IR 05000483/2019002
| ML19221B450 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 08/09/2019 |
| From: | O'Keefe N NRC/RGN-IV/DNMS/NMSB-B |
| To: | Diya F Ameren Missouri |
| References | |
| IR 2019002 | |
| Download: ML19221B450 (51) | |
Text
August 9, 2019
SUBJECT:
CALLAWAY UNIT 1 - INTEGRATED INSPECTION REPORT 05000483/2019002
Dear Mr. Diya:
On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Callaway Plant. On July 2, 2019, the NRC inspectors discussed the results of this inspection with Mr. T. Herrmann, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspectors did not identify any finding or violation of more than minor significance.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Neil F. O'Keefe, Chief Reactor Projects Branch B
Docket No.: 05000483 License No.: NPF-30
Enclosure:
Inspection Report 05000483/2019002 With Attachments:
Documents Reviewed Request for Information O
Inspection Report
Docket Number:
05000483
License Number:
Report Number:
Enterprise Identifier: I-2019-002-0006
Licensee:
Union Electric Company
Facility:
Callaway Plant
Location:
Steedman, MO 65077
Inspection Dates:
April 1 to June 30, 2019
Inspectors:
C. Alldredge, Senior Enforcement Specialist
B. Baca, Health Physicist
D. Bradley, Senior Resident Inspector
R. Carrion, Senior Reactor Inspector
P. Elkmann, Senior Emergency Preparedness Inspector
N. Greene, Senior Health Physicist
S. Janicki, Resident Inspector
J. O'Donnell, Health Physicist
B. Tharakan, Senior Project Engineer
D. You, Resident Inspector
Approved By:
Neil F. O'Keefe, Chief
Reactor Projects Branch B
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at the Callaway Plant in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
PLANT STATUS
Callaway began the inspection period at approximately 20 percent power with a planned shutdown in progress for the refueling outage. On April 1, 2019, the licensee shut down the reactor and commenced the planned refueling outage. On April 17, with the reactor defueled and in no Mode, safety-related bus NB01 lost power and was automatically reenergized by the associated emergency diesel generator due to a loss of the 365 kV switchyard bus (NRC Event 54005). On May 11, with the reactor in Mode 4, the licensee identified an auxiliary building door that had been blocked open through reactor Mode ascension (NRC Event 54061).
On May 16, the licensee commenced a reactor startup. Later that day, an automatic reactor trip occurred due to high flux in the source range (NRC Event 54069) when operators failed to block this trip when conditions called for them to do so. On May 17, the licensee commenced a reactor startup. On May 18, the licensee tripped the main turbine due to high vibrations and the reactor remained critical, by design, due to the low power level at the time of the turbine trip.
The licensee restored the main turbine to service and connected the main generator to the electric grid on May 19. The licensee reached full power on May 22 and remained at this power level through the end of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Summer Readiness Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated summer readiness of offsite and alternate alternating current (AC)power systems on June 5, 2019. The inspectors also reviewed the prioritization of efforts to restore offsite power to support Callaway, including a tour of the Ameren Transmission facility in St. Louis, for a design basis loss of offsite power event.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Essential service water trains A and B on April 22, 2019
- (2) Emergency diesel generator train A on April 28, 2019
- (3) Residual heat removal system train B on May 8, 2019
- (4) Main turbine and electro-hydraulic control systems on June 4, 2019
71111.05Q - Fire Protection
Quarterly Inspection (IP Section 03.01) (5 Samples)
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) Switchyard including switchyard control building, fire area S-15 on April 22, 2019
- (2) Spent fuel pool, bridge, and laydown area, fire area FB-1 on May 10, 2019
- (3) Control building 2016' elevation, fire areas C-13, C-15, C-17, and C-35 on May 29, 2019
- (4) Spent fuel pool heat exchanger rooms and cask wash down area, fire area FB-1 on June 4, 2019
- (5) Emergency diesel generator train A and essential switchgear train B, fire areas D-1 and C-10 on June 20, 2019
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 02.02a.) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) Control building 1974' elevation, room 3101, on May 8, 2019
71111.07A - Heat Sink Performance
Annual Review (IP Section 02.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) Component cooling water heat exchanger EEG01A on April 4, 2019
71111.08P - Inservice Inspection Activities (PWR) PWR Inservice Inspection Activities Sample (IP Section 03.01)
The inspectors verified that the reactor coolant system boundary, steam generator tubes, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from April 8 through April 12, 2019:
03.01.a - Nondestructive Examination and Welding Activities
- (1) NDE activity type: Magnetic Particle Testing (MT)a) Pipe to flange weld (FW-01), Job #17002729, Task 180, Report 5010-19-0001, ASME Class 3
b) Pipe to crossover tee weld (FW-17), Job # 17002729, Task 500, Report 5010-19-0008, ASME Class 3
c) Pipe to elbow weld (FW-21), Job # 17002729, Task 500, Report 5010-19-0009, ASME Class 3
d) Pipe to crossover tee weld (FW-10), Job # 17002729, Task 500, Report 5010-19-0012, ASME Class 3
- (2) NDE activity type: Ultrasonic Testing (UT)a) RPV replacement stud 2, Report 19-000245, ASME Class1
- (3) NDE activity type: Visual Testing (VT)a) Fuel transfer system tube and flange, Job #17512708, Task 510, Report 5040-19-002, ASME Class IWE (VT-1)
03.01.b - Pressurized-Water Reactor Vessel Upper Head Penetration Examination Activities
- (1) Penetration numbers 1 through 78, Job #13503632; no indications identified
03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities
- (1) Condition Report 201800861-002, boric acid screen and evaluation
- (2) Condition Report 201801218-001, boric acid screen and evaluation
- (3) Condition Report 201801218-002, boric acid screen and evaluation
03.01.d - No steam generator tube inspections were performed this inspection period 03.01.e - The inspectors reviewed 10 condition reports associated with inservice inspection related topics and determined that the licensee was entering issues into the corrective action program and taking appropriate actions to resolve
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
The inspectors observed and evaluated licensed operator performance in the control room during:
- (1) Reduced reactor coolant system inventory, including infrequently performed test or evolution (IPTE) briefs, on May 5, 2019
- (2) Vacuum fill of the reactor coolant system on May 6, 2019
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
The inspectors observed and evaluated licensed operator training in the simulator for:
- (1) Reactor start-up on May 6, 2019
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness Inspection (IP Section 02.01) (1 Sample)
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
- (1) Essential service water including butterfly valves on April 8, 2019
Quality Control (IP Section 02.02) (1 Sample)
The inspectors evaluated maintenance and quality control activities associated with the following equipment performance activities:
- (1) Residual heat removal train A including hand-switches on June 21, 2019
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) Planned elevated risk during polar crane maintenance and operation on April 4, 2019
- (2) Planned elevated risk for the train A work window on April 8, 2019
- (3) Planned elevated risk during switchyard maintenance on April 2, 2019
- (4) Planned elevated risk for reactor power ascension and recovery of a digital turbine hydraulics controller on May 20, 2019
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 02.02) (6 Samples)
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) Dropped control rod H-8, Condition Report 201901077, on April 12, 2019
- (2) Turbine-driven auxiliary feedwater pump internal inspection results, Condition Report 201902635, on April 17, 2019
- (3) Reactor coolant motor-operated valve BBHV0016 stem nut wear, Condition Report 201902462, on April 18, 2019
- (4) Switchyard breaker MDV45 failure to close, Condition Report 201902658, on April 18, 2019
- (5) Essential service water failure analysis for valves EFHV0065 and EFHV0066, Condition Report 201806521, on May 9, 2019
- (6) Control room air conditioning unit SGK04A degraded cooling capacity, Condition Report 201904050, on May 31, 2019
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following permanent modification:
- (1) Main turbine generator governor controls, MP 08-0027, on April 4, 2019
71111.19 - Post-Maintenance Testing
Post Maintenance Test Sample (IP Section 03.01) (7 Samples)
The inspectors evaluated the following post maintenance tests:
- (1) Polar crane and load cell after equipment outage on April 6, 2019
- (2) Ultimate heat sink cooling tower fans train B after equipment outage on April 12, 2019
- (3) Essential service water modification MP 17-0006 on April 16, 2019
(4)36 kV circuit breaker MDV55 after modification on April 22, 2019
- (5) Main feedwater regulating valves AEFCV0510 and AEFCV0530 after equipment outage on May 5, 2019
(6)125 Vdc battery NK11 after replacement on May 13, 2019
- (7) Load shedding and emergency load sequencing train A after equipment outage on May 19, 2019
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated refueling outage RF23 from April 1 through May 22, 2019
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Inservice Testing (IP Section 03.01)
- (1) Pressurizer power operated relief valve inservice test in Mode 4 on April 3, 2019
- (2) Component cooling water cross tie valves inservice testing on June 2, 2019
Reactor Coolant System (RCS) Leakage Detection Testing (IP Section 03.01) (1 Sample)
- (1) RCS water inventory balance surveillance post-reactor startup from Refueling Outage RF23 on June 19, 2019
Surveillance Tests (other) (IP Section 03.01) (3 Samples)
- (1) Engineered safety features actuation systems train A on April 5, 2019
- (2) Class 1E electrical equipment air conditioning system actuation and flow test on date May 11, 2019
- (3) Turbine-driven auxiliary feedwater pump test in Mode 3 on May 15, 2019
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
- (1) The inspectors evaluated Procedure EIP-ZZ-00101, Addendum 2, "Emergency Action Level Technical Basis Document," Revision 16, on May 1, 2019
This evaluation does not constitute NRC approval.
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
- (1) Team 4 full participation emergency response organization drill on June 6,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Contamination and Radioactive Material Control (IP Section 02.03) (1 Sample)
The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material. The inspectors verified the following sealed sources are accounted for and are intact:
(1)0029GZ (2)3217GN (3)81-616 (4)0819GG/4660
- (5) E-083/S-13
- (6) CNP-148
- (7) MRC-4108 High Radiation Area and Very High Radiation Area Controls (IP Section 02.05) (1 Sample)
The inspectors evaluated risk-significant high radiation area and very high radiation area controls.
Instructions to Workers (IP Section 02.02) (1 Sample)
The inspectors evaluated instructions to workers including radiation work permits used to access high radiation areas:
Radiation work packages
- (1) R23HDDESTUD, Revision 0 - install stud tensioner hoists, deten0sion reactor vessel studs, remove reactor vessel studs, clean stud holes, lubricate stud holes, install stud hole plugs, and install guides studs/pins
- (2) R23HDSTUD18, Revision 0 - Refuel 23 activities to remove reactor vessel stuck stud 18, including thread repairs, and inspect its stud hole; includes cutting, boring, QC/Engineering inspections, and associated cavity work (except cavity decontamination)
- (3) R23STD18DECON, Revision 0 - RF23 upper cavity gross rinse, vacuum of seal ring, upper cavity decontamination, and reactor vessel flange cleaning to support removal of stuck reactor vessel stud 18, includes all Radiation Protection coverage and surveys
- (4) R23ENGHRA, Revision 0 - R23 engineering activities inside high radiation areas in all radiologically controlled areas including the reactor building
(5)
===16003707510, Revision 0 - RT new nipolet to valve weld on Valve EMV0161
Electronic alarming dosimeter alarms
- (1) The licensee did not have an occurrence of a dosimeter alarm during the inspection period. The inspectors reviewed corrective action documents, radiation work permits and ALARA plans, as well as, interviewed workers to ensure the licensee was evaluating and controlling occupational worker exposures appropriately.
Labeling of containers
- (1) Framatome core offloading/reloading and stuck stud removal equipment boxes
- (2) Westinghouse fuel assembly inspection equipment boxes
- (3) Pipefitters equipment boxes for the radiologically controlled area use
- (4) Radioactive material (radioactive source) storage containers
- (5) Radioactive material trash bags in the reactor containment building and auxiliary building Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 02.06)===
The inspectors evaluated radiation worker performance and radiation protection technician proficiency.
Radiological Hazard Assessment (IP Section 02.01) (1 Sample)
The inspectors evaluated radiological hazards assessments and controls. The inspectors reviewed the following:
Radiological surveys
- (1) General containment
- (2) Reactor cavity
- (3) Reactor head
- (4) Inside bioshield
- (5) Incore tunnel
Risk significant radiological work activities
- (1) Reactor head lift
- (2) Refuel activities
- (3) Reactor head stud replacement - stuck stud 2 and 18
- (4) Cavity decontamination
- (5) Radiography
Air sample survey records
- (1) Reactor containment building entries: 29-MAR-19-200005,7,8; and 31-Mar-19-200004, 5, 8
- (2) Reactor containment building outage dailies: 08-APR-19-200008,9,10; 09-APR-19-200012,13,14; and 10-APR-19-200004,5,6
- (3) Reactor cavity: 08-APR-19-200023, 24; 08-APR-19-200025, 26; 09-APR-19-200003,5; 09-APR-19-200006,8; and 10-APR-19-200023, 24
- (4) Reactor head stand O-ring cutout: 10-APR-19-200007,18
- (5) Breach of Valve BGHV8149B: 10-APR-19-200029, 34
Radiological Hazards Control and Work Coverage (IP Section 02.04) (1 Sample)
The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.
Radiological work package for areas with airborne radioactivity
- (1) There were no radiation work permits with airborne radioactivity available for review during this inspection. The inspectors reviewed radiation work permits with the highest potential for airborne radioactivity and the results for air samples taken during the inspection period.
71124.02 - Occupational ALARA Planning and Controls
Implementation of ALARA and Radiological Work Controls (IP Section 02.03) (1 Sample)
The inspectors reviewed ALARA practices and radiological work controls by reviewing the following activities:
- (1) RWP 16003707510, EMV0161 radiography
- (2) RWP R23HDSTUD18, remove stuck stud 18
- (3) RWP R23STD18DECON, RF23 Cavity Decontamination
Radiation Worker Performance (IP Section 02.04) (1 Sample)
The inspectors evaluated radiation worker and radiation protection technician performance during general work in containment, decontamination of the vessel flange in preparation for the removal of stuck stud 2, and during the radiography of EMV0161 in the auxiliary building.
71124.05 - Radiation Monitoring Instrumentation
Calibration and Testing Program (IP Section 02.02) (1 Sample)
The inspectors evaluated the calibration and testing program implementation. The inspectors reviewed the following:
Alarm Setpoint and Calibration Method Check of Personnel Contamination Monitors, Portal Monitors and Small Article Monitors
- (1) TM-4010-HP
- (2) PM-4046-HP
Failure to Meet Calibration or Source Check Acceptance Criteria
- (1) CRM-4190-HP
Walk Downs and Observations (IP Section 02.01) (1 Sample)
The inspectors evaluated radiation monitoring instrumentation during plant walkdowns. The inspectors reviewed the following:
Portable Survey Instruments
- (1) CRM-4025-HP
- (2) CRM-4087-HP
- (3) CRM-4134-HP
- (4) CRM-4023-HP
- (5) CRM-4089-HP
- (6) ION-4174-HP
- (7) GMI-4178-HP Source Check Demonstration
- (1) ION-4172-HP
- (2) CRM-4115-HP
- (3) GMI-4178-HP
Area Radiation Monitors and Continuous Air Monitors (1)0-EG-RE-09 (2)0-GT-RE-33 (3)0-SD-RE-24 (4)0-SD-RE-38
- (5) CAM-4019-HP
- (6) CAM-4020-HP
Personnel Contamination Monitors, Portal Monitors and Small Article Monitors
- (1) TM-4010-HP
- (2) PCM-4054-HP
- (3) PM-4046-HP
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Calibration and Testing Program (Process & Effluent Monitors) (IP Section 02.02) (1 Sample)
The inspectors reviewed the following gaseous and liquid effluent monitor instrument calibrations and tests:
- (1) GH-RE-10 radwaste building unit vent functional test, June 13, 2019
- (2) GT-RE-21A plant unit vent calibration, January 29, 2019
- (3) GT-RE-21B plant unit vent calibration, August 23, 2018
- (4) HB-RE-18 liquid radwaste discharge monitor calibration, August 21, 2018
Dose Calculations (IP Section 02.05) (1 Sample)
The inspectors reviewed the following liquid and gaseous discharge permits to evaluate public dose calculations:
- (1) Batch liquid radioactive release permit numbers:
- RP09-2019-L0037;0
- RP09-2018-L0007;1
- RP09-2017-L0028;1
- (2) Batch airborne radioactive release permits:
- RP11A-2019-G0013;1
- RP13-2018-G0002;56
- RP13-2017-G0006;52 The inspectors reviewed the following annual radiological effluent release reports:
(1)2017 Annual Radiological Effluent Release Report (2)2018 Annual Radiological Effluent Release Report
The inspectors also reviewed the following abnormal gaseous or liquid tank discharges:
- (1) None were available for review during this inspection
Instrumentation and Equipment (IP Section 02.04) (1 Sample)
The inspectors reviewed the following radioactive effluent discharge system surveillance test results:
- (1) Auxiliary/fuel building emergency exhaust filter adsorber Unit B, in-place leak test
- (2) Control room pressurization filter adsorber Unit B, in-place leak test
- (3) Control room filter adsorber Unit A, in-place leak test
Sampling and Analysis (IP Section 02.03) (1 Sample)
The inspectors reviewed the following radioactive effluent sampling and analysis activities:
- (1) None were available for review during this inspection
The inspectors reviewed the following effluent discharge:
- (1) June 11, 2019, discharge monitor tank A discharge
Walk Downs and Observations (IP Section 02.01) (1 Sample)
The inspectors walked down the following gaseous and liquid radioactive effluent monitoring and filtered ventilation systems to assess the material condition and verify proper alignment according to plant design:
- (1) Liquid radwaste treatment system
- (2) Gaseous radwaste treatment system
71124.07 - Radiological Environmental Monitoring Program
Groundwater Protection Initiative (GPI) Implementation (IP Section 02.02) (1 Sample)
The inspectors evaluated the licensee's voluntary groundwater protection initiative through review of licensee documented leaks and spills since the last inspection, groundwater sampling results, and any changes to the licensee's groundwater sampling, ground water protection initiative, and spill and leak program and procedures. The inspectors reviewed and observed selected onsite groundwater locations as delineated in the licensee's program to ensure timely identification of inadvertent releases into the groundwater. The licensee had no entries of spills or leaks into their 10 CFR 50.75(g) records since the last inspection.
The licensee is continuing to monitor tritium through monitoring wells MW-31, MW-34, MW-36, MW-39, MW-47, MW-58, and MW-59. In 2017, the licensee identified a peak concentration in monitoring well MW-31 of 1,688 picoCuries per liter (pCi/l) in January which decreased by the end of the year to 278 pCi/l. In 2018, monitoring well MW-58 peaked at 911 pCi/l in January and decreased to 516 pCi/l by October. The licensee reported their sampling results in each respective annual radiological environmental operating report. The licensee is continuing to monitor the tritium levels and the continued decrease through natural attenuation.
Site Inspection (IP Section 02.01) (1 Sample)
The inspectors evaluated the radiological environmental monitoring program implementation:
Walkdowns, Calibrations, and Maintenance Record Review
- (1) Air sampling stations: A1, A7, A8, A9, A10, and A11
- (2) Thermoluminescent dosimeter (TLD) locations: 03, 05, 06, 21, 22a, 44, 45, 46, 47, and 61
- (3) Air sampler pump calibrations: LAS-4179, LAS-4182, and LAS-4201
- (4) Meteorological tower instrument calibrations
Environmental Sample Collections and Preparation Observation
- (1) Vegetation samples from three sample locations: V9, V11, and V16
- (2) Surface water grab samples from S01 and S02 locations
Licensee Actions in Response to Missed Sample, Inoperable Sampler, Lost TLD or Anomalous Measurement
- (1) Licensee instituted compensatory sampling for selected surface water sampling locations (S01 and S02) due to flooding conditions
- (2) Licensee replaced older air sampling pumps with new F&J pumps
- (3) Licensee converted air sample stations from a straight line sample port to an overhanging goose neck configuration
- (4) Missed environmental samples were evaluated for nominal equipment failures, aged equipment issues, power source issues, and sample reliability. The licensee made repairs, replaced equipment, and adjusted sampling locations to fulfill the environmental sampling program requirements. All missed and anomalous results were reported in the annual radiological environmental operating report.
Sampling Program for the Potential of Licensed Material Entering Groundwater
- (1) The inspectors reviewed data from and observed the following sampled groundwater wells: U1MW-31, U1MW-937D, U1MW-939R, U1MW-940, U1MW-941, and U1MW-GW
71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,
and Transportation
Radioactive Material Storage (IP Section 02.01)
The inspectors evaluated radioactive material storage in the follow areas:
- (1) Low Level Drum Storage Area (55-gallon drums)
- (2) Radwaste north yard
- (3) Radwaste south yard
The inspectors performed a container check (e.g., swelling, leakage and deformation) on the following containers:
(1)9563, sludge oil solidified waste (2)9673, solidified waste (3)9677, solidified waste (4)9687, solidified waste (5)9709, SLW sludge solidified waste (6)9710, oily waste (7)
16145, SGBD resin Radioactive Waste System Walkdown (IP Section 02.02)
The inspectors evaluated the following radioactive waste processing systems [and processes] during plant walkdowns:
Liquid or Solid Radioactive Waste Processing Systems
- (1) Self-engaging dewatering system
Radioactive Waste Resin and/or Sludge Discharges Processes
- (1) Resin handling system for spent resin and charcoal
Shipment Preparation (IP Section 02.04) (1 Sample)
The inspectors evaluated [and observed] the following radioactive material shipment preparation processes:
(1)19-021, UN2912, radioactive material, LSA-I, Class 7, resin, June 11, 2019
Shipping Records (IP Section 02.05) (1 Sample)
The inspectors evaluated the following non-excepted package shipment records:
(1)17-010, UN3321, radioactive material, LSA-II, Class 7, drummed mechanical filters, June 22, 2017
(2)17-012, UN3321, radioactive material, LSA-II, Class 7, dewatered resin, July 12, 2017 (3)17-061, UN2912, radioactive material, LSA-I, Class 7, dry active waste CYC 21, November 17, 2017
(4)18-001, UN3321, radioactive material, LSA-II, Class 7, dewatered resin and charcoal, January 12, 2018
(5)18-010, UN2911, radioactive material, Excepted Package, Class 7, instruments, April 12, 2018
(6)18-018, UN2911, radioactive material, Excepted Package, Class 7, instruments, September 20, 2018
(7)18-036, UN2912, radioactive material, LSA-I, Class 7, dry active waste, December 26, 2018
(8)19-005, UN3321, radioactive material, LSA-II, Class 7, resin and charcoal, March 19, 2019
Waste Characterization and Classification (IP Section 02.03) (1 Sample)
The inspectors evaluated the radioactive waste characterization and classification for the following waste streams:
(1)14Aug17-200011GEL, FBG02A BTRS Resin 2017, August 1, 2017 (2)17Aug17-200011FBGD, FBG02D BTRS Resin, August 17, 2017 (3)09MAR200018 DAW1, DAW CYCLE 22, March 8, 2018 (4)18APR18-200020 PV3/6, ALPS PV3/PV6 Resin, April 18, 2018 (5)07May18-200011(PV1), ALPS PV-1 Charcoal 2019, May 1, 2018 (6)16AUG18-200010(PV3), ALPS PV-3 Resin, August 15, 2018 (7)18Jan19-200021(PV2), ALPS PV-2 Charcoal 2019, January 15,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
BI02: RCS Leak Rate Sample (IP Section 02.11)===
- (1) April 1, 2018 through March 31, 2019
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (1 Sample)
- (1) April 1, 2018 through March 31, 2019
MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)
- (1) April 1, 2018 through March 31, 2019
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) October 1, 2018, through March 31, 2019 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences
Sample. (IP Section 02.16) (1 Sample)
- (1) October 1, 2018, through March 31, 2019
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Instrument air pressure control valves on June 22, 2019
Semiannual Trend Review (IP Section 02.02) (1 Sample)
The inspectors reviewed the licensees corrective action program for potential adverse trends in troubleshooting equipment issues when the cause of a deficiency is not immediately clear and for a trend in safety-related door issues on June 3, 2019.
71153 - Followup of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)
- (1) The inspectors evaluated essential service water valve EHV0066 valve coupling failure and the licensees response on April 12, 2019
Personnel Performance (IP Section 03.03) (2 Samples)
- (1) The inspectors evaluated an automatic reactor trip and the licensees performance on May 17, 2019
- (2) The inspectors evaluated a manual turbine trip and the licensees performance on May 18,
INSPECTION RESULTS
Observation: Semi-Annual Trend Review 71152 The inspectors reviewed the licensees corrective action program, performance indicators, system health reports, and other documentation to identify trends that might indicate the existence of a more significant safety issue for troubleshooting equipment issues when the cause of a deficiency is not immediately clear and for a trend in safety-related door issues.
The following troubleshooting examples were reviewed by the inspectors for 2019 where the licensee was unable to positively identify the cause or correct the apparent condition:
- Condition Report 201900105: The P-9 bistable light was found unexpectedly not lit during a routine control room walkdown. The licensee decided to make an unplanned entry into the reactor trip instrumentation technical specification based on the indication. The licensee determined there were no activities in progress that affected the indication, verified that that the P-9 bistable was in the correct state, and a lamp test confirmed the light bulb was functioning. The P-9 bistable light then spontaneously relit and the licensee exited Technical Specification 3.3.1. The licensee concluded that that the observed condition appeared to be an indication problem only but was unable to find a clear cause. The licensee later inspected and re-lamped indicator lights for this issue.
- Condition Report 201901077: Control rod H-8 dropped while operating control rod bank D. Extensive troubleshooting by the licensee could not determine a conclusive reason for the control rod drop. After performing an undetermined cause risk assessment per Procedure MDP-ZZ-TR001, Planning and Execution of Formal Troubleshooting Activities, the licensee recovered the rod. The licensee discussed the condition with the vendor, reviewed industry operating experience, and later performed inspections of the control rod drive mechanism during the refueling outage.
After eliminating other possible causes, the licensee concluded that the probable cause was crud in the latching mechanism.
- Condition Report 201903494: When the train B motor-driven auxiliary feedwater pump suction check valve failed its breakaway torque checks, the licensee decided to make an unplanned entry into the auxiliary feedwater system technical specification.
The licensee conducted an inspection of the valve's internals which did not identify an obvious cause for the increased torque required to operate the check valve. The licensee later concluded the valve packing was the cause of the increased resistance.
The licensee returned the check valve to service following an adjustment of the valve packing and a successful performance of the torque check. Although a clear cause was not identified, the licensee took steps to eliminate other possible causes and took corrective action to improve operating torque.
The inspectors noted that the for these three examples, the licensee conservatively declared the equipment inoperable and initiated timely actions to identify the cause of the condition.
When the condition self-cleared or the cause could not be positively identified, the licensee ensured that they ruled out the known possible causes and took appropriate corrective actions to try to address the problem. The inspectors verified that all issues were addressed within the scope of the corrective action program and that the completed and planned corrective actions were appropriate to correct the identified causes. The inspectors did not identify any trends or concerns that might be indicative of a more significant safety issue for troubleshooting equipment issues when the cause of a deficiency is not immediately clear.
The inspectors also reviewed an apparent trend in problems with doors that were important to safety. After the NRC identified Green non-cited violation 05000483/2018002-02 (ADAMS ML18221A398), an auxiliary building door that was blocked open during Mode ascension (NRC Event 54061), and damaged door seals identified by the NRC which were documented in Condition Report 201903536, the licensee wrote Condition Report 201904398 to evaluate 34 condition reports generated in 2019 for an adverse trend in door issues. The licensee recognized gaps in their staffs understanding of functions performed by doors, identifying degraded conditions (including during use), and timely resolution of the issues identified. The inspectors noted that condition reports were being appropriately generated for individual deficiencies but that programmatic issues remain to be addressed. The inspectors noted that many of the condition reports are the result of a concerted effort to identify door issues at a low threshold. The inspectors concluded that the licensee appropriately identified this trend in safety-related door issues and was acting to address the causes.
Overall, the inspectors concluded that the licensee demonstrated a low threshold for issue identification and documentation in the corrective action program. The licensee applied a risk-based approach to ensure corrective actions are completed commensurate with an issues safety significance. The inspectors did not identify any additional trends or concerns that might be indicative of a more significant issue with safety-related doors.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On July 2, 2019, the inspectors presented the integrated inspection results to Mr. T. Herrmann, Site Vice President, and other members of the licensee staff.
- On April 12, 2019, the inspectors presented the occupational radiation safety inspection results to Mr. T. Herrmann, Site Vice President and other members of the licensee staff.
- On April 12, 2019, the inspectors presented the inservice inspection results to Mr. T. Herrmann, Site Vice President and other members of the licensee staff.
- On June 14, 2019, the inspectors presented the public radiation safety inspection results to Mr. B. Cox, Assistant Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective
Action
Documents
Condition Reports
201104350, 201900304, 201903907, 201903907
Miscellaneous
ULDBD-GF-001
Miscellaneous Building HVAC
Procedures
EDP-ZZ-01129
Callaway Plant Risk Assessment
Procedures
ODP-ZZ-0016E
Operations Technician Watchstation Practices and
Rounds
Procedures
PDP-ZZ-00027
Summer Readiness Program
Corrective
Action
Documents
Condition Reports
201702402, 201806793, 201807138
Procedures
OTN-EJ-00001
Residual Heat Removal System
Miscellaneous
MP 16-0024
SGK05 Supplemental Fan System
Miscellaneous
Various
Fire Pre-plan Manual
Procedures
APA-ZZ-00703
Fire Protection Operability Criteria and Surveillance
Requirements
Procedures
APA-ZZ-00750
Hazard Barrier Program
Miscellaneous
PM0900506
Walkdown of the RWST FDN and Valve House
Miscellaneous
PM1009292
Clean Debris from UHS Cooling Tower Fan Deck
Drains
Procedures
Maintenance Rule Structures Inspection
Corrective
Action
Documents
Condition Reports
201902062, 201902231, 201902396, 201902456,
201902921
Work Orders
16506165, 17513066
Corrective
Action
Documents
Condition Reports
201800861, 201801218, 201804786, 201804794,
201804816, 201901976
Corrective
Action
Documents
Resulting from
Condition Reports
201902288
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Inspection
Engineering
Evaluations
Condition Reports
201800861-002, 201801218-001, 201801218-002
Miscellaneous
Callaway Nuclear Plant Containment Exterior
Concrete and Tendon Inspection Program
Miscellaneous
Callaway Nuclear Plant Containment Pressure
Boundary ISI Program, ASME Section XI, Subsection
Miscellaneous
Fourth Interval Inservice Inspection Program Plan,
Fourth Interval Inservice Inspection Program Plan
Miscellaneous
Fourth Interval Inservice Inspection Program Plan
Miscellaneous
Fourth Interval Inservice Inspection Program Plan
Appendix A, Code Cases and Requests for
Relief/Alternative Applied to the Fourth Interval
Miscellaneous
Fourth Interval Inservice Inspection Program Plan
Appendix A, Code Cases and Requests for
Relief/Alternative Applied to the Fourth Interval
- Draft
Miscellaneous
NDE Personnel Qualifications for D. Davis and W.
Thomas
Miscellaneous
Welding Personnel Qualifications for
- A. Carroll, M.
Collier,
- A. Weisacosky, and C.
Wood
Miscellaneous
Relief Request I4R-
Relief from the Requirements of the ASME Code,
Section XI, Table IWF-2500-1 for 100 Percent Visual
Examination of Class 1 Supports
Miscellaneous
Relief Request I4R-
Request for Alternative Applicable to the Fourth 10-
Year Inspection Program Interval
Miscellaneous
Specification C-
1003(Q)
Inservice Inspection of the Containment Post-
Tensioning System and Exterior Concrete Shell
NDE Reports
Job #13503632,
Task 500
RPV Head Bare Metal Examination Summary, ASME
Code Class 1
04/13/19
NDE Reports
Report 5010-19-
0001
Pipe to flange weld (FW-01), Job # 17002729, Task
180, ASME Class 3
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NDE Reports
Report 5010-19-
0008
Pipe to crossover tee weld (FW-17), Job # 17002729,
Task 500, ASME Class 3
NDE Reports
Report 5010-19-
0009
Pipe to elbow weld (FW-21), Job # 17002729, Task
500, ASME Class 3
NDE Reports
Report 5010-19-
0012
Pipe to crossover tee weld (FW-10), Job # 17002729,
Task 500, ASME Class 3
NDE Reports
Report 5040-19-
2
Fuel Transfer System Tube and Flange, Job #
17512708, Task 510, ASME Class IWE
NDE Reports
Report: 19-000245
Component: 2-CH-STUD-02-R2, Component
Description: RPV Stud #2 2nd Replacement, ASME
Code Class 1
04/29/19
Procedures
APA-ZZ-00661
Administration of Welding
Procedures
APA-ZZ-00662
ASME Section XI Repair/Replacement Program
Procedures
EDP-ZZ-01003
Inservice Inspection Program
Procedures
EDP-ZZ-01004
Boric Acid Corrosion Control Program
Procedures
Containment Post-Tensioning System Inspection
Procedures
ASME Section XI IWE Containment Pressure
Boundary Inspection
Procedures
LMT-08-PDI-UT-5
Straight Beam Ultrasonic Examination of Bolts and
Studs
Procedures
MDP-ZZ-LM001
Fluid Leak Management Program
Procedures
MTW-ZZ-WP002
Welder Performance Qualification
Procedures
MTW-ZZ-WP003
Control of Welding Filler Materials
Procedures
MTW-ZZ-WP006
Qualification of Welding Procedures
Procedures
QCP-ZZ-05040
Visual Examination to ASME VT-1
Procedures
QCP-ZZ-05041
Visual Examination to ASME VT-2
Procedures
QCP-ZZ-05042
Visual Examination to ASME VT-3
Procedures
QCP-ZZ-05048
Boric Acid Walkdown for RCS Pressure Boundary
Procedures
QCP-ZZ-05049
RPV Head Bare Metal Examination
Self-
Assessments
Self-Assessment
201309684-08
Material Degradation Management Plan
09/4/2014
Self-
Assessments
Self-Assessment
201309684-31
ISI Program, dated 6/20/14
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
17002729/180, 17002729/00, 17002729/40,
17992729/580
Corrective
Action
Documents
Condition Reports
201902794, 201901943, 201903344, 201903353,
201903360, 201903366, 201903372
Procedures
OTG-ZZ-00002
Reactor Startup - IPTE
Procedures
OTG-ZZ-00003
Plant Startup Hot Zero Power to 30% Power
Procedures
OTN-BB-00001
Procedures
ODMI 19-0002
Tuning Parameter Adjustments on Digital Controls
Post Mod Testing
OOA-ZZ-SSM01
Shutdown Safety Monitoring (SSM)
Corrective
Action
Documents
Condition Reports
201806521, 201902462, 201904050
Procedures
EDP-ZZ-01114
Motor Operated Valve Program Guide
Procedures
MTE-ZZ-QA006
Motor Operated Valve Analyst Guide
Work Orders
19002798
Corrective
Action
Documents
Condition Reports
201805239, 201902591, 201902876, 201903026,
201903553
Procedures
OTN-MD-00001
Switchyard Breakers and Disconnects
Work Orders
18000062, 18000065, 19001674
Corrective
Action
Documents
Condition Reports
201903004
Procedures
ITM-BB-L0053
BBLT0053A/B/BB Fill Vent and Calibration
Procedures
RCS Heatup and Cooldown Limitations
Procedures
OTA-RK-00018
Annunciator Response Procedure MCB Panel RK018
Corrective
Action
Documents
Condition Reports
201902874, 201902927, 201903657, 201903953,
201904075, 201904191
Procedures
Turbine Driven Aux Feedwater Pump Inservice Test -
Group B
Procedures
RCS Inventory Balance
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
PORV Inservice Test
Work Orders
17001333, 17001334, 17003817, 17512419,
17512680, 17513093, 17514041, 17514487,
19507557, 19507663, 19507685, 19507835
Corrective
Action
Documents
Condition Reports
201900315, 201900883, 201900908, 201900930,
201901021, 201901659, 201901908, 201901995
Miscellaneous
Air Sample Log
Various Air Sample Logs
01/16/2019
-
04/10/2019
Miscellaneous
PM1002835
Non-Special Nuclear Material RAM Stored in the
Spent Fuel Pool
Miscellaneous
Source Leak
Checks
Various Source Leak Checks
01/18/2017 -
01/25/2019
Procedures
APA-ZZ-01000
Callaway Energy Center Radiation Protection
Program
046
Procedures
APA-ZZ-01000,
Appendix A
Control of Radioactive Material
Procedures
APA-ZZ-01004
Radiological Work Standards
Procedures
HDP-ZZ-01200
Radiation Work Permits
Procedures
HDP-ZZ-01500
Radiological Postings
Procedures
HDP-ZZ-03000
Radiological Survey Program
Procedures
HDP-ZZ-06000
Contamination Control and Alpha Monitoring Program
Procedures
HSP-ZZ-00001
Radioactive Sealed Source Leak Check Surveillance
Procedures
HTP-ZZ-01203
Radiological Area Access Control
Procedures
HTP-ZZ-02005
Handling of Radioactive Material
Procedures
HTP-ZZ-06001
High Radiation / Locked High Radiation / Very High
Radiation Area Access
Procedures
HTP-ZZ-06028
Radiological Controls for Pools that Contain or Store
Spent Fuel
Procedures
HTP-ZZ-06042
Industrial Radiography Using a Radioactive Source
Radiation
Surveys
CA-M-20190401-10
RB2000I Mode 3 Survey
04/10/2019
Radiation
CA-M-20190402-24
R23 RB Lower Cavity Blind Flange Removal
04/02/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Surveys
Radiation
Surveys
CA-M-20190402-31
RB2023I Regen HX Post Shielding Survey
04/02/2019
Radiation
Surveys
CA-M-20190404-31
RB2023I Scaffold Build to BG1E0126
04/04/2019
Radiation
Surveys
CA-M-20190406-09
RBHead - Reactor Head Lift
04/06/2019
Radiation
Surveys
CA-M-20190408-05
RB-2000-I G/A Five Days After CRUD Burst
04/08/2019
Radiation
Surveys
CA-M-20190408-25
Reactor Vessel Head (On Stand)
04/06/2019
Radiation
Surveys
CA-M-20190410-26
Gross Cavity Decon
04/10/2019
Radiation
Surveys
CA-M-20190410-27
Rx Shield Plate Install Post Survey
04/10/2019
Radiation Work
Permits (RWPs)
R23ENGHRA
RF23 Engineering Activities Inside High Radiation
Areas in all RCA Areas Including the Reactor Building.
Radiation Work
Permits (RWPs)
R23FUEL
RF23 Offload Reactor, Perform FOSAR, Perform
Reactor Reload, Core Mapping, Insert Shuffle, Pool
Mapping, B5B Moves, and Miscellaneous Support
Activities.
Radiation Work
Permits (RWPs)
R23HDDESSTUD
RF23 Install Stud Tensioner Hoists, Detension
Reactor Vessel Studs, Remove Reactor Vessel Studs,
Clean Stud Holes, Lubricate Stud Holes,
Install Stud Hole Plugs, and Install Guides Studs/Pins.
Radiation Work
Permits (RWPs)
R23HDSTUD18
RF23 Activities to Remove Reactor Vessel Stuck Stud
18, Including Thread Repairs, and Inspect Its Stud
Hole. Includes Cutting,
Boring, QC/Engineering Inspections, and Associated
Cavity Work (Except Cavity Decontamination).
Radiation Work
Permits (RWPs)
R23RCPCHANGE
RF23 Motor Change on A Reactor Coolant Pump and
Associated Tasks.
Radiation Work
Permits (RWPs)
R23STD18DECON
RF23 Upper Cavity Gross Rinse, Vacuum of Seal
Ring, Upper Cavity Decontamination, and RV Flange
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Cleaning to Support Removal of
Stuck RV Stud #18. Includes all RP Coverage and
Surveys.
Self-
Assessments
AP18006
Nuclear Oversight Audit of Radiological and Non
Radiological Environmental Monitoring Programs
06/13/2018
Corrective
Action
Documents
Condition Reports
2018-02443, 2018-02930, 2018-02953, 2018-04531,
2018-04758, 2018-04903, 2018-05952, 2018-06019,
2018-06973, 2019-00904, 2019-00908, 2019-00998,
2019-01277, 2019-01355
Miscellaneous
RF23 Plant ALARA Review Committee (PARC)
Meeting
01/24/2019
Miscellaneous
RT Examination of 1" SCH 80 Pipe Weld in Room 113
of Aux Building Shot Plan
04/09/2019
Miscellaneous
Powering into the Future - Callaway Refuel 23 Daily
News Flyer
04/08/2019 -
04/11/2019
Miscellaneous
Refuel 23 Outage Update & Shiftly SOM Turnover
04/08/2019 -
04/11/2019
Miscellaneous
Callaway Radiation Protection Current Log
04/11/2019
Miscellaneous
CA2943
Radiography Checklist - Radioactive Source
04/09/2019
Miscellaneous
Reactor Vessel
Stuck Stud
Removal Project
01/31/2019
Procedures
APA-ZZ-01000
Callaway Energy Center Radiation Protection
Program
Procedures
APA-ZZ-01001
Callaway Plant ALARA Plant
Procedures
APA-ZZ-01004
Radiological Work Standards
Procedures
HDP-ZZ-01100
ALARA Planning and Review
Procedures
HDP-ZZ-01200
Radiation Work Permits
Procedures
HDP-ZZ-01500
Radiological Postings
Procedures
HDP-ZZ-06000
Contamination Control and Alpha Monitoring Program
Procedures
HTP-ZZ-01101
Administrative Controls for Radiation Shielding
Procedures
HTP-ZZ-01104
Hot Spot Trending Program
Procedures
HTP-ZZ-01203
Radiological Area Access Control
Procedures
HTP-ZZ-06001
High Radiation/Locked High Radiation/Very High
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Radiation Area Access
Procedures
HTP-ZZ-06042
Industrial Radiography Using A Radioactive Source
Radiation
Surveys
CA-M-20190402-14
SJ Sample & Boronometer / PASS Rooms
04/02/2019
Radiation
Surveys
CA-M-20190402-17
Access Pit
04/02/2019
Radiation
Surveys
CA-M-20190405-23
RB-2090 RF Stud Rack Survey Update 18501154.500
04/05/2019
Radiation
Surveys
CA-M-20190405-31
RB2047 General Area - Routine Survey
04/05/2019
Radiation
Surveys
CA-M-20190405-33
RB2068 General Area Routine
04/05/2019
Radiation
Surveys
CA-M-20190408-19
Safety Injection Pump Room A
04/08/2019
Radiation
Surveys
CA-M-20190408-32
RB2026' General Area Routine
04/08/2019
Radiation
Surveys
CA-M-20190408-5
RB-2000-I G/A Five Days After CRUD Burst
04/08/2019
Radiation
Surveys
CA-M-20190410-26
Gross Cavity Decontamination
04/10/2019
Radiation
Surveys
CA-M-20190410-27
Rx Shield Plate Install Post Survey
04/10/2019
Radiation Work
Permits (RWPs)
16003707510
EMV0161 Radiography
Radiation Work
Permits (RWPs)
18500671139
RF23 Scaffold to BGV0449
Radiation Work
Permits (RWPs)
R23HDDESTUD
Detension Reactor Vessel Studs
Radiation Work
Permits (RWPs)
R23HDRESTUD
Install Reactor Vessel Studs
Radiation Work
Permits (RWPs)
R23HDSTUD18
Remove Stuck Stud 18
Radiation Work
Permits (RWPs)
R23STD18DECON
RF23 Cavity Decontamination
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Self-
Assessments
201820044-064
NRC Pre Inspection Self-Assessment: Rad Safety
ALARA Planning and Occupational Dose Assessment
06/14/2018
Self-
Assessments
AP19001
Nuclear Oversight Audit of Radiation Protection
03/27/2019
Calculations
HPCI-05-03
Evaluate Plant Radioactivity Mixture (Set Points)
2/22/2005
Calculations
HPCI-1403
Use of PM-12 for Passive Monitoring
2/11/2018
Calibration
Records
16503276-500
SD-RE-024 Reactor Coolant Sample Room
3/16/2018
Calibration
Records
16513022-500
5/7/2018
Calibration
Records
17504995-500
SD-RE-038 Spent Fuel Pool Area Rad High
10/22/2018
Calibration
Records
17506055-500
SD-RE-012 Aux Bldg. Corridor Basement Hi
6/11/2019
Calibration
Records
17506056-500
SD-RE-015 Aux Bldg. Corridor Basement Hi
6/11/2019
Calibration
Records
17508210-500
GT-RE-059 CTMT High Range (Electronics
Calibration)
1/17/2019
Calibration
Records
17510146-500
GT-RE-033 CTMT Purge
2/8/2019
Calibration
Records
17512545-500
GT-RE-059 CTMT High Range (Isotopic Calibration)
4/10/2019
Calibration
Records
CAM-4019-HP
Calibration Certificate (PING-1A)
6/28/2018
Calibration
Records
CAM-4020-HP
Calibration Certificate (PING-1A)
2/27/2019
Calibration
Records
CAM-4045-HP
Calibration Certificate (Eberline AMS-4)
2/10/2018
Calibration
Records
CRM-4023-HP
Calibration Certificate (Ludlum Model 2000)
3/5/2019
Calibration
Records
CRM-4026-HP
Calibration Certificate (Ludlum Model 2000)
8/21/2018
Calibration
Records
CRM-4089-HP
Calibration Certificate (Ludlum Model 177)
1/26/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calibration
Records
CRM-4134-HP
Calibration Certificate (Ludlum Model 177)
2/6/2019
Calibration
Records
GPC-4003-HP
Instrument Calibration / Verification (Tennelec)
11/4/2007
Calibration
Records
GSS-4220-HP
Instrument Calibration / Verification (Ortec - Detector
2)
3/21/2019
Calibration
Records
LAS-4198-HP
Calibration Certificate (Radeco Model HD-29A)
1/28/2019
Calibration
Records
LSC-4004-HP
Instrument Calibration / Verification (Perkin-Elmer)
4/25/2018
Calibration
Records
PCM-4054-HP
Calibration Certificate (PCM-12)
8/28/2018
Calibration
Records
PM-4046-HP
Calibration Certificate (PM-12)
8/28/2018
Calibration
Records
TM-4010-HP
Calibration Certificate (SAM-12)
3/31/2019
Corrective
Action
Documents
Condition Reports
201703216, 201707720, 201800120, 201801122,
201805869, 201805975, 201900857, 201901599,
201902538, 201903111
Miscellaneous
Area Radiation Monitor Calibration Data
6/11/2019
Miscellaneous
Calibration of Xradin Ion Chamber A3, A4, & A6
3/23/2018
Procedures
APA-ZZ-00014
Conduct of Operations - Radiation Protection
Procedures
HDP-ZZ-04000
Radiation Protection Instrumentation Program
Procedures
HDP-ZZ-04700
Count Room and Whole Body Counter Quality Control
Program
Procedures
HSP-ZZ-00014
Rad Monitor Non-Functionality
Procedures
HTP-SD-06033
Control of Area Radiation Monitor Alarm Setpoints
Procedures
HTP-ZZ-04101-DTI-
M177-Cal
Ludlum Model 177 Frisker Calibration
Procedures
HTP-ZZ-04102-DTI-
RO2-CAL
Eberline RO-2 Survey Meter Calibration
Procedures
HTP-ZZ-04150
Operations of the GA Process Monitor System
Procedures
HTP-ZZ-04167-DTI-
Thermo-Radeye
Thermo RadEye Neutron Survey Meter Calibration
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NL-Cal
Procedures
HTP-ZZ-04176-DTI-
SAM12-Cal
Thermo Fisher Model SAM-12 Small Articles Monitor
Calibration
Procedures
HTP-ZZ-04178-DTI-
Telepole-Cal
Rotem Telepole Survey Meter Calibration
Procedures
HTP-ZZ-06020
Count Room Analytic and Quality Control Calculations
and Methods
Procedures
HTP-ZZ-07010
Alternate Method for Obtaining CHARMS Reading
Procedures
ISL-GT-00R59
CTMT High Range Area Rad Monitor Loop Calibration 22
Procedures
ITL-SD-00R00
Eberline Area Radiation Monitors
Radiation
Surveys
CA-M-20190327-19
NS-1 Neutron Source - Quarterly Routine
3/27/2019
Self-
Assessments
201807096-
010/201900029-
036
Instrument Program and Pre-NRC Inspection
3/28/2019
Self-
Assessments
AP19001
Nuclear Oversight Audit of Radiation Protection
3/27/2019
Calculations
RP09-2017-
L0028;1
Batch Liquid Radioactive Release Permit
07/28/2017
Calculations
RP09-2018-
L0007;1
Batch Liquid Radioactive Release Permit
2/01/2018
Calculations
RP09-2019-
L0037;0
Batch Liquid Radioactive Release Permit
06/11/2019
Calculations
RP11A-2019-
G0013;1
Batch Airborne Radioactive Release Permit
2/17/2019
Calculations
RP13-2017-
G0006;52
Continuous Airborne Radioactive Release Permit
2/07/2017
Calculations
RP13-2018-
G0002;56
Continuous Airborne Radioactive Release Permit
2/20/2018
Calibration
Records
Job 12504965.500
RW Bldg Disch Line Process Rad Mon Loop Cal
08/21/2018
Calibration
Records
Job 17502388.500
Ctmt Bld Air Exg Plenum (Unit Vent) Rad Xmt
08/23/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective
Action
Documents
Condition Report
201703216, 201703232, 201703516, 201800052,
201800125, 201801122, 201801301, 201802268,
201802267, 201802407, 201802547, 201803062,
201803391, 201805008, 201805070, 201805144,
201805978, 201805987, 201805989, 201806167,
201900239, 201900348, 201900353, 201900438
Miscellaneous
Callaway Energy Center 2017 Annual Radioactive
Effluent Release Report
Miscellaneous
Callaway Energy Center 2018 Draft Annual
Radioactive Effluent Release Report
Miscellaneous
Job 15510527
FGG02A In-Place Bypass Leakage Test
03/10/2017
Miscellaneous
Job 16509259
FGK02B In-Place Bypass Leakage Test
05/31/2018
Miscellaneous
Job 17503239
FGE01 In-Place Bypass Leakage Test
07/16/2018
Procedures
HSP-ZZ-00002
Radioactive Liquid Effluent Concentration
Procedures
HSP-ZZ-00003
Dose Assessments from Liquid Effluents
Procedures
HSP-ZZ-00004
Projected Dose from Liquid Waste
Procedures
HTP-ZZ-02006
Liquid Radwaste Release Permit (Batch)
Procedures
HTP-ZZ-02006
Liquid Radwaste Release Permit (Batch)
Procedures
HTP-ZZ-02007
Gaseous Radwaste Release Permit (Gas Decay
Tank)
Procedures
HTP-ZZ-02008
Gaseous Radwaste Release Permit (Auxiliary/Fuel
Building Ventilation)
Procedures
HTP-ZZ-02009
Gaseous Radwaste Release Permit (Radwaste
Building Ventilation)
Procedures
HTP-ZZ-03006
Use of Airborne Sampling Cart
Procedures
RW Building Exhaust Discharge Radiation Detector
Self-
Assessments
Nuclear Oversight Audit of Radiological and Non-
Radiological Environmental Monitoring Programs, AP
18006
06/13/2018
Self-
Assessments
Nuclear Oversight Audit of Radiation Protection
AP19001
03/27/2019
Calculations
HPCI 1092
Evaluation of the 2018 Annual Land Use Census
Calculations
HPCI 18-01
Evaluation of the 2017 Annual Land Use Census
Calculations
HPCI-1503
Calculation of Long-Term Meteorological Dispersion
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Parameters
Calculations
HPCI-1506
Evaluation of Air Sampler Locations with Respect to
the Recalculated Dispersion Parameters
Calibration
Records
Job 18504263
RD01-Primary Meteorological Tower Loop A
10/24/2018
Calibration
Records
Job 18504272
RD01-Primary Meteorological Tower Loop B
10/25/2018
Calibration
Records
Job 18511186
RD01-Primary Meteorological Tower Loop A
03/29/2019
Calibration
Records
Job 18511189
RD01-Primary Meteorological Tower Loop B
03/25/2019
Calibration
Records
LAS-4179
Low volume Air Sampler Serial Number 10216
11/09/18
Calibration
Records
LAS-4182
Low Volume Air Sampler Serial Number 8977
07/20/2018
Calibration
Records
LAS-4201
Low Volume Air Sampler Serial Number 8975
01/31/2019
Corrective
Action
Documents
Condition Reports
201700071, 201700835, 201701864, 201702166,
201702981, 201703331, 201703581, 201705266,
201705398, 201705399, 201705403, 201705417,
201706786, 201706793, 201706794, 201801634,
201801736, 201801950, 201802361, 201803357,
201900612, 201900937, 201901217, 201902100
Corrective
Action
Documents
Resulting from
Inspection
Condition Reports
201904252
Miscellaneous
Environmental Dosimetry Company - Annual Quality
Assurance Status Report: January - December 2017
03/07/2018
Miscellaneous
Environmental Dosimetry Company - Annual Quality
Assurance Status Report: January - December 2018
03/12/2019
Miscellaneous
AP18006
Nuclear Oversight Audit of Radiological and Non
Radiological Environmental Monitoring Programs
06/13/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
AP19001
Nuclear Oversight Audit of Radiation Protection
03/27/2019
Miscellaneous
APA-ZZ-01003
Off-Site Dose Calculation Manual
Miscellaneous
Annual Radiological Environmental Operating Report:
January 1-December 31, 2017
Miscellaneous
Annual Radiological Environmental Operating Report:
January 1-December 31, 2018
Miscellaneous
NAQA-17-0038
Audit Report 17-007 for the Audit of Environmental
Dosimetry Company
09/01/2017
Procedures
HDP-ZZ-07000
Radiological Environmental Monitoring Program and
Groundwater Protection Initiative
Procedures
HTP-ZZ-04123-DTI-
F&J-DF1T-CAL
F&J DF-1T Low Volume Air Sampler Calibration
Procedures
HTP-ZZ-07001-DTI-
Crop-Sampling
Collection and Shipping of Environmental Crop
Samples
Procedures
HTP-ZZ-07001-DTI-
Water-Sampling
Collection and Shipping of Environmental Water
Samples
Procedures
HTP-ZZ-07101-DTI-
REMP-SMPL-
SCHED
REMP Sample Locations and Analysis Schedule
Procedures
HTP-ZZ-07103-RP-
DTI-REMP-
DATAEVAL
Evaluation and Reporting of REMP Data
Procedures
ISL-RD-RD01A
Meteorological Monitoring Instruments - Elevator A
Loop Calibration
Procedures
ISL-RD-RD01B
Meteorological Monitoring Instruments - Elevator B
Loop Calibration
Procedures
RP-DTI-ENVIRON-
TLD LOCATIONS
Environmental TLD Locations
Procedures
RP-DTI-
ENVIRONMENTAL-
SPILLRESP
Response to Spills or Leaks of Radioactive Material
into Groundwater
Corrective
Action
Documents
Condition Report
201701008, 201702081, 201704005, 201706627,
201804430, 201804447, 201806969, 201900861,
201900930, 201901038, 201902796, 201904190
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
Callaway Final Safety Analysis Report (FSAR) -
Chapter 11.4
06/01/2018
Miscellaneous
2018 RAM and Radwaste Shipping Log
2018
Miscellaneous
Callaway Energy Center 2018 Annual Radioactive
Effluent Release Report
2018
Miscellaneous
Callaway Energy Center 2017 Annual Radioactive
Effluent Release Report
2017
Miscellaneous
2017 RAM and Radwaste Shipping Log
2017
Procedures
APA-ZZ-01011
Procedures
HTP-HC-09002
CFR 61 Sampling Program
Procedures
HTP-ZZ-02005
Handling of Radioactive Material
Procedures
HTP-ZZ-09003
Shipment of Radioactive Wastes
Procedures
RDP-ZZ-00200
Radwaste Operational Guidelines
Procedures
RTN-HC-01900
On-Site Storage Container Handling Procedure
Procedures
RTS-HC-00310
Primary Resin Sluice To Bulk Waste Disposal Station
Procedures
RTS-HC-00350
Primary Spent Resin Storage Tank Transfer To Bulk
Waste Disposal Station
Procedures
RTS-ZZ-CH040
Handling of Transport Cask Model 14-215H
Procedures
RTS-ZZ-CH050
Handling Procedure for CNS 8-120A Transport Cask
Radiation
Surveys
CA-M-20190409-24
RWY-4 & RWY-3 Radwaste Yard Plant (North &
South)
04/09/2019
Radiation
Surveys
CA-M-20190415-05
28 Drywaste Compactor Area - Quarterly Routine
04/14/2019
Radiation
Surveys
CA-M-20190421-24
25 Quarterly Routine Survey - Low Level Drum
Storage Area
04/21/2019
Radiation
Surveys
CA-M-20190524-02
RSS-1 Characterization - Resin Liner #PO661751-16
05/24/2019
Self-
Assessments
EPRI Solid Radioactive Waste Program Assessment
at Ameren Callaway Nuclear Power Plant
07/14/2017
Self-
Assessments
201900029-035
Simple Self-Assessment: Shipping Program
05/02/2019
Self-
Assessments
AP19001
Ameren Nuclear Oversight Audit of Radiation
Protection
03/27/2019
Shipping
17-010
UN3321, RAM, LSA-11, Class 7 (Drummed
06/22/2017
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Records
Mechanical Filters)
Shipping
Records17-012
UN3321, RAM, LSA-II, Class 7 (Dewatered Resin)
07/12/2017
Shipping
Records17-061
UN2912, RAM, LSA-I, Class 7 (Dry Active Waste
Cycle 21)
11/17/2017
Shipping
Records18-001
UN3321, RAM, LSA-II, Class 7 (Dewatered Resin and
Charcoal)
01/12/2018
Shipping
Records18-010
UN2911, RAM, Excepted Package, Class 7
(Instruments)
04/12/2018
Shipping
Records18-018
UN2911, RAM, Excepted Package, Class 7
(Instruments)
09/20/2018
Shipping
Records18-036
UN2912, RAM, LSA-I, Class 7 (Dry Active Waste)
2/26/2018
Shipping
Records19-005
UN3321, RAM, LSA-II, Class 7 (Resin and Charcoal)
03/19/2019
Shipping
Records19-021
UN2912, RAM, LSA-I, Class 7 (Resin)
06/11/2019
Corrective
Action
Documents
Condition Reports
201901943, 201903787, 201903832
The following items are requested for the
Occupational Radiation Safety Inspection
at Callaway
Dates of Inspection: 04/08/2019 to 04/12/2019
Integrated Report 2019002
Inspection areas are listed in the attachments below.
Please provide the requested information on or before Monday, March 25, 2019.
Please submit this information using the same lettering system as below. For example, all
contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled
1-A, applicable organization charts in file/folder 1-B, etc.
The information should be provided in electronic format or a secure document management
service. If information is placed on ims.certrec.com, please ensure the inspection exit date
entered is at least 30 days later than the onsite inspection dates, so the inspectors will have
access to the information while writing the report.
In addition to the corrective action document lists provided for each inspection procedure listed
below, please provide updated lists of corrective action documents at the entrance meeting.
The dates for these lists should range from the end dates of the original lists to the day of the
entrance meeting.
If more than one inspection procedure is to be conducted and the information requests appear
to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which
file the information can be found.
If you have any questions or comments, please contact Natasha Greene at 817-200-1154 or via
e-mail at Natasha.Greene@nrc.gov.
PAPERWORK REDUCTION ACT STATEMENT
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.
1.
Radiological Hazard Assessment and Exposure Controls (71124.01) and
Performance Indicator Verification (71151)
Date of Last Inspection:
November 5, 2018
A.
List of contacts and telephone numbers for the Radiation Protection Organization Staff
and Technicians, as well as the Licensing/Regulatory Affairs staff. Please include area
code and prefix. If work cell numbers are appropriate, then please include them as well.
B.
Applicable organization charts including position or job titles. Please include as
appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),
Engineering, and Emergency Protection. (Recent pictures are appreciated.)
C.
Copies of audits, self-assessments, LARs, and LERs written since the last inspection
date, related to this inspection area
D.
Procedure indexes for the radiation protection procedures and other related disciplines.
E.
Please provide procedures related to the following areas noted below. Additional
procedures may be requested by number after the inspector reviews the procedure
indexes.
1. Radiation Protection Program
2. Radiation Protection Conduct of Operations, if not included in #1.
3. Personnel Dosimetry
4. Posting of Radiological Areas
5. High Radiation Area Controls
6. RCA Access Controls and Radiation Worker Instructions
7. Conduct of Radiological Surveys
8. Radioactive Source Inventory and Control
9. Fuel Pool Inventory Access and Control
F.
Please provide a list of NRC Regulatory Guides and NUREGs that you are currently
committed to relative to this program. Please include the revision and/or date for the
commitment and where this may be located in your current licensing basis documents.
G.
Please provide a summary list of corrective action documents (including corporate and
sub-tiered systems) since the last inspection date.
1. Initiated by the radiation protection organization
2. Assigned to the radiation protection organization
NOTE: These lists should include a description of the condition that provides sufficient
detail that the inspectors can ascertain the regulatory impact, the significance
level assigned to the condition, the status of the action (e.g., open, working,
closed, etc.) and the search criteria used. Please provide in document formats
which are sortable and searchable so that inspectors can quickly and
efficiently determine appropriate sampling and perform word searches, as
needed. (Excel spreadsheets are the preferred format.) If codes are used,
please provide a legend for each column where a code is used.
H.
List of radiologically significant work activities scheduled to be conducted during the
inspection period. (If the inspection is scheduled during an outage, please also include a
list of work activities greater than 1 rem, scheduled during the outage with the dose
estimate for the work activity.) Please include the radiological risk assigned to each
activity.
I.
Provide a summary of any changes to plant operation that have resulted or could result
in a significant new radiological hazard. For each change, please provide the
assessment conducted on the potential impact and any monitoring done to evaluate it.
J.
List of active radiation work permits and those specifically planned for the on-site
inspection week.
K.
Please provide a list of air samples taken to verify engineering controls and a separate
list for breathing air samples in airborne radiation areas or high contamination work
areas. Please include the RWP the breathing air sampling supports.
L.
Please provide the current radioactive source inventory, listing all radioactive sources
that are required to be leak tested. Indicate which sources are deemed 10 CFR Part 20,
Appendix E, Category 1 or Category 2. Please indicate the radioisotope, initial and
current activity (w/assay date), and storage location for each applicable source.
M.
The last two leak test results for all required/applicable radioactive sources that have
failed its leak test within the last two years. Provide any applicable condition reports.
N.
A list of all non-fuel items stored in the spent fuel pools, and if available, their appropriate
dose rates (Contact / @ 30cm)
O.
A list of radiological controlled area entries greater than 100 millirem, since the last
inspection date. The list should include the date of entry, some form of worker
identification, the radiation work permit used by the worker, dose accrued by the worker,
and the electronic dosimeter dose alarm set-point used during the entry (for
Occupational Radiation Safety Performance Indicator verification in accordance with IP 71151).
P.
A list describing VHRAs and TS HRAs (> 1 rem/hour) that are current and historical.
Include their current status, locations, and control measures.
Q.
Temporary effluent monitor locations and calibrations (AMS-4) used to monitor normally
closed doors or off-normal release points (e.g., equipment hatch or turbine heater bay
doors). Include any CRs associated with this monitoring or instrumentation.
2.
Occupational ALARA Planning and Controls (71124.02)
Date of Last Inspection:
May 21, 2018
A.
List of contacts and telephone numbers for ALARA program personnel, as well as the
Licensing/Regulatory Affairs staff. Please include area code and prefix. If work cell
numbers are appropriate, then please include them as well.
B.
Applicable organization charts including position or job titles. Please include as
appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),
Engineering, and Emergency Protection. (Recent pictures are appreciated.)
C.
Copies of audits, self-assessments, LARs, and LERs, written since the date of last
inspection, focusing on ALARA
D.
Procedure index for ALARA Program procedures and other related disciplines.
E.
Please provide specific procedures related to the following areas noted below.
Additional Specific Procedures may be requested by number after the inspector reviews
the procedure indexes.
1. ALARA Program
2. ALARA Planning
3. ALARA Reviews
4. ALARA Committee
5. Radiation Work Permit Preparation
F.
Please provide a list of NRC Regulatory Guides and NUREGs that you are currently
committed to relative to this program. Please include the revision and/or date for the
commitment and where this may be located in your current licensing basis documents.
G.
Please provide a summary list of corrective action documents (including corporate and
sub-tiered systems) written since the date of last inspection, related to the ALARA
program, including exceeding RWP Dose Estimates.
NOTE: These lists should include a description of the condition that provides sufficient
detail that the inspectors can ascertain the regulatory impact, the significance
level assigned to the condition, the status of the action (e.g., open, working,
closed, etc.) and the search criteria used. Please provide in document formats
which are sortable and searchable so that inspectors can quickly and
efficiently determine appropriate sampling and perform word searches, as
needed. (Excel spreadsheets are the preferred format.) If codes are used,
please provide a legend for each column where a code is used.
H.
List of work activities (RWPs) greater than 1 rem, since date of last inspection,
including the original dose estimates and actual doses accrued. (Excel format
preferred). Please provide all revisions/changes, as well as any related RWPs that
support the work activity.
I.
List of active work activities (RWPs) that will be in use while we are onsite, including the
dose and dose rate settings, and if available, the planned dose. Include planning
documents and surveys. Include radiological risk assessments and proposed control
measures.
J.
Site dose totals for the past 3 years (based on dose of record). Also provide the current
year-to-date (YTD) collective radiation exposure (CRE). In addition, please provide
another document that separates the online and outage doses for the past 3 years.
K.
Most recent assessment of your isotopic mix, including the hard-to-detect radionuclides
and alpha hazards. Include a list of new and historical exposure issues (radiological
source term or high exposure areas/activities).
L.
If available, provide a copy of the lessons learned from the most recently completed
outage for each unit. Include a summary list of any associated corrective action
documents and the current status of any corrective actions assigned.
M.
Please provide the methods/reports that are in your process to meet the requirements of
CFR 20.1101(c) for periodic review of your RP program.
N.
Current exposure trends (BRAC dose rates and/or source term information).
The following items are requested for the
Public Radiation Safety Inspection
at Callaway
Dates of Inspection: 06/10/2019 to 06/14/2019
Integrated Report 2019002
Inspection areas are listed in the attachments below.
Please provide the requested information on or before Friday, May 24, 2019.
Please submit this information using the same lettering system as below. For example, all
contacts and phone numbers for Inspection Procedure 71124.05 should be in a file/folder titled
5-A, applicable organization charts in file/folder 5-B, etc.
The information should be provided in electronic format or a secure document management
service. If information is placed on a secured document management system, please ensure
the inspection exit date entered is at least 30 days later than the onsite inspection dates, so the
inspectors will have access to the information while writing the report.
In addition to the corrective action document lists provided for each inspection procedure listed
below, please provide updated lists of corrective action documents at the entrance meeting.
The dates for these lists should range from the end dates of the original lists to the day of the
entrance meeting.
If more than one inspection procedure is to be conducted and the information requests appear
to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which
file the information can be found.
If you have any questions or comments, please contact Natasha Greene at 817-200-1154 or via
e-mail at Natasha.Greene@nrc.gov.
PAPERWORK REDUCTION ACT STATEMENT
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.
5.
Radiation Monitoring Instrumentation (71124.05)
Date of Last Inspection:
February 27, 2017
A.
List of contacts and telephone numbers for the following areas below. Please include
area code and prefix. If work cell numbers are appropriate, then please include them as
well.
1. Process monitor calibration (Include Chemistry, Systems Engineering and I&C, as
applicable)
2. Radiation protection instrument calibration (Portable and Stationary)
3. Installed instrument calibrations (Include Systems Engineering and I&C)
4. Count room and Laboratory instrument calibrations (Include RP and Chemistry, as
applicable)
5. EP contacts for Equipment Important to Emergency Response/Preparedness
(EITER)
6. Licensing/Regulatory Affairs
B.
Applicable organization charts, including position or job titles. Please include as
appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),
Engineering, and Emergency Protection. (Recent pictures are appreciated.)
C.
Copies of audits, self-assessments, vendor or NUPIC audits for contractor support,
LARs, and LERs, performed since the date of the last inspection, related to:
1. Portable Radiation instruments: Area radiation monitors, portable continuous air
monitors (AMS3/4), portable survey instruments (count rate, dose rate, occupational
air sampling), electronic dosimeters, teledosimetry
2. Stationary Radiation Instruments: Portal monitors, small article monitors, personnel
contamination monitors, or whole body counters
3. Installed Radiation Instruments: Area radiation monitors (RMS), process monitors
(non-effluent), criticality monitors, accident monitors
4. Count Room instrumentation (Chemistry and RP, if separate RP Ops and Effluents):
Gamma Spec, LSC, Gross Alpha, Gross Beta, including bench-top counters
D.
Procedure indexes for radiation protection procedures and other related disciplines.
1. Calibration, use, and operation of continuous air monitors, portable survey
instruments, temporary area radiation monitors, electronic dosimeters, teledosimetry
2. Calibration use and operation of portal monitors, small article monitors, personnel
contamination monitors, and whole body counters
3. Calibration of installed area radiation monitors, process monitors, criticality monitors,
and accident monitors
4. Calibration use and operation of Count Room instrumentation (GS, LSC, GA, GB)
(include bench top counters here)
NOTE: Please ensure that RP, Chemistry, and I&C procedures are included, as
appropriate.
E.
Please provide specific procedures related to the following areas noted below.
Additional procedures may be requested by number after the inspector reviews the
procedure index.
1. Calibration of portable ion chambers
2. Calibration of Friskers
3. Calibration of telescoping high range instruments
4. Calibration of portable neutron instruments
5. Calibration of SAMs
6. Whole body counter calibration
7. Laboratory instrumentation quality control
8. Calibration of Containment/Drywell high range radiation monitor
F.
Please provide a list of NRC Regulatory Guides and NUREGs that you are currently
committed to relative to this program. Please include the revision and/or date for the
commitment and where this may be located in your current licensing basis documents.
G.
Please provide a summary list of corrective action documents (including corporate and
sub-tiered systems) written since the date of the last inspection, related to the following
programs:
1. Area radiation monitors, continuous air monitors, portable survey instruments,
electronic dosimeters, and teledosimetry
2. Portal monitors, small article monitors, personnel contamination monitors, and whole
body counters
3. Installed radiation monitors, criticality monitors, accident range monitors
4. Count room radiation instruments
NOTE: These lists should include a description of the condition that provides
sufficient detail that the inspectors can ascertain the regulatory impact, the
significance level assigned to the condition, the status of the action (e.g., open,
working, closed, etc.) and the search criteria used. Please provide in document
formats which are sortable and searchable so that inspectors can quickly and
efficiently determine appropriate sampling and perform word searches, as
needed. (Excel spreadsheets are the preferred format.) If codes are used,
please provide a legend for each column where a code is used.
H.
State the required calibration frequency and provide the most recent calibration data for
the whole body counters, at least one portable survey instrument, one area radiation
monitor, one air sampler, one continuous air monitor, and one drywell/containment high-
range monitor.
I.
Provide a list of any scheduled calibrations, while we are onsite, for the instrumentation
noted in request above, in 5-I.
J.
Provide the alarm set point values for the portal and personnel contamination monitors in
operation.
K.
Radiation Monitoring System health report for the previous 12 months
L.
Provide the following lists of instruments to include make, model, identifier (S/N or plant
ID), and location:
1. Portable radiation instruments currently in use (for EADs just make, model, and
quantity).
2. Stationary radiation instruments currently in use.
3. Installed Radiation monitors
a. Area radiation monitors and
b. Process radiation monitors.
(Include their instrumentation designator, function and calibration procedure
number and title.) Please indicate which, if any, detectors have been
replaced within the past 2 years (since the last inspection).
c. Radiation instrumentation abandoned in place.
d. Radiation instrumentation covered by the maintenance rule.
M.
Provide a list of sources used routinely for source check of portable, stationary, and
installed radiation monitoring instruments.
N.
Provide the NIST traceability and calibration or verification of the primary sources for
instrument calibration and the procedures used to achieve this.
6.
Radioactive Gaseous and Liquid Effluent Treatment (71124.06)
Date of Last Inspection:
February 27, 2017
A.
List of contacts and telephone numbers for the following areas. Please include area
code and prefix. If work cell numbers are appropriate, then please include them as well.
1. Radiological effluent control (liquid & gaseous) and reporting
(RP, Chemistry, RW, Ops, etc.)
2. Effluent Monitor calibration (liquid and gaseous) and maintenance
(RP, Chemistry, I&C, Maintenance, Systems Engineering, EP, etc.)
3. Engineered safety feature air cleaning systems for effluent release
(Systems Engineering, I&C, Maintenance, etc.)
4. Licensing/Regulatory Affairs
B.
Applicable organization charts including position or job titles for the above individuals
and also for their supportive Management. Please include as appropriate for your site,
Site Management, RP, Chemistry, Maintenance (I&C), Engineering, and Emergency
Protection. (Recent pictures are appreciated.)
C.
Copies of audits, self-assessments, vendor or NUPIC audits of contractor support, and
LERs written since the date of the last inspection, related to:
1. Radioactive effluents and effluent radiation monitors
2. Engineered Safety Feature Air cleaning systems
D.
Procedure indexes for the following areas and related disciplines.
1. Radioactive effluents and effluent radiation monitors (to include the flow monitors)
2. Engineered Safety Feature Air cleaning systems (both TS and non-TS systems for
effluents)
E.
Please provide specific procedures related to the following areas noted below.
Additional procedures may be requested by number after the inspector reviews the
procedure indexes.
1. Sampling and analysis of radioactive effluents
2. Effluent monitor setpoint determination
3. Generating radioactive effluent release permits
4. Effluent Monitor Calibrations (Include associated flow monitors)
5. Laboratory instrumentation quality control
6. In-place testing of HEPA filters and charcoal adsorbers for TS effluent exhaust
systems and other effluent air-cleaning systems, but not breathing air systems
F.
Please provide a list of NRC Regulatory Guides and NUREGs that you are currently
committed to relative to this program. Please include the revision and/or date for the
commitment and where this may be located in your current licensing basis documents.
G.
Please provide a summary list of corrective action documents (including corporate and
sub-tiered systems) written since the date of the last inspection, associated with:
1. Radioactive effluents
2. Effluent radiation monitors (include associated effluent flow monitors)
3. Engineered Safety Feature Air cleaning systems (effluents, not breathing air)
NOTE: These lists should include a description of the condition that provides
sufficient detail that the inspectors can ascertain the regulatory impact, the
significance level assigned to the condition, the status of the action (e.g., open,
working, closed, etc.) and the search criteria used. Please provide in document
formats which are sortable and searchable so that inspectors can quickly and
efficiently determine appropriate sampling and perform word searches, as
needed. (Excel spreadsheets are the preferred format.) If codes are used,
please provide a legend for each column where a code is used.
H.
Annual Radioactive Effluent Release Reports for the latest two calendar years
I.
Current revision of the Offsite Dose Calculation Manual (or other name, but include all
parts for effluents) and any changes made since the last inspection.
J.
The inter-laboratory comparison results for laboratory quality control performance of
effluent sample analysis for the latest two calendar years
K.
Effluent sampling schedule for the week of the inspection
L.
Provide the last three annual trends of vent/stack effluent flow rates, by chart or table.
M.
Operations department (or other responsible dept.) log records for effluent monitors
removed from service or out of service or a list of the same and compensatory actions
taken during the out of service condition.
N.
Listing or log of liquid and gaseous release permits since the date of the last inspection
O.
A list of the technical specification-required air cleaning systems with the two most
recent surveillance test dates of in-place filter testing (of HEPA filters and charcoal
adsorbers) and laboratory testing (of charcoal efficiency) and the work order numbers
associated with the surveillances (and their system number/name).
P.
System Health Report for radiation monitoring instrumentation. Also, please provide a
specific list of all effluent radiation monitors that were considered inoperable for 7 days
or more since the date of the last inspection. If applicable, please provide the relative
Special Report and condition report(s). If not covered by maintenance rule, please
provide rationale.
Q.
A list of significant changes made to the gaseous and liquid effluent process monitoring
system since the date of the last inspection. If applicable, please provide the
corresponding UFSAR section in which this change was documented.
R.
A list of any occurrence in which a non-radioactive system was contaminated by a
radioactive system since the date of the last inspection. Please include any relevant
condition report(s).
S.
Current Part 61 analyses for hard to detect radionuclides
T.
Latest Land Use Census (coordinate with 71124.07)
U.
Effluent based procedures for EALs or EOPs.
7.
Radiological Environmental Monitoring Program (71124.07)
Date of Last Inspection:
February 27, 2017
A.
List of contacts and telephone numbers for the following areas. Please include area
code and prefix. If work cell numbers are appropriate, then please include them as well.
1. Radiological environmental monitoring (RP, Chemistry, I&C, etc.)
2. Meteorological monitoring (RP, Chemistry, EP, I&C, System Engineering, etc.)
3. Maintenance and calibration of the above equipment
4. Licensing/Regulatory Affairs
B.
Applicable organization charts including position or job titles. Please include as
appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),
Engineering, and Emergency Protection. (Recent pictures are appreciated.)
C.
Copies of audits, self-assessments, vendor or NUPIC audits of contractor support, and
LERs written since the date of the last inspection, related to:
1. Radiological environmental monitoring program (including contractor environmental
laboratory audits, if used to perform environmental program functions)
2. Environmental TLD processing facility
3. Meteorological monitoring program
D.
Procedure index for the following areas and other related disciplines.
1. Radiological environmental monitoring program
2. Meteorological monitoring program
3. Maintenance and calibration of related instrumentation, including the meteorological
tower
E.
Please provide specific procedures related to the following areas noted below.
Additional procedures may be requested by number after the inspector reviews the
procedure indexes.
1. Sampling, collection and preparation of environmental samples
2. Sample analysis (if performed onsite)
3. Laboratory instrumentation quality control
4. Meteorological Tower sensor calibrations
F.
Please provide a list of NRC Regulatory Guides and NUREGs that you are currently
committed to relative to this program. Please include the revision and/or date for the
commitment and where this may be located in your current licensing basis documents.
G.
Please provide a summary list of corrective action documents (including corporate and
sub-tiered systems) written since the date of the last inspection, related to the following
programs:
1. Radiological environmental monitoring (include TLDs and air sample pumps or their
infrastructure)
2. Meteorological monitoring (include Met Tower sensors and support equipment)
These lists should include a description of the condition that provides sufficient
detail that the inspectors can ascertain the regulatory impact, the significance
level assigned to the condition, the status of the action (e.g., open, working,
closed, etc.) and the search criteria used. Please provide in document formats
which are sortable and searchable so that inspectors can quickly and
efficiently determine appropriate sampling and perform word searches, as
needed. (Excel spreadsheets are the preferred format.) If codes are used,
please provide a legend for each column where a code is used.
H.
Copies of the two most recent calibration packages for the meteorological tower
instruments
I.
Copies of the Annual Radiological Environmental Operating Reports and Land Use
Census for the latest two calendar years, and current revision of the Offsite Dose
Calculation Manual. Please include any supportive documentation for the changes
made to the ODCM since the last inspection.
J.
Copy of the environmental laboratorys inter-laboratory comparison program results for
the latest two calendar years, if not included in the Annual Radiological Environmental
Operating Report
K.
Data from the environmental laboratory documenting the analytical detection sensitivities
for the various environmental sample media (i.e., air, water, soil, vegetation, and milk)
L.
Quality Assurance audits (e.g., NUPIC) for contracted services
M.
Current NEI Groundwater Protection Initiative (GPI) Plan and status. Provide the most
recent monitoring results for each monitoring well per the GPI. Provide a separate list of
any missed samples, as applicable.
N.
Technical requirements manual or licensee controlled specifications which list the
meteorological instruments calibration requirements
O.
If applicable, per NEI 07-07, provide any reports that document any spills/leaks to
groundwater since the date of the last inspection. Please indicate what external
communications were made regarding each spill/leak.
P.
Provide any new entries into 10 CFR 50.75(g) files since the date of the last inspection.
Q.
Please identify your three highest X/Q (chi/Q) and/or D/Q sectors, as currently used in
the selection of your required REMP sampling locations. If these are different values
from your most recent meteorological assessment, please provide that assessment and
indicate the three highest X/Q and/or D/Q sectors per your latest assessment. Also
indicate your noted predominant and least prevalent wind direction/sector, as used in
your REMP analysis.
R.
Provide the height of the highest effluent release point. Please indicate if the height
accounts for plant grade elevation. Please also provide the most probable atmospheric
release height, if different from the highest effluent release point.
S.
Please provide a schedule of any planned REMP sampling activities while we, the NRC,
are scheduled to be onsite performing this inspection.
8.
Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage,
and Transportation (71124.08)
Date of Last Inspection:
February 27, 2017
A.
List of contacts and telephone numbers for the following areas. Please include area
code and prefix. If work cell numbers are appropriate, then please include them as well.
1. Solid Radioactive waste processing (RP, Chemistry, Ops, Maintenance, I&C,
Engineering, etc.)
2. Transportation of radioactive material/waste (RP, Maintenance, Ops, Security,
Chemistry, etc.)
3. personnel involved in solid radwaste processing, transferring, and transportation of
radioactive waste/materials)
4. Licensing/Regulatory Affairs
B.
Applicable organization charts including position or job titles. Please include as
appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),
Engineering, and Emergency Protection. (Recent pictures are appreciated.)
C.
Copies of audits, department self-assessments, and LERs written since the date of the
last inspection, related to:
1. Solid radioactive waste management
2. Radioactive material/waste transportation program
D.
Procedure index for the following areas and other related disciplines.
1. Solid radioactive waste management
2. Radioactive material/waste transportation
E.
Please provide specific procedures related to the following areas noted below.
Additional procedures may be requested by number after the inspector reviews the
procedure indexes.
1. Process control program and any changes made since the last inspection
2. Solid and liquid radioactive waste processing
3. Waste stream sampling and analysis
4. Waste characterization and classification
5. Radioactive material/waste packaging & shipping
F.
Please provide a list of NRC Regulatory Guides and NUREGs that you are currently
committed to relative to this program. Please include the revision and/or date for the
commitment and where this may be located in your current licensing basis documents.
G.
Please provide a summary list of corrective action documents (including corporate and
sub-tiered systems) written since the date of the last inspection, related to:
1. Solid radioactive waste
2. Transportation of radioactive material/waste
NOTE: These lists should include a description of the condition that provides
sufficient detail that the inspectors can ascertain the regulatory impact, the
significance level assigned to the condition, the status of the action (e.g., open,
working, closed, etc.) and the search criteria used. Please provide in document
formats which are sortable and searchable so that inspectors can quickly and
efficiently determine appropriate sampling and perform word searches, as
needed. (Excel spreadsheets are the preferred format.) If codes are used,
please provide a legend for each column where a code is used.
H.
Copies of training lesson plans for 49 CFR 172, Subpart H, for radwaste processing,
packaging, and shipping
I.
Provide a summary list or log of radioactive material and radioactive waste shipments for
the two most recent calendar years, in addition to the current calendar year.
J.
Please provide at least two different radioactive waste stream sample analysis results
and resulting scaling factors for the latest two calendar years.
K.
A listing of all onsite radwaste storage facilities. Please include a summary or list of the
items stored in each facility with the most recent dose rates/surveys.
L.
A list of any significant (e.g., DAW, resins, Type B or greater) radioactive shipments that
will be completed during our onsite inspection period. If available, please provide the
applicable shipping manifests/waste characterizations and most recent surveys for each
shipment.
M.
A list of significant changes made to the liquid or solid radwaste processing systems
since the date of the last inspection. If applicable, please provide the corresponding
UFSAR section in which this change was documented. Provide any supportive
documentation for the changes made or have it readily available for review.
N.
List of radioactive waste processing systems or equipment abandoned in place since the
last inspection.
O.
Please provide a schedule of radioactive material or waste processing or shipment
activities during the inspection week. Please indicate the current storage location of the
stored RAM or waste prepared for shipment, as well as any supportive surveys of its
measured dose rates. If available, please indicate its current stated waste class.