ULNRC-05863, Cycle 18 Commitment Change Summer Report

Cycle 18 Commitment Change Summer Report

ML12135A435
Person / Time
Site:	Callaway
Issue date:	05/14/2012
From:	Maglio S Ameren Missouri
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
ULNRC-05863
Download: ML12135A435 (5)

Text

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WAmeren Callaway Plant MISSOURI May 14, 2012 ULNRC-05863 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 50.71(e)(4)

Ladies and Gentlemen:

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

FACILITY OPERATING LICENSE NPF-30 CYCLE 18 COMMITMENT CHANGE

SUMMARY

REPORT Please find attached the Cycle 18 Commitment Change Summary Report required by NEI 99-04, "Guideline for Managing NRC Commitment Changes," for changes requiring NRC notification within the next refuel outage interval. These commitment revisions were completed at Callaway Plant Unit 1 for the period between June 13, 2010 and November 25, 2011 and were not reported to NRC in a previous submittal. The Cycle 18 Commitment Change Summary Report provides a description of each change completed along with a brief justification for each revised commitment.

If you should have any questions concerning this report, please contact Scott Maglio at (573) 676-8719.

This letter does not contain new commitments.

Sincerely,

~c~~~~~?

Regulatory Affairs Manager DRB/nls Enclosure PO Box 620 Fulton, MD 65251 AmerenMissouri.com

ULNRC-05863 May 14,2012 Page2 cc: Mr. Elmo E. Collins 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. Kaly Kalyanam Senior Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8G 14 Washington, DC 20555-2738

ULNRC-05863 May 14, 2012 Page 3 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:

A. C. Heflin F. M. Diya C. 0. Reasoner ill L. H. Graessle S.M. Maglio T. B. Elwood D. R. Brownawell R. W. Wilson D. R. Miller R. Holmes-Bobo NSRB Secretary Mr. Paul Parmenter, Director (SEMA)

Mr. Thomas Mohr, Senior REP Planner (SEMA)

Mr. Tom Masso, REP Planner (SEMA)

Mr. Bill Muilenburg (WCNOC)

Mr. Tim Hope (Luminant Power)

Mr. Ron Barnes (APS)

Mr. Tom Baldwin (PG&E)

Mr. Mike Murray (STPNOC)

Ms. Linda Conklin (SCE)

Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)

Mr. Dru Buntin (DNR)

Enclosure to ULNRC-05863 Page 1 CYCLE 18 COMMITMENT CHANGE

SUMMARY

REPORT In accordance with NEI 99-04, "Guidelines for Managing NRC Commitment Changes," as endorsed in Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," the following commitment changes are being reported. The changes were completed for Callaway Plant Unit 1 for the period from June 13, 2010 to November 25, 2011.

A description of each change completed along with a brief justification for each revised commitment is provided.

50106 Commitment 50106 is documented in AmerenUE letter ULNRC-04929 (ref License Amendment 165) which states that AmerenUE (now Ameren Missouri) will trend as-found and as-left data under Callaway's System Health Program for the three representative trip functions analyzed in WCAP-15376 (i.e., OTDT, SG level, and pressurizer pressure) for two years (4 data points) after implementation of the requested license amendment.

Justification:

This commitment, which was to complete two years of drift trending, was satisfied as of May 30, 2007. Commitment 50106 has thus been closed in Callaway's commitment tracking system.

50091 Commitment 50091 is documented in AmerenUE letter ULNRC-04813 in which it was acknowledged that AmerenUE would comply with First Revised NRC Order EA-03-009. The order established interim inspection requirements for reactor pressure vessel heads at pressurized water reactors until such requirements could be incorporated into 10 CFR 50.55a (i.e., after completion of the anticipated rulemaking).

Justification:

The requirements contained in EA-03-009 have since been transferred to 10 CFR 50.55a(g)(6)(D)(1)-

(6) which requires that licensees implement an augmented inservice inspection program. Once a licensee implements this requirement, First Revised NRC Order EA-03-009 no longer applies to that licensee and shall be deemed to be withdrawn.

Callaway's inservice inspection program has been augmented with these requirements. As such, First Revised NRC Order EA-03-009 is deemed withdrawn, and commitment 50091 has been closed in Callaway's commitment tracking system.

41176 Commitment 41176 was developed in response to NRC Bulletin IE 82-02. The bulletin required PWR facilities to develop maintenance procedures for threaded fastener practices, and it recommended quality assurance measures for fastener lubricants and injection sealant compounds. In addition, the

Enclosure to ULNRC-05863 Page2 bulletin required a one-time visual and surface exam of bolting on all in-scope reactor coolant pressure boundary components opened for inspection or maintenance during the subsequent outage.

Justification:

NRC IE Bulletin 82-02 required plants to develop a bolting program and also to perform a one-time, opportunistic exam of Class 1 bolting and to report the exam results to the NRC. Bulletin 82-02 expired in 1986, and the NRC has not included the additional exams in 10 CFR 50.55a, nor have the exams been incorporated into ASJ\.ffi Section XI. The 1980 edition through the 2011 addenda of Section XI require only a visual examination of the bolting that is within the scope of Bulletin 82-02.

Callaway has developed a bolting program, which included development/revision of the applicable maintenance procedures and quality assurance measures required by the bulletin, and has performed the required examination and reporting actions. Since the additional exams directed by the bulletin were only required to be performed once, and because they have completed, they have been removed from commitment 41176 via a revision to the commitment in Callaway's commitment tracking system.