ML22153A175

ULNRC-06729: Application for Technical Specification Change and Exemption Request Regarding Transition to Framatome Fuel, LDCN 22-0002

ML22153A175
Person / Time
Site:	Callaway
Issue date:	06/02/2022
From:	Bianco F Ameren Missouri, Union Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML22153A174	List: ML22153A175 ML22153A176 ML22153A177 ML22153A178 ML22153A179 ML22153A181 ML22153A182 ML22153A183 ML22153A185 ML22153A191 ML22153A192 ULNRC-06729, Attachment 4 - Framatome Affidavits for Withholding
References
ULNRC-06729, LDCN 22-0002
Download: ML22153A175 (5)

Text

June 2, 2022 ULNRC-06729 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 50.12 10 CFR 50.90 Ladies and Gentlemen:

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

RENEWED FACILITY OPERATING LICENSE NPF-30 APPLICATION FOR TECHNICAL SPECIFICATION CHANGE AND EXEMPTION REQUEST REGARDING TRANSITION TO FRAMATOME FUEL, LDCN 22-0002 Pursuant to 10 CFR 50.90, "Application for amendment of license or construction permit," and 10 CFR 50.12, "Specific exemptions," Ameren Missouri (Union Electric Company) herewith transmits an application for amendment to Renewed Facility Operating License Number NPF-30 and asks for exemption from specific regulations for Callaway Plant Unit 1.

The proposed license amendment request (LAR) will revise the Technical Specifications (TS) to allow the use ofFramatome GAIA fuel at Callaway Plant Unit 1. Additionally, pursuant to 10 CFR 50.12, Ameren Missouri requests an exemption from the provisions of 10 CFR 50.46, "Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors," and Appendix K to 10 CFR 50, "ECCS Evaluation Models," to allow the use of MS fuel rod cladding in future core reload applications. provides the evaluation of the proposed TS changes, including the description of the proposed changes, the no significant hazards consideration determination, the existing TS pages marked up to reflect the proposed changes, the revised (clean) TS pages, an informational copy of the marked-up TS Bases, and the supporting technical evaluations for the new fuel. Within Enclosure 1 are attachments that provide the Framatome affidavits for withholding of proprietary technical reports from the public; the supporting Framatome proprietary technical reports referenced in the technical Enclosure 1 Attachments 9, 10, 11 and 12 to this letter contain sensitive information. Withhold from public disclosure under 10 CFR 2.390(a)(4). Upon removal of Enclosure 1 Attachments 9, 10, 11 and 12, this letter is uncontrolled.

SENSITIVE INFORMATION -WITHHOLD UNDER 10 CFR 2.390(a)(4) 8315 County Road 459 : Steedman, MO 65077  : AmerenMissouri .com

ULNRC-06729 SENSITIVE INFORMATION -WITHHOLD UNDER 10 CFR 2.390(a)(4)

June 2, 2022 Page 2 of 5 evaluation, and attachments that provide the non-proprietary version of the Framatome technical reports .

Enclosure 2 provides the request for exemption from 10 CFR 50.46 and Appendix K to 10 CFR 50 requirements for the use of M5 clad for the new fuel.

Independent of this license amendment application, a separate LAR will be submitted to address changes required as a result of an updated spent fuel pool criticality analysis. That analysis is ongoing and requires the coordination of multiple vendors which precludes it from being ready for submittal as part of this LAR. The separate LAR will address a change to TS 4.3, Fuel Storage, to reflect the physical differences associated with the GAIA fuel. In addition, that LAR will also address a change to TS 3.7.17, Spent Fuel Assembly Storage. The separate submittal of that LAR will also require approval prior to the date required for this submittal and, therefore, is being treated as a separate licensing action. As previously indicated, approval of this fuel transition amendment is not reliant on the approval of the amendment addressing spent fuel storage.

It has been determined that this license amendment application does not involve a significant hazard consideration as determined per 10 CFR 50.92, "Issuance of amendment." Pursuant to 10 CFR 51.22, "Criterion categorical exclusion or otherwise not requiring environmental review," Section (b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

Further, this submittal does contain new commitments. Enclosure 3 provides the new regulatory commitments (as defined by NEI 99-04, "Guidelines for Managing NRC Commitment Changes,"

Revision 0) to be implemented.

In accordance with the Callaway Operating Quality Assurance Manual, the Onsite Review Committee has reviewed and approved the proposed changes and has approved the submittal of this amendment application.

Ameren Missouri requests approval of the requested license amendment prior to September 30, 2023 .

Ameren Missouri further requests that the license amendment be made effective upon NRC issuance, to be implemented prior to commencement of operating cycle 27.

In accordance with 10 CFR 50.91 "Notice for public comment; State consultation," Section (b)(l), a copy of this license amendment application is being provided to the designated Missouri State official.

If there are any questions, please contact Tom Elwood at 314-225-1905 .

Enclosure 1 Attachments 9, 10, 11 and 12 to this letter contain sensitive information. Withhold from public disclosure under 10 CFR 2.390(a)(4). Upon removal of Enclosure 1 Attachments 9, 10, 11 and 12, this letter is uncontrolled .

ULNRC-06729 SENSITIVE INFORMATION -WITHHOLD UNDER 10 CFR 2.390(a)(4)

June 2, 2022 Page 3 of 5 I declare under penalty of perjury that the foregoing is true and correct.

Senior Director, Nuclear Operations Executed on: ~b~r-~_) ~_ J-__

Enclosures:

1. Description and Assessment of the Proposed Change Attachments to Enclosure 1 include:

1 Marked-up Existing Technical Specifications 2 Revised Clean Technical Specifications 3 Marked-up Technical Specification Bases 4 Framatome Affidavits for Withholding 5 Non-Proprietary Version LAR Inputs Document 6 Non-Proprietary Version RLBLOCA Summary Report

7. Non-Proprietary Version SBLOCA Summary Report

8. Non-Proprietary Version Non-LOCA Summary Report

9. Proprietary Version LAR Inputs Document 10 Proprietary Version RLBLOCA Summary Report 11 Proprietary Version SBLOCA Summary Report 12 Proprietary Version Non-LOCA Summary Report

2. Exemption Request

3. Regulatory Commitments Enclosure 1 Attachments 9, 10, 11 and 12 to this letter contain sensitive information. Withhold from public disclosure under 10 CFR 2.390(a)(4). Upon removal of Enclosure 1 Attachments 9, 10, 11 and 12, this letter is uncontrolled.

ULNRC-06729 SENSITIVE INFORMATION - WITHHOLD UNDER 10 CFR 2.390(a)(4)

June 2, 2022 Page 4 of 5 cc: Mr. Scott A. Morris 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. Mahesh Chawla Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O81A Washington, DC 20555-0001 Enclosure 1 Attachments 9, 10, 11 and 12 to this letter contain sensitive information. Withhold from public disclosure under 10 CFR 2.390(a)(4). Upon removal of Enclosure 1 Attachments 9, 10, 11 and 12, this letter is uncontrolled.

ULNRC-06729 SENSITIVE INFORMATION - WITHHOLD UNDER 10 CFR 2.390(a)(4)

June 2, 2022 Page 5 of 5 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 6500 West Freeway, Suite 400 ,.

Fort Worth, TX 76116 (Certrec receives ALL attachments as long as they are non-safe~ards and may be publicly disclosed.)

Electronic distribution for the following can be made via Tech Spec ULNRC Distribution:

F. M. Diya B. L. Cox B. L. Jungmann D. E. Farnsworth T. A. Witt M. G. Hoehn J. W. Milligan T. B. Elwood B. D. Richardson D. E. Rickard NSRB Secretary STARS Regulatory Affairs Mr. Jay Silberg (Pillsbury Winthrop Shaw Pittman LLP)

Ms. Claire Eubanks (Missouri Public Service Commission)

Mr. Aaron Schmidt (DNR)

Enclosure 1 Attachments 9, 10, 11 and 12 to this letter contain sensitive information . Withhold from public disclosure under 10 CFR 2.390(a)(4). Upon removal of Enclosure 1 Attachments 9, 10, 11 and 12, this letter is uncontrolled .

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