ULNRC-05521, Request for Extension of Corrective Actions Completion Date for NRC Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors.

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Request for Extension of Corrective Actions Completion Date for NRC Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors.
ML081840061
Person / Time
Site: Callaway Ameren icon.png
Issue date: 06/24/2008
From: Graessle L
AmerenUE, Union Electric Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-04-002, TAC MC4671, ULNRC-05521
Download: ML081840061 (10)
v • d • e


Text

AmerenUE P0 Box 620 Callaway Plant Fulton, MO 65251 June 24, 2008 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop PI-137 Washington, DC 20555-0001 ULNRC-05521 Aer Ladies and Gentlemen:

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

FACILITY OPERATING LICENSE NPF-30 REQUEST FOR EXTENSION OF CORRECTIVE ACTIONS COMPLETION DATE FOR NRC GENERIC LETTER 2004-02, "POTENTIAL IMPACT OF DEBRIS BLOCKAGE ON EMERGENCY RECIRCULATION DURING DESIGN BASIS ACCIDENTS AT PRESSURIZED-WATER REACTORS" (TAC NO. MC4671)

References:

1. AmerenUE Letter ULNRC-05461, dated December 10, 2007.
2. AmerenUE Letter ULNRC-05465, dated December 20, 2007.
3. AmerenUE Letter ULNRC-05481, dated February 29, 2008
4. AmerenUE Letter ULNRC-05235, dated December 12, 2005
5. Letter dated November 27, 2007 from USNRC to A.

Pietrangelo, Nuclear Energy Institute By letters dated December 10 and 20, 2007 (Reference 1 and 2), Union Electric Company (AmerenUE) committed to completing all corrective actions associated with Generic Letter (GL) 2004-02 prior to or on June 30, 2008. Although plant-specific tests at the vendor testing facility were completed, the vendor documentation necessary for AmerenUE to complete subsequent analyses and evaluations has been delayed. Additionally, AmerenUE will implement corrective actions for the current containment sump strainer during the fall 2008 outage that will regain margin due to a vendor identified error with the containment sump clean strainer head loss.

Consequently, and as further explained in this letter, AmerenUE is requesting an extension to delay the completion of remaining corrective actions until December 15, 2008.

a subsidiary of Ameren Corporation

ULNRC-05521 June 24, 2008 Page 2 AmerenUE has successfully completed testing performed at a special test facility at Alden Research Laboratory. The tests were performed based on an established test protocol with input from the NRC Staff. There have been a number of delays in completion of the test report and subsequent analysis due to the number of tests being performed for other licensees and competing resources for completion. AmerenUE was present during testing that was performed at the test facility in January, 2008 for Callaway Plant, which demonstrated that adequate net positive suction head (NPSH) margin would be maintained. In addition, the testing confirmed the effectiveness of the new strainer design and its resistance to blockage from the transported debris.

The increase in head loss due to chemical effects was minimal. Bypass testing was also performed which is being evaluated in the downstream effects analysis.

Therefore, corrective actions are nearly complete.

In SECY-06-0078, dated March 31, 2006, the NRC staff recognized that licensees may encounter situations that could delay the implementation of corrective actions as committed in response to GL 2004-02. SECY-06-0078 describes that proposed extensions to permit completion of corrective actions after December 31, 2007 may be acceptable if, based on the licensee's request, the staff determines that "the licensee has a plant-specific technical/experimental plan with milestones and schedule to address outstanding technical issues with enough margin to account for uncertainties" and that "the licensee identifies mitigative measures to be put in place prior to December 31, 2007, and adequately describes how these mitigative measures will minimize the risk of degraded ECCS and CSS functions during the extension period."

AmerenUE has the following plant-specific technical/experimental plan with milestones and schedule to address outstanding technical issues with enough margin to account for uncertainties:

Additional plant-specific tests that support assumptions and corresponding conclusions contained in the GL 2004-02 evaluations for Callaway Plant were completed in January, 2008. The testing included strainer performance testing, head loss testing, and chemical effects/debris bypass testing that included debris transport. Although plant-specific tests at the vendor testing facility were completed, the vendor documentation necessary for AmerenUE to complete subsequent analyses and evaluations has been delayed.

AmerenUE expects receipt of the final test report from the vendor by mid-August 2008.

Following receipt of the final test report from the vendor, numerous additional actions are required by AmerenUE to complete formal verification of design inputs, assumptions and conclusions of AmerenUE calculations / evaluations conducted in response to issues identified in GL 2004-02. These activities include assessing the impact of the test results on strainer NPSH calculations, strainer bypass sampling impact on downstream effects analyses (in-vessel and ex-vessel), as well as potential impact on other Generic Letter 2004-02 corrective action evaluations. These activities also include compliance with

ULNRC-05521 June 24, 2008 Page 3 10 CFR 50, Appendix B requirements for design control, document control and quality assurance records. These activities will be complete by December 15, 2008.

The following mitigative measures were put in place prior to December 31, 2007 and continue to be in place:

" New containment emergency recirculation sump strainers were installed within each sump during Callaway's spring 2007 refueling outage. The new strainers have nominal 0.045 inch openings and a total surface area of 6623 square feet.

" Installation of debris barriers in the "A" and "D" loop entrances was also completed during the spring 2007 fueling outage. The debris barriers are designed to reduce the quantity of debris at the containment sumps following a high energy line break (HELB) inside the bioshield. The barriers will diminish the amount of debris that can take the shortest path to the containment sumps, thereby increasing the probability that debris will be held up in low flow areas or deposited on components within the post- HELB flood plain. This debris hold-up will decrease the quantity of debris at the containment sumps, thus minimizing blockage and maximizing NPSH available to the Emergency Core Cooling System (ECCS) and Containment Spray (CS) pumps. Similar barriers are also installed at secondary shield wall penetrations near the sumps and below the post accident water level.

  • In August 2003, Callaway increased the minimum Refueling Water Storage Tank (RWST) level to a nominal level of 96.3%. This administratively controlled RWST level assures capacity above the Technical Specification 3.5.4.2 minimum required volume of 394,000 gallons (93.6%), and is also above the current low alarm level of 95.3% (400,674 gallons). This change was performed as a compensatory measure for implementation of NRC Bulletin 2003-01 as described in AmerenUE's response to the bulletin (Ref.

4).

" Implementation of the following Westinghouse Owners Group candidate operator actions was completed at Callaway in April 2005 as part of the overall Emergency Operating Procedure (EOP's) upgrade effort. Additional details are provided in Callaway's response to Bulletin 2003-01.

a. COA 1A - Operator action to secure one spray pump before recirculation alignment
b. COA 5 - Refill of RWST
c. COA 8 - Provide Guidance on Symptoms and Identification of CTMT sump blockage

ULNRC-05521 June 24, 2008 Page 4

d. COA 9 - Develop contingency actions to be taken in response to CTMT sump blockage Implementation is complete for Callaway plant procedures and processes described in Reference 1 to support the GL 2004-02 hardware modifications and revised operating practices, as well as to support the assumptions, initial conditions and conclusions of the expected final version of GL 2004-02 related evaluations, when the evaluations are completed and documented.

Administrative procedures and processes include implementation of changes to programmatic controls for design change processes and containment material controls, as well as implementation of a containment coatings assessment program and a containment latent debris assessment program.

In light of AmerenUE's request for extension of the remaining corrective actions for GL 2004-02, this letter transmits changes to previously identified regulatory commitments (as contained in Reference 1). Consistent with guidance in Reference 5 for licensees with approved extensions, AmerenUE will submit an update to the supplemental response to GL 2004-02 describing the results of the testing and the implementation of calculations, evaluations and other changes described in Reference 1 within 90 days of completion of all actions needed to address GL 2004-02. The commitment changes are being submitted in accordance with guidance provided by industry document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," as endorsed in Regulatory Issues Summary 00-017, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff." Enclosure I lists the AmerenUE commitments contained in this letter and which supersede those previously contained in Reference 1.

Please contact Tom Elwood, Supervising Engineer, Regulatory Affairs and Licensing at 573-676-6479 for any questions you may have regarding this request.

I declare under penalty of perjury that the foregoing is true and correct Sincerely, Executed on: June 24, 2008 Luke H. Graessle Manager, Regulatory Affairs BFH/nls Enclosure

ULNRC-05521 June 24, 2008 Page 5 cc: Mr. Elmo E. Collins, Jr.

Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Mohan C. Thadani (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O-8G14 Washington, DC 20555-2738

ULNRC-05521 June 24, 2008 Page 6 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4200 South Hulen, Suite 630 Fort Worth, TX 76109 (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:

C. D. Naslund A. C. Heflin T. E. Herrmann G. A. Hughes S. M. Maglio T. B. Elwood L. H. Graessle S. L. Gallagher L. M. Belsky (NSRB)

Mr. Ron Reynolds, Director (SEMA)

Mr. Edward Gray, Senior REP Planner (SEMA)

Mr. John Campbell, REP Planner (SEMA)

Ms. Diane M. Hooper (WCNOC)

Mr. Dennis Buschbaum (TXU)

Mr. Scott Bauer (Palo Verde)

Mr. Stan Ketelsen (PG&E)

Mr. Scott Head (STP)

Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)

Mr. Floyd Gilzow (DNR)

ULNRC-0552 1 Enclosure I Page 1 of 4 LIST OF COMMITMENTS The following table provides an update/status for each of the open actions committed to by AmerenUE in Reference 1 of the cover letter. The numbering in this table is maintained consistent with Reference 1. Any other statements in this document are provided for information purposes and are not considered commitments. Please direct questions regarding these commitments to Tom Elwood, Supervising Engineer, Regulatory Affairs and Licensing at 573-676-6479.

COMMITMENT Status Due Date/Event

2. The following corrective action activities will be completed:
b. Downstream effects evaluation. Initial downstream evaluations have been December 15, 2008 performed; however, refinements are being pursued using test data and input from PWROG/NRC discussions concerning nuclear fuel.
c. Upstream effects evaluation. Upstream evaluations have been performed and December 15, 2008 will be included in the Westinghouse team analysis summary report associated with item 41f. of this table.
3. Submit an update to information contained in Callaway's The analyses are proceeding and refinements December 15, 2008 response to Generic Letter 2004-02 Requested Information are being pursued. The update of information Item 2 contained in section 2(c) of Callaway's September 1, 2005 (ULNRC-05 194) response to Generic Letter 2004-02 will be provided after completion of item 4.f. of this table.

ULNRC-0552 1 Enclosure I Page 2 of 4 COMMITMENT Status Due Date/Event

4. The following evaluations and testing will be completed:
b. NEI 04-07 debris generation calculation. The debris generation calculation has been December 15, 2008 performed and will be included in the Westinghouse team analysis summary report associated with item 4.f. of this table.
c. NEI 04-07 debris transport calculation. The debris transport calculation has been December 15, 2008 performed and will be included in the Westinghouse team analysis summary report associated with item 4.f. of this table.
d. Evaluate the impact of chemical effects on WCAP 16530-NIP guidance was used as part of December 15, 2008 containment emergency sump strainer head loss during the strainer performance testing performed in design basis accident conditions January 2008.
e. Confirmation that the replacement sump strainer The current strainer performance test report is December 15, 2008 design provides for available NPSH to be in excess of based on the March 13, 2006 strainer test 'ing required NPSH. and has been used in the determination of adequate NPSH. This item is currently being revised after receipt of final testing reports from the containment sump strainer testing performed in January 2008.
f. Completion of the final site acceptance review of the Several of the items contained in the final report December 15, 2008 Westinghouse team analysis summary report. have been completed but the final report will not be issued until all items are completed.

ULNRC-05521 Enclosure I Page 3 of4 COMMITMENT Status Due Date/Event

g. Replacement sump screen head loss testing Strainer performance testing was previously December 15, 2008 performed during the week of March 13, 2006.

This item is currently being revised after receipt of final testing reports from the containment sump strainer testing performed in January 2008

5. The following item will be completed::

c Evaluation and implementation of potential Implementation of potential modification to the December 15, 2008 modification to the safety injection system to address safety injection system is dependant on the downstream effects. refinements mentioned in Item 2.b. of this table.

Based on the evaluations completed to date, the downstream effects evaluations have been performed and conclude that there are no modifications necessary for the Safety Injection system. However, as GSI- 191 evaluations are finalized, this conclusion will be re-evaluated to determine if additional efforts are required.

6. Callaway will complete removal of containment spray Removal of containment spray system (CSS) December 15, 2008 system (CS 5) pump cyclone separators, if required based pump cyclone separators is dependent on the on the results of the downstream effects evaluation, results of the downstream effects evaluation identified as item 2.b of this table.
7. The following programs and controls will be implemented at Callaway to control debris sources.

ULNRC-05521 Enclosure I Page 4 of 4 COMMITMENT Status Due Date/Event

a. Changes to design change process procedures to ensure Complete Complete that necessary engineering evaluations will be performed for plant design that either directly or indirectly affects containment, ECCS, or CSS.
b. Changes to containment entry and material control Complete Complete procedure requirements for control of materials during work activities conducted in the containment.
c. Changes to programs and procedures that have the Complete Complete potential to add tags and labels inside containment.
d. Implementation of a containment coatings assessment Complete Complete program
e. Implementation of a containment latent debris Complete Complete assessment program f Implementation of changes to the inspection processes Complete Complete for the installed sump strainers

Text

AmerenUE P0 Box 620 Callaway Plant Fulton, MO 65251 June 24, 2008 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop PI-137 Washington, DC 20555-0001 ULNRC-05521 Aer Ladies and Gentlemen:

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

FACILITY OPERATING LICENSE NPF-30 REQUEST FOR EXTENSION OF CORRECTIVE ACTIONS COMPLETION DATE FOR NRC GENERIC LETTER 2004-02, "POTENTIAL IMPACT OF DEBRIS BLOCKAGE ON EMERGENCY RECIRCULATION DURING DESIGN BASIS ACCIDENTS AT PRESSURIZED-WATER REACTORS" (TAC NO. MC4671)

References:

1. AmerenUE Letter ULNRC-05461, dated December 10, 2007.
2. AmerenUE Letter ULNRC-05465, dated December 20, 2007.
3. AmerenUE Letter ULNRC-05481, dated February 29, 2008
4. AmerenUE Letter ULNRC-05235, dated December 12, 2005
5. Letter dated November 27, 2007 from USNRC to A.

Pietrangelo, Nuclear Energy Institute By letters dated December 10 and 20, 2007 (Reference 1 and 2), Union Electric Company (AmerenUE) committed to completing all corrective actions associated with Generic Letter (GL) 2004-02 prior to or on June 30, 2008. Although plant-specific tests at the vendor testing facility were completed, the vendor documentation necessary for AmerenUE to complete subsequent analyses and evaluations has been delayed. Additionally, AmerenUE will implement corrective actions for the current containment sump strainer during the fall 2008 outage that will regain margin due to a vendor identified error with the containment sump clean strainer head loss.

Consequently, and as further explained in this letter, AmerenUE is requesting an extension to delay the completion of remaining corrective actions until December 15, 2008.

a subsidiary of Ameren Corporation

ULNRC-05521 June 24, 2008 Page 2 AmerenUE has successfully completed testing performed at a special test facility at Alden Research Laboratory. The tests were performed based on an established test protocol with input from the NRC Staff. There have been a number of delays in completion of the test report and subsequent analysis due to the number of tests being performed for other licensees and competing resources for completion. AmerenUE was present during testing that was performed at the test facility in January, 2008 for Callaway Plant, which demonstrated that adequate net positive suction head (NPSH) margin would be maintained. In addition, the testing confirmed the effectiveness of the new strainer design and its resistance to blockage from the transported debris.

The increase in head loss due to chemical effects was minimal. Bypass testing was also performed which is being evaluated in the downstream effects analysis.

Therefore, corrective actions are nearly complete.

In SECY-06-0078, dated March 31, 2006, the NRC staff recognized that licensees may encounter situations that could delay the implementation of corrective actions as committed in response to GL 2004-02. SECY-06-0078 describes that proposed extensions to permit completion of corrective actions after December 31, 2007 may be acceptable if, based on the licensee's request, the staff determines that "the licensee has a plant-specific technical/experimental plan with milestones and schedule to address outstanding technical issues with enough margin to account for uncertainties" and that "the licensee identifies mitigative measures to be put in place prior to December 31, 2007, and adequately describes how these mitigative measures will minimize the risk of degraded ECCS and CSS functions during the extension period."

AmerenUE has the following plant-specific technical/experimental plan with milestones and schedule to address outstanding technical issues with enough margin to account for uncertainties:

Additional plant-specific tests that support assumptions and corresponding conclusions contained in the GL 2004-02 evaluations for Callaway Plant were completed in January, 2008. The testing included strainer performance testing, head loss testing, and chemical effects/debris bypass testing that included debris transport. Although plant-specific tests at the vendor testing facility were completed, the vendor documentation necessary for AmerenUE to complete subsequent analyses and evaluations has been delayed.

AmerenUE expects receipt of the final test report from the vendor by mid-August 2008.

Following receipt of the final test report from the vendor, numerous additional actions are required by AmerenUE to complete formal verification of design inputs, assumptions and conclusions of AmerenUE calculations / evaluations conducted in response to issues identified in GL 2004-02. These activities include assessing the impact of the test results on strainer NPSH calculations, strainer bypass sampling impact on downstream effects analyses (in-vessel and ex-vessel), as well as potential impact on other Generic Letter 2004-02 corrective action evaluations. These activities also include compliance with

ULNRC-05521 June 24, 2008 Page 3 10 CFR 50, Appendix B requirements for design control, document control and quality assurance records. These activities will be complete by December 15, 2008.

The following mitigative measures were put in place prior to December 31, 2007 and continue to be in place:

" New containment emergency recirculation sump strainers were installed within each sump during Callaway's spring 2007 refueling outage. The new strainers have nominal 0.045 inch openings and a total surface area of 6623 square feet.

" Installation of debris barriers in the "A" and "D" loop entrances was also completed during the spring 2007 fueling outage. The debris barriers are designed to reduce the quantity of debris at the containment sumps following a high energy line break (HELB) inside the bioshield. The barriers will diminish the amount of debris that can take the shortest path to the containment sumps, thereby increasing the probability that debris will be held up in low flow areas or deposited on components within the post- HELB flood plain. This debris hold-up will decrease the quantity of debris at the containment sumps, thus minimizing blockage and maximizing NPSH available to the Emergency Core Cooling System (ECCS) and Containment Spray (CS) pumps. Similar barriers are also installed at secondary shield wall penetrations near the sumps and below the post accident water level.

  • In August 2003, Callaway increased the minimum Refueling Water Storage Tank (RWST) level to a nominal level of 96.3%. This administratively controlled RWST level assures capacity above the Technical Specification 3.5.4.2 minimum required volume of 394,000 gallons (93.6%), and is also above the current low alarm level of 95.3% (400,674 gallons). This change was performed as a compensatory measure for implementation of NRC Bulletin 2003-01 as described in AmerenUE's response to the bulletin (Ref.

4).

" Implementation of the following Westinghouse Owners Group candidate operator actions was completed at Callaway in April 2005 as part of the overall Emergency Operating Procedure (EOP's) upgrade effort. Additional details are provided in Callaway's response to Bulletin 2003-01.

a. COA 1A - Operator action to secure one spray pump before recirculation alignment
b. COA 5 - Refill of RWST
c. COA 8 - Provide Guidance on Symptoms and Identification of CTMT sump blockage

ULNRC-05521 June 24, 2008 Page 4

d. COA 9 - Develop contingency actions to be taken in response to CTMT sump blockage Implementation is complete for Callaway plant procedures and processes described in Reference 1 to support the GL 2004-02 hardware modifications and revised operating practices, as well as to support the assumptions, initial conditions and conclusions of the expected final version of GL 2004-02 related evaluations, when the evaluations are completed and documented.

Administrative procedures and processes include implementation of changes to programmatic controls for design change processes and containment material controls, as well as implementation of a containment coatings assessment program and a containment latent debris assessment program.

In light of AmerenUE's request for extension of the remaining corrective actions for GL 2004-02, this letter transmits changes to previously identified regulatory commitments (as contained in Reference 1). Consistent with guidance in Reference 5 for licensees with approved extensions, AmerenUE will submit an update to the supplemental response to GL 2004-02 describing the results of the testing and the implementation of calculations, evaluations and other changes described in Reference 1 within 90 days of completion of all actions needed to address GL 2004-02. The commitment changes are being submitted in accordance with guidance provided by industry document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," as endorsed in Regulatory Issues Summary 00-017, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff." Enclosure I lists the AmerenUE commitments contained in this letter and which supersede those previously contained in Reference 1.

Please contact Tom Elwood, Supervising Engineer, Regulatory Affairs and Licensing at 573-676-6479 for any questions you may have regarding this request.

I declare under penalty of perjury that the foregoing is true and correct Sincerely, Executed on: June 24, 2008 Luke H. Graessle Manager, Regulatory Affairs BFH/nls Enclosure

ULNRC-05521 June 24, 2008 Page 5 cc: Mr. Elmo E. Collins, Jr.

Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Mohan C. Thadani (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O-8G14 Washington, DC 20555-2738

ULNRC-05521 June 24, 2008 Page 6 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4200 South Hulen, Suite 630 Fort Worth, TX 76109 (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:

C. D. Naslund A. C. Heflin T. E. Herrmann G. A. Hughes S. M. Maglio T. B. Elwood L. H. Graessle S. L. Gallagher L. M. Belsky (NSRB)

Mr. Ron Reynolds, Director (SEMA)

Mr. Edward Gray, Senior REP Planner (SEMA)

Mr. John Campbell, REP Planner (SEMA)

Ms. Diane M. Hooper (WCNOC)

Mr. Dennis Buschbaum (TXU)

Mr. Scott Bauer (Palo Verde)

Mr. Stan Ketelsen (PG&E)

Mr. Scott Head (STP)

Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)

Mr. Floyd Gilzow (DNR)

ULNRC-0552 1 Enclosure I Page 1 of 4 LIST OF COMMITMENTS The following table provides an update/status for each of the open actions committed to by AmerenUE in Reference 1 of the cover letter. The numbering in this table is maintained consistent with Reference 1. Any other statements in this document are provided for information purposes and are not considered commitments. Please direct questions regarding these commitments to Tom Elwood, Supervising Engineer, Regulatory Affairs and Licensing at 573-676-6479.

COMMITMENT Status Due Date/Event

2. The following corrective action activities will be completed:
b. Downstream effects evaluation. Initial downstream evaluations have been December 15, 2008 performed; however, refinements are being pursued using test data and input from PWROG/NRC discussions concerning nuclear fuel.
c. Upstream effects evaluation. Upstream evaluations have been performed and December 15, 2008 will be included in the Westinghouse team analysis summary report associated with item 41f. of this table.
3. Submit an update to information contained in Callaway's The analyses are proceeding and refinements December 15, 2008 response to Generic Letter 2004-02 Requested Information are being pursued. The update of information Item 2 contained in section 2(c) of Callaway's September 1, 2005 (ULNRC-05 194) response to Generic Letter 2004-02 will be provided after completion of item 4.f. of this table.

ULNRC-0552 1 Enclosure I Page 2 of 4 COMMITMENT Status Due Date/Event

4. The following evaluations and testing will be completed:
b. NEI 04-07 debris generation calculation. The debris generation calculation has been December 15, 2008 performed and will be included in the Westinghouse team analysis summary report associated with item 4.f. of this table.
c. NEI 04-07 debris transport calculation. The debris transport calculation has been December 15, 2008 performed and will be included in the Westinghouse team analysis summary report associated with item 4.f. of this table.
d. Evaluate the impact of chemical effects on WCAP 16530-NIP guidance was used as part of December 15, 2008 containment emergency sump strainer head loss during the strainer performance testing performed in design basis accident conditions January 2008.
e. Confirmation that the replacement sump strainer The current strainer performance test report is December 15, 2008 design provides for available NPSH to be in excess of based on the March 13, 2006 strainer test 'ing required NPSH. and has been used in the determination of adequate NPSH. This item is currently being revised after receipt of final testing reports from the containment sump strainer testing performed in January 2008.
f. Completion of the final site acceptance review of the Several of the items contained in the final report December 15, 2008 Westinghouse team analysis summary report. have been completed but the final report will not be issued until all items are completed.

ULNRC-05521 Enclosure I Page 3 of4 COMMITMENT Status Due Date/Event

g. Replacement sump screen head loss testing Strainer performance testing was previously December 15, 2008 performed during the week of March 13, 2006.

This item is currently being revised after receipt of final testing reports from the containment sump strainer testing performed in January 2008

5. The following item will be completed::

c Evaluation and implementation of potential Implementation of potential modification to the December 15, 2008 modification to the safety injection system to address safety injection system is dependant on the downstream effects. refinements mentioned in Item 2.b. of this table.

Based on the evaluations completed to date, the downstream effects evaluations have been performed and conclude that there are no modifications necessary for the Safety Injection system. However, as GSI- 191 evaluations are finalized, this conclusion will be re-evaluated to determine if additional efforts are required.

6. Callaway will complete removal of containment spray Removal of containment spray system (CSS) December 15, 2008 system (CS 5) pump cyclone separators, if required based pump cyclone separators is dependent on the on the results of the downstream effects evaluation, results of the downstream effects evaluation identified as item 2.b of this table.
7. The following programs and controls will be implemented at Callaway to control debris sources.

ULNRC-05521 Enclosure I Page 4 of 4 COMMITMENT Status Due Date/Event

a. Changes to design change process procedures to ensure Complete Complete that necessary engineering evaluations will be performed for plant design that either directly or indirectly affects containment, ECCS, or CSS.
b. Changes to containment entry and material control Complete Complete procedure requirements for control of materials during work activities conducted in the containment.
c. Changes to programs and procedures that have the Complete Complete potential to add tags and labels inside containment.
d. Implementation of a containment coatings assessment Complete Complete program
e. Implementation of a containment latent debris Complete Complete assessment program f Implementation of changes to the inspection processes Complete Complete for the installed sump strainers
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