ML25069A599
| ML25069A599 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/10/2025 |
| From: | Mahesh Chawla Plant Licensing Branch IV |
| To: | Elwood T Union Electric Co |
| Chawla M | |
| References | |
| EPID L-2024-LLR-0084 | |
| Download: ML25069A599 (3) | |
Text
From:
Mahesh Chawla To:
Elwood, Thomas B Cc:
Tony Nakanishi; Matthew Mitchell; John Honcharik; Ami Agrawal; Michael Bloodgood; Scott Schwind; Nathan Brown; Doug Broaddus
Subject:
Callaway Plant, Unit 1 - Acceptance of Requested Licensing Action - 10 CFR 50.55a(z)(1) Relief Request from ISI Requirements EPID: L-2024-LLR-0084 Date:
Monday, March 10, 2025 8:52:00 AM Importance:
High
Dear Mr. Elwood:
By letter dated December 19, 2024 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML24354A196), Union Electric Company, doing business as Ameren Missouri (the licensee), submitted proposed alternatives to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, regarding (1) the pneumatic leakage test requirement in subsection IWE-5221(a) (Proposed Alternative IWE-01) and (2) the pre-weld surface examination requirement of subsection IWA-4422.2.2(a) (Proposed Alternative IWE-02) for Callaway Plant, Unit No. 1 (Callaway). IWE-5221(a) requires the performance of a pneumatic leakage test per IWE-5223 or, alternatively, a bubble test-vacuum box technique per IWE-5224, following a weld repair activity prior to returning the component to service. IWA-4422.2.2(a), requires the performance of a surface examination of the defect removal area prior to welding. During the Callaway 2023 fall refueling outage, the licensee performed a weld repair of the metal containment liner without performing the ASME Code requirements in the subsection specified above (non-compliance ASME weld repair). The licensee proposed alternative is for the NRC retroactive authorization of the non-compliance ASME weld repairs during the Callaway 2023 fall refueling outage. The licensee requests that the proposed alternatives to remain in effect until (1) the end of the Callaway 2025 spring refueling outage (Proposed Alternative IWE-01) and (2) the end of plant life (Proposed Alternative IWE-02), respectively.
The NRC staff reviewed your application and concluded that the supplemental information was necessary to enable the NRC staff to make an independent assessment regarding the acceptability of the proposed alternative in terms of regulatory requirements for the protection of public health and safety and the environment. The request for supplemental information was transmitted to you via an email on January 21, 2025 (ML25022A012). The NRC staff recommended holding a public meeting to discuss potential modified information necessary for proposed alternatives that would be submitted in response to this request for supplemental information.
On January 24, 2025, an Observation public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Union Electric Company, doing business as Ameren Missouri (the licensee) via teleconference. The purpose of the meeting was to discuss supplemental information needed for the proposed alternatives to certain American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, requirements for Callaway Plant, Unit No. 1, as documented in the supplemental information request dated January 21, 2025. During the meeting, the NRC staff discussed why the proposed alternatives could not be reviewed as proposed and the type of information that could be provided in response to the request. The NRC staff also discussed the timelines for the submittal of the supplement and the completion of the review. Subsequently, on February 4, 2025, a second Observation public meeting was held
to further discuss the details on how to address the NRC staffs concerns.
To support the second teleconference, the licensee made available two preliminary supplements (ML25034A253 and ML25034A255) to revise the original proposed alternative. During the teleconference the NRC staff discussed the details in the preliminary supplements for the revised proposed alternative and identified information that the licensee should include in the supplements to be submitted on the docket. Per the discussion during the teleconference, the licensee submitted the revised supplements on February 24, 2025 (ADAMS Package No. ML25055A151) and requested verbal approval of proposed alternatives IWE-01 and IWE-02 to restore compliance with 10 CFR 50.55a and ASME BPVC requirements as soon as possible. The licensee resubmitted Relief Request IWE-02 with a correction in a supplement dated March 3, 2025 (ADAMS Package No.
The NRC staff has reviewed your application, as supplemented, and concluded on March 3, 2025, that it does provide technical information in sufficient detail to enable the NRC staff to perform its detailed technical review and make an independent assessment regarding the acceptability of the proposed alternative in terms of regulatory requirements and the protection of public health and safety and the environment. During a teleconference on March 3, 2025, the NRC staff granted a verbal authorization to Callaway Plant, Unit 1. The verbal authorization was formally transmitted in an email dated March 4, 2025 (ML25063A143). The meeting summary for the meetings on January 24, 2025, and February 4, 2025, was issued on March 6, 2025 (ADAMS Package No. ML25062A266)
Based on the information provided in your submittal and discussions during the subsequent teleconferences, the NRC staff has estimated that this licensing request will take approximately 265 hours0.00307 days <br />0.0736 hours <br />4.381614e-4 weeks <br />1.008325e-4 months <br /> to complete. The NRC staff expects to issue its final safety evaluation in approximately 5 months, which is August 4, 2025. If there are 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 requests for additional information, and unanticipated addition of scope to the review. 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.
Sincerely, Mahesh(Mac) 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 OFFICE NRR/DORL/LPL4/PM NRR/DNRL/NPHP/BC NRR/DORL/LPL4/BC NAME MChawla MMitchell TNakanishi DATE 3/7/2025 3/7/2025 3/7/2025