ULNRC-06528, Path Forward for Resolution of GL 2004-02

Path Forward for Resolution of GL 2004-02

ML19268A169
Person / Time
Site:	Callaway
Issue date:	09/24/2019
From:	Banker S Ameren Missouri, Union Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ULNRC-06528
Download: ML19268A169 (7)

Text

4\

Stephanie Banker r Vice President Engineering Ameren Missouri Callaway Energy Center F 573-676-4056 September 24, 2019 ULNRC-06528 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-000 1 10 CfR 50.54(f)

Ladies and Gentlemen:

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

RENEWED FACILITY OPERATING LICENSE NPF-30 PATH FORWARD FOR RESOLUTION OF GL 2004-02 In the letter identified as Reference 1 (in the list of references provided on page 3 of this letter), Union Electric Co. (dba Ameren Missouri) described the closure path being taken for resolution of Generic Letter (GL) 2004-02 (Reference 3) and Generic Issue GI-191 (formerly Generic Safety Issue GSI-191) for the Callaway Plant. Specifically, Ameren Missouri proposed to achieve resolution of GL 2004-02 and GI-1 91 by implementing Option 2b, Full Risk-Informed Resolution Path, of SECY-12-0093 (Reference 4), utilizing the methodology developed by South Texas Project (STP). This resolution path is still being pursued by Ameren Missouri and is ongoing.

Per Reference 1 it was initially noted that the necessary applicationlcorrespondence for resolving GI 1 9 1 at Callaway Plant would be submitted by December 3 1 201 5 This was identified as a commitment (Commitment No. 5026 1) in Attachment 2 of the letter. In References 2 and 5, Ameren Missouri subsequently revised its submittal commitment. In Reference 2, it was clarified that the GI 1 9 1 closure correspondence to be submitted for Callaway would likely be in the form of a license amendment request (LAR) and proposed regulatory exemption (similar to STPs submittal). The current commitment described in Attachment 1 to Reference 5 states that the submittal will either be made by September 26, 201 9, or one year afier issuance of the NRCs Safety Evaluation (SE) for WCAP-1 7788, Comprehensive Analysis and Test Programs for GSI-1 91 Closure, whichever is later.

Several activities have transpired subsequent to the Reference 5 letter, including actions by the NRC staff regarding closure of GI-1 9 1 (Reference 6) and issuance of a Technical Evaluation Letter (Reference 7), in lieu of a Safety Evaluation that identified unresolved issues concerning WCAP 17788. In 2018, a Technical Specification (TS) traveler developed by the Technical Specifications Task Force (TSTF), i.e., TSTF-567, Revision 1, Add Containment Sump TS to Address GSI-19l 83 1 5 County Road 459 : Steedrnan, NIJ 65077 : \.nierenlv{issouri.coni

09/24/2019 ULNRC-06528 Page2 of 5 Issues, was approved by the NRC and made available to licensees (Reference 8) for proposing appropriate Technical Specification changes in connection with their GL 2004-02 responses.

Recently, a pre-submittal meeting was conducted with the NRC in which representatives from and for Ameren Missouri provided a presentation/summary of the combined LAR and exemption request to be submitted as the final response to GL 2004-02 for Callaway. Insights from that meeting are now being factored into the intended submittal. In light of these activities, additional time is needed to finalize the complete submittal.

Based on the above, it is proposed that the date for submitting the GL 2004-02 closure correspondence for Callaway Plant be extended to June 1 1 2020. The revised submittal commitment is documented in the attachment (Attachment 1) to this letter.

For any questions concerning the contents 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:  ? /cL%/ t  : Revised Commitment

09/24/2019 ULNRC-06528 Page3of5 References 1 . Ameren Missouri letter ULNRC-05989, Path Forward for Resolution of GSI-l 91 dated May 16, 20 1 3 (Accession No. ML13136A290).

2. Ameren Missouri Letter ULNRC-06100, Path forward for Resolution ofGSI-191, dated March 31, 2014 (AccessionNo. 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. ML0423605$6).

4. NRC Policy Issue SECY-12-0093, Closure Options for Generic Safety Issue 191, Assessment ofDebris Accumulation on Pressurized-Water Reactor Sump Performance, dated July 9, 2012 (Accession No. ML121310648).

5 . Ameren Missouri Letter ULNRC-0641 7, Path Forward for Resolution of G$I-1 9 1 dated March 6, 2018 (AccessionNo. ML14090A355).

6. NRC Memorandum from R. V. Furstenau to H. K. Nieh, Closure of Generic Issue GI- 191, Assessment ofDebris Accumulation on PWR Sump Performance, dated July 23, 2019 (Accession No. ML19203A299).

7. NRC Memorandum from V. G. Cusumano to M. Gavrilas, Technical Evaluation Report of In-Vessel Debris Effects, dated June 13, 2019 (Accession No. ML19178A252).

NRC letter from V. Cusumano to Technical Specifications Task force, Final Safety Evaluations of Technical Specifications Task Force Traveler TSTf-567, Revision 1 Add Containment Sump TS to address GSI-191 Issues (EPID: L-2017-PMP-0005), dated July 3, 2018 (Accession No. ML18109A071)

• - . - w-__ w- 1

09/24/2019 ULNRC-06528 Page4of5 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 Kios Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O9E3 Washington, DC 20555-000 1

- _. I- - rIW J1-

09/24/2019 ULNRC-06528 Page5 of 5 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 6100 Western Place, Suite 1050 FortWorth,TX 76107

( 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 B. L. Cox F. J. Bianco S. P. Banker R. C. Wink E. C. Olson T. B. Elwood L. E. Eitel R. J. Andreasen NSRB Secretary STARS Regulatory Affairs Mr. Jay Silberg (Pillsbury Winthrop Shaw Pittman LLP)

-. tr I

.. W flhT I I to ULNRC-06528 Page 1 of 1 Attachment 1 Revised Commitment Current Commitment per ULNRC-06417 COMMITMENTS Due Date/Event Commitment Number Ameren Missouri will submit closure September 26, 2019 5026 1 Rev. 2 correspondence (e.g., License Amendment and regulatory exemption request) for resolving OR GSI- 191 at Callaway Energy Center pursuant to SECY-12-0093 Option 2b (risk-informed 1 year following issuance of approach). the Safety Evaluation for WCAP-1 7788, Comprehensive Analysis and Test Programs for GSI 191 Closure Whichever_is_later.

Proposed Change to Commitment 50261 COMMITMENTS Due Date/Event Commitment Number Ameren Missouri will submit closure June 1 1 2020

, 5026 1 Rev. 3 correspondence (e.g., a combined license amendment and regulatory exemption request) for resolving GL 2004-02 at Callaway Energy Center pursuant to SECY-12-0093 Option 2b (risk-informed approach).

83 15 County Road 459 : Steedman, MO 65077 : ArnerenMissourLcorn

COMMITMENT REVISION, INITIATION, DELETION REQUEST (CRIDR)

ORIGINATOR

1. Check the appropriate request: Revision LI Initiation LI Implementation I Completion

2. Name (print) I. P. Kovar 3. Date 09/24/2019

4. Commitment No. 50261 (RARL will enter this in case of initiation)

5. Commitment

Description:

See Attached, or LI See CA2358

6. Source document, section, and date ULNRC-06528, Attachment 1 September 26, 2019

7. Reference documents, sections, and dates ULNRC-06417, Attachment 1 March 6, 2018

( use attachments if necessary)

8. Justification for revision, initiation, or deletion: (attach additional pages as required)

To address NRC staff actions to close GI-191 (formerly GSI-191), issue a Technical Evaluation Report that identified unresolved issues concerning WCAP-17788, and approve TSTF-567, Rev. 1 and the insights ,

gained from the recent pre-submittal meeting, additional time will be needed to prepare the submittal.

CRITERIA FOR A COMMITMENT

9. Place an x by any of the following items that apply to the commitment text (initiation and revision only):

a) It is a written promise by Ameren Missouri Callaway Plant to the NRC to perform an action by a given date.

b) LI It is a written promise by Ameren Missouri Callaway Plant to another regulatory agency to perform an action by a given date.

c) LI It is a written promise by Ameren Missouri Callaway Plant to another entity to perform an action by a given date.

If none of the items can be marked, this text may not represent a commitment. In this case, contact RARL for further directions.

10. Action Documents CR 200910285-052 11. Recommended Responsible Person(s) J. P. Kovar

12. Approving Manager q;5L((

tIcZ41 19 Forward CRDR package to RARt

13. Commitment coordinator 14. Date Entered CTS Instructions

1. -3. Self explanatory

4. Enter the number ofthe commitment being revised or deleted.

5. Provide a description ofthe Commitment by either attaching a sheet to this form, or via the CA2358.

6. Enter the title ofthe source document, the section ofthe source document that contains the commitment text, and the date the document was issued. The source document is the document in which Ameren Missouri commits an action to outside organizations.

7 . Enter the title of the source documents, the sections containing the reference text, and the date the documents were issued.

Reference documents are any documents that contain redundant, similar, or supporting information with respect to the source text.

8. Enter the reason for revising, initiating, or deleting this commitment.

9. Select the applicable choice. Ifnone apply, this may not be a commitment, bitt an obligation.

10. Enter document(s) which satisfy the commitment (if known).

11 . Enter responsible person(s) (if known).

12. Signature ofthe Approving manager Return CRIDR to RARL Z170.0050 Pagelofi CA1571 Rev. 000 APA-ZZ-00540