IR 05000483/2024002
| ML24198A046 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 07/18/2024 |
| From: | Greg Werner NRC/RGN-IV/DORS/PBB |
| To: | Diya F Ameren Missouri |
| References | |
| IR 2024002, IR 2024001 | |
| Download: ML24198A046 (28) | |
Text
July 18, 2024
SUBJECT:
CALLAWAY PLANT AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION - INTEGRATED INSPECTION REPORT 05000483/2024002 AND 07201045/2024001
Dear Fadi Diya:
On June 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Callaway Plant. On July 10, 2024, the NRC inspectors discussed the results of this inspection with K. Scott, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
Two findings of very low safety significance (Green) are documented in this report. These findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations 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 the 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 the 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, Gregory E. Werner, Chief Reactor Projects Branch B Division of Operating Reactor Safety Docket Nos. 05000483, 07201045 License No. NPF-30
Enclosure:
As stated
Inspection Report
Docket Number:
05000483 and 07201045
License Number:
Report Number:
05000483/2024002 and 07201045/2024001
Enterprise Identifier:
I-2024-002-0008 and I-2024-001-0015
Licensee:
Ameren Missouri
Facility:
Callaway Plant and Independent Spent Fuel Storage Installation
Location:
Steedman, MO
Inspection Dates:
April 1 to June 30, 2024
Inspectors:
B. Baca, Health Physicist
L. Brookhart, Senior Spent Fuel Storage Inspector
N. Brown, Resident Inspector
J. Freeman, Spent Fuel Storage Inspector
J. Melfi, Project Engineer
D. Proulx, Senior Project Engineer
S. Schwind, Senior Resident Inspector
E. Simpson, Nuclear Systems Scientist
Approved By:
Gregory E. Werner, Chief
Reactor 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
Failure to Provide Adequate Work Instructions for Performing Maintenance on the Standby Diesel Generator Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000483/2024002-01 Open/Closed
[H.1] -
Resources 71111.15 The inspectors reviewed a self-revealed Green finding and associated non-cited violation of Technical Specification 5.4.1.a for the licensees failure to have an adequate maintenance procedure as required by Regulatory Guide 1.33, Quality Assurance Program Requirements, revision 2, February 1978. Specifically, licensee work instruction PM1000121, revision 1, did not adequately provide the level of detail required to ensure jacket water bolting was torqued to the correct value during restoration from maintenance in refueling outage 25 resulting in the bolts being found loose during a January 2024 maintenance outage.
Failure to Take Timely Corrective Action for Nonconservative Technical Specifications Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000483/2024002-02 Open/Closed
[H.1] -
Resources 71152A The inspectors identified a finding and associated Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to promptly correct a condition adverse to quality regarding technical specification surveillance acceptance criteria. Specifically, from 2006 to June 2024, Technical Specification 3.8.1, AC Sources - Operating, and Technical Specification 3.8.2, AC Sources - Shutdown, contained surveillance acceptance criteria for diesel generator steady state frequency that were not justified by analysis.
Additional Tracking Items
None.
PLANT STATUS
The Callaway Plant began the inspection period at 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, 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 high temperatures for the ultimate heat sink cooling tower and control building heating ventilation and air conditioning systems on June 27, 2024.
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending thunderstorms on May 7, 2024.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)diesel-driven fire pumps on April 22, 2024 (2)safety injection system train A partial alignment on April 23, 2024
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the control room envelope on June 24, 2024.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 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)diesel-and electric-driven fire pumphouse on April 23, 2024 (2)essential service water pumphouse, fire areas UNPH and USPH, on April 24, 2024 (3)engineered safety features A switchgear room number 1, fire area C-9, on April 2, 2024 (4)engineered safety features B switchgear room number 2, fire area C-10, on April 2, 2024 (5)component cooling water pump and heat exchanger area A, room 1406, on June 20, 2024
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the onsite fire brigade training and performance during an unannounced fire drill on April 9, 2024.
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
(1)train B class 1E switchgear room air conditioning unit essential service water heat exchanger SGK05B on April 15, 2024
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 surveillance testing and routine operations on June 20, 2024.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated staff crew A emergency preparedness drill and exercise performance indicator scenario on May 23, 2024.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:
(1)safety injection train B system on April 24, 2024
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)diesel-driven fire pump A and electric-driven fire pump outage on April 22, 2024 (2)risk mitigation activities during increased turbine trip risk activities on April 30, 2024 (3)planned maintenance on emergency diesel generator train A and essential service water train A on May 9, 2024 (4)turbine-driven auxiliary feedwater pump maintenance outage on June 13, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
(1)component cooling water isolation valve EGHV0069B on April 11, 2024 (2)emergency diesel generator A operability on April 30, 2024 (3)valve EGHV0016, train B component cooling water supply/return isolation valve flange bolts not torqued to required value on May 22, 2024
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
(1)temporary power installed in 480 volt load center for fire pumphouse on April 22-23, 2024
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (4 Samples)
(1)emergency diesel generator B post-maintenance test after exhaust leak repairs on April 4, 2024 (2)480 VAC NGO1 breakers on April 10, 2024 (3)essential service water train B post-maintenance test on April 4, 2024 (4)emergency diesel generator A testing following maintenance on May 9, 2024
Surveillance Testing (IP Section 03.01) (4 Samples)
(1)emergency diesel generator A monthly surveillance on April 10, 2024 (2)control rod partial movement on May 3, 2024 (3)residual heat removal pump B on June 14, 2024 (4)safety injection trains A and B signal slave relay testing on June 20, 2024
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
(1)essential service water pump A inservice test on April 23,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.
Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
(1)radiation workers exiting the radiologically controlled area and monitoring personal items with the tool equipment monitors (2)demobilizing and packaging equipment from the dry spent fuel campaign under radiation work permit (RWP) 24DFSDEMOBE, "Demobilize Dry Fuel Storage Equipment," revision 0
Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
(1)decontamination of dry spent fuel tools, equipment, and components under RWP CEC03CLOSE, "2024 Dry Fuel Storage Campaign-CEC03: Remove HI-TRAC from cask loading pit, decontaminate, close & prepare multipurpose canister (MPC)for movement CEC-03," revision 0 (2)demobilizing and packaging equipment from the dry spent fuel campaign under RWP 24DFSDEMOBE, "Demobilize Dry Fuel Storage equipment," revision 0 (3)dry spent fuel canister closure which included welding under RWP CEC03CLOSE, "2024 Dry Fuel Storage Campaign-CEC03: Remove HI-TRAC from cask loading pit, decontaminate, close & prepare MPC for movement CEC-03," revision 0 (4)dry spent fuel canister transfer to the UMAX storage under RWP CEC03TRAN, "2024 Dry Fuel Storage Campaign-CEC03: Move loaded HI-TRAC from Cask Wash Down Pit to Hi-Storm UMAX, Including Download CEC-03," revision 0 High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (5 Samples)
The inspectors evaluated licensee controls of the following high radiation areas (HRAs) and very high radiation areas:
(1)containment personnel hatch - locked HRA (2)radwaste drumming station (room 7213) - locked HRA (3)radwaste valve room (room 7220) - locked HRA (4)cask washdown pit containing MPC - HRA (5)radioactive material (spent resin) locked storage container - HRA 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.
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.
External Dosimetry (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.
Internal Dosimetry (IP Section 03.03) (1 Sample)
The inspectors evaluated the following internal dose assessments:
- (1) six personnel contamination events since the previous inspection period
Special Dosimetric Situations (IP Section 03.04) (2 Samples)
The inspectors evaluated the following special dosimetric situations:
(1)three dose assessments for workers declared pregnant (2)nine extremity dose assessment evaluation for multipack dosimetry assignments made for RWP R26CAVDECON, "Cavity Decontamination Activities"
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===
- (1) April 2023 through March 2024
MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)
- (1) April 2023 through March 2024
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) July 1 through March 31, 2023 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) July 1 through March 31, 2023
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)damaged hypoid gear in actuator for valve EMHV8821A (condition report 202401656)
(2)nonconservative values in Technical Specifications (TSs) 3.8.1 and 3.8.2 (condition report 200603324)
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors performed a review of the negative trend in the quality assurance records program.
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Follow Up (IP Section 03.01)
- (1) The inspectors evaluated the automatic turbine-driven auxiliary feedwater pump actuation on March 29, 2024.
- (2) The inspectors evaluated the invalid actuation of automatic turbine-driven auxiliary feedwater pump on March 29,
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
===60855 - Operation of an ISFSI The inspectors performed a review of the licensees independent spent fuel storage installation (ISFSI) activities to verify compliance with requirements of the Certificate of Compliance 72-1040, license amendment 0, the HI-STORM UMAX FSAR revision 2, and HI-STORM FW FSAR revision 3. The inspectors reviewed selected procedures, corrective action reports, and records to verify ISFSI operations were compliant with the certificate's TSs, requirements in the Final Safety Analysis Report, and NRC regulations.
Operation Of An ISFSI===
- (1) The inspectors evaluated the licensees dry cask storage operations, from May 13 through May 17, 2024, during an on-site inspection. The Callaway ISFSI is located within the Part 50 reactor's protected area. The UMAX ISFSI vault was designed to hold 48 MPCs, each with 37 spent fuel assemblies (MPC-37). At the time of the routine loading inspection, the Callaway UMAX ISFSI contained a total of 36 canisters, and the licensee was in the process of loading and processing the 37th canister in the spent fuel building.
During the on-site inspection, the inspectors evaluated and observed the following activities:
- walk-down of the ISFSI haul path
- welding and non-destructive testing of the lid-to-shell weld
- processing of the spent nuclear fuel for storage, including bulk water removal, forced helium dehydration, and helium backfill operations
- final sealing of the canister, including welding of the vent and port cover plates, non-destructive testing, and helium leak-testing
- heavy load lifts using the cask handling crane to remove the transfer cask with the loaded canister from the canister processing area to the HI-PORT
- transportation of the 37th canister on the vertical cask transporter from the spent fuel building to the ISFSI using the HI-PORT
- heavy load lifts to transfer the MPC-37 from the transfer cask to the vertical ventilated module The inspectors reviewed and evaluated the following documentation during the inspection:
- fuel selection evaluations for the canisters loaded since the last NRC ISFSI inspection, the inspectors reviewed the contents of canisters 26-37 against the license's TSs for approved contents
- radiation surveys for dose at the owner-controlled boundary to verify compliance with the requirements of 10 CFR 72.104 for calendar years 2021, 2022, and 2023
- quality assurance program implementation, including recent quality assurance audits, surveillances, receipt inspection, and quality control activities related to ISFSI operations
- compliance to TSs for operational surveillance activities and Final Safety Analysis Report required annual maintenance activities
- documentation of annual maintenance activities for the sites cask handling crane, vertical cask transporter, and special lifting devices
- selected licensee design changes and program changes to the ISFSI performed under the site's 10 CFR 72.48 program
- changes made by the licensee in the site's 10 CFR Part 72.212 evaluation report from revision 5 to revision
INSPECTION RESULTS
Failure to Provide Adequate Work Instructions for Performing Maintenance on the Standby Diesel Generator Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000483/2024002-01 Open/Closed
[H.1] -
Resources 71111.15 The inspectors reviewed a self-revealed Green finding and associated non-cited violation of TS 5.4.1.a for the licensees failure to have an adequate maintenance procedure as required by Regulatory Guide 1.33, Quality Assurance Program Requirements, revision 2, February 1978. Specifically, licensee work instruction PM1000121, revision 1, did not adequately provide the level of detail required to ensure jacket water bolting was torqued to the correct value during restoration from maintenance in refueling outage 25 resulting in the bolts being found loose during a January 2024 maintenance outage.
Description:
On January 18, 2024, during a maintenance window, a worker identified three loose bolts on the train A standby diesel generator jacket water cooling system piping flange.
The standby diesel generator jacket water cooling system is designed to provide cooling to the diesel cylinders and turbo chargers to ensure proper operation during the diesel generators 7-day mission time following a design basis accident.
The licensee stopped work, reinstalled the bolts, and performed an extent of condition walkdown on the train A and B standby diesel generators looking for loose bolting on the jacket water cooling piping. The walkdown did not identify any other loose bolts on the train A or B generators. A review of previously performed surveillance tests did not identify any leakage from the jacket water flange. The licensees review of the plant computer point associated with the jacket water makeup valve, KJZ0067, which would have actuated should there have been a leak in the jacket water cooling system, did not show any actuation since coming out of refueling outage 26 during the fall of 2023.
The licensee initiated condition report 202400391 and investigated how the bolts could have backed out. They identified that the last time the bolts were manipulated during maintenance was during refueling outage 25 in the spring of 2022. A review of the work instruction, PM1000121, Change Upper & Lower WTR HDR O-Rings & Jumper O-Rings, revision 1, found that the bolts were torqued to wrench tight. The Fairbanks Morse Generator Manual, M-018-00309, revision 155, contains a torque table for various metric thread diameters.
Based on the size of the bolting, M 12 x 1.75, the correct torque value for the bolts was 30-35 ft. lbs. The licensee identified that the lack of actual torque values in work instruction PM1000121 was the probable cause of the bolts backing out of the threaded fasteners.
Corrective Actions: The licensee reinstalled the bolts with thread locking compound, as allowed by Bolting Manual, revision 20, and torqued the bolts to the value specified in vendor manual M-018-00309. A revision to work instruction PM1000121, Change Upper & Lower WTR HDR O-Rings & Jumper O-Rings, was also made to include the torque values from the vendor manual and the use of thread locking compound.
Corrective Action References: The licensee entered these issues into the corrective action program with condition report 202400391.
Performance Assessment:
Performance Deficiency: The failure to provide adequate work instructions for performing maintenance on the standby diesel generator A was a performance deficiency.
Screening: The inspectors determined that the performance deficiency was more than minor because it was associated with the procedure quality 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, failure to include the vendor specified torque value for the standby diesel generator jacket water cooling bolts resulted in the bolts disengaging.
Significance: The inspectors assessed the significance of the finding using IMC 0609 appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined the finding impacted mitigating systems and used exhibit 2 to evaluate the condition. The finding was determined to be of very low safety significance (Green)because it
- (1) was not a deficiency affecting design or qualification of a mitigating system,
- (2) does not represent a loss of the probability risk analysis (PRA) function of a single train TS system for greater than allowed outage time,
- (3) does not represent a loss of PRA function of one train of a multi-train TS system for greater than its allowed outage time,
- (4) does not represent a loss of the PRA function of two separate TS systems for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,
- (5) does not represent a loss of PRA system and/or function as defined by the plant risk information e-book or the licensees PRA for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and
- (6) does not result in the loss of a high safety-significant, non-TS train for greater than 3 days.
Cross-Cutting Aspect: Human Performance, H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety. Specifically, the licensees procedure was inadequate to ensure the jacket water flange bolts did not back out.
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 work instruction, PM1000121, Change Upper &
Lower WTR HDR O-Rings & Jumper O-Rings, Revision 1, in part, to meet this requirement.
Contrary to the above, work instruction PM1000121 which was performed on, April 27, 2022, failed to include adequate instructions for the torquing of the train A standby diesel generator jacket water cooling flange bolts. As a result, the bolts were found loose during maintenance in January 2024.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.
Failure to take Timely Corrective Action for Nonconservative Technical Specifications Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000483/2024002-02 Open/Closed
[H.1] -
Resources 71152A The inspectors identified a finding and associated Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to promptly correct a condition adverse to quality regarding technical specification surveillance acceptance criteria. Specifically, from 2006 to June 2024, Technical Specification 3.8.1, AC Sources - Operating, and Technical Specification 3.8.2, AC Sources - Shutdown, contained surveillance acceptance criteria for diesel generator steady state frequency that were not justified by analysis
Description:
In 1993, Westinghouse issued Nuclear Safety Advisory Letter NSAL 93-1907 to inform licensees that the standard TSs for diesel generator test frequencies in TS 3.8.1 (i.e. 58.8 to 61.2 Hz) were just reference values and were not justified by analysis. The NSAL noted that the lower end of the limit, 58.8 Hz, was not sufficient to support assumed flowrates of safety-related equipment powered by the diesel generators, and recommended this TS be changed to require frequencies from 60-61.2 Hz. When the licensee received this letter, they scheduled a periodic preventive maintenance item to verify diesel generator frequencies were greater than 60 Hz and closed the issue. The TS was not amended, and the periodic surveillance procedures were not revised to reflect the new criteria.
On April 27, 2006, the licensee received an operating experience notification concerning another facility that identified that the diesel generator surveillance frequency limits specified in the TS were nonconservative because they also used the reference values of 58.8 to 61.2 Hz rather than having acceptance criteria justified by analysis. It was also noted that the vendor had recommended acceptance criteria greater than 60 Hz to meet the assumed flowrates of the safety analysis. The licensee initiated condition report 200603324 to place this item into the corrective action program.
The licensees initial response was to follow the guidance of Administrative Letter 98-10, Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety, which was applicable at the time. This guidance stated that upon discovery that a TS was not sufficient to assure plant safety, the licensee should immediately impose administrative limits in plant procedures to assure safety as an interim measure, then promptly submit a license amendment request (LAR) to correct the condition in accordance with 10 CFR Part 50, appendix B, criterion XVI. The administrative letter gave two examples where licensees had inadequate responses to a nonconservative TS, in which the licensees took over an operating cycle (18 months) to resolve the deficient TS.
The licensee noted that TS surveillance requirement (SR) 3.8.1.2 (monthly surveillance),
TS SR 3.8.1.11 (18 months) and TS SR 3.8.1.19 (18 months) required the licensee to verify that the diesel generators maintain steady state frequencies of 58.8 to 61.2 Hz following fast starts. The licensee took action to revise procedure OSP-SA-2413A[B], Train A [B] Diesel Generator and Sequencer Testing, the 18-month surveillance tests, to include the administrative limits for frequency prescribed by the vendor of 60 to 61.2 Hz. The licensee did not revise the monthly surveillance procedure since it required the diesel generator to be synchronized to and follow grid frequency which would not indicate health of the diesel generator. The licensee took the position that the TS SR limits on steady state frequency only applied to the fully loaded condition when synchronized to the grid, and not when unloaded.
After imposing administrative controls, the licensee drafted LAR OL-1271 to correct TS SRs 3.8.1.2, 3.8.1.11, and 3.8.1.19 to implement the more restrictive acceptance range of diesel generator frequency to 60 to 61.2 Hz. During a meeting with operations, engineering, licensing, and quality assurance management to review the LAR, the licensee determined not to submit the LAR due to concerns about potential operability issues and/or the increased potential for TS noncompliance that could be introduced by changing the minimum required steady-state frequency to greater than or equal to 60 Hz. There was no discussion as to whether the current TS represented safe operation. Engineering was directed to find an alternate approach. In 2009, the licensee closed the corrective action to revise the TS because inadequate diesel generator TS was considered an industry issue. No additional actions were taken until 2015, when the licensee reopened the corrective action to amend the nonconservative TS.
In 2015, the licensee noted that Westinghouse had developed WCAP-17398-NP in 2012, which included a calculation methodology to precisely calculate the acceptable voltage and frequency to maintain adequate emergency core cooling flows post-accident. The NRC provided a safety evaluation report in February 2016. The licensee further delayed implementation of an amendment to TS 3.8.1 until Westinghouse was ready to issue a generic TS frequency change for diesel generators, and thus did not develop an LAR.
In 2017, the licensee updated condition report 200603324 to further extend the completion of revising the TS, with the statement that there was a risk that the next NRC comprehensive design basis inspection may identify the issue. Further entries indicated that licensee was waiting for an industry solution to the issue.
On April 25, 2024, while reviewing the morning leadership package, the inspectors noted that the licensee had an entry under open operability determinations titled Technical Specifications 3.8.1 and 3.8.2 are Nonconservative, referencing condition report 200603324 with a forecast closure date of 2026. The inspectors noted that Regulatory Guide 1.239, Licensee Actions to Address Nonconservative Technical Specifications, states the following:
Occasionally, licensees have determined that the TS may be nonconservative. Examples include, but are not limited to, an improper or inadequate TS value, required action, or completion time. When this occurs, in the interim, licensees typically enter the nonconservative TS into their corrective action program, conduct an evaluation, and, if necessary, institute administrative controls that instruct the operators to maintain a more restrictive value for a particular parameter or to take a more conservative action. Following the implementation of such administrative controls, most licensees have properly considered reporting under 10 CFR 50.72, 10 CFR 50.73, or both and have promptly submitted a license amendment request to correct the TS. However, some licensees have failed to comply with NRC reporting requirements, significantly delayed submitting a license amendment request to correct the TS, or improperly concluded that a license amendment request was unnecessary if administrative controls are implemented.
Regulatory Guide 1.239 also superseded Administrative Letter 98-10 and endorsed the guidance of NEI 15-03 Licensee Actions to Address Nonconservative Technical Specifications. The guidance of NEI 15-03 repeated the actions of NRC Administrative Letter 98-10, that, upon identification of a nonconservative TS, licensees should implement administrative controls on a short-term interim basis, and promptly submit a license amendment. It also states that the generic nature of a nonconservative TS does not alleviate the licensees responsibility to promptly correct their TS. The NEI guidance also contains an example of a violation of 10 CFR Part 50, appendix B, criterion XVI, in which a licensee waited 5 years to correct a nonconservative TS related to diesel generator frequency.
Since the licensee had not corrected the diesel generator TS 3.8.1 frequency range for over 18 years, the inspectors concluded that was not timely corrective action, and thus a violation of 10 CFR Part 50, appendix B, criterion XVI.
Corrective Actions: The licensee initiated a condition report to enter this item into the corrective action program and plan to submit a license amendment request in the last quarter of 2024.
Corrective Action References: Condition Report 200603324.
Performance Assessment:
Performance Deficiency: The licensees failure to promptly correct a condition adverse to quality was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the design control 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 was associated with failure to correct nonconservative TSs that would allow diesel generator operation outside the bounds of the safety analysis.
Significance: The inspectors assessed the significance of the finding using IMC 0609 appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined the finding impacted mitigating systems and used exhibit 2 to evaluate the condition. The finding was determined to be of very low safety significance (Green)because it was a deficiency affecting the design of a mitigating system and the emergency diesel generator maintained its probabilistic risk assessment functionality.
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.
Specifically, the licensee did not commit the resources to promptly correct the inadequate TSs. Although the initial performance deficiency occurred greater than three years prior, the condition continues until the TSs are corrected.
Enforcement:
Violation: Title 10 of CFR Part 50, Appendix B, Criterion XVI, Corrective Action, states, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected.
Contrary to the above, from April 14, 2006, to June 30, 2024, a condition adverse to quality was not promptly corrected. Specifically, in April 2006, the licensee was informed that TS SRs 3.8.1.2, 3.8.1.11 and 3.8.1.19 were nonconservative because the acceptance criteria of 58.8 to 61.2 Hz for diesel generator frequency was not justified by analysis and should be 60 to 61.2 Hz. However, the licensee had not taken action to correct the nonconservative TSs as of June 2024.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: The inspectors performed a review of the negative trend in the quality assurance records program.
71152S The inspectors performed a review of the of potential adverse trends in the licensees corrective action program with emphasis on the implementation of the licensees quality assurance record program. Inspectors sampled a population of condition reports during the period of January 1 through June 30, 2024. Based on the samples reviewed, the inspectors identified a negative trend in the quality assurance records program associated with 11 condition reports regarding missing or incomplete records, improper record storage, and missing timeliness deadlines for record retention. The inspectors discussed this trend with the licensee, and they initiated condition report 202404599 to address the negative trend.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On July 10, 2024, the inspectors presented the integrated inspection results to K. Scott, Site Vice President, and other members of the licensee staff.
- On June 27, 2024, the inspectors presented the occupational radiation safety inspection results to K. Scott, Site Vice President, and other members of the licensee staff.
- On May 16, 2024, the inspectors presented the ISFSI inspection results to W. Witt, Senior Director Nuclear Operations, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
60855
Corrective Action
Documents
2300487
Regarding Holtec Certificate of Compliance (CoC) 1040
Amendment 0, Revision 1
60855
Engineering
Changes
2.48-1597
Aluminum basket shim for HI-STORM FW
60855
Engineering
Changes
2.48-1608
Change in HI-STORM UMAX FSAR computer model
program
60855
Miscellaneous
CFR 72.212
Evaluation Report
Callaway Plant,
Unit 1
Dry Fuel Storage System for Spent Nuclear Fuel Docket
Number 72-1045
60855
Miscellaneous
HGMPC0001
Loading Plan
Loading plan for Canister HGMPC0001
60855
Miscellaneous
HI-STORM FW
Final safety analysis report for FW system
60855
Miscellaneous
Holtec 1040 HI-
STORM UMAX
Final safety analysis report for HI-STORM UMAX
60855
Miscellaneous
Holtec 1040
UMAX License
Certificate of Compliance No. 1040 for the HI-STORM
UMAX cask storage system
60855
Procedures
HSP-366
HI-TRAC Lift Lugs inspection
60855
Procedures
HSP-720
Inspection of Horizontal Lift beam, lift links, and downloader
components for ASME B30.2 requirements
60855
Procedures
Control Room Shift and Daily Log Readings and Channel
Checks
60855
Procedures
Vent Surveillance
Documentation of Technical Specification requirements for
requested dates
60855
Radiation
Surveys
ISFSI Pad Survey
Survey CA-M-20240222-4 Semi Annual ISFSI Pad Survey
60855
Radiation
Surveys
ISFSI Posted
OSL Data
Verify compliance with 10 CFR 72.104 requirements.
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
60855
Self-Assessments
Dry Cask Storage
Surveillance
SP23005 Letter to
File
QA surveillance
60855
Self-Assessments Nuclear Oversight
Audit of Dry Fuel
Storage AP21005
Dry Fuel Storage program QA audit
60855
Work Orders
JOB 21500410-
500
Annual inspection of large overhead cask handling crane
meeting ASME B30.2 requirements
2/14/2023
Corrective Action
Documents
Condition Reports
2400283, 202402233, 202402961
Procedures
APA-ZZ-00322,
Appendix B
Work Week Schedule and Execution
Procedures
OTO-ZZ-00012
Severe Weather
Procedures
PDP-ZZ-00027
Seasonal Readiness Program
Work Orders
Jobs
17001890, 17004923, 19003303, 19004768
Corrective Action
Documents
Condition Reports
202207673, 202208438, 202302688, 202307412,
2401673, 202403710
Procedures
APA-ZZ-00703
Fire Protection Operability Criteria and Surveillance
Requirements
Procedures
EDP-ZZ-01012
Control Room Envelope Habitability Program
Procedures
EDP-ZZ-04107
HVAC Pressure Boundary Control
Procedures
OTN-EM-00001
Safety Injection System
Procedures
OTN-EM-00001,
CL0002
Safety Injection System Outside Containment Valve Lineup
Calculations
KC-51
Detailed Fire Modeling Report, Fire Compartment A-16
Calculations
KC-96
Fire Safety Analysis Calculation, Fire Area A-16
Miscellaneous
Fire Preplan Manual
Miscellaneous
T210.0001
Training Scenario Fire Drill Number 24-1
Procedures
OTO-KC-00001,
Addendum C-10
Control Building South Engineered Safety Features
Switchgear Room
Procedures
OTO-KC-00001,
Addendum C-9
Control Building North Engineered Safety Features
Switchgear Room
Corrective Action
Condition Reports
2302663, 202303127, 202304836, 202309038,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
2402779
Miscellaneous
Heat Exchanger Inspection Report
04/15/2024
Procedures
EDP-ZZ-01112
Heat Exchanger Predictive Performance Manual
Work Orders
Jobs
251680, 235000870
Miscellaneous
Emergency Preparedness LOCT cycle 24-3 DEPI on
May 23, 2024
05/06/2024
through
06/21/2;024
Procedures
APA-ZZ-00003
Shift Relief and Turnover
Procedures
ODP-ZZ-00001,
Addendum 1
Annunciator Response
Procedures
ODP-ZZ-000011
Control Room Decorum
Procedures
Safety Injection System Train B Valve Inservice Test
Work Orders
Jobs
20505514, 23002819, 21505329, 18504363, 22511757,
2004100, 205106820
Miscellaneous
Daily Site Risk Assessment
6/11/2024
through
6/13/2024
Miscellaneous
Shift Managers Operational Focus Items
6/11/2024
through
6/13/2024
Miscellaneous
Shift Managers Operational Focus Items
04/30/2024
Miscellaneous
Daily Site Risk Assessment
04/30/2024
Miscellaneous
2050029
Risk Assessment for Fire Pump Outage
04/23/2024
Miscellaneous
Requests for
Resolution
06316A, 014080B, 240111
Procedures
APA-ZZ-00315
Risk Management Programs
Procedures
APA-ZZ-00315
Appendix B
Technical Specification Risk Assessments
Procedures
APA-ZZ-00315
Appendix C
Risk Management Actions
Procedures
APA-ZZ-00315,
Appendix A
Configuration Risk Management Program - Online
and 4
Procedures
APA-ZZ-00750
Hazard Barrier Program
Work Orders
Jobs
18001564, 22512274
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Condition Reports
2401648, 202403190, 202403496
Procedures
APA-ZZ-00801
Procedures
CTP-SJ-01102
Auxiliary Building Sample Station (SJ-143) Operation
Procedures
KDP-ZZ-00013
Emergency Response Facility and Equipment Evaluation
Procedures
APA-ZZ-00605
Temporary System Modifications
045
Work Orders
Job
20500029.270
Install Temporary Power to CPKC1002A AND CPKC1002B
Work Orders
WPA 115357
Install Temporary Power to CPKC 1002A and CPKC 1002B
04/18/2024
Corrective Action
Documents
Condition Reports
2402529, 202402598, 202402599, 202402614,
2404220
Procedures
ITM-SF-00006
CRD Current Trace Testing
Procedures
ODP-ZZ-00008
Nitrogen Monitoring Required in Both A and B Emergency
Diesel Generator Rooms While Diesel Running
Procedures
RHR Train B Inservice Test - Group A
Procedures
Standby Diesel Generator A Periodic Tests
Procedures
Train A SIS Slave Relay Test
Procedures
Train B SIS Slave Relay Test
Procedures
Control Rod Partial Movement
Procedures
OTS-SF-00001
Control Road Repositioning
Work Orders
Jobs
24502791, 19507533, 19507535, 22513159, 24500629,
24500650, 24503681, 24504110, 18001654.911, 18004031,
20505498, 21000903, 22510721, 22512340, 23001676,
24501210
ALARA Plans
24-ISFSI Project
24 Dry Fuel Storage Campaign ALARA Plan
3/11/2024
Procedures
HDP-ZZ-01200
Radiation Work Permits
Procedures
HDP-ZZ-01500
Radiological Postings
Procedures
HDP-ZZ-03000
Radiological Survey Program
Procedures
HDP-ZZ-03000
APPB
Performing Radiation Surveys
Procedures
HDP-ZZ-03000
APPC
Performing Contamination Surveys
Procedures
HDP-ZZ-03000
Spent Fuel Storage Cask Surveys
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
APPH
Procedures
HDP-ZZ-06000
Contamination Control and Alpha Monitoring Program
Radiation
Surveys
CA-M-20240513-
24 DFS CEC 01 MPC 317 Survey Moving to Cask
Washdown Pit
05/13/2024
Radiation
Surveys
CA-M-20240513-
24 DFS CEC 01 MPC 317 Decon/Downpost CA of Hi-
Trac/MPC in Cask Washdown Pit
05/13/2024
Radiation
Surveys
CA-M-20240513-
24 DFS CEC 01 MPC 317 Annulus Technical
Specification
05/13/2024
Radiation
Surveys
CA-M-20240513-
24 DFS CEC 01 MPC 317 Cask Washdown Pit MPC/Hi-
Trac Lower Pit Pre/Post Decon Survey
05/13/2024
Radiation
Surveys
CA-M-20240514-
24 DFS Fuel Building 2026-foot Cask Washdown Pit Post
Blowdown Survey (CEC 01 MPC 317)
05/14/2024
Radiation
Surveys
CA-M-20240514-
24 DFS ROVA Removal/Post Shielding Removal (CEC 01
MPC 317)
05/14/2024
Radiation
Surveys
CA-M-20240515-
24 DFS Technical Specification (CEC 01 MPC 317)
05/15/2024
Radiation
Surveys
CA-M-20240515-
24 DFS CEC 01 MPC 317 Technical Specification
05/15/2024
Radiation
Surveys
CA-M-20240515-
24 DFS CEC 01 MPC 317 ISFSI Mating Device
05/15/2024
Radiation
Surveys
CA-M-20240520-
24 DFS CEC 02 MPC 318 Survey Moving to Cask
Washdown Pit
05/20/2024
Radiation
Surveys
CA-M-20240520-
24 DFS CEC 02 MPC 318 Post Blowdown/Gross Dewater
Survey
05/21/2024
Radiation
Surveys
CA-M-20240520-
24 DFS CEC 02 MPC 318 Annulus Technical
Specification
05/20/2024
Radiation
Surveys
CA-M-20240520-
24 DFS CEC 02 MPC 318 Decon/Downpost CA of Hi-
Trac/MPC in Cask Washdown Pit
05/20/2024
Radiation
Surveys
CA-M-20240522-
24 DFS CEC 02 MPC 318 Hi-Trac Top View-RVOA
Removal
05/22/2024
Radiation
Surveys
CA-M-20240523-
24 DFS CEC 02 MPC 318 Technical Specification
05/22/2024
Radiation
Surveys
CA-M-20240523-
24 DFS CEC 02 MPC 318 Technical Specification
05/23/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Radiation
Surveys
CA-M-20240523-
24 DFS CEC 02 MPC 318 - ISFSI Mating Device/Hi-Trac
Lid
05/23/2024
Radiation
Surveys
CA-M-20240526-
24 DFS CEC 03 MPC 319 Decon/Downpost CA of Hi-
Trac/MPC in Cask Washdown Pit
05/26/2024
Radiation
Surveys
CA-M-20240527-
24 DFS CEC 03 MPC 319 Survey Moving to Cask
Washdown Pit
05/27/2024
Radiation
Surveys
CA-M-20240527-
24 DFS CEC 03 MPC 319 Annulus Technical
Specification
05/27/2024
Radiation
Surveys
CA-M-20240528-
24 DFS CEC 03 MPC 319 Cask Washdown Pit Post
Blowdown Survey
05/27/2024
Radiation
Surveys
CA-M-20240528-
24 DFS Technical Specification CEC 03 MPC 319
05/28/2024
Radiation
Surveys
CA-M-20240529-
24 DFS CEC 03MPC 319 ROVA Removal/Post Shielding
Removal
05/29/2024
Radiation Work
Permits (RWPs)
24DFSDEMOBE
Demobilize and store DFS equipment which includes
disassembly, decontamination support, RP coverage and
storage activities
Radiation Work
Permits (RWPs)
24DFSHCA
Decon activities on HI-TRAC Annulus Area
Radiation Work
Permits (RWPs)
CEC01CLOSE
24 DRY FUEL STORAGE CAMPAIGN CEC-01: Remove
HI-TRAC from cask loading pit, decontaminate, close &
prepare MPC for movement CEC-01
Radiation Work
Permits (RWPs)
CEC02CLOSE
24 DRY FUEL STORAGE CAMPAIGN CEC-02: Remove
HI-TRAC from cask loading pit, decontaminate, close &
prepare MPC for movement CEC-02
Radiation Work
Permits (RWPs)
CEC03CLOSE
24 DRY FUEL STORAGE CAMPAIGN CEC-03: Remove
HI-TRAC from cask loading pit, decontaminate, close &
prepare MPC for movement CEC-03
Calibration
Records
NA
Fast Scan Calibration Check Count
Multiple
Calibration
Records
NA
Fast Scan Background Check QA Count
Multiple
Calibration
Records
NA
Whole Body Counter Calibration Check Count
Multiple
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calibration
Records
NA
Whole Body Counter Background Check QA Count
Multiple
Corrective Action
Documents
Condition Reports
2204651, 202206786, 202302813, 202307061,
2307654, 202307679, 202308189, 202402537,
2404078, 202404415
Procedures
HTP-ZZ-01302-
DTI-DPW
Response to Positive In Vivo Count for Declared Pregnant
Woman
Procedures
HTP-ZZ-01302-
DTI-Medical
Admin
Response to a Medical Administration of Radioactive
Nuclides
Procedures
HTP-ZZ-01433-
DTI-Multipack
Sentinel Multi-Pack Operations
Procedures
HTP-ZZ-01480-
DTI-SRD
External Radiation Dose Evaluation SRD Related
Procedures
HTP-ZZ-01489-
DTI-DLR
External Radiation Dose Evaluation DLR Related
Procedures
HTP-ZZ-06009
Personnel Contamination Assessment and Decontamination
Procedures
RP-DTI-EXT-
DOS-DLR-
Operations
DLR Operations
Procedures
RP-DTI-EXT-
DOS-DLR-
Processing
Disposition of Dosimeter of Legal Record for Processing
Procedures
RP-DTI-
FASTSCAN-OP
Operation of the Canberra FastScan
Procedures
RP-DTI-In Vitro
Bioassay
In-Vitro Bioassay Sample Collection
Procedures
RP-DTI-
VARSKIN-Use
VARSKIN Use
Procedures
RP-STI-CHAIR-
OP
Whole Body Chair Operations
Radiation Work
Permits (RWPs)
R26CAVDECON
Specific Radiation Work Permit
71151
Miscellaneous
Radiological controlled area greater than 100 mrem dose
05/28/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
accrued per entry summary
71151
Miscellaneous
Callaway Energy Center 2023 Annual Radioactive Effluent
Release Report
04/30/2024
71151
Miscellaneous
PM0911004
Dose Assessment from Liquid Effluents
03/31/2024
71151
Miscellaneous
PM0911009
Dose Assessment from Noble Gases
03/31/2024
71151
Miscellaneous
PM0911010
Dose Assessment from Radioiodines and Particulates
03/31/2024
Corrective Action
Documents
Condition Reports
200603324, 202402477
Miscellaneous
LTU 05-03
Flowserve Technical Update
Miscellaneous
LTU-05-02
FLowserve Technical Update
03/05/2009
Miscellaneous
Licensee Actions to Address Nonconservative Technical
Specifications
Corrective Action
Documents
Condition Reports
2400041, 202400891, 202400956, 202401387,
2401847, 202401986, 202402062, 202402123,
2403580, 202403696, 202403790, 202404131,
2404208, 202404599
Procedures
APA-ZZ-00220
Record Management
Miscellaneous
Automatic Turbine-Driven Auxiliary Feedwater Pump
Actuation
Miscellaneous
Invalid Actuation of Automatic Turbine-Driven Auxiliary
Feedwater Pump