ML18355A488

NRR E-mail Capture - Formal Release of RAI Ref: Callaway Plant EAL Changes, L-2018-LLA-0239

ML18355A488
Person / Time
Site:	Callaway
Issue date:	12/20/2018
From:	John Klos Plant Licensing Branch IV
To:	Elwood T AmerenUE
References
L-2018-LLA-0239
Download: ML18355A488 (4)

Text

NRR-DMPSPEm Resource From: Klos, John Sent: Thursday, December 20, 2018 10:42 AM To: 'Telwood@ameren.com' Cc: Klos, John

Subject:

Formal release of RAI Ref: Callaway Plant EAL changes, L-2018-LLA-0239 Importance: High

Tom, By letter dated September 4, 2018, Union Electric Company (dba, Ameren Missouri) requested approval for an emergency action level (EAL) scheme change for Callaway Plant (Callaway), (Agencywide Documents Access and Management System (ADAMS) Accession Number ML18247A467). Callaway proposes a license amendment for changes to

a. EAL CA6.1, Cold Shutdown / Refueling System Malfunction - Hazardous event affecting a SAFETY SYSTEM needed for the current operating MODE: Alert, and

b. SA9.1 System Malfunction - Hazardous event affecting a SAFETY SYSTEM needed for the current operating MODE: Alert (including addition of a new definition for the term Loss of Safety Function (LOSF) and re-definition of the term Visible Damage), along with deletion of Initiating Condition (IC)

HG I and associated EAL HG 1.1 , Hazard -HOSTILE ACTION resulting in loss of physical control of the facility: General Emergency, in connection with the Callaway Plant Radiological Emergency Response Plan.

The Nuclear Regulatory Commission (NRC) staff has reviewed the submittal and has determined that a request for additional Information (RAI) is needed to complete its technical review and make a regulatory finding regarding this licensing action.

A clarification call was held with your staff on Tuesday, December 18, 2018 to further define the question below and this RAI is now released formally with a 60 day calendar response time from today; thereby, this RAI is due on Wednesday, February 20, 2019 by the close of business.

Regulatory Basis:

The requirements of Section 50.47(b)(4), Emergency Plans, to Title 10 of the Code of Federal Regulations (10 CFR) states , in part, that:

A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee...

Guidance:

The most recent industry EAL scheme development guidance is provided in the Nuclear Energy Institute (NEI) document NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, November 2012 (ADAMS Accession Number ML12326A805). By letter dated March 28, 2013, the NRC endorsed NEI 99-01, Revision 6, as acceptable generic (i.e., non-plant-specific) EAL scheme development guidance (ADAMS Accession No. ML12346A463).

1

Emergency Preparedness Frequently Asked Question (EPFAQ) 2016-02 is intended to ensure that an Alert should only be declared when actual or potential substantial performance issues with SAFETY SYSTEMS have occurred as a result of a hazardous event. The threshold values for EPFAQ 2016-02 meet this intention by requiring a hazardous event that causes degraded performance on one train of a SAFETY SYSTEM concurrent with either degraded performance or sufficient visible damage to a second train of a safety system to cause concern regarding the reliability or operability of the affected component.

The notes provided in EPFAQ 2016-02 support those threshold values by providing that damage to an out of service system should not result in a CA6 or SA9 declaration and that a declaration should only be made when there are indications of degraded performance on one safety system train with indications of degraded performance or visible damage to a second safety system train (which is consistent with the threshold values of CA6 and SA9).

The focus of the threshold value is the extent of the damage caused by the hazardous event. If a hazardous event adversely impacts the operation of a safety system and there is concurrent damage on a second safety system, then an Alert classification should be made.

Request for Additional Information:

Note: In the RAIs below, the section or initiating condition category are listed with the Callaway nomenclature first and if any change from NEI guidance listed in brackets.

Callaway RAI-1 CA6.1 and SA9.1 [CA6 and SA9]

Page 2 of Attachment 1, Evaluation of Proposed Emergency Action Levels, proposes the following wording for CA6.1 and SA9.1, as Note 12 states :

This EAL is applicable when a Table C-6, Hazardous Events, causes a LOSS Of SAFETY FUNCTION on a SAFETY SYSTEM required for the current operating MODE, then this emergency classification is not warranted.

However, Attachment 3, Emergency Action Level Technical Bases Document, provides the following wording for CA6.1 and SA9.1 Note 12:

This EAL is applicable when a Table C-6, Hazardous Events, causes a LOSS OF SAFETY FUNCTION on a SAFETY SYSTEM required for the current operating MODE.

The wording Note 12, in either of the above versions, includes LOSS OF SAFETY FUNCTION as a defined term. This definition appears to require an assessment that determines whether or not a safety function assumed in the accident analysis cannot be performed. This is neither consistent with the NEI 99-01, Revision 6 or the EPFAQ 2016-02 versions of CA6.1 and SA9.1.

a. Concerning Note 12, as provided on page 2 of Attachment 1, please explain how the proposed wording would not cause confusion when it appears to state that the EAL is applicable AND that an emergency classification is not warranted.

b. Concerning Note 12, as provided in Attachment 3, the addition of LOSS OF SAFETY FUNCTION criteria is not consistent with the proposed EALs CA6.1 and SA9.1 threshold values.

Please explain how a timely and accurate assessment of CA6.1 and SA9.1 can be performed with a note, as sated above, that is not consistent with the EAL threshold values and requires either a safety function determination or some other form of an 2

operability determination. Note: This RAI response should explanation and provide, in much greater detail, justification for a deviation that is not consistent with the definition of an Alert emergency classification.

Thanks in advance, John Klos DORL Callaway, Columbia Project Manager U.S. NRC, Office of Nuclear Reactor Regulation, Division of Operating Reactor Licensing, O9D22 NRC/NRR/DORL/LPL4, MS O9E3 Washington, DC 20555-0001 301.415.5136, John.Klos@NRC.gov 3

Hearing Identifier: NRR_DMPS Email Number: 720 Mail Envelope Properties (BL0PR0901MB23718426338BAC4D9D8F6A25E3BF0)

Subject:

Formal release of RAI Ref: Callaway Plant EAL changes, L-2018-LLA-0239 Sent Date: 12/20/2018 10:42:16 AM Received Date: 12/20/2018 10:42:17 AM From: Klos, John Created By: John.Klos@nrc.gov Recipients:

"Klos, John" <John.Klos@nrc.gov>

Tracking Status: None

"'Telwood@ameren.com'" <Telwood@ameren.com>

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