ML25177A045
| ML25177A045 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 06/26/2025 |
| From: | James Drake NRC/RGN-IV/DORS/EB2 |
| To: | Diya F Ameren Missouri |
| References | |
| IR 2025010 | |
| Download: ML25177A045 (1) | |
See also: IR 05000483/2025010
Text
June 26, 2025
Fadi Diya, Senior Vice President
and Chief Nuclear Officer
Ameren Missouri
Callaway Plant
8315 County Road 459
Steedman, MO 65077
SUBJECT:
CALLAWAY PLANT - NOTIFICATION OF AN NRC FIRE PROTECTION
BASELINE INSPECTION (NRC INSPECTION REPORT 05000483/2025010)
AND REQUEST FOR INFORMATION
Dear Fadi Diya:
The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC),
Region IV staff will conduct a fire protection baseline inspection at the Callaway Plant in August
and September 2025. The inspection team will be comprised of two reactor inspectors from the
NRC Region IV office and one reactor inspector from the NRC Headquarters office. The
inspection will be conducted in accordance with Inspection Procedure 71111, Attachment
21N.05, Fire Protection Team Inspection, the NRCs baseline fire protection inspection
procedure.
The schedule for the inspection is as follows:
Information gathering visit (Remote): August 4 - 8, 2025
On-site inspection: August 25 - 30, 2025
Remote inspection: September 8 - 12, 2025
The purpose of the information gathering visit is to obtain information and documentation
needed to support the inspection and to become familiar with the fire protection program, fire
protection features, post-fire safe shutdown capabilities and plant layout. This will be completed
remotely with assistance from the resident inspectors.
The team lead will review the initial set of documents requested in the enclosure to select the
scope of structures, systems, and components for evaluation, and identify additional documents
needed to support the inspection. The enclosure to this letter provides an initial list of the
documents the team will need for review. We request that your staff transmit copies of the
documents listed in the enclosure to the NRC Region IV office for team use in preparation for
the inspection. Please provide this information so that it is available to the inspection team by
the dates listed in the enclosure.
F. Diya
2
During the inspection planning meeting(s), the team leader will discuss the following inspection
support administrative details: (1) office space size and location; (2) specific documents
requested to be made available to the team in their office spaces; (3) arrangements for reactor
site access (including radiation protection training, security, safety, and fitness for duty
requirements); and (4) the availability of knowledgeable plant staff and licensing organization
personnel to serve as points of contact during the inspection.
We request that personnel be available at the site during the inspection who are knowledgeable
regarding those plant systems required to achieve and maintain safe and stable plant
conditions, including the electrical aspects of the nuclear safety capability assessment, reactor
plant fire protection systems and features, and the station fire protection program and its
implementation.
PAPERWORK REDUCTION ACT STATEMENT
This letter contains mandatory information collections that are subject to the Paperwork
Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management and Budget (OMB)
approved these information collections (approval number 3150-0011). Send comments
regarding this information collection to the Information Services Branch, Office of the Chief
Information Officer, Mail Stop: T6 A10M, U.S. Nuclear Regulatory Commission, Washington,
DC 20555-0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the Desk Officer, Office
of Information and Regulatory Affairs, NEOB-10202, (3150-0011) Office of Management and
Budget, Washington, DC 20503.
PUBLIC PROTECTION NOTIFICATION
The NRC may not conduct nor sponsor, and a person is not required to respond to a request for
information or an information collection requirement unless the requesting document displays a
currently valid OMB control number.
This letter and its enclosure 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.
Your cooperation and support during this inspection will be appreciated. If you have questions
concerning this inspection or the inspection teams information or logistical needs, please
contact James Drake, the team lead inspector, in the Region IV office at (817) 200-1558, or
James.Drake@nrc.gov.
Sincerely,
James Drake, Senior Reactor Inspector
Engineering Branch 2
Division of Operating Reactor Safety
Signed by Drake, James
on 06/26/25
F. Diya
3
Docket No. 5000483
License No. NPF-30
Enclosure:
1.
Fire Protection Team Inspection Document Request
cc w/ encl: Distribution via LISTSERV
esmith@ameren.com
SUNSI Review
ADAMS:
Non-Publicly Available
Non-Sensitive
Keyword:
By: JFD
Yes No
Publicly Available
Sensitive
OFFICE
SRI:DORS/EB2
BC:DORS/EB2
NAME
JDrake
GWarnick
SIGNATURE
/RA/
/RA/
DATE
06/26/25
06/26/25
Enclosure
Fire Protection Team Inspection Document Request
The documents and information requested below should generally be made available to the
inspection team prior to the inspection. Electronic format is the preferred format, except where
specifically noted. If electronic files are made available via a secure document management
service, then the remote document access must allow inspectors to download, save, and print
the documents.
If a secure document management service is utilized, it is recommended that a separate folder
be used corresponding to each item listed below. It is recommended that multiple documents
within each folder be individually entered and also combined into a ZIP file which is uploaded
into the same folder. Documents should be identified by both document number and noun
name.
To allow review before the information gathering visit, the documents requested in items A.1
thru A.11 should be made available to the team no later than July 16, 2025.
Based on review of the documentation, the team leader will identify the scope for the inspection
prior to the end of the on-site information gathering visit or in-office review of the information
obtained.
This document request is based on typical documents that a generic plant might have. As such,
this generic document request is not meant to imply that any specific plant is required to have all
of the listed documents. It is recognized that some documents listed below may not be available
for your plant. In addition, the document titles listed below are based on typical industry
document names; your plant-specific document titles may vary.
To allow review before the on-site inspection week(s), all requested documents should be made
available to the team no later than July 21, 2025.
2
A.
DESIGN AND LICENSING BASIS DOCUMENTS
A.1
Post-fire Nuclear Safety Capability, Systems, and Separation Analysis (changes
since 2022)
A.2
Fire Hazards Analysis and/or NFPA 805 Design Basis Document (changes since
2022)
A.3
Fire Probabilistic Risk Assessment (PRA) Summary Document or full PRA
Document (changes since 2022)
A.4
NFPA 805 Transition Report, developed in accordance with NEI 04-02 (changes
since 2022)
A.5
Fire Risk Evaluations (i.e., NFPA 805 Section 2.4.3) (changes since 2022)
A.6
Plant Change Evaluations (i.e., NFPA 805 Section 2.4.4) (since 2022)
A.7
Facility Operating License. (changes since 2022)
A.8
A list of the ten most risk significant plant systems for core damage frequency
from the fire protection probabilistic risk assessment.
A.9
A list of the ten most risk significant plant systems for large early release
frequency from the fire protection probabilistic risk assessment.
A.10
Plant layout drawings which identify: (electronic format)
Plant fire area boundaries (changes since 2022)
Combustible control zone drawings (changes since 2022)
Areas protected by automatic fire suppression and detection (changes since
2022)
A.11
For recovery actions, provide the following:
Manual Action Feasibility Study (changes since 2022)
Operator Time Critical Action Program (changes since 2022)
Timelines for time-critical manual actions (changes since 2022)
Timeline validations
3
B.
GENERAL PLANT DESIGN DOCUMENTS
B.1
Piping and instrumentation diagrams (P&IDs) and legend list for components
used to achieve and maintain post-fire safe shutdown for the sample systems or
fire areas selected (electronic format). (changes since 2022)
B.2
Piping and instrumentation diagrams and legend list for fire protection systems,
including the fire water supply; water suppression sprinklers; and deluge,
gaseous suppression systems for the sample systems or fire areas selected
(electronic format). (changes since 2022)
B.3
AC and DC electrical system single line diagrams, from off-site power down to
the highest safety-related bus level (typically 4kV, EDG bus) (electronic format).
(changes since 2022)
B.4
Single line diagrams for motor control centers (MCCs) that supply post-fire
nuclear safety component loads for the sample systems or fire areas selected
(electronic format). (changes since 2022)
B.5
Equipment location drawings which identify the physical plant locations of post-
fire safety shutdown equipment for the sample systems or fire areas selected
(electronic format). (changes since 2022)
C.
CLASSIC FIRE PROTECTION
C.1
Copy of fire protection program implementing procedures (e.g., administrative
controls, surveillance testing, and fire brigade). (changes since 2022)
C.2
List, with descriptions, of calculations and engineering analyses, studies, or
evaluations for the fire protection system, including the fire water system.
(changes since 2022)
C.3
Last two completed surveillances of fire protection features for the sample
systems or features within the fire areas selected (detection, suppression,
damper inspections, damper tests, penetration inspections, barrier inspections,
etc.).
C.4
List, with descriptions, of routine tests, surveillances, and preventive
maintenance on fire pumps, including pump controllers and batteries. (changes
since 2022)
C.5
Last two completed annual fire pump pressure and flow tests with a complete
copy of the test procedure.
C.6
Last two completed monthly and/or quarterly fire pump tests with a complete
copy of the test procedure.
C.7
Last two completed fire water system flow tests and flushes with a complete copy
of the test procedure.
4
C.8
For Fire Brigade Drills, provide the following:
Last five fire brigade drill critiques
Last drill critique for a drill with off-site fire department support
Last unannounced drill critique
Last back-shift drill critique
Dates, shifts, and locations of unannounced drills for the last three years
Summary of any unsatisfactory drill performance items for the last three years
Last unannounced drill critique by a qualified individual independent of the
licensees staff
C.9
For fire brigade equipment provide the following:
Procedure for inventory and inspection (changes since 2022)
Most recent inspection and inventory results
C.10
Fire Brigade Qualifications, including self-contained breathing apparatus, (SCBA)
and training lesson plans.
C.11
Copy of the evaluation or analysis of the effects of fire suppression activities on
the ability to achieve the nuclear safety performance criteria for the sample
systems or fire areas selected demonstrating:
The automatic or manual actuation of a suppression system, due to a fire in a
single location, will not indirectly cause damage to the success path
The inadvertent actuation or rupture of a suppression system will not
indirectly cause damage to the success path
Adequate drainage for areas protected by water suppression systems
The hydrostatic rating of any floor penetration seals installed within the fire
areas that are credited with keeping water from leaking into fire areas below
C.12
Pre-fire plans for all fire areas. (changes since 2022)
C.13
Impairment Log (at start of inspection) for fire protection features that are out of
service.
C.14
List of penetration seal work, re-work, or installation activities, in the last three
years.
C.15
List of fire wrap work, re-work, or installation activities, in the last three years.
5
C.16
Fire protection system health reports for the two most recent quarters.
C.17
Fire protection program health reports for the two most recent quarters.
C.18
Licensee evaluations of industry operating experience concerning fire protection
issues completed in the last three years.
C.19
List of fire event analysis reports for the last three years.
C.20
Fire protection program requirement changes since 2022 (e.g., limiting conditions
for operation, surveillance test requirements) covered by technical specifications,
the technical requirements manual, the updated final safety analysis report,
procedures or similar documents.
C.21
Fire Protection System(s) Design Basis Document. (changes since 2022)
C.22
List of applicable NFPA codes and standards and issuance dates (i.e., codes of
record). (changes since 2022)
C.23
A list or document identifying any deviations from the NFPA codes of record.
C.24
Organization charts of site personnel down to the level of fire protection staff
personnel.
C.25
A contact list of key site personnel who will be supporting this inspection, giving
the office location and phone number.
C.26
The team would like to observe an unannounced fire brigade drill in the plant, if
possible, during the week of August 25, 2025. Please put us in contact with the
appropriate personnel for planning fire brigade drills during the information
gathering trip.
C.27
The team would like to perform a walkdown of the sample fire protection systems
and/or fire areas with fire protection personnel in the plant during the week of
August 25, 2025. Please put us in contact with the appropriate personnel for
planning the walkdowns during the information gathering trip.
D.
ELECTRICAL
D.1
Electrical system health reports for the two most recent quarters.
D.2
Surveillance procedures and last surveillance demonstrating operability of
components required for alternative shutdown.
E.
OPERATIONS
E.1
The team would like to perform a walkthrough of a sample of post-fire safe
shutdown procedures with qualified operators in the plant during the week of
August 25, 2025. Please put us in contact with the appropriate personnel for
planning the walkthroughs during the information gathering trip.
6
E.2
List, with descriptions, of licensed operator Job Performance Measures (JPMs)
for operator actions required to achieve and maintain post-fire safe shutdown.
E.3
List, with descriptions, of non-licensed operator training associated with non-
licensed operator actions to achieve and maintain post-fire nuclear safe
shutdown (including JPMs, in-field training walkdowns, simulations, or initial
qualification).
E.4
Lesson plans for post-fire safe shutdown training for licensed and non-licensed
operators.
E.5
Thermal hydraulic calculation or analysis that determines the time requirements
for time-critical manual operator actions. (changes since 2022)
E.6
Operating procedures to achieve and maintain post-fire safe shutdown from the
control room and requiring a control room evacuation. (changes since 2022)
E.7
For safe shutdown equipment and tools, provide the following:
Procedure for inventory and inspection (changes since 2022)
Most recent inspection and inventory results
E.8
List, with descriptions, of procedures that implement cold shutdown repairs.
(changes since 2022)
E.9
For cold shutdown repairs, if required, provide the following:
Procedure for inventory and inspection (i.e., needed tools, material, etc.)
(changes since 2022)
Most recent inspection and inventory results
F.
ADMINISTRATIVE CONTROL, OVERSIGHT, AND CORRECTIVE ACTION
PROGRAMS
F.1
Copies of procedures that control the configuration of the fire protection program,
features, and post-fire safe shutdown methodology and system design. Also,
copies of procedures that govern the implementation of plant modifications,
maintenance, and special operations and their impact on fire protection.
(changes since 2022)
F.2
List of open and closed condition reports for the fire protection systems for the
last three years.
F.3
List of open and closed condition reports associated with the post-fire safe
shutdown analysis for the last three years.
7
F.4
List of open and closed condition reports associated with operator actions to
achieve and maintain post-fire safe shutdown for the last three years.
F.5
List of open and closed condition reports associated with the fire protection
program including plant change evaluations, post-fire operating procedures
and/or training, timeline evaluations for operator actions, and supporting
engineering evaluations, analysis, or calculations for the last three years.
F.6
List of open and closed condition reports for emergency lighting units for the last
three years.
F.7
Self-assessments, peer assessments, and audits of fire protection activities for
the last three years.
F.8
Self-assessments, peer assessments, and audits of post-fire nuclear safety
capability methodology for the last three years.
F.9
Provide administrative procedures that control temporary modifications,
permanent plant changes, design changes, procedure changes, ageing
management changes, equivalency evaluations, suitability analyses,
calculations, commercial grade dedication, safety-security interface, and repairs.
F.10
Provide procedures that control the following: combustible controls, hot work,
monitoring, compensatory measures, and workarounds.
F.11
Last five hot work permits (at power).
F.12
Last five transient combustible permits (at power).
G.
Aging Management Program
G.1
Copies of the aging management programs applicable to fire protection including
but not limited to the following: (changes since 2022)
Fire Protection
Fire Water System
Aboveground Metallic Tanks
Buried and Underground Piping and Tanks
G.2
Copies of procedures, work orders, preventive maintenance tasks, or other
documents which implement the commitments made as part of the license
extension related to fire protection. (changes since 2022)
G.3
List of aging management activities related to fire protection performed to date.