ML17115A062

2017/04/25 NRR E-mail Capture - Requests for Additional Information -- Callaway Plant, Unit 1, Technical Specification 5.6.5, Core Operating Limits Report CAC MF8463

ML17115A062
Person / Time
Site:	Callaway
Issue date:	04/25/2017
From:	Klos J J Plant Licensing Branch IV
To:	Elwood T B AmerenUE
References
MF8463
Download: ML17115A062 (3)

Text

1 NRR-PMDAPEm Resource From: Klos, John Sent: Tuesday, April 25, 2017 8:10 AM To: 'Telwood@ameren.com' Cc: Klos, John

Subject:

Requests for Additional Information --

CALLAWAY PLANT, UNIT 1, TECHNICAL SPECIFICATION 5.6.5, "CORE OPER ATING LIMITS REPORT" CAC MF8463 Follow Up Flag:Follow up Flag Status:

Flagged

Dear Mr. Elwood,

By letter dated October 11, 2016, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16286A553), Union Electric Company (UE, the licensee), dba Ameren Missouri submitted a License Amendment Request (LAR) to amend the Callaway's Technical Specification (TS) 5.6.5, "Core Operating Limits Report (COLR)", to include references to the PARAGON and NEXUS Nuclear Data Methodology, (WCAP-16045-P-A and its Addendum 1-A), and New Pin Power Recovery Methodology (WCAP-10965-P-A, Addendum 2-A).

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the submittal and determined that the requests for additional information (RAIs) below are needed to complete the technical review and make a regulatory finding regarding this LAR.

You have stated that a clarification call for these RAIs are not needed, via voice mail. These RAIs are being issued formally with a response due 30 days from today on May 25, 2017.

REQUESTS FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST CALLAWAY UNIT 1 DOCKET NO. 50-483 (CAC MF8463)

By letter dated October 11, 2016, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16286A553), Union Electric Company (UE, the licensee), dba Ameren Missouri submitted a License Amendment Request (LAR) to amend the Callaway's Technical Specification 5.6.5, "Core Operating Limits Report (COLR)", to include references to the PARAGON and NEXUS Nuclear Data Methodology, (WCAP-16045-P-A and its Addendum 1-A), and New Pin Power Recovery Methodology (WCAP-10965-P-A, Addendum 2-A), respectively.

The requests for additional information (RAIs) listed below are needed to support NRC staff's continued technical review of the proposed LAR.

Regulatory Basis for RAIs: Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36, "Technical Specifications," includes the method of controlling reactor physics parameters to assure conformance by specifying specific value(s) determined to be within specified acceptance criteria (usually the limits of the safety analyses) using an approved calculation methodology.

RAIS:

21. NRC Generic Letter (GL) 88-16, "Removal of Cycle-Specific Parameter Limits from Technical Specifications," allows licensees to control certain reactor physics parameters on a cycle-by-cycle basis by moving them to a separate report, provided they specify the calculation methodology. The discussion in the GL references terms indicating that approval of licensee control of these parameters is contingent on selection of a single, specific methodology (e.g., "the specified methodology" and "an NRC-approved methodology," etc.).

The proposed amendment would preserve both the current PHOENIX-P/ANC nuclear design methodology and the new PARAGON-NEXUS/ANC nuclear design methodology in the licensee's TS. By leaving both the current and proposed methodologies in the TS, the proposed amendment leaves open the possibility that either methodology could be used to calculate the core operating limits addressed in the COLR, effectively creating a new, ambiguous methodology. The NRC staff has therefore been unable to determine that the proposed amendment is consistent with GL 88-16 guidance. Please propose a revision to TS 5.6.5 that provides for a single, unambiguous method to determine how the core operating limits discussed in the submittal will be calculated.

2. (Clarification) Addendum 1-A to WCAP-16045-P-A brings about a change to the way boron letdown curves are calculated and input into the overall nuclear design method. Because of this, in previous reviews of PARAGON-NEXUS/ANC applications, the NRC staff found it necessary to verify that no changes were made to the analysis methods for post-loss of coolant accident (LOCA) subcriticality and boric acid precipitation behavior. Please verify that no changes are made to these analysis methods as part of this LAR.

Thank you,

John Klos DORL Callaway, Columbia Project Manager U.S. NRC, Office of Nuclear Reactor Regulation, Division of Operating Re actor Licensing, O8E7 NRC/NRR/DORL/LPL4, MS O8H4A Washington, DC 20555-0001 301.415.5136, 301.415.2102 (fax)

John.Klos@NRC.gov

Hearing Identifier: NRR_PMDA Email Number: 3467 Mail Envelope Properties (2cc83d6509654dabaeb2550c0e7a8a4f)

Subject:

Requests for Additional Information -- CALLAWAY PLANT, UNIT 1, TECHNICAL SPECIFICATION 5.6.5, "CORE OPERATING LIMITS REPORT" CAC MF8463 Sent Date: 4/25/2017 8:10:08 AM Received Date: 4/25/2017 8:10:12 AM From: Klos, John Created By: John.Klos@nrc.gov Recipients: "Klos, John" <John.Klos@nrc.gov> Tracking Status: None

"'Telwood@ameren.com'" <Telwood@ameren.com> Tracking Status: None

Post Office: HQPWMSMRS05.nrc.gov Files Size Date & Time MESSAGE 4346 4/25/2017 8:10:12 AM

Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received: Follow up