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| number = ML18123A395
| number = ML18123A395
| issue date = 05/03/2018
| issue date = 05/03/2018
| title = Callaway Plant - NRC Integrated Inspection Report 05000483/2018001
| title = NRC Integrated Inspection Report 05000483/2018001
| author name = Taylor N H
| author name = Taylor N
| author affiliation = NRC/RGN-IV/DRP/RPB-B
| author affiliation = NRC/RGN-IV/DRP/RPB-B
| addressee name = Diya F
| addressee name = Diya F
Line 9: Line 9:
| docket = 05000483
| docket = 05000483
| license number = NPF-030
| license number = NPF-030
| contact person = Taylor N H
| contact person = Taylor N
| document report number = IR 2018001
| document report number = IR 2018001
| document type = Inspection Report, Letter
| document type = Inspection Report, Letter
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:May 3, 2018
 
==SUBJECT:==
CALLAWAY PLANT - NRC INTEGRATED INSPECTION REPORT 05000483/2018001
 
==Dear Mr. Diya:==
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Callaway Plant. On April 4, 2018, the NRC inspectors discussed the results of this inspection with Mr. Tim Herrmann, 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.a 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.
 
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Callaway Plant. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
 
Sincerely,
/RA/
 
Nicholas H. Taylor, Branch Chief Project Branch B Division of Reactor Projects
 
Docket No. 50-483 License No. NPF-30
 
Enclosure:
Inspection Report 05000483/2018001 w/Attachment 1: Supplemental Information
 
Attachment 2: Request for Information
 
Enclosure U.S. NUCLEAR REGULATORY COMMISSION
 
==Inspection Report==
Docket Number:
05000483
 
License Number:
NPF-30
 
Report Number:
05000483/2018001
 
Enterprise Identifier: I-2018-001-0006
 
Licensee:
Union Electric Company
 
Facility:
Callaway Plant
 
Location:
8315 County Road 459
 
Steedman, MO 65077
 
Inspection Dates:
January 1, 2018, to March 31, 2018
 
Inspectors:
D. Bradley, Senior Resident Inspector
S. Janicki, Resident Inspector
S. Alferink, Reactor Inspector
D. Dodson, Senior Resident Inspector
R. Kopriva, Senior Reactor Inspector
S. Makor, Reactor Inspector
J. Melfi, Project Engineer
 
Approved By:
N. Taylor
Chief, Project Branch B
Division of Reactor Projects
 
=SUMMARY=
The NRC continued monitoring licensees performance by conducting an integrated inspection at the Callaway Plant in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs 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 tables below. A NRC-identified non-cited violation is documented in report section 71111.1
 
===List of Findings and Violations===
Failure to Maintain Emergency Operating Procedures Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000483/2018001-01 Closed
[H.3] - Human Performance,
Change Management 71111.11 Licensed Operator Performance The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a,
"Procedures," for the licensee's failure to maintain emergency operating procedures for aligning auxiliary feedwater suction sources. Specifically, the licensee added continuous action steps to emergency operating procedures that placed both motor-driven auxiliary feedwater pumps in pull-to-lock and isolated their associated recirculation lines after depleting the two non-safety-related suction sources. These actions cause two of the three safety-related auxiliary feedwater pumps to be rendered inoperable prior to aligning the safety-related suction source of essential service water which is credited in accident analysis.
 
===Additional Tracking Items===
Type Issue number Title Report Section Status URI 05000483/2016001-01 Possible Incorrect Screening of the Spent Fuel Pool Decay Heat Removal Key Safety Function 71111.05AQ Closed LER 05000483/2013-009-00 Appendix R Unanalyzed Condition - Direct Current Ammeter Circuits Without Overcurrent Protection 71153 Closed LER 05000483/2014-004-00 Postulated Hot Short Fire Event that Could Adversely Impact Shutdown Equipment 71153 Closed LER 05000483/2017-001-00 05000483/2017-001-01 Violation of Technical Specification 3.7.9 Due to Ultimate Heat Sink Cooling Tower Train Inoperability 71153 Closed
 
LER 05000483/2017-002-01 Inadequate Protection from Tornado Missiles Identified due to Nonconforming Design 71153 Closed LER 05000483/2017-003-00 Violation of Technical Specification 3.6.3,
Containment Isolation Check Valve Found in Open Position 71153 Closed NOV 05000483/2017007-01 Not Verifying the Operation and Timing of the Engineered Safety Feature Transformer XNB01 Load Tap Changer 92702 Closed
 
=PLANT STATUS=
 
Callaway Plant began the inspection period at full power. On March 14, 2018, the licensee reduced power to 45 percent to replace a reactor coolant system flow transmitter, commenced ascending in power upon completion of testing, and returned to full power on the same day.
 
The licensee 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==
===Impending Severe Weather (1 Sample)===
The inspectors evaluated readiness for impending adverse weather conditions for:
: (1) Severe winter weather on January 11, 2018
 
==71111.04 - Equipment Alignment==
===Partial Walkdown (3 Samples)===
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
: (1) Component cooling water train B on January 10, 2018
: (2) Control room filtration unit FGK02B on January 25, 2018
: (3) Battery charger NK26 on February 7, 2018
 
===Complete Walkdown (1 Sample)===
The inspectors evaluated system configurations during a complete walkdown of:
: (1) Instrument AC power (NN) system on January 18, 2018
 
==71111.05AQ - Fire Protection Annual/Quarterly==
===Quarterly Inspection (5 Samples)===
The inspectors evaluated fire protection program implementation in the following selected areas:
: (1) Control building 2016 elevation, fire area C-15 on January 12, 2018
: (2) Auxiliary feedwater pipe chase 1988 elevation, fire area A-1 on February 16, 2018
: (3) Control room air conditioning and filtration units, fire areas A-21 and A-22 on March 6, 2018
: (4) Electrical penetration rooms, fire areas A-17 and A-18 on March 11, 2018
: (5) Intake structure, fire area IS-1 on March 28, 2018
 
==71111.06 - Flood Protection Measures==
===Internal Flooding (1 Sample)===
The inspectors evaluated internal flooding mitigation protection:
: (1) Control building 2016 elevation on January 9, 2018
 
==71111.07 - Heat Sink Performance==
===Heat Sink (1 Sample)===
The inspectors evaluated:
: (1) Emergency diesel generator jacket water heat exchanger train A on March 22, 2018
 
==71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance==
===Operator Requalification (1 Sample)===
The inspectors observed and evaluated simulator training for operating crews:
: (1) Electrical faults on February 6, 2018
 
===Operator Performance (1 Sample)===
The inspectors observed and evaluated:
: (1) Surveillance testing for the auxiliary feedwater system on February 20, 2018
: (2) Surveillance testing for the emergency diesel generator train B and reactor coolant flow transmitter troubleshooting on March 7, 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) 125 VDC system (NK) on January 17, 2018
: (2) Instrument AC power system (NN) on February 14, 2018
 
==71111.13 - Maintenance Risk Assessments and Emergent Work Control==
{{IP sample|IP=IP 71111.13|count=5}}
 
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
: (1) Elevated risk actions due to planned centrifugal charging pump B and component cooling water equipment outage on January 30, 2018
: (2) Elevated risk actions due to planned switchyard maintenance on February 5, 2018
: (3) Elevated risk actions due to planned safety injection train A equipment outage on February 13, 2018
: (4) Emergent risk actions due to auxiliary feedwater pump door failure on February 20, 2018
: (5) Elevated risk actions due to planned turbine-driven auxiliary feedwater pump equipment outage on February 27, 2018
 
==71111.15 - Operability Determinations and Functionality Assessments==
{{IP sample|IP=IP 71111.15|count=5}}
 
The inspectors evaluated the following operability determinations and functionality assessments:
: (1) Rising level trend in safety injection accumulators on January 8, 2018
: (2) Reactor building service air header supply containment isolation valve KAV0118 out of position on January 15, 2018
: (3) Battery charger NK25 equalize potentiometer failure on January 16, 2018
: (4) Spent fuel pool calculation assumptions on February 13, 2018
: (5) Turbine-driven auxiliary feedwater pump room door DSK13311 failure on March 2, 2018
 
==71111.18 - Plant Modifications==
{{IP sample|IP=IP 71111.18|count=1}}
 
The inspectors evaluated the following permanent modification:
: (1) MP 12-0020 electrical tie-ins for FLEX on March 29, 2018
 
==71111.19 - Post Maintenance Testing==
{{IP sample|IP=IP 71111.19|count=5}}
 
The inspectors evaluated the following post maintenance tests:
: (1) Control room air conditioning unit SGK04B equipment outage on January 10, 2018
: (2) Class 1E battery charger NK25 equipment outage on January 22, 2018
: (3) Class 1E battery charger NK21 equipment outage on January 29, 2018
: (4) Turbine-driven auxiliary feedwater pump equipment outage on February 28, 2018
: (5) Emergency diesel generator and essential service water train A equipment outage on March 23, 2018
 
==71111.22 - Surveillance Testing==
The inspectors evaluated the following surveillance tests:
 
===Routine===
{{IP sample|IP=IP 71111.22|count=1}}
: (1) OSP-NE-0001A, standby diesel generator A periodic tests on January 24, 2018
 
===In-service (2 Samples)===
: (1) OSP-BG-P005A, centrifugal charging pump A inservice test - Group B on February 15, 2018
: (2) OSP-EG-P01BD, component cooling water train B pump and valve inservice test - group A on March 29, 2018
 
===Containment Isolation Valve (1 Sample)===
: (1) OSP-KC-LL067, containment isolation valve leak rate test and results of check valve internal inspection under Condition Report 201706233 on March 15, 2018
 
===71114.06Drill Evaluation Emergency Planning Drill===
{{IP sample|IP=IP 71114.06|count=1}}
The inspectors evaluated the radiological emergency response plan drill:
: (1) Team 4 on March 8, 2018
 
===Drill/Training Evolution (1 Sample)===
The inspectors evaluated annual emergency response organization training evolution:
: (1) Team 4 on February 1,
 
==OTHER ACTIVITIES - BASELINE==
===71151 - Performance Indicator Verification===
{{IP sample|IP=IP 71151|count=3}}
The inspectors verified licensee performance indicators submittals listed below:
: (1) MS06: Emergency AC Power Systems (01/01/2017-12/31/2017)
: (2) MS10: Cooling Water Support Systems (01/01/2017-12/31/2017)
: (3) BI01: Reactor Coolant System (RCS) Specific Activity Sample (01/01/2017-12/31/2017)
 
==71152 - Problem Identification and Resolution==
===Annual Follow-up of Selected Issues (2 Samples)===
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
: (1) Safety injection pump oil leak, Condition Report 201704706
: (2) Ultimate heat sink cooling tower shroud bolting, Condition Report 201010236
 
===71153 - Follow-up of Events and Notices of Enforcement Discretion Licensee Event Reports===
{{IP sample|IP=IP 71153|count=5}}
The inspectors evaluated the following licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:
: (1) Licensee Event Report 05000483/2013-009-00, Appendix R Unanalyzed Condition - Direct Current Ammeter Circuits Without Overcurrent Protection, on October 9, 2013
: (2) Licensee Event Report 05000483/2014-004-00, Postulated Hot Short Fire Event that Could Adversely Impact Shutdown Equipment, on September 19, 2014
: (3) Licensee Event Reports 05000483/2017-001-00 and 05000483/2017-001-01, Violation of Technical Specification 3.7.9 Due to Ultimate Heat Sink (UHS) Cooling Tower Train Inoperability, on June 16, 2017
: (4) Licensee Event Report 05000483/2017-002-01, Inadequate Protection from Tornado Missiles Identified due to Nonconforming Design, on August 15, 2017
: (5) Licensee Event Report 05000483/2017-003-00, Violation of Technical Specification 3.6.3, Containment Isolation Check Valve Found in Open Position, on October 31, 2017
 
===92702 - Followup on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, Confirmatory Orders, and Alternative Dispute Resolution Confirmatory Orders Notice of Violation===
{{IP sample|IP=IP 92702|count=1}}
The inspectors reviewed the licensees response to Notice of Violation 05000483/2017007-01, Not Verifying the Operation and Timing of the Engineered Safety Feature Transformer XNB01 Load Tap Changer, and determined that the reason, corrective actions taken and planned to address recurrence, and the date when full compliance was achieved for this violation is adequately addressed and captured on the docket.
 
==INSPECTION RESULTS==
Failure to Maintain Emergency Operating Procedures Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000483/2018001-01 Closed
[H.3]Human Performance, Change Management 71111.11 Licensed Operator Performance The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a, "Procedures," for the licensee's failure to maintain emergency operating procedures for aligning auxiliary feedwater suction sources. Specifically, the licensee added continuous action steps to emergency operating procedures that placed both motor-driven auxiliary feedwater pumps in pull-to-lock and isolated their associated recirculation lines after depleting the two non-safety-related suction sources. These actions cause two of the three safety related auxiliary feedwater pumps to be rendered inoperable prior to aligning the safety related suction source of essential service water which is credited in accident analysis.
 
=====Description:=====
On March 7, 2018, the inspectors performed an observation of licensed control room operators and reviewed the use of auxiliary feedwater pumps (AFW or AFPs) in Emergency Operating Procedures (EOPs). The AFW system provides a reliable source of water to the steam generators and removes thermal energy from the reactor coolant system through the release of secondary steam to the atmosphere. The AFW pumps are comprised of two motor-driven (MD) pumps and one turbine-driven (TD) pump. Each pump has recirculation lines to provide a constant discharge pathway and prevent pump damage. These AFW pumps can be supplied with the following three suction sources:
: (1) Condensate storage tank (CST) - non-safety-related and normally aligned
: (2) Hardened CST (HCST) - non-safety-related
: (3) Essential service water (ESW) - safety-related
 
In their review of EOPS, the inspectors noted that the following continuous action step was found in several EOPs and titled AFW Supply Switchover Criteria:
 
If CST to AFP suction header pressure lowers to less than 11.5 PSIG, THEN PERFORM EOP Addendum 42, HCST Alignment.
 
If CST to AFP suction header pressure lowers to less than 2.75 PSIG, THEN PERFORM EOP Addendum 19, Aligning ESW to AFW Suction.
 
The inspectors reviewed EOP Addendum 42, HCST Alignment, Revision 1, which states the following and accomplishes it in step 1 of the addendum:
 
When the HCST is supplying AFW, ONLY the TDAFW will be used, since it can be aligned to recirc back to the HCST. Therefore, the MDAFPs will be placed in Pull-to-Lock prior to isolating MDAFP recirc lines back to the CST.
 
The inspectors noted that EOP Addendum 19, Aligning ESW to AFW Suction, Revision 3, did not restore the isolated and disabled motor-driven AFW pumps. Instead, EOP Addendum 19 refers only to the ESW valve lineup. As written, the discussed EOP addenda would leave the control room staff with only the turbine-driven AFW pump available.
 
The inspectors then reviewed accident analysis including section 15.2.8, Feedwater System Pipe Break, of the Final Safety Analysis Report which states:
 
For the auxiliary feedwater system, the worst case configuration has been used, i.e., only three intact steam generators receive auxiliary feedwater following the break... one motor-driven AFW pump to the intact steam generatorthe turbine-driven AFW pump has been assumed to fail... the second motor-driven AFW pump is assumed to deliverequally split to the two remaining intact steam generators...
 
The inspectors noted that the accident analysis of Final Safety Analysis Report chapter 15 does not refer to use of the HCST and does not refer to operator action to manually un-isolate motor-driven AFW pumps to reach and maintain safe shutdown.
 
The inspectors reviewed the extent of condition for the AFW Supply Switchover Criteria continuous action steps and found it in the following EOPs:
: (1) E-0, Reactor Trip or Safety Injection, Revision 19
: (2) E-1, Loss of Reactor or Secondary Coolant, Revision 19
: (3) E-3, Steam Generator Tube Rupture, Revision 22
: (4) ES-0.1, Reactor Trip Response, Revision 18
: (5) FR-H.1, Response To Loss of Secondary Heat Sink, Revision 18
 
The inspectors noted the HCST Alignment addendum was created in February 2016 and modified in October 2016 to the current Revision 1. The procedure review process noted the non-safety HCST is a useful water source prior to using the ESW... the HCST is maintained at a higher cleanliness. Further, the procedure review noted the HCST:
 
does not have a recirculation line from the Motor Drive Aux Feed pumps to the HCST... EOP Add 42 allows for the alignment of the recirc valves and stops the Motor Drive Aux Feedwater Pumps to prevent possible damage from overheating. Since this overall modification has been evaluated previously, this procedure change does not require further 50.59 review.
 
The inspectors concluded the licensee failed to maintain EOPs for aligning auxiliary feedwater suction sources. Specifically, the EOPs placed both motor-driven auxiliary feedwater pumps in pull-to-lock and isolated their associated recirculation lines prior to aligning the safety-related suction source of essential service water. This configuration and operator actions are not supported by the accident analysis in the Final Safety Analysis Report.
 
Further, the licensee did not provide an adequate procedure for restoring the motor-driven AFW pumps from this configuration. Since the continuous action steps are pervasive across EOPs, it is plausible that an operating crew would enact the AFW supply switchover actions prior to fully diagnosing the accident and contrary to the goal of the EOP they were utilizing.
 
Corrective Actions: The licensee issued a night order clarifying the requirements for auxiliary feedwater in the EOPs and revised EOP Addendum 42, HCST Alignment.
 
Corrective Action Reference: Condition Reports 201801260 and 201801570.
 
=====Performance Assessment:=====
Performance Deficiency: The failure to maintain Emergency Operating Procedures for aligning auxiliary feedwater suction sources was a performance deficiency.
 
Screening: This performance deficiency was more than minor, and therefore a finding, because it adversely affected the procedure quality attribute of the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee added continuous action steps to EOPs that placed both motor-driven auxiliary feedwater pumps in pull-to-lock and isolated their associated recirculation lines after depleting the two non-safety-related suction sources. These actions cause two of the three safety related auxiliary feedwater pumps to be rendered inoperable prior to aligning the safety related suction source of essential service water which is credited in accident analysis.
 
Significance: Using Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, the inspectors determined that the finding was of very low safety significance (Green) because
: (1) the finding was not a deficiency affecting the design or qualification of a mitigating system;
: (2) the finding did not represent a loss of system and/or function;
: (3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and
: (4) the finding does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensee's maintenance rule program for greater than 24 hours.
 
Cross-Cutting Aspect: The finding had a cross-cutting aspect in the area of human performance associated with change management because the licensee failed to use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. Specifically, the licensee prioritized the motor-driven AFW pumps health due to a lack of recirculation ability over the accident analysis by not adequately screening the procedure changes into 50.59 review in 2016.
 
=====Enforcement:=====
Violation: Technical Specification 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2. Section 6 of Appendix A to Regulatory Guide 1.33, Revision 2, requires procedures for combating emergencies and other significant events. The licensee established EOP Addendum 42, HCST Alignment, Revision 1, in part, to meet the regulatory requirement. Step 1 of EOP Addendum 42 placed both motor-driven auxiliary feedwater pumps in pull-to-lock and isolated their associated recirculation lines.
 
Contrary to the above, prior to March 7, 2018, the licensee failed to maintain procedures for combating emergencies and other significant events. Specifically, the licensee failed to maintain EOPs for aligning auxiliary feedwater suction sources. The licensee added continuous action steps to EOPs that placed both motor-driven auxiliary feedwater pumps in pull-to-lock and isolated their associated recirculation lines after depleting the two non-safety-related suction sources. These actions cause two of the three safety related auxiliary feedwater pumps to be rendered inoperable prior to aligning the safety related suction source of essential service water which is credited in accident analysis.
 
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy.
 
Unresolved Item (Closed)
Possible Incorrect Screening of the Spent Fuel Pool Decay Heat Removal Key Safety Function URI 05000483/2016001-01 71111.05AQ Quarterly Inspection
 
=====Description:=====
In Unresolved Item 05000483/2016001-01, the inspectors documented an issue of concern with the licensees National Fire Protection Association (NFPA) Standard 805, Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating Plants, non-power operations assessment. Specifically, the inspectors developed an issue of concern because the licensee screened the potential loss of spent fuel pool cooling from further consideration for any fire event during non-power operations based on adequate procedural guidance and time when the procedures would not maintain the fuel in a safe and stable condition.
 
To address this unresolved item, the inspectors requested that the Office of Nuclear Reactor Regulation (NRR) work with the Nuclear Energy Institute NFPA 805 Task Force in accordance with the NFPA 805 Frequently Asked Questions (FAQ) Program to review and update the guidance in FAQ 07-0040, Non-Power Operations Clarifications, Revision 4. The inspectors documented this request in a memo, dated March 31, 2016 (ML16091A152). The updated guidance was issued in FAQ 07-0040, Revision 5 on May 20, 2016 (ML17331B109). This revision was accepted by NRR staff in a memo, dated November 28, 2017 (ML17331B108).
 
The revised guidance provided clarification for the treatment of spent fuel pool cooling during non-power operations. The revised guidance stated that, Spent fuel pool configurations are not considered to be risk-significant and are not treated as a higher risk evolution. In the approval memo, the NRR staff agreed with the revised guidance, stating, The NRC staff agrees that the loss of spent fuel pool cooling does not need to be considered a higher risk evolution.
 
The licensee documented the non-power operations assessment in Calculation KC-26, Appendix 1, NFPA 805 Non-power Operations Assessment, Revision 3. The licensee performed this assessment based, in part, on guidance in FAQ 07-0040, Revision 4.
 
During the current inspection, the inspectors reviewed the licensees non-power operations assessment and the revised guidance in FAQ 07-0040, Revision 5. In accordance with the revised guidance, the licensee did not need to perform additional analyses (Steps F.2 and F.3. of FAQ 07-0040) associated with spent fuel pool cooling because the staff agreed that the normal fire protection program defense-in-depth actions provide reasonable assurance that the spent fuel pool remains less than boiling. Based on the licensees non-power operations assessment and the revised guidance, the inspectors determined that no performance deficiency existed.
 
Corrective Action Reference: Condition Report 201600726
 
Observation 92702Followup on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, Confirmatory Orders, and Alternative Dispute Resolution Confirmatory Orders Discussion: The inspection team determined that the licensee had not: 1) adequately performed a timing test of the transformer XNB01 load tap changer to ensure proper operation; and 2) periodically performed a timing test of the transformer XNB01 load tap changer to ensure proper operation to maintain the operability of the offsite power sources.
 
Since the issuance of the violation in 2014, the licensee had opportunities to perform a timing test of transformer XNB01 load tap changer (refueling outages in fall 2014 and spring 2016).
 
Corrective Steps Taken and Results Achieved: The timing test of the XNBO1 load tap changer was successfully tested on October 20, 2017. Timing testing of the XNBO1 and XNB02 load tap changers will continue to be performed on a routine basis, going forward.
 
Also, Callaway work management procedure will be revised to establish schedule dates for jobs associated with addressing NRC violations. Rescheduling jobs beyond the scheduled date would require justification as well as approval by management. The licensee will review any NRC violations received since October 2015 for jobs that are credited for restoring compliance. The basis for selecting October 2015 was that it coincided with the last time a comprehensive pre-Problem Identification and Resolution inspection self-assessment was performed. In that assessment, the timeliness of corrective actions for NRC violations prior to October 2015 was evaluated. Lessons learned in connection with this Notice of Violation will be communicated by station leadership. This will include expectations on identifying and adhering to the scheduled date for jobs addressing violations, as mentioned above. Both actions were complete by February 28, 2018.
 
The inspectors reviewed the licensees response to the Notice of Violation along with corrective action documents. All findings were documented in NRC Inspection Report 05000483/2017007, ADAMS accession number ML17283A392. Notice of Violation 0500483/2017007-01 is closed.
 
MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
 
On April 4, 2018, the inspectors presented the integrated quarterly resident inspection results to Mr. Tim Herrmann, Site Vice President, and other members of the licensee staff.
 
=DOCUMENTS REVIEWED=
 
Inspection Procedure 71111.01: Adverse Weather Protection
Procedures
Number
Title
Revision
OTN-QJ-00003
Plant Freeze Protection Heat Tracing Procedure
OTO-ZZ-00012
Severe Weather
 
Condition Reports
201800054
201800255
 
Inspection Procedure 71111.04: Equipment Alignment
Procedures
Number
Title
Revision
OTN-NK-00001
Class 1E 125 VDC Electrical System
OTN-NN-00001
20 V Vital AC Instrument Power - Class 1E (Channel 1)
OTN-EG-00001
Component Cooling Water System
 
Calculations
Number
Title
Revision
E-H-18
System NN Relay Settings - Calculate Settings for NN
Protective Relays
GK-11
Electrical Heat Loads in the Control Building During Normal
and ESFAS Conditions
GL-10 Add 2
Evaluate Tube Plugging Limits for SGL 15 A/B
EG-54
Allowable Gas Void Volume for each Train of the
Component Cooling Water Suction Piping
M-EG-20
Max CCW Temperature Post LOCA
 
Miscellaneous
Number
Title
Revision
10466-M-612
Design Specification for Room Coolers
M-618.2
Spec for Q-Listed HVAC Ductwork (Installation)
RFR 180048
Evaluate Non-Safety Accessories in Safety HVAC Systems
 
Miscellaneous
Number
Title
Revision
M-22EG01
Piping and Instrumentation Diagram Component Cooling
Water System
ULDBD-EG-01
Component Cooling Water System
M-082-00039
Instruction Manual for Component Cooling Water Pumps
 
Condition Reports
201707171
201706754
201800235
201800933
201801160
201800157
201800176
201303691
 
Inspection Procedure 71111.05: Fire Protection
Procedures
Number
Title
Revision
Fire Preplan Manual
FPP-ZZ-00000
Guidelines for Writing Prefire Strategy Procedures and
Preplans
APA-ZZ-00700
Fire Protection Program
 
Condition Reports
201706984
201801219
201801220
200910299
200505787
200809214
201604688
 
Inspection Procedure 71111.06: Flood Protection Measures
Procedures
Number
Title
Revision
Fire Preplan Manual
OTO-ZZ-00005
Flooding
 
Calculations
Number
Title
Revision
AMN-010-CALC-002 Flood Levels in Control Building Rooms Due to Pipe
Break or Crack
 
Condition Reports
201609311
201800649
 
Inspection Procedure 71111.07A: Heat Exchanger Performance
Procedures
Number
Title
Revision
HX-1.PMB
Heat Exchangers
APA-ZZ-00801
Foreign Material Exclusion
EDP-ZZ-01112
Heat Exchanger Predicative Performance Manual
 
Calculations
Number
Title
Revision
KJ-20
Evaluate Tube Plugging Limits for EKJ03A/B,
EKJ04A/B, and EKJ06A/B
M-1196-00002
Jacket Water Cooler Performance Evaluation
 
Jobs
13511907
09512424
 
Condition Reports
201500625
201600703
201800394
201801456
200803533
200909091
200204569
 
Inspection Procedure 71111.11: Licensed Operator Requalification Program and
Licensed Operator Performance
Procedures
Number
Title
Revision
AL-30
Auxiliary Feedwater System Performance During a Loss of
Normal Feedwater Flow and Non-Emergency A/C Power
E-0
Reactor Trip or Safety Injection
ISF-AL-00P37
CST to AFP Suction Header Pressure Channel Operational
Test
ISL-BB-0F434
RCS Flow Channel Cal Loop 3 Protection 1
OSP-AL-00003
Auxiliary Feedwater LSP CST to ESW Valve Operability
 
Procedures
Number
Title
Revision
T61.0810 8
Licensed Operator Continuing Training - Simulator Training
Scenario Guide
January 23,
2018
Condition Reports
201707139
201102329
201801260
 
Inspection Procedure 71111.12: Maintenance Effectiveness
Procedures
Number
Title
Revision
APA-ZZ-00395
Significant Operator Response Timing
EDP-ZZ-01128
Maintenance Rule Program
EDP-ZZ-01128,
Appendix 1
SSCs in the Scope of the Maintenance Rule at Callaway
EDP-ZZ-01128,
Appendix 2
Summary of SSC Performance Criteria
EDP-ZZ-01128,
Appendix 3
Maintenance Rule Shutdown Performance Criteria
EDP-ZZ-01128,
Appendix 4
Maintenance Rule System Functions
OSP-SA-2413A
Train A Diesel Generator and Sequencer Testing
 
Miscellaneous
Number
Title
Revision
E-051C-00010
Qualification Report for Class 1E 125 VDC Electronically
Controlled Manual Switches
E-1061
Specification for Class 1E AC Vital Bus Inverters and Swing
Inverters
MP-130020
Modification to Install Class 1E Swing Inverters
 
Condition Reports
200805033
201303158
201307777
20143898
201407350
201505907
201602855
201603286
201603312
201604824
201605545
201607358
201702520
201705797
201706481
201800216
 
Miscellaneous
Number
Title
Revision/
Date
LER 2014-003-00 Inverter NN11 Inadvertently Transferred to Its Alternate
Source
August 7,
2014
LER 2014-003-02 Inverter NN11 Inadvertently Transferred to Its Alternate
Source
August 6,
2015
ODMI 15-0006
Thermography Indicated Elevated Temperatures on
Disconnect NN0311
 
Inspection Procedure 71111.13: Maintenance Risk Assessments and Emergent Work
Control
Procedures
Number
Title
Revision
APA-ZZ-00750
Hazard Barrier Program
ODP-ZZ-00002,
Appendix 2
Risk Management Actions For Planned Risk Significant
Activities
EDP-ZZ-01129
Callaway Energy Center Risk Assessment
APA-ZZ-00322
Integrated Work Management Process Description
APA-ZZ-00322,
Appendix F
Online Work Integrated Risk Management
 
APA-ZZ-00315
Configuration Risk Management Program
ODP-ZZ-00002,
Appendix 1
Protected Equipment Program
OTN-BG-00001
Chemical and Volume Control System
MPE-ZZ-QY054
Inspection and Test of Protective Lockout Relays, General
Electric Type HEA
OTN-MD-00001
Switchyard Breakers and Disconnects
MTM-AL-QP002
Turbine Driven Auxiliary Feedwater Pump
 
Jobs
16513469
16508486
18000148
16508306
14504707
16514154
15503300
17500047
 
Condition Reports
201800516
201106906
200604069
201605319
201705780
 
201505319
201800176
201800157
200000661
 
Inspection Procedure 71111.15: Operability Determinations and Functionality
Assessments
Procedures
Number
Title
Revision
APA-ZZ-00391
Beyond Design Basis Program
APA-ZZ-00391,
Appendix 2
Sequence of Events Timeline
OSP-KC-00015
Fire Door Inspections
APA-ZZ-00750
Hazard Barrier Program
OTG-ZZ-00006
Plant Cooldown Hot Standby to Cold Shutdown
OSP-GT-00003
Containment Closure
OSP-GP-00001
Containment Isolation Verification
 
Miscellaneous
Number
Title
Revision
M-22FC02
Auxiliary Feedwater Pump Turbine P&ID
M-FC-03
Auxiliary Feedwater Pump Turbine Room Analysis
M-YY-49,
Addendum 4
Additional HELB Scenarios
2
Auxiliary & Reactor Building Elevation 2000 Floor Plan
 
Westinghouse Clarification on the Basis for the Boil Off
Time of the Callaway Energy Center Spent Fuel Pool
ULNRC-06421
Licensee Event Report 2018-001-00 Violation of Technical
Specification 3.6.3 Containment Isolation Manual Valve
Found in Open Position
M-22KA02
Compressed Air System P&ID
 
Jobs
18000323
13511394
09501018
18000249
18000735
Condition Reports
201800066
201800235
201800194
 
Inspection Procedure 71111.18: Plant Modifications
Miscellaneous
Number
Title
Revision
MP 12-0020
Field Change Notice
 
Seismic II/I Hazard Analysis Review for MP 12-0020
 
STARS ENG-5001-8.3, Section 13 FP Review
 
Inspection Procedure 71111.19: Post Maintenance Testing
Procedures
Number
Title
Revision
MTM-AL-QP002
Turbine Driven Auxiliary Feedwater Pump
MPE-NK-QB004 NK Class 1E Battery Charger Inspection
OSP-GK-0002B
Train B Control Room Ventilation and Pressure Test
OSP-NE-0001A
Standby Diesel Generator A Periodic Tests
OSP-NE-00003
Technical Specification Actions - A/C Sources
OTN-EF-00001
Essential Service Water System
 
Miscellaneous
Number
Title
Revision
M-22FC02
Auxiliary Feedwater Pump Turbine P&ID
MP 15-0020
Install Fuses in 250Vdc Control Circuits
E-23NK11
25 Volt DC Class 1E Power System Schematic Diagram
 
Jobs
17004200
16002592
15505343
16509603
18000735
14000994
18000457
17503253
13511907
17004111
16511918
 
Condition Reports
201706923
201800442
201704649
201704899
201800145
201700177
201800206
201705121
201604537
201110062
201800926
201820013
201800874
200801131
201703920
200811040
 
Inspection Procedure 71111.22: Surveillance Testing
Procedures
Number
Title
Revision
OSP-BG-P005A
Centrifugal Charging Pump A Inservice Test
APA-ZZ-00340
Surveillance Program Administration
OSP-BG-00001
Boron Injection Flow Paths Modes 1, 2 and 3
ODP-ZZ-00036
Technical Specification Application for Containment Isolation
Valves
EDP-ZZ-01128
Summary of SSC Performance Criteria
APA-ZZ-00549,
Appendix B
Guidelines used to determine functional importance for a
component
 
Miscellaneous
Number
Title
Revision/
Date
M-721-00093
Instruction Manual for Centrifugal Charging/Safety-Injection
Pumps Operation and Maintenance
M-22BG01
Chemical and Volume Control System P&ID
MP 12-0020
Field Change Notice
Night Order
Condition Report 201706233/Condition Report 201706926,
KCV0478 may stick open during flow through
penetrations P067
January 31,
2018
ULDBD-BB-001
Reactor Coolant System
 
Jobs
17514632
05504483
17004820
 
Condition Reports
201800330
201800423
200702585
200901841
200306153
200502806
201706233
201706926
201800323
 
Inspection Procedure 71114.06: Drill Evaluation
Procedures
Number
Title
Revision
APA-ZZ-00925
Training and Qualification of Plant Personnel
 
Procedures
Number
Title
Revision
EIP-ZZ-A0066
Radiological Emergency Response Plan Training
EIP-ZZ-A0001
Emergency Response Organization
 
Condition Reports
201801245
201801251
201801252
2000800921
201008419
200808431
 
Inspection Procedure 71151: Performance Indicator Verification
Procedures
Number
Title
Revision
CSP-ZZ-02550
Pressurized Reactor Coolant Sample
CSP-ZZ-07600
RCS Activity Determinations
 
Miscellaneous
Number
Title
Revision
Date
MSPI Derivation Reports (Cooling Water Systems)
Various
Control Room Log
Various
NRC Performance Indicator Transmittal Report, First
Quarter 2015, Mitigating Systems Cornerstone
April 11, 2018
NRC Performance Indicator Transmittal Report, Second
Quarter 2015, Mitigating Systems Cornerstone
July 18,
2018
NRC Performance Indicator Transmittal Report, Third
Quarter 2015, Mitigating Systems Cornerstone
October 25,
2018
NRC Performance Indicator Transmittal Report, Fourth
Quarter 2015, Mitigating Systems Cornerstone
January 16,
2018
Condition Reports
201101025
201004284
 
Inspection Procedure 71152: Problem Identification and Resolution
Procedures
Number
Title
Revision
APA-ZZ-00500
Corrective Action Program
ESP-EF-0001A
Ultimate Heat Sink Train A Cooling Tower Fill Inspection
 
Miscellaneous
Number
Title
Revision
EM-04
Safety Injection System (Cold Leg Recirculation Phase)
Fault Tree Model
BG-32
High Pressure Coolant Injection System (Cold Leg
Recirculation Phase) Fault Tree Model
BN-28
RWST Drain Down Time and Volume Loss During SBLOCA 0
M-015-U012-08
Specification for Ultimate Heat Sink Cooling Tower
 
Condition Reports
201706900
201707137
201704706
201010236
 
Inspection Procedure 71153: Follow-up of Events and Notices of Enforcement Discretion
Drawings
Number
Title
Revision
E-21NK02(Q)
Class IE 125V dc System Meter and Relay Diagram
J-200-00075
Main Control Board RL025 and RL026 Wiring Diagram
E-21NK01(Q)
Class IE 125V dc System Meter and Relay Diagram
E-051-00079
Battery Chargers Wiring Diagram
E-23NK11(Q)
25 Volt dc Class IE Power System Schematic
E-23CD02
Schematic Diagram Emergency Seal Oil Pump
E-23FC02
Schematic Diagram Feed Pump Turbine Emergency
Bearing Oil Pumps
E-21NK02(Q)
Class IE 125V dc System Meter and Relay Diagram
E-23CB03
Schematic Diagram Emergency Bearing Oil Pump
M-840-00014
Hydrogen and Water Cooling Wiring Diagram
M-840-00023
Schematic Diagram (Hydrology and Stator Cooling)
E-21NK01(Q)
Class IE 125V dc System Meter and Relay Diagram
 
Drawings
Number
Title
Revision
E-21NK01(Q)
Class IE 125V dc System Meter and Relay Diagram
M-830-00015
Emergency Bearing Oil Pump
IC-4061-T1 dc Magnetic Starter
M-012-00079
Wiring Diagram (Emergency Oil Pump Starter Circuit)
E-051-00058
SCR Controlled Battery Charger Schematic
M-835-00014
D.C. Magnetic Starter 72-13 (CD01) (Counter -
Electromotive Force) Emergency Seal Oil Pump Motor
J-200-00081
Main Control Board RL025 and RL026 Wiring Diagram
 
Miscellaneous
Number
Title
Revision/
Date
FR-087114
Bimetallic Thermal Overload Relays
December 13,
2017
Calculation KC-26 Nuclear Safety Capability Assessment Calculations:
KC-26
MP 15-0020
Install Fuses in 250 Vdc Control Circuits To Address
NFPA805 Concerns
 
Condition Reports
201706133
201706233
201706924
201706926
201801657
 
Initial Request for Information
Quarterly Baseline Inspection
Callaway Plant
 
Inspection Report: 05000483/2018001
Inspection Dates: January 1 - March 31, 2018
Inspection Procedure: IP 71111 series, IP 71152
Lead Inspector: Dan Bradley, Senior Resident Inspector
Information Requested For 1st Quarter 2018
The following information should be sent to the resident office in hard copy or electronic format
(Certrec IMS preferred) to the attention of Dan Bradley by January 15, 2018. These items shall
be available and ready for review on the day indicated in this request. Please provide
requested documentation electronically in pdf files, Excel, or other searchable formats, if
possible. The information should contain descriptive names and be indexed and hyperlinked to
facilitate ease of use. If requested documents are large and/or only hard copy formats are
available, please inform the inspector and provide subject documentation.
Please provide the following information for the 125 VDC (NK) and Instrument AC Power (NN)
systems:
1.
A list of all calculations and drawings associated with the selected systems.
2.
A list of condition reports associated with the selected systems for the last 3 years.
3.
A list of work orders associated with the selected systems for the last 3 years, including
all open work orders.
4.
An Excel spreadsheet list of equipment basic events (with definitions), including
importance measures sorted by risk achievement worth and Fussell-Vesely from your
internal events probabilistic risk assessment. Include basic events with a risk
achievement value of 1.3 or greater.
5.
A list of any pre-existing evaluations or calculations with low design margins for the
selected systems.
6.
A list of maintenance rule components and functions; based on engineering or expert
panel judgment, for the selected systems.
7.
A list of maintenance rule functional failure evaluations for the last 3 years for the
selected systems.
8.
A list of operating experience evaluations for the last 3 years for the selected systems.
9.
A list of all procedures and calculations that involve time-critical operator actions.
 
10. A list of permanent and temporary modifications performed in the past 3 years for the
selected systems. Include a list of any documents associated with modifications such
as: calculations, specifications, vendor manuals, Final Safety Analysis Report,
Technical Specifications and Bases updates, updated procedures, and maintenance and
surveillance activities and procedures.
11. A list of the design calculations that provide the design margin information for the
selected systems.
2. A list of root cause evaluations associated with component failures or design issues
initiated/completed in the last 3 years for the selected systems.
13. A list of any common-cause failures of components in the last 3 years for the selected
systems.
14. An electronic copy of the design bases documents for the selected systems.
15. An electronic copy of the system health notebooks for the selected systems.
Inspector Contact Information:
Dan Bradley
Senior Resident Inspector
573-676-3181
Dan.Bradley@nrc.gov
Mailing Address:
U.S. NRC Resident Inspector Office
201 NRC Road
Steedman, MO 65077
 
ML18123A395
SUNSI Review:
ADAMS:
Non-Publicly Available
Non-Sensitive
Keyword:
By: NHT/rdr
Yes No
Publicly Available
Sensitive
NRC-002
OFFICE
SRI/DRP/B
RI/DRP/B
C:DRS/EB1
C:DRS/EB2
C:DRS/OP
C:DRS/PSB2
NAME
DBradley
SJanicki
TFarnholtz
JDrake
VGaddy
HGepford
SIGNATURE
/RA/
/RA/
/RA/
/RA/
/RA/
/RA/
DATE
5/2/18
5/2/18
4/25/18
4/29/18
4/25/18
4/30/18
OFFICE
TL:DRS/IPAT
C:DRP/B
 
NAME
GGeorge
NTaylor
 
SIGNATURE
/RA/
/RA/
 
DATE
4/25/18
5/3/18
 
May 3, 2018
 
Mr. Fadi Diya, Senior Vice President
and Chief Nuclear Officer
Ameren Missouri
Callaway Plant
P. O. Box 620
Fulton, MO 65251
SUBJECT:
CALLAWAY PLANT - NRC INTEGRATED INSPECTION
REPORT 05000483/2018001
Dear Mr. Diya:
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at your Callaway Plant. On April 4, 2018, the NRC inspectors discussed the results of this
inspection with Mr. Tim Herrmann, 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.a of the Enforcement Policy.
If you contest the violation or significance of this NCV, you should provide a response within
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.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a
response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the
: [[contact::U.S. Nuclear Regulatory Commission]], ATTN: Document Control Desk,
Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the
NRC resident inspector at the Callaway Plant.
 
F. Diya
 
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
: [[contact::H. Taylor]], Branch Chief
Project Branch B
Division of Reactor Projects
Docket No. 50-483
License No. NPF-30
Enclosure:
Inspection Report 05000483/2018001
w/Attachment 1: Supplemental Information
2: Request for Information
 
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
 
Docket Number:
05000483
 
License Number:
NPF-30
 
Report Number:
05000483/2018001
 
Enterprise Identifier: I-2018-001-0006
 
Licensee:
Union Electric Company
 
Facility:
Callaway Plant
 
Location:
8315 County Road 459
 
Steedman, MO 65077
 
Inspection Dates:
January 1, 2018, to March 31, 2018
 
Inspectors:
: [[contact::D. Bradley]], Senior Resident Inspector
: [[contact::S. Janicki]], Resident Inspector
: [[contact::S. Alferink]], Reactor Inspector
: [[contact::D. Dodson]], Senior Resident Inspector
: [[contact::R. Kopriva]], Senior Reactor Inspector
: [[contact::S. Makor]], Reactor Inspector
: [[contact::J. Melfi]], Project Engineer
 
Approved By:
N. Taylor
Chief, Project Branch B
Division of Reactor Projects
 
SUMMARY
The NRC continued monitoring licensees performance by conducting an integrated inspection
at the Callaway Plant in accordance with the Reactor Oversight Process. The Reactor
Oversight Process is the NRCs 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 tables below. A NRC-identified non-cited violation is documented in report
section 71111.11.
List of Findings and Violations
Failure to Maintain Emergency Operating Procedures
Cornerstone
Significance
Cross-cutting
Aspect
Report
Section
Mitigating
Systems
Green
NCV 05000483/2018001-01
Closed
[H.3] - Human
Performance,
Change
Management
71111.11
Licensed
Operator
Performance
The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a,
"Procedures," for the licensee's failure to maintain emergency operating procedures for
aligning auxiliary feedwater suction sources. Specifically, the licensee added continuous
action steps to emergency operating procedures that placed both motor-driven auxiliary
feedwater pumps in pull-to-lock and isolated their associated recirculation lines after depleting
the two non-safety-related suction sources. These actions cause two of the three
safety-related auxiliary feedwater pumps to be rendered inoperable prior to aligning the
safety-related suction source of essential service water which is credited in accident analysis.
Additional Tracking Items
Type
Issue number
Title
Report
Section
Status
URI
05000483/2016001-01
Possible Incorrect Screening
of the Spent Fuel Pool Decay
Heat Removal Key Safety
Function
71111.05AQ
Closed
LER
05000483/2013-009-00
Appendix R Unanalyzed
Condition - Direct Current
Ammeter Circuits Without
Overcurrent Protection
71153
Closed
LER
05000483/2014-004-00
Postulated Hot Short Fire
Event that Could Adversely
Impact Shutdown Equipment
71153
Closed
LER
05000483/2017-001-00
05000483/2017-001-01
Violation of Technical
Specification 3.7.9 Due to
Ultimate Heat Sink Cooling
Tower Train Inoperability
71153
Closed
 
LER
05000483/2017-002-01
Inadequate Protection from
Tornado Missiles Identified
due to Nonconforming
Design
71153
Closed
LER
05000483/2017-003-00 Violation of Technical
Specification 3.6.3,
Containment Isolation Check
Valve Found in Open
Position
71153
Closed
NOV
05000483/2017007-01
Not Verifying the Operation
and Timing of the
Engineered Safety Feature
Transformer XNB01 Load
Tap Changer
2702
Closed
 
PLANT STATUS
Callaway Plant began the inspection period at full power. On March 14, 2018, the licensee
reduced power to 45 percent to replace a reactor coolant system flow transmitter, commenced
ascending in power upon completion of testing, and returned to full power on the same day.
The licensee 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
Impending Severe Weather (1 Sample)
The inspectors evaluated readiness for impending adverse weather conditions for:
(1) Severe winter weather on January 11, 2018
71111.04 - Equipment Alignment
Partial Walkdown (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) Component cooling water train B on January 10, 2018
(2) Control room filtration unit FGK02B on January 25, 2018
(3) Battery charger NK26 on February 7, 2018
Complete Walkdown (1 Sample)
The inspectors evaluated system configurations during a complete walkdown of:
(1) Instrument AC power (NN) system on January 18, 2018
 
71111.05AQ - Fire Protection Annual/Quarterly
Quarterly Inspection (5 Samples)
The inspectors evaluated fire protection program implementation in the following selected
areas:
(1) Control building 2016 elevation, fire area C-15 on January 12, 2018
(2) Auxiliary feedwater pipe chase 1988 elevation, fire area A-1 on February 16, 2018
(3) Control room air conditioning and filtration units, fire areas A-21 and A-22 on March 6,
2018
(4) Electrical penetration rooms, fire areas A-17 and A-18 on March 11, 2018
(5) Intake structure, fire area IS-1 on March 28, 2018
71111.06 - Flood Protection Measures
Internal Flooding (1 Sample)
The inspectors evaluated internal flooding mitigation protection:
(1) Control building 2016 elevation on January 9, 2018
71111.07 - Heat Sink Performance
Heat Sink (1 Sample)
The inspectors evaluated:
(1) Emergency diesel generator jacket water heat exchanger train A on March 22, 2018
71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance
Operator Requalification (1 Sample)
The inspectors observed and evaluated simulator training for operating crews:
(1) Electrical faults on February 6, 2018
Operator Performance (1 Sample)
The inspectors observed and evaluated:
(1) Surveillance testing for the auxiliary feedwater system on February 20, 2018
(2) Surveillance testing for the emergency diesel generator train B and reactor coolant flow
transmitter troubleshooting on March 7, 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) 125 VDC system (NK) on January 17, 2018
(2) Instrument AC power system (NN) on February 14, 2018
71111.13 - Maintenance Risk Assessments and Emergent Work Control (5 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent
work activities:
(1) Elevated risk actions due to planned centrifugal charging pump B and component
cooling water equipment outage on January 30, 2018
(2) Elevated risk actions due to planned switchyard maintenance on February 5, 2018
(3) Elevated risk actions due to planned safety injection train A equipment outage on
February 13, 2018
(4) Emergent risk actions due to auxiliary feedwater pump door failure on February 20, 2018
(5) Elevated risk actions due to planned turbine-driven auxiliary feedwater pump equipment
outage on February 27, 2018
71111.15 - Operability Determinations and Functionality Assessments (5 Samples)
The inspectors evaluated the following operability determinations and functionality
assessments:
(1) Rising level trend in safety injection accumulators on January 8, 2018
(2) Reactor building service air header supply containment isolation valve KAV0118 out of
position on January 15, 2018
(3) Battery charger NK25 equalize potentiometer failure on January 16, 2018
(4) Spent fuel pool calculation assumptions on February 13, 2018
(5) Turbine-driven auxiliary feedwater pump room door DSK13311 failure on March 2, 2018
71111.18 - Plant Modifications (1 Sample)
The inspectors evaluated the following permanent modification:
(1) MP 12-0020 electrical tie-ins for FLEX on March 29, 2018
 
71111.19 - Post Maintenance Testing (5 Samples)
The inspectors evaluated the following post maintenance tests:
(1) Control room air conditioning unit SGK04B equipment outage on January 10, 2018
(2) Class 1E battery charger NK25 equipment outage on January 22, 2018
(3) Class 1E battery charger NK21 equipment outage on January 29, 2018
(4) Turbine-driven auxiliary feedwater pump equipment outage on February 28, 2018
(5) Emergency diesel generator and essential service water train A equipment outage on
March 23, 2018
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Routine (1 Sample)
(1) OSP-NE-0001A, standby diesel generator A periodic tests on January 24, 2018
In-service (2 Samples)
(1) OSP-BG-P005A, centrifugal charging pump A inservice test - Group B on February 15,
2018
(2) OSP-EG-P01BD, component cooling water train B pump and valve inservice test -
group A on March 29, 2018
Containment Isolation Valve (1 Sample)
(1) OSP-KC-LL067, containment isolation valve leak rate test and results of check valve
internal inspection under Condition Report 201706233 on March 15, 2018
71114.06Drill Evaluation
Emergency Planning Drill (1 Sample)
The inspectors evaluated the radiological emergency response plan drill:
(1) Team 4 on March 8, 2018
Drill/Training Evolution (1 Sample)
The inspectors evaluated annual emergency response organization training evolution:
(1) Team 4 on February 1, 2018
 
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification (3 Samples)
The inspectors verified licensee performance indicators submittals listed below:
(1) MS06: Emergency AC Power Systems (01/01/2017-12/31/2017)
(2) MS10: Cooling Water Support Systems (01/01/2017-12/31/2017)
(3) BI01: Reactor Coolant System (RCS) Specific Activity Sample (01/01/2017-12/31/2017)
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issues:
(1) Safety injection pump oil leak, Condition Report 201704706
(2) Ultimate heat sink cooling tower shroud bolting, Condition Report 201010236
71153 - Follow-up of Events and Notices of Enforcement Discretion
Licensee Event Reports (5 Samples)
The inspectors evaluated the following licensee event reports which can be accessed at
https://lersearch.inl.gov/LERSearchCriteria.aspx:
(1) Licensee Event Report 05000483/2013-009-00, Appendix R Unanalyzed Condition -
Direct Current Ammeter Circuits Without Overcurrent Protection, on October 9, 2013
(2) Licensee Event Report 05000483/2014-004-00, Postulated Hot Short Fire Event that
Could Adversely Impact Shutdown Equipment, on September 19, 2014
(3) Licensee Event Reports 05000483/2017-001-00 and 05000483/2017-001-01, Violation
of Technical Specification 3.7.9 Due to Ultimate Heat Sink (UHS) Cooling Tower Train
Inoperability, on June 16, 2017
(4) Licensee Event Report 05000483/2017-002-01, Inadequate Protection from Tornado
Missiles Identified due to Nonconforming Design, on August 15, 2017
(5) Licensee Event Report 05000483/2017-003-00, Violation of Technical
Specification 3.6.3, Containment Isolation Check Valve Found in Open Position, on
October 31, 2017
 
2702 - Followup on Traditional Enforcement Actions Including Violations, Deviations,
Confirmatory Action Letters, Confirmatory Orders, and Alternative Dispute Resolution
Confirmatory Orders
Notice of Violation (1 Sample)
The inspectors reviewed the licensees response to Notice of
Violation 05000483/2017007-01, Not Verifying the Operation and Timing of the Engineered
Safety Feature Transformer XNB01 Load Tap Changer, and determined that the reason,
corrective actions taken and planned to address recurrence, and the date when full
compliance was achieved for this violation is adequately addressed and captured on the
docket.
INSPECTION RESULTS
Failure to Maintain Emergency Operating Procedures
Cornerstone
Significance
Cross-cutting Aspect
Report Section
Mitigating Systems
Green
NCV 05000483/2018001-01
Closed
[H.3]Human
Performance, Change
Management
71111.11
Licensed
Operator
Performance
The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a,
"Procedures," for the licensee's failure to maintain emergency operating procedures for
aligning auxiliary feedwater suction sources. Specifically, the licensee added continuous
action steps to emergency operating procedures that placed both motor-driven auxiliary
feedwater pumps in pull-to-lock and isolated their associated recirculation lines after depleting
the two non-safety-related suction sources. These actions cause two of the three safety
related auxiliary feedwater pumps to be rendered inoperable prior to aligning the safety
related suction source of essential service water which is credited in accident analysis.
Description:
On March 7, 2018, the inspectors performed an observation of licensed control room
operators and reviewed the use of auxiliary feedwater pumps (AFW or AFPs) in Emergency
Operating Procedures (EOPs). The AFW system provides a reliable source of water to the
steam generators and removes thermal energy from the reactor coolant system through the
release of secondary steam to the atmosphere. The AFW pumps are comprised of two
motor-driven (MD) pumps and one turbine-driven (TD) pump. Each pump has recirculation
lines to provide a constant discharge pathway and prevent pump damage. These AFW
pumps can be supplied with the following three suction sources:
(1) Condensate storage tank (CST) - non-safety-related and normally aligned
(2) Hardened CST (HCST) - non-safety-related
(3) Essential service water (ESW) - safety-related
In their review of EOPS, the inspectors noted that the following continuous action step was
found in several EOPs and titled AFW Supply Switchover Criteria:
If CST to AFP suction header pressure lowers to less than 11.5 PSIG,
THEN PERFORM EOP Addendum 42, HCST Alignment.
If CST to AFP suction header pressure lowers to less than 2.75 PSIG,
THEN PERFORM EOP Addendum 19, Aligning ESW to AFW Suction.
 
The inspectors reviewed EOP Addendum 42, HCST Alignment, Revision 1, which states the
following and accomplishes it in step 1 of the addendum:
When the HCST is supplying AFW, ONLY the TDAFW will be used, since it
can be aligned to recirc back to the HCS
: [[contact::T. Therefore]], the MDAFPs will be
placed in Pull-to-Lock prior to isolating MDAFP recirc lines back to the
CST.
The inspectors noted that EOP Addendum 19, Aligning ESW to AFW Suction, Revision 3,
did not restore the isolated and disabled motor-driven AFW pumps. Instead, EOP
Addendum 19 refers only to the ESW valve lineup. As written, the discussed EOP addenda
would leave the control room staff with only the turbine-driven AFW pump available.
The inspectors then reviewed accident analysis including section 15.2.8, Feedwater System
Pipe Break, of the Final Safety Analysis Report which states:
For the auxiliary feedwater system, the worst case configuration has been
used, i.e., only three intact steam generators receive auxiliary feedwater
following the break... one motor-driven AFW pump to the intact steam
generatorthe turbine-driven AFW pump has been assumed to fail... the
second motor-driven AFW pump is assumed to deliverequally split to the
two remaining intact steam generators...
The inspectors noted that the accident analysis of Final Safety Analysis Report chapter 15
does not refer to use of the HCST and does not refer to operator action to manually un-isolate
motor-driven AFW pumps to reach and maintain safe shutdown.
The inspectors reviewed the extent of condition for the AFW Supply Switchover Criteria
continuous action steps and found it in the following EOPs:
(1) E-0, Reactor Trip or Safety Injection, Revision 19
(2) E-1, Loss of Reactor or Secondary Coolant, Revision 19
(3) E-3, Steam Generator Tube Rupture, Revision 22
(4) ES-0.1, Reactor Trip Response, Revision 18
(5) FR-H.1, Response To Loss of Secondary Heat Sink, Revision 18
The inspectors noted the HCST Alignment addendum was created in February 2016 and
modified in October 2016 to the current Revision 1. The procedure review process noted the
non-safety HCST is a useful water source prior to using the ESW... the HCST is
maintained at a higher cleanliness. Further, the procedure review noted the HCST:
does not have a recirculation line from the Motor Drive Aux Feed pumps to
the HCST... EOP Add 42 allows for the alignment of the recirc valves and
stops the Motor Drive Aux Feedwater Pumps to prevent possible damage
from overheating. Since this overall modification has been evaluated
previously, this procedure change does not require further 50.59 review.
The inspectors concluded the licensee failed to maintain EOPs for aligning auxiliary feedwater
suction sources. Specifically, the EOPs placed both motor-driven auxiliary feedwater pumps
in pull-to-lock and isolated their associated recirculation lines prior to aligning the
safety-related suction source of essential service water. This configuration and operator
 
actions are not supported by the accident analysis in the Final Safety Analysis Report.
Further, the licensee did not provide an adequate procedure for restoring the motor-driven
AFW pumps from this configuration. Since the continuous action steps are pervasive across
EOPs, it is plausible that an operating crew would enact the AFW supply switchover actions
prior to fully diagnosing the accident and contrary to the goal of the EOP they were utilizing.
Corrective Actions: The licensee issued a night order clarifying the requirements for auxiliary
feedwater in the EOPs and revised EOP Addendum 42, HCST Alignment.
Corrective Action Reference: Condition Reports 201801260 and 201801570.
Performance Assessment:
Performance Deficiency: The failure to maintain Emergency Operating Procedures for
aligning auxiliary feedwater suction sources was a performance deficiency.
Screening: This performance deficiency was more than minor, and therefore a finding,
because it adversely affected the procedure quality attribute of the Mitigating Systems
Cornerstone objective of ensuring the availability, reliability, and capability of systems that
respond to initiating events to prevent undesirable consequences. Specifically, the licensee
added continuous action steps to EOPs that placed both motor-driven auxiliary feedwater
pumps in pull-to-lock and isolated their associated recirculation lines after depleting the two
non-safety-related suction sources. These actions cause two of the three safety related
auxiliary feedwater pumps to be rendered inoperable prior to aligning the safety related
suction source of essential service water which is credited in accident analysis.
Significance: Using Inspection Manual Chapter 0609, Attachment 4, Initial Characterization
of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings
At-Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, the
inspectors determined that the finding was of very low safety significance (Green) because
(1) the finding was not a deficiency affecting the design or qualification of a mitigating system;
(2) the finding did not represent a loss of system and/or function; (3) the finding did not
represent an actual loss of function of a single train for greater than its technical specification
allowed outage time; and (4) the finding does not represent an actual loss of function of one
or more non-technical specification trains of equipment designated as high safety-significant
in accordance with the licensee's maintenance rule program for greater than 24 hours.
Cross-Cutting Aspect: The finding had a cross-cutting aspect in the area of human
performance associated with change management because the licensee failed to use a
systematic process for evaluating and implementing change so that nuclear safety remains
the overriding priority. Specifically, the licensee prioritized the motor-driven AFW pumps
health due to a lack of recirculation ability over the accident analysis by not adequately
screening the procedure changes into 50.59 review in 2016.
Enforcement:
Violation: Technical Specification 5.4.1.a requires, in part, that written procedures shall be
established, implemented, and maintained covering the applicable procedures recommended
in Appendix A of Regulatory Guide 1.33, Revision 2. Section 6 of Appendix A to Regulatory
Guide 1.33, Revision 2, requires procedures for combating emergencies and other significant
events. The licensee established EOP Addendum 42, HCST Alignment, Revision 1, in part,
to meet the regulatory requirement. Step 1 of EOP Addendum 42 placed both motor-driven
auxiliary feedwater pumps in pull-to-lock and isolated their associated recirculation lines.
 
Contrary to the above, prior to March 7, 2018, the licensee failed to maintain procedures for
combating emergencies and other significant events. Specifically, the licensee failed to
maintain EOPs for aligning auxiliary feedwater suction sources. The licensee added
continuous action steps to EOPs that placed both motor-driven auxiliary feedwater pumps in
pull-to-lock and isolated their associated recirculation lines after depleting the two
non-safety-related suction sources. These actions cause two of the three safety related
auxiliary feedwater pumps to be rendered inoperable prior to aligning the safety related
suction source of essential service water which is credited in accident analysis.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2.a of the Enforcement Policy.
Unresolved Item
(Closed)
Possible Incorrect Screening of the Spent Fuel Pool
Decay Heat Removal Key Safety Function
URI 05000483/2016001-01
71111.05AQ
Quarterly
Inspection
Description: In Unresolved Item 05000483/2016001-01, the inspectors documented an issue
of concern with the licensees National Fire Protection Association (NFPA) Standard 805,
Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating
Plants, non-power operations assessment. Specifically, the inspectors developed an issue of
concern because the licensee screened the potential loss of spent fuel pool cooling from
further consideration for any fire event during non-power operations based on adequate
procedural guidance and time when the procedures would not maintain the fuel in a safe and
stable condition.
To address this unresolved item, the inspectors requested that the Office of Nuclear Reactor
Regulation (NRR) work with the Nuclear Energy Institute NFPA 805 Task Force in accordance
with the NFPA 805 Frequently Asked Questions (FAQ) Program to review and update the
guidance in FAQ 07-0040, Non-Power Operations Clarifications, Revision 4. The inspectors
documented this request in a memo, dated March 31, 2016 (ML16091A152). The updated
guidance was issued in FAQ 07-0040, Revision 5 on May 20, 2016 (ML17331B109). This
revision was accepted by NRR staff in a memo, dated November 28, 2017 (ML17331B108).
The revised guidance provided clarification for the treatment of spent fuel pool cooling during
non-power operations. The revised guidance stated that, Spent fuel pool configurations are
not considered to be risk-significant and are not treated as a higher risk evolution. In the
approval memo, the NRR staff agreed with the revised guidance, stating, The NRC staff
agrees that the loss of spent fuel pool cooling does not need to be considered a higher risk
evolution.
The licensee documented the non-power operations assessment in Calculation KC-26,
Appendix 1, NFPA 805 Non-power Operations Assessment, Revision 3. The licensee
performed this assessment based, in part, on guidance in FAQ 07-0040, Revision 4.
During the current inspection, the inspectors reviewed the licensees non-power operations
assessment and the revised guidance in FAQ 07-0040, Revision 5. In accordance with the
revised guidance, the licensee did not need to perform additional analyses (Steps F.2
and F.3. of FAQ 07-0040) associated with spent fuel pool cooling because the staff agreed
that the normal fire protection program defense-in-depth actions provide reasonable
assurance that the spent fuel pool remains less than boiling. Based on the licensees
non-power operations assessment and the revised guidance, the inspectors determined that
no performance deficiency existed.
 
Corrective Action Reference: Condition Report 201600726
Observation
2702Followup on Traditional
Enforcement Actions Including
Violations, Deviations,
Confirmatory Action Letters,
Confirmatory Orders, and
Alternative Dispute Resolution
Confirmatory Orders
Discussion: The inspection team determined that the licensee had not: 1) adequately
performed a timing test of the transformer XNB01 load tap changer to ensure proper
operation; and 2) periodically performed a timing test of the transformer XNB01 load tap
changer to ensure proper operation to maintain the operability of the offsite power sources.
Since the issuance of the violation in 2014, the licensee had opportunities to perform a timing
test of transformer XNB01 load tap changer (refueling outages in fall 2014 and spring 2016).
Corrective Steps Taken and Results Achieved: The timing test of the XNBO1 load tap
changer was successfully tested on October 20, 2017. Timing testing of the XNBO1 and
XNB02 load tap changers will continue to be performed on a routine basis, going forward.
Also, Callaway work management procedure will be revised to establish schedule dates for
jobs associated with addressing NRC violations. Rescheduling jobs beyond the scheduled
date would require justification as well as approval by management. The licensee will review
any NRC violations received since October 2015 for jobs that are credited for restoring
compliance. The basis for selecting October 2015 was that it coincided with the last time a
comprehensive pre-Problem Identification and Resolution inspection self-assessment was
performed. In that assessment, the timeliness of corrective actions for NRC violations prior to
October 2015 was evaluated. Lessons learned in connection with this Notice of Violation will
be communicated by station leadership. This will include expectations on identifying and
adhering to the scheduled date for jobs addressing violations, as mentioned above. Both
actions were complete by February 28, 2018.
The inspectors reviewed the licensees response to the Notice of Violation along with
corrective action documents. All findings were documented in NRC Inspection
Report 05000483/2017007, ADAMS accession number ML17283A392. Notice of
Violation 0500483/2017007-01 is closed.
 
MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On April 4, 2018, the inspectors presented the integrated quarterly resident inspection results to
Mr. Tim Herrmann, Site Vice President, and other members of the licensee staff.
 
DOCUMENTS REVIEWED
Inspection Procedure 71111.01: Adverse Weather Protection
Procedures
Number
Title
Revision
OTN-QJ-00003
Plant Freeze Protection Heat Tracing Procedure
OTO-ZZ-00012
Severe Weather
 
Condition Reports
201800054
201800255
 
Inspection Procedure 71111.04: Equipment Alignment
Procedures
Number
Title
Revision
OTN-NK-00001
Class 1E 125 VDC Electrical System
OTN-NN-00001
20 V Vital AC Instrument Power - Class 1E (Channel 1)
OTN-EG-00001
Component Cooling Water System
 
Calculations
Number
Title
Revision
E-H-18
System NN Relay Settings - Calculate Settings for NN
Protective Relays
GK-11
Electrical Heat Loads in the Control Building During Normal
and ESFAS Conditions
GL-10 Add 2
Evaluate Tube Plugging Limits for SGL 15 A/B
EG-54
Allowable Gas Void Volume for each Train of the
Component Cooling Water Suction Piping
M-EG-20
Max CCW Temperature Post LOCA
 
Miscellaneous
Number
Title
Revision
10466-M-612
Design Specification for Room Coolers
M-618.2
Spec for Q-Listed HVAC Ductwork (Installation)
RFR 180048
Evaluate Non-Safety Accessories in Safety HVAC Systems
 
Miscellaneous
Number
Title
Revision
M-22EG01
Piping and Instrumentation Diagram Component Cooling
Water System
ULDBD-EG-01
Component Cooling Water System
M-082-00039
Instruction Manual for Component Cooling Water Pumps
 
Condition Reports
201707171
201706754
201800235
201800933
201801160
201800157
201800176
201303691
 
Inspection Procedure 71111.05: Fire Protection
Procedures
Number
Title
Revision
Fire Preplan Manual
FPP-ZZ-00000
Guidelines for Writing Prefire Strategy Procedures and
Preplans
APA-ZZ-00700
Fire Protection Program
 
Condition Reports
201706984
201801219
201801220
200910299
200505787
200809214
201604688
 
Inspection Procedure 71111.06: Flood Protection Measures
Procedures
Number
Title
Revision
Fire Preplan Manual
OTO-ZZ-00005
Flooding
 
Calculations
Number
Title
Revision
AMN-010-CALC-002 Flood Levels in Control Building Rooms Due to Pipe
Break or Crack
 
Condition Reports
201609311
201800649
 
Inspection Procedure 71111.07A: Heat Exchanger Performance
Procedures
Number
Title
Revision
HX-1.PMB
Heat Exchangers
APA-ZZ-00801
Foreign Material Exclusion
EDP-ZZ-01112
Heat Exchanger Predicative Performance Manual
 
Calculations
Number
Title
Revision
KJ-20
Evaluate Tube Plugging Limits for EKJ03A/B,
EKJ04A/B, and EKJ06A/B
M-1196-00002
Jacket Water Cooler Performance Evaluation
 
Jobs
13511907
09512424
 
Condition Reports
201500625
201600703
201800394
201801456
200803533
200909091
200204569
 
Inspection Procedure 71111.11: Licensed Operator Requalification Program and
Licensed Operator Performance
Procedures
Number
Title
Revision
AL-30
Auxiliary Feedwater System Performance During a Loss of
Normal Feedwater Flow and Non-Emergency A/C Power
E-0
Reactor Trip or Safety Injection
ISF-AL-00P37
CST to AFP Suction Header Pressure Channel Operational
Test
ISL-BB-0F434
RCS Flow Channel Cal Loop 3 Protection 1
OSP-AL-00003
Auxiliary Feedwater LSP CST to ESW Valve Operability
 
Procedures
Number
Title
Revision
T61.0810 8
Licensed Operator Continuing Training - Simulator Training
Scenario Guide
January 23,
2018
Condition Reports
201707139
201102329
201801260
 
Inspection Procedure 71111.12: Maintenance Effectiveness
Procedures
Number
Title
Revision
APA-ZZ-00395
Significant Operator Response Timing
EDP-ZZ-01128
Maintenance Rule Program
EDP-ZZ-01128,
Appendix 1
SSCs in the Scope of the Maintenance Rule at Callaway
EDP-ZZ-01128,
Appendix 2
Summary of SSC Performance Criteria
EDP-ZZ-01128,
Appendix 3
Maintenance Rule Shutdown Performance Criteria
EDP-ZZ-01128,
Appendix 4
Maintenance Rule System Functions
OSP-SA-2413A
Train A Diesel Generator and Sequencer Testing
 
Miscellaneous
Number
Title
Revision
E-051C-00010
Qualification Report for Class 1E 125 VDC Electronically
Controlled Manual Switches
E-1061
Specification for Class 1E AC Vital Bus Inverters and Swing
Inverters
MP-130020
Modification to Install Class 1E Swing Inverters
 
Condition Reports
200805033
201303158
201307777
20143898
201407350
201505907
201602855
201603286
201603312
201604824
201605545
201607358
201702520
201705797
201706481
201800216
 
Miscellaneous
Number
Title
Revision/
Date
LER 2014-003-00 Inverter NN11 Inadvertently Transferred to Its Alternate
Source
August 7,
2014
LER 2014-003-02 Inverter NN11 Inadvertently Transferred to Its Alternate
Source
August 6,
2015
ODMI 15-0006
Thermography Indicated Elevated Temperatures on
Disconnect NN0311
 
Inspection Procedure 71111.13: Maintenance Risk Assessments and Emergent Work
Control
Procedures
Number
Title
Revision
APA-ZZ-00750
Hazard Barrier Program
ODP-ZZ-00002,
Appendix 2
Risk Management Actions For Planned Risk Significant
Activities
EDP-ZZ-01129
Callaway Energy Center Risk Assessment
APA-ZZ-00322
Integrated Work Management Process Description
APA-ZZ-00322,
Appendix F
Online Work Integrated Risk Management
 
APA-ZZ-00315
Configuration Risk Management Program
ODP-ZZ-00002,
Appendix 1
Protected Equipment Program
OTN-BG-00001
Chemical and Volume Control System
MPE-ZZ-QY054
Inspection and Test of Protective Lockout Relays, General
Electric Type HEA
OTN-MD-00001
Switchyard Breakers and Disconnects
MTM-AL-QP002
Turbine Driven Auxiliary Feedwater Pump
 
Jobs
16513469
16508486
18000148
16508306
14504707
16514154
15503300
17500047
 
Condition Reports
201800516
201106906
200604069
201605319
201705780
 
201505319
201800176
201800157
200000661
 
Inspection Procedure 71111.15: Operability Determinations and Functionality
Assessments
Procedures
Number
Title
Revision
APA-ZZ-00391
Beyond Design Basis Program
APA-ZZ-00391,
Appendix 2
Sequence of Events Timeline
OSP-KC-00015
Fire Door Inspections
APA-ZZ-00750
Hazard Barrier Program
OTG-ZZ-00006
Plant Cooldown Hot Standby to Cold Shutdown
OSP-GT-00003
Containment Closure
OSP-GP-00001
Containment Isolation Verification
 
Miscellaneous
Number
Title
Revision
M-22FC02
Auxiliary Feedwater Pump Turbine P&ID
M-FC-03
Auxiliary Feedwater Pump Turbine Room Analysis
M-YY-49,
Addendum 4
Additional HELB Scenarios
2
Auxiliary & Reactor Building Elevation 2000 Floor Plan
 
Westinghouse Clarification on the Basis for the Boil Off
Time of the Callaway Energy Center Spent Fuel Pool
ULNRC-06421
Licensee Event Report 2018-001-00 Violation of Technical
Specification 3.6.3 Containment Isolation Manual Valve
Found in Open Position
M-22KA02
Compressed Air System P&ID
 
Jobs
18000323
13511394
09501018
18000249
18000735
Condition Reports
201800066
201800235
201800194
 
Inspection Procedure 71111.18: Plant Modifications
Miscellaneous
Number
Title
Revision
MP 12-0020
Field Change Notice
 
Seismic II/I Hazard Analysis Review for MP 12-0020
 
STARS ENG-5001-8.3, Section 13 FP Review
 
Inspection Procedure 71111.19: Post Maintenance Testing
Procedures
Number
Title
Revision
MTM-AL-QP002
Turbine Driven Auxiliary Feedwater Pump
MPE-NK-QB004 NK Class 1E Battery Charger Inspection
OSP-GK-0002B
Train B Control Room Ventilation and Pressure Test
OSP-NE-0001A
Standby Diesel Generator A Periodic Tests
OSP-NE-00003
Technical Specification Actions - A/C Sources
OTN-EF-00001
Essential Service Water System
 
Miscellaneous
Number
Title
Revision
M-22FC02
Auxiliary Feedwater Pump Turbine P&ID
MP 15-0020
Install Fuses in 250Vdc Control Circuits
E-23NK11
25 Volt DC Class 1E Power System Schematic Diagram
 
Jobs
17004200
16002592
15505343
16509603
18000735
14000994
18000457
17503253
13511907
17004111
16511918
 
Condition Reports
201706923
201800442
201704649
201704899
201800145
201700177
201800206
201705121
201604537
201110062
201800926
201820013
201800874
200801131
201703920
200811040
 
Inspection Procedure 71111.22: Surveillance Testing
Procedures
Number
Title
Revision
OSP-BG-P005A
Centrifugal Charging Pump A Inservice Test
APA-ZZ-00340
Surveillance Program Administration
OSP-BG-00001
Boron Injection Flow Paths Modes 1, 2 and 3
ODP-ZZ-00036
Technical Specification Application for Containment Isolation
Valves
EDP-ZZ-01128
Summary of SSC Performance Criteria
APA-ZZ-00549,
Appendix B
Guidelines used to determine functional importance for a
component
 
Miscellaneous
Number
Title
Revision/
Date
M-721-00093
Instruction Manual for Centrifugal Charging/Safety-Injection
Pumps Operation and Maintenance
M-22BG01
Chemical and Volume Control System P&ID
MP 12-0020
Field Change Notice
Night Order
Condition Report 201706233/Condition Report 201706926,
KCV0478 may stick open during flow through
penetrations P067
January 31,
2018
ULDBD-BB-001
Reactor Coolant System
 
Jobs
17514632
05504483
17004820
 
Condition Reports
201800330
201800423
200702585
200901841
200306153
200502806
201706233
201706926
201800323
 
Inspection Procedure 71114.06: Drill Evaluation
Procedures
Number
Title
Revision
APA-ZZ-00925
Training and Qualification of Plant Personnel
 
Procedures
Number
Title
Revision
EIP-ZZ-A0066
Radiological Emergency Response Plan Training
EIP-ZZ-A0001
Emergency Response Organization
 
Condition Reports
201801245
201801251
201801252
2000800921
201008419
200808431
 
Inspection Procedure 71151: Performance Indicator Verification
Procedures
Number
Title
Revision
CSP-ZZ-02550
Pressurized Reactor Coolant Sample
CSP-ZZ-07600
RCS Activity Determinations
 
Miscellaneous
Number
Title
Revision
Date
MSPI Derivation Reports (Cooling Water Systems)
Various
Control Room Log
Various
NRC Performance Indicator Transmittal Report, First
Quarter 2015, Mitigating Systems Cornerstone
April 11, 2018
NRC Performance Indicator Transmittal Report, Second
Quarter 2015, Mitigating Systems Cornerstone
July 18,
2018
NRC Performance Indicator Transmittal Report, Third
Quarter 2015, Mitigating Systems Cornerstone
October 25,
2018
NRC Performance Indicator Transmittal Report, Fourth
Quarter 2015, Mitigating Systems Cornerstone
January 16,
2018
Condition Reports
201101025
201004284
 
Inspection Procedure 71152: Problem Identification and Resolution
Procedures
Number
Title
Revision
APA-ZZ-00500
Corrective Action Program
ESP-EF-0001A
Ultimate Heat Sink Train A Cooling Tower Fill Inspection
 
Miscellaneous
Number
Title
Revision
EM-04
Safety Injection System (Cold Leg Recirculation Phase)
Fault Tree Model
BG-32
High Pressure Coolant Injection System (Cold Leg
Recirculation Phase) Fault Tree Model
BN-28
RWST Drain Down Time and Volume Loss During SBLOCA 0
M-015-U012-08
Specification for Ultimate Heat Sink Cooling Tower
 
Condition Reports
201706900
201707137
201704706
201010236
 
Inspection Procedure 71153: Follow-up of Events and Notices of Enforcement Discretion
Drawings
Number
Title
Revision
E-21NK02(Q)
Class IE 125V dc System Meter and Relay Diagram
J-200-00075
Main Control Board RL025 and RL026 Wiring Diagram
E-21NK01(Q)
Class IE 125V dc System Meter and Relay Diagram
E-051-00079
Battery Chargers Wiring Diagram
E-23NK11(Q)
25 Volt dc Class IE Power System Schematic
E-23CD02
Schematic Diagram Emergency Seal Oil Pump
E-23FC02
Schematic Diagram Feed Pump Turbine Emergency
Bearing Oil Pumps
E-21NK02(Q)
Class IE 125V dc System Meter and Relay Diagram
E-23CB03
Schematic Diagram Emergency Bearing Oil Pump
M-840-00014
Hydrogen and Water Cooling Wiring Diagram
M-840-00023
Schematic Diagram (Hydrology and Stator Cooling)
E-21NK01(Q)
Class IE 125V dc System Meter and Relay Diagram
 
Drawings
Number
Title
Revision
E-21NK01(Q)
Class IE 125V dc System Meter and Relay Diagram
M-830-00015
Emergency Bearing Oil Pump
IC-4061-T1 dc Magnetic Starter
M-012-00079
Wiring Diagram (Emergency Oil Pump Starter Circuit)
E-051-00058
SCR Controlled Battery Charger Schematic
M-835-00014
D.C. Magnetic Starter 72-13 (CD01) (Counter -
Electromotive Force) Emergency Seal Oil Pump Motor
J-200-00081
Main Control Board RL025 and RL026 Wiring Diagram
 
Miscellaneous
Number
Title
Revision/
Date
FR-087114
Bimetallic Thermal Overload Relays
December 13,
2017
Calculation KC-26 Nuclear Safety Capability Assessment Calculations:
KC-26
MP 15-0020
Install Fuses in 250 Vdc Control Circuits To Address
NFPA805 Concerns
 
Condition Reports
201706133
201706233
201706924
201706926
201801657
 
Initial Request for Information
Quarterly Baseline Inspection
Callaway Plant
 
Inspection Report: 05000483/2018001
Inspection Dates: January 1 - March 31, 2018
Inspection Procedure: IP 71111 series, IP 71152
Lead Inspector: Dan Bradley, Senior Resident Inspector
Information Requested For 1st Quarter 2018
The following information should be sent to the resident office in hard copy or electronic format
(Certrec IMS preferred) to the attention of Dan Bradley by January 15, 2018. These items shall
be available and ready for review on the day indicated in this request. Please provide
requested documentation electronically in pdf files, Excel, or other searchable formats, if
possible. The information should contain descriptive names and be indexed and hyperlinked to
facilitate ease of use. If requested documents are large and/or only hard copy formats are
available, please inform the inspector and provide subject documentation.
Please provide the following information for the 125 VDC (NK) and Instrument AC Power (NN)
systems:
1.
A list of all calculations and drawings associated with the selected systems.
2.
A list of condition reports associated with the selected systems for the last 3 years.
3.
A list of work orders associated with the selected systems for the last 3 years, including
all open work orders.
4.
An Excel spreadsheet list of equipment basic events (with definitions), including
importance measures sorted by risk achievement worth and Fussell-Vesely from your
internal events probabilistic risk assessment. Include basic events with a risk
achievement value of 1.3 or greater.
5.
A list of any pre-existing evaluations or calculations with low design margins for the
selected systems.
6.
A list of maintenance rule components and functions; based on engineering or expert
panel judgment, for the selected systems.
7.
A list of maintenance rule functional failure evaluations for the last 3 years for the
selected systems.
8.
A list of operating experience evaluations for the last 3 years for the selected systems.
9.
A list of all procedures and calculations that involve time-critical operator actions.
 
10. A list of permanent and temporary modifications performed in the past 3 years for the
selected systems. Include a list of any documents associated with modifications such
as: calculations, specifications, vendor manuals, Final Safety Analysis Report,
Technical Specifications and Bases updates, updated procedures, and maintenance and
surveillance activities and procedures.
11. A list of the design calculations that provide the design margin information for the
selected systems.
2. A list of root cause evaluations associated with component failures or design issues
initiated/completed in the last 3 years for the selected systems.
13. A list of any common-cause failures of components in the last 3 years for the selected
systems.
14. An electronic copy of the design bases documents for the selected systems.
15. An electronic copy of the system health notebooks for the selected systems.
Inspector Contact Information:
Dan Bradley
Senior Resident Inspector
573-676-3181
Dan.Bradley@nrc.gov
Mailing Address:
U.S. NRC Resident Inspector Office
201 NRC Road
Steedman, MO 65077
 
ML18123A395
SUNSI Review:
ADAMS:
Non-Publicly Available
Non-Sensitive
Keyword:
By: NHT/rdr
Yes No
Publicly Available
Sensitive
NRC-002
OFFICE
SRI/DRP/B
RI/DRP/B
C:DRS/EB1
C:DRS/EB2
C:DRS/OP
C:DRS/PSB2
NAME
DBradley
SJanicki
TFarnholtz
JDrake
VGaddy
HGepford
SIGNATURE
/RA/
/RA/
/RA/
/RA/
/RA/
/RA/
DATE
5/2/18
5/2/18
4/25/18
4/29/18
4/25/18
4/30/18
OFFICE
TL:DRS/IPAT
C:DRP/B
 
NAME
GGeorge
NTaylor
 
SIGNATURE
/RA/
/RA/
 
DATE
4/25/18
5/3/18
}}
}}

Latest revision as of 22:58, 5 January 2025

NRC Integrated Inspection Report 05000483/2018001
ML18123A395
Person / Time
Site: Callaway Ameren icon.png
Issue date: 05/03/2018
From: Nick Taylor
NRC/RGN-IV/DRP/RPB-B
To: Diya F
Ameren Missouri
Taylor N
References
IR 2018001
Download: ML18123A395 (30)
v • d • e


Text

May 3, 2018

SUBJECT:

CALLAWAY PLANT - NRC INTEGRATED INSPECTION REPORT 05000483/2018001

Dear Mr. Diya:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Callaway Plant. On April 4, 2018, the NRC inspectors discussed the results of this inspection with Mr. Tim Herrmann, 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.a 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.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Callaway Plant. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Nicholas H. Taylor, Branch Chief Project Branch B Division of Reactor Projects

Docket No. 50-483 License No. NPF-30

Enclosure:

Inspection Report 05000483/2018001 w/Attachment 1: Supplemental Information

Attachment 2: Request for Information

Enclosure U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number:

05000483

License Number:

NPF-30

Report Number:

05000483/2018001

Enterprise Identifier: I-2018-001-0006

Licensee:

Union Electric Company

Facility:

Callaway Plant

Location:

8315 County Road 459

Steedman, MO 65077

Inspection Dates:

January 1, 2018, to March 31, 2018

Inspectors:

D. Bradley, Senior Resident Inspector

S. Janicki, Resident Inspector

S. Alferink, Reactor Inspector

D. Dodson, Senior Resident Inspector

R. Kopriva, Senior Reactor Inspector

S. Makor, Reactor Inspector

J. Melfi, Project Engineer

Approved By:

N. Taylor

Chief, Project Branch B

Division of Reactor Projects

SUMMARY

The NRC continued monitoring licensees performance by conducting an integrated inspection at the Callaway Plant in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs 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 tables below. A NRC-identified non-cited violation is documented in report section 71111.1

List of Findings and Violations

Failure to Maintain Emergency Operating Procedures Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000483/2018001-01 Closed

[H.3] - Human Performance,

Change Management 71111.11 Licensed Operator Performance The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a,

"Procedures," for the licensee's failure to maintain emergency operating procedures for aligning auxiliary feedwater suction sources. Specifically, the licensee added continuous action steps to emergency operating procedures that placed both motor-driven auxiliary feedwater pumps in pull-to-lock and isolated their associated recirculation lines after depleting the two non-safety-related suction sources. These actions cause two of the three safety-related auxiliary feedwater pumps to be rendered inoperable prior to aligning the safety-related suction source of essential service water which is credited in accident analysis.

Additional Tracking Items

Type Issue number Title Report Section Status URI 05000483/2016001-01 Possible Incorrect Screening of the Spent Fuel Pool Decay Heat Removal Key Safety Function 71111.05AQ Closed LER 05000483/2013-009-00 Appendix R Unanalyzed Condition - Direct Current Ammeter Circuits Without Overcurrent Protection 71153 Closed LER 05000483/2014-004-00 Postulated Hot Short Fire Event that Could Adversely Impact Shutdown Equipment 71153 Closed LER 05000483/2017-001-00 05000483/2017-001-01 Violation of Technical Specification 3.7.9 Due to Ultimate Heat Sink Cooling Tower Train Inoperability 71153 Closed

LER 05000483/2017-002-01 Inadequate Protection from Tornado Missiles Identified due to Nonconforming Design 71153 Closed LER 05000483/2017-003-00 Violation of Technical Specification 3.6.3,

Containment Isolation Check Valve Found in Open Position 71153 Closed NOV 05000483/2017007-01 Not Verifying the Operation and Timing of the Engineered Safety Feature Transformer XNB01 Load Tap Changer 92702 Closed

PLANT STATUS

Callaway Plant began the inspection period at full power. On March 14, 2018, the licensee reduced power to 45 percent to replace a reactor coolant system flow transmitter, commenced ascending in power upon completion of testing, and returned to full power on the same day.

The licensee 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

Impending Severe Weather (1 Sample)

The inspectors evaluated readiness for impending adverse weather conditions for:

(1) Severe winter weather on January 11, 2018

71111.04 - Equipment Alignment

Partial Walkdown (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Component cooling water train B on January 10, 2018
(2) Control room filtration unit FGK02B on January 25, 2018
(3) Battery charger NK26 on February 7, 2018

Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of:

(1) Instrument AC power (NN) system on January 18, 2018

71111.05AQ - Fire Protection Annual/Quarterly

Quarterly Inspection (5 Samples)

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

(1) Control building 2016 elevation, fire area C-15 on January 12, 2018
(2) Auxiliary feedwater pipe chase 1988 elevation, fire area A-1 on February 16, 2018
(3) Control room air conditioning and filtration units, fire areas A-21 and A-22 on March 6, 2018
(4) Electrical penetration rooms, fire areas A-17 and A-18 on March 11, 2018
(5) Intake structure, fire area IS-1 on March 28, 2018

71111.06 - Flood Protection Measures

Internal Flooding (1 Sample)

The inspectors evaluated internal flooding mitigation protection:

(1) Control building 2016 elevation on January 9, 2018

71111.07 - Heat Sink Performance

Heat Sink (1 Sample)

The inspectors evaluated:

(1) Emergency diesel generator jacket water heat exchanger train A on March 22, 2018

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (1 Sample)

The inspectors observed and evaluated simulator training for operating crews:

(1) Electrical faults on February 6, 2018

Operator Performance (1 Sample)

The inspectors observed and evaluated:

(1) Surveillance testing for the auxiliary feedwater system on February 20, 2018
(2) Surveillance testing for the emergency diesel generator train B and reactor coolant flow transmitter troubleshooting on March 7, 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) 125 VDC system (NK) on January 17, 2018
(2) Instrument AC power system (NN) on February 14, 2018

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

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

(1) Elevated risk actions due to planned centrifugal charging pump B and component cooling water equipment outage on January 30, 2018
(2) Elevated risk actions due to planned switchyard maintenance on February 5, 2018
(3) Elevated risk actions due to planned safety injection train A equipment outage on February 13, 2018
(4) Emergent risk actions due to auxiliary feedwater pump door failure on February 20, 2018
(5) Elevated risk actions due to planned turbine-driven auxiliary feedwater pump equipment outage on February 27, 2018

71111.15 - Operability Determinations and Functionality Assessments

Main article: IP 71111.15

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Rising level trend in safety injection accumulators on January 8, 2018
(2) Reactor building service air header supply containment isolation valve KAV0118 out of position on January 15, 2018
(3) Battery charger NK25 equalize potentiometer failure on January 16, 2018
(4) Spent fuel pool calculation assumptions on February 13, 2018
(5) Turbine-driven auxiliary feedwater pump room door DSK13311 failure on March 2, 2018

71111.18 - Plant Modifications

Main article: IP 71111.18

The inspectors evaluated the following permanent modification:

(1) MP 12-0020 electrical tie-ins for FLEX on March 29, 2018

71111.19 - Post Maintenance Testing

Main article: IP 71111.19

The inspectors evaluated the following post maintenance tests:

(1) Control room air conditioning unit SGK04B equipment outage on January 10, 2018
(2) Class 1E battery charger NK25 equipment outage on January 22, 2018
(3) Class 1E battery charger NK21 equipment outage on January 29, 2018
(4) Turbine-driven auxiliary feedwater pump equipment outage on February 28, 2018
(5) Emergency diesel generator and essential service water train A equipment outage on March 23, 2018

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine

Main article: IP 71111.22
(1) OSP-NE-0001A, standby diesel generator A periodic tests on January 24, 2018

In-service (2 Samples)

(1) OSP-BG-P005A, centrifugal charging pump A inservice test - Group B on February 15, 2018
(2) OSP-EG-P01BD, component cooling water train B pump and valve inservice test - group A on March 29, 2018

Containment Isolation Valve (1 Sample)

(1) OSP-KC-LL067, containment isolation valve leak rate test and results of check valve internal inspection under Condition Report 201706233 on March 15, 2018

71114.06Drill Evaluation Emergency Planning Drill

Main article: IP 71114.06

The inspectors evaluated the radiological emergency response plan drill:

(1) Team 4 on March 8, 2018

Drill/Training Evolution (1 Sample)

The inspectors evaluated annual emergency response organization training evolution:

(1) Team 4 on February 1,

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

Main article: IP 71151

The inspectors verified licensee performance indicators submittals listed below:

(1) MS06: Emergency AC Power Systems (01/01/2017-12/31/2017)
(2) MS10: Cooling Water Support Systems (01/01/2017-12/31/2017)
(3) BI01: Reactor Coolant System (RCS) Specific Activity Sample (01/01/2017-12/31/2017)

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Safety injection pump oil leak, Condition Report 201704706
(2) Ultimate heat sink cooling tower shroud bolting, Condition Report 201010236

71153 - Follow-up of Events and Notices of Enforcement Discretion Licensee Event Reports

Main article: IP 71153

The inspectors evaluated the following licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) Licensee Event Report 05000483/2013-009-00, Appendix R Unanalyzed Condition - Direct Current Ammeter Circuits Without Overcurrent Protection, on October 9, 2013
(2) Licensee Event Report 05000483/2014-004-00, Postulated Hot Short Fire Event that Could Adversely Impact Shutdown Equipment, on September 19, 2014
(3) Licensee Event Reports 05000483/2017-001-00 and 05000483/2017-001-01, Violation of Technical Specification 3.7.9 Due to Ultimate Heat Sink (UHS) Cooling Tower Train Inoperability, on June 16, 2017
(4) Licensee Event Report 05000483/2017-002-01, Inadequate Protection from Tornado Missiles Identified due to Nonconforming Design, on August 15, 2017
(5) Licensee Event Report 05000483/2017-003-00, Violation of Technical Specification 3.6.3, Containment Isolation Check Valve Found in Open Position, on October 31, 2017

92702 - Followup on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, Confirmatory Orders, and Alternative Dispute Resolution Confirmatory Orders Notice of Violation

Main article: IP 92702

The inspectors reviewed the licensees response to Notice of Violation 05000483/2017007-01, Not Verifying the Operation and Timing of the Engineered Safety Feature Transformer XNB01 Load Tap Changer, and determined that the reason, corrective actions taken and planned to address recurrence, and the date when full compliance was achieved for this violation is adequately addressed and captured on the docket.

INSPECTION RESULTS

Failure to Maintain Emergency Operating Procedures Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000483/2018001-01 Closed

[H.3]Human Performance, Change Management 71111.11 Licensed Operator Performance The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a, "Procedures," for the licensee's failure to maintain emergency operating procedures for aligning auxiliary feedwater suction sources. Specifically, the licensee added continuous action steps to emergency operating procedures that placed both motor-driven auxiliary feedwater pumps in pull-to-lock and isolated their associated recirculation lines after depleting the two non-safety-related suction sources. These actions cause two of the three safety related auxiliary feedwater pumps to be rendered inoperable prior to aligning the safety related suction source of essential service water which is credited in accident analysis.

Description:

On March 7, 2018, the inspectors performed an observation of licensed control room operators and reviewed the use of auxiliary feedwater pumps (AFW or AFPs) in Emergency Operating Procedures (EOPs). The AFW system provides a reliable source of water to the steam generators and removes thermal energy from the reactor coolant system through the release of secondary steam to the atmosphere. The AFW pumps are comprised of two motor-driven (MD) pumps and one turbine-driven (TD) pump. Each pump has recirculation lines to provide a constant discharge pathway and prevent pump damage. These AFW pumps can be supplied with the following three suction sources:

(1) Condensate storage tank (CST) - non-safety-related and normally aligned
(2) Hardened CST (HCST) - non-safety-related
(3) Essential service water (ESW) - safety-related

In their review of EOPS, the inspectors noted that the following continuous action step was found in several EOPs and titled AFW Supply Switchover Criteria:

If CST to AFP suction header pressure lowers to less than 11.5 PSIG, THEN PERFORM EOP Addendum 42, HCST Alignment.

If CST to AFP suction header pressure lowers to less than 2.75 PSIG, THEN PERFORM EOP Addendum 19, Aligning ESW to AFW Suction.

The inspectors reviewed EOP Addendum 42, HCST Alignment, Revision 1, which states the following and accomplishes it in step 1 of the addendum:

When the HCST is supplying AFW, ONLY the TDAFW will be used, since it can be aligned to recirc back to the HCST. Therefore, the MDAFPs will be placed in Pull-to-Lock prior to isolating MDAFP recirc lines back to the CST.

The inspectors noted that EOP Addendum 19, Aligning ESW to AFW Suction, Revision 3, did not restore the isolated and disabled motor-driven AFW pumps. Instead, EOP Addendum 19 refers only to the ESW valve lineup. As written, the discussed EOP addenda would leave the control room staff with only the turbine-driven AFW pump available.

The inspectors then reviewed accident analysis including section 15.2.8, Feedwater System Pipe Break, of the Final Safety Analysis Report which states:

For the auxiliary feedwater system, the worst case configuration has been used, i.e., only three intact steam generators receive auxiliary feedwater following the break... one motor-driven AFW pump to the intact steam generatorthe turbine-driven AFW pump has been assumed to fail... the second motor-driven AFW pump is assumed to deliverequally split to the two remaining intact steam generators...

The inspectors noted that the accident analysis of Final Safety Analysis Report chapter 15 does not refer to use of the HCST and does not refer to operator action to manually un-isolate motor-driven AFW pumps to reach and maintain safe shutdown.

The inspectors reviewed the extent of condition for the AFW Supply Switchover Criteria continuous action steps and found it in the following EOPs:

(1) E-0, Reactor Trip or Safety Injection, Revision 19
(2) E-1, Loss of Reactor or Secondary Coolant, Revision 19
(3) E-3, Steam Generator Tube Rupture, Revision 22
(4) ES-0.1, Reactor Trip Response, Revision 18
(5) FR-H.1, Response To Loss of Secondary Heat Sink, Revision 18

The inspectors noted the HCST Alignment addendum was created in February 2016 and modified in October 2016 to the current Revision 1. The procedure review process noted the non-safety HCST is a useful water source prior to using the ESW... the HCST is maintained at a higher cleanliness. Further, the procedure review noted the HCST:

does not have a recirculation line from the Motor Drive Aux Feed pumps to the HCST... EOP Add 42 allows for the alignment of the recirc valves and stops the Motor Drive Aux Feedwater Pumps to prevent possible damage from overheating. Since this overall modification has been evaluated previously, this procedure change does not require further 50.59 review.

The inspectors concluded the licensee failed to maintain EOPs for aligning auxiliary feedwater suction sources. Specifically, the EOPs placed both motor-driven auxiliary feedwater pumps in pull-to-lock and isolated their associated recirculation lines prior to aligning the safety-related suction source of essential service water. This configuration and operator actions are not supported by the accident analysis in the Final Safety Analysis Report.

Further, the licensee did not provide an adequate procedure for restoring the motor-driven AFW pumps from this configuration. Since the continuous action steps are pervasive across EOPs, it is plausible that an operating crew would enact the AFW supply switchover actions prior to fully diagnosing the accident and contrary to the goal of the EOP they were utilizing.

Corrective Actions: The licensee issued a night order clarifying the requirements for auxiliary feedwater in the EOPs and revised EOP Addendum 42, HCST Alignment.

Corrective Action Reference: Condition Reports 201801260 and 201801570.

Performance Assessment:

Performance Deficiency: The failure to maintain Emergency Operating Procedures for aligning auxiliary feedwater suction sources was a performance deficiency.

Screening: This performance deficiency was more than minor, and therefore a finding, because it adversely affected the procedure quality attribute of the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee added continuous action steps to EOPs that placed both motor-driven auxiliary feedwater pumps in pull-to-lock and isolated their associated recirculation lines after depleting the two non-safety-related suction sources. These actions cause two of the three safety related auxiliary feedwater pumps to be rendered inoperable prior to aligning the safety related suction source of essential service water which is credited in accident analysis.

Significance: Using Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, the inspectors determined that the finding was of very low safety significance (Green) because

(1) the finding was not a deficiency affecting the design or qualification of a mitigating system;
(2) the finding did not represent a loss of system and/or function;
(3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and
(4) the finding does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensee's maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Cross-Cutting Aspect: The finding had a cross-cutting aspect in the area of human performance associated with change management because the licensee failed to use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. Specifically, the licensee prioritized the motor-driven AFW pumps health due to a lack of recirculation ability over the accident analysis by not adequately screening the procedure changes into 50.59 review in 2016.

Enforcement:

Violation: Technical Specification 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2. Section 6 of Appendix A to Regulatory Guide 1.33, Revision 2, requires procedures for combating emergencies and other significant events. The licensee established EOP Addendum 42, HCST Alignment, Revision 1, in part, to meet the regulatory requirement. Step 1 of EOP Addendum 42 placed both motor-driven auxiliary feedwater pumps in pull-to-lock and isolated their associated recirculation lines.

Contrary to the above, prior to March 7, 2018, the licensee failed to maintain procedures for combating emergencies and other significant events. Specifically, the licensee failed to maintain EOPs for aligning auxiliary feedwater suction sources. The licensee added continuous action steps to EOPs that placed both motor-driven auxiliary feedwater pumps in pull-to-lock and isolated their associated recirculation lines after depleting the two non-safety-related suction sources. These actions cause two of the three safety related auxiliary feedwater pumps to be rendered inoperable prior to aligning the safety related suction source of essential service water which is credited in accident analysis.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy.

Unresolved Item (Closed)

Possible Incorrect Screening of the Spent Fuel Pool Decay Heat Removal Key Safety Function URI 05000483/2016001-01 71111.05AQ Quarterly Inspection

Description:

In Unresolved Item 05000483/2016001-01, the inspectors documented an issue of concern with the licensees National Fire Protection Association (NFPA) Standard 805, Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating Plants, non-power operations assessment. Specifically, the inspectors developed an issue of concern because the licensee screened the potential loss of spent fuel pool cooling from further consideration for any fire event during non-power operations based on adequate procedural guidance and time when the procedures would not maintain the fuel in a safe and stable condition.

To address this unresolved item, the inspectors requested that the Office of Nuclear Reactor Regulation (NRR) work with the Nuclear Energy Institute NFPA 805 Task Force in accordance with the NFPA 805 Frequently Asked Questions (FAQ) Program to review and update the guidance in FAQ 07-0040, Non-Power Operations Clarifications, Revision 4. The inspectors documented this request in a memo, dated March 31, 2016 (ML16091A152). The updated guidance was issued in FAQ 07-0040, Revision 5 on May 20, 2016 (ML17331B109). This revision was accepted by NRR staff in a memo, dated November 28, 2017 (ML17331B108).

The revised guidance provided clarification for the treatment of spent fuel pool cooling during non-power operations. The revised guidance stated that, Spent fuel pool configurations are not considered to be risk-significant and are not treated as a higher risk evolution. In the approval memo, the NRR staff agreed with the revised guidance, stating, The NRC staff agrees that the loss of spent fuel pool cooling does not need to be considered a higher risk evolution.

The licensee documented the non-power operations assessment in Calculation KC-26, Appendix 1, NFPA 805 Non-power Operations Assessment, Revision 3. The licensee performed this assessment based, in part, on guidance in FAQ 07-0040, Revision 4.

During the current inspection, the inspectors reviewed the licensees non-power operations assessment and the revised guidance in FAQ 07-0040, Revision 5. In accordance with the revised guidance, the licensee did not need to perform additional analyses (Steps F.2 and F.3. of FAQ 07-0040) associated with spent fuel pool cooling because the staff agreed that the normal fire protection program defense-in-depth actions provide reasonable assurance that the spent fuel pool remains less than boiling. Based on the licensees non-power operations assessment and the revised guidance, the inspectors determined that no performance deficiency existed.

Corrective Action Reference: Condition Report 201600726

Observation 92702Followup on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, Confirmatory Orders, and Alternative Dispute Resolution Confirmatory Orders Discussion: The inspection team determined that the licensee had not: 1) adequately performed a timing test of the transformer XNB01 load tap changer to ensure proper operation; and 2) periodically performed a timing test of the transformer XNB01 load tap changer to ensure proper operation to maintain the operability of the offsite power sources.

Since the issuance of the violation in 2014, the licensee had opportunities to perform a timing test of transformer XNB01 load tap changer (refueling outages in fall 2014 and spring 2016).

Corrective Steps Taken and Results Achieved: The timing test of the XNBO1 load tap changer was successfully tested on October 20, 2017. Timing testing of the XNBO1 and XNB02 load tap changers will continue to be performed on a routine basis, going forward.

Also, Callaway work management procedure will be revised to establish schedule dates for jobs associated with addressing NRC violations. Rescheduling jobs beyond the scheduled date would require justification as well as approval by management. The licensee will review any NRC violations received since October 2015 for jobs that are credited for restoring compliance. The basis for selecting October 2015 was that it coincided with the last time a comprehensive pre-Problem Identification and Resolution inspection self-assessment was performed. In that assessment, the timeliness of corrective actions for NRC violations prior to October 2015 was evaluated. Lessons learned in connection with this Notice of Violation will be communicated by station leadership. This will include expectations on identifying and adhering to the scheduled date for jobs addressing violations, as mentioned above. Both actions were complete by February 28, 2018.

The inspectors reviewed the licensees response to the Notice of Violation along with corrective action documents. All findings were documented in NRC Inspection Report 05000483/2017007, ADAMS accession number ML17283A392. Notice of Violation 0500483/2017007-01 is closed.

MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.

On April 4, 2018, the inspectors presented the integrated quarterly resident inspection results to Mr. Tim Herrmann, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Procedure 71111.01: Adverse Weather Protection

Procedures

Number

Title

Revision

OTN-QJ-00003

Plant Freeze Protection Heat Tracing Procedure

OTO-ZZ-00012

Severe Weather

Condition Reports

201800054

201800255

Inspection Procedure 71111.04: Equipment Alignment

Procedures

Number

Title

Revision

OTN-NK-00001

Class 1E 125 VDC Electrical System

OTN-NN-00001

20 V Vital AC Instrument Power - Class 1E (Channel 1)

OTN-EG-00001

Component Cooling Water System

Calculations

Number

Title

Revision

E-H-18

System NN Relay Settings - Calculate Settings for NN

Protective Relays

GK-11

Electrical Heat Loads in the Control Building During Normal

and ESFAS Conditions

GL-10 Add 2

Evaluate Tube Plugging Limits for SGL 15 A/B

EG-54

Allowable Gas Void Volume for each Train of the

Component Cooling Water Suction Piping

M-EG-20

Max CCW Temperature Post LOCA

Miscellaneous

Number

Title

Revision

10466-M-612

Design Specification for Room Coolers

M-618.2

Spec for Q-Listed HVAC Ductwork (Installation)

RFR 180048

Evaluate Non-Safety Accessories in Safety HVAC Systems

Miscellaneous

Number

Title

Revision

M-22EG01

Piping and Instrumentation Diagram Component Cooling

Water System

ULDBD-EG-01

Component Cooling Water System

M-082-00039

Instruction Manual for Component Cooling Water Pumps

Condition Reports

201707171

201706754

201800235

201800933

201801160

201800157

201800176

201303691

Inspection Procedure 71111.05: Fire Protection

Procedures

Number

Title

Revision

Fire Preplan Manual

FPP-ZZ-00000

Guidelines for Writing Prefire Strategy Procedures and

Preplans

APA-ZZ-00700

Fire Protection Program

Condition Reports

201706984

201801219

201801220

200910299

200505787

200809214

201604688

Inspection Procedure 71111.06: Flood Protection Measures

Procedures

Number

Title

Revision

Fire Preplan Manual

OTO-ZZ-00005

Flooding

Calculations

Number

Title

Revision

AMN-010-CALC-002 Flood Levels in Control Building Rooms Due to Pipe

Break or Crack

Condition Reports

201609311

201800649

Inspection Procedure 71111.07A: Heat Exchanger Performance

Procedures

Number

Title

Revision

HX-1.PMB

Heat Exchangers

APA-ZZ-00801

Foreign Material Exclusion

EDP-ZZ-01112

Heat Exchanger Predicative Performance Manual

Calculations

Number

Title

Revision

KJ-20

Evaluate Tube Plugging Limits for EKJ03A/B,

EKJ04A/B, and EKJ06A/B

M-1196-00002

Jacket Water Cooler Performance Evaluation

Jobs

13511907

09512424

Condition Reports

201500625

201600703

201800394

201801456

200803533

200909091

200204569

Inspection Procedure 71111.11: Licensed Operator Requalification Program and

Licensed Operator Performance

Procedures

Number

Title

Revision

AL-30

Auxiliary Feedwater System Performance During a Loss of

Normal Feedwater Flow and Non-Emergency A/C Power

E-0

Reactor Trip or Safety Injection

ISF-AL-00P37

CST to AFP Suction Header Pressure Channel Operational

Test

ISL-BB-0F434

RCS Flow Channel Cal Loop 3 Protection 1

OSP-AL-00003

Auxiliary Feedwater LSP CST to ESW Valve Operability

Procedures

Number

Title

Revision

T61.0810 8

Licensed Operator Continuing Training - Simulator Training

Scenario Guide

January 23,

2018

Condition Reports

201707139

201102329

201801260

Inspection Procedure 71111.12: Maintenance Effectiveness

Procedures

Number

Title

Revision

APA-ZZ-00395

Significant Operator Response Timing

EDP-ZZ-01128

Maintenance Rule Program

EDP-ZZ-01128,

Appendix 1

SSCs in the Scope of the Maintenance Rule at Callaway

EDP-ZZ-01128,

Appendix 2

Summary of SSC Performance Criteria

EDP-ZZ-01128,

Appendix 3

Maintenance Rule Shutdown Performance Criteria

EDP-ZZ-01128,

Appendix 4

Maintenance Rule System Functions

OSP-SA-2413A

Train A Diesel Generator and Sequencer Testing

Miscellaneous

Number

Title

Revision

E-051C-00010

Qualification Report for Class 1E 125 VDC Electronically

Controlled Manual Switches

E-1061

Specification for Class 1E AC Vital Bus Inverters and Swing

Inverters

MP-130020

Modification to Install Class 1E Swing Inverters

Condition Reports

200805033

201303158

201307777

20143898

201407350

201505907

201602855

201603286

201603312

201604824

201605545

201607358

201702520

201705797

201706481

201800216

Miscellaneous

Number

Title

Revision/

Date

LER 2014-003-00 Inverter NN11 Inadvertently Transferred to Its Alternate

Source

August 7,

2014

LER 2014-003-02 Inverter NN11 Inadvertently Transferred to Its Alternate

Source

August 6,

2015

ODMI 15-0006

Thermography Indicated Elevated Temperatures on

Disconnect NN0311

Inspection Procedure 71111.13: Maintenance Risk Assessments and Emergent Work

Control

Procedures

Number

Title

Revision

APA-ZZ-00750

Hazard Barrier Program

ODP-ZZ-00002,

Appendix 2

Risk Management Actions For Planned Risk Significant

Activities

EDP-ZZ-01129

Callaway Energy Center Risk Assessment

APA-ZZ-00322

Integrated Work Management Process Description

APA-ZZ-00322,

Appendix F

Online Work Integrated Risk Management

APA-ZZ-00315

Configuration Risk Management Program

ODP-ZZ-00002,

Appendix 1

Protected Equipment Program

OTN-BG-00001

Chemical and Volume Control System

MPE-ZZ-QY054

Inspection and Test of Protective Lockout Relays, General

Electric Type HEA

OTN-MD-00001

Switchyard Breakers and Disconnects

MTM-AL-QP002

Turbine Driven Auxiliary Feedwater Pump

Jobs

16513469

16508486

18000148

16508306

14504707

16514154

15503300

17500047

Condition Reports

201800516

201106906

200604069

201605319

201705780

201505319

201800176

201800157

200000661

Inspection Procedure 71111.15: Operability Determinations and Functionality

Assessments

Procedures

Number

Title

Revision

APA-ZZ-00391

Beyond Design Basis Program

APA-ZZ-00391,

Appendix 2

Sequence of Events Timeline

OSP-KC-00015

Fire Door Inspections

APA-ZZ-00750

Hazard Barrier Program

OTG-ZZ-00006

Plant Cooldown Hot Standby to Cold Shutdown

OSP-GT-00003

Containment Closure

OSP-GP-00001

Containment Isolation Verification

Miscellaneous

Number

Title

Revision

M-22FC02

Auxiliary Feedwater Pump Turbine P&ID

M-FC-03

Auxiliary Feedwater Pump Turbine Room Analysis

M-YY-49,

Addendum 4

Additional HELB Scenarios

2

Auxiliary & Reactor Building Elevation 2000 Floor Plan

Westinghouse Clarification on the Basis for the Boil Off

Time of the Callaway Energy Center Spent Fuel Pool

ULNRC-06421

Licensee Event Report 2018-001-00 Violation of Technical Specification 3.6.3 Containment Isolation Manual Valve

Found in Open Position

M-22KA02

Compressed Air System P&ID

Jobs

18000323

13511394

09501018

18000249

18000735

Condition Reports

201800066

201800235

201800194

Inspection Procedure 71111.18: Plant Modifications

Miscellaneous

Number

Title

Revision

MP 12-0020

Field Change Notice

Seismic II/I Hazard Analysis Review for MP 12-0020

STARS ENG-5001-8.3, Section 13 FP Review

Inspection Procedure 71111.19: Post Maintenance Testing

Procedures

Number

Title

Revision

MTM-AL-QP002

Turbine Driven Auxiliary Feedwater Pump

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

OSP-GK-0002B

Train B Control Room Ventilation and Pressure Test

OSP-NE-0001A

Standby Diesel Generator A Periodic Tests

OSP-NE-00003

Technical Specification Actions - A/C Sources

OTN-EF-00001

Essential Service Water System

Miscellaneous

Number

Title

Revision

M-22FC02

Auxiliary Feedwater Pump Turbine P&ID

MP 15-0020

Install Fuses in 250Vdc Control Circuits

E-23NK11

25 Volt DC Class 1E Power System Schematic Diagram

Jobs

17004200

16002592

15505343

16509603

18000735

14000994

18000457

17503253

13511907

17004111

16511918

Condition Reports

201706923

201800442

201704649

201704899

201800145

201700177

201800206

201705121

201604537

201110062

201800926

201820013

201800874

200801131

201703920

200811040

Inspection Procedure 71111.22: Surveillance Testing

Procedures

Number

Title

Revision

OSP-BG-P005A

Centrifugal Charging Pump A Inservice Test

APA-ZZ-00340

Surveillance Program Administration

OSP-BG-00001

Boron Injection Flow Paths Modes 1, 2 and 3

ODP-ZZ-00036

Technical Specification Application for Containment Isolation

Valves

EDP-ZZ-01128

Summary of SSC Performance Criteria

APA-ZZ-00549,

Appendix B

Guidelines used to determine functional importance for a

component

Miscellaneous

Number

Title

Revision/

Date

M-721-00093

Instruction Manual for Centrifugal Charging/Safety-Injection

Pumps Operation and Maintenance

M-22BG01

Chemical and Volume Control System P&ID

MP 12-0020

Field Change Notice

Night Order

Condition Report 201706233/Condition Report 201706926,

KCV0478 may stick open during flow through

penetrations P067

January 31,

2018

ULDBD-BB-001

Reactor Coolant System

Jobs

17514632

05504483

17004820

Condition Reports

201800330

201800423

200702585

200901841

200306153

200502806

201706233

201706926

201800323

Inspection Procedure 71114.06: Drill Evaluation

Procedures

Number

Title

Revision

APA-ZZ-00925

Training and Qualification of Plant Personnel

Procedures

Number

Title

Revision

EIP-ZZ-A0066

Radiological Emergency Response Plan Training

EIP-ZZ-A0001

Emergency Response Organization

Condition Reports

201801245

201801251

201801252

2000800921

201008419

200808431

Inspection Procedure 71151: Performance Indicator Verification

Procedures

Number

Title

Revision

CSP-ZZ-02550

Pressurized Reactor Coolant Sample

CSP-ZZ-07600

RCS Activity Determinations

Miscellaneous

Number

Title

Revision

Date

MSPI Derivation Reports (Cooling Water Systems)

Various

Control Room Log

Various

NRC Performance Indicator Transmittal Report, First

Quarter 2015, Mitigating Systems Cornerstone

April 11, 2018

NRC Performance Indicator Transmittal Report, Second

Quarter 2015, Mitigating Systems Cornerstone

July 18,

2018

NRC Performance Indicator Transmittal Report, Third

Quarter 2015, Mitigating Systems Cornerstone

October 25,

2018

NRC Performance Indicator Transmittal Report, Fourth

Quarter 2015, Mitigating Systems Cornerstone

January 16,

2018

Condition Reports

201101025

201004284

Inspection Procedure 71152: Problem Identification and Resolution

Procedures

Number

Title

Revision

APA-ZZ-00500

Corrective Action Program

ESP-EF-0001A

Ultimate Heat Sink Train A Cooling Tower Fill Inspection

Miscellaneous

Number

Title

Revision

EM-04

Safety Injection System (Cold Leg Recirculation Phase)

Fault Tree Model

BG-32

High Pressure Coolant Injection System (Cold Leg

Recirculation Phase) Fault Tree Model

BN-28

RWST Drain Down Time and Volume Loss During SBLOCA 0

M-015-U012-08

Specification for Ultimate Heat Sink Cooling Tower

Condition Reports

201706900

201707137

201704706

201010236

Inspection Procedure 71153: Follow-up of Events and Notices of Enforcement Discretion

Drawings

Number

Title

Revision

E-21NK02(Q)

Class IE 125V dc System Meter and Relay Diagram

J-200-00075

Main Control Board RL025 and RL026 Wiring Diagram

E-21NK01(Q)

Class IE 125V dc System Meter and Relay Diagram

E-051-00079

Battery Chargers Wiring Diagram

E-23NK11(Q)

25 Volt dc Class IE Power System Schematic

E-23CD02

Schematic Diagram Emergency Seal Oil Pump

E-23FC02

Schematic Diagram Feed Pump Turbine Emergency

Bearing Oil Pumps

E-21NK02(Q)

Class IE 125V dc System Meter and Relay Diagram

E-23CB03

Schematic Diagram Emergency Bearing Oil Pump

M-840-00014

Hydrogen and Water Cooling Wiring Diagram

M-840-00023

Schematic Diagram (Hydrology and Stator Cooling)

E-21NK01(Q)

Class IE 125V dc System Meter and Relay Diagram

Drawings

Number

Title

Revision

E-21NK01(Q)

Class IE 125V dc System Meter and Relay Diagram

M-830-00015

Emergency Bearing Oil Pump

IC-4061-T1 dc Magnetic Starter

M-012-00079

Wiring Diagram (Emergency Oil Pump Starter Circuit)

E-051-00058

SCR Controlled Battery Charger Schematic

M-835-00014

D.C. Magnetic Starter 72-13 (CD01) (Counter -

Electromotive Force) Emergency Seal Oil Pump Motor

J-200-00081

Main Control Board RL025 and RL026 Wiring Diagram

Miscellaneous

Number

Title

Revision/

Date

FR-087114

Bimetallic Thermal Overload Relays

December 13,

2017

Calculation KC-26 Nuclear Safety Capability Assessment Calculations:

KC-26

MP 15-0020

Install Fuses in 250 Vdc Control Circuits To Address

NFPA805 Concerns

Condition Reports

201706133

201706233

201706924

201706926

201801657

Initial Request for Information

Quarterly Baseline Inspection

Callaway Plant

Inspection Report: 05000483/2018001

Inspection Dates: January 1 - March 31, 2018

Inspection Procedure: IP 71111 series, IP 71152

Lead Inspector: Dan Bradley, Senior Resident Inspector

Information Requested For 1st Quarter 2018

The following information should be sent to the resident office in hard copy or electronic format

(Certrec IMS preferred) to the attention of Dan Bradley by January 15, 2018. These items shall

be available and ready for review on the day indicated in this request. Please provide

requested documentation electronically in pdf files, Excel, or other searchable formats, if

possible. The information should contain descriptive names and be indexed and hyperlinked to

facilitate ease of use. If requested documents are large and/or only hard copy formats are

available, please inform the inspector and provide subject documentation.

Please provide the following information for the 125 VDC (NK) and Instrument AC Power (NN)

systems:

1.

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

2.

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

3.

A list of work orders associated with the selected systems for the last 3 years, including

all open work orders.

4.

An Excel spreadsheet list of equipment basic events (with definitions), including

importance measures sorted by risk achievement worth and Fussell-Vesely from your

internal events probabilistic risk assessment. Include basic events with a risk

achievement value of 1.3 or greater.

5.

A list of any pre-existing evaluations or calculations with low design margins for the

selected systems.

6.

A list of maintenance rule components and functions; based on engineering or expert

panel judgment, for the selected systems.

7.

A list of maintenance rule functional failure evaluations for the last 3 years for the

selected systems.

8.

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

9.

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

10. A list of permanent and temporary modifications performed in the past 3 years for the

selected systems. Include a list of any documents associated with modifications such

as: calculations, specifications, vendor manuals, Final Safety Analysis Report,

Technical Specifications and Bases updates, updated procedures, and maintenance and

surveillance activities and procedures.

11. A list of the design calculations that provide the design margin information for the

selected systems.

2. A list of root cause evaluations associated with component failures or design issues

initiated/completed in the last 3 years for the selected systems.

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

systems.

14. An electronic copy of the design bases documents for the selected systems.

15. An electronic copy of the system health notebooks for the selected systems.

Inspector Contact Information:

Dan Bradley

Senior Resident Inspector

573-676-3181

Dan.Bradley@nrc.gov

Mailing Address:

U.S. NRC Resident Inspector Office

201 NRC Road

Steedman, MO 65077

ML18123A395

SUNSI Review:

ADAMS:

Non-Publicly Available

Non-Sensitive

Keyword:

By: NHT/rdr

Yes No

Publicly Available

Sensitive

NRC-002

OFFICE

SRI/DRP/B

RI/DRP/B

C:DRS/EB1

C:DRS/EB2

C:DRS/OP

C:DRS/PSB2

NAME

DBradley

SJanicki

TFarnholtz

JDrake

VGaddy

HGepford

SIGNATURE

/RA/

/RA/

/RA/

/RA/

/RA/

/RA/

DATE

5/2/18

5/2/18

4/25/18

4/29/18

4/25/18

4/30/18

OFFICE

TL:DRS/IPAT

C:DRP/B

NAME

GGeorge

NTaylor

SIGNATURE

/RA/

/RA/

DATE

4/25/18

5/3/18

May 3, 2018

Mr. Fadi Diya, Senior Vice President

and Chief Nuclear Officer

Ameren Missouri

Callaway Plant

P. O. Box 620

Fulton, MO 65251

SUBJECT:

CALLAWAY PLANT - NRC INTEGRATED INSPECTION

REPORT 05000483/2018001

Dear Mr. Diya:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

at your Callaway Plant. On April 4, 2018, the NRC inspectors discussed the results of this

inspection with Mr. Tim Herrmann, 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.a of the Enforcement Policy.

If you contest the violation or significance of this NCV, you should provide a response within

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.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a

response within 30 days of the date of this inspection report, with the basis for your

disagreement, to the

U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,

Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the

NRC resident inspector at the Callaway Plant.

F. Diya

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 05000483/2018001

w/Attachment 1: Supplemental Information

2: Request for Information

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number:

05000483

License Number:

NPF-30

Report Number:

05000483/2018001

Enterprise Identifier: I-2018-001-0006

Licensee:

Union Electric Company

Facility:

Callaway Plant

Location:

8315 County Road 459

Steedman, MO 65077

Inspection Dates:

January 1, 2018, to March 31, 2018

Inspectors:

D. Bradley, Senior Resident Inspector
S. Janicki, Resident Inspector
S. Alferink, Reactor Inspector
D. Dodson, Senior Resident Inspector
R. Kopriva, Senior Reactor Inspector
S. Makor, Reactor Inspector
J. Melfi, Project Engineer

Approved By:

N. Taylor

Chief, Project Branch B

Division of Reactor Projects

SUMMARY

The NRC continued monitoring licensees performance by conducting an integrated inspection

at the Callaway Plant in accordance with the Reactor Oversight Process. The Reactor

Oversight Process is the NRCs 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 tables below. A NRC-identified non-cited violation is documented in report

section 71111.11.

List of Findings and Violations

Failure to Maintain Emergency Operating Procedures

Cornerstone

Significance

Cross-cutting

Aspect

Report

Section

Mitigating

Systems

Green

NCV 05000483/2018001-01

Closed

[H.3] - Human

Performance,

Change

Management

71111.11

Licensed

Operator

Performance

The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a,

"Procedures," for the licensee's failure to maintain emergency operating procedures for

aligning auxiliary feedwater suction sources. Specifically, the licensee added continuous

action steps to emergency operating procedures that placed both motor-driven auxiliary

feedwater pumps in pull-to-lock and isolated their associated recirculation lines after depleting

the two non-safety-related suction sources. These actions cause two of the three

safety-related auxiliary feedwater pumps to be rendered inoperable prior to aligning the

safety-related suction source of essential service water which is credited in accident analysis.

Additional Tracking Items

Type

Issue number

Title

Report

Section

Status

URI

05000483/2016001-01

Possible Incorrect Screening

of the Spent Fuel Pool Decay

Heat Removal Key Safety

Function

71111.05AQ

Closed

LER 05000483/2013-009-00

Appendix R Unanalyzed

Condition - Direct Current

Ammeter Circuits Without

Overcurrent Protection

71153

Closed

LER 05000483/2014-004-00

Postulated Hot Short Fire

Event that Could Adversely

Impact Shutdown Equipment

71153

Closed

LER 05000483/2017-001-00

05000483/2017-001-01

Violation of Technical Specification 3.7.9 Due to

Ultimate Heat Sink Cooling

Tower Train Inoperability

71153

Closed

LER 05000483/2017-002-01

Inadequate Protection from

Tornado Missiles Identified

due to Nonconforming

Design

71153

Closed

LER 05000483/2017-003-00 Violation of Technical Specification 3.6.3,

Containment Isolation Check

Valve Found in Open

Position

71153

Closed

NOV

05000483/2017007-01

Not Verifying the Operation

and Timing of the

Engineered Safety Feature

Transformer XNB01 Load

Tap Changer

2702

Closed

PLANT STATUS

Callaway Plant began the inspection period at full power. On March 14, 2018, the licensee

reduced power to 45 percent to replace a reactor coolant system flow transmitter, commenced

ascending in power upon completion of testing, and returned to full power on the same day.

The licensee 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

Impending Severe Weather (1 Sample)

The inspectors evaluated readiness for impending adverse weather conditions for:

(1) Severe winter weather on January 11, 2018

71111.04 - Equipment Alignment

Partial Walkdown (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

(1) Component cooling water train B on January 10, 2018

(2) Control room filtration unit FGK02B on January 25, 2018

(3) Battery charger NK26 on February 7, 2018

Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of:

(1) Instrument AC power (NN) system on January 18, 2018

71111.05AQ - Fire Protection Annual/Quarterly

Quarterly Inspection (5 Samples)

The inspectors evaluated fire protection program implementation in the following selected

areas:

(1) Control building 2016 elevation, fire area C-15 on January 12, 2018

(2) Auxiliary feedwater pipe chase 1988 elevation, fire area A-1 on February 16, 2018

(3) Control room air conditioning and filtration units, fire areas A-21 and A-22 on March 6,

2018

(4) Electrical penetration rooms, fire areas A-17 and A-18 on March 11, 2018

(5) Intake structure, fire area IS-1 on March 28, 2018

71111.06 - Flood Protection Measures

Internal Flooding (1 Sample)

The inspectors evaluated internal flooding mitigation protection:

(1) Control building 2016 elevation on January 9, 2018

71111.07 - Heat Sink Performance

Heat Sink (1 Sample)

The inspectors evaluated:

(1) Emergency diesel generator jacket water heat exchanger train A on March 22, 2018

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (1 Sample)

The inspectors observed and evaluated simulator training for operating crews:

(1) Electrical faults on February 6, 2018

Operator Performance (1 Sample)

The inspectors observed and evaluated:

(1) Surveillance testing for the auxiliary feedwater system on February 20, 2018

(2) Surveillance testing for the emergency diesel generator train B and reactor coolant flow

transmitter troubleshooting on March 7, 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) 125 VDC system (NK) on January 17, 2018

(2) Instrument AC power system (NN) on February 14, 2018

71111.13 - Maintenance Risk Assessments and Emergent Work Control (5 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent

work activities:

(1) Elevated risk actions due to planned centrifugal charging pump B and component

cooling water equipment outage on January 30, 2018

(2) Elevated risk actions due to planned switchyard maintenance on February 5, 2018

(3) Elevated risk actions due to planned safety injection train A equipment outage on

February 13, 2018

(4) Emergent risk actions due to auxiliary feedwater pump door failure on February 20, 2018

(5) Elevated risk actions due to planned turbine-driven auxiliary feedwater pump equipment

outage on February 27, 2018

71111.15 - Operability Determinations and Functionality Assessments (5 Samples)

The inspectors evaluated the following operability determinations and functionality

assessments:

(1) Rising level trend in safety injection accumulators on January 8, 2018

(2) Reactor building service air header supply containment isolation valve KAV0118 out of

position on January 15, 2018

(3) Battery charger NK25 equalize potentiometer failure on January 16, 2018

(4) Spent fuel pool calculation assumptions on February 13, 2018

(5) Turbine-driven auxiliary feedwater pump room door DSK13311 failure on March 2, 2018

71111.18 - Plant Modifications (1 Sample)

The inspectors evaluated the following permanent modification:

(1) MP 12-0020 electrical tie-ins for FLEX on March 29, 2018

71111.19 - Post Maintenance Testing (5 Samples)

The inspectors evaluated the following post maintenance tests:

(1) Control room air conditioning unit SGK04B equipment outage on January 10, 2018

(2) Class 1E battery charger NK25 equipment outage on January 22, 2018

(3) Class 1E battery charger NK21 equipment outage on January 29, 2018

(4) Turbine-driven auxiliary feedwater pump equipment outage on February 28, 2018

(5) Emergency diesel generator and essential service water train A equipment outage on

March 23, 2018

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine (1 Sample)

(1) OSP-NE-0001A, standby diesel generator A periodic tests on January 24, 2018

In-service (2 Samples)

(1) OSP-BG-P005A, centrifugal charging pump A inservice test - Group B on February 15,

2018

(2) OSP-EG-P01BD, component cooling water train B pump and valve inservice test -

group A on March 29, 2018

Containment Isolation Valve (1 Sample)

(1) OSP-KC-LL067, containment isolation valve leak rate test and results of check valve

internal inspection under Condition Report 201706233 on March 15, 2018

71114.06Drill Evaluation

Emergency Planning Drill (1 Sample)

The inspectors evaluated the radiological emergency response plan drill:

(1) Team 4 on March 8, 2018

Drill/Training Evolution (1 Sample)

The inspectors evaluated annual emergency response organization training evolution:

(1) Team 4 on February 1, 2018

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification (3 Samples)

The inspectors verified licensee performance indicators submittals listed below:

(1) MS06: Emergency AC Power Systems (01/01/2017-12/31/2017)

(2) MS10: Cooling Water Support Systems (01/01/2017-12/31/2017)

(3) BI01: Reactor Coolant System (RCS) Specific Activity Sample (01/01/2017-12/31/2017)

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program

related to the following issues:

(1) Safety injection pump oil leak, Condition Report 201704706

(2) Ultimate heat sink cooling tower shroud bolting, Condition Report 201010236

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

Licensee Event Reports (5 Samples)

The inspectors evaluated the following licensee event reports which can be accessed at

https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) Licensee Event Report 05000483/2013-009-00, Appendix R Unanalyzed Condition -

Direct Current Ammeter Circuits Without Overcurrent Protection, on October 9, 2013

(2) Licensee Event Report 05000483/2014-004-00, Postulated Hot Short Fire Event that

Could Adversely Impact Shutdown Equipment, on September 19, 2014

(3) Licensee Event Reports 05000483/2017-001-00 and 05000483/2017-001-01, Violation

of Technical Specification 3.7.9 Due to Ultimate Heat Sink (UHS) Cooling Tower Train

Inoperability, on June 16, 2017

(4) Licensee Event Report 05000483/2017-002-01, Inadequate Protection from Tornado

Missiles Identified due to Nonconforming Design, on August 15, 2017

(5) Licensee Event Report 05000483/2017-003-00, Violation of Technical Specification 3.6.3, Containment Isolation Check Valve Found in Open Position, on

October 31, 2017

2702 - Followup on Traditional Enforcement Actions Including Violations, Deviations,

Confirmatory Action Letters, Confirmatory Orders, and Alternative Dispute Resolution

Confirmatory Orders

Notice of Violation (1 Sample)

The inspectors reviewed the licensees response to Notice of

Violation 05000483/2017007-01, Not Verifying the Operation and Timing of the Engineered

Safety Feature Transformer XNB01 Load Tap Changer, and determined that the reason,

corrective actions taken and planned to address recurrence, and the date when full

compliance was achieved for this violation is adequately addressed and captured on the

docket.

INSPECTION RESULTS

Failure to Maintain Emergency Operating Procedures

Cornerstone

Significance

Cross-cutting Aspect

Report Section

Mitigating Systems

Green

NCV 05000483/2018001-01

Closed

[H.3]Human

Performance, Change

Management

71111.11

Licensed

Operator

Performance

The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a,

"Procedures," for the licensee's failure to maintain emergency operating procedures for

aligning auxiliary feedwater suction sources. Specifically, the licensee added continuous

action steps to emergency operating procedures that placed both motor-driven auxiliary

feedwater pumps in pull-to-lock and isolated their associated recirculation lines after depleting

the two non-safety-related suction sources. These actions cause two of the three safety

related auxiliary feedwater pumps to be rendered inoperable prior to aligning the safety

related suction source of essential service water which is credited in accident analysis.

Description:

On March 7, 2018, the inspectors performed an observation of licensed control room

operators and reviewed the use of auxiliary feedwater pumps (AFW or AFPs) in Emergency

Operating Procedures (EOPs). The AFW system provides a reliable source of water to the

steam generators and removes thermal energy from the reactor coolant system through the

release of secondary steam to the atmosphere. The AFW pumps are comprised of two

motor-driven (MD) pumps and one turbine-driven (TD) pump. Each pump has recirculation

lines to provide a constant discharge pathway and prevent pump damage. These AFW

pumps can be supplied with the following three suction sources:

(1) Condensate storage tank (CST) - non-safety-related and normally aligned

(2) Hardened CST (HCST) - non-safety-related

(3) Essential service water (ESW) - safety-related

In their review of EOPS, the inspectors noted that the following continuous action step was

found in several EOPs and titled AFW Supply Switchover Criteria:

If CST to AFP suction header pressure lowers to less than 11.5 PSIG,

THEN PERFORM EOP Addendum 42, HCST Alignment.

If CST to AFP suction header pressure lowers to less than 2.75 PSIG,

THEN PERFORM EOP Addendum 19, Aligning ESW to AFW Suction.

The inspectors reviewed EOP Addendum 42, HCST Alignment, Revision 1, which states the

following and accomplishes it in step 1 of the addendum:

When the HCST is supplying AFW, ONLY the TDAFW will be used, since it

can be aligned to recirc back to the HCS

T. Therefore, the MDAFPs will be

placed in Pull-to-Lock prior to isolating MDAFP recirc lines back to the

CST.

The inspectors noted that EOP Addendum 19, Aligning ESW to AFW Suction, Revision 3,

did not restore the isolated and disabled motor-driven AFW pumps. Instead, EOP

Addendum 19 refers only to the ESW valve lineup. As written, the discussed EOP addenda

would leave the control room staff with only the turbine-driven AFW pump available.

The inspectors then reviewed accident analysis including section 15.2.8, Feedwater System

Pipe Break, of the Final Safety Analysis Report which states:

For the auxiliary feedwater system, the worst case configuration has been

used, i.e., only three intact steam generators receive auxiliary feedwater

following the break... one motor-driven AFW pump to the intact steam

generatorthe turbine-driven AFW pump has been assumed to fail... the

second motor-driven AFW pump is assumed to deliverequally split to the

two remaining intact steam generators...

The inspectors noted that the accident analysis of Final Safety Analysis Report chapter 15

does not refer to use of the HCST and does not refer to operator action to manually un-isolate

motor-driven AFW pumps to reach and maintain safe shutdown.

The inspectors reviewed the extent of condition for the AFW Supply Switchover Criteria

continuous action steps and found it in the following EOPs:

(1) E-0, Reactor Trip or Safety Injection, Revision 19

(2) E-1, Loss of Reactor or Secondary Coolant, Revision 19

(3) E-3, Steam Generator Tube Rupture, Revision 22

(4) ES-0.1, Reactor Trip Response, Revision 18

(5) FR-H.1, Response To Loss of Secondary Heat Sink, Revision 18

The inspectors noted the HCST Alignment addendum was created in February 2016 and

modified in October 2016 to the current Revision 1. The procedure review process noted the

non-safety HCST is a useful water source prior to using the ESW... the HCST is

maintained at a higher cleanliness. Further, the procedure review noted the HCST:

does not have a recirculation line from the Motor Drive Aux Feed pumps to

the HCST... EOP Add 42 allows for the alignment of the recirc valves and

stops the Motor Drive Aux Feedwater Pumps to prevent possible damage

from overheating. Since this overall modification has been evaluated

previously, this procedure change does not require further 50.59 review.

The inspectors concluded the licensee failed to maintain EOPs for aligning auxiliary feedwater

suction sources. Specifically, the EOPs placed both motor-driven auxiliary feedwater pumps

in pull-to-lock and isolated their associated recirculation lines prior to aligning the

safety-related suction source of essential service water. This configuration and operator

actions are not supported by the accident analysis in the Final Safety Analysis Report.

Further, the licensee did not provide an adequate procedure for restoring the motor-driven

AFW pumps from this configuration. Since the continuous action steps are pervasive across

EOPs, it is plausible that an operating crew would enact the AFW supply switchover actions

prior to fully diagnosing the accident and contrary to the goal of the EOP they were utilizing.

Corrective Actions: The licensee issued a night order clarifying the requirements for auxiliary

feedwater in the EOPs and revised EOP Addendum 42, HCST Alignment.

Corrective Action Reference: Condition Reports 201801260 and 201801570.

Performance Assessment:

Performance Deficiency: The failure to maintain Emergency Operating Procedures for

aligning auxiliary feedwater suction sources was a performance deficiency.

Screening: This performance deficiency was more than minor, and therefore a finding,

because it adversely affected the procedure quality attribute of the Mitigating Systems

Cornerstone objective of ensuring the availability, reliability, and capability of systems that

respond to initiating events to prevent undesirable consequences. Specifically, the licensee

added continuous action steps to EOPs that placed both motor-driven auxiliary feedwater

pumps in pull-to-lock and isolated their associated recirculation lines after depleting the two

non-safety-related suction sources. These actions cause two of the three safety related

auxiliary feedwater pumps to be rendered inoperable prior to aligning the safety related

suction source of essential service water which is credited in accident analysis.

Significance: Using Inspection Manual Chapter 0609, Attachment 4, Initial Characterization

of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings

At-Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, the

inspectors determined that the finding was of very low safety significance (Green) because

(1) the finding was not a deficiency affecting the design or qualification of a mitigating system;

(2) the finding did not represent a loss of system and/or function; (3) the finding did not

represent an actual loss of function of a single train for greater than its technical specification

allowed outage time; and (4) the finding does not represent an actual loss of function of one

or more non-technical specification trains of equipment designated as high safety-significant

in accordance with the licensee's maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Cross-Cutting Aspect: The finding had a cross-cutting aspect in the area of human

performance associated with change management because the licensee failed to use a

systematic process for evaluating and implementing change so that nuclear safety remains

the overriding priority. Specifically, the licensee prioritized the motor-driven AFW pumps

health due to a lack of recirculation ability over the accident analysis by not adequately

screening the procedure changes into 50.59 review in 2016.

Enforcement:

Violation: Technical Specification 5.4.1.a requires, in part, that written procedures shall be

established, implemented, and maintained covering the applicable procedures recommended

in Appendix A of Regulatory Guide 1.33, Revision 2. Section 6 of Appendix A to Regulatory

Guide 1.33, Revision 2, requires procedures for combating emergencies and other significant

events. The licensee established EOP Addendum 42, HCST Alignment, Revision 1, in part,

to meet the regulatory requirement. Step 1 of EOP Addendum 42 placed both motor-driven

auxiliary feedwater pumps in pull-to-lock and isolated their associated recirculation lines.

Contrary to the above, prior to March 7, 2018, the licensee failed to maintain procedures for

combating emergencies and other significant events. Specifically, the licensee failed to

maintain EOPs for aligning auxiliary feedwater suction sources. The licensee added

continuous action steps to EOPs that placed both motor-driven auxiliary feedwater pumps in

pull-to-lock and isolated their associated recirculation lines after depleting the two

non-safety-related suction sources. These actions cause two of the three safety related

auxiliary feedwater pumps to be rendered inoperable prior to aligning the safety related

suction source of essential service water which is credited in accident analysis.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with

Section 2.3.2.a of the Enforcement Policy.

Unresolved Item

(Closed)

Possible Incorrect Screening of the Spent Fuel Pool

Decay Heat Removal Key Safety Function

URI 05000483/2016001-01

71111.05AQ

Quarterly

Inspection

Description: In Unresolved Item 05000483/2016001-01, the inspectors documented an issue

of concern with the licensees National Fire Protection Association (NFPA) Standard 805,

Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating

Plants, non-power operations assessment. Specifically, the inspectors developed an issue of

concern because the licensee screened the potential loss of spent fuel pool cooling from

further consideration for any fire event during non-power operations based on adequate

procedural guidance and time when the procedures would not maintain the fuel in a safe and

stable condition.

To address this unresolved item, the inspectors requested that the Office of Nuclear Reactor

Regulation (NRR) work with the Nuclear Energy Institute NFPA 805 Task Force in accordance

with the NFPA 805 Frequently Asked Questions (FAQ) Program to review and update the

guidance in FAQ 07-0040, Non-Power Operations Clarifications, Revision 4. The inspectors

documented this request in a memo, dated March 31, 2016 (ML16091A152). The updated

guidance was issued in FAQ 07-0040, Revision 5 on May 20, 2016 (ML17331B109). This

revision was accepted by NRR staff in a memo, dated November 28, 2017 (ML17331B108).

The revised guidance provided clarification for the treatment of spent fuel pool cooling during

non-power operations. The revised guidance stated that, Spent fuel pool configurations are

not considered to be risk-significant and are not treated as a higher risk evolution. In the

approval memo, the NRR staff agreed with the revised guidance, stating, The NRC staff

agrees that the loss of spent fuel pool cooling does not need to be considered a higher risk

evolution.

The licensee documented the non-power operations assessment in Calculation KC-26,

Appendix 1, NFPA 805 Non-power Operations Assessment, Revision 3. The licensee

performed this assessment based, in part, on guidance in FAQ 07-0040, Revision 4.

During the current inspection, the inspectors reviewed the licensees non-power operations

assessment and the revised guidance in FAQ 07-0040, Revision 5. In accordance with the

revised guidance, the licensee did not need to perform additional analyses (Steps F.2

and F.3. of FAQ 07-0040) associated with spent fuel pool cooling because the staff agreed

that the normal fire protection program defense-in-depth actions provide reasonable

assurance that the spent fuel pool remains less than boiling. Based on the licensees

non-power operations assessment and the revised guidance, the inspectors determined that

no performance deficiency existed.

Corrective Action Reference: Condition Report 201600726

Observation

2702Followup on Traditional

Enforcement Actions Including

Violations, Deviations,

Confirmatory Action Letters,

Confirmatory Orders, and

Alternative Dispute Resolution

Confirmatory Orders

Discussion: The inspection team determined that the licensee had not: 1) adequately

performed a timing test of the transformer XNB01 load tap changer to ensure proper

operation; and 2) periodically performed a timing test of the transformer XNB01 load tap

changer to ensure proper operation to maintain the operability of the offsite power sources.

Since the issuance of the violation in 2014, the licensee had opportunities to perform a timing

test of transformer XNB01 load tap changer (refueling outages in fall 2014 and spring 2016).

Corrective Steps Taken and Results Achieved: The timing test of the XNBO1 load tap

changer was successfully tested on October 20, 2017. Timing testing of the XNBO1 and

XNB02 load tap changers will continue to be performed on a routine basis, going forward.

Also, Callaway work management procedure will be revised to establish schedule dates for

jobs associated with addressing NRC violations. Rescheduling jobs beyond the scheduled

date would require justification as well as approval by management. The licensee will review

any NRC violations received since October 2015 for jobs that are credited for restoring

compliance. The basis for selecting October 2015 was that it coincided with the last time a

comprehensive pre-Problem Identification and Resolution inspection self-assessment was

performed. In that assessment, the timeliness of corrective actions for NRC violations prior to

October 2015 was evaluated. Lessons learned in connection with this Notice of Violation will

be communicated by station leadership. This will include expectations on identifying and

adhering to the scheduled date for jobs addressing violations, as mentioned above. Both

actions were complete by February 28, 2018.

The inspectors reviewed the licensees response to the Notice of Violation along with

corrective action documents. All findings were documented in NRC Inspection

Report 05000483/2017007, ADAMS accession number ML17283A392. Notice of

Violation 0500483/2017007-01 is closed.

MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On April 4, 2018, the inspectors presented the integrated quarterly resident inspection results to

Mr. Tim Herrmann, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Procedure 71111.01: Adverse Weather Protection

Procedures

Number

Title

Revision

OTN-QJ-00003

Plant Freeze Protection Heat Tracing Procedure

OTO-ZZ-00012

Severe Weather

Condition Reports

201800054

201800255

Inspection Procedure 71111.04: Equipment Alignment

Procedures

Number

Title

Revision

OTN-NK-00001

Class 1E 125 VDC Electrical System

OTN-NN-00001

20 V Vital AC Instrument Power - Class 1E (Channel 1)

OTN-EG-00001

Component Cooling Water System

Calculations

Number

Title

Revision

E-H-18

System NN Relay Settings - Calculate Settings for NN

Protective Relays

GK-11

Electrical Heat Loads in the Control Building During Normal

and ESFAS Conditions

GL-10 Add 2

Evaluate Tube Plugging Limits for SGL 15 A/B

EG-54

Allowable Gas Void Volume for each Train of the

Component Cooling Water Suction Piping

M-EG-20

Max CCW Temperature Post LOCA

Miscellaneous

Number

Title

Revision

10466-M-612

Design Specification for Room Coolers

M-618.2

Spec for Q-Listed HVAC Ductwork (Installation)

RFR 180048

Evaluate Non-Safety Accessories in Safety HVAC Systems

Miscellaneous

Number

Title

Revision

M-22EG01

Piping and Instrumentation Diagram Component Cooling

Water System

ULDBD-EG-01

Component Cooling Water System

M-082-00039

Instruction Manual for Component Cooling Water Pumps

Condition Reports

201707171

201706754

201800235

201800933

201801160

201800157

201800176

201303691

Inspection Procedure 71111.05: Fire Protection

Procedures

Number

Title

Revision

Fire Preplan Manual

FPP-ZZ-00000

Guidelines for Writing Prefire Strategy Procedures and

Preplans

APA-ZZ-00700

Fire Protection Program

Condition Reports

201706984

201801219

201801220

200910299

200505787

200809214

201604688

Inspection Procedure 71111.06: Flood Protection Measures

Procedures

Number

Title

Revision

Fire Preplan Manual

OTO-ZZ-00005

Flooding

Calculations

Number

Title

Revision

AMN-010-CALC-002 Flood Levels in Control Building Rooms Due to Pipe

Break or Crack

Condition Reports

201609311

201800649

Inspection Procedure 71111.07A: Heat Exchanger Performance

Procedures

Number

Title

Revision

HX-1.PMB

Heat Exchangers

APA-ZZ-00801

Foreign Material Exclusion

EDP-ZZ-01112

Heat Exchanger Predicative Performance Manual

Calculations

Number

Title

Revision

KJ-20

Evaluate Tube Plugging Limits for EKJ03A/B,

EKJ04A/B, and EKJ06A/B

M-1196-00002

Jacket Water Cooler Performance Evaluation

Jobs

13511907

09512424

Condition Reports

201500625

201600703

201800394

201801456

200803533

200909091

200204569

Inspection Procedure 71111.11: Licensed Operator Requalification Program and

Licensed Operator Performance

Procedures

Number

Title

Revision

AL-30

Auxiliary Feedwater System Performance During a Loss of

Normal Feedwater Flow and Non-Emergency A/C Power

E-0

Reactor Trip or Safety Injection

ISF-AL-00P37

CST to AFP Suction Header Pressure Channel Operational

Test

ISL-BB-0F434

RCS Flow Channel Cal Loop 3 Protection 1

OSP-AL-00003

Auxiliary Feedwater LSP CST to ESW Valve Operability

Procedures

Number

Title

Revision

T61.0810 8

Licensed Operator Continuing Training - Simulator Training

Scenario Guide

January 23,

2018

Condition Reports

201707139

201102329

201801260

Inspection Procedure 71111.12: Maintenance Effectiveness

Procedures

Number

Title

Revision

APA-ZZ-00395

Significant Operator Response Timing

EDP-ZZ-01128

Maintenance Rule Program

EDP-ZZ-01128,

Appendix 1

SSCs in the Scope of the Maintenance Rule at Callaway

EDP-ZZ-01128,

Appendix 2

Summary of SSC Performance Criteria

EDP-ZZ-01128,

Appendix 3

Maintenance Rule Shutdown Performance Criteria

EDP-ZZ-01128,

Appendix 4

Maintenance Rule System Functions

OSP-SA-2413A

Train A Diesel Generator and Sequencer Testing

Miscellaneous

Number

Title

Revision

E-051C-00010

Qualification Report for Class 1E 125 VDC Electronically

Controlled Manual Switches

E-1061

Specification for Class 1E AC Vital Bus Inverters and Swing

Inverters

MP-130020

Modification to Install Class 1E Swing Inverters

Condition Reports

200805033

201303158

201307777

20143898

201407350

201505907

201602855

201603286

201603312

201604824

201605545

201607358

201702520

201705797

201706481

201800216

Miscellaneous

Number

Title

Revision/

Date

LER 2014-003-00 Inverter NN11 Inadvertently Transferred to Its Alternate

Source

August 7,

2014

LER 2014-003-02 Inverter NN11 Inadvertently Transferred to Its Alternate

Source

August 6,

2015

ODMI 15-0006

Thermography Indicated Elevated Temperatures on

Disconnect NN0311

Inspection Procedure 71111.13: Maintenance Risk Assessments and Emergent Work

Control

Procedures

Number

Title

Revision

APA-ZZ-00750

Hazard Barrier Program

ODP-ZZ-00002,

Appendix 2

Risk Management Actions For Planned Risk Significant

Activities

EDP-ZZ-01129

Callaway Energy Center Risk Assessment

APA-ZZ-00322

Integrated Work Management Process Description

APA-ZZ-00322,

Appendix F

Online Work Integrated Risk Management

APA-ZZ-00315

Configuration Risk Management Program

ODP-ZZ-00002,

Appendix 1

Protected Equipment Program

OTN-BG-00001

Chemical and Volume Control System

MPE-ZZ-QY054

Inspection and Test of Protective Lockout Relays, General

Electric Type HEA

OTN-MD-00001

Switchyard Breakers and Disconnects

MTM-AL-QP002

Turbine Driven Auxiliary Feedwater Pump

Jobs

16513469

16508486

18000148

16508306

14504707

16514154

15503300

17500047

Condition Reports

201800516

201106906

200604069

201605319

201705780

201505319

201800176

201800157

200000661

Inspection Procedure 71111.15: Operability Determinations and Functionality

Assessments

Procedures

Number

Title

Revision

APA-ZZ-00391

Beyond Design Basis Program

APA-ZZ-00391,

Appendix 2

Sequence of Events Timeline

OSP-KC-00015

Fire Door Inspections

APA-ZZ-00750

Hazard Barrier Program

OTG-ZZ-00006

Plant Cooldown Hot Standby to Cold Shutdown

OSP-GT-00003

Containment Closure

OSP-GP-00001

Containment Isolation Verification

Miscellaneous

Number

Title

Revision

M-22FC02

Auxiliary Feedwater Pump Turbine P&ID

M-FC-03

Auxiliary Feedwater Pump Turbine Room Analysis

M-YY-49,

Addendum 4

Additional HELB Scenarios

2

Auxiliary & Reactor Building Elevation 2000 Floor Plan

Westinghouse Clarification on the Basis for the Boil Off

Time of the Callaway Energy Center Spent Fuel Pool

ULNRC-06421

Licensee Event Report 2018-001-00 Violation of Technical Specification 3.6.3 Containment Isolation Manual Valve

Found in Open Position

M-22KA02

Compressed Air System P&ID

Jobs

18000323

13511394

09501018

18000249

18000735

Condition Reports

201800066

201800235

201800194

Inspection Procedure 71111.18: Plant Modifications

Miscellaneous

Number

Title

Revision

MP 12-0020

Field Change Notice

Seismic II/I Hazard Analysis Review for MP 12-0020

STARS ENG-5001-8.3, Section 13 FP Review

Inspection Procedure 71111.19: Post Maintenance Testing

Procedures

Number

Title

Revision

MTM-AL-QP002

Turbine Driven Auxiliary Feedwater Pump

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

OSP-GK-0002B

Train B Control Room Ventilation and Pressure Test

OSP-NE-0001A

Standby Diesel Generator A Periodic Tests

OSP-NE-00003

Technical Specification Actions - A/C Sources

OTN-EF-00001

Essential Service Water System

Miscellaneous

Number

Title

Revision

M-22FC02

Auxiliary Feedwater Pump Turbine P&ID

MP 15-0020

Install Fuses in 250Vdc Control Circuits

E-23NK11

25 Volt DC Class 1E Power System Schematic Diagram

Jobs

17004200

16002592

15505343

16509603

18000735

14000994

18000457

17503253

13511907

17004111

16511918

Condition Reports

201706923

201800442

201704649

201704899

201800145

201700177

201800206

201705121

201604537

201110062

201800926

201820013

201800874

200801131

201703920

200811040

Inspection Procedure 71111.22: Surveillance Testing

Procedures

Number

Title

Revision

OSP-BG-P005A

Centrifugal Charging Pump A Inservice Test

APA-ZZ-00340

Surveillance Program Administration

OSP-BG-00001

Boron Injection Flow Paths Modes 1, 2 and 3

ODP-ZZ-00036

Technical Specification Application for Containment Isolation

Valves

EDP-ZZ-01128

Summary of SSC Performance Criteria

APA-ZZ-00549,

Appendix B

Guidelines used to determine functional importance for a

component

Miscellaneous

Number

Title

Revision/

Date

M-721-00093

Instruction Manual for Centrifugal Charging/Safety-Injection

Pumps Operation and Maintenance

M-22BG01

Chemical and Volume Control System P&ID

MP 12-0020

Field Change Notice

Night Order

Condition Report 201706233/Condition Report 201706926,

KCV0478 may stick open during flow through

penetrations P067

January 31,

2018

ULDBD-BB-001

Reactor Coolant System

Jobs

17514632

05504483

17004820

Condition Reports

201800330

201800423

200702585

200901841

200306153

200502806

201706233

201706926

201800323

Inspection Procedure 71114.06: Drill Evaluation

Procedures

Number

Title

Revision

APA-ZZ-00925

Training and Qualification of Plant Personnel

Procedures

Number

Title

Revision

EIP-ZZ-A0066

Radiological Emergency Response Plan Training

EIP-ZZ-A0001

Emergency Response Organization

Condition Reports

201801245

201801251

201801252

2000800921

201008419

200808431

Inspection Procedure 71151: Performance Indicator Verification

Procedures

Number

Title

Revision

CSP-ZZ-02550

Pressurized Reactor Coolant Sample

CSP-ZZ-07600

RCS Activity Determinations

Miscellaneous

Number

Title

Revision

Date

MSPI Derivation Reports (Cooling Water Systems)

Various

Control Room Log

Various

NRC Performance Indicator Transmittal Report, First

Quarter 2015, Mitigating Systems Cornerstone

April 11, 2018

NRC Performance Indicator Transmittal Report, Second

Quarter 2015, Mitigating Systems Cornerstone

July 18,

2018

NRC Performance Indicator Transmittal Report, Third

Quarter 2015, Mitigating Systems Cornerstone

October 25,

2018

NRC Performance Indicator Transmittal Report, Fourth

Quarter 2015, Mitigating Systems Cornerstone

January 16,

2018

Condition Reports

201101025

201004284

Inspection Procedure 71152: Problem Identification and Resolution

Procedures

Number

Title

Revision

APA-ZZ-00500

Corrective Action Program

ESP-EF-0001A

Ultimate Heat Sink Train A Cooling Tower Fill Inspection

Miscellaneous

Number

Title

Revision

EM-04

Safety Injection System (Cold Leg Recirculation Phase)

Fault Tree Model

BG-32

High Pressure Coolant Injection System (Cold Leg

Recirculation Phase) Fault Tree Model

BN-28

RWST Drain Down Time and Volume Loss During SBLOCA 0

M-015-U012-08

Specification for Ultimate Heat Sink Cooling Tower

Condition Reports

201706900

201707137

201704706

201010236

Inspection Procedure 71153: Follow-up of Events and Notices of Enforcement Discretion

Drawings

Number

Title

Revision

E-21NK02(Q)

Class IE 125V dc System Meter and Relay Diagram

J-200-00075

Main Control Board RL025 and RL026 Wiring Diagram

E-21NK01(Q)

Class IE 125V dc System Meter and Relay Diagram

E-051-00079

Battery Chargers Wiring Diagram

E-23NK11(Q)

25 Volt dc Class IE Power System Schematic

E-23CD02

Schematic Diagram Emergency Seal Oil Pump

E-23FC02

Schematic Diagram Feed Pump Turbine Emergency

Bearing Oil Pumps

E-21NK02(Q)

Class IE 125V dc System Meter and Relay Diagram

E-23CB03

Schematic Diagram Emergency Bearing Oil Pump

M-840-00014

Hydrogen and Water Cooling Wiring Diagram

M-840-00023

Schematic Diagram (Hydrology and Stator Cooling)

E-21NK01(Q)

Class IE 125V dc System Meter and Relay Diagram

Drawings

Number

Title

Revision

E-21NK01(Q)

Class IE 125V dc System Meter and Relay Diagram

M-830-00015

Emergency Bearing Oil Pump

IC-4061-T1 dc Magnetic Starter

M-012-00079

Wiring Diagram (Emergency Oil Pump Starter Circuit)

E-051-00058

SCR Controlled Battery Charger Schematic

M-835-00014

D.C. Magnetic Starter 72-13 (CD01) (Counter -

Electromotive Force) Emergency Seal Oil Pump Motor

J-200-00081

Main Control Board RL025 and RL026 Wiring Diagram

Miscellaneous

Number

Title

Revision/

Date

FR-087114

Bimetallic Thermal Overload Relays

December 13,

2017

Calculation KC-26 Nuclear Safety Capability Assessment Calculations:

KC-26

MP 15-0020

Install Fuses in 250 Vdc Control Circuits To Address

NFPA805 Concerns

Condition Reports

201706133

201706233

201706924

201706926

201801657

Initial Request for Information

Quarterly Baseline Inspection

Callaway Plant

Inspection Report: 05000483/2018001

Inspection Dates: January 1 - March 31, 2018

Inspection Procedure: IP 71111 series, IP 71152

Lead Inspector: Dan Bradley, Senior Resident Inspector

Information Requested For 1st Quarter 2018

The following information should be sent to the resident office in hard copy or electronic format

(Certrec IMS preferred) to the attention of Dan Bradley by January 15, 2018. These items shall

be available and ready for review on the day indicated in this request. Please provide

requested documentation electronically in pdf files, Excel, or other searchable formats, if

possible. The information should contain descriptive names and be indexed and hyperlinked to

facilitate ease of use. If requested documents are large and/or only hard copy formats are

available, please inform the inspector and provide subject documentation.

Please provide the following information for the 125 VDC (NK) and Instrument AC Power (NN)

systems:

1.

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

2.

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

3.

A list of work orders associated with the selected systems for the last 3 years, including

all open work orders.

4.

An Excel spreadsheet list of equipment basic events (with definitions), including

importance measures sorted by risk achievement worth and Fussell-Vesely from your

internal events probabilistic risk assessment. Include basic events with a risk

achievement value of 1.3 or greater.

5.

A list of any pre-existing evaluations or calculations with low design margins for the

selected systems.

6.

A list of maintenance rule components and functions; based on engineering or expert

panel judgment, for the selected systems.

7.

A list of maintenance rule functional failure evaluations for the last 3 years for the

selected systems.

8.

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

9.

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

10. A list of permanent and temporary modifications performed in the past 3 years for the

selected systems. Include a list of any documents associated with modifications such

as: calculations, specifications, vendor manuals, Final Safety Analysis Report,

Technical Specifications and Bases updates, updated procedures, and maintenance and

surveillance activities and procedures.

11. A list of the design calculations that provide the design margin information for the

selected systems.

2. A list of root cause evaluations associated with component failures or design issues

initiated/completed in the last 3 years for the selected systems.

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

systems.

14. An electronic copy of the design bases documents for the selected systems.

15. An electronic copy of the system health notebooks for the selected systems.

Inspector Contact Information:

Dan Bradley

Senior Resident Inspector

573-676-3181

Dan.Bradley@nrc.gov

Mailing Address:

U.S. NRC Resident Inspector Office

201 NRC Road

Steedman, MO 65077

ML18123A395

SUNSI Review:

ADAMS:

Non-Publicly Available

Non-Sensitive

Keyword:

By: NHT/rdr

Yes No

Publicly Available

Sensitive

NRC-002

OFFICE

SRI/DRP/B

RI/DRP/B

C:DRS/EB1

C:DRS/EB2

C:DRS/OP

C:DRS/PSB2

NAME

DBradley

SJanicki

TFarnholtz

JDrake

VGaddy

HGepford

SIGNATURE

/RA/

/RA/

/RA/

/RA/

/RA/

/RA/

DATE

5/2/18

5/2/18

4/25/18

4/29/18

4/25/18

4/30/18

OFFICE

TL:DRS/IPAT

C:DRP/B

NAME

GGeorge

NTaylor

SIGNATURE

/RA/

/RA/

DATE

4/25/18

5/3/18

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