IR 05000483/2017008

Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/ Staffing/Multi-Unit Dose Assessment Plans - Inspection Report 05000483/2017008

ML17277A053
Person / Time
Site:	Callaway
Issue date:	10/03/2017
From:	Taylor N H NRC/RGN-IV/DRP/RPB-A
To:	Diya F Ameren Missouri
Taylor N H
References
EA-12-049, EA-12-051 IR 2017008
Download: ML17277A053 (15)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 1600 E. LAMAR BLVD.

ARLINGTON, TX 76011-4511 October 3, 2017 Mr. Fadi Diya, Senior Vice President and Chief Nuclear Officer Ameren Missouri Callaway Plant P.O. Box 620 Fulton, MO 65251 SUBJECT: CALLAWAY PLANT

- INSPECTION OF THE IMPLEMENTATION OF MITIGATION STRATEGIES AND SPENT FUEL POOL INSTRUMENTATION ORDERS AND EMERGENCY PREPAREDNESS COMMUNICATION/ STAFFING/MULTI-UNIT DOSE ASSESSMENT PLANS

- INSPECTION REPORT 05000483/2017008

Dear Mr. Diya:

On September 1 , 201 7, the U.S. Nuclear Regulatory Commission (NRC) completed the onsite portion of an inspection at the Callaway Plant. On September 26, 2017 , the NRC inspectors discussed the results of this inspection with Ms. S. Banker, Senior Director, Engineering, and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.

The inspection examined activities conducted under your license as they relate to the implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049 and EA-12-051) and emergency preparedness communication s , staffing, and multi-unit/source dose assessment plans; your compliance with the Commission's rules and regulations; and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with station personnel.

The NRC inspectors did not identify any findings or violations of more than minor significance associated with this inspection.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management 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 David Proulx Acting for/

Nicholas H. Taylor

, Chief Project Branch B Division of Reactor Projects Docket No. 50

-483 License No. NPF

-30 Enclosure:

Inspection Report 05000 483/20170 08 w/ Attachment: Supplemental Information cc w/ encl: Electronic Distribution

1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket: 050004 83 License: NPF-30 Report: 05000483/2017008 Licensee: Union Electric Company Facility: Callaway Plant Location: Junction Highway CC and Highway O Steedman, Missouri Dates: August 28

- September 26, 2017 Inspectors:

R. Alexander, Sr. Project Engineer (Team Leader)

S. Alferink, Reactor Inspector D. Bradley, Sr. Resident Inspector

- Callaway M. Stafford, Project Engineer Approved By: Nicholas H. Taylor Chief, Project Branch B Division of Reactor Projects

2

SUMMARY

IR 05000483/2017008

08/28/2017 - 09/26/2017; Callaway Plant

Temporary Instruction 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans

, issued December 23, 2015.

The inspection covered a one-week inspection by the resident inspector and three inspectors from the Region IV office. No findings were identified. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG

-1649, "Reactor Oversight Process," Revision 5.

A. NRC-Identified and Self-Revealing Findings

None

B. Licensee-Identified Violations

None 3

REPORT DETAILS

4. Other Activities

4OA5 Other Activities

(TI 2515/191)

The objective of Temporary Instruction (TI) 2515/191 "Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi

-Unit Dose Assessment Plans

," is to verify that licensees have adequately implemented the mitigation strategies as described in the licensee's Final Integrated Plan (ADAMS Accession No

. ML16189A304

) and the NRC's plant safety evaluation (ADAMS Accession No. ML17010A332) and to verify that the licensees installed reliable water level measurement instrumentation in their spent fuel pools. The purpose of this TI is also to verify the licensees have implemented Emergency Preparedness (EP) enhancements as described in their site

-specific submittals and NRC safety assessments, including multi

-unit dose assessment capability and enhancements to ensure that staffing is sufficient and communications can be maintained during such an event.

The inspection verified that plans for complying with NRC Orders EA 049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond

-Design-Basis External Events

," (ADAMS Accession No. ML12229A174) and EA 051, "Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation

," (ADAMS Accession No. ML12056A044) are in place and are being implemented by the licensee. Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012

, request for information letter and multiunit dose assessment information provided per COMSECY-13-0010, "Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned," dated March 27, 2013 (ADAMS Accession No. ML12339A262).

The team discussed the plans and strategies with plant staff, reviewed documentation, and where appropriate, performed plant walk downs to verify that the strategies could be implemented as stated in the licensee's submittals and the NRC staff

-prepared safety evaluation. For most strategies, this included verification that the strategy was feasible, procedures and/or guidance had been developed, training had been provided to plant staff, and required equipment had been identified and staged. Specific details of the team's inspection activities are described in the following sections.

1. Mitigation Strategies for Beyond

-Design-Basis External Events

a. Inspection Scope

The team examined the licensee's established guidelines and implementing procedures for the beyond

-design-basis mitigation strategies. The team assessed how the licensee coordinated and documented the interface/transitio n between existing off

-normal and emergency operating procedures with the newly developed mitigation strategies. The team selected a number of mitigation strategies and conducted plant walk downs with licensed operators and responsible plant staff to assess: the adequacy and completeness of the procedures

, familiarity of operators with the procedure objectives 4 and specific guidance, staging and compatibility of equipment

, and the practicality of the operator actions prescribed by the procedures, consistent with the postulated scenarios.

The team verified that a preventive maintenance program had been established for the FLEX portable equipment and that periodic equipment inventories were in place and being conducted. Additionally, the team examined the introductory and planned periodic/refresher training provided to the Operations and Security staffs most likely to be tasked with implementation of the FLEX mitigation strategies. The team also reviewed the introductory and planned periodic training provided to the Emergency Response Organization personnel.

b. Assessment Based on samples selected for review, the team verified that the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is generally in compliance with NRC Order EA 049. The team verified that the licensee satisfactorily:

Developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX strategies for postulated external events

, Integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs are clear when using existing plant procedures

, Protected FLEX equipment from site

-specific hazards

, Developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability

, Trained their staff to assure personnel proficiency in the mitigation of beyond-design-basis events

, and Developed means to ensure that the necessary off

-site FLEX equipment will be available from off

-site locations

. The team verified that any non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.

c. Findings

No findings identified.

5 2. Spent Fuel Pool (SFP) Instrumentation

a. Inspection Scope

The team examined the licensee's newly installed spent fuel pool instrumentation. Specifically, the team verified the sensors were installed as described in the plant specific submittals and the associated safety evaluation and that the cabling for the power supplies and the indications for each channel are physically and electrically separated. Additionally, environmental conditions and accessibility of the instruments were evaluated. Documents reviewed are listed in the attachment.

b. Assessment Based on samples selected for review, the team determined that the licensee satisfactorily installed and established control of the SFP instrumentation as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is generally in compliance with NRC Order EA 051. The team verified that the licensee satisfactorily:

Installed the SFP instrumentation sensors, cabling and power supplies to provide physical and electrical separation as described in the plant specific submittal and safety evaluation

Installed the SFP instrumentation display in the location, environmental conditions and accessibility as described in the plant specific submittals; and Trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation.

The team verified that any non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.

c. Findings

No findings identified.

3. Staffing and Communication Request for Information

a. Inspection Scope

Through discussions with plant staff, review of documentation and plant walk downs, the team verified that the licensee has implemented required changes to staffing, communications equipment

, and facilities to support an Extended Loss of All AC Power (ELAP) scenario as described in the licensee's staffing assessment and the NRC safety assessment. The team also verified that the licensee has implemented dose assessment (including releases from spent fuel pools) capability using the licensee's site-specific dose assessment software and approach as described in the licensee's dose assessment submittal. Documents reviewed are listed in the attachment.

6 b. Assessment The team reviewed information provided in the licensee's multi

-unit dose submittal and in response to the NRC's March 12, 2012, request for information letter and verified that the licensee satisfactorily implemented enhancements pertaining to Near

-Term Task Force Recommendation 9.3 response to a large scale natural emergency event that results in an extended loss of all ac power to the site and impedes access to the site.

The team verified the following:

Licensee satisfactorily implemented required staffing change(s) to support an ELAP scenario , Emergency preparedness communications equipment and facilities are sufficient for dealing with an ELAP scenario

, and Implemented dose assessment capabilities (including releases from spent fuel pools) using the licensee's site

-specific dose assessment software and approach.

The team verified that any non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.

c. Findings

No findings identified.

4OA6 Exit Exit Meeting Summary

On September 1, 2017, the team presented the on-site inspection results in a management debrief to T. Herrmann, Site Vice President

, and other members of the site staff. The inspectors confirmed that proprietary information examined during the inspection had been returned to the licensee. The team lead completed an exit meeting conducted with S. Banker, Senior Director, Engineering

, a nd other members of the site staff, via telephone on September 26, 2017 , to discuss the final results of the inspection.

ATTACHMENT: SUPPLEMENTA L INFORMATION

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

S. Abel, Director, Engineering Projects

A. Alley, Engineering Program Supervisor

S. Banker, Senior Director Engineering

F. Bianco, Director, Nuclear Operations

J. Cortez, Director, Training

M. Covey, Manager, Operations

B. Cox, Senior Director Nuclear Operations

D. Farnsworth, Director, Work Management

T. Herrmann, Site Vice President

T. Holland, Shift Manager

B. Huhmann, Regulatory Affairs Supervisor

B. Jungmann, Director, Maintenance

S. Kovaleski, Director, Engineering Design

G. Kremer, Director, Engineering Programs

M. McLachlan, Senior Director Plant Support

K. Mills, Director, Engineering Systems

T. Moser, Director, Nuclear Projects

J. Nurrenbern, FLEX Program Enginee

r

E. Olson, Director, Engineering Programs

J. Patterson, Director, Nuclear Projects

E. Ptasznik, Licensing Engineer

S. Sandbothe, Director , Plant Support

D. Stepanovic, Manager, Materials

NRC Personnel

S. Janicki, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Closed 2515/191 TI Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi

-Unit Dose Assessment Plans

, issued December 23, 2015

LIST OF DOCUMENTS REVIEWED

Section 4OA5

Other Activities Corrective Action Documents

201106180

201408448

201601716

201605315

201605701

201605787

201607008

201607646

201607894

201607938

201609168

201609286

201700008

201700079

201701274

201702320

201703278

201703911

201703920

201704462 201704470*

201704490*

201704488*

201704491*

201704499*

201704501*

201704502*

20170503* 201704509*

201704513*

201704514*

201704515*

201704539*

201704551*

201704552*

• - indicates corrective action document written by the licensee as a result of the NRC inspection

Procedures

Number Title Revision

APA-ZZ-00102 EOP/OTO Writers Manual

APA-ZZ-00391 Beyond Design Basis (BDB) Program Document

APA-ZZ-00391, Appendix 8

Callaway Plant Final Integrated Plan

APA-ZZ-00500 Corrective Action Program

APA-ZZ-00500, Appendix 17

CAP, Screening Process Guidelines

ECA-0.0 Loss of All AC Power

EDP-ZZ-04600 Engineering Change Control

EIP-ZZ-01211 Accident Dose Assessment

FSG-11 Alternate SFP Makeup and Cooling

FSG-12 Alternate Containment Cooling

FSG-13 Transition from FLEX Equipment

FSG-14 Shutdown RCS Makeup

FSG-3 Alternate Low Pressure Feedwater

FSG-4 ELAP DC Bus Load Shed/Management

FSG-40 FLEX Support Guidelines Flowchart

Procedures

Number Title Revision

FSG-41 FLEX Emergency Communications

FSG-43 Nitrogen and Instrument Air Strategy

FSG-44 FLEX Diesel Fuel Strategy

FSG-45 Temporary Ventilation, Lighting, and Power

FSG-46 Mobile Water Purification Unit

FSG-48 FLEX ESW Pump

FSG-5 Initial Assessment and FLEX Equipment Staging

FSG-50 Freeze Protection for ELAP Response

FSG-51 Temporary Sump Pump Operation

FSG-6 Alternate HCST Makeup

FSG-7 Loss of Vital Instrumentation or Control Power

FSG-9 Low Decay Heat Temperature Control

IP-ENG-001 Standard Design Process

ITL-EC-00L39

LOOP-LVL; Spent Fuel Pool Lvl

ITL-EC-00L59

LOOP-LVL; Spent Fuel Pool Primary Level

ITL-ED-00L60

LOOP-LVL; Spent Fuel Pool Backup Level

ODP-ZZ-00002 Equipment Status Control

ODP-ZZ-00025 EOP/OTO User's Guide

ODP-ZZ-00030 EOP Implementation Guide

OTO-NB-00005 Loss of All AC Power While on RHR

Parent/Model Work Orders Number Title Revision / Date

1008428

FLEXP-HALE-1 (Flex Hale Pump)

- 6 month maintenance April 25, 2017

1008430

FLEXP-HALE-1-FLEX P Hale Pump #1

- 12 month maintenance April 25, 2017

1008432

FLEXP-HALE-1-FLEX P Hale Pump #1

- 36 month maintenance plan 0

1008589

FLEXG-480-1-480 Volt FLEX Generator # 1

- 12 month June 21, 2017

1008591

FLEXG-480-1-480 Volt FLEX Generator # 1

- 9 year maintenance plan

Parent/Model Work Orders Number Title Revision / Date

1008643

FLEXP-SFP-1-fLEX P SFP Pump # 1

- 36 month maintenance plan

1008645

FLEXP-SFP-2-FLEX P SF? Pump # 2

- 6 month maintenance June 19, 2017

1008656

FLEXP-SFP-1-FLEX P SFP Pump # 1 - 12 month maintenance June 20, 2017

1008678

FLEXH-WATER-1-FLEX H Water #1

- 36 month electrical inspection plan 0

1008692

FLEXP-AFW-1-FLEX AFW Pump #1

- 6 month battery inspection June 22, 2017

1008693

FLEXP-AFW-1-FLEX AFW Pump #1

- 12 month functional test June 21, 2017

1008694

FLEXP-AFW-1-FLEX AFW Pump #1

- 36 month functional test plan 0

1008712 Inventory FLEX Emergency Food and Water Supplies

- 12 month inspection August 18, 2017

1008807

FLEXG-240-1-Kubota G1-11000 240 volt generator 1

- 6 month maintenance June 27, 2017

1008808

FLEXG-240-1-Kubota G1-11000 240 volt generator 1

- 36 month maintenance plan

1008878

FLEXT-COMMS-01-FLEX T Communications trailer # 1

- 6 month maintenance June 2, 2017

1008879

FLEXT-COMMS-01-FLEX T Communications trailer # 1

- 36 month maintenance plan

1008967

FLEXT-FUEL-0 1-FLEX I Fueling Trailer # 1

- 6 month maintenance June 2, 2017

1008968

FLEXT-FUEL-0 1-FLEX I Fueling Trailer # 1

- 36 month maintenance plan

14000593.915

Functional Test Passive Antenna Connection to Aux Building 2

Calculations

Number Title Revision / Date 81402-C-001 Development of Enveloped Ground Motion Response Spectra for HCSTF Design

81402-C-013 Hardened Condensate Storage Tank Design

81402-C-014 Hardened Condensate Storage Tank Facility

81402-C-017 Qualification of Ring Net and Framing System for Tornado Missile Loads

95599-M-001 1974' Auxiliary Building Flooding Elevation

AMN-003-CALC-017 AFW Hydraulic Calculation for FLEX Piping Configuration

CEC-CS-005-00 Liquefaction Resistance and Post

-Earthquake Settlement for ISFSI at Callaway Energy Center

CN-PEUS-12-09 Callaway FLEX Battery Coping Analysis

DAR-SEE-II-12-17 Evaluation of Alternate Coolant Sources for Responding to a Postulated Extended Loss of All AC Power at the Callaway Energy Center

SC-670005-01 Superstructure Design Calculations

SC-670005-03 Missile Impact Evaluation

Z-1052-S-002 Robust Missile Barrier Calculation

Miscellaneous

Documents/Reports Number Title Revision / Date

Callaway Plant, Unit

- Safety Evaluation Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders

EA-12-049 and EA

-12-051 February 2, 2017

Control Room Operator Logs June 19 - 22, 2017

NEI 12-02 Phase 2 Extended Loss of Alternating Current Power (ELAP) Emergency Response Organization (ERO) Staffing Analysis Report

NANTeL Generic Basic FLEX Training

NANTeL Generic Advanced FLEX Training

LOCT Cycle 13

-4, 13-5, 14-2, 15-1, 15-2, 15-5 and 16-2 Training Documents

NLOCT Cycle 13

-4, 13-5, 15-1, 15-2 and 15-6 Training Documents

GET Plant Access Callaway

I/C Fukushima Seminar

51-9242058-002 SAFER Response Plan for Callaway Energy Center November 5, 2015

Miscellaneous

Documents/Reports Number Title Revision / Date

APA-ZZ-00391, Appendix 7

FLEX Validation Documentation

MP 13-0026 Spent Fuel Pool Cooling During BDBEE

0.2

MP 13-0027 SFP Instrumentation for NRC Order EA

-12-051 1

MP 13-0028 RWST Tie-In to Support FLEX Strategies

MP 15-0012 Engineering Disposition: HCST Tank, Protective Barrier System, Valve House, and Electrical Power

007 Self-Assessment

201720030-035 FLEX Program Compliance with NRC Requirements June 12, 2017

T61.OSLPS PRI 1 TRRQ Review for Hardened CST and New FLEX Equipment October 26, 2016 T62.1000.8

Fukushima Event August 14, 2012 T62.1000.8

Fukushima Modifications May 1, 2014

T62.P100.6

Introduction to Plant Emergency Conditions

- Part 2 October 28, 2013 T63.0630.8

TRRQ

201309537 Westinghouse Guided Wave RADAR Spent Fuel Pool Level Indication System June 18, 2014

T64.0340.8

RP - Station Blackout July 18, 2013

T64.0340.8

RP - Fukushima Modifications July 21, 2015

T64.0340.8

RP - Temp Power to HPAC

May 15, 2017

T64.0340.8

RP - Operating Experience July 24, 2012

T64.0360.8

Chemistry

- FLEX Debris Removal May 23, 2016

T64.0360.8

Chemistry

- FLEX Loss of Power January 14, 2014 T64.0360.8

Chemistry

- Atmospheric Hazards July 17, 2015

T64.0360.8

Chemistry Continuing Training January 14, 2014 T67.0200.8

2016-2 Electrical Continuing Training August 1, 2016

T68.SORI.5

Crisis Leadership March 5, 2015

ML17277A053

SUNSI Review By:

RDA ADAMS

Yes

No

Non-Sensitive

Sensitive

Publicly Available Non-Publicly Available Keyword:

NRC-002 OFFICE SPE:DRP/A PE:DRP/C RE:DRS/EB2

SRI:DRP/B BC:DRP/B

NAME RAlexander

MStafford SAlferink DBradley NTaylor

SIGNATURE /RA/ /RA-E/ /RA-E/ /RA-E/ /RA DProulx Acting for/

DATE 09/27/17 10/03/17 09/28/17 09/28/17 10/03/17