ML22256A223

Regulatory Audit Summary Regarding License Amendment Request to Revise Technical Specifications Adopt TSTF-505 and TSTF-439, Revision 2

ML22256A223
Person / Time
Site:	Callaway
Issue date:	10/17/2022
From:	Mahesh Chawla NRC/NRR/DORL/LPL4
To:	Diya F Ameren Missouri
Chawla M, NRR/DORL/LPL4
References
EPID L-2021-LLA-0197
Download: ML22256A223 (8)

Text

October 17, 2022 Mr. Fadi Diya Senior Vice President and Chief Nuclear Officer Ameren Missouri Callaway Energy Center 8315 County Road 459 Steedman, MO 65077

SUBJECT:

CALLAWAY PLANT, UNIT NO. 1 - REGULATORY AUDIT

SUMMARY

REGARDING 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 letter dated October 21, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21294A393), as supplemented by letters dated November 24, 2021 (ML21328A182), and June 30, 2022 (ML22181B129), Union Electric Company, dba Ameren Missouri (the licensee), submitted a license amendment request 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.

To support its review of the license amendment request, the U.S. Nuclear Regulatory Commission (NRC) staff conducted a virtual regulatory audit from March 22, 2022, through March 25, 2022. During the regulatory audit, the NRC staff reviewed documents and held discussions with members of Ameren Missouri and its contractors. The regulatory audit summary report is enclosed with this letter.

F. Diya If you have any questions, please contact me at 301-415-8371 or via email 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:

Audit Summary cc: Listserv

OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY AUDIT

SUMMARY

IN SUPPORT 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 NO. 1 DOCKET NO. 50-483

1.0 BACKGROUND

By letter dated October 21, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21294A393), as supplemented by letters dated November 24, 2021 (ML21328A182), and June 30, 2022 (ML22181B129), 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.

To support its review of the LAR, the U.S. Nuclear Regulatory Commission (NRC) staff conducted a virtual regulatory audit from March 22, 2022, through March 24, 2022. During the regulatory audit, the NRC staff reviewed documents and held discussions with members of Ameren Missouri and its contractors. The purpose of the audit was to gain an understanding of the information needed to support the NRC staffs licensing decision regarding the LAR and to develop requests for additional information (RAIs).

The information submitted in support of the LAR is under final review in accordance with Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-101, Revision 6, License Amendment Review Procedures (ML19248C539). The regulatory audit is a planned license or regulation-related activity that includes the examination and evaluation of primarily non-docketed information. The regulatory audit is conducted with the intent to gain understanding, to verify information, and/or to identify information that will require docketing to support the basis of a licensing or regulatory decision. Performing a regulatory audit of the licensees information is expected to assist the NRC staff in efficiently conducting its review or gain insights on the licensees processes or procedures. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket.

Enclosure

However, the NRC staff may review supporting information retained as records under Title 10 of the Code of Federal Regulations (10 CFR) Section 50.71, Maintenance of records, making of reports, and/or 10 CFR 54.37, Additional records and recordkeeping requirements, which, although not required to be submitted as part of the licensing action, would help the NRC staff better understand the licensees submitted information.

2.0 AUDIT ACTIVITIES AND OBSERVATIONS 2.1 Desk and Virtual Audit The desk audit was conducted by the NRC staff consistent with the regulatory audit plan dated February 18, 2022 (ML22048A002). The NRC staff provided information needs in the audit plan, as supplemented. The NRC staff reviewed documents during the desk-audit phase that were responsive to the information needs and made available by the licensee in an electronic reading room.

The second phase of the audit was conducted virtually between the dates of March 22-24, 2022. Detailed discussions were held on various topics between the audit team members and the licensee, aided by information needs identified by the staff in the audit plan, as supplemented, along with the licensees presentations and prepared responses to audit questions. A follow-up discussion was held on May 25, 2022, with the Callaway project manager, licensee staff, and NRR technical reviewers to discuss the collective status of audit questions. The NRC staff used the information gathered from the audit to determine whether additional information is warranted on the docket to support rendering of an NRC staff finding.

The attachment to this audit report provides a list of the information that the NRC staff reviewed throughout the audit.

3.0 RESULTS OF THE AUDIT The NRC staff did not make any regulatory decisions regarding the LAR during the audit. On May 25, 2022, during the virtual audit call, the licensee opted to provide a supplement to include the additional information the NRC staff identified. At the audit exit on March 24, 2022, the NRC staff reviewed the proposed resolution to the audit questions with the licensee and reached a consensus regarding the questions which were resolved and closed. The licensee agreed to provide the response to the remainder of the questions on the docket. The NRC staff communicated to the licensee that upon review of the supplement the staff would determine the need for an RAI. The licensee provided the supplement (ML22181B129) on June 30, 2022, to address the information needs.

Attachment:

Audit Information Reviewed

CALLAWAY TSTF 505 AUDIT INFORMATION REVIEWED No. # Branch-Request Name of Document 1 Audit Plan Item PRA-IE-UNCERT_APP5, Disposition of Key Uncertainties: Risk Informed Completion Times (RITS 4b), Revision 1, June 2021 2 Audit Plan Item Callaway Plant Procedure PRA-ZZ-00001, PRA

[Probabilistic Risk Assessment] Model Updates and Maintenance, Revision 002 3 Audit Plan Item Callaway Plant Procedure PRA-ZZ-00002, Risk Monitoring Software Configuration Control, Revision 000 4 Audit Plan Item CEC Procedure ODP-ZZ-00002, APP 2, Risk Management Actions for Planned Risk Significant Activities, Revision 019 5 Audit Plan Item CEC Procedure ODP-ZZ-00002, APP 3, Risk Management Actions for Fire Risk Systems and Components, Revision 003 6 Audit Plan Item Procedure APA-ZZ-00315, Configuration Risk Management Program, Revision 015 7 Audit Plan Item PRA-SY-CTMT, At-Power Internal Events PRA (IEPRA), Containment Safeguards Systems Analysis Notebook, Revision 000 8 Audit Plan Item PRA-SY-SA, At-Power IEPRA, Load Shedding &

Emergency Load Sequencer, Engineered Safety Feature Actuation, and Reactor Protection Systems Analysis Notebook, Revision 001 9 Audit Plan Item PRA-SY-AE, At-Power IEPRA, Main Feedwater System Analysis Notebook, Revision 000 10 Audit Plan Item APA-ZZ-00315 APP A DRAFT 11 Audit Plan Item APA-ZZ-00315 APP B DRAFT 12 Audit Plan Item APA-ZZ-00315 APP C DRAFT 13 Audit Plan Item APA-ZZ-00315 APP D DRAFT 14 Audit Plan Item APA-ZZ-00315 APP E DRAFT 15 Audit Plan Item APA-ZZ-00315 DRAFT 16 Audit Plan Item 8600-X-89233, Single Line Diagram On-Site Electrical Power Distribution System Rev. 57 17 Audit Plan Item 8618-X-94076, One Line Diagram Metering and Relaying 345-13, 8KB Safeguard Transformers PDSM-V22 and V24, Rev. 8 18 Audit Plan Item E-21001, Main Single Line Diagram FSAR Figure 8.3-2 Sheet 1, Rev. 27 19 Audit Plan Item E-21001 (Q), DC Main Single Line Diagram FSAR Rev. 16 20 Audit Plan Item Risk-Informed Completion Time (RICT) Audit-Electrical Plant Presentation Revision 1 Attachment

No. # Branch-Request Name of Document 21 NRR1/DRA2/APLA(C)3 Licensee Response to APLA(C) Question (Q)-02c -

Motor Control Center (MCC) Frequently Ask Question (FAQ)14-0009 22 NRR/DRA/APLA(C) Licensee Response to APLA(C) Q-01 PRA Model Uncertainty Analysis Process 23 NRR/DRA/APLA(C) Licensee Response to APLA(C) Q-02d Disposition of Model Assumptions and Sources of Uncertainty 03222022 24 NRR/DRA/APLA(C) Licensee Response to APLA(C) Q-02g Disposition of Model Assumptions_Uncert_Flooding 03222022 25 NRR/DRA/APLA(C) Licensee Response to APLA(C) Q-02e Sensitivity 03222022 26 NRR/DRA/APLA Licensee Response to APLA Q-03, Modeling of Analog Instrumentation and Control (I&C) Systems 27 NRR/DRA/APLA Licensee Response to APLA Q-04, Modeling of Digital I&C Systems 28 NRR/DRA/APLA Licensee Response to APLA Q-05, Impact of Seasonal Variations 29 NRR/DRA/APLA Licensee Response to APLA Q-06, In-Scope LCOs

[Limiting Conditions for Operation] and Corresponding PRA Modeling 30 NRR/DRA/APLA Licensee Response to APLA Q-07, Open Phase Condition 31 NRR/DRA/APLC Licensee Response to APLC Q-01, External Hazards 32 NRR/DSS4/STSB5 Final Safety Analysis Report (FSAR) SP Table 15.0-6, Rev. OL-15 33 RICT LAR Audit Action Tracking 03222022 34 OTN-EA-00001-R041, Service Water System Administrative Correction 35 NRR/DRA/APLC PRA-Seismic-Plant_Response_R001 36 NRR/DSS/STSB TS AC 5.5.9 - Steam Generator Program 37 NRR/DRA WCAP-16341-P-R0 Simplified Large Early Release Frequency (LERF) 38 NRR/DSS/SCPB6 Licensee Response to SCPB Q-01 39 NRR/DSS/STSB Licensee Response to STSB Q-03-final-GJP 40 NRR/DSS/STSB Licensee Response to STSB Q-02 response 41 NRR/DSS/STSB Licensee Response to STSB Q-03b and Q-03c response 42 NRR/DEX7/EEEB8 Enclosure to ULNRC-06739, Table E.1-1 In Scope TS/LCO Conditions to Corresponding PRA Functions 1

Office of Nuclear Reactor Regulation (NRR) 2 Division of Risk Assessment (DRA) 3 Probabilistic Risk Assessment (PRA) Licensing Branch A (APLA)/Branch C (APLC) 4 Division of Safety Systems (DSS) 5 Technical Specifications Branch (STSB) 6 Containment and Plant Systems Branch (SCPB) 7 Division of Engineering and External Hazards (DEX) 8 Electrical Engineering Branch (EEEB)

No. # Branch-Request Name of Document 43 NRR/DRA/APLA Licensee Response to Updated_APLA(C) Q-02b -

Fire Assumed Failed Equipment 44 NRR/DRA/APLA Licensee Response to Updated_APLA(C) Q-02c -

MCC FAQ-0009 45 NRR/DRA Licensee Response to Updated_APLC(C) Q-01 PRA Model Uncertainty Analysis Process 45 NRR/DRA Licensee Response to Updated_APLA(C) Q-02 Disposition Model Assumptions and Sources of Uncertainty 46 NRR/DRA/APLC Licensee Response to Updated_APLA(C) Q-02f Disposition of high winds Direct to LERF Model Assumptions 47 NRR/DRA/APLC Licensee Response to Updated_APLA(C) Q-02g Disposition of Model Assumptions_Uncert_Flooding 48 NRR/DRA/APLC Licensee Response to Updated_APLAC Q-02e Sensitivity 49 NRR/DRA/APLA9 Licensee Response to Updated_APLA Q-04 Digital I&C Systems 50 Licensee Response to Updated_APLA Q-05 Impact of Seasonal Variations 51 NRR/DRA/APLC Licensee Response to Updated_APLC Q-01 External Hazards 52 NRR/DSS/STSB(SNS Licensee Response to Updated_STSB and SNSB Q-B)10 01 Revision 1 9

Electrical Instrumentation and Controls Branch (EICB) 10 Nuclear Systems Performance Branch (SNSB)

ML22256A223 OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DEX/EEEB/BC NRR/DEX/EICB/BC NAME MChawla PBlechman WMorton MWaters DATE 9/20/2022 9/20/2022 10/11/2022 10/13/2022 OFFICE NRR/DRA/APLA/BC NRR/DRA/APLC/BC(A) NRR/DSS/SCPB/BC NRR/DSS/SNSB/BC (A)

NAME RPascarelli SVasavada BWittick DWoodyatt DATE 10/11/2022 9/21/2022 9/21/2022 9/21/2022 OFFICE NRR/DSS/STSB/BC NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME VCusumano JDixon-Herrity MChawla DATE 9/21/2022 10/17/2022 10/17/2022