ULNRC-06196, Cycle 20 Commitment Change Summary Report, Guideline for Managing NRC Commitment Changes, for Changes Requiring NRC Notification Annually or at a Frequency Consistent with That Required for FSAR Updates Per 10CFR 50.71.

Cycle 20 Commitment Change Summary Report, Guideline for Managing NRC Commitment Changes, for Changes Requiring NRC Notification Annually or at a Frequency Consistent with That Required for FSAR Updates Per 10CFR 50.71.

ML15077A161
Person / Time
Site:	Callaway
Issue date:	03/18/2015
From:	Maglio S Ameren Missouri
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ULNRC-06196
Download: ML15077A161 (5)

Text

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'WAmeren Callaway Plant MISSOURI March 18, 2015 ULNRC-06196 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 50.71(e)(4)

Ladies and Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

FACILITY OPERATING LICENSE NPF-30 CYCLE 20 COMMITMENT CHANGE

SUMMARY

REPORT Please find attached the Cycle 20 Commitment Change Summary Report required by NEI 99-04, "Guideline for Managing NRC Commitment Changes," for changes requiring NRC notification annually or at a frequency consistent with that required for FSAR updates per 10 CFR 50.71(e)(4).

These commitment revisions were completed at Callaway Plant Unit 1 for the period between May 29, 2013 and November 22, 2014, and were not reported to NRC in a previous submittal. The Cycle 20 Commitment Change Summary Report provides a description of each change completed along with a brief justification for each revised commitment.

If you should have any questions concerning this report, please contact Scott Maglio at (573) 676-8719.

This letter does not contain new commitments.

Sincerely,

.()eo t--\- A-. 'IV\ ~

Scott A. Magliy Manager, Regulatory Affairs DRB/

Enclosure

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ULNRC-06196 March 18, 2015 Page2 cc: Mr. Marc L. Dapas 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. Fred Lyon Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8B 1 Washington, DC 20555-2738

ULNRC-06196 March 18, 2015 Page 3 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4150 International Plaza Suite 820 Fort Worth, TX 76109 (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 D. W. Neterer L. H. Graessle T. E. Herrmann B.L.Cox S. A. Maglio T. B. Elwood Corporate Communications NSRB Secretary Mr. Greg Voss, REP Manager (SEMA)

STARS Regulatory Affairs Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)

Ms. Leanne Tippett-Mosby (DNR)

Enclosure to ULNRC-06196 Page 1 CYCLE 20 COMMITMENT CHANGE

SUMMARY

REPORT In accordance with NEI 99-04, "Guidelines for Managing NRC Commitment Changes," as endorsed in Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," the following commitment changes are being reported. The changes were completed for Callaway Plant Unit 1 for the period from May 29,2013 to November 22,2014.

A description of each change completed, along with a brief justification for each revised commitment, is provided.

Commitment 42210 (ref. ULNRC-02294, Generic Letter 90-03)

This commitment implements Generic Letter 90-03, "Relaxation of Staff Position in Generic Letter 83-28, Item 2.2 Part 2 'Vendor Interface for Safety-Related Components."' The primary change in this commitment was to increase the periodicity of vendor re-contact from "with the maximum interval between contacts with a vendor not to exceed 24 months" to "with the customary interval between contacts with a vendor being 3 years, based on industry standard practice for vendor re-contact programs."

Justification for change:

The original position taken by the NRC in Part 2 of Item 2.2 ofGL 83-28 includes the sentence: "The program shall include periodic communication with vendors .... " With the above-described change to Callaway's commitment, the intent of maintaining communication with vendors continues to be met. This change is consistent with current industry standard practice for vendor re-contact programs.

A large number of commitments were either deleted, initiated or revised to support Callaway's License Amendment Request to adopt NFPA 805, "Performance-Based Standard for fire Protection of Light Water Reactor Generating Plants (2001 Edition)." Individual notifications (ULNRC-05871, ULNRC-05876, ULNRC-05952, ULNRC-06011, ULNRC-06030 and ULNRC-06060) were filed in support of these changes. However, several of these commitments were changed subsequent to the notifications/correspondence and are thus reported as follows:

Commitments 50196-50198 (ref. ULNRC-05781)

These three commitments revise training modules to add discussion addressing radiological release considerations during firefighting. The commitment text specified the course and module numbers to which this material would be added. The course numbering system subsequently changed, so the text of these commitments was adjusted accordingly.

Enclosure to ULNRC-06196 Page2 Justification for change:

The content of the added material did not change from what was described in the commitment.

The only change was in the course numbering system.

Commitments 50155 and 50166 (ref. ULNRC-05781)

These two commitments revised procedure APA-ZZ-00741, "Control of Combustible Materials," to include discussion related to the removal of waste, debris, scrap and combustible packing materials; and the removal of cribbing timbers; respectively. The commitment text specified the section and step numbers that would be revised to include this discussion. This procedure was extensively rewritten in support of the NFPA 805 project. Due to the rewrite, the changes made to support these commitments fit into other procedure sections than those which were originally identified. These commitments were revised to delete the section and step numbers identified in the text of these commitments.

Justification for change:

The original intent of these commitments is unchanged. The only change was to delete the procedural section and step numbers that would otherwise be revised.