ML22182A411

Letter - Environmental Assessment & Finding of No Significant Impact Requests for Amendment & Regulatory Exemptions for a Risk-Informed Approach to Address GSI-191 and Respond to GL 2004-02 (EPID L-2021-LLA-0059 & L-2021-LLE-00021)

ML22182A411
Person / Time
Site:	Callaway
Issue date:	08/23/2022
From:	Mahesh Chawla NRC/NRR/DORL/LPL4
To:	Diya F Ameren Missouri, Union Electric Co
Chawla M, NRR/DORL/LPL4
Shared Package
ML22182A401	List: ML22182A406 ML22182A411
References
EPID L-2021-LLA-0059, EPID L-2021-LLE-0021
Download: ML22182A411 (22)

Text

August 23, 2022

Mr. Fadi Diya Senior Vice President and Chief Nuclear Officer Ameren Missouri Callaway Energy Center 8315 County Road 459 Steedman, MO 65077

SUBJECT:

CALLAWAY PLANT, UNIT NO. 1 - ENVIRONMENTAL ASSESSMENT AND FINDING OF NO SIGNIFICANT IMPACT RELATED TO REQUESTS FOR LICENSE AMENDMENT 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 L-2021-LLE-0021)

Dear Mr. Diya:

Enclosed is a copy of the Environmental Assessment and Finding of No Significant Impact related to your request for certain regulatory exemptions and associated license amendment dated March 31, 2021 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML21090A184), as supplemented by letters dated May 27, 2021 (ML21147A222), July 22, 2021 (ML21203A192), August 23, 2021 (ML21237A135), October 7, 2021 (ML21280A378), January 27, 2022 (ML22027A804), March 8, 2022 (ML22068A027),

and May 26, 2022 (ML22146A337). The proposed amendment and requested exemptions would allow the use of deterministic and risk-informed approach to address Generic Safety Issue (GSI)-191 and close Generic Letter (GL) 2004-02, and grant relief from certain requirements in Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 50.46(a)(1) and 10 CFR Part 50, Appendix A, General Design Criterion (GDC) 35, Emergency core cooling, GDC 38, Containment heat removal, and GDC 41, Containment atmosphere cleanup.

F. Diya

The Environmental Assessment and Finding of No Significant Impact is being forwarded to the Office of the Federal Register for publication. If you have any questions, please contact me at 301-415-8371 or via email at Mahesh.Chawla@nrc.gov.

Sincerely,

/RA Siva Lingam for/

Mahesh L. Chawla, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket No. 50-483

Enclosure:

Federal Register Notice

cc: Listserv

ENCLOSURE

ENVIRONMENTAL ASSESSMENT AND FINDING OF NO SIGNIFICANT IMPACT

UNION ELECTRIC COMPANY

CALLAWAY PLANT, UNIT NO. 1

DOCKET NO. 50-483

[7590-01-P]

NUCLEAR REGULATORY COMMISSION

[Docket No. 50-483; NRC-2022-0139]

Union Electric Company, dba Ameren Missouri

Callaway Plant, Unit No. 1

AGENCY: Nuclear Regulatory Commission.

ACTION: Environmental assessment and finding of no significant impact; issuance.

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) is issuing an

environmental assessment (EA) prepared under the National Environmental Policy Act

of 1969 (NEPA) and NRCs regulations. This EA summarizes the results of the NRC

staffs environmental review, which evaluates the potential environmental impacts of

granting exemptions from NRC regulations and issuing an associated license

amendment in response to a request from the Union Electric Company, doing business

as (dba) Ameren Missouri (Ameren, the licensee) for Renewed Facility Operating

License NPF-30, for the Callaway Plant, Unit No. 1 (Callaway). Specifically, the licensee

is seeking a license amendment and regulatory exemptions that would, if granted, allow

the licensee to use both a deterministic and risk-informed approach to address safety

issues discussed in Generic Safety Issue (GSI)-191, Assessment of Debris

Accumulation in PWR [Pressurized Water Reactor] Sump Pump Performance and to

close Generic Letter (GL) 2004-02, Potentia l Impact of Debris Blockage on Emergency

Recirculation During Design Basis Accidents at Pressurized-Water Reactors. The NRC

staff is issuing a final EA and finding of no significant impact (FONSI) associated with the

proposed exemptions.

DATES: The EA and FONSI referenced in this document is available on [INSERT

DATE OF PUBLICATION IN THE FEDERAL REGISTER].

ADDRESSES: Please refer to Docket ID NRC-2022-0139 when contacting the NRC

about the availability of information regarding this document. You may obtain publicly

available information related to this document using any of the following methods:

Federal Rulemaking Website: Go to https://www.regulations.gov and

search for Docket ID NRC-2022-0139. Address questions about Docket IDs in

Regulations.gov to Stacy Schumann; telephone: 301-415-0624; email:

Stacy.Schumann@nrc.gov. For technical questions, contact the individual listed in the

For Further Information Contact section of this document

NRCs Agencywide Documents Access and Management System

(ADAMS): You may obtain publicly available documents online in the ADAMS Public

Documents collection at https://www.nrc. gov/reading-rm/adams.html. To begin the

search, select Begin Web-based ADAMS Search. For problems with ADAMS, please

contact the NRCs Public Document Room (PDR) reference staff at 1-800-397-4209,

301-415-4737, or by email to PDR.Resource@nrc.gov. For the convenience of the

reader, instructions about obtaining materials referenced in this document are provided

in the Availability of Documents section.

NRCs PDR: You may examine and purchase copies of public documents,

by appointment, at the NRCs PDR, Room P1 B35, One White Flint North, 11555

Rockville Pike, Rockville, Maryland 20852. To make an appointment to visit the PDR,

please send an email to PDR.Resource@nrc.gov or call 1-800-397-4209 or 301-415-

4737, between 8:00 a.m. and 4:00 p.m. Eastern Time (ET), Monday through Friday,

except Federal holidays.

2 FOR FURTHER INFORMATION CONTACT: Mahesh Chawla, Office of Nuclear

Reactor Regulation, U.S. Nuclear Regulatory Commission, Washington, DC 20555-

0001; telephone: 301-415-8371, email: Mahesh.Chawla@nrc.gov.

SUPPLEMENTARY INFORMATION:

I. Introduction

The NRC is considering a request to grant certain regulatory exemptions and

issue a license amendment for Renewed Facility Operating License NPF-30, issued to

Ameren, for Callaway, located in Callaway County, Missouri. The regulatory exemptions

and associated license amendment, if granted, would allow Ameren to incorporate the

use of a risk-informed approach to address safety issues discussed in GSI-191 and

respond to GL 2004-02. Pursuant to Section 51.21 of title 10 of the Code of Federal

Regulations (10 CFR), Criteria for and identification of licensing and regulatory actions

requiring environmental assessments, the NRC has prepared an EA summarizing the

findings of the NEPA review of the proposed action. The NRC concluded that the

proposed action will have no significant environ mental impact. In accordance with

10 CFR 51.31(a), the NRC has determined not to prepare an environmental impact

statement for the proposed licensing actions and is issuing a FONSI.

The NRC established GSI-191 to determine whether the transport and

accumulation of debris from a loss-of-coolant accident (LOCA) in the PWR containment

structure would impede the operation of the em ergency core cooling system (ECCS) or

containment spray system (CSS). A LOCA wi thin the containment structure is assumed

to be caused by a break in the primary coolant loop piping. Water discharged from the

pipe break and debris would collect on the containment structure floor and within the

containment emergency sump. During this type of accident, the ECCS and CSS would

initially draw cooling water from the refueling water storage tank. However, realigning

3 the ECCS pumps to the containment emergency sump would provide long-term cooling

of the reactor core. Therefore, successful long-term cooling depends on the ability of the

containment emergency sump to provide adequate flow to the residual heat removal

(RHR) recirculation pumps for extended periods of time.

One of the concerns addressed by the implementation of GSI-191 is that debris

material, such as insulation installed on piping and components, within the containment

structure, could be dislodged by a jet of high-pressure water and steam during the

LOCA. Water, along with debris, would accumulate at the bottom of the containment

structure and flow towards the emergency sump pumps. Insulation and other fibrous

debris material could block the emergency sump screens and suction strainers, which in

turn could prevent the ability of the containment emergency sump to provide adequate

water flow to the RHR pumps (for more information, see NUREG-0897, Containment

Emergency Sump Performance: Technical Finding Related to Unresolved Safety Issue

A-43, Revision 1).

The NRC issued GL 2004-02 to address this safety concern by requesting PWR

licensees, pursuant to 10 CFR 50.54(f), to use an NRC-approved methodology to

perform a mechanistic evaluation of the potential for the adverse effects of post-

accident debris blockage and operation with debris-laden fluids to impede or prevent the

recirculation functions of the ECCS and CSS following all postulated accidents for which

the recirculation of these systems is required and submit this information to the NRC for

evaluation.

In 2012, the NRC staff developed options for resolution of GSI-191, which are

discussed in SECY-12-0093, Closure Options for Generic Safety Issue 191,

Assessment of Debris Accumulation on Pressurized-Water Reactor Sump Performance,

dated July 9, 2012. The licensee has proposed to use both a deterministic method, with

4 plant-specific testing, and a risk-informed approach to demonstrate compliance with

10 CFR 50.46, Acceptance criteria for emergency core colling systems for light-water

nuclear power reactors, and 10 CFR Part 50, Appendix A, General Design Criteria (GDC) 35, Emergency core cooling, GDC 38, Containment heat removal, and GDC 41, Containment atmosphere cleanup, and to resolve GSI-191 for Callaway. Because,

historically, the NRC staff has not allowed licensees to use a risk-informed approach to

show compliance with the requirements of 10 CFR 50.46, the licensee requested

exemptions from 10 CFR 50.46(a)(1) and GDC 35, 38, and 41, as well as an

amendment to the associated technical specific ations to allow the use of a risk-informed

approach to resolve GSI-191. If approved, the proposed action would not authorize any

modifications within the containment structure, physical changes to the ECCS, or other

modifications to the plant. Rather, the proposed action would only allow the use of an

alternate methodology to show compliance with the regulations that require the ECCS

and CSS function during certain LOCA events.

II. Environmental Assessment

Description of the Proposed Action

The proposed action as requested by the licensee is to grant certain regulatory

exemptions and amend Facility Operating Lice nse NPF-30. The regulatory exemptions

would allow Ameren to change the licensing basis LOCA analysis identified in the

updated final safety analysis report to use a risk-informed approach to address safety

issues discussed in GSI 191 and to close GL 2004 02. If approved, no physical

modifications to the nuclear plant or changes to reactor operations involving the ECCS

would be required. The proposed action is in response to the licensees application

dated March 31, 2021, as supplemented by letters dated May 27, 2021; July 22, 2021;

August 23, 2021; October 7, 2021; January 27, 2022; March 8, 2022; and May 26, 2022.

5 Need for the Proposed Action

The proposed action is needed because, as the holder of Renewed Facility

Operating License No. NPF-30, Ameren is expected to address the safety issues

discussed in GSI-191 and to close GL 2004-02 for Callaway. Consistent with SECY 0093, the licensee chose an approach, which requires, in part, that Ameren request that

the NRC amend the renewed facility operating license and grant certain regulatory

exemptions for Callaway.

Environmental Impacts of the Proposed Action

Callaway is located on an approximately 7,354-acre (2,976 hectare) site in

Callaway County, Missouri, approximately 10 miles (16 kilometers) southeast of Fulton,

Missouri, and 80 miles (129 kilometers) west of the St. Louis metropolitan area.

Callaway consists of a single four-loop Westinghouse PWR unit. The reactor

core of the unit heats water, which is pumped to four steam generators, where the

heated water is converted to steam. The steam is then used to turn turbines, which are

connected to electrical generators that produce electricity. A simplified drawing of a

PWR can be viewed at https://www.nrc.gov/reactors/pwrs.html.

The reactor, steam generators, and other components are housed in a concrete

and steel containment structure (building). The containment structure is a reinforced

concrete cylinder with a concrete slab base and hemispherical dome. A welded steel

liner is attached to the inside face of the concrete shell to ensure a high degree of leak

tightness. In addition, the 4-foot (1.2-meter)-thick concrete walls of the containment

structure serve as a radiation shield. Additional information on the plant structures and

systems, as well as the environmental im pact statement for license renewal, can be

found in NUREG-1437, Supplement 51, Generic Environmental Impact Statement for

6 License Renewal of Nuclear Plants: Supplement 51 Regarding Callaway Plant, Unit 1:

Final Report.

Radiological and non-radiological impacts on the environment that may result

from granting the regulatory exemptions and issuing the license amendment are

summarized in the following sections.

Non-Radiological Impacts

No changes would be made to structures or land use within the Callaway site as

a result of the proposed action, and non-radiological liquid effluents or gaseous

emissions would not change. In additi on, the license amendment and regulatory

exemptions would not result in any changes to the use of resources or create any new

environmental impacts. Therefore, there would be no non-radiological impacts to

environmental resources or any irreversible and irretrievable commitments.

Since granting the regulatory exempti ons and issuing the license amendment

would not result in environmental effects, there would be no non-radiological cumulative

impact.

Radiological Impacts

Radioactive Gaseous and Liquid Effluents and Solid Waste

Callaway uses waste treatment systems to collect, process, recycle, and dispose

of gaseous, liquid, and solid wastes that contain radioactive material in a safe and

controlled manner within NRC and Environmental Protection Agency (EPA) radiation

safety standards.

The license amendment and regulatory exemptions, if granted, would not require

any physical change to the nuclear plant or reactor operations; therefore, there would be

no changes to the plant radioactive waste treatment systems. A detailed description of

7 the Callaway radioactive waste handling and disposal activities is presented in chapter

2.1.2 of Supplement 51 to NUREG-1437.

Radioactive Gaseous Effluents

The objectives of the Callaway gaseous waste management system (GWMS) are

to process and control the release of radioactive gaseous effluents into the environment

to be within the requirements of 10 CFR 20.1301, Dose limits for individual members of

the public, and to be consistent with the as low as reasonably achievable (ALARA) dose

objectives set forth in Appendix I to 10 CFR Part 50. The GWMS is designed so that

radiation exposure to plant workers is within the dose limits in 10 CFR 20.1201,

Occupational dose limits for adults.

Granting the regulatory exemptions and issuing the license amendment would

not require any physical changes to the nuclear plant or reactor operations that would

affect the release of radioactive gaseous effl uents into the environment; therefore, there

would be no changes to the GWMS. The existing equipment and plant procedures that

control radioactive releases to the environment would continue to be used to maintain

radioactive gaseous releases within the dose limits in 10 CFR 20.1301 and the ALARA

dose objectives in Appendix I to 10 CFR Part 50.

Radioactive Liquid Effluents

The function of the Callaway liquid waste processing system (LWPS) is to collect

and process radioactive liquid wastes to reduce radioactivity and chemical

concentrations to levels acceptable for discharge to the environment or to recycle the

liquids for use in plant systems. The principal objectives of the LWPS are to collect

liquid effluents (wastes) that may contain radioactive material and to maintain sufficient

processing capability so that liquid waste may be discharged to the environment below

the regulatory limits in 10 CFR 20.1301 and consistent with the ALARA dose objectives

8 in Appendix I to 10 CFR Part 50. The liquid effluent is routed through a monitor that

measures the radioactivity and can automatically terminate the release in the event

radioactivity exceeds predetermined levels. The liquid effluent is discharged from the

plant into the Missouri River via a pipeline.

Granting the regulatory exemptions and issuing the license amendment would

not require any physical change to the nuclear plant or reactor operations; therefore,

there would be no changes to the LWPS. The existing equipment and plant procedures

that control radioactive releases to the environment will continue to be used to maintain

radioactive liquid releases within the dose limits in 10 CFR 20.1301 and the ALARA

dose objectives in Appendix I to 10 CFR Part 50.

Radioactive Solid Wastes

The function of the Callaway solid waste processing system (SWPS) is to

process, package, and store the solid radioactive wastes generated by nuclear plant

operations until they are shipped off site to a vendor for further processing or for

permanent disposal at a licensed burial facility, or both. The storage areas have

restricted access and shielding to reduce radiation rates to plant workers. The principal

objectives of the SWPS are to package and tr ansport the waste in compliance with NRC

regulations in 10 CFR Part 61, Licensing Requirements for Land Disposal of

Radioactive Waste, and 10 CFR Part 71, Packaging and Transportation of Radioactive

Material, and the U.S. Department of Transportation regulations in 49 CFR Parts 170

through 179; and to maintain the dose limits in 10 CFR 20.1201, 10 CFR 20.1301, and

Appendix I to 10 CFR Part 50.

The existing equipment and plant procedures that control radioactive solid waste

handling would continue to be used to maintain exposures within the dose limits in

10 CFR 20.1201, 10 CFR 20.1301, and 10 CFR Part 50 Appendix I. Therefore, there

9 will be no changes to the SWPS and issuing the license amendment and granting the

regulatory exemptions will not result in any physical changes to the nuclear plant or

reactor operations that would affect the release of radioactive solid wastes into the

environment.

Occupational Radiation Doses

The license amendment and regulatory exemptions, if granted, would not require

any physical change to the nuclear plant or changes to reactor operations; therefore,

there would be no change to any in-plant radiation sources. In addition, no new operator

actions would be implemented that could affe ct occupational radiation exposure. The

licensees radiation protection program monitors radiation levels throughout the nuclear

plant to establish appropriate work controls, training, temporary shielding, and protective

equipment requirements so that worker doses remain within the dose limits in

10 CFR Part 20, Standards for Protection Against Radiation, Subpart C, Occupational

Dose Limits. The license amendment and regulatory exemptions would not change

radiation levels within the nuclear plant and, therefore, there would be no increased

radiological impact to the workers.

Offsite Radiation Dose

The primary sources of offsite dose to me mbers of the public from Callaway are

radioactive gaseous and liquid effluents. As discussed previously, there would be no

change to the operation of Callaway radioactive GWMS and LWPS or their ability to

perform their intended functions. Also, there would be no change to the Callaway

radiation monitoring system and procedures used to control the release of radioactive

effluents in accordance with radiation protection standards in 10 CFR 20.1301,

40 CFR Part 190, Environmental Radiation Protection Standards for Nuclear Power

Operations, and the ALARA dose objectives in Appendix I to 10 CFR Part 50.

10 Based on this information, the offsite radiation dose to members of the public

would not change and would continue to be within regulatory limits. Therefore, the

license amendment and regulatory exemptions would not change offsite dose levels

and, consequently, there would be no significant health effects from the proposed action.

Design-Basis Accidents

Design-basis accidents at Callaway, are evaluated by both the licensee and the

NRC to ensure that the unit would continue to withstand the spectrum of postulated

accidents without undue hazard to the public health and safety and to ensure the

protection of the environment.

Separate from its environmental review, the NRC is evaluating the licensees

technical and safety analyses provided in support of the proposed action. The results of

the NRC staffs safety review and conclusion will be documented in a publicly available

safety evaluation. The NRC staff must conclude in its safety evaluation that taking the

proposed action will (1) provide reasonable assurance that the health and safety of the

public will not be endangered by operation in the proposed manner, (2) provide

reasonable assurance that such activities will be conducted in compliance with the

Commission's regulations, and (3) not be inimical to the common defense and security

or to the health and safety of the public. The NRC will not take the proposed action

absent such a safety conclusion.

Radiological Cumulative Impacts

The radiological dose limits for protection of the public and plant workers have

been developed by the NRC and the EPA to address the cumulative impact of acute and

long-term exposure to radiation and radioactive material. These dose limits are codified

in 10 CFR Part 20 and 40 CFR Part 190.

11 Cumulative radiation doses are required to be within the limits set forth in the

regulations cited in the previous paragraph. The license amendment and exemptions

would not require physical changes to the plant or changes to plant activities; in-plant

radiation sources would not change and offsite radiation dose to members of the public

would not change. Therefore, the NRC staff c oncludes that there would be no significant

cumulative radiological impact from the proposed action.

Radiological Impacts Summary

Based on these evaluations, the licens e amendment and exemptions would not

result in any significant radiological impacts. Therefore, the safety evaluation must

conclude that the proposed action will (1) provide reasonable assurance that the health

and safety of the public will not be endangered by operation in the proposed manner,

(2) provide reasonable assurance that such activities will be conducted in compliance

with the Commission's regulations, and (3) not be inimical to the common defense and

security or to the health and safety of the public. The NRC would not take the proposed

action absent such a safety conclusion.

Environmental Impacts of the Alternatives to the Proposed Action

As discussed earlier, licensees have options for responding to GL 2004-02 and

for demonstrating compliance with 10 CFR 50.46. Consistent with these options and as

an alternative to the proposed action, the licensee could choose to remove and replace

insulation within the reactor containment building. This alternative would require the

physical removal and disposal of significant amounts of insulation from a radiation area

within the reactor containment building, and the installation of new insulation less likely

to impact sump performance.

The removal of the existing insulation from the containment building would

generate radiologically contaminated waste. Ameren estimated that approximately

12 5,500 cubic feet (6.6 tons) of fiberglass insulation would have to be removed from the

Callaway containment. The removed insulation would require special handling and

packaging so that it could be safely transported from the site. The licensee would likely

use existing facilities to process and store this material until it could be transported to a

low-level radioactive or hazardous waste disposal site. Energy (fuel) would be

expended to transport the insulation and land would be expended at the disposal site.

The removal of the old insulation and installation of new insulation would expose

workers to radiation. Based on planning documents prepared in 2010, Ameren

estimated that the expected total dose for replacing insulation in Callaway, would be

between 350 and 400 person-rem. This estimate was considered in line with estimates

from other utilities impacted by this same issue. Ameren also indicated that this initial

estimate would now likely be higher due to the intervening 12 years of continuous plant

operation. The NRC reviewed NUREG-0713, Volume 41, Occupational Radiation

Exposure at Commercial Nuclear Power Reactors and Other Facilities: Fifty-Second

Annual Report, and determined that Amerens average baseline collective radiation

exposure is approximately 22 person-rem. The additional 350 to 400-plus person-rem

collective exposure would be shared across the entire work force involved with removing

and reinstalling insulation. In SECY-12-0093, the NRC staff attempted to develop a total

occupational dose estimate for the work involved in insulation removal and replacement

associated with GSI-191. Due to uncertainties in the scope of work required to remove

and replace insulation at a specific nuclear plant and other site-specific factors such as

source term and hazardous materials, the NRC staff was unable to estimate the total

occupational dose associated with this work. However, dose estimates were provided

by the Nuclear Energy Institute (NEI) in a letter to the NRC dated March 30, 2012, based

on information collected on occupational radi ation exposures that have been, or could

13 be, incurred during insulation removal and replacement. In the letter, NEI noted similar

difficulties in estimating the potential amount of radiation exposure, but provided a per

unit estimate of between 80 and 525 person-rem. Given uncertainties in the scope of

work and other nuclear plant-specific factors such as source term and hazardous

materials, the NRC staff found no basis to conclude that the NEI estimates were

unreasonable. Accordingly, because Amerens estimate of potential additional radiation

exposure resulting from the alternative approach of removing and replacing insulation is

consistent with the NEI estimated range, the NRC staff considers Amerens estimate to

be reasonable.

As stated in the Occupational Radiation Doses section of this document,

Amerens radiation protection program monitors radiation levels throughout the nuclear

plant to establish appropriate work controls, training, temporary shielding, and protective

equipment requirements so that worker doses are expected to remain within the dose

limits in 10 CFR 20.1201.

In addition, as stated in the Offsite Radiation Dose section of this document,

Ameren also has a radiation monitoring system and procedures in place to control the

release of radioactive effluents in accordance with radiation protection standards in

10 CFR 20.1301, 40 CFR Part 190, and the ALARA dose objectives in Appendix I to

10 CFR Part 50. Therefore, radiation exposure to members of the public would be

maintained within the NRC dose criteria in 10 CFR 20.1301, 40 CFR Part 190, and the

ALARA dose objectives of appendix I to 10 CFR Part 50.

Based on this information, impacts to members of the public from removing and

replacing insulation within the reactor containment building would not be significant.

However, impacts to plant workers and the environment from implementing this

alternative would be greater than implementing the proposed action.

14 Alternative Use of Resources

The proposed action would not involve the use of any different resources (e.g.,

water, air, land, nuclear fuel) not previously considered in NUREG-1437,

Supplement 51.

Agencies and Persons Consulted

In accordance with its stated policy, on June 27, 2022, the NRC staff consulted

with the State of Missouri official, Mr. Aaron Schmidt, regarding the environmental

impact of the proposed action. The State of Missouri official has not provided any

comments on the EA and FONSI.

III. Finding of No Significant Impact

The licensee requested to amend Renewed Facility Operating License No. NPF-

30 to grant exemptions for Callaway, from certain requirements of 10 CFR 50.46(a)(1)

and 10 CFR Part 50, Appendix A, GDC 35, 38, and 41. This proposed action would not

significantly affect plant safety, would not have a significant adverse effect on the

probability of an accident occurring, and would not have any significant radiological or

non-radiological impacts. It would also not result in any changes to radioactive effluents

or emissions, exposures to nuclear plant workers and members of the public, or any

changes to radiological and non-radiological impacts to the environment.

Consistent with 10 CFR 51.21, the NRC conducted an environmental review of

the proposed action. Based on the EA included in Section II of this notice and

incorporated by reference in this FONSI, the NRC staff finds that the proposed action will

not have a significant effect on the quality of the human environment. Accordingly, the

NRC has determined there is no need to prepar e an environmental impact statement for

the proposed action.

15 The NRC staffs evaluation considered the information provided in the licensees

application as supplemented, and the NRC staffs review of related environmental

documents.Section IV of this notice lists documents related to the proposed action and

includes information on the availability of the documents, including the related

environmental document NUREG-1437, Supplement 51, which provides the latest

environmental review of current operations and description of environmental conditions

at Callaway.

This FONSI and other related environmental documents may be examined,

and/or copied for a fee, at the NRCs PDR, located at One White Flint North,

11555 Rockville Pike, Rockville, Maryland 20852. Publicly available records are also

accessible online in the ADAMS Public Documents collection at

https://www.nrc.gov/reading-rm/adams.html. Persons who do not have access to

ADAMS or who encounter problems in acce ssing the documents located in ADAMS

should contact the NRCs PDR reference staff by telephone at 1-800-397-4209 or 301-

415-4737, or by email to PDR.Resource@nrc.gov.

IV. Availability of Documents.

The documents identified in the following table are available to interested

persons through one or more of the following methods, as indicated.

DOCUMENT ADAMS ACCESSION NO.

U.S. Nuclear Regulatory Commission. ML042360586 Generic Letter 2004-02: Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors, dated September 13, 2004.

U.S. Nuclear Regulatory Commission. ML112440046 NUREG-0897, Containment Emergency Sump Performance: Technical Findings Related to Unresolved Safety Issue A-43, Revision 1, October 1985.

16 DOCUMENT ADAMS ACCESSION NO.

Ameren Missouri. ML21090A184 (package)

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," dated March 31, 2021.

Ameren Missouri. ML21147A222 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.

Ameren Missouri. ML21203A192 (package)

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.

Ameren Missouri. ML21237A135 (package)

Letter ULNRC-06683, Transmittal of Documents Identified from NRC Audit of License Amendment Request Regarding Risk-Informed Approach to Closure of Generic Safety Issue 191 (EPID L-2021-LLA-0059),

dated August 23, 2021.

Ameren Missouri. ML21280A378 (package)

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.

Ameren Missouri ML22027A804 (package)

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)," dated January 27, 2022.

Ameren Missouri. ML22068A027 (package)

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)," dated March 8, 2022.

17 DOCUMENT ADAMS ACCESSION NO.

Ameren Missouri. ML22146A337 (package)

Letter 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, dated May 26, 2022.

Nuclear Energy Institute. ML12095A319 GSI-191 Dose Estimates, dated March 30, 2012.

SECY-12-0093, Closure Options for Generic Safety ML121320270 (package)

Issue - 191, Assessment of Debris Accumulation on Pressurized-Water Reactor Sump Performance, dated July 9, 2012.

SRM-SECY-12-0093, Staff Requirements - SECY ML12349A378 0093 - Closure Options for Generic Safety Issue - 191, Assessment of Debris Accumulation on Pressurized-Water Reactor Sump Performance, dated December 14, 2012.

U.S. Nuclear Regulatory Commission. ML14289A140 NUREG-1437, Supplement 51, Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Supplement 51 Regarding Callaway Plant, Unit 1: Final Report, October 2014.

U.S. Nuclear Regulatory Commission. ML22111A013 NUREG-0713, Volume 41, Occupational Radiation Exposure at Commercial Nuclear Power Reactors and Other Facilities 2019: Fifty-Second Annual Report, April 2022.

Dated: August 23, 2022.

For the Nuclear Regulatory Commission.

/RA/

Siva P. Lingam, Project Manager, Plant Licensing Branch IV, Division of Operator Reactor Licensing, Office of Nuclear Reactor Regulation.

18

Package ML22182A401 Letter ML22182A411 FRN ML22182A406 *byemail OFFICE NRR/DORL/LPL4/PM* NRR/DORL/LPL4/LA* NMSS/REF/ERLRB/BC*

NAME MChawla PBlechman TSmith DATE 7/1/2022 7/1/2022 7/5/2022 OFFICE OGC - NLO* NRR/DORL/LPL4/BC* NRR/DORL/LPL/PM*

NAME JEzell JDixon-Herrity MChawla (SLingam for)

DATE 8/17/2022 8/19/2022 8/23/2022