ML13246A307

Memorandum to File - Verbal Authorization of Relief Request PR-07, Testing Frequency for Pumps and Valves, Third 10-year Inservice Testing Interval

ML13246A307
Person / Time
Site:	Callaway
Issue date:	09/09/2013
From:	Lyon C Plant Licensing Branch IV
To:	Heflin A Union Electric Co
Lyon C
References
TAC MF2642
Download: ML13246A307 (3)

Text

September 9, 2013 MEMORANDUM TO: FILE FROM: Carl F. Lyon, Project Manager /ra/

Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

SUBJECT:

CALLAWAY PLANT, UNIT 1 -

SUMMARY

OF TELEPHONE CONFERENCE RE: VERBAL AUTHORIZATION FOR RELIEF REQUEST PR-07 (TAC NO. MF2642)

This memorandum summarizes the telephone discussion on August 30, 2013, between the U.S. Nuclear Regulatory Commission (NRC) staff and Union Electric Company (dba Ameren Missouri, the licensee). The discussion was in regard to the licensees request for relief PR-07 for Callaway Plant, Unit 1. Participants in the discussion included S. Maglio and T. Elwood (the licensee) and T. Lupold, J. Billerbeck, B. Singal, and F. Lyon (NRC).

1.0 INTRODUCTION

By letter dated August 29, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13242A294), the licensee submitted alternative request PR-07 to the NRC requesting use of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), Case OMN-20, Inservice Test Frequency, for the inservice testing (IST) program.

2.0 TECHNICAL EVALUATION

The licensees request applies to the various test frequency specifications of the ASME OM Code. The ASME OM Code specifies test intervals but does not include a tolerance band on these intervals.

The lack of a tolerance band on the ASME OM Code IST intervals restricts operational flexibility.

There may be a conflict where IST could be required (i.e., the frequency could expire), but the plant operating conditions may not be suitable for performance of the required testing.

Requiring the licensee to meet the ASME OM Code requirements, without an allowance for defined frequency and frequency extensions for IST of pumps and valves, results in a hardship without a compensating increase in the level of quality and safety. Based on the prior acceptance by the NRC staff of the similar Technical Specification (TS) test interval definitions and interval extension criteria, the staff concludes that implementation of the test interval definitions and interval extension criteria contained in ASME OM Code Case OMN-20 is acceptable. Allowing usage of Code Case OMN-20 provides reasonable assurance of operational readiness of pumps and valves subject to the ASME OM Code IST.

3.0 CONCLUSION

As set forth above, the NRC staff determines that for alternative request PR-07, the proposed alternative provides reasonable assurance that the affected components are operationally ready. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in paragraph 50.55a(a)(3)(ii) of Title 10 of the Code of Federal Regulations, and is in compliance with the ASME OM Code requirements.

Therefore, on August 30, 2013, the Chief, Component Performance, NDE, and Testing Branch, Division of Engineering, and the Acting Chief, Plant Licensing Branch IV, Division of Operating Reactor Licensing, verbally authorized alternative request PR-07 at Callaway Plant, Unit 1, for the remainder of the third 10-year IST program interval, which is scheduled to end on December 19, 2014. All other ASME OM Code requirements for which relief has not been specifically requested and approved in this relief request remain applicable.

The NRC's written final safety evaluation will follow as a matter of routine. The staff may ask clarification questions as it prepares the written safety evaluation. The licensee had no additional comments or questions.

Docket No. 50-483

ML13246A307 *via email OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME FLyon* JBurkhardt MMarkley FLyon DATE 9/5/13 9/5/13 9/9/13 9/9/13