ML23019A080

Notification of Comprehensive Engineering Team Inspection (05000483/2023011) and Request for Information

ML23019A080
Person / Time
Site:	Callaway
Issue date:	01/19/2023
From:	Vincent Gaddy NRC/RGN-IV/DORS/EB1
To:	Diya F Ameren Missouri
Braisted J
References
IR 2023011
Download: ML23019A080 (9)

See also: IR 05000483/2023011

Text

January 19, 2023

Mr. Fadi Diya

Senior Vice President

and Chief Nuclear Officer

Ameren Missouri

8315 County Road 459

Steedman, MO 65077

SUBJECT: CALLAWAY PLANT - NOTIFICATION OF COMPREHENSIVE ENGINEERING

TEAM INSPECTION (05000483/2023011) AND REQUEST FOR INFORMATION

Dear Mr. Diya:

The purpose of this letter is to notify you that U.S. Nuclear Regulatory Commission (NRC) staff

will conduct the comprehensive engineering team inspection at the Callaway Plant beginning on

May 8, 2023. The inspection team will be composed of seven personnel from the NRC Region

IV office. The inspection will be conducted in accordance with NRC inspection procedure (IP)

71111.21M, Comprehensive Engineering Team Inspection, dated October 7, 2022.

The objectives of the inspection are to verify: that risk-significant structures, systems, and

components (SSCs) classified as regulatory treatment of non-safety systems (RTNSS) that are

of high or intermediate importance have been maintained and will operate within their design

and licensing bases requirements; that modifications to risk-significant SSCs did not introduce

conditions that adversely impact the ability of SSCs to perform their design and licensing bases

functions; that the design basis, licensing basis, and performance capability of SSCs have not

been adversely impacted by changes introduced through degraded conditions and other

activities; and that requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.59

have been appropriately implemented.

The inspection will include an onsite information gathering visit by the team lead and two weeks

of onsite inspection by the team. The schedule for the inspection is as follows:

Onsite Information Gathering Visit: March 20 - 24, 2023

Offsite Preparation Week: May 1 - 5, 2023

Onsite Inspection Weeks: May 8 - 12, 2023, and May 22 - 26, 2023

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

Callaway Plants SSCs, programs, processes, and procedures and to ensure the resources

needed to support the team, as necessary, to conduct an effective and efficient inspection. This

visit may include a tour of installed plant SSCs associated with potential inspection samples.

During the visit, the team lead will also review the information provided in the initial information

request to select a list of potential inspection samples. The team lead may also identify other

information needed to support the inspection during this visit.

F.Diya 2

To minimize the impact on your staff and to ensure an effective and efficient inspection, we

have enclosed two separate requests for information needed prior to the onsite information

gathering visit and offsite inspection preparation week. The first request (Enclosure 1) is

generally for information that will be used to choose the inspection samples or information that

will be applicable to all inspection samples throughout the inspection. This information should be

made available to the team lead prior to the information gathering visit. The second request

(Enclosure 2) is for information that is specific to an individual sample and should be made

available prior to the offsite preparation week.

Additional information requests, interviews with your staff, and/or tours of facilities or installed

plant components will be made by the team throughout the inspection to complete their review

of the selected inspection samples. It is important that all documentation provided to the team is

complete and up to date to minimize the number of additional documents requested during the

preparation and/or the onsite portions of the inspection. Additionally, to facilitate an efficient

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.

We understand that Thomas Forland from your Regulatory Affairs organization is our contact for

this inspection. If there are any questions about the inspection or the information requested,

please contact the team lead, Jonathan Braisted, by telephone at 817-200-1469 or by e-mail at

Jonathan.Braisted@nrc.gov. Enclosure 3 contains additional contact information for the

inspection team.

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, under 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 rules and practices, a copy of this letter and its

enclosures will be available electronically for public inspection in the NRC public document

room or from the publicly available records (PARS) component of NRCs document system

(ADAMS). ADAMS is accessible from the NRC Web site.

Sincerely,

Signed by Gaddy, Vincent

on 01/19/23

Vincent G. Gaddy, Chief

Engineering Branch 1

Division of Operating Reactor Safety

F. Diya 3

Docket No. 05000483

License No. NPF-30

Enclosures:

1. Documents Requested Prior to

Information Gathering Visit

2. Documents Requested Prior to

Inspection Preparation Week

3. Inspection Team Contact Information

cc w/ encl: Distribution via LISTSERV

ML23019A080

Non-Sensitive Publicly Available

SUNSI Review

Sensitive Non-Publicly Available

OFFICE BC:DORS/EB1 SRI:DORS/EB1

NAME VGaddy JBraisted

SIGNATURE /RA/ /RA/

DATE 01/19/23 01/19/23

Enclosure 1

Documents Requested Prior to Information Gathering Visit

The documents and information requested below should generally be made available to the

inspection team for the team's use both on-site and off-site during the information gathering

visit. Electronic format is the preferred media. If electronic media is made available via an

internet based remote document management system, then the remote document access must

allow inspectors to download, save, and print the documents in the NRC's regional office.

Electronic media on compact disc or paper records (hard copy) are acceptable. At the end of

the inspection, the documents in the team's possession will not be retained.

This document request is based on typical documents that a generic plant might have. As such,

this document request is not meant to imply that any specific plant is required to have all of the

listed documents. In addition, your plant specific document titles may vary from the document

titles listed below. We also request that the information provided be sorted by the list below.

Documents requested by March 13, 2023:

1. Copy of Callaway Plants probabilistic risk assessment (PRA) summary document for

the current internal events, external events (e.g., fire, flooding, seismic), and

shutdown PRA models of record.

2. From the internal events PRA, a sortable list of structures, systems, and components

(SSCs) sorted by risk achievement worth (RAW) and Birnbaum value for both core

damage frequency (CDF) and large early release frequency (LERF). Include all basic

events with RAW values of 1.3 or greater and Birnbaum values of 1E-6 or greater.

3. From the external events PRA, a sortable list of SSCs sorted by RAW and Birnbaum

value for both CDF and LERF. Include all basic events with RAW values of 1.3 or

greater and Birnbaum values of 1E-6 or greater.

4. From the internal events PRA, a sortable list of human failure events (HFEs) sorted

by RAW and Birnbaum value for both CDF and LERF.

5. From the external events PRA, a sortable list of HFEs sorted by RAW for both CDF

and LERF.

6. Sortable list of SSCs and HFEs sorted by engineering or expert panel judgement

such as those performed to identify risk significant SSCs for Legal Plant Names

Maintenance Rule program.

7. Sortable list of SSCs with known low analytical, operating, maintenance, or

complexity margin, if available.

8. Sortable list of temporary or permanent modifications that were implemented within

the past four years. Implemented means accepted or placed into service and

declared functional/operable, as applicable. Modifications may include, but are not

limited to, equivalency evaluations, commercial grade dedications, and changes to

SSCs, procedures, set points, calculations, designs, and/or the licensing bases.

Enclosure 1

9. Sortable list of 10 CFR 50.59 applicability determinations of implemented changes,

tests, and experiments that did not result in a screening within the past four years.

10. Sortable list of 10 CFR 50.59 screenings of implemented changes, tests, and

experiments that did not result in an evaluation within the past four years.

11. Sortable list of 10 CFR 50.59 evaluations of implemented changes, tests, and

experiments that did not result in an application for a license amendment within the

past four years.

12. Sortable list of implemented changes, tests, and experiments where an alternate

process or screening criteria was applied within the past four years.

13. Copy of the last two submittals of the report containing a brief description of any

changes, tests, and experiments, including a summary of the evaluation of each,

required by 10 CFR 50.59(d)(2).

14. Copy of training and qualification records of personnel who performed 10 CFR 50.59

activities within the past four years.

15. Sortable list of operating experience evaluations performed within the past four

years. Operating experience sources may include, but are not limited to, NRC

generic communications, licensee event reports, plant operating experience, 10 CFR

Part 21 reports, previous NRC inspection findings, and vendor communications.

16. Sortable list of corrective action program documents associated with issues identified

during the last NRC design bases inspection.

17. Copy of implementing/program procedures, as applicable, for performing

modifications, time critical/sensitive operator actions, 10 CFR 50.59 activities,

operating experience evaluations, and the corrective action program.

18. Copy of any self-assessments or audits in preparation for this inspection or related to

activities associated with this inspection (i.e., design, modifications, 10 CFR 50.59,

operating experience) performed within the past four years.

19. Copy of the updated final safety analysis report, technical specifications, and

technical requirements manual, including applicable bases documents.

20. Sortable list of SSCs, including identifying designators and corresponding names.

21. List of site contacts that will be associated with the inspection.

2

Enclosure 2

Documents Requested Prior to Inspection Preparation Week

For the samples identified by the team lead, the documents and information requested below

should generally be made available to the inspection team for the team's use both on-site and

off-site during the inspection. Electronic format is the preferred media. If electronic media is

made available via an internet based remote document management system, then the remote

document access must allow inspectors to download, save, and print the documents in the

NRC's regional office. Electronic media on compact disc or paper records (hard copy) are

acceptable. At the end of the inspection, the documents in the team's possession will not be

retained.

This document request is based on typical documents that a generic plant might have. As such,

this document request is not meant to imply that any specific plant is required to have all the

listed documents. In addition, your plant specific document titles may vary from the document

titles listed below. We also request that the information provided be sorted by the list below for

each sample.

Documents requested for each sample type by April 24, 2023:

1. Structure, System, and Component (SSC) Samples

a. Copy of relevant design bases document, system description, etc.

b. Copy of relevant vendor manuals (i.e., installation, operation, maintenance).

c. Copy of relevant calculations and drawings.

d. List of preventive maintenance activities and frequency.

e. List of inspections/tests and frequency.

f. Copy of the system health notebook.

g. List of relevant corrective action program documents within the past four

years.

h. Copy of relevant normal, abnormal, or emergency procedures.

2. Modification Samples

a. Copy of the complete change package.

b. Copy of the complete implementing work order.

c. Copy of any post-modification tests, etc.

d. Copy of any relevant corrective action program documents.

e. Copy of relevant vendor manuals (i.e., installation, operation, maintenance).

Enclosure 2

f. Copy of affected procedures, training materials, preventive maintenance or

inspection/testing activities, calculations, design specifications, drawings,

updated final safety analysis report, technical specifications, etc.

3. 10 CFR 50.59 Samples

a. Copy of the relevant 10 CFR 50.59 applicability determination, screening, or

evaluation.

b. Copy of any relevant corrective action program documents.

c. Copy of any affected procedures, training materials, preventive maintenance

or inspection/testing activities, calculations, design specifications, drawings,

updated final safety analysis report, technical specifications, etc.

4. Operating Experience Samples

a. Copy of the complete operating experience evaluation.

b. Copy of any relevant corrective action program documents.

c. Copy of any affected procedures, training materials, preventive maintenance

or inspection/testing activities, calculations, design specifications, drawings,

updated final safety analysis report, technical specifications, etc.

2

Enclosure 3

Inspection Team Contact Information

Jonathan Braisted (Lead) Dustin Bryen Wes Cullum

Senior Reactor Inspector Reactor Inspector Senior Reactor Inspector

817-200-1469 817-200-1078 817-200-1563

Jonathan.Braisted@nrc.gov Dustin.Bryen@nrc.gov Wes.Cullum@nrc.gov

Dustin Reinert Fabian Thomas Nnaerika Okonkwo

Senior Reactor Inspector Reactor Inspector Reactor Inspector

817-200-1534 817-200-1126 817-200-1114

Dustin.Reinert@nrc.gov Fabian.Thomas@nrc.gov Nnaerika.Okonkwo@nrc.gov

TBD

Reactor Inspector

817-200-XXXX

First.Last@nrc.gov

Mailing Address:

U.S. NRC, Region IV

Attn: Jonathan Braisted

1600 East Lamar Blvd.

Arlington, TX 76011-4511

Enclosure 3