callaway plant - nrc integrated inspection report 05000483 ... · 4 (3) auxiliary feedwater...

January 28, 2019

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 05000483/2018004 Dear Mr. Diya: On December 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Callaway Plant. On January 2, 2019, the NRC inspectors discussed the results of this inspection with Mr. B. Cox, Assistant Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report. NRC inspectors documented one finding of very low safety significance (Green) in this report. This finding involved a violation of NRC requirements. 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 this 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 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the Callaway Plant.

F. Diya 2

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, Branch Chief Project Branch B Division of Reactor Projects

Docket No. 50-483 License No. NPF-30 Enclosure: Inspection Report 05000483/2018004 w/attachments: 1. Documents Reviewed 2. Request for Information Quarterly Baseline Inspection 3. Request for Information Occupational Radiation Safety

Inspection

Enclosure

U.S. NUCLEAR REGULATORY COMMISSION Inspection Report

Docket Number: 05000483 License Number: NPF-30 Report Number: 05000483/2018004

Enterprise Identifier: I-2018-004-0006 Licensee: Union Electric Company Facility: Callaway Plant Location: 8315 County Road 459

Steedman, Missouri Inspection Dates: October 1, 2018 to December 31, 2018 Inspectors: D. Bradley, Senior Resident Inspector

S. Janicki, Resident Inspector B. Baca, Health Physicist E. Combs, Project Engineer P. Elkmann, Senior Emergency Preparedness Inspector H. Freeman, Senior Reactor Inspector D. Loveless, Senior Reactor Analyst J. Melfi, Project Engineer J. O’Donnell, CHP, Health Physicist

Approved By: N. Taylor

Chief, Project Branch B Division of Reactor Projects

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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 below.

List of Findings and Violations

Fuel Oil Filtration Renders Emergency Diesel Generator Inoperable Cornerstone Significance Cross-

cutting Aspect

Inspection Procedure

Mitigating Systems

Green NCV 05000483/2018004-01 Closed

None 71153— Follow-up of Events and Notices of Enforcement Discretion

The inspectors identified a Green, non-cited violation of Technical Specification 3.8.1, “AC Sources – Operating,” for the licensee’s failure to take required actions for an inoperable emergency diesel generator. Specifically, the licensee connected a non-safety, commercial-grade filtration skid to the emergency diesel generator fuel oil storage tank on two occasions for a maintenance activity. Each of these two occasions rendered the diesel generator inoperable due to the non-seismically qualified flow path and exposure to postulated tornado missiles. The duration of each period of inoperability exceeded the required actions and associated completion times to shutdown to Mode 3.

Additional Tracking Items

Type Issue number Title Inspection Procedure

Status

LER 05000483/2018-004-00 Violation of TS 3.8.1 “AC Sources – Operating”

71153— Follow-up of Events and Notices of Enforcement Discretion

Closed

URI 05000483/2014008-03 Emergency Diesel Generator Operability Evaluations using a 7-Day Mission Time

71152—Problem Identification and Resolution

Closed

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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. REACTOR SAFETY

71111.01—Adverse Weather Protection

Seasonal Extreme Weather (1 Sample)

The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures on November 26, 2018.

71111.04—Equipment Alignment

Partial Walkdown (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains: (1) Instrument air pressure control and check valves on October 2, 2018 (2) Essential service water train B on October 17, 2018 (3) Residual heat removal train A on November 6, 2018

71111.05AQ—Fire Protection Annual/Quarterly

Quarterly Inspection (4 Samples)

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

(1) Residual heat removal heat exchanger trains A and B, fire areas A-10 and A-9 on

October 10, 2018

(2) Instrument air compressors, fire area TB-1 on November 12, 2018

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(3) Auxiliary feedwater mezzanine and valve rooms including 2013’ elevation, fire area A-30 on December 9, 2018

(4) Transformer yard, fire area YD-1 on December 10, 2018

71111.06—Flood Protection Measures

Internal Flooding (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the control building 2047’ elevation on November 2, 2018.

71111.11—Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (1 Sample)

The inspectors observed and evaluated:

(1) Licensed operator continuing training in the simulator on October 1, 2018 (2) Licensed operator continuing training in the simulator on December 12, 2018 Operator Performance (1 Sample)

The inspectors observed and evaluated control room staff in the following evolutions:

(1) Emergent work on air conditioning unit SGK05B on November 6, 2018 (2) Deep backshift activities on November 16, 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) Governor oil systems for auxiliary feedwater and emergency diesel generators on

November 16, 2018

(2) Instrument air in-service testing and check valve predictive maintenance on December 12, 2018

71111.13—Maintenance Risk Assessments and Emergent Work Control (4 Samples)

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

(1) Elevated risk actions due to planned containment spray pump train A in-service testing during a switchyard breaker replacement on October 10, 2018

(2) Elevated risk actions due to planned emergency diesel generator and essential service water train B equipment outage on October 16, 2018

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(3) Elevated risk actions due to planned residual heat removal train B equipment outage on November 7, 2018

(4) Elevated risk actions due to planned control room air conditioning system modifications on November 23, 2018

71111.15—Operability Determinations and Functionality Assessments (4 Samples)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Ultimate heat sink cooling tower sump on October 24, 2018 (2) Refueling water storage tank and non-seismic connections on October 24, 2018 (3) Spent fuel cooling pump train B motor current evaluation on November 16, 2018 (4) Instrument air supply check valve single point vulnerability on November 21, 2018

71111.18—Plant Modifications (1 Sample)

The inspectors evaluated the service air compressor control and indication modification under modification package MP 08-0005 on October 22, 2018.

71111.19—Post Maintenance Testing (5 Samples)

The inspectors evaluated the following post-maintenance tests:

(1) Containment spray train B equipment outage on October 10, 2018

(2) Emergency diesel generator train B and essential service water train B equipment outage on October 17, 2018

(3) Residual heat removal train B equipment outage on November 7, 2018

(4) Atmospheric steam dumps equipment outage on November 28, 2018

(5) Essential service water isolation to air compressors equipment outage on December 14, 2018

71111.22—Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine (4 Samples)

(1) Centrifugal charging pump train A test on October 24, 2018

(2) Ultimate heat sink tower inlet and pump discharge temperatures test on October 31, 2018

(3) Alternate offsite power alignment circuit breaker and engineered safety features actuation systems testing on November 26, 2018

(4) Safety-related nitrogen pressure drop test on December 11, 2018

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71114.04—Emergency Action Level and Emergency Plan Changes (1 Sample)

The inspectors evaluated Revision 51 of the Callaway Radiological Emergency Response Plan on November 1, 2018. This evaluation does not constitute NRC approval.

RADIATION SAFETY

71124.01—Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (1 Sample)

The inspectors evaluated radiological hazards assessments and controls. Instructions to Workers (1 Sample)

The inspectors evaluated worker instructions. Contamination and Radioactive Material Control (1 Sample)

The inspectors evaluated contamination and radioactive material controls. Radiological Hazards Control and Work Coverage (1 Sample)

The inspectors evaluated radiological hazards control and work coverage. High Radiation Area and Very High Radiation Area Controls (1 Sample)

The inspectors evaluated risk-significant high radiation area and very high radiation area controls. Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample)

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

71124.03—In-Plant Airborne Radioactivity Control and Mitigation

Engineering Controls (1 Sample)

The inspectors evaluated airborne controls and monitoring. Use of Respiratory Protection Devices (1 Sample)

The inspectors evaluated respiratory protection. Self-Contained Breathing Apparatus for Emergency Use (1 Sample)

The inspectors evaluated the licensee’s self-contained breathing apparatus program.

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OTHER ACTIVITIES – BASELINE

71151—Performance Indicator Verification (4 Samples)

The inspectors verified licensee performance indicator submittals listed below:

(1) MS07: High Pressure Injection Systems (10/01/2017–09/30/2018)

(2) MS09: Residual Heat Removal Systems (10/01/2017–09/30/2018)

(3) OR01: Occupational Exposure Control Effectiveness Sample (10/01/2017–09/30/2018)

(4) PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences Radiological Effluent Occurrences Sample (10/01/2017–09/30/2018)


Semiannual Trend Review (1 Sample)

The inspectors reviewed the licensee’s corrective action program for trends in non-safety system interactions with safety-related systems and calculation margin tracking for safety-related systems that might be indicative of a more significant safety issue. Annual Follow-up of Selected Issues (3 Samples)

The inspectors reviewed the licensee’s implementation of its corrective action program related to the following issues:

(1) Containment spray train B room cooler circuit breaker failure under Condition Report 201805359 on October 29, 2018

(2) Non-safety components associated with safety-related ventilation systems under Request for Resolution 180048 and Condition Report 201806086 on October 31, 2018

(3) Debris removal capability associated with Callaway’s diverse and flexible mitigation strategies under Condition Report 201802046 on December 2, 2018

71153—Follow-up of Events and Notices of Enforcement Discretion

Licensee Event Reports (1 Sample)

The inspectors evaluated Licensee Event Report 2018-004-00, Violation of TS 3.8.1, “AC Sources – Operating,” and the licensee’s response on October 23, 2018, which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx.

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INSPECTION RESULTS

Fuel Oil Filtration Renders Emergency Diesel Generator Inoperable Cornerstone Significance Cross-cutting

Aspect Report Section

Mitigating Systems

Green NCV 05000483/2018004-01 Closed

None 71153— Follow-up of Events and Notices of Enforcement Discretion

The inspectors identified a Green, non-cited violation of Technical Specification 3.8.1, “AC Sources – Operating,” for the licensee’s failure to take required actions for an inoperable emergency diesel generator. Specifically, the licensee connected a non-safety, commercial-grade filtration skid to the emergency diesel generator fuel oil storage tank on two occasions for a maintenance activity. Each of these two occasions rendered the diesel generator inoperable due to the non-seismically qualified flow path and exposure to postulated tornado missiles. The duration of each period of inoperability exceeded the required actions and associated completion times to shutdown to Mode 3. Description:

On August 20, 2018, the licensee started job 16503286 to filter the train B emergency diesel generator fuel oil storage tank. This periodic maintenance task is performed on a 24-month frequency with the goal of ensuring the fuel oil is maintained at a high quality level. Procedure OTS-JE-00002, “Filtration of Emergency D/G Fuel Oil,” Revision 11, directs the use of a temporary filtration system. This non-safety, commercial-grade filtration skid was placed near the fuel oil storage tanks on ground elevation. The suction pathway required removal of a metal plug which sits above the buried fuel oil storage tank. After filtering the fuel oil, the diesel fuel is returned to the storage tank via connection on the side of the diesel building to complete the process loop. This temporary filtration skid is run for a minimum of 80 hours. Per Procedure OTS-JE-00002, the emergency diesel generator and associated fuel oil system remain operable during the evolution. On August 24, 2018, the inspectors toured the station and questioned this filtration activity. The inspectors noted there was no barrier impairment in place for the removal of the metal plug above the fuel oil storage tank that appeared to serve as a tornado missile shield. Further, the inspectors questioned the operability of the emergency diesel generator and fuel oil systems since they were connected to a non-safety, non-seismic temporary system. The inspectors noted there was no operator stationed at the filtration skid and no procedural reference to timeliness of response to isolate a leak for a design-basis earthquake. Step 3.10 of Procedure OTS-JE-00002 instead stations a security officer at the system stating, “If the filtration unit develops a leak, security should contact the control room.” The licensee completed the filtration activity shortly after the questions were raised and generated Condition Report 201804251 to resolve the NRC’s questions. The inspectors interviewed personnel regarding the process to filter fuel oil, reviewed the history of the filtration procedures, and reviewed recently completed jobs for fuel oil filtration. The inspectors concluded that the emergency diesel generator was inoperable during the fuel oil filtration activity for two reasons.

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First, the emergency diesel generator fuel oil system is described in Section 9.5.4 of the final safety analysis report as subject to General Design Criterion (GDC) 2 requiring that the systems withstand the effects of natural phenomena such as earthquakes. By connecting a non-safety, non-seismic temporary filtration system, the safety-related and seismically-qualified emergency diesel generator fuel oil system was now vulnerable to earthquakes. Specifically, the non-seismic hoses could fail and cause a loss of fuel oil. This loss of fuel oil had not been appropriately quantified or analyzed including operator response timeliness to maintain operability. Without adequate fuel oil, the emergency diesel generator would not be able to perform its specified safety function. Second, the metal hatch above the fuel oil storage tank was designed to serve as a tornado missile shield. By removing this protection without implementing administrative controls per Procedure APA-ZZ-00750, “Hazard Barrier Program,” Revision 41, the licensee was not appropriately validating and monitoring the appropriate weather conditions to remove the hatch. As a result, fuel oil storage tank components beneath the missile shield were now exposed to tornado-borne hazards that could render the fuel oil system unable to perform its specified safety function. Without adequate fuel oil, the emergency diesel generator would not be able to perform its specified safety function. The inspectors determined the emergency diesel generator was inoperable from August 20-24, 2018. The licensee, in parallel, determined the fuel oil filtration evolution rendered train B emergency diesel generator inoperable and documented the issue in Licensee Event Report 2018-004-00, “Violation of TS 3.8.1 ‘AC Sources – Operating,’” as a violation of technical specifications. As part of the cause evaluation, the licensee determined an additional violation of technical specifications occurred from February 29 through March 4, 2016, during a similar fuel oil filtration activity at that time on the train B emergency diesel generator fuel oil storage tank. No violations of technical specifications associated with the train A emergency diesel generator were identified. Although Procedure OTS-JE-00002 allowed both the connection of a non-seismic system to the safety-related fuel oil storage system and the removal of a tornado missile shield without administrative controls, the inspectors concluded that the licensee had codified this incorrect information into the procedure. The inspectors noted that the last significant review of Procedure OTS-JE-00002 occurred in 1999 and incorrectly concluded that continuous manning of the filtration skid by security did not require further evaluation for operator actions. The inspectors concluded that this error was not reflective of current performance. The inspectors concluded the licensee failed to take required actions for an inoperable emergency diesel generator. Specifically, the licensee connected a non-safety, commercial-grade filtration skid to the emergency diesel generator fuel oil storage tank on two occasions. Each activity rendered the diesel generator inoperable due to the non-seismically qualified flow path and exposure to postulated tornado missiles. The duration of each period of inoperability exceeded the required actions and associated completion times to shutdown to Mode 3. The two occasions of identified inoperability were from February 29 to March 4, 2016, and from August 20-24, 2018.

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Corrective Actions: The licensee initiated condition reports and prohibited further fuel oil filtration activity pending corrective actions. Corrective Action References: Condition Reports 201804251 and 201804276. Performance Assessment:

Performance Deficiency: The failure to take required actions for an inoperable emergency diesel generator was a performance deficiency. Screening: The inspectors determined the performance deficiency was more than minor, and therefore a finding, because it adversely affected the configuration control 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 (i.e. core damage). Specifically, the licensee connected a non-safety, commercial-grade filtration skid to the emergency diesel generator fuel oil storage tank on two occasions for a maintenance activity. Each of these two occasions rendered the diesel generator inoperable due to the non-seismically qualified flow path and exposure to postulated tornado missiles. The duration of each period of inoperability exceeded the required actions and associated completion times to shutdown to Mode 3. Significance: The inspectors screened this finding utilizing 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,” and Exhibit 4, “External Events Screening Questions,” dated June 19, 2012. The inspectors determined that the finding required a detailed risk evaluation because the finding involved the loss or degradation of equipment that was specifically designed to mitigate a seismic or severe weather initiating event, and if this equipment were assumed to be completely failed, the loss of this function, by itself, would degrade one or more trains of a system that supports a risk significant system or function during these external initiating events. Specifically, as reported in Licensee Event Report 2018-004-00, “Violation of TS 3.8.1 ‘AC Sources – Operating,’” the train B emergency diesel generator would have been unable to perform its intended function following a seismic event or strike by a tornado-generated missile when the fuel oil system was connected to the fuel oil filtration skid on two occasions. The senior reactor analyst performed a bounding risk evaluation for the performance deficiency and determined that the finding was of very low safety significance (Green). The analyst assumed that the only vulnerabilities to the fuel transfer system were seismic events or tornado-generated missiles. The following two bounding analyses were performed: High Winds:

The risk increase from external events related to wind that could result in a non-recoverable loss of offsite power had more than a negligible impact. A Category EF2 or greater tornado could result in loss of the offsite power lines that would not be quickly repairable. The analyst obtained the frequency of a Category EF2 tornado occurring onsite using the data developed by the Office of Nuclear Reactor Research utilizing the methodology from NUREG/CR-4461, “Tornado Climatology of the Contiguous United States,” Revision 2.

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The analyst used the frequency for high winds represented by an EF2 Tornado (TIFEF2) from data developed by the Office of Nuclear Reactor Research. For the Callaway Plant, this frequency was 7.22 x 10-5/year. Over the maximum 106-hour exposure period, the probability of a Category EF2 tornado touching down at the site was 8.74 x 10-7. Using the methods described in NUREG/CR-2944, the analyst determined the conditional probability of a tornado-generated missile strike, given the following assumptions:

1. The estimated area of strike that could potentially disable the emergency diesel generators with the oil filtration skid attached was approximately 2 ft2

2. Given the location and type of site, the estimated number of missiles available would be 30,000

3. The Ψ for a small target area was used (2.8 x 10-10 missiles/ft2)

This resulted in a conditional missile strike probability of 1.70 x 10-5. Therefore, the upper bound of the incremental conditional core damage probability was 1.49 x 10-11. Seismic Events: The dominant risk from a postulated seismic event occurs when the event is large enough to destroy the switchyard insulators causing a non-recoverable loss of offsite power. The analyst made the bounding assumption that this event would also damage the oil filtration skid in such a manner that the train B emergency diesel generator would fail from lack of fuel oil. The analyst calculated the likelihood of a seismically-induced loss of offsite power using the seismic hazard for the Callaway Plant and the methods described in the Risk Assessment of Operational Events Handbook, Volume 2, “External Events,” Revision 4. The analyst quantified this frequency over the range of the seismic hazard and determined the frequency of a seismically-induced loss of offsite power at the Callaway Plant was 3.48 x 10-5/year. Over the maximum 106-hour exposure period, the probability of a seismically-induced loss of offsite power at the site was 4.21 x 10-7. Given that the oil filtration skid only affected one train of emergency power at a time, by administrative control, the analyst determined qualitatively that the incremental conditional core damage probability would be less than 1 x 10-7 because of the low probability of the train A diesel generator being unavailable and/or unreliable. Cross-cutting Aspect: The finding did not have a cross-cutting aspect since the last significant review of Procedure OTS-EJ-00002 was in 1999. The associated performance deficiency is not reflective of current performance. Enforcement:

Violation: Technical Specification 3.8.1, “AC Sources – Operating,” requires, in part, that two diesel generators capable of supplying the onsite Class 1E power distribution subsystems shall be operable in Modes 1, 2, 3, and 4. Technical Specification 3.8.1, Condition B, requires, in part, that if one diesel generator is inoperable, then restore the diesel generator to operable status within 72 hours. Technical Specification 3.8.1, Condition G, states, in part, that if the required action and associated completion time of Condition B is not met, then be in Mode 3 in 6 hours and Mode 5 in 36 hours.

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Contrary to the above, from February 29 through March 4, 2016, and from August 20 through August 24, 2018, the train B diesel generator was inoperable due to use of a non-seismically qualified filtration activity and exposure to postulated tornado missiles. Action was not taken to place Callaway Plant in Mode 3 within 6 hours and Mode 5 within 36 hours as required by Technical Specification 3.8.1, Required Actions G.1 and G.2. Disposition: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Observation 71152—Problem

Identification and Resolution

The inspectors reviewed the licensee’s corrective action program, performance indicators, system health reports, and other documentation to identify trends that might be indicative of a more significant safety issue for non-safety system interactions with safety-related systems and calculation margin tracking for safety-related systems. The inspectors evaluated procedures where temporary and permanent non-safety systems are connected to safety-related systems for maintenance or operational tasks. The inspectors’ efforts included an initial extent of condition review for the fuel oil filtration non-cited violation documented in this report and checked for tasks that could challenge the operability of mitigating equipment. The licensee also performed an extent of condition review including procedurally controlled temporary modifications. The following issues were identified that did not rise to the level of an inspection finding:

• Condition Report 201806086 documented two locations where failure of non-safety ventilation instrumentation plugs could cause diversion of flow used in safety-related ventilation, but only minimally impacted available calculation margin

• Condition Report 201806273 documented instrumentation test box equipment installation on ultimate heat sink cooling tower components and administrative controls of test equipment while briefly bypassing automatic signals during surveillance tests

• Condition Report 201805139 documented the chemistry process for treating sections of essential service water supply piping where a non-safety, temporary piping rig is briefly connected to add chemicals

• Condition Report 201805523 documented the periodic functional check of sump pumps for the emergency diesel generator room by briefly draining essential service water from the jacket water heat exchanger

• Condition Report 201805205 documented the periodic testing of check valves in the boron injection header using a temporary pump during refueling outages

• Condition Reports 201806414 and 201804251 documented the licensee’s extent of condition review for procedurally controlled temporary modifications including the issues documented above

The inspectors determined the licensee performed an appropriate review including scope and depth. The inspectors noted the licensee did not identify a trend and that the issues identified had minimal impact, on the scale of minutes, to challenge the operability of systems.

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The inspectors also reviewed calculation margin in safety-related systems, such as fluid leakage, and the methods of tracking challenges to that margin. The inspectors noted that condition reports were appropriately being generated for individual deficiencies and the inspectors were further reviewing any aggregation efforts performed of those condition reports. The inspectors did not identify a trend associated with tracking of margin for these safety-related systems. The inspectors noted the following observations:

• Essential service water deficiencies are tracked in a system engineering spreadsheet, owned by engineering, and tracked to the milliliter per minute level of detail. This system has been identified as having low margin.

• Emergency diesel generator fluid systems (jacket water, fuel oil, lubrication oil) deficiencies are not explicitly tracked in an aggregate tracker due to a large available margin. Instead, the licensee utilizes a white paper that documents the significant margin in those diesel fluid systems and this document is owned by engineering. The inspectors did not identify any aggregate issues that would challenge the calculated margin of fluids.

• Safety-related ventilation deficiencies are tracked in the equipment out of service log system, owned by operations, and tracked to the square inch level of detail for openings in ventilation boundaries. These systems have a moderate amount of margin.

• In general, operations receives accurate information on open deficiencies in fluid systems and references them in immediate or prompt operability determinations.

• The methods used to track issues vary from system to system and are not standardized in procedures.

• The most robust tracking system is using equipment out of service log software since it is also used to track technical specification entries, requires software permissions to edit, and is integrated with the work management software to validate when individual deficiencies/condition reports are corrected.

• The other methods of tracking are vulnerable to additional human performance errors since there is no procedural requirement to update or track the deficiencies including resolution.

• Overall, the tracking methods have worked for the licensee and the inspectors did not identify any issues or condition reports that would have challenged calculated margin for these safety-related fluid systems.

The inspectors verified that all issues were addressed within the scope of the corrective action program and that the completed and planned corrective actions were appropriate to correct the identified causes. The inspectors did not identify any trends or concerns that might be indicative of a more significant safety issue for non-safety system interactions with safety-related systems and calculation margin tracking for safety-related systems.

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Unresolved Item (Closed)

Emergency Diesel Generator Operability Evaluations using a 7-Day Mission Time URI 05000483/2014008-03


Description:

In 2014, the biennial problem identification and resolution inspection team identified an issue concerning the licensee’s use of a 7-day mission time for performing operability determinations of the emergency diesel generators as written in Procedure APA-ZZ-00500, Appendix 1, “Operability and Functionality Determinations,” Revision 22. The team also noted that while the design basis accidents, as described in Final Safety Analysis Report, Chapter 15, were analyzed out to 30 days, Section 3.1.2 “Additional Single Failure Assumptions,” stated in part that “all offsite power is simultaneously lost and is restored within 7 days.” The team requested clarification from the Office of Nuclear Reactor Regulation in Task Interface Agreement 2014-10 (non-public ADAMS Accession Number ML15089A455) as to whether the licensee should be performing operability determinations using a 7-day or a 30-day mission time. On October 19, 2018, the Office of Nuclear Reactor Regulation provided clarification in a letter from Kathryn M. Brock, Deputy Director, Division of Operating Reactor Licensing, to Jeffrey A. Clark, Deputy Director, Division of Reactor Safety, Region IV (ADAMS Accession Number ML16081A395). In summary, the letter stated that the NRC staff has reviewed the matter and has determined that, although “EDG mission time” is not a term used in Callaway's licensing basis documents, the Callaway Final Safety Analysis Report does assume in designing for and analyzing for a design basis accident, that all offsite power is restored within 7 days. Therefore, based on this clarification, the inspection team determined that the licensee’s use of a 7-day mission time for operability determinations of the emergency diesel generators at Callaway Plant was acceptable. Corrective Action Reference: The licensee documented the NRC’s response to Task Interface Agreement 2014-10 in Condition Report 201805611 to determine whether any additional actions were necessary based upon this determination.

EXIT MEETINGS AND DEBRIEFS

On November 9, 2018, the inspectors presented the radiation protection baseline inspection results to Mr. B. Cox, Assistant Site Vice President, and other members of the licensee staff. The inspectors verified no proprietary information was retained or documented in this report. On December 13, 2018, the inspector presented the changes to the Radiological Emergency Response Plan inspection results to Mr. G. Rausch, Manager, Emergency Preparedness, and other members of the licensee staff. The inspectors verified no proprietary information was retained or documented in this report. On January 2, 2019, the inspectors presented the quarterly resident inspection results to Mr. B. Cox, Assistant Site Vice President, and other members of the licensee staff. The inspectors verified no proprietary information was retained or documented in this report.

Attachment 1

DOCUMENTS REVIEWED

Inspection Procedure 71111.01: Adverse Weather Protection Condition Reports

199900950 201207346 201309159 201500260 201508329 Procedures

Number Title Revision

OTN-GF-00001 Miscellaneous Building HVAC Systems 9

OTN-QJ-00003 Plant Freezer Protection Heat Tracing Procedure 3

OTS-ZZ-00007 Plant Cold Weather 35 Miscellaneous Documents


ULDBD-GF-001 Miscellaneous Buildings HVAC 20 Inspection Procedure 7111104: Equipment Alignment Condition Reports

2007410451 201102524 201102992 201204392 201204937 Procedures


APA-ZZ-00304 Control of Callaway Equipment List 43

APA-ZZ-00395 Significant Operator Response Timing 29

EDP-ZZ-07001 Cable Management Program 4

OSP-KA-V0002 Instrument Air Supply to Containment Isolation Inservice Valve Test

16

OSP-KA-V0003 Nitrogen Accumulator Inservice Leak Test 30

OTN-KA-00001 Compressed Air System 27

OTS-ZZ-00004 Plant Cooldown with Loss of Instrument Bus 13 Drawings


M-22KA01 Compressed Air System 35

M-22KA07 Compressed Air 5 System SKIDS CKA01A, CKA01B, CKA01C

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A1-2

Miscellaneous Documents

Number Title Date

RFR 06571A Cable Storage in Room 1408 December 12, 1989 Inspection Procedure 71111.05AQ: Fire Protection Annual/Quarterly Condition Reports

200905202 201207181 201704747 201800785 Procedures


APA-ZZ-00700 Fire Protection Program 25

EIP-ZZ-00226 Fire Response Procedure for Callaway Plant 20

ODP-ZZ-00002, Appendix 3

Risk Management Actions for Fire Risk Systems and Components

3

Drawings


M-2Y1311D Penetration Closure Schedule Auxiliary Building 2 Miscellaneous Documents

Number Title Revision or Date

Fire Preplan Manual Various

KC-43 Code Compliance Evaluation NFPH 805 0 Inspection Procedure 71111.06: Flood Protection Condition Reports

201806879 Procedures


MDP-ZZ-E0001 Cable Installation Procedure 17

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Fire Preplan Manual 38

AMN-010-CALC-002 Flood Level in Control Building Rooms Due to Pipe Break or Crack

0

ARC-922 Review of Door Pressure Retention Limits 1

M-FL-08 Determine Flood Levels in Control Building Rooms 6A Inspection Procedure 71111.11: Licensed Operator Requalification Program and Licensed Operator Performance Condition Reports

201801352 201804072 201804099 Work Orders

18509216 Procedures


ODP-ZZ-00001 Operations Department – Code of Conduct 104 Miscellaneous Documents


T61.0810 8 LOCT Guide Various Inspection Procedure 71111.12: Maintenance Effectiveness Condition Reports

201009936 201501242 201601339 201607870 201801292

201804823 Work Orders

15503300 18506414 Procedures


APA-ZZ-00320 Work Execution 68

APA-ZZ-00356 Pump and Valve Inservice Test Program 25

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Procedures


EDP-ZZ-01131 Plant Health and Performance Monitoring Program 28

EDP-ZZ-01131, Appendix O

Single Point Vulnerabilities 7

MDP-ZZ-L0001 Lubrication Program 18 Drawings


M-22KA01 Compressed Air System 35 Miscellaneous Documents


Oil Analysis Results Various

RFR 160853 Mobil 1 10w30 Synthetic Formula Change December 6, 2016

E190.0074 Inservice Testing Program 33 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


APA-ZZ-00322, Appendix F

Online Work Integrated Risk Management 17

OSP-EN-P001B Train B Containment Spray Pump Inservice Test 50

OSP-EN-V001B Train B Containment Spray Valve Operability 23 Miscellaneous Documents


MP 17-0005 Essential Service Water Hammer Mitigation Modification 0

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Inspection Procedure 71111.15: Operability Determinations and Functionality Condition Reports

199701249 201010145 201805501 Procedures


OSP-EN-P001A Train A Containment Spray Pump Inservice Test 48 Miscellaneous Documents


10-05 50.59 Evaluation: Operator Actions Evaluated in RFR 201011371

1

Inspection Procedure 71111.18: Plant Modifications Condition Reports

200705593 201802044 201802489 Work Orders

05110017 07004589 07006226 Procedures


EDP-ZZ-01131, Appendix O

Single Point Vulnerabilities 7

Drawings


M-22KA01 Piping and Instrument Diagram – Compressed Air System Sheet 1

35

M-22KA05 Piping and Instrument Diagram – Compressed Air System Sheet 5

16



J-600A General Service Control Valves 18

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KA-37 Backup Nitrogen Supply System Design Pressure losses

0

RFR 200509242 KAPCV0104 Replacement 0 Inspection Procedure 71111.19: Post Maintenance Testing Condition Reports

201805238 2018005245 201805251 Work Orders

10502280 14503672 15510773 15511793 17505326

17505391 17505614 17506205 18002227 18504221

18004612 Procedures


APA-ZZ-00322, Appendix E

Post-Maintenance Test Program 12

ISF-ZZ-00P44 Essential Service Water Train B Flow to Air Compressor B

22

OSP-AB-V002A Steam Generator Atmospheric Steam Dump Valves Inservice Test

45

Inspection Procedure 71111.22: Surveillance Testing Condition Reports

201406773 201408096 201604473 201704959 201804199

201805560 201805563 Work Orders

18003285 18507920 18508476 18508478 S719677 Procedures


ISL-EF-00T67 Loop Temperature: Essential Service Water A Cool Tower Inlet and Pump Discharge Temperatures

7

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OSP-BG-P005A Centrifugal Charging Pump A Inservice Test 50

OSP-KA-V0003 Nitrogen Accumulator Inservice Leak Rate Test 30 Miscellaneous Documents


ODP-ZZ-00002 Equipment Status Control 91

ODP-ZZ-00004 Locked Component Control 43

OSP-SA-2413A Train A Diesel Generator and Sequencer Testing 27 Inspection Procedure 71124.01: Radiological Hazard Assessment and Exposure Controls Procedures


APA-ZZ-00014 Conduct of Operations - Radiation Protection 24

APA-ZZ-01000 Callaway Energy Center Radiation Protection Program 45

APA-ZZ-01004 Radiological Work Standards 31

HDP-ZZ-01500 Radiological Postings 47

HDP-ZZ-03000 Radiological Survey Program 46

HDP-ZZ-03000, Appendix A

Frequency and Location of Routine Radiological Surveys

14

HDP-ZZ-03000, Appendix B

Performing Radiation Surveys 12

HDP-ZZ-03000, Appendix C

Performing Contamination Surveys 7

HDP-ZZ-03000, Appendix D

Performing Airborne Radioactivity Surveys 9

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

HTP-ZZ-01203 Radiological Area Access Controls 56

HTP-ZZ-02004 Control of Radioactive Sources 39

HTP-ZZ-06001 High Radiation/Locked High Radiation/Very High Radiation Area Access

51

HTP-ZZ-06028 Radiological Controls For Pools That Contain or Store Spent Fuel

9

HTP-ZZ-06034 Resin Sluice 11

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Audits and Self-Assessments

Number Title Date

201600059-20 HRA/LHRA/VHRA Controls October 28, 2016

201820044-64 NRC Pre Inspection Self-Assessment Radiation Safety ALARA Planning and Occupational Dose Assessment June 14, 2018

AP17001 Nuclear Oversight Audit of Radiation Protection AP17001

February 28, 2017

Condition Reports

201705741 201705800 201706423 201706633 201706639

201706643 201706748 201707085 201801202 201802892

201803330 201804818 201805484 Radiation Work Permits


17500901 Primary Resin Change Out/Sampling of Low Dose RW Demineralizers including RP Support and Post Sluice Surveys

0

18BRHREE Electrical Maintenance Activities During the B RHR TSO. Includes work on EJHV8804B, EJFCV0611, and DPEJ01B.

0

18BRHRIC I&C Maintenance Activities During the B RHR TSO. Includes work on EJHV8804B, EJFCV0611, and DPEJ01B.

0

18BRHRMISC Miscellaneous Work Group Activities During the B RHR TSO

0

18BRHRMM Mechanical Maintenance Activities During the B RHR TSO

0

18BRHRSCAFF Build, Remove and Inspect Scaffolds During the B RHR TSO

0

18RP Radiation Protection On-Shift and Routine Activities 1 Radiation Surveys

CA-M-20170621-3 CA-M-20171204-3 CA-M-20180605-1

CA-M-20180823-13 CA-M-20180829-7 CA-M-20180918-6

CA-M-20181005-8 CA-M-20181010-4 CA-M-20181023-4

CA-M-20181023-5 CA-M-20181031-1

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ALARA Packages


18-10120 092018 RB Entry 0

18-ISFSI Project Dry Cask Campaign 0 Miscellaneous Documents

Title Date

Non-Special Nuclear Material RAM Stored in the Spent Fuel Pool (PM1002835)

October 9, 2018

Radioactive Sources Requiring Leak Check January 5, 2017

Radioactive Sources Requiring Leak Check July 3, 2017

Radioactive Sources Requiring Leak Check January 12, 2018

Radioactive Sources Requiring Leak Check July 27, 2018

Source Inventory November 6, 2018 Inspection Procedure 71124.03: In-Plant Airborne Radioactivity Control and Mitigation Procedures


APA-ZZ-00340, Appendix 4

Survey Frequency Control Program STI List 7

APA-ZZ-00500 Corrective Action Program 70

APA-ZZ-04136-DTI-PING-APANTEC-OP

APANTEC PING-1A Continuous Air Monitoring Operation

3

EDP-ZZ-01120 Ventilation Filter Testing Program 9

ESP-GK-03001 FGK01A Charcoal Test Canister Removal and Lab Testing

20

ESP-GK-03010 FGK01A In-Place Bypass Leakage Test 10

ESP-UB-03001 FUB7001 Charcoal Test Canister Removal and Lab Testing

18

ESP-UB-03012 FUB7001 In-Place Bypass Leakage Test 4

ETP-ZZ-03004 In-Place Bypass Leakage Testing of Absorber Stage 10

ETP-ZZ-03005 In-Place Bypass Leakage Testing of HEPA Filters 10

HDP-ZZ-08000 Respiratory Protection Program 23

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Procedures


HTP-ZZ-08203-DTI-REGULATORS

Testing Scott Regulators and Respirators Using the Biosystems PosiChek 3 USB Tester

10

HTP-ZZ-08300-DTI-AIRPAK75

SCOTT AIR-PAK 75 SCBA Respirator Inspection and Storage

16

HTP-ZZ-08300-DTI-POST HYDRO

Post Hydrostatic Testing of Breathing Air Cylinders 5

HTP-ZZ-08501-DTI-AIR TEST

Testing of Breathing Air 5

Audits and Self-Assessments Number Title Date

SP16006 Nuclear Oversight Performance Assessment of Refuel 21 Execution

June 2, 2016

Condition Reports

201703855 201800292 201802547 201803613 201805645 HEPA and Charcoal Filter Test Records

W/O Number Title Date

16509259 FGK02B - In-Place Filter Testing May 31, 2018

16509892 FGK01A - In-Place Filter Testing April 11, 2018

16509893 FGK02A - In-Place Filter Testing June 14, 2018

16512255 FUB7001 - In-Place Filter Testing June 16, 2017

17503239 FGK01A - Laboratory Canister Testing July 23, 2018 Respirator Testing, Inspection, and Inventory Records

Number Title Date

18509565 Respiratory Protection Equipment Inspection - Certification

October 17, 2018


August 10, 2018


July 13, 2018

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Respirator Testing, Inspection, and Inventory Records

Number Title Date


May 15, 2018


April 13, 2018

01207882 Post Hydro Cylinder Inspection/Leak Check March 2, 2018

SPR-00027-HP Respiratory Protection Maintenance February 22, 2018

SPR/SKR-0010-HP

Respiratory Protection Maintenance August 19, 2018

Breathing Air Test Records

Number Title Date

COM-0001-HP Breathing Air Sample Data Sheet September 26, 2017

COM-0001-HP Breathing Air Sample Data Sheet January 2, 2018

COM-0001-HP Breathing Air Sample Data Sheet May 10, 2018

COM-0001-HP Breathing Air Sample Data Sheet July 11, 2018 Miscellaneous Documents

Title Date

Use of Delta Protection Mururoa BLU Single-Use Respiratory Protection Suit

December 18, 2006

Use of Delta Protection Respiratory Protection Equipment September 14, 2005 Inspection Procedure 71151: Performance Indicator Verification Condition Reports

201306800 Procedures


Mitigating Systems Performance Index Basis Document 18

APA-ZZ-00500 Corrective Action Program 71

APA-ZZ-01111 Mitigating Systems Performance Index Program Administration

5

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Procedures


RP-DTI-Performance Indicators

Radiation Protection Performance Indicators 2

RRA-ZZ-00001 NRC Performance Indicator Program 10 Miscellaneous Documents

Number Title Date

4Q17 MSPI Margin Report




AP18006 Nuclear Oversight Audit of Radiological and Non-Radiological Environmental Monitoring Programs

June 13, 2018

Inspection Procedure 71152: Problem Identification and Resolution Condition Reports

201800206 201800952 201802505 201802558 201802680

201803513 201804428 201804677 201707185 201705711

201800394 201800794 Procedures


APA-ZZ-00323 Configuration Management Process 18

EDP-ZZ-04023 Calculations 44

EDP-ZZ-01131 Plant Health and Performance Monitoring Program 28

ODP-ZZ-00002 Equipment Status Control 91 Miscellaneous Documents


CR 201805611 Receipt of response to TIA 2014-10, Emergency Diesel Generator Mission Time for Operability Evaluations at Callaway Plant

October 25, 2018

RFR 180048 Evaluate Non-Safety Accessories in Safety HVAC Systems

1

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TIA 2014-10 Response to Task Interface Agreement 2014-10 Related to the Regulatory Position on Emergency Diesel Generator Mission Time for Operability Evaluations at Callaway Plant, Unit No. 1 (CAC No. MF5099, EPID L-2015-LRA-0001)

October 19, 2018

ZZ-452 Post-Accident Filter Loading 0 Inspection Procedure 71153: Follow-up of Events and Notices of Enforcement Discretion Condition Reports

199400711 199701249 199901106 201804251 Procedures


FSG Executive Volume for Westinghouse Owners Group

1

FSG-05 Initial Assessment and FLEX Equipment Staging 2

FSG-44 FLEX Diesel Fuel Strategy 2

OTS-JE-00002 Filtration of Emergency D/G Fuel Oil 11

Attachment 2

Initial Request for Information Quarterly Baseline Inspection

Callaway Plant Inspection Report: 05000483/2018004 Inspection Dates: October 1 – December 31, 2018 Inspection Procedure: IP 71111 series, IP 71151, IP 71152 Lead Inspector: Dan Bradley, Senior Resident Inspector Information Requested For 4th 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 October 29, 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 Instrument Air (KA) 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 evaluations or calculations with low design margins for the selected system.

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

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

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

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

9. A list of permanent and temporary modifications performed in the past 3 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.

10. 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.

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11. A list of any common-cause failures of components in the last 3 years for the selected

system.

12. An electronic copy of the design bases documents for the selected system.

13. 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) MS07: High Pressure Injection Systems

b) MS09: Residual Heat Removal Systems

Inspector Contact Information: Dan Bradley Senior Resident Inspector 573-676-3181 [email protected] Mailing Address: U.S. NRC Resident Inspector Office 8201 NRC Road Steedman, MO 65077

Attachment 3

The following items are requested for the Occupational Radiation Safety Inspection

at Callaway

Dates of Inspection: 11/05/2018 to 11/09/2018

Integrated Report 2018004 Inspection areas are listed in the attachments below. Please provide the requested information on or before Monday, October 15, 2018. Please submit this information using the same lettering system as below. For example, all contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled “1-A,” applicable organization charts in file/folder “1-B,” etc. If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at least 30 days later than the onsite inspection dates, so the inspectors will have access to the information while writing the report. In addition to the corrective action document lists provided for each inspection procedure listed below, please provide updated lists of corrective action documents at the entrance meeting. The dates for these lists should range from the end dates of the original lists to the day of the entrance meeting. If more than one inspection procedure is to be conducted and the information requests appear to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which file the information can be found. If you have any questions or comments, please contact John O'Donnell at 817-200-1441 or via e-mail at [email protected].

PAPERWORK REDUCTION ACT STATEMENT This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget, control number 3150-0011.

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1. Radiological Hazard Assessment and Exposure Controls (71124.01) and Performance Indicator Verification (71151) Date of Last Inspection: October 16, 2017

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

and Technicians, as well as the Licensing/Regulatory Affairs staff. Please include area code and prefix. If work cell numbers are appropriate, then please include them as well.

B. Applicable organization charts including position or job titles. Please include as appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C), Engineering, and Emergency Protection. (Recent pictures are appreciated.)

C. Copies of audits, self-assessments, LARs, and LERs written since the last inspection date, related to this inspection area

D. Procedure indexes for the radiation protection procedures and other related disciplines. E. Please provide procedures related to the following areas noted below. Additional

procedures may be requested by number after the inspectors reviews the procedure indexes. 1. Radiation Protection Program 2. Radiation Protection Conduct of Operations, if not included in #1. 3. Personnel Dosimetry 4. Posting of Radiological Areas 5. High Radiation Area Controls 6. RCA Access Controls and Radiation Worker Instructions 7. Conduct of Radiological Surveys 8. Radioactive Source Inventory and Control 9. Fuel Pool Inventory Access and Control

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

committed to relative to this program. Please include the revision and/or date for the commitment and where this may be located in your current licensing basis documents.

G. Please provide a summary list of corrective action documents (including corporate and sub-tiered systems) since the last inspection date. 1. Initiated by the radiation protection organization 2. Assigned to the radiation protection organization

NOTE: These lists should include a description of the condition that provides sufficient detail that the inspectors can ascertain the regulatory impact, the significance level assigned to the condition, the status of the action (e.g., open, working, closed, etc.) and the search criteria used. Please provide in document formats which are “sortable” and “searchable” so that inspectors can quickly and efficiently determine appropriate sampling and perform word searches, as needed. (Excel spreadsheets are the preferred format.) If codes are used, please provide a legend for each column where a code is used.

H. List of radiologically significant work activities scheduled to be conducted during the inspection period. (If the inspection is scheduled during an outage, please also include a list of work activities greater than 1 rem, scheduled during the outage with the dose

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

I. Provide a summary of any changes to plant operation that have resulted or could result in a significant new radiological hazard. For each change, please provide the assessment conducted on the potential impact and any monitoring done to evaluate it.

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

K. Please provide a list of air samples taken to verify engineering controls and a separate list for breathing air samples in airborne radiation areas or high contamination work areas. Please include the RWP the breathing air sampling supports.

L. Please provide the current radioactive source inventory, listing all radioactive sources that are required to be leak tested. Indicate which sources are deemed 10 CFR Part 20, Appendix E, Category 1 or Category 2. Please indicate the radioisotope, initial and current activity (w/assay date), and storage location for each applicable source.

M. The last two leak test results for all required/applicable radioactive sources that have failed its leak test within the last two years. Provide any applicable condition reports.

N. A list of all non-fuel items stored in the spent fuel pools, and if available, their appropriate dose rates (Contact / @ 30cm)

O. A list of radiological controlled area entries greater than 100 millirem, since the last inspection date. The list should include the date of entry, some form of worker identification, the radiation work permit used by the worker, dose accrued by the worker, and the electronic dosimeter dose alarm set-point used during the entry (for Occupational Radiation Safety Performance Indicator verification in accordance with IP 71151).

P. A list describing VHRAs and TS HRAs (> 1 rem/hour) that are current and historical. Include their current status, locations, and control measures.

Q. Temporary effluent monitor locations and calibrations (AMS-4) used to monitor normally closed doors or off-normal release points (e.g., equipment hatch or turbine heater bay doors). Include any CRs associated with this monitoring or instrumentation.

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3. In-Plant Airborne Radioactivity Control and Mitigation (71124.03) Date of Last Inspection: April 11, 2016

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

code and prefix. If work cell numbers are appropriate, then please include them as well. 1. Respiratory Protection Program 2. Self-contained breathing apparatus 3. Ventilation Systems for breathing air (not effluents) 4. Licensing/Regulatory Affairs

B. Applicable organization charts including position or job titles. Please include as appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C), Engineering, and Emergency Protection. (Recent pictures are appreciated.)

C. Copies of audits, self-assessments, vendor or NUPIC audits for contractor support (SCBA), LARs, and LERs, written since the date of last inspection related to: 1. Installed air filtration systems 2. Self-contained breathing apparatuses

D. Procedure index for Radiation Protection, Maintenance, I&C, and other related disciplines. 1. Use, operation, and maintenance of installed and portable continuous air monitors 2. Use operation, and maintenance of installed air filtration units for breathing air (e.g.,

for airline respirators, emergency ventilation systems). 3. Use, operation, and maintenance of temporary air filtration units and vacuums 4. Respiratory protection and other related disciplines.

E. Please provide specific procedures related to the following areas noted below. Additional Specific Procedures may be requested by number after the inspectors reviews the procedure indexes. 1. Respiratory protection program 2. Use and maintenance of self-contained breathing apparatuses 3. Air quality testing for SCBAs or other compressed or supplied air systems 4. Use and testing of installed plant air cleaning systems used for breathing air, such as

control room emergency ventilation, technical support center, operations support center, and emergency operations facility (When containment purge is not used as an effluent system, then it can be considered as a breathing air system used prior to outages during RCS breach and flood up.)

F. Please provide a list of NRC Regulatory Guides and NUREGs that you are currently committed to relative to this program. Please include the revision and/or date for the commitment and where this may be located in your current licensing basis documents.

G. Please provide a summary list of corrective action documents (including corporate and sub-tiered systems) written since the date of last inspection, related to the Airborne Monitoring program including: 1. In-plant continuous air monitors (installed or portable), not effluent monitors 2. Self-contained breathing apparatus 3. Air cleaning systems (not effluent) 4. Respiratory protection program

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NOTE: These lists should include a description of the condition that provides sufficient detail that the inspectors can ascertain the regulatory impact, the significance level assigned to the condition, the status of the action (e.g., open, working, closed, etc.) and the search criteria used. Please provide in document formats which are “sortable” and “searchable” so that inspectors can quickly and efficiently determine appropriate sampling and perform word searches, as needed. (Excel spreadsheets are the preferred format.) If codes are used, please provide a legend for each column where a code is used.

H. List of SCBA qualified personnel - reactor operators and emergency response personnel. For the control room individuals, please indicate their normally scheduled shift and specific mask size, as well as note if they are permitted/fitted for eyewear.

I. Inspection records for self-contained breathing apparatuses (SCBAs) staged in the plant for use since the date of last inspection.

J. SCBA training and qualification records for control room operators, shift supervisors, STAs, and OSC personnel for the last year. A selection of personnel may be asked to demonstrate proficiency in donning, doffing, and performance of functionality check for respiratory devices

K. List of respirators (available for use) by type (APR, SCBA, PAPR, etc.), manufacturer, model, quantity by size, and location. Be prepared to demonstrate that these respirators are NIOSH certified. Include in the list the specific quantities and sizes staged for emergency use.

L. Provide one-line drawings of the supplied air and air cleaning systems identified in E.3 and E.4 above.

M. List work activities requiring respiratory protection and the type of respirator used (include PAPRs)

N. Please have available, on-site, the records demonstrating the compressed air for SCBAs or supplied air for a breathing air system is at least Grade D.

O. A list of the technical specification-required air cleaning systems with the two most recent surveillance test dates of in-place filter testing (of HEPA filters and charcoal adsorbers) and laboratory testing (of charcoal efficiency) and the work order numbers associated with the surveillances (and their system number/name).

F. Diya 3

CALLAWAY PLANT - NRC INTEGRATED INSPECTION REPORT 05000483/2018004 – January 28, 2019 DISTRIBUTION SMorris, RA MShaffer, DRA AVegel, DRP MHay, DRP RLantz, DRS GMiller, DRS DCylkowski, RC ARivera-Varona, RIV/OEDO VDricks, ORA JWeil, OCA JKlos, NRR AMoreno, RIV/CAO BMaier, RSLO RKellar, IPAT NTaylor, DRP BTharakan, DRP DBradley, DRP SJanicki, DRP JMelfi, DRP ECombs, DRP DYancey, DRP PJayroe, IPAT MHerrera, DRMA R4Enforcement ROP Reports Electronic Distribution for Callaway Plant

DOCUMENT NAME: CWY IR2018004 DSB.docx ADAMS ACCESSION NUMBER: ML19028A045 SUNSI Review ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: DBradley Yes No Publicly Available Sensitive NRC-002 OFFICE SRI/DRP/B RI/DRP/B C/DRS/EB1 AC:DRS/EB2 C:DRS/OB C:DRS/PSB2 NAME DBradley SJanicki VGaddy JDrake GWerner HGepford SIGNATURE DSB SMJ vgg JFD GEW hjg DATE 1/22/19 1/22/19 1/17/19 1/22/2019 01/20/2019 1/17/19 OFFICE ATL/DRS/IPAT C:DRP/B NAME RKellar NTaylor SIGNATURE RLK /RA/ DATE 1/17/19 1/28/19

OFFICIAL RECORD COPY