ULNRC-06491, Additional Supplement to License Amendment Request for Addition of New Technical Specification 3.7.20, Class IE Electrical Equipment Air Conditioning (A/C) System (LDCN 16-0013)
| ML19066A314 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/07/2019 |
| From: | Wink R Ameren Missouri, Union Electric Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LDCN 16-0013, ULNRC-06491 | |
| Download: ML19066A314 (12) | |
Text
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VAmeren MISSOURI Callaway Plant March 7, 2019 ULNRC-06491 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 50.90 Ladies and Gentlemen:
DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.
RENEWED FACILITY OPERATING LICENSE NPF-30 ADDITIONA L SUPPLEMEN T TO LICENSE AMENDMENT REQUEST FOR ADDITION OF NEW TECHNICAL SPECIFICATION 3.7.20, "CLASS lE ELECTRICAL EQUIPMENT AIR CONDITION ING (A/C) SYSTEM" (LDCN 16-0013)
References:
- 1. Ameren Missouri letter ULNRC-06401, "License Amendment Request for Addition of New Technical Specification 3.7.20, 'Class lE Electrical Equipment Air Conditioning (A/C) System' (LDCN 16-0013)," dated March 9, 2018 (ADAMS Accession No. ML18068A685)
- 2. NRC letter, "Callaway Plant, Unit No. 1 - Regulatory Audit Summary Regarding License Amendment Request to Incorporate a New Technical Specification 3.7.20 (EPID-L-2018-LLA-0062)," dated January 4, 2019 (ADAMS Accession No. ML18353B016)
- 3. NRC Request for Additional Information (received via e-mail, "Formal Release of RAis, Ref:
Callaway Plant Class IE LAR, L-2018-LLA-0062" on January 9, 2019) (ADAMS Accession No. ML19010AOIO)
- 4. Ameren Missouri letter ULNRC-06477, "Supplement to License Amendment Request for Addition of New Technical Specification 3.7.20, 'Class IE Electrical Equipment Air Conditioning (A/C) System' (LDCN 16-0013)," dated January 23, 2019 (ADAMS Accession No. ML19024A470)
- 5. Ameren Missouri letter ULNRC-06482, "Response to Request for Additional Information Pertaining to License Amendment Request for Addition of New Technical Specification 3.7.20, 'Class IE Electrical Equipment Air Conditioning (A/C) System' (LDCN 16-0013),"
dated February 8, 2019 (ADAMS Accession No. ML19039A353)
- 6. NRC letter, "Callaway Plant, Unit No. 1 - License Condition Associated with License Amendment Regarding Addition of New Technical Specification 3.7.20, 'Class IE Electrical Equipment Air Conditioning (A/C) System' (EPID L-2018-LLA-0062)," dated February 21, 2019 (ADAMS Accession No. ML19044A505)
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ULNRC-06491 March 7, 2019 Page 2 of6 By letter dated March 9, 2018 (Reference 1) and as supplemented by letter dated January 23, 2019 (Reference 4), Union Electric Company (dba Ameren Missouri) submitted a License Amendment Request (LAR) for the Callaway Plant (Callaway). Per the requested license amendment, the Callaway Technical Specifications would be revised to incorporate a new Technical Specification (TS), i.e., TS 3. 7.20, for the Class IE Electrical Equipment Air Conditioning (A/C) System at Callaway. In addition, TS 5.5.11, "Ventilation Filter Testing Program," would be revised per the LAR by changing the value specified for the wattage required to be dissipated by the heater in each of the two control room pressurization trains from 15 +/- 2 kW to 5 +/- 1 kW.
As explained in the LAR, the Class IE Electrical Equipment A/C System provides area cooling within the Control Building for the Class IE electrical switchgear, as well as for safety-related inverters, batteries and battery chargers. However, this system is not specifically addressed in the Technical Specifications. Ameren Missouri's proposed LAR will incorporate appropriate TS requirements for the system, including a Condition and Required Actions for when one Class IE electrical equipment A/C train is declared inoperable.
The proposed Required Actions for the noted Condition include an allowance ofup to 30 days for restoring the inoperable Class IE electrical equipment A/C train to Operable status, provided compensatory actions are taken to monitor equipment room temperatures and ensure they remain within limits as supported by placing one train of the "supplemental cooling system" into service (to be described in the Bases for proposed TS 3.7.20 and in the FSAR). The supplemental cooling system is being installed per plant modification MP 16-0024 and will augment the capability of one operable Class IE electrical equipment A/C train to cool the rooms/areas of both trains of Class IE electrical equipment. MP 16-0024 will be completed in the forthcoming refueling outage at Callaway (i.e.,
Refuel 23, scheduled to begin on April 1, 2019), as completion of the modification is essential for implementation of the anticipated license amendment.
Another plant modification is planned for completion during Refuel 23 in connection with the requested license amendment. Specifically, plant modification MP 17-0024 will reduce the wattage of the charcoal heaters in the pressurization trains associated with the control room ventilation system. This will reduce the heat load seen by either or both of the Class 1E electrical equipment A/C trains since the Class IE Electrical Equipment A/C System interacts with the control room ventilation system within the overall Control Building ventilation envelope. Credit is taken for this modification in the heat load calculations performed in support of the LAR, and it is the basis for the requested change to TS 5.5.11 (noted above).
In the Reference 1 letter, and as subsequently modified in Attachment 5 of the Reference 4 letter dated January 23, 2019, specific commitments were identified for completion of each the above noted modifications and for making needed changes to Callaway's Emergency Operating Procedures (EOPs) for the supplemental cooling system. These commitments were made in recognition of the need to have the modifications completed and the EOP changes ready for implementation of the requested license amendment. However, in a letter recently issued on February 21, 2019 (identified as Reference 6), the NRC stated its intention for Callaway "to elevate all of the commitments in Attachment 5 of the letter dated January 23, 2019, as a condition of the license by referring to it in a future Section 2.C.18" of Callaway's
ULNRC-06491 March 7, 2019 Page 3 of6 Operating License. Per the NRC's letter, Ameren Missouri was asked to provide marked-up pages (and "clean" pages) for the proposed license condition, as a supplement to the LAR, by March 8, 2019.
In addition, in support of the proposed license condition and to facilitate issuance of the NRC's Safety Evaluation in a timely manner, Ameren Missouri was asked per the NRC's letter to perform a final review of the commitments in Attachment 5 of the Reference 4 letter in order to prevent any unintended consequences of their application as a license condition, and then to provide confirmation of this review in the letter to be submitted by March 8, 2019.
In accordance with what was requested in the NRC's February 21, 2019 letter, this letter is hereby submitted by Ameren Missouri to request incorporation of the noted license condition and to provide confirmation that the commitments identified in Attachment 5 have been reviewed and are still valid and acceptable for referencing in the proposed license condition. The license condition itself is proposed to be added as item/condition (18) to Section 2.C of the Callaway Operating License, which would read as follows:
(18) Implementation Actions for New Technical Specification 3.7.20 The planned plant modifications and emergency operating procedure changes described as commitments in Attachment 5 of Ameren Missouri letter ULNRC-06477, "Supplement to License Amendment Request for Addition of New Technical Specification 3.7.20, 'Class 1E Electrical Equipment Air Conditioning (A/C) System' (LDCN 16-0013)," dated January 23, 2019, shall be completed prior to implementation of the license amendment requested per Ameren Missouri letter ULNRC-06401, "License Amendment Request for Addition of New Technical Specification 3.7.20, 'Class 1E Electrical Equipment Air Conditioning (A/C) System' (LDCN 16-0013)," dated March 9, 2018, as supplemented by the noted January 23, 2019 letter (ULNRC-06477) and Ameren Missouri letter ULNRC-06491, "Additional Supplement to License Amendment Request for Addition of New Technical Specification 3.7.20, 'Class 1E Electrical Equipment Air Conditioning (A/C) System' (LDCN 16-0013)," dated March 7, 2019. Completion of the planned plant modifications means physical completion, including completion of the post-modification testing.
A mark-up of the affected page of the Operating License showing the proposed license condition and where it is to be placed within the license is provided as Attachment 1 to this letter. A "clean" Operating License page reflecting placement of the proposed license condition is provided as Attachment 2.
Although the proposed addition of the noted license condition is regarded as an additional supplement to the LAR submitted per the Reference 1 application and supplemented by the Reference 4 letter, it should be noted that the proposed change to the Operating License has no impact on those letters or any of the other correspondence related to the LAR, i.e., References 2, 3 and 5. No changes to the TS changes proposed per the LAR are being made. Further, this additional supplement does not change the "No Significant Hazards Consideration" conclusions reached in the LAR, nor does it change the conclusion regarding no need for an environmental assessment based on the categorical exclusion provisions of 10 CFR 51.22. As already noted, submittal of this additional supplement is intended to facilitate issuance of the NRC's Safety Evaluation in order to support implementatio n of the requested amendment during the forthcoming refueling outage which is scheduled to begin on April 1, 2019.
ULNRC-06491 March 7, 2019 Page 4 of 6 The Callaway Onsite Review Committee has reviewed and approved this LAR supplement for submittal to the NRC. In accordance with 10 CFR 50.91 "Notice for public comment; State consultation," Section (b)(l), a copy of this supplement to Ameren Missouri's LAR is being provided to the designated Missouri State official.
If there are any questions regarding this LAR supplement, please contact Mr. Tom Elwood at 314-225-1905.
I declare under penalty of perjury that the foregoing is true and correct.
Sincerely, ~,,_ /)
/2c_J_/ L
/R~fr C. Wink Manager, Regulatory Affairs Executed on: 3 J'l Attachments to this letter:
- 1. Marked-up Operating License Page
- 2. Operating License Page Reflecting Incorporation of Proposed Change
ULNRC-06491 March 7, 2019 Page 5 of 6 cc: Mr. Scott A. Morris 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 09E3 Washington, DC 20555-0001
ULNRC-06491 March 7, 2019 Page 6 of6 Index and send hardcopy to QA File A160.0761 Hardcopy:
Certrec Corporation 6100 Western Place, Suite 1050 Fort Worth, TX 76107 (Certrec receives ALL attachments as long as they are non-safeguard s and may be publicly disclosed.)
Electronic distribution for the following can be made via Tech Spec ULNRC Distribution:
F. M. Diya T. E. Herrmann B. L. Cox F. J. Bianco S. P. Banker L. H. Kanuckel S. L. Abel R. C. Wink T. B. Elwood B. D. Richardson D.R. Waller Corporate Communicatio ns NSRB Secretary STARS Regulatory Affairs Mr. Jay Silberg (Pillsbury Winthrop Shaw Pittman LLP)
Missouri Public Service Commission Mr. Steve Feeler (DNR)
Mr. Dru Buntin (DNR) to ULNRC-06491 Attachment 1 to ULNRC-06491 Marked-up Operating License Page 2 Pages
Attachment I to ULNRC-06491 Page I of2 Operating License Revision 080
- 1. In order to ensure that the threads for RPV closure stud hole No. 18 can perform their intended function throughout the period of extended operation, UE shall remove stuck stud No. 18. If repair of stud hole No. 18 is required following removal of the stud, the repair plan shall include inspection of the stud hole prior to and after the completion of the repair. *
- 2. In order to ensure that RPV stud holes with damaged threads can continue to perform their intended function throughout the period of extended operation, UE shall perform a laser inspection for the threads of repaired RPV stud hol~ location Nos. 2, 4, 5, 7, 9, and 53. If inspection lNSER.T ATTACHED iEXT of these ~p~ stud holes reveals that there is ad~i.tiona~
( , degradation m any of these stud holes, the cond1t1on will O'- LICENSE CONPITION 2.C 18,. be entered in the Corrective Action Program for evaluation and corrective action, and UE shall also inspect the remaining repaired RPV stud hole locations (Nos. 13, 25, D. n xemp 10n rom certain requrremen s of Appendix to 10 CFR Part 50, are described in the October 9, 1984 staff letter. This exemption is authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest. Therefore, this exemption is hereby granted pursuant to 10 CFR 50.12. With the granting of this exemption the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.
E. UE shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 10 CFR 73.21, are entitled: "Callaway Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision O" submitted by letter dated October 20, 2004, as supplemented by the letter May 11, 2006.
UE shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The Callaway Plant Unit 1 CSP was approved by License Amendment No. 203, as supplemented by changes approved per License Amendment No. 214.
F. Deleted per Amendment No. 169.
G. UE shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.
Renewed License No. NPF_:-30 ~
Amendment No. "21+"'"
A140.0001 to ULNRC-06491 Page 2 of2 Text for License Condition 2.C(18)
(18) Implementation Actions for New Technical Specification 3.7.20 The planned plant modifications and emergency operating procedure changes described as commitments in Attachment 5 of Ameren Missouri letter ULNRC-06477, "Supplement to License Amendment Request for Addition of New Technical Specification 3.7.20, 'Class 1E Electrical Equipment Air Conditioning (A/C) System' (LDCN 16-0013)," dated January 23, 2019, shall be completed prior to implementation of the license amendment requested per Ameren Missouri letter ULNRC-06401, "License Amendment Request for Addition of New Technical Specification 3.7.20, 'Class 1E Electrical Equipment Air Conditioning (A/C)
System' (LDCN 16-0013)," dated March 9, 2018, as supplemented by the noted January 23, 2019 letter (ULNRC-06477) and Ameren Missouri letter ULNRC-06491, "Additional Supplement to License Amendment Request for Addition of New Technical Specification 3.7.20, 'Class 1E Electrical Equipment Air Conditioning (A/C) System' (LDCN 16-0013),"
dated March 7, 2019. Completion of the planned plant modifications means physical completion, including completion of the post-modification testing.
to ULNRC-06491 Attachment 2 to ULNRC-06491 Operating License Page Reflecting Incorporation of Proposed Change 2 Pages to Operating License ULNRC-06491 Revision 080 Page 1 of2 1. In order to ensure that the threads for RPV closure stud hole No. 18 can perform their intended functionthroug hout the period of extended operation, UE shall remove stuck stud No. 18. If repair of stud hole No. 18 is required following removal of the stud, the repair plan shall include inspection of the stud hole prior to and after the completion of the repair.
- 2. In order to ensure that RPV stud holes with damaged threads can continue to perform their intended function throughout the period of extended operation, UE shall perform a laser inspection for the threads of repaired RPV stud hole location Nos. 2, 4, 5, 7, 9, and 53. If inspection of these RPV stud holes reveals that there is additional degradation in any of these stud holes, the condition will be entered in the Corrective Action Program forevaluation and corrective action, and UE shall also inspect the remaining repaired RPV stud hole locations (Nos. 13, 25, 39 and 54).
(18) Implementation Actions for New Technical Specification 3.7.20 The planned plant modifications and emergency operating procedure changes described as commitments in Attachment 5 of Ameren Missouri letter ULNRC-06477, "Supplement to License Amendment Request for Addition of New Technical Specification 3. 7.20, 'Class 1E Electrical Equipment Air Conditioning (A/C) System' (LDCN 16-0013),"
dated January 23, 2019, shall be completed prior to implementation of the license amendment requested per Ameren Missouri letter ULNRC-06401, "License Amendment Request for Addition of New Technical Specification 3.7.20, 'Class 1E Electrical Equipment Air Conditioning (A/C) System' (LDCN 16-0013)," dated March 9, 2018, as supplemented by the noted January 23, 2019 letter (ULNRC-0647 7) and Ameren Missouri letter ULNRC-06491, "Additional Supplement to License Amendment Request for Addition of New Technical Specification 3. 7.20, 'Class 1E Electrical Equipment Air Conditioning (A/C) System' (LDCN 16-0013)," dated March 7, 2019. Completion of the planned plant modifications means physical completion, including completion of the post-modification testing.
D. An Exemption from certain requirements of Appendix J to 10 CFR Part 50, are described in the October 9, 1984 staff letter. This exemption is authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest. Therefore, this exemption is hereby granted pursuant to 10 CFR 50.12. With the granting of this exemption the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.
E. UE shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authorityof Renewed License No. NPF-30 Amendment No.
A140.0001 to ULNRC-06491 Operating License Page 2 of2 Revision 080 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 10 CFR 73.21, are entitled: "Callaway Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision O" submitted by letter dated October 20, 2004, as supplemented by the letter May 11, 2006.
UE shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The Callaway Plant Unit 1 CSP was approved by License Amendment No. 203, as supplemented by changes approved per License Amendment No. 214.
F. Deleted per Amendment No. 169.
G. UE shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.
H. This renewed license is effective as of the date of issuance and shall expire at Midnight on October 18, 2044.
FOR THE NUCLEAR REGULATORY COMMISSION IRA/
William M. Dean, Director Office of Nuclear Reactor Regulations Attachments/Appendices:
- 1. Attachment 1 (Deleted per Amendment No. 169)
- 2. Attachment 2 (Deleted per Amendment No. 169)
- 3. Appendix A - Technical Specifications (NUREG-1058, Revision 1)
- 4. Appendix B - Environmental Protection Plan
- 5. Appendix C - Additional Conditions Date of Issuance: March._ _6=---* 2015 Renewed License No. NPF-30 Amendment No.
A140.0001