ULNRC-06482, Response to Request for Additional Information Pertaining to License Amendment Request for Addition of New Technical Specification 3.7.20, Class 1E Electrical Equipment Air Conditioning (A/C) System.

Response to Request for Additional Information Pertaining to License Amendment Request for Addition of New Technical Specification 3.7.20, Class 1E Electrical Equipment Air Conditioning (A/C) System.

ML19039A353
Person / Time
Site:	Callaway
Issue date:	02/08/2019
From:	Abel S Ameren Missouri
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML19039A352	List: ML19039A354 ULNRC-06482, Response to Request for Additional Information Pertaining to License Amendment Request for Addition of New Technical Specification 3.7.20, Class 1E Electrical Equipment Air Conditioning (A/C) System.
References
LDCN 16-0013, ULNRC-06482
Download: ML19039A353 (5)

Text

!iAmeI$efl Callaway Plant MISSOURI February 8, 2019 ULNRC-06482 U. S Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-000 1 10 CFR 50.90 Ladies and Gentlemen:

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

RENEWED FACILITY OPERATING LICENSE NPF-30 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION PERTAINING TO LICENSE AMENDMENT REQUEST FOR ADDITION OF NEW TECHNICAL SPECIFICATION 3.7.20, CLASS 1E ELECTRICAL EQUIPMENT AIR CONDITIONING (A/C) SYSTEM (LDCN 16-0013)

References:

1 . Ameren Missouri letter ULNRC-06401 , License Amendment Request for Addition of New Technical Specification 3 .7.20, Class 1E Electrical Equipment Air Conditioning (A/C) System (LDCN 16-0013), dated March 9, 201 8 (ADAM Accession Number ML18068A685)

2. NRC letter, 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), dated January 4, 2019. (ADAMS Accession Number ML18353B016) 3 NRC Request for Additional Information (received via e-mail, Formal Release of RATs, Ref:

Callaway Plant Class 1E LAR, L-201 8-LLA-0062 on January 9, 201 9) (ADAMS Accession Number ML19O1OAO1O)

4. Ameren Missouri letter ULNRC-06477, Supplement to License Amendment Request for Addition ofNew Technical Specification 3.7.20, Class 1E Electrical Equipment Air Conditioning (A/C) System (LDCN 16-00 1 3), dated January 23 , 2019 (ADAM Accession Number ML19024A470)

By letter dated March 9, 201 8 (Reference 1) Union Electric Company (dba Ameren Missouri) submitted a License Amendment Request (LAR) for the Callaway Plant. Per the requested license amendment, the Callaway Technical Specifications would be revised to incorporate a new Technical Specification (TS), i.e., TS 3.7.20, for the Class 1E Electrical Equipment Air Conditioning (A/C)

System at Callaway. In addition, TS 5 .5 1 1 , Ventilation Filter Testing Program, would be revised to

83 15 County Road 459 : Steedirian, 1\1J 65077 : i\.riierenN4issouri.corri.

ULNRC-06482 February 8, 2019 Page 2 of 5 change the value specified for the wattage required to be dissipated by the heater in each control room pressurization train from 1 5 +/- 2 kW to 5 +/- 1 kW.

The Class 1E Electrical Equipment A/C System provides area cooling within the Control Building for the Class 1E switchgear, as well as safety-related inverters, batteries and battery chargers. At present, the system is not specifically addressed in the Technical Specifications. Ameren Missouris proposed LAR will incorporate appropriate TS requirements for this important support system, including a Condition and Required Action for when one Class 1E electrical equipment A/C train is declared inoperable.

The proposed Required Actions for the noted Condition would allow up to 30 days for restoring the inoperable Class 1E electrical equipment A/C train to Operable status, provided compensatory actions are taken, which consist mainly of monitoring room temperatures to ensure room temperatures remain within limits as supported by placing one train of the supplemental cooling system into service (to be described in the Bases for proposed TS 3.7.20 and in the FSAR). The supplemental cooling system augments the capability of one operable Class 1E electrical equipment A/C train to cool the rooms/areas of both trains of Class 1E electrical equipment. The system is being installed under a plant modification (MP 1 6-0024) that will be completed in the forthcoming refueling outage, i.e., in time for implementation ofthe requested license amendment.

The basis and details for proposed TS 3.7.20, as well as more detailed descriptions ofthe associated plant modifications (including the supplemental cooling system) and the underlying technical analyses, are provided in the Reference 1 EAR as well as in the recently submitted supplement to the EAR, (Reference 4).

To support the NRC staff s review of the LAR and its basis, an audit was conducted at the Callaway plant in September (201 8). A summary of the audit was provided in an NRC letter issued on January 9, 2019 (Reference 2), and a summary of the audit questions/requests along with the final Ameren Missouri responses was included in the Reference 4 EAR supplement. As described in the Reference 2 and 4 letters, all of the items/issues identified from the audit were resolved except for one item/area for which it was determined that additional information is needed. That item/area mainly concerns the analysis of heat loads and use of the supplemental cooling system following an accident or hazard with a Class 1E electrical equipment A/C train inoperable at the onset of such an event. As anticipated, therefore, a request for additional information, in the form of several, individual questions/requests, was issued by the NRC on January 9, 201 9, (Reference 3). Responses to the RAI questions/requests were requested to be submitted on or by February 8, 2019.

The response to the NRCs January 9, 2019 RAT is hereby provided via Attachment 1 to this letter.

The attached response includes background information provided in the NRCs RAT, followed by responses to the individual questions/requests contained in the RAI.

Ifthere are any questions regarding this EAR supplement, please contact Mr. Tom Elwood at 3 14-225-1905.

ULNRC-06482 February 8, 2019 Page 3 of 5 I declare under penalty of perjury that the foregoing is true and correct.

Director, Engineering Design and Projects Executed on: 2 Attachments to this letter:

1 . RAT Questions and Responses

ULNRC-06482 February 8, 2019 Page 4 of 5 cc: Mr. Scott A. Morris 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. L. John Kios Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 09E3 Washington, DC 20555-0001

ULNRC-06482 February 8, 2019 Page 5 of 5 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 6100 Western Place, Suite 1050 Fort Worth, TX 76107

( 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 Tech Spec ULNRC Distribution:

F. M. Diya T. E. Herrmann B. L. Cox F. J. Bianco S. P. Banker L. H. Kanuckel S. L. Abel R. C. Wink T. B. Elwood B. D. Richardson D. R. Wailer Corporate Communications NSRB Secretary STARS Regulatory Affairs Mr. Jay Silberg (Pillsbury Winthrop Shaw Pittman LLP)

Missouri Public Service Commission Mr. Steve Feeler (DNR)

Mr. Dru Buntin (DNR)