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): Difference between revisions

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.t Callaway Plant 8315 County Road 459 : Steedman, MO 65077 : AmerenMissouri.com
D ecember 21, 2023
.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:
 
UL NRC -06847
 
U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
 
10 C FR 50.55a
 
L adies and Gentlemen:
 
DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.
DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.
RENEWED FACILITY OPERATING LICENSE NPF-30 SUPPLEMENT TO RELIEF REQUEST FROM REQUIREMENTS OF A SME BPV CODE,
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)  
SECTION XI, SUBSECTION IWL REGARDING EXAMINATION AND TESTING OF THE UNBONDED POST-TENSIONING SYSTEM (RELIEF REQUEST C3R -01)


==References:==
==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)
: 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)
: 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.


On October 26, 2023, Ameren Missouri submitted a letter ( Reference 1) request ing 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.
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 (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.
.t 8315 County Road 459 : Steedman, MO 65077: AmerenMissouri.com.t
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.
.t 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 dur ations 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, A meren Missouri confirm s 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 surveill ance in the current third inspection interval is the 40th year surveillance.
 
To f urther clarify, section 2.1 of Enclosure 2 describes program changes proposed by Ameren Missouri's contractor/consultant, i.e., BCP Engineers and Consultants. The ir recommendations were intended for Ameren Missouri's consideration based on the evaluations addressed in section 3 and 4 of their technical report. The scop e of those recommendations is beyond the scope of the Reference1 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.
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 s tates, "It is the NRC staff's understanding that the relief request only seeks NRC's approval through the 40th year."
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).
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 alternative s 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.
 
Lastly, as requested in Reference 2, Amer en 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.
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


Sincerely,
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  
Brent L. Jungmann Sen ior Director, Nuclear Engineering
 
ULNRC-06847 December 21, 2023 Page 3 o f 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.)


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:
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)
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. Kathleen McNelis (Public Service Commission)
Ms. Claire Eubanks (Public Service Commission)
Ms. Claire Eubanks (Public Service Commission)}}
 
.}}

Latest revision as of 07:20, 25 November 2024

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 Ameren icon.png
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)
v • d • e


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

.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.

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 (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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