ML073300475
| ML073300475 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/30/2007 |
| From: | Donohew J NRC/NRR/ADRO/DORL/LPLIV |
| To: | Naslund C Union Electric Co |
| Donohew J N, NRR/DORL/LPL4, 415-1307 | |
| References | |
| GL-03-001, TAC MB9783 | |
| Download: ML073300475 (5) | |
Text
November 30, 2007 Mr. Charles D. Naslund Senior Vice President and Chief Nuclear Officer Union Electric Company Post Office Box 620 Fulton, MO 65251
SUBJECT:
CALLAWAY PLANT, UNIT 1 - RESPONSES TO GENERIC LETTER 2003-01, CONTROL ROOM HABITABILITY (TAC NO. MB9783)
Dear Mr. Naslund:
By letter dated June 12, 2003, the U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2003-01, Control Room Habitability, to (1) alert all holders of operating licenses for nuclear reactor power facilities of the findings at U.S. power reactor facilities suggesting that the control room licensing and design bases, and applicable regulatory requirements may not be met, and that existing technical specification surveillance requirements may not be adequate, (2) emphasize the importance of reliable, comprehensive surveillance testing to verify control room habitability, (3) request the licensees to submit information that demonstrates that their facility control rooms comply with the current facility licensing and design bases, and applicable regulatory requirements, and that suitable design, maintenance and testing control measures are in place for maintaining this compliance, and (4) collect the requested information to determine if additional regulatory action is required.
The NRC acknowledges the receipt of your responses to GL 2003-01 dated August 11, 2003, December 15, 2004, June 6, 2006, and July 16, and October 30, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML032370463, ML050040232, ML061720088, ML072060073, and ML073110132, respectively), for the Callaway Plant, Unit 1 (Callaway).
The GL requested that you confirm that your control room meets the applicable habitability regulatory requirements (e.g., General Design Criteria (GDC) 1, 3, 4, 5, and 19, draft GDC, or principal design criteria), with special attention to the following: (1) determination of the most limiting unfiltered and/or filtered inleakage into the control room and comparison to values used in your facility design bases for meeting control room operator dose limits from accidents (GL 2003-01, Item 1a); (2) determination that the most limiting unfiltered inleakage is incorporated into your hazardous chemical assessments (GL 2003-01, Item 1b); and (3) determination that reactor control capability is maintained in the control room or at the alternate shutdown location in the event of smoke (GL 2003-01, Item 1b). The GL further requested information on any compensatory measures in use at your facility to demonstrate control room habitability, and the plans to retire them (GL 2003-01, Item 2).
C. D. Naslund In your August 11, 2003, letter, you indicated that you were pursuing an alternate Control Room Envelope (CRE) inleakage testing method because, as was stated in the letter, the GL-identified method (i.e., American Society for Testing and Materials (ASTM) E 741-00, Standard Test Method for Determining Air Change in a Single Zone by Means of a Tracer Gas Dilution) would not provide valid results for the Callaway CRE design. Your letter of December 15, 2004, indicated that you had performed an alternate method tracer gas test on September 17-19, 2004, and provided preliminary results. Your letter of June 6, 2006, provided the results of the Brookhaven National Laboratory-developed Atmospheric Tracer Depletion (ATD) test. It was stated that the maximum tested value of CRE unfiltered inleakage in the emergency and pressurization mode was 10.1 cubic feet per minute (cfm) and Control Building unfiltered inleakage was 166 cfm, which were in general agreement with your Callaway dose analysis assumptions.
In your October 30, 2007, letter, you provided the 12 types of information identified in Regulatory Guide (RG) 1.197, Demonstrating Control Room Envelope Integrity At Nuclear Power Reactors, Regulatory Position C.1.3, as being needed for the staff to assess the capability and thus the acceptability of an alternate test method for determining the Callaway CRE inleakage.
In this information, you included details of testing performed at another nuclear plant that demonstrated a correlation in results between ASTM E 741 method and ATD method tests that met the comparability standard of RG 1.197, Regulatory Position 1.2. Although the correlation testing described did not consider a configuration with the unique Control Building/Control Room design of Callaway and how non-conservative an ASTM E 741 method test result might be relative to the ATD method used at Callaway, the NRC staff reviewed the information you provided and determined that, for your design of Control Building pressurization/filtration and Control Room pressurization/filtration, the ATD method test as you described is consistent with the guidance of RG 1.197 and the NRC staff concludes that the ATD method is acceptable for Callaway.
In your letters previously identified, you also provided information that there were currently no onsite or offsite storage or transportation of chemicals that would pose a credible threat to CRE habitability at Callaway. You also indicated that your chemical control program incorporated features necessary to maintain control of hazardous chemicals with respect to CRE habitability and that you had updated your offsite and onside hazardous chemical analysis and confirmed previous assessments. Additionally, your letters stated that that you had an evaluation performed to confirm reactor control capability from either the control room or the alternate shutdown panel in the event of smoke, and confirmed that Callaway meet the Appendix A guidance of Nuclear Energy Institute 99-03, Control Room Habitability Assessment Guidance.
The NRC staff finds these responses are an acceptable response to Item 1(b) of GL 2003-01.
In your December 15, 2004, response letter, you indicated that a license amendment request (LAR) would be submitted to revise your technical specifications for implementing Technical Specification Task Force Traveler (TSTF)-448, Control Room Habitability, as appropriate.
The information you provided in your responses to the GL appears to support your position that no compensatory measures need to be in place to demonstrate control room habitability and that you are committed to meet the General Design Criteria of Title 10 of the Code of Federal Regulations, Part 50, Appendix A, regarding control room habitability.
C. D. Naslund The information provided above and your commitment to submit a LAR based on TSTF-448 is acceptable for purposes of closing out your response to GL 2003-01.
Sincerely,
/RA/
Jack N. Donohew, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483 cc: See next page
ML073300475 OFFICE DORL/LPL4/PM DORL/LPL4/LA DPR/PGCB/BC DSS/SCVB/BC DORL/LPL4/BC NAME JDonohew JBurkhardt MMurphy RDennig THiltz DATE 11/27/07 11/27/2007 11/29/07 11/29/07 11/30/07
Callaway Plant, Unit 1 (November 2007) cc:
John ONeill, Esq.
Pillsbury Winthrop Shaw Pittman LLP 2300 N. Street, N.W.
Washington, D.C. 20037 Mr. Tom Elwood, Supervising Engineer Regulatory Affairs and Licensing AmerenUE P.O. Box 620 Fulton, MO 65251 Mr. Les H. Kanuckel, Manager Quality Assurance AmerenUE P.O. Box 620 Fulton, MO 65251 Mr. Luke Graessle, Manager Regulatory Affairs AmerenUE P.O. Box 620 Fulton, MO 65251 Mr. Scott Maglio Assistant Manager, Regulatory Affairs AmerenUE P.O. Box 620 Fulton, MO 65251 U.S. Nuclear Regulatory Commission Resident Inspector Office 8201 NRC Road Steedman, MO 65077-1302 Missouri Public Service Commission Governor Office Building 200 Madison Street P.O. Box 360 Jefferson City, MO 65102-0360 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Mr. H. Floyd Gilzow Deputy Director for Policy Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102-0176 Mr. Rick A. Muench, President and CEO Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KA 66839 Certrec Corporation 4200 South Hulen, Suite 422 Fort Worth, TX 76109 Technical Services Branch Chief FEMA Region VII 2323 Grand Boulevard, Suite 900 Kansas City, MO 64108-2670 Kathleen Logan Smith, Executive Director and Kay Drey, Representative, Board of Directors Missouri Coalition for the Environment 6267 Delmar Blvd., Suite 2E St. Louis, City, MO 63130 Mr. Lee Fritz, Presiding Commissioner Callaway County Courthouse 10 East Fifth Street Fulton, MO 65251 Mr. Keith G. Henke, Planner III Division of Community and Public Health Office of Emergency Coordination Missouri Department of Health and Senior Services 930 Wildwood Drive P.O. Box 570 Jefferson City, MO 65102 Mr. Scott Clardy, Director Section for Environmental Public Health Missouri Department of Health and Senior Services 930 Wildwood Drive P.O. Box 570 Jefferson City, MO 65102 Director, Missouri State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102-0116