IR 05000483/2017008
| ML17277A053 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 10/03/2017 |
| From: | Taylor N H NRC/RGN-IV/DRP/RPB-A |
| To: | Diya F Ameren Missouri |
| Taylor N H | |
| References | |
| EA-12-049, EA-12-051 IR 2017008 | |
| Download: ML17277A053 (15) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 1600 E. LAMAR BLVD.
ARLINGTON, TX 76011-4511 October 3, 2017 Mr. Fadi Diya, Senior Vice President and Chief Nuclear Officer Ameren Missouri Callaway Plant P.O. Box 620 Fulton, MO 65251
SUBJECT: CALLAWAY PLANT
- INSPECTION OF THE IMPLEMENTATION OF MITIGATION STRATEGIES AND SPENT FUEL POOL INSTRUMENTATION ORDERS AND EMERGENCY PREPAREDNESS COMMUNICATION/ STAFFING/MULTI-UNIT DOSE ASSESSMENT PLANS
- INSPECTION REPORT 05000483/2017008
Dear Mr. Diya:
On September 1 , 201 7, the U.S. Nuclear Regulatory Commission (NRC) completed the onsite portion of an inspection at the Callaway Plant. On September 26, 2017 , the NRC inspectors discussed the results of this inspection with Ms. S. Banker, Senior Director, Engineering, and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.
The inspection examined activities conducted under your license as they relate to the implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049 and EA-12-051) and emergency preparedness communication s , staffing, and multi-unit/source dose assessment plans; your compliance with the Commission's rules and regulations; and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with station personnel.
The NRC inspectors did not identify any findings or violations of more than minor significance associated with this inspection.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading
-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA David Proulx Acting for/
Nicholas H. Taylor
, Chief Project Branch B Division of Reactor Projects Docket No. 50
-483 License No. NPF
-30
Enclosure:
Inspection Report 05000 483/20170 08 w/
Attachment:
Supplemental Information cc w/ encl: Electronic Distribution
1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket: 050004 83 License: NPF-30 Report: 05000483/2017008 Licensee: Union Electric Company Facility: Callaway Plant Location: Junction Highway CC and Highway O Steedman, Missouri Dates: August 28
- September 26, 2017 Inspectors:
R. Alexander, Sr. Project Engineer (Team Leader)
S. Alferink, Reactor Inspector D. Bradley, Sr. Resident Inspector
- Callaway M. Stafford, Project Engineer Approved By: Nicholas H. Taylor Chief, Project Branch B Division of Reactor Projects
2
SUMMARY
- 08/28/2017 - 09/26/2017; Callaway Plant
- Temporary Instruction 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans
, issued December 23, 2015.
The inspection covered a one-week inspection by the resident inspector and three inspectors from the Region IV office. No findings were identified. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG
-1649, "Reactor Oversight Process," Revision 5.
A. NRC-Identified and Self-Revealing Findings
None
B. Licensee-Identified Violations
None 3
REPORT DETAILS
4. Other Activities
4OA5 Other Activities
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
) and the NRC's plant safety evaluation (ADAMS Accession No. ML17010A332) and to verify that the licensees installed reliable water level measurement instrumentation in their spent fuel pools. The purpose of this TI is also to verify the licensees have implemented Emergency Preparedness (EP) enhancements as described in their site
-specific submittals and NRC safety assessments, including multi
-unit dose assessment capability and enhancements to ensure that staffing is sufficient and communications can be maintained during such an event.
The inspection verified that plans for complying with NRC Orders EA 049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond
-Design-Basis External Events
," (ADAMS Accession No. ML12229A174) and EA 051, "Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation
," (ADAMS Accession No. ML12056A044) are in place and are being implemented by the licensee. Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012
, request for information letter and multiunit dose assessment information provided per COMSECY-13-0010, "Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned," dated March 27, 2013 (ADAMS Accession No. ML12339A262).
The team discussed the plans and strategies with plant staff, reviewed documentation, and where appropriate, performed plant walk downs to verify that the strategies could be implemented as stated in the licensee's submittals and the NRC staff
-prepared safety evaluation. For most strategies, this included verification that the strategy was feasible, procedures and/or guidance had been developed, training had been provided to plant staff, and required equipment had been identified and staged. Specific details of the team's inspection activities are described in the following sections.
1. Mitigation Strategies for Beyond
-Design-Basis External Events
a. Inspection Scope
The team examined the licensee's established guidelines and implementing procedures for the beyond
-design-basis mitigation strategies. The team assessed how the licensee coordinated and documented the interface/transitio n between existing off
-normal and emergency operating procedures with the newly developed mitigation strategies. The team selected a number of mitigation strategies and conducted plant walk downs with licensed operators and responsible plant staff to assess: the adequacy and completeness of the procedures
, familiarity of operators with the procedure objectives 4 and specific guidance, staging and compatibility of equipment
, and the practicality of the operator actions prescribed by the procedures, consistent with the postulated scenarios.
The team verified that a preventive maintenance program had been established for the FLEX portable equipment and that periodic equipment inventories were in place and being conducted. Additionally, the team examined the introductory and planned periodic/refresher training provided to the Operations and Security staffs most likely to be tasked with implementation of the FLEX mitigation strategies. The team also reviewed the introductory and planned periodic training provided to the Emergency Response Organization personnel.
b. Assessment Based on samples selected for review, the team verified that the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is generally in compliance with NRC Order EA 049. The team verified that the licensee satisfactorily:
Developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX strategies for postulated external events
, Integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs are clear when using existing plant procedures
, Protected FLEX equipment from site
-specific hazards
, Developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability
, Trained their staff to assure personnel proficiency in the mitigation of beyond-design-basis events
, and Developed means to ensure that the necessary off
-site FLEX equipment will be available from off
-site locations
. The team verified that any non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.
c. Findings
No findings identified.
5 2. Spent Fuel Pool (SFP) Instrumentation
a. Inspection Scope
The team examined the licensee's newly installed spent fuel pool instrumentation. Specifically, the team verified the sensors were installed as described in the plant specific submittals and the associated safety evaluation and that the cabling for the power supplies and the indications for each channel are physically and electrically separated. Additionally, environmental conditions and accessibility of the instruments were evaluated. Documents reviewed are listed in the attachment.
b. Assessment Based on samples selected for review, the team determined that the licensee satisfactorily installed and established control of the SFP instrumentation as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is generally in compliance with NRC Order EA 051. The team verified that the licensee satisfactorily:
Installed the SFP instrumentation sensors, cabling and power supplies to provide physical and electrical separation as described in the plant specific submittal and safety evaluation
- Installed the SFP instrumentation display in the location, environmental conditions and accessibility as described in the plant specific submittals; and Trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation.
The team verified that any non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.
c. Findings
No findings identified.
3. Staffing and Communication Request for Information
a. Inspection Scope
Through discussions with plant staff, review of documentation and plant walk downs, the team verified that the licensee has implemented required changes to staffing, communications equipment
, and facilities to support an Extended Loss of All AC Power (ELAP) scenario as described in the licensee's staffing assessment and the NRC safety assessment. The team also verified that the licensee has implemented dose assessment (including releases from spent fuel pools) capability using the licensee's site-specific dose assessment software and approach as described in the licensee's dose assessment submittal. Documents reviewed are listed in the attachment.
6 b. Assessment The team reviewed information provided in the licensee's multi
-unit dose submittal and in response to the NRC's March 12, 2012, request for information letter and verified that the licensee satisfactorily implemented enhancements pertaining to Near
-Term Task Force Recommendation 9.3 response to a large scale natural emergency event that results in an extended loss of all ac power to the site and impedes access to the site.
The team verified the following:
Licensee satisfactorily implemented required staffing change(s) to support an ELAP scenario , Emergency preparedness communications equipment and facilities are sufficient for dealing with an ELAP scenario
, and Implemented dose assessment capabilities (including releases from spent fuel pools) using the licensee's site
-specific dose assessment software and approach.
The team verified that any non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.
c. Findings
No findings identified.
4OA6 Exit Exit Meeting Summary
On September 1, 2017, the team presented the on-site inspection results in a management debrief to T. Herrmann, Site Vice President
, and other members of the site staff. The inspectors confirmed that proprietary information examined during the inspection had been returned to the licensee. The team lead completed an exit meeting conducted with S. Banker, Senior Director, Engineering
, a nd other members of the site staff, via telephone on September 26, 2017 , to discuss the final results of the inspection.
ATTACHMENT: SUPPLEMENTA L INFORMATION
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- S. Abel, Director, Engineering Projects
- A. Alley, Engineering Program Supervisor
- S. Banker, Senior Director Engineering
- F. Bianco, Director, Nuclear Operations
- J. Cortez, Director, Training
- M. Covey, Manager, Operations
- B. Cox, Senior Director Nuclear Operations
- D. Farnsworth, Director, Work Management
- T. Herrmann, Site Vice President
- T. Holland, Shift Manager
- B. Huhmann, Regulatory Affairs Supervisor
- B. Jungmann, Director, Maintenance
- S. Kovaleski, Director, Engineering Design
- G. Kremer, Director, Engineering Programs
- M. McLachlan, Senior Director Plant Support
- K. Mills, Director, Engineering Systems
- T. Moser, Director, Nuclear Projects
- J. Nurrenbern, FLEX Program Enginee
r
- E. Olson, Director, Engineering Programs
- J. Patterson, Director, Nuclear Projects
- E. Ptasznik, Licensing Engineer
- S. Sandbothe, Director , Plant Support
- D. Stepanovic, Manager, Materials
NRC Personnel
- S. Janicki, Resident Inspector
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Closed 2515/191 TI Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi
-Unit Dose Assessment Plans
, issued December 23, 2015
LIST OF DOCUMENTS REVIEWED
Section 4OA5
- Other Activities Corrective Action Documents
- 201106180
- 201408448
- 201601716
- 201605315
- 201605701
- 201605787
- 201607008
- 201607646
- 201607894
- 201607938
- 201609168
- 201609286
- 201700008
- 201700079
- 201701274
- 201702320
- 201703278
- 201703911
- 201703920
- 201704462 201704470*
- 201704490*
- 201704488*
- 201704491*
- 201704499*
- 201704501*
- 201704502*
- 20170503* 201704509*
- 201704513*
- 201704514*
- 201704515*
- 201704539*
- 201704551*
- 201704552*
- - indicates corrective action document written by the licensee as a result of the NRC inspection
Procedures
- Number Title Revision
- APA-ZZ-00102 EOP/OTO Writers Manual
- APA-ZZ-00391 Beyond Design Basis (BDB) Program Document
- APA-ZZ-00391, Appendix 8
- Callaway Plant Final Integrated Plan
- APA-ZZ-00500 Corrective Action Program
- APA-ZZ-00500, Appendix 17
- CAP, Screening Process Guidelines
- ECA-0.0 Loss of All AC Power
- EDP-ZZ-04600 Engineering Change Control
- EIP-ZZ-01211 Accident Dose Assessment
- FSG-11 Alternate SFP Makeup and Cooling
- FSG-12 Alternate Containment Cooling
- FSG-13 Transition from FLEX Equipment
- FSG-14 Shutdown RCS Makeup
- FSG-3 Alternate Low Pressure Feedwater
- FSG-40 FLEX Support Guidelines Flowchart
Procedures
- Number Title Revision
- FSG-41 FLEX Emergency Communications
- FSG-43 Nitrogen and Instrument Air Strategy
- FSG-44 FLEX Diesel Fuel Strategy
- FSG-45 Temporary Ventilation, Lighting, and Power
- FSG-46 Mobile Water Purification Unit
- FSG-5 Initial Assessment and FLEX Equipment Staging
- FSG-50 Freeze Protection for ELAP Response
- FSG-51 Temporary Sump Pump Operation
- FSG-6 Alternate HCST Makeup
- FSG-7 Loss of Vital Instrumentation or Control Power
- FSG-9 Low Decay Heat Temperature Control
- IP-ENG-001 Standard Design Process
- ITL-EC-00L39
- LOOP-LVL; Spent Fuel Pool Lvl
- ITL-EC-00L59
- LOOP-LVL; Spent Fuel Pool Primary Level
- ITL-ED-00L60
- LOOP-LVL; Spent Fuel Pool Backup Level
- ODP-ZZ-00002 Equipment Status Control
- ODP-ZZ-00025 EOP/OTO User's Guide
- ODP-ZZ-00030 EOP Implementation Guide
- Parent/Model Work Orders Number Title Revision / Date
- 1008428
- FLEXP-HALE-1 (Flex Hale Pump)
- 6 month maintenance April 25, 2017
- 1008430
- FLEXP-HALE-1-FLEX P Hale Pump #1
- 12 month maintenance April 25, 2017
- 1008432
- FLEXP-HALE-1-FLEX P Hale Pump #1
- 36 month maintenance plan 0
- 1008589
- FLEXG-480-1-480 Volt FLEX Generator # 1
- 12 month June 21, 2017
- 1008591
- FLEXG-480-1-480 Volt FLEX Generator # 1
- 9 year maintenance plan
- Parent/Model Work Orders Number Title Revision / Date
- 1008643
- FLEXP-SFP-1-fLEX P SFP Pump # 1
- 36 month maintenance plan
- 1008645
- FLEXP-SFP-2-FLEX P SF? Pump # 2
- 6 month maintenance June 19, 2017
- 1008656
- FLEXP-SFP-1-FLEX P SFP Pump # 1 - 12 month maintenance June 20, 2017
- 1008678
- FLEXH-WATER-1-FLEX H Water #1
- 36 month electrical inspection plan 0
- 1008692
- FLEXP-AFW-1-FLEX AFW Pump #1
- 6 month battery inspection June 22, 2017
- 1008693
- FLEXP-AFW-1-FLEX AFW Pump #1
- 12 month functional test June 21, 2017
- 1008694
- FLEXP-AFW-1-FLEX AFW Pump #1
- 36 month functional test plan 0
- 1008712 Inventory FLEX Emergency Food and Water Supplies
- 12 month inspection August 18, 2017
- 1008807
- FLEXG-240-1-Kubota G1-11000 240 volt generator 1
- 6 month maintenance June 27, 2017
- 1008808
- FLEXG-240-1-Kubota G1-11000 240 volt generator 1
- 36 month maintenance plan
- 1008878
- FLEXT-COMMS-01-FLEX T Communications trailer # 1
- 6 month maintenance June 2, 2017
- 1008879
- FLEXT-COMMS-01-FLEX T Communications trailer # 1
- 36 month maintenance plan
- 1008967
- FLEXT-FUEL-0 1-FLEX I Fueling Trailer # 1
- 6 month maintenance June 2, 2017
- 1008968
- FLEXT-FUEL-0 1-FLEX I Fueling Trailer # 1
- 36 month maintenance plan
- 14000593.915
- Functional Test Passive Antenna Connection to Aux Building 2
Calculations
- Number Title Revision / Date 81402-C-001 Development of Enveloped Ground Motion Response Spectra for HCSTF Design
- 81402-C-013 Hardened Condensate Storage Tank Design
- 81402-C-014 Hardened Condensate Storage Tank Facility
- 81402-C-017 Qualification of Ring Net and Framing System for Tornado Missile Loads
- 95599-M-001 1974' Auxiliary Building Flooding Elevation
- CEC-CS-005-00 Liquefaction Resistance and Post
-Earthquake Settlement for ISFSI at Callaway Energy Center
- CN-PEUS-12-09 Callaway FLEX Battery Coping Analysis
- DAR-SEE-II-12-17 Evaluation of Alternate Coolant Sources for Responding to a Postulated Extended Loss of All AC Power at the Callaway Energy Center
- SC-670005-01 Superstructure Design Calculations
- SC-670005-03 Missile Impact Evaluation
- Z-1052-S-002 Robust Missile Barrier Calculation
Miscellaneous
- Documents/Reports Number Title Revision / Date
- Callaway Plant, Unit
- Safety Evaluation Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders
-12-051 February 2, 2017
- Control Room Operator Logs June 19 - 22, 2017
- NEI 12-02 Phase 2 Extended Loss of Alternating Current Power (ELAP) Emergency Response Organization (ERO) Staffing Analysis Report
- NANTeL Generic Basic FLEX Training
- NANTeL Generic Advanced FLEX Training
- LOCT Cycle 13
-4, 13-5, 14-2, 15-1, 15-2, 15-5 and 16-2 Training Documents
- NLOCT Cycle 13
-4, 13-5, 15-1, 15-2 and 15-6 Training Documents
- GET Plant Access Callaway
- I/C Fukushima Seminar
- 51-9242058-002 SAFER Response Plan for Callaway Energy Center November 5, 2015
Miscellaneous
- Documents/Reports Number Title Revision / Date
- APA-ZZ-00391, Appendix 7
- FLEX Validation Documentation
- 0.2
-12-051 1
- MP 15-0012 Engineering Disposition: HCST Tank, Protective Barrier System, Valve House, and Electrical Power
- 007 Self-Assessment
- 201720030-035 FLEX Program Compliance with NRC Requirements June 12, 2017
- Fukushima Event August 14, 2012 T62.1000.8
- Fukushima Modifications May 1, 2014
- T62.P100.6
- Introduction to Plant Emergency Conditions
- Part 2 October 28, 2013 T63.0630.8
- TRRQ
- 201309537 Westinghouse Guided Wave RADAR Spent Fuel Pool Level Indication System June 18, 2014
- T64.0340.8
- RP - Station Blackout July 18, 2013
- T64.0340.8
- RP - Fukushima Modifications July 21, 2015
- T64.0340.8
- RP - Temp Power to HPAC
- May 15, 2017
- T64.0340.8
- RP - Operating Experience July 24, 2012
- T64.0360.8
- Chemistry
- FLEX Debris Removal May 23, 2016
- T64.0360.8
- Chemistry
- FLEX Loss of Power January 14, 2014 T64.0360.8
- Chemistry
- Atmospheric Hazards July 17, 2015
- T64.0360.8
- Chemistry Continuing Training January 14, 2014 T67.0200.8
- 2016-2 Electrical Continuing Training August 1, 2016
- T68.SORI.5
- Crisis Leadership March 5, 2015
- SUNSI Review By:
- Yes
- No
- Non-Sensitive
- Sensitive
- Publicly Available Non-Publicly Available Keyword:
- NRC-002 OFFICE SPE:DRP/A PE:DRP/C RE:DRS/EB2
- SRI:DRP/B BC:DRP/B
- NAME RAlexander
- MStafford SAlferink DBradley NTaylor
- SIGNATURE /RA/ /RA-E/ /RA-E/ /RA-E/ /RA DProulx Acting for/
- DATE 09/27/17 10/03/17 09/28/17 09/28/17 10/03/17