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MONTHYEARML23354A1062023-12-20020 December 2023 Ameren Missouri - Procedure Review Form for EIP-ZZ-COO1O Addendum G, Rev. 11, Backup EOF Checklist Project stage: Request ML23354A2442023-12-20020 December 2023 License Renewal Resolution for Commitments 34 and 35 – Perform Evaluation of Crack Initiation and Propagation in Steam Generator Divider Plate and Tube-To-Tubesheet Welds Project stage: Request ML24122A1502024-05-0707 May 2024 Audit Plan to Support Review of Steam Generator License Renewal Response to Commitment Nos 34 and 35 Project stage: Other ML24247A3042024-09-11011 September 2024 Regulatory Audit Questions for License Renewal Commitments 34 and 35 (EPID L-2024-LRO-0009) - Non-Proprietary Project stage: Other 2024-05-07
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Category:Audit Plan
MONTHYEARML24247A3042024-09-11011 September 2024 Regulatory Audit Questions for License Renewal Commitments 34 and 35 (EPID L-2024-LRO-0009) - Non-Proprietary ML24212A2822024-08-0202 August 2024 Regulatory Audit Summary Concerning Review of Request No. C3R-01 for Proposed Alternative to ASME Code, Section XI Requirements for Containment Building Inspections ML24122A1502024-05-0707 May 2024 Audit Plan to Support Review of Steam Generator License Renewal Response to Commitment Nos 34 and 35 ML24052A3662024-02-26026 February 2024 Regulatory Audit Plan in Support of Proposed Alternative to ASME Code, Section XI Requirements for Containment Building Inspections ML23065A3212023-03-28028 March 2023 Regulatory Audit Plan and Setup of Online Reference Portal for License Amendment Request to Clarify Support System Requirements for the Residual Heat Removal & Control Room Air Conditioning Systems ML23068A3772023-03-20020 March 2023 Regulatory Audit Plan and Setup of Online Reference Portal for License Amendment Request and Exemption for Fuel Transition to Framatome Gaia Fuel (EPID L-2022-LLA-0150 and EPID L-2022-LLE-0030) - Nonproprietary ML22061A0042022-03-0707 March 2022 Audit Questions for License Amendment Request to Revise Technical Specifications to Adopt TSTF-505 and TSTF-439, Revision 2 ML22048A0022022-02-18018 February 2022 Regulatory Audit Plan and Setup of Online Reference Portal for License Amendment Request to Revise Technical Specifications to Adopt TSTF-505, Revision 2 and TSTF-439, Revision 2 ML21197A0632021-07-23023 July 2021 Audit Plan and Setup of Online Reference Portal for License Amendment Request Risk-Informed Approach for Closure of Generic Safety Issue-191 ML21110A1232021-04-27027 April 2021 Audit Questions for License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors ML21039A2222021-02-18018 February 2021 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 ML18156A4042018-06-19019 June 2018 Regulatory Audit Plan for September 18-19, 2018, in Support of License Amendment Request to Incorporate New Technical Specification 3.7.20 ML17177A4462017-07-0606 July 2017 Audit Plan for Licensee Responses Concerning Seismic Hazard Reevaluations Related to Request for Information -(50.54(F) Letter) Regarding Recommendation 2.1 of the Near-Term Task Force ML16259A1892016-12-0505 December 2016 Nuclear Regulatory Commission Plan for the Audit of Mitigation Strategies Assessment Submittals Related to Order EA-12-049, Order to Modify Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events ML15309A3262015-11-0909 November 2015 Plan for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Instrumentation Related to Orders EA-12-049 and EA-12-051 ML14356A0032015-02-10010 February 2015 Audit of Licensee Responses to the Expedited Seismic Evaluation Process to Support Implementation of Near-Term Task Force Recommendation 2.1, Seismic ML14083A6202014-03-26026 March 2014 Nuclear Regulatory Commission Audits of Licensee Responses to Reliable Spent Fuel Pool Instrumentation Order EA-12-051 2024-09-11
[Table view] Category:Letter
MONTHYEARIR 05000483/20240032024-10-23023 October 2024 Integrated Inspection Report 05000483/2024003 IR 05000483/20240132024-10-21021 October 2024 Design Basis Assurance Inspection (Programs) Inspection Report 05000483/2024013 IR 05000483/20244012024-10-0909 October 2024 Material Control and Accounting Program Inspection Report 05000483/2024401 Public ULNRC-06901, Concurrent Inoperability of Control Room Air Conditioning System Train and Opposite Train Emergency Diesel Generator Results in Condition Prohibited by Technical Specifications Limiting (Letter)2024-10-0101 October 2024 Concurrent Inoperability of Control Room Air Conditioning System Train and Opposite Train Emergency Diesel Generator Results in Condition Prohibited by Technical Specifications Limiting (Letter) ML24247A3042024-09-11011 September 2024 Regulatory Audit Questions for License Renewal Commitments 34 and 35 (EPID L-2024-LRO-0009) - Non-Proprietary IR 05000483/20244032024-08-28028 August 2024 Security Baseline Inspection 05000483-2024-403 IR 05000483/20240052024-08-14014 August 2024 Updated Inspection Plan for Callaway Plant (Report 05000483/2024005) IR 05000483/20253012024-08-0505 August 2024 Notification of NRC Initial Operator Licensing Examination 05000483/2025301 ML24212A2822024-08-0202 August 2024 Regulatory Audit Summary Concerning Review of Request No. C3R-01 for Proposed Alternative to ASME Code, Section XI Requirements for Containment Building Inspections IR 05000483/20240022024-07-18018 July 2024 And Independent Spent Fuel Storage Installation Integrated Inspection Report 05000483/2024002 and 07201045/2024001 ML24185A1032024-07-16016 July 2024 2024 Biennial Problem Identification and Resolution Inspection Report ULNRC-06891, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00052024-06-26026 June 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0005 ULNRC-06892, Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC00062024-06-26026 June 2024 Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC0006 ULNRC-06884, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00022024-06-12012 June 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0002 ULNRC-06885, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00032024-06-12012 June 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0003 ULNRC-06886, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00042024-06-12012 June 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0004 ML24144A0492024-06-11011 June 2024 Requests for Relief from ASME OM Code Pump and Valve Testing Requirements for Fifth 120-Month Inservice Testing Interval ML24158A5222024-06-0606 June 2024 Application to Revise Technical Specifications to Adopt Tstf-569, Rev. 2, Revise Response Time Testing Definition (LDCN 24-0008) ML24178A1132024-06-0606 June 2024 Ameren Missouris Intent to Adopt Revision 1 to Amendment 0 of Certificate of Compliance No. 1040 as Applicable to the ISFSI at the Callaway Plant Site ML24143A1632024-05-23023 May 2024 Independent Spent Fuel Storage Installation Registration of Dry Spent Storage Canister HGMPC0001 ML24137A2342024-05-16016 May 2024 Independent Spent Fuel Storage Installation - Registration of Dry Spent Fuel Storage Canister HGMPC0011 ULNRC-06882, Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC00122024-05-16016 May 2024 Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC0012 ML24122A1502024-05-0707 May 2024 Audit Plan to Support Review of Steam Generator License Renewal Response to Commitment Nos 34 and 35 IR 05000483/20244022024-05-0606 May 2024 Security Baseline Inspection Report 05000483/2024402 (Full Report) ULNRC-06877, Final Safety Analysis Report Revision OL-27 and Technical Specification Bases Revision 252024-05-0606 May 2024 Final Safety Analysis Report Revision OL-27 and Technical Specification Bases Revision 25 ULNRC-06856, CFR 50.59 and 10 CFR 72.48 Summary Report2024-05-0101 May 2024 CFR 50.59 and 10 CFR 72.48 Summary Report IR 05000483/20240112024-05-0101 May 2024 NRC Post-Approval Site Inspection for License Renewal (Phase 2) Report 05000483/2024011 ULNRC-06869, Submittal of Callaway, Unit 1, 2023 Annual Radiological Environmental Operating Report2024-04-30030 April 2024 Submittal of Callaway, Unit 1, 2023 Annual Radiological Environmental Operating Report ML24122A1132024-04-30030 April 2024 Submittal of Callaway, Unit 1, 2023 Annual Radioactive Effluent Release Report ULNRC-06876, Registration of Dry Spent Fuel Storage Canister HGMPC00102024-04-25025 April 2024 Registration of Dry Spent Fuel Storage Canister HGMPC0010 ULNRC-06866, Submittal of Cycle 26 Commitment Change Summary Report2024-04-17017 April 2024 Submittal of Cycle 26 Commitment Change Summary Report ULNRC-06871, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00072024-04-17017 April 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0007 ULNRC-06872, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00082024-04-17017 April 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0008 ML24108A1082024-04-17017 April 2024 Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC0009 IR 05000483/20240012024-04-16016 April 2024 Integrated Inspection Report 05000483/2024001 IR 05000483/20244042024-04-0909 April 2024 Cyber Security Inspection Report 05000483/2024404 ML24088A3212024-04-0101 April 2024 Notification of Commercial Grade Dedication Inspection (05000483/2024013) and Request for Information ML24086A5132024-03-26026 March 2024 CFR 50.46 Annual Report Regarding ECCS Evaluation Model Revisions ULNRC-06863, Submittal of Annual Exposure Report for 20232024-03-20020 March 2024 Submittal of Annual Exposure Report for 2023 ML24079A1622024-03-19019 March 2024 Re Nuclear Property Insurance Reporting ML24066A1932024-03-0707 March 2024 2024 Callaway Plant Notification of Biennial Problem Identification and Resolution Inspection and Request for Information ULNRC-06852, Owners Activity Reports (OAR-1 Forms) for Cycle/Refuel 262024-03-0505 March 2024 Owners Activity Reports (OAR-1 Forms) for Cycle/Refuel 26 IR 05000483/20230062024-02-28028 February 2024 Annual Assessment Letter for Callaway Plant Report 05000483/2023006 ML24052A3662024-02-26026 February 2024 Regulatory Audit Plan in Support of Proposed Alternative to ASME Code, Section XI Requirements for Containment Building Inspections IR 05000483/20230022024-02-21021 February 2024 Amended Integrated Inspection Report 05000483/2023002 ULNRC-06858, Completion of License Renewal Activities Prior to Entering the Period of Extended Operation2024-02-21021 February 2024 Completion of License Renewal Activities Prior to Entering the Period of Extended Operation ML24036A1712024-02-20020 February 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0079 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) ULNRC-06853, Submittal of 2023 Fitness for Duty Performance Data Per Per 10 CFR 26.7172024-01-29029 January 2024 Submittal of 2023 Fitness for Duty Performance Data Per Per 10 CFR 26.717 ML24008A0552024-01-19019 January 2024 Acceptance of Requested Licensing Action - Proposed Alternative to the Requirements of the ASME Code (EPID L-2023-LLR- 0061) IR 05000483/20230042024-01-19019 January 2024 – Integrated Inspection Report 05000483/2023004 2024-09-11
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May 7, 2024
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 TO SUPPORT REVIEW OF STEAM GENERATOR LICENSE RENEWAL RESPONSE TO COMMITMENT NOS. 34 AND 35 (EPID L-2024-LRO-0009)
Dear Fadi Diya:
By letter dated December 20, 2023 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML23354A244), Union Electric Company, doing business as Ameren Missouri (the licensee), submitted to the U.S. Nuclear Regulatory Commission (NRC) a response to license renewal Commitment Nos. 34 and 35 for the Callaway Plant, Unit No. 1 (Callaway). In March 2015, the NRC published NUREG-2172, Safety Evaluation Report Related to the License Renewal of Callaway Plant, Unit 1, which documents the technical review of the Callaway license renewal application (ML15068A342).
The NRC staff reviewed the Callaway submittal regarding the license renewal resolution for Commitment Nos. 34 and 35 and determined that a regulatory audit would be necessary to support its review of the submittal. A regulatory audit is a planned activity that includes the examination and evaluation of primarily non-docketed information. The audit will be conducted to increase the staffs understanding of the submittal and identify information that will need to be docketed to support staffs regulatory findings.
The NRC staff plans to conduct the audit from May 20, 2024, through August 30, 2024, in accordance with the enclosed audit plan.
F. Diya
If you have any questions, please contact me at 301-415-8371 or via email 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
AUDIT PLAN
TO SUPPORT REVIEW OF LICENSE RENEWAL RESPONSE
TO COMMITMENT NOS. 34 AND 35
UNION ELECTRIC COMPANY
CALLAWAY PLANT, UNIT 1
DOCKET NO. 50-483
1.0 BACKGROUND
By letter dated December 20, 2023 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML23354A244), Union Electric Company doing business as Ameren Missouri (the licensee), submitted to the U.S. Nuclear Regulatory Commission (NRC) a response to license renewal Commitment Nos. 34 and 35 for the Callaway Plant, Unit No. 1 (Callaway). In March 2015, the NRC published NUREG-2172 Safety Evaluation Report Related to the License Renewal of Callaway Plant, Unit 1, Volume 1, which documents the technical review of the Callaway license renewal application (ML15068A342).
In accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR)
Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, and NUREG-2172, appendix A, License Renewal Commitments, the NRC staff will perform an audit to gain a better understanding of: (1) how the Callaway steam generator reactor coolant system (RCS) pressure boundary is adequately maintained in the presence of divider plate weld cracking, and (2) how the susceptibility of the Callaway steam generator tube-to-tubesheet welds to primary water stress corrosion cracking (PWSCC).
2.0 REGULATORY AUDIT BASES
License renewal requirements are specified in 10 CFR Part 54. In March 2015, the NRC published NUREG-2172, a final safety evaluation report to the license renewal of Callaway.
In NUREG-2172, appendix A, Callaway Plant Unit 1 License Renewal Commitments, Callaway Commitment No. 34 provided the licensee three options to fulfill this commitment. The licensee has chosen Option 2: Analysis, which requires Callaway to:
Perform an analytical evaluation of the steam generator divider plate welds in order to establish a technical basis which concludes that the steam generator RCS pressure boundary is adequately maintained with the presence of steam generator divider plate weld cracking. The analytical evaluation will be submitted to the NRC for review and approval.
Callaway Commitment No. 35 provided the licensee three options to fulfill this commitment. The licensee has chosen Option 2: Analysis, which requires Callaway to:
Perform an analytical evaluation of the steam generator tube-to-tubesheet welds either determining that the welds are not susceptible to PWSCC or redefining the
Enclosure
reactor coolant pressure boundary of the tubes, where the steam generator tube-to-tubesheet welds are not required to perform a reactor coolant pressure boundary function. The redefinition of the reactor coolant pressure boundary will be submitted as part of a license amendment request requiring approval from the NRC. The evaluation for determination that the welds are not susceptible to PWSCC and do not require inspection will be submitted to the NRC for review.
3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY
The licensee performed an analytical evaluation specific to the Callaway steam generators because it could not be determined if the steam generators were bounded by the industry analyses, Electric Power Research Institut e (EPRI) Steam Generator Management Program Report 3002002850, Investigation of Crack Initiation and Propagation in the Steam Generator Channel Head Assembly, that the staff accepted for the divider plate PWSCC evaluation in License Renewal (LR) Interim Staff Guidance (ISG) LR-ISG-2016-01, Changes to Aging Management Guidance for Various Steam Generator Components (ML16237A383).
The NRC staff is unable to determine from the information submitted whether the licensees analysis establishes an adequate technical basis for (1) concluding that the steam generator reactor coolant boundary would be maintained in the presence of divider plate cracking, and (2) evaluating the susceptibility of the steam generator tube-to-tubesheet welds to PWSCC. The audit team will view documentation and calculat ions the licensee referenced as technical support, focusing on the key assumptions, methodology, and inputs.
4.0 AUDIT ACTIVITIES
For the audit, the NRC staff will review the licensees submittal dated December 20, 2023, and documentation on the licensees electronic portal (ePortal). The staff will have the opportunity to have technical discussions with the licensee to gain context, clarity, and information on the documentation to support the staffs review. The audit is coordinated to support the development of the reviewers reasonable assurance for the safety findings to be documented in the safety evaluation.
The Division of Operating Reactor Licensing (DORL) Plant Licensing Branch 4 (LPL 4) project manager will coordinate all communications with the licensee. NRC technical staff requests for communication with the licensee will require approval of their respective technical branch chief and the DORL branch chief. Following completion of the audit, an audit report will be iss ued.
5.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY AUDIT
Throughout the audit, the NRC staff will review the supporting documents as appropriate and requested, on the ePortal. The staff may request additional documents to be added to the ePortal over the course of the audit. The staff requests for ePortal additions shall be made, as needed, to the DORL project manager, who will provide the requests to the licensee.
6.0 AUDIT TEAM
Team Member Branch/Division David Rudland Division of New and Renewed Licenses (DNRL)
Andrew Johnson Corrosion and Steam Generators Branch (NCSG)/DNRL Gregory Makar NCSG/DNRL Paul Klein NCSG/DNRL Mahesh Chawla DORL/LPL4
7.0 LOGISTICS
The attachment to this audit plan provides a list of documents needed for this audit. The audit will be conducted using telecommunications from May 20 2024, through August 30, 2024.
Entrance and exit briefings will be held at the beginning and end of the audit.
8.0 DELIVERABLES
An audit summary will be prepared within 90 days of the completion of the audit. If the NRC staff identifies information during the audit that is needed to support its regulatory decision, the staff will issue a request for additional information to the licensee after completion of the audit.
Attachment:
List of Documents List of Documents
References From Enclosure 1 of the Submittal Dated December 20, 2023 (Agencywide Document Access and Management System (ADAMS) Package Accession No. ML23354A244) for Callaway Plant, Unit No. 1
Framatome Document 51-9268036-000, EPRI [Electric Power Research Institute]
SGMP [Steam Generator Management Program] for Channel Head Aging of the Framatome RSG [Replacement Steam Generator] Designs (Reference 2).
Framatome Document 32-9360111-000, Framatome RSG Channel Head and Tubesheet Stress Analysis for Flaw Evaluation (Reference 3).
Framatome Document 32-9364633-000, Framatome RSG Channel Head and Tubesheet Flaw Tolerance Evaluation (Reference 4).
Framatome Document 32-9055891-007, Fatigue and PWSCC [Primary Water Stress Corrosion Cracking] Crack Growth Evaluation Tool AREVACGC (Reference 7).
EPRI-Framatome Project Agreement 10012545, Divider Plate Cracking Assessment for Framatome Replacement Steam Generator s, EPRI Task ID 1-072913-04-01, May 29, 2020 (Reference 13).
License Renewal Other Documentation
Documentation of inputs for the calculation of the tube-to-tubesheet chromium content described in section 2.0 of enclosure 2 of the submittal dated December 20, 2023 (e.g.,
a summary of the manufacturing completion reports that provide the detailed chromium contents).
Attachment
ML24122A150 OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DNRL/NCSG/BC NAME MChawla PBlechman SBloom DATE 4/30/2024 5/1/2024 5/6/2024 OFFICE NRR/DNRL/NLRP/BC NRR/DORL/LPL/BC NRR/DORL/LPL4/PM NAME LGibson JRankin MChawla DATE 5/7/2024 5/7/2024 5/7/2024