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| number = ML17277A053
| number = ML17277A053
| issue date = 10/03/2017
| issue date = 10/03/2017
| title = 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
| 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 = Taylor N H
| author name = Taylor N
| author affiliation = NRC/RGN-IV/DRP/RPB-A
| author affiliation = NRC/RGN-IV/DRP/RPB-A
| addressee name = Diya F
| addressee name = Diya F
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| docket = 05000483
| docket = 05000483
| license number = NPF-030
| license number = NPF-030
| contact person = Taylor N H
| contact person = Taylor N
| case reference number = EA-12-049, EA-12-051
| case reference number = EA-12-049, EA-12-051
| document report number = IR 2017008
| document report number = IR 2017008
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=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:October 3, 2017
[[Issue date::October 3, 2017]]


Mr. Fadi Diya, Senior Vice President and Chief Nuclear Officer Ameren Missouri Callaway Plant P.O. Box 620 Fulton, MO 65251
==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


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/  


==Dear Mr. Diya:==
Nicholas H. Taylor, Chief Project Branch B Division of Reactor Projects
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 Commission's 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 NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's 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  
Docket No. 50-483 License No. NPF-30  


===Enclosure:===
===Enclosure:===
Inspection Report 05000483/2017008 w/  
Inspection Report 05000483/2017008 w/ Attachment: Supplemental Information


===Attachment:===
REGION IV==
Supplemental Information cc w/ encl: Electronic Distribution 1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION 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 2
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=
=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 NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 5.
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.


===A. NRC-Identified and Self-Revealing Findings===
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.
None 


===B. Licensee-Identified Violations===
===NRC-Identified and Self-Revealing Findings===
None 3
None
 
===Licensee-Identified Violations===
None


=REPORT DETAILS=
=REPORT DETAILS=
4. Other Activities  
 
===4. Other Activities===
{{a|4OA5}}
{{a|4OA5}}
==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 licensee's Final Integrated Plan (ADAMS Accession No. ML16189A304) and the NRC's 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 licensee's 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 team's inspection activities are described in the following sections. 1. Mitigation Strategies for Beyond-Design-Basis External Events


==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====
====a. Inspection Scope====
The team examined the licensee's 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 4 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.
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====
====c. Findings====
No findings identified.
No findings identified.


5 2. Spent Fuel Pool (SFP) Instrumentation
===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.


====a. Inspection Scope====
b. Assessment  
The team examined the licensee's 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.
 
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.
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====
====c. Findings====
No findings identified. 3. Staffing and Communication Request for Information
No findings identified.


===3. Staffing and Communication Request for Information===
====a. Inspection Scope====
====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 licensee's 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 licensee's site-specific dose assessment software and approach as described in the licensee's dose assessment submittal. Documents reviewed are listed in the attachment.
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


6 b. Assessment  The team reviewed information provided in the licensee's multi-unit dose submittal and in response to the NRC's 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 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,     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 licensee's site-specific dose assessment software and approach.
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.


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.
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.
Line 79: Line 137:
====c. Findings====
====c. Findings====
No findings identified.
No findings identified.
{{a|4OA6}}
{{a|4OA6}}
==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:
==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=
=SUPPLEMENTAL INFORMATION=


==KEY POINTS OF CONTACT==
==KEY POINTS OF CONTACT==
===Licensee Personnel===
===Licensee Personnel===
: [[contact::S. Abel]], Director, Engineering Projects  
: [[contact::S. Abel]], Director, Engineering Projects  
: [[contact::A. Alley]], Engineering Program Supervisor
: [[contact::A. Alley]], Engineering Program Supervisor  
: [[contact::S. Banker]], Senior Director Engineering  
: [[contact::S. Banker]], Senior Director Engineering  
: [[contact::F. Bianco]], Director, Nuclear Operations  
: [[contact::F. Bianco]], Director, Nuclear Operations  
Line 103: Line 164:
: [[contact::G. Kremer]], Director, Engineering Programs  
: [[contact::G. Kremer]], Director, Engineering Programs  
: [[contact::M. McLachlan]], Senior Director Plant Support  
: [[contact::M. McLachlan]], Senior Director Plant Support  
: [[contact::K. Mills]], Director, Engineering Systems  
: [[contact::K. Mills]], Director, Engineering Systems  
: [[contact::T. Moser]], Director, Nuclear Projects  
: [[contact::T. Moser]], Director, Nuclear Projects  
: [[contact::J. Nurrenbern]], FLEX Program Engineer  
: [[contact::J. Nurrenbern]], FLEX Program Engineer  
: [[contact::E. Olson]], Director, Engineering Programs  
: [[contact::E. Olson]], Director, Engineering Programs  
: [[contact::J. Patterson]], Director, Nuclear Projects  
: [[contact::J. Patterson]], Director, Nuclear Projects  
: [[contact::E. Ptasznik]], Licensing Engineer
: [[contact::E. Ptasznik]], Licensing Engineer  
: [[contact::S. Sandbothe]], Director, Plant Support  
: [[contact::S. Sandbothe]], Director, Plant Support  
: [[contact::D. Stepanovic]], Manager, Materials
: [[contact::D. Stepanovic]], Manager, Materials  
 
===NRC Personnel===
===NRC Personnel===
: [[contact::S. Janicki]], Resident Inspector  
: [[contact::S. Janicki]], Resident Inspector  
 
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
==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    
===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==
==LIST OF DOCUMENTS REVIEWED==
==Section 4OA5: Other Activities Corrective Action Documents
 
: 201106180
: 201408448
: 201601716
: 201605315
: 201605701
: 201605787
: 201607008
: 201607646
: 201607894
: 201607938
: 201609168
: 201609286
: 201700008
: 201700079
: 201701274
: 201702320
: 201703278
: 201703911
: 201703920
: 201704462
: 201704470*
: 201704490*
: 201704488*
: 201704491*
: 201704499*
: 201704501*
: 201704502*
: 20170503*
: 201704509*
: 201704513*
: 201704514*
: 201704515*
: 201704539*
: 201704551* 201704552*==
  * - indicates corrective action document written by the licensee as a result of the NRC inspection
===Procedures===
: Number Title Revision
: APA-ZZ-00102 EOP/OTO Writers Manual 13
: APA-ZZ-00391 Beyond Design Basis (BDB) Program Document 3
: APA-ZZ-00391, Appendix 8 Callaway Plant Final Integrated Plan 1
: APA-ZZ-00500 Corrective Action Program 67
: APA-ZZ-00500, Appendix 17 CAP, Screening Process Guidelines 31
: ECA-0.0 Loss of All AC Power 25
: EDP-ZZ-04600 Engineering Change Control 0
: EIP-ZZ-01211 Accident Dose Assessment 34
: FSG-11 Alternate SFP Makeup and Cooling 3
: FSG-12 Alternate Containment Cooling 2
: FSG-13 Transition from FLEX Equipment 0
: FSG-14 Shutdown RCS Makeup 2
: FSG-3 Alternate Low Pressure Feedwater 3
: FSG-4 ELAP DC Bus Load Shed/Management 3
: FSG-40 FLEX Support Guidelines Flowchart 1
===Procedures===
: Number Title Revision
: FSG-41 FLEX Emergency Communications 1
: FSG-43 Nitrogen and Instrument Air Strategy 3
: FSG-44 FLEX Diesel Fuel Strategy 2
: FSG-45 Temporary Ventilation, Lighting, and Power 2
: FSG-46 Mobile Water Purification Unit 0
: FSG-48 FLEX ESW Pump 1
: FSG-5 Initial Assessment and FLEX Equipment Staging 3
: FSG-50 Freeze Protection for ELAP Response 2
: FSG-51 Temporary Sump Pump Operation 1
: FSG-6 Alternate HCST Makeup 2
: FSG-7 Loss of Vital Instrumentation or Control Power 1
: FSG-9 Low Decay Heat Temperature Control 2
: IP-ENG-001 Standard Design Process 0
: ITL-EC-00L39
: LOOP-LVL; Spent Fuel Pool Lvl 13
: ITL-EC-00L59
: LOOP-LVL; Spent Fuel Pool Primary Level 2
: ITL-ED-00L60
: LOOP-LVL; Spent Fuel Pool Backup Level 2
: ODP-ZZ-00002 Equipment Status Control 88
: ODP-ZZ-00025 EOP/OTO User's Guide 29
: ODP-ZZ-00030 EOP Implementation Guide 12
: OTO-NB-00005 Loss of All AC Power While on RHR 1
: Parent/Model Work Orders Number Title Revision / Date
: 1008428
: FLEXP-HALE-1 (Flex Hale Pump) - 6 month maintenance April 25, 2017
: 1008430
: FLEXP-HALE-1-FLEX P Hale Pump #1 - 12 month maintenance April 25, 2017
: 1008432
: FLEXP-HALE-1-FLEX P Hale Pump #1 - 36 month maintenance plan 0
: 1008589
: FLEXG-480-1-480 Volt FLEX Generator # 1 - 12 month June 21, 2017
: 1008591
: FLEXG-480-1-480 Volt FLEX Generator # 1 - 9 year maintenance plan 0 
: Parent/Model Work Orders Number Title Revision / Date
: 1008643
: FLEXP-SFP-1-fLEX P SFP Pump # 1 - 36 month maintenance plan 0
: 1008645
: FLEXP-SFP-2-FLEX P SF? Pump # 2 - 6 month maintenance June 19, 2017
: 1008656
: FLEXP-SFP-1-FLEX P SFP Pump # 1 - 12 month maintenance June 20, 2017
: 1008678
: FLEXH-WATER-1-FLEX H Water #1 - 36 month electrical inspection plan 0
: 1008692
: FLEXP-AFW-1-FLEX AFW Pump #1 - 6 month battery inspection June 22, 2017
: 1008693
: FLEXP-AFW-1-FLEX AFW Pump #1 - 12 month functional test June 21, 2017
: 1008694
: FLEXP-AFW-1-FLEX AFW Pump #1 - 36 month functional test plan 0
: 1008712 Inventory FLEX Emergency Food and Water Supplies - 12 month inspection August 18, 2017
: 1008807
: FLEXG-240-1-Kubota G1-11000 240 volt generator 1 - 6 month maintenance June 27, 2017
: 1008808
: FLEXG-240-1-Kubota G1-11000 240 volt generator 1 - 36 month maintenance plan 0
: 1008878
: FLEXT-COMMS-01-FLEX T Communications trailer # 1 - 6 month maintenance June 2, 2017
: 1008879
: FLEXT-COMMS-01-FLEX T Communications trailer # 1  - 36 month maintenance plan 0
: 1008967
: FLEXT-FUEL-0 1-FLEX I Fueling Trailer # 1 - 6 month maintenance June 2, 2017
: 1008968
: FLEXT-FUEL-0 1-FLEX I Fueling Trailer # 1 - 36 month maintenance plan 0 14000593.915 Functional Test Passive Antenna Connection to Aux Building 2
===Calculations===
: Number Title Revision / Date 81402-C-001 Development of Enveloped Ground Motion Response Spectra for HCSTF Design 0 81402-C-013 Hardened Condensate Storage Tank Design 0 
: 81402-C-014 Hardened Condensate Storage Tank Facility 0 81402-C-017 Qualification of Ring Net and Framing System for Tornado Missile Loads 0 95599-M-001 1974' Auxiliary Building Flooding Elevation 0
: AMN-003-CALC-017 AFW Hydraulic Calculation for FLEX Piping Configuration 3
: CEC-CS-005-00 Liquefaction Resistance and Post-Earthquake Settlement for ISFSI at Callaway Energy Center 0
: CN-PEUS-12-09 Callaway FLEX Battery Coping Analysis 1
: DAR-SEE-II-12-17 Evaluation of Alternate Coolant Sources for Responding to a Postulated Extended Loss of All AC Power at the Callaway Energy Center 0
: SC-670005-01 Superstructure Design Calculations 0
: SC-670005-03 Missile Impact Evaluation 0 Z-1052-S-002 Robust Missile Barrier Calculation 3
===Miscellaneous===
: Documents/Reports Number Title Revision / Date
: Callaway Plant, Unit 1 - Safety Evaluation Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders
: EA-12-049 and
: EA-12-051 February 2, 2017
: Control Room Operator Logs June 19 - 22, 2017
: NEI 12-02 Phase 2 Extended Loss of Alternating Current Power (ELAP) Emergency Response Organization (ERO) Staffing Analysis Report
: NANTeL Generic Basic FLEX Training 13
: NANTeL Generic Advanced FLEX Training 1
: LOCT Cycle 13-4, 13-5, 14-2, 15-1, 15-2, 15-5 and 16-2 Training Documents
: NLOCT Cycle 13-4, 13-5, 15-1, 15-2 and 15-6 Training Documents
: GET Plant Access Callaway
: I/C Fukushima Seminar
: 51-9242058-002 SAFER Response Plan for Callaway Energy Center
: November 5, 2015
===Miscellaneous===
: Documents/Reports Number Title Revision / Date
: APA-ZZ-00391, Appendix 7 FLEX Validation Documentation 1
: MP 13-0026 Spent Fuel Pool Cooling During BDBEE 0.2
: MP 13-0027 SFP Instrumentation for NRC Order
: EA-12-051 1
: MP 13-0028 RWST Tie-In to Support FLEX Strategies 0
: MP 15-0012 Engineering Disposition: HCST Tank, Protective Barrier System, Valve House, and Electrical Power 007 Self-Assessment 201720030-035 FLEX Program Compliance with NRC Requirements June 12, 2017 T61.OSLPS PRI 1 TRRQ Review for Hardened CST and New FLEX Equipment October 26, 2016 T62.1000.8 Fukushima Event August 14, 2012 T62.1000.8 Fukushima Modifications May 1, 2014 T62.P100.6 Introduction to Plant Emergency Conditions - Part 2 October 28, 2013 T63.0630.8 TRRQ
: 201309537 Westinghouse Guided Wave RADAR Spent Fuel Pool Level Indication System June 18, 2014 T64.0340.8 RP - Station Blackout July 18, 2013 T64.0340.8 RP - Fukushima Modifications July 21, 2015 T64.0340.8 RP - Temp Power to HPAC May 15, 2017 T64.0340.8 RP - Operating Experience July 24, 2012 T64.0360.8 Chemistry - FLEX Debris Removal May 23, 2016 T64.0360.8 Chemistry - FLEX Loss of Power January 14, 2014 T64.0360.8 Chemistry - Atmospheric Hazards July 17, 2015 T64.0360.8 Chemistry Continuing Training January 14, 2014 T67.0200.8 2016-2 Electrical Continuing Training August 1, 2016 T68.SORI.5 Crisis Leadership March 5, 2015 
: ML17277A053
: SUNSI Review By:
: RDA ADAMS
: Yes
: No
: Non-Sensitive
: Sensitive
: Publicly Available
: Non-Publicly Available Keyword:
: NRC-002 OFFICE SPE:DRP/A PE:DRP/C RE:DRS/EB2 SRI:DRP/B BC:DRP/B
: NAME RAlexander MStafford SAlferink DBradley NTaylor
: SIGNATURE /RA/ /RA-E/ /RA-E/ /RA-E/ /RA DProulx Acting for/
: DATE 09/27/17 10/03/17 09/28/17 09/28/17 10/03/17
}}
}}

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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