ULNRC-06735, Response to Request for Additional Information Regarding Request for License Amendment and Regulatory Exemptions for Risk-Informed Approach to Address GSI-191 and Respond to Generic Letter 2004-02 (LDCN 19-0014).

Response to Request for Additional Information Regarding Request for License Amendment and Regulatory Exemptions for Risk-Informed Approach to Address GSI-191 and Respond to Generic Letter 2004-02 (LDCN 19-0014).

ML22146A338
Person / Time
Site:	Callaway
Issue date:	05/27/2022
From:	Witt T Ameren Missouri, Union Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML22146A337	List: ML22146A339 ULNRC-06735, Response to Request for Additional Information Regarding Request for License Amendment and Regulatory Exemptions for Risk-Informed Approach to Address GSI-191 and Respond to Generic Letter 2004-02 (LDCN 19-0014).
References
EPID L-2021-LLA-0059, EPID L-2021-LLE-0021, ULNRC-06735
Download: ML22146A338 (5)

Text

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WAmeren Callaway Plant MISSOURI May 26, 2022 ULNRC-06735 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 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING REQUEST FOR LICENSE AMENDMENT AND REGULATORY EXEMPTIONS FOR RISK-INFORMED APPROACH TO ADDRESS GSI-191 AND RESPOND TO GENERIC LETTER 2004-02 (LDCN 19-0014)

(EPID L-2021-LLA-0059 AND EPID L-2021-LLE-0021)

On March 31, 2021, and per Reference 1 included in the list of references on page 3 of this letter, Ameren Missouri submitted a license amendment request (LAR) to the NRC, in combination with a request for regulatory exemptions, in order to adopt a risk-informed approach for resolving GSI-191 and responding to Generic Letter (GL) 2004-02, for the Callaway plant.

Subsequent to submittal of the Reference 1 LAR, a number ofletters/supplemep.ts were submitted in support of the LAR and/or in response to NRC correspondence regarding the LAR, as identified in the list ofreferences on page 3. Specifically, initial supplements to the LAR were submitted by Ameren Missouri per References 2, 3, and 4. In addition, an audit was planned and executed by the NRC in August 2021 for the LAR, which required correspondence to be exchanged between the NRC and Ameren Missouri. That correspondence included an NRC letter for providing the audit plan in advance of the audit (identified as Reference 5) as well as an NRC letter that provided an audit summary following the audit (per Reference 6). Responses to the various audit items (i.e.,

questions/requests addressed during or from the audit) were documented and provided via the Ameren Missouri letters identified as References 7 and 8.

This letter is submitted in order to respond to a request for additional information (RAI) electronically received (via e-mail) from the NRC on April 5, 2022, which is identified as Reference 9 (on page 3 of this letter). The responses to the individual requests/questions contained in the RAI are hereby provided in the enclosure to this letter.

, 8315 County Road 459 Steedman, MO 65077 AmerenMissouri.com

ULNRC-06735 May 26, 2022 Page 2 of 5 It is acknowledged that this letter for submitting the enclosed RAI responses is being submitted after the target date that was discussed with the NRC staff and identified in Reference 9. The delay was due to inadequate coordination between onsite personnel and the contractor providing essential input to the responses, during the current refueling outage. The untimely submittal has been documented in a condition report and is being addressed accordingly.

In regard to the Reference 1 LAR, it should be noted that the additional information provided in the attachment to this letter has no impact on 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.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," Section (b)(l), a copy of this supplement to the Reference 1 LAR and regulatory exemption request is being provided to the designated Missouri State official. This supplement was reviewed by the Callaway Plant Onsite Review Committee.

For any questions regarding this submittal, please contact Tom Elwood (Supervisor, Regulatory Affairs - Licensing) at (314) 225-1905.

I declare under penalty of perjury that the foregoing is true and correct.

Sincerely,

~tJ,;7i?Q Todd A. Witt Manager, Regulatory Affairs Executed on: )1c,..y ZGI :zoz;z,

Enclosure:

Ameren Missouri Response to NRC RAis

ULNRC-06735 May 26, 2022 Page 3 of 5

References:

1. Ameren Missouri letter ULNRC-06526, "Request for License Amendment and Regulatory Exemptions for a Risk-Informed Approach to Address GSI-191 and Respond to GL 2004-02 (LDCN 19-0014)," dated March 31, 2021 (ADAMS Accession No. ML21090A184)

2. Ameren Missouri Letter ULNRC-06664, "Supplement to Request for License Amendment and Regulatory Exemptions for a Risk-Informed Approach to Address GSI-191 and Respond to GL 2004- 02 (LDCN 19-0014)," dated May 27, 2021 (ADAMS Accession No. ML21147A222)

3. Ameren Missouri letter ULNRC-06651, "Supplement to Request for License Amendment and Regulatory Exemptions for a Risk-Informed Approach to Address GSI-191 and Respond to GL 2004- 02 (LDCN 19-0014)," dated July 22, 2021 (ADAMS Accession No. ML21203A192)

4. Ameren Missouri letter ULNRC-06692, "Third Supplement to Request for License Amendment and Regulatory Exemptions for a Risk-Informed Approach to Address GSI-191 and Respond to GL 2004- 02 (LDCN 19-0014)," dated October 7, 2021 (ADAMS Accession No. ML21280A379)

5. NRC letter to Ameren Missouri, "Callaway Plant, Unit No. 1 - Audit Plan and Setup of Online Reference Portal for License Amendment Request Regarding Risk-Informed Approach for Closure of Generic Safety Issue-191 (EPID L-2021 -LLA-0059)," dated July 23, 2021 (ADAMS Accession No. ML21197A063)

6. NRC Letter to Ameren Missouri, "Callaway Plant, Unit No. 1- Audit Summary for License Amendment Request and Regulatory Exemptions for a Risk-Informed Approach to Address Generic Safety Issue-191 and Respond to Generic Letter 2004-02 (EPID L-2021 LLA 0059 and EPID L-2021-LLE-0021)," dated September 14, 2021 (ADAMS Accession No. ML21238A138)

7. Ameren Missouri letter ULNRC-06690, "Fourth (Post-Audit) Supplement to Request for License Amendment and Regulatory Exemptions for a Risk-Informed Approach to Address GSI-191 and Respond to GL 2004-02 (LDCN 19-0014) (EPID L-2021 LLA 0059 and EPID L-2021-LLE-0021)," dated January 27, 2022 (ADAMS Accession No. ML22027A805)

8. Ameren Missouri letter ULNRC-06721, "Fifth (Post-Audit) Supplement to Request for License Amendment and Regulatory Exemptions for a Risk-Informed Approach to Address GSI-191 and Respond to GL 2004-02 (LDCN 19-0014) (EPID L-2021 LLA 0059 and EPID L-2021-LLE-0021)," dated March 8, 2022 (ADAMS Accession No. ML22068A027)

9. NRC letter, "Final RAis for GSI-191 LAR and Exemption Request for Callaway,!' transmitted via e-mail on April 5, 2022 (ADAMS Accession No. ML22096A023)

ULNRC-06735 May 26, 2022 Page 4 of 5 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. Mahesh Chawla Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O81A Washington, DC 20555-0001

ULNRC-06735 May 26, 2022 Page 5 of 5 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 6500 West Freeway, Suite 400 Fort Worth, TX 76116 (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 Tech Spec ULNRC Distribution:

F. M. Diya T. E. Herrmann B. L. Cox F. J. Bianco D. Farnsworth T. A. Witt T. B. Elwood R.J. Andreasen NSRB Secretary STARS Regulatory Affairs Mr. Jay Silberg (Pillsbury Winthrop Shaw Pittman LLP)

Ms. Claire Eubanks (Missouri Public Service Commission) -

Mr. Aaron Schmidt (DNR)

,