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| {{#Wiki_filter:November 30, 2021 Mr. Fadi Diya Senior Vice President and Chief Nuclear Officer Ameren Missouri Callaway Energy Center 8315 County Road 459 Steedman, MO 65077 | | {{#Wiki_filter:November 30, 2021 |
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| | Mr. Fadi Diya Senior Vice President and Chief Nuclear Officer Ameren Missouri Callaway Energy Center 8315 County Road 459 Steedman, MO 65077 |
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| ==SUBJECT:== | | ==SUBJECT:== |
| CALLAWAY PLANT, UNIT NO. 1 - SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF REQUESTED LICENSING ACTIONS RE: LICENSE AMENDMENT REQUEST FOR ADOPTION OF ALTERNATE SOURCE TERM AND REVISION OF TECHNICAL SPECIFICATIONS (EPID L-2021-LLA-0177) | | CALLAWAY PLANT, UNIT NO. 1 - SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF REQUESTED LICENSING ACTIONS RE: LICENSE AMENDMENT REQUEST FOR ADOPTI ON OF ALTERNATE SOURCE TERM AND REVISION OF TECHNICAL SPECIFICATIONS (EPID L-2021-LLA-0177) |
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| ==Dear Mr. Diya:== | | ==Dear Mr. Diya:== |
| | By {{letter dated|date=September 28, 2021|text=letter dated September 28, 2021}} (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21272A167), Union Electric Company, dba Ameren Missouri (the licensee) submitted a license amendment request for Callaway Pl ant, Unit No. 1 (Callaway). |
| | Pursuant to Title 10 of Code of Federal Regulations (10 CFR) Section 50.90, Application for amendment of license, construction permit, or early site permit, and 10 CFR 50.67, Accident Source Term, the licensee requested to incorporate the alterna tive source term dose analysis methodology into the Callaway licensing basis and to revise Callaway Technical Specifications 3.7.10, Control Room Emergency Ventilation Syst em (CREVS); 5.5.11, Ventilation Filter Testing Program (VFTP); and 5.5.17, Contr ol Room Envelope Habitability Program. |
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| | The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staffs acceptance review of this amendment request. The acceptance review was performed to determine if there is sufficient technical informa tion in scope and depth to allow the NRC staff to complete its detailed technical review. The accep tance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensin g basis of the plant. |
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| | Consistent with 10 CFR 50.90, an application for an amendment t o a license (including the technical specifications) must fully describe the changes reque sted, and following as far as applicable, the form prescribed for original applications. Sec tion 50.34 of 10 CFR addresses the content of technical information required. This section stipul ates that the submittal address the design and operating characteristics, unusual or novel design f eatures, and principal safety considerations. |
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| By {{letter dated|date=September 28, 2021|text=letter dated September 28, 2021}} (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21272A167), Union Electric Company, dba Ameren Missouri (the licensee) submitted a license amendment request for Callaway Plant, Unit No. 1 (Callaway).
| | The NRC staff has reviewed your application and concluded that the information delineated in the enclosure to this letter is necessary to enable the staff t o make an independent assessment regarding the acceptability of the proposed amendment request i n terms of regulatory requirements for the protection of public health and safety and the environment. |
| Pursuant to Title 10 of Code of Federal Regulations (10 CFR) Section 50.90, Application for amendment of license, construction permit, or early site permit, and 10 CFR 50.67, Accident Source Term, the licensee requested to incorporate the alternative source term dose analysis methodology into the Callaway licensing basis and to revise Callaway Technical Specifications 3.7.10, Control Room Emergency Ventilation System (CREVS); 5.5.11, Ventilation Filter Testing Program (VFTP); and 5.5.17, Control Room Envelope Habitability Program.
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| The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staffs acceptance review of this amendment request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparentinformation insufficiencies in its characterization of the regulatory requirements or the licensingbasis of the plant.
| | F. Diya |
| Consistent with 10 CFR 50.90, an application for an amendment to a license (including the technical specifications) must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications. Section 50.34 of 10 CFR addresses the content of technical information required. This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations.
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| The NRC staff has reviewed your application and concluded that the information delineated in the enclosure to this letter is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed amendment request in terms of regulatory requirements for the protection of public health and safety and the environment. | | In order to make the application complete, the NRC staff reques ts that the licensee supplement the application to address the information requested in the enc losure by December 1, 2021. |
| | This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staffs request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, Filing of app lication, and the NRC will cease its activities associated with the application. If the a pplication is subsequently accepted for review, you will be advised of any further information need ed to support the NRC staffs detailed technical review by separate correspondence. |
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| | The information requested and associated timeframe in this lett er were discussed with Mr. Thomas Elwood of your staff on November 10, 2021. |
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| F. Diya In order to make the application complete, the NRC staff requests that the licensee supplement the application to address the information requested in the enclosure by December 1, 2021.
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| This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staffs request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, Filing of application, and the NRC will cease its activities associated with the application. If the application is subsequently accepted for review, you will be advised of any further information needed to support the NRC staffs detailed technical review by separate correspondence.
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| The information requested and associated timeframe in this letter were discussed with Mr. Thomas Elwood of your staff on November 10, 2021.
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| If you have any questions regarding this matter, please contact me at 301-415-8371, or by e-mail to Mahesh.Chawla@nrc.gov. | | If you have any questions regarding this matter, please contact me at 301-415-8371, or by e-mail to Mahesh.Chawla@nrc.gov. |
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| Sincerely, | | Sincerely, |
| /RA/
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| Mahesh L. Chawla, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483 | | /RA/ |
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| | Mahesh L. Chawla, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation |
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| | Docket No. 50-483 |
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| ==Enclosure:== | | ==Enclosure:== |
| | Supplemental Information Needed |
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| | cc: Listserv SUPPLEMENTAL INFORMATION NEEDED |
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| | LICENSE AMENDMENT REQUEST FOR ADOPTION OF ALTERNATE SOURC TERM AND |
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| | REVISION OF TECHNICAL SPECIFICATIONS |
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| | UNION ELECTRIC COMPANY |
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| | CALLAWAY PLANT, UNIT NO. 1 |
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| Supplemental Information Needed cc: Listserv
| | DOCKET NO. 50-483 |
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| SUPPLEMENTAL INFORMATION NEEDED LICENSE AMENDMENT REQUEST FOR ADOPTION OF ALTERNATE SOURC TERM AND REVISION OF TECHNICAL SPECIFICATIONS UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT NO. 1 DOCKET NO. 50-483 By {{letter dated|date=September 28, 2021|text=letter dated September 28, 2021}} (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21272A167), Union Electric Company, dba Ameren Missouri (the licensee) submitted a license amendment request (LAR) for Callaway Plant, Unit No. 1 (Callaway). Pursuant to Title 10 of Code of Federal Regulations (10 CFR) Section 50.90, Application for amendment of license, construction permit, or early site permit, and 10 CFR 50.67, Accident Source Term, the licensee requested to incorporate the alternative source term dose analysis methodology into the Callaway licensing basis and to revise Callaway Technical Specifications 3.7.10, Control Room Emergency Ventilation System (CREVS);
| | By {{letter dated|date=September 28, 2021|text=letter dated September 28, 2021}} (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21272A167), Union Electric Company, dba Ameren Missouri (the licensee) submitted a license amendment request (LAR) for Calla way Plant, Unit No. 1 (Callaway). Pursuant to Title 10 of Code of Federal Regulations (10 CFR) Section 50.90, Application for amendment of license, construction permit, or early site permit, and 10 CFR 50.67, Accident Source Term, the licensee requested to incorporate the alternative source term dose analysis methodology into the Callaway licensi ng basis and to revise Callaway Technical Specifications 3.7.10, Control Room Emergency Ventilation System (CREVS); |
| 5.5.11, Ventilation Filter Testing Program (VFTP); and 5.5.17, Control Room Envelope Habitability Program. | | 5.5.11, Ventilation Filter Testing Program (VFTP); and 5.5.17, Control Room Envelope Habitability Program. |
| REGULATORY BASIS During its acceptance review of the licensees submittal, the NRC staff identified that it required additional information to be able to confirm direct input to the licensees radiological dose evaluation. In particular, data and information related to the accident-related onsite and offsite atmospheric dispersion models and the meteorological (Met) data input to them. These needs were discussed during previous pre-application submittal meetings. The required data and information are identified below. | | |
| The regulatory basis for this request is first rooted in the phrase following as far as applicable, the form prescribed for original applications, from the regulation at 10 CFR 50.90. | | REGULATORY BASIS |
| The regulation at 10 CFR 50.67(b)(1) go on to state that [t]he application shall contain an evaluation of the consequences of applicable design-basis accidents previously analyzed in the safety analysis report. In turn, the regulation at 10 CFR 50.67(b)(2) requires that the applicant's analysis demonstrates with reasonable assurance that the dose limits at any point on the exclusion area boundary (EAB) and the outer boundary of the low population zone (LPZ), | | |
| and at the control room, are met. Those dose analyses require, as a direct input, dispersion parameters, which are based on the use of appropriate dispersion models that rely, in part, on the input of representative Met data. | | During its acceptance review of the licensees submittal, the N RC staff identified that it required additional information to be able to confirm direct input to th e licensees radiological dose evaluation. In particular, data and information related to the accident-related onsite and offsite atmospheric dispersion models and the meteorological (Met) data input to them. These needs were discussed during previous pre-application submittal meetin gs. The required data and information are identified below. |
| BACKGROUND INFORMATION Several items needed to support the NRC staffs technical review were initially identified during a discussion at the June 14, 2018, pre-submittal LAR meeting, and as described in the meeting summary dated August 21, 2018 (ADAMS Accession No. ML18215A375). The August 21, 2018, meeting summary was also referenced in the meeting summary dated April 16, 2021 (ADAMS Accession No. ML21103A003), of a subsequent pre-submittal meeting held on Enclosure | | |
| | The regulatory basis for this request is first rooted in the ph rase following as far as applicable, the form prescribed for original applications, fro m the regulation at 10 CFR 50.90. |
| | The regulation at 10 CFR 50.67(b)(1) go on to state that [t]he application shall contain an evaluation of the consequences of applicable design-basis accid ents previously analyzed in the safety analysis report. In turn, the regulation at 10 CFR 50. 67(b)(2) requires that the applicant's analysis demonstrates with reasonable assurance that the dose limits at any point on the exclusion area boundary (EAB) and the outer boundary of the low population zone (LPZ), |
| | and at the control room, are met. Those dose analyses require, as a direct input, dispersion parameters, which are based on the use of appropriate dispersio n models that rely, in part, on the input of representative Met data. |
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| | BACKGROUND INFORMATION |
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| | Several items needed to support the NRC staffs technical revie w were initially identified during a discussion at the June 14, 2018, pre-submittal LAR meeting, a nd as described in the meeting summary dated August 21, 2018 (ADAMS Accession No. ML18215A375). The August 21, 2018, meeting summary was also referenced in the meeting summar y dated April 16, 2021 (ADAMS Accession No. ML21103A003), of a subsequent pre-submitta l meeting held on |
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| March 15, 2021. Items called for in the June 14, 2018, meeting, to be part of the AST LAR submittal that the NRC staff finds were not included, are: | | March 15, 2021. Items called for in the June 14, 2018, meeting, to be part of the AST LAR submittal that the NRC staff finds were not included, are: |
| Item 20.c Provide sequential hourly (ASCII-character) data files for each year in accordance with the format in Appendix A of RG 1.23, Revision 1, including respective units of measure. If a different submission is made, please explain the data format provided. | | |
| Item 20.d Provide sequential hourly (ASCII-character) data files in format, required for input to ARCON96 including respective units of measure. | | Item 20.c Provide sequential hourly (ASCII-character) data fi les for each year in accordance with the format in Appendix A of RG 1.23, Revision 1, |
| Item 21.c A submittal of the text files of [PAVAN or PAVAN-NAI] model input and output for all runs. | | including respective units of measure. If a different submissi on is made, please explain the data format provided. |
| Item 22.c A submittal of the text files of [ARCON96 or ARCON96-NAI] model input and output for all runs. | | |
| The Met data files in Items 20.c and 20.d are reviewed and needed as input to NRCs confirmatory PAVAN and ARCON96 dispersion model runs. The text files called for in Items 21.c and 22.c are reviewed and used to build the confirmatory model run files of the dispersion analyses at offsite (i.e., the EAB and outer boundary of the LPZ) and onsite (control room and technical support center) receptors. | | Item 20.d Provide sequential hourly (ASCII-character) data fi les in format, required for input to ARCON96 including respective units of measure. |
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| | Item 21.c A submittal of the text files of [PAVAN or PAVAN-NAI ] model input and output for all runs. |
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| | Item 22.c A submittal of the text files of [ARCON96 or ARCON96 -NAI] model input and output for all runs. |
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| | The Met data files in Items 20.c and 20.d are reviewed and needed as input to NRCs confirmatory PAVAN and ARCON96 dispersion model runs. The text files called for in Items 21.c and 22.c are reviewed and used to build the confirma tory model run files of the dispersion analyses at offsite (i.e., the EAB and outer boundar y of the LPZ) and onsite (control room and technical support center) receptors. |
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| Further, the NRC staff notes that the licensee cited dispersion models of different names (i.e., | | Further, the NRC staff notes that the licensee cited dispersion models of different names (i.e., |
| PAVAN-NAI and ARCON96-NAI) in its presentation slides during pre-application meetings. On the other hand, the proposed revisions to the Callaway Updated Final Safety Analysis Report appear to refer only to the NRC versions of the PAVAN and ARCON96 dispersion models. As a result, it cannot yet be concluded that either PAVAN and PAVAN-NAI and/or ARCON96 and ARCON96-NAI are equivalent. | | PAVAN-NAI and ARCON96-NAI) in its presentation slides during pr e-application meetings. On the other hand, the proposed revisions to the Callaway Updated Final Safety Analysis Report appear to refer only to the NRC versions of the PAVAN and ARCON 96 dispersion models. As a result, it cannot yet be concluded that either PAVAN and PAVAN-NAI and/or ARCON96 and ARCON96-NAI are equivalent. |
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| SUPPLEMENTAL DATA AND INFORMATION NEEDED | | SUPPLEMENTAL DATA AND INFORMATION NEEDED |
| : 1) Provide the requested Met data and dispersion model input and output files identified in Items 20.c, 20.d, 21.c, and 22.c as indicated in ADAMS Accession No. ML18215A375 and discussed during our clarification call of October 27, 2021. | | : 1) Provide the requested Met data and dispersion model input an d output files identified in Items 20.c, 20.d, 21.c, and 22.c as indicated in ADAMS Accessio n No. ML18215A375 and discussed during our clarification call of October 27, 2021. |
| : 2) Clarify any differences between the PAVAN and PAVAN-NAI and the ARCON96 and ARCON96-NAI dispersion models. | | : 2) Clarify any differences between the PAVAN and PAVAN-NAI and the ARCON96 and ARCON96-NAI dispersion models. |
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| ML21319A006 *by e-mail OFFICE NRR/DORL/LPL4/PM* NRR/DORL/LPL4/LA* NRR/DEX/EXHB/BC NAME MChawla PBlechman BHayes DATE 11/15/2021 11/15/2021 11/15/2021 OFFICE NRR/DORL/LPL4/BC* NRR/DORL/LPL4/PM* | | ML21319A006 *by e-mail OFFICE NRR/DORL/LPL4/PM* NRR/DORL/LPL4/LA* NRR/DEX/EXHB/BC NAME MChawla PBlechman BHayes DATE 11/15/2021 11/15/2021 11/15/2021 OFFICE NRR/DORL/LPL4/BC* NRR/DORL/LPL4/PM* |
| NAME JDixon-Herrity MChawla DATE 11/30/2021 11/30/2021}} | | NAME JDixon-Herrity MChawla DATE 11/30/2021 11/30/2021}} |
Letter Sequence Acceptance Review |
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EPID:L-2021-LLA-0177, License Amendment Request for Adoption of Alternate Source Term and Revision of Technical Specifications (Approved, Closed) |
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Category:Letter
MONTHYEARIR 05000483/20240032024-10-23023 October 2024 Integrated Inspection Report 05000483/2024003 IR 05000483/20240132024-10-21021 October 2024 Design Basis Assurance Inspection (Programs) Inspection Report 05000483/2024013 IR 05000483/20244012024-10-0909 October 2024 Material Control and Accounting Program Inspection Report 05000483/2024401 Public ULNRC-06901, Concurrent Inoperability of Control Room Air Conditioning System Train and Opposite Train Emergency Diesel Generator Results in Condition Prohibited by Technical Specifications Limiting (Letter)2024-10-0101 October 2024 Concurrent Inoperability of Control Room Air Conditioning System Train and Opposite Train Emergency Diesel Generator Results in Condition Prohibited by Technical Specifications Limiting (Letter) ML24247A3042024-09-11011 September 2024 Regulatory Audit Questions for License Renewal Commitments 34 and 35 (EPID L-2024-LRO-0009) - Non-Proprietary IR 05000483/20244032024-08-28028 August 2024 Security Baseline Inspection 05000483-2024-403 IR 05000483/20240052024-08-14014 August 2024 Updated Inspection Plan for Callaway Plant (Report 05000483/2024005) IR 05000483/20253012024-08-0505 August 2024 Notification of NRC Initial Operator Licensing Examination 05000483/2025301 ML24212A2822024-08-0202 August 2024 Regulatory Audit Summary Concerning Review of Request No. C3R-01 for Proposed Alternative to ASME Code, Section XI Requirements for Containment Building Inspections IR 05000483/20240022024-07-18018 July 2024 And Independent Spent Fuel Storage Installation Integrated Inspection Report 05000483/2024002 and 07201045/2024001 ML24185A1032024-07-16016 July 2024 2024 Biennial Problem Identification and Resolution Inspection Report ULNRC-06892, Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC00062024-06-26026 June 2024 Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC0006 ULNRC-06891, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00052024-06-26026 June 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0005 ULNRC-06884, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00022024-06-12012 June 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0002 ULNRC-06886, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00042024-06-12012 June 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0004 ULNRC-06885, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00032024-06-12012 June 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0003 ML24144A0492024-06-11011 June 2024 Requests for Relief from ASME OM Code Pump and Valve Testing Requirements for Fifth 120-Month Inservice Testing Interval ML24158A5222024-06-0606 June 2024 Application to Revise Technical Specifications to Adopt Tstf-569, Rev. 2, Revise Response Time Testing Definition (LDCN 24-0008) ML24178A1132024-06-0606 June 2024 Ameren Missouris Intent to Adopt Revision 1 to Amendment 0 of Certificate of Compliance No. 1040 as Applicable to the ISFSI at the Callaway Plant Site ML24143A1632024-05-23023 May 2024 Independent Spent Fuel Storage Installation Registration of Dry Spent Storage Canister HGMPC0001 ULNRC-06882, Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC00122024-05-16016 May 2024 Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC0012 ML24137A2342024-05-16016 May 2024 Independent Spent Fuel Storage Installation - Registration of Dry Spent Fuel Storage Canister HGMPC0011 ML24122A1502024-05-0707 May 2024 Audit Plan to Support Review of Steam Generator License Renewal Response to Commitment Nos 34 and 35 ULNRC-06877, Final Safety Analysis Report Revision OL-27 and Technical Specification Bases Revision 252024-05-0606 May 2024 Final Safety Analysis Report Revision OL-27 and Technical Specification Bases Revision 25 IR 05000483/20244022024-05-0606 May 2024 Security Baseline Inspection Report 05000483/2024402 (Full Report) IR 05000483/20240112024-05-0101 May 2024 NRC Post-Approval Site Inspection for License Renewal (Phase 2) Report 05000483/2024011 ULNRC-06856, CFR 50.59 and 10 CFR 72.48 Summary Report2024-05-0101 May 2024 CFR 50.59 and 10 CFR 72.48 Summary Report ULNRC-06869, Submittal of Callaway, Unit 1, 2023 Annual Radiological Environmental Operating Report2024-04-30030 April 2024 Submittal of Callaway, Unit 1, 2023 Annual Radiological Environmental Operating Report ML24122A1132024-04-30030 April 2024 Submittal of Callaway, Unit 1, 2023 Annual Radioactive Effluent Release Report ULNRC-06876, Registration of Dry Spent Fuel Storage Canister HGMPC00102024-04-25025 April 2024 Registration of Dry Spent Fuel Storage Canister HGMPC0010 ML24108A1082024-04-17017 April 2024 Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC0009 ULNRC-06871, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00072024-04-17017 April 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0007 ULNRC-06872, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00082024-04-17017 April 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0008 ULNRC-06866, Submittal of Cycle 26 Commitment Change Summary Report2024-04-17017 April 2024 Submittal of Cycle 26 Commitment Change Summary Report IR 05000483/20240012024-04-16016 April 2024 Integrated Inspection Report 05000483/2024001 IR 05000483/20244042024-04-0909 April 2024 Cyber Security Inspection Report 05000483/2024404 ML24088A3212024-04-0101 April 2024 Notification of Commercial Grade Dedication Inspection (05000483/2024013) and Request for Information ML24086A5132024-03-26026 March 2024 CFR 50.46 Annual Report Regarding ECCS Evaluation Model Revisions ULNRC-06863, Submittal of Annual Exposure Report for 20232024-03-20020 March 2024 Submittal of Annual Exposure Report for 2023 ML24079A1622024-03-19019 March 2024 Re Nuclear Property Insurance Reporting ML24066A1932024-03-0707 March 2024 2024 Callaway Plant Notification of Biennial Problem Identification and Resolution Inspection and Request for Information ULNRC-06852, Owners Activity Reports (OAR-1 Forms) for Cycle/Refuel 262024-03-0505 March 2024 Owners Activity Reports (OAR-1 Forms) for Cycle/Refuel 26 IR 05000483/20230062024-02-28028 February 2024 Annual Assessment Letter for Callaway Plant Report 05000483/2023006 ML24052A3662024-02-26026 February 2024 Regulatory Audit Plan in Support of Proposed Alternative to ASME Code, Section XI Requirements for Containment Building Inspections ULNRC-06858, Completion of License Renewal Activities Prior to Entering the Period of Extended Operation2024-02-21021 February 2024 Completion of License Renewal Activities Prior to Entering the Period of Extended Operation ML24036A1712024-02-20020 February 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0079 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) ULNRC-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 ML24008A0552024-01-19019 January 2024 Acceptance of Requested Licensing Action - Proposed Alternative to the Requirements of the ASME Code (EPID L-2023-LLR- 0061) IR 05000483/20230042024-01-19019 January 2024 – Integrated Inspection Report 05000483/2023004 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 2024-09-11
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML24066A1932024-03-0707 March 2024 2024 Callaway Plant Notification of Biennial Problem Identification and Resolution Inspection and Request for Information ML23200A2982023-07-19019 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 2024-03-07
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Text
November 30, 2021
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 - SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF REQUESTED LICENSING ACTIONS RE: LICENSE AMENDMENT REQUEST FOR ADOPTI ON OF ALTERNATE SOURCE TERM AND REVISION OF TECHNICAL SPECIFICATIONS (EPID L-2021-LLA-0177)
Dear Mr. Diya:
By letter dated September 28, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21272A167), Union Electric Company, dba Ameren Missouri (the licensee) submitted a license amendment request for Callaway Pl ant, Unit No. 1 (Callaway).
Pursuant to Title 10 of Code of Federal Regulations (10 CFR) Section 50.90, Application for amendment of license, construction permit, or early site permit, and 10 CFR 50.67, Accident Source Term, the licensee requested to incorporate the alterna tive source term dose analysis methodology into the Callaway licensing basis and to revise Callaway Technical Specifications 3.7.10, Control Room Emergency Ventilation Syst em (CREVS); 5.5.11, Ventilation Filter Testing Program (VFTP); and 5.5.17, Contr ol Room Envelope Habitability Program.
The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staffs acceptance review of this amendment request. The acceptance review was performed to determine if there is sufficient technical informa tion in scope and depth to allow the NRC staff to complete its detailed technical review. The accep tance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensin g basis of the plant.
Consistent with 10 CFR 50.90, an application for an amendment t o a license (including the technical specifications) must fully describe the changes reque sted, and following as far as applicable, the form prescribed for original applications. Sec tion 50.34 of 10 CFR addresses the content of technical information required. This section stipul ates that the submittal address the design and operating characteristics, unusual or novel design f eatures, and principal safety considerations.
The NRC staff has reviewed your application and concluded that the information delineated in the enclosure to this letter is necessary to enable the staff t o make an independent assessment regarding the acceptability of the proposed amendment request i n terms of regulatory requirements for the protection of public health and safety and the environment.
F. Diya
In order to make the application complete, the NRC staff reques ts that the licensee supplement the application to address the information requested in the enc losure by December 1, 2021.
This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staffs request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, Filing of app lication, and the NRC will cease its activities associated with the application. If the a pplication is subsequently accepted for review, you will be advised of any further information need ed to support the NRC staffs detailed technical review by separate correspondence.
The information requested and associated timeframe in this lett er were discussed with Mr. Thomas Elwood of your staff on November 10, 2021.
If you have any questions regarding this matter, please contact me at 301-415-8371, or by e-mail to Mahesh.Chawla@nrc.gov.
Sincerely,
/RA/
Mahesh L. Chawla, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket No. 50-483
Enclosure:
Supplemental Information Needed
cc: Listserv SUPPLEMENTAL INFORMATION NEEDED
LICENSE AMENDMENT REQUEST FOR ADOPTION OF ALTERNATE SOURC TERM AND
REVISION OF TECHNICAL SPECIFICATIONS
UNION ELECTRIC COMPANY
CALLAWAY PLANT, UNIT NO. 1
DOCKET NO. 50-483
By letter dated September 28, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21272A167), Union Electric Company, dba Ameren Missouri (the licensee) submitted a license amendment request (LAR) for Calla way Plant, Unit No. 1 (Callaway). Pursuant to Title 10 of Code of Federal Regulations (10 CFR) Section 50.90, Application for amendment of license, construction permit, or early site permit, and 10 CFR 50.67, Accident Source Term, the licensee requested to incorporate the alternative source term dose analysis methodology into the Callaway licensi ng basis and to revise Callaway Technical Specifications 3.7.10, Control Room Emergency Ventilation System (CREVS);
5.5.11, Ventilation Filter Testing Program (VFTP); and 5.5.17, Control Room Envelope Habitability Program.
REGULATORY BASIS
During its acceptance review of the licensees submittal, the N RC staff identified that it required additional information to be able to confirm direct input to th e licensees radiological dose evaluation. In particular, data and information related to the accident-related onsite and offsite atmospheric dispersion models and the meteorological (Met) data input to them. These needs were discussed during previous pre-application submittal meetin gs. The required data and information are identified below.
The regulatory basis for this request is first rooted in the ph rase following as far as applicable, the form prescribed for original applications, fro m the regulation at 10 CFR 50.90.
The regulation at 10 CFR 50.67(b)(1) go on to state that [t]he application shall contain an evaluation of the consequences of applicable design-basis accid ents previously analyzed in the safety analysis report. In turn, the regulation at 10 CFR 50. 67(b)(2) requires that the applicant's analysis demonstrates with reasonable assurance that the dose limits at any point on the exclusion area boundary (EAB) and the outer boundary of the low population zone (LPZ),
and at the control room, are met. Those dose analyses require, as a direct input, dispersion parameters, which are based on the use of appropriate dispersio n models that rely, in part, on the input of representative Met data.
BACKGROUND INFORMATION
Several items needed to support the NRC staffs technical revie w were initially identified during a discussion at the June 14, 2018, pre-submittal LAR meeting, a nd as described in the meeting summary dated August 21, 2018 (ADAMS Accession No. ML18215A375). The August 21, 2018, meeting summary was also referenced in the meeting summar y dated April 16, 2021 (ADAMS Accession No. ML21103A003), of a subsequent pre-submitta l meeting held on
Enclosure
- 2 -
March 15, 2021. Items called for in the June 14, 2018, meeting, to be part of the AST LAR submittal that the NRC staff finds were not included, are:
Item 20.c Provide sequential hourly (ASCII-character) data fi les for each year in accordance with the format in Appendix A of RG 1.23, Revision 1,
including respective units of measure. If a different submissi on is made, please explain the data format provided.
Item 20.d Provide sequential hourly (ASCII-character) data fi les in format, required for input to ARCON96 including respective units of measure.
Item 21.c A submittal of the text files of [PAVAN or PAVAN-NAI ] model input and output for all runs.
Item 22.c A submittal of the text files of [ARCON96 or ARCON96 -NAI] model input and output for all runs.
The Met data files in Items 20.c and 20.d are reviewed and needed as input to NRCs confirmatory PAVAN and ARCON96 dispersion model runs. The text files called for in Items 21.c and 22.c are reviewed and used to build the confirma tory model run files of the dispersion analyses at offsite (i.e., the EAB and outer boundar y of the LPZ) and onsite (control room and technical support center) receptors.
Further, the NRC staff notes that the licensee cited dispersion models of different names (i.e.,
PAVAN-NAI and ARCON96-NAI) in its presentation slides during pr e-application meetings. On the other hand, the proposed revisions to the Callaway Updated Final Safety Analysis Report appear to refer only to the NRC versions of the PAVAN and ARCON 96 dispersion models. As a result, it cannot yet be concluded that either PAVAN and PAVAN-NAI and/or ARCON96 and ARCON96-NAI are equivalent.
SUPPLEMENTAL DATA AND INFORMATION NEEDED
- 1) Provide the requested Met data and dispersion model input an d output files identified in Items 20.c, 20.d, 21.c, and 22.c as indicated in ADAMS Accessio n No. ML18215A375 and discussed during our clarification call of October 27, 2021.
- 2) Clarify any differences between the PAVAN and PAVAN-NAI and the ARCON96 and ARCON96-NAI dispersion models.
ML21319A006 *by e-mail OFFICE NRR/DORL/LPL4/PM* NRR/DORL/LPL4/LA* NRR/DEX/EXHB/BC NAME MChawla PBlechman BHayes DATE 11/15/2021 11/15/2021 11/15/2021 OFFICE NRR/DORL/LPL4/BC* NRR/DORL/LPL4/PM*
NAME JDixon-Herrity MChawla DATE 11/30/2021 11/30/2021