ML20304A456

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Enclosures to Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors
ML20304A456
Person / Time
Site: Callaway Ameren icon.png
Issue date: 10/30/2020
From:
Ameren Missouri, Union Electric Co
To:
Office of Nuclear Reactor Regulation
Shared Package
ML20304A454 List:
References
ULNRC-06550
Download: ML20304A456 (9)


Text

Enclosure 2 to U LN RC-06550 Mark-up of Operating License (OL)

IS0.69 LAR

1. In order to ensure that the threads for RPV closure stud hole No. 18 can perform their intended function throughout the period of extended operation, UE shall remove stuck stud No. 18. If repair of stud hole No. 18 is required following removal of the stud, the repair plan shall include inspection of the stud hole prior to and after the completion of the repair.
2. In order to ensure that RPV stud holes with damaged threads can continue to perform their intended function throughout the period of extended operation, UE shall perform a laser inspection for the threads of repaired RPV stud hole location Nos. 2, 4, 5, 7, 9, and 53. If inspection of these RPV stud holes reveals that there is additional degradation in any of these stud holes, the condition will be entered in the Corrective Action Program for evaluation and corrective action, and UE shall also inspect the remaining repaired RPV stud hole locations (Nos. 13, 25, 39 and 54).

(18) Implementation Actions for New Technical Specification 3.7.20 The planned plant modifications and emergency operating procedure changes described as commitments in Attachment 5 of Ameren Missouri letter ULNRC-06477, "Supplement to License Amendment Request for Addition of New Technical Specification 3.7.20, 'Class 1E Electrical Equipment Air Conditioning (A/C) System' (LDCN 16-0013)," dated January 23, 2019, shall be completed prior to implementation of the license amendment requested per Ameren Missouri letter ULNRC-06401, "License Amendment Request for Addition of New Technical Specification

3. 7 .20, 'Class 1E Electrical Equipment Air Conditioning (A/C) System' (LDCN 16-0013)," dated March 9, 2018, as supplemented by the noted January 23, 2019 letter (ULNRC-06477) and Ameren Missouri letter ULNRC-06491, "Additional Supplement to License Amendment Request See insert A for Addition of New Technical Specification 3.7.20, 'Class 1E Electrical Equipment Air Conditioning (A/C) System' (LDCN 16-0013)," dated March 7, 2019. Completion of the planned plant modifications means physical completion, including completion of the post-modification testing.

D. An Exemption from certain requirements of Appendix J to 10 CFR Part 50, are described in the October 9, 1984 staff letter. This exemption is authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest. Therefore, this exemption is hereby granted pursuant to 10 CFR 50.12. With the granting of this exemption the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.

E. UE shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements Renewed License No. NPF-30 Amendment No. 219

!Insert A (19) Implementation of 10 CFR 50.69, "Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors" Ameren Missouri is approved to implement 10 CFR 50.69 using the processes for categorization of Risk Informed Safety Class (RISC)-1, RISC-2, RISC-3, and RISC-4 SSCs using: Probabilistic Risk Assessment (PRA) models to evaluate risk associated with internal events, including internal flooding, internal fire, high winds, and seismic risk; the shutdown safety assessment process to assess shutdown risk; the Arkansas Nuclear One, Unit 2 (ANO-2) passive categorization method to assess passive component risk for Class 2 and Class 3 SSCs and their associated supports; and the results of non-PRA evaluations that are based on a screening of other external hazards updated using the external hazard screening significance process identified in American Society of Mechanical Engineers (ASME)/American Nuclear Society (ANS) PRA Standard RA-Sa-2009; as specified in License Amendment No. [XXX] dated [Date].

to ULNRC-06550 Clean Copy of Affected Operating License Pages

1. In order to ensure that the threads for RPV closure stud hole No. 18 can perform their intended function throughout the period of extended operation, UE shall remove stuck stud No.
18. If repair of stud hole No. 18 is required following removal of the stud, the repair plan shall include inspection of the stud hole prior to and after the completion of the repair.
2. In order to ensure that RPV stud holes with damaged threads can continue to perform their intended function throughout the period of extended operation, UE shall perform a laser inspection for the threads of repaired RPV stud hole location Nos. 2, 4, 5, 7, 9, and 53. If inspection of these RPV stud holes reveals that there is additional degradation in any of these stud holes, the condition will be entered in the Corrective Action Program forevaluation and corrective action, and UE shall also inspect the remaining repaired RPV stud hole locations (Nos. 13, 25, 39 and 54 ).

(18) Implementation Actions for New Technical Specification 3.7.20 The planned plant modifications and emergency operating procedure changes described as commitments in Attachment 5 of Ameren Missouri letter ULNRC-06477, "Supplement to License Amendment Request for Addition of New Technical Specification 3.7.20, 'Class 1E Electrical Equipment Air Conditioning (A/C) System' (LDCN 16-0013)," dated January 23, 2019, shall be completed prior to implementation of the license amendment requested per Ameren Missouri letter ULNRC-06401, "License Amendment Request for Addition of New Technical Specification 3.7.20,

'Class 1E Electrical Equipment Air Conditioning (A/C) System' (LDCN 16-0013)," dated March 9, 2018, as supplemented by the noted January 23, 2019 letter (ULNRC-06477) and Ameren Missouri letter ULNRC-06491, "Additional Supplement to License Amendment Request for Addition of New Technical Specification 3.7.20, 'Class 1E Electrical Equipment Air Conditioning (A/C) System' (LDCN 16-0013)," dated March 7, 2019. Completion of the planned plant modifications means physical completion, including completion of the post-modification testing.

(19) Implementation of 10 CFR 50.69. "Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors" Ameren Missouri is approved to implement 10 CFR 50.69 using the processes for categorization of Risk Informed Safety Class (RISC)-1, RISC-2, RISC-3, and RISC-4 SSCs using: Probabilistic Risk Assessment (PRA) models to evaluate risk associated with internal events, including internal flooding, internal fire, high winds, and seismic risk; the shutdown safety assessment process to assess shutdown risk; the Arkansas Nuclear One, Unit 2 (ANO-2) passive categorization method to assess passive component risk for Class 2 and Class 3 SSCs and their associated supports; and the results of non-PRA evaluations that are based on a screening of other external hazards updated using Renewed License No. NPF-30 Amendment No. 2xx

the external hazard screening significance process identified in American Society of Mechanical Engineers (ASME)/American Nuclear Society (ANS) PRA Standard RA-Sa-2009; as specified in License Amendment No. [XXX] dated [Date].

D. An Exemption from certain requirements of Appendix J to 10 CFR Part 50, are described in the October 9, 1984 staff letter. This exemption is authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest. Therefore, this exemption is hereby granted pursuant to 10 CFR 50.12. With the granting of this exemption the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.

E. UE shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 10 CFR 73.21, are entitled: "Callaway Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision O" submitted by letter dated October 20, 2004, as supplemented by the letter May 11, 2006.

UE shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The Callaway Plant Unit 1 CSP was approved by License Amendment No. 203, as supplemented by changes approved per License Amendment No. 214.

F. Deleted per Amendment No. 169.

G. UE shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.

H. This renewed license is effective as of the date of issuance and shall expire at Midnight on October 18, 2044.

FOR THE NUCLEAR REGULATORY COMMISSION IRA/

William M. Dean, Director Office of Nuclear Reactor Regulations Renewed License No. NPF-30 Amendment No. 2xx

Attachments/Appendices:

1. Attachment 1 (Deleted per Amendment No. 169)
2. Attachment 2 (Deleted per Amendment No.169)
3. Appendix A - Technical Specifications (NUREG-1058, Revision 1)
4. Appendix B - Environmental Protection Plan
5. Appendix C - Additional Conditions Date of Issuance: March- - " '6- -, 2015 Renewed License No. NPF-30 Amendment No. 2xx to ULNRC-06550 Commitment

LIST OF COMMITMENTS The following table identifies those actions committed to by Ameren Missouri in this document. Any other statements in this document are provided for information purposes and are not considered commitments. Please direct questions regarding these commitments to: Justin Hiller at 314-225-1141.

COMMITMENT Due Date/Event COMN The resolution of Fire PRA Suggestion F&O Prior to using the 50437 FSS-Bl-03 was determined to be an upgrade Fire PRA to during F&O closure review. The upgrade was support not reviewed at the time of identification and implementation has not yet been reviewed by an independent of any alternative peer review. To resolve FSS-Bl-03 and also treatments under close NFPA-805 LAR Table S-3 the 10 CFR 50.69 Implementation item 13-805-001, the Fire PRA application.

was updated to perform the Human Reliability Analysis (HRA) evaluations for MCR abandonment using detailed assessments within HRA Calculator rather than the screening values discussed in this F&O. This change was determined by a recent independent peer review team to be an upgrade. PRA scope and technical adequacy guidance requires upgrades to be independently peer reviewed and Finding F&Os to be closed, or dispositioned for a given application. Therefore, Ameren Missouri will conduct a focused scope peer review on this upgrade and close any new Finding F&Os using an endorsed closure process.