ML120670110
| ML120670110 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 01/19/2012 |
| From: | Elwood T Ameren Corp |
| To: | Thadani M Plant Licensing Branch IV |
| Thadani, M C, NRR/DORL/LPL4, 415-1476 | |
| References | |
| TAC ME5173 | |
| Download: ML120670110 (1) | |
Text
From:
Elwood, Thomas B [TElwood@ameren.com]
Sent:
Thursday, January 19, 2012 7:19 PM To:
Thadani, Mohan
Subject:
Correction Needed for License Amendment 204 Attachments:
Excerpts from Ameren Missouri Letters.pdf; App C to OL.pdf Mohan -
Sorry for the delay in getting this e-mail note to you about License Amendment 204. As we discussed on the phone last week, I am sending you this e-mail to explain the basis for the correction that need to be made to License Amendment 204.
As you know, License Amendment 204 incorporated a new Surveillance Requirement (SR) into our Technical Specifications. Specifically, new (SR 3.3.8.6 requires the performance of response time testing on the portion of our Emergency Exhaust System (EES) that is designed to effect isolation of the normal fuel building ventilation exhaust flow path and initiate the fuel building ventilation isolation signal (FBVIS) mode of operation in the event of a demand (such as a fuel handling accident).
When we prepared the license amendment request (LAR) that led to Amendment 204, we could not anticipate exactly when the amendment would be received. Since we knew a new SR would go into effect with the issuance (i.e., implementation) of the amendment, we did not want to be caught in a position where we would suddenly have to have met the new SR, if you know what I mean. So, we requested a provision to delay performance of the SR until the next refueling outage. The provision was requested in all of the letters that were submitted for the LAR. [See the attached excerpts from the original request (Ameren Missouri letter ULNRC-05744) and all of the supplements (Ameren Missouri Letters ULNRC-05793, ULNRC-058212 and ULNRC-05812]. The following is the wording that generally appears in these letters:
Since SR 3.3.8.6 is a new Surveillance Requirement, the first required performance will come due by the end of the first surveillance interval that begins or is in effect on the date of implementation of this amendment. (This is similar to the License Condition applied to new Surveillance Requirements added by License Amendment 133 for the Improved Technical Specification conversion.) Since the license amendment will be issued after the start of Refuel 18, SR 3.3.8.6 will first be met during Refuel l9 (Spring 2013).
As we discussed last week, this provision was omitted from License Amendment 204. Our desire is to have this provision stated in some part of the amended license or wherever you think is appropriate. As you indicated in our discussion last week, the NRC can issue a correction to the license amendment to include this provision. That would be greatly appreciated.
I'll just point out one option for you to consider. A previous PM of ours added Appendix C to our License awhile back to list provisions that were just like the one we are asking for now. They were mostly for when we did the ITS conversion, but this Appendix was utilized not too long ago for the amendment that
was issued to us for the Control Room Habitability Issue associated with Generic Letter 2003-01, i.e.,
License Amendment 190. I've attached Appendix C to this e-mail. You could consider use of this Appendix, but I'm sure it's not your only option.
Feel free to call me if you'd like to discuss this further, Mohan. Thanks!
- Tom Tom Elwood Supervising Engineer, Regulatory Affairs and Licensing C 314.225.1905 F 573.676.4202 E telwood@ameren.com Ameren Missouri - Callaway Plant PO Box 620 Fulton, MO 65251 The information contained in this message may be privileged and/or confidential and protected from disclosure. If the reader of this message is not the intended recipient, or an employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. Note that any views or opinions presented in this message are solely those of the author and do not necessarily represent those of Ameren. All e-mails are subject to monitoring and archival.
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