ML13156A353

Editorial Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal

ML13156A353
Person / Time
Site:	Callaway
Issue date:	06/05/2013
From:	Ameren Missouri, Union Electric Co
To:	Office of Nuclear Reactor Regulation
Shared Package
ML131560446	List: ML13156A352 ML13156A353 ULNRC-05994, Review of Safety Evaluation with Open Items
References
ULNRC-05994
Download: ML13156A353 (12)

Text

Enclosure 2 - ULNRC-05994 June 05, 2013 CALLAWAY PLANT UNIT 1 LICENSE RENEWAL APPLICATION Editorial Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 Page 1 of 12

Enclosure 2 - ULNRC-05994 June 05, 2013 Editorial Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 No. SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to Page Section indicate suggested text)

1. xv Abbreviations Correct abbreviation for AERM. Revise the sentence as follows:

"AERM aging effect requiring mechanism management"

2. 1-8 OI B2.1.3-1 Reword the phrase, On multiple occasions, Revise the sentence as follows:

which indicates an ongoing and repetitive problem.

On multiple occasions early in plant operation or On several occasions in the past

3. 2-5 2.1.3.3.1 Reword the second paragraph under Staff Revise the sentence as follows:

Evaluation which mentions training using corporate license renewal project procedures. "personnel had been trained using corporate STARS and Callaway license renewal project procedures"

4. 2-33 2.3.2.1 In the second paragraph, correct the term spray Revise text as follows:

additive educators.

educators eductors

5. 2-41 2.3.3.4.1 Revise the third line to use the word convey Revise the sentence as follows:

rather than transmits to be consistent with LRA Section 2.3.3.4. and transmits conveys the heat to the UHS cooling tower.

6. 2-89 2.4.7.2 Revise text in the second full paragraph to be Revise text as follows:

consistent with LRA Table 2.4-12.

"These supports are included in LRA Table 2.4-12 as component types Supports Mech Equip Class 1 [, 2, or 3], or Supports Mech Equip Non_ASME, depending"

7. 2-95 2.5.1.1 Add bullets under insulated cable and connections Revise the bullets as follows:

and add "(includes the following)" to be consistent with the as-submitted LRA Section 2.5 (ULNRC- "insulated cable and connections (includes the 05830 dated 12/15/2011). following):

• Electrical cables and connections not subject to 10 CFR 50.49 EQ requirements Page 2 of 12

Enclosure 2 - ULNRC-05994 June 05, 2013 Editorial Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 No. SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to Page Section indicate suggested text)

• Electrical cables and connections not subject to 10 CFR 50.49 EQ requirements used in instrumentation circuits that are sensitive to reduction in conductor insulation resistance

• Inaccessible power cables not subject to 10 CFR 50.49 EQ requirements

8. 2-95 2.5.1.1 Revise the bulleted list for metal enclosed bus Revise the bulleted list as follows:

(including the following) to be consistent with the as-submitted LRA Section 2.5 (ULNRC-05830 dated

• metal enclosed bus (including the following):

12/15/2011). MEQ was added to the list under o Bus and connections Amendment 10 (September 20, 2012).

o Enclosure o Insulation and insulators

• Mechanical environmental qualification (MEQ) components

9. 3-14 3.0.3.1.1 Revise the sentence as follows:

Revise the FSAR Supplement paragraph to reference the correct RAI number B2.1.5-4b The FSAR supplement was amended in response to RAI (ULNRC-05957 dated 2/14/2013). B1.4-1b B2.1.5-4b discussed in SER Section 3.0.3.1.4.

10. 3-17 3.0.3.1.3 Correct the typo in the last sentence of third Revise the sentence as follows:

paragraph.

ASME Code Section XI

11. 3-18 3.0.3.1.3 Revise the paragraph as follows:

Correct the numbering of the program elements at the bottom of page 3-18 and top of 3-19. Based on its audit, and review of the applicants Reactor 3-19 Head Closure Stud Bolting Program, the staff finds that the program elements one, two, three, four, and six, for which the applicant claimed consistency with the GALL Report, are consistent with the corresponding program elements of GALL Report AMP XI.M3. Program elements Page 3 of 12

Enclosure 2 - ULNRC-05994 June 05, 2013 Editorial Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 No. SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to Page Section indicate suggested text) two four and five, "detection of aging effects," and "monitoring and trending," respectively, are associated with Open Item B2.1.3-1, Part (a).

12. 3-29 3.0.3.1.4 The SER indicates that Callaway revised LRA Revise the sentence in the third full paragraph as Appendix A1.1 (as part of letter ULNRC-05957, follows:

February 14, 2013). LRA Appendix B2.1.1 was also revised. In addition, the applicant revised LRA Appendix A1.1 (FSAR supplement for the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program),

and LRA Appendix B2.1.1, consistent with its response.

13. 3-31 3.0.3.1.5 Revise the Staff Evaluation, first paragraph, title Revise the sentence as follows:

and issue date for the NEI 03-08 document.

Consider adding the ADAMS number ML101050337 "NEI 03-08, Revision 2 (ADAMS Accession No.

for this document to the SER text. ML101050337), "Guidelines for the Management of Materials Issues," dated April 5 January, 2010."

14. 3-39 3.0.3.1.5 Correct the item number in the first paragraph Revise the sentence as follows:

under the evaluation for A/LAI No. 7, last sentence to be consistent with MRP-227-A. "include the plant-specific analysis as part of its LRA submittal or the inspection plan that would be submitted in accordance with A/LAI No. 8, Item (b2)."

15. 3-48 3.0.3.1.6 In the third full paragraph, change the reference to Revise the sentence as follows:

the Callaway FAC procedure from EDZ-01115 to EDP-ZZ-01115 to be consistent with the response Although the programs implementing procedure, EDZ-to RAI B2.1.7-3 in letter dated August 21, 2012. 01115 EDP-ZZ-01115,

16. 3-53 3.0.3.1.7 Correct the date in the second paragraph. Revise the date as follows:

By letter dated July 5, 2013 2012

17. 3-55 3.0.3.1.7 Update the quoted information from the response Revise the paragraph as follows:

to RAI B2.1.9-7 (ULNRC-05886, August 6, 2012) and add quotation marks. "The [f]irst paragraph of Section 10 of [AREVA NP Inc.,]

Page 4 of 12

Enclosure 2 - ULNRC-05994 June 05, 2013 Editorial Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 No. SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to Page Section indicate suggested text) document 51-9172264-00 identifies the forms of degradation detected in the Callaway Unit- 1 replacement steam generators at the [RFO 18] outage.

These mechanisms were AVB and tube support plate TSP wears wear. There was no degradation associated with the secondary side findings (inner bundle or steam drum)."

18. 3-56 3.0.3.1.7 Correct the date at the bottom of the third Revise the date as follows:

paragraph.

By letter dated July 5, 2013 2012

19. 3-81 3.0.3.1.18 The FSAR supplement was also revised under Revise the sentence as follows:

Amendment 1, letter dated April 25, 2012 and should be mentioned. Refer to the fourth full The staff finds that the information in the FSAR paragraph of the SER. supplement, as amended by letters dated April 25, 2012 and February 28, 2013, is an adequate summary description of the program.

20. 3-82 3.0.3.1.19 Correct the date of the letter which submitted Revise the date as follows:

Amendment 10. Refer to the third paragraph of the SER. "By letter dated September 10 20, 2012, the applicant provided LRA Amendment 10"

21. 3-88 3.0.3.2.2 In the first paragraph of Section 3.0.3.2.2, EPRI- Revise the paragraph as follows:

5769 should be EPRI NP-5769. For EPRI TR-104213, The LRA also states that the general practices Application should be plural. established in this program are consistent with NUREG-1339, "Resolution of Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear Power Plants," EPRI NP-5769, "Degradation and Failure of Bolting in Nuclear Power Plants" (with the exceptions noted in NUREG-1339 for safety-related bolting) and EPRI TR-104213, "Bolted Joint Maintenance and Applications Guide,"

which are recommended by the GALL Report.

Page 5 of 12

Enclosure 2 - ULNRC-05994 June 05, 2013 Editorial Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 No. SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to Page Section indicate suggested text)

22. 3-108 3.0.3.2.6 Correct the title of ANSI N45.2.6-1978 in the first Revise the sentence as follows:

paragraph.

ANSI N45.2.6-1978, Qualifications of Nuclear Power Plant Inspection, Examination, and Testing Personnel for Nuclear Power Plants.

23. 3-116 3.0.3.2.7 For consistency with the response to RAI B2.1.14- Revise the last bullet as follows:

5a, Part a, submitted on October 31, 2012, include text that is missing from the sixth (last) bullet. "The joints were visually inspected, an ultrasonic time-of-flight diffraction examination was performed, and a hydrostatic test was conducted."

Similarly, revise the second sentence of the second Revise second sentence of second full paragraph below full paragraph below the bulleted list to refer to the bulleted list as follows:

time-of-flight diffraction examination consistent "In addition, the ultrasonic time-of-flight ultrasonic with the response to RAI B2.1.14-5a. diffraction examination technique is an industry-recognized means of detecting cracking in joints"

24. 3-120 3.0.3.2.7 Revise the first bullet in the list to include a missing Revise the first bullet as follows:

word.

fire water system program.

25. 3-127 3.0.3.2.8 The last bullet at the bottom of the page starts with Revise the bullet as follows:

Part (e): For clarity, the applicable RAI should be noted since the preceding sentence cites several RAI B2.1.15-2 Part (e):

RAIs for this AMP. (Refer to ULNRC-05886 dated August 6, 2012.)

26. 3-130 3.0.3.2.8 The middle of the first full paragraph states, The Revise the sentence as follows:

Callaway Addendum to FSAR Section 9.5.1.2.1 states Revise this statement to refer to the Site The Callaway Site Addendum to FSAR Section 9.5.1.2.1 Addendum to the FSAR. states Page 6 of 12

Enclosure 2 - ULNRC-05994 June 05, 2013 Editorial Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 No. SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to Page Section indicate suggested text)

27. 3-142 3.0.3.2.11 In the first paragraph, last sentence, correct the Revise the sentence as follows:

acronym for the chemical and volume control system for consistency with Section 3.3 of the SER. "The LRA further states that the Selective Leaching Program will manage gray cast iron and copper alloy with greater than 15-percent zinc components within the fire protection, CVC controls system, service water,"

28. 3-143 3.0.3.2.11 Revise the second paragraph of the Operating Revise text as follows:

Experience discussion to refers to the Inspection Report from the Region IV Inspection (NRC letter As discussed in the audit inspection report, the staff dated November 20, 2012, (ML12328A053). reviewed

29. 3-160 3.0.3.2.15 Revise Enhancement 1 to include missing text. Revise text as follows:

"will be enhanced before the period of extended operation to specify"

30. 3-160 3.0.3.2.15 Revise the second sentence of Enhancement 1 to Revise the sentence as follows:

be consistent with LRA B2.1.26 (Enhancement to Element 2). In this enhancement, the applicant stated that the procedures will be enhanced before the extended operation to specify that whenever replaced replacement of bolting is required, bolting material, installation torque or tension, and use of lubricants and sealants are in accordance with the guidelines of EPRI NP-5769, EPRI TR-104213, and the additional recommendations of NUREG-1339.

31. 3-170 3.0.3.2.17 Revise the first partial paragraph, last sentence to Revise the sentence as follows:

correct the procedure reference. as identified in procedure ESP-AAZZ-01013 Section 7.5 and the quantitative acceptance criteria described in ESP-AAZZ-01013, Appendix D.

Page 7 of 12

Enclosure 2 - ULNRC-05994 June 05, 2013 Editorial Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 No. SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to Page Section indicate suggested text)

32. 3-180 3.0.3.2.20 Revise the first paragraph under Operating Revise the sentence as follows:

Experience to include the word one.

"The channel consists of two fission chambers in one detector housing"

33. 3-184 3.0.3.2.21 Revise Enhancement 2 to match LRA with Revise the sentence as follows:

Amendment No. 1 (ULNRC-05856 dated April 25, 2012). "(1) cables are not submerged or immersed in water, (2) cables/splices and cable support structures are intact, and"

34. 3-200 3.0.3.2.23 Consider revising the first paragraph, last sentence Revise the sentence as follows:

citation of 10 CFR 50.55a to be more specific and consistent with LRA Appendix A2.3. LRA cites 10 CFR 50.55a(b)(2)(viii)(B).

35. 3-215 3.0.5.2.4 Consider rewording the sentence in the paragraph Revise the sentence as follows:

titled, Schedule for Implementing the Operating Experience Review Activities, to clarify that no new In its response to RAI B1.4-1b dated February 14, 2013, enhancements were identified in the response to the applicant identified no additional enhancements.

RAI B1.4-1b.

36. 3-242 3.1.2.1.1 Revise the sentence as follows:

In the fourth paragraph, correct the heat number for bounding ferrite content that is given as 3-3347. The applicant also stated that the calculated ferrite contents are 19.65 percent and 18.69 percent for heat Nos. 3-3325 and 3-3347 3-3447, respectively and that these values are below the 20 percent threshold value for static-cast CF8A material.

37. 3-246 3.1.2.1.2 Correct multiple instances where ASME Revise the sentence as follows:

3-255 Subsections contain a typo and refer to IWC twice.

Subsections IWB, IWC, and IWCD Program Refer to:

• 3-246, paragraph (a)

• 3-255, first paragraph, eleventh line Page 8 of 12

Enclosure 2 - ULNRC-05994 June 05, 2013 Editorial Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 No. SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to Page Section indicate suggested text)

38. 3-267 3.1.2.2.6 Correct the typo in the section number for the ISI Revise the sentence as follows:

program as stated in the first full paragraph, last sentence. "The staffs evaluation of the applicants ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program and Water Chemistry Program is documented in SER Sections 3.0.3.1.1 and 3.0.3.1.2 respectively."

39. 3-303 3.2.2.2.4 Revise the sentence as follows:

Revise the third paragraph to refer to a single normal charging pump. The applicant also stated that normal charging is provided by the normal charging pumps pump and that check valves in the system prevent normal charging flow from going through the high pressure safety injection pump minimum flow recirculation orifices.

40. 3-382 Table 3.5-1 Revise title to NUREG-1800, Rev. 2 title applicable Revise as follows:

to PWR Containments: PWR Concrete (Reinforced and Prestressed) and Steel Containments BWR Concrete and Steel (Mark I, II, III) Containments PWR Concrete (Reinforced and Prestressed) and Steel Containments

41. 3-403 3.5.2.1.1 Correct the ASME code reference in the last Revise the sentence as follows:

sentence of the first partial paragraph of the page.

In its review of components associated with items 3.5.1-25, the staff finds the applicants proposal to manage aging using the ASME Section IX XI, Subsection IWL Program acceptable .

42. 3-442 3.6.2.2.3 Revise the third paragraph, last sentence, to Revise the sentence as follows:

distinguish that the FSAR section reference is from the Site Addendum (SA). "The applicant noted that the Callaway FSAR - SA Section 2.3.1.2.10 shows"

43. 4-15 4.2.2.2 Last paragraph describes generic Cu data as Revise the paragraph as follows:

reported in ORNL Report ORNL/TM-2006/530 and Page 9 of 12

Enclosure 2 - ULNRC-05994 June 05, 2013 Editorial Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 No. SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to Page Section indicate suggested text) the best estimate copper content and standard In its RAI response, the applicant stated that ORNL deviation. The response to RAI 4.2.2-1a reported Report ORNL/TM-2006/530 provides the mean, these values out to four significant figures. Request standard deviation (), minimum, and maximum Cu revision of this discussion to report the numeric values for the SA-508, Class 2, forging data analyzed in values consistent with the response to RAI 4.2.2-1a the report. The applicant noted that the mean value for (ULNRC-05918, October 15, 2012). the Cu content is 0.122 0.1220 percent, with a of 0.031 0.0313 percent, resulting in a mean + 2 upper bound value of 0.184 0.1846 percent. The applicant stated that the USE and PTS calculations for the reactor vessel inlet and outlet nozzles are revised to incorporate the 0.184 0.1846 percent Cu content for these nozzle forgings. The staff finds the applicants response to RAI 4.2.2-1a acceptable because the applicant invoked the mean + 2 upper bound value for establishing the 0.184 0.1846 percent generic Cu content for its inlet and outlet nozzles forgings. The staff noted that the generic Cu content of 0.184 0.1846 percent is a statistically conservative value that is consistent with statistical analyses performed on industry-wide data.

44. 4-31 4.3.1.2.2 Revise the statement in the last paragraph to be Revise the statement as follows:

consistent with the cycle count projection method discussion in LRA Section 4.3.1.2. thus, the staff determined that it is reasonable that the 60-year projections are not solely based more heavily on data from the entire history of plant operation because recent operating practices because they are expected to be more representative of how the plant will operate in the future.

45. 4-39 4.3.2.1.2, third Incorporate text after the statement beginning, Revise the paragraph as follows:

4-50 paragraph The staff determined that the program includes 4-52 three monitoring methods to note that fatigue Specifically for the [RCP thermal barrier flange; Page 10 of 12

Enclosure 2 - ULNRC-05994 June 05, 2013 Editorial Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 No. SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to Page Section indicate suggested text) 4.3.2.4.2, monitoring of the applicable component is based pressurizer lower head; and reactor vessel internals], the second full on cycle counting. This is consistent with the applicants program ensures that the numbers of paragraph disposition of the Class 2 RHR heat exchangers and transients actually experienced during the period of regenerative heat exchanger in SER Section 4.3.8.2. extended operation remain below the assumed number 4.3.3.2, second in the fatigue analyses or corrective actions will be full paragraph taken.

46. 4-44 4.3.2.2.2 Revise text to remove use of the abbreviation Revise text as follows:

CUFen which is inconsistent with the LRA as revised by letter ULNRC-05938 dated December 13, CUFen Uen 2012 (ML12349A179 and ML12349A180).

47. 4-54 4.3.4.1 Revise text to remove the use of the abbreviation Revise text as follows:

through EAF CUF which is inconsistent with the LRA as 4-60 revised by letter ULNRC-05938 dated December 13, EAF CUF Uen 2012 (ML12349A179 and ML12349A180).

48. 4-60 4.3.4.2 Revise the third full paragraph to include the word Revise the paragraph as follows:

age, which appears to be missing.

The staff noted that this location is monitored by CBF, which is based on the premise that the incremental fatigue usage of each transient, which is based on the ASME Code fatigue analysis with an assumed number of occurrences for each transient, can be accumulated to provide a fatigue usage as the components age during the period of extended operation."

49. 4-60 4.3.4.2 A word appears to be missing in the statement in Revise the sentence as follows:

the last sentence of the paragraph at the top of the page. Finally, for each screening method, if the criteria provided by the staff in RAI 4.3-21 were not considered, the applicant was requested to provide its justification.

Page 11 of 12

Enclosure 2 - ULNRC-05994 June 05, 2013 Editorial Comments Regarding the Safety Evaluation Report (SER) with Open Items Related to the License Renewal of Callaway Plant, Unit 1 No. SER Location Comment Suggested Resolution (use underline and/or strikethrough formatting to Page Section indicate suggested text)

50. 4-68 4.3.8.1 To be consistent with LRA Section 4.3.8, consider Revise the paragraph as follows:

changing the order of the discussion of the Fatigue Monitoring Program in the first paragraph of the The transients used in this fatigue analysis will be Regenerative Heat Exchanger discussion. counted by the Fatigue Monitoring Program. The LRA further states that the thermal analysis of the shell side nozzles, the tubeside outlet nozzle, and cross shell junction indicated these areas are not subject to fatigue.

and the transients used in this analysis will be counted by the Fatigue Monitoring Program.

51. 4-69 4.3.8.1 Revise the SER to identify these transients. Revise the sentence as follows:

Residual Heat Removal Heat Exchangers. The LRA states that the fatigue analysis for the RHR heat exchangers explains that a fatigue analysis is not necessary for the these associated transients since they are very weak.

52. 4-121 4.7.10.3 Revise date to be consistent with Amendment 10, Revise the date as follows:

which was submitted September 20, 2012.

September 20, 2013 2012

53. B-4 Appendix B Revise date to be consistent with letter dated Revise the date as follows:

November 29, 2012. November 29, 2013 2012 Page 12 of 12