Text

Day Response to NRC Bulletin 2011-01, Mitigating Strategies.
	ML111640447
Person / Time
Site:	Callaway
Issue date:	06/10/2011
From:	Reasoner C; Ameren Missouri, Union Electric Co
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	BL-11-001, ULNRC-05795
	Download: ML111640447 (6)
	v • d • e

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WAmeren Callaway Plant MISSOURI June 10, 2011 ULNRC-05795 u.s. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 50.54(f)

Ladies and Gentlemen:

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

FACILITY OPERATING LICENSE NPF-30 30-DAY RESPONSE TO NRC BULLETIN 2011-01, "MITIGATING STRATEGIES" Pursuant to 10 CFR 50.54(f), this letter provides the Ameren Missouri (Union Electric Company) 30-day response to NRC Bulletin 2011-01, "Mitigating Strategies," dated May 11, 2011. The bulletin was issued to confirm continued compliance with 10 CFR 50.54(hh)(2) and request information regarding the mitigation strategies program.

The NRC identified the following three objectives:

1. To require that addressees provide a comprehensive verification of their compliance with the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section

50. 54(hb)(2),

2. To notify addressees about the NRC staff's need for information associated with licensee mitigating strategies under 10 CFR 50.54(hb)(2) in light of the recent events at Japan's Fukushima Daiichi facility in order to determine if 1) additional assessment of program implementation is needed, 2) the current inspection program should be enhanced, or 3) further regulatory action is warranted, and

3. To require that addressees provide a written response to the NRC in accordance with 10 CFR 50.54(f).

NRC Bulletin 2011-01 requested that, within 30 days, licensees submit a response to questions to confirm continued compliance with 10 CFR 50.54(hh)(2), and that within 60 days, licensees provide

.. .. .... .... ..................... ........ ........... .... ........... .. ..... ..... .... PO Box 620 Fulton, MO 65251 AmerenMissouri.com

ULNRC-05795 June 10,2011 Page 2 information regarding mitigation strategies programs required by 10 CFR 50.54(hh)(2). Ameren Missouri's 30-day response is provided in the attachment.

This letter does not contain new commitments.

If you have questions regarding this letter please contact Steve Hogan at 573-544-5881 .

I declare under penalty of perjury that the foregoing and attached are true and correct.

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Cleveland O. Reasoner m Vice President Engineering KRA

Enclosure:

1. 30-Day Response to Bulletin 2011-01

VLNRC-05795 June 10, 2011 Page 3 cc: Mr. Elmo E. Collins, Jr.

Regional Administrator US. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 Senior Resident Inspector Callaway Resident Office US. 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 0-8G 14 Washington, DC 20555-2738 Mr. James Polickoski Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U S. Nuclear Regulatory Commission Mail Stop 0-8BIA Washington, DC 20555-2738

ULNRC-05795 June 10, 2011 Page 4 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4200 South Hulen, Suite 630 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 Responses and Reports ULNRC Distribution:

A. C. Heflin F. M . Diya C. O. Reasoner III D . W. Neterer S. P. Banker S. M. Maglio T. B. Elwood S. P. Hogan S. L. Gallagher T. L. Woodward (NSRB)

L. M. Belsky (NSRB)

Mr. Paul Parmenter, Director (SEMA)

Mr. Thomas Mohr, Senior REP Planner (SEMA)

Mr. John Campbell, REP Planner (SEMA)

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. John O'Neill (pillsbury Winthrop Shaw Pittman LLP)

Mr. Dru Buntin (DNR)

Enclosure 1 to ULNRC-05795 30-Day Response to Bulletin 2011-01 The NRC has requested the following information:

In order to confirm continued compliance with 10 CFR 50.54(hb)(2), within 30 days ofthe date of this bulletin, the NRC requests that licensees provide the following information on their mitigating strategies programs.

NRC Request 1 Is the equipment necessary to execute the mitigating strategies, as described in your submittals to the NRC, available and capable ofperforming its intendedfunction?

Ameren Missouri Response 1 Ameren Missouri inspected and inventoried equipment necessary to implement the mitigating strategies required by 10 CFR 50.54 (hb)(2) and verified it was available. With two exceptions, all components were found to be available and functional. Two items were not located, a manifold and hose for venting containment. This condition was documented in our corrective action program and corrective actions are complete. Note that our strategy does provide alternate strategies for the missing equipment. In addition, the portable pump required for some of the strategies was tested to ensure it was capable of performing its intended function with respect to the mitigation strategies.

This inspection and equipment testing was re-performed recently as a result ofthe events at Fukushima. Letters of Agreement! Memorandums of Understanding with offsite organizations were also re-validated and/or re-issued, as appropriate.

NRC Request 2 Are the guidance and strategies implemented capable of being executed considering the current configuration ofyour facility and current staffing and skill levels of the staff?

Ameren Missouri Response 2 Ameren Missouri verified that the mitigation strategies associated with large area fires and explosions are available and capable of being performed as described in our Mitigation Strategy License Condition. Each procedure implementing the required mitigation strategies was walked down to ensure the procedure(s) is in place and capable of being implemented. The mitigation strategies have been maintained. During this verification, one calculation was performed to confirm the upper limit of containment pressure in which the containment depressurization strategy could be used effectively.

This calculation validated that the depressurization strategy would not work within one specific guideline, so it was deleted from that guideline. Note that alternate strategies are provided to depressurize containment. Additionally, a precaution was added to other guidelines where the Page 1 of2 to ULNRC-05795 depressurization strategy is used to note the identified limitation. This condition was documented in our corrective action program and corrective actions are complete.

Ameren Missouri's mitigation strategies continue to meet the commitments described in our B.5.b submittals as documented in the B.5.b Safety Evaluation Report - SER. (See Reference 1 below.)

Further, Ameren Missouri is capable of executing the strategies with the current staffing. As discussed above, each procedure implementing the required mitigation strategies was walked down to ensure the procedures were in place and capable of being implemented. In developing the strategies, Ameren Missouri considered staffing and skill levels in order to perform the strategies. Operations and support staff have had training and periodic retraining, as required, on the mitigation strategies procedures.

In the event of certain threats, plant personnel are directed to disperse in accordance with procedures to maximize survivability in order to implement the strategies should they be needed. Procedures identify the command and control responsibilities, including succession, as appropriate. Procedures are in place to call back fire brigade/security/emergency response organization members to assure adequate staffing in the event of a large fire or explosion.

Reference 1: Callaway Plant, Unit 1 - Conforming License Amendment to Incorporate The Mitigation Strategies Required by Section B.5.b. of Commission Order EA-02-026 (TAC No. MD4518), dated June 27, 2007 Page 2 of2