ML21111A037

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Inspection Manual Chapter 0375 Recommendation for Callaway Plant
ML21111A037
Person / Time
Site: Callaway Ameren icon.png
Issue date: 05/03/2021
From: O'Keefe N
NRC/RGN-IV/DRP/RPB-B
To: Scott Moore
NRC Region 4
References
Download: ML21111A037 (3)


Text

May 3, 2021 MEMORANDUM TO: Scott A. Morris, Regional Administrator THRU: Ryan E. Lantz, Acting Director /RA/

Division of Reactor Projects FROM: Neil F. OKeefe, Chief /RA/

Project Branch B Division of Reactor Projects

SUBJECT:

INSPECTION MANUAL CHAPTER 0375 RECOMMENDATION FOR CALLAWAY PLANT Pursuant to Inspection Manual Chapter (IMC) 0375, Implementation of the Reactor Oversight Process at Reactor Facilities in an Extended Shutdown Condition for Reasons Not Related to Performance, this memorandum documents the Reactor Projects Branch B recommendation on implementation of the provisions of IMC 0375 for the Callaway Plant extended shutdown.

The Callaway Plant experienced a reactor trip on December 24, 2020, due to a main generator fault. The fault resulted in damage to the non-safety main generator and associated support systems that necessitated an extended outage to complete repairs. The expected duration of the outage is sufficiently long to consider implementing IMC 0375. The IMC 0375 allows the Regional Administrator significant flexibility in deciding whether and how to implement the guidance. Branch B has reviewed IMC 0375 and discussed the guidance it contains with the Inspection Program Assessment Branch, which owns the guidance. While a formal cause evaluation has not yet been completed, the licensee provided a briefing on their discovery information concerning the damage and developed the expected outage work scope sufficiently to support the present decision-making for oversight. The following recommendation was developed based on the information available.

Recommendation: The benefits of implementing all or parts of IMC 0375 are limited in this case. Specifically, there is no plant condition or safety performance issue that would drive the need to establish additional regulatory oversight or complex inspection planning. Therefore, Branch B recommends using the flexibilities available within the Reactor Oversight Process (ROP) baseline inspection program with special attention to documenting regulatory decisions, monitoring ROP performance Indicators that may become invalid, and consideration of monitoring of restart readiness of operators.

CONTACT: Neil OKeefe, DRP/B 817-917-5646.

S. Morris 2 The following factors support this recommendation:

  • The cause of the shutdown appears to be directly related to recent work within the main generator and is not applicable to any other plant equipment. The extent of condition for the damage was limited to the non-safety main generator and its support systems.

Therefore, there is no need to develop an inspection plant to ensure adequate discovery.

  • There were no safety performance issues or equipment concerns, either prior to the event or associated with the event, that necessitate further regulatory consideration or monitoring of corrective action effectiveness to ensure adequate safety prior to returning to operation.
  • The ability to perform baseline inspections or safety assessments is not expected to be affected by the nature or the expected duration of the outage.
  • Reactor Projects Branch B plans to work with the Operations Branch to consider whether to implement additional oversight prior to the unit restart based on operator proficiency following an extended outage. A recommendation will be provided and documented at that time.
  • The Be Risk Smart process was used to evaluate potential risks and risk management options. Choosing to not implement IMC 0375 is a low risk option that can be managed using normal processes.

Further recommendations on regional oversight of the Callaway Plant will be provided when the licensee is ready for restart following the extended outage.

John D. Digitally signed by John D.

Monninger Action: Approve / Disapprove Monninger Date: 2021.05.10 20:08:00

-05'00' Scott A. Morris Date Regional Administrator

ML21111A037 SUNSI Review ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: DLP Yes No Publicly Available Sensitive NRC-002 OFFICE SPE:DRP/B C:DRP/B AD:DRP NAME DProulx NOKeefe RLantz SIGNATURE /RA/ /RA/ /RA/

DATE 03/29/21 04/21/21 04/21/21