ULNRC-06920, Supplemental Information for Requests for Relief from Inservice Inspection Requirements of ASME Boiler Pressure Vessel Code, Section XI for the Instrument Tunnel Sump Liner
| ML25055A152 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 02/24/2025 |
| From: | Elwood T Ameren Missouri, Union Electric Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML25055A151 | List: |
| References | |
| ULNRC-06920 | |
| Download: ML25055A152 (1) | |
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.t Callaway Plant 8315 County Road 459 : Steedman, MO 65077 : AmerenMissouri.com
.t February 24, 2025 ULNRC-06920 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 SUPPLEMENTAL INFORMATION FOR REQUESTS FOR RELIEF FROM INSERVICE INSPECTION REQUIREMENTS OF ASME BOILER PRESSURE VESSEL CODE, SECTION XI FOR THE INSTRUMENT TUNNEL SUMP LINER
References:
Provided on Page 3.
By letter dated December 19, 2024, (Reference 1), Union Electric Company (Ameren Missouri) submitted to the Nuclear Regulatory Commission (NRC) for approval, relief request IWE-01 (Reference 2) and relief request IWE-02 (Reference 3) for the Callaway Plant. The proposed alternatives were submitted to restore compliance with American Society Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPVC),Section XI requirements associated with weld repair activities previously on the Instrument Tunnel Sump liner, as explained in more detail in the Reference 1 letter. The relief requests are currently undergoing NRC review.
Specifically, relief request IWE-01 proposes postponing performance of the ASME BPVC,Section XI, IWE-5221(a) pneumatic leakage test that was not performed in the Fall of 2023 on the Instrument Tunnel Sump liner and to perform the test during Callaway's next refueling outage (Refuel 27), which is scheduled to begin on March 29, 2025. Relief request IWE-02 proposes performing ultrasonic testing, also during Refuel 27, for all locations where welds were completed in the Fall of 2023 on the Instrument Tunnel Sump liner. This proposed alternative would be done in lieu of the pre-weld surface examination requirements of ASME BPVC,Section XI, IWA-4422.2.2(a). For each of the relief requests, the basis for the proposed alternative is that complying with the noted Code requirement would result in hardship or unusual difficulty without a compensating level of quality or safety.
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WAmeren MISSOURI
ULNRC-06920 February 24, 2025 Page 2 of 5 On January 24, 2025, the NRC held a meeting with Ameren Missouri to discuss supplemental information necessary for the proposed alternatives (Reference 4). Ameren Missouri provided the requested supplemental information via References 5 and 6, and on February 4, 2025, a follow-up meeting was held to further discuss the supplemental information provided by Ameren Missouri (Reference 7). The relief requests have now been revised to incorporate the finalized supplemental information. The purpose of this letter, therefore, is to provide the revised relief requests as Enclosures 1 and 2 of this letter. The enclosures supersede the versions provided per References 2 and 3.
As noted in the previous correspondence (References 1, 2 and 3), Callaway's third 10-year Containment Pressure Boundary Inservice Inspection (ISi) Program, which began December 1, 2017 and ends on November 20, 2026, complies with the 2007 Edition through the 2008 Addenda of the ASME BPVC,Section XI.
Supporting information, including the justification for each request, is provided in the enclosed relief requests. Ameren Missouri respectfully requests review and verbal approval of request IWE-01 and IWE-02 as soon as possible, as the intent is to restore compliance with 10 CFR 50.55a and ASME BPVC requirements as soon as practical.
Please contact Thomas B. Elwood at (314) 225-1905 if there are any questions about this submittal.
This letter does not contain new commitments.
ESS, 10 CFR 50.55a Relief Request IWE-01, 10 CFR 50.55a Relief Request IWE-02 Sincerely, Thomas B. Elwood Manager, Regulatory Affairs
ULNRC-06920 February 24, 2025 Page 3 of 5
References:
- 1. Ameren Missouri letter ULNRC-06890, "Callaway Plant, Unit 1 - 10 CFR 50.55a(z)(1) Requests for Relief from Inservice Inspection Requirements of ASME Boiler Pressure Vessel Code,Section XI," dated December 19, 2024 (ADAMS Accession No. ML24354A197)
- 2. Enclosure 1 of Ameren Missouri letter ULNRC-06890, "Callaway Plant, Unit 1 - 10 CFR 50.55a(z)(1) Requests for Relief from Inservice Inspection Requirements of ASME Boiler Pressure Vessel Code,Section XI," dated December 19, 2024 (ADAMS Accession No. ML24354A198)
- 3. Enclosure 2 of Ameren Missouri letter ULNRC-06890, "Callaway Plant, Unit 1 - 10 CFR 50.55a(z)(1) Requests for Relief from Inservice Inspection Requirements of ASME Boiler Pressure Vessel Code,Section XI," dated December 19, 2024 (ADAMS Accession No. ML24354A199)
- 4. NRC meeting notice, "Teleconference with Union Electric Company to Discuss Supplemental Information Needed for the Proposed Alternatives to Certain ASME Code,Section XI, Requirements for Callaway Plant, Unit No. 1 (EPID L-2024-LLR-0084)," dated January 23, 2025 (ADAMS Accession No. ML25023A157)
- 5. "Callaway Plant, Unit 1 - Supplemental Information Enclosure 1 - IWE-01 (EDIP L-2024-LLR-0084)," dated February 3, 2025 (ADAMS Accession No. ML25034A253)
- 6. "Callaway Plant, Unit 1 - Supplemental Information Enclosure 2 - IWE-02 (EDIP L-2024-LLR-0084)," dated February 3, 2025 (ADAMS Accession No. ML25034A255)
- 7. NRC meeting notice, "Teleconference with Union Electric Company to Discuss Supplemental Information Needed for the Proposed Alternatives to Certain ASME Code,Section XI, Requirements for Callaway Plant, Unit No. 1 (EPID L-2024-LLR-0084)," dated January 30, 2025 (ADAMS Accession No. ML25030A254)
ULNRC-06920 February 24, 2025 Page 4 of 5 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-06920 February 24, 2025 Page 5 of 5 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 Responses and Reports ULNRC Distribution:
F. M. Diya K. C. Scott T. M. Hart J. G. Beck T. A. Witt T. B. Elwood NSRB Secretary STARS Regulatory Affairs Mr. Jay Silberg (Pillsbury Winthrop Shaw Pittman LLP)