ML21039A222

Audit Plan and Setup of Online Reference Portal for License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors

ML21039A222
Person / Time
Site:	Callaway
Issue date:	02/18/2021
From:	Mahesh Chawla Plant Licensing Branch IV
To:	Diya F Ameren Missouri, Union Electric Co
Chawla M
References
EPID L-2020-LLA-0235
Download: ML21039A222 (7)

Text

February 18, 2021 Mr. Fadi Diya Senior Vice President and Chief Nuclear Officer Ameren Missouri Callaway Energy Center 8315 County Road 459 Steedman, MO 65077

SUBJECT:

CALLAWAY PLANT, UNIT NO. 1 - AUDIT PLAN AND SETUP OF ONLINE REFERENCE PORTAL FOR LICENSE AMENDMENT REQUEST TO ADOPT 10 CFR 50.69, RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS AND COMPONENTS FOR NUCLEAR POWER REACTORS (EPID L-2020-LLA-0235)

Dear Mr. Diya:

By application dated October 30, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20304A454), Union Electric Company, dba Ameren Missouri (the licensee), submitted a license amendment request for Callaway Plant, Unit No. 1 (Callaway). The proposed amendment would modify the Callaway licensing basis by the addition of a license condition (i.e., License Condition 2.(C).(19)), to allow for the implementation of the provisions of Title 10 of the Code of Federal Regulations (10 CFR),

Section 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors.

To improve the efficiency of the U.S. Nuclear Regulatory Commission (NRC) reviews, the licensees representatives and the NRC staff have discussed the use of an audit using an online reference portal that would allow the NRC staff and contractors limited read-only access to the basis documents and other reference materials cited in the applications. The NRC staff plans to initially conduct a desk audit to review the documentation provided on the portal. The online reference portal would allow the NRC staff to audit basis documents to determine whether the information included in the documents is necessary to reach a safety conclusion on the application. Documents identified as necessary for analysis of the application will be identified by the NRC staff. The licensee will be formally requested to submit those documents on the NRC docket. Use of the online reference portal is acceptable, as long as the following conditions are met:

The online reference portal will be password-protected and passwords will be assigned to those directly involved in the review on a need-to-know basis; The online reference portal will be sufficiently secure to prevent staff from printing, saving, or downloading any documents; and

F. Diya Conditions of use of the online reference portal will be displayed on the login screen and will require concurrence by each user.

The NRC staff would like to request that the portal be populated with the documents listed in the enclosure to this letter. This is the initial list identified by the NRC staff. If the licensee intends to submit a license amendment request for Technical Specifications Task Force (TSTF)

Traveler TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF

[Risk-Informed TSTF] Initiative 4b, the NRC staff prefers that additional supporting documents be included in the portal. The NRC staff may request additional documents during the review, which will be transmitted to you via email. This will help with the preparation for a virtual audit.

Please provide NRC staff access to the portal and send me the information needed to access the portal, such as username and password, as soon as possible. The conditions associated with the online reference portal must be maintained throughout the duration of the review process. Please provide written confirmation that Ameren Missouri agrees to the terms and conditions set forth in this letter.

If you have any questions, please contact me at (301) 415-8371 or by e-mail at Mahesh.Chawla@nrc.gov.

Sincerely,

/RA/

Mahesh L. Chawla, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483

Enclosure:

Audit Plan cc: Listserv

ML21039A222 via e-mail OFFICE NRR/DORL/LPL4/PM* NRR/DORL/LPL4/LA* NRR/DEX/EXHB* NRR/DRA/APLA/BC*

NAME MChawla PBlechman BHayes RPascarelli DATE 2/11/2021 2/11/2021 2/17/2021 2/12/2021 OFFICE NRR/DEX/EMIB* NRR/DRA/APLC/BC* NRR/DORL/LPL4/BC* NRR/DORL/LPL4/PM*

NAME ABuford SRosenberg JDixon-Herrity MChawla DATE 2/17/2021 2/16/2021 2/18/2021 2/18/2021 REMOTE AUDIT PLAN REGARDING RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS AND COMPONENTS UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT NO. 1 DOCKET NO. 50-483

1.0 BACKGROUND

By letter dated October 30, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20304A454), Union Electric Company, dba Ameren Missouri (the licensee) requested that the U.S. Nuclear Regulatory Commission (NRC) modify the licensing basis for Callaway Plant, Unit No. 1 (Callaway). The proposed license amendment would modify the Callaway licensing basis to allow for the implementation of the provisions of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors. The proposed changes are based on Nuclear Energy Institute (NEI) 00-04, 10 CFR 50.69 SSC [Structure, System, and Component] Categorization Guideline, Revision 0, dated July 2005 (ADAMS Accession No. ML052910035), which is endorsed by the NRC in Regulatory Guide 1.201, Guidelines for Categorizing Structures, Systems, and Components in Nuclear Power Plants According to their Safety Significance, Revision 1, dated May 2006 (ADAMS Accession No. ML061090627).

2.0 REGULATORY AUDIT BASES A regulatory audit is a planned license or regulation-related activity that includes the examination and evaluation of primarily non-docketed information. The audit is conducted with docketing to support the basis of a licensing or regulatory decision. Performing a regulatory audit is expected to assist the NRC staff in efficiently conducting its review of the license amendment request (LAR) and to gain insights of the licensees processes and procedures.

Information that the NRC staff relies upon to make the safety determination must be submitted on the docket.

The basis of this remote audit is the licensees LAR for Callaway, and NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition, Section 19.2, Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance, dated June 2007 (ADAMS Accession No. ML071700658).

The remote audit will be performed consistent with NRC Office of Nuclear Reactor Regulation Office Instruction LIC-111, Regulatory Audits, Revision 1, dated October 31, 2019 (ADAMS Accession No. ML19226A274). An audit was determined to be the most efficient approach toward a timely resolution of issues associated with this LAR review, since the NRC staff will have an opportunity to minimize the potential for multiple rounds of requests for additional Enclosure 1

information (RAIs) and ensure no unnecessary burden will be imposed by requiring the licensee to address issues that are no longer necessary to make a safety determination.

3.0 PURPOSE AND SCOPE The purpose of the remote audit is to gain a more detailed understanding of the licensees process to implement risk-informed categorization and treatment of SSCs as proposed in the LAR. The NRC staff will review internal events (excluding internal flooding) probabilistic risk assessment (PRA), internal flooding PRA, high winds PRA, seismic PRA, and fire PRA and the risk-informed approach implementing 10 CFR 50.69.

The areas of focus for the regulatory audit are the information contained in the licensees submittal, the enclosed audit information needs, and all associated and relevant supporting documentations (e.g., methodology, process information, calculations, etc.). The relevant supporting documents are identified below.

4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY REMOTE AUDIT The following documentation should be available to the audit team:

Callaway Energy Center Report PRA-OEH-ANALYSIS, Other External Hazards:

Screening Assessment Notebook, Update 8 Pressurized-Water Reactor Owners Group (PWROG)-19012-P, Peer Review of the Callaway Internal Events and Internal Flood Probabilistic Risk Assessment, dated April 2019 PWROG-19022-P, Peer Review of the Callaway External Hazard Screening Assessment and High Winds Probabilistic Risk Assessment, dated April 2019 PWROG-19034-P, Independent Assessment of Facts & Observations Closure and Focused Scope Peer Review of the Callaway Probabilistic Risk Assessments, dated November 2019 PWROG-18044-P, Peer Review of the Callaway Seismic Probabilistic Risk Assessment, dated June 2018 PWROG-19011-P, Independent Assessment of Facts & Observations Closure and Focused Scope Peer Review of the Callaway Seismic Probabilistic Risk Assessment, dated March 2019 LTR-RAM-II-10-019, Fire PRA Peer Review Against the Fire PRA Standard Supporting Requirements from Section 4 of the American Society of Mechanical Engineers (ASME)/American Nuclear Society (ANS) Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessments for Nuclear Power Plant Applications for The Callaway Nuclear Plant Fire Probabilistic Risk Assessment, dated October 2009 AMN#PES00021-REPT-001, Callaway Energy Center Fire Probabilistic Risk Assessment Peer Review F&Os [Facts and Observations] Closure, dated June 2019

AMN#PES00031-REPT-001, Callaway Energy Center Probabilistic Risk Assessment Focused Scope Peer Review, dated July 2020 AMN#PES00031-REPT-002, Callaway Energy Center Probabilistic Risk Assessment Peer Review F&Os Closure, dated July 2020 PWROG-19020-NP Revision 1, Newly Developed Method Peer Review Pilot-General Screening Criteria for Loss of Room Cooling in PRA Modeling, dated April 2020 PWROG-18027-NP Revision 0, Loss of Room Cooling in PRA Modeling, dated April 2020.

PRA-IE-UNCERT, Probabilistic Risk Assessment (PRA), Uncertainty Analysis Notebook, Revision 000 PRA-IE-UNCERT Appendix 6, Disposition of Key Uncertainties: Risk-Informed Engineering Programs (10CFR50.69), Revision 000.

PRA notebooks associated with the seismic and high winds PRA models, including model assumptions, hazards, fragilities, plant responses, quantifications, uncertainty analysis, and etc.

Any draft or final risk-informed completion time program procedures (i.e., risk management action procedure, PRA functionality determination procedure, recording limiting condition for operation procedures, etc.).

5.0 AUDIT TEAM The members of the audit team are anticipated to be:

Mahesh Chawla, Project Manager, NRC (Mahesh.Chawla@nrc.gov)

Joshua Havertape, APLA,1 NRC (Joshua.Havertape@nrc.gov)

Jeff Circle, APLA, NRC (Jeff.Circle@nrc.gov)

De Wesley Wu, APLC,2 NRC (De.Wu@nrc.gov)

Keith Tetter, APLC, NRC (Keith.Tetter@nrc.gov)

Kaihwa (Robert) Hsu, EMIB,3 NRC (Kaihwa.Hsu@nrc.gov)

Kevin Quinlan, EXHB,4 NRC (Kevin.Quinlan@nrc.gov)

David Heeszel, EXHB, NRC (David.Heeszel@nrc.gov)

Garill Coles, Contractor, PNNL5 (garill.coles@pnnl.gov) 1 Probabilistic Risk Assessment Licensing Branch A 2

Probabilistic Risk Assessment Licensing Branch C 3

Mechanical Engineering and inservice testing Branch 4

External Hazards Branch 5

Pacific Northwest National Laboratory

6.0 LOGISTICS Once the electronic portal is set up and the documentation is made available to the NRC staff, a virtual audit will be scheduled and conducted remotely. The virtual audit will be conducted via Microsoft Teams, or a compatible platform to be agreed upon. Prior to the audit, the NRC staff and contractors will review the portal information and develop audit questions. An entrance briefing will be held at the beginning of the audit, and an exit briefing will be held at the end of the audit. The NRC project manager will coordinate with the licensee the audit date and any identified changes to the schedule and logistics.

7.0 SPECIAL REQUESTS The NRC staff would like access to the documents listed above in Section IV through an online portal that allows the NRC staff and contractors to access documents remotely by February 22, 2021. The NRC staff and contractors access to the online portal should be terminated by September 30, 2021.

The following conditions associated with the online portal must be maintained throughout the duration that the NRC staff and contractors have access to the online portal:

The online portal will be password-protected, and separate passwords will be assigned to the NRC staff and contractors who are participating in the audit.

The online portal will be sufficiently secure to prevent the NRC staff and contractors from printing, saving, downloading, or collecting any information on the online portal.

Conditions of use of the online portal will be displayed on the login screen and will require acknowledgment by each user.

User name and password information should be provided directly to the NRC staff and contractors. The NRC project manager will provide Ameren Missouri the names and contact information of the NRC staff and contractors who will be participating in the audit. All other communications should be coordinated with the NRC project manager.

8.0 DELIVERABLES An audit summary, which may be public, will be prepared within 90 days of the completion of the site audit. If the NRC staff identifies information during the remote audit that is needed to support its regulatory decision, the staff will issue RAIs to the licensee after the completion of the site audit.