ML21335A452

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Supplement to License Amendment Request for Adoption of Alternative Source Term and Revision of Technical Specifications
ML21335A452
Person / Time
Site: Callaway 
Issue date: 12/01/2021
From: Meyer S
Ameren Missouri, Union Electric Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML21335A451 List:
References
EPIP L-2021-LLA-0177, ULNRC-06696
Download: ML21335A452 (6)


Text

\\4 Ailieren Callaway Plant MISSOURI December 1, 2021 ULNRC-06696 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 SUPPLEMENT TO LICENSE AMENDMENT REQUEST FOR ADOPTION OF ALTERNATIVE SOURCE TERM AND REVISION OF TECHNICAL SPECIFICATIONS tEPID L-2021-LLA-0177)

References:

1.

Ameren Missouri letter ULNRC-06636, License Amendment Request for Adoption of Alternate Source Term and Revision of Technical Specifications, dated September 28, 2021 (ADAMS Accession No. ML21272A168) 2.

NRR e-mail capture,

Subject:

LIC-l 09 Acceptance Review (Unacceptable for Review with Opportunity to Supplement) - Callaway Plant, Unit 1

- License Amendment Request -

Callaway Plant, Unit 1 - Adoption of Alternate Source Term and Revision of TSs

- EPID L 2021-LLA-0177, dated November 4, 2021 (ADAMS Accession No. ML21308A069)

By letter dated September 28, 2021 (Reference 1), Ameren Missouri submitted a license amendment request (LAR) for adopting the alternative source term methodology addressed in 10 CFR 50.67.

Subsequent to submittal of the Reference 1 LAR, however, the need to identify information contained in Enclosure 1 of the LAR as security sensitive was re-evaluated, thus requiring a change to be made to the LAR. In addition, needed corrections and changes to the various enclosures provided with the LAR were identified. This supplement to the LAR is being submitted to address these changes. It also provides additional information requested pursuant to Reference 2 above, as further explained below.

As noted above, one aspect of the Reference 1 LAR that requires correction is that Enclosure 1 of the submittal, Evaluation of Changes, was unnecessarily identified as containing security sensitive information. From additional discussion and evaluation subsequent to the submittal, it was determined that none ofthe material contained in the noted enclosure must be identified as security sensitive. As a 83 15 county Road 159 Steecirnan, f1 65077 J\\.rrieren1\\Iissouri.corri

ULNRC-06696 December 1, 2021 Page 2 of 6 result, that information is now being provided, and specifically, it is included in Enclosure 1 to this LAR supplement, which is an updated version of Enclosure 1 provided in the Reference 1 LAR.

Consequently, Enclosure 1 is no longer requested to be withheld from public disclosure pursuant to 10 CFR 2.390. It should also be noted that typographical errors subsequently identified in the original have been corrected. Those changes are indicated by the use of revision bars in Enclosure 1 to this letter.

Because Enclosure 1 in the Reference 1 LAR was identified as containing information to be withheld from public disclosure, a redacted version of Enclosure 1 was provided as Enclosure 2 to the LAR.

Now that it has been determined that none of the provided information must considered security sensitive information (as described above), a redacted version of the enclosure is no longer needed. To reflect this change, Enclosure 2 to this LAR supplement is provided. Enclosure 2 corresponds to the originally provided Enclosure 2, but it only contains a single sentence stating that a separate non-proprietary version (ofthe information provided in Enclosure 1) is no longer needed.

As previously noted, several minor corrections were identified to be needed in other enclosures provided with Reference 1 LAR. These included errors in the placement of horizontal separator lines, incorrect page numbers, text missing from mark-up annotations, and inconsistencies between the Technical Specification (TS) marked-up and retyped pages. To address those errors, corrected copies of the previously submitted proposed TS change mark-ups, retyped TS pages, TS Bases change mark-ups (information only), and Final Safety Analysis Report (FSAR) change mark-ups (information only),

are provided in Enclosures 3 through 6, respectively, to this LAR supplement.

By e-mail dated November 4, 2021 (Reference 2), the NRC staff requested additional information that is needed to support acceptance ofthe requested license amendment for review. The requested information includes meteorological data and run specification inputs to, and outputs from, the software codes that were used to establish atmospheric relative concentration (x/Q) parameters for evaluating the consequences of postulated accidents, along with a clarification of the differences between the ARCON96 and PAVAN codes used by the NRC and the ARCON96-NAI and PAVAN NAT codes that were used to perform the Callaway Plant calculations.

The additional information requested by the NRC is provided in Enclosures 7 through 14 to this LAR supplement. Enclosure 7 contains the Callaway Plant hourly meteorological data (wind speed and direction at the 1 0-meter and 60-meter elevations, and delta temperature per 1 00 feet of elevation) for the years 2013 through 2016 in the format specified in Appendix A to Regulatory Guide 1.23, Rev. 1. contains the Callaway Plant hourly meteorological data (wind speed and direction at the 1 0-meter and 60-meter elevations, and atmospheric stability class) for the years 2013 through 2016 in the input format used by ARCON96-NAI. Enclosure 9 contains the run specifications for the ARCON96-NAI runs that were performed for each of the release point I receptor pairs that are described in Table 3-26 ofEnclosure 1. Enclosure 10 contains the output summary logs from the ARCON96-NAI runs, along with the cumulative frequency distribution results provided in Enclosure 1 1. Enclosure 12 contains PAVAN-NAI meteorological data input in the form of ajoint frequency distribution table, along with run specifications for Reactor Building (RB) and for Refueling Water Storage Tank (RWST) leakage releases evaluated at the Exclusion Area Boundary (EAB) and Low Population Zone (LPZ) Boundary. The PAVAN-NAI results are provided in Enclosure 13.

ULNRC-06696 December 1, 2021 Page 3 of 6 A summary ofthe differences between ARCON96 and ARCON96-NAI, and between PAVAN and PAVAN-NAI, is provided in Enclosure 14.

The corrections to previously submitted information and the supplemental information provided in the enclosures to this letter have no impact on the changes requested and described in the LAR. As such, they do not change the No Significant Hazards Consideration conclusions reached in the LAR, nor do they change the conclusion regarding no need for an environmental assessment based on the categorical exclusion provisions of 10 CFR 51.22.

This letter does not contain new commitments.

Ifthere are any questions, please contact Mr. Tom Elwood at 314-225-1905.

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

Sincerely,

/2; Steve J. Meyer Manager, Regulatory Affairs Executed on: / 2/

1

ULNRC-06696 December 1, 2021 Page 4 of 6

Enclosures:

1.

Full Scope Implementation of Alternative Source Term - Evaluation of Proposed Changes 2.

Full Scope Implementation of Alternative Source Term - Evaluation of Proposed Changes 3.

Proposed Technical Specification Changes (Mark-up) 4.

Retyped Technical Specification Pages 5.

Proposed Technical Specification Bases Changes (Mark-up for Information Only) 6.

Proposed Final Safety Analysis Report Changes (Mark-up for Information Only) 7.

Callaway Plant Hourly Meteorological Data from 2013 through 201 6 in Regulatory Guide 1.23, Rev. 1, Appendix A Format 8.

Callaway Plant Hourly Meteorological Data from 2013 through 201 6 in ARCON96-NAI Input Format 9.

ARCON96-NAI Input Run Specifications 1 0. ARCON96-NAI Output Summary Logs 1 1. ARCON96-NAI Output Cumulative Frequency Distribution Results

12. PAVAN-NAI Input Meteorological Data and Run Specifications for Reactor Building and Refueling Water Storage Tank Releases Evaluated at Exclusion Area Boundary and Low Population Zone Boundary 13. PAVAN-NAI Output for Reactor Building and Refueling Water Storage Tank Releases Evaluated at Exclusion Area Boundary and Low Population Zone Boundary
14. Summary ofDifferences Between ARCON96 and ARCON96-NAI and Between PAVAN and PAVAN-NAI Codes

ULNRC-06696 December 1, 2021 Page 5 of 6 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-06696 December 1, 2021 Page 6 of 6 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 M. A. McLachlan K. A. Mills B. L. Jungmann E. C. Olson S. J. Meyer T. B. Elwood B. D. Richardson NSRB Secretary STARS Regulatory Affairs Mr. Jay Silberg (Pillsbury Winthrop Shaw Pittman LLP)