IR 05000483/2020003

Integrated Inspection Report 05000483/2020003

ML20307A663
Person / Time
Site:	Callaway
Issue date:	11/02/2020
From:	O'Keefe N NRC/RGN-IV/DRP/RPB-B
To:	Diya F Ameren Missouri
References
IR 2020003
Download: ML20307A663 (21)

Text

November 2, 2020

SUBJECT:

CALLAWAY PLANT - INTEGRATED INSPECTION REPORT 05000483/2020003

Dear Mr. Diya:

On September 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Callaway Plant. On October 7, 2020, the NRC discussed the results of this inspection with Mr. B. Cox, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation documented in this inspection report, 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 Callaway Plant.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Cornelius Digitally signed by Cornelius F. O'Keefe F. O'Keefe Date: 2020.11.02 17:21:45 -06'00'

Neil F. O'Keefe, Chief Reactor Projects Branch B Division of Reactor Projects Docket No. 05000483 License No. NPF-30

Enclosure:

As stated

Inspection Report

Docket Number: 05000483 License Number: NPF-30 Report Number: 05000483/2020003 Enterprise Identifier: I-2020-003-0007 Licensee: Union Electric Company Facility: Callaway Plant Location: Steedman, MO Inspection Dates: July 1, 2020 to September 30, 2020 Inspectors: D. Bradley, Senior Resident Inspector S. Janicki, Resident Inspector R. Alexander, Senior Emergency Preparedness Inspector K. Clayton, Senior Operations Engineer Approved By: Neil F. O'Keefe, Chief Reactor Projects 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 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.

List of Findings and Violations

Failure to Implement Emergency Diesel Generator Surveillance Procedures Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71111.04 Systems NCV 05000483/2020003-01 Complacency Open/Closed The inspectors reviewed a self-revealed Green, non-cited violation of Technical Specification 5.4.1.a , Procedures, for the licensees failure to implement Procedure OSP-NE-0001B, Standby Diesel Generator B Periodic Tests. Specifically, the operator did not comply with the caution statement to raise generator load greater than 109 KW within three seconds to prevent actuating the reverse power relay and tripping emergency diesel generator output breaker NB0211. This resulted in emergency diesel generator B being inoperable for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while the licensee ruled out other causes through troubleshooting.

Additional Tracking Items

None.

PLANT STATUS

Callaway Plant began the inspection period at rated thermal power. The unit operated at or near rated thermal power through September 24, 2020. On September 24, 2020, the licensee began a coast-down of reactor power into the planned refueling outage. On September 27, 2020, the licensee experienced an automatic reactor trip due to a main generator trip. The unit remained shut down through the end of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week and during that time conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed onsite portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

71111.01 - Adverse Weather Protection

External Flooding Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment for safety-related structures, including roofs, are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding on August 20, 2020.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

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

(1) Emergency diesel generator output circuit breakers, including trip features, on July 24, 2020

(2) Motor-driven auxiliary feedwater system, train B, on August 25, 2020

(3) Rod control on September 7, 2020

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of train A of component cooling water on August 31, 2020.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Auxiliary building 1974' elevation, fire area A-1, on August 19, 2020

(2) Control building 2016' elevation including electrical equipment air conditioning room, switchboard and battery rooms, fire areas C-13 and C-15, on August 24, 2020

(3) Control building 2000' elevation including vital switchgear, fire area C-10, on September 12, 2020

(4) Spent fuel pool area, fire area FB-1, on September 14, 2020

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during the following drills:

• Unannounced fire drill in the lower cable spreading room, fire area C-21, on July 2, 2020

• Announced fire drill in the north electrical penetration room, fire area A-18, on July 20, 2020

71111.06 - Flood Protection Measures

Cable Degradation (IP Section 03) (1 Sample)

The inspectors evaluated cable submergence protection in:

(1) Essential service water cable vaults MH01A and MH01B, on July 1, 2020

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (1 Sample)

Annual Requalification Exam Results are reviewed.

(1) On July 28, 2020, the inspectors completed one sample by reviewing and evaluating the licensed operator examination failure rates for the requalification annual operating exam administered for the exam cycle. There were no failures on the annual examinations.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (2 Samples)

(1) The inspectors observed and evaluated licensed operator performance in the control room during planned work on the train B motor-driven auxiliary feedwater system on August 12, 2020.

(2) The inspectors observed and evaluated licensed operator performance in the control room during post-maintenance testing on the turbine-driven auxiliary feedwater pump and restoration of an intake pump on August 26, 2020.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated licensed control room operator training in the simulator on July 6, 2020.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Auxiliary feedwater system, including issues during valve closure tests and pneumatic controls, on August 4, 2020

(2) Emergency diesel generator system, including issues with the air start system and output circuit breaker, on September 25, 2020

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Planned elevated risk for maintenance on train B components including the control room air conditioner and containment coolers on July 29, 2020

(2) Planned elevated risk for maintenance on train A essential service water and emergency diesel generator on August 3, 2020

(3) Unplanned elevated risk for maintenance on the alternate emergency power supply system on August 7, 2020.

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Nuclear instrument surveillance testing results, Condition Report 202003415, on July 22, 2020

(2) Essential service water pump room supply fan damper failure to close, Condition Report 202003794, on August 6, 2020

(3) Control room emergency ventilation system opening, Condition Report 202003819, on August 25, 2020

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:

(1) Emergency exhaust system train A following planned maintenance on July 6, 2020

(2) Control room air conditioning system train B following planned maintenance on July 22, 2020

(3) Containment spray system train B following planned maintenance on July 27, 2020

(4) Emergency diesel generator train A following planned maintenance on August 4, 2020

(5) Motor-driven auxiliary feedwater train B following planned maintenance on August 11, 2020

(6) Turbine-driven auxiliary feedwater pump following planned maintenance on August 25, 2020

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Partial)

(1) The inspectors evaluated refueling outage RF24 activities from September 27-30, 2020 (Partial).

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Control room emergency ventilation system air filtration unit B on August 10, 2020

(2) Emergency exhaust system - fuel building ventilation isolation test on August 17, 2020

(3) Ultimate heat sink train B cooling tower fan performance testing on August 19, 2020

Inservice Testing (IP Section 03.01) (1 Sample)

(1) Essential service water train B inservice test, including flow balance, on August 25, 2020

71114.02 - Alert and Notification System Testing

Inspection Review (IP Section 02.01-02.04) (1 Sample)

(1) The inspectors evaluated the maintenance and testing of the alert and notification system between April 1, 2018, and June 30, 2020.

71114.03 - Emergency Response Organization Staffing and Augmentation System

Inspection Review (IP Section 02.01-02.02) (1 Sample)

(1) The inspectors evaluated the readiness of the Emergency Preparedness Organization between April 1, 2018, and June 30, 2020.

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes:

• Radiological Emergency Response Plan (RERP), Revision 52; issued on April 30, 2020 This evaluation does not constitute NRC approval.

71114.05 - Maintenance of Emergency Preparedness

Inspection Review (IP Section 02.01 - 02.11) (1 Sample)

(1) The inspectors evaluated the maintenance of the emergency preparedness program between April 1, 2018, and June 30, 2020.

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated the emergency response organization team 5 training drill on September 10, 2020.

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the emergency response organization team 4 training drill on September 15,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

EP01: Drill/Exercise Performance (IP Section 02.12) ===

(1) April 1, 2019, through March 31, 2020

EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)

(1) April 1, 2019, through March 31, 2020

EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample)

(1) April 1, 2019, through March 31, 2020

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) (1 Sample)

(1) July 1, 2019, through June 30, 2020 IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (1 Sample)

(1) July 1, 2019, through June 30, 2020

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (1 Sample)

(1) July 1, 2019, through June 30, 2020

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)

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

(1) Extent of condition inspection results for safety-related ventilation fan systems from Condition Report 202001783 on July 20, 2020

71153 - Follow-up of Events and Notices of Enforcement Discretion Event Follow-up (IP Section 03.01)

(1) The inspectors evaluated a security diesel generator issue, Condition Report 20200494, and licensees response on September 29, 2020.

Personnel Performance (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the reactor trip caused by a main generator breaker trip and licensees performance on September 27,

INSPECTION RESULTS

Failure to Implement Emergency Diesel Generator Surveillance Procedures Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71111.04 Systems NCV 05000483/2020003-01 Complacency Open/Closed The inspectors reviewed a self-revealed Green, non-cited violation of Technical Specification 5.4.1.a , Procedures, for the licensees failure to implement Procedure OSP-NE-0001B, Standby Diesel Generator B Periodic Tests. Specifically, the operator did not comply with the caution statement to raise generator load greater than 109 KW within three seconds to prevent actuating the reverse power relay and tripping the emergency diesel generator output breaker. This resulted in emergency diesel generator B being inoperable for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while the licensee ruled out other causes through troubleshooting.

Description:

On June 24, 2020, operations personnel were performing a startup of emergency diesel generator (EDG) B in accordance with Procedure OSP-NE-0001B, Standby Diesel Generator B Periodic Tests, Revision 67. After closing EDG B output circuit breaker NB0211, step 6.3.17 directed the operator to transfer load to the EDG greater than 0.2 MW. A caution statement prior to step 6.3.17 directed the operator to raise generator load greater than 109 KW within three seconds to prevent the EDG B reverse power relay from tripping the generator output breaker.

After closing the generator output breaker, the control room operator performed step 6.3.17 to raise EDG B loading. The first load adjustment failed to provide sufficient load requiring the operator to perform a second adjustment. During the second load adjustment, the generator output breaker tripped open on reverse power. The licensee declared EDG B inoperable and placed the EDG B hand switch in pull-to-lock.

Following the circuit breaker trip, the licensee conducted interviews and performed troubleshooting including a system walk-down of the diesel generator to identify the cause of the trip. The licensee determined the most probable cause of the trip was a legacy procedure issue regarding initial EDG loading given meter accuracy. The minimum required loading in the procedure, combined with the accuracy of the meter, places the generator loading near the 109 KW with little margin between the generator output and reverse power relay setpoints. To restore the EDG to operable, the licensee issued a night order to increase the initial loading of the EDG and re-performed the surveillance test successfully. The EDG was returned to operable 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the initial trip.

The licensee benchmarked other utilities and determined initial EDG loading of 0.7 to 1.0 MW are commonly used values at other nuclear stations. The inspectors determined this initial loading range was appreciably higher than Callaways original value. Although the low margin to a reverse power trip existed in the surveillance procedure and contributed to the trip, the inspectors did not find the procedure guidance to be the primary cause of the output breaker trip.

The inspectors assessment found that the most likely cause of the EDG output breaker trip was a human performance error where the operator failed to properly implement the EDG startup procedure contained in Procedure OSP-NE-0001B in a timely manner. The inspectors noted that the EDG start up procedure has been used successfully without challenging the reverse power trip setpoint on initial loading for over 10 years. Additionally, the operator performing the EDG startup was standing a proficiency watch and not a normal member of the on-shift crew. As a result, the operator challenged the setpoints for the reverse power trip by performing two small load adjustments after closing the generator output breaker rather than a single timely load increase large enough to clear the reverse power setpoint. Further, the inspectors determined that, although the licensee discussed the lack of proficiency during the EDG surveillance pre-job brief, the human performance and error reduction tools of peer checker and switch flagging were not adequate to prevent the event.

Corrective Actions: The licensee declared EDG B inoperable, performed troubleshooting to identify the cause of the output breaker trip, interviewed the operating crew, issued a night order to increase the initial EDG loading requirements, completed the EDG B surveillance test successfully, and generated a condition report.

Corrective Action References: Condition Report 202003091

Performance Assessment:

Performance Deficiency: The failure of licensed operators to adequately load the emergency diesel generator upon initial startup is a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the performance deficiency resulted in the EDG being declared inoperable for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> including being placed in pull-to-lock while troubleshooting was performed to identify the cause of the breaker tripping.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was determined to be of very low safety significance (Green) because it

(1) was not a design deficiency,

(2) did not represent a loss of system and/or function,

(3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time,

(4) did not represent a loss of the probabilistic risk assessment (PRA)function of two separate technical specification systems for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,

(5) did not represent a loss of a PRA system and/or function for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and

(6) did not result in the loss of a high safety-significant, nontechnical specification train.

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. The finding had a human performance cross-cutting aspect associated with avoiding complacency, in that the watch team did not implement appropriate error reductions tools (H.12). Specifically, while it was acknowledged at the pre-job brief that the operator performing the startup was not a normal member of the watch team and was standing a proficiency watch, additional error reduction measures were not used. As a result, the operators initial loading caused the EDG output breaker to trip on the reverse power relay.

Enforcement:

Violation: Technical Specification 5.4.1.a, Procedures, states in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.

Regulatory Guide 1.33, Revision 2, Appendix A, Section 3.s, requires procedures for startup, operation, and shutdown of safety-related pressurized water reactor systems, including emergency power sources such as diesel generators. The licensee established Procedure OSP-NE-0001B, in part, to meet this requirement. Procedure OSP-NE-0001B requires operators to raise EDG loading above 109 KW within three seconds of closing the EDG output breaker to prevent a reverse power trip.

Contrary to the above, on June 24, 2020, the licensee failed to implement required procedures for startup, operation, and shutdown of safety-related PWR systems for emergency power sources such as diesel generators. Specifically, the licensee failed to raise EDG loading above 109 KW within three seconds of closing the EDG output breaker. As a result, EDG B loading was inadequate and EDG output breaker tripped on reverse power.

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

EXIT MEETINGS AND DEBRIEFS

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

• On August 4, 2020, the inspectors presented the emergency preparedness program inspection results to Mr. B. Cox, Site Vice President, and other members of the licensee staff.

• On September 24, 2020, the inspectors presented the annual operator requalification results to Mr. P. Swan, Operations Supervisor, and other members of the licensee staff.

• On October 7, 2020, the inspectors presented the integrated inspection results to Mr. B. Cox, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Corrective Action Condition Reports 201706767, 201701110, 201806495, 201901917,

Documents 202002834

Miscellaneous A-2327 Control Building and Communications Corridor Floor Plan @ 8

Elevation 2073'6" and Roof Plan @ Elevation 2087'2"

FSAR SP S 2.4 Hydrologic Engineering OL-13

M-07LF02 Plumbing and Drainage System 9

RFR 170332 Approve a Flat Diesel Building Roof Drain Cover 0

RMT-1.PMB Repetitive Maintenance Tasks 8

Procedures PMDI0825412 Clean Debris from Auxiliary Building Roof Drains 6

PMID0825413 Clean Debris from D/G Roof Drains 8

PMID25415 Clean Debris from RQ Roof Drains 7

PMID25416 Clean Debris from FB Roof Drains 7

71111.04 Corrective Action Condition Reports 199902065, 200001964, 20408637, 200602565,

Documents 200608195, 200908596, 201008319, 2012002567,

201208276, 2013003338, 201406950, 201502012,

201806495

Miscellaneous M-22EG02 Piping and Instrumentation Diagram - Component Cooling 26

Water System

M-763-00831 Full Length Rod Control System 13

MP 07-0010 Modify MCB Switches for ECHV0011, ECHV0012, 0.1

EGHV0101 and EGHV0102

Relay.BID Protective Relays 2

RFR 019265A Valves Locked/Surveilled per TS 4.7.4.A A

RFR 4794 Diesel Generator Breakers NB0111 and NB0211 A

Procedures CTP-EG-06080 Component Cooling Water System Chemical Addition 18

MSE-NB-QY003 Operational Test Sequence of 4.16 kV Diesel Generator 16

NE02 Air Circuit Breaker 152NB021

OSP-EG-0001A Component Cooling Water Train A Valve Alignment 7

Surveillance

OSP-EG-0001B Component Cooling Water Train B Valve Alignment 3

Surveillance

OSP-SF-00001 Shutdown Margin Calculations 47

Inspection Type Designation Description or Title Revision or

Procedure Date

OSP-SF-00002 Control Rod Partial Movement 28

OTO-SF-00001 Control Rod Malfunctions 23

71111.05 Corrective Action Condition Reports 201707147, 201804247, 20190305, 201904398, 202003512

Documents

Miscellaneous Fire Pre-Plan 40

NFPA 805 Performance-Based Standard for Fire Protection for Light 2001

Water Reactor Electric Generating Plants

Procedures APA-ZZ-00700 Fire Protection Program 26

APA-ZZ-00701 Control of Fire Permits 25

APA-ZZ-00750 Hazard Barrier Program 46

FPP-ZZ-00009 Fire Protection Training Program 35

71111.06 Corrective Action Condition Reports 202003131, 202003220

Documents

Work Orders 19510909, 19509056

71111.11Q Corrective Action Condition Reports 202003932

Documents

Miscellaneous T61.08108 Simulator Scenario 02/04/2020

Procedures OSP-AL-P0002 Turbine-Driven Auxiliary Feedwater Pump Inservice Test 81

OSP-AL-P001B Motor-Driven Auxiliary Feedwater Pump Inservice Test 66

ODP-ZZ-00001 Operations Department - Code of Conduct 107

Work Orders 19003560, 18502371

71111.12 Corrective Action Condition Reports 200308233, 201506272, 201703831, 201905886,

Documents 202002091, 202004225, 202004331

Miscellaneous NN-03 System Voltage Drop 3

RFR 20117 Offsite Source Verification B

RFR 6844 Diesel Generator Technical Specification Interpretation A

ULDBD-NE/KJ- Emergency Diesel Generators 3

001

Procedures OSP-NE-00001B Standby Diesel Generator B Periodic Tests 68

OSP-NE-00003 Technical Specification Actions - A.C. Sources 34

EDP-ZZ-01128 Maintenance Rule Program 29

EDP-ZZ-01128, Maintenance Rule System Functions 23

Appendix 4

Inspection Type Designation Description or Title Revision or

Procedure Date

OTG-ZZ-00005 Plant Shutdown 20% Power to Hot Standby 50

OSP-AL-V001A Train A Auxiliary Feedwater Valve Inservice Test 60

71111.13 Corrective Action Condition Reports 202002470, 202002696, 202003483, 202003375

Documents

Miscellaneous NUMARC 93-01 Industry Guideline for Monitoring the Effectiveness of 4A

Maintenance at Nuclear Power Plants

TSB 3.8.1 AC Sources - Operating 15

Procedures APA-ZZ-00312 Probabilistic Risk Assessment 11

APA-ZZ-00312, Online Work Integrated Risk Management 19

Appendix F

EDP-GK-0113 Heat Exchanger Predictive Performance Manual 24

PRA-ZZ-00001 PRA Model Updates and Maintenance 1

71111.15 Corrective Action Condition Reports 202001602, 202003794

Documents Condition Reports 201701745, 201804482, 202003819

Drawings M-U2GD-1 (Q) Piping and Instrumentation Diagram Essential Service Water 12

Pumphouse & Ultimate Heat Sink Elec. Rm. HVAC

Procedures APA-ZZ-00013 Conduct of Maintenance 38

PDP-ZZ-00017 Fix-it-Now Team Process 12/3/2019 15

Work Orders 16005679.900

71111.19 Corrective Action Condition Reports 202003334, 202003518, 202003531

Documents Condition Reports 201400345, 201407748, 201408914, 201701135,

201805449, 201905399, 202000047, 202004285

Miscellaneous A210.0083 Valve Retest Manual 59

Job 19003907

MR633276 Material Request - Charcoal

RFR 18621 IST TDAFP Speed Reference Acceptance Range B

Procedures APA-ZZ-00356 Pump and Valve Inservice Test Program 26

OSP-AL-P0002 Turbine Driven Auxiliary Feedwater Pump Inservice Test - 81

Group B

OSP-EN-P001B Train B Containment Spray Pump Inservice Test 52

OTN-GK-00001 Control Building HVAC System 61

Work Orders 19004892; 12502273; 20000658

71111.20 Corrective Action Condition Reports 202004895

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents

Procedures E-0 Reactor Trip or Safety Injection 27

ES-0.1 Reactor Trip Response 23

OTG-ZZ-00005 Plant Shutdown 20% Power to Hot Standby 50

71111.22 Procedures OSP-GG-00004 Emergency Exhaust System FBVIS Test 18

71114.02 Corrective Action Condition Reports 201803901, 201805003, 201806927, 201806954,

Documents 201905853, 201907255, 202001673, 202001710,

2001773, 202002446, 202002656

Miscellaneous Letter from FEMA Region VII, Approved January 2020 ANS 03/23/2020

Design Report

Siren Service Letter - Movement of Siren 53 and 05/27/2020

replacement of pole for Siren 51

K260.0010 Callaway Plant Alert and Notification System Design Report January

20

Procedures Vendor Document - Callaway Semi-Annual Preventative 12/2019

Maintenance & Repair Checklist (for Sirens)

KSP-ZZ-00008 Tone Alert Radios 9

KSP-ZZ-00110 Siren Alerting System Testing 16

KSP-ZZ-00602 Verification of Emergency Instruction Postings 6

71114.03 Corrective Action Condition Reports 201802480, 201803508, 201805536, 201805537,

Documents 201901089, 201907623, 202000729, 202003776

Miscellaneous SNUPPS RERP (Revision 5A), Section 8.2 02/1983

Licensing Impact Review (including RERP Evaluation Form) 01/22/1988

for RERP, Revision 11

Surveillance Augmentation Drill Report (touch the wall drill starting at 10/22/2018

18507225 0323 on 10/19/2018)

Surveillance Augmentation Drill Report (call-in drill starting at 0842 on 06/10/2019

19502304 06/08/2019)

Surveillance Augmentation Drill Report (call-in drill starting at 0954 on 05/11/2020

20502588 05/08/2020)

ULNRC-1732 Callaway Plant Radiological Emergency Response Plan, 02/26/1988

Revision 11

Procedures EIP-ZZ-00200 Augmentation of the Emergency Response Organization 21

KOA-ZZ-00200 Activation of the Callaway Plant Emergency Callout System 17

Inspection Type Designation Description or Title Revision or

Procedure Date

KSP-ZZ-00201 Emergency Augmentation Drill/Test 11

71114.04 Corrective Action Condition Reports 202003573

Documents

Resulting from

Inspection

Miscellaneous Radiological Emergency Response Plan (RERP) 52

EP Tracking No. 50.54(q) Screen - EIP-ZZ-00101 Add2, Revision 14 03/19/2018

2018011

EP Tracking No. 50.54(q) Evaluation - EIP-ZZ-01211, Accident Dose 02/26/2019

2018055 Assessment, Revision 38; URI Version 3.4 upgrade changes

EP Tracking No. 50.54(q) Screen - EIP-ZZ-A00001, ERO, Revision 21; 03/12/2020

20003 addition of POL0049 to Off-Normal Hours Definition

EP Tracking No. 50.54(q) Effectiveness Evaluation: CR 202001773, 04/13/2020

20006 Relocation of Emergency Siren 053 & Radiological

Emergency Response Plan (RERP), Revision 52

EP Tracking No. 50.54(q) Evaluation - Response time impact for JIC ERO 05/04/2020

20009 members (CR 202002249)

Procedures KDP-ZZ-00400 RERP Impact Evaluations and Changes 26

71114.05 Corrective Action Condition Reports 201802127, 201802748, 201803020, 201803725,

Documents 201803901, 201803903, 201803905, 201804072,

201804685, 201805481, 201904169, 201904375,

201905453, 201906349, 201906484, 201906661,

201906688, 201906718, 201906844, 201906852,

201906984, 201907878, 202000040, 202000869,

2002057, 202003581, 202003582

Miscellaneous Callaway Energy Center Muster Meeting Drill Report Third 07/30/2018

Quarter 2018

Contaminated Victim Drill Report 10/21/2019

Callaway Energy Center Annual ERO Drill (AED) Report 11/12/2019

AP18007 Nuclear Oversight Audit of Emergency Preparedness 09/06/2018

AP20007 Emergency Preparedness Audit (Plan) 06/17/2020

Job 17504120 2018 Population Update Analysis 04/10/2018

Job 17506751- Mini Scenario # 6 - Field Monitoring Team Report 05/24/2018

500

Inspection Type Designation Description or Title Revision or

Procedure Date

Job 17507545 2018 Letter of Agreement Information Surveillance: 09/10/2018

ST-12071

Job 18503865 2019 Population Update Analysis 03/25/2019

Job 18506769 Mini Scenario #8 Field Monitoring Team Drill Report 07/09/2019

Job 18509626 Mini-Scenario Team Drill 6/6/19 Health Physics Drill Report 06/10/2019

Job 18510002 2019 Letter of Agreement Information Surveillance: 07/16/2019

ST-12071

Job 19503524 2019 Population Update Analysis (Part 2) 05/22/2019

Job 19507106 2020 Population Update Analysis 05/26/2020

Job 19511162 2020 Health Physics Drill Report 06/23/2020

NES2019002 Notice of Closure Criteria to Escalation Letter OQC2019002 08/15/2019

(GTRE0032)

OQC20180010 Escalation of Emergency Action Level Classification 08/23/2018

Weaknesses

OQC2019002 Escalation of lack of a comprehensive plan to restore 03/27/2019

GTREOO32 to full compliance

OQC2019005 NOS Closure of Escalation on Emergency Action Level 04/01/2019

Classification Weaknesses

RERP, Appendix Evacuation Time Estimates (ETE) for the Callaway Nuclear 0 (June

G Plant Emergency Planning Zone 2012)

SP19006 12-Month Regulatory Required Review of the Emergency 06/25/2019

Preparedness Program in accordance with

CFR 50.54(t)(1)(ii)

Procedures EIP-ZZ-00212 Protective Action Recommendations 30

EIP-ZZ-A0020 Maintaining Emergency Preparedness 32

Self-Assessments 201900029-044 Exercise Readiness and Modified Program Inspection 03/26/2019

Work Orders Job 18003592 TSC Filter Absorber Unit Issue, TSC Non-Functional - Adjust 09/13/2018

Air Dampers

Job 19005574 Investigate ABRE0114 Lost Communication with RM-11 and 12/15/2019

RM-23

71114.06 Corrective Action Condition Reports

Documents

Miscellaneous Drill Guide - ERO Team - 9/10/20

Drill Guide - ERO Team - 9/15/20

Inspection Type Designation Description or Title Revision or

Procedure Date

71151 Miscellaneous Drill and Exercise Performance (DEP) PI Records (Annual 4Q/2019

ERO Drill Crew 3/Team 2, Crew 5/Controller Team, 19-05

LORT Crew 1), and related ERO Participation PI Records

Drill and Exercise Performance (DEP) PI Records (ERO 1Q/2020

Training Drill Team 5, Proficiency DEP 20-1 Crew 6), and

related ERO PI Participation Records

Drill and Exercise Performance (DEP) PI Records 2Q/2020

(Proficiency DEP 20-3 Crew 1 & Crew 5), and related ERO

PI Participation Records

Performance Indicator Basis Document Various

Alert & Notification System (ANS) PI - Weekly and Siren 3Q/2019,

Tests Results 4Q/2019,

1Q/2020, &

2Q/2020

Drill and Exercise Performance (DEP) PI Records (19-04 3Q/2019

LORT, 2019 WANO drill), and related ERO PI Participation

Records

Procedures KDP-ZZ-02000 NRC Performance Indicator (PI) Data Collection 18 & 19

71152 Corrective Action Condition Reports 202002097; 202003313; 202003346; 202003421;

Documents 202003567; 202003819; 202004179; 202004225;

2004243; 202004448; 202004496; 202004495

18