ULNRC-06930, Correction to Relief Request Iwe-02 Regarding Inservice Inspection Requirements of ASME Boiler Pressure Vessel Code, Section XI for Instrument Tunnel Sump Liner
| ML25062A126 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/03/2025 |
| From: | Elwood T Ameren Missouri, Union Electric Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML25062A125 | List: |
| References | |
| ULNRC-06930 | |
| Download: ML25062A126 (1) | |
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.t Callaway Plant 8315 County Road 459 : Steedman, MO 65077 : AmerenMissouri.com
.t March 3, 2025 ULNRC-06930 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 CORRECTION TO RELIEF REQUEST IWE-02 REGARDING INSERVICE INSPECTION REQUIREMENTS OF ASME BOILER PRESSURE VESSEL CODE, SECTION XI FOR 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. Subsequently, by letter dated February 24, 2025 (Reference 4), Ameren Missouri provided revisions of relief requests IWE-01 and IWE-02 (References 5 and 6), which included supplemental information identified from NRC meetings held on January 24, 2025, and February 4, 2025 (References 7 and 8). However, following submittal of the revised relief requests, an error was identified in relief request IWE-02 (Reference 6).
The error has now been corrected, and the purpose of this letter is to provide the corrected relief request IWE-02 via the enclosure to this letter.
Relief request IWE-02 proposes performing ultrasonic testing (UT) for all locations where welds were completed in the Fall of 2023 on the Instrument Tunnel Sump liner (as described in the Reference 4 letter). 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). Specifically, relief request IWE-02 states that straight beam UT will be performed; however, angle beam UT should have been indicated instead.
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WAmeren MISSOURI
ULNRC-06930 February 24, 2025 Page 2 of 5 Corrected relief request IWE-02 is provided in the enclosure to this letter. Ameren Missouri respectfully requests review and verbal approval of request 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 for any questions about this submittal.
This letter does not contain new commitments.
Sincerely, Thomas B. Elwood Manager, Regulatory Affairs ESS
Enclosure:
10 CFR 50.55a Relief Request IWE-02
ULNRC-06930 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, "Enclosure 1 - Proposed Alternative in accordance with 10 CFR 50.55(a)(z)(1) Alternative Provides Acceptable Level of Quality and Safety," dated December 19, 2024 (ADAMS Accession No. ML24354A198)
- 3. Enclosure 2 of Ameren Missouri letter ULNRC-06890, " Enclosure 2 - Proposed Alternative in accordance with 10 CFR 50.55(a)(z)(1) Alternative Provides Acceptable Level of Quality and Safety," dated December 19, 2024 (ADAMS Accession No. ML24354A199)
- 4. Ameren Missouri letter ULNRC-06920, "Callaway Plant, Unit 1 - Supplemental Information for Requests for Relief from Inservice Inspection Requirements of ASME Boiler Pressure Vessel Code,Section XI," dated February 24, 2025 (ADAMS Accession No. ML25055A152)
- 5. Enclosure 1 of Ameren Missouri letter ULNRC-06920, " Enclosure 1 - Proposed Alternative in accordance with 10 CFR 50.55(a)(z)(2) - Complying with Requirement Would Result in Hardship or Unusual Difficulty Without a Compensating Increase in the Level of Quality and Safety," dated February 24, 2025 (ADAMS Accession No. ML25055A153)
- 6. Enclosure 2 of Ameren Missouri letter ULNRC-06920, " Enclosure 2 - Proposed Alternative in accordance with 10 CFR 50.55(a)(z)(2) - Complying with Requirement Would Result in Hardship or Unusual Difficulty Without a Compensating Increase in the Level of Quality and Safety," dated February 24, 2025 (ADAMS Accession No. ML25055A154)
- 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 23, 2025 (ADAMS Accession No. ML25023A157)
- 8. 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-06930 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-06930 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)