ML21294A394

Request for License Amendment to Revise Technical Specifications to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4B, and TSTF-439, Revision 2, Eliminate Second .

ML21294A394
Person / Time
Site:	Callaway
Issue date:	10/21/2021
From:	Banker S Ameren Missouri, Union Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML21294A393	List: ML21294A394 ML21294A395 ML21294A396 ML21294A397 ML21294A398 ML21294A399 ML21294A400 ML21294A401 ML21294A402 ML21294A403 ML21294A404 ML21294A405 ML21294A406 ML21294A407 ML21294A408 ML21294A409 ML21294A410 ML21294A411 ULNRC-06688, Enclosure 12 - Risk Management Action Examples
References
ULNRC-06688
Download: ML21294A394 (5)

Text

, iimeren Callaway Plant MISSOURI October2l,2021 ULNRC-06628 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 REQUEST FOR LICENSE AMENDMENT TO REVISE TECUNICAL SPECIFICATIONS TO ADOPT TSTF-505, REVISION 2, PROVIDE RISK-INFORMED EXTENDED COMPLETION TIMES - RITSTF INITIATIVE 4B, AND TSTF-439, REVISION 2, ELIMINATE SECOND COMPLETION TIMES LIMITING TIME FROM DISCOVERY OF FAILURE TO MEET AN LCO (LDCN 20-0007)

Pursuant to 1 0 CFR 50.90, Application for amendment of license or construction permit, Ameren Missouri (Union Electric Company) herewith transmits an application for amendment to Renewed Facility Operating License Number NPF-30 for the Callaway Plant. The requested amendment would revise applicable Technical Specifications to implement risk-informed Completion Times and the Risk-Informed Completion Time (RICT) Program in accordance with the guidance of TSTF-505, Revision 2. In support of the adoption of TSTF-505, TSTF-439, Revision 2, which involves the elimination of second Completion Times currently specified in the Technical Specifications, will also be adopted. In addition, the requested amendment would remove obsolete one-time Completion Times contained in the applicable Technical Specifications.

Specifically, the proposed amendment would modify the Technical Specification requirements related to Completion Times (CTs) for specific Required Actions to provide the option to calculate a longer, risk-informed CT (RICT). A new program, the Risk-Informed Completion Time Program, is to be added to TS Section 5, Administrative Controls. The methodology for using the RICT Program is described in NEI 06-09-A, Risk Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines, Revision 0, which was approved by the NRC on May 17, 2007. Adherence to NEI-06-09-A is required by the RICT Program. The proposed amendment is consistent with NRC-approved TSTF-505, Revision 2, Provide Risk Informed Extended Completion Times

- RITSTF Initiative 4b. To support the adoption of TSTF-505, TSTF-439, Revision 2, is also adopted. TSTF-439 deletes the second Completion Times from specific Required Actions, revises the Improved Standard Technical Specification Example 1.3-3 to remove

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ULNRC-06688 October 21, 2021 Page 2 of 5 the second Completion Times, and revises the discussion in that Example to state that alternating between Conditions in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO is inconsistent with the basis ofthe Completion Times and is inappropriate.

Administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO will be implemented.

Essential information is provided in the Attachments and Enclosures to this letter. Attachments 1 through 6 provide the Description and Assessment of the proposed changes, a mark-up of the proposed Technical Specifications, the retyped Technical Specifications, a mark-up of the proposed Technical Specification Bases, a cross-reference between the TSTf-505 changes and Callaway Technical Specifications, and a Description and Assessment of proposed changes resulting from adoption of TSTf-439, respectively, in support ofthis amendment request. The mark-up ofthe proposed Technical Specification Bases is provided for information only. (Technical Specification Bases changes will be processed under the program for updates per TS 5.5. 14, Technical Specifications Bases Control Program, at the time this amendment is implemented.) The enclosures provide supporting technical information, as described in Attachment 1.

As described in Attachment 1, it has been determined that this license amendment application does not involve a significant hazard consideration as evaluated per 1 0 CFR 50.92, Issuance of amendment.

It has also been determined that pursuant to 10 CFR 5 1.22, Criterion categorical exclusion or otherwise not requiring environmental review, Section (b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

This submittal does not contain new commitments.

The Callaway Plant Onsite Review Committee has reviewed and approved the proposed changes and has approved the submittal of this amendment application.

Ameren Missouri requests approval of the requested license amendment within 12 months of the date of receipt of this letter. Ameren Missouri further requests that the license amendment be made effective upon NRC issuance, to be implemented within 1 80 days from the date of issuance.

In accordance with 10 CFR 50.91 Notice for public comment; State consultation, Section (b)(1), a copy ofthis amendment application is being provided to the designated Missouri State official.

Ifthere are any questions, please contact Tom Elwood at 3 14-225-1905.

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

Sincerely, 1cFsL Stephanie P. Banker Vice President, Nuclear Engineering and Support Executed on:

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ULNRC-06688 October 21, 2021 Page 3 of 5 Attachments:

1.

Description and Assessment 2.

Proposed Technical Specification Changes (Mark-up) 3.

Revised Technical Specification Pages 4.

Proposed Changes To Technical Specification Bases Changes (Mark-Up) Pages (For Information) 5.

Cross-Reference of T$TF-505 and Callaway Technical Specifications 6.

Description and Assessment Specific to TSTF-439

Enclosures:

1.

List of Revised Required Actions to Corresponding PRA Functions 2.

Information Supporting Consistency with Regulatory Guide 1.200, Revision 2 3.

Information Supporting Technical Adequacy of PRA Models Without PRA Standards Endorsed by Regulatory Guide 1.200, Revision 2 4.

Information Supporting Justification of Excluding Sources of Risk Not Addressed by the PRA Models 5.

Baseline Core Damage Frequency (CDF) and Large Early Release Frequency (LERF) 6.

Justification ofApplication ofAt-Power PRA Models to Shutdown Modes 7.

PRA Model Update Process 8.

Attributes of the Real Time Risk Model 9.

Key Assumptions and Sources of Uncertainty 1 0.

Program Implementation 1 1.

Monitoring Program 12.

Risk Management Action Examples

ULNRC-06688 October 21, 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. Mahesh Chawla Project Manager, Callaway Plant Office ofNuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 081A Washington, DC 20555-0001

ULNRC-06688 October 21, 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 Tech Spec ULNRC Distribution:

F. M. Diya B. L. Cox S. P. Banker F. J. Bianco D. Farnsworth S. J. Meyer T. B. Elwood J. W. Hiller 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)