ULNRC-06847, Supplement to Relief Request from Requirements of ASME BPV Code, Section XI, Subsection Iwl Regarding Examination and Testing of the Unbonded Post-Tensioning System (Relief Request C3R-01)

Supplement to Relief Request from Requirements of ASME BPV Code,Section XI, Subsection Iwl Regarding Examination and Testing of the Unbonded Post-Tensioning System (Relief Request C3R-01)

ML23355A180
Person / Time
Site:	Callaway
Issue date:	12/21/2023
From:	Jungmann B Ameren Missouri, Union Electric Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
ULNRC-06847
Download: ML23355A180 (1)

Text

Callaway Plant

.t December 21, 2023 ULNRC-06847 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 50.55a Ladies and Gentlemen:

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

RENEWED FACILITY OPERATING LICENSE NPF-30 SUPPLEMENT TO RELIEF REQUEST FROM REQUIREMENTS OF ASME BPV CODE, SECTION XI, SUBSECTION IWL REGARDING EXAMINATION AND TESTING OF THE UNBONDED POST-TENSIONING SYSTEM (RELIEF REQUEST C3R-01)

References:

1) Ameren Missouri letter ULNRC-06831, "Request for Relief from Requirements of ASME BPV Code, Section XL, Subsection IWL Regarding Examination and Testing of the Unbonded Post-Tensioning System (Relief Request C3R-01)," dated October 26, 2023 (ADAMS Accession No. ML23299A195)

2) NRC letter to Mr. Fadi Diya, "Callaway Plant, Unit No. 1 - Supplemental Information Needed for Acceptance of Requested Licensing Action Re: Request for Relief from Requirements of ASME Code,Section XI, Examination and Testing Unbonded Post-Tensioning System (EPID L-2023-LLR-0061)," dated December 14, 2023 (ADAMS Accession No. ML23346A039)

On October 26, 2023, Ameren Missouri submitted a letter (Reference 1) requesting relief from requirements of American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code,Section XI, Subsection IWL regarding examination and testing of the unbonded post-tensioning system (Relief Request C3R-01) for Callaway Plant. Subsequently, the NRC staff reviewed Ameren Missouri's relief request to assess the acceptability of the proposed alternative. From this review, the NRC requested (via Reference 2) that Ameren Missouri provide supplemental information to address their concerns with the request. Accordingly, the purpose of this letter is to provide the supplemental information requested in Reference 2 to address NRC staff concerns, as provided below.

.t 8315 County Road 459 : Steedman, MO 65077 : AmerenMissouri.com

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ULNRC-06847 December 21, 2023 Page 2 of 4 Supplemental Information

• Reference 2 states, "The U.S. Nuclear Regulatory Commission (NRC) staff noticed in section 2.1, "Proposed Program Changes," of Enclosure 2 [of the Reference 1 request] that the licensee requested durations of the proposed alternative [be extended] for multiple containment in-service inspection (CISI) intervals with future examinations to be performed in accordance with the following schedule: 2028 (45th), 2038 (55th), 2048 (65th), 2058 (75th)."

For clarification, Ameren Missouri confirms that the Reference 1 request is not requesting NRC approval of an alternative for multiple inspection intervals. In particular, Ameren Missouri proposes an alternative exclusively for the current third inspection interval of Callaway's Containment Exterior Concrete and Tendon Inspection (IWL) Program, as stated in section 6 of Enclosure 1 (Duration of Proposed Alternative for Relief Request C3R-01). The only remaining IWL surveillance in the current third inspection interval is the 40th year surveillance.

To further clarify, section 2.1 of Enclosure 2 describes program changes proposed by Ameren Missouri's contractor/consultant, i.e., BCP Engineers and Consultants. Their recommendations were intended for Ameren Missouri's consideration based on the evaluations addressed in section 3 and 4 of their technical report. The scope of those recommendations is beyond the scope of the Reference 1 request, as the relief request is focused only on the request described in Enclosure 1.

The BCP technical report (Enclosure 2) is solely referenced under the justification portion of Relief Request C3R-01 (section 5 of Enclosure 1) since it contains the necessary detailed evaluations of previous IWL visual examination findings / test results to support the relief request application.

• Reference 2 also states, "It is the NRC staff's understanding that the relief request only seeks NRC's approval through the 40th year."

Ameren Missouri confirms that the relief request application in Reference 1 only seeks NRC approval through the 40th year surveillance. In particular, Ameren Missouri only specifies examination alternatives for the 40th year surveillance as described in Enclosure 1 (Relief Request C3R-01).

Lastly, as requested in Reference 2, Ameren Missouri respectfully asks to move the original requested approval date of April 15, 2024 to a new requested approval date of August 15, 2024 for Relief Request C3R-01.

This letter does not contain new commitments. If there are any questions, please contact Tom Elwood at 314-225-1905.

Sincerely, Brent L. Jungmann Senior Director, Nuclear Engineering

ULNRC-06847 December 21, 2023 Page 3 of 4 cc: Mr. John Monninger 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 of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O8B1A Washington, DC 20555-0001

ULNRC-06847 December 21, 2023 Page 4 of 4 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 6500 West Freeway, Suite 400 Fort Worth, 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 Other Situations ULNRC Distribution:

F. M. Diya K. C. Scott W. A. Witt J. G. Beck B. L. Jungmann T. A. Witt T. B. Elwood NSRB Secretary STARS Regulatory Affairs Mr. Jay Silberg (Pillsbury Winthrop Shaw Pittman LLP)

Ms. Kathleen McNelis (Public Service Commission)

Ms. Claire Eubanks (Public Service Commission)

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