site within the last 5 years. 00 NRC FORM 366A (04-2018) Page _3_ of --1..._  
*) \ NRC FORM 366A (04-2018) ~<)QJ."R ll&#xa3;Cc,t...,.0'9 :*: % .. +.., +ct$ .... ii .. U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER) CONTINUATION SHEET (See NUREG-1022, R.3 for instruction and guidance for completing this form htt12://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1022/r3l)
APPROVED BY 0MB: NO. 3150-0104 EXPIRES: 03/31/2020 Estimated burden per response to comply with this mandatory collection request: 80 hours. Reported lessons learned are incorporated into the licensing process and fed back to industry. Send comments regarding burden estimate to the Information Services Branch (T-2 F43), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e-mail to lnfocollects.Resource@nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, (3150-0104), Office of Management and Budget, Washington, DC 20503. If a means used to impose an information collection does not display a currently valid 0MB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection. 1. FACILITY NAME 2. DOCKET NUMBER 3. LEA NUMBER YEAR SEQUENTIAL REV Calvert Cliffs Nuclear Power Plant Unit 1 05000317 NUMBER NO. 2018 -002 -00 NARRATIVE G. COMPONENT FAILURE DATA No component failures were identified. NRC FORM 366A (04-2018) Page_4_ of ....1.....}}