IR 05000483/2020010
| ML20167A310 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 06/12/2020 |
| From: | Ami Agrawal Division of Reactor Safety IV |
| To: | Diya F Ameren Missouri |
| References | |
| IR 2020010 | |
| Download: ML20167A310 (15) | |
Text
June 12, 2020
SUBJECT:
CALLAWAY PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000483/2020010
Dear Mr. Diya:
On May 7, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Callaway Plant and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, the team found no evidence of challenges to your organizations safety-conscious work environment.
Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
No findings or violations of more than minor significance were identified during this inspection.
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,
/RA/
Ami N. Agrawal, Team Lead Inspection Programs and Assessment Team Division of Reactor Safety Docket No. 05000483 License No. NPF-30
Enclosure:
As stated
Inspection Report
Docket Number: 05000483 License Number: NPF-30 Report Number: 05000483/2020010 Enterprise Identifier: I-2020-010-0002 Licensee: Union Electric Company Facility: Callaway Plant Location: Steedman, Missouri Inspection Dates: April 20 to May 7, 2020 Inspectors: R. Azua, Senior Reactor Inspector J. Braisted, Reactor Inspector P. Jayroe, Senior Reactor Inspector J. Melfi, Project Engineer Approved By: Ami N. Agrawal, Team Leader Inspection Programs and Assessment Team Division of Reactor Safety Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution 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.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
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 reviewed selected procedures and records 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), regional inspectors were directed to begin telework. The inspection documented below was determined that the objectives and requirements stated in the IP could be completed remotely.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
- Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the control rod drive mechanism.
- Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits, and self-assessments.
- Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Effectiveness of Problem Identification: Based on the samples reviewed, the team determined that the licensee's performance in this area adequately supported nuclear safety.
Overall, the team found that the licensee was identifying and documenting problems at an appropriately low threshold that supported nuclear safety. On average, the licensee was identifying and documenting approximately 562 condition reports (CRs) per month.
Effectiveness of Prioritization and Evaluation of Issues: Overall, the team found that the licensee was appropriately prioritizing and evaluating issues to support nuclear safety. Of the samples reviewed, the team found that the licensee correctly characterized each condition report as to whether it represented a condition adverse to quality, and then prioritized the evaluation and corrective actions in accordance with program guidance.
Effectiveness of Corrective Actions: Overall, the team concluded that the licensee's corrective actions supported nuclear safety. Specifically, the Callaway Plant developed effective corrective actions for the problems evaluated in the corrective action program and generally implemented these corrective actions in a timely manner commensurate with their safety significance.
- As part of this inspection, the team selected the control rod drive mechanism for a focused review within the corrective action program. For this system, the team performed sample selections of condition reports, looking at the adequacy of the licensee's evaluation process for determining which items are placed in the corrective actions process, and the corrective actions taken. The team also reviewed the licensee's use of operational experience and the Part 21 process with respect to this system. As a result of the off-site nature of this inspection, due to COVID-19 restrictions at the time of the inspection, the team was not able to walk down portions of this system. However, the team did not identify any concerns with this system.
Corrective Action Program Assessment: Based on the samples reviewed, the team determined the licensee's corrective action program complied with regulatory requirements and self-imposed standards, and the licensee's implementation of the corrective action program adequately supported nuclear safety. The team found that management's oversight of the corrective action program process was effective.
Assessment 71152B Operating Experience: The team reviewed a variety of sources of operating experience including Part 21 notifications and other vendor correspondence, NRC generic communications, and publications from various industry groups including Institute of Nuclear Power Operations (INPO) and Electric Power Research Institute (EPRI). The team determined that the Callaway Plant, is adequately screening and addressing issues identified through operational experience that apply to the station and that this information is evaluated in a timely manner once it is received.
Self-Assessments and Audit Assessments: The team reviewed a sample of the licensee's departmental self-assessments and audits to assess whether they regularly identified performance trends and effectively addressed them. The team also reviewed audit reports to assess the effectiveness of assessments in specific areas. Overall, the team concluded that the licensee had an adequate departmental self-assessment and audit process.
Assessment 71152B Safety-Conscious Work Environment: The team interviewed nine individuals. The purpose of these interviews was
- (1) to evaluate the willingness of the licensee staff to raise nuclear safety issues, either by initiating a CR or by another method,
- (2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems, and
- (3) to evaluate the licensee's safety-conscious work environment (SCWE). The focus group participants were from the security organization. Due to the challenges brought on by the COVID-19 pandemic, and the Callaway Plant's performance in this area prior to this inspection, the NRC chose to limit the number of personnel interviewed. Overall, the Callaway Plant has an adequate SCWE.
Willingness to Raise Nuclear Safety Issues: In the assessed focus group, the team found no evidence of challenges to SCWE. Individuals in this group expressed a willingness to raise nuclear safety concerns and other issues through at least one of the several means available.
Overall, the team concluded that the Callaway Plant maintained a healthy SCWE.
Employee Concerns Program: The team looked at the Callaway Plant's Employee Concerns Program (ECP). The team interviewed the ECP manager and discussed her cases.
Unfortunately, the team was unable to review the ECPs investigative packages due to the challenges created by the COVID-19 pandemic and the personal nature of the documents.
Overall, the team did not identify any concerns with the program.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified that no proprietary documents were retained or documented in this report.
- On May 7, 2020, the inspectors presented the biennial problem identification and resolution inspection results to Mr. Fadi Diya and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71152B Corrective Action Condition Reports 199001400, 199301554, 201302358, 201302424,
Documents 201502077, 201502077, 201505100, 201508347,
201604507, 201604820, 201609281, 201700788,
201700883, 201704393, 201705228, 201706617,
201707190, 201707502, 201800323, 201800866,
201801304, 201801760, 201801773, 201801783,
201801971, 201802129, 201802155, 201802212,
201802362, 201802509, 201802600, 201802633,
201802725, 201802727, 201802821, 201802938,
201803026, 201803067, 201803083, 201803201,
201803204, 201803234, 201803252, 201803300,
201803405, 201803580, 201803671, 201803716,
201804026, 201804051, 201804211, 201804212,
201804236, 201804251, 201804276, 201804434,
201804579, 201804654, 201804863, 201804925,
201805870, 201806199, 201806334, 201806389,
201806479, 201806593, 201900050, 201900066,
201900103, 201900136, 201900529, 201900788,
201900887, 201901077, 201901330, 201901423,
201901550, 201901764, 201901857, 201901903,
201902606, 201902636, 201902698, 201903070,
201903222, 201903406, 201903431, 201903552,
201903596, 201903630, 201903712, 201803787,
201903832, 201904071, 201904098, 201904168,
201904171, 201904220, 201904306, 201904591,
201904713, 201904807, 201904897, 201904906,
201904921, 201904983, 201904995, 201905140,
201905145, 201905250, 201905354, 201905364,
201905440, 201905495, 201905498, 201905641,
201905652, 201905654, 201905676, 201905708,
201905718, 201905722, 201905728, 201905752,
201905777, 201905827, 201905843, 201905850,
201905859, 201905901, 201906017, 201906022,
Inspection Type Designation Description or Title Revision or
Procedure Date
201906202, 201906298, 201906374, 201906404,
201906444, 201906686, 201906744, 201906847,
201906868, 201906878, 201907043, 201907047,
201907073, 201907171, 201907252, 201907361,
201907476, 201907630, 201907735, 201907784,
201907799, 201907807, 201907876, 201907884,
201907900, 201907951, 201907960, 201907973,
201908019, 201908040, 202000122, 202000212,
2000245, 202000314, 202000346, 202000352,
2000360, 202000364, 202000367, 202000371,
2000393, 202000476, 202000491, 202000511,
2000598, 202000625, 202000628, 202000689,
2000825, 202000856, 202000975, 202001216,
2001264, 202001296, 202001417, 202001438,
2001455, 202001556, 202001566, 202001573,
2001602, 202001983, 202001999, 202002007,
2002018, 202002025
Drawing 110D873 Rod Drive Power Supply System Reactor Trip Switchgear A
Rod Drive MG Set - Outline
3688C42-S011 Generator No. 1 Voltage Regulator 5
E-23SF21 Schematic Diagram Rod Drive M-G Sets 5
J-23SF01A Rod Control Loop Diagram, Sheet 1 of 2 5
J-23SF01B Rod Control Loop Diagram, Sheet 2 of 2 3
M-U2GD01 (Q) Piping and Instrumentation Diagram Essential Service Water 12
Pumphouse & Ultimate Heat Sink Elec. Rm. HVAC
Miscellaneous Night Order: Atmospheric Steam Dump Insulation 01/09/2019
Night Order: Boric Acid Identification and Monitoring During 03/23/2020
Implementation of POL0049
Night Order: Guidance for NN Inverter Alignment Following 11/15/2019
Inverter Failure
Night Order: RCP Vibration Inputs Defeated to Annunciators 08/20/2019
70A and 70B
Night Order: Sluggish Operation of the Moveable Gripper on 03/19/2020
Control Rod H08
Inspection Type Designation Description or Title Revision or
Procedure Date
Night Order: Steam Generator and RCS Pressure 11/26/2019
Equalization
Night Order: Temporary Safety Monitor Thresholds 09/16/2019
Accounting for BBHV8000B Closure
Night Order: Trigger Points and Actions for Elevated Main 04/14/2020
Generator Hydrogen Consumption Levels
Nuclear Oversight Audit of Operations and Chemistry - 06/18/2019
AP19003
Nuclear Oversight Audit of Materials Services - AP20001 02/26/2020
Callaway Semiannual Trend Report - July through 0
December 2019
Employee Concerns Program - ECP Investigator's Desk Top 6
Instructions
Proprietary WCAP - 17625-P MG Set Manual April 2013,
Document Revision 0
AUCA 20190005 Unplanned Loss of 'B' Switchyard Bus 07/18/2019
LER 1985-022-00 Manual Reactor Trips following CRD motor Generator Output 05/10/1985
Breaker Trips
LER 1985-026-00 Dropped Control Rods Cause High Negative Flux Rate 07/08/1985
LER 1986-024-02 Technical Specification 3.0.3 Entered Due to a Rod Control 01/30/1987
Card Failure
LER 1986-029-00 Manual Reactor Trip Due to a Rod Control Card Failure 09/23/1986
LER 1990-002-00 Electrical Problem in the Control Rod System Led to a 03/05/90
Condition Prohibited by the Plant's Technical Specifications
and a Temporary Waiver of Compliance
LER 1990-009-00 Technical Specification (3.0.3) Entry Due to Loss of the 09/04/1990
Digital Rod Position Indication System on a Failed Central
Control Card
Training Manual T63.0110 6 Rod Control System Introduction 02/15/1987
Training Manual T61.0110.6/T61.016D.6 SF -Rod Control Systems 6/6/2016
Training Manual T63.0110.6 Rod Control Logic Cabinet 02/15/1987
Training Manual T63.0110.6 Rod Control System Power Cabinet 02/15/1987
Procedures A210.0012 Operating Quality Assurance Manual (OQAM) 34
Inspection Type Designation Description or Title Revision or
Procedure Date
APA-ZZ-00500 Corrective Action Program 71
APA-ZZ-00500, Operability Determinations 35
Appendix 1
APA-ZZ-00500 Past-OP Reportability 26
Appendix 3
APA-ZZ-00500, Effectiveness Reviews 14
Appendix 7
APA-ZZ-00500, Corrective Action Program Training Requirements 17
Appendix 8
APA-ZZ-00500, Trending Program 18
Appendix 10
APA-ZZ-00500, Significant Adverse Condition - ADCN-1 36
Appendix 12
APA-ZZ-00500, Adverse Condition - ADCN-2 32
Appendix 13
APA-ZZ-00500, Adverse Condition - ADCN-3 38
Appendix 14
APA-ZZ-00500, Adverse Condition - ADCN-4 33
Appendix 15
APA-ZZ-00500, Other Issue - OI-A 23
Appendix 16
APA-ZZ-00500, Screening Process Guidelines 39
Appendix 17
APA-ZZ-00500, Equipment Failure Analysis 15
Appendix 18
APA-ZZ-00500, Common Cause Evaluation (CCE) 06
Appendix 19
APA-ZZ-00500, Other Issues - OI-B 28
Appendix 21
APA-ZZ-00500 Corrective Action Program Definitions 21
Appendix 22
APA-ZZ-00930 Employee Concerns Program 20
APA-ZZ-00932 Nuclear Safety Culture 2
APA-ZZ-00932, Nuclear Safety Culture Monitoring 12
Inspection Type Designation Description or Title Revision or
Procedure Date
Appendix 1
APA-ZZ-01400, Callaway Self-Assessment and Benchmarking Program 31
Appendix A
APA-ZZ-01400, Operating Experience 26
Appendix E
APA-ZZ-01400, Performance Indicators 10
Appendix F
ATX-ADM-3205 Transmission Design Engineering Design Quality Review 06/01/2019
Process
EDP-ZZ-04026 10 CFR Part 21 Evaluations 14
EDP-ZZ-04107 HVAC Pressure Boundary Control 32, 33
EDP-ZZ-06000 Vendor Equipment Technical Information Review Program 19
EE-006 Electrical Design Criteria/Inputs 7
LDP-ZZ-00500 Corrective Action Review Board 34
MPM-SK-QW001 Service and Inspection of Plant Doors 1
NISP-PI-02 Conduct of Self-Assessments and Benchmarks 0
ODP-AA-00002 Equipment Status Control 93
ODP-ZZ-00001 Operations Department - Code of Conduct 106
ODP-ZZ-00001, Reactivity Management / Operating Philosophy 26
Addendum 10
ODP-ZZ-00001, Crew Performance and Qualifications 49
Addendum 3
ODP-ZZ-00001, Operator Burdens and Workarounds 10
Addendum 12
ODP-ZZ-00002, Risk Management Actions for Planned Risk Significant 18
Appendix 2 Activities
ODP-ZZ-00014 Operational Mode Change Requirements 54, 55
OTA-RK-00026 Turbine Exhaust Hood Temperature High 4
OTG-ZZ-00002 Reactor Startup - IPTE 62
OTN-AC-00001 Main Turbine and Generator Systems 54
PDP-ZZ-00023 Work Screening and Processing 38
PDP-ZZ-00023, Priority Screening Matrix 6
Appendix A
Inspection Type Designation Description or Title Revision or
Procedure Date
ZZ-009 Pre-Job Activities for Engineering Change Packages and 1
Engineering Documents
Self-Assessments AP19001 Radiation Protection Audit 03/27/2019
AP19004 Maintenance, Work Management, and M&TE Programs 08/29/2019
Audit
AP19005 Audit Report - Nuclear Oversight Audit of the Corrective 10/23/2019
Action Program
FSA 201807096- Formal Self-Assessment - Standard Design 07/25/2019
015
FSA 201820044- Electrical Safety / Formal Self-Assessment 01/16/2019
071
FSA 201900029- Formal Self Assessment - EQ Program 03/28/2019
006
OSA 201900029- STARS Maintenance Self-Assessment 2019 06/20/2019
047
SA 202001257 Self Assessment - Boric Acid Program 03/05/2020
SBM 201820044- Cross Checks and Confirmations / Simple Benchmark 06/24/2019
2
SBM 201820044- Passive Monitoring / Simple Benchmark 06/24/2019
068
SSA 201500920- Self-Assessment and Benchmark Program 11/24/2015
SSA 201807096- Maintenance Lockout / Simple Self-Assessment 07/02/2018
005
SSA 201807096- Instrument Program and Pre-NRC Inspection 03/31/2019
010/201900029-
036
SSA 201820044- Simple Self-Assessment - ASME IWL Program - 07/31/2019
2 Containment Post Tensioning
SSA 201820044- Simple Self-Assessment - ASME GL89-13 Program 10/19/2018
019
SSA 201820044- Simple Self-Assessment - ASME Maintenance Rule 05/23/2018
20
Inspection Type Designation Description or Title Revision or
Procedure Date
SSA 201820044- Housekeeping/Material Storage 01/10/2019
23
SSA 201820044- NRC Pre Inspection Self Assessment - Rad Safety ALARA 06/14/2018
064 Planning and Occupational Dose Assessment
SSA 201820044- Simple Self-Assessment - ASME Fire Protection Program 11/11/2018
066
SSA 201900029- Simple Self-Assessment - ASME EN.1 Assessment on Key 02/15/2019
2 Component Specifications
SSA 201900029- MFIN Walkdown Effectiveness 01/09/2020
21
SSA 201900029- Effluent Leak Management (ELM) Program 12/17/2019
2
SSA 201900029- Effectiveness of Lifting & Rigging Program 07/16/2019
23
SSA 201900029- Shipping / Returns 12/20/2019
27
SSA 2019-00029- Procurement / Acceptance / Return backlogs 01/31/2020
28
SSA-201900029- Parts issue with oxidation, corrosion rust that had a job or 01/16/2020
29 plant impact
SSA-201900029- Reactivity Management 12/01/2019
2
SSA 201900029- Shipping Program 04/29/2019
035
SSA 201900029- Simple Self-Assessment - ASME Maintenance Rule (a)(3) 10/03/2019
048 Assessment
Work Orders 16002805, 17005384, 18001142, 18001740, 18001740,
18002534, 18003289, 18003541, 19000268, 19001090,
19002935, 19003307, 19005361, 20000522,
2