ULNRC-06024, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

ML13242A239
Person / Time
Site:	Callaway
Issue date:	08/29/2013
From:	Maglio S Ameren Missouri, Union Electric Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
ULNRC-06024, EA-12-049
Download: ML13242A239 (10)

Text

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WAmeren Callaway Plant MISSOURI August 29, 2013 ULNRC-06024 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10CFR2.202 Ladies and Gentlemen:

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

FACILITY OPERATING LICENSE NPF-30 FIRST SIX-MONTH STATUS REPORT IN RESPONSE TO MARCH 12, 2012 COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS (ORDER NUMBER EA-12-049)

References:

1. Letter dated March 12,2012 from E. J. Leeds and M. R. Johnson, USNRC, to Adam C.

Heflin, Callaway Plant, Union Electric Company, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (ADAMS Accession Number ML12054A736)

2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, August 29, 2012 (ADAMS Accession Number ML12229A174)

3. ULNRC-05924, "Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated October 29, 2012

4. ULNRC-05962, "Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated February 28, 2013

PO Box 620 Fulton, MO 65251 AmerenMissouri.com

ULNRC-06024 August 29, 2013 Page 2 of4 On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued the order identified above as Reference 1 to Union Electric Company (dba Ameren Missouri) for Callaway Plant.

Reference 1 was immediately effective and directs Ameren Missouri to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of final interim staff guidance from the NRC (Reference 2) and an Overall Integrated Plan pursuant to Section IV, Condition C. Reference 3 provided Ameren Missouri's initial status report regarding mitigation strategies. Reference 4 provided Ameren Missouri's Overall Integrated Plan.

Section IV, Condition C.2 ofReference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," provides direction regarding the content of the status reports. The enclosure to this letter provides Ameren Missouri's first six-month status report pursuant to Section IV, Condition C.2 of Reference 1.

This letter does not contain new commitments.

If you have any questions concerning the content of this letter, please contact Scott Maglio, Regulatory Affairs Manager, at 573-676-8719.

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

Sincerely,

~:~9 Executed on: -----------------

Regulatory Affairs Manager

Enclosure:

Ameren Missouri's First Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

ULNRC-06024 August 29, 2013 Page 3 of4 cc: Mr. Steven A. Reynolds Acting Regional Administrator U.S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Fred Lyon Project Manager, Callaway Plant Office ofNuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8B 1 Washington, DC 20555-2738 Mr. Eric Leeds Director, Office ofNuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-13H16M Washington, DC 20555-0001 Mr. Jack Davis Director, Mitigation Strategies Directorate Office ofNuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

ULNRC-06024 August 29, 2013 Page 4 of4 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4150 International Plaza Suite 820 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. 0. Reasoner III D.W. Neterer L. H. Graessle S. A. Maglio T. B. Elwood J. L. Fortman J. T. Patterson Corporate Communications NSRB Secretary STARS Regulatory Affairs Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)

Missouri Public Service Commission

Enclosure to ULNRC-06024 Ameren Missouri's First Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction Ameren Missouri developed an Overall Integrated Plan (OIP) (Reference 1) for the Callaway Plant, documenting the diverse and flexible strategies (FLEX), in response to NRC Order Number EA-12-049 (Reference 2). This enclosure provides an update of milestone accomplishments since submittal of the OIP (Reference 1), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any. Refer to Section 8 of this enclosure for a list of References.

2 Milestone Accomplishments The following milestones have been completed since the development of the OIP (Reference 1), and are current as of July 31, 2013.

• PWROG has issued the NSSS-specific guidance

• ECA-0.0, Rev 2+, Loss of all AC Power

• NSSS Specific FLEX Support Guidelines (FSG), Rev 0

• Submittal of six-month status report for implementation of order EA-12-049 (this document) 3 Milestone Schedule Status The following table provides an update to Attachment 2 of the OIP (Reference 1). The table provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed. The revised milestone target completion dates do not impact the Order EA-12-049 (Reference 2) implementation date.

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Enclosure to ULNRC-06024 Callaway Milestone Schedule Status Revised Target Original Target (Will be Activity Completion Date updated every Date 6 months)

Submit Overall Integrated February-2013 Complete Implementation Plan 6 Month Status Updates February-2015 Started Update 1 August-20 13 Complete Update 2 February-2014 Not Started Update 3 August-2014 Not Started Update 4 February-2015 Not Started FLEX Strategy Evaluation April-2013 Complete Perform Staffing Analysis December-2013 Not Started June 2014 Modifications November-2014 Started Modifications Evaluation April-2013 Started October 2013 Engineering and Implementation November-2014 Started N-1 Walkdown April-2013 Started December-20 13 Design Engineering March-2014 Started Unit 1 Implementation Outage November-2014 Not Started On-site FLEX Equipment December-2013 Started April2014 Purchase June-2013 Started March 2014 Procure December-2013 Started April2014 Off-site FLEX Equipment September-2014 Started Develop Strategies with RRC November-20 13 Started Install Off-site Delivery Station (if September-2014 Started necessary)

Procedures June-2014 Started PWROG issues NSSS-specific guidelines June-2013 Complete Create Callaway FSG April-2014 Started Create Maintenance Procedures June-2014 Not Started Training November-2014 Started Develop Training Plan April-2014 Started Implement Training May-2014 Not Started November-2014 Submit Completion Report November-2014 Not Started Page 2 of6

Enclosure to ULNRC-06024 4 Changes to Compliance Method The following changes have been made to Ameren Missouri's FLEX response documented in Reference 1.

4.1 Nitrogen Backup Capacity The Ameren Missouri FLEX response (Reference I) identified that Callaway Plant is designing a modification that will supplement the existing backup nitrogen capacity. The concept was to provide sufficient nitrogen bottle capacity to provide nitrogen for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of operation. In lieu of this modification, Ameren Missouri is revising its Phase I FLEX Strategy to provide a portable air compressor to supply the Atmospheric Relief Valves (ARVs) and the Turbine Driven Auxiliary Feedwater Pump (TDAFP) Flow Control Valves with compressed air. The installed nitrogen backup supply has sufficient capacity for approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of operation. The portable air compressor is planned to be connected to test connections upstream of the nitrogen accumulator tanks that supply the back-up nitrogen to these valves. The portable air compressors will be powered from a Phase 2 portable generator.

4.2 NK Battery Load Shed The Ameren Missouri FLEX response (Reference I) indicated that after NK (Class IE I25-VDC) load shedding, only ARVs ABPVOOOI and ABPV0002 would have DC power available for operation and the Control Room would only be able to remotely control Auxiliary Feedwater (AFW) to Steam Generator (SG) A and D. The original strategy was to open the disconnects to Class IE I25 VDC Batteries NK13 and NKI4 to preserve these batteries until after Class IE I25-VDC Batteries NKII and NKI2 were depleted. However, to preserve symmetrical cooldown Class IE I25-VDC Batteries NKI3 and NKI4 will be load shed except for the power to ARVs ABPV0003 and ABPV0004, as well as power to the TDAFP Flow Control Valves for SG Band SG D. Preliminary evaluation by Engineering indicates that this load is a low power draw from the batteries and would not cause a significant reduction in the amount oftime NK13 and NKI4 are able to supply I25-VDC power.

4.3 Storage/Protection of Equipment The Ameren Missouri FLEX response (Reference I) identified two locations for storage of Callaway Plant FLEX equipment. Callaway Plant is evaluating the use of one (I) storage location meeting the requirements ofNEI I2-06, Sections 4 through 9.

4.4 Deployment of Phase 2 480 V AC Diesel Generators The Ameren Missouri FLEX response (Reference I) identified that FLEX connection panels would be installed in Corridor 130I of the Auxiliary Building 2000 elevation and the plant west wall of the Control Building. Permanent sealed penetrations with grommets will be made in the walls of these buildings to provide access to the FLEX panels. Further evaluation has determined that it is not necessary to install the permanent sealed penetrations to the outside walls. In lieu of the wall penetrations, the cables from the Phase 2 portable 480-V AC diesel generators will be run through existing doorways.

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Enclosure to ULNRC-06024 4.5 Deployment of Phase 3 4160 VAC Diesel Generators The Ameren Missouri FLEX response (Reference 1) identified that to facilitate connection of the generator cables to the Class 1E 4160-V AC switchgear, two new sealed penetrations will be installed in the west wall of the control building. Further evaluation has determined that it is not necessary to install the permanent sealed penetrations to the outside walls. In lieu of the wall penetrations, the cables from the Phase 3 portable 4160-V AC diesel generators will be run through existing doorways.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation As described in Reference 1, Ameren Missouri is evaluating seismically qualifying the Condensate Storage Tank (CST) or installing a 670,000 gallon seismically qualified and missile protected CST.

Ameren Missouri is evaluating the need for relaxation of Section N.A.2 of Order EA-12-049 regarding full implementation no later than two (2) refueling cycles after submittal of the OIP, so that the option to install a new seismically qualified and missile protected CST may be pursued. Refer to Open Item 5 in Section 6 below. If an extension is requested, the specific details will be provided to the NRC in a separate submittal.

The Ameren Missouri FLEX response (Reference 1) also stated that Ameren Missouri is crediting use of the RCP SHIELD Seal in our FLEX Strategies. There is an industry identified issue, documented under 10CFR50 Part 21, with the current performance ofthis seal. The vendor (Westinghouse) has developed a plan to improve the RCP SHIELD Seal performance. Ameren Missouri is evaluating the need for relaxation from the requirement of Section N.A.2 of Order EA-12-049 regarding full implementation no later than two (2) refueling cycles after submittal of the OIP, so that the option to credit the RCP SHIELD Seals may be pursued. The current required implementation date for Callaway Plant is the Fall 2014 refueling outage. An extension of one additional refueling cycle may be requested which would move the implementation date to the spring of 2016, still within the maximum allowed time frame of December 2016. The extension would provide additional time to resolve the RCP Seal performance issue and to fully design and safely implement modifications to the Callaway Plant. A new Open Item, OI8 has been created to track resolution of this issue and is included in Section 6 below. If an extension is requested, the specific details will be provided to the NRC in a separate submittal.

6 Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary of the open items documented in the OIP or the Draft Safety Evaluation (SE) and the status of each item.

Overall Integrated Plan Open Item Status 011 The RWST will need to be missile protected to credit its use Started in FLEX strategies.

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Enclosure to ULNRC-06024 Overall Integrated Plan Open Item Status 012 GOTHIC analysis needs to be performed to demonstrate that Not started Containment pressure and temperature remain at acceptable levels and that instrumentation EQ requirements will be maintained.

013 An analysis will need to be performed to demonstrate Not started acceptable SFP cooling pump performance with the SFP in boil-off.

014 For non-Class IE instrumentation that will be repowered Not started using a temporary battery, an analysis will need to be performed to determine battery life and frequency of replacing battery 015 The current CST and CST pipe chase are non-seismic. Started. Relaxation of Order Callaway may pursue the construction of a new seismically requirements regarding the date qualified and missile protected CST. Current FLEX of full implementation may be strategies rely on the existing CST tank. Future evaluation needed to pursue the option to is required to determine the impact on FLEX strategies install a new CST.

should the new CST be constructed.

016 The method for isolating accumulators during RCS inventory Started control has not been fmalized 017 The method for repowering the SFP cooling pumps has not Started been finalized.

018 The Westinghouse RCP SHIELD Seal issue has not been Started. Relaxation of Order resolved. requirements regarding the date of full implementation may be needed to pursue the option to credit the Westinghouse RCP SHIELD Seal as part of the Callaway Energy Center FLEX Strategies.

Draft Safety Evaluation Open Item Status Draft NRC Safety Evaluation has not been received. N/A Page 5 of6

Enclosure to ULNRC-06024 7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

8 References The following references support the updates to the OIP described in this enclosure.

1. ULNRC-05962, "Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated February 28, 2013

2. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012 Page 6 of 6