ULNRC-06131, Request for Relaxation from NRC Order EA-12-049, Modifying License with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events.

Request for Relaxation from NRC Order EA-12-049, Modifying License with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events.

ML14217A236
Person / Time
Site:	Callaway
Issue date:	08/01/2014
From:	Neterer D Ameren Missouri
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, ULNRC-06131
Download: ML14217A236 (7)

Text

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WAmeren Callaway Plant MISSOURI August 1, 2014 ULNRC-06131 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 OrderNo. EA-12-049 Ladies and Gentlemen:

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

FACILITY OPERATING LICENSE NPF-30 REQUEST FOR RELAXATION FROM NRC ORDER EA-12-049, "MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS"

References:

1. Letter dated March 12,2012 from E. J. Leeds and M. R. Johnson, USNRC, to Adam C.

Heflin, Callaway Plant, Union Electric Company, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (ADAMS Accession Number ML12054A736)

2. ULNRC-05962, "Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated February 28, 2013 (ADAMS Accession Number ML13063A459)

3. ULNRC-06036, "Request for Relaxation from NRC Order EA-12-049, Order Modifying Licensees with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated October 9, 2013 (ADAMS Accession Number ML13283A033)

4. Letter dated December 11, 2013 from E. J. Leeds, to Adam C. Heflin, Union Electric Company, "Callaway Plant Unit 1- Relaxation of the Schedular Requirements for Order EA-12-049" (ADAMS Accession Number ML13319A668)

This letter transmits a request for relaxation of the requirements contained in NRC Order EA-12-049.

On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued an Order (Reference 1)

........................................................................................................................... PO Box 620 Fulton, MD 65251 AmerenMissouri .com

ULNRC-06I3I August I, 20I4 Page 2 to Union Electric Company (Ameren Missouri) for Callaway Plant. Reference I was immediately effective and directs Ameren Missouri to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. As described in the Overall Integrated Plan (OIP) for Callaway Plant (Reference 2), one requirement of the mitigation strategies is dependent upon implementation of a missile protected water source for Auxiliary Feedwater (Condensate Storage Tank) established in accordance with NRC Order EA-I2-049 (Reference I). Additionally, the OIP describes the plans for storage and protection of FLEX equipment, which was determined to be a new FLEX storage building.

In order to meet FLEX and Expedited Seismic Evaluation Process (ESEP) requirements, Callaway would either have to harden the present Condensate Storage Tank (CST) or build a new "hardened" CST. Callaway Plant elected to install a larger, more robust condensate storage tank, and subsequently transmitted a request to move the order implementation date (Reference 3). The NRC granted relaxation of the order implementation date to completion of the spring 20 I6 refueling outage (Reference 4).

Compliance with NRC Order EA-I2-049 would require Callaway Plant to design and construct a new hardened Condensate Storage Tank and FLEX storage building to Regulatory Guide (RG) I. 76 Revision 0. Callaway Plant is requesting approval of the use ofRG 1.76 Revision I, which is the latest NRC approved standard for design-basis tornado and design-basis tornado-generated missiles that a nuclear power plant should be designed to withstand.

Section IV ofNRC Order EA-12-049 (Reference I) states that licensees proposing to deviate from requirements contained in NRC Order EA-I2-049 may request that the Director, Office ofNuclear Reactor Regulation, relax those requirements. Therefore, in accordance with Section IV of NRC Order EA-I2-049, Ameren Missouri is requesting that the Director, Office ofNuclear Reactor Regulation, relax the requirement for completion of full implementation as prescribed in Section IV.A.2 ofNRC Order EA-12-049 and as described in the attachment to this letter.

Ameren Missouri considers that, upon approval by the NRC, the alternative full implementation dates regarding NRC Order EA-I2-049 proposed in the attachment will constitute a condition of the NRC Order EA-I2-049 for Callaway Plant. Therefore, there are no new regulatory commitments contained in this letter.

Should you have any questions concerning the content of this letter, please contact Scott Maglio, Regulatory Affairs Manager, at 573-676-8719.

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

ULNRC-06131 August 1, 2014 Page 3 Sincerely, Executed on: ---=t:J

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David W. Neterer Vice President, Nuclear Operations EMP Enclosure

ULNRC-06131 August 1, 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. Fred Lyon Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8B 1 Washington, DC 20555-2738 Mr. Eric Leeds Director, Office ofNuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-13H16M Washington, DC 20555-0001 Mr. Jack Davis Director, Mitigation Strategies Directorate Office ofNuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

ULNRC-06131 August 1, 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 Other Situations ULNRC Distribution:

F. M. Diya D. W. Neterer B.L.Cox L. H. Graessle S. A. Maglio Corporate Communications NSRB Secretary T. B. Elwood J. L. Fortman J. T. Patterson D. M. Stepanovic E. M. Ptasznik STARS Regulatory Affairs Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)

Missouri Public Service Commission

Enclosure to ULNRC-06131 Page 1 of2 REQUEST FOR RELAXATION OF NRC ORDER EA-12-049 REQUIREMENT IV.A.2 FOR CALLAWAY PLANT Relaxation Request Pursuant to the procedure specified in Section IV of Nuclear Regulatory Commission (NRC)

Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (Reference 1), Callaway Plant, hereby submits a request for relaxation from the Order requirements for compliance with Attachment 2 of the Order, specifically Item (3) for requirements for the protection of FLEX equipment from external events.

Order Requirement from Which Relaxation is Requested NRC Order EA-12-049,Section IV.A.2 requires compliance with Attachment 2 of the Order.

Item 3 of Attachment 2 requires licensees to provide reasonable protection for associated (FLEX) equipment from external events. To assist licensees with the measures needed to comply with the Order, the NRC provided interim staff guidance (ISG) JLD-ISG-2012-01 (Reference 3).

This ISG endorses the methodologies described in industry guidance document NEI 12-06 (Reference 4) as an acceptable approach to provide reasonable protection, storage, and deployment of the equipment associated with Order EA-12-049.

NEI 12-06 Section 3.2 discusses that if equipment is assumed to be available for use in the FLEX strategy, it is designed to be "robust" with respect to design basis external events. A robust design is defmed in NEI 12-06 as "the design of an SSC either meets the current plant design basis for the applicable external hazards or has been shown by analysis or test to meet or exceed the current design basis." For Callaway, this would require the use of Regulatory Guide 1.76, Revision 0 for the design of FLEX equipment associated with the Order. This impacts the design of the new hardened Condensate Storage Tank(s).

NEI 12-06 Section 7.3 .1 states that FLEX equipment should be stored "in a structure that meets the plant's design basis for high wind hazards." For Callaway, this would require the use of Regulatory Guide 1.76, Revision 0 for the design of the new FLEX storage building and its associated door(s).

As an alternative to NEI 12-06 definition of robust and FLEX storage building design requirements, Callaway Plant is requesting approval of the use of Regulatory Guide 1.76 Revision 1 as the criteria with respect to tornado winds and missiles for the new hardened CST(s) and the FLEX storage building roll-up door(s).

Justification for Relaxation Request Regulatory Guide (RG) 1.76, Revision 1 is the latest NRC approved standard for design-basis tornado and design-basis tornado-generated missiles that a nuclear power plant should be Page 1 of2

Enclosure to ULNRC-06131 designed to withstand. This document used information recorded for more than 46,000 tornado segments occurring over a 50 year period (1950 to 2003), where Revision 0 used only 2 years of tornado observed intensity date (1971-1972). As a result of the limited data, Revision 0 was overly conservative. Based on the additional data of actual tornados, Revision 1 provides more realistic wind loadings.

For the FLEX Storage Building doors, using Revision 0 would require Callaway to develop a new design that would be unique to the plant, require -2' thick door, and -4 people to manipulate. Revision 1 would allow Callaway to use commercially available designs and would result in a more efficient door design that would be significantly easier to design, operate, and maintain. For the hardened CST, the use of Revision 1 would allow the plant to construct a new structure to the latest NRC approved documents which are more realistic while still being conservative.

Conclusion Compliance with NRC Order EA-12-049 would require Callaway Plant to construct a new hardened Condensate Storage Tank(s) and FLEX storage building doors to RG 1.76 Revision 0.

Relaxation would allow design ofthese structures to RG 1.76 Revision 1. The use ofRG 1.76 Revision 1 will be used only for meeting NRC Order EA-12-049 and would not alter the plant's current design or licensing basis. Therefore, in accordance with the provisions of Section IV of the Order, Ameren Missouri requests relaxation of the requirement described in Section IV.A.2, specifically Item (3) under Attachment 2.

References

1. NRC Order EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12,2012 (ADAMS Accession Number ML12054A736)

2. ULNRC-05962, "Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated February 28, 2013 (ADAMS Accession Number ML13063A459)

3. JLD-ISG-2012-01, "Compliance With Order EA-12-049, Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond- Design-Basis External Events" (ADAMS Accession Number ML12229A174)

4. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,"

Revision 0 (ADAMS Accession Number ML12240A307)

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