ML23317A001
| ML23317A001 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 01/12/2024 |
| From: | Mahesh Chawla Plant Licensing Branch IV |
| To: | Diya F Union Electric Co |
| Chawla M | |
| References | |
| EPID L-2022-LLA-0176 | |
| Download: ML23317A001 (6) | |
Text
January 12, 2024 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 CLARIFY SUPPORT SYSTEM REQUIREMENTS FOR THE RESIDUAL HEAT REMOVAL AND CONTROL ROOM AIR CONDITIONING SYSTEM UNDER TECHNICAL SPECIFICATIONS 3.4.8, 3.7.11, AND 3.9.6 (EPID L-2022-LLA-0176)
Dear Mr. Diya:
By letter dated December 1, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22335A507), supplemented by letters dated October 16, 2023 (ML23289A214), and November 20, 2023 (ML23324A370), Union Electric Company, doing business as Ameren Missouri (the licensee), pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.90, Application for amendment of license, construction permit, or early site permit, submitted an application for amendment to Renewed Facility Operating License No. NPF-30 for the Callaway Plant, Unit No. 1 (Callaway).
The proposed amendment would revise Callaways Technical Specification (TSs),
licensing basis and Final Safety Analysis Report to allow use of one train of the normal, non-safety-related service water system to provide cooling water support (in lieu of support from the associated safety-related essential service water train) for one of two redundant trains of TS-required equipment when both equipment trains are required to be operable during cold shutdown/refueling conditions.
To support its review of the license amendment request, the U.S. Nuclear Regulatory Commission (NRC) staff conducted a regulatory audit virtually using an online portal. The NRC staff requested information during the initial phase of the audit, which was uploaded to the online portal by the licensee, for NRC staffs review. The virtual regulatory audit meeting was held between the NRC staff and the licensee representatives from April 11-12, 2023, followed by subsequent calls during which the NRC staff held discussions with the licensee. The audit was kept open to submit additional audit questions and to conduct follow-up audit discussions.
The regulatory audit summary report is enclosed with this letter.
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:
Regulatory Audit Summary cc: Listserv
Enclosure REGULATORY AUDIT
SUMMARY
IN SUPPORT OF LICENSE AMENDMENT REQUESTS TO CLARIFY SUPPORT SYSTEM REQUIREMENTS FOR THE RESIDUAL HEAT REMOVAL AND CONTROL ROOM AIR CONDITIONING SYSTEM UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT NO. 1 DOCKET NO. 50-483
1.0 BACKGROUND
By letter dated December 1, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22335A507), supplemented by letters dated October 16, 2023 (ML23289A214), and November 20, 2023 (ML23324A370), Union Electric Company, doing business as Ameren Missouri (the licensee), submitted a license amendment request (LAR) for Callaway Plant, Unit No. 1 (Callaway). The proposed amendment would revise Callaways Technical Specifications (TSs), TS Bases and Final Safety Analysis Report, to allow use of one train of the normal, non-safety-related service water system to provide cooling water support (in lieu of support from the associated safety-related essential service water train) for one of two redundant trains of TS-required equipment when both equipment trains are required to be operable during cold shutdown/refueling conditions.
The U.S. Nuclear Regulatory Commission (NRC) staff conducted a regulatory audit in accordance with the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, Revision 1, Regulatory Audits, dated October 31, 2019 (ML19226A274). 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 to 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.
During the regulatory audit, the NRC staff reviewed documents, responses to audit questions, 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 (RAI).
2.0 AUDIT ACTIVITIES AND OBSERVATIONS 2.1 Virtual Audit The audit was conducted by the NRC staff consistent with the regulatory audit plan dated March 28, 2023 (ML23065A321). The NRC staff provided the list of documents needed in the audit plan along with audit questions. The licensee uploaded the requested documents to an
electronic portal and provided access to the NRC audit team. The NRC staff reviewed the documents made available by the licensee in an electronic reading room.
The audit was conducted virtually in meetings during the dates of April 11-12, 2023, and subsequent follow-up meetings. Detailed discussions were held on various topics between the audit team members and the licensee, aided by information needs identified by the NRC staff in the audit plan, as supplemented, along with the licensees presentations and prepared responses to audit questions.
In addition, the NRC requested by email dated July 27, 2023 (ML23208A105), that responses be provided to additional questions which were later discussed during a call held on August 23, 2023, followed by another meeting held on September 13, 2023. At the conclusion of the audit activities, the NRC requested that the licensees responses to selected questions from the audit be transmitted by letter, which was subsequently provided by the supplemental letter dated October 16, 2023. A follow up teleconference was held on November 7, 2023, to get further clarification regarding the information provided in the supplemental letter. The licensee agreed to document this discussion on the docket and to provide the proposed changes to the TS bases. The licensee provided this information in a supplement dated November 20, 2023.
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 audit plan dated March 28, 2023, 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. At the audit exit meeting held on April 12, 2023, and during subsequent meetings, the NRC staff reviewed the proposed responses to the audit questions with the licensee, which were later provided in supplements dated October 16, 2023, and November 20, 2023. After reviewing the supplemented information, the NRC staff did not identify the need for any additional RAI.
4.0 AUDIT PARTICIPANTS NRC Participants from NRR Mahesh Chawla Project Manager, DORL1/LPL42 Vijay Goel Electrical Engineer, DEX3/EEEB4 Marie Pohida Senior Reliability and Risk Analyst, DRA5/APLC6 Keith Tetter Reliability and Risk Analyst, DRA/APLC Andrew Mihalik Reliability and Risk Analyst, DRA/APOB7 Hanry Wagage Senior Safety and Plant Systems Engineer, DSS8/SCPB9 Gordon Curran Safety and Plant Systems Engineer, DSS/SCPB Summer Sun Senior Nuclear Engineer, DSS/SNSB10 Matthew Hamm Safety and Plant Systems Engineer, DSS/STSB11 Licensee Participants Thomas Elwood Supervisor, Licensing and Regulatory Affairs Jeremy Morton Operations Shift Manager - Work Management Jonathan Cordz Safety Analysis Engineer Thomas Forland Senior Licensing Engineer Justin Hiller Supervisor - Probabilistic Risk Assessment 1 Division of Operating Reactor Licensing (DORL) 2 Plant Licensing Branch IV (LPL4) 3 Division of Engineering and External Hazards (DEX) 4 Electrical Engineering Branch (EEEB) 5 Division of Risk Assessment (DRA) 6 Probabilistic Risk Assessment Licensing Branch C (APLC) 7 Probabilistic Risk Assessment Oversight Branch (APOB) 8 Division of Safety Systems (DSS) 9 Containment and Plant Systems Branch (SCPB) 10 Nuclear Systems Performance Branch (SNSB) 11 Technical Specifications Branch (STSB)
- by email OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DEX/EEEB/BC NAME MChawla PBlechman WMorton DATE 11/21/2023 11/21/2023 12/1/2023 OFFICE NRR/DRA/APLC/BC NRR/DSS/SCPB/BC NRR/DSS/SNSB/BC NAME SVasavada BWittick PSahd DATE 12/7/2023 11/22/2023 12/6/2023 OFFICE NRR/DSS/STSB/BC(A)
NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME SMehta JRankin MChawla DATE 11/22/2023 12/11/2023 1/12/2024