ULNRC-06129, Three-Month Final Update to the Callaway LRA (Amendment 38)

Three-Month Final Update to the Callaway LRA (Amendment 38)

ML14213A113
Person / Time
Site:	Callaway
Issue date:	08/01/2014
From:	Kremer G Ameren Missouri
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ULNRC-06129
Download: ML14213A113 (5)

Text

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'WAmeren MISSOURI Callaway Plant July 31, 2014 ULNRC-06129 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Ladies and Gentlemen:

10 CFR 2.101 10 CFR 2.109(b) 10 CFR 50.4 10 CFR 50.30 10 CFR 51.53(c) 10 CFR 54 DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

FACILITY OPERATING LICENSE NPF-30 THREE-MONTH FINAL UPDATE TO THE CALLAWAY LRA (AMENDMENT 38)

References:

1) ULNRC-05830 dated December 15,2011

2) ULNRC-05939 dated December 19, 2012

3) ULNRC-06057 dated December 20,2013

4) NRC Letter dated January 13, 2014, "Callaway Plant, Unit!-

Issuance of Amendment Regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program in accordance with 10 CFR 50.48(c)" (TAC No. ME7046) (ML13274A596)

5) ULNRC-05941 dated December 20,2012

6) NRC Letter dated January 14, 2014, "Callaway Plant, Unit 1 -

Issuance of Amendment Re: Revision to Final Safety Analysis Report Associated with Seismic Damping Values for the Integrated Head Assembly" (TAC No. MF0407) (ML13358A005)

By the Reference I letter, Union Electric Company (Ameren Missouri) submitted a license renewal application (LRA) for Callaway Plant Unit 1. The application included the License Renewal Application (LRA) and the Environmental Report-Operating License Renewal Stage. References 2 and 3 transmitted the 2012 and 2013 LRA Annual Updates.

PO Box 620 Fulton, MD 65251 AmerenMissouri.com STARS

• Alliance

ULNRC-06129 July 31, 2014 Page2 As required by 10 CFR 54.21 (b), each year following submittal of the LRA, and at least 3 months before scheduled completion of the NRC review, an amendment to the LRA must be submitted that identifies any change to the current licensing basis (CLB) that materially affects the contents of the LRA, including the Final Safety Analysis Report (FSAR) supplement. Enclosure 1 of this letter provides LRA Amendment 38, which fulfills the requirement to submit an update at least 3 months before scheduled completion of the NRC review, anticipated to be completed in November 2014. This 3-month final update covers the period from October 1, 2013 through June 8, 2014, with additional supplements associated with the implementation ofthe NFPA 805 program on July 15, 2015 (Amendment No. 206, Reference 4). There have been no additional FSAR updates submitted since FSAR Revision OL-20, which was identified in the 2013 Annual Update (Reference 3). identifies LRA changes (line-in/line-out LRA pages) that have been made to reflect the following:

1. Update NFP A 805 system and component changes,

2. Correct the internal environment from treated borated water to demineralized water for a flow orifice on LRA Table 3.3.2-1 0,

3. Implement an enhancement of AMP XI.M27 (Fire Water Systems program) to check for evidence of voids beneath the floor of the fire water storage tanks (revised Table A4-1, Item 10),

4. Implement AMP: XI.E4 (Metal Enclosed Bus program) (revised Table A4-1, Items 30 and 33),

5. Clarify aging effects managed by AMP XI.M16A (PWR Vessel Internals program) to be consistent with LR-ISG-2011-04,

6. Revise the operating experience in AMP XI.E3 (Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualifications Requirements) to indicate installation of all non-safety related manhole sump pumps within the scope of license renewal has been completed, and

7. Revise LRA 2.3.3.29 boundary drawing reference.

The above resulted in a total of three (3) changes to license renewal commitments in Table A4-1 contained in this transmittal.

Ameren Missouri has routinely included amendments to the LRA with responses to requests for addition information (RAI). Information from previous amendments (Amendments 28-37) is not repeated in Enclosure 1. For reference, a summary table of LRA correspondence for the period covered by this update is included in Enclosure 2.

Also, it is noted that Ameren Missouri is modifying Callaway Plant Unit 1 during Refueling Outage 20 by replacing the original reactor vessel head with a replacement reactor vessel closure head (RRVCH).

Refueling Outage 20 is scheduled to start in October 2014 and expected to be completed in late November 2014. The intent of this modification is to install the RRVCH without functional changes to structures, systems, or components (SSCs). Differences are primarily the result of design improvements that have evolved over the years since the existing original head was placed into service. The RR VCH was fabricated of materials to address the Primary Water Stress Corrosion Cracking (PWSCC) concerns with Alloy 600 materials. The original penetration nozzles were

ULNRC-06129 July 31, 2014 Page3 constructed of Alloy 600 and attached with Alloy 82/182 weld materials, which are susceptible to PWSCC. The penetration nozzles on the RR VCH are constructed of Alloy 690 and attached with weld materials which industry experience and laboratory data have shown to be resistant to PWSCC.

The new RRVCH is being replaced under the provisions of 10 CFR 50.59, with the exception of one item related to the seismic design of the Integrated Head Assembly, which required NRC approval. A license amendment request to address this item was submitted on December 20, 2012 (Reference 5) and was approved by Amendment No. 207 to Facility Operating License No. NPF-30, dated January 14, 2014 (Reference 6). Updates to the licensing bases for the RR VCH will be made post Refuel 20 per the requirements of 10 CFR 54.37(b) and 10 CFR 50.71(e), including changes to aging management programs, as applicable.

If you have any questions with regard to this amendment, please contact Sarah Kovaleski at (573) 489-9435 or Roger Wink at (314) 225-1561.

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

Sincerely, Executed on: __

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~~

Greg Kremer Director, Engineering Programs DS/nls

Enclosures:

1) Amendment 38, LRA Changes-Three-Month Final Update Required by 10 CFR 54.21(b)

2) Summary of LRA Correspondence

ULNRC-06129 July 31, 2014 Page4 cc:

Mr. Marc L. Dapas 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. John Daily, Senior Project Manager Project Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-11F1 Washington, DC 20555 Mr. Tam Tran Project Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-11F1 Washington, DC 20555 Mr. Fred Lyon Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8B1 Washington, DC 20555-2738 Mr. Gregory A. Pick U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511

ULNRC-06129 July 31, 2014 Page 5 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4150 International Plaza Suite 820 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 Tech Spec ULNRC Distribution:

F. M. Diya S. P. Banker D. W. Neterer L. H. Graessle B.L.Cox M. A. McLachlan G. S. Kremer S. G. Kovaleski J. S. Geyer S. A. Maglio T. B. Elwood Corporate Communications NSRB Secretary B. C. Daniels R. C. Wink STARS Regulatory Affairs Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)

Missouri Public Service Commission Ms. Leanne Tippett-Mosby (DNR)

E. A. Blocher (STARS PAM COB)