IR 05000483/2015003

IR 05000483/2015003; on 06/21/2015 - 09/19/2015; Callaway Plant; Licensed Operator Requalification Program and Licensed Operator Performance, Operability Determinations and Functionality Assessments, and Radiation Monitoring Instrumentation

ML15306A580
Person / Time
Site:	Callaway
Issue date:	11/02/2015
From:	Nick Taylor NRC/RGN-IV/DRP/RPB-B
To:	Diya F Union Electric Co
NICK TAYLOR
References
IR 2015003
Download: ML15306A580 (59)

Text

UNITED STATES ber 2, 2015

SUBJECT:

CALLAWAY PLANT - NRC INTEGRATED INSPECTION REPORT 05000483/2015003

Dear Mr. Diya:

On September 19, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Callaway Plant. On September 30, 2015, the NRC inspectors discussed the results of this inspection with Mr. D. Neterer and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.

NRC inspectors documented three findings of very low safety significance (Green) in this report.

Two of these findings involved violations of NRC requirements. Further, inspectors documented a licensee-identified violation which was determined to be of very low safety significance in this report. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the NRC Enforcement Policy.

If you contest the violations or significance of these NCVs, 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, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the Callaway Plant.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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 Regional Administrator, Region IV; and the NRC resident inspector at the Callaway Plant.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Nicholas H. Taylor, Branch Chief Project Branch B Division of Reactor Projects Docket No. 50-483 License No. NPF-30 Enclosure:

Inspection Report 05000483 w/ Attachments:

1. Supplemental Information 2. Request for Information

ML15306A580 SUNSI Review ADAMS Non- Publicly Available By: NTaylor Yes No Sensitive Non-Publicly Available Sensitive OFFICE SRI/DRP/B RI/DRP/B C:DRS/PSB1 C:DRS/PSB2 C:DRS/EB1 C:DRS/EB2 NAME THartman MLangelier MHaire HGepford TFarnholtz GWerner SIGNATURE /RA/E-Taylor /RA/E- /RA/PElkman /RA/ /RA/ /RA/

Taylor for DATE 11/2/15 11/2/15 10/28/15 10/22/15 10/26/15 10/22/15 OFFICE TL/DRS/TSS C/DRS/OB C/DRP/B NAME ERuesch VGaddy NTaylor SIGNATURE /RA/ /RA/ /RA/

DATE 10/26/15 10/26/15 11/2/15

Letter to Fadi Diya from Nicholas Taylor November 2, 2015 SUBJECT: CALLAWAY PLANT - NRC INTEGRATED INSPECTION REPORT 05000483/2015003 DISTRIBUTION:

Regional Administrator (Marc.Dapas@nrc.gov)

Deputy Regional Administrator (Kriss.Kennedy@nrc.gov)

DRP Director (Troy.Pruett@nrc.gov)

DRP Deputy Director (Ryan.Lantz@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

DRS Deputy Director (Jeff.Clark@nrc.gov)

Senior Resident Inspector (Thomas.Hartman@nrc.gov)

Resident Inspector (Michael.Langelier@nrc.gov)

Branch Chief, DRP/B (Nick.Taylor@nrc.gov)

Senior Project Engineer, DRP/B (David.Proulx@nrc.gov)

Project Engineer, DRP/B (Shawn.Money@nrc.gov)

Project Engineer, DRP/B (Steven.Janicki@nrc.gov)

CWY Administrative Assistant (Dawn.Yancey@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (John.Klos@nrc.gov)

Acting Team Leader, DRS/TSS (Eric.Ruesch@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

RIV Congressional Affairs Officer (Angel.Moreno@nrc.gov)

RIV/ETA: OEDO (Cindy.Rosales-Cooper@nrc.gov)

ROPreports ROPassessments

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000483 License: NPF-30 Report: 05000483/2015003 Licensee: Union Electric Company Facility: Callaway Plant Location: Junction Highway CC and Highway O Steedman, MO Dates: June 21 through September 19, 2015 Inspectors: T. Hartman, Senior Resident Inspector M. Langelier, P.E., Resident Inspector L. Carson, II, Sr. Health Physicist C. Cowdrey, Operations Engineer N. Green, PhD, Health Physicist S. Hedger, Operations Engineer P. Hernandez, Health Physicist M. Kennard, Operations Engineer J. ODonnell, CHP, Health Physicist M. Phalen, Sr. Health Physicist J. Tice, Project Engineer Approved By: Nicholas H. Taylor Chief, Project Branch B Division of Reactor Projects-1- Enclosure

SUMMARY

IR 05000483/2015003; 06/21/2015 - 09/19/2015; Callaway Plant; Licensed Operator

Requalification Program and Licensed Operator Performance, Operability Determinations and Functionality Assessments, and Radiation Monitoring Instrumentation.

The inspection activities described in this report were performed between June 21 and September 19, 2015, by the resident inspectors at the Callaway Plant and inspectors from the NRCs Region IV office. Three findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. The significance of an inspection finding is indicated by its color (Green, White, Yellow, or Red) and determined using Inspection Manual Chapter 0609, Significance Determination Process, dated April 29, 2015. Cross-cutting aspects are determined using Inspection Manual Chapter 0310, Aspects within the Cross-Cutting Areas, Dated December 4, 2014. Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy, dated February 4, 2015. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a finding with four examples for failing to conduct and evaluate simulator performance testing in accordance with the standards of ANSI/ANS-3.5-2009. Specifically, the licensee failed to do the following:

• set the instantaneous main turbine load reduction to 50 percent as supported by design basis data in the 2014 performance of Transient (11), Maximum Design Load Rejection

• include the evaluation of parameter pressurizer temperature in the 30 percent, 50 percent, and 80 percent power Steady-State Performance Test as specified in accordance with the standard, Appendix B, Section B.3.1

• include the evaluation of parameter secondary heat balance data in the 30 percent, 50 percent, and 80 percent power Steady-State Performance Test as specified in accordance with the standard, Appendix B, Section B.3.1

• replicate the dynamic functioning of annunciators on the simulator panels used during normal, abnormal, off-normal, and emergency evolutions, or to identify and correct noticeable differences in accordance with the standard, Sections 4.2.1.2 and 4.2.1.4 The licensee initiated corrective action documented in Callaway Action Requests 201504760, 201504759, 201504418, and 201504355.

The licensees failure to conduct and evaluate performance testing in accordance with the ANSI/ANS-3.5-2009 standard as endorsed by Regulatory Guide 1.149, Revision 4, was the performance deficiency. The performance deficiency is more than minor because it adversely impacted the human performance 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. Additionally, if left uncorrected, the performance deficiency could have become more significant in that not correcting noticeable differences between the simulator and the reference plant can both leave the potential for negative training of licensed operators and call into question the ability to conduct valid licensing examinations with the simulator. Using Manual Chapter 0609, Significance Determination Process, Attachment 4, Tables 1, 2, and 3 worksheets; and the corresponding Appendix I, Licensed Operator Requalification Significance Determination Process (SDP), Flowchart Block #14, the finding was determined to have very low safety significance (Green) because it dealt with deficiencies associated with simulator testing, modification, and maintenance and there was no evidence that the plant-referenced simulator does not demonstrate the expected plant response or have uncorrected modeling and hardware deficiencies related to the examples.

The examples supporting this finding involved actions taken with the simulator testing and maintenance program before the present performance period. Therefore, no cross-cutting aspect is assigned to the finding. (Section 1R11)

Green.

The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B,

Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to follow their operability determination procedure. Specifically, when an auxiliary feedwater control valve failed to operate from the main control room, the licensee failed to evaluate the operability of the component in accordance with Procedure ODP-ZZ-00001, Addendum 15, Operability and Functionality Determinations. The immediate corrective action taken by the licensee was to evaluate the operability of the flow control valve. After determining that the equipment was inoperable, the licensee entered the required technical specification condition and performed the required technical specification actions. The licensee entered this issue into their corrective action program as Callaway Action Request 201502708.

This performance deficiency is more than minor and, therefore, a finding, because, if left uncorrected, it has the potential to lead to a more significant safety concern if safety-related systems are not properly evaluated for operability. The finding affects the Mitigating System Cornerstone because the performance deficiency is related to the auxiliary feedwater systems ability to conduct short-term decay heat removal. Using Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the finding was determined to be of very low safety significance because it did not affect system design, did not result in a loss of system function, did not represent a loss of function of a single train for greater than its technical specifications allowed outage time, and did not cause the loss of function of one or more non-technical specification trains of equipment designated as high safety-significance. This finding has a cross-cutting aspect of challenge the unknown in the human performance cross-cutting area because the licensee did not stop when faced with uncertain conditions. Specifically, rather than declaring the system inoperable and allowing the process to evaluate the condition, the licensee declared the system operable without fully understanding the failure mechanism [H.11]. (Section 1R15)

Cornerstone: Occupational Radiation Safety

Green.

The inspectors identified a non-cited violation of Callaway Plants License No. NPF-25, Condition 2.B.(3), for the licensee performing non-routine maintenance on a J.L. Shepherd calibrator without license authorization. The licensee documented this issue in their corrective action program as Corrective Action Request 201505175. Their immediate corrective action was to secure the calibration source and review their procedural requirements.

Performing non-routine maintenance on a J.L. Shepherd calibrator without a license authorization is a performance deficiency. This finding is more than minor because the performance deficiency adversely affects the Occupational Radiation Safety Cornerstone, in that, if the licensee performs non-routine maintenance on radiologically risk significant sources without being specifically authorized or trained on how to perform the non-routine maintenance, an uncontrolled high radiation area could result. Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008, the inspectors determined the violation was of very low safety significance (Green) because (1) it was not an as low as reasonably achievable finding, (2) there was no overexposure, (3) there was no substantial potential for an overexposure, and (4) the ability to assess dose was not compromised. The finding had a conservative bias cross-cutting aspect in the area of human performance, because individuals did not use decision making practices that emphasized prudent choices over those that were simply allowable, or ensure a proposed action was safe in order to proceed, rather than unsafe in order to stop. Specifically, licensee staff assumed that they could perform any type of maintenance on the calibrator without verifying that their license authorized those activities [H.14]. (Section 2RS5)

Licensee-Identified Violations

A violation of very low safety significance that was identified by the licensee has been reviewed by the NRC. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and corrective action tracking numbers are listed in Section 4OA7 of this report.

PLANT STATUS

Callaway began the inspection period at 100 percent power. On July 23, 2015, the plant was shut down due to excessive leakage from the reactor coolant system. Callaway identified and corrected the condition and returned the plant to 100 percent power on July 27. Callaway operated at full power until August 11 when the plant tripped off line from a fault on a distribution line coming into the plant switchyard. Callaway identified and corrected the condition and returned the plant to 100 percent power on August 13. Callaway operated at full power for the remainder of the inspection period with the exception of planned power reductions for routine surveillances and post-maintenance testing.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R04 Equipment Alignment

.1 Partial Walkdown

a. Inspection Scope

The inspectors performed partial system walk-downs of the following risk-significant systems:

• August 3, 2015, train A auxiliary feedwater system

• August 20, 2015, train B safety injection system

• September 10, 2015, train A control room air conditioning The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the trains were correctly aligned for the existing plant configuration.

These activities constituted three partial system walk-down samples as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

.2 Complete Walkdown

a. Inspection Scope

On August 31, 2015, the inspectors performed a complete system walk-down inspection of the essential service water system. The inspectors reviewed the licensees procedures and system design information to determine the correct system lineup for the existing plant configuration. The inspectors then visually verified that the system was correctly aligned for the existing plant configuration.

These activities constituted one complete system walk-down sample, as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

1R05 Fire Protection

Quarterly Inspection

a. Inspection Scope

The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on five plant areas important to safety:

• June 15, 2015, north and south ultimate heat sink cooling tower electrical rooms, fire areas UNCT and USCT

• July 15, 2015, train A essential service water pump room, fire area UNPH

• July 20, 2015, essential service water pipe space, fire area C-1

• August 12, 2015, residual heat removal heat exchanger rooms, fire areas A-9 and A-10

• September 1, 2015, train A emergency core cooling pump rooms, fire area A-2 For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensees fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.

These activities constituted five quarterly inspection samples, as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

a. Inspection Scope

On June 24, 2015, the inspectors completed an inspection of the stations ability to mitigate flooding due to internal causes. After reviewing the licensees flooding analysis, the inspectors chose two plant areas containing risk-significant structures, systems, and components that were susceptible to flooding:

• ultimate heat sink cooling tower north switchgear and fan room

• ultimate heat sink cooling tower south switchgear and fan room The inspectors reviewed plant design features and licensee procedures for coping with internal flooding. The inspectors walked down the selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether operator actions credited for flood mitigation could be successfully accomplished.

These activities constitute completion of one flood protection measures sample, as defined in Inspection Procedure 71111.06.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On July 24, 2015, the inspectors observed plant startup just-in-time simulator training for an operating crew. The inspectors assessed the performance of the operators and the evaluators critique of their performance.

These activities constitute completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

On July 23, 2015, the inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened activity and risk due to a technical specification required plant shutdown. The inspectors observed the operators performance of the following activities:

• power reduction

• reactor shutdown

• plant cooldown In addition, the inspectors assessed the operators adherence to plant procedures, including Procedure ODP-ZZ-00001, Operations Department - Code of Conduct, and other operations department policies.

These activities constitute completion of one quarterly licensed operator performance sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.3 Biennial Review of Requalification Program

The licensed operator requalification program involves two training cycles that are conducted over a 2-year period. In the first cycle, the annual cycle, the operators are administered an operating test consisting of job performance measures and simulator scenarios. In the second part of the training cycle, the biennial cycle, operators are administered an operating test and a comprehensive written examination. The examiners observed the associated training cycles during this inspection period.

a. Inspection Scope

To assess the performance effectiveness of the licensed operator requalification program, the inspectors conducted personnel interviews, reviewed both the operating tests and written examinations, and observed ongoing operating test activities.

The inspectors interviewed four licensee personnel from the training staff to determine their understanding of the policies and practices for administering requalification examinations. The inspectors also reviewed operator performance on the written examinations and operating tests. These reviews included observations of portions of the operating tests by the inspectors. The operating tests observed included seven job performance measures and two scenarios that were used in the current biennial requalification cycle. These observations allowed the inspectors to assess the licensee's effectiveness in conducting the operating test to ensure operator mastery of the training program content.

The results of these examinations were reviewed to determine the effectiveness of the licensees appraisal of operator performance and to determine if feedback of performance analyses into the requalification training program was being accomplished.

The inspectors interviewed members of the training department and reviewed minutes of training review group meetings to assess the responsiveness of the licensed operator requalification program to incorporate the lessons learned from both plant and industry events. Examination results were also assessed to determine if they were consistent with the guidance contained in NUREG 1021, Operator Licensing Examination Standards for Power Reactors, Revision 9, Supplement 1, and NRC Manual Chapter 0609, Appendix I, Licensed Operator Requalification Significance Determination Process.

On September 3, 2015, the licensee informed the inspectors of the completed cycle results for the station for both the written examinations and the operating tests:

• 10 of 10 crews passed the simulator portion of the operating test

• 57 of 57 licensed operators passed the simulator portion of the operating test

• 56 of 57 licensed operators passed the job performance measure portion of the operating test

• 56 of 57 licensed operators passed the written examination There were two licensed operators that failed a portion of the examination. Both the individual that failed the written exam and the job performance measure portion of the operating test were remediated, retested, and passed their retake examinations or tests.

The inspectors compared these results to NRC Inspection Manual Chapter 0609, Appendix I, Licensed Operator Requalification Significance Determination Process, values and determined that there were no findings based on these results and because all of the individuals that failed the applicable portions of their examinations and/or operating tests were remediated, retested, and passed their retake examinations prior to returning to shift.

The inspectors observed examination security measures in place during administration of the exams (including controls and content overlap) and reviewed any remedial training and re-examinations, if necessary. The inspectors also reviewed medical records of five licensed operators for conformance to license conditions and the licensees system for tracking qualifications and records of license reactivation for six operators.

The inspectors reviewed simulator performance for fidelity with the actual plant and the overall simulator program of maintenance, testing, and discrepancy correction. Part of the inspection included a review of a simulator issue that NRC examiners identified in the 2014 NRC initial licensing examination. It dealt with the simulators initiation of a safety injection signal during an anticipated transient without scram event (Simulator Fidelity Report within Examination Report 05000483/2014301). At the conclusion of this inspection, the licensee was in the process of reviewing the technical basis for the issue amongst their engineering and simulator staff. An evaluation of the issue is expected to be completed in October 2015. When the evaluation is made available, NRC staff will review the results to determine if any regulatory actions will result from this issue.

The inspectors completed one inspection sample of the biennial licensed operator requalification program.

b. Findings

Failure to Conduct Simulator Testing and Maintenance In Accordance With ANSI/ANS-3.5-2009

Introduction.

The inspectors identified a Green finding with four examples for failing to conduct simulator testing and maintenance in accordance with the standards of ANSI/ANS-3.5-2009. Specifically, the licensee failed to do the following:

• set the instantaneous main turbine load reduction to 50 percent as supported by design basis data in the 2014 performance of Transient (11), Maximum Design Load Rejection

• include the evaluation of parameter pressurizer temperature in the 30 percent, 50 percent, and 80 percent power Steady-State Performance Test as specified in accordance with the standard, Appendix B, Section B.3.1

• include the evaluation of parameter secondary heat balance data in the 30 percent, 50 percent, and 80 percent power Steady-State Performance Test as specified in accordance with the standard, Appendix B, Section B.3.1

• replicate the dynamic functioning of annunciators on the simulator panels used during normal, abnormal, off-normal, and emergency evolutions, or to identify and correct noticeable differences in accordance with the standard, Sections 4.2.1.2 and 4.2.1.4

Description.

In order to maintain an NRC-approved simulation facility, the licensee is required to conduct testing and maintenance throughout the life of the simulator to ensure that it can be used to model control manipulations consistent with the actual plant. An acceptable method for conducting this testing is by using industry standard ANSI/ANS-3.5, Nuclear Power Plant Simulators for Use in Operator Training and Examination. This industry standard has been endorsed by the NRC as an acceptable method to completing required simulator testing to meet the requirements of 10 CFR 55.46 per Regulatory Guide 1.149, Nuclear Power Plant Simulation Facilities for Use in Operator Training, License Examinations, and Applicant Experience Requirements. Per licensee Procedure TDP-IS-00002, Simulator Configuration Management, the licensee uses ANSI/ANS-3.5-2009 as the standard for their simulator testing.

Example 1: Transient (11), Maximum Design Load Rejection, involves initiating the maximum design step load reduction that will not result in a reactor trip. The document Simulator Information Formal Tracking Number 20130001, Test ID T5285 (accepted on December 5, 2013), represents the current record of completing this test. In the description of the test, it says that main turbine loading is reduced from 100 percent to 75 percent power. The basis for this plant-specific parameter is typically detailed in the Final Safety Analysis Report (FSAR), but there was no reference to the FSAR in the test record. The NRC inspectors located, and verified via discussion with the licensee, that the description for the maximum design load rejection was stated in the FSAR. In the FSAR, Revision OL-17, Section 7.7.1.8, it states, in part, that, The steam dump system, together with control rod movement, is designed to accept a 50 percent loss of net load without tripping the reactor. On July 14, 2015, the licensee communicated to the NRC inspectors that the tests initial conditions were not correctly set up to match the FSAR since 2000. The test was revised to include the correct initial conditions and recompleted on July 6, 2015. The results met the transient test acceptance criteria stated in ANSI-3.5-2009, Section 4.1.4.

The licensee is documenting corrective actions addressing this issue in Callaway Action Request 201504760.

Examples 2 and 3: The licensee had completed steady-state tests at 30 percent, 50 percent, and 80 percent reactor power levels in 2015. The tests, described in Appendix B, Section B.1.1, and Section 4.1.3.1 of the standard; involve operating the simulator at a fixed reactor power level, monitoring the output of defined plant parameters, and comparing to specific tolerance bands specified in the acceptance criteria. Two of the defined plant parameters, pressurizer temperature and secondary heat balance data, were not evaluated versus reference plant data in the tests. The NRC inspectors asked if the parameters were modeled in the simulator and if there was reference plant data available for comparison to the parameters. The licensee determined that these parameters were modeled in the simulator and that they could be evaluated versus available reference plant data as part of the tests. Pressurizer temperature was made available for tracking in the simulator in 2006, but the licensee failed to add it to the testing regimen. Secondary heat balance data used to be included in the steady-state tests, but during the process of implementing plant computer upgrades in the simulator during the 1998-2000 timeframe, tracking of this parameter set was discontinued.

On July 14, 2015, the licensee provided new testing records showing that the parameter pressurizer temperature was included in a new performance of the 30 percent, 50 percent, and 80 percent reactor power levels. Also, simulator secondary heat balance data was evaluated in steady-state tests evaluated versus four different calorimetric results completed in the plant associated with the current fuel load. No simulator fidelity issues were identified. The licensee is documenting corrective actions addressing these issues in Callaway Action Requests 201504759 and 201504418.

Example 4: Part of the inspection involves reviewing the status of equipment and controls in the plant control room versus the displays in the simulator to ensure that noticeable differences are identified. With their identification, the simulator differences can be corrected or tracked on a licensee simulator differences list, if justified by training needs analysis as having minimal impact on operator training. The expectation is that the simulators instrumentation and controls include those in the reference plant and that comparisons between the simulator and reference plant identify and address noticeable differences is discussed in ANSI-3.5-2009, Sections 3.2.1.2, 4.2.1.2, and 4.2.1.4.

On June 16, 2015, the NRC inspectors reviewed the current state of the plant control room. As part of this, the inspectors reviewed the defeated annunciator log book. There were several annunciators in the control room that were defeated within the last year, indicating recent changes. However, there were three annunciators that have been defeated for time ranging from July 20, 2005, to December 1, 2011. Since these alarms have been defeated for a long time, these are essentially permanent changes that remove the ability for control room operators to receive these alarms.

The three annunciators in question were not identified on the licensee simulator differences list, so the NRC inspectors asked the licensee about how they were addressing the modeling of these three annunciators in the simulator. It was determined on June 17, 2015, that these annunciator alarms were in service in the simulator, and had not been defeated to match the reference plant. In effect, the licensee left three active annunciators in the simulator that licensed operators could be called upon to respond to in abnormal events that they will not have to respond to in the actual plant.

The licensee took corrective action to place disabled annunciator tags on the three annunciators in the simulator that day. Licensee review of the actions taken in the 2005 through 2011 timeframe revealed that the defeated annunciators were evaluated in the plants change control processes, but were not evaluated for impact on the simulator.

Further actions are documented in Callaway Action Request 201504355.

Analysis.

The licensees failure to conduct testing and maintenance in accordance with the ANSI/ANS-3.5-2009 standard as endorsed by Regulatory Guide 1.149, Revision 4, was the performance deficiency. Per licensee Procedure TDP-IS-00002, Simulator Configuration Management, the licensee uses ANSI/ANS-3.5-2009 as the standard for simulator testing and maintenance. The performance deficiency is more than minor because it adversely impacted the human performance 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.

Additionally, if left uncorrected, the performance deficiency could have become more significant in that not completing the required simulator testing and maintenance correctly can lead to not detecting and correcting errors in the simulator so it actually models the plant correctly. This can leave the potential for negative training of licensed operators and call into question the ability to conduct valid licensing examinations with the simulator. Using Manual Chapter 0609, Significance Determination Process, 4, Tables 1, 2, and 3 worksheets (issue date June 19, 2012); and the corresponding Appendix I, Licensed Operator Requalification Significance Determination Process (SDP), Flowchart Block #14 (issue date December 6, 2011), the finding was determined to have very low safety significance (Green) because the issue dealt with deficiencies associated with simulator testing, modifications, and maintenance, and there was no evidence that the plant-referenced simulator does not demonstrate the expected plant response or does not have uncorrected modeling and hardware deficiencies related to these examples.

The examples supporting this finding involved actions taken with the simulator testing and maintenance program before the present performance period. Therefore, no cross-cutting aspect is assigned.

Enforcement.

This finding does not involve enforcement action because no regulatory requirement violation was identified. Because this finding does not involve a violation and has very low safety significance, it is identified as FIN 05000483/2015003-01, Failure to Conduct Simulator Testing and Maintenance In Accordance With ANSI/ANS-3.5-2009.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed three instances of degraded performance or condition of structures, systems, and components:

• July 24, 2015, digital feedwater control panel issue resulting in trip of train B main feedwater pump

• July 24, 2015, train A centrifugal charging pump motor bearing oil seal loose

• September 1, 2015, reactor coolant system boundary leakage The inspectors reviewed the extent of condition of possible common cause structure, system, and component failures and evaluated the adequacy of the licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the structures, systems, and components. The inspectors assessed the licensees characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.

These activities constituted completion of three maintenance effectiveness samples, as defined in Inspection Procedure 71111.12.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

On June 22, 2015, the inspectors reviewed a risk assessment performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk for the replacement of auxiliary building/fuel building fire protection cross-connect valve KCV0068.

The inspectors verified that this risk assessment was performed in a timely manner and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensees risk assessment and verified that the licensee implemented appropriate risk management actions based on the result of the assessment.

The inspectors also observed portions of three emergent work activities that had the potential to cause an initiating event or to affect the functional capability of mitigating systems:

• July 22, 2015, reactor coolant system leak on valve BBV0400

• July 29, 2015, auxiliary feedwater flow control valve ALHV0009 common cause failure concerns

• August 3, 2015, power range nuclear instrument N43 failed downscale The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected structures, systems, and components.

These activities constitute completion of four maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed four operability determinations that the licensee performed for degraded or nonconforming structures, systems, or components:

• June 8, 2015, train A emergency diesel generator room fan failure, Callaway Action Request 201504143

• June 15, 2015, train A control room air conditioning unit tripped, Callaway Action Request 201504294

• July 23, 2015, auxiliary feedwater flow control valve ALHV0011 did not open on demand, Callaway Action Request 201505586

• August 3, 2015, safety injection accumulator C not sampled, Callaway Action Request 201505586 The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded structure, system, or component to be operable, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability of the degraded structure, system, or component.

The inspectors reviewed operator actions taken or planned to compensate for degraded or nonconforming conditions. The inspectors verified that the licensee effectively managed these operator workarounds to prevent adverse effects on the function of mitigating systems and to minimize their impact on the operators ability to implement abnormal and emergency operating procedures.

These activities constitute completion of four operability and functionality review samples, which included one operator work-around sample, as defined in Inspection Procedure 71111.15

b. Findings

Introduction.

Inspectors identified a finding of very low safety significance (Green) and associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to perform an operability determination for a safety related component in accordance with plant procedures. Specifically, when an auxiliary feedwater control valve failed to operate from the main control room, the licensee failed to evaluate the operability of the component in accordance with the plant procedure.

Description.

On July 23, 2015, during a forced plant outage, the running main feedwater pump was tripped due to issues with the speed control. The auxiliary feedwater system was subsequently placed in service manually in accordance with Procedure OTN-AL-00001, Auxiliary Feedwater System. Per the procedure, the motor-driven auxiliary feedwater pump flow control valves, ALHV0005, ALHV0007, ALHV0009, and ALHV0011, were closed and the pumps were started. After the pumps were started, the motor-driven auxiliary feedwater pump flow control valve controllers were manually set at approximately 50 percent open and with the exception of ALHV0011, the valves opened as demanded. The control room crew sent an operator to investigate and open the valve locally. The operator began to open ALHV0011, and once it was off its closed seat, the valve operated as expected from the main control room.

Procedure OTN-AL-00001 contains a "Precaution and Limitation" discussing how the turbine-driven auxiliary feedwater pump flow control valves, which are pneumatically-operated, can become hydraulically locked if the valves are closed while the turbine-driven pump is running then subsequently secured, the valves are leaking, or they are closed while the motor-driven pumps are running. The procedure goes on to discuss that this condition may require operator intervention to open the valves, but due to the design, it does not affect the function of the valves. This precaution was brought to the attention of the shift manager with the belief that it should apply to the motor-operated valves as well. The shift manager also misinterpreted the precautions applicability to the motor-driven auxiliary feedwater flow control valves, which are motor-operated not pneumatically-operated. Based on this misperception, the shift manager made the determination that ALHV0011 was operable throughout this event.

The inspectors challenged the licensee about the position that ALHV0011 could become hydraulically locked. The licensees engineering staff evaluated the condition and determined that the valve could not become hydraulically locked and would not have been able to perform its design function in the as-found condition. The licensee then declared the valve inoperable until the cause of the failure was determined and repaired.

Procedure APA-ZZ-00500, Appendix 1, Operability and Functionality Determinations, is the governing document for evaluating operability and it references Procedure ODP-ZZ-00001, Addendum 15, Operability and Functionality Determinations, as guidance for the shift manager. Procedure ODP-ZZ-00001, Addendum 15, dictates that recognition of a degraded or nonconforming condition is the entry point for operability and functionality determinations. In this case, the shift manger failed to recognize the stuck closed valve as a degraded or nonconforming condition and, therefore, did not perform an operability determination.

Analysis.

The licensees failure to follow their operability determination procedure was a performance deficiency. The performance deficiency is more than minor and, therefore, a finding, because, if left uncorrected, it had the potential to lead to a more significant safety concern. Specifically, if the licensee had not corrected the degraded condition of valve ALHV0011, the valve may have failed to respond during an event and challenged the safety function of the motor driven auxiliary feedwater system. The finding affects the Mitigating System Cornerstone because the performance deficiency is related to the auxiliary feedwater systems ability to conduct short-term decay heat removal.

This finding was assessed using Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, dated April 29, 2015, and was determined to be of very low safety significance because it did not affect system design, did not result in a loss of system function, did not represent a loss of function of a single train for greater than its technical specifications allowed outage time, and did not cause the loss of function of one or more non-technical specification trains of equipment designated as high safety-significance. This finding has a cross-cutting aspect of challenge the unknown in the human performance cross-cutting area because the licensee did not stop when faced with uncertain conditions. Specifically, rather than declaring the system inoperable and allowing the process to evaluate the condition, the licensee declared the system operable without fully understanding the failure mechanism [H.11].

Enforcement.

Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be accomplished in accordance with procedures.

Procedure ODP-ZZ -00001, Addendum 15, Operability and Functionality Determinations, Revison 8, an Appendix B quality related procedure, requires licensee personnel to recognize potentially degraded or nonconforming conditions and evaluate operability. Contrary to the above, on July 23, 2015, the licensee did not recognize a degraded condition and evaluate operability. Specifically, licensee personnel did not recognize an auxiliary feedwater valve that would not respond to main control board signals was degraded and, therefore, did not identify the valve was inoperable. Because this finding is of very low safety significance and was entered into the corrective action program as Callaway Action Request 201505411, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy:

NCV 05000483/2015003-02, Failure to Follow Operability Determination Procedure.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed four post-maintenance testing activities that affected risk-significant structures, systems, or components:

• July 5, 2015, train B class 1E switchgear air conditioning unit after bearing replacement

• July 27, 2015, train A centrifugal charging pump after motor seal replacement

• July 27, 2015, auxiliary feedwater flow control valve ALHV0011 after potentiometer repair

• August 12, 2015, auxiliary feedwater flow control valves ALHV0005 and ALHV0007 after Modutronics card replacement The inspectors reviewed licensing- and design-basis documents for the structures, systems, or components and the maintenance and post-maintenance test procedures.

The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected systems, structures, and components.

These activities constitute completion of four post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

a. Inspection Scope

During the stations forced outages that concluded on July 27 and August 13, 2015, the inspectors evaluated the licensees outage activities. The inspectors verified that the licensee considered risk in developing and implementing the outage plan, appropriately managed personnel fatigue, and developed mitigation strategies for losses of key safety functions. This verification included the following:

• review and verification of the licensees fatigue management activities

• monitoring of shutdown and cooldown activities

• verification that the licensee maintained defense-in-depth during outage activities

• monitoring of heat-up and startup activities These activities constitute completion of two outage activities samples, as defined in Inspection Procedure 71111.20.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed three risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the structures, systems, and components were capable of performing their safety functions:

In-service tests:

• August 18, 2015, train B safety injection pump testing Other surveillance tests:

• August 19, 2015, train B centrifugal charging pump testing

• August 21, 2105, train B solid state protection system slave relay testing The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected structures, systems, or components following testing.

These activities constitute completion of three surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS5 Radiation Monitoring Instrumentation

a. Inspection Scope

The inspectors evaluated the accuracy and operability of the radiation monitoring equipment used by the licensee

(1) to monitor areas, materials, and workers to ensure a radiologically safe work environment and

(2) to detect and quantify radioactive process streams and effluent releases. The inspectors interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance in the following areas:

• selected plant configurations and alignments of process, post-accident, and effluent monitors with descriptions in the Final Safety Analysis Report and the offsite dose calculation manual

• selected instrumentation, including effluent monitoring instrument, portable survey instruments, area radiation monitors, continuous air monitors, personnel contamination monitors, portal monitors, and small article monitors to examine their configurations and source checks

• calibration and testing of process and effluent monitors, laboratory instrumentation, whole body counters, post-accident monitoring instrumentation, portal monitors, personnel contamination monitors, small article monitors, portable survey instruments, area radiation monitors, electronic dosimetry, air samplers, and continuous air monitors

• audits, self-assessments, and corrective action documents related to radiation monitoring instrumentation since the last inspection These activities constitute completion of one sample of radiation monitoring instrumentation as defined in Inspection Procedure 71124.05.

b. Findings

Introduction.

The inspectors identified a Green NCV of Callaway Plants License No. NPF-25, Condition 2.B.(3), for the licensee performing non-routine maintenance on a J.L. Shepherd calibrator without license authorization.

Description.

Callaway uses a J.L. Shepherd Model 89-400 shielded calibration range irradiator (the Shepherd) to calibrate portable radiation detection instrumentation used by the radiation protection staff. The Shepherd contains two Cs-137 sealed sources with original activities of 400 Ci and 130 mCi, manually controlled by a vertical rod. At the time of the inspection, the source activities were approximately 290 Ci and 95 mCi, respectively. The 290 Ci source produced a radiation field of 1006 R/hr at one foot from the source.

On May 29, 2014, while performing the routine preoperational checks on the Shepherd calibrator, a radiation protection technician discovered that the safety interlock had failed. This interlock system is designed to prevent the calibrators cabinet door from being opened while the source is unshielded. Upon discovery, the radiation protection technician controlled the hazard by securing the source in the shielded position by placing a locked high radiation area padlock on the source rod. On June 2, 2014, licensee staff performed non-routine maintenance on the calibrator, replacing the failed safety interlock spring to repair the safety interlock system.

The inspectors determined that performing maintenance on the interlock system of the Shepherd was not authorized by Callaways license. The NRC defines non-routine maintenance in NUREG-1556, Volume 5, Program-Specific Guidance About Self-Shielded Irradiator Licenses, to be any repair, removal, replacement, or alteration involving: electrical and mechanical systems that control source or shielding movement, the irradiators shielding or sealed source, safety interlocks, any component that may affect safe operation of the irradiator, or any other activities during which personnel could receive radiation doses exceeding NRC limits.

The licensee performed similar work multiple times in 2011 and 2014, demonstrating their lack of understanding of the Part 50 license commitments to Part 30. Prior to 2011, Callaway routinely had the vendor come to the plant to perform repairs and maintenance.

Analysis.

Performing non-routine maintenance on a J.L. Shepherd calibrator without license authorization is a performance deficiency. The finding is more than minor because the performance deficiency adversely affects the Occupational Radiation Safety Cornerstone, in that, if the licensee performs non-routine maintenance on radiologically risk significant sources without being specifically authorized or trained on how to perform the non-routine maintenance, an uncontrolled high radiation area could result. Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008, the inspectors determined the violation was of very low safety significance (Green) because

(1) it was not an as low as reasonably achievable (ALARA) finding,

(2) there was no overexposure,

(3) there was no substantial potential for an overexposure, and

(4) the ability to assess dose was not compromised. The finding had a conservative bias cross-cutting aspect in the area of human performance, because individuals did not use decision making practices that emphasized prudent choices over those that were simply allowable, or ensure a proposed action was safe in order to proceed, rather than unsafe in order to stop.

Specifically, licensee staff assumed that they could perform any type of maintenance on the calibrator without verifying that their license authorized those activities [H.14].

Enforcement.

Union Electric Company License No. NPF-25, Condition 2.B(3) states, in part, that the Commission licensed Union Electric Company, pursuant to 10 CFR Part 30, to receive, possess, and use at any time any byproduct material as sealed sources for reactor instrumentation and radiation monitoring equipment calibration. Title 10 of the Code of Federal Regulations 30.34(c) states, in part, that each person licensed by the Commission pursuant to the regulations in this part shall confine his possession and use of the byproduct material to the locations and purposes authorized in the license. Except as otherwise provided in the license, a license issued pursuant to the regulations in this part shall carry with it the right to receive, acquire, own, and possess byproduct material.

Contrary to the above, on June 2, 2014, the licensee did not confine its possession and use of the byproduct material to the locations and purposes authorized in the license, namely to receive, acquire, own, and possess byproduct material. Specifically, the licensee performed non-routine maintenance, i.e., repairing of the safety interlock, on a J.L. Shepherd device without a specific license condition authorizing the repair. This violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. The issue was entered into the licensees corrective action program as Callaway Action Request 201505175: NCV 050004832014003-03, Unauthorized Non-Routine Maintenance on a Sealed Source Device.

2RS6 Radioactive Gaseous and Liquid Effluent Treatment

a. Inspection Scope

The inspectors evaluated whether the licensee maintained gaseous and liquid effluent processing systems and properly mitigated, monitored, and evaluated radiological discharges with respect to public exposure. The inspectors verified that abnormal radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors are out-of-service, were controlled in accordance with the applicable regulatory requirements and licensee procedures. The inspectors verified that the licensees quality control program ensured radioactive effluent sampling and analysis adequately quantified and evaluated discharges of radioactive materials. The inspectors verified the adequacy of public dose projections resulting from radioactive effluent discharges. The inspectors interviewed licensee personnel and reviewed or observed the following items:

• radiological effluent release reports since the previous inspection and reports related to the effluent program issued since the previous inspection

• effluent program implementing procedures, including sampling, monitor setpoint determinations and dose calculations

• equipment configuration and flow paths of selected gaseous and liquid discharge system components, filtered ventilation system material condition, and significant changes to their effluent release points, if any, and associated 10 CFR 50.59 reviews

• selected portions of the routine processing and discharge of radioactive gaseous and liquid effluents (including sample collection and analysis)

• controls used to ensure representative sampling and appropriate compensatory sampling

• results of the inter-laboratory comparison program

• effluent stack flow rates

• surveillance test results of technical specification-required ventilation effluent discharge systems since the previous inspection

• significant changes in reported dose values

• selected radioactive liquid and gaseous waste discharge permits

• Part 61 analyses and methods used to determine which isotopes are included in the source term

• offsite dose calculation manual changes

• meteorological dispersion and deposition factors

• latest land use census

• records of abnormal gaseous or liquid tank discharges

• groundwater monitoring results

• changes to the licensees written program for identifying and controlling contaminated spills/leaks to groundwater

• identified leakage or spill events and entries made into 10 CFR 50.75

(g) records, if any, and associated evaluations of the extent of the contamination and the radiological source term

• offsite notifications, and reports of events associated with spills, leaks, and groundwater monitoring results

• audits, self-assessments, reports, and corrective action documents related to radioactive gaseous and liquid effluent treatment since the last inspection These activities constitute completion of one sample of radioactive gaseous and liquid effluent treatment, as defined in Inspection Procedure 71124.06.

b. Findings

No findings were identified.

2RS7 Radiological Environmental Monitoring Program

a. Inspection Scope

The inspectors evaluated whether the licensees radiological environmental monitoring program quantified the impact of radioactive effluent releases to the environment and sufficiently validated the integrity of the radioactive gaseous and liquid effluent release program. The inspectors verified that the radiological environmental monitoring program was implemented consistent with the licensees technical specifications and offsite dose calculation manual, and that the radioactive effluent release program met the design objective in Appendix I to 10 CFR Part 50. The inspectors verified that the licensees radiological environmental monitoring program monitored non-effluent exposure pathways, was based on sound principles and assumptions, and validated that doses to members of the public were within regulatory dose limits. The inspectors reviewed or observed the following items:

• annual environmental monitoring reports and offsite dose calculation manual

• selected air sampling and dosimeter monitoring stations

• collection and preparation of environmental samples

• operability, calibration, and maintenance of meteorological instruments

• selected events documented in the annual environmental monitoring report which involved a missed sample, inoperable sampler, lost dosimeter, or anomalous measurement

• selected structures, systems, or components that may contain licensed material and has a credible mechanism for licensed material to reach ground water

• records required by 10 CFR 50.75(g)

• significant changes made by the licensee to the offsite dose calculation manual as the result of changes to the land census or sampler station modifications since the last inspection

• calibration and maintenance records for selected air samplers, composite water samplers, and environmental sample radiation measurement instrumentation

• inter-laboratory comparison program results

• audits, self-assessments, reports, and corrective action documents related to the radiological environmental monitoring program since the last inspection These activities constitute completion of one sample of radiological environmental monitoring program as defined in Inspection Procedure 71124.07.

b. Findings

No findings were identified.

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation (71124.08)

a. Inspection Scope

The inspectors evaluated the effectiveness of the licensees programs for processing, handling, storage, and transportation of radioactive material. The inspectors interviewed licensee personnel and reviewed the following items:

• the solid radioactive waste system description, process control program, and the scope of the licensees audit program

• control of radioactive waste storage areas including container labeling/marking and monitoring containers for deformation or signs of waste decomposition

• changes to the liquid and solid waste processing system configuration including a review of waste processing equipment that is not operational or abandoned in place

• radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides

• processes for waste classification including use of scaling factors and 10 CFR Part 61 analysis

• shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and preparation of the disposal manifest

• audits, self-assessments, reports, and corrective action reports radioactive solid waste processing, and radioactive material handling, storage, and transportation performed since the last inspection These activities constitute completion of one sample of radioactive solid waste processing, and radioactive material handling, storage, and transportation as defined in Inspection Procedure 71124.08.

b. Findings

No findings were identified.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security

4OA1 Performance Indicator Verification

.1 Unplanned Scrams per 7000 Critical Hours (IE01)

a. Inspection Scope

The inspectors reviewed licensee event reports for the period of third quarter 2014 through second quarter 2015 to determine the number of scrams that occurred. The inspectors compared the number of scrams reported in these licensee event reports to the number reported for the performance indicator. Additionally, the inspectors sampled monthly operating logs to verify the number of critical hours during the period. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the data reported.

These activities constituted verification of the unplanned scrams per 7000 critical hours performance indicator for Callaway Plant, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.2 Unplanned Power Changes per 7000 Critical Hours (IE03)

a. Inspection Scope

The inspectors reviewed operating logs and corrective action program records for the period of third quarter 2014 through second quarter 2015 to determine the number of unplanned power changes that occurred. The inspectors compared the number of unplanned power changes documented to the number reported for the performance indicator. Additionally, the inspectors sampled monthly operating logs to verify the number of critical hours during the period. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the data reported.

These activities constituted verification of the unplanned power outages per 7000 critical hours performance indicator for Callaway Plant, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.3 Unplanned Scrams with Complications (IE04)

a. Inspection Scope

The inspectors reviewed the licensees basis for including or excluding in this performance indicator each scram that occurred between the third quarter 2014 and second quarter 2015. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the data reported.

These activities constituted verification of the unplanned scrams with complications performance indicator for Callaway Plant, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.4 Safety System Functional Failures (MS05)

a. Inspection Scope

For the period of second quarter 2014 through first quarter 2015, the inspectors reviewed licensee event reports, maintenance rule evaluations, and other records that could indicate whether safety system functional failures had occurred. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, and NUREG-1022, Event Reporting Guidelines: 10 CFR 50.72 and 50.73, Revision 3, to determine the accuracy of the data reported.

These activities constituted verification of the safety system functional failures performance indicator for Callaway Plant, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.

b. Findings

No findings were identified.

.2 Annual Follow-up of Selected Issues

a. Inspection Scope

On July 1, 2015, the inspectors selected Callaway Action Request 201504790, which identified the train B Class 1E air conditioning unit (SGK05B) fan bearing has high vibrations for an in-depth follow-up.

The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews, and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the condition.

These activities constitute completion of one annual follow-up sample as defined in Inspection Procedure 71152.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On June 18, 2015, the inspectors debriefed Mr. B. Cox, Senior Director, Nuclear Operations, and other members of the licensee's staff of the results of the licensed operator requalification program inspection. On September 10, 2015, the results of the inspection were telephonically exited with Mr. B. Cox, Senior Director, Nuclear Operations, and other members of your staff.

The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On July 17, 2015, the inspectors presented the radiation safety inspection results to Mr. F. Diya, Vice President, Nuclear Operations, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On September 30, 2015, the inspectors presented the inspection results to Mr. D. Neterer, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meet the criteria of the NRC Enforcement Policy, for being dispositioned as an NCV.

Title 10 of the Code of Federal Regulations 55.46(c), Plant-Referenced Simulators, requires, in part, that a plant-referenced simulator must demonstrate expected plant response to operator input and to transient and accident conditions to which the simulators have been designed to respond. Contrary to the above, on December 12, 2013, and March 23, 2015, the simulator failed to demonstrate expected plant response to operator input and to transient and accident conditions to which the simulator has been designed to respond. Specifically, during simulator post-event testing on those dates, the simulator did not correspond in direction of change of all monitored plant parameters and, in one case, the letdown portion of the chemical and volume control system automatically isolated when this did not occur in the reference plant. The violation was of very low safety significance because it dealt with identified simulator modeling deficiencies that did not negatively impact operator performance in the actual plant during reportable events. The licensee entered this issue into their corrective action program as Callaway Action Report 201504406.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

F. Bianco, Director, Nuclear Operations

M. Covey, Assistant Operations Manager, Support

B. Cox, Senior Director, Nuclear Operations

F. Diya, Senior Vice President and Chief Nuclear Officer

R. Farnam, Director, Training

J. Geyer, Director, Radiation Protection

L. Graessle, Senior Director, Operations Support

C. Graham, Consulting Health Physicist

W. Gruer, Manager, Operations (Training)

J. Houston, Senior Health Physicist, Radiation Protection

G. Hurla, Supervisor, Radiation Protection

J. Little, Supervisor, Safety Analysis/Reactor Engineering

S. Maglio, Manager, Regulatory Affairs

J. Mayer, Supervisor, Radwaste Operations

M. McLachlan, Director, Engineering Systems

J. McLaughlin IV, NESM System Engineer, Systems Engineering

V. Miller, Supervisor, Radiation Protection

S. Petzel, Engineer, Regulatory Affairs

J. Reuter, Technician, Radiation Protection

C. Smith, Manager, Radiation Protection

R. Stough, Operations Training Manager

F. Stuckey, Health Physicist

T. Trent, ALARA Coordinator, Radiation Protection

D. Turley, Supervisor, Engineering Systems

T. Witt, Licensing Engineer, Regulatory Affairs

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000483/2015003-01 FIN Failure to Conduct Simulator Testing and Maintenance In Accordance with ANSI/ANS-3.5-2009 (Section 1R11)

05000483/2015003-02 NCV Failure to Follow Operability Determination Procedure (Section 1R15)

05000483/2015003-03 NCV Unauthorized Non-Routine Maintenance on a Sealed Source Device (Section 2RS5)