IR 05000483/2019002

Integrated Inspection Report 05000483/2019002

ML19221B450
Person / Time
Site:	Callaway
Issue date:	08/09/2019
From:	O'Keefe N NRC/RGN-IV/DNMS/NMSB-B
To:	Diya F Ameren Missouri
References
IR 2019002
Download: ML19221B450 (51)

Text

ust 9, 2019

SUBJECT:

CALLAWAY UNIT 1 - INTEGRATED INSPECTION REPORT 05000483/2019002

Dear Mr. Diya:

On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Callaway Plant. On July 2, 2019, the NRC inspectors discussed the results of this inspection with Mr. T. Herrmann, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspectors did not identify any finding or violation of more than minor significance.

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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Neil F. O'Keefe, Chief Reactor Projects Branch B Docket No.: 05000483 License No.: NPF-30

Enclosure:

Inspection Report 05000483/2019002 With Attachments:

Documents Reviewed Request for Information O

Inspection Report

Docket Number: 05000483 License Number: NPF-30 Report Number: 05000483/2019002 Enterprise Identifier: I-2019-002-0006 Licensee: Union Electric Company Facility: Callaway Plant Location: Steedman, MO 65077 Inspection Dates: April 1 to June 30, 2019 Inspectors: C. Alldredge, Senior Enforcement Specialist B. Baca, Health Physicist D. Bradley, Senior Resident Inspector R. Carrion, Senior Reactor Inspector P. Elkmann, Senior Emergency Preparedness Inspector N. Greene, Senior Health Physicist S. Janicki, Resident Inspector J. O'Donnell, Health Physicist B. Tharakan, Senior Project Engineer D. You, Resident Inspector Approved By: Neil F. O'Keefe, Chief Reactor Projects Branch B Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at the 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 No findings or violations of more than minor significance were identified.

Additional Tracking Items None.

PLANT STATUS

Callaway began the inspection period at approximately 20 percent power with a planned shutdown in progress for the refueling outage. On April 1, 2019, the licensee shut down the reactor and commenced the planned refueling outage. On April 17, with the reactor defueled and in no Mode, safety-related bus NB01 lost power and was automatically reenergized by the associated emergency diesel generator due to a loss of the 365 kV switchyard bus (NRC Event 54005). On May 11, with the reactor in Mode 4, the licensee identified an auxiliary building door that had been blocked open through reactor Mode ascension (NRC Event 54061).

On May 16, the licensee commenced a reactor startup. Later that day, an automatic reactor trip occurred due to high flux in the source range (NRC Event 54069) when operators failed to block this trip when conditions called for them to do so. On May 17, the licensee commenced a reactor startup. On May 18, the licensee tripped the main turbine due to high vibrations and the reactor remained critical, by design, due to the low power level at the time of the turbine trip.

The licensee restored the main turbine to service and connected the main generator to the electric grid on May 19. The licensee reached full power on May 22 and remained at this power level through the end 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 plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. 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 Summer Readiness Sample (IP Section 03.01)

The inspectors evaluated summer readiness of offsite and alternate alternating current (AC)power systems on June 5, 2019. The inspectors also reviewed the prioritization of efforts to restore offsite power to support Callaway, including a tour of the Ameren Transmission facility in St. Louis, for a design basis loss of offsite power event.

71111.04 - Equipment Alignment Partial Walkdown Sample (IP Section 03.01)

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

(1) Essential service water trains A and B on April 22, 2019

(2) Emergency diesel generator train A on April 28, 2019

(3) Residual heat removal system train B on May 8, 2019

(4) Main turbine and electro-hydraulic control systems on June 4, 2019

71111.05Q - Fire Protection Quarterly Inspection (IP Section 03.01)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Switchyard including switchyard control building, fire area S-15 on April 22, 2019

(2) Spent fuel pool, bridge, and laydown area, fire area FB-1 on May 10, 2019

(3) Control building 2016' elevation, fire areas C-13, C-15, C-17, and C-35 on May 29, 2019

(4) Spent fuel pool heat exchanger rooms and cask wash down area, fire area FB-1 on June 4, 2019

(5) Emergency diesel generator train A and essential switchgear train B, fire areas D-1 and C-10 on June 20, 2019

71111.06 - Flood Protection Measures Inspection Activities - Internal Flooding (IP Section 02.02a.)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Control building 1974' elevation, room 3101, on May 8, 2019

71111.07A - Heat Sink Performance Annual Review (IP Section 02.01)

The inspectors evaluated readiness and performance of:

(1) Component cooling water heat exchanger EEG01A on April 4, 2019

71111.08P - Inservice Inspection Activities (PWR) PWR Inservice Inspection Activities Sample (IP Section 03.01)

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 8 through April 12, 2019:

03.01.a - Nondestructive Examination and Welding Activities

(1) NDE activity type: Magnetic Particle Testing (MT)a) Pipe to flange weld (FW-01), Job #17002729, Task 180, Report 5010-19-0001, ASME Class 3 b) Pipe to crossover tee weld (FW-17), Job # 17002729, Task 500, Report 5010-19-0008, ASME Class 3 c) Pipe to elbow weld (FW-21), Job # 17002729, Task 500, Report 5010-19-0009, ASME Class 3 d) Pipe to crossover tee weld (FW-10), Job # 17002729, Task 500, Report 5010-19-0012, ASME Class 3

(2) NDE activity type: Ultrasonic Testing (UT)a) RPV replacement stud 2, Report 19-000245, ASME Class1

(3) NDE activity type: Visual Testing (VT)a) Fuel transfer system tube and flange, Job #17512708, Task 510, Report 5040-19-002, ASME Class IWE (VT-1)03.01.b - Pressurized-Water Reactor Vessel Upper Head Penetration Examination Activities

(1) Penetration numbers 1 through 78, Job #13503632; no indications identified 03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities

(1) Condition Report 201800861-002, boric acid screen and evaluation

(2) Condition Report 201801218-001, boric acid screen and evaluation

(3) Condition Report 201801218-002, boric acid screen and evaluation 03.01.d - No steam generator tube inspections were performed this inspection period 03.01.e - The inspectors reviewed 10 condition reports associated with inservice inspection related topics and determined that the licensee was entering issues into the corrective action program and taking appropriate actions to resolve

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

The inspectors observed and evaluated licensed operator performance in the control room during:

(1) Reduced reactor coolant system inventory, including infrequently performed test or evolution (IPTE) briefs, on May 5, 2019

(2) Vacuum fill of the reactor coolant system on May 6, 2019 Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

The inspectors observed and evaluated licensed operator training in the simulator for:

(1) Reactor start-up on May 6, 2019

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness Inspection (IP Section 02.01)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Essential service water including butterfly valves on April 8, 2019

Quality Control (IP Section 02.02) (1 Sample)

The inspectors evaluated maintenance and quality control activities associated with the following equipment performance activities:

(1) Residual heat removal train A including hand-switches on June 21, 2019

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Planned elevated risk during polar crane maintenance and operation on April 4, 2019

(2) Planned elevated risk for the train A work window on April 8, 2019

(3) Planned elevated risk during switchyard maintenance on April 2, 2019

(4) Planned elevated risk for reactor power ascension and recovery of a digital turbine hydraulics controller on May 20, 2019

71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 02.02)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Dropped control rod H-8, Condition Report 201901077, on April 12, 2019

(2) Turbine-driven auxiliary feedwater pump internal inspection results, Condition Report 201902635, on April 17, 2019

(3) Reactor coolant motor-operated valve BBHV0016 stem nut wear, Condition Report 201902462, on April 18, 2019

(4) Switchyard breaker MDV45 failure to close, Condition Report 201902658, on April 18, 2019

(5) Essential service water failure analysis for valves EFHV0065 and EFHV0066, Condition Report 201806521, on May 9, 2019

(6) Control room air conditioning unit SGK04A degraded cooling capacity, Condition Report 201904050, on May 31, 2019

71111.18 - Plant Modifications Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

The inspectors evaluated the following permanent modification:

(1) Main turbine generator governor controls, MP 08-0027, on April 4, 2019

71111.19 - Post-Maintenance Testing Post Maintenance Test Sample (IP Section 03.01)

The inspectors evaluated the following post maintenance tests:

(1) Polar crane and load cell after equipment outage on April 6, 2019

(2) Ultimate heat sink cooling tower fans train B after equipment outage on April 12, 2019

(3) Essential service water modification MP 17-0006 on April 16, 2019

(4) 36 kV circuit breaker MDV55 after modification on April 22, 2019

(5) Main feedwater regulating valves AEFCV0510 and AEFCV0530 after equipment outage on May 5, 2019

(6) 125 Vdc battery NK11 after replacement on May 13, 2019

(7) Load shedding and emergency load sequencing train A after equipment outage on May 19, 2019

71111.20 - Refueling and Other Outage Activities Refueling/Other Outage Sample (IP Section 03.01)

(1) The inspectors evaluated refueling outage RF23 from April 1 through May 22, 2019

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Inservice Testing (IP Section 03.01)

(1) Pressurizer power operated relief valve inservice test in Mode 4 on April 3, 2019

(2) Component cooling water cross tie valves inservice testing on June 2, 2019 Reactor Coolant System (RCS) Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1) RCS water inventory balance surveillance post-reactor startup from Refueling Outage RF23 on June 19, 2019

Surveillance Tests (other) (IP Section 03.01) (3 Samples)

(1) Engineered safety features actuation systems train A on April 5, 2019

(2) Class 1E electrical equipment air conditioning system actuation and flow test on date May 11, 2019

(3) Turbine-driven auxiliary feedwater pump test in Mode 3 on May 15, 2019

71114.04 - Emergency Action Level and Emergency Plan Changes Inspection Review (IP Section 02.01-02.03)

(1) The inspectors evaluated Procedure EIP-ZZ-00101, Addendum 2, "Emergency Action Level Technical Basis Document," Revision 16, on May 1, 2019 This evaluation does not constitute NRC approval.

71114.06 - Drill Evaluation Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)

(1) Team 4 full participation emergency response organization drill on June 6,

71124.01 - Radiological Hazard Assessment and Exposure Controls Contamination and Radioactive Material Control (IP Section 02.03)

The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material. The inspectors verified the following sealed sources are accounted for and are intact:

(1) 0029GZ

(2) 3217GN

(3)81-616

(4) 0819GG/4660

(5) E-083/S-13

(6) CNP-148

(7) MRC-4108 High Radiation Area and Very High Radiation Area Controls (IP Section 02.05) (1 Sample)

The inspectors evaluated risk-significant high radiation area and very high radiation area controls.

Instructions to Workers (IP Section 02.02) (1 Sample)

The inspectors evaluated instructions to workers including radiation work permits used to access high radiation areas:

Radiation work packages

(1) R23HDDESTUD, Revision 0 - install stud tensioner hoists, deten0sion reactor vessel studs, remove reactor vessel studs, clean stud holes, lubricate stud holes, install stud hole plugs, and install guides studs/pins

(2) R23HDSTUD18, Revision 0 - Refuel 23 activities to remove reactor vessel stuck stud 18, including thread repairs, and inspect its stud hole; includes cutting, boring, QC/Engineering inspections, and associated cavity work (except cavity decontamination)

(3) R23STD18DECON, Revision 0 - RF23 upper cavity gross rinse, vacuum of seal ring, upper cavity decontamination, and reactor vessel flange cleaning to support removal of stuck reactor vessel stud 18, includes all Radiation Protection coverage and surveys

(4) R23ENGHRA, Revision 0 - R23 engineering activities inside high radiation areas in all radiologically controlled areas including the reactor building

(5) 16003707510, Revision 0 - RT new nipolet to valve weld on Valve EMV0161 Electronic alarming dosimeter alarms

(1) The licensee did not have an occurrence of a dosimeter alarm during the inspection period. The inspectors reviewed corrective action documents, radiation work permits and ALARA plans, as well as, interviewed workers to ensure the licensee was evaluating and controlling occupational worker exposures appropriately.

Labeling of containers

(1) Framatome core offloading/reloading and stuck stud removal equipment boxes

(2) Westinghouse fuel assembly inspection equipment boxes

(3) Pipefitters equipment boxes for the radiologically controlled area use

(4) Radioactive material (radioactive source) storage containers

(5) Radioactive material trash bags in the reactor containment building and auxiliary building Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 02.06) (1 Sample)

The inspectors evaluated radiation worker performance and radiation protection technician proficiency.

Radiological Hazard Assessment (IP Section 02.01) (1 Sample)

The inspectors evaluated radiological hazards assessments and controls. The inspectors reviewed the following:

Radiological surveys

(1) General containment

(2) Reactor cavity

(3) Reactor head

(4) Inside bioshield

(5) Incore tunnel Risk significant radiological work activities

(1) Reactor head lift

(2) Refuel activities

(3) Reactor head stud replacement - stuck stud 2 and 18

(4) Cavity decontamination

(5) Radiography Air sample survey records

(1) Reactor containment building entries: 29-MAR-19-200005,7,8; and 31-Mar-19-200004, 5, 8

(2) Reactor containment building outage dailies: 08-APR-19-200008,9,10; 09-APR-19-200012,13,14; and 10-APR-19-200004,5,6

(3) Reactor cavity: 08-APR-19-200023, 24; 08-APR-19-200025, 26; 09-APR-19-200003,5; 09-APR-19-200006,8; and 10-APR-19-200023, 24

(4) Reactor head stand O-ring cutout: 10-APR-19-200007,18

(5) Breach of Valve BGHV8149B: 10-APR-19-200029, 34 Radiological Hazards Control and Work Coverage (IP Section 02.04) (1 Sample)

The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.

Radiological work package for areas with airborne radioactivity

(1) There were no radiation work permits with airborne radioactivity available for review during this inspection. The inspectors reviewed radiation work permits with the highest potential for airborne radioactivity and the results for air samples taken during the inspection period.

71124.02 - Occupational ALARA Planning and Controls Implementation of ALARA and Radiological Work Controls (IP Section 02.03)

The inspectors reviewed ALARA practices and radiological work controls by reviewing the following activities:

(1) RWP 16003707510, EMV0161 radiography

(2) RWP R23HDSTUD18, remove stuck stud 18

(3) RWP R23STD18DECON, RF23 Cavity Decontamination

Radiation Worker Performance (IP Section 02.04) (1 Sample)

The inspectors evaluated radiation worker and radiation protection technician performance during general work in containment, decontamination of the vessel flange in preparation for the removal of stuck stud 2, and during the radiography of EMV0161 in the auxiliary building.

71124.05 - Radiation Monitoring Instrumentation Calibration and Testing Program (IP Section 02.02)

The inspectors evaluated the calibration and testing program implementation. The inspectors reviewed the following:

Alarm Setpoint and Calibration Method Check of Personnel Contamination Monitors, Portal Monitors and Small Article Monitors

(1) TM-4010-HP

(2) PM-4046-HP Failure to Meet Calibration or Source Check Acceptance Criteria

(1) CRM-4190-HP

Walk Downs and Observations (IP Section 02.01) (1 Sample)

The inspectors evaluated radiation monitoring instrumentation during plant walkdowns. The inspectors reviewed the following:

Portable Survey Instruments

(1) CRM-4025-HP

(2) CRM-4087-HP

(3) CRM-4134-HP

(4) CRM-4023-HP

(5) CRM-4089-HP

(6) ION-4174-HP

(7) GMI-4178-HP Source Check Demonstration

(1) ION-4172-HP

(2) CRM-4115-HP

(3) GMI-4178-HP Area Radiation Monitors and Continuous Air Monitors

(1) 0-EG-RE-09

(2) 0-GT-RE-33

(3) 0-SD-RE-24

(4) 0-SD-RE-38

(5) CAM-4019-HP

(6) CAM-4020-HP Personnel Contamination Monitors, Portal Monitors and Small Article Monitors

(1) TM-4010-HP

(2) PCM-4054-HP

(3) PM-4046-HP

==71124.06 - Radioactive Gaseous and Liquid Effluent Treatment Calibration and Testing Program (Process & Effluent Monitors) (IP Section 02.02) (1 Sample)

The inspectors reviewed the following gaseous and liquid effluent monitor instrument calibrations and tests:

(1) GH-RE-10 radwaste building unit vent functional test, June 13, 2019

(2) GT-RE-21A plant unit vent calibration, January 29, 2019

(3) GT-RE-21B plant unit vent calibration, August 23, 2018

(4) HB-RE-18 liquid radwaste discharge monitor calibration, August 21, 2018 Dose Calculations (IP Section 02.05)==

The inspectors reviewed the following liquid and gaseous discharge permits to evaluate public dose calculations:

(1) Batch liquid radioactive release permit numbers:

• RP09-2019-L0037;0

• RP09-2018-L0007;1

• RP09-2017-L0028;1

(2) Batch airborne radioactive release permits:

• RP11A-2019-G0013;1

• RP13-2018-G0002;56

• RP13-2017-G0006;52 The inspectors reviewed the following annual radiological effluent release reports:

(1) 2017 Annual Radiological Effluent Release Report

(2) 2018 Annual Radiological Effluent Release Report The inspectors also reviewed the following abnormal gaseous or liquid tank discharges:

(1) None were available for review during this inspection

Instrumentation and Equipment (IP Section 02.04) (1 Sample)

The inspectors reviewed the following radioactive effluent discharge system surveillance test results:

(1) Auxiliary/fuel building emergency exhaust filter adsorber Unit B, in-place leak test

(2) Control room pressurization filter adsorber Unit B, in-place leak test

(3) Control room filter adsorber Unit A, in-place leak test

Sampling and Analysis (IP Section 02.03) (1 Sample)

The inspectors reviewed the following radioactive effluent sampling and analysis activities:

(1) None were available for review during this inspection The inspectors reviewed the following effluent discharge:

(1) June 11, 2019, discharge monitor tank A discharge

Walk Downs and Observations (IP Section 02.01) (1 Sample)

The inspectors walked down the following gaseous and liquid radioactive effluent monitoring and filtered ventilation systems to assess the material condition and verify proper alignment according to plant design:

(1) Liquid radwaste treatment system

(2) Gaseous radwaste treatment system

71124.07 - Radiological Environmental Monitoring Program Groundwater Protection Initiative (GPI) Implementation (IP Section 02.02)

The inspectors evaluated the licensee's voluntary groundwater protection initiative through review of licensee documented leaks and spills since the last inspection, groundwater sampling results, and any changes to the licensee's groundwater sampling, ground water protection initiative, and spill and leak program and procedures. The inspectors reviewed and observed selected onsite groundwater locations as delineated in the licensee's program to ensure timely identification of inadvertent releases into the groundwater. The licensee had no entries of spills or leaks into their 10 CFR 50.75(g) records since the last inspection.

The licensee is continuing to monitor tritium through monitoring wells MW-31, MW-34, MW-36, MW-39, MW-47, MW-58, and MW-59. In 2017, the licensee identified a peak concentration in monitoring well MW-31 of 1,688 picoCuries per liter (pCi/l) in January which decreased by the end of the year to 278 pCi/l. In 2018, monitoring well MW-58 peaked at 911 pCi/l in January and decreased to 516 pCi/l by October. The licensee reported their sampling results in each respective annual radiological environmental operating report. The licensee is continuing to monitor the tritium levels and the continued decrease through natural attenuation.

Site Inspection (IP Section 02.01) (1 Sample)

The inspectors evaluated the radiological environmental monitoring program implementation:

Walkdowns, Calibrations, and Maintenance Record Review

(1) Air sampling stations: A1, A7, A8, A9, A10, and A11

(2) Thermoluminescent dosimeter (TLD) locations: 03, 05, 06, 21, 22a, 44, 45, 46, 47, and 61

(3) Air sampler pump calibrations: LAS-4179, LAS-4182, and LAS-4201

(4) Meteorological tower instrument calibrations Environmental Sample Collections and Preparation Observation

(1) Vegetation samples from three sample locations: V9, V11, and V16

(2) Surface water grab samples from S01 and S02 locations Licensee Actions in Response to Missed Sample, Inoperable Sampler, Lost TLD or Anomalous Measurement

(1) Licensee instituted compensatory sampling for selected surface water sampling locations (S01 and S02) due to flooding conditions

(2) Licensee replaced older air sampling pumps with new F&J pumps

(3) Licensee converted air sample stations from a straight line sample port to an overhanging goose neck configuration

(4) Missed environmental samples were evaluated for nominal equipment failures, aged equipment issues, power source issues, and sample reliability. The licensee made repairs, replaced equipment, and adjusted sampling locations to fulfill the environmental sampling program requirements. All missed and anomalous results were reported in the annual radiological environmental operating report.

Sampling Program for the Potential of Licensed Material Entering Groundwater

(1) The inspectors reviewed data from and observed the following sampled groundwater wells: U1MW-31, U1MW-937D, U1MW-939R, U1MW-940, U1MW-941, and U1MW-GW

71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation Radioactive Material Storage (IP Section 02.01)

The inspectors evaluated radioactive material storage in the follow areas:

(1) Low Level Drum Storage Area (55-gallon drums)

(2) Radwaste north yard

(3) Radwaste south yard The inspectors performed a container check (e.g., swelling, leakage and deformation) on the following containers:

(1) 9563, sludge oil solidified waste

(2) 9673, solidified waste

(3) 9677, solidified waste

(4) 9687, solidified waste

(5) 9709, SLW sludge solidified waste

(6) 9710, oily waste

(7) 16145, SGBD resin Radioactive Waste System Walkdown (IP Section 02.02) (1 Sample)

The inspectors evaluated the following radioactive waste processing systems [and processes] during plant walkdowns:

Liquid or Solid Radioactive Waste Processing Systems

(1) Self-engaging dewatering system Radioactive Waste Resin and/or Sludge Discharges Processes

(1) Resin handling system for spent resin and charcoal

Shipment Preparation (IP Section 02.04) (1 Sample)

The inspectors evaluated [and observed] the following radioactive material shipment preparation processes:

(1)19-021, UN2912, radioactive material, LSA-I, Class 7, resin, June 11, 2019

Shipping Records (IP Section 02.05) (1 Sample)

The inspectors evaluated the following non-excepted package shipment records:

(1)17-010, UN3321, radioactive material, LSA-II, Class 7, drummed mechanical filters, June 22, 2017

(2)17-012, UN3321, radioactive material, LSA-II, Class 7, dewatered resin, July 12, 2017

(3)17-061, UN2912, radioactive material, LSA-I, Class 7, dry active waste CYC 21, November 17, 2017

(4)18-001, UN3321, radioactive material, LSA-II, Class 7, dewatered resin and charcoal, January 12, 2018

(5)18-010, UN2911, radioactive material, Excepted Package, Class 7, instruments, April 12, 2018

(6)18-018, UN2911, radioactive material, Excepted Package, Class 7, instruments, September 20, 2018

(7)18-036, UN2912, radioactive material, LSA-I, Class 7, dry active waste, December 26, 2018

(8)19-005, UN3321, radioactive material, LSA-II, Class 7, resin and charcoal, March 19, 2019 Waste Characterization and Classification (IP Section 02.03) (1 Sample)

The inspectors evaluated the radioactive waste characterization and classification for the following waste streams:

(1) 14Aug17-200011GEL, FBG02A BTRS Resin 2017, August 1, 2017

(2) 17Aug17-200011FBGD, FBG02D BTRS Resin, August 17, 2017

(3) 09MAR200018 DAW1, DAW CYCLE 22, March 8, 2018

(4) 18APR18-200020 PV3/6, ALPS PV3/PV6 Resin, April 18, 2018

(5) 07May18-200011(PV1), ALPS PV-1 Charcoal 2019, May 1, 2018

(6) 16AUG18-200010(PV3), ALPS PV-3 Resin, August 15, 2018

(7) 18Jan19-200021(PV2), ALPS PV-2 Charcoal 2019, January 15,

OTHER ACTIVITIES - BASELINE

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

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

(1) April 1, 2018 through March 31, 2019 MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (1 Sample)

(1) April 1, 2018 through March 31, 2019

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

(1) April 1, 2018 through March 31, 2019 OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) October 1, 2018, through March 31, 2019 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences

Sample. (IP Section 02.16) (1 Sample)

(1) October 1, 2018, through March 31, 2019

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues (IP Section 02.03)

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

(1) Instrument air pressure control valves on June 22, 2019

Semiannual Trend Review (IP Section 02.02) (1 Sample)

The inspectors reviewed the licensees corrective action program for potential adverse trends in troubleshooting equipment issues when the cause of a deficiency is not immediately clear and for a trend in safety-related door issues on June 3, 2019.

71153 - Followup of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)

(1) The inspectors evaluated essential service water valve EHV0066 valve coupling failure and the licensees response on April 12, 2019

Personnel Performance (IP Section 03.03) (2 Samples)

(1) The inspectors evaluated an automatic reactor trip and the licensees performance on May 17, 2019

(2) The inspectors evaluated a manual turbine trip and the licensees performance on May 18,

INSPECTION RESULTS

Observation: Semi-Annual Trend Review 71152 The inspectors reviewed the licensees corrective action program, performance indicators, system health reports, and other documentation to identify trends that might indicate the existence of a more significant safety issue for troubleshooting equipment issues when the cause of a deficiency is not immediately clear and for a trend in safety-related door issues.

The following troubleshooting examples were reviewed by the inspectors for 2019 where the licensee was unable to positively identify the cause or correct the apparent condition:

• Condition Report 201900105: The P-9 bistable light was found unexpectedly not lit during a routine control room walkdown. The licensee decided to make an unplanned entry into the reactor trip instrumentation technical specification based on the indication. The licensee determined there were no activities in progress that affected the indication, verified that that the P-9 bistable was in the correct state, and a lamp test confirmed the light bulb was functioning. The P-9 bistable light then spontaneously relit and the licensee exited Technical Specification 3.3.1. The licensee concluded that that the observed condition appeared to be an indication problem only but was unable to find a clear cause. The licensee later inspected and re-lamped indicator lights for this issue.

• Condition Report 201901077: Control rod H-8 dropped while operating control rod bank D. Extensive troubleshooting by the licensee could not determine a conclusive reason for the control rod drop. After performing an undetermined cause risk assessment per Procedure MDP-ZZ-TR001, Planning and Execution of Formal Troubleshooting Activities, the licensee recovered the rod. The licensee discussed the condition with the vendor, reviewed industry operating experience, and later performed inspections of the control rod drive mechanism during the refueling outage.

After eliminating other possible causes, the licensee concluded that the probable cause was crud in the latching mechanism.

• Condition Report 201903494: When the train B motor-driven auxiliary feedwater pump suction check valve failed its breakaway torque checks, the licensee decided to make an unplanned entry into the auxiliary feedwater system technical specification.

The licensee conducted an inspection of the valve's internals which did not identify an obvious cause for the increased torque required to operate the check valve. The licensee later concluded the valve packing was the cause of the increased resistance.

The licensee returned the check valve to service following an adjustment of the valve packing and a successful performance of the torque check. Although a clear cause was not identified, the licensee took steps to eliminate other possible causes and took corrective action to improve operating torque.

The inspectors noted that the for these three examples, the licensee conservatively declared the equipment inoperable and initiated timely actions to identify the cause of the condition.

When the condition self-cleared or the cause could not be positively identified, the licensee ensured that they ruled out the known possible causes and took appropriate corrective actions to try to address the problem. The inspectors verified that all issues were addressed within the scope of the corrective action program and that the completed and planned corrective actions were appropriate to correct the identified causes. The inspectors did not identify any trends or concerns that might be indicative of a more significant safety issue for troubleshooting equipment issues when the cause of a deficiency is not immediately clear.

The inspectors also reviewed an apparent trend in problems with doors that were important to safety. After the NRC identified Green non-cited violation 05000483/2018002-02 (ADAMS ML18221A398), an auxiliary building door that was blocked open during Mode ascension (NRC Event 54061), and damaged door seals identified by the NRC which were documented in Condition Report 201903536, the licensee wrote Condition Report 201904398 to evaluate 34 condition reports generated in 2019 for an adverse trend in door issues. The licensee recognized gaps in their staffs understanding of functions performed by doors, identifying degraded conditions (including during use), and timely resolution of the issues identified. The inspectors noted that condition reports were being appropriately generated for individual deficiencies but that programmatic issues remain to be addressed. The inspectors noted that many of the condition reports are the result of a concerted effort to identify door issues at a low threshold. The inspectors concluded that the licensee appropriately identified this trend in safety-related door issues and was acting to address the causes.

Overall, the inspectors concluded that the licensee demonstrated a low threshold for issue identification and documentation in the corrective action program. The licensee applied a risk-based approach to ensure corrective actions are completed commensurate with an issues safety significance. The inspectors did not identify any additional trends or concerns that might be indicative of a more significant issue with safety-related doors.

EXIT MEETINGS AND DEBRIEFS

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

• On July 2, 2019, the inspectors presented the integrated inspection results to Mr. T. Herrmann, Site Vice President, and other members of the licensee staff.

• On April 12, 2019, the inspectors presented the occupational radiation safety inspection results to Mr. T. Herrmann, Site Vice President and other members of the licensee staff.

• On April 12, 2019, the inspectors presented the inservice inspection results to Mr. T. Herrmann, Site Vice President and other members of the licensee staff.

• On June 14, 2019, the inspectors presented the public radiation safety inspection results to Mr. B. Cox, Assistant Site Vice President and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Corrective Condition Reports 201104350, 201900304, 201903907, 201903907

Action

Documents

71111.01 Miscellaneous ULDBD-GF-001 Miscellaneous Building HVAC 3

71111.01 Procedures EDP-ZZ-01129 Callaway Plant Risk Assessment 50

71111.01 Procedures ODP-ZZ-0016E Operations Technician Watchstation Practices and 45

Rounds

71111.01 Procedures PDP-ZZ-00027 Summer Readiness Program 8

71111.04 Corrective Condition Reports 201702402, 201806793, 201807138

Action

Documents

71111.04 Procedures OTN-EJ-00001 Residual Heat Removal System 28

71111.05Q Miscellaneous MP 16-0024 SGK05 Supplemental Fan System 8

71111.05Q Miscellaneous Various Fire Pre-plan Manual 40

71111.05Q Procedures APA-ZZ-00703 Fire Protection Operability Criteria and Surveillance 30

Requirements

71111.05Q Procedures APA-ZZ-00750 Hazard Barrier Program 44

71111.06 Miscellaneous PM0900506 Walkdown of the RWST FDN and Valve House

71111.06 Miscellaneous PM1009292 Clean Debris from UHS Cooling Tower Fan Deck

Drains

71111.06 Procedures ESP-ZZ-01013 Maintenance Rule Structures Inspection 8

71111.07A Corrective Condition Reports 201902062, 201902231, 201902396, 201902456,

Action 201902921

Documents

71111.07A Work Orders 16506165, 17513066

71111.08P Corrective Condition Reports 201800861, 201801218, 201804786, 201804794,

Action 201804816, 201901976

Documents

71111.08P Corrective Condition Reports 201902288

Action

Documents

Resulting from

Inspection Type Designation Description or Title Revision or

Procedure Date

Inspection

71111.08P Engineering Condition Reports 201800861-002, 201801218-001, 201801218-002

Evaluations

71111.08P Miscellaneous Callaway Nuclear Plant Containment Exterior 4

Concrete and Tendon Inspection Program

71111.08P Miscellaneous Callaway Nuclear Plant Containment Pressure 4

Boundary ISI Program, ASME Section XI, Subsection

IWE

71111.08P Miscellaneous Fourth Interval Inservice Inspection Program Plan, 0

Fourth Interval Inservice Inspection Program Plan

71111.08P Miscellaneous Fourth Interval Inservice Inspection Program Plan 1

71111.08P Miscellaneous Fourth Interval Inservice Inspection Program Plan 0

Appendix A, Code Cases and Requests for

Relief/Alternative Applied to the Fourth Interval

71111.08P Miscellaneous Fourth Interval Inservice Inspection Program Plan 1 - Draft

Appendix A, Code Cases and Requests for

Relief/Alternative Applied to the Fourth Interval

71111.08P Miscellaneous NDE Personnel Qualifications for D. Davis and W.

Thomas

71111.08P Miscellaneous Welding Personnel Qualifications for

A. Carroll,

M.

Collier,

R. Holliday,

A. Langkop,

D. Leeper,

J. Parker,

N. Rosenquist,

B. Thomas,

A. Weisacosky, and C.

Wood

71111.08P Miscellaneous Relief Request I4R- Relief from the Requirements of the ASME Code,

Section XI, Table IWF-2500-1 for 100 Percent Visual

Examination of Class 1 Supports

71111.08P Miscellaneous Relief Request I4R- Request for Alternative Applicable to the Fourth 10-

Year Inspection Program Interval

71111.08P Miscellaneous Specification C- Inservice Inspection of the Containment Post- 13

1003(Q) Tensioning System and Exterior Concrete Shell

71111.08P NDE Reports Job #13503632, RPV Head Bare Metal Examination Summary, ASME 04/13/19

Task 500 Code Class 1

71111.08P NDE Reports Report 5010-19- Pipe to flange weld (FW-01), Job # 17002729, Task

0001 180, ASME Class 3

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.08P NDE Reports Report 5010-19- Pipe to crossover tee weld (FW-17), Job # 17002729,

0008 Task 500, ASME Class 3

71111.08P NDE Reports Report 5010-19- Pipe to elbow weld (FW-21), Job # 17002729, Task

0009 500, ASME Class 3

71111.08P NDE Reports Report 5010-19- Pipe to crossover tee weld (FW-10), Job # 17002729,

0012 Task 500, ASME Class 3

71111.08P NDE Reports Report 5040-19- Fuel Transfer System Tube and Flange, Job #

2 17512708, Task 510, ASME Class IWE

71111.08P NDE Reports Report: 19-000245 Component: 2-CH-STUD-02-R2, Component 04/29/19

Description: RPV Stud #2 2nd Replacement, ASME

Code Class 1

71111.08P Procedures APA-ZZ-00661 Administration of Welding 16

71111.08P Procedures APA-ZZ-00662 ASME Section XI Repair/Replacement Program 23

71111.08P Procedures EDP-ZZ-01003 Inservice Inspection Program 31

71111.08P Procedures EDP-ZZ-01004 Boric Acid Corrosion Control Program 22

71111.08P Procedures ESP-ZZ-01012 Containment Post-Tensioning System Inspection 9

71111.08P Procedures ESP-ZZ-01016 ASME Section XI IWE Containment Pressure 8

Boundary Inspection

71111.08P Procedures LMT-08-PDI-UT-5 Straight Beam Ultrasonic Examination of Bolts and 0

Studs

71111.08P Procedures MDP-ZZ-LM001 Fluid Leak Management Program 19

71111.08P Procedures MTW-ZZ-WP002 Welder Performance Qualification 27

71111.08P Procedures MTW-ZZ-WP003 Control of Welding Filler Materials 24

71111.08P Procedures MTW-ZZ-WP006 Qualification of Welding Procedures 9

71111.08P Procedures QCP-ZZ-05040 Visual Examination to ASME VT-1 23

71111.08P Procedures QCP-ZZ-05041 Visual Examination to ASME VT-2 30

71111.08P Procedures QCP-ZZ-05042 Visual Examination to ASME VT-3 21

71111.08P Procedures QCP-ZZ-05048 Boric Acid Walkdown for RCS Pressure Boundary 14

71111.08P Procedures QCP-ZZ-05049 RPV Head Bare Metal Examination 5

71111.08P Self- Self-Assessment Material Degradation Management Plan 09/4/2014

Assessments 201309684-08

71111.08P Self- Self-Assessment ISI Program, dated 6/20/14

Assessments 201309684-31

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.08P Work Orders 17002729/180, 17002729/00, 17002729/40,

17992729/580

71111.12 Corrective Condition Reports 201902794, 201901943, 201903344, 201903353,

Action 201903360, 201903366, 201903372

Documents

71111.12 Procedures OTG-ZZ-00002 Reactor Startup - IPTE 61

71111.12 Procedures OTG-ZZ-00003 Plant Startup Hot Zero Power to 30% Power 64

71111.12 Procedures OTN-BB-00001 Reactor Coolant System - IPTE 50

71111.13 Procedures ODMI 19-0002 Tuning Parameter Adjustments on Digital Controls 0

Post Mod Testing

OOA-ZZ-SSM01 Shutdown Safety Monitoring (SSM) 9

71111.15 Corrective Condition Reports 201806521, 201902462, 201904050

Action

Documents

71111.15 Procedures EDP-ZZ-01114 Motor Operated Valve Program Guide 36

71111.15 Procedures MTE-ZZ-QA006 Motor Operated Valve Analyst Guide 10

71111.15 Work Orders 19002798

71111.19 Corrective Condition Reports 201805239, 201902591, 201902876, 201903026,

Action 201903553

Documents

71111.19 Procedures OTN-MD-00001 Switchyard Breakers and Disconnects 30

71111.19 Work Orders 18000062, 18000065, 19001674

71111.20 Corrective Condition Reports 201903004

Action

Documents

71111.20 Procedures ITM-BB-L0053 BBLT0053A/B/BB Fill Vent and Calibration 1

71111.20 Procedures OSP-BB-00007 RCS Heatup and Cooldown Limitations 14

71111.20 Procedures OTA-RK-00018 Annunciator Response Procedure MCB Panel RK018 4

71111.22 Corrective Condition Reports 201902874, 201902927, 201903657, 201903953,

Action 201904075, 201904191

Documents

71111.22 Procedures OSP-AL-P0002 Turbine Driven Aux Feedwater Pump Inservice Test - 80

Group B

71111.22 Procedures OSP-BB-00009 RCS Inventory Balance 38

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.22 Procedures OSP-BB-V002A PORV Inservice Test 14

71111.22 Work Orders 17001333, 17001334, 17003817, 17512419,

17512680, 17513093, 17514041, 17514487,

19507557, 19507663, 19507685, 19507835

71124.01 Corrective Condition Reports 201900315, 201900883, 201900908, 201900930,

Action 201901021, 201901659, 201901908, 201901995

Documents

71124.01 Miscellaneous Air Sample Log Various Air Sample Logs 01/16/2019

-

04/10/2019

71124.01 Miscellaneous PM1002835 Non-Special Nuclear Material RAM Stored in the

Spent Fuel Pool

71124.01 Miscellaneous Source Leak Various Source Leak Checks 01/18/2017 -

Checks 01/25/2019

71124.01 Procedures APA-ZZ-01000 Callaway Energy Center Radiation Protection 046

Program

71124.01 Procedures APA-ZZ-01000, Control of Radioactive Material 22

Appendix A

71124.01 Procedures APA-ZZ-01004 Radiological Work Standards 31

71124.01 Procedures HDP-ZZ-01200 Radiation Work Permits 33

71124.01 Procedures HDP-ZZ-01500 Radiological Postings 48

71124.01 Procedures HDP-ZZ-03000 Radiological Survey Program 47

71124.01 Procedures HDP-ZZ-06000 Contamination Control and Alpha Monitoring Program 24

71124.01 Procedures HSP-ZZ-00001 Radioactive Sealed Source Leak Check Surveillance 15

71124.01 Procedures HTP-ZZ-01203 Radiological Area Access Control 57

71124.01 Procedures HTP-ZZ-02005 Handling of Radioactive Material 49

71124.01 Procedures HTP-ZZ-06001 High Radiation / Locked High Radiation / Very High 51

Radiation Area Access

71124.01 Procedures HTP-ZZ-06028 Radiological Controls for Pools that Contain or Store 9

Spent Fuel

71124.01 Procedures HTP-ZZ-06042 Industrial Radiography Using a Radioactive Source 14

71124.01 Radiation CA-M-20190401-10 RB2000I Mode 3 Survey 04/10/2019

Surveys

71124.01 Radiation CA-M-20190402-24 R23 RB Lower Cavity Blind Flange Removal 04/02/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

Surveys

71124.01 Radiation CA-M-20190402-31 RB2023I Regen HX Post Shielding Survey 04/02/2019

Surveys

71124.01 Radiation CA-M-20190404-31 RB2023I Scaffold Build to BG1E0126 04/04/2019

Surveys

71124.01 Radiation CA-M-20190406-09 RBHead - Reactor Head Lift 04/06/2019

Surveys

71124.01 Radiation CA-M-20190408-05 RB-2000-I G/A Five Days After CRUD Burst 04/08/2019

Surveys

71124.01 Radiation CA-M-20190408-25 Reactor Vessel Head (On Stand) 04/06/2019

Surveys

71124.01 Radiation CA-M-20190410-26 Gross Cavity Decon 04/10/2019

Surveys

71124.01 Radiation CA-M-20190410-27 Rx Shield Plate Install Post Survey 04/10/2019

Surveys

71124.01 Radiation Work R23ENGHRA RF23 Engineering Activities Inside High Radiation 0

Permits (RWPs) Areas in all RCA Areas Including the Reactor Building.

71124.01 Radiation Work R23FUEL RF23 Offload Reactor, Perform FOSAR, Perform 0

Permits (RWPs) Reactor Reload, Core Mapping, Insert Shuffle, Pool

Mapping, B5B Moves, and Miscellaneous Support

Activities.

71124.01 Radiation Work R23HDDESSTUD RF23 Install Stud Tensioner Hoists, Detension 0

Permits (RWPs) Reactor Vessel Studs, Remove Reactor Vessel Studs,

Clean Stud Holes, Lubricate Stud Holes,

Install Stud Hole Plugs, and Install Guides Studs/Pins.

71124.01 Radiation Work R23HDSTUD18 RF23 Activities to Remove Reactor Vessel Stuck Stud 0

Permits (RWPs) 18, Including Thread Repairs, and Inspect Its Stud

Hole. Includes Cutting,

Boring, QC/Engineering Inspections, and Associated

Cavity Work (Except Cavity Decontamination).

71124.01 Radiation Work R23RCPCHANGE RF23 Motor Change on A Reactor Coolant Pump and 0

Permits (RWPs) Associated Tasks.

71124.01 Radiation Work R23STD18DECON RF23 Upper Cavity Gross Rinse, Vacuum of Seal 0

Permits (RWPs) Ring, Upper Cavity Decontamination, and RV Flange

Inspection Type Designation Description or Title Revision or

Procedure Date

Cleaning to Support Removal of

Stuck RV Stud #18. Includes all RP Coverage and

Surveys.

71124.01 Self- AP18006 Nuclear Oversight Audit of Radiological and Non 06/13/2018

Assessments Radiological Environmental Monitoring Programs

71124.02 Corrective Condition Reports 2018-02443, 2018-02930, 2018-02953, 2018-04531,

Action 2018-04758, 2018-04903, 2018-05952, 2018-06019,

Documents 2018-06973, 2019-00904, 2019-00908, 2019-00998,

2019-01277, 2019-01355

71124.02 Miscellaneous RF23 Plant ALARA Review Committee (PARC) 01/24/2019

Meeting

71124.02 Miscellaneous RT Examination of 1" SCH 80 Pipe Weld in Room 113 04/09/2019

of Aux Building Shot Plan

71124.02 Miscellaneous Powering into the Future - Callaway Refuel 23 Daily 04/08/2019 -

News Flyer 04/11/2019

71124.02 Miscellaneous Refuel 23 Outage Update & Shiftly SOM Turnover 04/08/2019 -

04/11/2019

71124.02 Miscellaneous Callaway Radiation Protection Current Log 04/11/2019

71124.02 Miscellaneous CA2943 Radiography Checklist - Radioactive Source 04/09/2019

71124.02 Miscellaneous Reactor Vessel 01/31/2019

Stuck Stud

Removal Project

71124.02 Procedures APA-ZZ-01000 Callaway Energy Center Radiation Protection 45

Program

71124.02 Procedures APA-ZZ-01001 Callaway Plant ALARA Plant 27

71124.02 Procedures APA-ZZ-01004 Radiological Work Standards 31

71124.02 Procedures HDP-ZZ-01100 ALARA Planning and Review 24

71124.02 Procedures HDP-ZZ-01200 Radiation Work Permits 33

71124.02 Procedures HDP-ZZ-01500 Radiological Postings 48

71124.02 Procedures HDP-ZZ-06000 Contamination Control and Alpha Monitoring Program 24

71124.02 Procedures HTP-ZZ-01101 Administrative Controls for Radiation Shielding 26

71124.02 Procedures HTP-ZZ-01104 Hot Spot Trending Program 6

71124.02 Procedures HTP-ZZ-01203 Radiological Area Access Control 57

71124.02 Procedures HTP-ZZ-06001 High Radiation/Locked High Radiation/Very High 51

Inspection Type Designation Description or Title Revision or

Procedure Date

Radiation Area Access

71124.02 Procedures HTP-ZZ-06042 Industrial Radiography Using A Radioactive Source 14

71124.02 Radiation CA-M-20190402-14 SJ Sample & Boronometer / PASS Rooms 04/02/2019

Surveys

71124.02 Radiation CA-M-20190402-17 Access Pit 04/02/2019

Surveys

71124.02 Radiation CA-M-20190405-23 RB-2090 RF Stud Rack Survey Update 18501154.500 04/05/2019

Surveys

71124.02 Radiation CA-M-20190405-31 RB2047 General Area - Routine Survey 04/05/2019

Surveys

71124.02 Radiation CA-M-20190405-33 RB2068 General Area Routine 04/05/2019

Surveys

71124.02 Radiation CA-M-20190408-19 Safety Injection Pump Room A 04/08/2019

Surveys

71124.02 Radiation CA-M-20190408-32 RB2026' General Area Routine 04/08/2019

Surveys

71124.02 Radiation CA-M-20190408-5 RB-2000-I G/A Five Days After CRUD Burst 04/08/2019

Surveys

71124.02 Radiation CA-M-20190410-26 Gross Cavity Decontamination 04/10/2019

Surveys

71124.02 Radiation CA-M-20190410-27 Rx Shield Plate Install Post Survey 04/10/2019

Surveys

71124.02 Radiation Work 16003707510 EMV0161 Radiography 0

Permits (RWPs)

71124.02 Radiation Work 18500671139 RF23 Scaffold to BGV0449 0

Permits (RWPs)

71124.02 Radiation Work R23HDDESTUD Detension Reactor Vessel Studs 0

Permits (RWPs)

71124.02 Radiation Work R23HDRESTUD Install Reactor Vessel Studs 0

Permits (RWPs)

71124.02 Radiation Work R23HDSTUD18 Remove Stuck Stud 18 0

Permits (RWPs)

71124.02 Radiation Work R23STD18DECON RF23 Cavity Decontamination 0

Permits (RWPs)

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.02 Self- 201820044-064 NRC Pre Inspection Self-Assessment: Rad Safety 06/14/2018

Assessments ALARA Planning and Occupational Dose Assessment

71124.02 Self- AP19001 Nuclear Oversight Audit of Radiation Protection 03/27/2019

Assessments

71124.05 Calculations HPCI-05-03 Evaluate Plant Radioactivity Mixture (Set Points) 2/22/2005

71124.05 Calculations HPCI-1403 Use of PM-12 for Passive Monitoring 12/11/2018

71124.05 Calibration 16503276-500 SD-RE-024 Reactor Coolant Sample Room 3/16/2018

Records

71124.05 Calibration 16513022-500 EG-RE-009 CCW HX A Inlet 5/7/2018

Records

71124.05 Calibration 17504995-500 SD-RE-038 Spent Fuel Pool Area Rad High 10/22/2018

Records

71124.05 Calibration 17506055-500 SD-RE-012 Aux Bldg. Corridor Basement Hi 6/11/2019

Records

71124.05 Calibration 17506056-500 SD-RE-015 Aux Bldg. Corridor Basement Hi 6/11/2019

Records

71124.05 Calibration 17508210-500 GT-RE-059 CTMT High Range (Electronics 1/17/2019

Records Calibration)

71124.05 Calibration 17510146-500 GT-RE-033 CTMT Purge 2/8/2019

Records

71124.05 Calibration 17512545-500 GT-RE-059 CTMT High Range (Isotopic Calibration) 4/10/2019

Records

71124.05 Calibration CAM-4019-HP Calibration Certificate (PING-1A) 6/28/2018

Records

71124.05 Calibration CAM-4020-HP Calibration Certificate (PING-1A) 2/27/2019

Records

71124.05 Calibration CAM-4045-HP Calibration Certificate (Eberline AMS-4) 12/10/2018

Records

71124.05 Calibration CRM-4023-HP Calibration Certificate (Ludlum Model 2000) 3/5/2019

Records

71124.05 Calibration CRM-4026-HP Calibration Certificate (Ludlum Model 2000) 8/21/2018

Records

71124.05 Calibration CRM-4089-HP Calibration Certificate (Ludlum Model 177) 1/26/2019

Records

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.05 Calibration CRM-4134-HP Calibration Certificate (Ludlum Model 177) 2/6/2019

Records

71124.05 Calibration GPC-4003-HP Instrument Calibration / Verification (Tennelec) 11/4/2007

Records

71124.05 Calibration GSS-4220-HP Instrument Calibration / Verification (Ortec - Detector 3/21/2019

Records 2)

71124.05 Calibration LAS-4198-HP Calibration Certificate (Radeco Model HD-29A) 1/28/2019

Records

71124.05 Calibration LSC-4004-HP Instrument Calibration / Verification (Perkin-Elmer) 4/25/2018

Records

71124.05 Calibration PCM-4054-HP Calibration Certificate (PCM-12) 8/28/2018

Records

71124.05 Calibration PM-4046-HP Calibration Certificate (PM-12) 8/28/2018

Records

71124.05 Calibration TM-4010-HP Calibration Certificate (SAM-12) 3/31/2019

Records

71124.05 Corrective Condition Reports 201703216, 201707720, 201800120, 201801122,

Action 201805869, 201805975, 201900857, 201901599,

Documents 201902538, 201903111

71124.05 Miscellaneous Area Radiation Monitor Calibration Data 6/11/2019

71124.05 Miscellaneous Calibration of Xradin Ion Chamber A3, A4, & A6 3/23/2018

71124.05 Procedures APA-ZZ-00014 Conduct of Operations - Radiation Protection 25

71124.05 Procedures HDP-ZZ-04000 Radiation Protection Instrumentation Program 29

71124.05 Procedures HDP-ZZ-04700 Count Room and Whole Body Counter Quality Control 22

Program

71124.05 Procedures HSP-ZZ-00014 Rad Monitor Non-Functionality 26

71124.05 Procedures HTP-SD-06033 Control of Area Radiation Monitor Alarm Setpoints 6

71124.05 Procedures HTP-ZZ-04101-DTI- Ludlum Model 177 Frisker Calibration 5

M177-Cal

71124.05 Procedures HTP-ZZ-04102-DTI- Eberline RO-2 Survey Meter Calibration 2

RO2-CAL

71124.05 Procedures HTP-ZZ-04150 Operations of the GA Process Monitor System 54

71124.05 Procedures HTP-ZZ-04167-DTI- Thermo RadEye Neutron Survey Meter Calibration 0

Thermo-Radeye

Inspection Type Designation Description or Title Revision or

Procedure Date

NL-Cal

71124.05 Procedures HTP-ZZ-04176-DTI- Thermo Fisher Model SAM-12 Small Articles Monitor 5

SAM12-Cal Calibration

71124.05 Procedures HTP-ZZ-04178-DTI- Rotem Telepole Survey Meter Calibration 10

Telepole-Cal

71124.05 Procedures HTP-ZZ-06020 Count Room Analytic and Quality Control Calculations 24

and Methods

71124.05 Procedures HTP-ZZ-07010 Alternate Method for Obtaining CHARMS Reading 8

71124.05 Procedures ISL-GT-00R59 CTMT High Range Area Rad Monitor Loop Calibration 22

71124.05 Procedures ITL-SD-00R00 Eberline Area Radiation Monitors 9

71124.05 Radiation CA-M-20190327-19 NS-1 Neutron Source - Quarterly Routine 3/27/2019

Surveys

71124.05 Self- 201807096- Instrument Program and Pre-NRC Inspection 3/28/2019

Assessments 010/201900029-

036

71124.05 Self- AP19001 Nuclear Oversight Audit of Radiation Protection 3/27/2019

Assessments

71124.06 Calculations RP09-2017- Batch Liquid Radioactive Release Permit 07/28/2017

L0028;1

71124.06 Calculations RP09-2018- Batch Liquid Radioactive Release Permit 02/01/2018

L0007;1

71124.06 Calculations RP09-2019- Batch Liquid Radioactive Release Permit 06/11/2019

L0037;0

71124.06 Calculations RP11A-2019- Batch Airborne Radioactive Release Permit 02/17/2019

G0013;1

71124.06 Calculations RP13-2017- Continuous Airborne Radioactive Release Permit 12/07/2017

G0006;52

71124.06 Calculations RP13-2018- Continuous Airborne Radioactive Release Permit 12/20/2018

G0002;56

71124.06 Calibration Job 12504965.500 RW Bldg Disch Line Process Rad Mon Loop Cal 08/21/2018

Records

71124.06 Calibration Job 17502388.500 Ctmt Bld Air Exg Plenum (Unit Vent) Rad Xmt 08/23/2018

Records

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.06 Corrective Condition Report 201703216, 201703232, 201703516, 201800052,

Action 201800125, 201801122, 201801301, 201802268,

Documents 201802267, 201802407, 201802547, 201803062,

201803391, 201805008, 201805070, 201805144,

201805978, 201805987, 201805989, 201806167,

201900239, 201900348, 201900353, 201900438

71124.06 Miscellaneous Callaway Energy Center 2017 Annual Radioactive

Effluent Release Report

71124.06 Miscellaneous Callaway Energy Center 2018 Draft Annual

Radioactive Effluent Release Report

71124.06 Miscellaneous Job 15510527 FGG02A In-Place Bypass Leakage Test 03/10/2017

71124.06 Miscellaneous Job 16509259 FGK02B In-Place Bypass Leakage Test 05/31/2018

71124.06 Miscellaneous Job 17503239 FGE01 In-Place Bypass Leakage Test 07/16/2018

71124.06 Procedures HSP-ZZ-00002 Radioactive Liquid Effluent Concentration 21

71124.06 Procedures HSP-ZZ-00003 Dose Assessments from Liquid Effluents 11

71124.06 Procedures HSP-ZZ-00004 Projected Dose from Liquid Waste 16

71124.06 Procedures HTP-ZZ-02006 Liquid Radwaste Release Permit (Batch) 93

71124.06 Procedures HTP-ZZ-02006 Liquid Radwaste Release Permit (Batch) 93

71124.06 Procedures HTP-ZZ-02007 Gaseous Radwaste Release Permit (Gas Decay 48

Tank)

71124.06 Procedures HTP-ZZ-02008 Gaseous Radwaste Release Permit (Auxiliary/Fuel 30

Building Ventilation)

71124.06 Procedures HTP-ZZ-02009 Gaseous Radwaste Release Permit (Radwaste 29

Building Ventilation)

71124.06 Procedures HTP-ZZ-03006 Use of Airborne Sampling Cart 32

71124.06 Procedures ISF-GH-0R10B RW Building Exhaust Discharge Radiation Detector 32

71124.06 Self- Nuclear Oversight Audit of Radiological and Non- 06/13/2018

Assessments Radiological Environmental Monitoring Programs, AP

18006

71124.06 Self- Nuclear Oversight Audit of Radiation Protection 03/27/2019

Assessments AP19001

71124.07 Calculations HPCI 1092 Evaluation of the 2018 Annual Land Use Census 1

71124.07 Calculations HPCI 18-01 Evaluation of the 2017 Annual Land Use Census 0

71124.07 Calculations HPCI-1503 Calculation of Long- Term Meteorological Dispersion 1

Inspection Type Designation Description or Title Revision or

Procedure Date

Parameters

71124.07 Calculations HPCI-1506 Evaluation of Air Sampler Locations with Respect to 1

the Recalculated Dispersion Parameters

71124.07 Calibration Job 18504263 RD01-Primary Meteorological Tower Loop A 10/24/2018

Records

71124.07 Calibration Job 18504272 RD01-Primary Meteorological Tower Loop B 10/25/2018

Records

71124.07 Calibration Job 18511186 RD01-Primary Meteorological Tower Loop A 03/29/2019

Records

71124.07 Calibration Job 18511189 RD01-Primary Meteorological Tower Loop B 03/25/2019

Records

71124.07 Calibration LAS-4179 Low volume Air Sampler Serial Number 10216 11/09/18

Records

71124.07 Calibration LAS-4182 Low Volume Air Sampler Serial Number 8977 07/20/2018

Records

71124.07 Calibration LAS-4201 Low Volume Air Sampler Serial Number 8975 01/31/2019

Records

71124.07 Corrective Condition Reports 201700071, 201700835, 201701864, 201702166,

Action 201702981, 201703331, 201703581, 201705266,

Documents 201705398, 201705399, 201705403, 201705417,

201706786, 201706793, 201706794, 201801634,

201801736, 201801950, 201802361, 201803357,

201900612, 201900937, 201901217, 201902100

71124.07 Corrective Condition Reports 201904252

Action

Documents

Resulting from

Inspection

71124.07 Miscellaneous Environmental Dosimetry Company - Annual Quality 03/07/2018

Assurance Status Report: January - December 2017

71124.07 Miscellaneous Environmental Dosimetry Company - Annual Quality 03/12/2019

Assurance Status Report: January - December 2018

71124.07 Miscellaneous AP18006 Nuclear Oversight Audit of Radiological and Non 06/13/2018

Radiological Environmental Monitoring Programs

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.07 Miscellaneous AP19001 Nuclear Oversight Audit of Radiation Protection 03/27/2019

71124.07 Miscellaneous APA-ZZ-01003 Off-Site Dose Calculation Manual 23

71124.07 Miscellaneous AREOR Annual Radiological Environmental Operating Report:

January 1- December 31, 2017

71124.07 Miscellaneous AREOR Annual Radiological Environmental Operating Report:

January 1- December 31, 2018

71124.07 Miscellaneous NAQA-17-0038 Audit Report 17-007 for the Audit of Environmental 09/01/2017

Dosimetry Company

71124.07 Procedures HDP-ZZ-07000 Radiological Environmental Monitoring Program and 9

Groundwater Protection Initiative

71124.07 Procedures HTP-ZZ-04123-DTI- F&J DF-1T Low Volume Air Sampler Calibration 8

F&J-DF1T-CAL

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

Crop-Sampling Samples

71124.07 Procedures HTP-ZZ-07001-DTI- Collection and Shipping of Environmental Water 11

Water-Sampling Samples

71124.07 Procedures HTP-ZZ-07101-DTI- REMP Sample Locations and Analysis Schedule 32

REMP-SMPL-

SCHED

71124.07 Procedures HTP-ZZ-07103-RP- Evaluation and Reporting of REMP Data 2

DTI-REMP-

DATAEVAL

71124.07 Procedures ISL-RD-RD01A Meteorological Monitoring Instruments - Elevator A 15

Loop Calibration

71124.07 Procedures ISL-RD-RD01B Meteorological Monitoring Instruments - Elevator B 10

Loop Calibration

71124.07 Procedures RP-DTI-ENVIRON- Environmental TLD Locations 5

TLD LOCATIONS

71124.07 Procedures RP-DTI- Response to Spills or Leaks of Radioactive Material 10

ENVIRONMENTAL- into Groundwater

SPILLRESP

71124.08 Corrective Condition Report 201701008, 201702081, 201704005, 201706627,

Action 201804430, 201804447, 201806969, 201900861,

Documents 201900930, 201901038, 201902796, 201904190

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.08 Miscellaneous Callaway Final Safety Analysis Report (FSAR) - 06/01/2018

Chapter 11.4

71124.08 Miscellaneous 2018 RAM and Radwaste Shipping Log 2018

71124.08 Miscellaneous Callaway Energy Center 2018 Annual Radioactive 2018

Effluent Release Report

71124.08 Miscellaneous Callaway Energy Center 2017 Annual Radioactive 2017

Effluent Release Report

71124.08 Miscellaneous 2017 RAM and Radwaste Shipping Log 2017

71124.08 Procedures APA-ZZ-01011 Process Control Program 14

71124.08 Procedures HTP-HC-09002 10 CFR 61 Sampling Program 4

71124.08 Procedures HTP-ZZ-02005 Handling of Radioactive Material 49

71124.08 Procedures HTP-ZZ-09003 Shipment of Radioactive Wastes 6

71124.08 Procedures RDP-ZZ-00200 Radwaste Operational Guidelines 21

71124.08 Procedures RTN-HC-01900 On-Site Storage Container Handling Procedure 6

71124.08 Procedures RTS-HC-00310 Primary Resin Sluice To Bulk Waste Disposal Station 47

71124.08 Procedures RTS-HC-00350 Primary Spent Resin Storage Tank Transfer To Bulk 14

Waste Disposal Station

71124.08 Procedures RTS-ZZ-CH040 Handling of Transport Cask Model 14-215H 12

71124.08 Procedures RTS-ZZ-CH050 Handling Procedure for CNS 8-120A Transport Cask 5

71124.08 Radiation CA-M-20190409-24 RWY-4 & RWY-3 Radwaste Yard Plant (North & 04/09/2019

Surveys South)

71124.08 Radiation CA-M-20190415-05 7228 Drywaste Compactor Area - Quarterly Routine 04/14/2019

Surveys

71124.08 Radiation CA-M-20190421-24 7225 Quarterly Routine Survey - Low Level Drum 04/21/2019

Surveys Storage Area

71124.08 Radiation CA-M-20190524-02 RSS-1 Characterization - Resin Liner #PO661751-16 05/24/2019

Surveys

71124.08 Self- EPRI Solid Radioactive Waste Program Assessment 07/14/2017

Assessments at Ameren Callaway Nuclear Power Plant

71124.08 Self- 201900029-035 Simple Self-Assessment: Shipping Program 05/02/2019

Assessments

71124.08 Self- AP19001 Ameren Nuclear Oversight Audit of Radiation 03/27/2019

Assessments Protection

71124.08 Shipping 17-010 UN3321, RAM, LSA-11, Class 7 (Drummed 06/22/2017

Inspection Type Designation Description or Title Revision or

Procedure Date

Records Mechanical Filters)

71124.08 Shipping 17-012 UN3321, RAM, LSA-II, Class 7 (Dewatered Resin) 07/12/2017

Records

71124.08 Shipping 17-061 UN2912, RAM, LSA-I, Class 7 (Dry Active Waste 11/17/2017

Records Cycle 21)

71124.08 Shipping 18-001 UN3321, RAM, LSA-II, Class 7 (Dewatered Resin and 01/12/2018

Records Charcoal)

71124.08 Shipping 18-010 UN2911, RAM, Excepted Package, Class 7 04/12/2018

Records (Instruments)

71124.08 Shipping 18-018 UN2911, RAM, Excepted Package, Class 7 09/20/2018

Records (Instruments)

71124.08 Shipping 18-036 UN2912, RAM, LSA-I, Class 7 (Dry Active Waste) 12/26/2018

Records

71124.08 Shipping 19-005 UN3321, RAM, LSA-II, Class 7 (Resin and Charcoal) 03/19/2019

Records

71124.08 Shipping 19-021 UN2912, RAM, LSA-I, Class 7 (Resin) 06/11/2019

Records

71153 Corrective Condition Reports 201901943, 201903787, 201903832

Action

Documents

The following items are requested for the

Occupational Radiation Safety Inspection

at Callaway

Dates of Inspection: 04/08/2019 to 04/12/2019

Integrated Report 2019002

Inspection areas are listed in the attachments below.

Please provide the requested information on or before Monday, March 25, 2019.

Please submit this information using the same lettering system as below. For example, all

contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled

1-A, applicable organization charts in file/folder 1-B, etc.

The information should be provided in electronic format or a secure document management

service. If information is placed on ims.certrec.com, please ensure the inspection exit date

entered is at least 30 days later than the onsite inspection dates, so the inspectors will have

access to the information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed

below, please provide updated lists of corrective action documents at the entrance meeting.

The dates for these lists should range from the end dates of the original lists to the day of the

entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear

to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which

file the information can be found.

If you have any questions or comments, please contact Natasha Greene at 817-200-1154 or via

e-mail at Natasha.Greene@nrc.gov.

PAPERWORK REDUCTION ACT STATEMENT

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.

1. Radiological Hazard Assessment and Exposure Controls (71124.01) and

Performance Indicator Verification (71151)

Date of Last Inspection: November 5, 2018

A. List of contacts and telephone numbers for the Radiation Protection Organization Staff

and Technicians, as well as the Licensing/Regulatory Affairs staff. Please include area

code and prefix. If work cell numbers are appropriate, then please include them as well.

B. Applicable organization charts including position or job titles. Please include as

appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),

Engineering, and Emergency Protection. (Recent pictures are appreciated.)

C. Copies of audits, self-assessments, LARs, and LERs written since the last inspection

date, related to this inspection area

D. Procedure indexes for the radiation protection procedures and other related disciplines.

E. Please provide procedures related to the following areas noted below. Additional

procedures may be requested by number after the inspector reviews the procedure

indexes.

1. Radiation Protection Program

2. Radiation Protection Conduct of Operations, if not included in #1.

3. Personnel Dosimetry

4. Posting of Radiological Areas

5. High Radiation Area Controls

6. RCA Access Controls and Radiation Worker Instructions

7. Conduct of Radiological Surveys

8. Radioactive Source Inventory and Control

9. Fuel Pool Inventory Access and Control

F. Please provide a list of NRC Regulatory Guides and NUREGs that you are currently

committed to relative to this program. Please include the revision and/or date for the

commitment and where this may be located in your current licensing basis documents.

G. Please provide a summary list of corrective action documents (including corporate and

sub-tiered systems) since the last inspection date.

1. Initiated by the radiation protection organization

2. Assigned to the radiation protection organization

NOTE: These lists should include a description of the condition that provides sufficient

detail that the inspectors can ascertain the regulatory impact, the significance

level assigned to the condition, the status of the action (e.g., open, working,

closed, etc.) and the search criteria used. Please provide in document formats

which are sortable and searchable so that inspectors can quickly and

efficiently determine appropriate sampling and perform word searches, as

needed. (Excel spreadsheets are the preferred format.) If codes are used,

please provide a legend for each column where a code is used.

H. List of radiologically significant work activities scheduled to be conducted during the

inspection period. (If the inspection is scheduled during an outage, please also include a

list of work activities greater than 1 rem, scheduled during the outage with the dose

estimate for the work activity.) Please include the radiological risk assigned to each

activity.

I. Provide a summary of any changes to plant operation that have resulted or could result

in a significant new radiological hazard. For each change, please provide the

assessment conducted on the potential impact and any monitoring done to evaluate it.

J. List of active radiation work permits and those specifically planned for the on-site

inspection week.

K. Please provide a list of air samples taken to verify engineering controls and a separate

list for breathing air samples in airborne radiation areas or high contamination work

areas. Please include the RWP the breathing air sampling supports.

L. Please provide the current radioactive source inventory, listing all radioactive sources

that are required to be leak tested. Indicate which sources are deemed 10 CFR Part 20,

Appendix E, Category 1 or Category 2. Please indicate the radioisotope, initial and

current activity (w/assay date), and storage location for each applicable source.

M. The last two leak test results for all required/applicable radioactive sources that have

failed its leak test within the last two years. Provide any applicable condition reports.

N. A list of all non-fuel items stored in the spent fuel pools, and if available, their appropriate

dose rates (Contact / @ 30cm)

O. A list of radiological controlled area entries greater than 100 millirem, since the last

inspection date. The list should include the date of entry, some form of worker

identification, the radiation work permit used by the worker, dose accrued by the worker,

and the electronic dosimeter dose alarm set-point used during the entry (for

Occupational Radiation Safety Performance Indicator verification in accordance with IP 71151).

P. A list describing VHRAs and TS HRAs (> 1 rem/hour) that are current and historical.

Include their current status, locations, and control measures.

Q. Temporary effluent monitor locations and calibrations (AMS-4) used to monitor normally

closed doors or off-normal release points (e.g., equipment hatch or turbine heater bay

doors). Include any CRs associated with this monitoring or instrumentation.

2. Occupational ALARA Planning and Controls (71124.02)

Date of Last Inspection: May 21, 2018

A. List of contacts and telephone numbers for ALARA program personnel, as well as the

Licensing/Regulatory Affairs staff. Please include area code and prefix. If work cell

numbers are appropriate, then please include them as well.

B. Applicable organization charts including position or job titles. Please include as

appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),

Engineering, and Emergency Protection. (Recent pictures are appreciated.)

C. Copies of audits, self-assessments, LARs, and LERs, written since the date of last

inspection, focusing on ALARA

D. Procedure index for ALARA Program procedures and other related disciplines.

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures may be requested by number after the inspector reviews

the procedure indexes.

1. ALARA Program

2. ALARA Planning

3. ALARA Reviews

4. ALARA Committee

5. Radiation Work Permit Preparation

F. Please provide a list of NRC Regulatory Guides and NUREGs that you are currently

committed to relative to this program. Please include the revision and/or date for the

commitment and where this may be located in your current licensing basis documents.

G. Please provide a summary list of corrective action documents (including corporate and

sub-tiered systems) written since the date of last inspection, related to the ALARA

program, including exceeding RWP Dose Estimates.

NOTE: These lists should include a description of the condition that provides sufficient

detail that the inspectors can ascertain the regulatory impact, the significance

level assigned to the condition, the status of the action (e.g., open, working,

closed, etc.) and the search criteria used. Please provide in document formats

which are sortable and searchable so that inspectors can quickly and

efficiently determine appropriate sampling and perform word searches, as

needed. (Excel spreadsheets are the preferred format.) If codes are used,

please provide a legend for each column where a code is used.

H. List of work activities (RWPs) greater than 1 rem, since date of last inspection,

including the original dose estimates and actual doses accrued. (Excel format

preferred). Please provide all revisions/changes, as well as any related RWPs that

support the work activity.

I. List of active work activities (RWPs) that will be in use while we are onsite, including the

dose and dose rate settings, and if available, the planned dose. Include planning

documents and surveys. Include radiological risk assessments and proposed control

measures.

J. Site dose totals for the past 3 years (based on dose of record). Also provide the current

year-to-date (YTD) collective radiation exposure (CRE). In addition, please provide

another document that separates the online and outage doses for the past 3 years.

K. Most recent assessment of your isotopic mix, including the hard-to-detect radionuclides

and alpha hazards. Include a list of new and historical exposure issues (radiological

source term or high exposure areas/activities).

L. If available, provide a copy of the lessons learned from the most recently completed

outage for each unit. Include a summary list of any associated corrective action

documents and the current status of any corrective actions assigned.

M. Please provide the methods/reports that are in your process to meet the requirements of

CFR 20.1101(c) for periodic review of your RP program.

N. Current exposure trends (BRAC dose rates and/or source term information).

The following items are requested for the

Public Radiation Safety Inspection

at Callaway

Dates of Inspection: 06/10/2019 to 06/14/2019

Integrated Report 2019002

Inspection areas are listed in the attachments below.

Please provide the requested information on or before Friday, May 24, 2019.

Please submit this information using the same lettering system as below. For example, all

contacts and phone numbers for Inspection Procedure 71124.05 should be in a file/folder titled

5-A, applicable organization charts in file/folder 5-B, etc.

The information should be provided in electronic format or a secure document management

service. If information is placed on a secured document management system, please ensure

the inspection exit date entered is at least 30 days later than the onsite inspection dates, so the

inspectors will have access to the information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed

below, please provide updated lists of corrective action documents at the entrance meeting.

The dates for these lists should range from the end dates of the original lists to the day of the

entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear

to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which

file the information can be found.

If you have any questions or comments, please contact Natasha Greene at 817-200-1154 or via

e-mail at Natasha.Greene@nrc.gov.

PAPERWORK REDUCTION ACT STATEMENT

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.

5. Radiation Monitoring Instrumentation (71124.05)

Date of Last Inspection: February 27, 2017

A. List of contacts and telephone numbers for the following areas below. Please include

area code and prefix. If work cell numbers are appropriate, then please include them as

well.

1. Process monitor calibration (Include Chemistry, Systems Engineering and I&C, as

applicable)

2. Radiation protection instrument calibration (Portable and Stationary)

3. Installed instrument calibrations (Include Systems Engineering and I&C)

4. Count room and Laboratory instrument calibrations (Include RP and Chemistry, as

applicable)

5. EP contacts for Equipment Important to Emergency Response/Preparedness

(EITER)

6. Licensing/Regulatory Affairs

B. Applicable organization charts, including position or job titles. Please include as

appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),

Engineering, and Emergency Protection. (Recent pictures are appreciated.)

C. Copies of audits, self-assessments, vendor or NUPIC audits for contractor support,

LARs, and LERs, performed since the date of the last inspection, related to:

1. Portable Radiation instruments: Area radiation monitors, portable continuous air

monitors (AMS3/4), portable survey instruments (count rate, dose rate, occupational

air sampling), electronic dosimeters, teledosimetry

2. Stationary Radiation Instruments: Portal monitors, small article monitors, personnel

contamination monitors, or whole body counters

3. Installed Radiation Instruments: Area radiation monitors (RMS), process monitors

(non-effluent), criticality monitors, accident monitors

4. Count Room instrumentation (Chemistry and RP, if separate RP Ops and Effluents):

Gamma Spec, LSC, Gross Alpha, Gross Beta, including bench-top counters

D. Procedure indexes for radiation protection procedures and other related disciplines.

1. Calibration, use, and operation of continuous air monitors, portable survey

instruments, temporary area radiation monitors, electronic dosimeters, teledosimetry

2. Calibration use and operation of portal monitors, small article monitors, personnel

contamination monitors, and whole body counters

3. Calibration of installed area radiation monitors, process monitors, criticality monitors,

and accident monitors

4. Calibration use and operation of Count Room instrumentation (GS, LSC, GA, GB)

(include bench top counters here)

NOTE: Please ensure that RP, Chemistry, and I&C procedures are included, as

appropriate.

E. Please provide specific procedures related to the following areas noted below.

Additional procedures may be requested by number after the inspector reviews the

procedure index.

1. Calibration of portable ion chambers

2. Calibration of Friskers

3. Calibration of telescoping high range instruments

4. Calibration of portable neutron instruments

5. Calibration of SAMs

6. Whole body counter calibration

7. Laboratory instrumentation quality control

8. Calibration of Containment/Drywell high range radiation monitor

F. Please provide a list of NRC Regulatory Guides and NUREGs that you are currently

committed to relative to this program. Please include the revision and/or date for the

commitment and where this may be located in your current licensing basis documents.

G. Please provide a summary list of corrective action documents (including corporate and

sub-tiered systems) written since the date of the last inspection, related to the following

programs:

1. Area radiation monitors, continuous air monitors, portable survey instruments,

electronic dosimeters, and teledosimetry

2. Portal monitors, small article monitors, personnel contamination monitors, and whole

body counters

3. Installed radiation monitors, criticality monitors, accident range monitors

4. Count room radiation instruments

NOTE: These lists should include a description of the condition that provides

sufficient detail that the inspectors can ascertain the regulatory impact, the

significance level assigned to the condition, the status of the action (e.g., open,

working, closed, etc.) and the search criteria used. Please provide in document

formats which are sortable and searchable so that inspectors can quickly and

efficiently determine appropriate sampling and perform word searches, as

needed. (Excel spreadsheets are the preferred format.) If codes are used,

please provide a legend for each column where a code is used.

H. State the required calibration frequency and provide the most recent calibration data for

the whole body counters, at least one portable survey instrument, one area radiation

monitor, one air sampler, one continuous air monitor, and one drywell/containment high-

range monitor.

I. Provide a list of any scheduled calibrations, while we are onsite, for the instrumentation

noted in request above, in 5-I.

J. Provide the alarm set point values for the portal and personnel contamination monitors in

operation.

K. Radiation Monitoring System health report for the previous 12 months

L. Provide the following lists of instruments to include make, model, identifier (S/N or plant

ID), and location:

1. Portable radiation instruments currently in use (for EADs just make, model, and

quantity).

2. Stationary radiation instruments currently in use.

3. Installed Radiation monitors

a. Area radiation monitors and

b. Process radiation monitors.

(Include their instrumentation designator, function and calibration procedure

number and title.) Please indicate which, if any, detectors have been

replaced within the past 2 years (since the last inspection).

c. Radiation instrumentation abandoned in place.

d. Radiation instrumentation covered by the maintenance rule.

M. Provide a list of sources used routinely for source check of portable, stationary, and

installed radiation monitoring instruments.

N. Provide the NIST traceability and calibration or verification of the primary sources for

instrument calibration and the procedures used to achieve this.

6. Radioactive Gaseous and Liquid Effluent Treatment (71124.06)

Date of Last Inspection: February 27, 2017

A. List of contacts and telephone numbers for the following areas. Please include area

code and prefix. If work cell numbers are appropriate, then please include them as well.

1. Radiological effluent control (liquid & gaseous) and reporting

(RP, Chemistry, RW, Ops, etc.)

2. Effluent Monitor calibration (liquid and gaseous) and maintenance

(RP, Chemistry, I&C, Maintenance, Systems Engineering, EP, etc.)

3. Engineered safety feature air cleaning systems for effluent release

(Systems Engineering, I&C, Maintenance, etc.)

4. Licensing/Regulatory Affairs

B. Applicable organization charts including position or job titles for the above individuals

and also for their supportive Management. Please include as appropriate for your site,

Site Management, RP, Chemistry, Maintenance (I&C), Engineering, and Emergency

Protection. (Recent pictures are appreciated.)

C. Copies of audits, self-assessments, vendor or NUPIC audits of contractor support, and

LERs written since the date of the last inspection, related to:

1. Radioactive effluents and effluent radiation monitors

2. Engineered Safety Feature Air cleaning systems

D. Procedure indexes for the following areas and related disciplines.

1. Radioactive effluents and effluent radiation monitors (to include the flow monitors)

2. Engineered Safety Feature Air cleaning systems (both TS and non-TS systems for

effluents)

E. Please provide specific procedures related to the following areas noted below.

Additional procedures may be requested by number after the inspector reviews the

procedure indexes.

1. Sampling and analysis of radioactive effluents

2. Effluent monitor setpoint determination

3. Generating radioactive effluent release permits

4. Effluent Monitor Calibrations (Include associated flow monitors)

5. Laboratory instrumentation quality control

6. In-place testing of HEPA filters and charcoal adsorbers for TS effluent exhaust

systems and other effluent air-cleaning systems, but not breathing air systems

F. Please provide a list of NRC Regulatory Guides and NUREGs that you are currently

committed to relative to this program. Please include the revision and/or date for the

commitment and where this may be located in your current licensing basis documents.

G. Please provide a summary list of corrective action documents (including corporate and

sub-tiered systems) written since the date of the last inspection, associated with:

1. Radioactive effluents

2. Effluent radiation monitors (include associated effluent flow monitors)

3. Engineered Safety Feature Air cleaning systems (effluents, not breathing air)

NOTE: These lists should include a description of the condition that provides

sufficient detail that the inspectors can ascertain the regulatory impact, the

significance level assigned to the condition, the status of the action (e.g., open,

working, closed, etc.) and the search criteria used. Please provide in document

formats which are sortable and searchable so that inspectors can quickly and

efficiently determine appropriate sampling and perform word searches, as

needed. (Excel spreadsheets are the preferred format.) If codes are used,

please provide a legend for each column where a code is used.

H. Annual Radioactive Effluent Release Reports for the latest two calendar years

I. Current revision of the Offsite Dose Calculation Manual (or other name, but include all

parts for effluents) and any changes made since the last inspection.

J. The inter-laboratory comparison results for laboratory quality control performance of

effluent sample analysis for the latest two calendar years

K. Effluent sampling schedule for the week of the inspection

L. Provide the last three annual trends of vent/stack effluent flow rates, by chart or table.

M. Operations department (or other responsible dept.) log records for effluent monitors

removed from service or out of service or a list of the same and compensatory actions

taken during the out of service condition.

N. Listing or log of liquid and gaseous release permits since the date of the last inspection

O. A list of the technical specification-required air cleaning systems with the two most

recent surveillance test dates of in-place filter testing (of HEPA filters and charcoal

adsorbers) and laboratory testing (of charcoal efficiency) and the work order numbers

associated with the surveillances (and their system number/name).

P. System Health Report for radiation monitoring instrumentation. Also, please provide a

specific list of all effluent radiation monitors that were considered inoperable for 7 days

or more since the date of the last inspection. If applicable, please provide the relative

Special Report and condition report(s). If not covered by maintenance rule, please

provide rationale.

Q. A list of significant changes made to the gaseous and liquid effluent process monitoring

system since the date of the last inspection. If applicable, please provide the

corresponding UFSAR section in which this change was documented.

R. A list of any occurrence in which a non-radioactive system was contaminated by a

radioactive system since the date of the last inspection. Please include any relevant

condition report(s).

S. Current Part 61 analyses for hard to detect radionuclides

T. Latest Land Use Census (coordinate with 71124.07)

U. Effluent based procedures for EALs or EOPs.

7. Radiological Environmental Monitoring Program (71124.07)

Date of Last Inspection: February 27, 2017

A. List of contacts and telephone numbers for the following areas. Please include area

code and prefix. If work cell numbers are appropriate, then please include them as well.

1. Radiological environmental monitoring (RP, Chemistry, I&C, etc.)

2. Meteorological monitoring (RP, Chemistry, EP, I&C, System Engineering, etc.)

3. Maintenance and calibration of the above equipment

4. Licensing/Regulatory Affairs

B. Applicable organization charts including position or job titles. Please include as

appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),

Engineering, and Emergency Protection. (Recent pictures are appreciated.)

C. Copies of audits, self-assessments, vendor or NUPIC audits of contractor support, and

LERs written since the date of the last inspection, related to:

1. Radiological environmental monitoring program (including contractor environmental

laboratory audits, if used to perform environmental program functions)

2. Environmental TLD processing facility

3. Meteorological monitoring program

D. Procedure index for the following areas and other related disciplines.

1. Radiological environmental monitoring program

2. Meteorological monitoring program

3. Maintenance and calibration of related instrumentation, including the meteorological

tower

E. Please provide specific procedures related to the following areas noted below.

Additional procedures may be requested by number after the inspector reviews the

procedure indexes.

1. Sampling, collection and preparation of environmental samples

2. Sample analysis (if performed onsite)

3. Laboratory instrumentation quality control

4. Meteorological Tower sensor calibrations

F. Please provide a list of NRC Regulatory Guides and NUREGs that you are currently

committed to relative to this program. Please include the revision and/or date for the

commitment and where this may be located in your current licensing basis documents.

G. Please provide a summary list of corrective action documents (including corporate and

sub-tiered systems) written since the date of the last inspection, related to the following

programs:

1. Radiological environmental monitoring (include TLDs and air sample pumps or their

infrastructure)

2. Meteorological monitoring (include Met Tower sensors and support equipment)

These lists should include a description of the condition that provides sufficient

detail that the inspectors can ascertain the regulatory impact, the significance

level assigned to the condition, the status of the action (e.g., open, working,

closed, etc.) and the search criteria used. Please provide in document formats

which are sortable and searchable so that inspectors can quickly and

efficiently determine appropriate sampling and perform word searches, as

needed. (Excel spreadsheets are the preferred format.) If codes are used,

please provide a legend for each column where a code is used.

H. Copies of the two most recent calibration packages for the meteorological tower

instruments

I. Copies of the Annual Radiological Environmental Operating Reports and Land Use

Census for the latest two calendar years, and current revision of the Offsite Dose

Calculation Manual. Please include any supportive documentation for the changes

made to the ODCM since the last inspection.

J. Copy of the environmental laboratorys inter-laboratory comparison program results for

the latest two calendar years, if not included in the Annual Radiological Environmental

Operating Report

K. Data from the environmental laboratory documenting the analytical detection sensitivities

for the various environmental sample media (i.e., air, water, soil, vegetation, and milk)

L. Quality Assurance audits (e.g., NUPIC) for contracted services

M. Current NEI Groundwater Protection Initiative (GPI) Plan and status. Provide the most

recent monitoring results for each monitoring well per the GPI. Provide a separate list of

any missed samples, as applicable.

N. Technical requirements manual or licensee controlled specifications which list the

meteorological instruments calibration requirements

O. If applicable, per NEI 07-07, provide any reports that document any spills/leaks to

groundwater since the date of the last inspection. Please indicate what external

communications were made regarding each spill/leak.

P. Provide any new entries into 10 CFR 50.75(g) files since the date of the last inspection.

Q. Please identify your three highest X/Q (chi/Q) and/or D/Q sectors, as currently used in

the selection of your required REMP sampling locations. If these are different values

from your most recent meteorological assessment, please provide that assessment and

indicate the three highest X/Q and/or D/Q sectors per your latest assessment. Also

indicate your noted predominant and least prevalent wind direction/sector, as used in

your REMP analysis.

R. Provide the height of the highest effluent release point. Please indicate if the height

accounts for plant grade elevation. Please also provide the most probable atmospheric

release height, if different from the highest effluent release point.

S. Please provide a schedule of any planned REMP sampling activities while we, the NRC,

are scheduled to be onsite performing this inspection.

8. Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage,

and Transportation (71124.08)

Date of Last Inspection: February 27, 2017

A. List of contacts and telephone numbers for the following areas. Please include area

code and prefix. If work cell numbers are appropriate, then please include them as well.

1. Solid Radioactive waste processing (RP, Chemistry, Ops, Maintenance, I&C,

Engineering, etc.)

2. Transportation of radioactive material/waste (RP, Maintenance, Ops, Security,

Chemistry, etc.)

3. personnel involved in solid radwaste processing, transferring, and transportation of

radioactive waste/materials)

4. Licensing/Regulatory Affairs

B. Applicable organization charts including position or job titles. Please include as

appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),

Engineering, and Emergency Protection. (Recent pictures are appreciated.)

C. Copies of audits, department self-assessments, and LERs written since the date of the

last inspection, related to:

1. Solid radioactive waste management

2. Radioactive material/waste transportation program

D. Procedure index for the following areas and other related disciplines.

1. Solid radioactive waste management

2. Radioactive material/waste transportation

E. Please provide specific procedures related to the following areas noted below.

Additional procedures may be requested by number after the inspector reviews the

procedure indexes.

1. Process control program and any changes made since the last inspection

2. Solid and liquid radioactive waste processing

3. Waste stream sampling and analysis

4. Waste characterization and classification

5. Radioactive material/waste packaging & shipping

F. Please provide a list of NRC Regulatory Guides and NUREGs that you are currently

committed to relative to this program. Please include the revision and/or date for the

commitment and where this may be located in your current licensing basis documents.

G. Please provide a summary list of corrective action documents (including corporate and

sub-tiered systems) written since the date of the last inspection, related to:

1. Solid radioactive waste

2. Transportation of radioactive material/waste

NOTE: These lists should include a description of the condition that provides

sufficient detail that the inspectors can ascertain the regulatory impact, the

significance level assigned to the condition, the status of the action (e.g., open,

working, closed, etc.) and the search criteria used. Please provide in document

formats which are sortable and searchable so that inspectors can quickly and

efficiently determine appropriate sampling and perform word searches, as

needed. (Excel spreadsheets are the preferred format.) If codes are used,

please provide a legend for each column where a code is used.

H. Copies of training lesson plans for 49 CFR 172, Subpart H, for radwaste processing,

packaging, and shipping

I. Provide a summary list or log of radioactive material and radioactive waste shipments for

the two most recent calendar years, in addition to the current calendar year.

J. Please provide at least two different radioactive waste stream sample analysis results

and resulting scaling factors for the latest two calendar years.

K. A listing of all onsite radwaste storage facilities. Please include a summary or list of the

items stored in each facility with the most recent dose rates/surveys.

L. A list of any significant (e.g., DAW, resins, Type B or greater) radioactive shipments that

will be completed during our onsite inspection period. If available, please provide the

applicable shipping manifests/waste characterizations and most recent surveys for each

shipment.

M. A list of significant changes made to the liquid or solid radwaste processing systems

since the date of the last inspection. If applicable, please provide the corresponding

UFSAR section in which this change was documented. Provide any supportive

documentation for the changes made or have it readily available for review.

N. List of radioactive waste processing systems or equipment abandoned in place since the

last inspection.

O. Please provide a schedule of radioactive material or waste processing or shipment

activities during the inspection week. Please indicate the current storage location of the

stored RAM or waste prepared for shipment, as well as any supportive surveys of its

measured dose rates. If available, please indicate its current stated waste class.

A3-10