IR 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, Gregory E. Werner, Chief Projects Branch B Division of Operating Reactor Safety Docket No. 05000483 License No. NPF-30 Enclosure:
Inspection Report 05000483/2022001 Signed by Werner, Gregory on 04/26/22
ML22111A360 X SUNSI Review By: DLB ADAMS:
X Yes No Sensitive X Non-Sensitive Non-Publicly Available X Publicly Available Keyword 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
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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
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GEW DATE 4/22/2022 04/22/2022 04/22/2022 4/22/2022 04/26/2022
Enclosure U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number:
05000483
License Number:
Report Number:
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
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 as Described in the Alert and Notification System Report 71114.04 Closed
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.
REACTOR SAFETY
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 and Notification System Report URI 05000483/2021003-01 71114.04
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
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
POL0059
Callaway Energy Center Personnel Support Plan
Procedures
OTO-ZZ-00012
Severe Weather
Corrective Action
Documents
Condition Reports
201602500, 201603131, 201707731, 201807138,
201907023, 201907538
Miscellaneous
Valve Retest Manual
Miscellaneous
GK-11
Electrical Heat Loads in the Control Building During Normal
and ESFAS Conditions Calculation
Miscellaneous
M-22 MEJ01
Piping and Instrumentation Diagram Residual Heat Removal
System - FSAR Figure 5.4-7
Procedures
ITP-ZZ-00004
Response Time Testing
Procedures
ODP-ZZ-00002
Equipment Status Control
Procedures
Procedures
OTN-AL-00001
Auxiliary Feedwater System
Procedures
OTN-BG-00001
Chemical and Volume Control System
Procedures
OTN-NN-00001
20V Vital AC Instrument Power
Corrective Action
Documents
Condition Reports
2007887, 202107019, 202200902, 202200905
Miscellaneous
Fire Preplan Manual
Various
Miscellaneous
KC-168
Callaway Fire Protection Monitoring Calculation
Procedures
EDP-ZZ-01101
Fire Protection Monitoring Program
Procedures
FFP-ZZ-00009
Fire Protection Training Program
Procedures
Fire Door Inspections
Procedures
SDP-KC-00001
Requirements for and Duties of Compensatory Fire Watches
Procedures
SDP-KC-00002
Fire Door Position Verification
Drawings
A-2319
Fuel Building Floor Plans
Drawings
M-22KC01
Fire Protection System Piping and Instrumentation Diagram
Miscellaneous
Drill Guides
Various
Procedures
APA-ZZ-00750
Hazard Barrier Program
Procedures
ODP-ZZ-00002
Equipment Status Control
Procedures
ODP-ZZ-00001
Operations Department - Code of Conduct
108
Procedures
ODP-ZZ-00002
Equipment Status Control
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
ODP-ZZ-00014
Operational Mode Change Requirements
Procedures
Shutdown Margin Calculations
Procedures
Estimated Critical Position Calculation
Procedures
OTG-ZZ-00002
Reactor Startup - IPTE
Procedures
OTO-AE-00002
Steam Generator Water Level Control Malfunctions
Procedures
OTO-BB-00003
RCS Excessive Leakage
Procedures
OTO-ZZ-00001
Control Room Inaccessibility
Procedures
OTS-ZZ-00001
Cooldown from Outside the Control Room
Procedures
T61.08108
Simulator Training Scenario Guide S-2 Cycle 22-1
Corrective Action
Documents
Condition Reports
201504790, 202106661, 2021006768, 202106771,
2106773, 202106774, 202106780
Miscellaneous
Industry Guidelines for Monitoring the Effectiveness of
Maintenance
4F
Procedures
APA-ZZ-00340,
Appendix 1
Surveillance Frequency Control Program
Procedures
APA-ZZ-00500
Corrective Action Program
and 75
Procedures
APA-ZZ-00500,
Appendix 14
Adverse Condition ADCN-3
Procedures
APA-ZZ-00549,
Appendix B
Guidelines Used to Determine Functional Importance of a
Component
Procedures
EDP-ZZ-01128
Procedures
EDP-ZZ-01128,
Appendix 4
Maintenance Rule System Functions
Procedures
ITP-ZZ-00004
Response Time Testing
Corrective Action
Documents
Condition Reports
201207322, 201207612, 201803059, 202000019
Miscellaneous
29570, GLD Grille Removal
2/16/2021
Miscellaneous
Industry Guidelines for Monitoring the Effectiveness of
Maintenance at Nuclear Power Plants
4F
Miscellaneous
Risk Profile,
January 2 - 8,
22
Procedures
APA-ZZ-00322,
Appendix F
Online Work Integrated Risk Management
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
APA-ZZ-01250
Operational Decision Making
Procedures
EDP-ZZ-01128,
Appendix 1
SSCs in the Scope of the Maintenance Rule at Callaway
Procedures
ODP-ZZ-00002
Equipment Status Control
Procedures
ODP-ZZ-0002,
Appendix 2
Risk Management Actions for Planned Risk Significant
Activities
Corrective Action
Documents
Condition Report
2005988, 202200072, 202200366, 202200375,
2200788, 202200942
Miscellaneous
8618-X-94742
Switchyard Relay Panel
Miscellaneous
GL-19
Auxiliary Building 2026' Cooler Failure GOTHIC Analysis
Various
Procedures
APA-ZZ-00340
Surveillance Program Administration
Procedures
APA-ZZ-00750
Hazard Barrier Program
Procedures
ODP-ZZ-00002
Equipment Status Control
Procedures
OSP-EF-P0001B
Essential Service Water Train B Inservice Test
Corrective Action
Documents
Condition Reports
101607603, 202001972, 202006423
Procedures
APA-ZZ-00115
SAMG Writers Guide
Corrective Action
Documents
Condition Reports
19900011, 200503123, 200503150, 201403339,
2201212, 202201240
Miscellaneous
E-1061
20V AC Bus Inverter and Swing Inverter
Procedures
MTE-GK-QC001
Control Room and Class 1E Air Conditioning Unit Charging
Procedures
OTN-EG-00001
Component Cooling Water System
Procedures
OTN-NN-000001,
Addendum 1
Inverter Inservice Verification
Work Orders
21507708, 20501759
Corrective Action
Documents
Condition Reports
2000691, 2020006986, 202103948, 202106533,
2200124
Miscellaneous
M-240
Seismic Qualification
Procedures
APA-ZZ-00340
Surveillance Program Administration
Procedures
APA-ZZ-00356
Pump & Valve IST Program
Procedures
EDP-ZZ-02222
Vibration Predicative Maintenance Program
Procedures
M-712-00068
Reactor Coolant Pump Manual
Procedures
RHR Train A Inservice Test
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Standby Diesel Generator A Periodic Tests
Procedures
Standby Diesel Generator B Periodic Tests
Work Orders
21507645, 21512440, 21511979, 19502238, 21511945
Miscellaneous
Letter from
Robert
Nuclear
Regulatory
Commission, to
Bruce C.
Foreman, Federal
Emergency
Management
Agency
Request for Assistance to Address a Concern Regarding
Callaway Plant Alert and Notification System Siren Design
Change
11/18/2021
Miscellaneous
Letter from
Thomas K.
Warnock, Federal
Emergency
Management
Agency, to
Michael
McCoppin,
Nuclear
Regulatory
Commission
Callaway Energy Center Alert and Notification System Siren
Design Change
2/4/2022
71151
Miscellaneous
21 NRC Performance Indicator Transmittal Report, First
Quarter
71151
Miscellaneous
21 NRC Performance Indicator Transmittal Report,
Second Quarter
71151
Miscellaneous
21 NRC Performance Indicator Transmittal Report, Third
Quarter
71151
Miscellaneous
21 NRC Performance Indicator Transmittal Report, Fourth
Quarter
Corrective Action
Documents
Condition Reports
216981, 202201243
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
APA-ZZ-00500
Corrective Action Program
Procedures
APA-ZZ-00750
Hazard Barrier Program
Corrective Action
Documents
Condition Reports
2200154, 202200163
Procedures
SSPS Train B Functional Test
Procedures
Reactor Trip Breaker B Trip Actuating Device Operational
Test
20