ULNRC-06766, Correction of Text Contained in Enclosures Provided with Supplements 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)

Correction of Text Contained in Enclosures Provided with Supplements 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)

ML22251A343
Person / Time
Site:	Callaway
Issue date:	09/08/2022
From:	Witt T Ameren Missouri, Union Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML22251A342	List: ML22251A344 ML22251A345 ULNRC-06766, Correction of Text Contained in Enclosures Provided with Supplements 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)
References
EPID L-2021-LLA-0059, EPID L-2021-LLE-0021, ULNRC-06766
Download: ML22251A343 (6)

Text

1Aiiieren MISSOURI Callaway Plant September 8, 2022 ULNRC-06766 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 CORRECTION OF TEXT CONTAINED IN ENCLOSURES PROVIDED WITH SUPPLEMENTS 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)

(EPID L-2021-LLA-0059 AND EPID L-2021-LLE-0021)

On March 3 1 2021 and per Reference 1 identified in the list of references on page 5 of this letter, Ameren Missouri (Union Electric Company) submitted a license amendment request (LAR) to the NRC, in combination with a request for regulatory exemptions, to adopt a risk-informed approach for resolving GSI-191 and responding to Generic Letter (GL) 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors, for the Callaway plant.

The combined submittal requests NRC approval ofthe risk-informed RoverD approach for addressing concerns about postulated, accident-generated debris in the containment and its potential effects on containment sump performance and core cooling in the event ofpipe break/loss-of-coolant accident (LOCA) in the containment. This approach shows that the risk associated with debris from pipe breaks that generate quantities of debris not bounded by plant-specific prototypical testing is very small (in accordance with the acceptance criteria of RG 1 1 74). On the deterministic side, it shows that the effects of debris bounded by the plant-specific testing are acceptable or mitigated in accordance with NRC-accepted methodology for resolution of GL 2004-02.

As part ofthe requested changes, new Callaway Technical Specification (TS) 3.6.8, Containment Sumps, based on Technical Specification Task Force (TSTF) traveler TSTF-567, Add Containment 83 1 5 (tnty load 159 : Steedrrian, 1\/1J 65077 : A.iiiereri1vIissouri.con

ULNRC-06766 September 8, 2022 Page 2 of 6

$ump TS to Address G$I-1 91 Issues, (Rev. 1) is proposed such that it would be dedicated to the containment sumps in lieu ofhaving the sumps addressed only as a support system behind the Emergency Core Cooling System and Containment Spray System Technical Specifications (as is the case per the current Callaway Technical Specifications). The proposed Limiting Condition for Operation (LCO) for TS 3 .6.8 would require both trains of containment sumps to be Operable such that Operability would be understood to include the condition that containment accident generated and transported debris, as analyzed based on materials existing in the containment, is within analyzed limits. Proposed TS 3.6.8 would include Conditions and Required Actions that apply when the LCO is not met. Condition A would specifically address the condition of having one or more containment sumps inoperable due to containment accident generated and transported debris exceeding the analyzed limits. Condition B addresses having one or more containment sumps inoperable for reasons other than Condition A, such as when there is a physical deficiency (e.g., a sizable hole) in one or more of the sump strainers.

Subsequent to submittal of the Reference 1 LAR, a number ofletters/supplements were submitted in support of the LAR and/or in response to NRC correspondence regarding the LAR. Of the various letters/supplements, only two are of concern to this submittal, and they are identified as References 2 and 3 in the list ofreferences on page 5. Information provided in the letter identified as Reference 2 required correcting/revising information and/or certain pages that had been previously provided in Enclosure 2 ofthe Reference 1 LAR. The affected pages included, in particular, the marked-up and clean (retyped) TS pages provided to indicate the TS changes being proposed by the LAR. Since those pages were being revised, new/replacement pages were provided in a new Enclosure 2 to the Reference 2 letter, such that new Reference 2 Enclosure 2 was identified as a replacement for the previously provided Reference 1 Enclosure 2. The Reference 2 letter also addressed the need to correct a proprietary information concern, and that contributed to the decision to entirely replace .

After submittal ofthe Reference 2 letter, an additional proprietary information concern was identified. Resolution of that concern also affected pages/information contained in previously provided Enclosure 2, such that it was again determined that Enclosure 2 should be replaced. A new , replacing the two previously provided enclosures, was thus provided per the letter identified as Reference 3 The new Enclosure 2 again included marked-up and clean TS pages reflecting the proposed TS changes.

Recently, from the NRC staff s review of the Reference 1 LAR and its supplements, an inconsistency was identified in regard to the marked-up and clean TS pages provided within Enclosure 2 of the LAR and noted supplements. The inconsistency concerns the wording proposed/intended for Condition A ofnew TS 3 .6.8, which reads as follows, based on what was provided in Enclosure 2 of the Reference 1 LAR:

A. One or more containment sumps inoperable due to containment accident generated and transported debris exceeding the analyzed limits.

By comparing the above wording to what was included within the versions of Enclosure 2 provided per References 2 and 3, it has been confirmed that the phrase exceeding the analyzed limits was omitted (but should have been included) in those versions.

ULNRC-06766 September 8, 2022 Page 3 of 6 Besides the above discrepancy regarding Condition A, a discrepancy regarding Condition B was also identified within Enclosure 2 ofthe same LAR supplements (References 2 and 3). In this instance, an extraneous 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> was inadvertently placed in the upper portion of the Completion Time column for Required Action B. 1 for which 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> was already appropriately specified in the lower portion of the Completion Time column for this Required Action. This extraneous text was not included (and not intended to be included) in proposed TS 3.6.8 as provided in the original (Reference 1) LAR.

Since the T$ 3 .6. 8 wording provided in Enclosure 2 of the Reference 1 LAR is what was intended for each ofthe above cases (as based on the wording prescribed by TSTF-567), and since Enclosure 2 was subsequently replaced by the Reference 2 letter and then again by the Reference 3 letter, an updated/corrected version ofthe TS 3.6.8 wording needs to be provided, thereby affirming the intended Condition A wording. The purpose of this letter, therefore, is to provide the corrected wording, which is herewith provided in the attachments to this letter. As it is not necessary to entirely replace Enclosure 2, in this case, the attached TS 3 .6.8 pages are provided as replacement pages for what was previously provided in Enclosure 2 ofthe Reference 2 and Reference 3 letters.

Accordingly, marked-up TS 3.6.8 pages are provided in Attachment 1, and clean retyped pages for TS 3 .6.8 are provided in Attachment 2. The Condition A and Condition B (Required Action B. 1 Completion Time) wording in the attached is identical to what was provided in the Reference 1 LAR.

Since this correction letter affirms the intended TS changes and serves to ensure consistency between the LAR and its supplements, there are no changes to the intended TS changes as proposed.

Consequently, there is no change to the No Significant Hazards Consideration conclusions reached in the LAR, nor is there any change to 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 of perjury that the foregoing is true and correct.

Sincerely, 27 Todd A. Witt Manager, Regulatory Affairs Executed on: 7- -

Attachments:

1. Marked-up TS pages for TS 3.6.8

2. Retyped TS pages for TS 3.6.8

ULNRC-06766 September 8, 2022 Page 4 of 6

References:

1 . Ameren Missouri letter ULNRC-06526, Request for License Amendment and Regulatory Exemptions for a Risk-Informed Approach to Address GSI 1 9 1 and Respond to GL 2004-02 (LDCN 1 9-00 1 4), dated March 3 1 2021 (ADAMS Accession No. ML21090A184)

2. 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, 202 1 (ADAMS Accession No. ML21203A192) 3 . Ameren Missouri Letter ULNRC-06692, Third Supplement to Request for License Amendment and Regulatory Exemptions for a Risk-Informed Approach to Address GSI- 1 9 1 and Respond to GL 2004-02 (LDCN 19-0014), dated October 7, 2021 (ADAMS Accession No. ML21280A379)

ULNRC-06766 September 8, 2022 Page 5 of 6 cc: Mr. Scott A. Morris Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1 600 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 of Nuclear Reactor Regulation U. S Nuclear Regulatory Commission Mail Stop O8B1A Washington, DC 20555-0001

ULNRC-06766 September 8, 2022 Page 6 of 6 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 6500 West Freeway, Suite 400 Fort Worth, 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 T. A. Witt T. B. Elwood NSRB Secretary STARS Regulatory Affairs Mr. Jay Silberg (Pillsbury Winthrop Shaw Pittman LLP)

Mr. Aaron Schmidt (DNR)