ULNRC-06264, Callaway Plant, Unit 1 - Revision of TS 2.1.1.1 and 5.6.5 to Remove Uncertainties from the DNBR Safety Limit and Adopt Approved WCAP-14565-P-A Methodology: Difference between revisions

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#REDIRECT [[ULNRC-06264, Revision of TS 2.1.1.1 and 5.6.5 to Remove Uncertainties from the DNBR Safety Limit and Adopt Approved WCAP-14565-P-A Methodology]]
| number = ML15313A192
| issue date = 11/09/2015
| title = Callaway Plant, Unit 1 - Revision of TS 2.1.1.1 and 5.6.5 to Remove Uncertainties from the DNBR Safety Limit and Adopt Approved WCAP-14565-P-A Methodology
| author name = Maglio S A
| author affiliation = Ameren Missouri
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000483
| license number = NPF-030
| contact person =
| case reference number = ULNRC-06264
| document type = Letter type:ULNRC, Technical Specification, Amendment
| page count = 7
}}
 
=Text=
{{#Wiki_filter:Callaway Plant MISSOURI November 09, 2015 ULNRC-06264 U.S.Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-000 1 10 CFR 50.90 Ladies and Gentlemen:
DOCKET NUMBER 50-483 CALLA WAY PLANT UNIT 1 UNION ELECTRIC CO.RENEWED FACILITY OPERATING LICENSE NPF-30 REVISION OF TS 2.1.1.1 AND 5.6.5 TO REMOVE UNCERTAINTIES FROM THE DNBR SAFETY LIMIT AND ADOPT APPROVED WCAP-14565-P-A METHODOLOGY
 
==Reference:==
 
ULNRC-06215 Letter from S.A.Maglio (Ameren Missouri)to U.S.Nuclear Regulatory Commission,"Revision of TS 2.1.1.1 and 5.6.5 to Remove Uncertainties from the DNBR Safety Limit and Adopt Approved WCAP-14565-P-A Methodology,"
dated May 8, 2015[NRC ADAMS Accession Number ML15132A137j In the referenced document above, Ameren Missouri submitted an application for amendment to Renewed Facility License Number NPF-30 for the Callaway Plant.That amendment application proposed changes to Technical Specification (TS)requirements to adopt the NRC approved methodology described in WCAP-14565-P-A Addendum 2-P-A,"Extended Application of ABB-NV Correlation and Modified ABB-NV Correlation WLOP for PWR Low Pressure Applications,"
and revise TS 2.1.1.1 to provide a safety limit for the Departure from Nucleate Boiling Ratio (DNBR)that is aligned with the original intent of approved topical report WCAP-144$3,"Generic Methodology for Expanded Core Operating Limits Report."From the NRC staffs review, a request for additional information (RAI)was identified and issued electronically on October 13, 2015 with a response requested by November 12, 2015.Attachment 1 provides the requested information.
The information provided in Attachment 1 does not affect the licensing evaluations submitted in the referenced amendment application, nor does Attachment 1 alter the conclusions of those licensing evaluations.
Ameren Missouri continues to request approval of this license amendment request prior to reactor criticality during the restart from the upcoming Refuel 21 outage.Reactor criticality is currently scheduled for May 04, 2016.As noted in Ameren Missouri's May 08, 2015 letter, Ameren Missouri PD Box 620: Fulton, I'1O 65251: rnerenIVissouri.corn STARS Alliance ULNRC-06264 November 09, 2015 Page 2 requests that the license amendment be made effective upon NRC issuance, to be implemented within 90 days from the date of issuance.This submittal does not contain new commitments.
If there are any questions, please contact Mr.Tom Elwood at 314-225-1905.
I declare under penalty of perjury that the foregoing is true and correct.Sincerely, Executed on:/10 tf7 4 Scott A.Maglio Manager, Regulatory Affairs TAW Attachments:
1.Response to NRC Request for Additional Information Regarding LDCN 15-0005 ULNRC-06264 November 06, 2015 Page 3 cc: Mr.Marc L.Dapas Regional Administrator U.S.Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Senior Resident Inspector Callaway Resident Office U.S.Nuclear Regulatory Commission
$201 NRC Road$teedman, MO 65077 Mr.L.John Klos Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U.S.Nuclear Regulatory Commission Mail Stop O$H4 Washington, DC 20555-000 1 ULNRC-06264 November 06, 2015 Page 4 Index and send hardcopy to QA File A160.0761 Hardcopy: Certrec Corporation 6100 Western Place, Suite 1050 fort Worth, IX 76107 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)
Electronic distribution for the following can be made via Tech Spec ULNRC Distribution:
F.M.Diya D.W.Neterer L.H.Graessle T.E.Herrmann B.L.Cox L.H.Kanuckel S.A.Maglio I.B.Elwood Corporate Communications NSRB Secretary STARS Regulatory Affairs Mr.John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)Missouri Public Service Commission Mr.Robert D.Stout (DNR)Ms.Leanne Tippett-Mosby (DNR)
Enclosure to ULNRC-06264 Attachment 1 Page 1 of 3 ATTACHMENT 1 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING LDCN 15-0005 Enclosure to ULNRC-06264 Attachment 1 Page 2 of 3 REQUEST FOR ADDITIONAL INFORMATION CALLA WAY PLANT, UNIT 1 UNION ELECTRIC CO.LICENSE AMENDMENT APPLICATION TO REVISE IS 2.1.1.1 AND 5.6.5 TO REMOVE UNCERTAINTIES FROM THE DNBR SAFETY LIMIT AND ADOPT APPROVED WCAP-14565-P-A METHODOLOGY The NRC staff requests additional information to complete its review of the license amendment request (LAR)to revise Technical Specification (IS)2.1.1.1 and 5.6.5 to remove uncertainties from the Departure from Nucleate Boiling Ratio (DNBR)safety limit and adopt approved WCAP-14565-P-A methodology.
By letter dated May 08, 2015 (NRC ADAMS Accession No.ML15132A137), Ameren Missouri (the licensee)requested the removal of analytical uncertainties from TS 2.1.1.1 consistent with the intent of WCAP-144$3-A.
From NRC staff review of the provided application, the NRC staff has the following question listed below.Question 1 10 CFR 50.36(c)requires licensees to include safety limits in the TS, defined as limits upon important process variables that are found to be necessary to reasonably protect the integrity of certain of the physical barriers that guard against the uncontrolled release of radioactivity.
The Departure from Nucleate Boiling Ration (DNBR)limit is one such safety limit, since it protects the integrity of the fuel cladding.The proposed change to IS 2.1.1.1 would only specify the 95/95 DNBR limit associated with the WRB-2 correlation.
However, the license amendment request is requesting approval of two additional alternative DNB correlations, each of which has its own unique DNBR limit.Please explain why the DNBR limits associated with the ABB-NV and Westinghouse Low Pressure Departure from Nucleate Boiling correlations are not being included in IS 2.1.1.1.RAI Response The proposed Technical Specification (TS)2.1.1.1 content provided in Reference 1 is consistent with the format in Volume 1 of NUREG-143 1, Revision 4 (Reference 2).The current format for TS 2.1.1.1 in Reference 2 is based on the approved topical report WCAP-14483-A,"Generic Methodology for Expanded Core Operating Limits Report,"(Reference 3).The Safety Evaluation Report (SER)for Reference 3 states that the safety limits, which were originally included in the Westinghouse TS as the Reactor Core Limits figure (Figure 2.1.1-1)to satisfy 1OCFR5O.36, are"intended to provide the relationship between the process variables that are available Enclosure to ULNRC-06264 Attachment 1 Page 3 of 3 to the operator (i.e., T-avg, pressurizer pressure, and thermal power)and the DNB design basis safety limit."With the approval of Reference 3, the Reactor Core Limits figure itself was moved from TS 2.1.1.1 to the COLR, and replaced with the true safety limits (DNBR and fuel melting limits)that are protected by staying within the bounds for the process variables defined by the Reactor Core Limits figure, thereby ensuring that the intent of 1OCFR5O.36 is satisfied.
Since the WRB-2 correlation is the only DNB correlation used to establish the COLR Reactor Core Limits figure for the Callaway plant, only the WRB-2 correlation and the associated 95/95 DNBR limit are specifically listed in TS 2.1.1.1.This is consistent with the format for 15 2.1.1.1 as specified in Reference 2.While the ABB-NV and Westinghouse Low Pressure (WLOP)DNB correlations will be used in the safety analyses for the Callaway plant, these correlations are neither applicable to nor will they be used for the establishment of the COLR Reactor Core Limits figure.It is not appropriate to list any DNB correlations and their associated limits in TS 2.1.1.1 that are not used in the establishment of the COLR Reactor Core Limits figure.
 
==References:==
 
1.Letter from S.A.Maglio (Ameren Missouri)to U.S.Nuclear Regulatory Commission,"Revision of TS 2.1.1.1 and 5.6.5 to Remove Uncertainties from the DNBR Safety Limit and Adopt Approved WCAP-14565-P-A Methodology' dated May 8, 2015[Nuclear Regulatory Commission ADAMS Accession Number ML 1513 2A 137].2.Standard Technical Specifications
-Westinghouse Plants: Volume 1, Specifications, NUREG 1431, Revision 4, April, 2012.3.D.S.Huegel, J.D.Andrachek, and C.E.Morgan,"Generic Methodology for Expanded Core Operating Limits Report,"WCAP-144$3-A, January, 1999.
Callaway Plant MISSOURI November 09, 2015 ULNRC-06264 U.S.Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-000 1 10 CFR 50.90 Ladies and Gentlemen:
DOCKET NUMBER 50-483 CALLA WAY PLANT UNIT 1 UNION ELECTRIC CO.RENEWED FACILITY OPERATING LICENSE NPF-30 REVISION OF TS 2.1.1.1 AND 5.6.5 TO REMOVE UNCERTAINTIES FROM THE DNBR SAFETY LIMIT AND ADOPT APPROVED WCAP-14565-P-A METHODOLOGY
 
==Reference:==
 
ULNRC-06215 Letter from S.A.Maglio (Ameren Missouri)to U.S.Nuclear Regulatory Commission,"Revision of TS 2.1.1.1 and 5.6.5 to Remove Uncertainties from the DNBR Safety Limit and Adopt Approved WCAP-14565-P-A Methodology,"
dated May 8, 2015[NRC ADAMS Accession Number ML15132A137j In the referenced document above, Ameren Missouri submitted an application for amendment to Renewed Facility License Number NPF-30 for the Callaway Plant.That amendment application proposed changes to Technical Specification (TS)requirements to adopt the NRC approved methodology described in WCAP-14565-P-A Addendum 2-P-A,"Extended Application of ABB-NV Correlation and Modified ABB-NV Correlation WLOP for PWR Low Pressure Applications,"
and revise TS 2.1.1.1 to provide a safety limit for the Departure from Nucleate Boiling Ratio (DNBR)that is aligned with the original intent of approved topical report WCAP-144$3,"Generic Methodology for Expanded Core Operating Limits Report."From the NRC staffs review, a request for additional information (RAI)was identified and issued electronically on October 13, 2015 with a response requested by November 12, 2015.Attachment 1 provides the requested information.
The information provided in Attachment 1 does not affect the licensing evaluations submitted in the referenced amendment application, nor does Attachment 1 alter the conclusions of those licensing evaluations.
Ameren Missouri continues to request approval of this license amendment request prior to reactor criticality during the restart from the upcoming Refuel 21 outage.Reactor criticality is currently scheduled for May 04, 2016.As noted in Ameren Missouri's May 08, 2015 letter, Ameren Missouri PD Box 620: Fulton, I'1O 65251: rnerenIVissouri.corn STARS Alliance ULNRC-06264 November 09, 2015 Page 2 requests that the license amendment be made effective upon NRC issuance, to be implemented within 90 days from the date of issuance.This submittal does not contain new commitments.
If there are any questions, please contact Mr.Tom Elwood at 314-225-1905.
I declare under penalty of perjury that the foregoing is true and correct.Sincerely, Executed on:/10 tf7 4 Scott A.Maglio Manager, Regulatory Affairs TAW Attachments:
1.Response to NRC Request for Additional Information Regarding LDCN 15-0005 ULNRC-06264 November 06, 2015 Page 3 cc: Mr.Marc L.Dapas Regional Administrator U.S.Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Senior Resident Inspector Callaway Resident Office U.S.Nuclear Regulatory Commission
$201 NRC Road$teedman, MO 65077 Mr.L.John Klos Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U.S.Nuclear Regulatory Commission Mail Stop O$H4 Washington, DC 20555-000 1 ULNRC-06264 November 06, 2015 Page 4 Index and send hardcopy to QA File A160.0761 Hardcopy: Certrec Corporation 6100 Western Place, Suite 1050 fort Worth, IX 76107 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)
Electronic distribution for the following can be made via Tech Spec ULNRC Distribution:
F.M.Diya D.W.Neterer L.H.Graessle T.E.Herrmann B.L.Cox L.H.Kanuckel S.A.Maglio I.B.Elwood Corporate Communications NSRB Secretary STARS Regulatory Affairs Mr.John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)Missouri Public Service Commission Mr.Robert D.Stout (DNR)Ms.Leanne Tippett-Mosby (DNR)
Enclosure to ULNRC-06264 Attachment 1 Page 1 of 3 ATTACHMENT 1 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING LDCN 15-0005 Enclosure to ULNRC-06264 Attachment 1 Page 2 of 3 REQUEST FOR ADDITIONAL INFORMATION CALLA WAY PLANT, UNIT 1 UNION ELECTRIC CO.LICENSE AMENDMENT APPLICATION TO REVISE IS 2.1.1.1 AND 5.6.5 TO REMOVE UNCERTAINTIES FROM THE DNBR SAFETY LIMIT AND ADOPT APPROVED WCAP-14565-P-A METHODOLOGY The NRC staff requests additional information to complete its review of the license amendment request (LAR)to revise Technical Specification (IS)2.1.1.1 and 5.6.5 to remove uncertainties from the Departure from Nucleate Boiling Ratio (DNBR)safety limit and adopt approved WCAP-14565-P-A methodology.
By letter dated May 08, 2015 (NRC ADAMS Accession No.ML15132A137), Ameren Missouri (the licensee)requested the removal of analytical uncertainties from TS 2.1.1.1 consistent with the intent of WCAP-144$3-A.
From NRC staff review of the provided application, the NRC staff has the following question listed below.Question 1 10 CFR 50.36(c)requires licensees to include safety limits in the TS, defined as limits upon important process variables that are found to be necessary to reasonably protect the integrity of certain of the physical barriers that guard against the uncontrolled release of radioactivity.
The Departure from Nucleate Boiling Ration (DNBR)limit is one such safety limit, since it protects the integrity of the fuel cladding.The proposed change to IS 2.1.1.1 would only specify the 95/95 DNBR limit associated with the WRB-2 correlation.
However, the license amendment request is requesting approval of two additional alternative DNB correlations, each of which has its own unique DNBR limit.Please explain why the DNBR limits associated with the ABB-NV and Westinghouse Low Pressure Departure from Nucleate Boiling correlations are not being included in IS 2.1.1.1.RAI Response The proposed Technical Specification (TS)2.1.1.1 content provided in Reference 1 is consistent with the format in Volume 1 of NUREG-143 1, Revision 4 (Reference 2).The current format for TS 2.1.1.1 in Reference 2 is based on the approved topical report WCAP-14483-A,"Generic Methodology for Expanded Core Operating Limits Report,"(Reference 3).The Safety Evaluation Report (SER)for Reference 3 states that the safety limits, which were originally included in the Westinghouse TS as the Reactor Core Limits figure (Figure 2.1.1-1)to satisfy 1OCFR5O.36, are"intended to provide the relationship between the process variables that are available Enclosure to ULNRC-06264 Attachment 1 Page 3 of 3 to the operator (i.e., T-avg, pressurizer pressure, and thermal power)and the DNB design basis safety limit."With the approval of Reference 3, the Reactor Core Limits figure itself was moved from TS 2.1.1.1 to the COLR, and replaced with the true safety limits (DNBR and fuel melting limits)that are protected by staying within the bounds for the process variables defined by the Reactor Core Limits figure, thereby ensuring that the intent of 1OCFR5O.36 is satisfied.
Since the WRB-2 correlation is the only DNB correlation used to establish the COLR Reactor Core Limits figure for the Callaway plant, only the WRB-2 correlation and the associated 95/95 DNBR limit are specifically listed in TS 2.1.1.1.This is consistent with the format for 15 2.1.1.1 as specified in Reference 2.While the ABB-NV and Westinghouse Low Pressure (WLOP)DNB correlations will be used in the safety analyses for the Callaway plant, these correlations are neither applicable to nor will they be used for the establishment of the COLR Reactor Core Limits figure.It is not appropriate to list any DNB correlations and their associated limits in TS 2.1.1.1 that are not used in the establishment of the COLR Reactor Core Limits figure.
 
==References:==
 
1.Letter from S.A.Maglio (Ameren Missouri)to U.S.Nuclear Regulatory Commission,"Revision of TS 2.1.1.1 and 5.6.5 to Remove Uncertainties from the DNBR Safety Limit and Adopt Approved WCAP-14565-P-A Methodology' dated May 8, 2015[Nuclear Regulatory Commission ADAMS Accession Number ML 1513 2A 137].2.Standard Technical Specifications
-Westinghouse Plants: Volume 1, Specifications, NUREG 1431, Revision 4, April, 2012.3.D.S.Huegel, J.D.Andrachek, and C.E.Morgan,"Generic Methodology for Expanded Core Operating Limits Report,"WCAP-144$3-A, January, 1999.}}

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