ML13156A352
| ML13156A352 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 06/05/2013 |
| From: | Ameren Missouri, Union Electric Co |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML131560446 | List: |
| References | |
| ULNRC-05994 | |
| Download: ML13156A352 (31) | |
Text
Enclosure 1 - ULNRC-05994 June 05, 2013 Page 1 of 31 CALLAWAY PLANT UNIT 1 LICENSE RENEWAL APPLICATION Technical Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1
- ULNRC-05994 June 05, 2013 Technical Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 Page 2 of 31 No.
SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section
- 1.
1-5 1.3 In the fifth paragraph, the NRC does not conclude whether the Indemnity Agreement requires revision.
Add a concluding sentence. (If the license number changes with the LRA amendment, a conforming change to the Indemnity Agreement is needed; If the license number is unchanged, Ameren believes no changes are necessary.)
- 2.
1-7 1.5 In the third and fourth paragraphs under Open Item 2.3.3.20-1, ULNRC-05877 dated 7/2/12 did not state that the referenced systems "are not required to function in case of a fire or for compliance with 10 CFR 50.48."
Revise the sentence as follows:
" they are not required to function to suppress a fire or are not required for compliance with to meet the criteria of 10 CFR 50.48."
- 3.
2-9 2.1.4.1.2 In the application of scoping criteria in (a)(1), last paragraph of the page, the sentence should apply to main steam and main feedwater, not main steam and steam generator blowdown.
Revise paragraph as follows:
The staff reviewed the supplemental response to RAI 2.1-2 and the response to RAI 2.3.4.2-1, as documented in SER Section 2.3.4.2, and determined that the applicant had performed an evaluation and provided a basis for the main steam supply and steam generator blowdown main feedwater systems indicating that: (1) the safety-related to nonsafety-related interface was located in the wall connecting the safety-related auxiliary building and nonsafety-related turbine building and (2) the FSAR documented the results of an analysis that concluded a failure of the nonsafety-related piping attached to safety-related piping and located in the turbine building would not affect the intended function of the attached safety-related pipe.
- 4.
2-17 2.1.4.5.1 The block quote after the third paragraph of SER Section 2.1.4.5 is accurate but the title and section that introduce it in the third paragraph of SER Section 2.1.4.5 are not. The block quote can be Revise the third paragraph as follows:
LRA Section 2.3.1 2.1.3.1, Scoping Methodology Determination of the License Renewal Boundary, states
- ULNRC-05994 June 05, 2013 Technical Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 Page 3 of 31 No.
SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section found in LRA Section 2.1.3.1, which is titled Determination of the License Renewal Boundary.
in part:
- 5.
2-28 2.3.1.1.1 The first sentence of the first paragraph of SER Section 2.3.1.1.1 is not consistent with LRA Section 2.3.1.1. The SER should not include reactor vessel internals as a pressure boundary.
Revise the sentence as follows:
LRA Section 2.3.1.1 states that the purpose of the reactor vessel and internals is to function as a RCS pressure boundary which acts as a barrier to prevent the release of radioactivity generated within the reactor.
- 6.
2-28 2.3.1.1.1 The SER states the vessel is supported by pads on the bottom of each of the nozzles.
The vessel is supported by pads on the bottom of 4 of the 8 nozzles. Refer to FSAR (SP) Figure 5.4-13.
Delete the following sentence:
The vessel is supported by pads on the bottom of each of the nozzles.
- 7.
2-29 2-30 2.3.1.2.1 Last sentence of the first paragraph discusses the functions of the head vent system. This is not discussed in the LRA Section 2.3.1.2. Recommend deleting the head vent sentences. This same comment applies to the second bullet on page 2-30 as well.
Delete the following sentences:
Pg. 2-29:
A reactor vessel head vent system is provided for the removal of non-condensable gases and for additional letdown capability from the RCS.
Pg. 2-30:
to provide for the removal of non-condensable gases and for additional letdown capability from the RCS using the reactor vessel head vent system
- 8.
2-33 2.3.2.1 The first paragraph of Section 2.3.2.1, second sentence, should state that trisodium phosphate is used to raise the pH, as indicated in LRA Section 2.3.2.1.
Revise the sentence as follows:
The containment spray system also delivers sodium hydroxide from the spray additive system to mix with the borated spray water uses trisodium phosphate for pH control to promote absorption of airborne iodine from
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SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section the containment atmosphere, should this fission product be released in an accident.
- 9.
2-33 2.3.2.1 The third paragraph of Section 2.3.2.1 should refer to containment spray system component types instead of pressurizer component types.
Revise the sentence as follows:
The intended functions of the pressurizer containment spray component types within the scope of license renewal include the following:
- 10.
2-36 2.3.2.5.1 In the last sentence of the first paragraph, the purpose of the BRWS should include supplying borated water to the containment spray system, to be consistent with the first paragraph in the BRWS description in LRA Section 2.3.2.5.
Revise the sentence as follows:
The purpose of the BRWS system is to store borated water so that it is available to the refueling pool during refueling, the chemical and volume control (CVC) system during abnormal operating conditions, and the containment spray system and ECC system during accident conditions.
- 11.
2-77 2.3.4.2.1 In the third paragraph on the page, the first sentence incorrectly includes the steam generator blowdown system as having torsional restraints.
The blowdown system has isolation restraints. This paragraph applies only to the main steam and main feedwater systems.
Revise the sentence as follows:
The staff reviewed the applicants FSAR assessment, RAI response, and supplemental plant drawings of the "no break zones" and torsional restraints for the main steam, and main feedwater, and steam generator blowdown systems.
- 12.
2-85 2.4.3.1 Delete last sentence in the first paragraph in SER section 2.4.3.1 (Auxiliary Building). The system description paragraph in LRA Section 2.4.4 identifies that the auxiliary boiler room is evaluated with the turbine building.
Delete the following sentence:
The structure also houses the auxiliary boiler room that is evaluated with the turbine building.
- 13.
2-88 2.4.6.1 The first paragraph on top of page is missing a reference to SBO. Revise to be consistent with the opening paragraph of SER Section 2.4.6.1.
Revise the sentence as follows:
The intended function of the miscellaneous in-scope structures is support fire protection (10 CFR 50.48) and
- ULNRC-05994 June 05, 2013 Technical Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 Page 5 of 31 No.
SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section SBO (10 CFR 50.63) in accordance with the requirements
- 14.
2-89 2.4.7.2 Add non to safety-related in the first sentence of the second full paragraph.
Revise the sentence as follows:
The staff noted LRA Section 2.4.7 only lists the Category I safety-related RWST and valvehouse, the nonsafety-related CST, and the FWST as the tanks within the scope of license renewal.
- 15.
2-93 2.4.12.1 Add supports for in two locations in the first paragraph, first sentence.
Revise the sentence as follows:
In LRA Section 2.4.12, the applicant described the supports commodity as including supports for American Society of Mechanical Engineers (ASME) Class 1, 2, and 3 piping and components, and supports for non-ASME piping and components evaluated as commodities across system boundaries.
- 16.
2-95 2.5.1.1 In the sentence under the bulleted list of component types, add "expansion/separation" to the list of intended functions for consistency with LRA Table 2.5-1 for component type Metal Enclosed Bus (Enclosure).
Revise the sentence as follows:
"The intended functions of the electrical and I&C systems component types within the scope of license renewal are to provide electrical continuity, expansion/separation, structural support, and electrical insulation"
- 17.
3-11 3.0.3.1.1 The first sentence of the second paragraph of Section 3.0.3.1.1 requires revision. The statement regarding IWB-3000, IWC-3000, and IWD-3000 is in the basis document, but not the LRA.
Delete the following sentence:
In addition, the LRA states that indications and relevant conditions detected during examinations are evaluated in accordance with the ASME Code Section XI, Articles IWB-3000, IWC-3000, and IWD-3000.
- ULNRC-05994 June 05, 2013 Technical Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 Page 6 of 31 No.
SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section
- 18.
3-12 3.0.3.1.1 Revise the second paragraph under Staff Evaluation, which discusses the RI-ISI program, to include the following:
Reword the first sentence. The GALL Report does not mention explicit examination categories.
The Callaway RI-ISI program covers Class 1 and Class 2 welds, not just Class 1.
Examination category R-A is replacing B-F, B-J, C-F-1, and C-F-2, not just B-F and B-J.
Revise the paragraph as follows:
The "detection of aging effects" program element in GALL Report AMP XI.M1 states that ASME Code Section XI Tables IWB-2500-1 and IWC-2500-1 are is used to determine the examination requirements for Class 1 and Class 2 components, respectively. of Categories B-F and B-J welds. The staff noted that the applicant implemented risk-informed inservice inspection (RI-ISI) with Examination Category R-A in lieu of Categories B-F, and B-J, C-F-1, and C-F-2 for the current 10-year ISI interval as approved by the NRC. The RI-ISI provides alternative inspection requirements for a subset of Class 1 and Class 2 piping welds.
- 19.
3-12 3.0.3.1.1 In the second paragraph under Operating Experience, reword the description of the flaw to characterize it more accurately. The fabrication flaw was not initially on the inside surface, but propagated to the inside surface.
Revise the sentence as follows:
The applicants evaluation concluded that the indication was a result of a fabrication. The flaw had propagated to on the inside surface, but and that the growth toward the outside surface was minimal to nonexistent.
- 20.
3-15 3.0.3.1.2 Revise the first bullet at the top of page 3-15 to be consistent with the Operating Experience described in LRA Section B2.1.2, item 2.
Revise as follows:
Following the replacement of the steam generators in 2005, the applicant implemented an optimized methoxy-propyl-amine/ethanol-amine chemistry plan, which, along with the replacement of key susceptible piping with more corrosion resistant material significantly reduced corrosion transport rates in the extraction steam and drain piping.
- 21.
3-15 3.0.3.1.2 Revise the second bullet, second sentence, to be consistent with the Operating Experience described in LRA Section B2.1.2, item 5.
Revise the paragraph as follows:
The sulfate spike later was identified as oxalic acid,
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SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section which is found in lubricants used in cutting, drilling, and hydrostatic expansion of the steam generator components. Oxalates degrade the performance of ion chromatographs, causing false sulfate measurements.
The oxalates were removed by the letdown mixed beds.
- 22.
3-17 3.0.3.1.3 Correct conversion error in second paragraph.
Revise the sentence as follows:
and is threaded to 6.73 6.67 cm (2.625 in.) above the base of the stud hole
- 23.
3-17 3.0.3.1.3 In the fourth paragraph on the page, beginning with "The staff finds that" the description of the request in RAI B2.1.3-1a is not consistent with the docketed RAI.
Revise the paragraph as follows:
By letter dated October 24, 2012, the staff issued RAI B2.1.3-1a to request that the applicant provide additional information regarding its basis for the adequacy of stud No. 18 to perform its intended function during the period of extended operation, considering that it has remained stuck since 1996. for determining that all of the engaged threads for stud No. 18 are undamaged. In addition, the staff requested that the applicant provide the analyses and the specific details of inspection results performed on stud No. 18 used to support the determination that stud No. 18 has 16.52 cm (6.505 in.) of thread engagement, and that the of a required minimum thread engagement of is 16.03 cm (6.31 in.).
- 24.
3-17 3.0.3.1.3 Revise the last paragraph on page 3-17 to add a sentence from the November 20th 2012 RAI response about thread condition.
Revise the paragraph as follows:
"In its response dated November 20, 2012, the applicant also stated that the threads for stud No. 18 and its stud hole were inspected immediately prior to installation of
- ULNRC-05994 June 05, 2013 Technical Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 Page 8 of 31 No.
SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section the stud. The applicant stated, at that time, the threads were intact. The applicant"
- 25.
3-18 3.0.3.1.3 Correct the conversions in the first and fourth full paragraphs.
Revise the conversions as follows:
16/83 6.67 cm (2.625 in.)
- 26.
3-18 3.0.3.1.3 In the first full paragraph on page 3-18, the RAI response (November 20, 2012) did not state that the 6.31 inches is required to meet ASME Code limits.
Delete the following sentence:
The applicant also provided the basis for stating that only 16.03 cm (6.31 in.) of thread engagement is required to meet the ASME Code limits.
- 27.
3-18 3.0.3.1.3 In the second full paragraph on the page, the burr is described as two burrs. It was only one burr. In addition, the SER describes removal of the burr as rework. From an ASME perspective, removal of the burr did not qualify as rework.
Revise the paragraph as follows:
In addition, in its previous response the applicant had stated that a burr was removed from threads 10 and 11 on stud No. 18 had two locations on threads 10 and 11, which were reworked just before the stud getting stuck (burrs that were removed) just before the stud was inserted..
- 28.
3-19 3.0.3.1.3 In the fifth paragraph under Operating Experience, the paraphrase of part (a) of RAI B2.1.3-2 implies that every location where there was damage to threads had a stuck stud, which is not true.
Recommend copying the request from the original RAI (NRC letter dated July 18, 2012).
Revise the paragraph as follows:
Identify all missing stud or stud hole threads. For each location, identify when the RPV flange assembly studs or stud hole locations have had past experience with stuck studs, when damage was first detected, and summarize the corrective actions taken to resolve the issue. Identify all RPV flange assembly studs or stud hole locations that have had past experience with stuck studs, damage, or missing stud/stud hole threads. For each location, identify when the issue was first detected, and summarize the corrective actions that were taken to resolve the issue.
- ULNRC-05994 June 05, 2013 Technical Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 Page 9 of 31 No.
SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section
- 29.
3-20 3.0.3.1.3 In the second full paragraph, the text does not match RAI B2.1.3-2a request (issue portion)(NRC letter dated October 24, 2012).
Revise the sentence as follows:
"Moreover, the staff is uncertain how future RPV closure stud bolting issues will be assessed during the period of extended operation in this respect (e.g., if all additional stud locations became damaged over time)."
- 30.
3-21 3.0.3.1.3 In the fifth paragraph on the page, the sentence regarding the two threads should be reworded to more accurately characterize the burr on the stud.
Removal of the burr was not considered rework in the sense of an ASME repair. Also, it should be clarified that the risk of plastic deformation is to the threads.
Revise the paragraph as follows:
Since the applicant stated that a burr was removed from threads 10 and 11 two threads on the No. 18 stud were re-worked, it is not clear to the staff that recommendation 2 from the 1989 report will be met for this location. Furthermore, recommendation 4, (also from the 1989 report) stated, in part, that if damage approaches the limiting values, or if the vessel is operated with a missing stud, vessel hyrdotests should be avoided, and the plant heat-up rate limited to 50 ºF in order to minimize the risk of localized plastic deformation to the threads.
- 31.
3-23 3.0.3.1.4 In the fifth paragraph, last sentence, use of the word "obscures" in the SER is inconsistent with the text in AMP audit report (NRC letter dated August 9, 2012).
Revise the sentence as follows:
"when leakage from other locations obscures interferes with the visual examinations of the reactor vessel nozzle welds and other RCPB components specified in ASME Code Cases N-770-1 and N-722-1."
- 32.
3-27 3.0.3.1.4 In the third full paragraph, third sentence, there is a minor text difference between the SER and response letter August 21, 2012.
Revise the sentence as follows :
"The applicant further indicated that as described in its corrective action documents, the exposure of the low alloy carbon steel base metal was caused by (1) grinding during repair activities, (2) grinding during the
- ULNRC-05994 June 05, 2013 Technical Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 Page 10 of 31 No.
SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section completion of the cladding application in the lower dome-to-torus weld, and/or (3) buffing or smoothing performed following onsite vessel installation."
- 33.
3-30 3.0.3.1.5 In the second paragraph under "Summary of Technical Information in the Application," first sentence, the text does not match the GALL or LRA Section B2.1.6.
Revise the sentence as follows :
"(c) loss of fracture toughness induced by either neutron irradiation embrittlement or thermal aging embrittlement;"
- 34.
3-30 3.0.3.1.5 The SER Summary of Technical Information in the Application section for the PWR Vessel Internals program states that the as-submitted LRA identifies the guidance of the EPRI Report 1016596 (MRP-227 Rev. 0) was used as guidance for the PWR Vessel Internals AMP.
The Staff Evaluation section for the PWR Vessel Internals program does not indicate that LRA Amendment 1 dated April 25, 2012 revised the PWR Vessel Internal program to be consistent with the guidance of MRP-227-A (EPRI Report 1022863) and the associated NRC Safety Evaluation.
Recommend revising the first paragraph of Staff Evaluation section for the PWR Vessel Internals program to indicate that applicant revised the PWR Vessel Internal program to be consistent with the guidance of MRP-227-A (EPRI Report 1022863) and the associated NRC Safety Evaluation.
- 35.
3-31 3.0.3.1.5 In the last paragraph of the Summary of Technical Information section, the first sentence contains text that does not match LRA Section B2.1.6, fourth paragraph under Program Description.
Revise the sentence as follows :
"The LRA states that the PWR Vessel Internals Program inspects these components using methods which include either visual examination (VT-3), or enhanced visual examination ( EVT-1), inspection methods or ultrasonic volumetric inspection examination, and physical measurements methods."
- ULNRC-05994 June 05, 2013 Technical Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 Page 11 of 31 No.
SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section
- 36.
3-35 3.0.3.1.5 In the third full paragraph, the SER text does not match M-227-A page 2-5.
Revise the text as follows:
"Specifically, with regard to fuel loading patterns, the MRP-227-A report assumes a 60-year licensed life for the facility and that the reactor for the facility will operate at normal high neutron leakage fuel loading patterns"
- 37.
3-41 3.0.3.1.5 In the second line on this page, the SER uses the word "should" while MRP-227-A uses the word "shall."
Note that A/LAI No. 8 Item (3) uses "shall" ensure both in the SER and in MRP-227-A.
Revise the sentence as follows:
"In this A/LAI, the staff stated that, if an applicant plans to implement an AMP that deviates from the guidance provided in the MRP-227-A report, the applicant should identify where its AMP deviates from the recommendations of MRP-227-A report and should shall provide a justification for any deviation that impacts the reports recommendations for "Primary" and "Expansion" inspection category components."
- 38.
3-43 3.0.3.1.5 In the first paragraph, third sentence of Item 5, the SER uses the word "should" while MRP-227-A uses the word "shall."
Revise the sentence as follows:
"Thus, in A/LAI No. 8, Item (5), the staff recommended that PWR license renewal applicants that reference and will be implementing the recommendations in the MRP-227-A report should shall evaluate the CLB for their facilities to determine if they have any plant-specific TLAAs for the RVI components that need be addressed."
- 39.
3-46 3.0.3.1.6 To be consistent with the LRA Section B2.1.7, the first paragraph of SER Section 3.0.3.1.6 should be changed.
Revise the sentence as follows:
The program manages wall thinning of carbon or low alloy steel piping components in single-phase and two-phase, high energy fluids.
- ULNRC-05994 June 05, 2013 Technical Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 Page 12 of 31 No.
SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section
- 40.
3-46 3.0.3.1.6 To be consistent with the LRA Section B2.1.7, the last paragraph on this page is missing a sentence explaining that the piping excluded from the FAC report was done so because it is used <2% of the time.
Revise the paragraph as follows:
The applicant also stated that during its review to determine if there were other similar errors in the LRA, it identified one additional occurrence and consequently revised the appropriate tables in LRA Amendment 7 to remove the two erroneous items. These lines were excluded from the FAC program because they operate less than two percent of the time, not because their material is not susceptible to FAC. The staff finds the applicants response
- 41.
3-49 3.0.3.1.6 In the fourth paragraph on the page, the response to RAI B2.1.7-5a is paraphrased to state that ME-013 had been revised to limit the applicability to operability determinations and evaluations of reduced wall thickness due to corrosion and erosion. The wording in ME-013 does not specify reduced wall thickness due to corrosion and erosion, nor did the response to RAI B2.1.7-5a use this phrase.
Revise the sentence as follows:
In its response dated November 8, 2012, the applicant stated that it had revised ME-013 to limit the applicability of the use of CMTRs to operability determinations and evaluations of reduced wall thickness due to corrosion and erosion to support continued plant operation until repairs could be implemented.
- 42.
3-51 3.0.3.1.7 Revise the Staff Evaluation section for the Steam Generators AMP to indicate that reduction of heat transfer was added as an aging effect requiring management by LRA Amendment 13, dated October 24, 2012.
Revise the Staff Evaluation section for the Steam Generators AMP to indicate that reduction of heat transfer was added as an aging effect requiring management.
- 43.
3-54 3.0.3.1.7 Update Operating Experience to show that one tube was plugged due to manufacturing defects (Amendment 1, dated April 25, 2012) and to match text in LRA if intent is a direct quote.
Revise the section as follows:
"[d]uring [RFO] 14 (fFall 2005), the [steam generators]
were replaced with AREVA designed steam generators
- ULNRC-05994 June 05, 2013 Technical Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 Page 13 of 31 No.
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Page Section with alloy 690 thermally treated tubes. Pre-service eddy current inspections found 77 small dings, four tubes with signals similar to outside diameter axial cracking, and 33 tubes with a spiral signal pattern. After analyzing the signals and the tubes containing indications, the tubes were found to have no detectable degradation. Two tubes were One tube was plugged because of due to manufacturing defects. Visual inspections of the [steam generator] secondary side were performed to identify any foreign objects that may have been left behind after uprighting and installation of the steam generators.
Several foreign objects were found during these inspections and removed before prior to placing the steam generators in service."
- 44.
3-58 3.0.3.1.9 Under the Summary of Technical Information in the Application in the second paragraph, third sentence, the statement is not correct. The AMP does not include destructive examinations of butt welds.
Revise the sentence as follows:
"The LRA also states that the program will include a volumetric or opportunistic destructive examinations of socket welds and volumetric examinations (by ultrasonic testing) of butt welds to identify potential cracking."
- 45.
3-59 3.0.3.1.9 Revise the top paragraph on the page, second sentence, to be consistent with the LRA Section B2.1.20.
Revise the sentence as follows:
"and incorporated into ASME Code Section XI is not available by the time of the inspections, then a qualified plant procedure for volumetric examination of ASME Code Class 1 small-bore piping socket welds will be used."
- 46.
3-59 3.0.3.1.9 Revise the top paragraph, last sentence, to be consistent with the LRA Section B2.1.20.
Revise the sentence as follows:
"The LRA also states that the program includes controls
- ULNRC-05994 June 05, 2013 Technical Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 Page 14 of 31 No.
SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section to implementation an alternate of a plant-specific periodic inspection AMP, should evidence of ASME Code Class 1 small-bore piping cracking caused by IGSCC or fatigue be confirmed by review of plant-specific operating experience."
- 47.
3-60 3.0.3.1.9 Revise the first full paragraph, last sentence, to reference the correct AMP number.
Revise the sentence as follows:
"with the corresponding program elements of GALL Report AMP XI.M35. Program element one, "scope of program," is associated with Open Item B2.1.20-1."
- 48.
3-64 3.0.3.1.12 Correct the AMP number in Staff Evaluation, second paragraph.
Revise the sentence as follows:
GALL Report AMP XI.S21 ASME Section XI, Subsection IWL, program element six, acceptance criteria, recommends that the program use acceptance criteria provided in IWL-2510, which references American Concrete Institute (ACI) 201.1R and ACI 349.3R for identification of concrete degradation.
- 49.
3-66 3.0.3.1.12 Correct the AMP number in the Operating Experience discussion, fourth full paragraph.
Revise the sentence as follows:
GALL Report AMP XI.S21 ASME Section XI, Subsection IWL, program element 10, operating experience, references NUREG-1522, Assessment of Inservice Condition of Safety-Related Nuclear Power Plant Structures, dated June 1995.
- 50.
3-69 3.0.3.1.13 Revise the first paragraph to be consistent with LRA Section B2.1.29.
Revise the paragraph as follows:
The LRA states that as part of ILRT pretest requirements, general inspection of accessible and inaccessible interior and exterior surfaces of the containment SCs are
- ULNRC-05994 June 05, 2013 Technical Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 Page 15 of 31 No.
SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section performed for evidence of structural deterioration before initiating an integrated leak rate test (ILRT), or Type A testing. The LRA also states before the next ILRT Type A test if the test interval has been extended to 10 years.
The LRA further states before the ILRT Type A test is performed.
- 51.
3-77 3.0.3.1.16 In the second paragraph under "Staff Evaluation,"
the Program Element that raised concerns with the staff was Element 6 - Acceptance Criteria, as described in Callaway's AMP Audit report, page 81 (NRC letter dated August 9, 2012).
Revise the sentence as follows:
"For the "corrective action acceptance criteria" program element, the staff determined the need for additional information, which resulted in the issuance of an RAI, as discussed below."
- 52.
3-82 3.0.3.1.19 Correct the temperature in the second paragraph, first sentence.
Revise the sentence as follows:
"plus a 10°C -8°C (18°F) heat rise because of energization of the cable.
Explanation: The 10°C is a temperature rise or difference and not an absolute temperature thus 18F temp change equals a 10C temp change.
T: 122°F (50°C) - 104°F (40°C) = 18°F 50°C - 40°C = 10°C
- 53.
3-83 3.0.3.1.19 Correct the CAR referenced in first OE paragraph.
Revise the sentence as follows:
"In CAR No. 2008010322200904936, the applicant observed main steam isolation valve area temperature"
- ULNRC-05994 June 05, 2013 Technical Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 Page 16 of 31 No.
SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section
- 54.
3-83 3.0.3.1.19 Under the Operating Experience discussion, revise the third paragraph statement of RAI B3.2-1 to be consistent with the text in the NRC letter dated August 23, 2012.
Revise the sentence as follows:
"By letter dated August 23, 2012, the staff issued RAI B3.2-1 requesting the applicant to (a) provide the schedule for performing self assessment reports and EQ health reports consistent with LRA Section B3.2.identify schedules or frequencies for publishing health reports, self assessments, or benchmark report evaluations of the EQ of Electric Components Program and"
- 55.
3-84 3.0.3.1.19 Correct the GALL Chapter error in the second full paragraph, last sentence.
Revise the sentence as follows:
"In addition, the staff finds that the conditions and operating experience at the plant are bounded by those for which GALL Report AMP XI.E1 X.E1 was evaluated."
- 56.
3-104 3.0.3.2.5 The SER description of the program should be revised to be consistent with LRA Section B2.1.12 to avoid confusion with scope of components and associated aging effects managed by the program.
Revise the sentence as follows:
The LRA states that the Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems program manages loss of material and loss of preload for bolting for all cranes, trolley, and hoist structural components; fuel handling equipment and applicable rails; and loss of preload for bolting within the scope of license renewal.
- 57.
3-110 3.0.3.2.7 The last sentence under Summary of Technical Information in the Application should state that wall thickness and internal inspections are required.
Revise the sentence as follows:
The program also includes pipe wall thickness examinations or and internal inspections of fire water piping.
- 58.
3-113 3.0.3.2.7 The date for Enhancement 2 does not match LRA Section B2.1.14.
Revise the sentence as follows:
Pipe wall thickness examinations and internal
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SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section inspections will be performed commencing in 2015 after 2014 and throughout the period of extended operation.
- 59.
3-114 3.0.3.2.7 Revise the wording of Enhancement 4 to be consistent with LRA Section B2.1.14.
Revise the paragraph as follows:
sprinkler heads before 50 years in service, or test a representative sample and test every 10 years thereafter or representative samples will be submitted for field-service testing by a recognized testing laboratory in accordance with NFPA 25. The program will field-service test additional representative samples every 10 years thereafter.
- 60.
3-116 3.0.3.2.7 At the bottom of page, the paraphrased response to RAI B2.1.14-5 (part d) (ULNRC-05886, August 6, 2012) omitted some of the intended meaning.
Revise the paragraph as follows:
in 2011, visual inspection of the internal and external surfaces of excavated fire hydrant piping was performed, and no degradation was noted. There was no physical damage or breaks in the coating, and no signs of microbial infestation. In June 2012, and no signs of microbial infestation or wall loss adverse conditions were noted.
- 61.
3-118 3.0.3.2.7 Revise third paragraph for consistency with the response to RAI B2.1.14-5b, Part a (ULNRC-05950, January 24, 2013).
Revise the sentence as follows:
The test results are trended to ensure that adequate margin, including anticipated degradation and corrective action, exists through the next flow test.
- 62.
3-118 3.0.3.2.7 The last sentence in the third paragraph should be omitted. This statement in the response to RAI B2.1.14-5b, Part a (ULNRC-05950, January 24, 2013), was in reference to restoring the test Delete the following sentence:
Depending on the results, the corrective actions for tests not meeting acceptance criteria could include pipe
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SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section interval from every 2 years to every 3 years at some future point. These actions are suitably listed as parenthetical examples at the end of the fourth paragraph.
cleaning, refurbishment, or replacement.
- 63.
3-120 3.0.3.2.7 Revise the first paragraph, last sentence to include detail, consistent with RAI B2.1.14-5 (part b).
Revise the sentence as follows:
in conjunction with yearly testing fire main flush.
- 64.
3-120 3.0.3.2.7 In the bulleted list, revise the fourth bullet date to be consistent with the LRA.
Revise the sentence as follows:
Commencing in 2015 after 2014 (reference Commitment No. 10)
- 65.
3-122 3.0.3.2.7 Under the FSAR Supplement section, the list of enhancements includes "Perform MIC Index Trending." This should be deleted from the list of enhancements. It was added to Appendix A and Appendix B of the LRA. This action is already performed, so no enhancement is needed.
Delete the following bullet:
Perform MIC Index trending.
- 66.
3-122 3.0.3.2.7 The first and second bullets do not match LRA.
Recommend using wording in Table A4-1 (Item No.
10). Currently, the first bullet omits discussion of internal inspection.
Revise the bullets as follows:
- Include non-intrusive pipe wall thickness examinations on fire water piping to be performed every 3 years. Each 3-year sample will include at least three locations, for a total of 30.5 meters (100 feet) of above-ground fire water piping, and be selected based on system susceptibility to corrosion or fouling and evidence of performance degradation during system flow testing or periodic flushes. In addition, internal inspections will be performed on accessible exposed portions of fire water piping during plant
- ULNRC-05994 June 05, 2013 Technical Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 Page 19 of 31 No.
SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section maintenance activities. Pipe wall thickness examinations and internal inspections will be performed commencing after 2014 and throughout the period of extended operation.
- Replace sprinkler heads before reaching prior to 50 years in service or have a recognized testing laboratory field-service test a representative sample in accordance with NFPA 25 and test additional samples every 10 years thereafter, in accordance with NFPA 25 to ensure signs of aging are detected in a timely manner.
- 67.
3-124 to 3-125 3.0.3.2.8 The first sentence of the final paragraph on pg. 3-124 states, The staff did not find the applicants response to Part (a) in and of itself acceptable because The last sentence of top paragraph on pg. 3-125 indicates that the staffs concerns described in RAI B2.1.15-2 Parts (a) and (f) are resolved. These two statements appear to contradict each others conclusion regarding the resolution of Part (a) and could cause confusion.
Clearly state on both pages that the concern described in RAI B2.1.15-2 has been resolved. If needed, clarify that the applicants response to Part (f) aided in the resolution of Part (a).
- 68.
3-128 3.0.3.2.8 The middle of the second paragraph states, As noted above in the staff evaluation of RAI B2.1.15-3, Part (a), the applicant amended its program to include a one-time inspection of a sample of the CSTs sides in lieu of opportunistic inspections.
To clarify, the RWST is also part of the discussion of RAI B2.1.15-3 part (a). Also, using the term insulated outer surfaces would more clearly Revise the sentence as follows:
As noted above in the staff evaluation of RAI B2.1.15-3, Part (a), the applicant amended its program to include a one-time inspection of a sample of the CSTs and RWSTs insulated outer surfaces sides in lieu of opportunistic inspections.
- ULNRC-05994 June 05, 2013 Technical Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 Page 20 of 31 No.
SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section describe the part of the tank, versus just sides.
(Refer to ULNRC-05886, August 6, 2012.)
- 69.
3-140 3-141 3.0.3.2.10 Revise the discussion for Reactor Vessel Surveillance AMP Enhancement 2 for AMP Element 5 (Monitoring and Trending) to indicate it has been completed as updated by LRA Amendment 14 in letter ULNRC-05923 dated October 31, 2012.
Delete the discussion of Enhancement 2 and replace it with a review of the completed enhancement, as follows:
Enhancement 2. LRA Section B2.1.17 states an enhancement to the monitoring and trending program element. In this enhancement, the applicant stated that procedures will be enhanced to specifically require the evaluation of the impact of plant operation changes on the extent of RV embrittlement. The staff reviewed this enhancement against the corresponding program element in GALL Report AMP XI.M31 and finds it acceptable because when it is implemented it will ensure that the applicants program is consistent with the recommendaWon of the monitoring and trending program element, which states that if future plant operations exceed RV embrittlement limitations or bounds, such as operating at a lower cold-leg temperature or higher fluence, the impact of plant operation changes on the extent of RV embrittlement is evaluated.
- require that plant operation changes be evaluated to determine the impact on reactor vessel embrittlement.
- 70.
3-144 3.0.3.2.12 The second to last paragraph mentions that the scope of program program element in the LRA does not describe the components included in the scope of the program. This statement infers that there is a section in the LRA titled Scope of Revise the sentence as follows:
As discussed in the audit report, the scope of program program element in the LRA applicants basis document does not describe the components included in the scope
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SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section Program; however, individual elements are only in the AMP Program Evaluation Reports.
of the program.
- 71.
3-145 3.0.3.2.12 Revise the wording in the first paragraph of Operating Experience to be consistent with changes made to LRA Amendment 1 dated April 25, 2012.
Revise the sentence as follows:
during maintenance activities for the cooling water centrifugal charging pump room cooler,
- 72.
3-148 3-158 3.0.3.2.14 Revise the first paragraph under "Summary of Technical Information in the Application" second sentence so that the aging effects listed are consistent with the as-submitted LRA (ULNRC-05830 dated 12/15/2011).
In the same paragraph, last sentence, several other techniques such as trending of Cathodic Protection are not mentioned. Cathodic Protection trending was added under Amendment 5 (ULNRC-05886 dated August 6, 2012), which impacted Appendix A and B; however, the second paragraph of SER page 3-158 only mentions that Appendix A was updated.
Revise Pg. 3-148 as follows:
"The LRA states that the AMP addresses steel, stainless steel, and HDPE piping and tanks exposed to a buried or underground environment to manage the effects of loss of material, cracking, and blistering, and changes in on color of the external surfaces of these components."
Revise Pg. 3-158 as follows:
"In its response, dated August 6, 2012, the applicant revised LRA Section Sections A1.25 and B2.1.25 to state that the cathodic protection system is operated consistent with the guidance in NACE SP0169-2007 for piping and NACE RP0285-2002 for tanks, that trending of the cathodic protection system is performed to identify changes in the effectiveness of the system and to ensure that the rectifiers are available to protect buried components, and that an annual cathodic protection survey is performed. consistent with NACE SP0169-2007."
- 73.
3-160 3.0.3.2.15 Revise the first sentence under Operating experience to identify the correct AMP.
Revise the sentence as follows:
Subsection IWL IWE Program.
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SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section
- 74.
3-162 3.0.3.2.16 Revise the second paragraph to include omitted detail.
Revise the sentence as follows:
1-inch diameter with a specified minimum yield strength
- 75.
3-168 3.0.3.2.17 Correct the last paragraph GALL reference when discussing aggressive groundwater.
Revise the sentence as follows:
sulfates greater than 1,500 ppm) and/or where the concrete structural elements have experienced degradation
- 76.
3-170 3.0.3.2.17 In the third paragraph on this page just below indented quote, the described applicant action is still in process.
Revise the sentence as follows:
because the applicant revised is revising the structures monitoring procedure
- 77.
3-177 3.0.3.2.19 In the last sentence of Enhancement 1, change XI.E3 to XI.E1.
Revise the sentence as follows:
"..will be consistent with the recommendations of GALL Report AMP XI.E3 XI.E1 for the "scope of program" program element."
- 78.
3-200 3.0.3.2.23 Revise the third paragraph wording to be consistent with the LRA Appendix B3.3 wording.
Revise the paragraph as follows:
measured tendon prestress must remain above or within a stated tolerance below be within a stated tolerance from the predicted lower limit (PLL) line for the vertical and hoop tendon groups The LRA also states that the trend lines is generated with a based on regression analysis, as described in consistent with IN 99-10, Revision_1, "Degradation of Prestressing Tendon Systems in Prestressed Concrete Containments,,. fFor both tendon groups, the regression analysis demonstrated that prestress should remain
- ULNRC-05994 June 05, 2013 Technical Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 Page 23 of 31 No.
SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section above the applicable MRVs for at least 60 years of operation
- 79.
3-201 3.0.3.2.23 Under Enhancement 2, there is no requirement for the AMP or Callaway to conform to RG 1.35 during the period of extended operation.
Revise the sentence as follows:
C-1003(Q), will be used to calculate the PLL lines consistent with NRC RG 1.35, Inservice Inspection of Ungrouted Tendons in Prestressed Concrete Containments, and RG 1.35.1, Determining Prestressing Forces for Inspection of Prestress Concrete Containments, for vertical and hoop tendon groups to 60 years.
- 80.
3-211 3.0.5.2.4 Revise the wording in the first full paragraph, first sentence, to be consistent with the RAI B1.4-1b response from letter dated February 14, 2013. The RAI response did not use the word all.
Revise the sentence as follows:
In its response dated February 14, 2013, the applicant clarified that the Operating Experience Program requires review of all topical reports
- 81.
3-224 Table 3.1-1 SER Table 3.1-1, item 3.1.1-27 states Consistent with the GALL Report. This item should be identified as not applicable to Callaway. This item is only applicable to nickel-alloy control rod guide tube assemblies and guide tube support pins.
Callaway control rod guide tube assemblies and guide tube support pins are made of stainless steel.
As discussed in SER 3.1.2.2.13, items 3.1.1-32 and 3.1.1-53 now apply to these components instead of 3.1.1-27.
Revise the sentence as follows:
Consistent with the GALL Report Not applicable to Callaway (see SER Section 3.1.2.2.13)
- 82.
3-287 Table 3.2-1 Item 19, Item 21, The SER Table 3.2-1 partially incorporates LR-ISG-2011-01 Rev. 1 (e.g. item 20). The following line items on SER Table 3.2-1 require revision to be Revise SER Table 3.2-1 as follows:
Item 19 (Component)
- ULNRC-05994 June 05, 2013 Technical Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 Page 24 of 31 No.
SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section Item 22 consistent with LR-ISG-2011-01 Rev. 1:
Item 19 (Component)
Item 21 (Aging Management Program)
Item 22 (Aging Management Program)
Stainless steel Heat exchanger tubes exposed to Treated water, Treated water (borated) (3.2.1-19)
Item 21 (Aging Management Program)
Chapter XI.M2, Water Chemistry and Chapter XI.M32, One-Time Inspection Item 22 (Aging Management Program)
Chapter XI.M2, Water Chemistry and Chapter XI.M32, One-Time Inspection
- 83.
3-287 Table 3.2-1 Item 19 The AMP in LRA Supplements, or Amendments column of SER Table 3.2-1 line item 19 requires revision to be consistent with the LRA Amendment 9 dated September 20, 2012, that identified Water Chemistry and One-Time Inspection as the applicable AMPs.
Revise AMP in LRA Supplements, or Amendments column of SER Table 3.2-1 line item 19 as follows:
Not applicable Water Chemistry and One-Time Inspection
- 84.
3-293 Table 3.2-1, Item 61 SER Table 3.2-1, item 3.2.1-61 states Consistent with the GALL Report. It should be not applicable to Callaway since there is no nickel alloy piping installed.
Revise the sentence as follows:
Consistent with the GALL Report Not applicable to Callaway (see SER Section 3.2.2.1.1)
- 85.
3-293 Table 3.2-1, Item 62 SER Table 3.2-1, item 3.2.1-62 states Consistent with the GALL Report. It should be not applicable to Callaway since there is no nickel alloy piping installed.
Revise the sentence as follows:
Consistent with the GALL Report Not applicable to Callaway (see SER Section 3.2.2.1.1)
- 86.
3-295 3.2.2.1.1 In the second paragraph of the section AMR Results Identified as Not Applicable, items 3.2.1-61 and 3.2.1-62 should be included since there is no nickel alloy piping installed.
Revise the sentence as follows:
For LRA Table 3.2-1, items 3.2.1-10, 3.2.1-11, 3.2.1-12, 3.2.1-14, 3.2.1-16, 3.2.1-21, 3.2.1-23, 3.2.1-24, 3.2.1-25, 3.2.1-27, 3.2.1-34, 3.2.1-35, 3.2.1-37, 3.2.1-39, 3.2.1-42,
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SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section 3.2.1-45, 3.2.1-53a, and 3.2.1-55, 3.2.1-61, and 3.2.1-62, the applicant claimed that the corresponding items in the GALL Report are not applicable because the component, material, and environment combination described in the SRP-LR does not exist for in-scope SCs at Callaway.
- 87.
3-311 Table 3.3-1 Item 17, Item 28, Item 29 SER Table 3.3-1 partially incorporates LR-ISG-2011-01 Rev. 1 (e.g. item 124 and 125). The following line items on SER Table 3.3-1 require revision to be consistent with LR-ISG-2011-01 Rev. 1:
Item 17 (Component)
Item 28 (Component)
Item 29 (Component)
Revise as follows:
Item 17 (Component)
Stainless steel heat exchanger tubes exposed to treated water, Treated borated water (3.3.1-17)
Item 28 (Component)
Stainless steel, steel (with stainless steel or nickel-alloy cladding) spent fuel storage racks (BWR), spent fuel storage racks (PWR), piping, piping components, and piping elements, piping, Piping, piping components, and piping elements; tanks exposed treated water >60 °C
(>140 °F), treated borated water (Primary oxygen levels controlled) >60 °C (>140 °F) (3.3.1-28)
Item 29 (Component)
Steel (with stainless steel cladding); stainless steel piping, piping components, and piping elements exposed to treated borated water (Primary oxygen levels controlled)
(3.3.1-29)
- 88.
3-311 Table 3.3-1 The AMP in LRA Supplements, or Amendments Revise AMP in LRA Supplements, or Amendments
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SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section Item 17 column of SER Table 3.3-1 line item 17 requires revision to be consistent with the LRA Amendment 9 dated September 20, 2012, that identified Water Chemistry (B2.1.2) and One-Time Inspection (B2.1.18) as the applicable AMPs.
column of SER Table 3.3-1 line item 17 as follows:
Not applicable Water Chemistry and One-Time Inspection
- 89.
3-313 Table 3.3-1 Item 29 The AMP in LRA Supplements, or Amendments column of SER Table 3.3-1 line item 29 requires revision to be consistent with the LRA Amendment 18 dated December 19, 2012, that identified Water Chemistry (B2.1.2) as the applicable AMP.
Revise AMP in LRA Supplements, or Amendments column of SER Table 3.3-1 line item 29 as follows:
Water Chemistry and One-Time Inspection Also revise the Staff Evaluation column of SER Table 3.3-1 line item 29 as follows:
"Consistent with the GALL Report (see SER Section 3.3.2.1.1 3.3.2.1.3)"
- 90.
3-358 3.3.2.3.23 In the second paragraph under this section, there are no line items for insulation in LRA Table 3.3.2-
- 23.
Delete the second paragraph that begins with Calcium Silicate Insulation Exposed to Plant Indoor Air.
- 91.
3-388 Table 3.5-1 Item 26 Table 3.5-1 item 26 is for moisture barriers managed by the ASME Section XI, Subsection IWE.
However, Callaway does not have a moisture barrier component as part of its containment pressure boundary. LRA Table 3.5-1, item 3.5.1-026, was revised by Amendment 6 in a letter dated August 9, 2012, to state that at Callaway, there is no moisture barrier between the steel liner and internal concrete surface of the containment, and that this line is not applicable to Callaway.
Revise the sentence as follows:
Consistent with the GALL Report Not applicable to Callaway (see SER Section 3.5.2.1.1)
- 92.
3-402 3.5.2.1.1 In the first paragraph of Section 3.5.2.1.1, add items 3.5.1-76 and 3.5.1-84 to the list of items which are not applicable to Callaway because they Revise the sentence as follows:
For LRA Table 3.5-1, items 3.5.1-15, 3.5.1-16, 3.5.1-22,
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SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section are only applicable to BWRs to be consistent with SER Table 3.5-1.
3.5.1-36 through 3.5.1-41, and 3.5.1-45, 3.5.1-76, and 3.5.1-84 the applicant claimed that the corresponding AMR items in the GALL Report are not applicable because the associated items are only applicable to BWRs.
- 93.
3-402 3.5.2.1.1 In the second paragraph of Section 3.5.2.1.1, add item 3.5.1-26 to the list of items not applicable because the component, material, and environment combination described in the SRP-LR does not exist for in-scope SCs at Callaway. This item refers to a moisture barrier between the steel liner and inner concrete surface of the containment. As noted in the response to RAI B2.1.26-1 and LRA Amendment 6 (August 9, 2012),
there is no moisture barrier at Callaway.
Revise the sentence as follows:
For LRA Table 3.5-1, items 3.5.1-23, 3.5.1-26, 3.5.1-27, 3.5.1-62, 3.5.1-71, 3.5.1-79, 3.5.1-85, and 3.5.1-94, the applicant claimed that the corresponding items in the GALL Report are not applicable because the component, material, and environment combination described in the SRP-LR does not exist for in-scope SCs at Callaway.
- 94.
3-404 3-406 3.5.2.1.3 3.5.2.1.5 The last sentence in the second paragraph refers to ASME Code B30 inspections at a frequency that exceeds the 5-year interval recommended in GALL Report AMP XI.S6. This is misleading because the Code B30 inspections are more frequent (yearly) than the recommendations of XI.S6.
Revise the sentence as follows:
acceptable because visual inspections for cranes are performed in accordance with ASME Code B30 standards, which require inspections more frequently than at a frequency that exceeds the 5-year interval recommended in GALL Report AMP XI.S6.
- 95.
3-411 3.5.2.2.1 Revise the third paragraph on this page to be consistent with the response to RAI B2.1.26-1. In this response, Callaway revised the LRA per Amendment No. 6 (August 9, 2012) to remove the reference to the moisture barrier in this location.
Revise the sentence as follows:
The applicant stated that it manages aging of the there is no moisture barrier at the interface between the liner and the concrete with the ASME Section XI, Subsection IWE Program. The staff reviewed the IWE Program and noted that the program includes provisions to manage age-related degradation of steel liner at the moisture barrier.
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SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section
- 96.
3-445 3.6.2.2.3 Correct the calculation in the second paragraph, eighth sentence.
Revise the sentence as follows:
"The NESC-installed tension for a 60-year conductor at Callaway would be 9,282 lbs (15,470 x 0.6) resulting in an installed margin of 4,945 6188 lbs (15,470 lbs - 9,282 lbs)."
- 97.
4-54 4.3.4.1 In the first sentence of the last paragraph of SER Section 4.3.4.1, the use of final contradicts the Table title of Preliminary. Revise the first sentence to be consistent with the title of Table 4.3-7 as noted in LRA Amendment 2 submitted by letter ULNRC-05860 dated May 3, 2012 (ML12128A150). Changes made by LRA Amendment 2 are noted in the first and third paragraphs of SER Section 4.3.4.1.
Revise the sentence as follows:
"LRA Table 4.3-7, "Preliminary Identification of Additional Sentinel Locations for EAF Sentinel Locations for EAF Monitoring, identifies the final locations
- 98.
4-59 4.3.4.2 In the second to last paragraph on this page, the SER states, Finally, since NUREG/CR-6909 was used for Ni-Cr-Fe steels, the applicant was requested, in Part (d) [of RAI 4.3-20], to confirm that the fatigue curve in Appendix A, Figure A.3, of NUREG/CR-6909 was used for determining the Fen of Ni-Cr-Fe steels.
However the revision to this response is not discussed. The revised response to this request was made in letter ULNRC-05938 dated December 13, 2012 (ML12349A179 and ML12349A180).
Revise the paragraph as follows:
The EAF screening was revised not to use the equations in NUREG/CR-6909 for the Fen for Ni-Cr-Fe. Instead NUREG/CR-5704 is used to compute Fen for Ni-Cr-Fe material if the CUF is determined from the ASME Code fatigue curve. This approach is only used for the EAF screening. Further refinement of the Uen will use the methods in NUREG/CR-6909 for Ni-Cr-Fe material.
- 99.
4-60 1-10 4.3.4.2 Open Item 4.3.4-1 In the first full paragraph of Section 4.3.4.2 and in the second paragraph of Open Item 4.3.4-1, revise text to remove the term normalized scale which Revise text as follows:
normalized scale consistent level of rigor
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SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section is used in the SER & Open Item, but is not used in the response to RAI Set 23 (ULNRC-05979 dated April 26, 2013).
100. 4-60 4.3.4.2 The SER reopens the discussion on the safety injection nozzle in the fourth full paragraph of page 4-60 and states it as an Open Item. This is inconsistent with the previous statement in the first full paragraph of page 4-56 that:
Thus, the staff finds the Fatigue Monitoring Program is capable of managing the EAF CUF of the safety injection nozzle less than 1.0.
Reconcile the paragraphs on the SI nozzle monitoring Open Item on page 4-60 with the SI nozzle discussion on page 4-56.
101. 14-74 4-77 4.3.8.2 Revise the first paragraphs on pages 4-74 and 4-77 to be consistent with RAI response 4.3-17 part (c)
(ULNRC-05915, October 11, 2012) and to clarify that initiating maximum purification and affecting boron concentration do not result in the letdown flow step decrease and return to normal transient.
Revise the paragraph as follows:
However, it is only normally changed to initiate maximum purification or to affect boron concentration changes associated with load follow and plant shutdown.
Both of these operations necessitate an increase in the letdown flow. The letdown flow reductions do not support the typical operation of the plant, and there are currently no plans to implement a letdown flow reduction below nominal letdown flow (75 gpm).
102. 14-74 4-77 4.3.8.2 Consistent with the previous comment, whether or not the plant operates as a load-following plant or initiates maximum purification does not factor into the amount of margin available. Only the number of plant shutdown cycles would factor into the estimated number of letdown flow step decrease and return to normal cycles.
Revise the paragraph as follows:
The staff noted that since the applicant currently operates its plant on 18-month refueling cycles, it can be expected that approximately 40 cycles occur because of plant shutdowns. In addition, since the applicant does not operate as a load-following plant or operate in such a manner to normally initiate maximum purification, tThe staff finds it reasonable that there is margin
- ULNRC-05994 June 05, 2013 Technical Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 Page 30 of 31 No.
SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section (approximately 2,960 cycles) to account for occurrences of the "letdown flow step decrease and return to normal transient through the period of extended operation.
103. 4-86 4.5.2 The wording from Callaways tendon surveillance specification is offered for consideration for the last paragraph on page 4-86 that discusses prestressing force within 90% of PLL. The IWL-3221.1 requirements impose the testing of two additional tendons if the measured force is less than the PLL.
The wording within 90% of the PLL seems confusing in this discussion.
Revise the paragraph using the language from Callaways tendon surveillance specification, C-1003, which states:
If the measured prestressing force of the selected tendon in a group lies between the prescribed lower limit and 90 percent of the prescribed lower limit, two adjacent (accessible) tendons, one on each side of this tendon shall be checked for their prestressing forces. If the measured prestressing force of any two tendons falls below 95 percent of the prescribed lower limits of the tendons, additional lift-off testing shall be done to detect the cause and extent of such occurrence.
If the measured prestressing force of any tendon lies below 90 percent of the prescribed lower limit, the defective tendon shall be completely detensioned and additional lift-off testing shall be done so as to determine the cause and extent of such occurrence.
104. 14-89 4.6.1.1 In the last paragraph of this section, the following statement needs clarity: "For loading condition V, the LRA states that the main steam line calculated stress is below that associated with 500 cycles.
LRA Section 4.6.1 states: The allowable stress is based on 100 startup-shutdown cycles for an assumed plant design life of 40 years. LRA Section Revise the paragraph as follows:
For loading condition V, the LRA states that the main steam line calculated stress is below that associated with 500 cycles. The LRA states that allowable stress is based on 100 startup-shutdown cycles for an assumed plant design life of 40 years, however, a review of the ASME Code Section III Table I-9-1 shows that the allowable
- ULNRC-05994 June 05, 2013 Technical Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 Page 31 of 31 No.
SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to indicate suggested text)
Page Section 4.6.1 also states A review of the ASME Section III Table I-9-1 shows that the allowable stress for 500 cycles envelopes the calculated stress.
stress for 500 cycles envelopes the calculated stress.
105.24-103 4.7.3.2 In the second paragraph, revise the SER to be consistent with RAI 4.7.3-1 response (ULNRC-05906, September 20, 2012).
Revise the sentence as follows:
The applicant also stated that, even though its current operation schedules an 8-week a refueling outage with the average duration of less than 8 weeks every 18 months 106.24-111 4.7.7.2 The first full paragraph on page 4-111 of the SER states that the reactor coolant loop (RCL) LBB analysis does not consider the aging effect of thermal embrittlement. Thermal embrittlement is considered in the RCL LBB analysis by the selection of fully aged material. The analysis accounts for an aging mechanism that the RCL is not susceptible to per XI.M12.
Revise the paragraph as follows:
In addition, the staff finds it acceptable that the fracture mechanics evaluation in the RCL LBB analysis is not a TLAA, in accordance with 10 CFR 54.3, because it does not involve time-limited assumptions defined by the current operating term, and it does not consider the aging effect of thermal aging embrittlement.
107. 2A-7 Appendix A SER Commitment Table Item 12 should be revised to be consistent with the changes to LRA Table A4-1 item 12 identified in LRA Amendment 20 (Callaway letter ULNRC-05930 dated January 24, 2013).
Revise the commitment as follows:
Remove the blisters in the coating, and inspect the base metal for aging, and repair the coating in the train A emergency diesel generator fuel oil storage tank.