IR 05000483/2022001

Integrated Inspection Report 05000483/2022001

ML22111A360
Person / Time
Site:	Callaway
Issue date:	04/26/2022
From:	Greg Werner NRC/RGN-IV/DORS
To:	Diya F Ameren Missouri
References
IR 2022001
Download: ML22111A360 (15)

Text

April 26, 2022

SUBJECT:

CALLAWAY PLANT - INTEGRATED INSPECTION REPORT 05000483/2022001

Dear Mr. Diya:

On March 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Callaway Plant. On April 6, 2022, 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.

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, Signed by Werner, Gregory on 04/26/22 Gregory E. Werner, Chief Projects Branch B Division of Operating Reactor Safety Docket No. 05000483 License No. NPF-30 Enclosure:

Inspection Report 05000483/2022001

ML22111A360 X SUNSI Review ADAMS: Sensitive Non-Publicly Available Keyword By: DLB X Yes No X Non-Sensitive X Publicly Available NRC-002 OFFICE SRI/DORS/B RI/DORS/B TL:DORS/IPAT C:DORS/EB1 C:DORS/EB2 NAME DBradley SJanicki AAgrawal VGaddy NTaylor SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/

DATE 04/22/2022 4/25/2002 4/25/2002 4/25/2022 4/22/2022 OFFICE C:DORS/OB C:DRSS/DIORB C:DORS/RCB SPE:DORS/B C:DORS/B NAME HGepford GWarnick MHaire DProulx GWerner SIGNATURE /RA/ /RA/ /RA/ /RA/ GEW DATE 4/22/2022 04/22/2022 04/22/2022 4/22/2022 04/26/2022

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number: 05000483 License Number: NPF-30 Report Number: 05000483/2022001 Enterprise Identifier: I-2022-001-0005 Licensee: Ameren Missouri Facility: Callaway Plant Location: Steedman, MO Inspection Dates: January 1 to March 31, 2022 Inspectors: D. Bradley, Senior Resident Inspector S. Hedger, Senior Emergency Preparedness Inspector S. Janicki, Resident Inspector J. Melfi, Project Engineer A. Smallwood, Project Engineer Approved By: Gregory E. Werner, Chief Projects Branch B Division of Operating Reactor Safety Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at the Callaway Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

Type Issue Number Title Report Section Status URI 05000483/2021003-01 Failure to Maintain Siren Design 71114.04 Closed as Described in the Alert and Notification System Report

PLANT STATUS

Callaway began the inspection period at rated thermal power. On January 7, 2022, the plant tripped during surveillance testing on the reactor trip circuit breakers. On January 10, the licensee restarted the reactor. On January 11 the licensee reached rated thermal power and remained at or near rated thermal power for the remainder 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 activities described in IMC 2515, Appendix D, Plant Status, conducted routine reviews using IP 71152, Problem Identification and Resolution, observed risk significant activities, and completed on-site portions of IPs. 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.

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 cold temperatures and precipitation for the emergency diesel generators and condensate storage tank on February 1, 2022.

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) Vital inverter NN17 on January 12, 2022

(2) Centrifugal charging pump A on January 25, 2022

(3) Residual heat removal pump A on March 9, 2022

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

(1) The inspectors evaluated system configurations during a complete walkdown of the A motor-driven auxiliary feedwater system on February 22, 2022.

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 2026 foot elevation general area and motor generator set room, fire areas A-16 and A-26, on January 5, 2022

(2) Essential service water pumphouse and ultimate heat sink cooling tower, fire areas UNPH and UNCT, on January 12, 2022

(3) Control building and communication corridor 2016 foot elevation, non-vital switchgear and transformer room, fire area C-15 on January 31, 2022

(4) Fuel building 2047 foot elevation general area, fire area FB-1 on March 8, 2022

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

(1) The inspectors evaluated the on-site fire brigade training and performance during an announced fire drill on January 31, 2022.

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) Spent fuel pool cooling system and storage area rooms on March 15, 2022

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 reactor startup activities on January 9-10, 2022.

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

(1) The inspectors observed and evaluated licensed operator training in the simulator, including reactor coolant system leak training and emergency procedures, on February 10, 2022.

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) Residual heat removal pump A on January 3, 2022

(2) Room cooling for the B component cooling water pump room, including the failure of SGL11B on December 11, 2021, under Condition Report 202106768, on January 26, 2022

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) Elevated risk for a planned work window on train B residual heat removal system on January 4, 2022

(2) Elevated risk for a planned work window on train B centrifugal charging pump and component cooling water system on January 25, 2022

(3) Elevated risk for a planned work window on train B class 1E air conditioning system on February 1, 2022

(4) Elevated risk for a planned work window on train B control room emergency ventilation system on February 23, 2022

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) Longer closing times observed on component cooling water return isolation valve, EGHV0069B, under Condition Report 202200072, on January 6, 2022

(2) Tripped room cooler SGL15A for the north electrical penetration room, under Condition Report 202200375, on January 19, 2022

(3) Equipment installed in switchyard breaker enclosures MDV 54/55, under Condition Report 202200788, on February 8, 2022

(4) Essential service water leakage on the A emergency diesel generator jacket water heat exchanger EKJ06A, under Condition Report 202200942, on February 17, 2022

71111.18 - Plant Modifications

Severe Accident Management Guidelines Update (IP Section 03.03) (1 Sample)

(1) The inspectors verified the site Severe Accident Management Guidelines were updated in accordance with the pressurized water reactor generic severe accident technical guidelines and validated in accordance with NEI 14-01, Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents, Revision 1, on January 3, 2022

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)

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

(1) Train B residual heat removal pump after a planned work window on January 5, 2022

(2) Train A vital AC instrument system power inverter NN11 after a planned work window on January 10, 2022

(3) Train B centrifugal charging pump after a planned work window on January 25, 2022

(4) Train B class 1E electrical equipment air conditioning after a planned work window on February 2, 2022

(5) Train B component cooling water system after a planned work window on February 22, 2022

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:

Surveillance Tests (other) (IP Section 03.01) (3 Samples)

(1) Train B emergency diesel generator monthly test on January 6, 2022

(2) Train A emergency diesel generator fast start test on January 19, 2022

(3) Reactor coolant pump under frequency and under voltage surveillance test on

February 24, 2022 Inservice Testing (IP Section 03.01) (2 Samples)

(1) Train A centrifugal charging pump on January 11, 2022

(2) Train A residual heat removal pump and valve on March 1, 2022

71114.04 - Emergency Action Level and Emergency Plan Changes

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

(1) The inspectors evaluated input provided by the Federal Emergency Management Agency regarding an observed deviation from the licensee's alert and notification system (ANS) siren pole design as described in the approved ANS design report.

The deviation was identified during an inspection conducted September 20-24, 2021.

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (2 Samples)

The inspectors evaluated:

(1) Team 4 emergency response organization training drill on February 10, 2022

(2) Team 3 emergency response organization training drill on March 10,

OTHER ACTIVITIES - BASELINE

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

MS06: Emergency AC Power Systems (IP Section 02.05) ===

(1) January 1, 2021, through December 31, 2021

MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)

(1) January 1, 2021, through December 31, 2021 BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)

(1) January 1, 2021, through December 31, 2021

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

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

(1) Barrier impairment during the replacement of door DSK33022, under Condition Report 202106981, on January 27, 2022

71153 - Follow-up of Events and Notices of Enforcement Discretion Personnel Performance (IP Section 03.03)

(1) The inspectors evaluated a reactor trip during reactor trip breaker surveillance testing and the licensees performance on January 7 and January 8,

INSPECTION RESULTS

Unresolved Item Failure to Maintain Siren Design as Described in the Alert 71114.04 and Notification System Report URI 05000483/2021003-01

Description:

During an inspection conducted September 20-24, 2021, the inspectors identified a deviation between the height of the licensee's emergency response sirens and the design height as described in their Federal Emergency Management Agency (FEMA) approved ANS design report. Therefore, inspectors documented the apparent deviation between the siren pole construction and the design report in Unresolved Item 05000483/2020003-01 (ML21306A347). On November 18, 2021, the NRC requested a review by FEMA to establish whether the licensee was in compliance with the ANS requirements (ML21322A108).

On February 4, 2022, FEMAs response (ML22039A086) indicated that the licensee's change to the siren pole heights was inconsistent with the commitments in the approved ANS design report (December 2020). However, a more recently approved revision to the ANS design report (March 24, 2021), adopting the Integrated Public Alert and Warning System as the primary means of public notification, did acknowledge that the sirens were approximately 40 feet high. FEMA determined that the reduced height of the siren poles does not negatively impact the siren system's coverage. Based on this, and clarifying communications with FEMA (ML22047A231), the deviation does not meet the definition of a significant change as defined in 44 CFR 350.14(b).

Using FEMA's input, the inspectors concluded that, from January to March 2021, the as-built design for 23 of 29 of the siren poles was not in compliance with an approved ANS design report. These changes were made without FEMAs prior approval. However, since the deviation did not meet FEMA's determination criteria of constituting a significant change, it is considered a minor performance deficiency. The issue is being addressed by the licensee in the corrective action program.

Corrective Action Reference: Condition Report

EXIT MEETINGS AND DEBRIEFS

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

On April 6, 2022, the inspectors presented the integrated inspection results to Mr. B. Cox, Site Vice President, and other members of the licensee staff.

On March 28, 2022, the inspectors presented the ANS siren design unresolved item inspection results to Mr. G. Rauch, Manager, Emergency Preparedness, and other members of the licensee staff.

THIRD PARTY REVIEWS The inspectors reviewed Institute on Nuclear Power Operations reports that were issued during the inspection period.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Miscellaneous POL0059 Callaway Energy Center Personnel Support Plan 2

71111.01 Procedures OTO-ZZ-00012 Severe Weather 44

71111.04 Corrective Action Condition Reports 201602500, 201603131, 201707731, 201807138,

Documents 201907023, 201907538

71111.04 Miscellaneous Valve Retest Manual 60

71111.04 Miscellaneous GK-11 Electrical Heat Loads in the Control Building During Normal 5

and ESFAS Conditions Calculation

71111.04 Miscellaneous M-22 MEJ01 Piping and Instrumentation Diagram Residual Heat Removal 62

System - FSAR Figure 5.4-7

71111.04 Procedures ITP-ZZ-00004 Response Time Testing 17

71111.04 Procedures ODP-ZZ-00002 Equipment Status Control 95

71111.04 Procedures OSP-EJ-V001A Train A RHR Valve IST 7

71111.04 Procedures OTN-AL-00001 Auxiliary Feedwater System 38

71111.04 Procedures OTN-BG-00001 Chemical and Volume Control System 57

71111.04 Procedures OTN-NN-00001 120V Vital AC Instrument Power 22

71111.05 Corrective Action Condition Reports 202007887, 202107019, 202200902, 202200905

Documents

71111.05 Miscellaneous Fire Preplan Manual Various

71111.05 Miscellaneous KC-168 Callaway Fire Protection Monitoring Calculation 1

71111.05 Procedures EDP-ZZ-01101 Fire Protection Monitoring Program 30

71111.05 Procedures FFP-ZZ-00009 Fire Protection Training Program 39

71111.05 Procedures OSP-KC-00015 Fire Door Inspections 24

71111.05 Procedures SDP-KC-00001 Requirements for and Duties of Compensatory Fire Watches 12

71111.05 Procedures SDP-KC-00002 Fire Door Position Verification 12

71111.06 Drawings A-2319 Fuel Building Floor Plans 3

71111.06 Drawings M-22KC01 Fire Protection System Piping and Instrumentation Diagram 14

71111.06 Miscellaneous Drill Guides Various

71111.06 Procedures APA-ZZ-00750 Hazard Barrier Program 43

71111.06 Procedures ODP-ZZ-00002 Equipment Status Control 95

71111.11Q Procedures ODP-ZZ-00001 Operations Department - Code of Conduct 108

71111.11Q Procedures ODP-ZZ-00002 Equipment Status Control 95

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.11Q Procedures ODP-ZZ-00014 Operational Mode Change Requirements 56

71111.11Q Procedures OSP-SF-00001 Shutdown Margin Calculations 48

71111.11Q Procedures OSP-SF-00005 Estimated Critical Position Calculation 22

71111.11Q Procedures OTG-ZZ-00002 Reactor Startup - IPTE 64

71111.11Q Procedures OTO-AE-00002 Steam Generator Water Level Control Malfunctions 13

71111.11Q Procedures OTO-BB-00003 RCS Excessive Leakage 27

71111.11Q Procedures OTO-ZZ-00001 Control Room Inaccessibility 48

71111.11Q Procedures OTS-ZZ-00001 Cooldown from Outside the Control Room 10

71111.11Q Procedures T61.08108 Simulator Training Scenario Guide S-2 Cycle 22-1

71111.12 Corrective Action Condition Reports 201504790, 202106661, 2021006768, 202106771,

Documents 202106773, 202106774, 202106780

71111.12 Miscellaneous NUMARC 93-01 Industry Guidelines for Monitoring the Effectiveness of 4F

Maintenance

71111.12 Procedures APA-ZZ-00340, Surveillance Frequency Control Program 3

Appendix 1

71111.12 Procedures APA-ZZ-00500 Corrective Action Program 71 and 75

71111.12 Procedures APA-ZZ-00500, Adverse Condition ADCN-3 42

Appendix 14

71111.12 Procedures APA-ZZ-00549, Guidelines Used to Determine Functional Importance of a 13

Appendix B Component

71111.12 Procedures EDP-ZZ-01128 Maintenance Rule Program 32

71111.12 Procedures EDP-ZZ-01128, Maintenance Rule System Functions 38

Appendix 4

71111.12 Procedures ITP-ZZ-00004 Response Time Testing 17

71111.13 Corrective Action Condition Reports 201207322, 201207612, 201803059, 202000019

Documents

71111.13 Miscellaneous Fire Impairment 29570, GLD Grille Removal 12/16/2021

71111.13 Miscellaneous NUMARC 93-01 Industry Guidelines for Monitoring the Effectiveness of 4F

Maintenance at Nuclear Power Plants

71111.13 Miscellaneous Risk Profile,

January 2 - 8,

22

71111.13 Procedures APA-ZZ-00322, Online Work Integrated Risk Management 22

Appendix F

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.13 Procedures APA-ZZ-01250 Operational Decision Making 18

71111.13 Procedures EDP-ZZ-01128, SSCs in the Scope of the Maintenance Rule at Callaway 11

Appendix 1

71111.13 Procedures ODP-ZZ-00002 Equipment Status Control 95

71111.13 Procedures ODP-ZZ-0002, Risk Management Actions for Planned Risk Significant 17

Appendix 2 Activities

71111.15 Corrective Action Condition Report 202005988, 202200072, 202200366, 202200375,

Documents 202200788, 202200942

71111.15 Miscellaneous 8618-X-94742 Switchyard Relay Panel

71111.15 Miscellaneous GL-19 Auxiliary Building 2026' Cooler Failure GOTHIC Analysis Various

71111.15 Procedures APA-ZZ-00340 Surveillance Program Administration 37

71111.15 Procedures APA-ZZ-00750 Hazard Barrier Program 48

71111.15 Procedures ODP-ZZ-00002 Equipment Status Control 95

71111.15 Procedures OSP-EF-P0001B Essential Service Water Train B Inservice Test 72

71111.18 Corrective Action Condition Reports 101607603, 202001972, 202006423

Documents

71111.18 Procedures APA-ZZ-00115 SAMG Writers Guide 30

71111.19 Corrective Action Condition Reports 19900011, 200503123, 200503150, 201403339,

Documents 202201212, 202201240

71111.19 Miscellaneous E-1061 120V AC Bus Inverter and Swing Inverter

71111.19 Procedures MTE-GK-QC001 Control Room and Class 1E Air Conditioning Unit Charging 13

71111.19 Procedures OTN-EG-00001 Component Cooling Water System 62

71111.19 Procedures OTN-NN-000001, Inverter Inservice Verification

Addendum 1

71111.19 Work Orders 21507708, 20501759

71111.22 Corrective Action Condition Reports 202000691, 2020006986, 202103948, 202106533,

Documents 202200124

71111.22 Miscellaneous M-240 Seismic Qualification

71111.22 Procedures APA-ZZ-00340 Surveillance Program Administration 50

71111.22 Procedures APA-ZZ-00356 Pump & Valve IST Program 28

71111.22 Procedures EDP-ZZ-02222 Vibration Predicative Maintenance Program 25

71111.22 Procedures M-712-00068 Reactor Coolant Pump Manual 45

71111.22 Procedures OSP-EJ-P001A RHR Train A Inservice Test 3

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.22 Procedures OSP-NE-0001A Standby Diesel Generator A Periodic Tests 68

71111.22 Procedures OSP-NE-0001B Standby Diesel Generator B Periodic Tests 69

71111.22 Work Orders 21507645, 21512440, 21511979, 19502238, 21511945

71114.04 Miscellaneous Letter from Request for Assistance to Address a Concern Regarding 11/18/2021

Robert

E. Kahler, Callaway Plant Alert and Notification System Siren Design

Nuclear Change

Regulatory

Commission, to

Bruce

C.

Foreman, Federal

Emergency

Management

Agency

71114.04 Miscellaneous Letter from Callaway Energy Center Alert and Notification System Siren 2/4/2022

Thomas K. Design Change

Warnock, Federal

Emergency

Management

Agency, to

Michael

McCoppin,

Nuclear

Regulatory

Commission

71151 Miscellaneous 2021 NRC Performance Indicator Transmittal Report, First

Quarter

71151 Miscellaneous 2021 NRC Performance Indicator Transmittal Report,

Second Quarter

71151 Miscellaneous 2021 NRC Performance Indicator Transmittal Report, Third

Quarter

71151 Miscellaneous 2021 NRC Performance Indicator Transmittal Report, Fourth

Quarter

71152A Corrective Action Condition Reports 20216981, 202201243

Documents

Inspection Type Designation Description or Title Revision or

Procedure Date

71152A Procedures APA-ZZ-00500 Corrective Action Program 75

71152A Procedures APA-ZZ-00750 Hazard Barrier Program 48

71153 Corrective Action Condition Reports 202200154, 202200163

Documents

71153 Procedures ISF-SB-00A32 SSPS Train B Functional Test 36

71153 Procedures OSP-SB-0001B Reactor Trip Breaker B Trip Actuating Device Operational 20

Test

13