IR 05000483/2022002

Integrated Inspection Report 05000483/2022002

ML22199A307
Person / Time
Site:	Callaway
Issue date:	07/27/2022
From:	Greg Werner NRC/RGN-IV/DORS
To:	Diya F Ameren Missouri
Proulx D
References
IR 2022002
Download: ML22199A307 (31)

Text

July 27, 2022

SUBJECT:

CALLAWAY PLANT - INTEGRATED INSPECTION REPORT 05000483/2022002

Dear Mr. Diya:

On June 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Callaway Plant. On July 6, 2022, the NRC inspectors discussed the results of this inspection with Mr. Fred Bianco, Senior Director, Nuclear Operations, and other members of your staff.

The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at the Callaway Plant.

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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Signed by Werner, Gregory on 07/27/22 Gregory E. Werner, Chief Projects Branch B Division of Operating Reactor Safety Docket No. 05000483 License No. NPF-30

Enclosure:

As stated

Inspection Report

Docket Number: 05000483 License Number: NPF-30 Report Number: 05000483/2022002 Enterprise Identifier: I-2022-002-0000 Licensee: Ameren Missouri Facility: Callaway Plant Location: Steedman, MO Inspection Dates: April 1 to June 30, 2022 Inspectors: C. Alldredge, Health Physicist D. Antonangeli, Health Physicist B. Baca, Health Physicist D. Bradley, Senior Resident Inspector J. Drake, Senior Reactor Inspector S. Janicki, Resident Inspector J. Melfi, Project Engineer S. Schwind, Resident Inspector A. Smallwood, Acting Resident Inspector J. Vera, Acting Senior Resident Inspector Approved By: Gregory E. Werner, Chief Projects Branch B Division of Operating Reactor Safety Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at 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

Failure to Correctly Translate Design Requirements for the Auxiliary Feedwater System Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71152A Systems NCV 05000483/2022002-01 Open/Closed The inspectors identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion III,

Design Control, for the licensees failure to assure that applicable regulatory requirements and the design bases, as defined in 10 CFR 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies, were correctly translated into specifications, drawings, procedures, and instructions. Specifically, in 1998, the licensee improperly changed the FSAR and plant operating procedures to allow use of the auxiliary feedwater systems beyond responding to plant events or for required testing. Prior to this change, the auxiliary feedwater systems environmental qualification was assessed as moderate-energy on the basis that the system was infrequently used and was not used during plant startups or hot-standby. As a result, the licensee operated the auxiliary feedwater system for operational convenience and in a manner that conflicted with NRC design requirements for the system.

Additional Tracking Items

None.

PLANT STATUS

Callaway began the inspection period at rated thermal power. On April 4, 2022, the plant performed a planned shutdown for a refueling outage. On May 28, 2022, Callaway began a planned reactor startup. On May 30, 2022, Callaway synchronized the main generator to the electric grid. On June 3, 2022, Callaway reached rated thermal power and remained at or near rated thermal power for the remainder 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 activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. 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.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of summer hot temperatures for the emergency diesel generators, essential service water, and the condensate storage tank on May 9, 2022.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (7 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) train B spent fuel pooling cooling during elevated plant risk on April 22, 2022

(2) train A emergency diesel generator jacket water system following maintenance on May 4, 2022

(3) train A 4.16 KV Class 1E vital bus, NB01, on May 2, 2022

(4) train A safety injection system on May 12, 2022

(5) train A component cooling water during reduced reactor coolant inventory on May 18, 2022

(6) train A containment spray system on May 24, 2022

(7) train B component cooling water system on May 25, 2022

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) reactor building, fire area RB-1, on April 18, 2022

(2) residual heat removal, trains A and B, heat exchanger rooms, fire areas A-9 and A-10, on April 22, 2022

(3) control room air conditioning rooms, trains A and B, fire areas A-21 and A-22, on April 27, 2022

(4) diesel generator building, fire areas D-1 and D-2, on May 17, 2022

(5) laundry and decontamination room, fire area C-6, on May 17, 2022

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated internal flooding mitigation protections in the auxiliary feedwater pump rooms and pipe chase on May 18, 2022.

.

71111.07A - Heat Exchanger/Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness and performance of the ultimate heat sink cooling tower and underground piping modification on May 2, 2022.

71111.08P - Inservice Inspection Activities (Pressurized Water Reactor) Pressurized Water Reactor Inservice Inspection Activities Sample (IP Section 03.01)

(1) 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 4 to July 6, 2022.

03.01.a - Nondestructive Examination and Welding Activities dye penetrant examination EM01H010112 safety injection pipe support attachment weld visual examination loop A pipe support loop D pipe support visual examination essential service water train A to containment coolers, piping and supports visual examination essential service water train B to containment coolers, piping and supports ultrasonic examination reactor vessel closure studs, various ultrasonic examination 2EJ-04-FO34, elbow to pipe ultrasonic examination reactor vessel inlet nozzle, 2-BB-01-F302. This included the review of a relevant indication that the licensee analytically evaluated and accepted for continued service.

the inspectors reviewed the weld package for EEG0lA, component cooling water heat exchanger A slip-on flange and 150 pound blind flange assembly for the A component cooling water heat exchanger.

03.01.c - Pressurized Water Reactor Boric Acid Corrosion Control Activities The inspectors reviewed 11 boric acid evaluations and screenings associated with the following condition reports: 202101905, 202101949, 202101957,

===202101989, 202102033, 202102039, 202102043, 202102062, and 202102071.

03.01.d - Pressurized Water Reactor Steam Generator Tube Examination Activities The inspectors reviewed the results of the 100 percent full length eddy current inspection of all tubes with bobbin coil probe.

No tubes exhibited degradation exceeding the tube integrity criteria provided in the degradation assessment.

No tubes required in situ pressure testing to support the condition monitoring assessment based on the degradation assessment and Electric Power Research Institute (EPRI) In Situ Pressure Test Guidelines.

No tube leakage was reported during this operating interval.

Problem Identification and Resolution review of Inservice items The inspectors evaluated a sample of 22 condition reports associated with inservice inspection activities.

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) The inspectors observed and evaluated licensed operator performance in the control room during the reactor startup on May 28, 2022.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the simulator during just-in-time-training for reactor startups on May 16, 2022.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) feedwater isolation valve maintenance on April 20, 2022

(2) medium voltage switchgear and bus maintenance on May 11, 2022

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:

(1) emergency diesel fuel oil quality control, including receipt testing, on April 25, 2022

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) planned elevated risk for reactor disassembly on April 4, 2022

(2) planned elevated risk actions due to fuel offload on April 13, 2022

(3) planned elevated risk during reloading of fuel on May 10, 2022

(4) planned elevated risk during reactor head assembly and vacuum filling of the reactor coolant system on May 16, 2022

(5) planned elevated risk during reactor startup on May 28, 2022

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) emergency diesel generator train A jacket water leak, condition report 202201971, on April 5, 2022

(2) residual heat removal flow control valve position, condition report 202202138, on April 11, 2022

(3) emergency diesel generator train A cylinder liner and piston damage, condition report 202202278, on May 2, 2022

(4) reactor vessel stud thread indication, condition report 202202882, on May 11, 2022

(5) vital battery NK13 specific gravity after charging, condition report 202202942, on May 12, 2022

(6) ultimate heat sink cooling tower bypass valve damage, condition report 202203343, on May 18, 2022

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 temporary or permanent modifications:

(1) seal table high pressure fitting replacement under job 21001926.

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:

(1) residual heat removal train A, under job 22503610, on April 18, 2022

(2) emergency diesel generator A, under job 21500305, on April 25, 2022

(3) essential service water train A flow verification, under Job 20004407, on April 30, 2022

(4) emergency diesel generator B, under job 20500340, on May 9, 2022

(5) safeguards transformer B, under job 19002550, on May 11, 2022

(6) pressurizer power-operated relief valve, under job 20511888, on May 23, 2022

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated refueling outage 25 activities from April 4 to May 30, 2022.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:

Surveillance Tests (other) (IP Section 03.01) (4 Samples)

(1) component cooling water system train A on April 8, 2022

(2) emergency exhaust system train A on April 13, 2022

(3) pre-fuel movement surveillance verifications on April 19, 2022

(4) main steam isolation valve testing on May 22, 2022

Inservice Testing (IP Section 03.01) (1 Sample)

(1) excess letdown to reactor coolant drain tank and seal water heat exchanger inservice leak test on April 29, 2022

FLEX Testing (IP Section 03.02) (1 Sample)

(1) FLEX auxiliary feedwater system surveillance test on April 14,

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.

Instructions to Workers (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.

Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)

The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:

(1) potentially contaminated material and worker/personnel surveys leaving the radiological control area during refueling outage 25

(2) highly activated radioactive material and high dose rate filter storage in the spent fuel pool

(3) storage, posting, and labeling of radioactive sources: 3217GN, 4660/0819GG, 5030GH, and E-083

Radiological Hazards Control and Work Coverage (IP Section 03.04) (5 Samples)

The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:

(1) ALARA package R25-53020, revision 0, (radiation work permit (RWP)

R25SGLANCE, revision 0) to perform steam generator water lancing

(2) ALARA package R25-53023SG, revision 0, (RWP R25SGHHOL, revision 0) to remove and replace secondary hand hole covers on all steam generators

(3) ALARA review R25-56321, revision 1, (RWP R25LOWERINLIFT, revision 1) to remove and reinstall reactor vessel lower internals (core barrel lift)

(4) RWP R25SGFOSAR, revision 0, to perform steam generator secondary side foreign object search through hand holes (secondary side inspection)

(5) RWP R25SGUI, revision 0, to inspect EBB01B and EBB01C steam generator upper internals which include equipment movements, manway removal and reinstallation, radiation protection coverage, and other support tasks High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (3 Samples)

The inspectors evaluated licensee controls of the following high radiation areas and very high radiation areas:

(1) In-core detector and thimble tube storage in the in-core tunnel

(2) regenerative heat exchanger piping

(3) steam generators' secondary side and secondary hand hole access Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)

(1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Permanent Ventilation Systems (IP Section 03.01) (2 Samples)

The inspectors evaluated the configuration of the following permanently installed ventilation systems:

(1) FGK02A control room pressure filter adsorber unit A

(2) FUB 7001 technical support center filter adsorber unit

Temporary Ventilation Systems (IP Section 03.02) (1 Sample)

The inspectors evaluated the configuration of the following temporary ventilation system:

(1) radioactive storage building decontamination bench

Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees use of respiratory protection devices.

Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.

71124.06 - Radioactive Gaseous and Liquid Effluent Treatment

Walkdowns and Observations (IP Section 03.01) (4 Samples)

The inspectors evaluated the following radioactive effluent systems during walkdowns:

(1) liquid radwaste discharge system

(2) reactor building vent

(3) radwaste building vent

(4) containment purge that discharges into the reactor building vent system

Sampling and Analysis (IP Section 03.02) (5 Samples)

Inspectors evaluated the following effluent samples, sampling processes and compensatory samples:

(1) reactor building vent, GT-RE-31, particulate sample dated June 14, 2022

(2) radwaste building vent, RP-13, noble gas sample dated August 8, 2019

(3) reactor building vent, GT-RE-21C, iodine sample dated June 1, 2021

(4) reactor building vent, GT-RE-31, particulate sample dated July 2, 2019

(5) liquid discharge monitor tank B sample dated August 27, 2020

Dose Calculations (IP Section 03.03) (2 Samples)

The inspectors evaluated the following dose calculations:

(1) batch liquid radioactive release permit RP10-2022-L0025

(2) continuous airborne radioactive release permit RP13-2020-G0002

Abnormal Discharges (IP Section 03.04) (1 Sample)

The inspectors evaluated the following abnormal discharges:

(1) abnormal gaseous discharge from the waste gas decay tank D into room 7107 which vented into the radwaste vent on August 28, 2022

71124.07 - Radiological Environmental Monitoring Program

Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated environmental monitoring equipment and observed the collection of environmental samples.

Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the implementation of the licensees radiological environmental monitoring program.

Groundwater Protection Initiative Implementation (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees implementation of the Groundwater Protection Initiative to identify incomplete or discontinued program elements. The licensee is appropriately adjusting their monitoring program to meet the groundwater protection program elements.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS05: Safety System Functional Failures Sample (IP Section 02.04) ===

(1) April 1, 2021, through March 31, 2022

MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)

(1) April 1, 2021, through March 31, 2022

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) October 1 through December 31, 2021 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences Radiological Effluent Occurrences Sample (IP Section 02.16)

(1 Sample)

(1) October 1 through December 31, 2021

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Diesel generator train B cooling supply fan blade corrective maintenance, under condition report 202203776, on June 13, 2022

(2) Auxiliary feedwater environmental qualification design basis, under condition report 202204047, on June 15, 2022

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in component cooling water that might be indicative of a more significant safety issue.

71153 - Follow Up of Events and Notices of Enforcement Discretion Personnel Performance (IP Section 03.03)

(1) The inspectors evaluated the transition to automatic feedwater regulating valve control during reactor startup and the licensees performance on May 31,

INSPECTION RESULTS

Failure to Correctly Translate Design Requirements for the Auxiliary Feedwater System Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71152A Systems NCV 05000483/2022002-01 Open/Closed The inspectors identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion III, Design Control, for the licensees failure to assure that applicable regulatory requirements and the design bases, as defined in 10 CFR 50.2 and as specified in the license application, for those structures, systems and components to which this appendix applies, were correctly translated into specifications, drawings, procedures, and instructions. Specifically, in 1998, the licensee improperly changed the FSAR and plant operating procedures to allow use of the auxiliary feedwater systems beyond responding to plant events or for required testing.

Prior to this change, the auxiliary feedwater systems environmental qualification was assessed as moderate-energy on the basis that the system was infrequently used and not used during plant startups or hot-standby. As a result, the licensee operated the auxiliary feedwater system for operational convenience and in a manner that conflicted with NRC design requirements for the system.

Description:

Callaways auxiliary feedwater system (AFW or AFS) provides a reliable safety-related source of high-pressure feedwater to maintain steam generator water level and remove heat from the reactor coolant system when the main feedwater system is unavailable.

As an essential system, AFW is the credited source of makeup water to the steam generators and is required to achieve and maintain safe shutdown and mitigate the consequences of a hypothetical accident.

Callaways Final Safety Analysis Report (FSAR) incorporated NRC Branch Technical Position ASB 3-1, "Protection Against Postulated Piping Failures in Fluid Systems Outside Containment," dated November 24, 1975, and NRC Branch Technical Position MEB 3-1, "Postulated Break and Leakage Locations in Fluid System Piping Outside Containment,"

dated November 24, 1975, as the basis for classifying high-energy systems and criteria for determining postulated high-energy line break locations. Branch Technical Position ASB 3-1 identified high-energy piping as those systems or portions of systems where either of the following conditions are met:

Maximum operating temperature exceeds 200°F Maximum operating pressure exceeds 275 psig, during normal plant conditions Callaways FSAR section 3.6.1.1, table 3.6-2, and NRC Branch Technical Position MEB 3-1 provided additional criteria for categorizing high-energy or moderate-energy systems.

Table 3.6-2, section B.2.e, Fluid Systems Qualifying as High-Energy or Moderate-Energy Systems, allowed fluid systems that qualify as high-energy for only short operational periods but qualify as moderate-energy fluid systems for the major operational period to be treated as a moderate-energy system for the purpose of postulating pipe breaks. Specifically, an operational period is considered short if the fraction of time that the system operates within the pressure-temperature conditions specified for high-energy fluid systems is about 2% of the time that the system operates as a moderate-energy fluid system (e.g., systems such as the reactor decay heat removal system qualify as moderate-energy fluid systems; however, systems such as AFW systems operated during pressurized water reactor startup, hot-standby, or shutdown qualify as high-energy fluid systems).

The original Westinghouse design categorized the AFW system as a high-energy system because either the sections of line which connected to the main feedwater piping or the steam generator are pressurized during plant operation or when in use during startup, hot-standby, and shutdown. During initial licensing in June 1981, the licensee informed the NRC that a motor-driven startup feedwater pump would be used during normal startup and shutdown operations instead of the AFW system. In a July 1981 letter, the NRC responded that "the applicants stated the AFW system will be classified the same as a moderate-energy system because it will only be used under accident conditions. A separate startup/shutdown feedwater train is being added to the main feedwater system. This was found acceptable by NRC." As a result, at the time of initial plant startup, revision 5 of the licensees FSAR reflects similar language stating "the AFS is not used during startup and shutdown; therefore, it is considered a moderate-energy system for the purposes of pipe breaks in the AFS."

In June 1998, the licensee created an engineering task to evaluate the use of the AFW system for routine activities including plant startup and shutdown. This evaluation, performed under Request for Resolution 10782, only referenced original Westinghouse documentation and did not include NRC correspondence from around the time of initial plant startup. Due to this incomplete review of the design basis, the licensee implemented FSAR Change Notice FSARCN 98-040 which added to section 10.4.9 of the FSAR, "If the normal motor driven startup feedwater pump is not available, the AFS may be operated with AFW pump discharge valves throttled when the reactor is below 10% power to maintain steam generator water levels during plant heatups or cooldowns."

This allowance for AFW use when the startup feedwater pump was unavailable was then later translated into plant procedures including procedure OTG-ZZ-00001, Plant Heatup:

Cold Shutdown to Hot Standby, revision 95. Specifically, section 5.7 addresses steam generator operation when the plant is in Modes 3, 4, and 5 stating, feed steam generators using either of the followingauxiliary feed[or] after chemistry approvalusing a condensate pump. This was also translated into Callaways license renewal application which, in Section 2.3.4.5, states that the purpose of the AFW system is to provide feedwater to the steam generators during startup, shutdown, and emergency conditions (Agencywide Documents Access and Management System (ADAMS) Accession Number ML15068A342).

The inspectors identified the improper design basis during a review of the design and operational history of the AFW system. The inspectors noted that classification of a system as moderate-energy, versus high-energy, results in reduced requirements for engineering analysis and system modifications for a hypothetical steam line break. Specifically, these items include the dynamic effects of pipe whip, jet impingement on surrounding targets, in-pipe fluid transients (water hammer) caused by the sudden break, and environmental effects in the form of spray wetting from fluid discharge from the break, and harsh ambient temperatures and humidity.

The inspectors noted the licensee has used the AFW system for operational convenience, as recently as December 2020, with the reactor in hot-standby. Specifically, while high in Mode 3 and exiting an outage, the licensee used the A and B motor-driven AFW pumps over 30 times over the five days leading up to a reactor startup to maintain steam generator water levels within desired bands.

The inspectors also noted that the licensee could restore compliance by either reverting to the previously approved guidance on operating the AFW as a moderate-energy system or pursuing a license amendment to harden the AFW system for use as a high-energy system.

Further, the inspectors assessed this issue under technical specifications but noted that it was a design issue only that did not affect operability.

The inspectors concluded the licensee failed to correctly translate the design requirements associated with high-energy line breaks into structures, systems and components.

Specifically, the licensee incorrectly changed the design basis of the AFW system without having a complete or accurate understanding of their facilitys design bases or regulatory requirements for high-energy line breaks and their effects on essential systems and components required to shut down the reactor and mitigate the consequences of an accident.

This resulted in a condition where AFW was operated outside of the design basis, as approved by the NRC, such that the licensee was simultaneously claiming the system as moderate-energy and utilizing it for non-emergency operational convenience.

Corrective Actions: The licensee generated condition reports to document the issues identified with the AFW systems design basis and to drive corrective action.

Corrective Action References: condition reports 202201251 and 202204047.

Performance Assessment:

Performance Deficiency: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the improper design change in 1998 led to the operation of the AFW system outside of its environmental qualification design.

Significance: The inspectors assessed the significance of the finding using Manual Chapter 0609, appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined the finding was of very low safety significance (Green)because the finding was a deficiency affecting the design or qualification of a mitigating SSC but the SSC maintained its operability or PRA functionality.

Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance. Specifically, the licensee implemented a FSAR change in 1998 that was the proximate cause of the performance deficiency.

Enforcement:

Violation: Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion III, requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in § 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions.

Contrary to the above, the licensee failed to establish measures to assure that applicable regulatory requirements and the design basis, as defined in section 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions.

Specifically, from June 30, 1998, to June 10, 2022, the licensee improperly changed the FSAR and plant operating procedures to allow use of the AFW systems beyond responding to plant events or for required testing. Prior to this change, the AFW systems environmental qualification was assessed as moderate-energy on the basis that the system was infrequently used and not used during plant startups or hot-standby. As a result, the licensee operated the AFW system for operational convenience and in a manner that conflicted with NRC design requirements for the system.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Observation: Semiannual Trend Review 71152S The inspectors reviewed the licensees corrective action program, system health reports, and other documentation to identify trends that might indicate the existence of a more significant safety issue related to the component cooling water (CCW) system.

Background:

In April 2021, the licensee wrote condition report 202102341 to assess a potential trend in CCW valve leak-by leading to slow changes in each trains surge tank level. The review included 11 condition reports, dating back to 2013, where operations noted surge tank levels would increase or decrease by a rate of up to 2 percent per hour. The cause of this level change was determined to be leak-by of butterfly and check valves for the non-safety service loop, both on the supply and return sides, when certain configurations of CCW pump trains are operated. At the time of the 2021 trend review, the licensee determined there was a trend but qualified that the trend was not adverse on safety or reliability of CCW. Specifically, the licensee noted there was not an increasing frequency of events and the leakage value itself was also stable across events. The licensee evaluated the leakage amount as within the makeup capacity of the non-safety demineralized water system and the safety-related essential service water system (ESW), which supplies make-up water to the CCW system during design basis events. As a corrective action, the licensee generated a new on-demand preventative maintenance task to adjust the valves' travel limits to better seat the discs when increased leakage is detected. Lastly, an effectiveness review was assigned to monitor the CCW system for surge tank leakage over the next two years and ensure issues identified are corrected within three months of any future condition reports using the new preventative maintenance task PM1010051.

In November 2021, the licensee wrote condition report 202106142 for another occurrence of CCW surge tank levels changing due to valve leak-by. At that time, the licensee scheduled the new preventative maintenance task PM1010051. Later, however, the scope of the proposed work task changed to increase torque on the valve operator for valve EGHV0054 which was ultimately unsuccessful when performed in January 2022. Then, a series of work tasks were scheduled with the intention to perform valve work in the upcoming spring 2022 outage.

On May 2, 2022, during restoration of train A of CCW during a planned maintenance and refueling outage, operations staff wrote condition report 202202963 documenting a missed opportunity to address the CCW valve leak-by. Specifically, the licensee identified that only one of the potential six valves with leak-by, valve EGV0061, had been incorporated into the scope of refueling outage 25. The other valves had not been appropriately flagged for an outage scope review due to a human performance error when screening the job packages.

As a result, when operations restored train A of CCW, they noted the surge tank level change issue occurring again.

On May 7, 2022, the licensee wrote condition report 202203151 to document another occasion of CCW valve leak-by which was considered a post-maintenance test failure for the work on valve EGV0061. On May 8, 2022, the licensee wrote condition report 202203169 to document that the previous strategy of running certain combinations of CCW pumps was not effective at limiting the CCW surge tank trends due to valve leak-by. Through these condition reports, the licensee assigned corrective actions to review the CCW system at a higher level for a system health concern and to track the individual valve maintenance tasks to ensure they are scheduled.

Inspector Assessment:

The NRC independently reviewed the history of the CCW system including in the corrective action program. It is important to note that the leakage referred to in this discussion is between trains of a closed system. The scenario of concern is operation of one train of CCW post-event and ensuring enough cooling water is available, including system leakage and available make-up water, for that train for the required duration of time to mitigate a hypothetical accident.

The inspectors noted that the licensee has performed operability reviews on the condition reports in question. Further, the FSAR describes the ability to make-up to the CCW system via safety-related ESW post-accident and the NRC confirmed that the licensee has accounted for this leakage in their ESW inventory calculations for design basis events. As such, the current leakage is bounded by existing analysis and operability is supported.

Finally, there has been no more-than-minor consequence to this leakage existing in the system since it is well within the capability of both safety and non-safety makeup. Beyond the operability review, the NRC provided observations to the licensee on this history of CCW system leakage.

The inspectors determined that the corrective action program has not been effective in addressing the issues with intra-train leakage in the CCW system in a timely manner. This includes the licensee missing an opportunity to address the known CCW butterfly valve leakage in the most recent refueling outage. Despite a significant duration for other planned work in the 2022 outage, the licensee was unable to successfully address the known valve issues that have existed since 2013. Further, the licensee has yet to execute any adjustment of butterfly valve travel limits under preventative maintenance task PM1010051 although they were aware of CCW valve leak-by in November 2021 and again in January 2022. As a result, the effectiveness review under condition report 202102341 is now disconnected from actual troubleshooting that has taken place since April 2021. Further, this effectiveness review is still open, with a due date of 2023, despite the multiple documented cases of CCW valve leak-by in one year which would exceed the criteria set in the review.

Although there have not been any failures to maintain CCW inventory within limits in the last 2 years, the licensee has not prioritized addressing degraded conditions in the system. The licensee's current corrective action strategy lacks coordination and has the potential to lead to more significant safety concerns. Specifically, excessive intra-train valve leakage could result in unplanned inoperable equipment which would impact the availability and reliability of the CCW system.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On April 15, 2022, the inspectors presented the occupational radiation safety inspection results to Mr. B. Cox, Site Vice President, and other members of the licensee staff.

On June 16, 2022, the inspectors presented the public radiation safety inspection results to Mr. B. Cox, Site Vice President, and other members of the licensee staff.

On July 6, 2022, the inspectors presented the Callaway inservice inspection results to Mr. F. Bianco, Senior Director, Nuclear Operations, and other members of the licensee staff.

On July 6, 2022, the inspectors presented the integrated inspection results to Mr. F. Bianco, Senior Director, Nuclear Operations, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Corrective Action Condition Reports 202201245, 202202252, 202202482, 202202906

Documents

71111.04 Corrective Action Condition Reports 202003812, 202003821, 202004518, 202006123,

Documents 202103840, 202202635

71111.04 Drawings M-22EG01 Piping and Instrument Diagram Component Cooling Water 10

System

71111.04 Drawings M-22EG02 Piping and Instrument Diagram Component Cooling Water 21

System

71111.04 Drawings M-22G03 Piping and Instrument Diagram Component Cooling Water 24

System

71111.04 Miscellaneous Checklist 0001 Standby Diesel Generator 'A' System Valve Alignment 15

71111.04 Procedures OSP-NB-00001 Class 1E Electrical Source Verification 46

71111.04 Procedures OTN-NE-0001A Standby Diesel Generation System - Train A 54

71111.05 Corrective Action Condition Reports 201805579, 202203491

Documents

71111.05 Miscellaneous Fire Preplan Manual 41

71111.05 Procedures OTO-KC-00001 Fire Response 20

71111.06 Calculations Pipe room flooding

calculation

71111.06 Corrective Action Condition Reports 202002097, 202003154, 202003693

Documents

71111.06 Miscellaneous Licensee Event Wolf Creek LER, Potential Submergence of Safety-Related 1/14/2002

Report Equipment due to an Inadequate Flooding Calculation

05000482/2001-

001-00

71111.06 Miscellaneous M-22-AL01 Piping & Instrumentation Diagram - Auxiliary Feedwater 51

System - FSAR Figure 10.4-9

71111.06 Miscellaneous M-FL-04 Determine Flood Levels in Auxiliary Building Rooms 1206 3

and 1207

71111.07A Miscellaneous MP 19-0018 UHS Tower Return to UHS Pond 2

71111.08P Calculations EF-123 UHS (Ultimate Heat Sink)Thermal Performance Analysis 2

using GOTHIC

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.08P Corrective Action Condition Report 202101905, 202101949, 202101957, 202101989,

Documents 202102033, 202102039, 202102043, 202102062,

2102071, 201805365, 202100700, 202101280,

2101449, 202101612, 202101905, 202102148,

201905820, 202102197, 202102997, 201907170,

2103062, 202104099, 202104306, 202104411,

2105219, 201902445, 202005161, 202005211,

2005386, 202006090, 201608055, 202101905,

2005161

71111.08P Corrective Action Condition Reports 202201971, 20222086, 20222219, 20222247, 20222253,

Documents 20222262, 20222298, 20222099, 202205161, 202205211,

Resulting from 202202197, 202202253, 202202262, 202202298,

Inspection 202204498, 202204515, 202202247

71111.08P Engineering SCP-RV000-TR- Callaway Unit 1 Reactor Vessel Cold Leg Elbow to 0

Evaluations CF-000001-P Safe-End Stainless Steel Weld Flaw Evaluation

71111.08P Miscellaneous 51-9312589 -000 Callaway Unit 1 Steam Generator Operational Assessment 0

to Support Deferral of Planned Inspections from 1R24 to

1R25

71111.08P Miscellaneous Fourth Interval Inservice Inspection Program Plan 2

71111.08P Miscellaneous 51 - 9258120 - 000 Callaway 1RF21 Secondary Side Visual Inspection Final 0

Report

71111.08P Miscellaneous 51 - 9259621 - 000 Callaway Unit 1 SG Condition Monitoring for Cycles 19, 20 0

and 21 and Final Operational Assessment for Cycles 22,

and 24

71111.08P Miscellaneous 51 - 9345615 - 000 Callaway Unit 1 SG Condition Monitoring for Cycles 22, 23, 05/20/2022

and 25 and Preliminary Operational Assessment for

Cycles 26, 27, 28, 29 and 30

71111.08P Miscellaneous 51 - 9346179 - 000 Callaway RFO25 SG ECT Inspection Plan 0

71111.08P Miscellaneous AP20003 Nuclear Oversight Audit of In-service Inspection (ISI) and 10/27/2020

In-service Testing (IST)

71111.08P Miscellaneous ASME OMa Section Preservice and Inservice Examination and Testing of 2005 edition

ISTD Dynamic Restraints (Snubbers) in Light-Water Reactor

Nuclear Power Plants

71111.08P Miscellaneous BT 202000212-003 Topic/Title: INPO Materials Review Visit (MRV) 03/05/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

Preparation Self-Assessment

71111.08P Miscellaneous EPID L-2018-LLR- Callaway Plant, Unit 1- Request for Relief Request Related 1

0039 to the Inservice Inspection Program for Class 3 Buried

High-Density Polyethylene Piping

71111.08P Miscellaneous ETP-BB-01309 Steam Generator Eddy Current Testing Acquisition and 25

Analysis Guidelines

71111.08P Miscellaneous SCP-04-52 CALLAWAY PLANT WCAP-16280-P, Flaw Evaluation 5/17/2004

Handbook for Callaway Unit 1 Reactor Vessel Inlet Nozzle

Safe End Weld Region

71111.08P Miscellaneous ULNRC-06630 Callaway Plant Unit 1 Union Electric Co. Renewed Facility 0

Operating License NPF-30 Owners Activity Reports (OAR-

Forms) for Cycle/Refuel 24

71111.08P Procedures A210.0069 Callaway Energy Center Operational Quality Control 33

Manual (OQCM)

71111.08P Procedures APA-ZZ-0036 Callaway Rigging Program 31

71111.08P Procedures APA-ZZ-00365, Callaway Rigging Operations 15

Addendum R

71111.08P Procedures APA-ZZ-00500 Corrective Action Program 75

71111.08P Procedures APA-ZZ-00661 Administration of Welding 20

71111.08P Procedures APA-ZZ-00661, Personnel Approved to Perform Weld 9

Appendix 3 Inspections/Examinations

71111.08P Procedures APA-ZZ-00662 ASME Section Xi Repair/Replacement Program 26

71111.08P Procedures APA-ZZ-00741 Control of Combustible Materials 38

71111.08P Procedures APA-ZZ-00741, Flammable Liquid Cabinet Locations 28

Appendix 1

71111.08P Procedures APA-ZZ-00810 NPDES Permit Compliance 25

71111.08P Procedures APA-ZZ-00831 Hazardous Chemical Control Program 21

71111.08P Procedures APA-ZZ-00831, Ameren UE Hazardous Materials System Label-Exempt 2

Appendix B Permits

71111.08P Procedures EDP-ZZ-01004 Boric Acid Corrosion Control Program 25

71111.08P Procedures EDP-ZZ-01007 Mechanical Snubber Program 32

71111.08P Procedures ESP-ZZ-00356 Technical Specification 5.5.2.B Verification Integrated Leak 7

Rate Requirements for Primary Coolant Sources Outside

Containment

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.08P Procedures ETP-ZZ-04051 Hanger and Restraint - Repair and Rework 13

71111.08P Procedures LMT-21-PAUT-029 Phased Array Ultrasonic Examination Report Socket Weld 0

Examination Demonstration

71111.08P Procedures PDI-UT-5 PDI Generic Procedure for the Straight Beam Ultrasonic G

Examination of Bolts and Studs

71111.08P Procedures QCP-ZZ-05000 Liquid Penetrant Examination 28

71111.08P Procedures QCP-ZZ-05010 Magnetic Particle Examination 23

71111.08P Procedures QCP-ZZ-0504 Visual Examination to ASME VT-3 22

71111.08P Procedures QCP-ZZ-05040 Visual Examination to ASME VT-1 25

71111.08P Procedures QCP-ZZ-05041 Visual Examination to ASME VT-2 31

71111.08P Procedures QCP-ZZ-05048 Boric Acid Walkdown for RCS Pressure Boundary 15

71111.08P Procedures QSP-ZZ-65044 Mechanical Snubber Visual and Transient Event Inspection 14

71111.11Q Procedures OTG-ZZ-00002 Reactor Startup - IPTE 64

71111.12 Corrective Action Condition Reports 202202870

Documents

71111.12 Miscellaneous EPRI 1009210 Storage and Handling of Fuel Oil for Standby Diesel 2

Generator Systems

71111.12 Procedures CSP-ZZ-07350 Diesel Fuel Oil Testing Program 30

71111.12 Procedures OTS-JE-00001 Receipt and Handling of Diesel Fuel Oil 10

71111.12 Work Orders 22501931

71111.13 Procedures ODP-ZZ-00002 Risk Management Actions for Planned Risk Significant 19

Activities

71111.15 Corrective Action Condition Reports 202203378, 202203432, 202203343 202203400,

Documents 202203419

71111.18 Miscellaneous Job 21001926 Seal Table High Pressure Fitting Replacement

71111.18 Miscellaneous MP 20-0031 Seal Table High Pressure Fitting Replacement

71111.19 Procedures OTN-NE-0001A Standby Diesel Generation System - Train A 30

71111.19 Procedures OTN-NE-0001B Standby Diesel Generation System - Train B 57

71111.19 Work Orders 21500305, 20500340

71111.20 Corrective Action Condition Reports 202201969, 202201971, 202202004, 202202018,

Documents 202202043

71111.20 Miscellaneous Shutdown Safety Management Plan 2

71111.20 Procedures ODP-ZZ-00002, Risk Management Actions for Planned Risk Significant 19

Inspection Type Designation Description or Title Revision or

Procedure Date

Appendix 2 Activities

71111.20 Procedures OOA-AE-00004 Steam Generator Secondary Data 3

71111.20 Procedures OOA-BB-00003 Refuel Level Indications 14

71111.20 Procedures OTN-BB-00002, Draining the RCS to Limited Inventory or Reduced 32

Addendum 6 Inventory - IPTE

71111.22 Miscellaneous Inservice Testing Program 36

71111.22 Procedures APA-ZZ-00356 Pump and Valve Inservice Test Program 28

71111.22 Procedures OSP-AB-V02HS Main Steam Isolation Valve Inservice Test 10

71111.22 Procedures OSP-AB-V2CSD Main Steam Isolation Valve Functional Stroke 14

71111.22 Work Orders 20511775

71124.01 ALARA Plans R25-53023 SG RWP 25SGHHOLE: SG Secondary Side Hand Hole Work - 04/05/2022

Remove / Replace Secondary Hand Hole Covers on All

Steam Generators

71124.01 ALARA Plans R25-53321 RB RWP R25SGMAN: Steam Generator Manway Cover 04/02/2022

SGMANWAY Removal, Re-installation and Bolt Hole Work

71124.01 Corrective Action Condition Reports 202106297, 202106638, 202200202, 202200298,

Documents 202200311, 202200779, 202200848, 202200914,

2201023, 202201503, 202201679, 202201707

71124.01 Miscellaneous Access Control Dose by Selected Departments Report: 04/12/2022

April 8 - April 12, 2022

71124.01 Miscellaneous Source Trax: Source Inventory Report H120.0032 01/19/2022

71124.01 Miscellaneous ALARA Briefing RWP R25SGDRUM: Steam Generator Playpen Set 04/09/2022

Package Up/Tear Down, Operating the Two River Technologies

Vacuum Systems, and Ventilation Set Up/Tear Down

71124.01 Miscellaneous ALARA Briefing RWP R25SGHHOLE and RWP R25SGFOSAR: 04/02/2022

Package Remove/Replace Secondary Hand Hole Covers on All

Steam Generators and Perform Steam Generator

Secondary Side Foreign Object Search Through Hand

Holes (SSI).

71124.01 Procedures APA-ZZ-0100 Radiological Work Standards 35

71124.01 Procedures APA-ZZ-01000 Callaway Energy Center Radiation Protection Program 48

71124.01 Procedures APA-ZZ-01004 General Instructions for Donning / Removing Protective 8

Appendix A Clothing

71124.01 Procedures APA-ZZ-01004 General Instruction for Personnel Frisking Upon Exit from a 5

Inspection Type Designation Description or Title Revision or

Procedure Date

Appendix B Satellite RCA or Contaminated Area

71124.01 Procedures ETP-BB-03151 Reactor Vessel Lower Internals Removal - IPTE 18

71124.01 Procedures HDP-ZZ-01500 Radiological Postings 52

71124.01 Procedures HDP-ZZ-03000 Radiological Survey Program 49

71124.01 Procedures HDP-ZZ-03000 Performing Radiation Surveys 14

Appendix B

71124.01 Procedures HDP-ZZ-03000 Performing Contamination Surveys 8

Appendix C

71124.01 Procedures HDP-ZZ-03000 Performing Airborne Radioactivity Surveys 9

Appendix D

71124.01 Procedures HTP-ZZ-06001 High Radiation/Locked High Radiation/Very High Radiation 54

Area Access

71124.01 Procedures HTP-ZZ-06028 Radiological Controls for Pools that Contain or Store Spent 10

Fuel

71124.01 Radiation CA-M-20160402-38 RB2023 Steam Generator Lance Platforms BART's 04/02/2016

Surveys Installation

71124.01 Radiation CA-M-20220404-10 RB2026 Pressurizer Shed Initial Entry 04/04/2022

Surveys

71124.01 Radiation CA-M-20220405-8 RB2009 Lower Cavity - Blind Flange Removal 04/05/2022

Surveys

71124.01 Radiation CA-M-20220406-1 RB2023I Reactor Building Sludge Lance Platforms 04/06/2022

Surveys General Area Survey

71124.01 Radiation CA-M-20220407-16 RB2031I Insulation Removal from Steam Generator A, B, 04/07/2022

Surveys C, D Hand Holes

71124.01 Radiation CA-M-20220408-27 RBADSGHH-A Posting Steam Generator Hand Holes 04/08/2022

Surveys

71124.01 Radiation CA-M-20220411-10 RB2000 Inside Bioshield Crud Burst Verification 04/11/2022

Surveys

71124.01 Radiation CA-M-20220411-15 RB2000 Inside Bioshield - Insulation Removal from 04/11/2022

Surveys Reactor Coolant Drain Lines

71124.01 Radiation Work R25ISISCAFF R25ISISCAFF - ISI Scaffold Build/Removal to Support ISIS 0

Permits (RWPs) Inspection in High Radiation Areas

71124.01 Radiation Work R25LCPREP4FUEL R25LCPREP4FUEL - Lower Cavity Refueling Preparations 0

Permits (RWPs)

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.01 Work Orders 19506144/350 Remove Lagging and Insulation on Piping Spool BB-020- 05/12/2019

BCA-2 (Reactor Coolant Drain Insulation Removal)

71124.01 Work Orders 20512592/500 Lower Cavity Refueling Preparation HKE08 12/03/2020

71124.01 Work Orders PM1002835 Inventory Non-Special Nuclear Material Stored in Spent 04/01/2022

Fuel Pool

71124.03 ALARA Plans R25-51520 RB RWP R25CAVDECON: Reactor Cavity Decontamination 03/21/2022

RFDECON Activities, Upper/Lower Levels, Gross Rinse and Rusty

Flange Including All RP Coverage and Surveys

71124.03 ALARA Plans RF25 S/G RWP R25SGEC and RWP R25SGECSETUP: Setup 04/02/2022

PRIMARY Steam Generator Eddy Current Equipment and Steam

Generator Tube Eddy Current Testing in All Four Steam

Generators

71124.03 Corrective Action Condition Reports 202106298, 202106861, 202200150

Documents

71124.03 Procedures ESP-GK-03001 FGK01A Charcoal Test Canister Removal and Lab Testing 20

71124.03 Procedures ESP-GK-03003 FGK02A Charcoal Test Canister Removal and Lab Testing 19

71124.03 Procedures ESP-UB-03001 FUB7001 Charcoal Test Canister Removal and Lab 18

Testing

71124.03 Procedures ESP-UB-03012 FUB7001 In-Place Bypass Leakage Test 4

71124.03 Procedures HDP-ZZ-01200 Radiation Work Permits 34

71124.03 Procedures HDP-ZZ-08000 Respiratory Protection Program 24

71124.03 Procedures HTP-ZZ-08002 Respiratory Protection Issue and Use

71124.03 Procedures HTP-ZZ-08203-DTI- Testing Scott Regulators and Respirators Using the 11

Regulators Biosystems Posichek 3 USB Tester

71124.03 Procedures HTP-ZZ-08208-DTI- Quantitative Respirator Fit Testing Using the TSI 3

FITPRO-TESTING Portacount Pro System

71124.03 Work Orders 18506321-500 FGK02 ESP-GK-03011 11/18/2019

71124.03 Work Orders 18508880-500 FUB7001 ESP-UB-03001 02/06/2020

71124.03 Work Orders 19003416, Posi3 USB Test Results - Functional Test 07/05/2019

19003417,

19003418,

19003419

71124.03 Work Orders 19501614-500 FUB7001 ESP-UB-03012 06/16/2020

71124.03 Work Orders 19513649.500 FGK02 ESP-GK-03011 03/11/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.03 Work Orders 20001373 Posi3 USB Test Results - Functional Test 05/20/2020

71124.03 Work Orders 20002251 Posi3 USB Test Results - Regulator/Demand Valve Test 08/11/2020

71124.03 Work Orders 20501202-500 FUB7001 ESP-UB-03001 07/13/2021

71124.03 Work Orders 20505547.500 FUB7001 ESP-UB-03012 12/15/2021

71124.03 Work Orders 21000856, Posi3 USB Test Results - Functional Test 03/02/2021

21000858,

21000851,

21000853,

21000863,

21000864

71124.03 Work Orders 21001105, Posi3 USB Test Results 03/16/2021

21001098

71124.03 Work Orders 21004857, Posi3 USB Test Results - Functional Test 12/29/2021

21004858,

21004876,

21004877

71124.06 Calculations HPCI 2001 Evaluation of the 2020 Annual Land Use Census 10/16/2020

71124.06 Calculations HPCI 2102 Evaluation of the 2021 Annual Land Use Census 12/08/2021

71124.06 Corrective Action Condition Reports 201907203, 202002020, 202004261, 202004262,

Documents 202005185, 202007065, 202007173, 202007364,

2100014, 202100617, 202101503, 202102260,

2102668, 202104502, 202104739, 202106133,

2106333, 202106385, 202106758, 202107065,

2200107, 202200123, 202200252, 202200298,

2200327, 202200430, 202201595, 202203111

71124.06 Miscellaneous Callaway Energy Center 2019 Annual Radioactive Effluent 0

Release Report

71124.06 Miscellaneous PV-5 resin Part 61 analysis sample report 06/06/2022

71124.06 Miscellaneous Ameren Missouri, Callaway: Results of Radiochemistry 06/20/2020

Cross Check Program, 2nd Quarter 2020, revision 1

71124.06 Miscellaneous Ameren Missouri, Callaway: Results of Radiochemistry 05/14/2021

Cross Check Program, 2nd Quarter 2021, revision 0

71124.06 Miscellaneous Ameren Missouri, Callaway: Results of Radiochemistry 06/12/2020

Cross Check Program, 2nd Quarter 2020, Additional

Inspection Type Designation Description or Title Revision or

Procedure Date

Position

71124.06 Miscellaneous Callaway Energy Center 2021 Annual Radioactive Effluent 0

Release Report

71124.06 Miscellaneous Callaway Energy Center 2020 Annual Radioactive Effluent 0

Release Report

71124.06 Miscellaneous RP09-2021-L0049 Batch liquid radioactive release permit package 12/02/2021

71124.06 Miscellaneous RP10-2020-L0032 Batch liquid radioactive release permit package 08/28/2020

71124.06 Miscellaneous RP11A-2019- Batch airborne radioactive release permit package 07/02/2019

G0040

71124.06 Miscellaneous RP12-2021-G0001 Continuous airborne radioactive release permit package 06/01/2021

71124.06 Miscellaneous RP13-2019-G0022 Continuous airborne radioactive release permit package 08/08/2019

71124.06 Miscellaneous RP13-2020-G0002 Continuous airborne radioactive release permit package 03/12/2020

71124.06 Procedures APA-ZZ-00500 Corrective Action Program 75

71124.06 Procedures APA-ZZ-00500 Screening Process Guidelines 44

Appendix 17

71124.06 Procedures APA-ZZ-01003 Off-site Dose Calculation Manual 26

71124.06 Procedures HTP-ZZ-02006 Liquid radwaste release permit (batch) 100

71124.06 Procedures HTP-ZZ-02007 Gaseous Radwaste Release Permit (Gas Decay Tank) 50

71124.06 Procedures HTP-ZZ-02008 Gaseous Radwaste Release Permit (Auxiliary/Fuel 32

Building Ventilation)

71124.06 Procedures HTP-ZZ-02008 Gaseous Radwaste Release Permit (Auxiliary/Fuel 11

Addendum A Building Ventilation)

71124.06 Procedures HTP-ZZ-02009 Gaseous Radwaste Release Permit (Radwaste Building 31

Ventilation)

71124.06 Procedures HTP-ZZ-02009 Gaseous Radwaste Release Permit (Radwaste Building 14

Addendum A Ventilation)

71124.06 Procedures HTP-ZZ-02012 Gaseous Radwaste Release Permit (Containment) 54

71124.06 Procedures HTP-ZZ-02012 Gaseous Radwaste Release Permit (Containment) 21

Addendum A

71124.06 Procedures HTP-ZZ-02014 Release Permit Processing Using the EMS Application 65

Software

71124.06 Procedures HTP-ZZ-02021 Gaseous Radwaste Release Permit (Miscellaneous 18

Release Points)

71124.06 Procedures RP-DTI-COUNT Count Room Routine Activities 28

Inspection Type Designation Description or Title Revision or

Procedure Date

ROOM-ROUTINES

71124.06 Self- 202200120-020 Environmental and Effluent Programs 03/30/2022

Assessments

71124.07 Calculations HPCI 2102 Evaluation of the 2021 Annual Land Use Census 12/08/2021

71124.07 Calibration LAS-4174-HP F&J air pump calibration 12/02/2021

Records

71124.07 Calibration LAS-4176-HP F&J air pump calibration 12/02/2021

Records

71124.07 Calibration LAS-4207-HP F&J air pump calibration 03/04/2022

Records

71124.07 Corrective Action Condition Reports 201905421, 201905939, 201907992, 202000692,

Documents 202001218, 202001969, 202002031, 202002402,

2006627, 202007110, 202100519, 202100825,

2101465, 202101626, 202101781, 202102041,

2102552, 202103504, 202105145, 202105648,

2106638, 202200514, 202200549, 202200557,

2202345

71124.07 Miscellaneous CA0424 Callaway Environmental Air Sample Data Sheet 06/16/2022

71124.07 Miscellaneous CA1349 Environmental Sample Collection Data Sheet 06/14/2022

71124.07 Procedures APA-ZZ-01003 Offsite Dose Calculation Manual 26

71124.07 Procedures HTP-ZZ-07001-DTI- Collection and Shipping of Environmental Air Samples 13

AIR-SAMPLING

71124.07 Procedures HTP-ZZ-07001-DTI- Collection and Shipping of Environmental Crop Samples 7

CROP-SAMPLING

71124.07 Procedures HTP-ZZ-07101-DTI- REMP Sample Locations and Analysis Schedule 54

REMP-SMPL-

SCHED

71124.07 Procedures RP-DTI- Environmental TLD Locations 7

ENVIRONMENTAL-

TLD-LOCATIONS

71124.07 Work Orders Job 20508244, 21504476.500, 21504486.500, 21511300.500,

21511304.500

71151 Corrective Action Condition Reports 202106638, 202106316, 202106824, 202200430,

Documents 202200914

Inspection Type Designation Description or Title Revision or

Procedure Date

71151 Miscellaneous Callaway Energy Center 2021 Annual Radioactive Effluent 04/20/2022

Release Report

71151 Miscellaneous MSPI Basis Documents and Data Various

71152S Corrective Action Condition Reports 202202963, 202203776, 202204047

Documents

71153 Corrective Action Condition Reports 202203767, 202203776, 202203879

Documents

71153 Procedures OTG-ZZ-00003 Plant Startup Hot Zero Power to 30% Power - IPTE 64

27