ML18106A705

Request to Extend Enforcement Discretion Provided in Enforcement Guidance Memorandum 15-002 for Tornado-Generated Missile Protection Non-Conformances Identified in Response to RIS 2015-06, Tornado Missile Protection:

ML18106A705
Person / Time
Site:	Callaway
Issue date:	05/03/2018
From:	Mike Franovich NRC/NRR/DRA
To:	Diya F Union Electric Co
Wu A
References
EPID L-2018-LLL-0011
Download: ML18106A705 (3)

Text

May 3, 2018 Mr. Fadi Diya Senior Vice President and Chief Nuclear Officer Union Electric Company Callaway Plant P.O. Box 620 Fulton, MO 65251

SUBJECT:

REQUEST TO EXTEND ENFORCEMENT DISCRETION PROVIDED IN ENFORCEMENT GUIDANCE MEMORANDUM 15-002 FOR TORNADO-GENERATED MISSILE PROTECTION NON-CONFORMANCES IDENTIFIED IN RESPONSE TO REGULATORY ISSUE

SUMMARY

2015-06, TORNADO MISSILE PROTECTION (EPID: L-2018-LLL-0011)

Dear Mr. Diya:

By letter dated March 23, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18082B083), Ameren Missouri requested the U.S. Nuclear Regulatory Commission (NRC, the Commission) to extend the expiration date for the period of enforcement for Callaway Plant, Unit 1 (Callaway), from June 10, 2018, to June 10, 2020, in accordance with information provided in Enforcement Guidance Memorandum (EGM) 15-002, Revision 1, Enforcement Discretion for Tornado Generated Missile Protection Non-Compliance, dated February 7, 2017 (ADAMS Accession No. ML16355A286).

Subsequently, the NRC staff has reviewed your letter in accordance with Commission direction as provided in EGM 15-002, Revision 1, and staff guidance provided in NRC Interim Staff Guidance, DSS-ISG-2016-01, Revision 1, Clarification of Licensee Actions in Receipt of Enforcement Discretion [per EGM 15-002], dated November 2017 (ADAMS Accession No. ML17128A344).

The NRC staff reviewed the information that you have provided and finds that the compensatory measures taken are consistent with EGM 15-002, Revision 1, and with interim staff guidance found in DSS-ISG-2016-01, Revision 1. Specifically, the staff found that Callaway has sufficiently described and evaluated the following six items described in DSS-ISG-2016-01, Revision 1, Appendix B: nonconformances applicable to the EGM, prompt compensatory actions, long-term compensatory actions, assessment of compensatory measures, need for additional enforcement discretion time, and timeline for restoring licensing basis compliance.

The NRC staff has concluded that the actions taken by Callaway can be effectively implemented and justify extension of the enforcement discretion date to June 10, 2020, because Callaway has sufficiently described and documented compensatory measures for identified nonconforming structures, systems, and components (SSCs), provided assurance that compensatory measures will be effective and maintained through the extended period for enforcement discretion, and described an implementable plan for restoring SSCs to compliance within the extended period for enforcement discretion. Therefore, the request to extend enforcement discretion is granted.

F. Diya If you are unable to meet the extended enforcement discretion expiration date, you are requested to contact the NRC staff at least 90 days in advance. Please contact Greg Casto at (301) 415-0565.

Sincerely,

/RA/

Michael X. Franovich, Director Division of Risk Assessment Office of Nuclear Reactor Regulation Docket Nos. 50-483

ML18106A705 *via e-mail OFFICE DRA/APLB DRA/APLB DSS/SCPB APLB DRA NAME AWu MPatterson* RDennig* GCasto* MFranovich DATE 04/11/2018 04/19/2018 04/19/2018 04/20/2018 05/ 03 /2018 May 3, 2018 Mr. Fadi Diya Senior Vice President and Chief Nuclear Officer Union Electric Company Callaway Plant P.O. Box 620 Fulton, MO 65251

SUBJECT:

REQUEST TO EXTEND ENFORCEMENT DISCRETION PROVIDED IN ENFORCEMENT GUIDANCE MEMORANDUM 15-002 FOR TORNADO-GENERATED MISSILE PROTECTION NON-CONFORMANCES IDENTIFIED IN RESPONSE TO REGULATORY ISSUE

SUMMARY

2015-06, TORNADO MISSILE PROTECTION (EPID: L-2018-LLL-0011)

Dear Mr. Diya:

By letter dated March 23, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18082B083), Ameren Missouri requested the U.S. Nuclear Regulatory Commission (NRC, the Commission) to extend the expiration date for the period of enforcement for Callaway Plant, Unit 1 (Callaway), from June 10, 2018, to June 10, 2020, in accordance with information provided in Enforcement Guidance Memorandum (EGM) 15-002, Revision 1, Enforcement Discretion for Tornado Generated Missile Protection Non-Compliance, dated February 7, 2017 (ADAMS Accession No. ML16355A286).

Subsequently, the NRC staff has reviewed your letter in accordance with Commission direction as provided in EGM 15-002, Revision 1, and staff guidance provided in NRC Interim Staff Guidance, DSS-ISG-2016-01, Revision 1, Clarification of Licensee Actions in Receipt of Enforcement Discretion [per EGM 15-002], dated November 2017 (ADAMS Accession No. ML17128A344).

The NRC staff reviewed the information that you have provided and finds that the compensatory measures taken are consistent with EGM 15-002, Revision 1, and with interim staff guidance found in DSS-ISG-2016-01, Revision 1. Specifically, the staff found that Callaway has sufficiently described and evaluated the following six items described in DSS-ISG-2016-01, Revision 1, Appendix B: nonconformances applicable to the EGM, prompt compensatory actions, long-term compensatory actions, assessment of compensatory measures, need for additional enforcement discretion time, and timeline for restoring licensing basis compliance.

The NRC staff has concluded that the actions taken by Callaway can be effectively implemented and justify extension of the enforcement discretion date to June 10, 2020, because Callaway has sufficiently described and documented compensatory measures for identified nonconforming structures, systems, and components (SSCs), provided assurance that compensatory measures will be effective and maintained through the extended period for enforcement discretion, and described an implementable plan for restoring SSCs to compliance within the extended period for enforcement discretion. Therefore, the request to extend enforcement discretion is granted.

F. Diya If you are unable to meet the extended enforcement discretion expiration date, you are requested to contact the NRC staff at least 90 days in advance. Please contact Greg Casto at (301) 415-0565.

Sincerely,

/RA/

Michael X. Franovich, Director Division of Risk Assessment Office of Nuclear Reactor Regulation Docket Nos. 50-483

ML18106A705 *via e-mail OFFICE DRA/APLB DRA/APLB DSS/SCPB APLB DRA NAME AWu MPatterson* RDennig* GCasto* MFranovich DATE 04/11/2018 04/19/2018 04/19/2018 04/20/2018 05/ 03 /2018