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| | issue date = 03/31/2008 | | | issue date = 03/31/2008 |
| | title = Request for Additional Information Related to LAR to Revise TS 3.7.8, Essential Service Water System, and TS 3.8.1, AC Sources - Operating, for One-time Completion Time Extension Re Underground Piping | | | title = Request for Additional Information Related to LAR to Revise TS 3.7.8, Essential Service Water System, and TS 3.8.1, AC Sources - Operating, for One-time Completion Time Extension Re Underground Piping |
| | author name = Thadani M C | | | author name = Thadani M |
| | author affiliation = NRC/NRR/ADRO/DORL/LPLIV | | | author affiliation = NRC/NRR/ADRO/DORL/LPLIV |
| | addressee name = Naslund C D | | | addressee name = Naslund C |
| | addressee affiliation = Union Electric Co | | | addressee affiliation = Union Electric Co |
| | docket = 05000483 | | | docket = 05000483 |
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| response to the following request for additional information (RAI) questions by May 15, 2008, to | | response to the following request for additional information (RAI) questions by May 15, 2008, to |
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| facilitate the continuation of the review by the NRC staff: | | facilitate the continuation of the review by the NRC staff: |
| : 1. The NRC staff asked for substantive justification that the known deficiencies in the probabilistic risk assessment (PRA) model, identified from peer reviews and identified to | | : 1. The NRC staff asked for substantive justification that the known deficiencies in the probabilistic risk assessment (PRA) model, identified from peer reviews and identified to |
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| deficient items and adequately justifies that these deficiencies or gaps do not impact the | | deficient items and adequately justifies that these deficiencies or gaps do not impact the |
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| risk results of this application. | | risk results of this application. |
| : 2. The NRC staff asked for discussion and justification of the truncation level for this application. The licensee's response identified the use of pre-solved cutsets to generate | | : 2. The NRC staff asked for discussion and justification of the truncation level for this application. The licensee's response identified the use of pre-solved cutsets to generate |
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| cutsets for the specific configuration(s) expected as result of the changes requested and | | cutsets for the specific configuration(s) expected as result of the changes requested and |
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| addressing the increased likelihood of the loss-of-service water initiating event. | | addressing the increased likelihood of the loss-of-service water initiating event. |
| : 3. The NRC staff requested the licensee to address initiating events not included in its risk assessment model, including fires, floods, seis mic events, and other external events. | | : 3. The NRC staff requested the licensee to address initiating events not included in its risk assessment model, including fires, floods, seis mic events, and other external events. |
| The licensee identified proposed compensatory measures, to include walkdowns of the | | The licensee identified proposed compensatory measures, to include walkdowns of the |
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| The staff is unable to conclude that these sources of risk will not be potentially significant | | The staff is unable to conclude that these sources of risk will not be potentially significant |
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| while the plant configuration has one service water header unavailable. | | while the plant configuration has one service water header unavailable. |
| (a) With regard to seismic risk, there is no risk mitigation provided by the compensatory measure of walkdowns of rooms identified as risk-important in a
| | (a) With regard to seismic risk, there is no risk mitigation provided by the compensatory measure of walkdowns of rooms identified as risk-important in a |
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| seismic margins analysis. Please provide a summary of the relationship between | | seismic margins analysis. Please provide a summary of the relationship between |
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| Otherwise, additional quantified estimates should be provided to characterize the | | Otherwise, additional quantified estimates should be provided to characterize the |
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| risk impact. | | risk impact. |
| (b) With regard to internal flooding, the NRC staff agrees that the compensatory measure of verifying the availability of flood mitigation equipment for the
| | (b) With regard to internal flooding, the NRC staff agrees that the compensatory measure of verifying the availability of flood mitigation equipment for the |
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| protected train is beneficial. However, the NRC staff needs to understand the | | protected train is beneficial. However, the NRC staff needs to understand the |
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| application. Otherwise, please provide additional quantified estimates enable the | | application. Otherwise, please provide additional quantified estimates enable the |
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| NRC staff to characterize the risk impact. | | NRC staff to characterize the risk impact. |
| (c) Similar to internal fires, the compensatory measures identified for walkdowns and monitoring of transient combustibles is a benefit. The staff must understand the
| | (c) Similar to internal fires, the compensatory measures identified for walkdowns and monitoring of transient combustibles is a benefit. The staff must understand the |
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| significant contributors to fire risk, how these could potentially impact the | | significant contributors to fire risk, how these could potentially impact the |
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| NRC staff to determine whether the fire risk is not significant for this application. | | NRC staff to determine whether the fire risk is not significant for this application. |
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| Otherwise, provide additional quantified estimates to characterize the risk impact. | | Otherwise, provide additional quantified estimates to characterize the risk impact. |
| (d) Please discuss the impact of this proposed TS change on other external events (i.e., hazardous material leaks, transportation events, high winds and tornadoes, etc.). Although weather-related loss-of-offsite power was addressed (and
| | (d) Please discuss the impact of this proposed TS change on other external events (i.e., hazardous material leaks, transportation events, high winds and tornadoes, etc.). Although weather-related loss-of-offsite power was addressed (and |
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| credited in the risk analyses), there is no discussion of high winds with regard to | | credited in the risk analyses), there is no discussion of high winds with regard to |
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| winds, or other discussion to characterize the site with regard to this source of | | winds, or other discussion to characterize the site with regard to this source of |
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| risk. Other external events were not discussed at all. | | risk. Other external events were not discussed at all. |
| : 4. The NRC staff previously requested the licensee to address sources of uncertainty in the risk analyses which may be significant for this application. In response, the licensee | | : 4. The NRC staff previously requested the licensee to address sources of uncertainty in the risk analyses which may be significant for this application. In response, the licensee |
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Letter Sequence RAI |
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TAC:MD7252, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO (Approved, Closed) |
Results
Other: ML083100134, ULNRC-05476, One-Time Completion Time Extension for Essential Service Water (ESW) System, ULNRC-05482, Response to Questions Received on February 7, 2008 Regarding Amendment to Revise Technical Specifications for Essential Service Water, ULNRC-05520, One-Time Completion Time Extension for Essential Service Water (ESW) System, (OL1281), ULNRC-05534, One-Time Completion Time Extension for Essential Service Water (ESW) System
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MONTHYEARML0725504882007-08-30030 August 2007 10 CFR 50.55a Request: Proposed Alternative to ASME Section Xi Requirements for Replacement of Class 3 Buried Piping Project stage: Request ULNRC-05445, One-Time Completion Time Extension for Essential Service Water (ESW) System2007-10-31031 October 2007 One-Time Completion Time Extension for Essential Service Water (ESW) System Project stage: Request ULNRC-05476, One-Time Completion Time Extension for Essential Service Water (ESW) System2008-02-21021 February 2008 One-Time Completion Time Extension for Essential Service Water (ESW) System Project stage: Other ML0803806472008-02-29029 February 2008 Summary of Meeting with Union Electric Company Callaway Plant, Unit 1, 8/30/2007 Relief Request and 10/31/2007 License Amendment Request Applications Related to Replacement of Essential Service Water Piping (Tac No. MD6792 and MD7252) Project stage: Meeting ULNRC-05482, Response to Questions Received on February 7, 2008 Regarding Amendment to Revise Technical Specifications for Essential Service Water2008-03-0707 March 2008 Response to Questions Received on February 7, 2008 Regarding Amendment to Revise Technical Specifications for Essential Service Water Project stage: Other ML0808800122008-03-31031 March 2008 Request for Additional Information Related to LAR to Revise TS 3.7.8, Essential Service Water System, and TS 3.8.1, AC Sources - Operating, for One-time Completion Time Extension Re Underground Piping Project stage: RAI ULNRC-05500, Response to Request for Additional Information One-Time Completion Time Extension for Essential Service Water (ESW) System2008-05-0606 May 2008 Response to Request for Additional Information One-Time Completion Time Extension for Essential Service Water (ESW) System Project stage: Response to RAI ML0815800112008-06-10010 June 2008 Request for Additional Information, Relief Request No. 13R-10 and License Amendment Request to Revise TS 3.7.8, Essential Service Water System, and TS 3.8.1, AC Sources - Operating, for One-time CT Extension Underground Piping Project stage: RAI ULNRC-05520, One-Time Completion Time Extension for Essential Service Water (ESW) System, (OL1281)2008-07-10010 July 2008 One-Time Completion Time Extension for Essential Service Water (ESW) System, (OL1281) Project stage: Other ULNRC-05534, One-Time Completion Time Extension for Essential Service Water (ESW) System2008-08-13013 August 2008 One-Time Completion Time Extension for Essential Service Water (ESW) System Project stage: Other ML0828106432008-10-31031 October 2008 Issuance of Amendment No. 186, Revise TS 3.7.8, Essential Service Water System, and TS 3.8.1, AC Sources - Operating, for One-time Completion Time Extension Re Underground Piping Project stage: Approval ML0831001342008-11-0606 November 2008 Correction to Amendment No. 186 Approving One-Time Extension of Completion Time for Inoperable Essential Service Water System and Emergency Diesel Generators Project stage: Other ML0834503272008-12-19019 December 2008 Summary of Meeting with Representatives of Union Electric Company, Licensee for Callaway Plant, Unit 1 Second Round of Requests for Information, Extension of Completion Time for Essential Service Water Systems (TAC Nos. MD6792 & MD7252) Project stage: Meeting 2008-02-29
[Table View] |
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Category:Letter
MONTHYEARULNRC-06853, Submittal of 2023 Fitness for Duty Performance Data Per Per 10 CFR 26.7172024-01-29029 January 2024 Submittal of 2023 Fitness for Duty Performance Data Per Per 10 CFR 26.717 IR 05000483/20230042024-01-19019 January 2024 Integrated Inspection Report 05000483/2023004 ML24008A0552024-01-19019 January 2024 Acceptance of Requested Licensing Action - Proposed Alternative to the Requirements of the ASME Code (EPID L-2023-LLR- 0061) ML23353A1712024-01-18018 January 2024 Issuance of Amendment No. 237 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, and 3.9.6 ML23317A0012024-01-12012 January 2024 Audit Summary Regarding LAR to Clarify Support System Requirements for the Residual Heat Removal and Control Room Air Conditioning System Under Technical Specifications 3.4.8, 3.7.11, and 3.9.6 ML23347A1212024-01-11011 January 2024 Issuance of Amendment No. 236 to Adopt TSTF-501, Revision 1, Relocate Stored Fuel Oil and Lube Volume Values to Licensee Control EPID L-2023-LLA-0046) ML24011A1492024-01-11011 January 2024 Notification of Post-Approval Site Inspection for License Renewal and Request for Information (05000483/2024011) ULNRC-06847, Supplement to Relief Request from Requirements of ASME BPV Code, Section XI, Subsection Iwl Regarding Examination and Testing of the Unbonded Post-Tensioning System (Relief Request C3R-01)2023-12-21021 December 2023 Supplement to Relief Request from Requirements of ASME BPV Code, Section XI, Subsection Iwl Regarding Examination and Testing of the Unbonded Post-Tensioning System (Relief Request C3R-01) ULNRC-06849, License Renewal Resolution for Commitments 34 and 35 Perform Evaluation of Crack Initiation and Propagation in Steam Generator Divider Plate and Tube-To-Tubesheet Welds2023-12-20020 December 2023 License Renewal Resolution for Commitments 34 and 35 Perform Evaluation of Crack Initiation and Propagation in Steam Generator Divider Plate and Tube-To-Tubesheet Welds ML23346A0392023-12-14014 December 2023 Supplemental Information Needed for Acceptance of Requested Licensing Action Request for Relief from Requirements of ASME Code, Section Xl, Examination and Testing Unbonded Post-Tensioning System ULNRC-06844, Request for Exemption from Specific Requirements in 2023 Security Rule, Enhanced Weapons, Firearms Background Checks, and Security Event Notification2023-12-0707 December 2023 Request for Exemption from Specific Requirements in 2023 Security Rule, Enhanced Weapons, Firearms Background Checks, and Security Event Notification 05000483/LER-2023-001, Submittal of LER 2023-001-00 for Callaway, Unit 1, Inoperable Instrument Tunnel Sump Level Indication Resulted in Condition Prohibited by Technical Specifications2023-11-29029 November 2023 Submittal of LER 2023-001-00 for Callaway, Unit 1, Inoperable Instrument Tunnel Sump Level Indication Resulted in Condition Prohibited by Technical Specifications ULNRC-06827, Supplement to License Amendment Request Regarding Support System Requirements for 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)2023-11-20020 November 2023 Supplement to License Amendment Request Regarding Support System Requirements for 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) IR 05000483/20230102023-11-15015 November 2023 NRC License Renewal Phase 1 Inspection Report 05000483 2023010 IR 05000483/20233012023-11-0909 November 2023 NRC Examination Report 05000483-2023301 ML23311A2082023-11-0909 November 2023 Reassignment of U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch IV ML23297A2502023-11-0606 November 2023 Individual Notice of Consideration of Issuance of Amendment to Renewed Facility Operating License, Proposed No Significant Hazards Consideration Determination and Opportunity for a Hearing (EPID L-2022-LLA-0176) - Letter IR 05000483/20240122023-10-24024 October 2023 Information Request for the Cybersecurity Baseline Inspection, Notification to Perform Inspection (05000483/2024012) ML23293A2652023-10-24024 October 2023 3rd Quarter 2023 Integrated Inspection Report ML23240A3692023-10-0505 October 2023 Issuance of Amendment No. 235 to Revise Technical Specifications to Use of Framatome Gaia Fuel (EPID L-2022-LLA-0150) (Non-Proprietary) ML23234A1522023-10-0505 October 2023 Exemption from the Requirements of 10 CFR Part 50, Section 50.46, and Appendix K Regarding Use of M5 Cladding Material (EPID L-2022-LLE-0030) (Letter) ML23305A0942023-10-0202 October 2023 10-CW-2023-09 Post-Exam Submittal ML23270B9662023-09-27027 September 2023 10 CFR 50.55a(z)(I) Request for Relief from ASME OM Code Pump and Valve Testing Requirements for Fifth 120-Month Inservice Testing Interval ML23228A0252023-09-25025 September 2023 Issuance of Amendment No. 234 to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Test Frequencies ML23261C3852023-09-25025 September 2023 Safety Evaluation for Operating Quality Assurance Manual Revision 36A ML23166B0882023-09-20020 September 2023 Issuance of Amendment No. 233 for Adoption of Alternative Source Term and Revision of Technical Specifications ML23206A1992023-09-15015 September 2023 Regulatory Audit Summary Regarding License Amendment and Regulatory Exemptions Request for Fuel Transition to Framatome Gaia Fuel (Epids L-2022-LLA-0150 and L-2022-LLE-0030) IR 05000483/20234012023-09-13013 September 2023 NRC Security Baseline Inspection Report 05000483/2023401 ML23240A7572023-08-31031 August 2023 NRC Initial Operator Licensing Examination Approval 05000483/2023301 IR 05000483/20230052023-08-23023 August 2023 Updated Inspection Plan for Callaway Nuclear Power Plant, Unit 1 (Report 05000483/2023005) - Mid Cycle Letter 2023 ULNRC-06824, Response to Request for Additional Information Regarding Operating Quality Assurance Manual (Oqam) Revision 36A2023-08-17017 August 2023 Response to Request for Additional Information Regarding Operating Quality Assurance Manual (Oqam) Revision 36A ML23219A1392023-08-15015 August 2023 Request for Withholding Information from Public Disclosure ULNRC-06830, Transmittal of Updated Technical Specification Markup and Clean Pages for License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak2023-08-15015 August 2023 Transmittal of Updated Technical Specification Markup and Clean Pages for License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak ML23215A1972023-08-0303 August 2023 Supplement to License Amendment and Exemption Request Regarding Use of Framatome Gaia Fuel (LDCN 22-0002) ULNRC-06223, Minor Correction to License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Test Frequencies (LDCN 2020-0004)2023-07-25025 July 2023 Minor Correction to License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Test Frequencies (LDCN 2020-0004) ULNRC-06799, Submittal of Licensee Event Report 2022-003-01, Class 1E Electrical Air Conditioning System Thermal Expansion Valve Failure Resulted in Condition Prohibited by Technical Specifications2023-07-13013 July 2023 Submittal of Licensee Event Report 2022-003-01, Class 1E Electrical Air Conditioning System Thermal Expansion Valve Failure Resulted in Condition Prohibited by Technical Specifications IR 05000483/20230022023-07-10010 July 2023 Integrated Inspection Report 05000483/2023002 ML23174A1272023-06-23023 June 2023 Cw FFD Document Request List 2023 ML23171A9942023-06-22022 June 2023 Acceptance of Request for Approval of Operating Quality Assurance Manual Revision 36a ULNRC-06821, Post-Audit Follow-Up Information in Support of Callaway'S License Amendment Request and Proposed Exemption to Allow Use of Framatome Gaia Fuel (LDCN 22-0002) (EPID L-2022-LLA-0150 and EPID L-2022-LLE-00301)2023-06-21021 June 2023 Post-Audit Follow-Up Information in Support of Callaway'S License Amendment Request and Proposed Exemption to Allow Use of Framatome Gaia Fuel (LDCN 22-0002) (EPID L-2022-LLA-0150 and EPID L-2022-LLE-00301) IR 05000483/20230112023-06-15015 June 2023 Comprehensive Engineering Team Inspection (CETI) Inspection Report 05000483/2023011 ULNRC-06822, Additional Information Regarding Request for NRC Approval of Operating Quality Assurance Manual (Oqam) Revision 36a2023-06-14014 June 2023 Additional Information Regarding Request for NRC Approval of Operating Quality Assurance Manual (Oqam) Revision 36a ML23158A1462023-06-13013 June 2023 Notification of Post-Approval Site Inspection for License Renewal and Request for Information Inspection (05000483/2023010) ULNRC-06815, Request for NRC Approval of Operating Quality Assurance Manual, Revision 36a2023-06-0505 June 2023 Request for NRC Approval of Operating Quality Assurance Manual, Revision 36a ULNRC-06818, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate .2023-06-0505 June 2023 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate . ML23093A0952023-05-10010 May 2023 Issuance of Amendment No. 232 Regarding Technical Specification Changes for Spent Fuel Storage ULNRC-06816, Withdrawal of Previously Submitted Enclosures Regarding License Amendment Request for Adoption of Alternative Source Term and Revision of Technical Specifications (LDCN 21-0015)2023-05-0909 May 2023 Withdrawal of Previously Submitted Enclosures Regarding License Amendment Request for Adoption of Alternative Source Term and Revision of Technical Specifications (LDCN 21-0015) ML23129A7942023-05-0909 May 2023 Post-Audit Supplement to License Amendment Request and Exemption to Allow Use of Framatome Gaia Fuel (LDCN 22-0002) (Iepid L-2022-LLA-0150 and EPID L-2022-LLE-0030) ML23122A3172023-05-0808 May 2023 Review of the Spring 2022 Steam Generator Tube Inservice Inspections ML23118A3492023-05-0808 May 2023 Request for Withholding Information from Public Disclosure 2024-01-29
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML23200A2982023-07-19019 July 2023 NRR E-mail Capture - Callaway Plant, Unit 1 - Final Request for Additional Information (RAI) - Request for Approval of Oqam, Revision 36a - EPID L-2023-LLQ-0000 ML23174A1272023-06-23023 June 2023 Cw FFD Document Request List 2023 ML23158A1462023-06-13013 June 2023 Notification of Post-Approval Site Inspection for License Renewal and Request for Information Inspection (05000483/2023010) ML23163A1572023-06-0606 June 2023 In-service Inspection Request for Information ML23096A0072023-04-0505 April 2023 NRR E-mail Capture - Final Request for Additional Information - Callaway Plant, Unit 1 - License Amendment Request to Revise TS 5.5.16 for Permanent Extension of Integrated Leak Rate Testing - EPID L-2022-LLA-0165 ML23080A1382023-03-21021 March 2023 Notification of Inspection (NRC Inspection Report 05000483/2023003) and Request for Information ML23073A0262023-03-13013 March 2023 NRR E-mail Capture - Final - Request for Additional Information - Callaway Plant, Unit 1 - SG Inspection Report Review - EPID L-2022-LRO-0143 ML23037A7092023-02-0606 February 2023 April 2023 Emergency Preparedness Exercise Inspection - Request for Information ML23026A0212023-01-24024 January 2023 NRR E-mail Capture - Final - Request for Additional Information - Callaway Plant, Unit 1 - LAR for Proposed Changes to TS for SFP - ML22287A0952022-10-14014 October 2022 NRR E-mail Capture - Final - Request for Additional Information - Callaway Plant, Unit 1 - License Amendment Request for Adoption of Alternate Source Term and Revision of Technical Specifications - EPID L-2021-LLA-0177 ML22269A4312022-09-26026 September 2022 November 2022 Emergency Preparedness Program Inspection - Request for Information ML22173A0562022-06-22022 June 2022 Information Request, Security IR 2022402 ML22167A0252022-06-15015 June 2022 NRR E-mail Capture - Final - Request for Additional Information - Callaway Plant, Unit 1 - LAR for Proposed Revision to Radiological Emergency Response Plan Regarding Response & Notification Goals - EPID L-2022-LLA-0024 ML22157A0572022-06-0606 June 2022 Notification of NRC Design Bases Assurance Inspection (Programs) (05000483/2022013) and Request for Information ML22154A0122022-06-0202 June 2022 NRR E-mail Capture - Final - Request for Additional Information - Callaway Plant, Unit 1 - License Amendment Request for Adoption of Alternate Source Term and Revision of Technical Specifications - EPID L-2021-LLA-0177 ML22151A0512022-05-27027 May 2022 NRR E-mail Capture - Final - Request for Additional Information - Columbia Generating Station - LAR to Change TS 3.4.11 - Reactor Coolant System Pressure and Temperature Limits - EPID L-2021-LLA-0191 ML22137A0292022-05-16016 May 2022 NRR E-mail Capture - Draft - Request for Additional Information - Callaway Plant, Unit 1 - License Amendment Request for Adoption of Alternate Source Term and Revision of Technical Specifications - EPID L-2021-LLA-0177 ML22096A0232022-04-0505 April 2022 NRR E-mail Capture - Callaway Plant - Final RAIs - License Amendment and Regulatory Exemptions for a Risk-Informed Approach to Address Generic Safety Issue - 191 and Respond to GL 2004-02 (EPIDs L-2021-LLA-0059 and L-2021-LLE-0021) ML21336A6392021-12-0202 December 2021 .05 Sec Doc Request ML21319A0062021-11-30030 November 2021 Supplemental Information Needed for Acceptance of Requested Licensing Actions License Amendment Request for Adoption of Alternate Source Term and Revision of Technical Specifications ML21258A0382021-09-14014 September 2021 NRR E-mail Capture - Final - Request for Additional Information - Callaway, Unit 1 - LAR to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors- EPID L-2020-LLA-023 ML21159A2352021-06-17017 June 2021 Notification of NRC Triennial Heat Exchanger/Heat Sink Performance Inspection (05000483/2021003) and Request for Information ML21130A5882021-05-11011 May 2021 Supplemental Information Needed for Acceptance of Requested Licensing Actions to Adopt a Risk-Informed Approach to Address GSI-191 and Respond to Generic Letter 2004 02 ML21088A3872021-03-30030 March 2021 Notification of Evaluations of Changes, Tests, and Experiments Inspection (Inspection Report 05000483/2021002) and Request for Information ML21007A1622021-01-0606 January 2021 NRR E-mail Capture - Final - Request for Additional Information - (COVID-19) Callaway Plant, Unit 1 - Additional Request for Exemption from Specific Requirements of 10 CFR Part 26, Fitness for Duty Programs - EPID L-2021-LLE-0242 ML20203M3682020-07-21021 July 2020 NRR E-mail Capture - Draft Request for Additional Information - Callaway Plant, Unit 1 - License Amendment Request - Revision to Technical Specification (TS) 5.3.1 and Deletion of TS 5.3.1.1 and 5.3.1.2 - EPID L-2020-LLA-0046 ML20162A1882020-06-10010 June 2020 Request for Supporting Information for the Callaway SPRA Audit Review - Draft Supplement ML20280A5442020-03-25025 March 2020 Cwy 2020 PIR Request for Information ML20064B6582020-02-27027 February 2020 Second, Third, and Fourth Request for Information for Callaway Dba Teams Inspection 2020011 ML19317E6332019-11-13013 November 2019 Request for Supporting Information for the Callaway SPRA Audit Review ML19107A5152019-04-11011 April 2019 Cwy 2019410 RFI Cyber Security Gap ML19078A2932019-03-18018 March 2019 Notification of an NRC Triennial Fire Protection Baseline Inspection (NRC Inspection Report 05000483/2019010) and Request for Information ML19023A2032019-01-22022 January 2019 Notification of NRC Triennial Heat Sink Performance Inspection (05000483/2019001) and Request for Information ML19009A3442019-01-0909 January 2019 NRR E-mail Capture - Formal Release of RAIs Ref: Callaway Plant Class 1E LAR, L-2018-LLA-0062 ML18355A4882018-12-20020 December 2018 NRR E-mail Capture - Formal Release of RAI Ref: Callaway Plant EAL Changes, L-2018-LLA-0239 ML18331A2052018-11-27027 November 2018 NRR E-mail Capture - Formal Release of RAIs Ref: Callaway Relief Request EPID L-2018-LLR-0051 ML18025B4672018-01-24024 January 2018 NRR E-mail Capture - Request for Extension of Due Date for RAI Response ML17304B1912017-10-31031 October 2017 NRR E-mail Capture - Requests for Additional Information Concerning Callaway License Amendment - Thermal Overload Protection ML17142A1352017-05-19019 May 2017 Notification of NRC Design Bases Assurance Inspection (05000483/2017007) and Initial Request for Information ML17115A0622017-04-25025 April 2017 NRR E-mail Capture - Requests for Additional Information -- Callaway Plant, Unit 1, Technical Specification 5.6.5, Core Operating Limits Report CAC MF8463 ML17038A2292017-02-0707 February 2017 NRR E-mail Capture - RAI Formal Release for Callaway SG Tube Inspection Report, MF8474 ML16111B3222016-04-20020 April 2016 Notification of Evaluations of Changes, Tests, and Experiments, and Permanent Plant Modifications Inspection (05000483/2016007) and Request for Information ML15316A1532015-11-12012 November 2015 Request for Additional Information Email, Relief Request 13R-11 (Pressurizer Welds) from Code Case N-460 Requirements, Third 10-Year Inservice Inspection Interval ML15096A0942015-04-0606 April 2015 Notification of Inspection (NRC Inspection Report 05000483/2015003) and Request for Information ML14353A1172014-12-22022 December 2014 Request for Additional Information, Round 3, License Amendment Request to Revise Final Safety Analysis Report Standard Plant Section 3.6 for High Density Polyethylene (Hdpe) Crack Exclusion ML14294A7752014-10-28028 October 2014 Request for Additional Information, Round 2, License Amendment Request to Revise Final Safety Analysis Report Standard Plant Section 3.6 for High Density Polyethylene (Hdpe) Crack Exclusion ML14203A0632014-07-25025 July 2014 Request for Additional Information, Relief Request I3R-17, Proposed Alternative to ASME Code, Section XI Requirements, Which Extends Rv ISI Frequency from 10 to 20 Years, Third 10-Year ISI Interval ML14178A8232014-07-0101 July 2014 Request for Additional Information, License Amendment Request to Revise Final Safety Analysis Report- Standard Plant Section 3.6 for High Density Polyethylene (Hdpe) Crack Exclusion ULNRC-06117, Callaway Plant, Unit 1, License Revewal Application, Request for Additional Information (RAI) Set 31 Responses2014-04-24024 April 2014 Callaway Plant, Unit 1, License Revewal Application, Request for Additional Information (RAI) Set 31 Responses ML14114A1102014-04-24024 April 2014 License Revewal Application, Request for Additional Information (RAI) Set 31 Responses 2023-07-19
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Text
March 31, 2008
Mr. Charles D. Naslund
Senior Vice President and Chief Nuclear Officer
Union Electric Company
Post Office Box 620
Fulton, MO 65251
SUBJECT:
CALLAWAY PLANT, UNIT 1 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST FOR ONE-TIME EXTENSION OF COMPLETION TIME FOR INOPERABLE ESSENTIAL
SERVICE WATER SYSTEM (TAC NO. MD7252)
Dear Mr. Naslund:
By application dated October 31, 2007, as supplemented by letter dated February 21, 2008, Union Electric Company (the licensee) requested the U.S. Nuclear Regulatory Commission (NRC) staff approval of a one-time change to the Technical Specifications (TS) for its Callaway
Plant.
The proposed change would revise the TS to extend the completion time (CT) associated with
an inoperable Essential Cooling Water train from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days, applicable once per train, and to be implemented prior to December 31, 2008. The licensee also proposed to eliminate
the second CT applicable to TS 3.8.1, Condition B in accordance with the NRC staff-approved
TS Task Force (TSTF) traveler TSTF-439.
The NRC staff has reviewed the information provided in your submittal and determined that
additional information is required in order to complete its review. Please provide a response to
the enclosed questions by May 15, 2008, to facilitate the continuation of the review by the NRC
staff. In the absence of your response by the requested date, the NRC staff may proceed to
deny your request pursuant to Title 10 of the Code of Federal Regulations, Part 2, Section 108, for not responding to this request within the time specified by the NRC staff.
If there are any questions, please contact me at (301) 415-1476, or e-mail mct@nrc.gov.
Sincerely,
/RA/ Mohan C. Thadani, Senior Project Manager
Plant Licensing Branch IV
Division of Operating Reactor Licensing
Office of Nuclear Reactor Regulation
Docket No. 50-483
Enclosure:
As stated
cc w/encl: See next page
ML (*) memo dated OFFICE NRR/LPL4/PM NRR/LPL4/LA DSS/APLA/BC NRR/LPL4/BC NAME MThadani, JBurkhardt MRubin (*) THiltz DATE 3/31/08 3/31/08 3/24/08 3/31/08 Callaway Plant, Unit 1 (November 2007)
cc:
John O'Neill, Esq.
Pillsbury Winthrop Shaw Pittman LLP
2300 N. Street, N.W.
Washington, D.C. 20037
Mr. Tom Elwood, Supervising Engineer
Regulatory Affairs and Licensing
AmerenUE P.O. Box 620
Fulton, MO 65251
Mr. Les H. Kanuckel, Manager
Quality Assurance
AmerenUE P.O. Box 620
Fulton, MO 65251
Mr. Luke Graessle, Manager
Regulatory Affairs
AmerenUE P.O. Box 620
Fulton, MO 65251
Mr. Scott Maglio
Assistant Manager, Regulatory Affairs
AmerenUE P.O. Box 620
Fulton, MO 65251
U.S. Nuclear Regulatory Commission
Resident Inspector Office
8201 NRC Road
Steedman, MO 65077-1302
Missouri Public Service Commission
Governor Office Building
200 Madison Street
P.O. Box 360
Jefferson City, MO 65102-0360
Regional Administrator, Region IV
U.S. Nuclear Regulatory Commission
611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005
Mr. H. Floyd Gilzow Deputy Director for Policy
Department of Natural Resources
P.O. Box 176
Jefferson City, MO 65102-0176
Mr. Rick A. Muench, President and CEO
Wolf Creek Nuclear Operating Corporation
P.O. Box 411
Burlington, KA 66839
Certrec Corporation
4200 South Hulen, Suite 422 Fort Worth, TX 76109
Technical Services Branch Chief
FEMA Region VII
2323 Grand Boulevard, Suite 900
Kansas City, MO 64108-2670
Kathleen Logan Smith, Executive Director
and Kay Drey, Representative, Board of
Directors
Missouri Coalition for the Environment
6267 Delmar Blvd., Suite 2E
St. Louis, City, MO 63130
Mr. Lee Fritz, Presiding Commissioner
Callaway County Courthouse
10 East Fifth Street
Fulton, MO 65251
Mr. Keith G. Henke, Planner III
Division of Community and Public Health
Office of Emergency Coordination
Missouri Department of Health and
Senior Services
930 Wildwood Drive
P.O. Box 570
Jefferson City, MO 65102
Mr. Scott Clardy, Director
Section for Environmental Public Health
Missouri Department of Health and
Senior Services
930 Wildwood Drive
P.O. Box 570
Jefferson City, MO 65102 Director, Missouri State Emergency
Management Agency P.O. Box 116 Jefferson City, MO 65102-0116 OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION RELATED TO ESSENTIAL SERVICE WATER UNION ELECTRIC COMPANY CALLAWAY PLANT DOCKET NO. 50-483 By application dated October 31, 2007, as supplemented by letter dated February 21, 2008, Union Electric Company (the licensee) requested the U.S. Nuclear Regulatory Commission (NRC) staff approval of a one-time change to the Technical Specifications (TS) for its Callaway
Plant. The NRC staff has reviewed the information provided in your submittal and determined
that additional information is required in order to complete its review. Please provide a
response to the following request for additional information (RAI) questions by May 15, 2008, to
facilitate the continuation of the review by the NRC staff:
- 1. The NRC staff asked for substantive justification that the known deficiencies in the probabilistic risk assessment (PRA) model, identified from peer reviews and identified to
the NRC staff in the submittal, would not significantly impact the application. In
response, to address the Scientech gap assessment against the American Society of
Mechanical Engineers internal events standard, the licensee restated that it "believed" these gaps would not invalidate the risk insights for this application, then argued that
since the existing PRA results were already greater than the Regulatory Guide 1.177
guidelines for permanent changes, the gaps would not result in any further significant
increase in the risk.
Please submit specific information which qualitatively discusses the substance of the
deficient items and adequately justifies that these deficiencies or gaps do not impact the
risk results of this application.
- 2. The NRC staff asked for discussion and justification of the truncation level for this application. The licensee's response identified the use of pre-solved cutsets to generate
the application risk results. The staff is concerned that the use of pre-solved cutsets for
this application may not be adequate to obtain an accurate assessment of the
configuration-specific risk level. Specific ally, the service water unavailability and random failure probability, coincident with the unavailability or failure of the backup normal
service water system (identified in other RAI responses as credited in the model),
represents a very unlikely failure mode, which may not appear in many cutsets above
truncation. Regenerating the cutsets with the service water train out-of-service to reflect
the actual configuration during the proposed extended completion time (CT) could result
in many more cutsets generated above the nominal truncation level, resulting in an
increase in the configuration-specific risk. This can be an especially significant problem
if the nominal unavailability and random failure probability result in large numbers of
cutsets just below the truncation level. In addition, initiating events, such as
loss-of-service water, are more likely to occur when one of the two trains is out-of-service. This frequency increase may not be reflected in the pre-solved cutsets, and, therefore, the risk contribution from such initiators would not be reflected in the
results.
Please provide risk results which avoid this potential non-conservatism by regenerating
cutsets for the specific configuration(s) expected as result of the changes requested and
addressing the increased likelihood of the loss-of-service water initiating event.
- 3. The NRC staff requested the licensee to address initiating events not included in its risk assessment model, including fires, floods, seis mic events, and other external events.
The licensee identified proposed compensatory measures, to include walkdowns of the
operable service water train, fire and flood watches in rooms identified as risk important
in the licensee's internal flooding, seismic margin, and fire protection evaluations, and
evaluation of transient combustibles within 20 feet of the operable service water train.
The staff is unable to conclude that these sources of risk will not be potentially significant
while the plant configuration has one service water header unavailable.
(a) With regard to seismic risk, there is no risk mitigation provided by the compensatory measure of walkdowns of rooms identified as risk-important in a
seismic margins analysis. Please provide a summary of the relationship between
the results of the seismic margins analyses which it identified in its response with
the specific configuration of the plant when it is reliant upon a single service
water header. The seismic ruggedness of the remaining operable service water
system should be addressed to justify that a seismic event is not likely to cause
damage to this system. The qualitative information should be adequate for the
NRC staff to conclude that seismic risk is not significant for this application.
Otherwise, additional quantified estimates should be provided to characterize the
risk impact.
(b) With regard to internal flooding, the NRC staff agrees that the compensatory measure of verifying the availability of flood mitigation equipment for the
protected train is beneficial. However, the NRC staff needs to understand the
significant contributors to internal flooding risk, how these could potentially
impact the remaining operable protected train of equipment, or otherwise result in
increased reliance upon that equipment, and either conclude that the risk of
these scenarios is not significant or that compensatory measures are in place to
mitigate these events. Please provide adequate qualitative information for the
NRC staff to determine whether the internal flooding risk is not significant for this
application. Otherwise, please provide additional quantified estimates enable the
NRC staff to characterize the risk impact.
(c) Similar to internal fires, the compensatory measures identified for walkdowns and monitoring of transient combustibles is a benefit. The staff must understand the
significant contributors to fire risk, how these could potentially impact the
remaining operable protected train of equipment or otherwise result in increased
reliance upon that equipment, and either conclude that the risk of these
scenarios is not significant or that compensatory measures are in place to
mitigate these events. Please provide adequate qualitative information for the
NRC staff to determine whether the fire risk is not significant for this application.
Otherwise, provide additional quantified estimates to characterize the risk impact.
(d) Please discuss the impact of this proposed TS change on other external events (i.e., hazardous material leaks, transportation events, high winds and tornadoes, etc.). Although weather-related loss-of-offsite power was addressed (and
credited in the risk analyses), there is no discussion of high winds with regard to
any unique vulnerabilities during the time the service water header is out of
service, the vulnerability of the backup normal service water system to high
winds, or other discussion to characterize the site with regard to this source of
risk. Other external events were not discussed at all.
- 4. The NRC staff previously requested the licensee to address sources of uncertainty in the risk analyses which may be significant for this application. In response, the licensee
stated, without justification or basis, that the assumptions applied and the use of point
estimates of mean values would not invalidate the risk analyses. For the specific areas
identified by the NRC staff as examples of key assumptions, the licensee identified the
methodologies used in the risk analyses, but did not provide any assessment as to the
impact of uncertainties associated with these assumptions on the application.
The purpose of this RAI was to request the licensee to review the important PRA
assumptions and elements of the model which are especially relevant to the risk of the
plant configuration with one service water header unavailable, to characterize the impact
of these uncertainties, and to develop and present its basis as to why these sources of
uncertainty do not adversely impact the result s of the risk analyses relevant to the NRC staff decision to accept a 14-day extended CT. Please provide a more specific technical
justification for your conclusions that the uncertainties do not affect the risk analyses.
With regard specifically to equipment repair credit, please identify what equipment
repairs are credited, the numerical value and basis for such credit, and the specific
impact to the risk metrics for this application. (Note that the NRC staff position does not
permit PRA credit for repair and restoration of any equipment subject to the extended CT
to be used in the calculation of the risk metrics.)