05000483/LER-2010-008-01, Re Inadequate Analysis Results in Component Cooling Water Train Declared Inoperable

Re Inadequate Analysis Results in Component Cooling Water Train Declared Inoperable

ML110600744
Person / Time
Site:	Callaway
Issue date:	02/28/2011
From:	Diya F Ameren Missouri
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ULNRC-05768 LER 10-008-01
Download: ML110600744 (8)

LER-2010-008, Re Inadequate Analysis Results in Component Cooling Water Train Declared Inoperable

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
4832010008R01 - NRC Website

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WAmeren MISSOURI Fadi M. Diva Vice President Nuclear Operations Ameren Missouri Callaway Plant T 573.676.6411 F 573.676.4056 February 28,2011 ULNRC-05768 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Ladies and Gentlemen:

10CFR50.73 DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

FACILITY OPERATING LICENSE NPF-30 LICENSEE EVENT REPORT 2010-008-01 INADEQUATE ANALYSIS RESULTS IN A COMPONENT COOLING WATER TRAIN DECLARED INOPERABLE The enclosed licensee event report (LER) is a revision to LER 2010-008-00, which was submitted on November 22,2010 by letter ULNRC-05745. This revision updates the LER with the long term corrective actions identified for the reported condition.

This letter does not contain new commitments.

CSP/nis Enclosure: LER 2010-008-001 Sincerely, Fadi M Diya Vice President Nuclear Operations Junction CC & Hwy 0 PO Box 620, MC CA-460 Fulton, MO 65251 AmerenMissouri.com

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WAmeren MISSOURI Fadi M. Diva Vice President Nuclear Operations Ameren Missouri Callaway Plant T 573.676.6411 F 573.676.4056 February 28,2011 ULNRC-05768 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Ladies and Gentlemen:

10CFR50.73 DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

FACILITY OPERATING LICENSE NPF-30 LICENSEE EVENT REPORT 2010-008-01 INADEQUATE ANALYSIS RESULTS IN A COMPONENT COOLING WATER TRAIN DECLARED INOPERABLE The enclosed licensee event report (LER) is a revision to LER 2010-008-00, which was submitted on November 22,2010 by letter ULNRC-05745. This revision updates the LER with the long term corrective actions identified for the reported condition.

This letter does not contain new commitments.

CSP/nis Enclosure: LER 2010-008-001 Sincerely, Fadi M Diya Vice President Nuclear Operations Junction CC & Hwy 0 PO Box 620, MC CA-460 Fulton, MO 65251 AmerenMissouri.com

ULNRC-05768 February 28, 2011 Page 2 cc:

Mr. Elmo E. Collins, Jr.

Regional Administrator U.S. Nuclear Regulatory Commission Region IV 612 E. Lamar 8Ivd., Suite 400 Arlington, TX76011-4125 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Mohan C. Thadani (2 copies)

Senior Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8G14 Washington, DC20555-2738 Mr. James Polickoski Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-881 A Washington, DC20555-2738 ULNRC-05768 February 28, 2011 Page 2 cc:

Mr. Elmo E. Collins, Jr.

Regional Administrator U.S. Nuclear Regulatory Commission Region IV 612 E. Lamar 8Ivd., Suite 400 Arlington, TX76011-4125 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Mohan C. Thadani (2 copies)

Senior Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8G14 Washington, DC20555-2738 Mr. James Polickoski Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-881 A Washington, DC20555-2738

ULNRC-05768 February 28, 2011 Page 3 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4200 South Hulen, Suite 422 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)

LEREvents@inpo.orq(must send the WORD version of the LER to this address)

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

A. C. Heflin F. M. Diya C. O. Reasoner III D. W. Neterer L. S. Sandbothe S. A. Maglio S. L. Gallagher T. L. Woodward (NSRB)

T. B. Elwood D. E. Dumbacher (NRC)

B. D. Brooks (WCNOC)

Ms. Diane M. Hooper (WCNOC)

Mr. Tim Hope (Luminant Power)

Mr. Ron Barnes (APS)

Mr. Tom Baldwin (PG&E)

Mr. Wayne Harrison (STPNOC)

Ms. Linda Conklin (SCE)

Mr.JohnO'Neill (Pillsbury Winthrop Shaw Pittman LLP)

Missouri Public Service Commission Records Center (INPO)

ULNRC-05768 February 28, 2011 Page 3 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4200 South Hulen, Suite 422 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)

LEREvents@inpo.orq(must send the WORD version of the LER to this address)

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

A. C. Heflin F. M. Diya C. O. Reasoner III D. W. Neterer L. S. Sandbothe S. A. Maglio S. L. Gallagher T. L. Woodward (NSRB)

T. B. Elwood D. E. Dumbacher (NRC)

B. D. Brooks (WCNOC)

Ms. Diane M. Hooper (WCNOC)

Mr. Tim Hope (Luminant Power)

Mr. Ron Barnes (APS)

Mr. Tom Baldwin (PG&E)

Mr. Wayne Harrison (STPNOC)

Ms. Linda Conklin (SCE)

Mr.JohnO'Neill (Pillsbury Winthrop Shaw Pittman LLP)

Missouri Public Service Commission Records Center (INPO)

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 08/31/2010 (9-2007)

, the NRC may digits/characters for each block) not conduct or sponsor, and a person is not required to respond to, the information collection.

13. PAGE Callaway Plant Unit 1 05000483 1 OF 5

4. TITLE Inadequate Analysis Results in a Component Cooling Water Train Declared Inoperable

5. EVENT DATE

6. LER NUMBER

7. REPORT DATE

8. OTHER FACILITIES INVOLVED SEQUENTIAL REV FACILITY NAME DOCKET NUMBER MONTH DAY YEAR YEAR NUMBER NO.

MONTH DAY YEAR FACILITY NAME DOCKET NUMBER 09 23 2010 2010 008 01 02 28 2011

9. OPERATING MODE

11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR§: (Check all that apply) o 20.2201(b) o 20.2203(a)(3)(i) o 50.73(a)(2)(i)(C) o 50.73(a)(2)(vii) 1 o 20.2201(d) o 20.2203(a)(3)(ii) o 50.73(a)(2)(ii)(A) o 50.73(a)(2)(viii)(A) o 20.2203(a)(1) o 20.2203(a)(4)

[8] 50.73(a)(2)(ii)(B) o 50.73(a)(2)(viii)(B) o 20.2203(a)(2)(i) o 50.36(c)(1)(i)(A) o 50.73(a)(2)(iii) o 50.73(a)(2)(ix)(A)

10. POWER LEVEL o 20.2203(a)(2)(ii) o 50.36(c)(1 )(ii)(A) o 50.73(a)(2)(iv)(A) o 50.73(a)(2)(x) o 20.2203(a)(2)(iii) o 50.36(c)(2) o 50.73(a)(2)(v)(A) o 73.71(a)(4) 100%

o 20.2203(a)(2)(iv) o 50.46(a)(3)(ii)

[8] 50.73(a)(2)(v)(B) o 73.71(a)(5) o 20.2203(a)(2)(v) o 50.73(a)(2)(i)(A) o 50.73(a)(2)(v)(C) o OTHER o 20.2203(a)(2)(vi)

[8] 50.73(a)(2)(i)(B)

[8] 50.73(a)(2)(v)(D)

Specify in Abstract below or in LICENSEE EVENT REPORT (LER)

2. DOCKET YEAR 05000483 2010

6. LER NUMBER I

SEQUENTIAL I REVISION NUMBER NUMBER 008 01

3. PAGE 2

OF

1.

DESCRIPTION OF STRUCTURE(S), SYSTEM(S) AND COMPONENT(S):

The Component Cooling Water (CCW) system [EllS system: CC] consists of two trains with two 100% capacity pumps [EllS system: CC, component: P] per train, each supplying cooling water flow to its independent safety loads and a common service loop. An independent surge tank [EllS system: CC, component: TK] is connected to the suction of each train via a 4-inch line.

The CCW service loop provides flow to safety related and non-safety related loads and as such is constructed of ASME Section III Class III seismic Category I piping with an exception for the ANSI B31.1 non-seismic portion that supplies cooling water to the Radwaste [EllS system: WD] building and Nuclear Sample Station coolers. This non-seismic section of piping is automatically isolated upon the receipt of a Safety Injection Signal (SIS), high flow indication in the non-safety related piping, and low CCW surge tank level.

During normal operation only one train of CCW is connected to the service loop. This train has one pump in operation supplying cooling flow to the service loop. The other three CCW pumps are normally in standby. Additionally, procedures are in place for MODE 4 operation to run two pumps in the train that is supplying both the Residual Heat Removal (RHR) heat exchanger [EllS system: BP, component: HX] and the service loop.

2.

INITIAL PLANT CONDITIONS

The plant was in MODE 1 when the condition was discovered. No structures, systems or components were inoperable at the time of discovery that contributed to this event.

3.

EVENT DESCRIPTION

The event is a postulated pipe break in the non-safety related, non-seismic Category I section of the CCW system downstream of the automatic isolation valves EGHV0069A1B and EGHV0070AlB. The break is postulated to be initiated by an external or seismic event. A break in the supply side was analyzed by the plant's architect engineer in 1985 with a determination that the break would be isolated in sufficient time that adequate net positive suction head (NPSH) would still be available for the CCW pumps.

On September 23, 2010, several non-conservative assumptions were identified in the (If more space is required, use additional copies of (If more space is required, use additional copies of (If more space is required, use additional copies of (If more space is required, use additional copies of (If more space is required, use additional copies of (If more space is required, use additional copies of NRC Form 366A) (17)

6.

CAUSE OF THE EVENT

This is a legacy issue that has existed since initial plant startup.

The cause was inadequate analysis of the effects of a guillotine pipe break in the non-safety related portion of the CCW system due to a seismic event. The difference in hydraulic diameter between the 4-inch diameter make up line from the surge tank to the CCW pumps and the 12-inch diameter line (from the CCW pumps to Radwaste building system loads) was not taken into account.

The calculation, M-EG-12-C, Component Cooling Water System, was performed in 1985 and the preparer is no longer available for comments. Why the difference in hydraulic diameter was not taken into account in this calculation cannot be determined due to the legacy nature of this issue.

7.

CORRECTIVE ACTIONS

As an interim measure, CCW flow to loads in the Radwaste building has been isolated.

During times when CCW flow is needed for the Radwaste building loads, Callaway will comply with the Action requirements of TS 3.7.7, Component Cooling Water System.

Calculation M-EG-12-C, Component Cooling Water System, has been superseded by a new calculation based on a more detailed flow model and newer technology.

A flow orifice will be installed in the safety related seismic Category 1 portion of the CCW supply lines to the Radwaste building. A check valve will be installed in the safety related seismic Category 1 portion of the CCW return lines from the Radwaste building.

8.

PREVIOUS SIMILAR EVENTS

I None identified at this time. 5