ML21280A379

Third Supplement to Request for License Amendment and Regulatory Exemptions for a Risk-Informed Approach to Address GSI-191 and Respond to GL-2004-02 (LDCN 19-0014)

ML21280A379
Person / Time
Site:	Callaway  (NPF-030)
Issue date:	10/07/2021
From:	Meyer S Ameren Missouri
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML21280A378	List: ML21280A379 ML21280A380 ML21280A381 ULNRC-06692, (Replacement for Enclosure 3, Callaway Methodology for a Risk-Informed Approach to Address Generic Letter 2004-02, of ULNRC-06526)
References
EPID L-2021-LLA-0059, EPID L-2021-LLE-0021, ULNRC-06692
Download: ML21280A379 (5)

Text

Ameren Callaway Plant MISSOURI October 7, 2021 ULNRC-06692 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 50.90 Ladies and Gentlemen:

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

RENEWED FACILITY OPERATING LICENSE NPF-30 THIRD SUPPLEMENT TO REQUEST FOR LICENSE AMENDMENT AND REGULATORY EXEMPTIONS FOR A RISK-INFORMED APPROACH TO ADDRESS GSI-191 AND RESPOND TO GE 2004-02 (LDCN 19-0014) tEPID L-2021-LLA-0059 AND EPID L-2021-LLE-0021)

References:

1.

Ameren Missouri letter ULNRC-06526, Request for License Amendment and Regulatory Exemptions for a Risk-Informed Approach to Address G$I-1 91 and Respond to GL 2004-02 (LDCN 1 9-00 1 4), dated March 3 1, 202 1 (ADAMS Accession No. ML21090A184) 2.

Ameren Missouri Letter ULNRC-06664, Supplement to Request for License Amendment and Regulatory Exemptions for a Risk-Informed Approach to Address GSI-191 and Respond to GL 2004-02 (LDCN 19-0014), dated May 27, 2021 (ADAMS Accession No. ML21147A222) 3.

Ameren Missouri letter ULNRC-0665 1, Supplement to Request for License Amendment and Regulatory Exemptions for a Risk-Informed Approach to Address GSI-191 and Respond to GL 2004-02 (LDCN 19-0014), dated July 22, 2021 (ADAMS Accession No. ML21203A192)

In the letter identified as Reference 1, Union Electric Company (Ameren Missouri) submitted its proposed resolution for addressing GSI-191 and responding to Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors, for the Callaway plant. As submitted, the letter is a combined request 83 15 County Road 459 Steedman, MO 65077 AmerenMissouri.com

ULNRC-06692 October 7, 2021 Page 2 of 5 for regulatory exemptions and license amendment, as it also requests NRC approval of the risk-informed RoverD approach for addressing concerns about accident generated debris in the containment and its potential effects on sump performance and core cooling.

During the NRC staffs acceptance review ofthe Reference 1 submittal, the need for supplemental information was identified and required to be submitted in order for the staff to make an independent assessment regarding the acceptability of the proposed amendment request and exemptions. The needed information was submitted via the Ameren Missouri letter identified as Reference 2 above, which was the first supplement submitted for the proposed amendment and exemptions.

During subsequent, further review of the Reference 1 letter and its enclosures, the NRC requested corrections to resolve two identified issues. Specifically, the issues included the lack ofpage headers and footers on the marked-up and retyped Technical Specification pages provided in Enclosure 2 of the letter, and the inadvertent inclusion of proprietary threshold criterion values in both Enclosures 2 and 3 of the letter. In order to address these issues identified by the NRC staff, replacements for Enclosures 2 and 3 to the Reference 1 letter were submitted to the NRC under cover of the letter identified as Reference 3.

Subsequent to submittal of Reference 3, the NRC staff identified an additional threshold criterion value that had been identified as proprietary for some ofthe analyzed break scenarios but which appeared in replacement Enclosures 2 and 3 (as provided with the Reference 3 letter). Based on consultation with the vendor (i.e., the owner ofthe proprietary information), Ameren Missouri confirmed that the threshold criterion value is in fact proprietary information. Therefore, in order to address this issue, new replacements for Enclosures 2 and 3 to the Reference 1 letter are hereby provided as Enclosures 2 and 3, respectively, to this letter.

Finally, in light ofthe various changes made to Enclosures 2 and 3 ofthe original submittal (as a result of this supplement and the previous supplements), a summary of the cumulative changes made to Enclosures 2 and 3 of the original submittal is provided as Enclosure 1 to this letter.

This letter does not contain new commitments.

If there are any questions, please contact Mr. Tom Elwood at 3 14-225-1905.

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

Sincerely, Steve J. Meyer Manager, Regulatory Affairs Executed on:

//?/2 o/

ULNRC-06692 October 7, 2021 Page 3 of 5

Enclosures:

Cumulative Summary of Changes to Enclosure 2, License Amendment Request, and Enclosure 3, Callaway Methodology for a Risk-Informed Approach to Address Generic Letter 2004-02, of ULNRC-06526

- Replacement for Enclosure 2, License Amendment Request, of ULNRC-06526

- Replacement for Enclosure 3, Callaway Methodology for a Risk Informed Approach to Address Generic Letter 2004-02, of ULNRC-06526

ULNRC-06692 October 7, 2021 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. M. Chawla Project Manager, Callaway Plant Office ofNuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O8B1A Washington, DC 20555-0001

ULNRC-06692 October 7, 2021 Page 5 of 5 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 6500 West Freeway, Suite 400 FortWorth,TX 76116 (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:

F. M. Diya B. L. Cox F. J. Bianco S. P. Banker S. J. Meyer S. M. Lange T. B. Elwood R. J. Andreasen NSRB Secretary STARS Regulatory Affairs Mr. Jay Silberg (Pillsbury Winthrop Shaw Pittman LLP)

Mr. Dan Beck (Missouri Public Service Commission)

Ms. Katie Jo Wheeler (DNR)