IR 05000483/2020010

Biennial Problem Identification and Resolution Inspection Report 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

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

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

Procedure

Type

Designation

Description or Title

Revision or

Date

71152B

Corrective Action

Documents

Condition Reports

199001400, 199301554, 201302358, 201302424,

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

Procedure

Type

Designation

Description or Title

Revision or

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

Rod Drive MG Set - Outline

A

3688C42-S011

Generator No. 1 Voltage Regulator

E-23SF21

Schematic Diagram Rod Drive M-G Sets

J-23SF01A

Rod Control Loop Diagram, Sheet 1 of 2

J-23SF01B

Rod Control Loop Diagram, Sheet 2 of 2

M-U2GD01 (Q)

Piping and Instrumentation Diagram Essential Service Water

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

Implementation of POL0049

03/23/2020

Night Order: Guidance for NN Inverter Alignment Following

Inverter Failure

11/15/2019

Night Order: RCP Vibration Inputs Defeated to Annunciators

70A and 70B

08/20/2019

Night Order: Sluggish Operation of the Moveable Gripper on

Control Rod H08

03/19/2020

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Night Order: Steam Generator and RCS Pressure

Equalization

11/26/2019

Night Order: Temporary Safety Monitor Thresholds

Accounting for BBHV8000B Closure

09/16/2019

Night Order: Trigger Points and Actions for Elevated Main

Generator Hydrogen Consumption Levels

04/14/2020

Nuclear Oversight Audit of Operations and Chemistry -

AP19003

06/18/2019

Nuclear Oversight Audit of Materials Services - AP20001

2/26/2020

Callaway Semiannual Trend Report - July through

December 2019

Employee Concerns Program - ECP Investigator's Desk Top

Instructions

Proprietary

Document

WCAP - 17625-P MG Set Manual

April 2013,

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

Breaker Trips

05/10/1985

LER 1985-026-00 Dropped Control Rods Cause High Negative Flux Rate

Reactor Trip

07/08/1985

LER 1986-024-02

Technical Specification 3.0.3 Entered Due to a Rod Control

Card Failure

01/30/1987

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

Condition Prohibited by the Plant's Technical Specifications

and a Temporary Waiver of Compliance

03/05/90

LER 1990-009-00 Technical Specification (3.0.3) Entry Due to Loss of the

Digital Rod Position Indication System on a Failed Central

Control Card

09/04/1990

Training Manual

T63.0110 6 Rod Control System Introduction

2/15/1987

Training Manual

T61.0110.6/T61.016D.6 SF -Rod Control Systems

6/6/2016

Training Manual

T63.0110.6 Rod Control Logic Cabinet

2/15/1987

Training Manual

T63.0110.6 Rod Control System Power Cabinet

2/15/1987

Procedures

A210.0012

Operating Quality Assurance Manual (OQAM)

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

APA-ZZ-00500

Corrective Action Program

APA-ZZ-00500,

Appendix 1

Operability Determinations

APA-ZZ-00500

Appendix 3

Past-OP Reportability

APA-ZZ-00500,

Appendix 7

Effectiveness Reviews

APA-ZZ-00500,

Appendix 8

Corrective Action Program Training Requirements

APA-ZZ-00500,

Appendix 10

Trending Program

APA-ZZ-00500,

Appendix 12

Significant Adverse Condition - ADCN-1

APA-ZZ-00500,

Appendix 13

Adverse Condition - ADCN-2

APA-ZZ-00500,

Appendix 14

Adverse Condition - ADCN-3

APA-ZZ-00500,

Appendix 15

Adverse Condition - ADCN-4

APA-ZZ-00500,

Appendix 16

Other Issue - OI-A

APA-ZZ-00500,

Appendix 17

Screening Process Guidelines

APA-ZZ-00500,

Appendix 18

Equipment Failure Analysis

APA-ZZ-00500,

Appendix 19

Common Cause Evaluation (CCE)

APA-ZZ-00500,

Appendix 21

Other Issues - OI-B

APA-ZZ-00500

Appendix 22

Corrective Action Program Definitions

APA-ZZ-00930

Employee Concerns Program

APA-ZZ-00932

Nuclear Safety Culture

APA-ZZ-00932,

Nuclear Safety Culture Monitoring

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Appendix 1

APA-ZZ-01400,

Appendix A

Callaway Self-Assessment and Benchmarking Program

APA-ZZ-01400,

Appendix E

Operating Experience

APA-ZZ-01400,

Appendix F

Performance Indicators

ATX-ADM-3205

Transmission Design Engineering Design Quality Review

Process

06/01/2019

EDP-ZZ-04026

CFR Part 21 Evaluations

EDP-ZZ-04107

HVAC Pressure Boundary Control

2, 33

EDP-ZZ-06000

Vendor Equipment Technical Information Review Program

EE-006

Electrical Design Criteria/Inputs

LDP-ZZ-00500

Corrective Action Review Board

MPM-SK-QW001

Service and Inspection of Plant Doors

NISP-PI-02

Conduct of Self-Assessments and Benchmarks

ODP-AA-00002

Equipment Status Control

ODP-ZZ-00001

Operations Department - Code of Conduct

106

ODP-ZZ-00001,

Addendum 10

Reactivity Management / Operating Philosophy

ODP-ZZ-00001,

Addendum 3

Crew Performance and Qualifications

ODP-ZZ-00001,

Addendum 12

Operator Burdens and Workarounds

ODP-ZZ-00002,

Appendix 2

Risk Management Actions for Planned Risk Significant

Activities

ODP-ZZ-00014

Operational Mode Change Requirements

54, 55

OTA-RK-00026

Turbine Exhaust Hood Temperature High

OTG-ZZ-00002

Reactor Startup - IPTE

OTN-AC-00001

Main Turbine and Generator Systems

PDP-ZZ-00023

Work Screening and Processing

PDP-ZZ-00023,

Appendix A

Priority Screening Matrix

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

ZZ-009

Pre-Job Activities for Engineering Change Packages and

Engineering Documents

Self-Assessments AP19001

Radiation Protection Audit

03/27/2019

AP19004

Maintenance, Work Management, and M&TE Programs

Audit

08/29/2019

AP19005

Audit Report - Nuclear Oversight Audit of the Corrective

Action Program

10/23/2019

FSA 201807096-

015

Formal Self-Assessment - Standard Design

07/25/2019

FSA 201820044-

071

Electrical Safety / Formal Self-Assessment

01/16/2019

FSA 201900029-

006

Formal Self Assessment - EQ Program

03/28/2019

OSA 201900029-

047

STARS Maintenance Self-Assessment 2019

06/20/2019

SA 202001257

Self Assessment - Boric Acid Program

03/05/2020

SBM 201820044-

2

Cross Checks and Confirmations / Simple Benchmark

06/24/2019

SBM 201820044-

068

Passive Monitoring / Simple Benchmark

06/24/2019

SSA 201500920-

Self-Assessment and Benchmark Program

11/24/2015

SSA 201807096-

005

Maintenance Lockout / Simple Self-Assessment

07/02/2018

SSA 201807096-

010/201900029-

036

Instrument Program and Pre-NRC Inspection

03/31/2019

SSA 201820044-

2

Simple Self-Assessment - ASME IWL Program -

Containment Post Tensioning

07/31/2019

SSA 201820044-

019

Simple Self-Assessment - ASME GL89-13 Program

10/19/2018

SSA 201820044-

20

Simple Self-Assessment - ASME Maintenance Rule

05/23/2018

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

SSA 201820044-

23

Housekeeping/Material Storage

01/10/2019

SSA 201820044-

064

NRC Pre Inspection Self Assessment - Rad Safety ALARA

Planning and Occupational Dose Assessment

06/14/2018

SSA 201820044-

066

Simple Self-Assessment - ASME Fire Protection Program

11/11/2018

SSA 201900029-

2

Simple Self-Assessment - ASME EN.1 Assessment on Key

Component Specifications

2/15/2019

SSA 201900029-

21

MFIN Walkdown Effectiveness

01/09/2020

SSA 201900029-

2

Effluent Leak Management (ELM) Program

2/17/2019

SSA 201900029-

23

Effectiveness of Lifting & Rigging Program

07/16/2019

SSA 201900029-

27

Shipping / Returns

2/20/2019

SSA 2019-00029-

28

Procurement / Acceptance / Return backlogs

01/31/2020

SSA-201900029-

29

Parts issue with oxidation, corrosion rust that had a job or

plant impact

01/16/2020

SSA-201900029-

2

Reactivity Management

2/01/2019

SSA 201900029-

035

Shipping Program

04/29/2019

SSA 201900029-

048

Simple Self-Assessment - ASME Maintenance Rule (a)(3)

Assessment

10/03/2019

Work Orders

16002805, 17005384, 18001142, 18001740, 18001740,

18002534, 18003289, 18003541, 19000268, 19001090,

19002935, 19003307, 19005361, 20000522,