ML22048A002
| ML22048A002 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 02/18/2022 |
| From: | Mahesh Chawla Plant Licensing Branch IV |
| To: | Diya F Union Electric Co |
| Chawla M | |
| References | |
| EPID L-2021-LLA-0197, TSTF-439, Rev 2, TSTF-505, Rev 2 | |
| Download: ML22048A002 (8) | |
Text
February 18, 2022 Mr. Fadi Diya Senior Vice President and Chief Nuclear Officer Ameren Missouri Callaway Energy Center 8315 County Road 459 Fulton, MO 65077
SUBJECT:
CALLAWAY PLANT, UNIT NO. 1 - REGULATORY AUDIT PLAN AND SETUP OF ONLINE REFERENCE PORTAL FOR LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-505, REVISION 2 AND TSTF-439, REVISION 2 (EPID L-2021-LLA-0197)
Dear Mr. Diya:
By application dated October 21, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21294A393), as supplemented by letter dated November 24, 2021 (ADAMS Accession No. ML21328A182), Union Electric Company, dba Ameren Missouri (the licensee), submitted a license amendment request (LAR) for Callaway Plant, Unit No. 1 (Callaway). The proposed amendment would modify the Callaway Technical Specifications (TSs) to implement risk-informed completion times and the Risk-Informed Completion Time Program in accordance with Technical Specifications Task Force (TSTF)
Traveler TSTF-505, Provide Risk-Informed Extended Completion Times - RITSTF [Risk-Informed TSTF] Initiative 4b, Revision 2. In support of the adoption of TSTF-505, the licensee also would adopt TSTF-439, Revision 2, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO [Limiting Condition for Operation], which involves the elimination of second completion times currently specified in the TSs. In addition, the proposed amendment would remove obsolete one-time completion times contained in the Callaway TSs.
The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the licensees LAR and determined that a regulatory audit would assist in the timely completion of the review. The NRC staff will conduct a regulatory audit to support its review in accordance with the enclosed audit plan. A regulatory audit is a planned activity that includes the examination and evaluation of primarily non-docketed information To improve the efficiency of the NRC staff reviews, the licensees representatives and the NRC staff have discussed having an audit using an online reference portal. The NRC staff plans to initially conduct a review of the documentation provided on the portal. The audit meeting with the licensee is scheduled for March 22-25, 2022. The online reference portal would allow the NRC staff to audit documents referenced in the request to determine whether the information included in the documents is necessary to reach a safety conclusion on the proposed amendment. The licensee will be formally requested to submit information needed to reach a
safety conclusion on the NRC docket. Use of the online reference portal is acceptable as long as the following conditions are met:
The online reference portal will be password-protected, and passwords will be assigned to those directly involved in the review on a need-to-know basis; The online reference portal will be sufficiently secure to prevent NRC staff and contractors from printing, saving, or downloading any documents; and Conditions of use of the online reference portal will be displayed on the login screen and will require concurrence by each user.
The NRC staff would like to request that the portal be populated with the documents listed in the attachment to the enclosure to this letter. This is the initial list identified by the NRC staff. The NRC staff may request additional documents during the review via email. Please provide the NRC staff with access to the portal and send me the information needed for access, such as username and password, as soon as possible. The conditions associated with the online reference portal must be maintained throughout the duration of the audit. Please provide written confirmation that Ameren Missouri agrees to the terms and conditions set forth in this letter.
If you have any questions, please contact me at 301-415-8371 or via e-mail at Mahesh.Chawla@nrc.gov.
Sincerely,
/RA/
Mahesh L. Chawla, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483
Enclosure:
Regulatory Audit Plan cc: Listserv
REGULATORY AUDIT PLAN TO SUPPORT REVIEW OF LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-505, REVISION 2 AND TSTF-439, REVISION 2 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483
1.0 BACKGROUND
By application dated October 21, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21294A393), as supplemented by letter dated November 24, 2021 (ADAMS Accession No. ML21328A182), Union Electric Company, dba Ameren Missouri (the licensee), submitted a license amendment request (LAR) for Callaway Plant, Unit No. 1 (Callaway). The proposed amendment would modify the Callaway Technical Specifications (TSs) to implement risk-informed completion times and the Risk-Informed Completion Time (RICT) program in accordance with Technical Specifications Task Force (TSTF) Traveler TSTF-505, Provide Risk-Informed Extended Completion Times - RITSTF
[Risk-Informed TSTF] Initiative 4b, Revision 2. In support of the adoption of TSTF-505, the licensee also would adopt TSTF-439, Revision 2, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO [Limiting Condition for Operation], which involves the elimination of second completion times currently specified in the TSs. In addition, the proposed amendment would remove obsolete one-time completion times contained in the Callaway TSs.
2.0 REGULATORY AUDIT BASES, SCOPE, AND METHODOLOGY A regulatory audit is a planned license or regulation-related activity that includes the examination and evaluation of primarily non-docketed information. The audit is conducted to further identify material the U.S. Nuclear Regulatory Commission (NRC) staff may determine is warranted on the docket to support the basis of a licensing or regulatory decision. Performing a regulatory audit is expected to assist the NRC staff in efficiently conducting its review of the LAR and to gain insights on the licensees processes and procedures. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket.
The basis of this remote audit is to support the NRC staff review of the licensees LAR for Callaway, and NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR -Light-Water Reactor] Edition, Section 19.2, Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance, dated June 2007 (ADAMS Accession No. ML071700658).
The remote audit will be performed consistent with NRC Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, Revision 1, Regulatory Audits, dated October 31, 2019 (ADAMS Accession No. ML19226A274). The NRC staff plans to initially conduct a desk audit to review the documentation provided on the portal. The audit meeting with the licensee is scheduled for March 22-25, 2022. An audit was determined to be the most efficient approach toward a timely resolution of issues associated with this LAR review, since the NRC staff will have an opportunity to minimize the potential for multiple rounds of requests for additional information (RAIs) and ensure that no unnecessary burden will be imposed by requiring the licensee to address issues that are no longer necessary to make a safety determination. Audit review items include the following:
Understand how the licensees proposed program implements the risk-informed application and conforms to NRC-endorsed Nuclear Energy Institute (NEI) guidance in NEI 06-09, Revision 0-A, Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines, November 2006 (ADAMS Accession No. ML12286A322)..
Gain a better understanding of the detailed calculations, analyses, and bases underlying the LAR and confirm the NRC staffs understanding of the LAR.
Gain a better understanding of plant design features and their implications for the LAR.
Identify any information needed to enable the NRC staffs evaluation of the technical acceptability of the probabilistic risk assessment (PRA) used for this application.
Identify any information needed to enable the NRC staffs evaluation of whether the proposed changes challenge design-basis functions or adversely affect the capability or capacity of plant equipment to perform design-basis functions.
Identify any information needed to enable the NRC staffs evaluation of diverse means for instrumentation and controls functions.
Identify questions and requests that may become formal RAIs per NRR Office Instruction LIC-115, Processing Requests for Additional Information, Revision 1, dated August 9, 2021 (ADAMS Accession No. ML21141A238).
3.0 INFORMATION AND OTHER MATERIALS NECESSARY FOR THE REMOTE REGULATORY AUDIT The NRC staff will request information as needed. The NRC staff will use an audit items list to identify the information (e.g., methodology, process information, and calculations) to be audited and the subjects of requested interviews and meetings. The NRC staff requests the licensee to have the requested audit information listed in the audit document request to be readily available and accessible for the NRC staffs review via a web-based portal.
The NRC staff requests the licensee to have the information referenced in the Attachment to this audit plan available and accessible for the NRC staffs review via an online reference portal as soon as feasible within few days of the issuance of this audit plan. The NRC staff requests that any supplemental information requested be available and accessible for the NRC staffs
review at the licensees earliest possible date from the date of the NRCs notification to the licensee of the new requests.
The licensee should be prepared to provide the following examples and demonstrations during the audit:
Demonstration of the risk monitor tool Example of an RICT calculation Example of PRA functional definition, development, and use Example of Risk Management Action determination Modeling of the instrumentation and controls LCOs in the PRA The NRC staff will audit the PRA methods that the licensee plans to use to determine the risk impact, including the licensee assessments of internal events (including internal flooding) and fire PRAs. The NRC staff will also audit the licensees quantification of risk from significant external events, whether the licensee uses PRA or bounding methods, and the licensees evaluation of defense-in-depth. The NRCc audit team is identified in Section 4.0.
4.0 AUDIT TEAM Division Branch NRR Staff/
Contractor Title Email DORL1 LPL42 Mahesh Chawla Project Manager Mahesh.Chawla@nrc.gov Dennis Galvin Project Manager (Backup)
Dennis.Galvin@nrc.gov DRA3 APLA4 Adrienne Brown (Integrated Review Team Lead)
Senior Reliability and Risk Analyst Adrienne.Driver@nrc.gov April Pulvirenti Reliability and Risk Analyst April.Pulvirenti@nrc.gov Jeff Circle Senior Reliability and Risk Analyst Jeff.Circle@nrc.gov APLC5 De Wu Reliability and Risk Analyst De.Wu@nrc.gov Keith Tetter Reliability and Risk Analyst Keith.Tetter@nrc.gov DSS6 STSB7 Andrea Russell Safety and Plant Systems Engineer Andrea.Russell@nrc.gov SCPB8 Chang Li Senior Safety and Plant Systems Engineer Chang.Li@nrc.gov Derek Scully Reactor Systems Engineer Derek.Scully@nrc.gov SNSB9 Summer Sun Senior Nuclear Engineer Summer.Sun@nrc.gov DEX10 EEEB11 Edmund Kleeh Electrical Engineer Edmund.Kleeh@nrc.gov Nadim Khan Electrical Engineer Nadim.Khan@nrc.gov EICB12 Ming Li Electronics Engineer Ming.Li@nrc.gov William Roggenbrodt Electronics Engineer William.Roggenbrodt@nrc.gov EMIB13 Kaihwa Hsu Senior Mechanical Engineer Kaihwa.Hsu@nrc.gov PNNL14 Garill Coles Contractor Garill.Coles@pnnl.gov 1 Division of Operating Reactor Licensing 2 Plant Licensing Branch IV 3 Division of Risk Assessment 4 Probabilistic Risk Assessment Licensing Branch A 5 Probabilistic Risk Assessment Licensing Branch C 6 Division of Safety Systems 7 Technical Specifications Branch 8 Containment and Plant Systems Branch 9 Nuclear Systems Performance Branch 10 Division of Engineering and External Hazards 11 Electrical Engineering Branch 12 Instrumentation and Controls Branch 13 Mechanical Engineering and Inservice Testing Branch 14 United States Department of Energy Pacific Northwest National Laboratory (PNNL)
5.0 SPECIAL REQUESTS The NRC requests access to requested documents and information through a web-based portal that allows the NRC staff and contractors to access documents over the internet. The following conditions associated with the online portal must be maintained while the NRC staff and contractors have access to the online portal:
The online portal will be password-protected. A separate password will be assigned to each member of the NRC staff and NRC contractors participating in the audit.
The online portal will prevent the NRC participants from printing, saving, downloading, or collecting any information directly from the online portal.
Conditions of use of the online portal will be displayed on the login screen and will require acknowledgment by each user.
Username and password information should be provided directly to members of the NRC staff and contractors. The NRC licensing project manager will provide the licensee with the names and contact information of the NRC staff and contractors participating in the audit. All other communications should be coordinated through the NRC project manager.
6.0 DELIVERABLES The NRC staff would like access to the documents requested through the online reference portal that allows the NRC staff and contractors to access documents remotely by February 25, 2022. The NRC staff and contractor access to the online portal should be terminated by June 30, 2022. The NRC staff will issue an audit summary report within 90 days of the completion of the audit. The NRC staff will develop any RAIs, as needed, consistent with the guidance in NRR Office Instruction LIC-115, Revision 1, and issue such RAIs separately from audit-related correspondence.
Attachment:
Requested Audit Materials List
Attachment REQUESTED AUDIT MATERIALS LIST ITEM AUDIT DOCUMENT REQUEST 1
PRA-IE-UNCERT_APP5, Disposition of Key Uncertainties: Risk Informed Completion Times (RITS 4b), Revision 1, June 2021 2
Callaway Plant Procedure PRA-ZZ-00001, PRA [Probabilistic Risk Assessment]
Model Updates and Maintenance, Revision 002 3
Callaway Plant Procedure PRA-ZZ-00002, Risk Monitoring Software Configuration Control, Revision 000 4
CEC Procedure, ODP-ZZ-00002, APP 2, Risk Management Actions for Planned Risk Significant Activities, Revision 019 5
CEC Procedure, ODP-ZZ-00002, APP 3, Risk Management Actions for Fire Risk Systems and Components, Revision 003 6
Procedure, APA-ZZ-00315, Configuration Risk Management Program, Revision 015.
7 Internal Events Probabilistic Analysis (IEPRA) System Notebook for Containment Cooling and Spray 8
IEPRA System Notebook for Engineered Safety Function Actuation System 9
IEPRA System Notebook for Main Feedwater and Main Turbine 10 Any risk-informed completion time (RICT) program procedures such as for:
RICT Program Risk Management Support of RICT Calculation of Risk Management Action Tracking and RICT Performance Monitoring 11 Applicable plant design and operation documentation as they pertain to audit question responses:
System, off-normal, and emergency operating procedures Flow diagrams One-line diagrams - main for plant alternating current (AC) distribution system, safety related buses, including AC and direct current (DC),
120-volt alternating current (VAC) vital buses, and diesel generators (DGs)
Schematics Piping and instrumentation diagrams Procedure(s) for loss of one safety AC or DC bus 12 Electrical presentation on the following:
Normal and emergency lineups (two offsite sources or DGs)
Shared loads between electrical system trains or divisions Main AC safety buses at medium and low voltage levels (not motor control centers including DC safety buses)
Proposed electrical technical specification changes and license amendment request Table E1-1 on minimum AC or DC sources to facilitate the RICT program
- concurrence via e-mail OFFICE NRR/DORL/LPL4/PM*
NRR/DORL/LPL4/LA*
NRR/DRA/APLA/BC*
NRR/DRA/APLC/BC*
NAME MChawla PBlechman RPascarelli SRosenberg (SVasavada for)
DATE 2/16/2022 2/17/2022 2/14/2022 2/14/2022 OFFICE NRR/DSS/SCPB/BC(A)*
NRR/DSS/SNSB/BC*
NRR/DSS/STSB/BC*
NRR/DEX/EICB/BC*
NAME SJones SKrepel (CPeabody for)
VCusumano MWaters DATE 2/10/2022 2/14/2022 2/9/2022 2/16/2022 OFFICE NRR/DEX/EEEB/BC*
NRR/DEX/EMIB/BC(A)*
NRR/DORL/LPL4/BC*
NRR/DORL/LPL4/PM*
NAME WMorton ITseng JDixon-Herrity (TWengert for)
MChawla DATE 2/14/2022 2/16/2022 2/18/2022 2/18/2022