ULNRC-06185, Fourth Six Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

Fourth Six Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

ML15057A303
Person / Time
Site:	Callaway
Issue date:	02/26/2015
From:	Herrmann T Ameren Missouri
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, ULNRC-06185
Download: ML15057A303 (13)

Text

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'fi~~Ameren Callaway Plant MISSOURI February 26, 2015 ULNRC-06185 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR2.202 Ladies and Gentlemen:

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

FACILITY OPERATING LICENSE NPF-30 FOURTH SIX MONTH STATUS REPORT IN RESPONSE TO MARCH 12, 2012 COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE SPENT FUEL POOL INSTRUMENTATION (ORDER NUMBER EA-12-051)

References:

1. Letter dated March 12, 201 2 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 Reliable Spent Fuel Pool Instrumentation" (ADAMS Accession No. ML12056A044)

2. NRC Interim Staff Guidance JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation," Revision 0, August 29, 2012 (ADAMS Accession No. ML12221A339)

3. ULNRC-05925, "Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation," dated October 29, 2012

4. ULNRC-05960, "Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation," dated February 28, 2013

5. ULNRC-06026, "First Six-Month Status Report In Response to March 12, 2012 Commission Order Modifying Licenses With Regard To Reliable Spent Fuel Pool Instrumentation," dated August 29, 2013

• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • PO Box 620 Fulton, MO 65251 AmerenMissouri.com ..............

STARS

• Alliance

ULNRC-06185 February 26, 2015 Page2

6. ULNRC-06088, "Second Six-Month Status Report In Response to March 12, 2012 Commission Order Modifying Licenses With Regard To Reliable Spent Fuel Pool Instrumentation," dated February 26, 2014

7. ULNRC-06136, Third Six Month Status Report In Response To March 12, 2012 Commission Order Modifying Licenses With Regard To Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated August 28, 2014 On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued an order identified above as Reference 1 to Union Electric Company (dba Ameren Missouri) for Callaway Plant. Reference 1 was immediately effective and directs Ameren Missouri to have a reliable indication of water level in associated spent fuel storage pools. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of final interim staff guidance from the NRC (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 3 provided Ameren Missouri's initial status report regarding reliable spent fuel pool instrumentation. Reference 4 provided Ameren Missouri's Overall Integrated Plan.

Section IV, Condition C.2 of Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. NEI 12-02, "Industry Guidance for Compliance with NRC Order EA-12-051, Reliable Spent Fuel Pool Instrumentation," provides direction regarding the content of the status reports. References 5, 6 and 7 provided Ameren Missouri's first, second and third six-month status reports. The enclosure to this letter provides Ameren Missouri's fourth six-month status report pursuant to Section IV, Condition C.2 of Reference 1.

This letter does not contain new commitments.

If 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.

Sincerely, Executed on: d_ I2_G::, I I

z_o) ~

Timothy E. Herrmann VP, Engineering

Enclosure:

Ameren Missouri's Fourth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

ULNRC-06185 February 26, 2015 Page 3 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 otNuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-13H16M Washington, DC 20555-0001 Mr. Jack Davis Director, Mitigation Strategies Directorate Office otNuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

ULNRC-06185 February 26, 2015 Page4 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 Responses and Reports ULNRC Distribution:

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

Missouri Public Service Commission

Enclosure to ULNRC-06185 Ameren Missouri's Fourth Six Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation 1 Introduction Ameren Missouri developed an Overall Integrated Plan (OIP) (Reference 1 in Section 8) for the Callaway Plant, documenting the requirements to install reliable Spent Fuel Pool Instrumentation System (SFPIS),

in response to NRC Order EA-12-051 (Reference 2). This enclosure provides an update of milestone accomplishments since the last update submittal of the OIP (Reference 13), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any. Refer to Section 8 of this enclosure for a list of References.

2 Milestone Accomplishments The following milestones have been completed since development of the SFPIS OIP (Reference 1), and are current as of January 31, 2015.

• Submittal of the fourth six-month status report for implementation of order EA-12-051 (this document).

• Receipt of SFP Instruments

• Create Procedures (Including Maintenance Procedures)

• Develop Training Plan

• Complete SFP Instrumentation Procedures & Training

• SFP Instruments Operational 3 Milestone Schedule Status The following table provides an update of the milestone schedule provided in the SFPLIS OIP to the NRC. The table provides the activity status of each item, and the expected completion date noting any changes. The dates are planning dates subject to change as design and implementation details are developed.

The revised milestone target completion dates do not impact the order implementation outage. Italicized text denotes that a Milestone was updated since the third six-month status update.

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Target Activity Revised Target MHestone Completion Date Status Completion Date Submit 60 Day Status Report Oct 2012 Complete Submit Overall Integrated Plan Feb 2013 Complete Submit 6 Month Updates:

Update 1 Aug 2013 Complete Update 2 Feb 2014 Complete Update 3 Aug 2014 Complete Modifications:

Modifications Evaluation Feb 2013 Complete Commence Engineering and Design Mar 2013 Complete Complete Design Dec 2013 Complete Receipt of SFP Instruments Apr 2014 Complete Procedures:

Create Procedures (Note I) Sep 2014 Complete Training:

Develop Training Plan Aug 2014 Complete Complete SFP Instrumentation Sep 2014 Complete Procedures & Training RAI Response:

RAI Response (Note 2) Jun 2013 Complete ISE RAI Response (Note 3) Mar 2014 Complete SFP Instruments Operational (Note 4) Nov 2014 Complete Submit Completion Report Dec 2014 Not Started Jul2016 Note 1: Includes Maintenance Procedures Note 2: The RAI referred to here is the NRC's RAI concerning the Overall Integrated Plan in response to Order EA-12-051 (Reference 3). Reference 4 provided Ameren Missouri's response to the RAI.

Note 3: The RAI's referred to here are from the NRC Interim Staff Evaluation (ISE) and Request for Additional Information concerning Overall Integrated Plan In Response To Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (Reference 6)

Note 4: Prior to the completion of Refuel 20, the SPFIS was installed and in operation with a battery supply that can last 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if site power is lost. Callaway requested relaxation (References 10 and 11) for the requirement described in NRC Order EA-12-051, Appendix 2, Section 1.6. The relaxation request was approved as documented in ML14154A400 (Reference 12). Upon implementation of Callaway's FLEX Strategies per NRC Order EA-12-049, full compliance with NRC Order EA-12-051 will be achieved.

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4 Changes to Compliance Method There are no changes to the compliance method documented in the Overall Integrated Plan (Reference 1) since the submittal of the Third Six Month Status Report (Reference 13) in August 2014.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Ameren Missouri requested via ULNRC-0603 6 (Reference 7) and received approval as documented in ML13319A668 (Reference 8) for relaxation of FLEX implementation per NRC Order EA-12-049 until the completion of Refuel 21 (Spring 20 16). FLEX implementation is required to comply with the power supply requirement described in NRC Order EA-12-051, Attachment 2, Section 1.6. Based on the approval of the relaxation request, Ameren Missouri submitted ULNRC-06113 (Reference 10) and ULNRC-06119 (Reference 11 ), to request relaxation of the power supply requirement described in NRC Order EA-12-051, Attachment 2, Section 1.6. This relaxation was approved by the NRC per ML14154A400 (Reference 12).

6 Open Items from Overall Integrated Plan and Interim Safety Evaluation There are no open items from the Overall Integrated Plan. All requested information for the RAI' s from the Interim Staff Evaluation was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6, as documented in the Third Month Status Report (Reference 13) in August 2014.

The following tables provide a summary of the open items documented in the Overall Integrated Plan or the Draft Safety Evaluation (SE) and the status of each item.

Overall Integrated Plan Open Item Status Interim Staff Evaluation Open Items (Note 1) Status RAINo.1 Requested information was Please provide the results of the calculation used to submitted on the STARS e-Portal determine the water elevation that is sufficient for the by March 31, 2014, as required by pump's required NPSH so the NRC staff may confirm that Reference 6.

Level 1 has been adequately identified.

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I* Interim Staff Evaluation Open Items (Note 1) Status RAINo.2 Requested information was Please clarify whether this wireless communications system submitted on the STARS e-Portal will be used as two separate point-to-point wireless by March 31, 2014, as required by communications systems (i.e., one system between the Reference 6.

sending unit and receiver for the primary level channel and a second system between the sending unit and receiver for the back-up level channel), or whether there will be shared communications channels over which both the primary and the backup channels can communicate simultaneously.

Also, please verify whether there are other wireless communication devices within the plant that will be allowed to share this wireless communications system.

RAINo.3 Requested information was Please provide a plant-specific evaluation of the interaction submitted on the STARS e-Portal of the proposed wireless technology with other plant by March 31, 2014, as required by systems, in particular, interactions and any malfunctions Reference 6.

that could result from potential failure modes of one channel, or due to BOB conditions.

RAINo.4 Requested information was Please provide additional information describing how the submitted on the STARS e-Portal proposed arrangement and routing of the cables meet the by March 31, 2014, as required by Order requirement to arrange the SFP level instrument Reference 6.

channels in a manner that provides reasonable protection of the level indication function against missiles that may result from damage to the structure over the SFP.

RAINo.S Requested information was Please clarify if a stilling well is part of the instrument submitted on the STARS e-Portal design and, if so, how its weight is accounted for and how it by March 31, 2014, as required by will be mounted and analyzed. Reference 6.

RAINo.6 Requested information was Please provide the results of the analyses used to verify the submitted on the STARS e-Portal design criteria and methodology for seismic testing of the by March 31, 20 14, as required by SFP instrumentation and the electronics units, including Reference 6.

design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.

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Intelim Staff Evaluation Open Items (Note 1) Status RAINo.7 Requested information was For each of the mounting attachments required to fasten submitted on the STARS e-Portal SFP level equipment to plant structures, please describe the by March 31, 20 14, as required by design inputs and the methodology that will be used to Reference 6.

qualify the structural integrity of the affected structures/equipment.

RAINo.8 Requested information was Please describe the quality assurance process to be used to submitted on the STARS e-Portal meet the augmented quality requirements identified in the by March 31, 20 14, as required by Order. Reference 6.

RAINo.9 Requested information was Please provide an analysis of the maximum expected submitted on the STARS e-Portal radiological conditions (dose rate and total integrated dose) by March 31, 20 14, as required by to which the transmitter electronics will be exposed. Reference 6.

Provide documentation indicating the cumulative (total integrated) radiological dose the electronics for this equipment are capable of withstanding. Discuss the time period over which the analyzed total integrated dose was applied.

RAINo. 10 Requested information was Please provide information indicating a) the temperature submitted on the STARS e-Portal ratings for all system electronics (including sensor by March 31, 20 14, as required by electronics, system electronics, transmitter, receiver and Reference 6.

display) and whether the ratings are continuous duty ratings; and, b) the maximum expected temperature in the room( s) in which the sensor electronics will be located under BOB conditions, with no ac power available to run Heating, Ventilation, and Air Conditioning (HVAC) systems.

RAINo. 11 Requested information was Please provide information indicating the maximum submitted on the STARS e-Portal expected relative humidity in the room in which the sensor by March 31, 2014, as required by electronics will be located under BOB conditions, with no Reference 6.

ac power available to run HVAC systems, and whether the sensor electronics are capable of continuously performing required functions under this expected humidity condition.

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Interim Staff Evaluation Open Items (Note 1) Status RAINo. 12 Requested information was Please provide the following: submitted on the STARS e-Portal by March 31, 2014, as required by Information describing the evaluation of the sensor Reference 6.

electronics design, the shock test method, test results, and forces applied to the sensor electronics applicable to successful tests demonstrating the testing provides an appropriate means to demonstrate reliability of the sensor electronics under the effects of severe shock.

Information describing the evaluation of the sensor electronics design, the vibration test method, test results, forces and their frequency ranges, and directions applied to the sensor applicable to successful tests demonstrating the testing provides an appropriate means to demonstrate reliability of the sensor electronics under the effects of high vibration.

RAINo. 13 Requested information was Please provide analysis of the seismic testing results and submitted on the STARS e-Portal show that the instrument performance reliability, following by March 31, 2014, as required by exposure to simulated seismic conditions representative of Reference 6.

the environment anticipated for the SFP structures at Callaway, has been adequately demonstrated. Include information describing the design inputs and methodology used m any analyses of the mounting of electronic equipment onto plant structures, as requested in RAI No. 7 above.

RAINo. 14 Requested information was Please provide the NRC staff with the final configuration of submitted on the STARS e-Portal the power supply source for each channel so the staff may by March 31, 2014, as required by conclude the two channels are independent from a power Reference 6.

supply assignment perspective.

RAINo.lS Requested information was Please provide the results of the calculation depicting the submitted on the STARS e-Portal battery backup duty cycle requirements demonstrating that by March 31, 2014, as required by battery capacity is sufficient to maintain the level indication Reference 6.

function until offsite resource availability is reasonably assured.

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lntemn Staff Evaluation 0pen Items @Note I) Status RAINo.16 Requested information was Please provide the following: submitted on the STARS e-Portal by March 31, 2014, as required by An estimate of the expected instrument channel accuracy Reference 6.

performance (e.g., in percent of span) under both a) normal SFP level conditions (approximately Level 1 or higher) and b) at the BOB conditions (i.e., radiation, temperature, humidity, post-seismic and post-shock conditions) that would be present if the SFP level were at the Level 2 and Level3 datum points.

A description of the methodology used for determining the maximum allowed deviation from the instrument channel design accuracy under normal operating conditions, which would be used as an acceptance criterion for a calibration procedure to alert operators and technicians that the channel requires adjustment to within normal design accuracy.

RAINo.17 Requested information was Please provide the following: submitted on the STARS e-Portal by March 31, 2014, as required by A description of the capability and provisions the proposed Reference 6.

level sensing equipment will have to enable periodic testing and calibration, including how this capability enables the equipment to be tested in-situ.

A description of the way such testing and calibration will enable the conduct of regular channel checks of each independent channel against the other, and against any other permanently-installed SFP level instrumentation.

A description of the functional checks to be performed, and the frequency at which they will be conducted. Describe how calibration tests will be performed, and the frequency at which they will be conducted. Discuss how these surveillances will be incorporated into the plant surveillance program.

A description of the preventive maintenance tasks required to be performed during normal operation, and the planned maximum surveillance interval that is necessary to ensure that the channels are fully conditioned to accurately and reliably perform their functions when needed.

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Interim Staff Evaluation Open Items (Note 1) Status RAINo. 18 Requested information was Please provide a list of the procedures addressing operation submitted on the STARS e-Portal

{both normal and abnormal response), calibration, test, by March 3 1, 20 14, as required by maintenance, and inspection that will be developed for use Reference 6.

of the SFP instrumentation. The licensee is requested to include a brief description of the specific technical objectives to be achieved within each procedure.

RAINo.19 Requested information was Please provide the following: submitted on the STARS e-Portal by March 31, 2014, as required by Further information describing the maintenance and testing Reference 6.

program the licensee will establish and implement to ensure that regular testing and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements. Include a description of plans to ensure that necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment.

A description of the compensatory actions to be taken in the event that one or both channels are non-functioning, as described in the guidance in NEI12-02 section 4.3.

A description of the planned compensatory actions to be taken when one of the instrument channels cannot be restored to functional status within 90 days.

RAINo. 20 Requested information was Please provide a description of the in-situ calibration submitted on the STARS e-Portal process at the SFP location that will result in the channel by March 31, 2014, as required by calibration being maintained at its design accuracy. Reference 6.

Note 1: An Interim Staff Evaluation has been received from the NRC (Reference 6).

7 Potential Interim Safety Evaluation Impacts There are no potential impacts to the Interim Safety Evaluation identified at this time.

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8 References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. ULNRC-05960,"0verall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)," dated February 28,2013.

2. NRC Order EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012.

3. Letter dated June 7, 2013 from C. F. Lyon, USNRC to A. C. Heflin, Union Electric Company, "Callaway Plant, Unit 1 - Request for Additional Information RE: Overall Integrated Plan in Response to Order EA-12-051, 'Reliable Spent Fuel Pool Instrumentation' (TAC NO. MF0773)"

(ADAMS Accession No. ML13121A187)

4. ULNRC-06008, "Response to Request for Additional Information With Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)," dated July 3, 2013

5. ULNRC-06026 First Six Month Status Report In Response To March 12, 2012 Commission Order Modifying Licenses With Regard To Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated August 29, 2013

6. ML13323A111, Callaway Plant, Unit 1 - Interim Staff Evaluation And Request For Additional Information Re: Overall Integrated Plan In Response To Order EA-12-051, Reliable Spent Fuel Pool Instrumentation {TAC NO. MF0773), dated November 25, 2013

7. ULNRC-06036, Request For Relaxation From NRC Order EA-12-049, "Order Modifying Licenses With Regard To Requirements For Mitigation Strategies For Beyond-Design-Basis External Events", dated October 09, 2013

8. ML13319A668, Callaway Plant, Unit 1- Relaxation Of The Schedular Requirements For Order EA-12-049 "Issuance Of Order To Modify Licenses With Regard To Requirements For Mitigation Strategies For Beyond Design Basis External Events", dated December 11, 2013

9. ULNRC-06088, Second Six Month Status Report In Response To March 12, 2012 Commission Order Modifying Licenses With Regard To Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 26, 2014

10. ULNRC-06113, Request For Relaxation From NRC Order EA-12-051, "Order Modifying Licenses With Regard To Reliable Spent Fuel Pool Instrumentation", dated April17, 2014

11. ULNRC-06119, Supplement to Request For Relaxation From NRC Order EA-12-051, "Order Modifying Licenses With Regard To Reliable Spent Fuel Pool Instrumentation", dated May 8, 2014

12. ML14154A400, Callaway Plant, Unit 1- Relaxation Of The Schedule Requirements For Order EA-12-051, "Order Modifying Licenses With Regard To Reliable Spent Fuel Pool Instrumentation" dated June 26, 2014

13. ULNRC-06136, Third Six Month Status Report In Response To March 12, 2012 Commission Order Modifying Licenses With Regard To Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated August 28, 2014 Page 9 of9