ULNRC-06417, Path Forward for Resolution of GSI-191
| ML18065A709 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/06/2018 |
| From: | Banker S Ameren Missouri, Union Electric Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GSI-191, ULNRC-06417 | |
| Download: ML18065A709 (5) | |
Text
4 Stephanie Banker Vice President Engineering Ameren Missouri MISSOURI Callaway Energy Center T 573-864-1323 F 573-676-4056 March 6,2018 ULNRC-0641 7 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington. DC 20555-0001 10 CfR 50.54(t)
Ladies and Gentlemen:
DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.
FACILITY OPERATING LICENSE NPF-30 PATH FORWARD FOR RESOLUTION Of GSI-191
References:
- 1) Ameren Missouri letter ULNRC-05989, Path Forward for Resolution of GSI-191, dated May 16, 2013 (Accession No. ML13136A290).
- 2) Arneren Missouri Letter ULNRC-06 100, Path Forward for Resolution of GSI-191, dated March 31, 2014 (Accession No. ML14090A355).
- 3) Generic Letter (GL) 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors, dated September 13, 2004 (Accession No. ML042360586).
- 4) NRC Policy Issue SECY-12-0093, Closure Options for Generic Safety Issue
- 191, Assessment of Debris Accumulation on Pressurized-Water Reactor Sump Performance, dated July 9, 2012 (Accession No. ML121310648).
In the letter identified as Reference 1, Union Electric Co. (dba Arneren Missouri) described the closure path being taken for resolution of Generic Letter (GL) 2004-02 (Reference 3) and Generic Safety Issue (GSI) -191 (Reference 4) for the Callaway Plant. Specifically, Arneren Missouri proposed to achieve resolution of GL 2004-02 (GSI-191) by implementing Option 2b, Full Risk-Informed Resolution Path, of SECY-12-0093 (Reference 4), utilizing the methodology developed by South Texas Project (SIP). This resolution path is still being pursued by Ameren Missouri and is ongoing.
In Reference 1, it was noted that the necessary request/correspondence for resolving GSI-1 91 at Callaway Plant would be submitted by December 31, 2015. This was identified as a commitment (Commitment No. 50261) in Attachment 2 of the letter. In Reference 2, Ameren Missouri subsequently revised its submittal commitment, noting that the submittal would either be made by a P.O. Box 620 Fulton, fy10 65251 ArnerenN4issouri.con
ULNRC-0641 7 March 6. 2018 Page 2 of 4 new, specified date or within one year following issuance of the Safety Evaluation for South Texas Projects GSI-191 resolution submittal. It was also clarified that the GSI-191 closure correspondence to be submitted for CaHaway would likely be in the form of a license amendment request and proposed regulatory exemption (similar to STPs submittal).
Due to activities that have transpired subsequent to the Reference 2 letter, including submittal of Westinghouse topical report WCAP-1778$, Comprehensive Analysis and Test Programs for GSI-1 91 Closure, by the Pressurized Water Reactor Owners Group (PWROG) to support GSI-191 closure.
Ameren Missouri is submitting this letter to again revise its submittal coiiirnitment. Revision of the submittal commitment is based on recognizing that the sticcess path for the risk-informed Option 2b approach is dependent on completion of the NRC staffs review and approval of WCAP-1778$,
including issuance of a Safety Evaluation (SE) for the report. At present, the PWROG is resolving the NRC staffs comments and requests for additional information, and by the current schedule, NRC issuance of the SE for WCAP-177$8 is projected to be beyond Callaways current submittal commitment date.
Based on the above, it is proposed that the date for submitting the GSI-l91 closure correspondence for Callaway Plant be extended to September 26, 2019, or to one year after issuance of the NRCs SE for WCAP-17788, whichever is later. This extension of Ameren Missouris submittal date will allow scifficient time for performing the necessary analysis using the WCAP-1 7788 methodology (when approved by the NRC). The revised commitment is documented in the attachment (Attachment I ) of this letter.
If you have any questions concerning the content of this letter, please contact Roger Wink, Regulatory Affairs Manager, at 573-310-7025.
I declare under penalty of perjury that the foregoing is true and correct.
Sincerely, Stephanie Banker Vice President
- Engineering Executed on: : Revised Commitment
ULNRC-0641 7 March 6, 2018 Page 3 of 4 cc:
Mr. Kriss M. Kennedy 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 Kios Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8H4 Washington, DC 20555-2738
ULNRC-064l 7 March 6. 201 8 Page 4 of4 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. Herrrnann S. P. Banker
- 3. 1. Cox R. C. Wink S. L. Abel T. B. Elwood L. E. Eitel R. J. Andreasen NSRB Secretary STARS Regulatory Affairs Mr. Jay Silberg (Pillsbury Winthrop Shaw Pittrnan LLP) to ULNRC-064 17 Page 1 of 1 Revised Commitment Previous Commitment ner ULNRC-05989 COMMITM ENTS Due Date/Event Commitment Number Ameren Missouri will submit the necessary December 31, 2015 50261 request/correspondence (e.g., regulatory exemption request) for resolving GSI-191 at Callaway PLant pursuant to Option 2b (risk informed approach).
Current Commitment 50261 per ULNRC-06100 COMMITMENTS Due Date/Event Commitment Number Ameren Missouri will submit closure September 1, 2017 50261, Rev.
1 correspondence (e.g., License Amendment and regulatory exemption request) for OR resolving GSI-191 at Callaway Energy Center pursuant to SECY-12-0093 Option 1 year following issuance of the 2b (risk-informed approach).
Safety Evaluation for the STP risk-informed GS 1-1 91 resolution submittal, whichever is later.
Proposed Chan e to Commitment 50261 COMMITMENTS Due Date/Event Commitment 1
Number Ameren Missouri will submit closure September 26, 2019 50261, Rev. 2 correspondence (e.g., License Amendment and regulatory exemption request) for OR resolving GSI-191 at Callaway Energy Center pursuant to SECY-12-0093 Option 1 year following issuance of the 2b (risk-informed approach).
Safety Evaluation for WCAP 1 7788, Comprehensive Analysis and Test Programs for GSI-191 Closure whichever is later.