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{{Adams
{{Adams
| number = ML17170A091
| number = ML17277A053
| issue date = 06/19/2017
| issue date = 10/03/2017
| title = Callaway-Notification of NRC Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/ Staffing/Multi-Unit Dose Assessment Plans (05000483/2017008) and Req
| title = Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/ Staffing/Multi-Unit Dose Assessment Plans - Inspection Report 05000483/2017008
| author name = Alexander R D, Dixon J L
| author name = Taylor N
| author affiliation = NRC/RGN-IV/DRP/RPB-B
| author affiliation = NRC/RGN-IV/DRP/RPB-A
| addressee name = Diya F
| addressee name = Diya F
| addressee affiliation = Ameren Corp
| addressee affiliation = Ameren Missouri
| docket = 05000483
| docket = 05000483
| license number = NPF-030
| license number = NPF-030
| contact person = Dixon J L
| contact person = Taylor N
| case reference number = TI-2515/191
| case reference number = EA-12-049, EA-12-051
| document report number = IR 2017008
| document report number = IR 2017008
| document type = Letter
| document type = Inspection Report, Letter
| page count = 7
| page count = 15
}}
}}


Line 19: Line 19:


=Text=
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 1600 E. LAMAR BLVD. ARLINGTON, TX 76011-4511 June 19, 201 7 Mr. Fadi Diya, Senior Vice President and Chief Nuclear Officer Ameren Missouri Callaway Plant P.O. Box 620 Fulton, MO 65251
{{#Wiki_filter:October 3, 2017


SUBJECT: CALLAWAY PLANT - NOTIFICATION OF NRC INSPECTION OF THE IMPLEMENTATION OF MITIGATION STRATEGIES AND SPENT FUEL POOL INSTRUMENTATION ORDERS AND EMERGENCY PREPAREDNESS COMMUNICATION/
==SUBJECT:==
STAFFING/MULTI
CALLAWAY PLANT - INSPECTION OF THE IMPLEMENTATION OF MITIGATION STRATEGIES AND SPENT FUEL POOL INSTRUMENTATION ORDERS AND EMERGENCY PREPAREDNESS COMMUNICATION/
-UNIT DOSE ASSESSMENT PLANS (05000483/2017008) AND REQUEST FOR INFORMATION
STAFFING/MULTI-UNIT DOSE ASSESSMENT PLANS - INSPECTION REPORT 05000483/2017008


==Dear Mr. Diya:==
==Dear Mr. Diya:==
The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC) staff will conduct a mitigation strategies for beyond
On September 1, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed the onsite portion of an inspection at the Callaway Plant. On September 26, 2017, the NRC inspectors discussed the results of this inspection with Ms. S. Banker, Senior Director, Engineering, and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.
-design-basis external events, spent fuel pool instrumentation, and emergency preparedness enhancements inspection at the Callaway Plant from August 28 - September 1, 2017. The inspection will consist of three reactor inspectors from the NRC
's Region IV office, plus one of the assigned Resident Inspectors at the Callaway Plant for one week. The inspection will be conducted in accordance with the NRC's Temporary Instruction 2515/191 , "Inspection of the Implementation of Mitigating Strategies and Spent Fuel Pool Instrumentation Orders, and Emergency Preparedness Communication/Staffing/Multi
-Unit Dose Assessment Plans."


Experience has shown that this inspection is resource intensive both for the NRC inspectors and licensee staff. In order to minimize the impact to your onsite resources and to ensure a productive inspection, we have enclosed a request for documents needed for this inspection activity. Please note that the documents are requested to be provided by August 11, 2017
The inspection examined activities conducted under your license as they relate to the implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049 and EA-12-051) and emergency preparedness communications, staffing, and multi-unit/source dose assessment plans; your compliance with the Commissions rules and regulations; and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with station personnel.
. During the onsite inspection, inspectors will verify that plans for complying with NRC Orders EA-12-049 and EA
-12-051 are in place and are being implemented. Inspectors will also verify the establishment of staffing and communications plans provided in response to the March 12, 2012, request for information letter, and multi-unit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013. These plans and information were provided in the site specific submittals, which were subsequently reviewed by the NRC staff for understanding and documented in the NRC's plant safety evaluations (SEs) and safety assessments. Therefore, appropriate personnel knowledgeable of the station's FLEX strategies, spent fuel pool instrumentation, and emergency preparedness enhancements should be available to support the inspector s at the site during the inspection. We have discussed the schedule for th is inspection activit y with your staff and understand that our regulatory contact for this inspection will be Elizabeth Ptasznik of your licensing organization. If there are any questions about this inspection or the material requested, please contact the l ead inspector , Ryan D. Alexander
, by telephone at 817-200-1195 or by e-mail at ryan.alexander@nrc.gov.


This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget, control number 3150 0011. The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid Office of Management and Budget control number.
The NRC inspectors did not identify any findings or violations of more than minor significance associated with this inspection.


In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading
-rm/adams.html (the Public Electronic Reading Room).


Sincerely,/RA/ John L. Dixon , Acting Chief Project Branch B Division of Reactor Projects Docket No. 50
Sincerely,
-483 License No. NPF
/RA David Proulx Acting for/  
-30  
 
Nicholas H. Taylor, Chief Project Branch B Division of Reactor Projects  
 
Docket No. 50-483 License No. NPF-30  


===Enclosure:===
===Enclosure:===
FLEX Strategies, Spent Fuel Pool Instrumentation
Inspection Report 05000483/2017008 w/ Attachment: Supplemental Information
, & EP Enhancements Inspection Request for Information
 
REGION IV==
Docket:
05000483 License:
NPF-30 Report:
05000483/2017008 Licensee:
Union Electric Company Facility:
Callaway Plant Location:
Junction Highway CC and Highway O Steedman, Missouri Dates:
August 28 - September 26, 2017 Inspectors: R. Alexander, Sr. Project Engineer (Team Leader)
S. Alferink, Reactor Inspector D. Bradley, Sr. Resident Inspector - Callaway M. Stafford, Project Engineer Approved By:
Nicholas H. Taylor Chief, Project Branch B Division of Reactor Projects
 
=SUMMARY=
IR 05000483/2017008; 08/28/2017 - 09/26/2017; Callaway Plant;
 
Temporary Instruction 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, issued December 23, 2015.
 
The inspection covered a one-week inspection by the resident inspector and three inspectors from the Region IV office. No findings were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.
 
===NRC-Identified and Self-Revealing Findings===
None
 
===Licensee-Identified Violations===
None


1 Enclosure Request for Information FLEX Strategies, Spent Fuel Pool Instrumentation, & EP Enhancements Inspection Callaway Plant Inspection Report:
=REPORT DETAILS=
050004 83/2017 008 Inspection Dates:
August 28
- September 1
, 2017 Inspection Procedure:
Temporary Instruction 2515/191 , "Inspection of the Implementation of Mitigating Strategies and Spent Fuel Pool Instrumentation Orders, and Emergency Preparedness Communication/Staffing/Multi
-Unit Dose Assessment Plans" Inspect o r s: Ryan D. Alexander
, Team Lead, Sr.


Project Engineer, Region IV Dan Bradley , Callaway Plant Senior Resident Inspector Steve Alferink, Reactor Inspector, Region IV Michael Stafford, Project Engineer, Region IV
===4. Other Activities===
{{a|4OA5}}


Information Requested for the In-Office Preparation Week The following information should be sent to the Region IV office in hard copy or electronic format (use of the Certrec IMS information portal is preferred), to the attention of Ryan Alexander , by August 11, 2017. The inspector s will select specific items from the information requested below and then request from your staff additional documents needed during the onsite inspection week. Also, we request that you categorize the documents in your response with the numbered list below.
==4OA5 Other Activities (TI 2515/191)==
The objective of Temporary Instruction (TI) 2515/191 Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, is to verify that licensees have adequately implemented the mitigation strategies as described in the licensees Final Integrated Plan (ADAMS Accession No. ML16189A304) and the NRCs plant safety evaluation (ADAMS Accession No. ML17010A332) and to verify that the licensees installed reliable water level measurement instrumentation in their spent fuel pools. The purpose of this TI is also to verify the licensees have implemented Emergency Preparedness (EP) enhancements as described in their site-specific submittals and NRC safety assessments, including multi-unit dose assessment capability and enhancements to ensure that staffing is sufficient and communications can be maintained during such an event.


Please provide requested documentation electronically if possible. If requested documents are large and only hard copy formats are available, please inform the lead inspector, and provide subject documentation during the first day of the onsite inspection. If you have any questions regarding this information request, please call the lead inspector as soon as possible.
The inspection verified that plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, (ADAMS Accession No. ML12229A174) and EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation, (ADAMS Accession No. ML12056A044) are in place and are being implemented by the licensee. Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012, request for information letter and multiunit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 (ADAMS Accession No. ML12339A262).


TI 2515/191
The team discussed the plans and strategies with plant staff, reviewed documentation, and where appropriate, performed plant walk downs to verify that the strategies could be implemented as stated in the licensees submittals and the NRC staff-prepared safety evaluation. For most strategies, this included verification that the strategy was feasible, procedures and/or guidance had been developed, training had been provided to plant staff, and required equipment had been identified and staged. Specific details of the teams inspection activities are described in the following sections.
- Appendix A A. Provide current revision of the FLEX Final Integrated Plan (i.e., current FLEX Program Document), including any revisions since July 2016 submission to the NRC
. B. Provide the FLEX Strategy Basis Document.


C. Provide each operating, off
===1. Mitigation Strategies for Beyond-Design-Basis External Events===
-normal, abnormal, and/or emergency procedures where entry into one or more FLEX Support Guideline(s) are initiated
====a. Inspection Scope====
. D. Provide a list and copies of every FLEX Support Guideline (FSG) or equivalent procedure which you developed or revised to implement your mitigating strategies.
The team examined the licensees established guidelines and implementing procedures for the beyond-design-basis mitigation strategies. The team assessed how the licensee coordinated and documented the interface/transition between existing off-normal and emergency operating procedures with the newly developed mitigation strategies. The team selected a number of mitigation strategies and conducted plant walk downs with licensed operators and responsible plant staff to assess: the adequacy and completeness of the procedures, familiarity of operators with the procedure objectives and specific guidance, staging and compatibility of equipment, and the practicality of the operator actions prescribed by the procedures, consistent with the postulated scenarios.


E. Provide a list of key piece s of equipment that directly perform a FLEX mitigation strategy for core cooling (RCS and Steam Generators), containment, and/or spent fuel pool cooling. F. Provide a listing/summaries of plant modifications completed related to the FLEX program.
The team verified that a preventive maintenance program had been established for the FLEX portable equipment and that periodic equipment inventories were in place and being conducted. Additionally, the team examined the introductory and planned periodic/refresher training provided to the Operations and Security staffs most likely to be tasked with implementation of the FLEX mitigation strategies. The team also reviewed the introductory and planned periodic training provided to the Emergency Response Organization personnel.


G. Provide a listing of calculations, evaluations, and 50.59 reviews related to the FLEX program and modifications
b. Assessment
.
2 H. Applicable site specific hazards for the Callaway Plant
: 1) Provide documents which show the locations and configuration of structure(s) which store FLEX equipment
. 2) Seismic (a) Provide the travel route(s) for FLEX equipment from storage location(s) to their location(s) of use, AND evaluation(s) which demonstrate that for the potential for soil liquefaction is not of a concern for these travel route(s).


(b) Seismic concerns for water source(s)
Based on samples selected for review, the team verified that the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is generally in compliance with NRC Order EA-12-049. The team verified that the licensee satisfactorily:
(1) If the FLEX water sources are seismically robust, then provide the assessment that shows that they are.
* Developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX strategies for postulated external events,
* Integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs are clear when using existing plant procedures,
* Protected FLEX equipment from site-specific hazards,
* Developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability,
* Trained their staff to assure personnel proficiency in the mitigation of beyond-design-basis events, and
* Developed means to ensure that the necessary off-site FLEX equipment will be available from off-site locations.


(2) If the FLEX water sources are not seismically robust, then provide:
The team verified that any non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.
(a) an assessment of alternate water sources, and (b) the procedure(s) which describe when and how to access those sources.


3) External Flooding {"Screened Out
====c. Findings====
" for Callaway Plant
No findings identified.
- no documents requested}
4) Severe storms with high winds (a) Provide evaluation/evidence as to how FLEX equipment is stored relative to protection from severe storms with high winds:
(1) In a structure that meets the plant's design basis for high wind hazards (e.g., existing safety
-related structure); OR (2) In a structure that meets the design requirements as described in ASCE 7-10, "Minimum Design Loads for Buildings and Other Structures," given the limiting tornado wind speeds from Regulatory Guide 1.76, and/or design
-basis hurricane wind speeds.


(b) Provide pathways via which you plan to move FLEX equipment from onsite storage areas to final deployment locations.
===2. Spent Fuel Pool (SFP) Instrumentation===
====a. Inspection Scope====
The team examined the licensees newly installed spent fuel pool instrumentation.


(1) Show how you designated and evaluated those pathways for post
Specifically, the team verified the sensors were installed as described in the plant specific submittals and the associated safety evaluation and that the cabling for the power supplies and the indications for each channel are physically and electrically separated. Additionally, environmental conditions and accessibility of the instruments were evaluated. Documents reviewed are listed in the attachment.
-storm accessibility for staging and connecting FLEX equipment.


5) Snow, Ice, and Extreme Cold For each key piece of equipment described in Item 5 (above) that directly performs or implements a FLEX mitigation strategy:
b. Assessment
(a) Provide procedures/documents demonstrating that the FLEX equipment is maintained at a temperature within a range to ensure that it will function when called


upon. (b) Provide procedures/documents demonstrating how the FLEX equipment can be moved from the storage location to its deployment location during extreme snowfall and ice storms.
Based on samples selected for review, the team determined that the licensee satisfactorily installed and established control of the SFP instrumentation as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is generally in compliance with NRC Order EA-12-051. The team verified that the licensee satisfactorily:
* Installed the SFP instrumentation sensors, cabling and power supplies to provide physical and electrical separation as described in the plant specific submittal and safety evaluation;
* Installed the SFP instrumentation display in the location, environmental conditions and accessibility as described in the plant specific submittals; and
* Trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation.


3 6) Extreme high temperatures For each key piece of equipment described in Item 5 (above) that directly performs or implements a FLEX mitigation strategy
The team verified that any non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.
: (a) Provide procedures/documents which describes the high
-temperature limit of the range within which the equipment will function.


(b) Provide procedures/documents which describe how the equipment is maintained below that limit in its storage location.
====c. Findings====
No findings identified.


I. Provide the station
===3. Staffing and Communication Request for Information===
-specific FLEX strategies time validation study(ies)
====a. Inspection Scope====
. J. Provide the relevant station procedure(s)/guideline(s) which describe the testing and maintenance program for FLEX equipment.
Through discussions with plant staff, review of documentation and plant walk downs, the team verified that the licensee has implemented required changes to staffing, communications equipment, and facilities to support an Extended Loss of All AC Power (ELAP) scenario as described in the licensees staffing assessment and the NRC safety assessment. The team also verified that the licensee has implemented dose assessment (including releases from spent fuel pools) capability using the licensees site-specific dose assessment software and approach as described in the licensees dose assessment submittal. Documents reviewed are listed in the attachment.


As applicable, provide a listing of the model work orders established to conduct period testing and maintenance activities for FLEX equipment. [A sample of records for completed maintenance/testing activities may be requested for review during the onsite inspection week.]
b. Assessment
K. Provide documents/procedures which describe the programmatic controls in place to ensure that if equipment and applicable connections are unavailable (e.g., due to maintenance , non-functionality), then compensatory measures are implemented in accordance with guidance outlined NEI 12
-06. L. Provide the station
-specific National SAFER Center "Playbook" M. Relative to personnel training on FLEX strategies, provide:
1) FLEX training bases document(s)
2) Lesson plans/training documents for site emergency response leaders responsible for the implementation of FLEX strategies. [Records for staff completing this training may be requested for review during the onsite inspection week.]
3) Lesson plans/training documents for site personnel responsible for the execution of mitigating strategies for BDBEEs (i.e., operators, craft personnel, security, radiation protection, etc.). [Records for staff completing this training may be requested for review during the onsite inspection week.]
N. A current copy of administrative procedure(s) for the CAP, modification program, operations procedure writing and implementation, and top-level documents for the work control and work scheduling programs.


(If FLEX related procedures such as FSGs or the FIP are maintained under a different process
The team reviewed information provided in the licensees multi-unit dose submittal and in response to the NRCs March 12, 2012, request for information letter and verified that the licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force Recommendation 9.3 response to a large scale natural emergency event that results in an extended loss of all ac power to the site and impedes access to the site.
, please include copies of those procedures.


) O. A current copy of the U/FSAR, Technical Specifications, and Technical Specification Bases documents.
The team verified the following:
* Licensee satisfactorily implemented required staffing change(s) to support an ELAP scenario,
* Emergency preparedness communications equipment and facilities are sufficient for dealing with an ELAP scenario, and
* Implemented dose assessment capabilities (including releases from spent fuel pools)using the licensees site-specific dose assessment software and approach.


P. Listing of corrective action program document summaries generated related to FLEX equipment, strategies, procedures, and/or training.
The team verified that any non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.


Q. A copy of any audits/self
====c. Findings====
-assessments related to your preparation for this inspection, as well as any related to the implementation or maintenance of the FLEX program.
No findings identified.
{{a|4OA6}}


TI 2515/191
==4OA6 Exit==
- Appendix B R. Provide the procedures implemented for maintenance, testing, calibration, and use of the primary and backup Spent Fuel Pool (SFP) instrumentation channels.
===Exit Meeting Summary===
On September 1, 2017, the team presented the on-site inspection results in a management debrief to T. Herrmann, Site Vice President, and other members of the site staff. The inspectors confirmed that proprietary information examined during the inspection had been returned to the licensee. The team lead completed an exit meeting conducted with S. Banker, Senior Director, Engineering, and other members of the site staff, via telephone on September 26, 2017, to discuss the final results of the inspection.


S. Provide lesson plans/training documents which describe the training program that address the use, maintenance, calibration, surveillance, and the use of alternate power to the primary and backup SFP instrument channels.
ATTACHMENT:


4 TI 2515/191
=SUPPLEMENTAL INFORMATION=
- Appendix C T. Communications:
1) Provide documents which show that the communications system(s), technologies, equipment and power supplies would be available from the beginning of the event and operate during an ELAP.


2) Provide the procedures and/or guidance used to implement the communication capabilities
==KEY POINTS OF CONTACT==
. 3) Provide documents which show that you have added any new communications equipment, portable power supplies and/or systems have been added to ongoing testing and preventative maintenance programs.
===Licensee Personnel===
: [[contact::S. Abel]], Director, Engineering Projects
: [[contact::A. Alley]], Engineering Program Supervisor
: [[contact::S. Banker]], Senior Director Engineering
: [[contact::F. Bianco]], Director, Nuclear Operations
: [[contact::J. Cortez]], Director, Training
: [[contact::M. Covey]], Manager, Operations
: [[contact::B. Cox]], Senior Director Nuclear Operations
: [[contact::D. Farnsworth]], Director, Work Management
: [[contact::T. Herrmann]], Site Vice President
: [[contact::T. Holland]], Shift Manager
: [[contact::B. Huhmann]], Regulatory Affairs Supervisor
: [[contact::B. Jungmann]], Director, Maintenance
: [[contact::S. Kovaleski]], Director, Engineering Design
: [[contact::G. Kremer]], Director, Engineering Programs
: [[contact::M. McLachlan]], Senior Director Plant Support
: [[contact::K. Mills]], Director, Engineering Systems
: [[contact::T. Moser]], Director, Nuclear Projects
: [[contact::J. Nurrenbern]], FLEX Program Engineer
: [[contact::E. Olson]], Director, Engineering Programs
: [[contact::J. Patterson]], Director, Nuclear Projects
: [[contact::E. Ptasznik]], Licensing Engineer
: [[contact::S. Sandbothe]], Director, Plant Support
: [[contact::D. Stepanovic]], Manager, Materials


U. Staffing: 1) Provide documents which show that onsite and augmented staff will be available to implement the strategies in response to a large scale natural event that results an ELAP and impedes access to the site, and that functions/tasks have been appropriately staffed. 2) Provide documents which show that the site access methods (e.g., roadways, navigable bodies of water and dockage, airlift, etc.) expected to be available following the event and available to the Emergency Response Organization (ERO) [as described in the Phase 1 and 2 staffing assessments and NRC safety assessment]. 3) Provide documents which show the testing, training, and drills/exercises performed by the station to demonstrate the ERO's ability to utilize the communications systems and/or equipment.
===NRC Personnel===
: [[contact::S. Janicki]], Resident Inspector


V. Provide documents and procedures which show that your dose assessment is capable of analyzing concurrent radiological releases from all on-site significant sources, including releases from spent fuel pools (i.e., multi
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
-unit/multi
===Closed===
-source dose assessment capability)
2515/191 TI Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, issued December 23, 2015
. Lead Inspector Contact Information:
Ryan D. Alexander , Sr. Project Engineer Mailing Address
: 817-200-11 95 U.S. NRC, Region IV Ryan.Alexander@nrc.gov Attn: Ryan Alexander, DRP 1600 East Lamar Blvd.


Arlington, TX 76011
==LIST OF DOCUMENTS REVIEWED==
-4511


ML17170A091 SUNSI Review By: RDA/rdr ADAMS: Yes No Sensitive Non-Sensitive Non-Publicly Available Publicly Available Keyword NRC-002 OFFICE DRP/RPBA C:DRP/RPBB NAME RAlexander JDixon SIGNATURE /RA/-E /RA/ DATE 06/14/2017 06/19/2017
}}
}}

Latest revision as of 07:49, 8 January 2025

Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/ Staffing/Multi-Unit Dose Assessment Plans - Inspection Report 05000483/2017008
ML17277A053
Person / Time
Site: Callaway Ameren icon.png
Issue date: 10/03/2017
From: Nick Taylor
NRC/RGN-IV/DRP/RPB-A
To: Diya F
Ameren Missouri
Taylor N
References
EA-12-049, EA-12-051 IR 2017008
Download: ML17277A053 (15)
v • d • e


Text

October 3, 2017

SUBJECT:

CALLAWAY PLANT - INSPECTION OF THE IMPLEMENTATION OF MITIGATION STRATEGIES AND SPENT FUEL POOL INSTRUMENTATION ORDERS AND EMERGENCY PREPAREDNESS COMMUNICATION/

STAFFING/MULTI-UNIT DOSE ASSESSMENT PLANS - INSPECTION REPORT 05000483/2017008

Dear Mr. Diya:

On September 1, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed the onsite portion of an inspection at the Callaway Plant. On September 26, 2017, the NRC inspectors discussed the results of this inspection with Ms. S. Banker, Senior Director, Engineering, and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.

The inspection examined activities conducted under your license as they relate to the implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049 and EA-12-051) and emergency preparedness communications, staffing, and multi-unit/source dose assessment plans; your compliance with the Commissions rules and regulations; and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with station personnel.

The NRC inspectors did not identify any findings or violations of more than minor significance associated with this inspection.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA David Proulx Acting for/

Nicholas H. Taylor, Chief Project Branch B Division of Reactor Projects

Docket No. 50-483 License No. NPF-30

Enclosure:

Inspection Report 05000483/2017008 w/ Attachment: Supplemental Information

REGION IV==

Docket:

05000483 License:

NPF-30 Report:

05000483/2017008 Licensee:

Union Electric Company Facility:

Callaway Plant Location:

Junction Highway CC and Highway O Steedman, Missouri Dates:

August 28 - September 26, 2017 Inspectors: R. Alexander, Sr. Project Engineer (Team Leader)

S. Alferink, Reactor Inspector D. Bradley, Sr. Resident Inspector - Callaway M. Stafford, Project Engineer Approved By:

Nicholas H. Taylor Chief, Project Branch B Division of Reactor Projects

SUMMARY

IR 05000483/2017008; 08/28/2017 - 09/26/2017; Callaway Plant;

Temporary Instruction 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, issued December 23, 2015.

The inspection covered a one-week inspection by the resident inspector and three inspectors from the Region IV office. No findings were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.

NRC-Identified and Self-Revealing Findings

None

Licensee-Identified Violations

None

REPORT DETAILS

4. Other Activities

4OA5 Other Activities (TI 2515/191)

The objective of Temporary Instruction (TI) 2515/191 Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, is to verify that licensees have adequately implemented the mitigation strategies as described in the licensees Final Integrated Plan (ADAMS Accession No. ML16189A304) and the NRCs plant safety evaluation (ADAMS Accession No. ML17010A332) and to verify that the licensees installed reliable water level measurement instrumentation in their spent fuel pools. The purpose of this TI is also to verify the licensees have implemented Emergency Preparedness (EP) enhancements as described in their site-specific submittals and NRC safety assessments, including multi-unit dose assessment capability and enhancements to ensure that staffing is sufficient and communications can be maintained during such an event.

The inspection verified that plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, (ADAMS Accession No. ML12229A174) and EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation, (ADAMS Accession No. ML12056A044) are in place and are being implemented by the licensee. Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012, request for information letter and multiunit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 (ADAMS Accession No. ML12339A262).

The team discussed the plans and strategies with plant staff, reviewed documentation, and where appropriate, performed plant walk downs to verify that the strategies could be implemented as stated in the licensees submittals and the NRC staff-prepared safety evaluation. For most strategies, this included verification that the strategy was feasible, procedures and/or guidance had been developed, training had been provided to plant staff, and required equipment had been identified and staged. Specific details of the teams inspection activities are described in the following sections.

1. Mitigation Strategies for Beyond-Design-Basis External Events

a. Inspection Scope

The team examined the licensees established guidelines and implementing procedures for the beyond-design-basis mitigation strategies. The team assessed how the licensee coordinated and documented the interface/transition between existing off-normal and emergency operating procedures with the newly developed mitigation strategies. The team selected a number of mitigation strategies and conducted plant walk downs with licensed operators and responsible plant staff to assess: the adequacy and completeness of the procedures, familiarity of operators with the procedure objectives and specific guidance, staging and compatibility of equipment, and the practicality of the operator actions prescribed by the procedures, consistent with the postulated scenarios.

The team verified that a preventive maintenance program had been established for the FLEX portable equipment and that periodic equipment inventories were in place and being conducted. Additionally, the team examined the introductory and planned periodic/refresher training provided to the Operations and Security staffs most likely to be tasked with implementation of the FLEX mitigation strategies. The team also reviewed the introductory and planned periodic training provided to the Emergency Response Organization personnel.

b. Assessment

Based on samples selected for review, the team verified that the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is generally in compliance with NRC Order EA-12-049. The team verified that the licensee satisfactorily:

  • Developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX strategies for postulated external events,
  • Integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs are clear when using existing plant procedures,
  • Protected FLEX equipment from site-specific hazards,
  • Developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability,
  • Trained their staff to assure personnel proficiency in the mitigation of beyond-design-basis events, and
  • Developed means to ensure that the necessary off-site FLEX equipment will be available from off-site locations.

The team verified that any non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.

c. Findings

No findings identified.

2. Spent Fuel Pool (SFP) Instrumentation

a. Inspection Scope

The team examined the licensees newly installed spent fuel pool instrumentation.

Specifically, the team verified the sensors were installed as described in the plant specific submittals and the associated safety evaluation and that the cabling for the power supplies and the indications for each channel are physically and electrically separated. Additionally, environmental conditions and accessibility of the instruments were evaluated. Documents reviewed are listed in the attachment.

b. Assessment

Based on samples selected for review, the team determined that the licensee satisfactorily installed and established control of the SFP instrumentation as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is generally in compliance with NRC Order EA-12-051. The team verified that the licensee satisfactorily:

  • Installed the SFP instrumentation sensors, cabling and power supplies to provide physical and electrical separation as described in the plant specific submittal and safety evaluation;
  • Installed the SFP instrumentation display in the location, environmental conditions and accessibility as described in the plant specific submittals; and
  • Trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation.

The team verified that any non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.

c. Findings

No findings identified.

3. Staffing and Communication Request for Information

a. Inspection Scope

Through discussions with plant staff, review of documentation and plant walk downs, the team verified that the licensee has implemented required changes to staffing, communications equipment, and facilities to support an Extended Loss of All AC Power (ELAP) scenario as described in the licensees staffing assessment and the NRC safety assessment. The team also verified that the licensee has implemented dose assessment (including releases from spent fuel pools) capability using the licensees site-specific dose assessment software and approach as described in the licensees dose assessment submittal. Documents reviewed are listed in the attachment.

b. Assessment

The team reviewed information provided in the licensees multi-unit dose submittal and in response to the NRCs March 12, 2012, request for information letter and verified that the licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force Recommendation 9.3 response to a large scale natural emergency event that results in an extended loss of all ac power to the site and impedes access to the site.

The team verified the following:

  • Licensee satisfactorily implemented required staffing change(s) to support an ELAP scenario,
  • Implemented dose assessment capabilities (including releases from spent fuel pools)using the licensees site-specific dose assessment software and approach.

The team verified that any non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.

c. Findings

No findings identified.

4OA6 Exit

Exit Meeting Summary

On September 1, 2017, the team presented the on-site inspection results in a management debrief to T. Herrmann, Site Vice President, and other members of the site staff. The inspectors confirmed that proprietary information examined during the inspection had been returned to the licensee. The team lead completed an exit meeting conducted with S. Banker, Senior Director, Engineering, and other members of the site staff, via telephone on September 26, 2017, to discuss the final results of the inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

S. Abel, Director, Engineering Projects
A. Alley, Engineering Program Supervisor
S. Banker, Senior Director Engineering
F. Bianco, Director, Nuclear Operations
J. Cortez, Director, Training
M. Covey, Manager, Operations
B. Cox, Senior Director Nuclear Operations
D. Farnsworth, Director, Work Management
T. Herrmann, Site Vice President
T. Holland, Shift Manager
B. Huhmann, Regulatory Affairs Supervisor
B. Jungmann, Director, Maintenance
S. Kovaleski, Director, Engineering Design
G. Kremer, Director, Engineering Programs
M. McLachlan, Senior Director Plant Support
K. Mills, Director, Engineering Systems
T. Moser, Director, Nuclear Projects
J. Nurrenbern, FLEX Program Engineer
E. Olson, Director, Engineering Programs
J. Patterson, Director, Nuclear Projects
E. Ptasznik, Licensing Engineer
S. Sandbothe, Director, Plant Support
D. Stepanovic, Manager, Materials

NRC Personnel

S. Janicki, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Closed

2515/191 TI Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, issued December 23, 2015

LIST OF DOCUMENTS REVIEWED

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