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MONTHYEARRS-20-044, Emergency License Amendment Request for a One-Time Extension of the Steam Generator Tube Inspections2020-04-0606 April 2020 Emergency License Amendment Request for a One-Time Extension of the Steam Generator Tube Inspections Project stage: Request ULNRC-06586, Attachment 4 - Affidavit2020-06-24024 June 2020 Attachment 4 - Affidavit Project stage: Request ML20178A6692020-06-26026 June 2020 Request for One-Time License Amendment to Defer Upcoming Steam Generator Inspection (LDCN 20-0013) Project stage: Request ML20178A6732020-06-26026 June 2020 Attachment 3 - Callaway Unit 1, Steam Generator Operational Assessment to Support Deferral of Planned Inspections from 1R24 to 1R25, Revision 1 (Redacted) Project stage: Request ML20190A0812020-07-15015 July 2020 Letter - Notice of Consideration of Issuance of Amendment to RFOL, Proposed Nshcd, and Opportunity for a Hearing and Order Imposing Procedures for Document Access to Sensitive Unclassified Non-Safeguards Information Project stage: Other ML20190A0792020-07-15015 July 2020, 20 July 2020 Notice of Consideration of Issuance of Amendment to RFOL, Proposed Nshcd, and Opportunity for a Hearing and Order Imposing Procedures for Document Access to Sensitive Unclassified Non-Safeguards Information (EPID L-2020-LLA-0142 Project stage: Request ML20190A0822020-07-20020 July 2020 FRN - Notice of Consideration of Issuance of Amendment to RFOL, Proposed Nshcd, and Opportunity for a Hearing and Order Imposing Procedures for Document Access to Sensitive Unclassified Non-Safeguards Information Project stage: Other ULNRC-06592, Supplement to License Amendment Request Regarding Deferral of Upcoming Steam Generator Inspection (LDCN 20-0013)2020-07-21021 July 2020 Supplement to License Amendment Request Regarding Deferral of Upcoming Steam Generator Inspection (LDCN 20-0013) Project stage: Supplement ML20205L4252020-07-22022 July 2020 NRR E-mail Capture - Callaway Plant, Unit 1 - Acceptance of Requested Licensing Action Request for One-Time License Amendment to Defer Upcoming Steam Generator Inspection (EPID L-2020-LLA-0142)(COVID-19) Project stage: Acceptance Review ML20212L3652020-08-0606 August 2020 Request for Withholding Information from Public Disclosure (EPID L-2020-LLA-0142) (COVID-19) Project stage: Withholding Request Acceptance ML20238C1072020-08-25025 August 2020 Response to Request for Additional Information (Redacted) Project stage: Response to RAI ULNRC-06603, Corrected Affidavit for Proprietary Information Provided in Support of License Amendment Request Regarding Defferal of Upcoming Steam Generator Inspection (LDCN 20-001)2020-09-0303 September 2020 Corrected Affidavit for Proprietary Information Provided in Support of License Amendment Request Regarding Defferal of Upcoming Steam Generator Inspection (LDCN 20-001) Project stage: Request ML20253A2532020-09-29029 September 2020 Request for Withholding Information from Public Disclosure (EPID L-2020-LLA-0142 (COVID-19)) Project stage: Withholding Request Acceptance ML20246G5702020-10-16016 October 2020 Issuance of Amendment No. 223 One-Time Deferral of the Steam Generator Tube Inspections Project stage: Approval 2020-07-20
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Category:Response to Request for Additional Information (RAI)
MONTHYEARULNRC-06824, Response to Request for Additional Information Regarding Operating Quality Assurance Manual (Oqam) Revision 36A2023-08-17017 August 2023 Response to Request for Additional Information Regarding Operating Quality Assurance Manual (Oqam) Revision 36A ULNRC-06821, Post-Audit Follow-Up Information in Support of Callaway'S License Amendment Request and Proposed Exemption to Allow Use of Framatome Gaia Fuel (LDCN 22-0002) (EPID L-2022-LLA-0150 and EPID L-2022-LLE-00301)2023-06-21021 June 2023 Post-Audit Follow-Up Information in Support of Callaway'S License Amendment Request and Proposed Exemption to Allow Use of Framatome Gaia Fuel (LDCN 22-0002) (EPID L-2022-LLA-0150 and EPID L-2022-LLE-00301) ML23156A6372023-06-0505 June 2023 Response to Request for Additional Information Regarding License Amendment Request for Permanent Extension of Type a and Type C Leak Rate Test Frequencies ML23129A7972023-05-0909 May 2023 Response to Audit Questions ML23088A1322023-03-29029 March 2023 Response to Request for Additional Information Regarding Results of Steam Generator Tube In-Service Inspection ML23052A0442023-02-21021 February 2023 Enclosure 2 - Supplement to License Amendment Request ML23052A0422023-02-21021 February 2023 Response to Request for Additional Information and Supplement to License Amendment Request Regarding Spent Fuel Storage (LDCN 22-0015) ML23052A0432023-02-21021 February 2023 Enclosure 1 - Response to Request for Additional Information ML22342B2662022-12-0808 December 2022 Enclosure - Ameren Missouri Response to NRC RAIs ML22335A4992022-11-16016 November 2022 Enclosure 1: Responses to Requested Information ML22244A1692022-09-0101 September 2022 Updated Response to RAT HFE-l ML22194A8032022-07-13013 July 2022 Enclosure 2: Ameren Missouri Verification Ofagreement Letters with State and EPZ Counties for Proposed Revision to Radiological Emergency Response Plan Regarding Response and Notification Goals ML22194A8022022-07-13013 July 2022 Enclosure 1: Ameren Missouri Response to NRC Requests for Additional Information ULNRC-06754, Response to Request for Additional Information Regarding Licensee Amendment Request for Adoption of Alternate Source Term and Revision of Technical Specifications2022-07-0505 July 2022 Response to Request for Additional Information Regarding Licensee Amendment Request for Adoption of Alternate Source Term and Revision of Technical Specifications ML22186A1052022-07-0505 July 2022 Response to Request for Additional Information Regarding Licensee Amendment Request for Adoption of Alternate Source Term and Revision of Technical Specifications ML22146A3392022-05-26026 May 2022 Enclosure 1: Ameren Missouri Response to NRC RAIs ML22068A0292022-03-0808 March 2022 Response to Audit Question/Item 23 in NRC Letter Dated September 14, 2021 ML21286A6822021-10-13013 October 2021 Response to Request for Additional Information Regarding License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors ULNRC-06629, Response to Request for Additional Information Pertaining to Additional Request for Exemption from Specific Requirements of 10 CFR Part 26, Fitness for Duty Programs2021-01-0707 January 2021 Response to Request for Additional Information Pertaining to Additional Request for Exemption from Specific Requirements of 10 CFR Part 26, Fitness for Duty Programs ULNRC-06602, Response to Request for Addition Information Pertaining to Revision to Technical Specification (TS) 5.3.1 and Deletion of TS 5.3.1.1 and TS 5.3.1.2 -2020-09-0202 September 2020 Response to Request for Addition Information Pertaining to Revision to Technical Specification (TS) 5.3.1 and Deletion of TS 5.3.1.1 and TS 5.3.1.2 - ML20238C1072020-08-25025 August 2020 Response to Request for Additional Information (Redacted) ULNRC-06591, Supplemental Information for Response to March, 2012 Information Request, Seismic Probabilistic Risk Assessment for Recommendation 2.12020-07-10010 July 2020 Supplemental Information for Response to March, 2012 Information Request, Seismic Probabilistic Risk Assessment for Recommendation 2.1 ML19325D6732019-11-21021 November 2019 Attachment 2 - Callaway Energy Center Seismic Probabilistic Risk Assessment in Response to 50.54(F) Letter with Regard to NTTF 2.1 Seismic - Supplemental Information ML19051A1372019-02-20020 February 2019 Attachment 1: Response to Request for Additional Information ULNRC-06482, Response to Request for Additional Information Pertaining to License Amendment Request for Addition of New Technical Specification 3.7.20, Class 1E Electrical Equipment Air Conditioning (A/C) System.2019-02-0808 February 2019 Response to Request for Additional Information Pertaining to License Amendment Request for Addition of New Technical Specification 3.7.20, Class 1E Electrical Equipment Air Conditioning (A/C) System. ML19039A3542019-02-0808 February 2019 RAI Questions and Responses ML19025A0712019-01-25025 January 2019 Response to Request for Additional Information Pertaining to Relief Request 14R-05 for Relief from Requirements of ASME Code Case N-770-2 Regarding Inspection Intervals for Reactor Vessel Nozzle Dissimilar Metal Welds ULNRC-06479, Attachment a - Mitsubishi Responses to NRC Wjp RAIs2019-01-25025 January 2019 Attachment a - Mitsubishi Responses to NRC Wjp RAIs ULNRC-06440, Response to Generic Letter 2016-01, Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools - Request for Supplemental Information2018-05-31031 May 2018 Response to Generic Letter 2016-01, Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools - Request for Supplemental Information ULNRC-06410, Callaway Plant, Unit 1 - Response to Request for Additional Information Concerning Proposed Revision of FSAR-Described Compliance with Regulatory Guide 1.106 Regarding MOV Thermal Overload Protection (Ldcn 16-0001)2018-02-0505 February 2018 Callaway Plant, Unit 1 - Response to Request for Additional Information Concerning Proposed Revision of FSAR-Described Compliance with Regulatory Guide 1.106 Regarding MOV Thermal Overload Protection (Ldcn 16-0001) ML18036A6762018-02-0505 February 2018 Enclosure 6: Response to Request for Additional Information (RAI) 1.d (MOV Performance Indicator Report for Cycle 21) ML18036A6742018-02-0505 February 2018 Enclosure 5: Response to Request for Additional Information (RAI) 1.d (MOV Performance Indicator Report for Cycle 20) ML18036A6732018-02-0505 February 2018 Enclosure 4: Response to Request for Additional Information (RAI) 1.d (MOV Performance Indicator Report for Cycle 19) ML18036A6722018-02-0505 February 2018 Enclosure 3: Response to Request for Additional Information (RAI) 1.c ULNRC-06410, Response to Request for Additional Information Concerning Proposed Revision of FSAR-Described Compliance with Regulatory Guide 1.106 Regarding MOV Thermal Overload Protection (LDCN 16-0001)2018-02-0505 February 2018 Response to Request for Additional Information Concerning Proposed Revision of FSAR-Described Compliance with Regulatory Guide 1.106 Regarding MOV Thermal Overload Protection (LDCN 16-0001) ML18036A6692018-02-0505 February 2018 Enclosure 1: Responses to Requests for Additional Information ML18036A6712018-02-0505 February 2018 Enclosure 2: Response to Request for Additional Information (RAI) Item 1.a ULNRC-06381, Spent Fuel Pool Evaluation Supplemental Report, Response to NRC Request for Information Pursuant to 10 CFR 50.54(F) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident2017-10-0303 October 2017 Spent Fuel Pool Evaluation Supplemental Report, Response to NRC Request for Information Pursuant to 10 CFR 50.54(F) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident ML17138A2132017-05-18018 May 2017 Response to Request for Additional Information Concerning Revision of TS 5.6.5, Core Operating Limits Report (Colr), to Allow the Use of the Paragon and Nexus Core Design Methods (LDCN 16-0011) ULNRC-06357, Response to Request for Additional Information, 2016 Steam Generator Tube Inspections2017-03-23023 March 2017 Response to Request for Additional Information, 2016 Steam Generator Tube Inspections ULNRC-06321, Response to Request for Additional Information, Third 10-Year Interval Inservice Inspection Request for Relief No. I3R-082016-07-0707 July 2016 Response to Request for Additional Information, Third 10-Year Interval Inservice Inspection Request for Relief No. I3R-08 ULNRC-06275, Response to Request for Additional Information (RA) Related to Operating Quality Assurance Manual (Oqam), Revision 31, Oqam Change Notice 15-0022016-01-12012 January 2016 Response to Request for Additional Information (RA) Related to Operating Quality Assurance Manual (Oqam), Revision 31, Oqam Change Notice 15-002 ULNRC-06266, Response to Request for Additional Information, Third 10-Year Interval Inservice Inspection, Request for Relief No. 13R-112015-11-24024 November 2015 Response to Request for Additional Information, Third 10-Year Interval Inservice Inspection, Request for Relief No. 13R-11 ULNRC-06238, Response to Supplemental Request for Additional Information (RAI) Related to License Amendment Request for Emergency Action Level (EAL) Upgrade Adopting NRC-Endorsed NEI 99-01, Revision 62015-08-31031 August 2015 Response to Supplemental Request for Additional Information (RAI) Related to License Amendment Request for Emergency Action Level (EAL) Upgrade Adopting NRC-Endorsed NEI 99-01, Revision 6 ULNRC-06230, Response to Request for Additional Information (RAI) Related to License Amendment Request for Emergency Action Level (EAL) Upgrade Adopting NRC-Endorsed NEI 99-01, Revision 62015-07-16016 July 2015 Response to Request for Additional Information (RAI) Related to License Amendment Request for Emergency Action Level (EAL) Upgrade Adopting NRC-Endorsed NEI 99-01, Revision 6 ULNRC-06233, Submittal of Requested Information on FSAR Section 3.1.2., Per July 9, 2015 Telephone Call2015-07-13013 July 2015 Submittal of Requested Information on FSAR Section 3.1.2., Per July 9, 2015 Telephone Call ULNRC-06227, Response to Request for Additional Information Related to License Amendment Request for Emergency Action Level Upgrade Adopting NRC-Endorsed NEI 99-01, Rev 62015-07-0606 July 2015 Response to Request for Additional Information Related to License Amendment Request for Emergency Action Level Upgrade Adopting NRC-Endorsed NEI 99-01, Rev 6 2023-08-17
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Attachment 2 to ULNRC-06595 Response to Request for Additional Information (Redacted)
framatGme RAI Response Regarding NP-386Q1NP Framatome Operational Assessment for Callaway Unit I One-Time License Amendment Request (LDCN 20-001 3)
Licensing Report August 2020 (c) 2020 Framatome Inc.
ANP-3867Q1 NP Revision I Copyright © 2020 Framatome Inc.
All Rights Reserved
Framatome Inc. ANP-3867Q1 NP Revision 1 RAI Response Regarding Framatome Operational Assessment for Callaway Unit 1 One-Time License Amendment Request (LDCN 20-0013)
Page i Nature of Changes Section(s)
Item or Page(s) Description and Justification I All Initial Issue 2 Section 4.0 Corrected a typo in Reference 6 from ccLiceYJ to License
Framatome Inc. ANP-3867Q1NP Revision I RAI Response Regarding Framatome Operational Assessment for Callaway Unit 1 One-Time License Amendment Request (LDCN 20-0013)
Page ii Contents Page
1.0 INTRODUCTION
1-1 2.0 RAI I 2-1 3.0 RAI 2 3-1
4.0 REFERENCES
4-1
Framatome Inc. ANP-3867Q1NP Revision I RAI Response Regarding Framatome Operational Assessment for Callaway Unit 1 One-Time License Amendment Request (LDCN 20-0013)
Page iii List of Figures Figure 2-1 AVB Wear Indications Weibull Fit 2-3 Figure 2-2 New AVE Wear Indications Depth Distributions 2-4
Framatome Inc. ANP-3867Q1NP Revision 1 RAI Response Regarding Framatome Operational Assessment for Callaway Unit 1 One-Time License Amendment Request (LDCN 20-0013)
Pane iv Nomenclature Acronym Definition AVB Anti-Vibration Bar ECT Eddy Current Testing EFPY Effective Full Power Years LAR License Amendment Request OA Operational Assessment PLP Potential Loose Part RAI Request for Additional Information SG Steam Generator TTS Top-of-Tubesheet
Framatome Inc. ANP-3867Q1NP Revision 1 RAI Response Regarding Framatome Operational Assessment for Callaway Unit I One-Time License Amendment Request (LDCN 20-00 13)
Page 1-1
1.0 INTRODUCTION
Framatome supported a one-time license amendment request (LAR) from Ameren Missouri for the deferral of fall 2020 steam generator (SG) tube inspections at the Callaway Plant (Unit 1) (Reference 1) by providing the technical justification in an operational assessment (OA) (References 2, 3, and 4).
On August 12, 2020, the U.S. Nuclear Regulatory Commission (NRC) staff requested the following additional information in order to complete their review of the subject LAR.
Request for Additional Information (RAI)
I . Section 5. 1 .3 of Attachment 2 discusses the treatment of new wear indications at the tube anti-vibration bar (AVE) locations. The analysis conservatively predicts over 700 total new indications at I R25 that are introduced in two populations at different intervals after I R21.
- a. Please discuss how the number of new indications are apportioned between the two populations and the basis for those numbers.
- b. Please provide an updated Figure 5-2 that also includes the I RI 8 new indication depth distribution. Discuss why the new indication deferral distribution sampled in the analysis as shown in Figure 5-2 is expected to be representative or conservative.
- 2. Table 3-4, Section 4.2.1, and Section 5.4 ofthe operational assessment describe the inspections performed with bobbin and array probes to detect foreign objects. The array probes were used in certain areas of the hot leg periphery and no tube lane to supplement the 100 percent bobbin probe inspection. Please discuss the reasoning behind supplemental array probe inspection in the hot leg only, in terms of probability of foreign object wear in the hot leg or cold leg tubes.
Note that all section numbers, tables and figures referenced in the request for additional information (RAI) are from the proprietary version of the OA (Attachment 2 of Reference I). A non-proprietary version of the OA is included in Reference 2.
Framatome Inc. ANP-3867Q1NP Revision 1 RAI Response Regarding Framatome Operational Assessment for Callaway Unit I One-Time License Amendment Request (LDCN 20-0013)
Page 2-1 2.0 RAI I QUESTION:
Section 5.1.3 of Attachment 2 discusses the treatment of new wear indications at the tube anti-vthration bar (AVB) locations. The analysis conservatively predicts over 700 total new indications at I R25 that are introduced in two populations at different intervals after 1R21.
- a. Please discuss how the number of new indications are apportioned between the two populations and the basis for those numbers.
- b. Please provide an updated Figure 5-2 that also includes the I RI 8 new indication depth distribution. Discuss why the new indication deferral distribution sampled in the analysis as shown in Figure 5-2 is expected to be representative or conservative.
RESPONSE
The number of new AVB wear indications initiated in the probabilistic model is determined through use of a Weibull fit to the cumulative number indications identified in the Callaway steam generators (SGs), as shown in Figure 2-1 The Weibull fit utilized in the evaluation reflects a more aggressive initiation rate than is expected to occur going forward and would project a much larger number of new indications during IR2I than actually occurred. This can be observed by noting that the actual number of newly reported indications decreased in I R2I as compared with I RI 8, which is a behavior consistent with the experience of most plants experiencing structure wear.
Since the Kunin distribution of new wear depths (Figure 2-2) is based on a three-cycle operating interval (IRI8 to 1R21), it is appropriate to introduce new flaws to the simulation at 1R24 (i.e., three cycles after 1R2I). The second population of new flaws is introduced at 1R25, after only one additional cycle of operation. This is quite conservative since the same 3-cycle Kunin depth distribution is used for this purpose.
Framatome Inc. ANP-3867Q1NP Revision I RAI Response Regarding Framatome Operational Assessment for Callaway Unit I One-Time License Amendment Request (LDCN 20-0013)
Page 2-2 Attenuation of AVB wear growth over time is an observed behavior; therefore, it is assumed that the depth distribution of new indications at I R21 will be similar if not bounding of an expected new indication depth distribution that would be identified after the following three-cycles (i.e., at 1R24). This attenuation can be observed in the Callaway new indication depth distributions from 1R15, 1R18 and 1R21, as shown in Figure 2-2. It should be noted that the SGs had only operated one cycle at 1R15, so the new indications at 1R15 were adjusted to a comparable 3-cycle length of 4.016 EFPY (i.e., the summation of Cycles 15, 16 and 17 from Reference 2).
Framatome Inc. ANP-3867Q1NP Revision 1 RAI Response Regarding Framatome Operational Assessment for Callaway Unit 1 One-Time License Amendment Request (LDCN 20-0013)
Page 2-3 Figure 2-1 AVB Wear Indications WeibuN Fit
[d,e]
Framatome Inc. ANP-3867Q1NP Revision I RAt Response Regarding Framatome Operational Assessment for Callaway Unit I One-Time License Amendment Request (LDCN 20-0013)
Page 2-4 Figure 2-2 New AVB Wear Indications Depth Distributions
Framatome Inc. ANP-3867Q1NP Revision I RAI Response Regarding Framatome Operational Assessment for CaHaway Unit 1 One-Time License Amendment Request (LDCN 20-00 13)
Page 3-1 3.0 RAI 2 QUESTION:
Table 3-4, Section 4.2.1, and Section 5.4 of the operational assessment describe the inspections performed with bobbin and array probes to detect foreign objects. The array probes were used in certain areas of the hot leg periphery and no tube lane to supplement the 100 percent bobbin probe inspection. Please discuss the reasoning behind supplemental array probe inspection in the hot leg only, in terms of probability of foreign object wear in the hot leg or cold leg tubes.
RESPONSE
No foreign object wear or foreign objects that could potentially impact tube integrity have been identified in the Callaway SGs to date, and the incorporation of loose part trapping features within the SG design provides a high level of assurance that tube integrity will not be impacted by foreign material going forward.
The array probe examination of the hot leg periphery tubes performed during 1R21 represents a 50% sample of the most important tubesheet region with respect to foreign object wear (i.e., 50% of hot leg plus cold leg locations). In the absence of any indication of foreign objects or wear during this examination, no expansion of the inspection scope into the cold leg was considered to be necessary. In addition, 100% of the top of tubesheet region (hot and cold leg) was examined with bobbin probes. While bobbin probe detection of foreign objects and wear very close to the TTS is not equal to that of the array probe, the bobbin probe inspection nonetheless provides additional assurance that significant foreign object wear was not present in the tubes.
The I R21 CMOA (Reference 5) summarizes these points:
I . Callaway has no history of foreign object wear or foreign objects. Neither ECT examinations nor secondary side visual inspections have identified foreign object wear or foreign objects through 9.369 EFPY of operation (through 1 R21).
Framatome Inc. ANP-3867Q1NP Revision I RAI Response Regarding Framatome Operational Assessment for Callaway Unit 1 One-Time License Amendment Request (LDCN 20-0013)
Page 3-2
- 2. During 1R18 and 1R21, visual inspections were performed along both the hot and cold leg periphery and inner bundle passes from the no-tube lane to the sludge pile region. These visual inspections can typically see 8 tubes deep into the bundle and as identified above, have identified no foreign objects.
- 3. During I RI 8 and I R21 visual inspections were performed in the upper steam drum of all four SGs. These inspections revealed no foreign objects on the loose part trapping screen, or any degradation of secondary side components that could result in foreign material entering the SG tube bundle.
- 4. Callaway water lanced all four SGs during I RI 8 and I R21 A review of the material found in the lancing strainers at 1R18 (Reference 7) and 1R21 identified only a small number of foreign objects such as tube scale, rubber, plastic, sludge rocks, string, and two small metallic pieces less than 0.5 in length, none of which pose a threat to tube integrity.
Framatome Inc. ANP-3867Q1NP Revision I RAI Response Regarding Framatome Operational Assessment for Callaway Unit I One-Time License Amendment Request (LDCN 20-0013)
Page 4-1
4.0 REFERENCES
I . NRC ADAMS Accession No. ML2OI 78A668, Callaway Plant Unit 1 Request for, One-Time License Amendment to Defer Upcoming Steam Generator Inspection (LDCN 20-0013).
- 2. NRC ADAMS Accession No. ML2O1 78A673 Attachment 3 Callaway Unit I, Steam Generator Operational Assessment to Support Deferral of Planned Inspections from 1 R24 to I R25, Revision I (Redacted). (Corresponds to Framatome Documents 5 1 -931 2589-000 (Proprietary) and 51 -931 2589-001 (Non-Proprietary).)
- 3. Framatome Letter Framatome-20-01407, from Josh Harrison to Carissa Richardson,
Subject:
Transmittal of the following Framatome Proprietary Documents and Related Affidavit for Ameren/Callaway Records and Use, dated June 25, 2020.
- 4. Framatome Letter Framatome-20-05105, from Josh Harrison to Carissa Richardson,
Subject:
51-9312589-000 Callaway Unit 1 Steam Generator Operational Assessment to Support Deferral of Planned Inspections from 1 R24 to 1R25, dated July 14, 2020.
- 5. Framatome Document 51-9259621-000, Callaway Unit I SG Condition Monitoring for Cycles 19, 20 and 21 and Final Operational Assessment for Cycles 22, 23 and 24.
- 6. NRC ADAMS Accession No. ML20203M328, Callaway Plant Unit 1, Supplement to License Amendment Request Regarding Deferral of Upcoming Steam Generator Inspection (LDCN 20-001 3).
- 7. Framatome Document 51-9177474-000, Callaway 1R18 Steam Generator Deposit Characterization.