ML18353B016

Regulatory Audit Summary License Amendment Request to Incorporate a New Technical Specification 3.7.20

ML18353B016
Person / Time
Site:	Callaway
Issue date:	01/04/2019
From:	Klos L Plant Licensing Branch IV
To:	Diya F Union Electric Co
Klos L, 415-5136
References
EPID L-2018-LLA-0062
Download: ML18353B016 (27)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 4, 2019 Mr. Fadi Diya Senior Vice President and Chief Nuclear Officer Ameren Missouri Callaway Energy Center 8315 County Road 459 Fulton, MO 65077

SUBJECT:

CALLAWAY PLANT, UNIT NO. 1 - REGULATORY AUDIT

SUMMARY

REGARDING LICENSE AMENDMENT REQUEST TO INCORPORATE A NEW TECHNICAL SPECIFICATION 3.7.20 (EPID L-2018-LLA-0062}

Dear Mr. Diya:

By letter dated March 9, 2018 (Agencywide Documents Access and Management System Accession No. ML18068A685), Union Electric Company (the licensee, dba Ameren Missouri),

submitted a license amendment request (LAR) requesting approval for a new Technical Specification (TS) related to room cooling for essential electrical equipment for Callaway Plant, Unit No. 1 (Callaway).

The proposed amendment would add new TS 3. 7.20, "Class 1E Electrical Equipment Air Conditioning (A/C) System," to the Callaway TSs. The proposed new TS will include (1) a Limiting Condition for Operation (LCO) statement, (2) an Applicability statement, during which the LCO must be met, (3) Actions (with Conditions, Required Actions, and Completion Times) to be applied when the LCO is not met, and (4) Surveillance Requirements with a specified Frequency to demonstrate that the LCO is met for the Class 1E Electrical Equipment A/C System trains at Callaway.

In addition, this proposed amendment for Callaway also requires revision of TS 5.5.11.e, "Ventilation Filter Testing Program (VFTP)," wherein the wattage value for moisture dissipation by the heater in each control room's pressurization train is proposed to be changed from 15 +/- 2 kilowatts (kW) to 5 +/- 1 kW.

To support its review of the amendment, the U.S. Nuclear Regulatory Commission (NRC) staff conducted a regulatory audit of the supporting calculations as they related to the requested TS changes. The onsite audit occurred on September 26 to September 27, 2018, at Callaway.

The remainder of the audit was conducted by the NRC staff via teleconference calls between the NRC staff and the licensee, ending on November 26, 2018.

The purpose of this regulatory audit was to enhance the NRC staff's technical understanding of the LAR and determine if planned design modifications and calculations performed by the licensee would support the bases for the proposed changes to the TSs. The areas of focus during the audit were the calculation methodologies, assumptions, and results used to reach conclusions in the LAR.

F. Diya The NRC regulatory audit summary, list of participants, and list of documents reviewed during the audit are enclosed.

If you have any questions, please contact me at 301-415-5136 or via e-mail at John.Klos@nrc.gov.

Sincerely, L. JohJ~oject Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483

Enclosure:

Regulatory Audit Summary cc: Listserv

OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY AUDIT

SUMMARY

OF THE LICENSE AMENDMENT REQUEST TO INCORPORATE NEW TECHNICAL SPECIFICATION 3.7.20 UNION ELECTRIC COMPANY CALLAWAY PLANT UNIT NO. 1 DOCKET NO. 50-483

1.0 BACKGROUND

By letter dated March 9, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18068A685), Union Electric Company (the licensee, dba Ameren Missouri), submitted a license amendment request (LAR) requesting approval for a new Technical Specification (TS) related to room cooling for essential electrical equipment for Callaway Plant, Unit No. 1 (Callaway).

The proposed amendment would add new TS 3.7.20, "Class 1E Electrical Equipment Air Conditioning (A/C) System," to the Callaway TSs. The proposed new TS will include (1) a Limiting Condition for Operation (LCO) statement, (2) an Applicability statement, during which the LCO must be met, (3) Actions (with Conditions, Required Actions, and Completion Times) to be applied when the LCO is not met, and (4) Surveillance Requirements (SRs) with a specified Frequency to demonstrate that the LCO is met for the Class 1E Electrical Equipment A/C System trains at Callaway.

In addition, this proposed amendment for Callaway also requires revision to TS 5.5.11 e, "Ventilation Filter Testing Program (VFTP)," wherein the wattage value for moisture dissipation by the heater in each control room's pressurization train is proposed to be changed from 15 +/- 2 kilowatts (kW) to 5 +/- 1 kW.

As part of the U.S. Nuclear Regulatory Commission (NRC) staff's review of the LAR, and due to the complexity of the proposed TS changes, which included its supporting calculations, and computer-based modeling, the NRC staff determined that a face-to-face audit, including field walkdowns with the licensee's staff, would enhance the NRC staff's technical review. Hence, the NRC staff planned a regulatory audit in accordance with the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195),

for the NRC staff to gain a better understanding of the licensee's calculations and other aspects of the LAR. Thereby, the audit improved the efficiency of the review and minimized the need, and number, of requests for additional information (RAls). The NRC staff issued the audit plan by letter dated June 19, 2018 (ADAMS Accession No. ML18156A404).

Enclosure

2.0 AUDIT DATES AND LOCATION The onsite portion of the regulatory audit was held at Callaway from September 26 to September 27, 2018. The NRC staff, via teleconference calls with the licensee, conducted the remainder of the audit, and informed the licensee that the audit was closed on November 26, 2018, via the completion of Table 1, below.

Tables 2 and 3, below, provide the list of attendees in the entrance and status briefing meetings held onsite. This resulted in numerous closed items with only one item to be issued as an RAI, while the remaining items would be place on the docket via a supplemental letter.

3.0 AUDIT TEAM MEMBERS (NRC STAFF)

The onsite audit team consisted of the following:

• Larry Wheeler, Audit Team Lead, Containment and Plant Systems Branch, Technical Reviewer

• Gurcharan Matharu, Electrical Engineering Operating Reactor Branch, Technical Reviewer

• John Klos, Callaway Project Manager, Plant Licensing Branch IV Support staff and management from NRC headquarters consisted of the following:

• Shaun Anderson, Containment and Plant Systems Branch, Branch Chief

• Nageswara Karipineni, Containment and Plant Systems Branch, Technical Reviewer

• Pete Snyder, Technical Specifications Branch, Technical Reviewer

• John Hughey, Human Factors Branch, Technical Reviewer 4.0 AUDIT

SUMMARY

The purpose of this regulatory audit was to enhance the NRC staff's technical understanding of the LAR and to determine if planned design modifications and calculations performed by the licensee, support the bases for the proposed changes to the TSs. The areas of focus during the audit were the calculation methodologies, assumptions, and results used to reach conclusions in the LAR.

Callaway opened the audit on September 26, 2018, with a power point presentation, which highlighted the progress made since the LAR was submitted on March 9, 2018. A walkdown of the Callaway control building room (where the Class 1E equipment is located) was conducted during the visit to help the NRC staff better understand the electrical room configuration associated with the heating, ventilation, and air conditioning (HVAC) system. The licensee also presented superimposed illustrations to demonstrate the existing and proposed configurations of planned hardware changes needed to support TS changes.

Table 1 provides a list of open items identified during the audit, with a short summary description of how these items were addressed.

The following key documents were reviewed during the audit:

• Calculation No. NAl-1719-004, Revision 1, "Callaway Control Building with Control Room Loss of Class 1E A/C GOTHIC Room Heat Up Installed Fans and Louvers."

• Calculation No. GK-11, Revision 4, "Electrical Heat Loads in the Control Building during Normal and ESFAS [Engineered Safety Features Actuation System] Conditions."

• Calculation No. 80-07, Revision 12, "Control Room SBO [Station Blackout] and Normal/LOCA [Loss-of-Coolant Accident] Electrical Hear Load Calculation."

• Calculation M-GK-370, Revision 1, "Post-Accident Battery Room H2 Concentration Levels."

• Calculation M-GK-01-C, Revision 1, "Control Room Pressurization Filtration Unit Heater."

• Drawings, "Duct General Assembly Drawings," M-2H3300 and 3400 series.

• Drawings, MP16-0024 and MP17-0024 series (proposed design modification drawings).

• Drawings, M-22GK03 and GK04 series, Piping and Instrumentation Drawings.

• Physical arrangement drawings of the areas of the Class 1E Electrical Equipment AC System and associated areas of cooling.

• Document regarding: Supplemental Fan System for Class 1E Cooling.

In summary, the audit enhanced the NRC staffs understanding of the Class 1E configuration, existing HVAC systems, calculations, and computer-based model (GOTHIC) used in support of the LAR.

Table 1 Items Identified During the Audit Review Item# Description Status Supplement.

RAl,or Closed 1 NRC staff needs to determine that the GOTHIC model The licensee presented the Gothic calculation to the NRC Closed documents the air flow patterns necessary to support the staff for review, and the staff reviewed the calculation for the LAR's related design modifications. representation of proper and complete air flow patterns.

Specifically, do the air flow patterns utilizing the new This item is closed based on the NRC staff review.

fans/ducts provide appropriate and complete air flow to the back of the Motor Control Centers?

2 The licensee's LAR proposes to change TS 5.5.11, The licensee stated in the audit that: Supplement "Ventilation Filter Test Program (VFTP)," lowering control room HVAC heater wattage from 15 +/- 2 kW to 5 +/- 1 kW. 1. The supportive original calculation was supplied and NRC staff needs to understand the basis for change from reviewed by NRC staff, which discusses the upper and the original 15 kW heater and the consequences, if any, lower limits supplied by the heater to the system and how on the charcoal filters. charcoal function is maintained.

NRC staff questions: 2. A change in voltage to the heater terminals was addressed in the related calculation provided to the NRC

1. Please provide a copy of the original calculation to staff for review of adequate system margins and proper support this proposed change. system protections.

2. The calculation reviewed during the audit documents 3. Voltage load flow cases/diagrams for the system related that 414 volts are the minimum allowable voltage at the to the heater's sizing were presented and discussed with bus. Assuming a 2-3 percent voltage drop from the bus NRC staff.

to the terminals of the heater produces a heat output of less than the 3.16 kW. Please provide a discussion 4. Reduced heater wattage testing methods and testing related to the adequacy of the proposed heater size and standards were discussed and presented to the NRC staff TS range based on limiting voltage at the heater for review.

terminals.

The information provided was reviewed by the NRC staff,

3. Please provide a discussion on the adequacy of the and the licensee plans to supplement the application proposed heater size when the 4160-volt bus is operating at 37 40 volts and 58.8 hertz (Hz).

Item# Description Status Supplement.

RAl,or Closed

4. Please discuss how the proposed filtration configuration with the reduced heater size will be tested to validate the adequacy of proposed design modification.

3 Typically the cables in the cable trays have a conductor The licensee addressed these engineering issues with the Supplement temperature of 90 degrees Centigrade (°C). The NRC NRC staff and provided detailed information related to staff needs to understand the LAR's assumptions related assumptions, and conservative considerations made to to the electrical conditions of the following: cable temperatures and transformer loads.

1. What temperature (conductors and other electrical The information provided was reviewed by the NRC staff at equipment) was used to evaluate heat input into the the audit and the licensee plans to supplement the rooms? amendment, via letter submission, with the detailed technical information concerning this question.

The major contributors to heat load are transformers and cables where heat generated is calculated as 12R with I, current, and R, resistance. Here, R increases as temperature increases.

Cables are designed to operate at 90 °C with room temperatures approaching 100 degrees Fahrenheit (°F),

or more, the cables may be operating at or above design temperature of 90 °C. Hence the "R" value of cables should be computed at appropriate conductor temperature.

With the onset of an event, such as a LOCA, the pressures in the reactor cooling system may be low and pumps may operate at runout conditions. Hence, the motors associated with the pumps may be operating above nominal rating resulting in higher current.

Please provide details on how the large loads were considered at the onset of an event and the first few initial hours.

Item# Description Status Supplement.

RAI, or Closed

2. The corresponding load on the transformers need to be confirmed. The current in the transformer should account for maximum load plus losses.

In addition, please provide details on the calculation that was developed to evaluate tray fill and any diversity factor used for heat loss calculations.

4 Callaway's Final Safety Analysis Report (FSAR), The licensee, during the audit period, discussed in detail Supplement Revision OL-22, Chapter 1, "Introduction and General with the NRC staff the procedures and protocols concerning Description of the Plant," Section 1.2.1.8, "Meteorology" normal, cold, and accident conditions related to the (ADAMS Accession No. ML17048A157), states, in part monitoring, control of minimum battery room temperatures.

that "The climate of the Callaway site is temperate continental with cold snowy winters and warm, humid The discussions specifically addressed plant operations summers. Based on climatological data from nearby during those periods of concern while applying the plant weather stations, the normal annual average temperature heating system, battery room historical operating is 55 °F at Columbia, Missouri. Extreme temperatures for experience, and the proposed amendment's calculations the area are 116 °F for Fulton, Missouri, and -26 °F for associated with battery room temperatures.

Fulton, Missouri."

The licensee's technical documents and discussions stated Callaway's TS, Facility Operating License NPF-30, the adequacy of batteries to perform, subject to the Technical Specifications (ADAMS Accession conditions above, for the proposed amendment.

No. ML053110040), SR 3.8.6.3 states: "Verify average electrolyte temperature of representative cells The information provided was reviewed by the NRC staff at is ~ [greater than or equal to] 60 °F." the audit, and the licensee plans to supplement the LAR, via letter submission, with the detailed technical information FSAR, Revision OL-22, Chapter 9, Section 9.4.1.2.3, concerning this question.

"System Operation," states, in part: "The ambient temperature in the battery rooms, under any mode of operation, will be between 60 °F and 90 °F" The batteries have minimum and maximum operating temperature limits. The battery will give the best results when working in a room temperature between 60 °F and 80 °F, but will function when ooeratinci in temperatures

Item# Description Status Supplement.

RAl,or Closed outside the allowable band. High temperatures increase the performance, but decrease the life of the cells; low temperatures reduce the performance.

The NRC staff needs clarification on the values associated with the Minimum Vital Battery Room Temperatures during an Extended Loss of Alternating Current Power Event calculation, and to understand the consequences of extreme winter temperatures and battery room temperatures that were evaluated during minimum heat load conditions.

The NRC staffs concern is related to a planned or unplanned 30-day outage, which may be in the middle of winter when the outside temperature is -26 °F.

Please consider the following scenario and related questions:

1. The plant is online, then the Emergency Core Cooling System (ECCS) is not operating and heat load in the areas of concern may be minimal. Please provide a discussion on any corrective actions that may be needed to maintain battery operability.

2. If an accident occurs 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or 7 days later, the load shedding reduces heat input into the rooms.

Please provide a discussion related to the operability of the batteries after a few days into the event. The accident could also occur at any time during the 30-day outage.

3. Assuming a SBO event occurs following an extended loss of offsite power event anytime during the proposed 30-day LCO, please provide a discussion related to the operability of battery for the required copinQ duration.

Item# Description Status Supplement.

RAI, or Closed

4. Please provide a discussion on the low end design temperature related to operability of the SR batteries.

5. How will this be controlled during the proposed completion time?

6. Do the battery room temperatures drop below 60 °F?

5 Maximum hydrogen (H2) discharge occurs during battery During the audit, the licensee presented and discussed with Supplement charging/discharging cycles. At the onset of an event, the NRC staff the H2 calculation and its use and application the battery supply maximum direct current loads would with the GOTHIC analysis for the LAR.

be close to their maximum load capability within the first few minutes and then would require recharge when The information provided was reviewed by the NRC staff power is restored. and the licensee plans to supplement the application.

The licensee's LAR did not present data related to the calculated of the H2 discharge for such a postulated scenario.

NRC staff questions:

1. The licensee needs to confirm that a H2 discharge calculation was utilized for this LAR.

2. It is not clear to the NRC staff how the proposed amendment's GOTHIC calculation considered H2 generation during battery charging and the licensee needs to present how H2 is distributed within the rooms when the HVAC is in recycle mode only.

Item# Description Status Supplement.

RAl,or Closed 6 During the NRC staff walkdown, the following questions The licensee addressed these observations and presented Supplement were developed: to the NRC staff detailed information concerning the temperature indicators and their alarms, readout

1. Several Class 1E rooms have wall mounted points/setpoints, operator actions, procedures changes, temperature indications. Do these read-out in the power sources, inputs/outputs to the plant computer system, main control room (MCR) or display out on the plant and their relationship to monitoring of battery room computer? temperatures.

2. Are these temperature indications also alarms points? The information provided was reviewed by the NRC staff at the audit, and the licensee plans to supplement the LAR, via

3. If these temperature indications are nonsafety-related letter submission, with the detailed technical information powered to the plant computer, how does the plant concerning this question computer indicate loss of power?

4. Are there procedures in place to monitor the battery room temperatures since there is no wall mounted thermocouple?

How will monitoring be performed for the proposed TS actions related to battery room temperatures, locally, every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or shift?

7 The diesel generator (DG) frequency, as stated in The licensee, during the audit period, discussed with the Supplement SR 3.8.1.11, Item c.4, documents that that value may be NRC staff information related to the LAR's analysis, DG as low as 58.8 Hz. The proposed amendment's frequency, ECCS conditions related to pump configuration, calculation needs to use air flow rates to calculate room and the fan flow rates to these questions.

temperatures for the DG.

The information provided was reviewed by the NRC staff The NRC staff has the following questions: and the licensee plans to supplement the application.

1. Does the proposed amendment's GOTHIC analysis use ECCS pump runout conditions, or some other condition?

Item# Description Status Supplement.

RAl,or Closed

2. Please identify which large pumps (greater than 50 horsepower) are assumed to have flow control or orifices.

3. Please provide details on changes in flow rates and any impact on room heatup calculations if the DG frequency is at 58.8 Hz.

8 The proposed TS Bases in Attachment 5 of the LAR The licensee stated in the audit that: Closed (ADAMS Accession No. ML18068A691 ), states that mitigating actions are to be taken with the starting of a: The 90 °F temperature limit serves as an initial condition recirculating fans to limit Class 1E room heat up less than in the room temperature analysis when a single train of

(<) 90 °F. Room temperature monitoring is proposed in Class 1E air conditioning is cooling both trains of Class 1E the TS required actions. electrical equipment rooms. When both trains of Class 1E air conditioning are available, it is not necessary to impose It is not clear to the NRC staff how the elements of a an initial condition temperature limit to demonstrate surveillance requirement to support proper MCR acceptable room temperatures over the 30-day mission time temperatures would be accounted for in this LAR. for the Class 1E electrical equipment. Room temperature limits and monitoring requirements are not included as an

1. Should the following elements be part of the LCO LCO or SR in the Improved Standard Technical related to this amendment; Specifications. Room temperature limits and monitoring requirements that are applicable when not in a Required

a. room temp < 90 °F; Action, have been relocated to FSAR Section 16.7.4, "Area

b. the 10 room numbers for cooling; and Temperature Monitoring." Based on this, it would not be C. mitigating actions. appropriate to impose the < 90 °F room temperature limit when both trains of Class 1E electrical equipment are operable.

b: The 10 room numbers are listed in the proposed Technical Specification Bases. This will provide the detailed information regarding which specific rooms are covered while maintaining a concise Technical Specification.

c: The mitigating actions are not applicable when both trains of Class 1E air conditioning equipment are operable.

Therefore, it would not be appropriate to list the mitioatino

Item# Description Status Supplement.

RAI, or Closed actions in the LCO. Required Action A.1 of proposed Technical Specification 3.7.20 was developed using Required Action B.1 of Technical Specification 3.7.10 as the model. As was previously discussed in this item, imposing the 90 °F temperature limit of Required Action A.2 as a SR applicable at all times, or as an LCO limit, would have no bases in the analyses for the condition of both trains of Class 1E Electrical Equipment Air Conditioning operable.

This item is closed based on the NRC staff's review.

9 The LAR's proposed completion time for this proposed The licensee discussed, at the audit, all the factors that Supplement TS change should primarily be selected based on the were considered to support the final duration of this TS maintenance component for the duration selected. change. The other factors included the components involved, the qualitative review of risk significance, and It is not clear to the NRC staff what were the additional elements of redundancy.

factors and considerations that accounted for the LAR's proposed completion time of 30 days. The information discussed at the audit was reviewed by the NRC staff and the licensee plans to supplement the LAR, NRC staff question: via a letter submission, with the detailed technical information concerning this question.

Justify why the proposed 30 days TS completion time is needed for normal maintenance of the chiller/HVAC system related to this proposed TS change?

10 The proposed LAR design modifications omitted technical The licensee presented to the NRC staff at the audit Supplement equipment and specification details. information related to equipment classification and power sources.

NRC staff question:

The information discussed at the audit was reviewed by the Please provide missing information such as equipment NRC staff and the licensee plans to supplement the LAR, safety class, 1E Power supply, seismic classification, and via a letter submission, with the detailed technical component testing for the design modifications that information concerning this question.

support this LAR.

Item# Description Status Supplement.

RAI, or Closed 11 Deleted by NRC staff - not used. N/A N/A 12 The LAR's proposal to shut down a complete train of The licensee discussed this item with the NRC staff during RAI Engineered Safety Feature (ESF) equipment (after the audit.

7 days), with one HVAC train unavailable prior to an event, may complicate plant safety considering significant The NRC plans to formally submit a detailed RAI on this equipment in one train (with inoperable HVAC) may not topic to the licensee, which would allow a fully developed be available for an extended period. and detailed technical response to be submitted by the licensee.

It is not clear to the NRC staff how the detailed combinations of events and plant conditions were considered for heat load calculations related to the proposed amendment.

13 Deleted by NRC staff- not used. N/A N/A 14 Deleted by NRC staff- not used. N/A N/A 15 NRC staff question: The information provided was reviewed by the NRC staff at Supplement the audit and the licensee plans to supplement the LAR, via

1. Are there any wall mounted control building area letter submission, with the detailed technical information heaters? concerning this question.

2. If so, are these heaters part of the GOTHIC heat load calculations? How are these area room heaters controlled?

16 Deleted by NRC staff - not used. N/A N/A 17 Deleted by NRC staff- not used. N/A N/A

Item# Description Status Supplement.

RAI, or Closed 18 NRC staff question: The information provided was reviewed by the NRC staff at Supplement the audit and the licensee plans to supplement the LAR, via Please describe the safety classification of the existing letter submission, with the detailed technical information Class 1E electrical HVAC trains and reference any FSAR concerning this question.

sections and tables, as appropriate?

19 Deleted by NRC staff- not used. N/A N/A 20 The TS bases for SR 3.7.20.2 state that this SR verifies The information discussed at the audit was reviewed by the Supplement that the heat removal capability of the A/C units is NRC staff and the licensee plans to supplement the LAR, adequate to remove the heat load assumed in the control via a letter submission, with the detailed technical room during design basis accidents. information concerning this question.

NRC staff question:

Please clarify if the intent was to state that this SR verifies that the heat removal capability of the A/C units is adequate to remove the heat load assumed in the Class 1 E Electrical area during design basis accidents.

21 NRC staff question: The licensee presented to the NRC staff at the audit, the Supplement intended "TRM like document" and use for FSAR

1. It is not clear to the technical staff if: Chapter 16.7.13.

a. A new technical requirements manual (TRM) The licensee plans to supplement the LAR, via a letter associated with the recirculation subsystem will be submission, with the detailed technical information created, including its associated SRs. concerning this question.

Additionally, will FSAR Section 16. 7.13, "Class 1E Electrical Equipment Air Conditioning (A/C)," be revised or deleted, as appropriate, to support this LAR?

22 The licensee's LAR dated March 9, 2018, includes The licensee, during the audit period, discussed with the Supplement information regarding potential cross-train impacts related NRC staff information related to the hydrogen gas to fire protection and hydrogen gas buildup. accumulation, fire protection, room penetrations, radiological

Item# Description Status Supplement.

RAl,or Closed NRC staff question: control ( control room habitability) and the separation distance between trains to address this question.

Please provide or summarize evaluations that address maintaining train independence, redundancy and The information provided was reviewed by the NRC staff separation when opening a communication pathway and the licensee plans to supplement the application.

between the Operable and Inoperable redundant Class 1E trains for any other applicable hazard or any requirements to maintain negative pressure in the affected areas for HVAC/radiological control issues. This question considers if the proposed operator action creates a condition that adversely impacts plant system independence, redundancy or separation relative to NUREG-1764, "Guidance for the Review of Changes to Human Actions," Revision 1, Section 4, "Level II Review Guidance" (ADAMS Accession No. ML072640413).

23 NRC staff question: The licensee discussed this item with the NRC staff during Supplement the audit.

Describe the administrative controls that alert control room operators during normal operations of the need to The information discussed at the audit was reviewed by the start the Class 1E room recirculation fan system within NRC staff and the licensee plans to supplement the LAR, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of a Class 1E AC train being Inoperable and to via a letter submission, with the detailed technical initiate mitigating actions. information concerning this question.

24 NRC staff question: The licensee discussed this item with the NRC staff during Supplement the audit.

Will the associated dampers automatically align when the Class 1E recirculation fan system is started or will the The information discussed at the audit was reviewed by the operator align dampers and start recirculation fans as NRC staff and the licensee plans to supplement the LAR, separate actions? via a letter submission, with the detailed technical information concerninq this Question.

25 NRC staff question: The licensee discussed this item with the NRC staff during Supplement the audit.

Please describe the operator actions required to place the recirculation fans/dampers into service. The information discussed at the audit was reviewed by the NRC staff and the licensee plans to supplement the

Item# Description Status Supplement.

RAI, or Closed amendment, via a letter submission, with the detailed technical information concerning this question.

26 NRC staff question: The information discussed at the audit was reviewed by the Supplement NRC staff and the licensee plans to supplement the LAR, Describe the specific operator actions required to place via a letter submission, with the detailed technical the new Class 1E recirculation fan system in service information concerning this question.

during normal operating conditions. Describe the administrative controls associated with manually placing the recirculation fans in service during normal operating conditions. Identify operator actions that will be proceduralized, or are already in procedures, or describe other applicable administrative controls.

27 NRC staff question: The information discussed at the audit was reviewed by the Supplement NRC staff and the licensee plans to supplement the LAR, Describe the training (and frequency of training) that will via a letter submission, with the detailed technical be provided regarding identifying the need to place the information concerning this question.

Class 1E recirculation fan system in service under normal operating conditions as well as the training that will be provided regarding the specific actions required to place the Class 1E recirculation fan system in service under normal operating conditions.

28 NRC staff question: The information discussed at the audit was reviewed by the Supplement NRC staff and the licensee plans to supplement the LAR, The licensee's LAR dated March 9, 2018, describes a via a letter submission, with the detailed technical maximum post-accident room temperature limit of 104 °F. information concerning this question.

A normal operating temperature of less than or equal to

(~ 90 °F is maintained to ensure that post-accident room temperatures will not exceed the 104 °F limit. However, the LAR does not appear to include analyses or other technical justification confirming the ability of one train of Class 1E A/C to cool both trains of Class 1E equipment under the heat loading of normal operation to the ~ 90 °F TS temperature limit requirement. (The heat load durinQ

Item# Description Status Supplement.

RAI, or Closed normal conditions is greater than the heat load during accident conditions since no load shedding is performed during normal conditions.) Also, the planned design modifications described in Attachment 2, Section 3.3 of the LAR (ADAMS Accession No. ML18068A688), do not indicate that ~ 90 °F temperature limit can be maintained for both trains of Class 1E equipment using only 1 train of Class 1E A/C.

Attachment 2, Section 3.1, "Normal and Design Basis Accident Environmental Conditions," of the LAR states in part: "The normal operating temperature of the Class 1E electrical equipment rooms, as specified in the FSAR, remains below the 90 °F maximum. Normally, the temperatures in the Class 1 E electrical equipment rooms are maintained between 68 °F and 75 °F, and during normal equipment operation (with both SGK05A or SGK05B units in service) the room temperatures are assured to remain below 90 °F. A single functional Class 1 E electrical equipment A/C train providing area cooling for both electrical equipment trains concurrent with accident condition (LOCA) heat loading will maintain the equipment room temperatures less than the 104 °F maximum for accident/faulted environmental conditions."

NRC staff question:

Please provide the historical data since it does not appear that operation of the new recirculation fan system can support both Class 1E trains~ 90 °F, under normal operating conditions, with only one Class 1E AC train operable (this may indicate that the proposed design modification cannot support the new proposed TS 3.7.20 Required Action A.2 of the LAR).

Item# Description Status Supplement.

RAI, or Closed 29 Attachment 2 in Section 3.3 subsection, "Credited Manual The information discussed at the audit was reviewed by the Supplement Operator Actions," of the LAR, discusses crediting NRC staff and the licensee plans to supplement the LAR, operator manual actions associated with the new via a letter submission, with the detailed technical Class 1E recirculation fan system. This subsection only information concerning this question.

addresses accident/event initiation and states that operators are trained on revisions to the Emergency Operating Procedures.

NRC staff question:

Describe the training (and frequency of training) that will be provided regarding identifying the need to place the Class 1E recirculation fan system in service under accident/event conditions, as well as the training that will be provided regarding the specific actions required to place the Class 1E recirculation fan system in service under accident/event conditions.

30 NRC staff question: The information discussed at the audit was reviewed by the Supplement NRC staff and the licensee plans to supplement the LAR,

1. Describe the validation that has been performed to via a letter submission, with the detailed technical demonstrate that the manual operator action credited information concerning this question.

in the GOTHIC calculation to restart the recirculation fans within 30 minutes of accident/event initiation is feasible and reliable?

2. How was this validation demonstration activity documented?

31 NRC staff question: The information discussed at the audit was reviewed by the Supplement NRC staff and the licensee plans to supplement the LAR,

1. Describe the validation that has been performed that via a letter submission, with the detailed technical demonstrates that the required load shed described in information concerning this question.

Attachment 2, in Section 3.3 subsection ("Credited Manual Operator Actions"), of the LAR, regarding

Item# Description Status Supplement.

RAI, or Closed credited operator manual actions can be reliably completed within the 30-minute credited timeframe in addition to all actions required to place the recirculation fans in service within the same 30-minute timeframe.

2. How was this validation demonstration activity documented?

32 NRC staff question: The information discussed at the audit was reviewed by the Supplement NRC staff and the licensee plans to supplement the LAR,

1. Is the 30-minute action time, discussed in via a letter submission, with the detailed technical Attachment 2, in Section 3.3 of the LAR, regarding information concerning this question.

credited operator manual actions, being controlled or should it be controlled as a time critical operator action?

2. What is the time margin available to place the Class 1E recirculation fan system in service under accident/event conditions?

33 NRC staff question: The information discussed at the audit was reviewed by the Supplement NRC staff and the licensee plans to supplement the LAR,

1. Describe all mitigating actions (referred to on page 40 via a letter submission, with the detailed technical of Attachment 2, Section 4.2, "Precedent," of the LAR) information concerning this question.

involving operator actions being relied on by Callaway to fulfill the requirements of Required Actions A.1 and A.2 under proposed TS 3. 7 .20 when utilizing the supplemental cooling system to fulfill the required actions.

2. Provide the human factors evaluations that justify the feasibility and reliability of the mitigating operator actions, and the validation performed to verify the feasibility and reliability of these actions.

Item# Description Status I Supplement.

RAl,or Closed 34 Callaway proposed to utilize the Surveillance Frequency The information discussed at the audit was reviewed by the I Supplement Control Program for SRs 3.7.20.1 and 3.7.20.2 NRC staff and the licensee plans to supplement the LAR, frequencies as shown in Attachment 3 of the LAR via a letter submission, with the detailed technical (ADAMS Accession No. ML18068A689). information concerning this question.

NRC staff question:

1. Please provide an initial SR frequency and basis for each SR below.

a. Verify action on an actually or simulated signal and ensure the capability to remove the assumed heat load.

35 Deleted by NRC staff - not used. N/A IN/A 36 The LAR does not document room to room delta The information discussed at the audit was reviewed by the I Supplement pressures, nor room H2 generation/concentrations. NRC staff and the licensee plans to supplement the LAR, via a letter submission, with the detailed technical NRC staff question: information concerning this question.

Please provide this data that supports room pressures and room H2 concentrations.

37 NRC staff question: The information was discussed at the audit with the NRC Supplement staff, and the licensee plans to supplement the LAR, via a Please provide a copy, via supplemental letter, letter submission, the detailed P&ID(s) to address this of the Piping and Instrumentation Diagram (P&ID) for the question.

control building HVAC system.

38 NRC staff question: Licensee response: Supplement Please provide, via supplemental letter, any and all The request was discussed at the audit with the NRC staff, updated documents for the final version of this LAR's and the licensee plans to supplement the LAR, via a letter design modifications. submission, the detailed documents for the final version of the LAR's design modifications.

Item# Description Status Supplement.

RAl,or Closed 39 Attachment 2, Section 3.3, "Planned Modifications," of the The information discussed at the audit was reviewed by the Supplement LAR, page 24 states, in part, " ... wall and door NRC staff, and the licensee plans to supplement the LAR, penetrations equipped with fires dampers ... " via a letter submission, with the detailed technical information concerning this question.

NRC staff question:

Describe the technical basis for the acceptability of the grills in the fires doors (without fire dampers).

40 NRC staff question: The information discussed at the audit was reviewed by the Supplement NRC staff, and the licensee plans to supplement the LAR, For the proposed amendment, are there any new flooding via a letter submission, with the detailed technical concerns with the modified fire door related to the new information concerning this question.

grills?

41 NRC staff question: The information discussed at the audit was reviewed by the Supplement NRC staff and closed for questions 1.a, band c for this item. to letter of

1. While reviewing the LAR's proposed Class 1E question 1)d.

Recirculation System Piping and Instrumentation Concerning question 1.d, the licensee plans to supplement Diagram, the NRC staff observed the following the LAR, via a letter submission, with the detailed technical discrepancies: information concerning this question.

a. Arrows that appear to incorrectly indicate A versus B train operation. (Note: The arrows as provided show only A train is in service, but B trains fans are showing flow arrows.)

b. Areas on the P&IDs, between ESF SG 1 and 2 indicate as open space where it should indicate a wall exists.

c. Please describe why there are 36-inch versus 30-inch openings between battery rooms.

d. Please document if a fan blade missile analyses

Item# Description Status Supplement.

RAI, or Closed for the new proposed fans were developed to support the LAR.

42 The NRC staff reviewed the GOTHIC calculation during The information discussed at the audit was reviewed by the Supplement the audit and found the following items. NRC staff and closed for questions 1., 2., and 4. for this to letter item. Question 3 of

1. No approval signatures or dates? this item.

Concerning Question 3. - The licensee plans to supplement

2. The GOTHIC calculation data stated that room 3101 the LAR and provide corrections to the LAR table in has at a maximum temperature of 120 °F. That Attachment 2, as appropriate, via a letter submission.

appears to be an editorial error on that page of the calculation. Please confirm.

3. Attachment 2, Section 3.2.3, "Results." Table 4, "Maximum Room Temperature Summary," of the LAR, and the listed GOTHIC calculations room temperatures are not consistent by a value of 0.01.

Please discuss.

4. Room delta pressures provided in the calculation show color blocking of green, red, and blue.

There is no legend associated with these colors.

NRC staff question:

1. Please provide the revised, final, signed calculation for audit review.

2. Described why this temperature is acceptable.

3. Provided a correction to the LAR table, as appropriate.

4. Described the color legion for this section of the calculation.

Item# Description Status Supplement.

RAl,or Closed 43 Fire doors are modified with new fans The information discussed at the audit was reviewed by the Supplement NRC staff, and the licensee plans to supplement the LAR, NRC staff question: via a letter submission, with the detailed technical information concerning this question.

Describe if the fire doors are part of the fan structure.

44 Attachment 2, Section 3.3 subsection "Fire Protection The request was discussed at the audit with the NRC staff, Supplement Evaluation," of the LAR, on page 29, references the and the licensee plans to supplement the LAR, via a letter Halon fire system, but during the NRC staff walkdown, it submission, the detailed P&ID(s) to address this question.

was noted that the halon is removed from certain elevations of the control building.

NRC staff question:

Please update the LAR with correct information, and a P&ID drawing since the drawing references Halon control panel.

45 Open grating is added to the LAR's six fire doors. The information discussed at the audit was reviewed by the Supplement NRC staff, and the licensee plans to supplement the LAR, NRC staff questions: via a letter submission, with the detailed technical information concerning this question.

1. Does this affect the normal air flow balance (path of least resistance) when not in proposed TS 3.7.20 actions?

2. Describe why this is acceptable, and is this air flow balance accounted for in the GOTHIC analysis?

Table 2 NRC Audit - Attendees September 26, 2018 L. Wheeler NRC-NRR !Technical Reviewer G. Matharu NRC-NRR rTechnical Reviewer J. Klos NRC-NRR Project Manager D. Bradley NRC-NRR Sr. Resident Inspector S. Janicki NRC-NRR Resident Inspector J. Cordz Union Electric Company Safety Analysis dba Ameren Missouri J. Little Ameren Missouri Licensing Engineer B. Richardson Ameren Missouri Supervisor of Safety Analysis J. Fortman Ameren Missouri Supervisor of ReQulatorv Affairs R. Pohlman Ameren Missouri Licensing J. Kovar Ameren Missouri Licensing Engineer M. Covey Ameren Missouri Manager, Operations M. Fletcher Ameren Missouri Fire Protection Engineer M.D. Haag Ameren Missouri Principal Design Engineer M. Lutz ~meren Missouri Design Engineer J. Claunch ~meren Missouri Supervisor of Engineering Programs R. Lutz ~meren Missouri Project Manager

~- Alley ~meren Missouri Supervisor Engineer S. Abel ~meren Missouri Director, Engineering Design a Projects R. Wink ~meren Missouri Regulatory Affairs Manager T. Elwood ~meren Missouri Regulatory Affairs Supervisor L. Krooswyk Burns & McDonnel Design/Project EnQineerinQ J. King Zachry Engineer

Table 3 NRC Audit -Attendees September 27, 2018 L. Wheeler NRC-NRR !Technical Reviewer G. Matharu NRC-NRR Technical Reviewer J. Klos NRC-NRR Project Manager S. Janicki NRC-NRR Resident Inspector rr. Herrmann Union Electric Company Site Vice President dba Ameren Missouri S. Banker Ameren Missouri Mee President Engineering B. Cox ~meren Missouri ~ssistant Site Vice President F. Bianco !Ameren Missouri Sr. Director Nuclear Operations D. Farnsworth Ameren Missouri Director, Nuclear Operations S. Ewins ~meren Missouri Project Engineer D. Waller ~meren Missouri Supervisor Project J. Kosky !Ameren Missouri Regulatory Affairs J. Cordz ~meren Missouri Safety Analysis J. Little ~meren Missouri Licensing Engineer B. Richardson !Ameren Missouri Supervisor Safety Analysis R. Pohlman !Ameren Missouri Licensing J. Kovar ~meren Missouri Licensing Engineer R. Lutz ~meren Missouri Project Manager R. Wink ~meren Missouri Regulatory Affairs Manager T. Elwood ~meren Missouri Regulatory Affairs Supervisor L. Krooswyk Burns & McDonnel Design/Project Engineering J. King lZachry Engineer

ML183538016 *by e-mail OFFICE NRR/D0RL/LPL4/PM NRR/D0RL/LPL4/LA NRR/DSS/SCPB/BC* NRR/D0RL/LPL4/BC NRR/DORL/LPL4/PM NAME JKlos PBlechman SAnderson RPascarelli JKlos DATE 1/3/19 12/20/18 12/19/2018 1/3/19 1/4/19