ML13283A033

Request for Relaxation from NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events.

ML13283A033
Person / Time
Site:	Callaway
Issue date:	10/09/2013
From:	Reasoner C Ameren Missouri
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049
Download: ML13283A033 (6)

Text

Cleve Reasoner

~~ Vice President Engineering WAmeren MISSOURI Ameren Missouri Callaway Energy Center T 573.676.8241 F 573.676.4056 October 09, 2013 ULNRC-06036 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Order No. EA-12-049 Ladies and Gentlemen:

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

FACILITY OPERATING LICENSE NPF-30 REQUEST FOR RELAXATION FROM NRC ORDER EA-12-049, "ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS"

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. 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 (ADAMS Accession Number ML13063A459)

This letter transmits a request for relaxation of the requirements contained in NRC Order EA-12-049.

On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued an Order (Reference 1) to Union Electric Company (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. As described in the Overall Integrated Plan for Callaway Plant (Reference 2), one requirement of the mitigation strategies is dependent upon implementation of a missile protected water source for Auxiliary Feedwater (Condensate Storage Tank) established in accordance with NRC Order EA-12-049 (Reference 1).

Junction CC & Hwy 0 Fulton, MD 65251 AmerenM issouri.com

PO Box 620, MC CA-460

ULNRC-06036 October 09, 2013 Page2 The currently identified date for establishing a missile protected water source for Auxiliary F eedwater is completion of the fall 2014 refueling outage. An extension of one additional refueling cycle is requested, which would move the implementation date to completion of the spring 2016 refueling outage. This would allow time to install a larger, more robust Condensate Storage Tank (CST) that would meet FLEX and Expedited Seismic Evaluation Process (ESEP) requirements.

Section IV ofNRC Order EA-12-049 (Reference 1) states that licensees proposing to deviate from requirements contained in NRC Order EA-12-049 may request that the Director, Office ofNuclear Reactor Regulation, relax those requirements. Therefore, in accordance with Section IV ofNRC Order EA-12-049, Ameren Missouri is requesting that the Director, Office ofNuclear Reactor Regulation, relax the requirement for completion of full implementation as prescribed in Section IV.A.2 ofNRC Order EA-12-049 and as described in the attachment to this letter.

Ameren Missouri considers that, upon approval by the NRC, the alternative full implementation dates regarding NRC Order EA-12-049 proposed in the attachment will constitute a condition of the NRC Order EA-12-049 for Callaway Plant. Therefore, there are no new regulatory commitments contained in this letter.

Should 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, Executed on: _ _ I o--+-/_9-.~/_1_3__

Cleveland Reasoner Vice President, Engineering Enclosure

ULNRC-06036 October 09, 2013 Page 3 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-06036 October 09, 2013 Page4 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 Other Situations ULNRC Distribution:

A. C. Heflin F. M. Diya C. 0. Reasoner III B. L. Cox L. H. Graessle S. A. Maglio Corporate Communications NSRB Secretary T. B. Elwood J. L. Fortman J. T. Patterson D.M. Stepanovic STARS Regulatory Affairs Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)

Missouri Public Service Commission

Enclosure to ULNRC-06036 Page 1 of2 REQUEST FOR RELAXATION OF NRC ORDER EA-12-049 REQUIREMENT IV.A.2 FORCALLAWAYPLANT Relaxation Request Pursuant to the procedure specified in Section IV of Nuclear Regulatory Commission (NRC)

Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (Reference 1), Callaway Plant, hereby submits a request for relaxation from the Order requirements for completion of full implementation no later than two (2) refueling cycles after submittal of the Overall Integrated Plan, as required in Condition C.l.a of the Order, or December 31,2016, whichever comes first.

Order Requirement from Which Relaxation is Requested NRC Order EA-12-049,Section IV.A.2 requires completion of full implementation ofthe Order requirements no later than two (2) refueling cycles after submittal of the Overall Integrated Plan, as required by Condition C.1.a or December 31, 2016, whichever comes first. In accordance with the requirements of the Order, Ameren Missouri submitted the Overall Integrated Plan for Callaway Plant (Reference 2) on February 28, 2013. The Overall Integrated Plan milestone schedule identified the completion dates for full implementation of NRC Order EA-12-049 as completion of the fall 2014 refueling outage for Callaway Plant.

NRC Order EA-12-049 requires the development, implementation, and maintenance of 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. As described in the Overall Integrated Plan for Callaway Plant (Reference 2), these mitigation strategies are dependent upon implementation of a seismically qualified and missile protected water source for Auxiliary Feedwater (Condensate Storage Tank). The current Condensate Storage Tank (CST) does not meet the missile protection requirements in NEI 12-06 Section 7 and therefore is not creditable for FLEX missile protection. Callaway Plant is designing and implementing a new and larger hardened CST that will meet the seismic requirements of Expedited Seismic Evaluation Process (ESEP) and missile protection ofNEI 12-06. This new tank will provide approximately 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of protected water source for the safety function of core cooling.

Justification for Relaxation Request Based on the complex design, lead time for materials, and construction time for a new tank to meet seismic requirements ofESEP and missile protection ofNEI 12-06, full implementation of the mitigation strategies in accordance with NRC Order EA-12-049 would not be completed by the Order requirement date. The current required implementation date is completion of the fall 2014 refueling outage. An extension of one additional refueling cycle is requested, which would move the implementation date to completion of the spring 2016 refueling outage, which is still Page 1 of2

Enclosure to ULNRC-06036 within the maximum allowed timeframe of December 2016. The extension would provide additional time to fully design and safely install a larger, more robust CST.

Conclusion Compliance with NRC Order EA-12-049 schedule requirement for full completion of implementation of mitigation strategies would require Callaway Plant to establish interim compensatory measures until construction of a new tank (to conform to ESEP requirements) is complete. Relaxation would allow the plant to focus on construction of a new tank versus interim compensatory measures. Therefore, in accordance with the provisions of Section IV of the Order, Ameren Missouri requests relaxation of the requirement described in Section IV.A.2.

References

1. NRC Order EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12,2012

2. 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 Page 2 of2