IR 05000483/2022004

Integrated Inspection Report 05000483/2022004

ML23009B605
Person / Time
Site:	Callaway
Issue date:	01/12/2023
From:	Greg Werner NRC/RGN-IV/DORS/PBB
To:	Diya F Ameren Missouri
References
IR 2022004
Download: ML23009B605 (24)

Text

January 11, 2023

SUBJECT:

CALLAWAY PLANT - INTEGRATED INSPECTION REPORT 05000483/2022004

Dear Fadi Diya:

On December 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Callaway Plant. On January 11, 2023, the NRC inspectors discussed the results of this inspection with you 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 Callaway Plant.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at 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 01/11/23 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: 05000483/2022004 Enterprise Identifier: I-2022-004-0000 Licensee: Ameren Missouri Facility: Callaway Plant Location: Steedman, MO Inspection Dates: October 1 to December 31, 2022 Inspectors: D. Bradley, Senior Resident Inspector S. Hedger, Senior Emergency Preparedness Inspector J. Melfi, Project Engineer D. Proulx, Senior Project Engineer S. Schwind, Senior Resident Inspector J. Vera, 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 Conduct Drills in Accordance with the Site Emergency Plan Cornerstone Significance Cross-Cutting Report Aspect Section Emergency Green [H.8] - 71114.05 Preparedness NCV 05000483/2022004-01 Procedure Open/Closed Adherence The inspectors identified a Green non-cited violation of 10 CFR 50.54(q)(2) associated with the licensees failure to follow their emergency plan. Specifically, the licensee failed to follow Callaway Plant Radiological Emergency Response Plan, revisions 52 and 53, section 8.2.3, which requires annual radiological monitoring drills. The licensee failed to conduct correctly scoped radiological monitoring drills in 2020 and 2021 by not including sampling activities both on-site and off-site.

Additional Tracking Items

None.

PLANT STATUS

Callaway plant began the inspection period at 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

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe cold weather on December 20, 2022.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (1 Sample)

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

(1) spent fuel pool cooling train B on October 6, 2022

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 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) control building 2000' elevation, Class 1 E switchgear train A, fire area C-9, on October 11, 2022

(2) control building 2000' elevation, Class 1 E switchgear train B, fire area C-10, on October 11, 2022

(3) auxiliary building 2047' elevation, general area, fire areas A-19 and A-20, on November 10, 2022

(4) auxiliary building 1974' and 2000' elevation, boron injection room and piping penetration room B, fire areas A-7 and A-25, on November 21, 2022

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)

(1) The inspectors observed and evaluated licensed operator performance in the control room during auxiliary feedwater system surveillance testing on October 31, 2022.

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

(1) The inspectors observed and evaluated licensed operator requalification training in the simulator on November 8, 2022.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

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

(1) valve EMHV8802B, safety injection pump B discharge to hot leg injection isolation, failure to stroke closed on October 4, 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) elevated risk due to 345 kV breaker testing in the switchyard on October 6, 2022

(2) elevated risk during a technical specification work window on train A class 1E electrical equipment air conditioning unit on October 18, 2022

(3) elevated risk during a technical specification work window on train A components including the emergency diesel generator, essential service water, and the ultimate heat sink on October 25, 2022

(4) elevated risk during calibration of main steam dump control loop pressure transmitter ABPT0500 on November 1, 2022

(5) elevated risk during maintenance on the normal charging pump on November 22, 2022

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)

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

(1) class 1E air conditioning unit SGK05A compressor temperature and other conditions under condition reports 202207056, 202206972, 202207007, 202207020, and

===202207111 on October 31, 2022

(2) void in safety injection pump B discharge piping under condition report 202207295 on November 4, 2022

(3) refueling water storage tank insulation removal during cold weather, condition report 202207052, on November 16, 2022

(4) ultimate heat sink fan design under condition report 202207687 on November 22, 2022

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

=

The inspectors evaluated the following temporary or permanent modifications:

(1) essential service water bypass valve shaft replacement under modification package MP 20-0068 on November 28, 2022

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) class 1E electrical equipment room air conditioner train B after a planned work window on October 11, 2022

(2) class 1E electrical equipment room air conditioner train A after a planned work window on October 19, 2022

(3) essential service water train A after a planned work window on October 26, 2022

(4) emergency diesel generator train A after a planned work window on October 27, 2022

(5) atmospheric steam dump train B after a planned work window on November 9, 2022

(6) control room air conditioning train A after a planned work window on November 15, 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) (1 Sample)

(1) emergency diesel generator train B fast start on a single air bank on October 12, 2022

71114.02 - Alert and Notification System Testing

Inspection Review (IP Section 02.01-02.04) (1 Sample)

(1) The inspectors evaluated the maintenance and testing of the alert and notification system between July 1 and November 18, 2022.

71114.03 - Emergency Response Organization Staffing and Augmentation System

Inspection Review (IP Section 02.01-02.02) (1 Sample)

(1) The inspectors evaluated the readiness of the Emergency Preparedness Organization between July 1, 2020, and November 18, 2022. Inspectors also evaluated the licensee's ability to staff their emergency response facilities in accordance with emergency plan commitments.

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors evaluated the 10 CFR 50.54(q) emergency plan change process and practices between July 1, 2020, and November 18, 2022. The evaluation reviewed screenings and evaluations documenting implementation of the process. In addition, the inspectors evaluated the following emergency plan revisions:

Radiological Emergency Response Plan, revision 54 (effective January 26, 2022)

Emergency Action Level Technical Basis Document (EIP-ZZ-00101, addendum 2), revision 19 (effective January 26, 2022)

The reviews of the change process documentation or the emergency plan changes do not constitute NRC approval.

71114.05 - Maintenance of Emergency Preparedness

Inspection Review (IP Section 02.01 - 02.11) (1 Sample)

(1) The inspectors evaluated the maintenance of the emergency preparedness program between July 1, 2020, and November 18, 2022. The evaluation reviewed evidence of completing various emergency plan commitments, the conduct of drills and exercises, licensee audits and assessments, and the maintenance of equipment important to emergency preparedness.

OTHER ACTIVITIES - BASELINE

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

MS07: High Pressure Injection Systems (IP Section 02.06) ===

(1) October 1, 2021, through September 30, 2022

MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)

(1) October 1, 2021, through September 30, 2022

BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)

(1) October 1, 2021, through September 30, 2022

EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)

(1) July 1, 2021, through September 30, 2022 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13)

(1 Sample)

(1) July 1, 2021, through September 30, 2022

EP03: Alert and Notification System Reliability Sample (IP Section 02.14) (1 Sample)

(1) July 1, 2021, through March 31, 2022 The licensee transitioned its alert and notification system to a purely non-siren-based system at the end of March 2022. The alert and notification PI and associated data will no longer required to be reported by the licensee, and thus will not be subject to further inspection/verification per IP 71151. Evaluation of the licensee's non-siren based alert notification system will be completed separately per IP 71114.02, Alert and Notification System Evaluation.

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) Room temperature monitoring not performed under condition report 202205390 on October 6, 2022

(2) Ultimate heat sink cooling tower fan DCEF01A failed to start under condition report 202206427 on December 2, 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 procedure usage that might be indicative of a more significant safety issue.

INSPECTION RESULTS

Failure to Conduct Drills in Accordance with the Site Emergency Plan Cornerstone Significance Cross-Cutting Report Aspect Section Emergency Green [H.8] - 71114.05 Preparedness NCV 05000483/2022004-01 Procedure Open/Closed Adherence The inspectors identified a Green non-cited violation of 10 CFR 50.54(q)(2) associated with the licensees failure to follow their emergency plan. Specifically, the licensee failed to follow Callaway Plant Radiological Emergency Response Plan, revisions 52 and 53, section 8.2.3, which requires annual radiological monitoring drills. The licensee failed to conduct correctly scoped radiological monitoring drills in 2020 and 2021 by not including sampling activities both on-site and off-site.

Description:

The inspectors reviewed drills and exercises conducted by the licensee between 2020 and 2022 and compared the drill and exercise evaluation reports to the requirements of the licensee emergency plan.

Callaway Plant Radiological Emergency Response Plan, revisions 52 and 53, section 8.2.3, requires that plant environs and radiological monitoring drills (on-site and off-site) are conducted annually. To verify these took place, the inspectors evaluated radiological monitoring drill reports (field monitoring teams) held on July 8, 2020, and August 19, 2021. In reviewing the reports, the inspectors observed that the various samples taken appeared to have been taken in one location. Discussion with the licensee staff revealed that all sampling activities in 2020 took place only off-site, and all in 2021 took place only on-site. For the 2022 drill, it was confirmed that it was completed on November 23, 2022, including sampling activity evaluation both on-site and off-site.

The inspectors reviewed the licensees documentation describing how emergency preparedness drills were developed and implemented. Licensee procedure KDP-ZZ-02001, Drill and Exercise Program, revision 28, section 6.1.1, says to test major parts of the emergency plan, including conduct of the radiological monitoring drill (field teams).

Definition 9.16 specifies that the drill requires both on-site and off-site sampling. Further, licensee procedure EIP-ZZ-A0020, Maintaining Emergency Preparedness, revision 34, section 5.4.9.e, reinforces that the required radiological monitoring drills include on-site and off-site collection and analysis of sample media. Procedural direction stated that activities to be evaluated were to include sampling in both locations, but the drill report scope descriptions did not include all salient elements described in them.

The inspectors determined that the licensee did not conduct annual radiological monitoring drills in a manner that ensured that all sampling activities were evaluated in all specified locations. Therefore, the inspectors concluded that the licensee did not follow the requirements of the site emergency plan.

Corrective Actions: The licensee entered these issues into the corrective action program.

Corrective Action References: Condition Report 202207914

Performance Assessment:

Performance Deficiency: The inspectors determined that the failure to conduct drills required by the emergency plan is a performance deficiency within the licensees ability to foresee and correct.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the ERO Performance attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The licensees ability to take adequate measures to protect the health and safety of the public is degraded when the licensee does not perform drills and exercises to ensure emergency response organization proficiency.

Significance: The inspectors assessed the significance of the finding using IMC 0609 appendix B, Emergency Preparedness SDP. The performance deficiency was determined to have very low safety significance (Green) because it was a failure to comply with NRC requirements, was not a loss of planning standard function, and was not a degraded risk significant planning standard function. The planning standard function was not lost because the licensee did conduct drills and training that addressed portions of the related emergency plan commitments.

Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. The finding had a cross-cutting aspect in the area of human performance associated with procedural adherence because the licensee did not follow processes, procedures, and work instructions to appropriately develop objective evaluation criteria for the radiological monitoring drills. Specifically, the drill documentation did not include the procedural requirement to evaluate sampling in both on-site and off-site locations.

This would have provided assurance that the emergency plan commitments would be addressed in further development of the drills scope.

Enforcement:

Violation: Title 10 CFR 50.54(q)(2) requires, in part, that a power reactor licensee follow an emergency plan which meets the requirements of Appendix E to 10 CFR, Part 50 and the standards of 10 CFR 50.47(b). Planning standard 10 CFR 50.47(b)(14) requires, in part, that the licensee conduct periodic drills to maintain key skills. Callaway Plant Radiological Emergency Response Plan, revisions 52 and 53, section 8.2.3, states, in part, that plant environs and radiological monitoring drills (on-site and off-site) are conducted annually.

Contrary to the above, between January 1, 2021, and November 23, 2022, Callaway Plant failed to follow an emergency plan which met the requirements of Appendix E and the standards of 10 CFR 50.47(b). Specifically, the licensee failed to conduct annual radiological monitoring drills involving the scope of evaluation required by the emergency plan to maintain key emergency response organization skills. The licensee failed to conduct annual radiological monitoring drills including sampling activity evaluation both on-site and off-site in 2020 and 2021.

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

Observation: The inspectors reviewed the licensees corrective action program, 71152S site-wide communications, and other documentation to determine if the licensee was identifying and entering trends into the corrective action program.

Background Between September 9 and October 13, 2022, the licensee documented 11 condition reports in their corrective action program related to procedure usage and adherence to plant standards. These occurrences involved administrative requirements, non-safety related work, or issues that were considered minor performance deficiencies. Together they represented an adverse trend regarding adherence to plant standards.

The licensee self-identified this trend in performance and on October 13, 2022, they issued a Red communication to their staff regarding these 11 condition reports. A Red communication is the vehicle used by licensee management for disseminating important information rapidly to first-line supervisors, who are required to present the information to their entire workgroup in-person. The subject of the communication was a Standards Stand Down which occurred the following day. It listed the 11 examples documented in the condition reports where plant standards had not been followed in a 24-day period. First-line supervisors then presented the information in the communication to their work groups on October 14, 2022, during the stand down.

Inspector Assessment The inspectors reviewed the 11 condition reports and concluded that none of the issues documented in them individually rose above a minor performance deficiency. Further, the inspectors agreed with the licensees conclusion that, collectively, the 11 occurrences were indicative of an adverse trend in standards usage and adherence. Given the general nature of the issues, an intentional communication and reinforcement of management expectations for procedure use was a reasonable corrective action accomplished by the Standards Stand Down on October 14.

The inspectors also noted that, aside from the original 11 condition reports, nothing was entered into the corrective action program to document this adverse trend until November 3, 2022. On that date, condition report 202207293 was generated to document a trend in minor deviations from procedure use.

The inspectors concluded that the licensee adequately identified an adverse trend and took reasonable corrective actions, but they did so outside of their corrective action program and its requirements. Specifically, condition report 202207293 was not initiated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovery of the condition as required by procedure APA-ZZ-00500, Corrective Action Program, revision 75. There are similarities between this observation and a minor performance deficiency discussed in the Callaway Plant Biennial Problem Identification and Resolution Inspection Report 05000483/2022010 (ADAMS Accession Number ML22277A822) regarding eight examples of failure to initiate condition reports where problems were known and corrected but not through the corrective action program.

The inspectors noted that several licensee organizations have also identified similar observations recently. For example, the licensees internal oversight group documented condition report 202205059 which states that station personnel are not always writing condition reports as required by the Corrective Action Program. The Nuclear Safety Review Board recommended continued engagement with the workforce around standards adherence in condition report 202207423. The performance improvement group generated condition report 202208006 to trend standards adherence through the month of November 2022 and noted there were a total of 15 examples of minor deviations.

Implementing an effective corrective action program is a key performance element in that a licensee demonstrates their ability to detect and correct problems at the right threshold.

Although there have not been any safety-significant impacts from issues around procedure adherence and the use of the corrective action program, the licensee has not always been effective in recognizing trends. The inspectors continued to monitor and assess the licensees use of the corrective action program through routine inspections. No additional trends were identified.

EXIT MEETINGS AND DEBRIEFS

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

On December 20, 2022, the inspectors presented the emergency preparedness program inspection results to Barry Cox, Site Vice President, and other members of the licensee staff.

On January 11, 2022, the inspectors presented the integrated inspection results to Fadi Diya, Senior Vice President and Chief Nuclear Officer, 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 202200010, 202200064, 202200563, 202206928,

Documents 202207317, 202207947, 202208041, 202208231

71111.01 Procedures OTO-ZZ-00012 Severe Weather 44

71111.01 Procedures OTS-ZZ-00007 Plant Cold Weather 41

71111.04 Corrective Action Condition Reports 201705354, 201706666, 201804179, 201804844

Documents

71111.04 Drawings M-01EC02 System Flow Diagram Fuel Pool Cooling and Clean-up B

System

71111.04 Drawings M-01EC01 System Flow Diagram Fuel Pool Cooling and Clean-up D

System

71111.04 Procedures OTN-EC-00001 Fuel Pool Cooling and Cleanup System 44

71111.05 Miscellaneous Fire Preplan Manual 42

71111.05 Miscellaneous KC-120 Fire Safety Analysis, Fire Area: C-9, ESF Switchgear Room 2

A

71111.05 Miscellaneous KC-121 Fire Safety Analysis, Fire Area: C-10, ESF Switchgear 2

Room B

71111.05 Miscellaneous KC-60 Detailed Fire Modeling Report, Fire Compartment: C-9, ESF 4

Switchgear Room North, Control Building, Elevation 2000

71111.05 Miscellaneous KC-61 Detailed Fire Modeling Report, Fire Compartment: C-10, 4

ESF Switchgear Room South, Control Building, Elevation

2000

71111.05 Work Orders 22000449

71111.11Q Corrective Action Condition Reports 202207189

Documents

71111.11Q Procedures ODP-ZZ-00001 Operations Department - Code of Conduct 108

71111.11Q Procedures OSP-AL-V001C Turbine Driven Auxiliary Feedwater Valve Inservice Test 62

71111.12 Corrective Action Condition Reports 202206571

Documents

71111.13 Corrective Action Condition Reports 202207040, 202207050, 202207058, 202207064,

Documents 202207208

71111.13 Procedures APA-ZZ-00322, Online Work Integrated Risk Management 24

Appendix F

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.13 Procedures ODP-ZZ-00002, Protected Equipment Program 32

Appendix 1

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

Appendix 2 Activities

71111.13 Work Orders 16505944, 21505608, 21504604, 21511873

71111.15 Corrective Action Condition Reports 202206972, 202207007, 202207020, 202207052,

Documents 202207056, 202207107, 202207111, 202207295,

2207671, 202207687, 202207728

71111.15 Miscellaneous EF-123 UHS Thermal Performance Analysis using GOTHIC 2

71111.18 Corrective Action Condition Reports 202202324, 202203328, 202203378, 202203394,

Documents 202203419

71111.18 Drawings M-1145-00005 Flanged Style Butterfly Valve Disc and Shaft Assembly 0

71111.18 Drawings M-1145-00007, Flanged Style Butterfly Valve with Limitorque Actuator 0

S001

71111.18 Miscellaneous CA0139 Senior Leadership Challenge Meeting Comments 0

71111.18 Miscellaneous CA4600B Design Equivalent Change Package 1

71111.18 Miscellaneous CA4620 Design Task Job Brief 1

71111.18 Miscellaneous CA4640 Design Risk Assessment 0

71111.18 Miscellaneous CA4642 Failure Modes and Effects Analysis 0

71111.18 Miscellaneous CA4643 Equipment Spare Part Rating Matrix 0

71111.18 Miscellaneous FCN01 Field Change Request 0

71111.18 Miscellaneous MP 20-0068 ESW Bypass Valve (EFHV0065/66) Shaft Replacement 1

71111.18 Work Orders 200044408, 19513019

71111.19 Corrective Action Condition Reports 202207058, 202207076, 202207189

Documents

71111.19 Procedures APA-ZZ-00322, Post-Maintenance Test Program 18

Appendix E

71111.19 Procedures ODP-ZZ-00002 Equipment Status Control 96

71111.19 Procedures OSP-EF-P001A ESW Train A Inservice Test 89

71111.19 Procedures OSP-KA-V0003 Nitrogen Accumulator Inservice Leak Rate Test 31

71111.19 Procedures OSP-NE-0001A Standby Diesel Generator A Periodic Tests 69

71111.19 Work Orders 21504040, 21503991, 18503096, 21504043, 21004019,

21504051, 20001021, 21504003, 19512893, 19513019,

Inspection Type Designation Description or Title Revision or

Procedure Date

21504066, 22511269, 20513223, 19513531, 19513532,

21507343

71111.22 Corrective Action Condition Reports 202206770

Documents

71111.22 Procedures OSP-NE-0001B Standby Diesel Generator B Periodic Tests 69

71111.22 Work Orders 22510732, 21501525

71114.02 Miscellaneous Alert and Notification System Evaluation Report, Callaway 3/1/2021

Energy Center

71114.02 Miscellaneous Report of Work Performed on the Outdoor Warning Siren 6/18/2020

System

71114.02 Miscellaneous Report of Work Performed on the Outdoor Warning Siren 10/25/2021

System

71114.02 Miscellaneous Report of Work Performed on the Outdoor Warning Siren 11/13/2020

System

71114.02 Miscellaneous Report of Work Performed on the Outdoor Warning Siren 10/21/2022

System

71114.02 Miscellaneous Report of Work Performed on the Outdoor Warning Siren 5/27/2021

System

71114.02 Miscellaneous Job 2020 Audit of Callaway Electric Coop Utility Report for Tone 0

19502946/500 Alert Radios

71114.02 Miscellaneous Job 20503116- 2021 Audit of Three Rivers Utility Report for Tone Alert 0

500 Radios

71114.02 Miscellaneous Job 21503381- 2022 Audit of Ameren Utility Report for Tone Alert Radios 0

500

71114.02 Procedures KSP-ZZ-00008 Tone Alert Radios 11

71114.02 Procedures KSP-ZZ-00110 Siren Alerting System Testing 18

71114.03 Corrective Action Condition Reports 202206013

Documents

71114.03 Miscellaneous Job/Task ERO Augmentation Drill/Test, Date: 9/6/2021 9/15/2021

Number:

21504806

71114.03 Miscellaneous Job/Task ERO Augmentation Drill/Test, Date: 10/21/2021 10/27/2021

Number:

21509156

Inspection Type Designation Description or Title Revision or

Procedure Date

71114.03 Miscellaneous Job/Task ERO Augmentation Drill/Test, Date: 3/1/2022 3/9/2022

Number:

21511692

71114.03 Miscellaneous Job/Task ERO Augmentation Drill/Test, Date: 6/8/2022 6/20/2022

Number:

2502275

71114.03 Miscellaneous Job/Task ERO Augmentation Drill/Test, Date: 9/10/2022 9/14/2022

Number:

2507242

71114.03 Miscellaneous Surveillance ERO Augmentation Drill/Test, Date: 9/13/2020 9/15/2020

Number:

20503127

71114.03 Miscellaneous Surveillance ERO Augmentation Drill/Test, Date: 12/14/2020 12/17/2020

Number:

20508820

71114.03 Miscellaneous Surveillance ERO Augmentation Drill/Test, Date: 2/2/2021 2/5/2021

Number:

20513218

71114.03 Miscellaneous Surveillance ERO Augmentation Drill/Test, Date: 5/10/2021 5/13/2021

Number:

21501631

71114.03 Procedures EIP-ZZ-00200 Augmentation of the Emergency Response Organization 22

71114.03 Procedures KOA-ZZ-00200 Activation of the Callaway Plant Emergency Callout System 17

71114.04 Corrective Action Condition Reports 202105820, 202106364

Documents

71114.04 Corrective Action Condition Reports 202207884, 202207906, 202207933, 202208187

Documents

Resulting from

Inspection

71114.04 Miscellaneous EIP-ZZ-00101, Emergency Action Level Technical Bases Document 19

Addendum 2

71114.04 Miscellaneous EP Tracking 50.54(q) Screening Form, Document: EIP-ZZ-00101, 12/13/2021

Number 2021037 Addendum 2, Revision 19, Emergency Action Level

Technical Bases Document

Inspection Type Designation Description or Title Revision or

Procedure Date

71114.04 Miscellaneous EP Tracking 50.54(q) Screening Form, Document: RERP Revision 53, 9/30/2021

Number: 2021019 Radiological Emergency Response Plan (Change 5)

71114.04 Miscellaneous EP Tracking 50.54(q) Effectiveness Evaluation Form, Document: RERP 10/28/2021

Number: 2021026 Revision 54, Radiological Emergency Response Plan

71114.04 Miscellaneous EP Tracking 50.54(q) Screening Form, Document: EIP-ZZ-00101, 12/16/2021

Number: 2021038 Addendum 2, Revision 19, Emergency Action Level

Technical Bases Document

71114.04 Miscellaneous EP Tracking 50.54(q) Effectiveness Evaluation Form, Document: 12/16/2021

Number: 2021038 EIP-ZZ-00101, Addendum 2, Revision 19, Emergency

Action Level Technical Bases Document

71114.04 Miscellaneous EP Tracking 50.54(q) Screening Form, Document: EIP-ZZ-00101, 12/16/2021

Number: 2021039 Addendum 2, Revision 19, Emergency Action Level

Technical Bases Document

71114.04 Miscellaneous EP Tracking 50.54(q) Screening Form, Document: EIP-ZZ-01211, 2/24/2022

Number: 2022017 Revision 43, Accident Dose Assessment (Changes 1-3, 6,

8-10, 14-16, 18, and 20)

71114.04 Miscellaneous EP Tracking 50.54(q) Screening Form, Document: EIP-ZZ-01211, 2/24/2022

Number: 2022017 Revision 43, Accident Dose Assessment (Changes 4 and

19)

71114.04 Miscellaneous EP Tracking 50.54(q) Screening Form, Document: EIP-ZZ-01211, 2/24/2022

Number: 2022017 Revision 43, Accident Dose Assessment (Changes 5, 7,

11-13, 17)

71114.04 Miscellaneous EP Tracking 50.54(q) Effectiveness Evaluation Form, Document: 2/24/2022

Number: 2022017 EIP-ZZ-01211, Revision 43, Accident Dose Assessment

(Changes 4 and 19)

71114.04 Miscellaneous EP Tracking 50.54(q) Screening Form, Document: EIP-ZZ-00212, 2/24/2022

Number: 2022018 Revision 32, Protective Action Recommendations

(Changes 1-15)

71114.04 Miscellaneous EP Tracking 50.54(q) Screening Form, Document: EIP-ZZ-00212, 2/24/2022

Number: 2022018 Revision 32, Protective Action Recommendations (Change

16)

71114.04 Miscellaneous EP Tracking 50.54(q) Effectiveness Evaluation Form, Document: 2/24/2022

Number: 2022018 EIP-ZZ-00212, Revision 32, Protective Action

Recommendations (Change 16)

Inspection Type Designation Description or Title Revision or

Procedure Date

71114.04 Miscellaneous EP Tracking 50.54(q) Screening Form, Document: EIP-ZZ-00212, 2/24/2022

Number: 2022018 Revision 32, Protective Action Recommendations

(Changes 17-18)

71114.04 Miscellaneous EP Tracking 50.54(q) Effectiveness Evaluation Form, Document: 2/24/2022

Number: 2022018 EIP-ZZ-00212, Revision 32, Protective Action

Recommendations (Changes 17-18)

71114.04 Miscellaneous EP Tracking 50.54(q) Effectiveness Evaluation Form, Document 10/25/2022

Number: 2022050 Number/Title: RERP, Appendix G, Revision 1, Evacuation

Time Estimates (ETE) for the Callaway Nuclear Plant

Emergency Planning Zone

71114.04 Procedures EIP-ZZ-00102 Emergency Implementing Actions 68

71114.04 Procedures EIP-ZZ-00212 Protective Action Recommendations 32, 33

71114.04 Procedures EIP-ZZ-01211 Accident Dose Assessment 43

71114.05 Corrective Action Condition Reports 202007070, 202100920, 202101027, 202103513,

Documents 202104753, 202104755, 202104759, 202105380,

2106651, 202200845, 202201214, 202207108,

2207171, 202207304

71114.05 Corrective Action Condition Reports 202207914, 202207932

Documents

Resulting from

Inspection

71114.05 Miscellaneous Health Physics Drill 6/23/2020

71114.05 Miscellaneous Callaway Energy Center Ingestion Pathway Exercise Drill 6/30/2017

Report, April 25, 2017

71114.05 Miscellaneous Callaway Energy Center, JIC SEMA Drill Report, June 28, 8/3/2022

22

71114.05 Miscellaneous Drill (2021), Contaminated Victim Drill 10/28/2021

71114.05 Miscellaneous Callaway Energy Center, ERO Training Drill Report, 4/15/2021

January 28, 2021, through March 4, 2021;

71114.05 Miscellaneous Health Physics Drill 5/26/2021

71114.05 Miscellaneous Callaway Energy Center, Annual ERO Drill (AED) Report, 1/26/2021

August 20, 2020, through September 24, 2020

71114.05 Miscellaneous Callaway Energy Center, Dress Rehearsal Drill Report, 10/12/2021

August 19, 2021 - Team 5 Participants

Inspection Type Designation Description or Title Revision or

Procedure Date

71114.05 Miscellaneous Callaway Energy Center, NRC Graded Exercise Report, 10/12/2021

September 21, 2021 - Team 5 - Participants

71114.05 Miscellaneous Health Physics (Chem) Drill 10/28/2021

71114.05 Miscellaneous Health Physics Drill 9/15/2020

71114.05 Miscellaneous Mini Scenario #7, Field Monitoring Team 8/19/2021

71114.05 Miscellaneous Contaminated Victim Drill 12/3/2020

71114.05 Miscellaneous Health Physics Drill 9/15/2022

71114.05 Miscellaneous Field Monitoring Team Drill 2020 7/8/2020

71114.05 Miscellaneous Health Physics Drill 6/14/2022

71114.05 Miscellaneous AP20007 Nuclear Oversight Audit of Emergency Preparedness 9/3/2020

71114.05 Miscellaneous AP22005 Nuclear Oversight Audit of Emergency Preparedness 9/28/2022

71114.05 Miscellaneous Job 19507106 2020 Population Update Analysis 5/26/2020

71114.05 Miscellaneous Job 20504723 2021 Population Update Analysis 5/24/2021

71114.05 Miscellaneous Surveillance Annual Review of the Emergency Preparedness Program 6/15/2021

Report SP21003

71114.05 Procedures APA-ZZ-00500 Corrective Action Program 75

71114.05 Procedures CDP-ZZ-08100 Post Accident Sampling Guidelines 6

71114.05 Procedures DTI-020 Regulatory Required Internal Assessments 31, 32

71114.05 Procedures DTI-033 Performance of Regulatory Required Reviews 4

71114.05 Procedures EIP-ZZ-A0020 Maintaining Emergency Preparedness 34, 35

71114.05 Procedures GDP-ZZ-00001 Nuclear Oversight Conduct of Operations 15

71114.05 Procedures GDP-ZZ-00002 NOS Regulatory Required Internal Assessments 14

71114.05 Procedures KDP-ZZ-00013 Emergency Response Facility and Equipment Evaluation 19

71114.05 Procedures KDP-ZZ-00013, Equipment Important to Emergency Response Matrix 13

Appendix 1

71114.05 Procedures KDP-ZZ-02001 Drill and Exercise Program 28

71114.05 Procedures KSP-ZZ-00007 Off-Site Effectiveness of the Emergency Preparedness 18

Program

71114.05 Work Orders Work Orders 20002242, 20003084, 21003371, 22003488, 22004037

71151 Corrective Action Condition Reports 202201984

Documents

71151 Corrective Action Condition Reports 202105449

Documents

Inspection Type Designation Description or Title Revision or

Procedure Date

71151 Miscellaneous PI Basis Reports Various

71151 Miscellaneous Control Room Logs Various

71151 Procedures KDP-ZZ-02000 NRC Performance Indicator (PI) Data Collection 23

71151 Procedures KSP-ZZ-00110 Siren Alert System Testing 18

71152A Corrective Action Condition Reports 202204157, 202205390, 202207044, 202207052,

Documents 202207107, 202207204, 202207208, 202206427

71152A Miscellaneous MRC Requested Reinstallation timeline of insulation 08/18/2022

Action

2205390-003

71152A Miscellaneous Request for CR Insulation removal room temperature monitoring not 08/29/2022

Change or performed per RFR 018668C

Rescreen

71152A Miscellaneous Request for Temporary Insulation Removal During Modes 1-4 08/28/1998

Resolution 18668

71152A Work Orders Job 19003544 Investigate and repair leakage on EBG01 lower RCS side

flange

19