ML24362A040
| ML24362A040 | |
| Person / Time | |
|---|---|
| Site: | Callaway  (NPF-030) |
| Issue date: | 02/13/2025 |
| From: | Mahesh Chawla Plant Licensing Branch IV |
| To: | Diya F Callaway Energy Center |
| Chawla M | |
| References | |
| EPID L-2024-LLA-0076 | |
| Download: ML24362A040 (1) | |
Text
February 13, 2025 Fadi Diya Senior Vice President and Chief Nuclear Officer Ameren Missouri Callaway Energy Center 8315 County Road 459 Steedman, MO 65077
SUBJECT:
CALLAWAY PLANT, UNIT NO. 1 - ISSUANCE OF AMENDMENT NO. 238 RE: REVISION TO TECHNICAL SPECIFICATIONS TO ADOPT TSTF-569, REVISION 2, REVISE RESPONSE TIME TESTING DEFINITION (EPID L-2024-LLA-0076)
Dear Fadi Diya:
The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No.238 to Renewed Facility Operating License No. NPF-30 for the Callaway Plant, Unit No. 1 (Callaway). The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated June 6, 2024.
The amendment revises the Callaway technical specifications (TSs) to adopt Technical Specifications Task Force (TSTF) Traveler TSTF-569, Revision 2, Revise Response Time Testing Definition. The amendment revises the TS definitions in Callaway TS section 1.1 for ENGINEERED SAFETY FEATURE (ESF) RESPONSE TIME and REACTOR TRIP SYSTEM (RTS) RESPONSE TIME that are referenced in surveillance requirements, hereafter, referred to as response time testing.
A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commissions monthly Federal Register notice.
Sincerely,
/RA/
Mahesh L. Chawla, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483
Enclosures:
- 1. Amendment No. 238 to NPF-30
- 2. Safety Evaluation cc: Listserv
UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT NO. 1 DOCKET NO. 50-483 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 238 License No. NPF-30
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Union Electric Company (UE, the licensee),
dated June 6, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
- 2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-30 is hereby amended to read as follows:
(2)
Technical Specifications and Environmental Protection Plan*
The Technical Specifications contained in Appendix A, as revised through Amendment No. 238 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 3.
This amendment is effective as of its date of issuance and shall be implemented within 90 days of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Tony T. Nakanishi, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to Renewed Facility Operating License No. NPF-30 and the Technical Specifications Date of Issuance: February 13, 2025 Tony T.
Nakanishi Digitally signed by Tony T. Nakanishi Date: 2025.02.13 08:57:36 -05'00'
ATTACHMENT TO LICENSE AMENDMENT NO. 238 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-30 CALLAWAY PLANT, UNIT NO. 1 DOCKET NO. 50-483 Replace the following pages of Renewed Facility Operating License No. NPF-30 and the Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Renewed Facility Operating License REMOVE INSERT Technical Specifications REMOVE INSERT 1.1-3 1.1-3 1.1-5 1.1-5
Renewed License No. NPF-30 Amendment No. 238 (3)
UE, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4)
UE, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source of special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5)
UE, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
C.
This renewed license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1)
Maximum Power Level UE is authorized to operate the facility at reactor core power levels not in excess of 3565 megawatts thermal (100% power) in accordance with the conditions specified herein.
(2)
Technical Specifications and Environmental Protection Plan*
The Technical Specifications contained in Appendix A, as revised through Amendment No. 238 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
(3)
Environmental Qualification (Section 3.11, SSER #3)**
Deleted per Amendment No. 169.
Amendments 133, 134, & 135 were effective as of April 30, 2000 however these amendments were implemented on April 1, 2000.
The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 238 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-30 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT NO. 1 DOCKET NO. 50-483
1.0 INTRODUCTION
By application dated June 6, 2024 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML24158A521), Union Electric Company, doing business as Ameren Missouri (the licensee), submitted a license amendment request (LAR) for Callaway Plant, Unit No. 1 (Callaway). The amendment would revise technical specification (TS) definitions in Callaway TS section 1.1 for ENGINEERED SAFETY FEATURE (ESF)
RESPONSE TIME and REACTOR TRIP SYSTEM (RTS) RESPONSE TIME that are referenced in surveillance requirements (SRs), hereafter, referred to as response time testing (RTT).
The proposed changes are based on Technical Specifications Task Force (TSTF) Traveler TSTF-569, Revision 2, Revise Response Time Testing Definition, dated June 25, 2019 (ML19176A034). The U.S. Nuclear Regulatory Commission (NRC or the Commission) issued a final safety evaluation (SE) approving TSTF-569, Revision 2, on August 14, 2019 (ML19176A191). The description of the generic changes and their justification are contained in these two documents.
2.0 REGULATORY EVALUATION
2.1 Description of Response Time Testing The RTS for Callaway initiates a unit shutdown, based on the values of selected unit parameters, to protect against violating the core fuel design limits and the reactor coolant system (RCS) pressure boundary during anticipated operational occurrences and to assist the engineering safety feature actuation system (ESFAS) in mitigating accidents. The ESFAS initiates necessary safety systems, based on the values of selected unit parameters, to protect against violating core design limits and the RCS pressure boundary and to mitigate accidents.
The RTT verifies that the individual channel or train actuation response times are less than or equal to the maximum values assumed in the accident analyses. The RTT acceptance criteria
are under licensee control. Individual component response times are not modeled in the accident analyses. The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the trip setpoint value at the sensor to the point at which the equipment reaches the required functional state (e.g., control and shutdown rods fully inserted in the reactor core).
2.2 Proposed Changes to the Technical Specifications Callaway Limiting Condition for Operation (LCO) 3.3.2 requires the ESFAS instrumentation for each function in TS table 3.3.2-1, Engineered Safety Feature Actuation System Instrumentation, to be Operable. To assure the LCO is met, SR 3.3.2.10 requires the licensee to verify that ESF response times are within limits. Similarly, Callaway LCO 3.3.1 requires the RTS instrumentation for each function in TS table 3.3.1-1, Reactor Trip System Instrumentation, to be Operable, and SR 3.3.1.16 requires the licensee to verify that RTS response times are within limits. The licensee proposed to add a statement to section 1.1 of the TS definitions for ENGINEERED SAFETY FEATURE (ESF) RESPONSE TIME and REACTOR TRIP SYSTEM (RTS) RESPONSE TIME which states the components have been evaluated in accordance with an NRC approved methodology.
In its application, the licensee stated that it requests adoption of NRC-approved TSTF-569, Revision 2. The only revision of TSTF-569 that is NRC approved is Revision 2. As described in section 1, Summary Description, of Revision 2 of TSTF-569:
The proposed change revises the definitions to eliminate the requirement for prior NRC review and approval of the response time verification of similar components, while retaining the requirement for the verification to be performed using the methodology contained in Attachment 1, titled, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only) Response Time Testing. The proposed change will permit licensees to verify the response time of similar component types using the methodology contained in Attachment 1, without obtaining prior NRC approval for each component.
Accordingly, as shown in the LAR, the request would add an additional in lieu of measurement alternative to measuring ESF response time and RTS response time. The additional alternative for ESF Response Time would be [i]n lieu of measurement, response time may be verified for selected components provided... the components have been evaluated in accordance with an NRC approved methodology. Similarly, for RTS Response Time, [i]n lieu of measurement, response time may be verified for selected components provided that... the components have been evaluated in accordance with an NRC approved methodology.
The application stated that the licensee concluded that the justifications presented in TSTF-569 and the SE prepared by the NRC staff are applicable to Callaway and provide the justification for the amendment request. The application identified the requested variations (e.g., identifying the site-specific TS numbers).
2.3 Applicable Regulatory Requirements and Guidance Under Title 10 of the Code of Federal Regulations (10 CFR) Section 50.90, Application for amendment of license, construction permit, or early site permit, whenever a holder of a license
wishes to amend the license, including TSs in the license, an application for amendment must be filed, fully describing the changes desired. Under 10 CFR 50.92(a), determinations on whether to grant an applied-for license amendment are to be guided by the considerations that govern the issuance of initial licenses to the extent applicable and appropriate. Both the common standards for licenses in 10 CFR 50.40(a), and those specifically for issuance of operating licenses in 10 CFR 50.57(a)(3), provide that there must be reasonable assurance that the activities at issue will not endanger the health and safety of the public, and that the applicant will comply with the Commission's regulations.
The licensee's request involves adding an option used to satisfy SRs. As described in 10 CFR 50.36(c)(3):
Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.
3.0 TECHNICAL EVALUATION
The NRC staff reviewed the request by comparing the licensees proposal against the changes described in TSTF-569, Revision 2. TSTF-569 is designed to make changes to NUREG-1431, Revision 5.0, Standard Technical Specifications, Westinghouse Plants, September 2021, Volume 1, Specifications (ML21259A155), and Volume 2, Bases (ML21259A159). The staff compared the TSs assumed in TSTF-569 with the current TSs for Callaway. The staff did not identify any material differences in the relevant TSs.
In the NRC safety evaluation for TSTF-569, the NRC staff concluded that the proposed change to TS section 1.1 would eliminate required direct measurement RTT for selected pressure transmitter/sensor and protection channel components but does not eliminate required surveillance testing for the entirety of an instrument channel or the system as a whole (e.g.,
RTS). Therefore, the NRC staff found that the proposed change is consistent with the surveillance testing requirements of 10 CFR 50.36.
The NRC staff confirmed that the proposed change in this LAR has no effect on the design, fabrication, use, or methods of testing of the instrumentation and will not affect the ability of the instrumentation to perform the functions assumed in the safety analysis. Therefore, compliance with General Design Criteria (GDC) 13 and GDC 21 or the equivalent plant-specific criteria is not affected.
The NRC staff finds that the methodology contained in TSTF-569, Revision 2, attachment 1, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only), provides a consistent, clear, and concise framework for determining that replacement components will operate at a level equivalent to that of the components being replaced. As such, using that methodology will assure that the necessary quality of the components is maintained and that the LCOs will be met. Accordingly, approving the incorporation of that methodology into the licensing basis, amending the TS to allow usage of the approved methodology, and approving the LAR to use the methodology in TSTF-569, Revision 2, results in TSs that continue to meet the requirements of 10 CFR 50.36(c)(3). These requirements will be continued to be met by performing SR 3.3.1.16 while using the new [i]n lieu of option and will assure that associated aspects of LCO 3.3.1 and 3.3.2 will be met.
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the Missouri State official was notified of the proposed issuance of the amendment on December 23, 2024. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration published in Federal Register on September 3, 2024 (89 FR71437), and there has been no public comment on such finding. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: Tarico Sweat, NRR Date: February 13, 2025
- concurrence via email OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DSS/STSB/BC*
NAME MChawla PBlechman SMehta DATE 12/26/2024 1/28/2025 12/16/2024 OFFICE NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME TNakanishi MChawla DATE 2/13/2025 2/13/2025