ULNRC-06825, Response to Regulatory Audit Questions and Supplement to License Amendment Request Regarding Support System Requirements for the Residual Heat Removal and Control Room Air Conditioning Systems Under Technical Specifications
| ML23289A215 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 10/16/2023 |
| From: | Witt T Ameren Missouri, Union Electric Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML23289A214 | List: |
| References | |
| ULNRC-06825, LDCN 22-0029 | |
| Download: ML23289A215 (1) | |
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Callaway Plant 8315 County Road 459 : Steedman, MO 65077 : AmerenMissouri.com
.t October 16, 2023 ULNRC-06825 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 REGULATORY AUDIT QUESTIONS AND SUPPLEMENT TO LICENSE AMENDMENT REQUEST REGARDING SUPPORT SYSTEM REQUIREMENTS FOR THE RESIDUAL HEAT REMOVAL AND CONTROL ROOM AIR CONDITIONING SYSTEMS UNDER TECHNICAL SPECIFICATIONS 3.4.8, 3.7.11, AND 3.9.6 (LDCN 22-0029)
References:
- 1. Ameren Missouri letter ULNRC-06781, License Amendment Request to Clarify Support System Requirements for the Residual Heat Removal System and Control Room Air Conditioning System Under Technical Specifications 3.4.8, 3.7.11, 3.9.6 (LDCN 22-0029), dated December 1, 2022 (ADAMS Accession No. ML22335A508)
- 2. NRC Letter, "Callaway Plant, Unit No. 1 - Regulatory Audit Plan and Setup of Online Reference Portal for License Amendment Request to Clarify Support System Requirements for the Residual Heat Removal and Control Room Air Conditioning Systems (EPID L-2022-LLA-0176)," dated March 28, 2023 (ADAMs Accession No, ML23065A321)
- 3. NRC e-mail capture,
Subject:
"Callaway Plant, Unit No. 1 - Regulatory Audit Questions - LAR to Clarify Support System Requirements for the Residual Heat Removal and Control Room Air Conditioning Systems (EPID L-2022-LLA-0176),"
dated July 27, 2023 (ADAMS Accession No. ML23208A105)
By letter dated December 1, 2022 (Reference 1), Ameren Missouri submitted a license amendment request (LAR) to clarify the support system requirements for the Residual Heat Removal (RHR) system and Control Room Air Conditioning System (CRACS) during shutdown modes. By letter dated March 28, 2023 (Reference 2), the NRC communicated their plans to conduct an audit of the
ULNRC-06825 October 16, 2023 Page 2 of 5 Reference 1 LAR and provided an initial listing of audit questions and requests for response. A set of additional, informal audit questions (and responses) verbalized during the audit was assembled as well.
After the audit (conducted in April), and by e-mail dated July 27, 2023 (Reference 3), the NRC staff provided additional audit questions for response. Those audit questions and Ameren Missouris responses to the questions were then clarified and discussed in telephone conferences conducted with the NRC staff on August 23 and September 1 3, 2023, as part of the overall audit activity. Attachment 1 to this letter provides Ameren Missouris documented responses to all the audit questions, i.e., those transmitted via References 2 and 3 as well as those taken from the audit discussions. Included in the attachment are some additional insights and clarifications identified during the noted teleconferences.
From development of the audit question responses, and based on discussions during the audit and teleconferences, it was determined that changes to the Technical Specifications should be proposed for the provision to use the Service Water system as a support system for the RHR system and CRACS.
The enclosure to this letter provides Technical Specification markups based on that determination.
Due to the additional information and proposed Technical Specification changes developed from responding to the audit questions, it was determined that the environmental and regulatory evaluations originally provided in the Reference 1 LAR, including the Basis for No Significant Hazards Consideration, should be revised. Accordingly, the revised evaluations are provided in Attachment 2.
The Callaway Onsite Review Committee has reviewed and approved submittal of this LAR supplement.
This submittal does not contain new commitments.
If there are any questions, please contact Tom Elwood at 314-225-1905.
I declare under penalty of perjury that the foregoing is true and correct.
Sincerely, Todd A. Witt Manager, Regulatory Affairs Executed on:
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.t ULNRC-06825 October 16, 2023 Page 3 of 5 Attachments: 1. Responses to Regulatory Audit Questions Regarding LAR to Clarify Support System Requirements for the Residual Heat Removal and Control Room Air Conditioning Systems
- 2. Updated Regulatory Evaluation and Environmental Evaluation for License Amendment Request
Enclosure:
Proposed TS Changes (Markups)
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.t ULNRC-06825 October 16, 2023 Page 4 of 5 cc:
Mr. John Monninger 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
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.t ULNRC-06825 October 16, 2023 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 K. C. Scott W. A. Witt B. L. Jungmann T. A. Witt T. B. Elwood NSRB Secretary STARS Regulatory Affairs Mr. Jay Silberg (Pillsbury Winthrop Shaw Pittman LLP)
Ms. Claire Eubanks (Missouri Public Service Commission)
Mr. Aaron Schmidt (DNR)