IR 05000483/2018003

NRC Integrated Inspection Report 05000483/2018003 and Independent Spent Fuel Storage Installation Inspection Report 07201045/2018001

ML18295A010
Person / Time
Site:	Callaway
Issue date:	10/19/2018
From:	Taylor N H NRC/RGN-IV/DRP/RPB-B
To:	Diya F Ameren Missouri
Taylor N H
References
IR 2018001, IR 2018003
Download: ML18295A010 (31)

Text

. October 1 9, 2018 Mr. Fadi Diya, Senior Vice President and Chief Nuclear Officer Ameren Missouri Callaway Plant 8315 County Road 459 Steedman, MO 65077

SUBJECT: CALLAWAY PLANT

- NRC INTEGRATED INSPECTION REPORT 05000483/2018003 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION INSPECTION REPORT 07201045/2018001

Dear Mr. Diya:

On September 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed a n inspection at your Callaway Plant. On October 3, 2018, 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. I nspectors documented a licensee-identified violation, which was determined to be of very low safety significance. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or significance of the NCV , you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20 555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and th e NRC resident inspector at the Callaway Plant. 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/ Nicholas H. Taylor, Chief Project Branch B Division of Reactor Projects Docket No s. 50-483 , 7 2-1045 License No. NPF-30 Enclosure s: Inspection Report 05000483/2018003 and 07201045/2018001 w/Attachment s 1: Documents Reviewed 2: Request for Information Quarterly Baseline Inspection cc: Electronic Distribution for Callaway Plant

Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number s: 05000483 and 07201045 License Number

NPF-30 Report Number s: 05000483/2018003 and 07201045/2018001 Enterprise Identifier s: I-2018-003-006 and I-2018-001-0135 Licensee: Union Electric Company Facility: Callaway Plant and Independent Spent Fuel Storage Installation Location: 8315 County Road 459 Steedman, Missouri 65077 Inspection Dates:

July 1, 2018 to September 30, 2018 Inspectors:

D. Bradley, Senior Resident Inspector S. Janicki, Resident Inspector S. Alferink, PhD, Reactor Inspector J. Drake, Senior Reactor Inspector L. Brookhart, Senior ISFSI Inspector, FCDB P. Elkmann, Senior Emergency Preparedness Inspector N. Hernandez, Operations Engineer C. Newport, Senior Resident Inspector E. Simpson, CHP, Health Physicist, FCDB C. Stott, Reactor Inspector Approved By:

N. Taylor Chief, Project Branch B Division of Reactor Projects

2

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensee's performance by conducting an integrated inspection at the Callaway Plant in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRC's program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

NRC-identified and self-revealed findings, violations, and additional items are summarized in the table s below. A licensee-identified non-cited violation is documented in the Inspection Results at the end of this report. List of Findings and Violations None. Additional Tracking Items Type Issue number Title Inspection Procedure Status URI 05000483/2018003

-01 Failure to perform 10 CFR 50.59 evaluation for compensatory measures associated with stagnant, inactive loop 71111.17T Open Type Issue number Title Inspection Procedure Status LER 05000483/2018

-002-00 Inadequate Emergency Operating Procedure Guidance for Asymmetric Natural Circulation Cooldown on May 7, 2018 71153 Closed 3

PLANT STATUS

Callaway Plant began the inspection period at full power 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

External Flooding

(1 Sample)

The inspectors evaluated readiness to cope with external flooding on July 16, 2018.

71111.04 - Equipment Alignment

Partial Walkdown (4 Samples) The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Remote shutdown panel on July 12, 2018

(2) Component cooling water emergency makeup valves on August 7, 20 18

(3) Fire water storage tanks on August 24, 2018

(4) Emergency exhaust system train B on August 25, 2018 Complete Walkdown (1 Sample) The inspectors evaluated system configurations during a complete walkdown of the component cooling water system train A on September 10, 2018.

71111.05AQ - Fire Protection Annual/Quarterly

Quarterly Inspection (4 Samples

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

(1) Load center and motor generator r oom, fire area A-27, on July 20, 2018

(2) Component cooling water train A, fire area A

-1 6 N, on September 5, 2018

(3) Component cooling water train B and remote shutdown panel, fire areas A

-16S, A-28, and A-33, on September 19, 2018

(4) Spent fuel pool cooling train A, fire area FB-1, on September 20, 2018 Annual Inspection (1 Sample) The inspectors evaluated fire brigade performance on July 23 and August 20, 2018.

71111.06 - Flood Protection Measures

Cables (1 Sample) The inspectors evaluated cable submergence protection in safety-related manhole MH01B on August 16, 2018.

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (1 Sample) The inspectors observed and evaluated licensed operator continuing training in the simulator on July 27, 2018.

Operator Performance (1 Sample) The inspectors observed and evaluated control room staff in the following evolutions

(1) Crew turnover on September 7, 2018

(2) Pressurizer backup heaters capacity test and post maintenance test on September 21, 2018 Operator Exams (1 Sample) The inspectors reviewed and evaluated requalification examination results on August 22 , 2018.

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness (2 Samples) The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions

(1) Emergency diesel generator including temperature switches on July 11, 2018

(2) Component cooling water including gas voiding on September 21, 2018

71111.13 - Maintenance Risk Assessments and Emergent Work Control

(5 Samples) The inspectors evaluated the risk assessments for the following planned and emergent work activities

(1) Elevated risk actions due to emergent work on the solid state protection system input relay K334 on July 9, 2018

(2) Elevated risk actions due to planned residual heat removal train A pump and valve inservice testing on July 20, 2018

(3) Elevated risk actions due to planned containment isolation signal train B relay testing on August 16, 2018

(4) Elevated risk actions due to planned control room filtration train A surveillance testing on August 2 8, 2018

(5) Elevated risk actions due to planned switchyard breaker replacement s on September 14, 2018

71111.15 - Operability Determinations and Functionality Assessments

(3 Samples

) The inspectors evaluated the following operability determinations and functionality assessments:

(1) Component cooling water piping penetration degradation on August 15, 2018

(2) Engineered safety features actuation system surveillance results on August 16, 2018

(3) Emergency diesel generator fuel oil filtration on August 24, 2018 71111.17T-Evaluations of Changes, Tests and Experiments (1 Sample) The inspectors evaluated the following from August 6-10, 2018: 10 CFR 50.59 Evaluations

(1) CA2512-16-05, modification package 13-0033, harden ed condensate storage tank

(2) CA2512 Final Safety Analysis Report change to increase the maximum design bases accident temperature for class 1E equipment rooms

(3) CA 2512 16-09 - procedure change (ODP-ZZ-00002) regarding when emergency diesel generator room ventilation supply fans are required

(4) C A 2512 17-02 - LDCN 17-0003, volume control tank explosive atmosphere (forced oxidation)10 CFR 50.59 Screening/Applicability Determinations

(1) CA2511-01160, m odification package 17-0012, bypass (jumper)

A ultimate heat sink fan motor high speed thermal overloads

(2) CA2511/OTN-AP-00003/002, hardened condensate storage tank

(3) CA2511/compensatory measures additions to OTO-ZZ-00012

(4) CA2511/OTN

-GK-00001/050, control building heating, ventilation, air conditioning system

(5) CA2511/OTN

-GK-00001/051 , control building heating ventilation, air conditioning system

(6) CA2511/OTN

-NG-00001/017, class 1E 4 80 heating ventilation, air conditioning electrical syst em

(7) CA2511-01088 , MP 16-0036/201606214

-modification of essential service water drains both component cooling water heat exchangers

(8) CA2511-01090, replacement of under frequency relay for reactor coolant pump motor

(9) CA2511/MP18

-0045 , NK battery replacement

(10) CA2511/OTN-EF-00001/073, essential service water system

(11) CA2511/EOPADD42/002 , r evise procedure to make the motor

-driven auxiliary feedwater pumps available when the hardened condensate storage tank is aligned to auxiliary feedwater suction

(12) CA2511/OTS-PA-00001/022

- operation and testing of alternate power source

(13) CA2511/OTN-EP-00001 ADD3/009

- initial fill and vent of safety injection accumulators

(14) CA2511/17000810

- cycle KJHS0180 to maintain jacket water temp in proper temperature band

(15) CA2511/OTN-EB-00001 ADD1/

007 - component cooling water equipment rotation and controlling temperature

(16) CA 2511/night order and immediate operability determination compensatory measures for Condition Report 201802284

(17) CA2511/OTN

-NG-00001/017, class 1E 480 heating ventilation, air conditioning electrical system

(18) CA2511/EOPADD42/002

, make the motor

-driven auxiliary feedwater pumps available when the hardened condensate storage tank is aligned to auxiliary feed water suction

71111.18 - Plant Modifications

(1 Sample) The inspectors evaluated modification package MP 07-0069, replace 480V load center circuit breakers with new Square D breaker s.

71111.19 - Post Maintenance Testing

(5 Samples

) The inspectors evaluated the following post maintenance tests:

(1) Battery charger NK22 after equipment outage on July 18, 2018

(2) Emergency exhaust system train A after equipment outage on August 8, 2018

(3) SGK04B modification after equipment outage on August 1 3, 2018

(4) Site 200 series electrical distribution after equipment outage on September 9, 2018

(5) Pressurizer backup heaters after equipment outage on September 21, 2018

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine (2 Samples)

(1) Containment isolation signal slave relay train A test on August 2, 2018

(2) Ultimate heat sink cooling tower fan, train s A and B, test on August 22, 2018 In-service (2 Samples)

(1) Emergency service water pump train A in-service test on July 11, 2018

(2) Emergency diesel generator fuel oil system train B in-service test on July 25, 2018

71114.04 - Emergency Action Level and Emergency Plan Changes

(1 Sample) The inspector s evaluated Procedure EIP-ZZ-00101, "Classification of Emergencies," Revision 55 on September 13, 2018. This evaluation does not constitute NRC approval.

OTHER ACTIVITIES

- BASELINE 71151-Performance Indicator Verification (3 Samples

) The inspectors verified licensee performance indicators submittals listed below:

(1) IE01: Unplanned Scrams per 7000 Critical Hours Sample (07/01/2017

- 06/30/2018

)

(2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample (07/01/2017

- 06/30/2018

)

(3) IE04: Unplanned Scrams with Complications Sample (07/01/2017

- 06/30/2018

)

71152 - Problem Identification and Resolution

Annual Follow

-up of Selected Issues (2 Sample s) The inspectors reviewed the licensee's implementation of its corrective action program related to the following issues:

(1) Essential service water system thermal performance evaluation including inventory losses under Condition Report 201803313 on August 9, 2018

(2) Switchyard breaker trip, MDV52-2 , under Condition Report 201803237 on July 28 , 2018 71153-Follow-up of Events and Notices of Enforcement Discretion Licensee Event Reports (1 Sample) The inspectors evaluated Licensee Event Report 2018-002-00, Inadequate Emergency Operating Procedure Guidance for Asymmetric Natural Circulation Cooldown on May 7, 2018, which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 60855-Operation of an Independent Spent Fuel Storage Installation and 60857-Review of 10 CFR 72.48 Evaluations The inspectors evaluated the licensee's operation of the Independent Spent Fuel Storage Installation (ISFSI) from August 11-17, 2018 , on-site at the Callaway Plant and conducted an in-office review of additional documentation, including quality assurance audit reports, condition reports, and documents related to the licensee's maintenance of their ISFSI and related equipment.

The Callaway ISFSI is a 10 CFR Part 72 general licensed ISFSI and utilized the Holtec HI-STORM UMAX Storage System, approved under Certificate of Compliance 1040, License Amendment 0, UMAX Final Safety Analysis Report Revision 2, and HI-STORM FW Final Safety Analysis Report Revision 3. This storage system utilizes the multi

-purpose canister (MPC-37) that stores 37 pressurized water reactor fuel assemblies in a below grade vertical ventilated module. Callaway had constructed the UMAX ISFSI to hold 48 MPC-37 canisters within the vertical ventilated modules at the site. The top ISFSI pad dimensions are 108.5 feet by 157.5 f eet, configured in six rows of eight canisters.

During the routine ISFSI inspection, Callaway was in the middle of their second loading campaign. Inspectors were onsite to observe the loading activities associated with canister number 4 out of 12 planned for the dry fuel storage campaign. By the end of the loading campaign, the licensee was expected to have a total of 18 canisters stored in the UMAX ISFSI.

The ISFSI activities specifically reviewed during the on

-site inspection and the subsequent in-office review included:

(1) Evaluated and observed fuel selection and fuel loading operations associated with the 4 th canister of the campaign (the 10 th cask placed at the ISFSI)

(2) Evaluated and observed welding of the canister, non

-destructive testing of the welds, pressure testing, forced helium drying, helium backfill, and heavy load movements from the spent fuel pool to the site's vertical cask transporter and into the vertical ventilated module

(3) Reviewed the licensee's loading, processing, and heavy load procedures associated with their current dry fuel storage campaign

(4) Reviewed the licensee's corrective action program implementation for ISFSI operations since the last routine ISFSI inspection which was completed in January 2017

(5) Reviewed quality assurance program implementation, including recent quality assurance audits, surveillances, and quality control activities

(6) Reviewed documentation for compliance with Technical Specification s related to operational surveillance activities and Final Safety Analysis Report required annual maintenance activities

(7) Reviewed the licensee's radiological monitoring data for the calendar years 2016 and 2017 to verify compliance with 10 CFR 72.104 requirements

(8) Reviewed spent fuel documentation for the canisters loaded since the last routine ISFSI inspection to verify the fuel met all technical specification requirements for storage (canisters 7-10)

(9) Reviewed annual maintenance activities for heavy lifting components which included special lifting devices and the site's cask handling crane

(10) Reviewed all 10 CFR 72.48 safety evaluations/screenings performed by the licensee for changes made to the ISFSI program since the last routine ISFSI inspection in accordance with NRC Inspection Procedure 60857

(11) Reviewed all changes made to the licensee's 10 CFR 72.212 report under the licensee's 10 CFR 72.48 program (Reviewed changes from Revision 2 and Revision 3)

INSPECTION RESULTS

Licensee-Identified Non

-Cited Violation 71153-Follow-up of Events and Notices of Enforcement Discretion This violation of very low safety significance was identified by the licensee and has been entered into the licensee's corrective action program and is being treated as a non

-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation:

Technical Specification 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2. Section 6 of Appendix A to Regulatory Guide 1.33, Revision 2, requires procedures for combating emergencies and other significant events. The licensee established Emergency Operating Procedure (EOP) ES-0.2, "Natural Circulation Cooldown," Revision 9, in part, to meet the regulatory requirement. Figure 1 of ES-0.2 allowed cooldown rates that exceeded the values used in the license basis for radiological consequence analyses and exceeded the values used in the design of the nitrogen accumulators for atmospheric steam dumps and turbine-driven auxiliary feedwater system actuations. This issue was discussed in Licensee Event Report 2018-002-00 , "Inadequate EOP Guidance for Asymmetric Natural Circulation Cooldown."

Contrary to the above, from April 29, 2008 through May 7, 2018, the licensee failed to maintain procedures for combating emergencies and other significant events.

Specifically, the licensee failed to maintain EOPs for natural circulation cooldown.

This performance deficiency resulted in atmospheric steam dumps and turbine-driven auxiliary feedwater systems being rendered inoperable due to depletion of the safety

-related actuation nitrogen.

Significance/Severity Level: This performance deficiency was more than minor, and therefore a finding, because it adversely affected the procedure quality attribute of the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. As a result, the licensee would not have been able to reach shutdown cooling conditions and the plant would have been placed in a condition of being unable to control decay heat removal via atmospheric steam dumps

. Using Inspection Manual Chapter 0609, Attachment 4, "Initial Characterization of Findings," and Appendix A, "The Significance Determination Process (SDP) for Findings At

-Power," Exhibit 2, "Mitigating Systems Screening Questions," dated June 19, 2012, the inspectors determined that the finding required a detailed risk evaluation since the finding represented an actual loss of function of at least a single train for greater than its technical specification allowed outage time.

Specifically, as reported in Licensee Event Report 2018-002-00, "Inadequate EOP Guidance for Asymmetric Natural Circulation Cooldown," atmospheric steam dumps and the turbine

-driven auxiliary feedwater system were rendered inoperable

, due to the inadequate EOP revision , in April 2008. As a result, this exceeded the allowed outage time for the associated Technical Specifications 3.7.4 and 3.7.5, respectively.

The senior reactor analyst reviewed the issue and determined that the issue was of very low safety significance, or Green. The senior reactor analyst noted that the impact of the performance deficiency on plant safety was limited to a steam line break leading to a consequential loss of offsite power. The frequency of all such events was estimated to be approximately 3.5 x 10-5/year, using values available in the plant

-specific SPAR model. According to the licensee, the design basis time that the nitrogen backup accumulators would provide motive force to the atmospheric steam dumps and the turbine

-driven auxiliary feedwater flow control valves was 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> with a maximum realistic time available of approximately 16.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. Therefore, the analyst used an average probability of nonrecovery of offsite power over a 12

-hour period (6.2 x 10-2). Additionally, the licensee has two air compressors supplied by the vital diesel generators that would eliminate the demand for the nitrogen accumulators. Therefore, the analyst applied a generic value for the failure of a multi-train system (3.0 x 10-3). Using these assumptions, the analyst calculated the frequency of a steam line break with unrecovered loss of offsite power and a failure of the remaining two air compressors. This bounded the value of the incremental conditional core damage frequency to less than 6.5 x 10-9/year. Corrective Action Reference: Condition Report 201802284.

Unresolved Item (Open) Failure to perform 10 CFR 50.59 evaluation for compensatory measures associated with stagnant, inactive loop. 05000483/20 18003-01 71111.17T Evaluations of Changes, Tests and Experiments Description

The inspectors identified an unresolved item related to implementation of 10 CFR 50.59, "Evaluations Changes, Tests and Experiments," for the licensee's failure to perform an adequate evaluation for compensatory measures for a stagnant, inactive loop.

The licensee enacted compensatory measures to support atmospheric dump valve/turbine

-driven AFW pump operability due to an issue identified for natural circulation cooldown with a faulted steam generator (i.e., inactive loop).

A reduction in the Technical Specificatio n 3.4.16 dose equivalent iodine (DEI) Ci/gm) was imposed without a 10 CFR 50.59 evaluation and/or license amendment.

Specifically, the licensee did not consider the compensatory measure of reducing Technical Specification 3.4.16 limits on DEI

-131 as a change to technical specifications.

The licensee considered this a temporary action that did not meet the intent of 10 CFR 50.90 for a technical specification change.

Planned Closure Action: There is currently an NEI paper under review by the NRC Headquarters Technical Specification Branch and a draft Regulatory Guide that addresses the issue of non

-conservative technical specifications and timely submittal of license amendment requests associated with them. This issue will be resolved based on the results of the Technical Specifications Branch's final decision on the subject.

Licensee Action: The licensee has entered the issue into their corrective action program.

Corrective Action Reference: Condition Report 201804069. EXIT MEETIN GS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report

. On August 10, 2018, the inspecto rs presented the Evaluations of Changes, Tests and Experiments inspection results to Mr. T. Herrmann, Site Vice President, and other members of the licensee staff.

On August 16, 2018, the inspector s presented the routine ISFSI inspection results to Mr. B. Cox, Senior Director Nuclear Operations, and other members of the licensee staff.

On August 22, 2018, the inspector s presented the annual requalification inspection results to Mr. M. Otten, Operations Training Manager, and other members of the licensee staff.

On September 26 , 2018, the emergency preparedness inspector presented the results of the review of changes to the licensee's emergency plan to Mr. G. Rausch, Manager, Emergency Preparedness, and other members of the licensee staff.

On October 3, 2018, the inspector s presented the quarterly resident inspector inspection results to Mr. T. Herrmann, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Procedure 71111.01: Adverse Weather Protection

Condition Reports

201001813 201706008 201702791 Procedures

Number Title Revision ODP-ZZ-00017 , Appendix 2 Technical Specification Related Annunciators

OOA-EF-00001 Ultimate Heat Sink Setpoint Levels

OTA-RK-00020 Annunciator Response Procedure MCB Panel RK020 4 OTN-EF-00001 Essential Service Water System

Miscellaneous Documents

Number Title Revision U-29-03-F Ultimate Heat Sink Retention Pond

- PMF Determination

RFR 22267A

Approve replacement for EFLIS0027/27A

Inspection Procedure 71111.04: Equipment Alignment

Condition Reports

200701435 200901558 201701338 201706207 201801283 201801316 201803443 201804144 201804154 201804197 201804204 201804251 Procedures

Number Title Revision APA-ZZ-00356 Pump and Valve Inservice Test Program

EDP-ZZ-01114 Motor Operated Valve Program Guide

EDP-ZZ-04107 HVAC Pressure Boundary Control

OSP-EG-0001A CCW Train A Valve Alignment Surveillance

OSP-GG-0005B B Train Fuel Building Negative Pressure Test

OTN-KC-00001, Addendum

Filling and Draining Fire Water Storage Tanks 7

Drawings Number Title Revision E-23EF02B Schematic Diagram ESW to SW System Isolation Valve

Miscellaneous Documents Number Title Revision Fire Preplan

Manual Various EF-15 Add 7 Essential Service Water System Fault Tree Model

RFR 22556 Clarify Note 3 on E

-23Al09 for Foxboro Contact

A RFR 23186B

Evaluate Using MOV

-Long-Life Grease on all MOVs

ULNRC-GG-001 Fuel Building Ventilation System

Inspection Procedure 71111.05AQ: Fire Protection Annual/Quarterly

Condition Reports

201801575 201802736 201803613 Procedures

Number Title Revision APA-ZZ-00750 Hazard Barrier Program

EDP-ZZ-04107 HVAC Pressure Boundary Control

FPP-ZZ-00009 Fire Protection Training Program

MTT-ZZ-00252 Installation of Flexible Fire Seals

Miscellaneous Documents

Number Title Revision Fire Preplan Manual

Various T66-1000 S Drill Planning and Authorization

Various Inspection Procedure 71111.06: Flood Protection

Condition Reports

201309387 201403831 201605812 201704709 201804053

Drawings Number Title Revision C-U203 ESWS Units 1 & 2 Electrical Manholes Plans, Sections & Detail 8 Miscellaneous Documents

Number Title MP 09-0049 Evaluate method of preventing water intrusion into manhole

MH01 Inspection Procedure 71111.11: Licensed Operator Requalification Program and Licensed Operator Performance

Condition Reports

200700956 200702502 200903732 201406048 201804776 201804779 Procedures

Number Title Revisio n APA-ZZ-00395 Significant Operator Response Timing

MPE-ZZ-QY054 Inspection and Test of Protective Lockout Relays, General Electric Type HEA

ODP-ZZ-00001 Operations Department

- Code of Conduct

104 ODP-ZZ-00003 Shift Relief and Turnover

Miscellaneous Documents

Title Date Annual Requalification Results Summary

July 6, 2018 Operations Night Orders

Inspection Procedure 71111.12: Maintenance Effectiveness

Condition Reports

201104544 201104651 201206896 201403496 201608165 201801489 201802184 Work Orders

397333

Procedures

Number Title Revision APA-ZZ-00296 Gas Intrusion Program

APA-ZZ-00500, Appendix 11

Degraded and Nonconforming Condition Resolution

EDP-ZZ-01128 Maintenance Rule Program

EDP-ZZ-01128, Appendix 2

Summary of SSC Performance Criteria

EDP-ZZ-01128, Appendix 4

Maintenance Rule System Functions

Drawnings Number Title M-22EG03 Piping and Instrument Diagram

- Component Cooling Water

Miscellaneous Documents Number Title EG-54 Allowable Gas Void Volume for Each Train of the Component Cooling Water Suction Piping

EG-55 Water Hammer due to Voids in Component Cooling Water System Piping

MP 10-0042 Install New CCW/Radwaste Flow Restriction Device

Inspection Procedure 71111.13: Maintenance Risk Assessments and Emergent Work Control Condition Reports

200706552 201011290 201705555 201706032 201707194 201804887 Work Orders

18000637 18002661 18507861

Procedures

Number Title Revision APA-ZZ-00322 Integrated Work Management Process Description

APA-ZZ-00322, Appendix F Online Work Integrated Risk Management

APA-ZZ-00356 Pump and Valve Insrvice Test Program

OSP-EJ-V001A Train A RHR Valve Inservice Test

OSP-EJ-P001A RHR Train A Inservice Test

OSP-GK-0001A A Train Control Room Filtration and Pressurization System Monthly Operability Verification

OSP-SA-0009B Train B CISA Slave Relay Test

Drawings Number Title Revision 8618-X-94080 One Line Diagram Metering and Relaying

345KV Differential and 345KV Bus

-A and B Pot. Devices

Miscellaneous Documents

Number Title RFR 019023A

Determine Retest Requirements for MDV41V511

Inspection Procedure 71111.15: Operability Determinations and Functionality

Assessments

Condition Reports

199400711 199701249 199901106 201010145 201801641 201804251 201804276 Work Orders

10002666 Procedures

Number Title Revision OTS-JE-00002 Filtration of Emergency D/G Fuel Oil

Inspection Procedure 71111.17T:

Evaluations of Changes, Tests and Experiments

Condition Reports

201403041 201601534 201603312 201608686 201700966 201702032 201703841 201704156 201707651 201802284 201803910 201803973 201804069 Calculations

Number Title Revision 81402-C-010 Design of Safety Related Pipe Supports for HCST Piping

81402-S-005 Pipe Stress and Support Load Evaluation of HCST Supply Line to Safety

-Related Auxiliary Feedwater System Suction 1 GK-19, Addendum

2016' Auxiliary Building Battery and SWBD room GOTHIC temperature analysis

GM-03 EDG Room Temperatures w/o HVAC

GM-03, Addendum

EDG Room Temperature Analysis With Both Air Supply Fans Unavailable

GM-03, Addendum

Inputs 3 GM-320 Diesel/Generators Building HVAC 0 GM-320, Addendum 2 Diesel Generator Building HVAC Update

M-FL-04, Addendum 6 Impact of MP 13

-0033 - Hardened Condensate Storage Tank Refuel 21 Tie

-Ins 2 NAI-1719-001 Callaway Control Building Loss of Class 1E A/C GOTHIC Room Heat Up Analysis

NAI-1719-001, Addendum 1 Control Building Temperature Analysis for Operability Evaluation

NAI-1719-002 Callaway Control Building with Control Room Loss of Class 1 E A/C GOTHIC Room Heat Up Analysis

NAI-1719-004 Callaway Control Building with Control

Room Loss of Class 1 E A/C GOTHIC Room Heat Up With Installed Fans and Louvers

NG-12 , Addendum 27 NG MCC Setpoint Calculation

NG-22, Addendum

NG Load Center Setpoint Calculation

Procedures

Number Title Revision APA-ZZ-00108 Primary Licensing Documents:

Change/Revision Process

APA-ZZ-00143 10 CFR 50.59 and 10 CFR 72.48 Reviews'

APA-ZZ-00600 Design Change Control

EDP-ZZ-04600 Engineering Change Control

ES-1.1 SI Termination

ES-1.1 SI Termination

ES-0.2 Natural Circulation Cooldown

ES-0.2 Natural Circulation Cooldown

ES-0.2 Natural Circulation Cooldown

ES-0.2 Natural Circulation Cooldown

FDP-ZZ-00103 License Document Change Process

IP-ENG-001 Standard Design Process

OTN-EF-0001 Essential Service Water System

OTN-EF-0001 Essential Service Water System

OTN-EF-0001 Essential Service Water System

ODP-ZZ-00002 Equipment Status Control

ODP-ZZ-00002 Equipment Status Control

ODP-ZZ-00002 Equipment Status Control

OTN-EB-00001, Addendum 1 Closed Cooling Water System

- Equipment Rotation and Controlling Temperature

OTN-EP-00001, Addendum 1 SI Accumulator Level Control

6, 7 OTN-EP-00001, Addendum 3 Initial Fill and Vent of SI Accumulators

8, 9 OTN-GK-00001 Control Building HVAC System

OTS-PA-00001 Operation and Testing of the Alternate Emergency Power Source 22 Drawings Number Title Revision 8600-X-90422 Storeroom 2 Power Plan Receptacles

8600-X-90424 Storeroom 2 Lighting Plan

EA04-H006-332 Pipe Supports, Service Water System Communication Corridor

EA04-H007-332 Pipe Supports, Service Water System Communication Corridor

EA04-H011-332 Pipe Supports, Service Water System Communication Corridor

E-009-00081 Metal-Clad Switchgear

- Title Sheet Electrical Diagram 9 E-009-00190 Metal-Clad Switchgear

- Indoor 7 E-009-00250 IM 13.8 KV Class 1E Potential Transformer Component 9 E-009-00252 Metal-Clad Switchgear

- Interconnection Diagram 7 E-009-00262 Metal-Clad Switchgear

- Equipment Summary 1 E-009-00339 AZZ Qualification Report for Frequency Relay ABB P/N 422C1276

E-018-00172 SZ 5 2SP-1WD Schematic

E-018-00223 Wiring Diagram 2SP

-1WD (SIZE 5)

E-21NK01 Class 1E 125V DC System

- Meter & Relay Diagram 17 E-21NK02 Class 1 E 125V DC System

- Meter & Relay Diagram 17 E-050-00006 Batteries

- 60 Cell NCN

-23 Layout ON

-2-S07-074530-816 Racks 13 E-050-00009 Layout For 60 Cell NCN

-13 Battery ON

-2-507-074520-816 Racks 10'

-0" LG 12 E-050-00032 Batteries

- NCX-NAX Typical Termination

Assemblies

E-U1NG01 Low Voltage System

- Class IE 480V Single Line Meter And Relay Diagram

E-U3EF02A Schematic Diagram

- Ultimate Heat Sink Cooling Tower Fans

GB01-H001-332 Pipe Supports, Central Chilled Water System Pumps Suction & Discharge 2 GB02-H003-332 Pipe Supports, Central Chilled Water System Pumps Suction & Discharge 1 M-22AL01(Q) Piping and Instrumentation Diagram Auxiliary Feedwater System

M-22EA01 Piping And Instrumentation Diagram Service Water System FSAR Figure 9.2

-1 Shee t 1 23 M-22EG02 Piping & Instrumentation Diagram Component Cooling Water System FSAR Figure 9.2

-3 Sheet 2 22 M-22EG22 Small Piping Isometric Component Cooling Water System Auxiliary Building Location 141

M-22GB01 Piping And Instrumentation Diagram Central Chilled Water System FSAR Figure 9.4

-10 18 M-23EA04 Piping Isometric

- Service Water System Comm. Corridor (Central Chillers)

M-23EG23 Small Piping Isometric Component Cooling Water System Auxiliary Building Location 142

M-29EG22 Hanger Location Dwg Small Pipe Component Cooling Water System Auxiliary Building Location 141

M-29EG23 Hanger Location Dwg. Small Pipes Component Cooling Water System Auxiliary Building Location 142

Miscellaneous Documents

Number Title Revision or Date 2005 ASHRAE Handbook Fundamentals

Callaway FSAR, Various Chapters

AABD 6.0 Callaway Energy Center Accident Analysis Basis Document Feedwater System Pipe Break

6A ANSI/IEEE C37.9

-1979 Test Procedure for AC High

-Voltage Circuit Breakers Rated on a Symmetrical Current Basis

EDN-01 Engineering Design Notice, MP 13

-0002 EDN-0 2 Engineering Design Notice, MP 13

-0002 IB 7.4.1.7

-5 ABB Circuit Shield Type 81 Series 422

, Vendor Manual IEEE Std 323-19 74 IEEE Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations

IEEE Std 450

-1995 IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead

-Acid Batteries for Stationary Applications

LTR-LIS-18-182 Attachment

1, Review of Mitigating Strategy for Stagnant/Voided

Loop as the Result of Asymmetric Natural Circulation

NUREG-0830, Supplement

No. 3 Safety Evaluation Report Related To The Operation Of Callaway Plant, Unit 1

RFR 15642 Formal Safety Evaluation

A, B RFR 201104353

Class 1E Electrical Equipment Survivability

RFR 201403041

Class 1E Electrical Equipment Survivability

STARS-ENG-5001-8.1 Replace EDG Fans CGM01A & B

September 4, 2012 STARS-ENG-5001-8.1 Hardened Condensate Storage Tank Refuel 21

T ie-Ins February 23, 2015 Inspection Procedure 71111.18: Plant Modifications

Condition Reports

201502453 201701626 201704103 201800905 201800917 201801692 201802679 Work Orders

11005902 11005918 15502053 17502428 Procedures

Number Title Revision EDP-ZZ-04600 Engineering Change Control

Miscellaneous Documents

Number Title Revision or Date CA2883 Technical Task Job Brief Checklist

June 8, 2016 LD-351023928-1 Masterpact Breaker

MP 07-0069 Replace 480V Load Center Circuit Breakers

NG-12 NG MCC Setpoint Calculation

SVP-133 Standard Verification Plan

TB-12-007 Masterpact Breakers Fail to Close

Inspection Procedure 71111.19: Post Maintenance Testing

Condition Reports

200408234 201801437 201803246 201803541 Work Orders

2501352 12002857 12003896 12508243 15000794 15511559 17501719 17502428 Procedures

Number Title Revision APA-ZZ-00322 App E

Post-Maintenance Test Program

MPE-NK-QB004 NK Class 1E Battery Charger Inspection

OSP-BB-00002 PZR Heater Capacity Test 9 OSP-SA-0009B Train A CISA Slave Relay Test

OTN-BB-00005 Pressurizer and Pressure Control

OTN-NK-00001 Add 2

25VDC Bus NK03 and Distribution System

OTN-PG-00001 480 VAC Non

-Class 1E Electrical System

OTO-ZZ-00012 Severe Weather

Drawings Number Title Revision E-23BB25 Pressurizer Heater Backup Group B Heater Grouping 1 Miscellaneous Documents

Number Title ULNRC Revise Ventilation System Surveillance Requirements to Operate for

Hours per Month

Inspection Procedure 71111.22: Surveillance Testing

Condition Reports

200600435 201001813 201206883 201804199 Work Orders

18003285 18504656

Procedures

Number Title Revision APA-ZZ-00340 Surveillance Program Administration

ISL-EF-00T67 Loop-TMP: ESW A Cool Twr Inlet and Pump Discharge Temperatures

OSP-EF-P001A ESW Train A Inservice Test

OSP-JE-P001B Train B Emergency Diesel Generator Fuel Oil System In-service Tests

Miscellaneous Documents

Number Title Revision AL-20 Evaluation of Tolerances for Fixed Parameters used in IST Pump Surveillances

ULDBD-EF-001 Essential Service Water System

Inspection Procedure

71151: Performance Indicator Verification

Condition Reports

201501431 Miscellaneous Documents

Title Revision NRC Performance Indicator Transmittal Report

Various Inspection Procedure

71152: Problem Identification and Resolution

Condition Reports

201705467 201705575 201800563 201800905 201801274 201801348 201801489 201801502 201801684 201801925 201802184 201802547 201803237 201803245 201803286 201803706 201803313 201803781 201803852 201804116 201804149 201804251 201804807 Work Orders

18002574

Miscellaneous Documents

Number Title Revision RFR 180142 Add Splice inside MH

59-50 and remove splice inside pull box between MH 59

-50 and MH 59

-51 to Cable CA

-3618 1 Inspection Procedure

71153: Follow

-up of Events and Notices of Enforcement Discretion

Condition Reports

201803580 Procedures

Number Title Revision APA-ZZ-00102 EOP/OTO Writer's Manual

E-3 Steam Generator Tube Rupture

ES-0.2 Natural Circulation Cooldown

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

Inspection Procedure

60855: Operation of an Independent Spent Fuel Storage Installation

and Inspection Procedure 60857: Review of 10 CFR 72.48 Evaluations

Condition Reports

201605802 201700196 201700328 201700621 201700649 201700652 201702372 201702969 201703274 201703295 201704069 201704732 201800292 201800328 201800713 201800920 201801469 201801531 201802109 201803118 201803195 201803220 201803274 201803310 20180402 201803404 201803406 201803430 201803434 201803457 201803464 201803465 201803559 Work Orders

15506408-500 15506409-500 15506643-500

Procedures

Number Title Revision 8 MC-GTAW Machine Gas Tungsten Arc Welding

APA-ZZ-00143 10 CFR 50.59 and 10 CFR 72.48 Reviews

APA-ZZ-00500 Corrective Action Program

APA-ZZ-01600 Dry Fuel Storage Program

ETP-ZZ-04020 Fuel Selection and Cask Loading for Dry Cask Storage 4 ETP-ZZ-04021 ISFSI Loading Campaign Performance

ETP-ZZ-04022 Pre-Operation Inspection

ETP-ZZ-04023 MPC Loading

ETP-ZZ-04024 MPC Sealing, Drying, and Backfill Operations

ETP-ZZ-04025 MPC Transfer

ETP-ZZ-04026 MPC Unloading

ETP-ZZ-04027 Responding to Abnormal Conditions

FDP-ZZ-00105 10 CFR 72.212 Report Maintenance

GQP-9.2 Liquid Penetrant Exam

GQP-9.6 Visual Examination of Welds

MSLT-MPC Helium Leak Test

Cal-1 MPM-KE-QH001 Cask Handling Crane Inspection

OSP-ZZ-00001 Control Room Shift and Daily Log Readings and Channel Checks

PI-CNSTR-OP Closure Welding MPC

Design Basis Documents

Number Title Revision CoC 10 40 Certificate of Compliance 1040 Holtec

HI-STORM UMAX Storage System

FSAR 1040 FSAR for Holtec HI

-STORM UMAX Storage System 2 FSAR 1032 FSAR for Holtec HI

-STORM FW Storage System 3 72.212 Callaway 10 CFR 72.212 Report

72.48 Applicability Determinations and 72.48 Screens

CA2510 CA3163 ECO-102-24 ECO-105-17 ECO-105-21 ECO-5018-75 ECO-5021-27 ECO-5021-29 ECO-5021-31 MP13-0009 MP 17-0007 1154R0 1229R0 1242R0 1285R0 Miscellaneous Documents Number Title Revision or Date 180000747Close

Specific Radiation Work Permit

180000747Trans

Specific Radiation Work Permit

180000747Trans

Specific Radiation Work Permit

18001046 Calibration Test Report

July 25, 2018

18001047 Calibration Test Report

August 1, 2018

ALARA Plan

2018 -ISFSI Project ALARA Package

CA-M-20180430-2 Survey of ISFSI Pad Quarterly Q217

April 30, 2018 DOC-104-209-105 MPC FW Lift Cleat Assembly Leased

March 27, 2018

ETP-ZZ-0420 Fuel Characteristics for Canister #7

-10 4 HSP-355 Periodic Inspection and Recertification of SLD

RWP-18DFS General Radiation Work Permit

TLD Data 2016 and 2017 ISFSI

Fence TLD Data

Initial Request

for Information

Quarterly Baseline Inspection

Callaway Plant

Inspection Report:

05000483/2018003

Inspection Dates: July

- September 30, 2018

Inspection Procedure:

IP 71111 series, IP 71151, IP 71152 Lead Inspector: Dan Bradley, Senior Resident Inspector Information Requested For 3 rd Quarter 2018 The following information

should be sent to the resident office in electronic format (Certrec IMS preferred)

to the attention

of Dan Bradley

by July 26, 2018. Please provide requested documentation electronically in "pdf" files, Excel, or other searchable formats, if possible. The information should contain descriptive

names and be indexed

or hyperlinked to facilitate ease of use. If requested documents are large and/or only hard copy formats are available, please inform the inspector for clarification

. Please provide the following information for the Component Coolin

g Water (EG) system

1. A list of all calculations and drawings associated with the selected system.

2. A list of condition reports associated with the selected system for the last 3 years.

3. A list of work orders associated with the selected system for the last 3 years, including all open work orders.

4. A list of any pre-existing evaluation

s or calculations with low design margins

for the selected system

. 5. A copy of the last 3 heat exchanger inspections including performance data for the selected system.

6. A list of maintenance rule components and functions; based on engineering or expert panel judgment, for the selected system

. 7. A list of maintenance rule functional failure evaluations for the last 3 years for the selected system.

8. A list of operating experience evaluations for the last 3 years for the selected system.

9. A list of all procedures and calculations that involve time-critical operator actions.

10. A list of permanent and temporary modifications performed in the past

years for the selected system. Include a list of any documents associated with

modifications such as:

calculations, specifications, vendor manuals, Final Safety Analysis Report, Technical

Specifications and Bases updates , updated procedures

, and maintenance and surveillance activities and procedures.

11. A list of root cause and apparent cause evaluations associated with component failures or design issues initiated/completed in the last 3

years for the selected system. 12. A list of any common

-cause failures of components in the last 3 years for the selected system. 13. An electronic copy of the design bases documents for the selected system

. 14. An electronic copy of the system health notebooks

for the selected system

. Additionally, please provide the basis documents used to compute or establish the following NRC Performance Indicators (PIs) for the most recent 4 quarters which data is available:

a) IE-01: Unplanned Scrams per 7000 Critical Hours

b) IE-03: Unplanned Power Changes per 7000 Critical Hours

c) IE-04: Unplanned Scrams with Complicatio

ns Inspector Contact Information:

Dan Bradley

Senior Resident

Inspector 573-676-3181 Dan.Bradley@nrc.gov

Mailing Address:

U.S. NRC Resident Inspector Office

201 NRC Road

Steedman, MO 65077

ML18295A01

SUNSI Review

By: NHT/RDR Non-Sensitive Sensitive Publicly Available Non-Publicly Available

Keyword: NRC-002 OFFICE SRI/DRP/B RI/DRP/B C:DRS/EB1 C:DRS/EB2 C:DRS/OP C:DRS/PSB2

NAME DBradley SJanicki TFarnholtz

GWerner VGaddy HGepford SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ DATE 10/19/18 10/16/18 10/09/2018

10/11/2018

10/9/18 10/15/18 OFFICE TL:DRS/IPAT

DNMS:FCDB C:DRP/B NAME GGeorge JKatanic NTaylor SIGNATURE /RA - HFreeman for/

/RA/ /RA/ DATE 10/09/2018

10/15/2018

10/19/2018