ML17170A091

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 Request for

ML17170A091
Person / Time
Site:	Callaway
Issue date:	06/19/2017
From:	Ryan Alexander, John Dixon NRC/RGN-IV/DRP/RPB-B
To:	Diya F Ameren Corp
Dixon J
References
TI-2515/191 IR 2017008
Download: ML17170A091 (7)

See also: IR 05000483/2017008

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E. LAMAR BLVD.

ARLINGTON, TX 76011-4511

June 19, 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 - 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 REQUEST FOR INFORMATION

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-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 NRCs 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 NRCs 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.

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 NRCs plant safety evaluations (SEs) and safety

assessments. Therefore, appropriate personnel knowledgeable of the stations FLEX

strategies, spent fuel pool instrumentation, and emergency preparedness enhancements should

be available to support the inspectors at the site during the inspection.

F. Diya 2

We have discussed the schedule for this inspection activity 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 lead 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.

In accordance with 10 CFR 2.390 of the NRCs 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 NRCs 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. 50-483

License No. NPF-30

Enclosure:

FLEX Strategies, Spent Fuel Pool

Instrumentation, & EP Enhancements

Inspection Request for Information

Request for Information

FLEX Strategies, Spent Fuel Pool Instrumentation, & EP Enhancements Inspection

Callaway Plant

Inspection Report: 05000483/2017008

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

Inspectors: 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

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 inspectors 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. 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.

TI 2515/191 - 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-normal, abnormal, and/or emergency procedures where entry

into one or more FLEX Support Guideline(s) are initiated.

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.

E. Provide a list of key pieces 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.

G. Provide a listing of calculations, evaluations, and 50.59 reviews related to the FLEX program

and modifications.

1 Enclosure

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)

(1) If the FLEX water sources are seismically robust, then provide the assessment

that shows that they are.

(2) If the FLEX water sources are not seismically robust, then provide:

(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 for Callaway Plant - 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 plants 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.

(1) Show how you designated and evaluated those pathways for post-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:

(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.

2

6) Extreme high temperatures

For each key piece of equipment described in Item 5 (above) that directly performs or

implements a FLEX mitigation strategy:

(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.

I. Provide the station-specific FLEX strategies time validation study(ies).

J. Provide the relevant station procedure(s)/guideline(s) which describe the testing and

maintenance program for FLEX equipment. 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.]

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, please include copies of those procedures.)

O. A current copy of the U/FSAR, Technical Specifications, and Technical Specification Bases

documents.

P. Listing of corrective action program document summaries generated related to FLEX

equipment, strategies, procedures, and/or training.

Q. A copy of any audits/self-assessments related to your preparation for this inspection, as well

as any related to the implementation or maintenance of the FLEX program.

TI 2515/191 - Appendix B

R. Provide the procedures implemented for maintenance, testing, calibration, and use of the

primary and backup Spent Fuel Pool (SFP) instrumentation channels.

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.

3

TI 2515/191 - 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.

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.

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 EROs ability to utilize the communications systems

and/or equipment.

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-unit/multi-source dose assessment capability).

Lead Inspector Contact Information:

Ryan D. Alexander, Sr. Project Engineer Mailing Address:

817-200-1195 U.S. NRC, Region IV

Ryan.Alexander@nrc.gov Attn: Ryan Alexander, DRP

1600 East Lamar Blvd.

Arlington, TX 76011-4511

4

ML17170A091

SUNSI Review ADAMS: Sensitive Non-Publicly Available Keyword

By: RDA/rdr Yes No Non-Sensitive Publicly Available NRC-002

OFFICE DRP/RPBA C:DRP/RPBB

NAME RAlexander JDixon

SIGNATURE /RA/-E /RA/

DATE 06/14/2017 06/19/2017