ULNRC-06087, Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

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Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
ML14057A770
Person / Time
Site: Callaway 
Issue date: 02/26/2014
From: Reasoner C
Ameren Missouri, Union Electric Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, ULNRC-06087
Download: ML14057A770 (13)
v • d • e


Text

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'WAmeren MISSOURI Callaway Plant

February 26, 2014 ULNRC-06087 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR2.202 Ladies and Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

FACILITY OPERATING LICENSE NPF-30 SECOND SIX-MONTH STATUS REPORT IN RESPONSE TO MARCH 12, 2012 COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS (ORDER NUMBER EA-12-049)

References:

1. Letter dated March 12,2012 from E. J. Leeds and M. R. Johnson, USNRC, to Adam C.

Heflin, Callaway Plant, Union Electric Company, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (ADAMS Accession Number ML12054A736)

2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, August 29, 2012 (ADAMS Accession Number ML12229A174)
3. ULNRC-05924, "Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated October 29, 2012
4. ULNRC-05962, "Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated February 28, 2013

..........................................................................................................................

                                                                                                                                                                                                                                                    • PO Box 620 Fulton, MO 65251 AmerenMissouri.com

STARS

  • Alliance

ULNRC-06087 February 26, 2014 Page2

5. ULNRC-06024, "First Six-Month Status Report In Response to March 12, 2012 Commission Order Modifying Licenses With Regard To Requirements For Mitigation Strategies For Beyond-Design-Basis External Events (Order Number EA-12-049),"

dated August 29, 2013 On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued the order identified above as Reference 1 to Union Electric Company (dba Ameren Missouri) for Callaway Plant.

Reference 1 was immediately effective and directs Ameren Missouri to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of final interim staff guidance from the NRC (Reference 2) and an Overall Integrated Plan pursuant to Section IV, Condition C. Reference 3 provided Ameren Missouri's initial status report regarding mitigation strategies. Reference 4 provided Ameren Missouri's Overall Integrated Plan.

Section IV, Condition C.2 of Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," provides direction regarding the content of the status reports. Reference 5 provided Ameren Missouri's first six-month status report. The enclosure to this letter provides Ameren Missouri's second six-month status report pursuant to Section IV, Condition C.2 of Reference 1.

This letter does not contain new commitments.

If you have any questions concerning the content of this letter, please contact Scott Maglio, Regulatory Affairs Manager, at 573-676-8719.

I declare under penalty of perjury that the foregoing is true and correct.

Sincerely, Executedon: z/zG/I'f

~-------

Cleveland Reasoner Vice President, Nuclear Operations

Enclosure:

Ameren Missouri's Second Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

ULNRC-06087 February 26, 2014 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 8201 NRC Road Steedman, MO 65077 Mr. Fred Lyon Project Manager, Callaway Plant Office ofNuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8B 1 Washington, DC 20555-2738 Mr. Eric Leeds Director, Office ofNuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-13H16M Washington, DC 20555-0001 Mr. Jack Davis Director, Mitigation Strategies Directorate Office ofNuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

ULNRC-06087 February 26, 2014 Page4 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4150 International Plaza Suite 820 Fort Worth, TX 76109 (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 Responses and Reports ULNRC Distribution:

F. M. Diya C. 0. Reasoner III D.W. Neterer L. H. Graessle S. A. Maglio T. B. Elwood J. L. Fortman J. T. Patterson D .M. Stepanovic Corporate Communications NSRB Secretary STARS Regulatory Affairs Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)

Missouri Public Service Commission

Enclosure to ULNRC-06087 Ameren Missouri's Second Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction Ameren Missouri developed an Overall Integrated Plan (OIP) (Reference 1) for the Callaway Plant, documenting the diverse and flexible strategies (FLEX), in response to NRC Order Number EA-12-049 (Reference 2). This enclosure provides an update of milestone accomplishments since submittal of the last status report (Reference 3), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any. Refer to Section 8 of this enclosure for a list of References.

2 Milestone Accomplishments The following milestones have been completed since the development of the OIP (Reference 1), and are current as of January 31, 2014.

  • Modification Evaluations have been completed.
  • Submittal of the second six-month status report for implementation of order EA-12-049 (this document) 3 Milestone Schedule Status The following table provides an update to the milestone schedule provided in the OIP to the NRC (Reference 1). The table provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

Ameren Missouri submitted a relaxation request per ULNRC-06036 (Reference 4) which was approved by the NRC (Reference 5). Several completion dates, such as the completion date for "Unit 1 Implementation Date" and "Submit Completion Report", have been revised accordingly. Further information concerning this relaxation request is provided in Section 5 of this enclosure.

Page 1 of9

Enclosure to ULNRC-06087 Callaway Milestone Schedule Status Revised Target Original Target (Will be Activity Completion Date updated every Date 6 months)

Submit Overall Integrated February-2013 Complete Implementation Plan 6 Month Status Updates Update 1 August-2013 Complete Update 2 February-2014 Complete Update 3 August-2014 Not Started Update4 February-2015 Not Started Update 5 August-2015 Not Started Update 6 February-2016 Not Started FLEX Strategy Evaluation April-2013 Complete Perform Staffing Analysis December-20 13 Not Started December-20 15 Modifications Modifications Evaluation April-2013 Complete Engineering and Implementation November-2014 Started May-2016 N-1 Walkdown April-2013 Started December-2014 Design Engineering March-2014 Started February-2015 Unit 1 Implementation Outage November-2014 Not Started May-2016 On-site FLEX Equipment Purchase June-2013 Started March-2015 Procure December-20 13 Started April-2015 Off-site FLEX Equipment Develop Strategies with RRC November-20 13 Started September-20 14 Install Off-site Delivery Station (if September-2014 Started necessary)

Procedures PWROG issues NSSS-specific guidelines June-2013 Complete Create Callaway FSG April-2014 Started April-2015 Create Maintenance Procedures June-2014 Not Started June-2015 Training Develop Training Plan April-2014 Started Implement Training May-2014 Started May-2016 Submit Completion Report November-2014 Not Started June-2016 Page 2 of9

Enclosure to ULNRC-06087 4 Changes to Compliance Method The following changes have been made to Ameren Missouri's FLEX response documented in Reference 1 since submittal of the last status report (Reference 3).

4.1 Shutdown/Refueling Modes Ameren Missouri will incorporate the supplemental guidance provided in the NEI position paper (Reference 6) entitled "Shutdown I Refueling Modes" to enhance the shutdown risk process and procedures.

4.2 RWST Missile Protection The Ameren Missouri FLEX response (Reference 1) identified that the Refueling Water Storage Tank (RWST) required missile protection to be credited for FLEX Strategies. Upon further review, it has been determined that the RWST does not require missile protection.

The makeup from the RWST is required for implementation of the FLEX Strategies at Callaway in Modes 1 - 4 no later than 46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> after the event (Reference 1, Table C-1: Timing and Deployment Timeline; Steam Generators Available (MODES 1-4). After 46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br />, the Regional Response Center (RRC) would have delivered a mobile boration skid that can be used provide RCS makeuplboration from the Ultimate Heat Sink (UHS) or Hardened Condensate Storage Tank (HCST) (i.e., seismic & missile hardened sources). Based upon this RCS makeup rate, the RWST does not require missile hardening for MODES 1-4.

For Shutdown/Refueling Modes Ameren Missouri will incorporate the supplemental guidance provided in the NEI position paper (Reference 6) entitled "Shutdown I Refueling Modes". Per NEI Frequently Asked Questions (FAQ) 2013-10, Shutdown Mode Capability Requirements for PWRs, the RWST (borated water source) does not need to be robust for all external events. The RWST is seismically qualified but is not missile protected. Ameren Missouri will implement appropriate risk management techniques such as pre-staging FLEX equipment to minimize the potential impact of an event. Since the RWST is seismically qualified, there is not an issue for a seismic event. The only issue for the RWST would be severe weather (tornado). For this type severe weather there is significant time to implement contingency plans to mitigate the consequences of such an event. In addition, Ameren Missouri has procedures in place to monitor severe weather in times of high risk evolutions during outages.

4.3 Battery Service Life Ameren Missouri has performed a battery service life calculation and determined our batteries would be able to provide instrument and control power for approximately 14 - 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> after a loss of all AC power. Ameren Missouri confirms that the FLEX strategy station battery run-time was calculated in accordance with the IEEE-485 methodology using manufacturer discharge test data applicable to the licensee's FLEX strategy as outlined in the NEI white paper on Extended Battery Duty Cycles. The detailed licensee calculations, supporting vendor discharge test data, FLEX strategy battery load profile, and other inputs/initial conditions required by IEEE-485 will be available on the licensee's web portal for documents and calculations. The time margin between the calculated station battery run-time for the FLEX strategy and the expected deployment time for FLEX equipment to supply the de loads is at least four (4) hours.

Page 3 of9

Enclosure to ULNRC-06087 4.4 Spent Fuel Pool Cooling The three connections (primary, secondary, and spray) for the Spent Fuel Pool Cooling strategy were originally designed to be external to the Fuel Building. Further evaluation determined that it would be cost prohibitive to design and construct a hardened structure external to the Fuel Building to protect these connections. Consequently, the strategy has been revised to place these connections just inside the building. An evaluation determined that the connection points would accessible early in the event.

In addition, Ameren Missouri has decided not to pursue use of a SFP Cooling System from the Regional Response Centers (RRC). The 4I60 VAC generators being procured from the RRC will not be able to supply sufficient power to include the Spent Fuel Pool Cooling Pumps in the supplied loads. Ameren Missouri will be obtaining a spare SFP Cooling (FLEX) Pump from the RRC.

4.5 Non-Class lE Instrumentation For non-Class 1E instrumentation identified in the February 20I3 OIP Submittal (see below for list)

Ameren Missouri has determined not to repower the non-Class IE racks with a temporary battery.

Instead, instrument readings will be obtained using portable instruments. As stated in our original submittal, Ameren Missouri will develop procedures to read this instrumentation locally, where applicable, using a portable instrument, as required by Section 5.3.3 of NEI I2-06. The key parameters powered from a non-Class IE source requiring use of portable instruments are:

  • SFP Temperature 5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Ameren Missouri evaluated the options of seismically qualifying the Condensate Storage Tank (CST) or installing a 670,000 gallon seismically qualified and missile protected CST. The evaluation determined that the installation of a new seismically qualified and missile protected CST was the best option. As a result, Ameren Missouri requested a relaxation of the implementation date for Order EA-I2-049 from the fall of20I4 (completion ofRefuel20) to the spring of20I6 (Refuel2I). This request was documented in ULNRC-06036 (Reference 4) and approved by the NRC per ML133I9A668 (Reference 5).

Page 4 of9

Enclosure to ULNRC-06087 6 Open Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the OIP or the Interim Staff Evaluation (IS E) and the status of each item.

Overall Integrated Plan Open Item Status 011 The R WST will need to be missile protected to credit its Closed.

use in FLEX strategies. Ameren Missouri has determined that the R WST does not require missile protection perNEI FAQ 2013-10, Shutdown Mode Capability Requirements for PWRs. See 4.2 above.

012 GOTHIC analysis needs to be performed to demonstrate Started.

that Containment pressure and temperature remain at The Gothic Analysis and acceptable levels and that instrumentation EQ Instrumentation EQ Analysis are requirements will be maintained. being performed. The results are currently under review.

013 An analysis will need to be performed to demonstrate Closed.

acceptable SFP cooling pump performance with the SFP The Spent Fuel Pool Cooling Pumps in boil-off. will not be repowered. SFP cooling will be maintained by continued makeup and boil-off using the Phase 2 portable equipment.

014 For non-Class IE instrumentation that will be Closed.

repowered using a temporary battery, an analysis will Ameren Missouri has determined that need to be performed to determine battery life and the non-Class 1E instrument racks frequency of replacing battery will not be re-powered via a temporary battery. The required instrument readings will be obtained via portable instruments. See 4.5 above.

015 The current CST and CST pipe chase are non-seismic. Started.

Callaway may pursue the construction of a new Ameren Missouri will construct a new seismically qualified and missile protected CST. Current CST that is seismically qualified and FLEX strategies rely on the existing CST tank. Future missile protected. Relaxation of Order evaluation is required to determine the impact on FLEX requirements regarding the date of strategies should the new CST be constructed. full implementation was requested (Reference 4) and has been approved (Reference 5).

Page 5 of9

Enclosure to ULNRC-06087 Overall Integrated Plan Open Item Status 0!6 The method for isolating accumulators during RCS Closed.

inventory control has not been finalized The accumulators will be vented during RCS inventory control to prevent nitrogen ingestion into the RCS.

0!7 The method for repowering the SFP cooling pumps has Closed.

not been finalized. The SFP Cooling Pumps will not be repowered. SFP cooling will be maintained by continued makeup and boil-off using the Phase 2 portable equipment.

OIS The Westinghouse RCP SHIELD Seal issue has not Started.

been resolved. See Status of Open Items 3 .2.1.2.B and 3.2.1.2.D in Section 7 below for additional information on this issue.

Interim Staff Evaluation Open Item Status 3.2.1.2.B RCP Seal 0-Ring Integrity and Leakage Rate Started Additional review of the licensee's applicable analysis and As stated in the ISE, The PWROG relevant Reactor Coolant Pump (RCP) seal leakage testing is working on these issues and will data is needed to justify that ( 1) the integrity of the submit the NRC position papers to associated 0-rings will be maintained at the temperature the NRC that will contain test data conditions experienced during the ELAP event, and (2) the regarding the maxtmum seal seal leakage rate used in the ELAP is adequate and leakage rates of Westinghouse acceptable. traditional and SHIELD seals, and Flowserve seals at higher cold-leg temperatures. The NRC will review the position papers upon their receipt.

Page 6 of9

Enclosure to ULNRC-06087 3.2.1.2.D RCP Seal Leakage Rate Started The acceptability of the use of the selected seals and the The PWROG is working on these RCP seal leakages rates in the ELAP analysis must be issues and will submit the NRC justified. position papers to the NRC that will contain test data regarding the maximum seal leakage rates of Westinghouse traditional and SHIELD seals, and Flowserve seals at higher cold-leg temperatures. The NRC will review the position papers upon their receipt.

3.2.1.3.A Specify Key Parameters Started.

During the NRC audit process the licensee was requested Ameren Missouri will provide the to provide the following information: If the ANS 5.1-1979 requested information.

+ 2 sigma model is used in the ELAP analysis, specify the values of the following key parameters used to determine the decay heat: (1) initial power level, (2) fuel enrichment, (3) fuel burnup, (4) effective full power operating days per fuel cycle, (5) number of fuel cycles, if hybrid fuels are used in the core, and (6) fuel characteristics based on the beginning of the cycle, middle of the cycle, or end of the cycle. Address the adequacy of the values used. If the different decay heat model is used, describe the specific model and address the acceptability of the model and the analytical results.

3.2.1.8.B Boric Acid Mixing Started The Pressurized-Water Reactor Owners Group submitted The NRC has subsequently to the NRC a position paper, dated August 15, 2013, which endorsed the position paper with provides test data regarding boric acid mixing under single- some clarifications (Reference 9) phase natural circulation conditions and outlined applicability conditions intended to ensure that boric acid Ameren Missouri will evaluate the addition and mixing would occur under conditions similar clarifications and update the OIP, to those for which boric acid mixing data is available. as needed.

During the audit process, the licensee informed the NRC staff of its intent to abide by the generic approach discussed above; however, the NRC staff concluded that the August 15, 2013, position paper was not adequately justified and that further information is required.

3.2.4.9.A Fuel Oil Quality Started.

Information is needed regarding plans for assuring and Ameren Missouri will provide the maintaining fuel oil quality. requested information.

Page 7 of9

Enclosure to ULNRC-06087 3.4.A Offsite Resource Capabilities Started.

Details are needed to demonstrate the mtmmum Ameren Missouri will provide the capabilities for offsite resources will be met per NEI 12-06 requested information.

Section 12.2.

7 Potential Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time.

8 References The following references support the updates to the OIP described in this enclosure.

1. ULNRC-05962, "Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated February 28, 2013
2. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012
3. ULNRC-06024, "First Six-Month Status Report In Response To March 12, 2012 Commission Order Modifying Licenses With Regard To Requirements For Mitigation Strategies For Beyond-Design-Basis External Events (Order Number EA-12-049)," dated August 29, 2013
4. ULNRC-06036, Request For Relaxation From NRC Order EA-12-049, "Order Modifying Licenses With Regard To Requirements For Mitigation Strategies For Beyond-Design-Basis External Events", dated October 09, 2013
5. ML13319A668, Callaway Plant, Unit 1- Relaxation Of The Schedular Requirements For Order EA-12-049 "Issuance Of Order To Modify Licenses With Regard To Requirements For Mitigation Strategies For Beyond Design Basis External Events", dated December 11 , 2013
6. ML133224A195, Callaway Plant, Unit 1 -Interim Staff Evaluation Relating To Overall Integrated Plan In Response To Order EA-12-049 (Mitigation Strategies) (TAC No. MF0772), dated December 19, 2013
7. ML13273A514, NEI Shutdown/Refueling Modes White Paper, Rev 0 9/18/13
8. ML13267A382, NRC Letter from Mr. Jack Davis, NRC, to Mr. Joseph E. Pollock, NRC Endorsement of FLEX Generic Open Item for Shutdown Refueling Modes, dated September 30, 2013
9. ML13276A183, NRC Letter from Mr. Jack Davis, NRC, to Mr. Jack Stringfellow, PWROG, NRC Endorsement ofPWROG Boron Mixing White Paper, dated January 8, 2014
10. ML13241A186, NEI Letter from Mr. Nicholas Pappas to NRC, Mr. Jack R. Davis, EA-12-049 Mitigating Strategies Resolution of Extended Battery Duty Cycles Generic Concern, dated August 27, 2013 Page 8 of9

Enclosure to ULNRC-06087

11. ML13241A188, NRC Letter from Mr. Jack Davis, NRC, to Mr. Joseph E. Pollock, Battery Life White Paper Endorsement, dated September 16, 2013 Page 9 of9
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