IR 05000483/2018002

NRC Integrated Inspection Report 05000483/2018002

ML18221A398
Person / Time
Site:	Callaway
Issue date:	08/08/2018
From:	Nick Taylor NRC Region 4
To:	Diya F Ameren Corp, Union Electric Co
References
IR 2018002
Download: ML18221A398 (46)

Text

ust 8, 2018

SUBJECT:

CALLAWAY PLANT - NRC INTEGRATED INSPECTION REPORT 05000483/2018002

Dear Mr. Diya:

On June 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Callaway Plant. On July 10, 2018, the NRC inspectors discussed the results of this inspection with Mr. M. McLachlan, Senior Director, and other members of your staff. The results of this inspection are documented in the enclosed report.

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

All of these findings involved violations of NRC requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the 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; 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 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 05000483/2018002 w/Attachments:

1: Documents Reviewed 2. Request for Information Quarterly Baseline Inspection 3: Request for Information O

Inspection Report

Docket Number: 05000483 License Number: NPF-30 Report Number: 05000483/2018002 Enterprise Identifier: I-2018-002-0006 Licensee: Union Electric Company Facility: Callaway Plant Location: 8315 County Road 459 Steedman, MO 65077 Inspection Dates: April 1 to June 30, 2018 Inspectors: D. Bradley, Senior Resident Inspector S. Janicki, Resident Inspector P. Elkmann, Senior Emergency Preparedness Inspector N. Greene, PhD, Senior Health Physicist P. Hernandez, Health Physicist D. You, Resident Inspector Approved By: N. Taylor Chief, Project Branch B Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the 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. Findings and violations being considered in the NRCs assessment are summarized in the tables below.

List of Findings and Violations Failure to Adequately Assess and Manage Risk Associated with Switchyard Work During a Planned Risk Significant Turbine-Driven Auxiliary Feedwater Pump Equipment Outage Cornerstone Significance Cross-cutting Report Section Aspect Initiating Green H.12 Avoid 71111.12 Events NCV 05000483/2018002-01 Complacency Maintenance Closed Effectiveness The inspectors identified a Green, non-cited violation of 10 CFR 50.65(a)(4), Requirements for monitoring the effectiveness of maintenance at Nuclear Power Plants, for the licensees failure to adequately assess and manage risk associated with switchyard work during a planned risk significant turbine-driven auxiliary feedwater pump equipment outage. Specifically, the licensee failed to properly classify switchyard work and manage the risk as required by Procedures APA-ZZ-00322, Appendix F, Online Work Integrated Risk Management,

Revision 16, and ODP-ZZ-00002, Appendix 2, Risk Management Actions for Planned Risk Significant Activities, Revision 13.

Failure to Establish Maintenance Procedures for Doors that Provide Safety-Related Functions Cornerstone Significance Cross-cutting Report Section Aspect Barrier Green H.4 71111.12 Integrity NCV 05000483/2018002-02 Teamwork Maintenance Closed Effectiveness The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a,

Procedures, for the licensees failure to establish, implement, and maintain procedures associated with door maintenance. Specifically, the licensee failed to establish, implement, and maintain maintenance procedures for doors that provide safety-related functions such as ventilation pressure boundaries. As a result, 15 safety-related doors were identified that either had degraded conditions or that did not have a periodic maintenance task to inspect the doors.

Failure to Critique an Inaccurate Emergency Classification During a Simulator Training Scenario Cornerstone Significance Cross-cutting Report Section Aspect Emergency Green P.6 71114.05 Preparedness NCV 05000483/2018002-03 Self- Maintenance of Closed Assessment Emergency Preparedness The inspectors identified a non-cited violation of 10 CFR 50.47(b)(14) for the licensees failure to critique an inaccurate emergency classification made during licensed operator training.

Failure of an Analysis of the Impact of Changes to Emergency Action Levels to Demonstrate the Changes Did Not Reduce the Effectiveness of the Emergency Plan Cornerstone Significance Cross-cutting Report Section Aspect Emergency Green H.14 71114.05 Preparedness NCV 05000483/2018002-04 Conservative Maintenance of Closed Bias Emergency Preparedness The inspectors identified a non-cited violation of 10 CFR 50.54(q)(3) for the failure of an analysis of the impact of changes to licensee emergency action levels to demonstrate that the changes did not reduce the effectiveness of the emergency plan.

Additional Tracking Items Type Issue number Title Report Status Section LER 05000483/2018-001-00 Violation of Technical 71153 Closed Specification 3.6.3, Containment Isolation Manual Valve Found in Open Position

PLANT STATUS

Callaway Plant began the inspection period at full power and remained at this power level through the end of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public Web site 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 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in Inspection Manual Chapter 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

71111.01Adverse Weather Protection Summer Readiness

The inspectors evaluated summer readiness of offsite and alternate alternating current power systems on May 3, 2018.

71111.04Equipment Alignment Partial Walkdown

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

(1) Safety injection pump train B on April 27, 2018

(2) Emergency diesel generator train B, including related essential service water on May 1, 2018

(3) Motor-driven auxiliary feedwater train A and train B on May 8, 2018

(4) Emergency diesel generator train A on May 29, 2018

71111.05AQFire Protection Annual/Quarterly Quarterly Inspection

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

(1) Containment spray train A, fire area A-2, on April 10, 2018

(2) Emergency diesel generator train A, fire area D-1, on April 10, 2018

(3) Auxiliary feedwater pump and valve rooms, fire areas A-13, A-14, A-15, A-29, and A-30, on June 12, 2018

(4) Fuel Handling Building, fire area FB-1, on June 28, 2018

71111.11Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification

The inspectors observed and evaluated simulator training for operating crews annual exam activities on May 31, 2018.

Operator Performance (1 Sample)

The inspectors observed and evaluated control rod positioning in the control room on May 11, 2018.

71111.12Maintenance Effectiveness Routine Maintenance Effectiveness

The inspectors evaluated the effectiveness of routine maintenance activities associated with the turbine-driven auxiliary feedwater system on May 9, 2018.

Quality Control (1 Sample)

The inspectors evaluated maintenance and quality control activities associated with the safety-related door preventive maintenance, including quality control, for hazard barriers on April 17, 2018.

71111.13Maintenance Risk Assessments and Emergent Work Control

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

(1) Elevated risk actions due to planned containment spray train A equipment outage on April 11, 2018

(2) Elevated risk actions due to planned emergency diesel generator train B and essential service water train B equipment outage on May 1, 2018

(3) Elevated risk actions due to planned main turbine control oil system equipment outage on May 28, 2018

(4) Elevated risk actions due to emergent work on the emergency diesel generator train A lube oil system on June 21, 2018

71111.15Operability Determinations and Functionality Assessments

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Residual heat removal valve interlocks on April 2, 2018

(2) Auxiliary transformer gas testing on April 12, 2018

(3) Air conditioning units, SGK04 and SGK05 series, restart capability on April 17, 2018

(4) Containment sump indications on April 24, 2018

(5) Emergency operating procedures for natural circulation cooldown on May 7, 2018

(6) Atmospheric steam dump and auxiliary feedwater nitrogen accumulators, including operator workaround review, on May 18, 2018

(7) Emergency diesel generator train B fuel rack displacement on May 22, 2018

(8) Safety injection tank C accumulator vent valve reseating on June 15, 2018

71111.19Post Maintenance Testing

The inspectors evaluated the following post maintenance tests:

(1) Essential service water cross-connect valve EFHV0026 equipment outage on April 23, 2018

(2) Essential service water cross-connect valve EFHV0040 equipment outage on April 25, 2018

(3) Containment cooler trains B and D after equipment outage on May 22, 2018

(4) Emergency diesel generator train B after equipment outage on May 30, 2018

(5) Control room air conditioning unit SGK04A equipment outage on June 5, 2018

(6) Circuit breaker NG02BJF2 after equipment outage on June 19, 2018

71111.22Surveillance Testing The inspectors evaluated the following surveillance tests: Routine

(1) ISF-AL-00P37, condensate storage tank to auxiliary feedwater suction header pressure channel test on April 17, 2018

(2) OSP-NB-00001, class 1E electrical source verification on May 14, 2018

(3) OSP-AL-V001B, train B auxiliary feedwater valve in-service test on April 24, 2018

(4) OSP-NE-0001A, emergency diesel generator train A periodic tests on June 13, 2018

In-service (1 Sample)

The inspectors evaluated OSP-EN-P001A, containment spray pump train A in-service test on April 11, 2018.

Reactor Coolant System Leak Detection (1 Sample)

The inspectors evaluated OSP-BB-00009, reactor coolant system inventory balance on May 15, 2018.

71114.02Alert and Notification System Testing

The inspectors evaluated maintenance and testing of the alert and notification system on April 25, 2018.

71114.03Emergency Response Organization Staffing and Augmentation System

The inspectors evaluated readiness of the emergency preparedness organization on April 26, 2018.

71114.04Emergency Action Level and Emergency Plan Changes

The inspectors evaluated submitted emergency action level and emergency plan changes on April 26, 2018. This evaluation does not constitute NRC approval.

71114.05Maintenance of Emergency Preparedness

The inspectors evaluated maintenance of the emergency preparedness program between April 23 and April 25, 2018.

71114.06Drill Evaluation Drill/Training Evolution

The inspectors evaluated the full participation drill, Team 5 on May 24,

71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls Radiological Work Planning

The inspectors evaluated the licensees radiological work planning by reviewing the following activities:

(1) RF22 crane valve work

(2) R22-55320 reactor building head lift

(3) R22-56321 remove/reinstall reactor vessel lower internals

(4) R22-50101 radiation Protection Routine Activities Reactor Building

(5) R22-55220 reactor building head removal Verification of Dose Estimates and Exposure Tracking Systems (1 Sample)

The inspectors evaluated dose estimates and exposure tracking.

71124.04 - Occupational Dose Assessment Source Term Characterization

===The inspectors evaluated the licensees source term characterization.

External Dosimetry===

The inspectors evaluated the licensees external dosimetry program.

Internal Dosimetry (1 Sample)

The inspectors evaluated the licensees internal dosimetry program.

Special Dosimetry Situations (1 Sample)

The inspectors evaluated the licensees performance for special dosimetry situations.

OTHER ACTIVITIES - BASELINE

71151Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

(1) MS05: Safety System Functional Failures Sample (04/01/2017 - 03/31/2018)

(2) MS08: Heat Removal Systems (04/01/2017 - 03/31/2018)

(3) BI02: Reactor Coolant System Leak Rate Sample (04/01/2017 - 03/31/2018)

(4) EP01: Drill/Exercise Performance Sample (04/01/2017 - 03/31/2018)

(5) EP02: Emergency Response Organization (ERO) Drill Participation Sample (04/01/2017 - 03/31/2018)

(6) EP03: Alert and Notification System Reliability Sample (04/01/2017 - 03/31/2018)

71152Problem Identification and Resolution Semiannual Trend Review

The inspectors reviewed the licensees corrective action program for trends that might be indicative of a more significant safety issue.

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

The inspectors evaluated Licensee Event Report 05000483/2018-001-00, Violation of Technical Specification 3.6.3, Containment Isolation Manual Valve Found in Open Position on March 12, 2018, which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx.

A minor violation was documented in the inspection results section of this report.

INSPECTION RESULTS

Failure to Adequately Assess and Manage Risk Associated with Switchyard Work During a Planned Risk Significant Turbine-driven Auxiliary Feedwater Pump Equipment Outage Cornerstone Significance Cross-cutting Report Aspect Section Initiating Green H.12 Avoid 71111.12 Events NCV 05000483/2018002-01 Complacency Maintenance Closed Effectiveness The inspectors identified a Green, non-cited violation of 10 CFR 50.65(a)(4), Requirements for monitoring the effectiveness of maintenance at nuclear power plants, for the licensees failure to adequately assess and manage risk associated with switchyard work during a planned risk significant turbine-driven auxiliary feedwater (TDAFW) pump equipment outage.

Specifically, the licensee failed to properly classify switchyard work and manage the risk as required by Procedures APA-ZZ-00322, Appendix F, Online Work Integrated Risk Management, Revision 16, and ODP-ZZ-00002, Appendix 2, Risk Management Actions for Planned Risk Significant Activities, Revision 13.

Description:

On February 20, 2018, the licensee was contacted by Ameren corporate regarding an issue with one of Callaways offsite power lines, Callaway-Bland-1. Ameren identified a likely failure of the trip tone transmitter, a programmable logic controller that communicates grid information between substations. The trip tone transmitter protects downline equipment during a grid transient by tripping the breaker prior to the transient reaching the breaker.

Condition Report 201800866 and Job 18000724 were written to document and correct this issue.

On February 27, 2018, the licensee commenced a scheduled technical specification equipment outage for the TDAFW pump. Risk management actions were briefed and established per Procedure ODP-ZZ-00002, Appendix 2, Risk Management Actions for Planned Risk Significant Activities, which included a requirement to NOT allow work in the switchyard that could cause a Loss of Offsite Power.

Later on February 27, 2018, the Ameren corporate relay team arrived on site to replace the Callaway-Bland-1 trip tone transmitter. This job required the relay team to access the switchyard and to replace the trip tone transmitter for Callaway-Bland-1 at switchyard breaker MDV44. This job was not listed on the weekly work schedule or incorporated into the sites overall risk management plan in the previous weeks. Callaways electrical maintenance team and the Ameren corporate relay team briefed operations on the job requirements, how the maintenance would be controlled, and the required switchyard entry. The brief also covered a precaution in the work package warning that work could result in a trip of the Callaway-Bland-1 line. While the precaution was covered during the brief, the maintenance team discussed that a loss of offsite power was unlikely, the precaution was automatically entered into the work package based on location, and the precaution was not because of an actual risk.

The inspectors reviewed the licensees assessment and management of risk.

Procedure APA-ZZ-00322, Appendix F, Section 4.4.9, MD system (switchyard circuit breaker)work was required to be evaluated at a minimum as Medium Risk in Nuclear Safety/Operational Risk . . . because of the potential consequence to nuclear safety.

Operations, however, updated the job risk to low, authorized vehicles in the switchyard, and gave permission for the work to proceed. Operations did not correctly re-perform the TDAFW pump risk assessment based on the new in-plant conditions as required by Procedure APA-ZZ-00322, Appendix F, Section 4.1.4.

Corrective Action: Since the switchyard work was complete when the issue was identified, the licensee initiated a condition report and calculated the increase in risk incurred as a result of this issue. The incremental core damage probability deficit (ICDPD) was found to be 3E-8 using the licensees safety monitor software.

Corrective Action Reference: Condition Report 201800866

Performance Assessment:

Performance Deficiency: Failure to adequately assess and manage risk associated with switchyard work during a risk-significant TDAFW pump maintenance period was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it adversely affected the protection against external factors attribute of the Initiating Event Cornerstone to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, Procedure ODP-ZZ-00002, Appendix 2, Risk Management Actions for Planned Risk Significant Activities, included a requirement to NOT allow work in the switchyard that could cause a Loss of Offsite Power.

Significance: Because the finding affects the licensees assessment of risk associated with performing maintenance activities, NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, dated June 19, 2012, directs significance determination via the use of NRC Inspection Manual Chapter 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, dated May 19, 2005. The inspectors used Inspection Manual Chapter 0609, Appendix K, to determine that the performance deficiency was of very low safety significance (Green). Specifically, the finding was not related to risk management actions only since the licensee failed to adequately assess risk. Since the finding involved approximately four hours of switchyard work with TDAFW pump out of service, the finding had a risk deficit of 3E-8 (<1E-6 ICDPD)determined from the licensees safety monitor software.

Cross-cutting Aspect: The finding had a cross-cutting aspect in the area of human performance associated with avoid complacency because the licensee failed to ensure individuals recognize and plan for the possibility of mistakes and ensure individuals implement the appropriate error reduction tools [H.12]. Specifically, the team assumed the switchyard work would be successful in the planning and briefing of the job. Although a vehicle was authorized in the switchyard and the work occurred in the relay room where offsite power can be tripped, the team decided that a loss of offsite power was unlikely and did not recognize the possibility of mistakes that could lead to inadvertent tripping of offsite power.

Enforcement:

Violation: Title 10 CFR 50.65(a)(4) states, in part, Before performing maintenance activities (including, but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from proposed maintenance activities. The licensee established procedures APA-ZZ-00322, Appendix F, Online Work Integrated Risk Management, Revision 16, and ODP-ZZ-00002, Appendix 2, Risk Management Actions for Planned Risk Significant Activities, Revision 13, in part, to meet this requirement.

Contrary to the above, on February 27, 2018, the licensee failed to adequately assess and manage the associated increase in risk from the switchyard work during risk significant TDAFW pump maintenance. Specifically, Procedure ODP-ZZ-00002, Appendix 2, Risk Management Actions for Planned Risk Significant Activities, included a requirement to NOT allow work in the switchyard that could cause a Loss of Offsite Power. The licensee failed to correctly update the original TDAFW pump risk assessment based on the new plant configuration with switchyard work in progress. As a result, the licensee incorrectly updated the job risk to low, authorized vehicles in the switchyard, and allowed work in the switchyard that could have resulted in a trip of the Callaway-Bland-1 line.

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

Failure to Establish Maintenance Procedures for Doors that Provide Safety-Related Functions Cornerstone Significance Cross-cutting Report Aspect Section Barrier Green H.4 71111.12 Integrity NCV 05000483/2018002-02 Teamwork Maintenance Closed Effectiveness The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a, Procedures, for the licensees failure to establish, implement, and maintain procedures associated with door maintenance. Specifically, the licensee failed to establish, implement, and maintain maintenance procedures for doors that provide safety-related functions such as ventilation pressure boundaries. As a result, 15 safety-related doors were identified that either had degraded conditions or that did not have a periodic maintenance task to inspect the doors.

Description:

On March 7, 2018, the inspectors toured the Auxiliary Building 2047 elevation and identified a degraded door seal on door DSK15121, associated with control room air conditioning units.

The inspectors shared their observations with the licensee and Condition Report 201801220 was written to document and correct this issue. The inspectors noted that some doors in this area of the plant interface with the control room ventilation boundary and serve a safety-related barrier function for ventilation to the control room during postulated accidents.

The inspectors reviewed licensee Procedure MPM-SK-QW001, Service and Inspection of Plant Doors, Revision 0, and challenged the licensee on preventative maintenance inspections for safety-related and non-safety doors.

As a result, the licensee performed an extent of condition review for door degradations. The inspectors, in parallel and independently of the licensee, performed a review of preventative maintenance on doors that provide safety-related functions. These reviews revealed 33 safety-related and non-safety related doors had degraded conditions or that did not have a periodic maintenance task to inspect the doors. Note that the degraded conditions included deficiencies that were not previously identified prior to this extent of condition review. The degraded conditions varied from missing seals, gaps due to door deformation, loose hardware, and other low level issues across several safety-related areas of the plant. These areas included the auxiliary building, the control building, and the fuel building. Of those 33 doors, 15 were safety-related with the remainder predominantly serving as fire barriers.

The summary of these issues are included in the table below.

Door DSKnnnnn Degraded No periodic CR Numbers

[S] safety- condition maintenance 20180nnnn related 11021 [S] X 1394 11194 [S] X 1364 11195 [S] X X 1394, 1773 11273 [S] X 1394 13011 [S] X 1773 13012 [S] X X 1394, 1773 13291 [S] X 1394 14031 X 1591 14052 X 1591 14081 [S] X 1364 14091 X 1591 14102 X 1591 14133 X 1358 15012 X 1591, 1219 15031 X 1363 15041 [S] X 1394 15071 [S] X 1364 15121 X 1220, 1315, 1581 15131 X 1329, 1581 21011 [S] X 1394 31041 [S] X 1394 32013 [S] X 1773 32242 X X 1394, 1773 33011 X 1591 33023 X 1591 33044 [S] X 1394 34041 X 1591 36161 X 1331 36092 X 1331 41011 [S] X 1394 61011 X X 1364, 1773 61021 X 1364 61022 X 1773 Further, the licensee initiated Condition Report 201801513, to document design discrepancies in the definition of air tight across various plant doors.

In each safety-related case, the licensee entered the issue into the corrective action program and was able to demonstrate operability of the associated structures, systems, and components.

The inspectors concluded the licensee failed to establish, implement, and maintain maintenance procedures for doors that provide safety-related functions such as ventilation pressure boundaries. Further, the inspectors determined the issue was programmatic across several safety-related areas of the plant and functions performed by the doors.

As an example of the failure to maintain door maintenance procedures, step 2 of Procedure MPM-SK-QW001, Addendum 5, Service and Inspection of Pressure Doors, Revision 0, states, the procedure applies to doors listed in Attachment 1 of this procedure.

Safety-related door DSK11195 is listed in Attachment 1 but the requirement to perform preventative maintenance was not translated to a recurring job. As a result, there was no preventative maintenance task assigned to inspect the door; although, the program required it. This issue was captured under Condition Report 201801773. When the lack of preventative maintenance was identified, the licensee inspected the door and found material deficiencies. This issue was captured under Condition Report 201801394. This is one example of the issues summarized in the table above.

The inspectors noted that the procedural guidance for maintenance technicians working on doors did not match up to engineerings threshold for identifying issues that could be adverse.

For example, Section 5.1 of Addendum 5 of Procedure MPM-SK-QW001 allows maintenance technicians to perform minor maintenance to correct deficiencies found and only requires a condition report be written if a condition is identified which affects the capability of the door to function as designed. Further, a sampling of jobs to perform safety-related door maintenance, such as Job 17513036, have a generic note stating, minor door seal damage is acceptable. Conversely, engineering tracks openings in ventilation pressure boundaries to the units of 0.1 inches squared under equipment out of service logs (EOSLs) such as EOSL 16429. This EOSL is a living document that aggregates known deficiencies in ventilation pressure boundaries in order to preserve the calculated margin of design basis heating, ventilation, and air conditioning (HVAC) systems. The inspectors determined there was inadequate communication across engineering and maintenance in order to preserve design assumptions for safety-related HVAC.

Corrective Actions: The licensee performed a walk-down of safety-related and non-safety doors, a review of safety-related door maintenance procedures, and entered issues into the corrective action program.

Corrective Action Reference: Condition Report 201803204

Performance Assessment:

Performance Deficiency: The failure to establish, implement, and maintain maintenance procedures for doors that provide safety-related functions such as ventilation pressure boundaries was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor, and therefore a finding, because it adversely affected the structure, system, and component, and the barrier performance attribute of the Barrier Integrity Cornerstone objective of providing reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. Specifically, the licensee identified 15 safety-related doors that either had deficiencies that were not previously identified during inspections or that did not have a periodic preventative maintenance task to inspect the doors. Further, the inspectors determined the issue was programmatic across several safety-related areas of the plant and functions performed by the doors.

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 3, Mitigating Systems Screening Questions, dated June 19, 2012, the inspectors determined that the finding was of very low safety significance (Green) because the finding only represented a degradation of the radiological barrier function provided for the control room, or auxiliary building, or spent fuel pool.

Cross-cutting Aspect: The finding had a cross-cutting aspect in the area of human performance associated with teamwork because the licensee failed to ensure individuals and work groups communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained [H.4].

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 9.a of Appendix A to Regulatory Guide 1.33, Revision 2, requires maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.

The licensee established Procedure MPM-SK-QW001, Service and Inspection of Plant Doors, Revision 0, and associated addendums, in part, to meet the regulatory requirement.

Step 2 of Procedure MPM-SK-QW001, Addendum 5, Service and Inspection of Pressure Doors, Revision 0, states the procedure applies to doors listed in Attachment 1 of this procedure.

Contrary to the above, prior to March 7, 2018, the licensee failed to apply the procedure to doors listed in Attachment 1 of Procedure MPM-SK-QW001, Addendum 5. As a result, the licensee failed to establish, implement, and maintain procedures for preventative maintenance that can affect the performance of safety-related pressure doors. Consequently, 15 safety-related doors were identified that either had degraded conditions or that did not have a periodic maintenance task to inspect the doors.

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

Failure to Critique an Inaccurate Emergency Classification During a Simulator Training Scenario Cornerstone Significance Cross-cutting Report Section Aspect Emergency Green P.6 71114.05 Preparedness NCV 05000483/2018002-03 Self- Maintenance of Closed Assessment Emergency Preparedness The inspectors identified a non-cited violation of 10 CFR 50.47(b)(14) for the licensees failure to critique an inaccurate emergency classification made during licensed operator training.

Description:

The inspectors reviewed records from a licensed operator training session conducted in the control room simulator on May 31, 2017. The inspectors determined that the scenario was designed to provide conditions leading to emergency action level SA9.1, hazards affecting a safety system. The records indicated that the shift manager incorrectly declared emergency action level FA1.1, loss of one fission product barrier, based on a belief that a reactor coolant system leak was in progress. When the shift manager informed the operations crew of the declaration, the crew informed the shift manager that the leak was not from the reactor coolant system. The shift manager reassessed conditions and subsequently declared emergency action level SA9.1. The correct classification was made within 15 minutes of conditions occurring which required classification and notifications made to offsite authorities.

The licensee evaluated the shift managers performance as accurate and reported the associated drill and exercise performance indicator opportunity to the NRC as a success.

The inspectors determined that the shift managers performance was not accurate and the declaration of emergency action level FA1.1 should have been determined to be a performance weakness in accordance with Emergency Preparedness Frequently Asked Question 13-07, dated April 1, 2014. The frequently asked question states that the initial declaration at an emergency classification level is to be evaluated for accuracy and that a subsequent correction does not negate an inaccurate initial declaration.

Corrective Actions: The licensee plans to correct the performance indicator submission to the NRC for Second Quarter 2017 and perform a human performance analysis for shift managers and emergency operations facility emergency coordinators.

Corrective Action Reference: Condition Report 201802099

Performance Assessment:

Performance Deficiency: The failure to critique an inaccurate emergency classification made during licensed operator training was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it adversely affected the Emergency Preparedness Cornerstone attribute of the emergency response organizations performance. The licensee may not be capable of taking adequate measures to protect the health and safety of the public if they do not maintain the emergency response organizations ability to recognize emergency classifications.

Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, dated September 22, 2015. The finding was determined to be of very low safety significance (Green) because it was a failure to comply with NRC requirements, was not a lost or degraded risk-significant planning standard function, and was not a loss of planning standard function. The finding was not a loss of planning standard function because the failure to critique occurred in a drill with limited evaluation.

Cross-cutting Aspect: The licensee failed to routinely conduct self-critical and objective assessments of its practices. Specifically, evaluators for a licensed operator training session were not self-critical about the classification of emergency events. The evaluators failed to recognize that the initial declaration of an emergency classification was required to be evaluated and that subsequent correction of an inaccurate declaration did not create a successful performance indicator opportunity [P.6].

Enforcement:

Violation: Title 10 CFR 50.47(b)(14) requires, in part, that deficiencies identified as a result of drills or exercises will be corrected.

Contrary to the above, on May 31, 2017, the licensee failed to correct a deficiency occurring in a drill. Specifically, the licensee failed to identify the declaration of an emergency classification as inaccurate and subsequently failed to correct the inaccurate performance.

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

Failure of an Analysis of the Impact of Changes to Emergency Action Levels to Demonstrate the Changes did not Reduce the Effectiveness of the Emergency Plan Cornerstone Significance Cross-cutting Report Section Aspect Emergency Green H.14 71114.05 Preparedness NCV 05000483/2018002-04 Conservative Maintenance Closed Bias of Emergency Preparedness The inspectors identified a non-cited violation of 10 CFR 50.54(q)(3), for the failure of an analysis of the impact of changes to licensee emergency action levels to demonstrate that the changes did not reduce the effectiveness of the emergency plan.

Description:

The inspectors reviewed analysis in 5054Q Assessment 2017027 for the impacts of a change to the emergency plan Procedure EIP-ZZ-00101, Addendum 2, Emergency Action Level Technical Bases Document, Revision 13, dated December 12, 2017. The licensee implemented the emergency action level changes on March 29, 2018. The inspectors noted that, in part, the emergency action level changes included a revised threshold for radiation monitors GT-RE-59 and GT-RE-60 in the fission product barrier initiating conditions.

The analysis of the change identified that the licensee used NUREG-1940, RASCAL 4:

Description of Models and Methods, dated December 2012 as the basis for the calculations which determined the revised radiation monitor thresholds. The analysis also identified that previous calculations for these radiation monitors were based on the licensees Final Safety Analysis Report (FSAR). The licensees stated basis for using NUREG-1940 was that it provided a source term that was more averaged over a spectrum of accidents and core conditions than a source term derived from the FSAR.

The inspectors discussed Assessment 2017027 with the licensee. The licensee stated that NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 6, dated November 2012 did not specify how to develop the source term(s) used to calculate radiological emergency action levels. Also, the use of NUREG-1940 to develop the radiological source term did not need to be justified because it was an NRC authored document. In addition, the licensee believes that the use of NUREG-1940 was acceptable to the NRC because other licensees had used NUREG-1940 to develop emergency action levels and those emergency action levels were approved as license amendments.

The inspectors reviewed a comparison of the assumed concentration of 15 isotopes listed in the FSAR to the assumed concentration of the same isotopes in the source term derived from NUREG-1940 and identified minor differences not likely to result in significant inaccuracies in the calculated radiation monitor thresholds. However, the source term used by the licensee also included radioactive isotopes not present in the FSAR, in the form of radioactive particulates. The licensees analysis did not address the effect of including these additional isotopes in calculations.

The inspectors concluded that the licensee could not adopt radiological source terms derived from NUREG-1940 without justifying why the derived radiological source term resulted in a more accurate calculation of emergency action levels than calculations derived from the source term specified in the FSAR. Further, the inspectors did not identify a valid justification for the use of NUREG-1940 in the regulatory analysis, dated December 12, 2017. As a result, the licensee failed to demonstrate the proposed change would not be a decrease in effectiveness.

Corrective Actions: The issue is not an immediate safety concern because the revisions to radiation monitor thresholds in the emergency action levels do not differ significantly from what the thresholds would have been had the FSAR source term been used as the basis for the calculation. The licensee will evaluate appropriate corrective actions in Condition Report 201802128.

Corrective Action Reference: Condition Report 201802128

Performance Assessment:

Performance Deficiency: The failure of the licensees 5054Q Assessment 2017027 to demonstrate the proposed emergency plan change did not reduce the effectiveness of the emergency plan was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it adversely affected the Emergency Preparedness Cornerstone attribute of procedure quality (emergency action level changes, plan changes). A licensee may not be capable of implementing adequate measures to protect the health and safety of the public if the licensee fails to demonstrate that changes made to its emergency plan and emergency action levels do not reduce the effectiveness of the emergency plan.

Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, dated September 22, 2015. The finding was determined to be of very low safety significance (Green) because it was a failure to comply with NRC requirements not associated with the emergency preparedness planning standards.

Cross-cutting Aspect: The licensee failed to demonstrate a conservative bias in making the choice of radiological source terms to use as the basis for calculating emergency action level thresholds. Specifically, the licensee did not demonstrate that use of a radiological source term deviating from its approved site FSAR provided a more accurate calculational basis before performing the calculation [H.14].

Enforcement:

Violation: Title 10 CFR 50.54(q)(3) requires, in part, that a licensee make changes to its emergency plan without NRC approval only if the licensee performs an analysis demonstrating that changes do not reduce the effectiveness of the plan.

Contrary to the above, on December 12, 2017, the licensee made changes to its emergency plan without NRC approval, but failed to perform an analysis demonstrating the changes did not reduce the effectiveness of the plan. Specifically, the licensees analysis of changes to Procedure EIP-ZZ-00101, Addendum 2, Emergency Action Level Technical Bases Document, Revision 13, did not demonstrate that use of a radiological source term derived from NUREG-1940 resulted in a more accurate calculation of emergency action level thresholds than would a calculation based on the approved site FSAR.

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

Observation 71152Problem Identification and Resolution The inspectors reviewed the licensees corrective action program, performance indicators, system health reports, and other documentation to identify trends that might be indicative of a more significant safety issue for the emergency diesel generators.

The inspectors reviewed adverse issues for the safety-related emergency diesel generators (EDGs) identified between July 1, 2017, and June 30, 2018. During this period, 181 EDG condition reports were generated. Of these, 129 condition reports were related to program concerns, such as knowledge transfer, benchmarking, industry operating experience, Part 21 evaluations, review of industry inspection findings, procedural enhancements, reportability, and documentation of other items, such as chemistry results.

The inspectors focused on the remaining 52 condition reports that documented adverse material conditions and planning/scheduling issues. As one example of the adverse material condition reports, the inspectors reviewed 10 condition reports related to the crack discovery on the train B EDG #6 main saddle bearing identified in the fall 2017 refueling outage:

• Condition Report 201706169 identified excessive bearing clearance with the train B EDG #6 main saddle bearing and evaluated reportability

• Condition Report 201706217 generated to track degraded and non-conforming conditions identified during Refueling Outage 22

• Condition Report 201706244 documented the crack discovery on the train B EDG #6 main saddle bearing

• Condition Report 201706386 documented damage to the train B EDG from rigging gear during the bearing saddle replacement

• Condition Report 201706399 identified loose fasteners as a possible contributing factor to the cracked saddle bearing

• Condition Report 201706768 documented a water leak during the hydrostatic test following the train B main saddle bearing replacement

• Condition Report 201706884 identified maintenance trends on the train B EDG during Refueling Outage 22

• Condition Report 201706935 documented liquid dye penetrant testing on EDG bearings

• Condition Report 201707356 identified EDG indications for input to the operational decision making process

• Condition Report 201800907 documented Fairbanks-Morse evaluation of the cracked main saddle bearing Similarly, the inspectors reviewed the remaining adverse material condition reports which covered a wide range of issues such as jacket water leakage, fuel oil leakage, fuel injector damage, degraded gaskets/o-rings, engine balancing, and foreign material exclusion in support systems.

In the work planning category, the licensee documented two issues with scheduling maintenance and one for work not ready to commence.

The inspectors verified that all issues were addressed within the scope of the corrective action program and that the completed and planned actions were appropriate to correct the identified causes. The inspectors noted that several of the adverse conditions identified were legacy issues or problems that the licensee corrected in order to restore the system. The inspectors did not identify any trends or concerns that might be indicative of a more significant safety issue for the EDGs.

Minor Violation 71153Follow-up of Events and Notices of Enforcement Discretion Minor Violation: Contrary to Technical Specification 3.6.3, Containment Isolation Valves, the licensee failed to maintain each containment isolation valve operable or enter applicable conditions and required actions for an inoperable containment isolation valve in Modes 1, 2, 3, and 4.

Specifically, the licensee failed to shut the reactor building service air header supply outer containment isolation valve KAV0118 after the fall 2017 refueling outage. As a result, isolation valve KAV0118 was left open from November 25, 2017, through January 11, 2018, which rendered the valves containment isolation function inoperable. The as-found testing demonstrated that the overall containment isolation function, for that penetration, was met with inner containment isolation valve KAV0039 in the normally shut position. Additional information can be found in Licensee Event Report 05000483/2018-001-00, Violation of Technical Specification 3.6.3, Containment Isolation Manual Valve Found in Open Position (ADAMS Accession Number ML18071A208).

The licensees failure to comply with Technical Specification 3.6.3, Containment Isolation Valves, and maintain each containment isolation valve operable or enter applicable conditions and required actions for an inoperable containment isolation valve in Modes 1, 2, 3, and 4 was a performance deficiency.

Screening: The inspectors determined the performance deficiency was minor because it was not a precursor to a significant event, did not have the potential to lead to a more significant safety concern, did not relate to a performance indicator that would have exceeded a threshold and did not adversely impact any of the cornerstone objectives. Specifically, the as-found local leak rate testing demonstrated that containment isolation function was met with inner containment isolation valve KAV0039 in the normally shut position.

Enforcement:

The failure to comply with Technical Specification 3.6.3, Containment Isolation Valves, and maintain each containment isolation valve operable or enter applicable conditions and required actions for an inoperable containment isolation valve in Modes 1, 2, 3, and 4 constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

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

On April 27, 2018, the inspector presented the onsite emergency preparedness inspection results to Mr. T. Herrmann, Site Vice President, and other members of the licensee staff On May 24, 2018, the inspectors presented the occupational radiation protection inspection results to Mr. B. Cox, Senior Director of Nuclear Operations, and other members of the licensee staff.

On July 10, 2018, the inspectors presented the integrated quarterly resident inspection results to Mr. M. McLachlan, Senior Director, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Procedure 71111.01: Adverse Weather Protection

Procedures

Number Title Revision

APA-ZZ-00322, Work Control Center Organization and Operation 30

Appendix D

AUE-SWP-000001 Electrical Safe Work Practices Manual 3

OSP-NB-00001 Class 1E Electrical Source Verification 40

OTA-RK-00016, NB01 Bus Lockout 1

Add 18A

OTA-RK-00016, NB01 Bus Undervoltage 0

Addendum 18B

OTN-NB-0001A, NB01 Loss of Power Recovery 0

Addendum 5

OTO-NB-00001 Loss of Power to NB01 32

Condition Reports

201701792 201703756 201704460 201801310 201801801

201802663

Inspection Procedure 71111.04: Equipment Alignment

Procedures

Number Title Revision

OSP-AL-00001 Auxiliary Feedwater Flow Paths Valve Alignment 10

OSP-EM-P001B Safety Injection Train B Inservice Test 50

OTN-EF-00001 Essential Service Water System 75

OTN-EM-00001 Safety Injection System 38

OTN-NE-0001A Standby Diesel Generation System - Train A 51

OTN-NE-0001B Standby Diesel Generation System - Train B 54

Drawings

Number Title Revision

M-22EM01 High Pressure Coolant Injection Sheet 2 39

M-22EM02 High Pressure Coolant Injection Sheet 3 23

Condition Reports

201304555 201304556 201701643 201702416 201703110

201704176 201704872 201706589 201706812 201800063

201800516 201800747 201801015 201802184 201802218

201802593 201802598

Jobs

16512414 16512503 17500445 17002539

Miscellaneous

Number Title Revision

RFR 15822 Evaluation of Safety Injection Test Line Valves Effects on A

System

Inspection Procedure 71111.05AQ: Fire Protection Annual/Quarterly

Condition Reports

201801761 201801925 201801983 201802068 201802161

201802699 201802736

Miscellaneous

Number Title Revision

Callaway Plant NFPA 805 Transition Report

Fire Preplan Manual 39

Inspection Procedure 71111.11: Licensed Operator Requalification Program and

Licensed Operator Performance

Procedures

Number Title Revision

OTS-SF-00001 Control Rod Positioning 10

Condition Reports

201007073 201509093 201801808 201801994 201802028

Jobs

18504417

Miscellaneous

Number Title

18-3 Annual exam scenarios and JPMs: Week of May 28, 2018

Inspection Procedure 71111.12: Maintenance Effectiveness

Procedures

Number Title Revision

APA-ZZ-00322 Integrated Work Management Process Description 20

APA-ZZ-00322, Work Week Schedule and Execution 56

Appendix B

APA-ZZ-00322, Online Work Integrated Risk management 16

Appendix F

APA-ZZ-00750 Hazard Barrier Program 41

MPM-SK-QW001 Service and Inspection of Plant Doors 0

Drawings

Number Title Revision

8618-X-95564 Interconnection Diagram Yard Startup Posn V42 Volt 5

XFMR & 345KV Line Posn-V44

Condition Reports

201302050 201504242 201701364 201701738 201801120

201801329 201801394 201801773 201802057 201802749

Jobs

17501498

Miscellaneous

Number Title Revision

100073 IM JZ-72.6 Line Coupling Tuner 0

Inspection Procedure 71111.13: Maintenance Risk Assessment and Emergent Work

Control

Procedures

Number Title Revision

APA-ZZ-00322 Integrated Work Management Process Description 20

Procedures

Number Title Revision

APA-ZZ-00322, Online Work Integrated Risk Management 16

Appendix F

APA-ZZ-00801 Foreign Material Exclusion 45

ETP-CH-ST001 EHC System Flush 1

OTN-CH-00001 Main Turbine Control Oil System 20

Drawings

Number Title Revision

M-22CH01 Main Turbine Hydraulic Control System Sheet 11 9

Condition Reports

201605024 201801712 201801754 201802018 201802052

201802080 201802284

Jobs

15509648 15509653

Inspection Procedure 71111.15: Operability Determinations and Functionality

Assessments

Procedures

Number Title Revision

APA-ZZ-00500 Operability and Functionality Determinations 32

BD-ES-0.2 Natural Circulation Cooldown 6, 7

DIESLE-EMER-0022 KJ Engine Fuel Rack Adjustment 1

ES-0.2 Natural Circulation Cooldown 13

ES-0.2 Natural Circulation Cooldown 14

MSM-KJ-QK001 Emergency Diesel Generator Inspection 40

MTM-KJ-QK001 Emergency Diesel Engine Disassembly, Inspection, 9

and Reassembly

MTT-ZZ-00264 Removal and Replacement of ITT General Controls 24

Hydramotor Actuators

ODP-ZZ-00001 Operator Burdens and Workarounds 9

ODP-ZZ-00027 Safety Function Determination Program 18

Procedures

Number Title Revision

OSP-KA-V003 Nitrogen Accumulator Inservice Leak Rate Test 30

OTN-GK-00001 Control Building HVAC System 53

OTO-GK-00001 Loss of Control Room HVAC 14

Drawings

Number Title Revision

E-23KJ07 Diesel Generator KKJ01B Governor Control 4

M-622.1-00023 Condensing Unit 19

Condition Reports

200706594 200900842 200903033 201007822 201408077

201704701 201801302 201801822 201802284 201802296

201802938

Jobs

15004983 18001143

Miscellaneous

Number Title Revision

BB-175 Reactor Coolant System Cooldown Rate EOP Action 0

Value 4

BB-175, Maximum Cooldown Rate During a Natural Circulation 0

Addendum 1 Cooldown to Address Flow Stagnation Issues

KA-37 Backup Nitrogen Supply System Design Pressure Losses 0

M-018-00309 IM Emergency Diesel Generator System 138

M-622.1-00061, Vendor manual: SGK04/SGK05

Table 001

ZZ-179 Plant AC Bus Load List 9

98-1031 Modification: Controllers for SGK05A and B A

Inspection Procedure 71111.19: Post Maintenance Testing

Procedures

Number Title Revision

OTN-GK-00001 Control Building HVAC System 53

Condition Reports

201706582 201800921 201802463 201802854 201802895

201802071 201802090 201802093 201802114 201802123

Jobs

11506485 12500205 16510841 16511475 11513141

2002430 14508639

Miscellaneous

Number Title Revision

GK-19 Calculation of DC and Engineered Safety Features 0C

Switchgear Room Heatup

ULDBD-GK-001 Control Building HVAC System 1

Inspection Procedure 71111.22: Surveillance Testing

Procedures

Number Title Revision

ODP-ZZ-00029 RCS Leakage Action Level Guideline 7

OSP-BB-00009 RCS Inventory Balance 38

OSP-NE-0001A Standby Diesel Generator A Periodic Tests 64

OTO-BB-00003 RCS Excessive Leakage 25

RRA-ZZ-00001 NRC Performance Indicator Program 9

Condition Reports

201503444 201707272

71114.02: Alert and Notification System Testing

Condition Reports

201700320 201700758 201702367 201703790 201704390 201707404

201707681 201800242 201800372 201800854

Procedures

Number Title Revision

KSP-ZZ-00008 Tone Alert Radios 9

KSP-ZZ-00110 Siren Alerting System Testing 15

Miscellaneous

Number Title Date

Annual Siren Maintenance Records for 2016

Annual Siren Maintenance Records for 2017

Callaway Plant Alert and Notification System January 2017

Design Report

WO16501542 2017 Tone Alert Radio Provider Audit March 30, 2017

WO16502178 2017 Annual Tone Alert Radio Battery March 28, 2017

Distribution

WO17500804 Monthly Distribution of Tone Alert Radios February 27, 2017

WO17503441 2018 Tone Alert Radio Provider Audit February 12, 2018

WO17514077 Monthly Distribution of Tone Alert Radios January 26, 2018

71114.03: Emergency Response Organization Staffing and Augmentation System

Condition Reports

201609198 201700307 201700316 201703154 201704382

Miscellaneous

Number Title Revision/Date

EIP-ZZ-00200 Augmentation of the Emergency Response 21

Organization

KSP-ZZ-00201 Emergency Augmentation Drill, Test 10

WO16501826 ERO Augmentation Test for May 24, 2016 May 25, 2016

WO16506957 ERO Augmentation Test for September 8, September 8, 2016

2016

WO16510907 ERO Augmentation Test for December 5, 2016 December 6, 2016

WO16510907 ERO Augmentation Test for December 12, December 13,

2016 2016

WO16514135 ERO Augmentation Test for March 10, 2017 March 13, 2017

WO17502683 ERO Augmentation Test for June 13, 2017 June 15, 2017

WO17506126 ERO Augmentation Test for August 6, 2017 August 7, 2017

WO17508091 ERO Augmentation Test for December 11, December 12,

2017 2017

WO17513914 ERO Augmentation Test for February 19, 2018 February 20, 2018

71114.04: Emergency Action Level and Emergency Plan Changes

Condition Reports

201802128

Miscellaneous

Number Title Date

EPCI 17-01 Calculation: Emergency Action Level Bases November 22,

for Fuel Clad and Reactor Coolant System 2017

Barrier Loss, and Containment Barrier Potential

Loss, Revision 1

71114.05 - Maintenance of Emergency Preparedness

Condition Reports

201700110 201700307 201700316 201700777 201700937 201701166

201701250 201701281 201701426 201702193 201702223 201702225

201702280 201702286 201702289 201702299 201702327 201702736

201703430 201703570 201703778 201703986 201704138 201704382

201705732 201802054 201802061 201802099 201802095 201802096

201802127 201802128

Work Orders

15505575 16501542 16502178 16506313

16508073 16510372 16510907 16511006

16512796 16513033 16513811 17501138

17503441 17503557 17507733

Miscellaneous

Number Title Revision/Date

Callaway Plant Radiological Emergency Response 50

Plan

Evaluation Report for the Radiation Monitoring Drill

conducted June 16, 2016

Evaluation Report for the Radiological Monitoring

Drill conducted September 1, 2016

Evaluation Report for the Health Physics Drill

conducted September 8, 2016

Evaluation Report for the Contaminated Victim Drill

conducted November 8, 2016

Evaluation Report for the Health Physics Drill

conducted March 7, 2017

Evaluation Report for Exercises conducted First March 28, 2017

Quarter 2017 (January 19, January 26, February 2,

February 9, February 16, February 23)

Evaluation Report for the Exercise conducted May 10, 2017

March 7, 2017

Evaluation Report for the Exercise conducted June 30, 2017

April 25, 2017

Evaluation Report for the Exercise conducted August 23, 2017

June 29, 2017

Evaluation Report for the Health Physics Drill

conducted August 2, 2017

Evaluation Report for the Contaminated Victim Drill

conducted August 31, 2017

Evaluation Report for Exercises conducted October 5, 2017

Third Quarter 2017 (July 20, July 27, August 3,

August 10, August 17, and August 24)

Evaluation Report for Exercises conducted April 10, 2018

First Quarter 2018 (January 18, January 25,

February 1, February 8, and February 15)

A210.0012 Operating Quality Assurance Manual 32A

ADCN 2-201702736 Performance Deficiencies with Emergency July 2017

(AUCA2017002) Classifications and Notifications

CR201704138 Common Cause Evaluation

CR201700937 Common Cause Analysis of Sentry Failures September 8, 2017

DTI-040 NOS Performance Assessments 9

EIP-ZZ-A0020 Maintaining Emergency Preparedness 31

EIP-ZZ-A0066 RERP Training Program 24

KDP-ZZ-00013 Emergency Response Facility and Equipment 15

Evaluation

KDP-ZZ-00013, Equipment Important to Emergency Response 5

Appendix 1 Matrix

KDP-ZZ-00400 RERP Impact Evaluations and Changes 25

KDP-ZZ-02001 Drill and Exercise Program 24

KSP-ZZ-00004 Emergency Response Facilities 4

KSP-ZZ-00007 Offsite Effectiveness of the Emergency 14

Preparedness Program

KSP-ZZ-00102 Monthly Emergency Communications Testing 14

KSP-ZZ-00103 Quarterly Emergency Communications Testing 5

KSP-ZZ-00602 Verification of Emergency Instruction Postings 4

OQC20170006 First Trimester 2017 Nuclear Oversight June 19, 2017

Performance Report

OQC20170013 Second Trimester 2017 Nuclear Oversight October 6, 2017

Performance Report

OQC20170017 Third Trimester Nuclear Oversight Performance January 31, 2018

Report

SBM-201720060-01 Benchmark Trip Report: Palo Verde JIC February 8, 2017

Operations

SBM-201820044-011 Benchmark Trip Report: Peer Evaluator for the April 4, 2018

Diablo Canyon QV Audit

SP17004 Emergency Preparedness 12-month Program October 24, 2017

Review

SSA-201600059-51 Simple Self-Assessment: Pre-NRC Program March 13, 2017

Inspection, IPX Exercise

SSA-201720039-009 Simple Self-Assessment: Implementation of

ACAD-15-010, Guidelines for the Training and

Qualification of Emergency Response Personnel

WO16506313 2017 Annual ETE Update April 19, 2017

2018 Annual ETE Update April 10, 2018

WO16510372 Annual Media Briefing Program August 9, 2017

WO16511006 2017 Annual Review of EALS with State August 28, 2017

WO16511251 Monthly Emergency Communications Testing March 1, 2017

WO16511926 Monthly Emergency Communications Testing November 3, 2016

WO16512796 Annual Radio Communications Test October 27, 2017

WO16513033 Monthly Source Checks December 2, 2017

WO16513082 Monthly Emergency Communications Testing November 10, 2016

(BURS Retest)

WO16513811 Monthly Process Radiation Monitor Source Checks December 28, 2016

WO16514038 Evaluation Report for the Radiological Monitoring

Drill conducted June 29, 2017

WO16514287 Monthly Emergency Communications Testing January 4 2017

WO17500337 Emergency Facility Readiness Inspection April 10, 2017

WO17501138 Callaway County Hospital Inventory/Inspection July 26, 2017

WO17503557 SGTR Monitor Source Checks May 1, 2017

WO17504722 Monthly Emergency Communications Testing June 7, 2017

WO17507733 Saint Marys Hospital Inventory/Inspection December 27, 2017

WO17509367 Monthly Emergency Communications Testing October 4, 2017

WO17513572 Monthly Emergency Communications Testing January 3, 2018

5054Q Assessment KSP-ZZ-00008, Revision 8 March 16, 2017

2017010

5054Q Assessment EIP-ZZ-PR020, Revision 40 May 19, 2017

2017016

5054Q Assessment KDP-ZZ-00013, Appendix 1, Revision 5 October 3, 2017

2017017

5054Q Assessment KDP-ZZ-02001, Revision 23 August 8, 2017

2017018

5054Q Assessment KDP-ZZ-02001, Revision 23 August 8, 2017

2017019

5054Q Assessment RERP Revision 49 August 23, 2017

2017024

5054Q Assessment ERO Duty Responders August 23, 2017

2017026

5054Q Assessment EIP-ZZ-00101, Addendum 2, Revision 13 November 28, 2017

2017027

5054Q Assessment EIP-ZZ-00101, Revision 54 September 26, 2017

2017036

5054Q Assessment EIP-ZZ-00101, Addendum 2, Revision 14 March 19, 2018

2017055

5054Q Assessment EIP-ZZ-00245, Addendum B, Revision 4 March 23, 2018

2017088

5054Q Assessment CR-201800454 February 7, 2018

2018010

5054Q Assessment EIP-ZZ-00101, Addendum 2, Revision 14 March 19, 2018

2018013

5054Q Assessment EIP-ZZ-00101, Addendum 2, Revision 14 March 19, 2018

2018014

5054Q Assessment EDP-ZZ-00005, Revision 14 March 21, 2018

2018015

Inspection Procedure 71114.06: Drill Evaluation

Procedures

Number Title Revision

EIP-ZZ-A0001 Emergency Response Organization 19

EIP-ZZ-A0066 Radiological Emergency Response Plan Training 24

EIP-ZZ-00101 Classifications of Emergencies 54

OTO-MA-00008 Rapid Load Reduction 36

OTG-ZZ-00004 Power Operations 97

OTO-ZZ-00012 Severe Weather 39

Condition Reports

200500736 200711355 201105132

Miscellaneous

Number Title Revision

NUREG-1022 Event Reporting Guidelines 10CFR50.72 and 50.73 3

71124.02: Occupational ALARA Planning and Controls

Procedures

Number Title Revision

APA-ZZ-00014 Conduct of Operations - Radiation Protection 23

APA-ZZ-00014 Appendix A - Radiation Protection Skill of the Craft 3

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

APA-ZZ-01001 Callaway Plant ALARA Program 26

APA-ZZ-01004 Radiological Work Standards 31

APA-ZZ-01004 Appendix D - General instruction for Use of DLR 3

APA-ZZ-01400 Performance Improvement Program Appendix H - 20

Performance Review Group

HDP-ZZ-01100 ALARA Planning and Review 23

HDP-ZZ-01200 Radiation Work Permits 33

Audits and Self-Assessments

Number Title Date

Radiation Protection Performance Review Group February 28, 2018

Meeting

Callaway Energy Center Refuel 22 Dose and Source January 10, 2018

Term Comparison Report

SP17006 Nuclear Oversight Performance Assessment of February 14, 2018

RF22

Condition Reports

201705692 201705803 201706722 201801083 201802051

201800459

Radiation Work Permits

Number Title Revision

18502032 Change SFP Clean-Up Filter 2018

17507741 Change SFP Clean-Up Filter 2017

16511578750 RF22 Scaffold All 1

R22RPCOVRB Refuel 22 Radiation Protection Job Coverage

R22HDLIPREP Refuel 22 Support Lower Core Barrel Movements 1

13004049 Replace Valve Packing in BGHV8160

13004049EM Emergent Work to Replace Solenoid and Testing 2

R221124AOV AOV Re-Work and Tests

R22AMHDLIFT Ameren Personnel Head Lift 1

R22AMHDSET Ameren Personnel Head Set

R22HDLIFT Perform Reactor Vessel Head Lift

R22AMHDPREP Ameren Personnel UI and Head Lift/Set Preps 1

ALARA Planning, In-Progress Reviews, and Post-Job Reviews

Number Title Date

R22-50101 Radiation Protection Routine Activities Reactor March 1, 2018

Building

R22-56321 Remove/Reinstall Reactor Vessel Lower Internals March 12, 2018

R22-55320 Reactor Building Head Lift March 12, 2018

R22 CRANEVLV Crane Valve Work March 12, 2018

WORK

R22-55220 Ameren Work in Cavity March 12, 2018

Miscellaneous

Callaway Energy Center Long Range Dose and Source Term Reduction Plan

Callaway Energy Center Long Range Dose and Source Term Reduction Plan Completed

Initiatives

71124.04 - Occupational Dose Assessment

Procedures

Number Title Revision

APA-ZZ-00014 Conduct of Operations - Radiation Protection 23

APA-ZZ-01000 Callaway Energy Center Radiation Protection 45

Program

APA-ZZ-01001 Callaway Plant ALARA Program 26

HDMZZ-01300 Callaway Internal Dose Assessment Guidelines 0

HDP-ZZ-01300 Internal Dosimetry Program 34

HDP-ZZ-04700 Count Room and Whole Body Counter Quality 22

Control Program

HDP-ZZ-08000 Respiratory Protection Program 23

HTP-ZZ-01302-DTI- Response to Positive In Vivo Count for Declared 6

DPW Pregnant Woman

HTP-ZZ-01433 Personnel Exposure Records 61

HTP-ZZ-04175-DTI- Thermo Scientific Model PM-12 Personal Monitor 9

PM12-OP Operation

HTP-ZZ-04564 APEX Suite Operations 16

RP-DTI-In Vitro In-Vitro Bioassay Sample Collection 3

Bioassay

RP-DTI-TRU Alpha Monitoring Facility Characterization 7

Assessment

Audit and Self-Assessments

Number Title Date

SP17006 Nuclear Oversight Performance Assessment of February 14, 2018

Refuel 22 Execution

AP17001 Nuclear Oversight Audit of Radiation Protection February 28, 2017

SR-2016-30 Exelon Supplier Audit: Landauer, Inc. August 26, 2016

Condition Reports

201700049 201700086 201700188 201700455 201700459

201700831 201700894 201702031 201702125 201702131

201702338 201702649 201702839 20173330 201703773

201703856 201707727 201800454 201800852 201801083

201801132

Calibration Records

Number Title Date

FS-5301-HP Canberra FastScan WBC System (at CPF) September 21,

2016

FS-5300-HP Canberra FastScan WBC system (at Annex September 22,

Building) 2016

PM-4053-HP ThermoFisher PM-12 July 5, 2017

PM-4046-HP ThermoFisher PM-12 September 2, 2017

WBC-6000-HP Canberra In Vivo Chair Counter July 14, 2017

FS-5300-HP Canberra FastScan WBC System Confirmation March 12, 2018

Count

PM-4047-HP ThermoFisher PM-12 April 11, 2018

Radiological Surveys

Number Title Date

CA-M-20180319-5 NS-1 Neutron Source - Quarterly Routine March 19, 2018

CA-M-20180507-12 1311 SJ Room Monthly Routine Survey May 7, 2018

Miscellaneous

Number Title Date

NVLAP Certificate of Accreditation: Landauer, Inc. January 1, 2018

DAW CYC 21 WMG Nuclide Distribution Report November 13,

2017

HPCI 0202-02 Callaway Electronic Dosimeter Calibration April 18, 2016

Adjustment Factor

H230.0078 Personnel Dosimetry Data: SMD/TLD Results January 3, 2018

January 1 - December 31, 2017

H230.0078 Personnel Dosimetry Data: SMD/TLD Results March 14, 2018

January 22 - March 5, 2018

Inspection Procedure 71151: Performance Indicator Verification

Procedures

Number Title Revision

EIP-ZZ-00101 Classification of Emergencies 54

EIP-ZZ-00201 Notifications 51

EIP-ZZ-00212 Protective Action Recommendations 30

KDP-ZZ-02000 NRC Performance Indicator Data Collection 18

KSP-ZZ-00110 Siren Alerting System Testing 15

Condition Reports

201700346 201702225 201702367 201702891 201703430

201703986 201704380 201707404 201707681 201800242

201800372

Miscellaneous

Number Title Date

NRC Performance Indicator Transmittal Reports, Mitigating 2017-2018

Systems Cornerstone

NRC Performance Indicator Transmittal Reports, Barrier 2017-2018

Integrity Cornerstone

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

Procedures

Number Title Revision

Date

APA-ZZ-00099 Plant Status Control Investigations

Appendix 2

OTG-ZZ-00001 Plant Heatup Cold Shutdown to Hot Standby 89

OTG-ZZ-00001 Plant Heatup Cold Shutdown to Hot Standby 90

OTG-ZZ-00006 Plant Cooldown Hot Standby to Cold Shutdown 79

OSP-GP-00001 Containment Isolation Verification 24

ODP-ZZ-00014 Operational Mode Change Requirements 53

ODP-ZZ-00036 Technical Specification Application for Containment Isolation 7

Valves

OSP-GT-00003 Containment Closure 21

Drawings

Number Title Revision

M-22KA02 Piping and Instrumentation Diagram Compressed Air 27

System (Service Air)

Condition Reports

201800194 201802608 201408376 201800202

Jobs

18000323

Miscellaneous

Number Title Revision

AUCA 2018-0001 Root Cause Analysis for CAR 201800194 KAV0118 Found 0

Open

Initial Request for Information

Quarterly Baseline Inspection

Callaway Plant

Inspection Report: 05000483/2018002

Inspection Dates: April 1 - June 30, 2018

Inspection Procedure: IP 71111 series, IP 71151, IP 71152

Lead Inspector: Dan Bradley, Senior Resident Inspector

Information Requested For 2nd Quarter 2018

The following information should be sent to the resident office in electronic format (Certrec IMS

preferred) to the attention of Dan Bradley by April 13, 2018. Please provide requested

documentation electronically in pdf files, Excel, or other searchable formats, if possible. The

information should contain descriptive names and be indexed or hyperlinked to facilitate ease of

use. If requested documents are large and/or only hard copy formats are available, please

inform the inspector for clarification.

Please provide the following information for the Auxiliary Feedwater (AL) system:

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

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

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

all open work orders.

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

selected system.

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

panel judgment, for the selected system.

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

selected system.

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

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

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

selected system. Include a list of any documents associated with modifications such as:

calculations, specifications, vendor manuals, Final Safety Analysis Report, Technical

Specifications and Bases updates, updated procedures, and maintenance and

surveillance activities and procedures.

10. A list of root cause and apparent cause evaluations associated with component failures

or design issues initiated/completed in the last 3 years for the selected system.

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

system.

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

13. An electronic copy of the system health notebooks for the selected system.

Additionally, please provide the basis documents used to compute or establish the following

NRC Performance Indicators (PIs) for the most recent 4 quarters which data is available:

a) MS-05: Safety System Functional Failures (SSFF)

b) MS-08: MSPI Heat Removal Systems

c) BI-02: Reactor Coolant System Leak Rate Sample

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

The following items are requested for the

Occupational Radiation Safety Inspection

at Callaway

(May 21 - 25, 2018)

Integrated Report 2018002

Inspection areas are listed in the attachments below.

Please provide the requested information on or before

April 30, 2018.

Please submit this information using the same lettering system as below. For example, all

contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled

1- A, applicable organization charts in file/folder 1- B, etc.

If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at

least 30 days later than the onsite inspection dates, so the inspectors will have access to the

information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed

below, please provide updated lists of corrective action documents at the entrance meeting.

The dates for these lists should range from the end dates of the original lists to the day of the

entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear

to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which

file the information can be found.

If you have any questions or comments, please contact Natasha Greene at (817) 200-1154 or

natasha.greene@nrc.gov. The other inspector is undetermined at this time.

PAPERWORK REDUCTION ACT STATEMENT

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget,

control number 3150-0011.

2. Occupational ALARA Planning and Controls (71124.02)

Date of Last Inspection: October 16, 2017

A. List of contacts and telephone numbers for ALARA program personnel

B. Applicable organization charts

C. Copies of audits, self-assessments, and LERs, written since date of last inspection,

focusing on ALARA

D. Procedure index for ALARA Program

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures may be requested by number after the inspector reviews

the procedure indexes.

1. ALARA Program

2. ALARA Committee

3. Radiation Work Permit Preparation

F. A summary list of corrective action documents (including corporate and sub-tiered

systems) written since date of last inspection, related to the ALARA program. In addition

to ALARA, the summary should also address Radiation Work Permit violations,

Electronic Dosimeter Alarms, and RWP Dose Estimates

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that

the inspector can perform word searches.

G. List of work activities greater than 1 rem, since date of last inspection,

Include original dose estimate and actual dose.

H. Site dose totals and 3-year rolling averages for the past 3 years (based on dose of

record)

I. Outline of source term reduction strategy

J. If available, provide a copy of the ALARA outage report for the most recently completed

outages for each unit

K. Please provide your most recent Annual ALARA Report.

4. Occupational Dose Assessment (Inspection Procedure 71124.04)

Date of Last Inspection: November 7, 2016

A. List of contacts and telephone numbers for the following areas:

1. Dose Assessment personnel

B. Applicable organization charts

C. Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs

written since date of last inspection, related to:

1. Occupational Dose Assessment

D. Procedure indexes for the following areas:

1. Occupational Dose Assessment

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures will be requested by number after the inspector reviews

the procedure indexes.

1. Radiation Protection Program

2. Radiation Protection Conduct of Operations

3. Personnel Dosimetry Program

4. Radiological Posting and Warning Devices

5. Air Sample Analysis

6. Performance of High Exposure Work

7. Declared Pregnant Worker

8. Bioassay Program

F. List of corrective action documents (including corporate and sub-tiered systems) written

since date of last inspection, associated with:

1. National Voluntary Laboratory Accreditation Program (NVLAP)

2. Dosimetry (TLD/OSL, etc.) problems

3. Electronic alarming dosimeters

4. Bioassays or internally deposited radionuclides or internal dose

5. Neutron dose

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that

the inspector can perform word searches.

G. List of positive whole body counts since date of last inspection, names redacted if

desired

H. Part 61 analyses/scaling factors

I. The most recent National Voluntary Laboratory Accreditation Program (NVLAP)

accreditation report or, if dosimetry is provided by a vendor, the vendors most recent

results

ML18221A398

SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: NTaylor 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 DSB SMJ TRF jfd vgg hjg

DATE 8/6/18 8/5/18 07/27/2018 7/26/18 7/26718 07/26/18

OFFICE TL:DRS/IPAT C:DRP/B

NAME GGeorge NTaylor

SIGNATURE HAF for NHT

DATE 07/31/18 8/8/18