ML20342A180

NRR E-mail Capture - Callaway - LIC-109 Acceptance Requested Licensing Action - Application to Adopt 10 CFR 50.69, Risk-Informed Categorization & Treatment of Structures, Systems & Components for Nuclear Power Reactors EPID L-2020-LLA-0235

ML20342A180
Person / Time
Site:	Callaway
Issue date:	12/06/2020
From:	Mahesh Chawla NRC/NRR/DORL/LPL4
To:	Elwood T AmerenUE
References
L-2020-LLA-0235
Download: ML20342A180 (3)

Text

From: Chawla, Mahesh Sent: Sunday, December 6, 2020 3:24 PM To: 'Elwood, Thomas B'

Subject:

Callaway Plant, Unit 1 - LIC-109 Acceptance of Requested Licensing Action -

Application to Adopt 10 CFR 50.69, "Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors" - EPID L-2020-LLA-0235

Dear Mr. Elwood:

By letter dated October 30, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20304A454), Union Electric Company (dba Ameren Missouri) submitted a request for an amendment to Renewed Facility Operating License No. NPF-30 for Callaway Plant, Unit 1 (Callaway). The proposed amendment would modify the Callaway Plant licensing basis by the addition of a License Condition, i.e., License Condition 2.(C).(19), to allow for the implementation of the provisions of Title 10 of the Code of Federal Regulations (10 CFR), Part 50.69, "Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors." The provisions of 10 CFR 50.69 allow adjustment of the scope of equipment subject to special treatment controls (e.g., quality assurance, testing, inspection, condition monitoring, assessment, and evaluation). For equipment determined to be of low safety significance, alternative treatment requirements can be implemented in accordance with this regulation. For equipment determined to be of high safety significance, requirements will not be changed or will be enhanced. This allows improved focus on equipment that has safety significance, resulting in improved plant safety.

The purpose of this email is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staffs acceptance review of this license amendment request (LAR).

The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.

Consistent with Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), an application for an amendment to a license (including the technical specifications) [or construction permit] must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications. Section 50.34 of 10 CFR addresses the content of technical information required. This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations.

The NRC staff has reviewed your application and concluded that it does provide technical information in sufficient detail to enable the NRC staff to complete its detailed technical review and make an independent assessment regarding the acceptability of the proposed amendment in terms of regulatory requirements and the protection of public health and safety and the environment. Given the lesser scope and depth of the acceptance review as compared to the detailed technical review, there may be instances in which issues that impact the NRC staffs ability to complete the detailed technical review are identified despite completion of an adequate acceptance review. You will be advised of any further

information needed to support the NRC staffs detailed technical review by separate correspondence.

Based on the information provided in your submittal and discussions during the pre-licensing meeting on September 8, 2020 [

Reference:

Meeting Summary, dated October 21, 2020 (ADAMS Accession No. ML20280A563)], the NRC staff has estimated that this licensing request will take approximately 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br /> to complete. The NRC staff expects to complete this review in approximately 12 months, which is December 2021. In the application, you also requested a parallel review of this application with another Callaway LAR to adopt Technical Specifications Task Force (TSTF-505), Risk-Informed Completion Time (RICT) Program, which you plan to submit within the next three months. The NRC staff is supportive of this request as it could result in efficiencies for NRCs review. However, the NRC staff is not able to fully assess the extent to which the TSTF-505 and 50.60 LAR reviews can be performed in parallel until the TSTF-505 LAR is submitted and the NRC staff conducts its acceptance review.

As such, the estimated schedule and hours provided above apply only to NRCs review of the 50.69 LAR, and do not account for any impacts that could occur if the TSTF-505 LAR is reviewed in parallel.

Upon receipt of the LAR to adopt TSTF-505, the NRC staff will evaluate your request for conducting the parallel review of both the LARs and determine at that time its feasibility and its impact on the current schedule and the estimated hours for its completion. If NRC determines a parallel review can be performed, you will be provided written notification of any resulting changes in the above estimated hours and schedule. Also, if there are other emergent complexities or challenges in our review that would cause changes to the initial forecasted completion date or significant changes in the forecasted hours, the reasons for the changes, along with the new estimates, will be communicated during the routine interactions with the assigned project manager.

These estimates are based on the NRC staffs initial review of the application and they could change due to several factors including delayed responses to requests for additional information, unanticipated addition of scope to the review, and review by NRC advisory committees or hearing-related activities. If such changes occur, they will be communicated by written correspondence. Additional delay may occur if the submittal is provided to the NRC in advance or in parallel with industry program initiatives or pilot applications.

If you have any questions, please contact me, at (301) 415-8371.

Sincerely, Mahesh Chawla, Project Manager Licensing Branch, LPL4 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Phone: (301) 415-8371 Email: Mahesh.Chawla@nrc.gov

Hearing Identifier: NRR_DRMA Email Number: 917 Mail Envelope Properties (DM8PR09MB6853E0C9986B8664BD4C5FBFF1CF0)

Subject:

Callaway Plant, Unit 1 - LIC-109 Acceptance of Requested Licensing Action -

Application to Adopt 10 CFR 50.69, "Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors" - EPID L-2020-LLA-0235 Sent Date: 12/6/2020 3:23:39 PM Received Date: 12/6/2020 3:23:00 PM From: Chawla, Mahesh Created By: Mahesh.Chawla@nrc.gov Recipients:

"'Elwood, Thomas B'" <TElwood@ameren.com>

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