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=Text=
=Text=
{{#Wiki_filter:October 3, 2017
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION


==SUBJECT:==
==REGION IV==
CALLAWAY PLANT  
1600 E. LAMAR BLVD.
- INSPECTION OF THE IMPLEMENTATION OF MITIGATION STRATEGIES AND SPENT FUEL POOL INSTRUMENTATION ORDERS AND EMERGENCY PREPAREDNESS COMMUNICATION/ STAFFING/MULTI-UNIT DOSE ASSESSMENT PLANS  
 
- INSPECTION REPORT 05000483/2017008
ARLINGTON, TX 76011-4511 October 3, 2017 Mr. Fadi Diya, Senior Vice President and Chief Nuclear Officer Ameren Missouri Callaway Plant P.O. Box 620 Fulton, MO 65251 SUBJECT: CALLAWAY PLANT - INSPECTION OF THE IMPLEMENTATION OF MITIGATION STRATEGIES AND SPENT FUEL POOL INSTRUMENTATION ORDERS AND EMERGENCY PREPAREDNESS COMMUNICATION/
STAFFING/MULTI-UNIT DOSE ASSESSMENT PLANS - INSPECTION REPORT 05000483/2017008


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


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


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


In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).


Sincerely,
Sincerely,
/RA David Proulx Acting for/
/RA David Proulx Acting for/
Nicholas H. Taylor
Nicholas H. Taylor, Chief Project Branch B Division of Reactor Projects Docket No. 50-483 License No. NPF-30
, Chief Project Branch B Division of Reactor Projects Docket No. 50-483 License No. NPF-30  


===Enclosure:===
===Enclosure:===
Inspection Report 05000 483/20170 08 w/ Attachment: Supplemental Information
Inspection Report 05000483/2017008 w/ Attachment: Supplemental Information


REGION IV Docket: 050004 83 License: NPF-30 Report: 05000483/2017008 Licensee: Union Electric Company Facility: Callaway Plant Location: Junction Highway CC and Highway O Steedman, Missouri Dates: August 28  
REGION IV==
- September 26, 2017 Inspectors:
Docket: 05000483 License: NPF-30 Report: 05000483/2017008 Licensee: Union Electric Company Facility: Callaway Plant Location: Junction Highway CC and Highway O Steedman, Missouri Dates: August 28 - September 26, 2017 Inspectors: R. Alexander, Sr. Project Engineer (Team Leader)
R. Alexander, Sr. Project Engineer (Team Leader)
S. Alferink, Reactor Inspector D. Bradley, Sr. Resident Inspector - Callaway M. Stafford, Project Engineer Approved Nicholas H. Taylor By: Chief, Project Branch B Division of Reactor Projects
S. Alferink, Reactor Inspector D. Bradley, Sr. Resident Inspector  
- Callaway M. Stafford, Project Engineer Approved By: Nicholas H. Taylor Chief, Project Branch B Division of Reactor Projects


2
Enclosure


=SUMMARY=
=SUMMARY=
IR 05000483/2017008
IR 05000483/2017008; 08/28/2017 - 09/26/2017; Callaway Plant;


; 08/28/2017 - 09/26/2017; Callaway Plant
Temporary Instruction 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, issued December 23, 2015.
;  Temporary Instruction 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans
, issued December 23, 2015.


The inspection covered a one-week inspection by the resident inspector and three inspectors from the Region IV office. No findings were identified. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG
The inspection covered a one-week inspection by the resident inspector and three inspectors from the Region IV office. No findings were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.
-1649, "Reactor Oversight Process," Revision 5.


===A. NRC-Identified and Self-Revealing Findings===
===NRC-Identified and Self-Revealing Findings===


None
None


===B. Licensee-Identified Violations===
===Licensee-Identified Violations===


None 3
None


=REPORT DETAILS=
=REPORT DETAILS=


4. Other Activities
===4. Other Activities===


{{a|4OA5}}
{{a|4OA5}}
==4OA5 Other Activities==
==4OA5 Other Activities (TI 2515/191)==


(TI 2515/191)
The objective of Temporary Instruction (TI) 2515/191 Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, is to verify that licensees have adequately implemented the mitigation strategies as described in the licensees Final Integrated Plan (ADAMS Accession No. ML16189A304) and the NRCs plant safety evaluation (ADAMS Accession No. ML17010A332) and to verify that the licensees installed reliable water level measurement instrumentation in their spent fuel pools. The purpose of this TI is also to verify the licensees have implemented Emergency Preparedness (EP) enhancements as described in their site-specific submittals and NRC safety assessments, including multi-unit dose assessment capability and enhancements to ensure that staffing is sufficient and communications can be maintained during such an event.
The objective of Temporary Instruction (TI) 2515/191 "Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi
-Unit Dose Assessment Plans
," is to verify that licensees have adequately implemented the mitigation strategies as described in the licensee's Final Integrated Plan (ADAMS Accession No
. ML16189A304
) and the NRC's plant safety evaluation (ADAMS Accession No. ML17010A332) and to verify that the licensees installed reliable water level measurement instrumentation in their spent fuel pools. The purpose of this TI is also to verify the licensees have implemented Emergency Preparedness (EP) enhancements as described in their site
-specific submittals and NRC safety assessments, including multi
-unit dose assessment capability and enhancements to ensure that staffing is sufficient and communications can be maintained during such an event.


The inspection verified that plans for complying with NRC Orders EA 049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond
The inspection verified that plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, (ADAMS Accession No. ML12229A174) and EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation, (ADAMS Accession No. ML12056A044) are in place and are being implemented by the licensee. Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012, request for information letter and multiunit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 (ADAMS Accession No. ML12339A262).
-Design-Basis External Events
," (ADAMS Accession No. ML12229A174) and EA 051, "Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation
," (ADAMS Accession No. ML12056A044) are in place and are being implemented by the licensee. Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012
, request for information letter and multiunit dose assessment information provided per COMSECY-13-0010, "Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned," dated March 27, 2013 (ADAMS Accession No. ML12339A262).


The team discussed the plans and strategies with plant staff, reviewed documentation, and where appropriate, performed plant walk downs to verify that the strategies could be implemented as stated in the licensee's submittals and the NRC staff
The team discussed the plans and strategies with plant staff, reviewed documentation, and where appropriate, performed plant walk downs to verify that the strategies could be implemented as stated in the licensees submittals and the NRC staff-prepared safety evaluation. For most strategies, this included verification that the strategy was feasible, procedures and/or guidance had been developed, training had been provided to plant staff, and required equipment had been identified and staged. Specific details of the teams inspection activities are described in the following sections.
-prepared safety evaluation. For most strategies, this included verification that the strategy was feasible, procedures and/or guidance had been developed, training had been provided to plant staff, and required equipment had been identified and staged. Specific details of the team's inspection activities are described in the following sections.


1. Mitigation Strategies for Beyond
===1. Mitigation Strategies for Beyond-Design-Basis External Events===
-Design-Basis External Events


====a. Inspection Scope====
====a. Inspection Scope====
The team examined the licensee's established guidelines and implementing procedures for the beyond
The team examined the licensees established guidelines and implementing procedures for the beyond-design-basis mitigation strategies. The team assessed how the licensee coordinated and documented the interface/transition between existing off-normal and emergency operating procedures with the newly developed mitigation strategies. The team selected a number of mitigation strategies and conducted plant walk downs with licensed operators and responsible plant staff to assess: the adequacy and completeness of the procedures, familiarity of operators with the procedure objectives and specific guidance, staging and compatibility of equipment, and the practicality of the operator actions prescribed by the procedures, consistent with the postulated scenarios.
-design-basis mitigation strategies. The team assessed how the licensee coordinated and documented the interface/transitio n between existing off
-normal and emergency operating procedures with the newly developed mitigation strategies. The team selected a number of mitigation strategies and conducted plant walk downs with licensed operators and responsible plant staff to assess: the adequacy and completeness of the procedures
, familiarity of operators with the procedure objectives 4 and specific guidance, staging and compatibility of equipment
, and the practicality of the operator actions prescribed by the procedures, consistent with the postulated scenarios.


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


b. Assessment Based on samples selected for review, the team verified that the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is generally in compliance with NRC Order EA 049. The team verified that the licensee satisfactorily:
b. Assessment Based on samples selected for review, the team verified that the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is generally in compliance with NRC Order EA-12-049. The team verified that the licensee satisfactorily:
Developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX strategies for postulated external events
* Developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX strategies for postulated external events,
,  Integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs are clear when using existing plant procedures
* Integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs are clear when using existing plant procedures,
,  Protected FLEX equipment from site
* Protected FLEX equipment from site-specific hazards,
-specific hazards
* Developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability,
,  Developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability
* Trained their staff to assure personnel proficiency in the mitigation of beyond-design-basis events, and
,  Trained their staff to assure personnel proficiency in the mitigation of beyond-design-basis events
* Developed means to ensure that the necessary off-site FLEX equipment will be available from off-site locations.
, and   Developed means to ensure that the necessary off
 
-site FLEX equipment will be available from off
The team verified that any non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.
-site locations
. The team verified that any non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.


====c. Findings====
====c. Findings====
No findings identified.
No findings identified.


5 2. Spent Fuel Pool (SFP) Instrumentation
===2. Spent Fuel Pool (SFP) Instrumentation===


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


b. Assessment Based on samples selected for review, the team determined that the licensee satisfactorily installed and established control of the SFP instrumentation as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is generally in compliance with NRC Order EA 051. The team verified that the licensee satisfactorily:
b. Assessment Based on samples selected for review, the team determined that the licensee satisfactorily installed and established control of the SFP instrumentation as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is generally in compliance with NRC Order EA-12-051. The team verified that the licensee satisfactorily:
Installed the SFP instrumentation sensors, cabling and power supplies to provide physical and electrical separation as described in the plant specific submittal and safety evaluation
* Installed the SFP instrumentation sensors, cabling and power supplies to provide physical and electrical separation as described in the plant specific submittal and safety evaluation;
;    Installed the SFP instrumentation display in the location, environmental conditions and accessibility as described in the plant specific submittals; and   Trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation.
* Installed the SFP instrumentation display in the location, environmental conditions and accessibility as described in the plant specific submittals; and
* Trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation.


The team verified that any non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.
The team verified that any non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.
Line 135: Line 114:
No findings identified.
No findings identified.


3. Staffing and Communication Request for Information
===3. Staffing and Communication Request for Information===


====a. Inspection Scope====
====a. Inspection Scope====
Through discussions with plant staff, review of documentation and plant walk downs, the team verified that the licensee has implemented required changes to staffing, communications equipment
Through discussions with plant staff, review of documentation and plant walk downs, the team verified that the licensee has implemented required changes to staffing, communications equipment, and facilities to support an Extended Loss of All AC Power (ELAP) scenario as described in the licensees staffing assessment and the NRC safety assessment. The team also verified that the licensee has implemented dose assessment (including releases from spent fuel pools) capability using the licensees site-specific dose assessment software and approach as described in the licensees dose assessment submittal. Documents reviewed are listed in the attachment.
, and facilities to support an Extended Loss of All AC Power (ELAP) scenario as described in the licensee's staffing assessment and the NRC safety assessment. The team also verified that the licensee has implemented dose assessment (including releases from spent fuel pools) capability using the licensee's site-specific dose assessment software and approach as described in the licensee's dose assessment submittal. Documents reviewed are listed in the attachment.


6 b. Assessment The team reviewed information provided in the licensee's multi
b. Assessment The team reviewed information provided in the licensees multi-unit dose submittal and in response to the NRCs March 12, 2012, request for information letter and verified that the licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force Recommendation 9.3 response to a large scale natural emergency event that results in an extended loss of all ac power to the site and impedes access to the site.
-unit dose submittal and in response to the NRC's March 12, 2012, request for information letter and verified that the licensee satisfactorily implemented enhancements pertaining to Near
-Term Task Force Recommendation 9.3 response to a large scale natural emergency event that results in an extended loss of all ac power to the site and impedes access to the site.


The team verified the following:
The team verified the following:
Licensee satisfactorily implemented required staffing change(s) to support an ELAP scenario ,     Emergency preparedness communications equipment and facilities are sufficient for dealing with an ELAP scenario
* Licensee satisfactorily implemented required staffing change(s) to support an ELAP scenario,
, and   Implemented dose assessment capabilities (including releases from spent fuel pools) using the licensee's site
* Emergency preparedness communications equipment and facilities are sufficient for dealing with an ELAP scenario, and
-specific dose assessment software and approach.
* Implemented dose assessment capabilities (including releases from spent fuel pools)using the licensees site-specific dose assessment software and approach.


The team verified that any non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.
The team verified that any non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.
Line 154: Line 130:
====c. Findings====
====c. Findings====
No findings identified.
No findings identified.
{{a|4OA6}}
==4OA6 Exit==


{{a|4OA6}}
===Exit Meeting Summary===
==4OA6 Exit Exit Meeting Summary==


On September 1, 2017, the team presented the on-site inspection results in a management debrief to T. Herrmann, Site Vice President
On September 1, 2017, the team presented the on-site inspection results in a management debrief to T. Herrmann, Site Vice President, and other members of the site staff. The inspectors confirmed that proprietary information examined during the inspection had been returned to the licensee. The team lead completed an exit meeting conducted with S. Banker, Senior Director, Engineering, and other members of the site staff, via telephone on September 26, 2017, to discuss the final results of the inspection.
, and other members of the site staff. The inspectors confirmed that proprietary information examined during the inspection had been returned to the licensee. The team lead completed an exit meeting conducted with S. Banker, Senior Director, Engineering
, a nd other members of the site staff, via telephone on September 26, 2017 , to discuss the final results of the inspection.


ATTACHMENT: SUPPLEMENTA L INFORMATION
ATTACHMENT:  


=SUPPLEMENTAL INFORMATION=
=SUPPLEMENTAL INFORMATION=
Line 169: Line 144:


===Licensee Personnel===
===Licensee Personnel===
: [[contact::S. Abel ]], Director, Engineering Projects
: [[contact::S. Abel]], Director, Engineering Projects
: [[contact::A. Alley]], Engineering Program Supervisor
: [[contact::A. Alley]], Engineering Program Supervisor
: [[contact::S. Banker ]], Senior Director Engineering
: [[contact::S. Banker]], Senior Director Engineering
: [[contact::F. Bianco ]], Director, Nuclear Operations
: [[contact::F. Bianco]], Director, Nuclear Operations
: [[contact::J. Cortez]], Director, Training
: [[contact::J. Cortez]], Director, Training
: [[contact::M. Covey]], Manager, Operations
: [[contact::M. Covey]], Manager, Operations
Line 180: Line 155:
: [[contact::T. Holland]], Shift Manager
: [[contact::T. Holland]], Shift Manager
: [[contact::B. Huhmann]], Regulatory Affairs Supervisor
: [[contact::B. Huhmann]], Regulatory Affairs Supervisor
: [[contact::B. Jungmann ]], Director, Maintenance
: [[contact::B. Jungmann]], Director, Maintenance
: [[contact::S. Kovaleski]], Director, Engineering Design
: [[contact::S. Kovaleski]], Director, Engineering Design
: [[contact::G. Kremer ]], Director, Engineering Programs
: [[contact::G. Kremer]], Director, Engineering Programs
: [[contact::M. McLachlan]], Senior Director Plant Support
: [[contact::M. McLachlan]], Senior Director Plant Support
: [[contact::K. Mills]], Director, Engineering Systems
: [[contact::K. Mills]], Director, Engineering Systems
: [[contact::T. Moser]], Director, Nuclear Projects
: [[contact::T. Moser]], Director, Nuclear Projects
: [[contact::J. Nurrenbern]], FLEX Program Enginee
: [[contact::J. Nurrenbern]], FLEX Program Engineer
r
: [[contact::E. Olson]], Director, Engineering Programs
: [[contact::E. Olson ]], Director, Engineering Programs
: [[contact::J. Patterson]], Director, Nuclear Projects
: [[contact::J. Patterson]], Director, Nuclear Projects
: [[contact::E. Ptasznik]], Licensing Engineer  
: [[contact::E. Ptasznik]], Licensing Engineer
: [[contact::S. Sandbothe]], Director , Plant Support
: [[contact::S. Sandbothe]], Director, Plant Support
: [[contact::D. Stepanovic]], Manager, Materials
: [[contact::D. Stepanovic]], Manager, Materials
===NRC Personnel===
===NRC Personnel===
: [[contact::S. Janicki]], Resident Inspector
: [[contact::S. Janicki]], Resident Inspector
Line 199: Line 172:
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==


Closed 2515/191 TI Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi
===Closed===
-Unit Dose Assessment Plans
 
, issued December 23, 2015
Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency 2515/191                    TI Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, issued December 23, 2015 Attachment


==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==


}}
}}

Latest revision as of 10:35, 19 December 2019

Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/ Staffing/Multi-Unit Dose Assessment Plans - Inspection Report 05000483/2017008
ML17277A053
Person / Time
Site: Callaway Ameren icon.png
Issue date: 10/03/2017
From: Nick Taylor
NRC/RGN-IV/DRP/RPB-A
To: Diya F
Ameren Missouri
Taylor N
References
EA-12-049, EA-12-051 IR 2017008
Download: ML17277A053 (15)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E. LAMAR BLVD.

ARLINGTON, TX 76011-4511 October 3, 2017 Mr. Fadi Diya, Senior Vice President and Chief Nuclear Officer Ameren Missouri Callaway Plant P.O. Box 620 Fulton, MO 65251 SUBJECT: CALLAWAY PLANT - INSPECTION OF THE IMPLEMENTATION OF MITIGATION STRATEGIES AND SPENT FUEL POOL INSTRUMENTATION ORDERS AND EMERGENCY PREPAREDNESS COMMUNICATION/

STAFFING/MULTI-UNIT DOSE ASSESSMENT PLANS - INSPECTION REPORT 05000483/2017008

Dear Mr. Diya:

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

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

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

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA David Proulx Acting for/

Nicholas H. Taylor, Chief Project Branch B Division of Reactor Projects Docket No. 50-483 License No. NPF-30

Enclosure:

Inspection Report 05000483/2017008 w/ Attachment: Supplemental Information

REGION IV==

Docket: 05000483 License: NPF-30 Report: 05000483/2017008 Licensee: Union Electric Company Facility: Callaway Plant Location: Junction Highway CC and Highway O Steedman, Missouri Dates: August 28 - September 26, 2017 Inspectors: R. Alexander, Sr. Project Engineer (Team Leader)

S. Alferink, Reactor Inspector D. Bradley, Sr. Resident Inspector - Callaway M. Stafford, Project Engineer Approved Nicholas H. Taylor By: Chief, Project Branch B Division of Reactor Projects

Enclosure

SUMMARY

IR 05000483/2017008; 08/28/2017 - 09/26/2017; Callaway Plant;

Temporary Instruction 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, issued December 23, 2015.

The inspection covered a one-week inspection by the resident inspector and three inspectors from the Region IV office. No findings were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.

NRC-Identified and Self-Revealing Findings

None

Licensee-Identified Violations

None

REPORT DETAILS

4. Other Activities

4OA5 Other Activities (TI 2515/191)

The objective of Temporary Instruction (TI) 2515/191 Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, is to verify that licensees have adequately implemented the mitigation strategies as described in the licensees Final Integrated Plan (ADAMS Accession No. ML16189A304) and the NRCs plant safety evaluation (ADAMS Accession No. ML17010A332) and to verify that the licensees installed reliable water level measurement instrumentation in their spent fuel pools. The purpose of this TI is also to verify the licensees have implemented Emergency Preparedness (EP) enhancements as described in their site-specific submittals and NRC safety assessments, including multi-unit dose assessment capability and enhancements to ensure that staffing is sufficient and communications can be maintained during such an event.

The inspection verified that plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, (ADAMS Accession No. ML12229A174) and EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation, (ADAMS Accession No. ML12056A044) are in place and are being implemented by the licensee. Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012, request for information letter and multiunit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 (ADAMS Accession No. ML12339A262).

The team discussed the plans and strategies with plant staff, reviewed documentation, and where appropriate, performed plant walk downs to verify that the strategies could be implemented as stated in the licensees submittals and the NRC staff-prepared safety evaluation. For most strategies, this included verification that the strategy was feasible, procedures and/or guidance had been developed, training had been provided to plant staff, and required equipment had been identified and staged. Specific details of the teams inspection activities are described in the following sections.

1. Mitigation Strategies for Beyond-Design-Basis External Events

a. Inspection Scope

The team examined the licensees established guidelines and implementing procedures for the beyond-design-basis mitigation strategies. The team assessed how the licensee coordinated and documented the interface/transition between existing off-normal and emergency operating procedures with the newly developed mitigation strategies. The team selected a number of mitigation strategies and conducted plant walk downs with licensed operators and responsible plant staff to assess: the adequacy and completeness of the procedures, familiarity of operators with the procedure objectives and specific guidance, staging and compatibility of equipment, and the practicality of the operator actions prescribed by the procedures, consistent with the postulated scenarios.

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

b. Assessment Based on samples selected for review, the team verified that the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is generally in compliance with NRC Order EA-12-049. The team verified that the licensee satisfactorily:

  • Developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX strategies for postulated external events,
  • Integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs are clear when using existing plant procedures,
  • Protected FLEX equipment from site-specific hazards,
  • Developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability,
  • Trained their staff to assure personnel proficiency in the mitigation of beyond-design-basis events, and
  • Developed means to ensure that the necessary off-site FLEX equipment will be available from off-site locations.

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

c. Findings

No findings identified.

2. Spent Fuel Pool (SFP) Instrumentation

a. Inspection Scope

The team examined the licensees newly installed spent fuel pool instrumentation.

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

b. Assessment Based on samples selected for review, the team determined that the licensee satisfactorily installed and established control of the SFP instrumentation as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is generally in compliance with NRC Order EA-12-051. The team verified that the licensee satisfactorily:

  • Installed the SFP instrumentation sensors, cabling and power supplies to provide physical and electrical separation as described in the plant specific submittal and safety evaluation;
  • Installed the SFP instrumentation display in the location, environmental conditions and accessibility as described in the plant specific submittals; and
  • Trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation.

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

c. Findings

No findings identified.

3. Staffing and Communication Request for Information

a. Inspection Scope

Through discussions with plant staff, review of documentation and plant walk downs, the team verified that the licensee has implemented required changes to staffing, communications equipment, and facilities to support an Extended Loss of All AC Power (ELAP) scenario as described in the licensees staffing assessment and the NRC safety assessment. The team also verified that the licensee has implemented dose assessment (including releases from spent fuel pools) capability using the licensees site-specific dose assessment software and approach as described in the licensees dose assessment submittal. Documents reviewed are listed in the attachment.

b. Assessment The team reviewed information provided in the licensees multi-unit dose submittal and in response to the NRCs March 12, 2012, request for information letter and verified that the licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force Recommendation 9.3 response to a large scale natural emergency event that results in an extended loss of all ac power to the site and impedes access to the site.

The team verified the following:

  • Licensee satisfactorily implemented required staffing change(s) to support an ELAP scenario,
  • Implemented dose assessment capabilities (including releases from spent fuel pools)using the licensees site-specific dose assessment software and approach.

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

c. Findings

No findings identified.

4OA6 Exit

Exit Meeting Summary

On September 1, 2017, the team presented the on-site inspection results in a management debrief to T. Herrmann, Site Vice President, and other members of the site staff. The inspectors confirmed that proprietary information examined during the inspection had been returned to the licensee. The team lead completed an exit meeting conducted with S. Banker, Senior Director, Engineering, and other members of the site staff, via telephone on September 26, 2017, to discuss the final results of the inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

S. Abel, Director, Engineering Projects
A. Alley, Engineering Program Supervisor
S. Banker, Senior Director Engineering
F. Bianco, Director, Nuclear Operations
J. Cortez, Director, Training
M. Covey, Manager, Operations
B. Cox, Senior Director Nuclear Operations
D. Farnsworth, Director, Work Management
T. Herrmann, Site Vice President
T. Holland, Shift Manager
B. Huhmann, Regulatory Affairs Supervisor
B. Jungmann, Director, Maintenance
S. Kovaleski, Director, Engineering Design
G. Kremer, Director, Engineering Programs
M. McLachlan, Senior Director Plant Support
K. Mills, Director, Engineering Systems
T. Moser, Director, Nuclear Projects
J. Nurrenbern, FLEX Program Engineer
E. Olson, Director, Engineering Programs
J. Patterson, Director, Nuclear Projects
E. Ptasznik, Licensing Engineer
S. Sandbothe, Director, Plant Support
D. Stepanovic, Manager, Materials

NRC Personnel

S. Janicki, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Closed

Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency 2515/191 TI Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, issued December 23, 2015 Attachment

LIST OF DOCUMENTS REVIEWED

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