ML19199A181

Notification of NRC Design Base Assurance Inspection (Programs) (05000483/2019011) and Initial Request for Information

ML19199A181
Person / Time
Site:	Callaway
Issue date:	07/18/2019
From:	Gerond George Region 4 Engineering Branch 1
To:	Diya F Ameren Missouri
George G
References
IR 2019011
Download: ML19199A181 (6)

See also: IR 05000483/2019011

Text

July 18, 2019

Mr. Fadi Diya, Senior Vice President

and Chief Nuclear Officer

Ameren Missouri

Callaway Plant

8315 County Road 459

Steedman, MO 65077

SUBJECT: CALLAWAY PLANT, UNIT 1 - NOTIFICATION OF NRC DESIGN BASES

ASSURANCE INSPECTION (PROGRAMS) (05000483/2019011) AND INITIAL

REQUEST FOR INFORMATION

Dear Mr. Diya:

On October 8, 2019, the NRC will begin an inspection at the Callaway Plant, Unit 1. A three-

person team will perform this inspection using NRC Inspection Procedure 71111.21N, Design

Bases Inspection (Programs); Attachment 1, Environmental Qualification under 10 CFR 50.49

Programs, Processes, and Procedures.

This inspection will evaluate the implementation of the environmental qualification of electrical

equipment program, as required by the Callaway Plant Operating License. Additionally, the

team will perform an inspection of the equipment qualification documentation files to verify that

electrical equipment important to safety meets the requirements of 10 CFR 50.49. The team will

select components that will be subjected to harsh environments and required to mitigate the

consequences of a design basis accident.

The inspection will include an information gathering site visit by the team leader and 2 weeks of

onsite inspection by the team. The inspection will consist of three NRC inspectors. The current

inspection schedule is as follows:

Onsite Information Gathering Visit: October 8, 2019

Preparation Week: October 14-18, 2019

Onsite Weeks: October 21-25, 2019; and November 4-8, 2019

The purpose of the information gathering visit is to meet with members of your staff to become

familiar with the Callaway Plant environmental qualification program. The lead inspector will

request a meeting with your personnel to discuss the site environmental qualification program

and procedures. Additionally, the lead inspector will request a discussion with your staff to

become familiar with the equipment qualification regulations and standards to which the site is

committed. Additional information and documentation needed to support the inspection will be

identified during the inspection, including interviews with engineering managers and engineers.

Our experience with these inspections has shown that they are resource intensive, both for the

NRC inspectors and the licensee staff. In order to minimize the inspection impact on the site

and to ensure a productive inspection, we have enclosed a request for information needed for

the inspection. This information should be made available to the lead inspector during the

F. Diya 2

October 8, 2019 visit. Since the inspection will be concentrated on the environmental

qualification of the equipment, the Equipment Qualification Master List (EQML) should be

available to review during the information gathering visit to assist in our selection of

components.

Additional requests by inspectors will be made during the onsite week for specific documents

needed to complete the review of that component/selection. It is important that all of these

documents are up-to-date and complete in order to minimize the number of additional

documents requested during the preparation and/or the onsite portions of the inspection. To

facilitate the inspection, we request that a contact individual be assigned to each inspector to

ensure information requests, questions, and concerns are addressed in a timely manner.

The lead inspector for this inspection is Gerond A. George. If there are any questions about

the inspection or the requested materials, please contact the lead inspector by telephone at

817-200-1562 or by e-mail at Gerond.George@nrc.gov.

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget, control

number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to

respond to, a request for information or an information collection requirement unless the

requesting document displays a currently valid Office of Management and Budget control

number.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be

made available electronically for public inspection in the NRC Public Document Room or from

the Publicly Available Records (PARS) component of NRCs document system (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the

Public Electronic Reading Room).

Sincerely,

/RA/

Gerond A. George, Chief (Acting)

Engineering Branch 1

Division of Reactor Safety

Docket No. 50-483

License No. NPF-30

Enclosure: Design Bases Inspection (Programs)

Environmental Qualification Request for Information

cc: Electronic Distribution for the Callaway Plant, Unit 1

Initial Request for Information

Design Bases Inspection (Programs), Environmental Qualification

Callaway Plant, Unit 1

Inspection Report: 05000483/2019011

Information Gathering Date: October 8, 2019

Inspection Dates: October 21-25, 2019

November 4-8, 2019

Inspection Procedure: IP 71111, Attachment 21N, Design Bases Inspection

(Programs)

Lead Inspector: Gerond A. George, Senior Reactor Inspector

I. Information Requested for Information Gathering Visit (October 8, 2019)

The following information should be provided to the lead inspector in hard copy or

electronic format (electronic database preferred), to the attention of Gerond A.

George by October 8, 2019, to facilitate the reduction in the items to be selected for a

final list of components. The inspection team will finalize the selected list during the prep

week using the documents requested in this enclosure. The specific items selected from

the lists shall be available and ready for review on the day indicated in this request.

• Please provide requested documentation electronically in pdf files, Excel, or other

searchable formats, if possible. The information should contain descriptive names and

be indexed and hyperlinked to facilitate ease of use. Information in "lists" should contain

enough information to be easily understood by someone who has knowledge of

pressurized water reactor technology. If requested documents are large and only hard

copy formats are available, please inform the inspectors, and provide subject

documentation during the first day of the onsite inspection.

1. List of components that are in Equipment Qualification Master List. If the plant is

approved to categorize structures, systems, and component in accordance with

10 CFR 50.69, please provide the Risk-Informed Safety Category of the component.

2. Listing of the Equipment Qualification Master List components sorted by Birnbaum

risk importance and risk achievement worth.

3. List of all post-accident monitoring instrumentation components and locations.

4. Documents which show the environmental service conditions expected for areas in

which the equipment qualification components are located.

5. Callaway Plant, word-searchable Updated Final Safety Analysis Report (UFSAR),

License Conditions, and Technical Specifications. Specifically identify which UFSAR

sections address environmental (including seismic) qualification, seismic.

Enclosure

6. NRC Safety Evaluation Reports associated with Callaway Plant environmental

qualification program.

7. Identify the various environmental qualification standards (including year, edition, or

revision) that Callaway Plant is committed.

8. Identify whether Callaway Plant has entered its period of extended operation (i.e.,

operation past the original 40-year license period).

9. Site (and corporate if applicable) procedures associated with the 10 CFR 50.49

environmental qualification program for electrical components. Additionally, please

provide similar procedures used to verify mechanical components meet their

10 CFR 50, Appendix A, Criterion 4, Environmental and Dynamic Effects Design

Bases. Include procedures for procurement of qualified equipment, maintenance of

qualified equipment, and modification to qualified equipment (including equivalency

or commercial grade dedication programs).

10. Site high energy line break analyses, including associated plant area drawings.

11. Procedures for material storage and shelf life controls.

12. List of commercial grade dedication evaluations performed, for which the dedicated

parts have been issued for installation on equipment qualification applications in the

plant, for the previous 5 years. Include description of the component the part was

issued to repair, work order, and date issued or installed.

13. List of condition reports related to the equipment qualification program or

environmental qualification of components (both electrical and mechanical) for the

previous 5 years.

14. Lists of modifications, repairs, or replacement of Equipment Qualification Master List

components completed for the previous 5 years.

15. List of modifications, repairs, or replacements of containment penetrations for the

previous 5 years.

16. List of components removed from the environmental qualification program since

beginning of operation.

17. Any self-assessments and quality assurance assessments of the environmental

qualification program performed in the previous 5 years.

18. List of systems, system numbers/designators and corresponding names.

II. Discussions Requested (October 8, 2019)

1. Interview with representative to discuss site environmental qualification service

condition analyses for plant areas, including plant drawings and assumptions. This

includes analysis for areas that are subject to high energy line breaks (HELB).

2

2. Interview with representative to discuss how environmental qualification mandated

maintenance elements are integrated into plant programs and procedures.

3. Interview with representative to discuss maintaining qualification for plant/equipment

that has entered its period of extended operation, if applicable.

III. Information Requested for Inspection Preparation (October 14, 2019)

1. Equipment qualification documentation files, including test reports, for the electrical

components selected by the lead inspector listed on the Equipment Qualification

Master List.

2. References associated with the electrical components equipment qualification

document files.

3. Vendor manuals and technical sheets associated with the selected electrical

components.

4. Tours of the rooms in which the selected electrical components are installed.

5. Tour of stored selected electrical components in the warehouse.

Inspectors Contact Information:

Gerond A. George Chad Stott Dustin Reinert, Ph.D.

Senior Reactor Inspector Reactor Inspector Reactor Inspector

817-200-1562 817-200-1526 817-200-1534

Gerond.George@nrc.gov Chad.Stott@nrc.gov Dustin.Reinert@nrc.gov

Mailing Address:

U.S. NRC, Region IV

Attn: Gerond A. George

1600 East Lamar Blvd.

Arlington, TX 76011-4511

3

ML19199A181

SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword: NRC-002

By: GAG Yes No Publicly Available Sensitive

OFFICE C:EB1

NAME GGeorge

SIGNATURE /RA/

DATE 07/18/2019