ULNRC-06240, Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

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Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
ML15239B402
Person / Time
Site: Callaway Ameren icon.png
Issue date: 08/27/2015
From: Herrmann T
Ameren Missouri, Union Electric Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, ULNRC-06240
Download: ML15239B402 (24)
v • d • e


Text

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'WAmeren MISSOURI Callaway Plant August 27, 2015 ULNRC-06240 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 2.202 Ladies and Gentlemen:

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

RENEWED FACILITY OPERATING LICENSE NPF-30 FIFTH SIX-MONTH STATUS REPORT IN RESPONSE TO MARCH 12, 2012 COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS (ORDER NUMBER EA-12-049)

References:

l.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. NRC Interim Staff Guidance 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, Revision 0, August 29, 2012 (ADAMS Accession Number ML12229A174)
3. ULNRC-05924, "Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated October 29, 2012
4. 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 PO Box 620 Fulton, MO 65251 AmerenMissouri .com **************

ULNRC-06240 August 27, 2015 Page 2

5. ULNRC-06024, First Six-Month Status Report In Response to March 12, 2012 Commission Order Modifying Licenses With Regard To Requirements For Mitigation Strategies For Beyond-Design-Basis External Events (Order Number EA-12-049),

dated August 29, 2013

6. ULNRC-06087, Second Six-Month Status Report In Response to March 12, 2012 Commission Order Modifying Licenses With Regard To Requirements For Mitigation Strategies For Beyond-Design-Basis External Events (Order Number EA-12-049),

dated February 26, 2014

7. ULNRC-06135, Third Six-Month Status Report In Response to March 12, 2012 Commission Order Modifying Licenses With Regard To Requirements For Mitigation Strategies For Beyond-Design-Basis External Events (Order Number EA-12-049),

dated August 28, 2014

8. ULNRC-06184, Fourth Six-Month Status Report In Response to March 12, 2012 Commission Order Modifying Licenses With Regard To Requirements For Mitigation Strategies For Beyond-Design-Basis External Events (Order Number EA-12-049),

dated February 26, 2015 On March 12, 2012, the U. S. Nuclear Regulatory Commission (NRC) issued the 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 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. 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 Missouris initial status report regarding mitigation strategies. Reference 4 provided Ameren Missouris 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 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, provides direction regarding the content of the status reports. References 5, 6, 7 and 8 provided Ameren Missouris first, second, third, and fourth six-month status reports. The enclosure to this letter provides Ameren Missouris fifth 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.

ULNRC-06240 August 27,2015 Page 3 I declare under penalty of perjury that the foregoing is true and correct.

Sincerely, Executed on: -'/l'--u-'---Gt'--_2_

' _7----,7,_,_z_o<_.~

Timothy E. Herrmann Vice President, Engineering

Enclosure:

Ameren Missouri's Fifth Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Event

. **~

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ULNRC-06240 August 27, 2015 Page 4 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. L. John Klos Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O-8B1 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-06240 August 27, 2015 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 Responses and Reports ULNRC Distribution:

F. M. Diya D.W. Neterer L. H. Graessle T. E. Herrmann B. L. Cox M. L McLachlan S. A. Maglio T. B. Elwood J.T. Patterson 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-06240 Ameren Missouris Fifth Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction Ameren Missouri developed an Overall Integrated Plan (OIP) (Reference 1) for the Callaway Plant, documenting the diverse and flexible strategies (FLEX), in response to NRC Order Number EA-12-049 (Reference 2). This enclosure provides an update of milestone accomplishments since submittal of the last status report (Reference 16), 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 the development of the OIP, and are current as of July 31, 2015.

Submittal of the fifth six-month status report (this submittal)

FLEX Strategy Evaluation Modifications Evaluation PWROG issues NSSS-specific guidelines Install Off-site Delivery Station (if necessary)

Develop Training Plan N-1 Walkdown 3 Milestone Schedule Status The following table provides an update to Attachment 2 of the OIP. The table provides the activity status of each item, and indicates whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed. The milestone target completion dates have been revised based on approval of the relaxation request discussed in Section 5.

Italicized text denotes that a Milestone was updated since the last six-month status update (Reference 16).

Page 1 of 19

Enclosure to ULNRC-06240 Callaway Milestone Schedule Revised Target Original Target Activity Activity Status Completion Date Date Submit Overall Integrated February-2013 Complete Implementation Plan 6 Month Status Updates Update 1 August-2013 Complete Update 2 February-2014 Complete Update 3 August-2014 Complete Update 4 February-2015 Complete Update 5 August-2015 Complete Update 6 February-2016 Not Started FLEX Strategy Evaluation April-2013 Complete Perform Staffing Analysis December-2013 Started November-2015 Modifications Modifications Evaluation April-2013 Complete Engineering and Implementation November-2014 Started May-2016 N-1 Walkdown April-2013 Complete Design Engineering March-2014 Started October-2015 Unit 1 Implementation Outage November-2014 Not Started May-2016 On-site FLEX Equipment Purchase June-2013 Started December-2015 Procure December-2013 Started April-2016 Off-site FLEX Equipment Develop Strategies with National SAFER November-2013 Started October 2015 Response Center (NSRC)

Install Off-site Delivery Station (if September-2014 Complete necessary)

Procedures PWROG issues NSSS-specific guidelines June-2013 Complete Create Callaway FSG (Note 1) April-2014 Started May-2016 Create Maintenance Procedures June-2014 Not Started May-2016 Training Develop Training Plan April-2014 Complete Implement Training May-2014 Started May-2016 Submit Completion Report November-2014 Not Started July-2016 Note 1: The Callaway FLEX Support Guidelines (FSG) have been created. The FSGs are awaiting final approval just prior to FLEX implementation.

Page 2 of 19

Enclosure to ULNRC-06240 4 Changes to Compliance Method The following changes have been made to Ameren Missouris Overall Integrated Plan (OIP)

(Reference 1) since submittal of the fourth Six-Month Status Report (Reference 16).

4.1 Modes 5-6 Strategies Ameren Missouri has further refined our Mode 5 - 6 Shutdown ELAP Strategy due to concerns that the Refueling Water Storage Tank (RWST) is not missile hardened. The strategy is being revised to utilize the new 500,000 gallon Hardened Condensate Storage Tank (HCST) as a water source and the Boric Acid Batching Tank (BABT) as the boron source for make-up to the Boric Acid Tanks (BATs). The BABT was evaluated and determined to meet Expedited Seismic Evaluation Program (ESEP) requirements for their use in our FLEX mitigating strategies.

4.2 New Hardened Condensate Storage Tank Update Ameren Missouri is constructing a new Hardened Condensate Storage Tank (HCST) that will meet FLEX and Expedited Seismic Evaluation Process (ESEP) requirements. The new 500,000 gallon HCST will provide at least thirty (30) hours of protected water source for the safety function of core cooling. This is a change from the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> reported in the third six-month update submittal via ULNRC-06135 (Reference 13). The new HCST will not replace the current CST since the CST is the design basis source of water for the Auxiliary Feedwater Pumps. The design of the new HCST will utilize Regulatory Guide 1.76 Revision 1 for wind loading design criteria. Regulatory Guide 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 designed to withstand.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation In Reference 4, Ameren Missouri formally requested relief from the requirement of Section IV.A.2 of the Order (EA-12-049) regarding full implementation no later than two (2) refueling cycles after submittal of the Overall Integrated Plan. NRC approval of the requested relief was received in Reference 5, relaxing full Order implementation for Callaway Plant until the completion of the spring 2016 refueling outage. The milestone schedule in Section 3 has been updated for consistency with the approved schedule relief. No additional relief is requested herein.

Page 3 of 19

Enclosure to ULNRC-06240 6 Open Items from Overall Integrated Plan and Interim Safety Evaluation The following tables provide a summary of the open items documented in the OIP or the Interim Safety Evaluation (ISE) and the status of each item. Statuses that are bolded and italicized indicate changes in the status from the previous submittal.

Overall Integrated Plan Open Item Status OI1 The RWST will need to be missile Closed protected to credit its use in FLEX The RWST will not be used as a credited source of strategies. borated water in our mitigating strategies; therefore the RWST does not require missile protection to support FLEX mitigation strategies.

For MODES 1-4, missile protection of the RWST is not a concern from a FLEX strategy standpoint since the RWST is not required as a Reactor Coolant System (RCS) make-up & boration source. The Boric Acid Tanks (BATs) provide sufficient make-up volume to maintain sub-cooling (natural circulation removing decay heat removal via the Steam Generators) and sub-criticality of the reactor core. Low leakage Reactor Coolant Pump (RCP) seals will limit RCS leakage to less than or equal to 1 gpm/RCP (4 gpm/total). Assuming a maximum unidentified RCS leakage of 1 gpm, the total RCS leakage is 5 gpm.

Ameren Missouri has revised our Mode 5 - 6 Shutdown ELAP Strategy due to concerns that the RWST is not missile protected or does not meet ESEP requirements. The revised strategy will utilize the new 500,000 gallon Hardened Condensate Storage Tank (HCST) as a water source and the Boric Acid Batching Tank (BABT) as our boron source for make-up to the Boric Acid Tanks (BATs).

OI2 GOTHIC analysis needs to be Started.

performed to demonstrate that The Gothic Analysis for all modes of operation has Containment pressure and temperature been performed. Containment pressure and remain at acceptable levels and that temperature remain at acceptable levels. The results instrumentation EQ requirements will be of the Instrumentation EQ Analysis are currently maintained. under review.

Page 4 of 19

Enclosure to ULNRC-06240 Overall Integrated Plan Open Item Status OI3 An analysis will need to be performed to Closed.

demonstrate acceptable SFP cooling The Spent Fuel Pool Cooling Pumps will not be pump performance with the SFP in boil- repowered. SFP cooling will be maintained by off. continued makeup and boil-off using the Phase 2 portable equipment.

OI4 For non-Class 1E instrumentation that Closed.

will be repowered using a temporary Ameren Missouri has determined that the non-Class battery, an analysis will need to be 1E instrument racks will not be re-powered via a performed to determine battery life and temporary battery. The required instrument readings frequency of replacing battery will be obtained via portable instruments.

OI5 The current CST and CST pipe chase Started.

are non-seismic. Callaway may pursue Ameren Missouri is constructing a new Hardened the construction of a new seismically Condensate Storage Tank (HCST) that is seismically qualified and missile protected CST. qualified and missile protected. Relaxation of Order Current FLEX strategies rely on the requirements regarding the date of full existing CST tank. Future evaluation is implementation was requested (Reference 4) and has required to determine the impact on been approved (Reference 5). FLEX Support FLEX strategies should the new CST be Guidelines (FSG) are being developed for use of the constructed. new HCST.

OI6 The method for isolating accumulators Closed.

during RCS inventory control has not The method for isolating accumulators during RCS been finalized inventory control has been finalized. Step 1 of FSG-10, Passive RCS Injection Isolation (Rev. 0),

determines if isolation of Safety Injection (SI)

Accumulators is desired. If the Steam Generators will be depressurized below 220 psig, then the SI accumulators are isolated by closure of their discharge isolation valves (if power is available from FLEX 480 VAC Generator) or vented to the containment atmosphere. Callaway Energy Center calculation, BB-180 Rev. 0 Add. 5 Minimum Steamline Pressure to Prevent Accumulator Nitrogen Injection, establishes the site specific value for the Westinghouse Owners Group Emergency Response Guidelines Setpoint O.07 that is used in the Emergency Operating Procedures (i.e.,

ECA-0.0, Loss of All AC Power, Step 17, Rev.

019). The site calculation takes into consideration the potential for nitrogen expansion/SI accumulator pressure increase from heat sources within the containment building (i.e., RCS).

Page 5 of 19

Enclosure to ULNRC-06240 Overall Integrated Plan Open Item Status OI7 The method for repowering the SFP Closed.

cooling pumps has not been finalized. The SFP Cooling Pumps will not be repowered. SFP cooling will be maintained by continued makeup and boil-off using the Phase 2 portable equipment.

OI8 The Westinghouse RCP SHIELD Seal Closed.

issue has not been resolved. This issue has been resolved. NRC Endorsement of TR-FSE-14-1-P, RCP SHIELD Seal is documented in NRC Letter from Mr. Jack Davis, Director, Mitigating Strategies Directorate to Mr. James A.

Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company LLC, dated May 28, 2014 (ML14132A128). (Reference 14)

Interim Safety Evaluation Open Item Status 3.2.1.2.B - RCP Seal O-Ring Integrity and Complete Leakage Rate This issue has been resolved. NRC Endorsement of Additional review of the licensee's applicable TR-FSE-14-1-P, RCP SHIELD Seal is documented analysis and relevant Reactor Coolant Pump in NRC Letter from Mr. Jack Davis, Director, (RCP) seal leakage testing data is needed to Mitigating Strategies Directorate to Mr. James A.

justify that (1) the integrity of the associated Gresham, Manager, Regulatory Compliance, 0-rings will be maintained at the temperature Westinghouse Electric Company LLC, dated May conditions experienced during the ELAP 28, 2014 (ML14132A128). (Reference 14) event, and (2) the seal leakage rate used in the ELAP is adequate and acceptable.

3.2.1.2.D - RCP Seal Leakage Rate Complete The acceptability of the use of the selected This issue has been resolved. NRC Endorsement of seals and the RCP seal leakages rates in the TR-FSE-14-1-P, RCP SHIELD Seal is documented ELAP analysis must be justified. in NRC Letter from Mr. Jack Davis, Director, Mitigating Strategies Directorate to Mr. James A.

Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company LLC, dated May 28, 2014 (ML14132A128). (Reference 14)

Page 6 of 19

Enclosure to ULNRC-06240 Interim Safety Evaluation Open Item Status 3.2.1.3.A - Specify Key Parameters Started.

During the NRC audit process the licensee Ameren Missouri is working with our NSSS was requested to provide the following provider and will provide the requested information.

information: If the ANS 5.1-1979 + 2 sigma model is used in the ELAP analysis, specify the values of the following key parameters used to determine the decay heat: (1) initial power level, (2) fuel enrichment, (3) fuel burnup, (4) effective full power operating days per fuel cycle, (5) number of fuel cycles, if hybrid fuels are used in the core, and (6) fuel characteristics based on the beginning of the cycle, middle of the cycle, or end of the cycle. Address the adequacy of the values used. If the different decay heat model is used, describe the specific model and address the acceptability of the model and the analytical results.

3.2.1.8.B Boric Acid Mixing Started.

The Pressurized-Water Reactor Owners The NRC has subsequently endorsed the position Group submitted to the NRC a position paper with some clarifications (Reference 9).

paper, dated August 15, 2013, which Ameren Missouri will evaluate the clarifications and provides test data regarding boric acid mixing include needed information in the Final Integrated under single-phase natural circulation Plan (FIP), if needed.

conditions and outlined applicability conditions intended to ensure that boric acid addition and mixing would occur under conditions similar to those for which boric acid mixing data is available.

During the audit process, the licensee informed the NRC staff of its intent to abide by the generic approach discussed above; however, the NRC staff concluded that the August 15, 2013, position paper was not adequately justified and that further information is required.

Page 7 of 19

Enclosure to ULNRC-06240 Interim Safety Evaluation Open Item Status 3.2.4.9.A Fuel Oil Quality Complete.

Information is needed regarding plans for All trailer mounted diesel-driven equipment housed assuring and maintaining fuel oil quality. inside the Hardened Storage Building (HSB) will be individually equipped with a trailer mounted automatic fuel oil purification system that maintains the quality of the fuel oil inside the trailer's tank.

After the ELAP, the only "guaranteed" source of fuel-oil (besides what is stored inside the HSB) will be the Emergency Diesel Fuel Oil Storage Tanks (TJE01A & B). Existing sampling requirements for TEJ01A/B are delineated in Diesel Fuel Oil Testing Program as required by T/S S/R 3.8.3.3. FSG-44, FLEX Diesel Fuel Strategy, has been developed to provide direction for supplying diesel fuel for FLEX response equipment during an ELAP event. This FSG provides guidance for obtaining diesel fuel oil from the Emergency Diesel Day Tanks (TJE02 A/B), as well as the Emergency Diesel Fuel Oil Storage Tanks (TJE01A & B). Instructions for obtaining fuel from other non-robust diesel fuel tanks are also included in this FSG in the event the tank survives the event.

3.4.A Offsite Resource Capabilities Complete Details are needed to demonstrate the The National Safer Response Centers (NSRC) in minimum capabilities for offsite resources Memphis, TN., and Phoenix, AR., are operational.

will be met per NEI 12-06 Section 12.2. Ameren Missouri has a contract with NSRC to provide Phase 3 FLEX portable equipment. The NRC Staff Assessment of the NSRCs is documented in NRC Letter from Mr. Jack Davis, Director Mitigating Strategies Directorate to Mr. Joseph E.

Pollock, Vice President, Nuclear Operations, Nuclear Energy Institute, dated September 26, 2014 (ML14265A107). The Staff Assessment evaluated all the items listed in NEI 12-06, Section 12.2.

(Reference 15).

Page 8 of 19

Enclosure to ULNRC-06240 Interim Safety Evaluation Status Confirmatory Item 3.1.1.2.A - CST Seismic Hazard Started Because the current CST is unprotected from The new Hardened Condensate Storage Tank (HCST) seismic hazard, the licensee is planning to is scheduled to complete by the end of Refuel 21 install a new CST. Verification of installation (RF21) is necessary.

3.1.1.2.B - Electrical Power for FLEX Complete Equipment Deployment Electrical Power will not be required to move or Information is needed regarding whether or deploy FLEX equipment from storage.

not electrical power will be required to move or deploy FLEX equipment from storage.

Page 9 of 19

Enclosure to ULNRC-06240 Interim Safety Evaluation Status Confirmatory Item 3.1.2.A - RWST and UHS Flood Levels Started Licensee stated that UHS and refueling water The RWST is not credited as a water source for any storage tank (RWST) are below flood levels FLEX mitigating strategy. Therefore, the RWST but the licensee needs to address potential being below the design-basis flood level will have consequences such as debris in the UHS or no impact on FLEX equipment deployment and access to RWST. In addition, the staff noted associated procedural interfaces.

that the deployment of FLEX equipment and For MODES 1-4, the RWST being located below associated procedural interfaces may be the maximum plant site flood level of Elevation impacted by the UHS and RWST being 840.16 ft. mean sea level (MSL) is not a concern below the design-basis flood level.

from a FLEX strategy standpoint since the RWST is not required as a Reactor Coolant System (RCS) make-up and boration source. The Boric Acid Tanks (BATs) provide sufficient make-up volume to maintain sub-cooling (natural circulation removing decay heat removal via the Steam Generators) and sub-criticality of the reactor core. Low leakage Reactor Coolant Pump (RCP) seals will limit RCS leakage to less than or equal to 1 gpm/RCP (4 gpm/total). Assuming a maximum unidentified RCS leakage of 1 gpm, the total RCS leakage is 5 gpm.

Ameren Missouri has revised our Mode 5 - 6 Shutdown ELAP Strategy due to concerns that the RWST is not missile protected or does not meet ESEP requirements. The revised strategy will utilize the new Hardened Condensate Storage Tank (HCST) as a water source and the Boric Acid Batching Tank (BABT) as our boron source for make-up to the Boric Acid Tanks (BATs).

The impact of the UHS being below flood level is still being evaluated. Ameren Missouri will provide the requested information in a later submittal.

Page 10 of 19

Enclosure to ULNRC-06240 Interim Safety Evaluation Status Confirmatory Item 3.1.3.3.A - The licensee did not provide Started.

information with regard to procedural The following will be included in the Ameren interface considerations as they relate to Missouri Final Integrated Plan (FIP):

tornados.

Tornados are generally fast moving events and over quickly. OTO-ZZ-00012, Severe Weather, provides instructions to prepare the plant for severe weather conditions and a potential station blackout. Ameren Missouri has identified multiple deployment routes for the FLEX portable equipment in the event of damage to the deployment routes. Ameren Missouri has also developed FLEX Support Guideline FSG-5, Initial Assessment and Flex Equipment Staging, to provide guidelines to establish clear access routes and for the deployment of the portable FLEX Equipment.

3.2.1.A - Potential Nitrogen Injection from Complete.

Accumulators into RCS Step 1 of FSG-10, Passive RCS Injection Isolation The licensee needs to confirm that adverse (Rev. 0), determines if isolation of Safety Injection quantities of nitrogen from accumulators will (SI) Accumulators is desired. If the Steam not be injected into the RCS during an ELAP Generators will be depressurized below 220 psig, event using an acceptable methodology that then the SI accumulators are isolated by closure of accounts for the potential for heat transfer their discharge isolation valves (if power is available from the containment building to the contents from FLEX 480 VAC Generator) or vented to the of the accumulator. containment atmosphere. Callaway Energy Center calculation, BB-180 Rev.0 Add. 5 Minimum Steamline Pressure to Prevent Accumulator Nitrogen Injection, establishes the site specific value for the Westinghouse Owners Group Emergency Response Guidelines Setpoint O.07 that is used in the Emergency Operating Procedures (i.e.,

ECA-0.0, Loss of All AC Power, Step 17, Rev.

019). The site calculation takes into consideration the potential for nitrogen expansion/SI accumulator pressure increase from heat sources within the containment building (i.e., RCS).

Page 11 of 19

Enclosure to ULNRC-06240 Interim Safety Evaluation Status Confirmatory Item 3.2.1.B - Effect of failure of NSR portion of Started TDAFP recirculation line Ameren Missouri is revising the FSGs to provide The licensee needs to confirm that the direction to isolate recirculation flow back to the potential failure of nonsafety-related portions CST. The construction of the new Hardened of the turbine-driven auxiliary feedwater Condensate Storage Tank will minimize the loss of pump recirculation header piping would not auxiliary feedwater from the turbine-driven AFW (1) adversely affect the quantity of pump recirculation header piping.

condensate required for secondary makeup or A Time Sensitive Action is being added to our (2) result in adverse accumulation of water in Sequence of Events Timeline to realign the the CST pipe chase or other areas of the turbine-driven auxiliary feedwater pump plant.

recirculation from the CST to the HCST within three (3) hours of the depletion of water from the CST. This will ensure an adequate quantity of condensate grade water for secondary makeup.

3.2.1.1.A - Use of NOTRUMP Computer Complete.

Code Ameren Missouri has used generic plant ELAP Reliance on the NOTRUMP code for the analyses performed with the NOTRUMP computer ELAP analysis of Westinghouse plants is code to support the mitigating strategy in its Overall limited to the flow conditions prior to reflux Integrated Plan (OIP). The use of NOTRUMP was condensation initiation. This includes limited to the thermal-hydraulic conditions before specifying an acceptable definition for reflux reflux condensation initiates. The initiation of condensation cooling. reflux condensation cooling is defined when the one-hour centered moving average (CMA) of the flow quality at the top of the SG U-tube bend exceeds 0.1 in any one loop.

3.2.1.2.C - RCP SHEILD SEAL Part 21 Complete.

Report This issue has been resolved. NRC Endorsement of Further information is required to assess TR-FSE-14-1-P, RCP SHIELD Seal is documented address the impacts of the Westinghouse 10 in NRC Letter from Mr. Jack Davis, Director CFR Part 21 report, Notification of the Mitigating Strategies Directorate to Mr. James A.

Potential Existence of Defects Pursuant to Gresham, Manager, Regulatory Compliance, 10CFR Part 21, dated July 26, 2013 Westinghouse Electric Company LLC, dated May (ADAMS Accession No. ML13211A168) on 28, 2014 (ML14132A128). (Reference 14) the use of the low seal leakage rate in the ELAP analysis.

Page 12 of 19

Enclosure to ULNRC-06240 Interim Safety Evaluation Status Confirmatory Item 3.2.1.5.A - Potential effect of containment Started.

harsh conditions of needed instrumentation The Gothic Analysis for all modes of operation has been performed. Containment pressure and The Integrated Plan did not address whether temperature remain at acceptable levels. The results instrumentation credited in the ELAP of the Instrumentation EQ Analysis are currently analysis for automatic actuations and for under review.

indications required for the operators to take action are reliable and accurate in the containment harsh conditions. The licensee responded to this question in the audit process by pointing out that the licensee's self-identified open item related to the containment environment (01 2) addresses this issue. The licensee also stated that Westinghouse will be asked to perform a GOTHIC analysis of the containment to demonstrate that acceptable temperature and pressure levels will not be exceeded.

3.2.1.6.A - Validation of FLEX Strategies Started On page 11 of the Integrated Plan, following FLEX Support Guidelines (FSG) have been the sequence of events listed, the licensee prepared for each task. Validation of the FSGs will stated that to confirm the times given, the be performed per the approved NEI Guidance. The licensee will prepare procedures for each validations will assure that required tasks, manual task, perform time study walkthroughs for actions, and decisions for FLEX strategies are each of the tasks under simulated ELAP feasible and may be executed within the constraints conditions, and account for equipment and identified in the Overall Integrated Plan (OIP)/Final tagging and other administrative procedures Integrated Plan (FIP) for Order EA-12-049.

required to perform the task. Further review of the Sequence of Events will be required following this review.

3.2.1.8.A - Borated Coolant Basis Started Adequate basis is needed for the timing and Ameren Missouri will provide the basis for the quantity of the injection of borated coolant as timing and quantity of the injection of borated well as justification that administrative coolant. In addition, Ameren Missouri will provide procedures will ensure that subcriticality the justification that administrative procedures will requirements for future cores are bounded. ensure that subcriticality requirements for future cores are bounded.

Page 13 of 19

Enclosure to ULNRC-06240 Interim Safety Evaluation Status Confirmatory Item 3.2.2.A - SFP Cooling Connection Points Complete.

The licensee stated the water supply for SFP ULNRC-06087, Ameren Missouris second six-cooling involves three connections points, all month OIP submittal update (Reference 12), section located on the exterior of the fuel building. 4.4, stated that the three connections (primary, The connection points on the exterior of the secondary, and spray) for the Spent Fuel Pool fuel building will need to be protected from Cooling strategy had been revised to place these high wind missile strikes. If protection is not connections just inside the building. An evaluation possible, the connection points will need to determined that the connection points would be relocated to the inside of the building. The accessible early in the event.

configuration needs to be resolved.

3.2.2.B - Basis for SFP boil-off time Complete The licensee stated that Westinghouse is The boil off time in the OIP to a level of 15 feet being asked to clarify the basis for the 48 above the fuel racks should have been 35.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

hour boil off time for the SFP level and the The basis is the time to boil from initial conditions resulting information will be provided in a of 140°F and atmospheric pressure is 5.46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br />. An future 6-month update to the Integrated Plan. additional time of 29.79 hours9.143519e-4 days <br />0.0219 hours <br />1.306217e-4 weeks <br />3.00595e-5 months <br /> was calculated for the boil-off time to a level in the SFP 15 feet above the fuel racks.

The time to boil of 5.46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> plus the boil-off time of 29.79 hours9.143519e-4 days <br />0.0219 hours <br />1.306217e-4 weeks <br />3.00595e-5 months <br /> (a total of 35.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) is the basis for a required action time of 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br />. The 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> basis allows for deployment time of SFP Make-Up portable equipment prior to reaching a level of 10 feet above the fuel racks.

The reference to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> appears to be an error from previous draft versions of the OIP predicated on a level of 10 feet above the fuel racks.

3.2.3.A - Containment Condition Analysis Started.

The licensee will use GOTHIC to analyze The Gothic Analysis for all modes of operation has containment conditions and based on the been performed. Containment pressure and results of this evaluation, will develop temperature remain at acceptable levels. The results required actions to ensure maintenance of of the Instrumentation EQ Analysis are currently containment integrity and required instrument under review.

function. The licensee stated that a detailed discussion of the GOTHIC analysis will be provided in a future 6-month update to address containment cooling during an ELAP event.

Page 14 of 19

Enclosure to ULNRC-06240 Interim Safety Evaluation Status Confirmatory Item 3.2.4.2.A - Hydrogen Accumulation Started.

Prevention FSG-45, Temporary Ventilation and Lighting, will The licensee needs to provide details provide detailed written instructions to address this regarding a plan to prevent hydrogen Confirmatory Item. The primary strategy is to accumulation in the battery room during provide positive ventilation via portable fans phases 2 and 3. powered from a small portable generator. FSG-45 also includes instructions to monitor hydrogen levels in the battery rooms.

3.2.4.2.B - Low Temperature Effect on Complete.

Batteries A Gothic Analysis was performed to ensure that the A discussion is needed specifically on the temperature in the battery rooms do not fall below extreme low temperatures effects of the 60°F due to extreme low outside temperatures until batteries capability to perform its function for such time that the FLEX generators are supplying the duration of the ELAP event. the battery chargers. The analysis showed with the original minimum room temperature of 60°F the battery rooms will have a slight temperature increase through the ELAP event with no equipment heaters. The DC powered equipment in the room surrounding the battery room will provide sufficient heat to keep the battery room temperatures above 60°F.

3.2.4.2.C - Coping for Beyond 24 Hours Started.

The licensee stated that an assessment of For coping times beyond 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, temporary room environmental conditions and effects on ventilation will be provided. Callaway will utilize key equipment was performed and the EOP Addendum 20, Control Room Cabinet Door assessment determined that the near term List, FSG-45, Temporary Ventilation and Lighting, actions were considered acceptable for 24 and Attachment II of Emergency Coordinator hours following a BDBEE scenario as Supplemental Guide, Fuel Building Ambient outlined in NEI 12-06. However, the licensee Cooling, to address NEI 12-06 Section 3.2.2, further stated that a future action is required Guideline 10.

to evaluate coping times beyond 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

This action should also address the capability to vent the SFP area.

Page 15 of 19

Enclosure to ULNRC-06240 Interim Safety Evaluation Status Confirmatory Item 3.2.4.3.A - Freeze Protection for FLEX Started.

Equipment Callaway has developed FSG-50, Freeze Protection The potential for (1) freezing of water in for ELAP Response. FSG-50 is being modified to FLEX equipment and (2) crystallization of incorporate ways to keep the Boric Acid Tanks boric acid solution, and therefore the potential (BATs) from freezing. An analysis is being need for heat tracing on Chemical and performed to determine heating requirements for volume control system lines, is still not the Boric Acid Tanks and for the batching of boric addressed for long periods of time during the acid after the BDBEE.

ELAP event scenarios. The licensee stated that additional work is required on these subjects to ensure that the potential for freezing and boron solidification is addressed.

3.2.4.4.A - Temporary Lighting Complete.

The licensee needs to provide information Callaway has developed FSG-45, Temporary concerning the source of power, storage Ventilation and Lighting. This FSG identifies the location and the procedures the operators will various sources of power available tor temporary use to stage temporary lights. lighting. Temporary Lighting will be stored in the Hardened Storage Building.

3.2.4.4.B - Communications Systems Complete Upgrade Callaway has modified the plant radio passive The NRC staff has reviewed the licensee antenna system in the power block to enhance radio communications assessment and has communications. The portable radio cart has been determined that the assessment for procured and is stored in the Hardened Storage communications is reasonable. Confirmation Building. External antennas have been installed in is required to demonstrate that upgrades to the Control Room, TSC, and EOF to support the site's communication systems have been satellite phone communications. Acceptance Testing completed. of the portable radio cart has been completed.

3.2.4.6.A - Temporary Ventilation Started.

There were several references in the Callaway will utilize EOP Addendum 20, Control Integrated Plan regarding the need for Room Cabinet Door List, FSG-45, Temporary analyses and procedures to address Ventilation and Lighting, and Attachment II of ventilation of areas such as equipment rooms Emergency Coordinator Supplemental Guide, Fuel and the spent fuel pool area. The licensee Building Ambient Cooling, to address NEI 12-06 responded to questions regarding habitability Section 3.2.2, Guideline 10.

and stated that the subject of area ventilation will be addressed in a future 6-month update.

Page 16 of 19

Enclosure to ULNRC-06240 Interim Safety Evaluation Status Confirmatory Item 3.2.4.7.A - RWST Missile Protection Started.

The licensee stated the primary strategy for Ameren Missouri has revised our Mode 5 - 6 providing adequate cooling during Modes 5 Shutdown ELAP Strategy due to concerns that the and 6 will take suction from the new RWST RWST is not missile protected. The revised strategy connection on the RWST drain line. The will utilize the new Hardened Condensate Storage licensee further stated that the RWST is Tank (HCST) as a water source and the Boric Acid seismically qualified but not missile Batching Tanks (BABT) as our boron source for protected. The licensee has noted a self- make-up to the Boric Acid Tanks (BATs). The identified open item stating that the RWST RWST will not be a credited source of borated will be missile protected to credit its use in water.

core cooling with SGs not available strategies.

3.2.4.10.A - Effect of Load Shed Evolution Started With regard to the battery load shed Ameren Missouri is formulating the response to this evolution, the licensee did not address the item and will provide the requested information at a general question as to whether the potential later update submittal.

loss of plant functions and resulting consequences has been addressed. Also, the licensee explained that the main generator seal oil pump is powered from the balance of plant batteries but did not address generator hydrogen hazards when the balance of plant batteries are exhausted. Licensee is requested to address these concerns.

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

Page 17 of 19

Enclosure to ULNRC-06240 8 References The following references support the updates to the OIP described in this enclosure.

1. 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
2. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012
3. ULNRC-06024, First Six-Month Status Report In Response To March 12, 2012 Commission Order Modifying Licenses With Regard To Requirements For Mitigation Strategies For Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 29, 2013
4. 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
5. 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
6. ML133224A195, Callaway Plant, Unit 1 - Interim Staff Evaluation Relating To Overall Integrated Plan In Response To Order EA-12-049 (Mitigation Strategies) (TAC No. MF0772), dated December 19, 2013
7. ML13273A514, NEI Shutdown/Refueling Modes White Paper, Rev 0 9/18/13
8. ML13267A382, NRC Letter from Mr. Jack Davis, NRC, to Mr. Joseph E. Pollock, NRC Endorsement of FLEX Generic Open Item for Shutdown Refueling Modes, dated September 30, 2013
9. ML13276A183, NRC Letter from Mr. Jack Davis, NRC, to Mr. Jack Stringfellow, PWROG, NRC Endorsement of PWROG Boron Mixing White Paper, dated January 8, 2014
10. ML13241A186, NEI Letter from Mr. Nicholas Pappas, Senior Project Manager, Nuclear Energy Institute, to NRC, Mr. Jack R. Davis, Director Mitigating Strategies Directorate, EA-12-049 Mitigating Strategies Resolution of Extended Battery Duty Cycles Generic Concern, dated August 27, 2013
11. ML13241A188, NRC Letter from Mr. Jack Davis, Director Mitigating Strategies Directorate to Mr.

Joseph E. Pollock, Vice President, Nuclear Operations, Nuclear Energy Institute, Battery Life White Paper Endorsement, dated September 16, 2013

12. ULNRC-06087, Second Six-Month Status Report In Response To March 12, 2012 Commission Order Modifying Licenses With Regard To Requirements For Mitigation Strategies For Beyond-Design-Basis External Events (Order Number EA-12-049)
13. ULNRC-06135, Third Six-Month Status Report In Response to March 12, 2012 Commission Order Modifying Licenses With Regard To Requirements For Mitigation Strategies For Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 28, 2014 Page 18 of 19

Enclosure to ULNRC-06240

14. ML14132A128, NRC Letter from Mr. Jack Davis, Director, Mitigating Strategies Directorate to Mr. James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company LLC, dated May 28, 2014.
15. ML14265A107, NRC Letter from Mr. Jack Davis, Director Mitigating Strategies Directorate to Mr.

Joseph E. Pollock, Vice President, Nuclear Operations, Nuclear Energy Institute, Staff Assessment of National SAFER Response Centers Established in Response to Order EA-12-049, dated September 26, 2014.

16. ULNRC-06184, Fourth Six-Month Status Report In Response to March 12, 2012 Commission Order Modifying Licenses With Regard To Requirements For Mitigation Strategies For Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 26, 2015 Page 19 of 19
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