ULNRC-06660, Cycle 24 Commitment Change Summary Report

Cycle 24 Commitment Change Summary Report

ML21173A230
Person / Time
Site:	Callaway
Issue date:	06/22/2021
From:	Bianco F Ameren Missouri, Union Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ULNRC-06660
Download: ML21173A230 (4)

Text

AI11er8fl Callaway Plant MISSOURI June 22, 2021 ULNRC-06660 U.S Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-000 1 10 CFR 50.71(e)(4)

Ladies and Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

RENEWED FACILITY OPERATING LICENSE NPF-30 CYCLE 24 COMMITMENT CHANGE

SUMMARY

REPORT Please find attached the Cycle 24 Commitment Change Summary Report required by NET 99-04, Guideline for Managing NRC Commitment Changes, for changes requiring NRC notification annually or at a frequency consistent with that required for FSAR updates per 10 CFR 50.7 1(e)(4).

These commitment revisions were completed at Callaway Plant during the period from May 19, 2019 to December 22, 2020, and were not reported to NRC in a previous submittal. The Cycle 24 Commitment Change Summary Report provides a description of each change completed, along with a briefjustification for each revised commitment.

For any questions concerning this report, please contact Mr. Tom Elwood, Supervising Engineer, Regulatory Affairs and Licensing at 314-225-1905.

This letter does not contain new commitments.

Bianco Senior Director, Nuclear Operations DRB/mlp Enclosure 83 15 County Road 459 : Steedman, MO 65077  : AmerenMissouri.com

ULNRC-06660 June 22, 2021 Page 2 of 3 cc: Mr. Scott A. Morris Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Senior Resident Inspector Callaway Resident Office U. S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. M. Chawla Project Manager, Callaway Plant Office ofNuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0831A Washington, DC 20555-000 1

ULNRC-06660 June 22, 2021 Page 3 of 3 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 6500 West Freeway, Suite 400 FortWorth,TX 76116 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)

Electronic distribution for the following can be made via Responses and Reports ULNRC Distribution:

F. M. Diya B. L. Cox F. J. Bianco S. P. Banker S. J. Meyer T. B. Elwood NSRB Secretary STARS Regulatory Affairs Mr. Jay Silberg (Pillsbury Winthrop Shaw Pittman LLP)

Enclosure to ULNRC-06660 Page 1 of 1 CYCLE 24 COMMITMENT CHANGE

SUMMARY

REPORT In accordance with NEI 99-04, Guidelines for Managing NRC Commitment Changes, as endorsed in Regulatory Issue Summary 2000-17, Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff, the following commitment change is being reported. This change was completed for Callaway Plant during the period from May 19, 2019 to December 22, 2020. A description ofthis completed change, along with a briefjustification for the revised commitment, is provided as follows:

Commitment 50 1 3 8 (Ref. ULNRC-03 548, dated 3/13/1997, Westinghouse Owner s Group document V-EC- 1 776, Revision 2, Risk Ranking Approach for Motor-Operated Valves in Response to Generic Letter 96-05)

All safety-related motor-operated valves required to be diagnostically tested in accordance with Generic Letter 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves, have historically been tested at an interval of 4 cycles (6 years). This commitment change revises MOV diagnostic test frequencies based on the individual MOVs risk significance and margin to performance limits (e.g., thrust, torque capabilities). 1ST program and Technical Specification required testing of in-scope MOVs is not impacted by this change. The risk ranking process looked in depth at the risk significance of program MOVs. Those MOVs that were placed in the High Risk category will continue to be tested on a periodicity not to exceed the current six-year frequency. The test interval for specific High Risk MOVs may be shorter than six years based on margin.

Justification Margin classification thresholds have been selected such that they are conservative compared to those typically used in the US nuclear industry in order to ensure that adequate margin exists to accommodate age-related valve/actuator degradation between Periodic Verification Tests, thus to protect Callaways overall margin of safety. Risk ranking has been performed using the approach established in Westinghouse Owner s Group document V-EC-1 776, Revision 2, Risk Ranking Approach for Motor-Operated Valves in Response to Generic Letter 96-05.

This approach is a typical practice in the US nuclear fleet.