IR 05000483/2021001

Integrated Inspection Report 05000483/2021001

ML21131A220
Person / Time
Site:	Callaway
Issue date:	05/11/2021
From:	O'Keefe N NRC/RGN-IV/DRP/RPB-B
To:	Diya F Ameren Missouri
References
IR 2021001
Download: ML21131A220 (23)

Text

May 11, 2021

SUBJECT:

CALLAWAY PLANT - INTEGRATED INSPECTION REPORT 05000483/2021001

Dear Mr. Diya:

On March 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Callaway Plant. On April 7, 2021, the NRC inspectors 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.

On December 24, 2020, Callaway Plant experienced an electrical fault in the non-safety main generator. Subsequent inspections of the damage and development of repair plans resulted in an expected outage duration that was of sufficient duration for the NRC to consider whether to implement Inspection Manual Chapter (IMC) 0375, Implementation of the Reactor Oversight Process at Reactor Facilities in an Extended Shutdown Condition for Reasons Not Related to Performance. The Regional Administrator, Region IV approved a decision to not implement the additional oversight measures contained in IMC 0375. This decision is documented in ADAMS Accession No. ML21111A037.

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 F. Digitally signed by Cornelius F. O'Keefe O'Keefe Date: 2021.05.11 16:49:27 -05'00'

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

Enclosure:

As stated

Inspection Report

Docket Number: 05000483 License Number: NPF-30 Report Number: 05000483/2021001 Enterprise Identifier: I-2021-001-0094 Licensee: Ameren Missouri Facility: Callaway Plant Location: Steedman, MO Inspection Dates: January 1, 2021 to March 31, 2021 Inspectors: J. Arellano, General Engineer, NRAN B. Baca, Health Physicist D. Bradley, Senior Resident Inspector A. Donley, Project Engineer S. Janicki, Acting Senior Resident Inspector J. O'Donnell, Senior Health Physicist E. Simpson, Health Physicist 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 Provide Adequate Work Instructions for Performing Maintenance on Motor Control Centers Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.9] - Training 71153 Systems NCV 05000483/2021001-01 Open/Closed The NRC identified a Green, non-cited violation of Technical Specification 5.4.1.a,

Procedures, for the Callaways failure to provide adequate work instructions for performing maintenance on motor control centers. Specifically, Callaway's procedure, MPE-ZZ-QS001,

Cleaning and Inspection of Motor Control Centers, Revision 36, failed to include instructions for the inspection of fuses and fuse clips including the adjustment of fuse clip tension as necessary to prevent fuse movement. As a result, the licensee failed to recognize that the control power fuse clip tension for safety-related essential service water isolation valve EFHV0024 was insufficient to prevent fuse movement, causing a loss of control power and inoperability of this valve

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000483/2020-005-00 Inoperable Isolation Valve 71153 Closed Between Safety-Related Essential Service Water and Nonsafety-Related Service Water

PLANT STATUS

Callaway Plant began the inspection period shut down for an unplanned outage and 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 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 Disease 2019 (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; conducted plant status activities as described in IMC 2515, Appendix D, Plant Status; 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 onsite. The inspections documented below met the objectives and requirements for completion of the IP.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal sub-zero temperatures and windchill for the following systems on February 1, 2021:

• Onsite power distribution system

• Offsite power and switchyard

• Auxiliary boiler

• Emergency diesel generators

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) Control room air conditioning train A partial lineup on February 24, 2021

(2) Emergency diesel generator train A partial lineup on March 5, 2021

(3) Centrifugal charging pump train B partial lineup on March 11, 2021

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

(1) The inspectors evaluated system configurations during a complete walkdown of the control room emergency ventilation system on March 18, 2021

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) Turbine building tank and storage area, fire area TB-1, on February 23, 2021

(2) Control building pipe space and tank area, fire area C-1, on February 26, 2021

(3) Control building north and south vertical cable chase rooms, fire areas C-2 and C-3, on March 2, 2021

(4) Upper cable spreading room, fire area C-22, on March 10, 2021

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Residual heat exchanger room train B on March 18, 2021

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

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

(1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the Control Room during plant cooldown to Mode 5 on February 27, 2021

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

(1) The inspectors observed and evaluated licensed operator continuing training on January 19, 2021

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 remain capable of performing their intended function:

(1) Safety-related fuse control program on February 8, 2021

(2) Diesel, auxiliary, and control building roof drains on March 12, 2021

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (4 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 during scheduled safety injection pump train A surveillance testing on January 12, 2021

(2) Unplanned elevated risk during extreme seasonal cold temperatures during scheduled offsite power line Mont-Cal-8 outage on February 15, 2021

(3) Planned elevated risk during scheduled service air compressor maintenance during transformer XPB121 replacement on February 18, 2021

(4) Planned elevated risk during scheduled emergency diesel generator train B testing on March 2, 2021

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)

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

(1) Circulating water and service water switchgear degraded cabling on January 21, 2021

(2) Alternate emergency power system diesel generator No. 2 control fuse failure on February 8, 2021

(3) Pressurizer backup heater group failure on February 20, 2021

(4) Pressurizer power-operated relief valve (PORV) B cable and environmental qualification seal on March 3, 2021

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (4 Samples)

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

(1) Control building and communications corridor to non-vital switchgear door seal repair on January 12, 2021

(2) Safety injection pump train A following planned maintenance on January 14, 2021

(3) Control room air conditioning system train B following planned maintenance on February 22, 2021

(4) Class 1E electrical equipment air conditioning train A following planned maintenance on March 19, 2021

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Control room emergency ventilation system train B surveillance testing on January 10, 2021

(2) Refueling water storage tank to refuel pool isolation valve testing on March 9, 2021

Inservice Testing (IP Section 03.01) (1 Sample)

(1) Safety injection pump train A inservice test on February 11, 2021

Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)

(1) Personnel access hatch and containment isolation verification on January 28, 2021

FLEX Testing (IP Section 03.02) (1 Sample)

(1) FLEX Hale pump No. 1 surveillance test on February 26, 2021

71114.06 - Drill Evaluation

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

The inspectors evaluated:

(1) Emergency preparedness team training and drill on March 4,

71124.01 - Radiological Hazard Assessment and Exposure Controls

Instructions to Workers (IP Section 03.02) (1 Sample)

The inspectors evaluated instructions to workers including the following radiation work permit used to access high radiation areas:

(1) Specific Radiation Work Permit 21501166750, "Resin Liner Shipment," Revision 0

Radiological Hazards Control and Work Coverage (IP Section 03.04) (1 Sample)

The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.

(1) The inspectors reviewed radiological work activities related to the resin and charcoal shipment under Specific Radiation Work Permit 21501166750, "Resin Liner Shipment," Revision 0, and associated potential airborne radioactivity areas.

High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (1 Sample)

The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:

(1) Transfer of a resin and charcoal liner from a storage vault to a transportation cask on March 17, 2021, which created a moving locked high radiation area (Specific Radiation Work Permit 21501166750, "Resin Liner Shipment," Revision 0).

Radiation Worker Performance and Radiation Protection Technician Proficiency (IP

Section 03.06) (1 Sample)

(1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements during the loading of a resin and charcoal liner on March 17, 2021, which created locked high radiation area conditions (Specific Radiation Work Permit 21501166750, "Resin Liner Shipment,"

Revision 0).

71124.02 - Occupational ALARA Planning and Controls

Implementation of ALARA and Radiological Work Controls (IP Section 03.03) (1 Sample)

The inspectors reviewed as low as reasonably achievable practices and radiological work controls. The inspectors reviewed the following activity:

(1) A resin and charcoal liner shipment on March 17, 2021, under ALARA Plan 21-0320, "Advanced Liquid Waste Processing System (ALPS) Activities" approved January 5, 2021.

Radiation Worker Performance (IP Section 02.04) (1 Sample)

The inspectors evaluated radiation worker and radiation protection technician performance during:

(1) A resin and charcoal liner shipment which created a locked high radiation area when transferred from the storage vault to the transportation cask (Specific Radiation Work Permit 21501166750, "Resin Liner Shipment," Revision 0).

71124.05 - Radiation Monitoring Instrumentation

Walkdowns and Observations (IP Section 03.01) (10 Samples)

The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:

(1) Personnel contamination monitoring equipment at the plant access control point: five Thermo-Scientific iPCM-12 units

(2) Personnel monitoring equipment at the plant access control point: two Thermo-Scientific PM-12 units

(3) Small article monitoring equipment at the plant access control point: two Thermo-Scientific SAM-12 units

(4) Plant area radiation monitor: Radwaste Building corridor, basement, SD-RE-01

(5) Plant area radiation monitor: Auxiliary Building Filter Unit, SD-RE-25

(6) Plant airborne effluent radiation monitor: Containment Building air exhaust vent monitor, GT-RE-21A

(7) Radiation monitoring equipment: CRM-4095-HP, Ludlum Model 177 count-rate meter with frisker

(8) Radiation monitoring equipment: ION-4249-HP, Thermo-Scientific RO20AA ion chamber

(9) Radiation monitoring equipment: GMI-4158-HP, MGP Instruments Telepole

(10) Radiation monitoring equipment: NRM-4132-HP, Thermo-Scientific RadEye NL (neutron) survey meter

Calibration and Testing Program (IP Section 03.02) (10 Samples)

The inspectors evaluated the calibration and testing of the following radiation detection instruments:

(1) Canberra Fastscan, FS-5300-HP, September 22, 2016

(2) Canberra Fastscan, FS-5301-HP, September 21, 2016

(3) Canberra Fastscan, FS-5300-HP, calibration confirmation, September 25, 2020

(4) Canberra Fastscan, FS-5301-HP, calibration confirmation, September 13, 2020

(5) Eberline AMS-4 continuous particulate air monitor, CAM-4059-HP, January 4, 2021

(6) RADeCO HD-29A air sampler, LAS-4200-HP, December 2, 2020

(7) Eberline RO-20, ION-4226-HP, February 27, 2020

(8) Rotem AMP-200 Geiger-Mueller detector, GMI-4231-HP, February 5, 2021

(9) Liquid radioactivity process monitor, CVCS letdown, SJ-RE-01, February 20, 2020

(10) Containment High Activity Monitor, GT-RE-59, January 18, 2019 Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (2 Samples)

The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:

(1) JOB 18508980-500, plant unit vent gaseous effluent radioactivity monitor, GT-RE-21B, March 31, 2020

(2) JOB 18508697-500, liquid radwaste effluent radioactivity monitor, BM-RE-18, February 28, 2020

71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &

Transportation

Radioactive Material Storage (IP Section 03.01)

Inspectors evaluated the licensees performance in controlling, labeling and securing radioactive materials.

(1) 55-gallon drums in the Low Level Drum Storage Area (Nos. 15990 and 15949)

(2) 55-gallon drums in the High-Level Drum Storage Area (Nos. 10224 and 16103)

(3) B-25 Box in Radwaste Yard Plant South (No. 15503)

Radioactive Waste System Walkdown (IP Section 03.02) (2 Samples)

Inspectors walked down accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality.

(1) Radwaste building filters and demineralizers

(2) Auxiliary building filters and demineralizers

Waste Characterization and Classification (IP Section 03.03) (2 Samples)

The inspectors evaluated the licensees characterization and classification of radioactive waste for the following waste streams:

(1) Dry Active Waste Sample Report (517088004) dated October 30, 2019

(2) Reactor Coolant System Filter Sample Report (517088006 GEL) dated September 9, 2019

Shipment Preparation (IP Section 03.04) (1 Sample)

(1) The inspectors observed Shipment 21-009A, containing LSA II radioactive material (resin and charcoal). The shipment was prepared according to requirements.

Shipping Records (IP Section 03.05) (4 Samples)

The inspectors evaluated the following non-excepted radioactive material shipments through a record review:

(1) Dry Active Waste shipment packages: 19-022 (LSA I - 2 containers) and 19-029 (LSA II - 7 containers)

(2) Filter shipment package: 20-027 (LSA II - 14 drums)

(3) Refueling Equipment shipment packages: 20-001 (SCO/LSA - 3 containers) and 20-032 (LSA II under head specimen tool)

(4) Resin shipment packages: 19-005 (LSA II),19-021 (LSA I), and 20-029 (LSA II - resin and charcoal)

OTHER ACTIVITIES - BASELINE

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

MS06: Emergency AC Power Systems (IP Section 03.05) ===

(1) January 1, 2020, through December 31, 2020

MS10: Cooling Water Support Systems (IP Section 03.09) (1 Sample)

(1) January 1, 2020 through December 31, 2020 BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 03.10) (1 Sample)

(1) January 1, 2020 through December 31, 2020

71153 - Follow-up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000483/2020-005-00, Inoperable Isolation Valve Between Safety-Related Essential Service Water and Nonsafety-Related Service Water (ADAMS Accession Number ML20322A166), on February 26, 2021. The circumstances surrounding this LER are documented in the Inspection Results section of this report. This licensee event report is closed.

INSPECTION RESULTS

Failure to Provide Adequate Work Instructions for Performing Maintenance on Motor Control Centers Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.9] - Training 71153 Systems NCV 05000483/2021001-01 Open/Closed The NRC identified a Green, non-cited violation of Technical Specification 5.4.1.a, Procedures, for the Callaways failure to provide adequate work instructions for performing maintenance on motor control centers. Specifically, Callaway's procedure, MPE-ZZ-QS001, Cleaning and Inspection of Motor Control Centers, Revision 36, failed to include instructions for the inspection of fuses and fuse clips including the adjustment of fuse clip tension as necessary to prevent fuse movement. As a result, the licensee failed to recognize that the control power fuse clip tension for safety-related essential service water isolation valve EFHV0024 was insufficient to prevent fuse movement, causing a loss of control power and inoperability of this valve.

Description:

Between July 22, 2020 and September 18, 2020, Callaway Plant experienced three unexpected A train engineered safety feature actuation systems (ESFAS) alarms while operating safety-related essential service water isolation valve EFHV0024. This valve is part of a valve pair that automatically closes during accident conditions to preserve ultimate heat sink inventory and isolate the essential service water (ESW) system from the non-safety service water system. Each instance of the A Train ESFAS alarm was accompanied by erratic and/or intermittent valve position indication (VPI) for EFHV0024.

The first unexpected A Train ESFAS alarm occurred on July 22, 2021 while restoring from a containment cooler flow rate surveillance test. The control room received the A train ESFAS alarm when the reactor operator attempted to close EFHV0024. No other abnormal indications were identified in the control room or following a walkdown of plant equipment in the field. The licensee documented the unexpected alarm in Condition Report 202003527 and generated Job 20002062 to investigate and repair the issue.

The control room received a second unexpected A train ESFAS alarm on August 17, 2020 while securing ESW after lowering the level in the ultimate heat sink (UHS) pond. The A train ESFAS alarm came in, then cleared, and the closed VPI flickered while opening EFHV0024. No other abnormal indications were observed in the control room or in the field.

The licensee documented this additional occurrence of the A train ESFAS alarm in Condition Report 202004022.

The third A train ESFAS alarm occurred on September 12, 2020 when closing EFHV0024 after starting ESW to lower UHS pond level. The A train ESFAS alarm came in, then cleared, and both the open and close VPI indicating lights flickered. No other abnormal indications were found in the control room or in the field. The licensee documented the third A train ESFAS alarm in Condition Report 202004586.

Callaway commenced troubleshooting the unexpected A train ESFAS alarms on September 18, 2020. While cycling EFHV0024, the licensee observed erratic voltage at the valve and intermittent VPI. Further investigation inside NG01AGF2, the feeder circuit breaker to EFHV0024, identified that the valves secondary control power fuse was improperly seated within the fuse clip. The licensee inspected the fuse and fuse clip and found the fuse clip tension was insufficient to prevent fuse movement, causing a loss of control power and inoperability of EFHV0024. The licensee adjusted the fuse clip tension and reinstalled the control power fuse. EFHV0024 was cycled multiple times as part of post-maintenance testing without any further issues and the valve was declared operable. The licensee documented the insufficient fuse clip tension identified during troubleshooting in Condition Report 202004735.

The inspectors reviewed the history of work associated with this component and associated procedures. The inspectors noted that the secondary control power fuse for EFHV0024 was last manipulated when it was installed on September 15, 2009. Following the initial installation, the control power fuse and fuse clip were not inspected as part of the licensees preventative maintenance program. Between 2009 and 2020, the fuse clip tension apparently relaxed until the tension was insufficient to prevent fuse movement causing a loss of control power and inoperability of EFHV0024. Industry operating experience indicates that this has been a known issue.

The inspectors determined that Callaways motor control center preventative maintenance procedure, MPE-ZZ-QS001, Cleaning and Inspection of Motor Control Centers, did not require fuse and fuse holder inspection at the time of the failure, contributing to the licensee not recognizing there was insufficient fuse clip tension, allowing fuse movement and eventually causing inoperability of EFHV0024; however, fuse and fuse clip checks had previously been included in earlier revision of the procedure due to past fuse and fuse clip problems.

The inspectors also reviewed procedures that describe the level of detail required in procedures and general awareness of electrical connections when performing maintenance.

For example, licensee procedure APA-ZZ-00013 Appendix 1, Maintenance Department Skill of the Craft Listings, Revision 9, states that the replacement, removal, and installation of fuses as activities that would not normally be detailed in written instructions. Procedure APA-ZZ-00013 Appendix 4, Maintenance Fundamentals and Technical Skills, Revision 2, discusses proper electrical connections and states that failure to ensure proper connection tightnesscould cause the connection to eventually fail. Ultimately, the inspectors determined that this combination of procedures did not ensure fuse tightness and good electrical connections until the several self-revealing failures occurred in 2020.

The inspectors independently reviewed the licensees cause evaluation and raised several questions to the licensee regarding the quality the cause evaluation, proposed corrective actions, and the extent of condition review. The licensees initial cause evaluation determined the cause of the ESFAS alarm was a loose fuse clip but failed to address the cause for the fuse clip becoming loose, procedural and training requirements for checking fuses and the fuse holder, or a review of operating experience on fuses and fuse holder vulnerabilities. In response to the inspectors questioning, the licensee revised the cause evaluation. The licensee documented the inspectors concerns and cause evaluation revision in Condition Report 202100214. The inspectors noted that the redundant isolation valve, paired and in series with EFHV0024, remained operable and would successfully isolate the safety-related ESW system from the non-safety service water system in an event, limiting the safety significance of the failure. The licensees corrective actions included revising the motor control center preventative maintenance Procedure MPE-ZZ-QS001, to prompt technicians to inspect motor control center fuse clip tightness every 48 months.

Corrective Actions: The licensee inspected the secondary control power fuse and clip for damage, adjusted the fuse clip tension, reinstalled the fuse, conducted post-maintenance testing, and revised the maintenance procedure to include fuse and fuse holder checks.

Corrective Action References: Condition Report 202004735

Performance Assessment:

Performance Deficiency: The failure to provide adequate work instructions for performing maintenance on motor control centers is a performance deficiency. Specifically, the failure to include fuse and fuse holder checks in the work scope for appropriate preventative maintenance procedures to detect problems known to occur based on station operating experience resulted in the failure to detect a repeat occurrence prior to a loss of operability in a safety-related motor-operated valve.

Screening: The inspectors determined the performance deficiency was more than minor, and therefore a finding, because it was associated with the Equipment 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 allowed the secondary control power fuse to move within the clip and caused intermittent electrical contact rendering EFHV0024 inoperable.

Significance: The inspectors assessed the significance of the finding utilizing Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, dated December 13, 2019, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, dated November 30, 2020. The finding was determined to be of very low safety significance (Green) because the finding (1)was not a design or qualification deficiency,

(2) did not represent a loss of the Probabilistic Risk Assessment (PRA) function of a single train Technical Specification (TS) system,

(3) did not represent a loss of the PRA function of one train of a multi-train TS system,

(4) did not represent a loss of the PRA function of two separate TS systems,

(5) did not represent a loss of a PRA system and/or function as defined in the Plant Risk Information Book or the licensees PRA and

(6) did not represent a loss of the PRA function of one or more non-TS trains of equipment designated as risk-significant in accordance with the licensees maintenance rule program. Specifically, the redundant valve, paired and in series with EFHV0024, retained its capability of isolating non-safety service water from safety-related ESW.

Cross-Cutting Aspect: H.9 - Training: The organization provides training and ensures knowledge transfer to maintain a knowledgeable, technically competent workforce and instill nuclear safety values. The inspectors concluded that the primary causal factor in removing preventative maintenance procedure instructions to verify fuse and fuse clip conditions was that the licensee had relied on training to ensure that skill of the craft would be sufficient to cover that scope. That specific training was subsequently discontinued following two cycles without a fuse clip issue. Therefore, the inspectors concluded that the finding had a Human Performance cross-cutting aspect associated with training, in that the verification of good electrical connections with fuses was no longer covered in the skill of the craft guidance and training for routine motor control center inspections.

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 listed in Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Revision 2, Appendix A, Section 9, Procedures for Performing Maintenance, requires, in part, that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. The licensee established procedure, MPE-ZZ-QS001, Cleaning and Inspection of Motor Control Centers, Revision 36, in part, to meet this requirement.

Contrary to the above, from September 15, 2009 to September 18, 2020, the licensee failed to establish, implement and maintain the maintenance procedure for the cleaning and inspecting of motor control centers that can affect safety-related equipment. Specifically, Procedure MPE-ZZ-QS001, Cleaning and Inspection of Motor Control Centers, Revision 36, a maintenance procedure that can affect safety-related equipment, failed to include adequate instructions for the inspection of fuses and fuse clips including adjusting fuse clip tension as necessary to prevent fuse movement. As a result, the control power fuse clip tension for safety-related ESW isolation valve, EFHV0024, was insufficient to prevent fuse movement, causing a loss of control power and inoperability of EFHV0024.

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 confirmed that proprietary information was controlled to protect from public disclosure.

• On March 11, 2021, the inspectors presented the public radiation safety inspection results to Mr. F. J. Bianco, Senior Director, Nuclear Operations, and other members of the licensee staff.

• On April 7, 2021, 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 201707668, 201707732, 201707733, 201800042,

Documents 201800054

Procedures OTA-RK-00020 Freeze Protection Trouble

Addendum 55F

OTN-QJ-00003 Plant Freeze protection Heat Tracing

OTO-ZZ-00012 Severe Weather 43

OTS-ZZ-00007 Plant Cold Weather 38

71111.04 Calculations ARC-1566 Analysis of ESW Pipe Supports due to Transient Loading

Train B Control Room Air Conditioners Supply Piping

Corrective Action Condition Reports 200703739, 20150, 200701725, 200204810, 20100511,

Documents 200704938

Miscellaneous RFR 16691 Evaluate Not Running the Not Running the CCP Lube Oil C

Pumps Always

Procedures ISP-SA-0006 Control Room Ventilation Time Response Test 10

ISP-SA-0006 Pump and Valve Inservice Test Program 28

OSP-BG-00002 Verify One Centrifugal Charging Pump Incapable of Injection 11

Into RCS

OSP-BG-P005B Centrifugal Charging Pump B Inservice Test 54

OSP-SA-2413A Train A Diesel Generator & Sequencer Testing 30

71111.05 Corrective Action Condition 201200573, 201404263, 201707147, 201801536,

Documents Reports 201303820, 201806088

Procedures APA-ZZ-00701 Control of Fire Protection Impairments 25

APA-ZZ-00741 Control of Combustible Materials 37

APA-ZZ-00750 Hazard Barrier Program 48

71111.06 Calculations M-FL-3 Auxiliary Building Flooding 3

Corrective Action Condition Reports 201900727, 202006279, 202004351, 202003539

Documents

Miscellaneous Fire Pre-Plan 40

Inspection Type Designation Description or Title Revision or

Procedure Date

Procedures OTO-ZZ-00005 Flooding 3

71111.11Q Procedures ODP-ZZ-00001 Operations Department - Code of Conduct

OOA-ZZ-SM001 Safety Monitor 7

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

OTG-ZZ-00007 Refueling, Preparation, Performance & Recovery 41

71111.12 Corrective Action Condition Reports 201806771, 201900135, 20190216, 202000754,

Documents 202002008, 202004375, 202100214

Drawings M-07LF02 Plumbing and Drainage Systems 9

Miscellaneous RFR 170332 Approve a Flat Diesel Building Roof Drain Cover

Procedures MPE-ZZ-QS001 Cleaning and Inspection of Motor Control Centers 37

71111.13 Corrective Action Condition Reports 202003851, 20207142, 202004121, 201907543

Documents

Procedures APA-ZZ-00315 Configuration Risk Management 15

EDP-ZZ-01120 Listing of Components That Have Multiple Functions 3

App

EDP-ZZ-01129 Callaway Energy Center Online Risk Management 52

ODP-ZZ-0002 Risk management Actions for Planned Risk-Significant 17

App 2 Activities

71111.15 Corrective Action Condition Reports 202100389, 202101036, 202100747, 202006192

Documents

Procedures OTN-PB-00001 Non-Class 1E 4.16KV Electrical System 22

OTN-PB-00001 Energizing and Cross-Tying Buses PB121, PB122 and 4

Add 3 PB123

Work Orders Job 18004342, 21000313, 21000728, 1904306, 20003752,

200003757

71111.19 Corrective Action Condition Reports 201302500, 201303980, 201509113, 200809375

Documents

Miscellaneous Chiller BID Chillers, refrigeration systems and their motors 2

Procedures OTN-GK-00001 Control Building HVAC 64

OTO-GK-00001 Loss of Control Room HVAC 15

71111.22 Corrective Action Condition Reports 200403447, 200706957, 201302126, 200507184,

Documents 201003638

Inspection Type Designation Description or Title Revision or

Procedure Date

Miscellaneous SSMP Forced Outage 73 Shutdown Safety Management Plan 1

Procedures FSG-5 Initial Assessment and FLEX Equipment Staging 4

MPE-GK-QG002 Control Room Emergency Ventilation System Train B Flow 10

Verification

OOA-XX-HALE FLEX Hale Pump Operator Aid 001

OSP-BN-V001A RWST to Refuel Pool Valve Inservice Test 12

OSP-EM-P001A Safety Injection Train A Inservice Test 54

OSP-GP-00001 Containment Isolation Verification 25

71114.06 Corrective Action Condition Reports 202101286, 202004552, 202101427

Documents

Procedures EIP-ZZ-00101 Classifications of Emergencies 55

EIP-ZZ-A0001 Emergency Response Organization 21

71124.01 Radiation Work Specific Radiation Resin Liner Shipment 0

Permits (RWPs) Work Permit

21501166750

71124.02 Miscellaneous 21-0320 ALPS ALARA Briefing Guide: ALPS Sluice and Refill Resin 01/05/2021

Activities

71124.05 Calculations APA-ZZ-010003 Offsite Dose Calculation Manual 25

Calibration CAM-4059-HP Calibration Certificate 01/04/2021

Records GMI-4202-HP Calibration Certificate 09/09/2019

GMI-4231-HP Calibration Certificate 02/05/2021

ION-4226-HP Calibration Certificate 02/27/2020

LAS-4200-HP Calibration Certificate 12/01/2020

Corrective Action Condition Reports 201904294, 201904332, 201904427, 201904494,

Documents 201904558, 201904667, 201904870, 201904897,

201905244, 201905246, 201906084, 201906484,

201906661, 201906688, 201906982, 201906984,

201907004, 201907175, 201907498, 201907713,

201907727, 201907878, 202000043, 202000328,

2000546, 202000710, 202000860, 202001040,

2001875, 202002028, 202002483, 202002486,

2003196, 202003233, 202003326, 202003456,

2003581, 202003733, 202003850, 202004088,

2004183, 202004429, 202004827, 202004968,

Inspection Type Designation Description or Title Revision or

Procedure Date

2004978, 202005865, 202006792, 202006902,

2007470, 202100813, 202100814, 202100886

Miscellaneous T63.0340 6 Digital High Range Radiation Monitors, LP 10 05/30/2019

Procedures HTP-ZZ-04149- Calibration of the ROTEM AMP-200 Area Monitor 11

DTI-AMP200-CAL

HTP-ZZ-04167- Thermo RadEye Neutron Survey Meter Calibration 0

DTI-Thermo-

Radeye NL-Cal

HTP-ZZ-04169- Mirion GMP-25 Survey Frisker Calibration 1

DTI-GMP-25-CAL

HTP-ZZ-04175- Thermo-Scientific Model PM-12 Personal Monitor Calibration 7

DTI-PM12-CAL

HTP-ZZ-04176- Thermo Fisher Model SAM-12 Small Articles Monitor 6

DTI-SAM12-CAL Calibration

HTP-ZZ-04177- Thermo Fisher Model IPCM-12 Calibration 8

DTI-IPCM12-CAL

ISL-GT-00R59 CTMT High Range Area Rad Monitor Loop Calibration 23

ISL-GT-0R21B LOOP-NUC; PLANT UNIT VENT EFF RADN DET 37

ISL-HB-00R18 RW BLDG DISCH LINE PROCESS RAD MON LOOP CAL 26

ITL-GH-0R10A Radwaste Bldg Vent Particulate and Iodine Radiation 25

Monitor Loop Calibration

ITL-GT-0R21A Unit Vent Particulate and Iodine Radiation Monitor Loop 22

Calibration

Self-Assessments AP20006 2020 Nuclear Oversight Audit of Radiological and Non- 05/29/2020

Radiological Environmental Monitoring Programs Audit

Eckert & Ziegler Results of Radiochemistry Cross Check Program Ameren 06/12/2020

Analytics Missouri Callaway

Work Orders JOB- 17501773, 18502045, 18504904, 18508697, 18508980,

18512500, 19500770, 19501197, 20505677

71124.08 Corrective Action Condition Reports 200709618, 201904290, 201904326, 201904499,

Documents 201904499, 201905491, 201905779, 201905779,

201906656, 201907108, 201907165, 201907696,

2001280, 202004138, 202100578, 202100766

Miscellaneous T52.PT37 C Security Part 37 Training 12/17/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

T64.RSHP.6 Radiation Protection: Shipping & Packaging Radioactive 06/12/2016

Material Training

Procedures APA-ZZ-00902 Personnel Additions, Changes, Terminations, and Access 29

Withdrawal

APA-ZZ-01000 Control of Radioactive Material 23

Appendix A

APA-ZZ-01011 Process Control Program (PCP) 15

HDP-ZZ-03000 Radiological Survey Program 49

HDP-ZZ-03000, Radioactive Material Shipment Surveys 10

Appendix F

HDP-ZZ-09000 Radioactive Material Shipping Program 5

HTP-HC-09002 10CFR61 Sampling Program 4

HTP-ZZ-09003 Shipment of Radioactive Materials 8

HTP-ZZ-09004 Shipment of Radioactive Wastes 7

NEI 14-04 Callaway Plant Part 37 Security Plan for the Protection of 2

Revision 1 Category 1 and Category 2 Quantities of Radioactive

Material, April 2016

RTS-HC-0230 Operation of Liner Grapple 14

RTS-ZZ-CH060 Handling of Transport Cask Model ATS-215 3

SDP-SF-00027 Protection of Category 1 and 2 Radioactive Materials 2

Radiation CA-M-20201119- RWY-4 Radwaste Yard Plant South - Routine 11/19/2020

Surveys 1

CA-M-20201120- SM-1 O/S RAM - Quarterly Routine - 20501966 11/20/2020

CA-M-20210114- 7226 RW Truck Bay - Routine 01/14/2021

CA-M-20210202- 7225 Low Level Drum Storage Area - Quarterly Survey 02/02/2021

CA-M-20210317- RSV-1 Avantech Cask Shipment 03/01/2021

Self-Assessments 202101192 Pre-NRC Self-Assessment Results 03/08/2021

AP19001 Nuclear Oversight Audit of Radiation Protection 03/27/2019

AP20005 Nuclear Oversight Audit of Security / Cyber-Security 06/19/2020

Program

Inspection Type Designation Description or Title Revision or

Procedure Date

AP20006 2020 Nuclear Oversight Audit of Radiological and Non- 05/29/2020

Radiological Environmental Monitoring

Programs Audit

Shipping Records 19-0038a JOB 19004496-570: Steam Generator Blow-Down Resin 11/21/2019

71151 Miscellaneous 1Q2020, 2Q2020, MSPI Margin Report

3Q2020, 4Q2020

Procedures APA-ZZ-01400 Performance Indicators 38

App F

71152 Procedures APA-ZZ-00500 Corrective Action Program 38

APA-ZZ-00500 Degraded and Nonconforming Condition Resolution 38

App 11

71153 Corrective Action Condition Reports 202004375, 202100214, 202100286

Documents

19