ML21203A194

Summary of Changes to Enclosure 2, License Amendment Request, and Enclosure 3, Callaway Methodology for a Risk-Informed Approach to Address Generic Letter 2004-02, of ULNRC-06526

ML21203A194
Person / Time
Site:	Callaway
Issue date:	07/22/2021
From:	Ameren Missouri
To:	Office of Nuclear Reactor Regulation
Shared Package
ML21203A192	List: ML21203A193 ML21203A194 ULNRC-06526, Methodology for a Risk-Informed Approach to Address Generic Letter 2004-02 ULNRC-06651, License Amendment Request for Risk-Informed Approach to Resolution of Generic Letter 2004-02
References
GL 2004-02, GSI-191, LDCN 19-0014, ULNRC-06651
Download: ML21203A194 (3)

Text

ULNRC-06651 Enclosure 1 to ULNRC-06651 Summary of Changes to Enclosure 2, "License Amendment Request," and Enclosure 3, "Callaway Methodology for a Risk-Informed Approach to Address Generic Letter 2004-02," of ULNRC-06526 (2 pages)

ULNRC-06651 Enclosure 1 Page 1 of 2 Summary of Changes to Enclosure 2, "License Amendment Request," and Enclosure 3, "Callaway Methodology for a Risk-Informed Approach to Address Generic Letter 2004-02," of ULNRC-06526 Section / Step Description Number Enclosure 2, Markups of licensing documents have now been provided on Attachments 2-2, 2-3, current Technical Specifications (TS), TS Bases, or Final Safety 2-4, and 2-5 Analysis Report (FSAR) pages, as applicable, and the clean TS pages have been reformatted to show header and footer information consistent with the format of the current TS. The revised markups also include punctuation, capitalization, section numbering, acronym usage, and other grammatical changes for consistency.

Enclosure 2, Changed the description of "containment sump" to read "A Attachment 2-3, TS containment sump consists of the in-containment ECCS and CSS Bases 3.6.8, recirculation flow paths (including debris Interceptors, trash racks, LCO, first paragraph, and curbs), the containment sump strainer, and the inlets to the second sentence and ECCS and CSS piping."

SURVEILLANCE REQUIREMENTS, second paragraph Enclosure 2, Added "15.6.5.5" as an additional FSAR Section Reference for Attachment 2-5, Table WCAP-16406-P-A and WCAP-17788-P.

1.6-2 Enclosure 2, The PWROG / vendor proprietary threshold value for fiber Attachment 2-5, deposited in fuel channels for a hot-leg break has been replaced Section 6.3A.1.2.1, with a reference to "the threshold value from Section 6.5.5.10.c of Step 2, first bullet WCAP 17788-P, Volume 1, Rev. 0."

Enclosure 2, Removed the unnecessary qualifiers "arguably" and "in a licensing Attachment 2-5, context" from the bulleted items following the sentence "The Section 6.3A.1.2.3 evaluation demonstrates sufficient safety margin, as summarized below."

Enclosure 2, Reworded the introductory paragraph to read "This section Attachment 2-5, describes those methodologies or elements of the methodologies Section 6.3A.2 used in support of the RoverD approach for addressing sump debris concerns such that changes to the identified methodologies or elements may involve additional regulatory requirements for NRC approval or notification."

ULNRC-06651 Enclosure 1 Page 2 of 2 Summary of Changes to Enclosure 2, "License Amendment Request," and Enclosure 3, "Callaway Methodology for a Risk-Informed Approach to Address Generic Letter 2004-02," of ULNRC-06526 Section / Step Description Number Enclosure 2, Reworded the introductory paragraph to read "Changes to any of Attachment 2-5, the key methodologies (including acceptance criteria) used in the Section 6.3A.2.1 RoverD approach for addressing GSI-191/GL 2004-02 concerns, as described in Section 6.3A.1 of this Appendix, are to be evaluated as a potential 'departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses,' consistent with 10 CFR 50.59(c)(2)(viii) (notwithstanding the fact that some of the methodologies are risk-informed or involve risk-informed elements)."

Enclosure 2, Removed the final sentence "Conditions that cause emergency Attachment 2-5, sump strainers to be inoperable must exceed the RG 1.174 Risk Section 6.3A.2.3 Region II - low risk threshold."

Enclosure 2, Changed Reference 1 to be the pending requested License Attachment 2-5, Amendment, and References 2 and 3 to match FSAR Table 1.6-2.

Section 6.3A.3 Enclosure 2, Added NUREG-1829, WCAP-16406-P-A, and WCAP-17788-P as Attachment 2-5, References 27, 28, and 29, respectively in FSAR 15.6.5.5 and in Sections 15.6.5.5 and the FSAR 15.6.7 listing of References.

15.6.7 Enclosure 3, A footnote was added to clarify that the recommended early Attachment 3-2, blockage fiber limit is not proprietary, based on its inclusion in Section 3.n, Heading WCAP-17788-NP, Rev. 1.

Core-Fiber Accumulation Histories, first paragraph, first sentence and second paragraph, first sentence Enclosure 3, The PWROG / vendor proprietary threshold value for fiber Attachment 3-2, deposited in fuel channels for a hot-leg break has been replaced Section 3.n, Heading with a reference to "the WCAP-17788-P (Volume 1, Section Core-Fiber 6.5.5.10.c) recommended limit."

Accumulation Histories, first paragraph, fourth sentence