ML13038A308

RAI for the Review of the Callaway Plant Unit 1, LRA, Set 22

ML13038A308
Person / Time
Site:	Callaway
Issue date:	02/21/2013
From:	Cuadradodejesus S License Renewal Projects Branch 1
To:	Heflin A Union Electric Co
CuadradoDeJesus S, 415-2946
References
TAC ME7708
Download: ML13038A308 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 21, 2013 Mr. Adam C. Heflin Senior Vice President and Chief Nuclear Officer Union Electric Company P.O. Box 620 Fulton, MO 65251

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE CALLAWAY PLANT, UNIT 1, LICENSE RENEWAL APPLICATION, SET 22 (TAC NO. ME7708)

Dear Mr. Heflin:

By letter dated December 15, 2011, Union Electric Company (Ameren Missouri) (the applicant) submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54) for renewal of Operating License No. NPF-30 for the Callaway Plant. Unit 1 (Callaway). The staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing this application in accordance with the guidance in NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants." During its review, the staff has identified areas where additional information is needed to complete the review.

The staffs requests for additional information are included in the enclosure. Further requests for additional information may be issued in the future.

Items in the enclosure were discussed with Sarah G. Kovaleski, of your staff, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me by telephone at 301-415-2946 or bye-mail at Samuel.CuadradoDeJesus@nrc.gov.

uel uadrad~~er Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-483

Enclosure:

As stated cc w/encl: Listserv

CALLAWAY PLANT, UNIT 1 LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION, SET 22 RAI A4-1

Background:

By letter dated December 15, 2011, Union Electric Company (Ameren Missouri) (the applicant) applied to the U.S. Nuclear Regulatory Commission (NRC) for renewal of the Callaway Plant, Unit 1 (Callaway), Operating License No. NPF-30 for an additional 20 years beyond the current expiration date, October 18, 2024. Included in the license renewal application (LRA) Section A4, Table A4-1, "License Renewal Commitments," are commitments for license renewal and an associated schedule for when Ameren Missouri plans to implement or complete the commitments.

The staff is reviewing the Callaway's LRA for compliance with the requirements of Title 10 of the Code of Federal Regulations (CFR) Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants," and will document its preliminary findings in its "Safety Evaluation Report with Open Items Related to the License Renewal of Callaway Plant Unit 1."

Upon the issuance of a renewed license, the NRC will impose a generic condition on the license. Specifically, the license condition will state that the applicant's final safety analysis report (FSAR) supplement describes certain programs to be implemented and activities to be completed prior to the period of extended operation and that Ameren Missouri shall implement those new programs and enhancements to existing programs no later than 6 months prior to the period of extended operation. The license condition will also state that Ameren Missouri shall complete those inspection or testing activities as noted in certain commitments either before the end of the last refueling outage prior to the period of extended operation or 6 months prior to the period of extended operation, whichever occurs later. The purpose of requiring the completion of implementation, inspection, and testing either before the end of the last refueling outage or prior to the 6-month time frame is to ensure that the implementation of programs and completion of specific activities can be verified by the NRC's oversight process before the plant enters the period of extended operation.

The license condition will state:

The licensee's FSAR supplement submitted pursuant to 10 CFR 54.21(d), as revised during the license renewal application review process, and as supplemented by Appendix A of NUREG-[XXXX], "Safety Evaluation Report Related to the License Renewal of Callaway Plant Unit 1 dated [Month Year],

II describes certain programs to be implemented and activities to be completed prior to the period of extended operation.

a. The licensee shall implement those new programs and enhancements to existing programs no later than 6 months prior to PEO.

ENCLOSURE

-2

b. The licensee shall complete those inspection and testing activities before the end of the last refueling outage prior to the PEO or 6-months prior to PEO, whichever occurs later.

The licensee shall notify the NRC in writing within 30 days after having accomplished item (a) above and include the status of those activities that have been or remain to be completed in item (b) above.

Issue:

As proposed in Callaway's LRA Section A4, Table A4-1, the implementation schedule for some commitments may conflict with the implementation schedule intended by the generic license condition.

Request:

1. Identify those commitments to implement new programs and enhancements to existing programs. Indicate when the implementation of these programs will be completed.

2. Identify those commitments to complete inspection or testing activities. Indicate when the completion of these inspection and testing activities will occur.

RAI B2.1.10-3b

Background:

The response dated November 20, 2012, to RAI B2.1.1 0-3a states that Callaway does not rely on estimated service life to manage internal coatings, and performs visual inspections as the primary method of monitoring coating conditions. The response cites statements from Electric Power Research Institute (EPRI) TR 1019157, "Guideline on Nuclear Safety-Related Coatings,"

to support its use of visual inspections. The response also states that corrective actions, extent of condition reviews, and evaluations for continued service are performed consistent with American Society for Testing and Materials (ASTM) D7167, "Standard Guide for Establishing Procedures to Monitor the Performance of Safety-Related Coating Service Level III Lining Systems in an Operating Nuclear Power Plant."

- 3 The response notes that this standard addresses performance of physical tests, such as dry film thickness or pull-off adhesion testing, and that physical testing is at the discretion of the evaluator.

The staff notes that Callaway's Open-Cycle Cooling Water System aging management program (AMP) implements coatings inspections through procedures EDP-ZZ-01112, "Heat Exchanger Predictive Performance Manual," and EDP-ZZ-3001, GL 89-13; Heat Exchanger Inspection."

Neither procedure refers to ASTM D7167, nor discusses the need to assess the integrity of degraded coatings through physical testing. The staff also notes that the signs of coating degradation, given in EDP-ZZ-3001 for as-found inspection criteria, only include "chips, iron deposits on the surface (indicative of holidays in the coating surface), scrapes, and any other sign of surface abrasion." The staff further notes that, although it addresses macrofouling, EDP-ZZ-01112 does not include loss of coating integrity in macrofouling. In addition, the staff notes that coatings in applicable heat exchangers and strainers are inspected every 5 years and 6 years, respectively.

Issue:

Callaway's current implementing procedures do not appear to include inspection criteria for coating delamination and do not address the need to assess the integrity of degraded coatings through physical tests, such as pull-off adhesion testing. It is not clear to the staff that coating delamination is considered and that the extent of delamination can be bounded through visual inspections. In addition, since Callaway does not account for the service life of coatings, the staff needs additional assurance that the current inspection frequencies of 5 years and 6 years are adequate.

Request:

1) Verify that the Open-Cycle Cooling Water System AM P includes inspections for signs of coating detachment (e.g., blistering, flaking/peeling/delamination) and provide the acceptance criteria for these inspections. Otherwise, provide the bases for not including signs of coating detachment in the inspections of coatings where degradation may adversely affect downstream components.

2) Describe the Open-Cycle Cooling Water System AMP activities that verify coating integrity when visual indications of coating detachment are identified during periodic inspections. Include industry standards as appropriate. If these activities do not include physical testing such as adhesion testing, provide the technical bases to demonstrate that downstream components will not be adversely affected by coating degradation.

3) Describe the timing of coatings inspections for the related heat exchangers and strainers in redundant trains. Specifically, discuss whether these inspections are staggered between redundant trains during subsequent outages and if applicable provide the time span between these alternating inspections. Include information to verify that the identical coating materials were installed with the same installation requirements in the redundant trains with the same operating conditions.

February 21,2013 Mr. Adam C. Heflin Senior Vice President and Chief Nuclear Officer Union Electric Company P.O. Box 620 Fulton, MO.65251

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE CALLAWAY PLANT, UNIT 1, LICENSE RENEWAL APPLICATION, SET 22 (TAC NO. ME7708)

Dear Mr. Heflin:

By letter dated December 15, 2011, Union Electric Company (Ameren Missouri) (the applicant) submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54) for renewal of Operating License No. NPF-30 for the Callaway Plant, Unit 1 (Callaway). The staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing this application in accordance with the guidance in NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants." During its review, the staff has identified areas where additional information is needed to complete the review.

The staff's requests for additional information are included in the enclosure. Further requests for additional information may be issued in the future.

Items in the enclosure were discussed with Sarah G. Kovaleski, of your staff, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me by telephone at 301-415-2946 or bye-mail at Samuel. CuadradoDeJesus@nrc.gov.

Sincerely, IRA!

Samuel Cuadrado de Jesus, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-483

Enclosure:

As stated cc w/encl: Listserv DISTRIBUTION:

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Letter to A. Heflin from S. Cuadrado DeJesus dated, February 21,2013

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE CALLAWAY PLANT, UNIT 1, LICENSE RENEWAL APPLICATION, SET 22 (TAC NO. ME7708)

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