ML082180851
ML082180851 | |
Person / Time | |
---|---|
Site: | Callaway |
Issue date: | 08/05/2008 |
From: | Vincent Gaddy NRC/RGN-IV/DRP/RPB-B |
To: | Heflin A Union Electric Co |
References | |
EA-08-190 IR-08-003 | |
Download: ML082180851 (58) | |
See also: IR 05000483/2008003
Text
UNITED STATES
NUC LE AR RE G UL AT O RY C O M M I S S I O N
R E GI ON I V
612 EAST LAMAR BLVD , SU I TE 400
AR LI N GTON , TEXAS 76011-4125
August 5, 2008
Mr. Adam C. Heflin, Senior Vice
President and Chief Nuclear Officer
Union Electric Company
P.O. Box 620
Fulton, MO 65251
SUBJECT: CALLAWAY PLANT - NRC INTEGRATED INSPECTION
REPORT AND NOTICE OF VIOLATION 05000483/2008003
Dear Mr. Heflin:
On June 24, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated
inspection at your Callaway Plant. The enclosed report documents the inspection results, which
were discussed on June 24, 2008, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
Based on the results of this inspection, one violation is cited in the enclosed Notice of
Violation (Notice) and the circumstances surrounding this violation are described in detail in the
enclosed report. The violation involved failure to implement corrective actions to preclude the
repetition of void formation in the emergency core cooling piping (EA-08-190). Although
determined to be of very low safety significance (Green), this violation is being cited because
one of the criteria specified in Section VI.A.1 of the NRC Enforcement Policy for a noncited
violation was satisfied. Specifically, AmerenUE failed to restore compliance within a reasonable
time after the violation was last identified in NRC Inspection Report 05000483/2006002-012.
Please note that you are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response. The NRC will use your
response, in part, to determine whether further enforcement action is necessary to ensure
compliance with regulatory requirements.
This report also documents four NRC-identified and self-revealing findings of very low safety
significance (Green). These findings were determined to involve violations of NRC
requirements. Additionally, two licensee-identified violations which were determined to be of
very low safety significance are listed in this report. However, because of the very low safety
significance and because they were entered into your corrective action program, the NRC is
treating these findings as NCVs consistent with Section VI.A of the NRC Enforcement Policy. If
you contest these NCVs, 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,
Union Electric Company -2-
ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional
Administrator, U.S. Nuclear Regulatory Commission Region IV, 612 East Lamar Drive,
Suite 400, Arlington, Texas 76011-4125; the Director, Office of Enforcement, U.S. Nuclear
Regulatory Commission, Washington DC 20555-0001; and the NRC Resident Inspector at the
Callaway Plant.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its
enclosures will be made available electronically for public inspection in the NRC Public
Document Room or from the Publicly Available Records component of NRCs document system
(ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the
Public Electronic Reading Room).
Sincerely,
/RA/
Vincent G. Gaddy, Chief,
Projects Branch B
Division of Reactor Projects
Docket: 50-483
License: NPF-30
Enclosures: Notice of Violation and
NRC Inspection Report 05000483/2008003
w/attachment: Supplemental Information
cc w/enclosure: Rick A. Muench, President and
John ONeill, Esq. Chief Executive Officer
Pillsbury Winthrop Shaw Pittman LLP Wolf Creek Nuclear Operating Corporation
2300 N. Street, N.W. P.O. Box 411
Washington, DC 20037 Burlington, KS 66839
Scott A. Maglio, Assistant Manager Kathleen Smith, Executive Director and
Regulatory Affairs Kay Drey, Representative Board of
AmerenUE Directors
P.O. Box 620 Missouri Coalition for the Environment
Fulton, MO 65251 6267 Delmar Boulevard, Suite 2E
St. Louis City, MO 63130
Missouri Public Service Commission
Governors Office Building Lee Fritz, Presiding Commissioner
200 Madison Street Callaway County Courthouse
P.O. Box 360 10 East Fifth Street
Jefferson City, MO 65102-0360 Fulton, MO 65251
H. Floyd Gilzow Les H. Kanuckel, Manager
Deputy Director for Policy Quality Assurance
Missouri Department of Natural Resources AmerenUE
P. O. Box 176 P.O. Box 620
Jefferson City, MO 65102-0176 Fulton, MO 65251
Union Electric Company -3-
Director, Missouri State Emergency Certrec Corporation
Management Agency 4200 South Hulen, Suite 422
P.O. Box 116 Fort Worth, TX 76109
Jefferson City, MO 65102-0116
Keith G. Henke, Planner III
Scott Clardy, Director Division of Community and Public Health
Section for Environmental Public Health Office of Emergency Coordination
Missouri Department of Health and Missouri Department of Health and
Senior Services Senior Services
P.O. Box 570 930 Wildwood,
Jefferson City, MO 65102-0570 P.O. Box 570
Jefferson City, MO 65102
Luke H. Graessle, Manager
Regulatory Affairs Technical Services Branch Chief
AmerenUE FEMA Region VII
P.O. Box 620 2323 Grand Boulevard, Suite 900
Fulton, MO 65251 Kansas City, MO 64108-2670
Thomas B. Elwood, Supervising Engineer Ronald L. McCabe, Chief
Regulatory Affairs and Licensing Technological Hazards Branch
AmerenUE National Preparedness Division
P.O. Box 620 DHS/FEMA
Fulton, MO 65251 9221 Ward Parkway, Suite 300
Kansas City, MO 64114-3372
Union Electric Company -4-
Electronic distribution by RIV:
Regional Administrator (Elmo.Collins@nrc.gov)
DRP Director (Dwight.Chamberlain@nrc.gov)
DRS Director (Roy.Caniano@nrc.gov)
DRS Deputy Director (Troy.Pruett@nrc.gov)
Senior Resident Inspector (David.Dumbacher@nrc.gov)
Branch Chief, DRP/B (Vincent.Gaddy@nrc.gov)
Senior Project Engineer, DRP/B (Rick.Deese@nrc.gov)
Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
Only inspection reports to the following:
M. Cox, OEDO RIV Coordinator (Mark.Cox@nrc.gov)
OEMail.Resource@nrc.gov
Enforcement Officer (Michael.Vasquez@nrc.gov)
Chief Allegation Coordination/Enforcement Staff (William.Jones@nrc.gov)
Office of Enforcement (Alexander.Sapountizis@nrc.gov)
ROPreports
CWY Site Secretary (Dawn.Yancey@nrc.gov)
SUNSI Review Completed: VGG ADAMS: ; Yes No Initials: __VGG__
- Publicly Available Non-Publicly Available Sensitive ;Non-Sensitive
R:\_Reactors\_CW\2008\CW 2008003RP-DED.doc ML 082180851
RIV:SRI:DRP/B C:DRS/OB C:DRS/PSB1 C:DRS/EB2 C:DRS/EB1
DDumbacher RELantz MPShannon NFO'Keefe RLBywater
/RA/ VGGaddy for /RA/ /RA/ /RA/ MFRunyan for /RA/
07/29/2008 07/9/2008 07/14/2008 07/15/2008 07/11/2008
C:DRS/PSB2 DRS/SRA ACES C:DRP/B D:DRP
GEWerner DPLoveless GMVasquez VGGaddy DDChamberlain
/RA/ /RA/ /RA/ /RA/ /RA/
07/17/2008 07/15/2008 07/24/2008 08/5/2008 07/28/2008
OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
NOTICE OF VIOLATION
AmerenUE Docket 50-483
Callaway Plant License NPF-30
During an NRC inspection conducted March 24 through June 24, 2008, a violation of NRC
requirements was identified. In accordance with the NRC Enforcement Policy, the violation is
listed below:
10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that
measures shall be established to ensure that, for significant conditions adverse to
quality, the cause of the condition is determined and corrective action taken to preclude
repetition.
Contrary to this, from December 26, 2006, through May 21, 2008, the licensee failed to
take corrective actions to preclude repetition of safety-related emergency core cooling
system pipe voiding, and the licensee determined that this condition was a significant
This violation is associated with a Green Significance Determination Process finding.
Pursuant to the provisions of 10 CFR 2.201, AmerenUE is hereby required to submit a written
statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document
Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, Region IV,
and a copy to the NRC Senior Resident Inspector at the facility that is the subject of this Notice
of Violation (Notice), within 30 days of the date of the letter transmitting this Notice. This reply
should be clearly marked as a "Reply to Notice of Violation EA-08-190," and should include:
(1) the reason for the violation, or, if contested, the basis for disputing the violation or severity
level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective
steps that will be taken to avoid further violations, and (4) the date when full compliance will be
achieved. Your response may reference or include previous docketed correspondence, if the
correspondence adequately addresses the required response. If an adequate reply is not
received within the time specified in this Notice, an order or a Demand for Information may be
issued as to why the license should not be modified, suspended, or revoked, or why such other
action as may be proper should not be taken. Where good cause is shown, consideration will
be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the NRCs document system (ADAMS), accessible from the
NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not
include any personal privacy, proprietary, or safeguards information so that it can be made
available to the public without redaction. If personal privacy or proprietary information is
necessary to provide an acceptable response, then please provide a bracketed copy of your
response that identifies the information that should be protected and a redacted copy of your
response that deletes such information. If you request withholding of such material, you must
specifically identify the portions of your response that you seek to have withheld and provide in
-1- Enclosure 1
detail the bases for your claim of withholding (e.g., explain why the disclosure of information will
create an unwarranted invasion of personal privacy or provide the information required by
10 CFR 2.390(b) to support a request for withholding confidential commercial or financial
information). If safeguards information is necessary to provide an acceptable response, please
provide the level of protection described in 10 CFR 73.21.
Dated this 5th day of July 2008
-2- Enclosure 1
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket: 50-483
License: NPF-30
Report: 05000483/2008003
Licensee: Union Electric Company
Facility: Callaway Plant
Location: Junction Highway CC and Highway O
Fulton, MO
Dates: March 25 - June 24, 2008
Inspectors: D. Dumbacher, Senior Resident Inspector
J. Groom, Resident Inspector
J. Drake, Senior Reactor Inspector, Plant Support, Branch 2
G. Guerra, CHP, Health Physicist, Plant Support Branch 1
Approved By: V. Gaddy, Chief, Project Branch B
Division of Reactor Projects
-1- Enclosure 2
SUMMARY OF FINDINGS
IR 05000483/2008003: 3/25 - 6/24/2008; Callaway Plant, Operability Evaluations,
Postmaintenance Testing, Surveillance Testing, and Identification and Resolution of Problems.
This report covered a 3-month period of inspection by resident inspectors. The significance of
most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual
Chapter 0609, "Significance Determination Process." Findings for which the Significance
Determination Process does not apply may be Green or assigned a severity level after NRC
management review. The NRCs program for overseeing the safe operation of commercial
nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4,
dated December 2006.
A. NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green. The inspectors identified a noncited violation of Technical
Specification 3.5.2, "Emergency Core Cooling Systems," after an inadequate
surveillance procedure resulted in the licensee failing to maintain the emergency
core cooling system full of water as required per Technical Specification 3.5.2.
On May 21, 2008, Callaway Plant engineering discovered that a section of the
cold leg recirculation piping, specifically the discharge of the residual heat
removal pumps to the safety injection pumps, contained 6.6 cubic feet of air.
Callaway monthly surveillance Procedure OSP-SA-00003, "Emergency Core
Cooling Flow Path Verification and Venting," had a purpose to: "Verify the ECCS
is full of water," in accordance with Technical Specification Surveillance
Requirement 3.5.2.3. The monthly verification and vent procedure was not
comprehensive enough to ensure all the emergency core cooling system was full
of water.
This finding was more than minor because it was similar to Example 3e of NRC
Inspection Manual Chapter 0612, Appendix E, "Examples of Minor Issues," and
met the Not Minor If, criteria because the failure to meet the licensees
administrative requirement for allowable void fraction impacted the ability of the
Train A safety injection system to function upon initiation of high-pressure
recirculation. This finding affected the mitigating systems cornerstone procedure
quality attribute. Using the Manual Chapter 0609.04, Phase 1 - Initial Screening
and Characterization of Findings, the inspectors determined that this finding
should be evaluated using the Phase 2 process described in Manual
Chapter 0609, Appendix A, Determining the Significance of Reactor Inspection
Findings for At-Power Situations. As described in Section III, of Appendix A,
given that the presolved table did not contain a suitable target or surrogate for
this finding, the senior reactor analyst used the risk-informed notebook to
evaluate the significance of this finding affecting only high-pressure recirculation
as very low risk significance (Green). This finding has a crosscutting aspect in
the area of human performance associated with the decision making component
because the licensee failed to use conservative assumptions in decision making
and did not adopt a requirement to demonstrate that a single vent valve was
sufficient to vent the affected line rather than assuming that an additional
-2- Enclosure 2
installed valve was not necessary to completely fill, vent, and test the line H.1(b)
(Section 1R15).
- Green. A self-revealing noncited violation of 10 CFR Part 50, Appendix B,
Criterion XVI, "Corrective Action," was identified after the licensee failed to
promptly correct leakage from diesel generator jacket water o-rings. On
February 20, 2008, during a normal surveillance run of Emergency Diesel
Generator B, Callaway operations personnel identified an approximately
80 drop-per-minute jacket water leak caused by premature failure of Nitrile type
o-rings. Following restoration of Emergency Diesel Generator B, the licensee
re-evaluated the preventative maintenance frequency for jacket water o-ring
replacement and reduced the replacement frequency from once every 3 years to
once every refueling cycle. Then, on May 28, 2008, during a routine surveillance
run of Emergency Diesel Generator A, Callaway operations personnel identified
that Emergency Diesel Generator A had a 200 drop-per-minute jacket water leak.
Similar to the condition observed on Emergency Diesel Generator B on
February 20, 2008, the source of the leakage was from Nitrile type o-rings within
the jacket water system. The o-rings responsible for jacket water leakage were
found to be of similar age to those that failed during the February 20, 2008,
surveillance but had not been replaced despite the change to the licensee's
preventive maintenance frequency.
This finding, failure to implement adequate corrective actions for degraded Nitrile
type o-rings in Emergency Diesel Generator A after previously identifying the
adverse condition on Emergency Diesel Generator B, was more than minor
because, if left uncorrected, degraded diesel generator jacket water o-rings could
become a more significant safety concern. This finding affected the mitigating
systems cornerstone. Using Manual Chapter 0609.04, Phase 1 - Initial
Screening and Characterization of Findings, this finding was determined to be of
very low safety significance because it was a design deficiency confirmed not to
result in loss of operability. This finding has a crosscutting aspect in the area of
human performance associated with the work controls component because the
licensee failed to plan work activities to support long-term equipment reliability by
addressing known degraded conditions in a more reactive than preventative
manner H.3(b) (Section 1R19).
- Green. The inspectors identified a violation of 10 CFR Part 50, Appendix B,
Criterion XVI, "Corrective Action," because the licensee failed to take corrective
actions to preclude repetition of void formation in emergency core cooling system
piping, a significant condition adverse to quality. After experiencing void
formations in 2005 and 2006, the NRC identified violations of Criterion XVI.
However, licensee corrective actions did not preclude repetition of void
formations that were discovered on May 21, 2008. On that date, Callaway Plant
engineering performed ultrasonic inspection of the safety injection system
common suction piping Line EM023-HCB - 6" and discovered a 6.6 cubic foot
voided area. This exceeded the allowable void fraction of 2.1 cubic feet required
for operability. This voided piping, determined to have existed for over a year,
was caused by relief valve maintenance on Valve EM8858A (May 7, 2007). The
maintenance restoration failed to perform an adequate fill and vent to ensure the
suction pipe was full of water. The inspectors identified several related examples
where the licensee had performed either inadequate operating experience
-3- Enclosure 2
evaluations, inadequate extent of condition reviews, or inadequate procedure
corrections. The violation is being cited in a Notice of Violation because the
licensee failed to restore compliance with a reasonable time after a violation was
last identified in 2006.
This finding, failure to restore compliance to prevent recurrence of emergency
core cooling system voids, was more than minor because it is similar to
Example 3e of NRC Inspection Manual Chapter 0612, Appendix E, "Examples of
Minor Issues," criteria because the failure impacted the ability of the emergency
core cooling system to function upon initiation of high-pressure recirculation.
Using the Manual Chapter 0609.04, Phase 1 - Initial Screening and
Characterization of Findings, the inspectors determined that this finding should
be evaluated using the Phase 2 process described in Manual Chapter 0609,
Appendix A, Determining the Significance of Reactor Inspection Findings for
At-Power Situations. As described in Section III, of Appendix A, given that the
presolved table did not contain a suitable target or surrogate for this finding, the
senior reactor analyst used the risk-informed notebook to evaluate the
significance of this finding as very low risk significance (Green). This finding has
a crosscutting aspect in the area of problem identification and resolution
associated with the corrective action program component because AmerenUE
failed to thoroughly evaluate voiding problems such that the resolutions
addressed causes and extent of condition, as necessary P.1(c) (Section 4OA2).
Cornerstone: Barrier Integrity
- Green. A self-revealing noncited violation of 10 CFR Part 50, Appendix B,
Criterion III, Design Control, was identified after determining that the licensee
had not adequately selected and reviewed the suitability of the design of the
containment air cooler control circuitry. On March 26, 2008, Containment Air
Cooler A fan shut down when shifted from fast to slow speed. Troubleshooting
by the licensee determined that voltage was lost to the control power circuitry
when the fast speed thermal overload tripped. Since the overload contacts were
wired in series, Containment Air Cooler A experienced a complete loss of control
power rendering it inoperable. The licensee determined the trip to be caused by
operation of containment air coolers in fast speed, during a period of higher than
normal containment pressure. The licensee analyzed the potential impact of the
newly discovered adverse containment cooler design vulnerability against design
basis accident scenarios. The licensee determined that a hot zero power main
steam line break results in a delayed safety injection signal allowing the fan
motor overloads to trip prior to being shed by the load sequencer. The
containment air coolers would then experience a complete loss of control power
and would not be capable of automatically restarting in slow speed. The analysis
revealed that the peak containment pressure limit of 48.1 psig would be
preserved. The licensee submitted a licensee event report as required by
10 CFR 50.73 since the inadequate containment air cooler control circuitry
resulted in a condition prohibited by the plants Technical Specifications.
This finding, failure to ensure the design of the containment air cooler control
circuitry was suitable for all plant conditions, was more than minor because it was
associated with the barrier integrity cornerstone attribute of design control and
affects the associated cornerstone objective to provide reasonable assurance
-4- Enclosure 2
that physical design barriers protect the public from radio nuclide releases
caused by accidents or releases. Using Manual Chapter 0609, Appendix H,
Containment Integrity Significance Determination Process," this finding was
determined to be a Type B finding since it was related to a degraded condition
that has potentially important implications for the integrity of the containment,
without affecting the likelihood of core damage. This finding was found to be of
very low safety significance because containment coolers are structures,
systems or components that are not significant contributors to the large early
release frequency. The inspectors determined that this finding does not have a
crosscutting aspect associated with it since the performance deficiency was not
indicative of current licensee performance (Section 1R15).
- Green. The inspectors identified a noncited violation of Technical
Specification 5.4.1.a, Procedures, after Callaway control room operators
improperly entered a wrong Technical Specification action statement due to the
failure to maintain the Technical Specification Bases current. On June 17, 2008,
during surveillance testing, Valve EMHV8823 failed to indicate fully closed.
Since EMHV8823 is an isolation valve for containment Penetration 49, the
licensee entered Technical Specification 3.6.3, Containment Isolation Valves,
Condition C, with an action to restore the valve to an operable status or isolate
the penetration within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after Valve EMHV8823
had been declared inoperable, Callaway licensing personnel contacted the
control room and informed them of an approved Technical Specification Bases
change that did not allow Technical Specification 3.6.3, Condition C, to be
applicable to containment Penetration 49. The Technical Specification Bases
change was effective May 1, 2008, but had not been issued to the control room.
The licensee determined that the more restrictive Technical Specification 3.6.3,
Condition A, should have been entered with an action to isolate the affected
penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The licensee performed a containment entry
following discovery of entry into Technical Specification 3.6.3, Condition A, and
found that Valve EMHV8823 failed its surveillance due to out of adjustment
position indicator limit switches. The valve was verified closed and isolated
allowing exit from Technical Specification 3.6.3, Condition A.
This finding, failure to ensure the Technical Specification Bases were maintained
current and available to the Callaway control room staff, was more than minor
because if left uncorrected, the failure to maintain the Technical Specification
Bases current could become a more significant safety concern. This finding was
determined to affect the barrier integrity cornerstone. Using Manual
Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings,
this finding is determined to be of very low safety significance since this finding
did not represent an actual open pathway in the physical integrity of reactor
containment and did not involve an actual reduction in function of hydrogen
ignitors in the reactor containment. This finding has a crosscutting aspect in the
area of human performance associated with the decision making component
because the licensee failed to communicate, in a timely manner, decisions to
personnel who have a need to know the information in order to perform work
safely H.1(c) (Section 1R22).
-5- Enclosure 2
B. Licensee-Identified Violations
Two violations of very low safety significance, which were identified by the licensee,
have been reviewed by the inspectors. Corrective actions taken or planned by the
licensee have been entered into the licensees corrective action program. These
violations and corrective action tracking numbers are listed in Section 4OA7.
-6- Enclosure 2
REPORT DETAILS
Summary of Plant Status
AmerenUE operated the Callaway Plant at near 100 percent for the entire quarter.
1. REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity and
1R01 Adverse Weather Protection (71111.01)
.1 Readiness of Offsite and Alternate AC Power System
a. Inspection Scope
The inspectors reviewed the licensees plant features, training lesson plans, and
procedures for operation and continued availability of offsite and alternate AC power
systems to verify they were appropriate. The review included communication protocols
and agreement procedures between the transmission system operator and the nuclear
power plant to verify that appropriate information is exchanged when issues arise that
could impact the offsite power system. Specifically, the procedures were verified to
ensure they specified:
- Required actions needed when notified by the transmission system operator that
posttrip voltage of the offsite power system would not be acceptable to assure
the continued operation of safety related loads without transferring to the onsite
power supply.
- Compensatory actions needed when it is not possible to predict the posttrip
voltage at the nuclear power plant for current grid conditions.
- Required assessment of plant risk based on maintenance activities which could
affect grid reliability, or the ability of the transmission system to provide the offsite
power system.
- Required communications between the nuclear power plant and the transmission
system operator when changes at the nuclear power plant could impact the
transmission system, or when the capability of the transmission system to
provide adequate offsite system power is challenged.
On May 16, 2008, the inspectors evaluated the licensee staffs preparations for summer
readiness of offsite and AC power systems against the sites procedures and determined
that the staffs actions were adequate. Documents reviewed are listed in the
attachment.
These activities constituted one readiness of offsite power inspection sample as defined
by Inspection Procedure 71111.01.
-7- Enclosure 2
b. Findings
No findings of significance were identified.
.2 Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
On May 2, 2008, the inspectors completed a review of the licensee's readiness for
impending adverse weather involving severe thunderstorms. The inspectors:
(1) reviewed plant procedures, the Final Safety Analysis Report (FSAR), and Technical
Specifications to ensure that operator actions defined in adverse weather procedures
maintained the readiness of essential systems; (2) walked down portions of the
emergency diesel generators and offsite power systems to ensure that adverse weather
protection features were sufficient to support operability; (3) reviewed maintenance
records to determine that applicable surveillance requirements were current before the
anticipated severe thunderstorms developed; and (4) reviewed plant modifications,
procedure revisions, and operator work arounds to determine if recent facility changes
challenged plant operation. Documents reviewed by the inspectors are listed in the
attachment.
These activities constituted one readiness for impending adverse weather inspection
sample as defined by Inspection Procedure 71111.01.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignments (71111.04)
.1 Quarterly Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial system walkdowns of the following risk-significant
systems:
- June 3, 2008, Train A auxiliary feedwater system while the Train B motor-driven
auxiliary feedwater pump was out of service for planned maintenance.
- June 10, 2008, Train A 480 volt NG Class 1E switchgear while the Train B
emergency diesel generator was out of service for planned and emergent
maintenance issues.
The inspectors selected these systems based on their risk significance relative to the
reactor safety cornerstones at the time they were inspected. The inspectors attempted
to identify discrepancies that could impact the function of the system, and, therefore,
potentially increase risk. The inspectors reviewed applicable operating procedures,
system diagrams, FSAR, Technical Specification requirements, outstanding work orders,
corrective action documents, and the impact of ongoing work activities on redundant
trains of equipment in order to identify conditions that could have rendered the systems
-8- Enclosure 2
incapable of performing their intended functions. The inspectors also walked down
accessible portions of the systems to verify components and support equipment were
aligned correctly and were operable. The inspectors examined the material condition of
the components and observed operating parameters of equipment to verify that there
were no obvious deficiencies. The inspectors also verified that the licensee had properly
identified and resolved equipment alignment problems that could cause initiating events
or impact the capability of mitigating systems or barriers and entered them into the
corrective action program with the appropriate significance characterization. Documents
reviewed are listed in the attachment.
These activities constituted two partial system walkdown samples as defined by
Inspection Procedure 71111.04.
b. Findings
No findings of significance were identified.
.2 Complete System Walkdown (71111.04S)
a. Inspection Scope
On April 17, 2008, the inspectors performed a complete system alignment inspection of
Train B of the residual heat removal system to verify the functional capability of the
system. The inspectors selected this system because it was considered both
safety-significant and risk-significant in the licensees probabilistic risk assessment. The
inspectors walked down the system to review mechanical and electrical equipment line
ups, electrical power availability, system pressure and temperature indications, as
appropriate, component labeling, component lubrication, component and equipment
cooling, hangers and supports, operability of support systems, and to ensure that
ancillary equipment or debris did not interfere with equipment operation. The inspectors
reviewed a sample of past and outstanding work orders to determine whether any
deficiencies significantly affected the system function. In addition, the inspectors
reviewed the corrective action program database to ensure that system equipment
alignment problems were being identified and appropriately resolved. The documents
used for the walkdown and issue review are listed in the attachment.
These activities constituted one complete system walkdown sample as defined by
Inspection Procedure 71111.04.
b. Findings
No findings of significance were identified.
-9- Enclosure 2
1R05 Fire Protection (71111.05)
.1 Quarterly Fire Inspector Tours (71111.05Q)
a. Inspection Scope
The inspectors conducted fire protection walkdowns which were focused on availability,
accessibility, and the condition of firefighting equipment in the following risk-significant
plant areas:
- March 27, 2008, Fire Area C-21, Lower Cable Spreading Room
- April 16, 2008, Fire Area A-17, Electrical Penetration Room (South)
- April 25, 2008, Condensate Storage Tank
- April 29, 2008, Fire Area A-23, Main Steam and Feedwater Isolation Valve
Enclosure
- April 30, 2008, Reactor Building
- June 18, 2008, Fire Area A-1, North Pipe Chase
The inspectors reviewed areas to assess if the licensee implemented a fire protection
program that adequately controlled combustibles and ignition sources within the plant,
effectively maintained fire detection and suppression capability, maintained passive fire
protection features in good material condition, and implemented adequate compensatory
measures for out of service, degraded or inoperable fire protection equipment, systems,
or features in accordance with the licensees fire plan. The inspectors selected fire
areas based on their overall contribution to internal fire risk as documented in the plants
Individual Plant Examination of External Events with later additional insights, their
potential to impact equipment which could initiate or mitigate a plant transient, or their
impact on the plants ability to respond to a security event. The inspectors verified that
fire hoses and extinguishers were in their designated locations and available for
immediate use; that fire detectors and sprinklers were unobstructed, that transient
material loading was within the analyzed limits; and fire doors, dampers, and penetration
seals appeared to be in satisfactory condition. Documents reviewed are listed in the
attachment.
These activities constituted six quarterly fire protection inspection samples as defined by
Inspection Procedure 71111.05.
b. Findings
No findings of significance were identified.
.2 Annual Fire Protection Drill Observation (71111.05A)
a. Inspection Scope
On March 27, 2008, the inspectors observed a fire brigade activation due to a report of
smoke in the laundry decontamination area. The observation evaluated the readiness of
- 10 - Enclosure 2
the plant fire brigade to fight fires. The inspectors verified that the licensee staff
identified deficiencies; openly discussed them in a self-critical manner at the drill debrief,
and took appropriate corrective actions. Specific attributes evaluated were: (1) proper
wearing of turnout gear and self-contained breathing apparatus; (2) proper use and
layout of fire hoses; (3) employment of appropriate fire fighting techniques; (4) sufficient
firefighting equipment brought to the scene; (5) effectiveness of fire brigade leader
communications, command, and control; (6) search for victims and propagation of the
fire into other plant areas; (7) smoke removal operations; (8) utilization of preplanned
strategies; (9) adherence to the preplanned drill scenario; and (10) drill objectives.
Documents reviewed are listed in the attachment.
These activities constituted one annual fire protection inspection sample as defined by
Inspection Procedure 71111.05.
b. Findings
No findings of significance were identified.
1R06 Flood Protection Measures (71111.06)
a. Inspection Scope
The inspectors reviewed selected risk-significant plant design features and licensee
procedures intended to protect the plant and its safety related equipment from internal
flooding events. The inspectors reviewed flood analyses and design documents,
including the FSAR, engineering calculations, and abnormal operating procedures for
licensee commitments. The inspectors reviewed licensee drawings to identify areas and
equipment that may be affected by internal flooding caused by the failure or
misalignment of nearby sources of water. The inspectors also reviewed the licensees
corrective actions for previously identified flood-related items. The inspectors performed
a walkdown of the following plant area to assess the adequacy of any watertight doors
and verify drains and sumps were clear of debris and operable, and that the licensee
complied with its flooding related commitments:
- June 23, 2008, Control Building West Corridor
The document reviewed during this inspection is listed as follows:
- Callaway Action Request 200805189
This inspection constituted one internal flooding sample as defined in Inspection
Procedure 71111.06.
b. Findings
No findings of significance were identified.
- 11 - Enclosure 2
1R11 Licensed Operator Requalification Program (71111.11)
a. Inspection Scope
On June 2, 2008, the inspectors observed a crew of licensed operators perform a
Cycle 08-3 as found scenario in the plants simulator to verify that operator performance
was adequate, evaluators were identifying and documenting crew performance
problems, and that training was being conducted in accordance with licensee
procedures. The scenario involved an operating design basis earthquake with a lockout
on essential 4 kV Bus NB01. The inspectors evaluated the crew in the following areas:
- Licensed operator performance
- Crew clarity and formality of communications
- Ability to take timely actions in the conservative direction
- Prioritization, interpretation, and verification of annunciator alarms
- Correct use and implementation of abnormal and emergency procedures
- Control board manipulations
- Oversight and direction from supervisors
- Ability to identify and implement appropriate Technical Specification actions and
Emergency Plan actions and notifications
The crews performance in these areas was compared to pre-established operator action
expectations and successful critical task completion requirements. Documents reviewed
are listed in the attachment.
This inspection constituted one quarterly licensed operator requalification program
sample as defined in Inspection Procedure 71111.11.
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness (71111.12)
a. Inspection Scope
The inspectors evaluated degraded performance issues involving the following
risk-significant systems:
- May 15, 2008, Callaway Action Request (CAR) 200801644, an additional anode
was found in the north end of the Train A emergency diesel generator intercooler
- May 15, 2008, CAR 200802854, KKJ01A (Train A emergency diesel generator)
engine oil sump high
- 12 - Enclosure 2
The inspectors reviewed events such as where ineffective equipment maintenance has
resulted in valid or invalid automatic actuations of risk-important systems and
independently verified the licensee's actions to address system performance or condition
problems in terms of the following:
- Implementing appropriate work practices
- Identifying and addressing common cause failures
- Scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule
- Characterizing system reliability issues for performance
- Charging unavailability time
- Trending key parameters for condition monitoring
- Ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or reclassification
- Verifying appropriate performance criteria for structures, systems, and
components/functions classified as (a)(2) or appropriate and adequate goals and
corrective actions for systems classified as (a)(1)
The inspectors assessed performance issues with respect to the reliability, availability,
and condition monitoring of the system. The inspectors verified maintenance
effectiveness issues were entered into the corrective action program with the appropriate
significance characterization. Documents reviewed are listed in the attachment.
This inspection constituted two quarterly maintenance effectiveness samples as defined
in Inspection Procedure 71111.12Q.
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
a. Inspection Scope
The inspectors reviewed the licensee's evaluation and management of plant risk for the
maintenance and emergent work activities affecting risk-significant and safety-related
equipment listed below to verify that the appropriate risk assessments were performed
prior to removing equipment for work:
- April 3, 2008, Routine - Work on turbine-driven auxiliary feedwater
Valve KAPCV-0102
- April 21, 2008, Emergency Diesel Generator A lube oil trouble shooting
- April 28, 2008, Routine - associated with Loose Creek-Callaway 345 kV line
outage
- 13 - Enclosure 2
- June 10, 2008, Risk management actions associated with Emergency Diesel
Generator B jacket water o-ring replacement outage
These activities were selected based on their potential risk significance relative to the
reactor safety cornerstones. As applicable for each activity, the inspectors verified that
risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate
and complete. When emergent work was performed, the inspectors verified that the
plant risk was promptly reassessed and managed. The inspectors reviewed the scope
of maintenance work, discussed the results of the assessment with the licensee's
probabilistic risk analyst or shift technical advisor, and verified plant conditions were
consistent with the risk assessment. The inspectors also reviewed Technical
Specification requirements and walked down portions of redundant safety systems,
when applicable, to verify risk analysis assumptions were valid and applicable
requirements were met. Documents reviewed are listed in the attachment.
These activities constituted four samples as defined by Inspection Procedure 71111.13.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations (71111.15)
a. Inspection Scope
The inspectors reviewed the following issues:
- March 26, 2008, CARs 200802348, 200802365, and 200802264, Containment
coolers inoperable in fast speed
operability determination, Revisions 3 and 4
- April 9, 2008, Source Range Channel N32 inoperable due to a failed surveillance
- April 23, 2008, Component cooling water system following Valve EGHV0069
failing inservice test stroke time surveillance
- April 30, 2008, CAR 200803465, Emergency diesel generator Garlock flexible
expansion joints
- May 6, 2008, CAR 200803462, Voiding identified in containment spray pump
piping from sump
- May 22, 2008, CAR 200904000, Line EM-023 allowable void fraction exceeded
The inspectors selected potential operability issues based on the risk significance of the
associated components and systems. The inspectors evaluated the technical adequacy
of the evaluations to ensure that Technical Specification operability was properly justified
and the subject component or system remained available such that no unrecognized
increase in risk occurred. The inspectors compared the operability and design criteria in
the appropriate sections of the Technical Specifications and FSAR to the licensees
- 14 - Enclosure 2
evaluations to determine whether the components or systems were operable. Where
compensatory measures were required to maintain operability, the inspectors
determined whether the measures in place would function as intended and were
properly controlled. The inspectors determined, where appropriate, compliance with
bounding limitations associated with the evaluations. Additionally, the inspectors
reviewed a sample of corrective action documents to verify that the licensee was
identifying and correcting deficiencies associated with operability evaluations.
Documents reviewed are listed in the attachment.
This inspection constituted seven samples as defined in Inspection Procedure 71111.15.
b. Findings
.1 Introduction. A self-revealing Green noncited violation (NCV) of 10 CFR Part 50,
Appendix B, Criterion III, Design Control, was identified after determining that the
licensee had not adequately selected and reviewed the suitability of the design of the
containment air cooler control circuitry.
Description. On March 26, 2008, Containment Air Cooler A fan shut down when shifted
from fast to slow speed. Troubleshooting by the licensee determined that voltage was
lost to the control power circuitry when the fast speed thermal overload tripped. Since
the overload contacts were wired in series, Containment Air Cooler A experienced a
complete loss of control power rendering it inoperable. AmerenUE personnel noted that
Precaution 3.6 of Procedure OTN-GN-00001, Containment Cooling and CRDM
Cooling, Revision 14, cautioned that high pressure and cool temperatures across
containment coolers will cause the coolers to operate close to the setpoint of the thermal
overloads. However, the licensees operability determination dismissed the 1987
precaution as not having a technical basis believing it was implemented to address
discrepancies in motor overload setpoints. Later, the licensee determined that operation
of containment air coolers in fast speed, during a period of higher than normal
containment pressure, challenged the fast speed thermal overload setpoint and resulted
in the trip of Containment Air Cooler A on March 26, 2008. As an interim measure to
prevent a trip from fast speed, the licensee imposed a standing order to maintain the
containment coolers in slow speed.
The licensee analyzed the potential impact of the newly discovered adverse containment
cooler design vulnerability against design basis accident scenarios. The licensee
determined that a hot zero power main steam line break results in a delayed safety
injection signal allowing the fan motor overloads to trip prior to being shed by the load
sequencer. The containment air coolers would then experience a complete loss of
control power and would not be capable of automatically restarting in slow speed. The
analysis revealed that in this scenario, utilizing assumed accident conditions, the peak
containment pressure would exceed the 48.1 psig limit described in the FSAR.
However, analysis using actual plant conditions determined that the peak containment
pressure limit of 48.1 psig would be preserved. The licensee submitted a licensee event
report (LER) as required by 10 CFR 50.73 since the inadequate containment air cooler
control circuitry resulted in a condition prohibited by the plants Technical Specifications.
The inspectors review of the licensees LER is described in Section 4OA3 of this report.
To address the design deficiency associated with the containment air cooler control
circuitry, the licensee completed a modification in April 2008 to reconfigure the circuit
- 15 - Enclosure 2
such that tripping of the fast speed overloads would not impact the safety-related slow
speed function of the containment air coolers.
Analysis. The performance deficiency associated with this finding involved the
licensees failure to ensure the design of the containment air cooler control circuitry was
suitable for all plant conditions. This finding was greater than minor because it was
associated with the barrier integrity cornerstone attribute of design control and affects
the associated cornerstone objective to provide reasonable assurance that physical
design barriers protect the public from radio nuclide releases caused by accidents or
releases. Using Manual Chapter 0609, Appendix H, Containment Integrity Significance
Determination Process," this finding was determined to be a Type B finding since it was
related to a degraded condition that has potentially important implications for the integrity
of the containment, without affecting the likelihood of core damage. This finding was
found to be of very low safety significance since containment coolers are structures,
systems, and components that have no impact on large early release frequency. The
inspectors determined that this finding does not have a crosscutting aspect associated
with it since the performance deficiency is not indicative of current licensee performance.
Enforcement. 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in
part, that measures be established for the selection and review for suitability of
application of materials, parts, equipment, and processes that are essential to the
safety-related functions of structures, systems, and components. Contrary to the above,
prior to April 2, 2008, the licensee failed to ensure that the containment air coolers would
be able to perform their safety-related function in all accident scenarios due to a design
deficiency associated with the overload contacts in the containment air cooler control
circuitry. Because this finding is of very low safety significance and has been entered
into the corrective action program as CAR 200702264, this violation is being treated as
an NCV consistent with Section VI.A of the NRC Enforcement Policy:
NCV 05000483/2008003-01, Failure to Ensure the Suitability of the Design of the
Containment Air Cooler Control Circuitry.
.2 Introduction. The inspectors identified a Green NCV of Technical Specification 3.5.2,
"Emergency Core Cooling Systems," after an inadequate surveillance procedure
resulted in the licensee failing to maintain the emergency core cooling system (ECCS)
full of water as required per Technical Specification 3.5.2.
Description. On May 21, 2008, Callaway Plant engineering discovered that a section of
the cold leg recirculation piping, specifically the discharge of the residual heat removal
pumps to the safety injection pumps, contained 6.6 cubic feet of air. This exceeded the
allowable void fraction of 2.1 cubic feet required for operability. Callaway monthly
surveillance Procedure OSP-SA-00003, "Emergency Core Cooling Flow Path
Verification and Venting," had a purpose to: "Verify the ECCS is full of water," in
accordance with Technical Specification Surveillance Requirement 3.5.2.3. This
monthly surveillance was reviewed as part of significant condition adverse to quality
(SCAQ) CAR 200501092 corrective actions. Callaway engineering had determined that
residual heat removal pump discharge vent Valve EJV0193 to the safety injection
system was the high point vent for these lines and was thus sufficient to vent
Line EM-023-HCB - 6" to the safety injection pumps. However, this vent valve was not
adequate due to the pipe sloping issues and normally closed Valves EMHIS8807A/B.
Venting through Valve EMV0179 was necessary to completely fill, vent, and test the line.
The monthly verification and vent procedure was inadequate to identify and remove air
- 16 - Enclosure 2
introduced by relief valve maintenance on May 7, 2007, and thus ensure the ECCS was
full of water. See Violation (VIO)05000483/2008003-05 in Section 4OA2.
Analysis. Failure to adequately verify ECCS piping was full of water as required by
Technical Specification 3.5.2 is a performance deficiency. This finding affected the
mitigating system cornerstone procedure quality attribute. This finding is more than
minor because it was similar to Example 3e of NRC Inspection Manual Chapter 0612,
Appendix E, "Examples of Minor Issues," and met the Not Minor If, criteria because the
failure to meet the licensees administrative requirement for allowable void fraction
impacted the ability of the Train A safety injection system to function upon initiation of
high-pressure recirculation. Using Manual Chapter 0609.04, Phase 1 - Initial Screening
and Characterization of Findings, the inspectors determined that this finding should be
evaluated using the Phase 2 process described in Manual Chapter 0609, Appendix A,
Determining the Significance of Reactor Inspection Findings for At-Power Situations.
As described in Section III of Appendix A, given that the presolved table did not contain
a suitable target or surrogate for this finding, the senior reactor analyst used the
risk-informed notebook to evaluate the significance of this finding. Table 2 provides the
definitions for acronyms and initialisms used in the risk-informed notebook and
discussed in this inspection report.
TABLE 2
Acronyms and Initialisms used in Phase 2 Notebook
Initialism Initiating Event or Mitigating Function
TPCS Transient with Loss of the Power Conversion System
SLOCA Small-Break Loss of Coolant Accident
MLOCA Medium-Break Loss of Coolant Accident
LLOCA Large-Break Loss of Coolant Accident
LOOP Loss of Offsite Power
MSLB Main Steam Line Break
LBDC Loss of Vital Direct-Current Bus
PCS Power Conversion System (Steam and Feed)
HPR High Pressure Recirculation
DEPR Depressurization of the Reactor Coolant System
EAC Emergency Power (Alternating Current)
TDAFW Turbine-Driven Auxiliary Feedwater Pump Train
SEAL Reactor Coolant Pump Seal Integrity
STIN Operators Stop High-Pressure Injection
MDAFW Motor-Driven Auxiliary Feedwater Pump Train
The analyst performed a Phase 2 estimation in accordance with Inspection Manual
Chapter 0609, Appendix A, Attachment 2, Site Specific Risk-Informed Inspection
Notebook Usage Rules. Given that the performance deficiency was known to have
existed for 378 days (May 7, 2007, until May 21, 2008) the analyst used 1 year as the
exposure period. In accordance with Table 2 of the risk-informed notebook, the analyst
evaluated all worksheets except LLOCA. All worksheets were evaluated using the
nominal 1-year initiating event frequency. Because this finding only affected system
functionality during recirculation, nominal mitigation credit was given for all functions with
the exception of HPR. For HPR, the analyst made the bounding assumption that either
- 17 - Enclosure 2
both centrifugal charging pumps or both safety injection pumps would be affected. This
assumption was supported by licensee evaluation. The analyst solved each applicable
worksheet and the dominant sequences are documented in Table 1.
TABLE 1
Phase 2 Dominant Sequences
Initiating Event Sequence Mitigating Functions Results
Number
Transients 1 AFW-PCS-HPR 9
TPCS 1 AFW-HPR 8
SLOCA 2 DEPR-HPR 8
MLOCA 2 DEPR-HPR 9
1 AFW-HPR 9
LOOP 5 EAC-TDAFW-HPR 9
9 EAC-SEAL-HPR 9
MSLB 8 STIN-HPR 8
LBDC 8 TDAFW-MDAFW-HPR 8
Using Inspection Manual Chapter 0609, Appendix A, Attachment 1, Table 5, Counting
Rule Worksheet, the analyst determined that the risk contribution of this finding from
internal initiating events was of very low risk significance. In accordance with
Appendix A, Attachment 1, Steps 2.2.5 and 2.2.6, the analyst and determined that the
risk contribution of this finding from external initiating events or the contribution from
large-early release frequency were very low. Therefore, this finding was of very low risk
significance (Green). This finding has a crosscutting aspect in the area of human
performance associated with the decision making component because the licensee
failed to use conservative assumptions in decision making and did not adopt a
requirement to demonstrate that the single vent Valve EJV0193 was sufficient to vent
the Line EM-023-HCB - 6" rather than assuming that installed Valve EMV0179 was not
necessary to completely fill, vent, and test the line H.1(b).
Enforcement. Technical Specification 3.5.2 "Emergency Core Cooling Systems,"
Surveillance Requirement 3.5.2.3, required that the licensee verify that ECCS piping is
full of water every 31 days. Contrary to the above, from June 2007 through April 2008,
AmerenUE surveillance Procedure OSP-SA-00003, "Emergency Core Cooling Flow
Path Verification and Venting," was inadequate to meet Technical Specification
Surveillance Requirement 3.5.2.3. Because this finding is of very low safety significance
and was entered into the licensee's corrective action program as CAR 200804000, this
violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC
Enforcement Policy: NCV 05000483/2008003-02, Inadequate Surveillance Procedure
Resulted in an Inoperable ECCS.
- 18 - Enclosure 2
1R18 Plant Modifications (71111.18)
a. Inspection Scope
The inspectors reviewed the design adequacy of the listed modifications. This included
verifying that the modification preparation did not impair the following: (a) in-plant
emergency/abnormal operating procedure actions, (b) key safety functions, and
(c) operator response to loss of key safety functions.
The inspectors verified that postmodification testing maintained the plant in a safe
configuration during testing and that the postmodification testing established operability
by: (a) verifying that unintended system interactions did not occur; (b) verifying that
performance characteristics, which could have been affected by the modification, met
the design bases; (c) validating the appropriateness of modification design assumptions;
and (d) demonstrating that the modification test acceptance criteria had been met.
- April 18, 2008, Modification M-08-0013 to separate fast and slow speed overload
contacts for containment air coolers
- June 1, 2008, Temporary Modification TM 08-0003 for the instrument air system
to provide an additional diesel-driven air compressor to improve system reliability
while the system was in degraded reliability
Documents reviewed are listed in the attachment.
These activities constituted two samples as defined by Inspection Procedure 71111.18.
b. Findings
No findings of significance were identified
1R19 Postmaintenance Testing (71111.19)
a. Inspection Scope
The inspectors reviewed the following postmaintenance activities to verify that
procedures and test activities were adequate to ensure system operability and functional
capability:
- April 10, 2008, Job 08002765.900, Source Range N32 postmaintenance test
- April 17, 2008, Postmaintenance test containment Cooler D,
Modification 0800267/950(951)(952)
- May 7, 2008, Job 06524419.940, Emergency Diesel Generator B
- May 28, 2008, Job 08003910, Postmaintence test of Emergency Diesel
Generator A following repair of jacket water leaks
- May 30, 2008, Job 08001080, Postmaintenance local leakrate test of
containment personnel hatch door
- 19 - Enclosure 2
These activities were selected based upon the structure, system, and component's
ability to impact risk. The inspectors evaluated these activities to verify (as applicable):
the effect of testing on the plant had been adequately addressed; testing was adequate
for the maintenance performed; acceptance criteria were clear and demonstrated
operational readiness; test instrumentation was appropriate; tests were performed as
written in accordance with properly reviewed and approved procedures; equipment was
returned to its operational status following testing (temporary modifications or jumpers
required for test performance were properly removed after test completion); and test
documentation was properly evaluated. The inspectors evaluated the activities against
Technical Specifications, the FSAR, 10 CFR Part 50 requirements, licensee procedures,
and various NRC generic communications to ensure that the test results adequately
ensured that the equipment met the licensing basis and design requirements. In
addition, the inspectors reviewed corrective action documents associated with
postmaintenance tests to determine whether the licensee was identifying problems and
entering them in the corrective action program and that the problems were being
corrected commensurate with their importance to safety. Documents reviewed are listed
in the attachment.
This inspection constitutes five samples as defined in Inspection Procedure 71111.19.
b. Findings
Introduction. A self-revealing Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI,
"Corrective Action," was identified after the licensee failed to promptly correct leakage
from diesel generator jacket water o-rings.
Description. On February 20, 2008, during performance of Procedure OSP-NE-0001B,
Standby Diesel Generator B Periodic Tests, Callaway operations personnel identified
that the Emergency Diesel Generator B had an approximately 80 drop-per-minute jacket
water leak. Analysis by the licensee determined the cause of the leakage to be from
premature failure of Nitrile type o-rings in the jacket water supply and return headers.
Operational history at Callaway revealed o-ring failures prior to reaching 3 years of
service life. The o-rings responsible for the February 20, 2008, leakage had been in
service since Refueling Outage 14 in October 2005. Following restoration of Emergency
Diesel Generator B, the licensee re-evaluated the preventative maintenance frequency
for jacket water o-ring replacement. Based on a review of prior o-ring failures, the
replacement schedule for diesel generator jacket water o-rings was reduced from once
every 3 years to once every refueling cycle.
On May 28, 2008, during performance of Procedure OSP-NE-0001A, Standby Diesel
Generator A Periodic Tests, Callaway operations personnel identified that Emergency
Diesel Generator A had a 200 drop-per-minute jacket water leak. Based on the quantity
of the leakage, operations personnel declared Emergency Diesel Generator A
inoperable. Similar to the condition observed on Emergency Diesel Generator B on
February 20, 2008, the source of the leakage was from Nitrile type o-rings within the
jacket water system. While the licensee replaced the o-rings responsible for jacket
water leakage following the February 20, 2008, surveillance, several Nitrile type o-rings
installed during Refueling Outage 14 in October 2005 remained in service in both
Emergency Diesel Generators Trains A and B including those that failed during the
May 28, 2008, surveillance.
- 20 - Enclosure 2
Subsequent analysis by the licensee determined that the required mission time of the
Emergency Diesel Generator A was preserved since adequate inventory in the jacket
water expansion tank existed such that the leakage observed on May 28, 2008, would
not have impacted the net positive suction head analysis for the jacket water cooling
pump.
Analysis. The performance deficiency associated with this finding involved the
licensees failure to implement adequate corrective actions for an adverse condition.
Specifically, the licensee failed to correct degraded Nitrile type o-rings in Emergency
Diesel Generator A after previously identifying the adverse condition on Emergency
Diesel Generator B. This finding was greater than minor because, if left uncorrected,
degraded diesel generator jacket water o-rings could become a more significant safety
concern. This finding affected the mitigating systems cornerstone. Using Manual
Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings, this
finding was determined be of very low safety significance because it was a design
deficiency confirmed not to result in loss of operability. This finding had a crosscutting
aspect in the area of human performance associated with the work control component
because the licensee failed to plan work activities to support long-term equipment
reliability by addressing known degraded conditions in a more reactive than preventative
manner H.3(b).
Enforcement. 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires,
in part, that measures be established to assure conditions adverse to quality are
promptly identified and corrected. Contrary to the above, the licensee failed to
implement adequate corrective actions for the identified adverse condition that Nitrile
type o-rings would prematurely fail prior to the completion of the regularly scheduled
3-year replacement interval. Because this violation is of very low safety significance and
has been entered into the licensee's corrective action program as CAR 200804164, this
violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC
Enforcement Policy: NCV 05000483/2008003-03, Failure to Correct a Condition
Adverse to Quality for Diesel Generator Jacket Water O-Rings.
1R22 Surveillance Testing (71111.22)
a. Inspection Scope
The inspectors reviewed the test results for the following activities to determine whether
risk-significant systems and equipment were capable of performing their intended safety
function and to verify testing was conducted in accordance with applicable procedural
and Technical Specification requirements:
- April 2, 2008, Job 07513515.500, Routine surveillance auxiliary building Train A
negative pressure test
- April 4, 2008, Job 08501501, Routine surveillance Slave Relay K645 test of
essential service water component lineup
- April 18, 2008, Job 08501499, Routine surveillance Slave Relay K615 test
- April 29, 2008, Job 08501254.500, Residual heat removal Pump A inservice test
- 21 - Enclosure 2
- May 5, 2008, Jobs 08502271 and 08503327, Routine surveillance containment
base strong motion accelerometer seismic monitor calibration
- May 14, 2008, Job 07505653, Residual heat removal Train B valve inservice test
- June 11, 2008, Job 08504820, Routine surveillance diesel generator Train B
1-hour run
- June 17, 2008, Job 08503115, Safety injection system Train A valve inservice
test
- June 18, 2008, Job 08505155, Routine surveillance ECCS flow path verification
and venting
- June 23, 2008, Job 08506247, Reactor coolant system leakage surveillance,
reactor coolant system inventory balance, plant status
The inspectors observed in-plant activities and reviewed procedures and associated
records to determine whether: any preconditioning occurred; effects of the testing were
adequately addressed by control room personnel or engineers prior to the
commencement of the testing; acceptance criteria were clearly stated, demonstrated
operational readiness, and were consistent with the system design basis; plant
equipment calibration was correct, accurate, and properly documented; as left setpoints
were within required ranges; the calibration frequency was in accordance with Technical
Specifications, the FSAR, procedures, and applicable commitments; measuring and test
equipment calibration was current; test equipment was used within the required range
and accuracy; applicable prerequisites described in the test procedures were satisfied;
test frequencies met Technical Specification requirements to demonstrate operability
and reliability; tests were performed in accordance with the test procedures and other
applicable procedures; jumpers and lifted leads were controlled and restored where
used; test data and results were accurate, complete, within limits, and valid; test
equipment was removed after testing; where applicable, test results not meeting
acceptance criteria were addressed with an adequate operability evaluation or the
system or component was declared inoperable; where applicable for safety-related
instrument control surveillance tests, reference setting data were accurately incorporated
in the test procedure; equipment was returned to a position or status required to support
the performance of the safety functions; and all problems identified during the testing
were appropriately documented and dispositioned in the corrective action program.
Documents reviewed are listed in the attachment.
The inspectors completed six routine, three inservice test, and one reactor coolant
system leakage samples.
b. Findings
Introduction. A self-revealing Green NCV of Technical Specification 5.4.1.a,
Procedures, was identified after Callaway control room operators improperly entered
the wrong Technical Specification action statement due to the failure to maintain the
Technical Specification Bases current.
- 22 - Enclosure 2
Description. On June 17, 2008, during surveillance testing, Valve EMHV8823 failed to
indicate fully closed. Since EMHV8823 is an isolation valve for containment
Penetration 49, the licensee entered Technical Specification 3.6.3, Containment
Isolation Valves," Condition C, with an action to restore the valve to an operable status
or isolate the penetration within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The control room staff believed the
appropriate action statement was entered since Condition C is described in the
Technical Specification Bases as applicable to flow paths that meet the requirements of
a closed system per the Callaway FSAR. Chapter 6.2.6.3 of the Callaway FSAR
described Containment Penetration 49 as a closed engineered safety feature
containment penetration.
Approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after Valve EMHV8823 had been declared inoperable, Callaway
licensing personnel contacted the control room and informed them of an approved
Technical Specification Bases change that did not allow the classification of containment
Penetration 49 as a closed system. Procedure APA-ZZ-00108, Primary Licensing
Document; Change/Revision Process," required that the change be implemented within
45 days following approval. The Technical Specification Bases change was effective
May 1, 2008, but had not been issued to the control room. The change resulted in
Condition C of Technical Specification 3.6.3 applying specifically to penetrations for
which a single containment isolation valve is credited per flow path. Since containment
Penetration 49 relies on multiple valves for flow path isolation, the licensee determined
that Condition C of Technical Specification 3.6.3 was not applicable for Penetration 49,
and the wrong Technical Specification action statement had been entered following the
failed surveillance on Valve EMHV8823. The licensee determined that the more
restrictive Technical Specification 3.6.3, Condition A, should have been entered with an
action to isolate the affected penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
The licensee performed a containment entry following discovery of entry into Technical Specification 3.6.3, Condition A, and found that Valve EMHV8823 had failed its
surveillance due to out-of-adjustment position indicator limit switches. The valve was
verified closed with power removed allowing exit from Technical Specification 3.6.3,
Condition A.
Analysis. The performance deficiency associated with this finding involved the
licensees failure to ensure the Technical Specification Bases were maintained current
and available to the Callaway control room staff. This finding was greater than minor
because, if left uncorrected, the failure to maintain the Technical Specification Bases
current could become a more significant safety concern. This finding was determined to
affect the barrier integrity cornerstone. Using Manual Chapter 0609.04, Phase 1 - Initial
Screening and Characterization of Findings," this finding is determined to be of very low
safety significance since this finding did not represent an actual open pathway in the
physical integrity of reactor containment and did not involve an actual reduction in
function of hydrogen ignitors in the reactor containment. This finding had a crosscutting
aspect in the area of human performance associated with the decision making
component because the licensee failed to communicate, in a timely manner, decisions to
personnel who have a need to know the information in order to perform work safely
Enforcement. Technical Specification 5.4.1.a, Procedures, required that written
procedures be established and implemented covering activities specified in Appendix A,
Typical Procedures for Pressurized Water Reactors, of Regulatory Guide 1.33, Quality
- 23 - Enclosure 2
Assurance Program Requirements (Operation), February 1978. Regulatory Guide 1.33,
Appendix A, Section 1, required administrative procedures for procedure review and
approval. Procedure APA-ZZ-00108 provides a process for implementing Technical
Specification Bases change notices. Contrary to the above, on May 1, 2008,
Procedure APA-ZZ-00108 was not adequate to ensure changes to the Technical
Specification Bases were implemented in a timely manner. Because of the very low
safety significance and AmerenUEs action to place this issue in their corrective action
program as CAR 200805283, this violation is being treated as an NCV in accordance
with Section VI.A.1 of the Enforcement Policy: NCV 05000483/2008003-04, Failure to
Maintain an Adequate Technical Specification Bases Change Process.
2. RADIATION SAFETY
Cornerstone: Occupational Radiation Safety
2OS1 Access Control to Radiologically Significant Areas (71121.01)
a. Inspection Scope
This area was inspected to assess the licensees performance in implementing physical
and administrative controls for airborne radioactivity areas, radiation areas, high
radiation areas, and worker adherence to these controls. The inspectors used the
requirements in 10 CFR Part 20, the Technical Specifications, and the licensees
procedures required by Technical Specifications as criteria for determining compliance.
During the inspection, the inspectors interviewed the radiation protection manager,
radiation protection supervisors, and radiation workers. The inspectors performed
independent radiation dose rate measurements and reviewed the following items:
- Performance indicator events and associated documentation packages reported
by the licensee in the occupational radiation safety cornerstone
- Controls (surveys, posting, and barricades) of radiation, high radiation, or
airborne radioactivity areas
- Radiation work permits, procedures, engineering controls, and air sampler
locations
- Physical and programmatic controls for highly activated or contaminated
materials (non-fuel) stored within spent fuel and other storage pools
- Self-assessments, audits, LERs, and special reports related to the access control
program since the last inspection
- Changes in licensee procedural controls of high dose rate - high radiation areas
and very high radiation areas
- Controls for special areas that have the potential to become very high radiation
areas during certain plant operations
- Posting and locking of entrances to accessible high dose rate - high radiation
areas and very high radiation areas
- 24 - Enclosure 2
Documents reviewed are listed in the attachment.
The inspectors completed 8 of the required 21 samples.
b. Findings
No findings of significance were identified.
2OS2 ALARA Planning and Controls (71121.02)
a. Inspection Scope
The inspectors assessed licensee performance with respect to maintaining individual
and collective radiation exposures as low as is reasonably achievable (ALARA). The
inspectors used the requirements in 10 CFR Part 20 and the licensees procedures
required by technical specifications as criteria for determining compliance. The
inspectors interviewed licensee personnel and reviewed:
- Current 3-year rolling average collective exposure
- Site-specific trends in collective exposures, plant historical data, and source-term
measurements
- Site-specific ALARA procedures
- Work activities of highest exposure significance during the inspection
- Integration of ALARA requirements into work procedure and radiation work
permit documents
- Post-job (work activity) reviews
- Workers use of the low dose waiting areas
- First-line job supervisors contribution to ensuring work activities are conducted in
a dose efficient manner
- Records detailing the historical trends and current status of tracked plant source
terms and contingency plans for expected changes in the source term due to
changes in plant fuel performance issues or changes in plant primary chemistry
- Source-term control strategy or justifications for not pursuing such exposure
reduction initiatives
- Specific sources identified by the licensee for exposure reduction actions,
priorities established for these actions, and results achieved since the last
refueling cycle
- Radiation worker and radiation protection technician performance during work
activities in radiation areas, airborne radioactivity areas, or high radiation areas
- 25 - Enclosure 2
- Declared pregnant workers during the current assessment period, monitoring
controls, and the exposure results
- Self-assessments, audits, and special reports related to the ALARA program
since the last inspection
- Resolution through the corrective action process of problems identified through
post-job reviews and post-outage ALARA report critiques
- Corrective action documents related to the ALARA program and follow-up
activities, such as initial problem identification, characterization, and tracking
- Effectiveness of self-assessment activities with respect to identifying and
addressing repetitive deficiencies or significant individual deficiencies
Documents reviewed are listed in the attachment.
The inspectors completed 9 of the required 15 samples and 8 of the optional samples.
b. Findings
No findings of significance were identified.
4. OTHER ACTIVITIES
4OA1 Performance Indicator Verification (71151)
.1 Data Submission Issue
a. Inspection Scope
The inspectors performed a review of the data submitted by the licensee for the first
Quarter 2008 performance indicators for any obvious inconsistencies prior to its public
release in accordance with IMC 0608, Performance Indicator Program.
This review was performed as part of the inspectors normal plant status activities and,
as such, did not constitute a separate inspection sample.
b. Findings
No findings of significance were identified.
.2 Safety System Functional Failures
Cornerstone: Mitigating Systems
a. Inspection Scope
The inspectors sampled licensee submittals for the safety system functional failures
performance indicator for the period March 2007 until March 2008. To determine the
accuracy of the performance indicator data reported during this period, performance
indicator definitions and guidance contained in the Nuclear Energy Institute (NEI)
- 26 - Enclosure 2
Document 99-02, Revision 5, Regulatory Assessment Performance Indicator
Guideline, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73,"
definitions and guidance were used. The inspectors reviewed the licensees operator
narrative logs, operability assessments, maintenance rule records, maintenance work
orders, issue reports, event reports and NRC integrated inspection reports for the period
of 2nd Quarter 2007, through 1st Quarter 2008 to validate the accuracy of the
submittals. The inspectors also reviewed the licensees issue report database to
determine if any problems had been identified with the performance indicator data
collected or transmitted for this indicator and none were identified. Documents reviewed
are listed in the attachment.
This inspection constitutes one safety system functional failures sample as defined by
b. Findings
No findings of significance were identified.
.3 Mitigating Systems Performance Index - High Pressure Injection Systems
Cornerstone: Mitigating Systems
a. Inspection Scope
The inspectors sampled licensee submittals for the mitigating systems performance
index - high pressure injection systems performance indicator for the period from
March 2007 until March 2008. To determine the accuracy of the performance indicator
data reported during this period, performance indicator definitions and guidance
contained in the NEI Document 99-02, 5, Regulatory Assessment Performance
Indicator Guideline, Revision 5, were used. The inspectors reviewed the licensees
operator narrative logs, issue reports, mitigating systems performance index derivation
reports, event reports, and NRC integrated inspection reports for the period of
2nd Quarter 2007 through 1st Quarter 2008 to validate the accuracy of the submittals.
The inspectors reviewed the mitigating systems performance index component risk
coefficient to determine if it had changed by more than 25 percent in value since the
previous inspection, and if so, that the change was in accordance with applicable NEI
guidance. The inspectors also reviewed the licensees issue report database to
determine if any problems had been identified with the performance indicator data
collected or transmitted for this indicator and none were identified. Documents reviewed
are listed in the attachment.
This inspection constitutes one mitigating systems performance index high pressure
injection systems sample as defined by Inspection Procedure 71151.
b. Findings
No findings of significance were identified.
- 27 - Enclosure 2
.4 Occupational Exposure Control Effectiveness
Cornerstone: Occupational Radiation Safety
a. Inspection Scope
The inspectors reviewed licensee documents from October 1, 2007, through March 31,
2008. The review included corrective action documentation that identified occurrences
in locked high radiation areas (as defined in the licensees Technical Specifications),
very high radiation areas (as defined in 10 CFR 20.1003), and unplanned personnel
exposures (as defined in NEI 99-02, "Regulatory Assessment Indicator Guideline,"
Revision 5). Additional records reviewed included ALARA records and whole body
counts of selected individual exposures. The inspectors interviewed licensee personnel
that were accountable for collecting and evaluating the performance indicator data. In
addition, the inspectors toured plant areas to verify that high radiation, locked high
radiation, and very high radiation areas were properly controlled. Performance indicator
definitions and guidance contained in NEI 99-02, Revision 5, were used to verify the
basis in reporting for each data element.
The inspectors completed the required sample (1) in this cornerstone.
b. Findings
No findings of significance were identified.
.5 Radiological Effluent Technical Specification/Offsite Dose Calculation Manual
Radiological Effluent Occurrences
Cornerstone: Public Radiation Safety
a. Inspection Scope
The inspectors reviewed licensee documents from October 1, 2007, through March 31,
2008. Licensee records reviewed included corrective action documentation that
identified occurrences for liquid or gaseous effluent releases that exceeded performance
indicator thresholds and those reported to the NRC. The inspectors interviewed licensee
personnel that were accountable for collecting and evaluating the performance indicator
data. Performance indicator definitions and guidance contained in NEI 99-02,
Revision 5, were used to verify the basis in reporting for each data element.
The inspectors completed the required sample (1) in this cornerstone.
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems (71152)
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency
Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical
Protection
- 28 - Enclosure 2
.1 Routine Review of Items Entered into the Corrective Action Program
a. Inspection Scope
As part of the various baseline inspection procedures discussed in previous sections of
this report, the inspectors routinely reviewed issues during baseline inspection activities
to verify that they were being entered into the licensees corrective action program at an
appropriate threshold, that adequate attention was being given to timely corrective
actions, and that adverse trends were identified and addressed. The attributes reviewed
included: the complete and accurate identification of the problem; that timeliness was
commensurate with the safety significance; that evaluation and disposition of
performance issues, generic implications, common causes, contributing factors, root
causes, extent of condition reviews, and previous occurrence reviews were proper and
adequate; and that the classification, prioritization, focus, and timeliness of corrective
actions were commensurate with safety and sufficient to prevent recurrence of the issue.
These routine reviews for the identification and resolution of problems did not constitute
any additional inspection samples.
b. Findings
No findings of significance were identified.
.2 Daily Corrective Action Program Reviews
a. Inspection Scope
In order to assist with the identification of repetitive equipment failures and specific
human performance issues for follow-up, the inspectors performed a daily screening of
items entered into the licensees corrective action program. This review was
accomplished through inspection of the stations daily condition report packages.
These daily reviews were performed, by procedure, as part of the inspectors daily plant
status monitoring activities and, as such, did not constitute any separate inspection
samples.
b. Findings
No findings of significance were identified.
.3 Selected Issue Follow-up Inspection
a. Inspection Scope
The inspectors selected the below listed issues for a more in-depth review. The
inspectors considered the following during the review of AmerenUE's actions:
(1) complete and accurate identification of the problem in a timely manner; (2) evaluation
and disposition of operability/reportability issues; (3) consideration of extent of condition,
generic implications, common cause, and previous occurrences; (4) classification and
prioritization of the resolution of the problem; (5) identification of root and contributing
causes of the problem; (6) identification of corrective actions; and (7) completion of
corrective actions in a timely manner.
- 29 - Enclosure 2
- Voiding discovered in the common residual heat removal discharge piping for
high pressure recirculation.
- FSAR changes/updates
Documents reviewed are listed in the attachment.
This inspection constituted two in-depth problem identification and resolution samples.
b. Findings
Introduction. The inspectors identified a Green violation of 10 CFR Part 50, Appendix B,
Criterion XVI, "Corrective Action," because the licensee failed to take corrective actions
to preclude repetition of void formations in the ECCS, a significant condition adverse to
quality (SCAQ). Contributors to the violation included: (1) the failure of corrective
actions from inspection report findings NCV 05000483/2005002-01,
05000483/2006012-04 and CAR 200501092 to ensure adequate fill and vent of
systems following maintenance to replace safety injection system relief valves, and
(2) inadequate extent of condition reviews in responding to internal and external
operating experience associated with pipe sloping issues in the safety injection system.
Description. On May 21, 2008, the Callaway Plant staff initiated CAR 200804000, a
SCAQ corrective action document, indicating that some piping in Train A safety injection
system suction lines had incorrect sloping and were susceptible to voiding due to high
points. Callaway Plant engineering performed ultrasonic inspection of the safety
injection system common suction piping Line EM023-HCB - 6" and discovered a
6.6 cubic foot voided area. This exceeded the allowable void fraction of 2.1 cubic feet
required for operability. This voided piping, determined to have existed for over a year,
was caused by relief valve maintenance on Valve EM8858A (May 7, 2007). The
maintenance restoration failed to perform an adequate fill and vent to ensure the suction
pipe was full of water.
In 2005 and 2006 the NRC issued NCVs regarding ineffective corrective actions related
to safety injection system voids in discharge piping (05000483/2005002-01 dated May 6,
2005, and 05000483/2006012-04 dated December 26, 2006). These were each 10 CFR
Part 50, Appendix B, Criterion XVI, NCVs, each for SCAQ. The Callaway Plant staff
issued CAR 200501092 as a SCAQ corrective action document. The CAR determined
that the causes of the voids (2004, 2005, and 2006) were related to incorrect pipe
sloping (allowing high points where voids could not be swept away by normal online
pump surveillances) and inadequate postmaintenance fill and vent operations (following
discharge piping relief Valve EM8853A replacement) to ensure the piping was full of
water.
Inadequate Operating Experience and Extent of Condition Corrections: The
inspectors identified several related examples where the licensee had performed either
inadequate operating experience evaluations, inadequate extent of condition reviews, or
inadequate procedure corrections.
Callaway CAR 200501092 referenced industry operating experience at Beaver Valley
Unit 2 in 2002: "The void was located in the piping used following a loss of coolant
- 30 - Enclosure 2
accident after the transfer to containment sump recirculation. The piping containing the
void led to a common suction header for both trains of high head pumps." This was the
same location as the voiding discovered at Callaway Plant on May 21, 2008.
NRC Information Notice 2006-21, "Operating Experience Regarding Entrainment of Air
into Emergency Core Cooling and Containment Spray Systems," dated September 21,
2006, discussed mechanisms that could result in air entrainment on the suction sides of
emergency core cooling pumps. The notice emphasized the importance of ensuring that
entrained air will not enter suction supply lines and impair the ability of the ECCS and
containment spray pumps to perform their safety function.
The licensee's evaluation of NRC Information Notice 2006-21 was documented in
CAR 200608956. It stated that the information notice was applicable to Callaway and
that past review of these operating experiences and Callaway procedures and practices
were adequate. The CAR was closed December 5, 2006.
Callaway CAR 200501092 had Action 7 assigned to address the previous NRC
violations discussed above. The action required that system specific fill and vent
restoration guidance be developed to address maintenance on ECCS safety-related
systems. Initially, operating department Standing Order 05-002 dated June 8, 2005,
stated that the CAR 200501092 common cause analysis supported the need for
formalized restoration instructions. Until the system specific restoration instructions
were developed, the standing order required reactor operators to perform reviews to
ensure dynamic filling and venting occurred to reduce the susceptibility of voiding. Also
nuclear engineering department staff were to provide concurrence on such restoration
plans. Night Order ODP-ZZ-00310, "System Fill and Vent," issued February 13, 2006,
reiterated that reactor operator reviews and engineering concurrence were required
when these risk-significant systems were drained. However, on May 7, 2007,
Procedure OTN-EM-00001, "Safety Injection System," (developed to address filling and
venting evaluations) had Line EM-023-HCB - 6" isolated by Valve EMHIS8807B being
closed. The procedure did not include use of the available installed vent Valve EM179
for this line.
Callaway monthly Surveillance OSP-SA-00003, "Emergency Core Cooling Flow Path
Verification and Venting," had a purpose to: "Verify the ECCS is full of water in
accordance with Technical Specification Surveillance Requirement 3.5.2.3." This
monthly surveillance was reviewed as part of CAR 200501092 corrective actions.
Callaway engineering had determined that residual heat removal pump discharge vent
Valve EJV0193 to the safety injection suction line was the high point vent for these lines
and was thus sufficient to vent supply Line EM-023-HCB - 6" to the safety injection
pumps. However, this vent valve was not adequate due to the pipe sloping issues and
normally closed Valves EMHIS8807A/B. The monthly verification and vent procedure
was inadequate to remove the air entrained by the May 7, 2007, relief valve
maintenance. See Section 1R15, NCV 05000483/2008003-02.
Callaway CARs 200800226 and 200800246, initiated in January 2008, discussed
operating experience at Wolf Creek Nuclear Operating Corporation describing gas
voiding in the residual heat removal piggyback Line EM-022-HCB - 6" to the suction of
centrifugal charging pumps and safety injection pumps. The CARs stated that Callaway
had taken a proactive approach and had immediately performed ultrasonic testing to
demonstrate that the associated piping was water solid. However, the adjacent
- 31 - Enclosure 2
connecting Line EM-023-HCB - 6" had not been vented nor had ultrasonic testing
occurred since the May 7, 2007, relief Valve EM8858A maintenance.
NRC Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling,
Decay Heat Removal, and Containment Spray Systems," was issued January 11, 2008.
The Callaway Plant staff initiated CAR 200800298 to respond to the generic letter. The
generic letter identified that a licensing basis concern existed for some plants, such as
Callaway, that Technical Specifications require verifying that ECCS discharge piping is
full of water but may not include verification of the suction piping despite the realistic
concern that gas accumulation in suction piping may be more serious than gas
accumulation in discharge piping. The void found in Line EM-023-HCB - 6" was the
discharge of the residual heat removal pumps providing suction to the Train A safety
injection pump. The Callaway monthly Surveillance OSP-SA-00003, "Emergency Core
Cooling Flow Path Verification and Venting," did not test for or vent the discharge line
from residual heat removal to safety injection pump suction piping.
Analysis. The inspectors determined that the failure to restore compliance within a
reasonable time by establishing measures to prevent void formation in ECCS suction
piping for the Train A safety injection system was a performance deficiency. This finding
is more than minor because it was similar to Example 3e of NRC Inspection Manual
Chapter 0612, Appendix E, "Examples of Minor Issues," and met the Not Minor If,
criteria because the failure to meet the licensees administrative requirement for
allowable void fraction impacted the ability of the Train A safety injection system to
function upon initiation of high-pressure recirculation. Using Manual Chapter 0609.04,
Phase 1 - Initial Screening and Characterization of Findings, the inspectors determined
that this finding should be evaluated using the Phase 2 process described in Manual
Chapter 0609, Appendix A, Determining the Significance of Reactor Inspection Findings
for At-Power Situations.
The senior reactor analyst determined that the risk of this finding was bounded by that
analyzed for NCV 05000423/2008003-02 (See Section 1R15.b.2). Therefore, this
finding was of very low risk significance (Green).
This finding has a crosscutting aspect in the area of problem identification and resolution
associated with the corrective action component because AmerenUE failed to thoroughly
evaluate voiding problems such that the resolutions addressed causes and extent of
condition, as necessary. This also includes, for significant problems, conducting
effectiveness reviews of corrective actions to ensure that the problems are resolved
Enforcement. 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," requires
the licensee to, in the case of SCAQ, establish measures to assure that the cause of the
condition is determined and corrective action is taken to preclude repetition. Contrary to
the above, from December 26, 2006, to May 21, 2008, the licensee did not implement
corrective action to preclude repetition of void formation in the safety injection piping
which the licensee categorized as an SCAQ. Specifically, void formation recurred after
performing maintenance on relief valve. Valve EM8858A, on May 7, 2007. Previously
discovered voiding of the safety injection system was last documented as an SCAQ in
NCV 05000483/2006012-04 dated December 26, 2006. For each instance of the
previously discovered voids, the causes were determined to be related to inadequate fill
and vent of the system piping following relief valve replacements and design deficiencies
- 32 - Enclosure 2
associated with inadequate sloping of the piping. It was a reasonable assumption that
maintenance that drained either the suction or discharge piping could create significant
void areas.
Although this violation is of very low safety significance, the violation is being
cited in a Notice of Violation consistent with Section VI.A.1 of the NRC Enforcement
Policy because the licensee did not restore compliance within a reasonable
time after a previous violation NCV 05000483/2006012-04 was identified:
VIO 05000483/2008003-05, Failure to Prevent Recurrence of Voids in ECCS Cold Leg
Recirculation Piping. This finding has been entered into the licensee's corrective action
program as a SCAQ in CAR 200804000.
.4 Semiannual Trend Review
The inspectors assessed trends that might indicate the existence of a more significant
safety issue. These issues included trends that might not rise to the level of an
inspection finding.
NRC-Identified Trends
The NRC identified emergency diesel generator material condition and design control
issues degrading diesel reliability:
- CAR 200801270: 80 Drops per minute jacket water leak identified on Diesel
Generator B
- CAR 200801644: Additional sacrificial anode found in Emergency Diesel
Generator A intercooler heat exchanger
- CAR 200802019: Emergency Diesel Generator B declared inoperable due to
fuel oil leaks
- CAR 200802177: Cracked fuel oil return line fitting identified on Emergency
Diesel Generator A
- CAR 200804164: Emergency Diesel Generator A declared inoperable due to a
200 drops per minute jacket water leak
Licensee-Identified Trends
The licensee identified a continued trend in plant status control and configuration control
with a key causal factor being procedure adherence.
of plant status control issues to be a "Failure to follow written instructions."
Procedure OSP-EN-P001A.
- CAR 200800580: A trend of critical steps not being included in work packages
was identified.
- 33 - Enclosure 2
- CAR 200802603: Component cooling water pump autostarted due to an
interlock with the centrifugal charging pumps. The operator failed to wait the
procedure prerequisite 30 minutes prior to securing the component cooling water
pump.
- CAR 200802818: Source range Channel N31 was not restored to "block" as
required by procedure in Mode 1.
- CAR 200800328: Not following procedures resulted in gaseous Radiation
Monitor RM-11 trip setpoint not being capable of isolating the waste gas decay
tank release.
- CAR 200803351: Steam generator blowdown tripped due to an incorrect
demineralizer valve lineup.
- CAR 200804483: Train B motor-driven auxiliary feedwater pump made
inoperable when its room cooler was taken to "stop" vice "auto." This was
performed outside the out of service restoration process.
This inspection constituted one semiannual trend review sample.
4OA3 Event Follow-up (71153)
(Closed) LER 05000483/2008-001-00, Containment Cooler Inoperability
On March 26, 2008, Containment Air Cooler A fan shut down when shifted from fast to
slow speed. The licensee determined that operation of containment air coolers in fast
speed, during a period of higher than normal containment pressure, would challenge the
fast speed thermal overload setpoint. Additionally, since the overload contacts are wired
in series, containment air coolers were determined to experience a complete loss of
control power following a trip from fast speed. The licensee analyzed the potential
impact of the containment cooler design vulnerability against design basis accident
scenarios. The licensee determined that a hot zero power main steam line break results
in a delayed safety injection signal allowing the fan motor overloads to trip prior to being
shed from the load sequencer. In this scenario, utilizing actual plant conditions, the peak
containment pressure would not exceed the 48.1 psig limit described in the FSAR. To
address the design deficiency associated with the containment air cooler control
circuitry, the licensee completed a modification in April 2008 to reconfigure the circuit
such that tripping of the fast speed overloads would not impact the safety-related slow
speed function of the containment air coolers. This finding is of very low safety
significance because the containment coolers are structures, systems, and components
that are not significant contributors to the large early release frequency. Licensee
corrective actions were recorded in CAR 200802264. The inspectors reviewed the LER
and identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion III, Design
Control, for the licensees failure to adequately review the suitability of the design of the
containment air cooler control circuitry (Section 1R15). This LER is closed.
This inspection constituted one sample of follow-up of events.
- 34 - Enclosure 2
4OA5 Other Activities
.1 Quarterly Resident Inspector Observations of Security Personnel and Activities
a. During the inspection period, the inspectors performed the following observations of
security force personnel and activities to ensure that the activities were consistent with
licensees security procedures and regulatory requirements relating to nuclear plant
security. These observations took place during both normal and off-normal plant
working hours.
These quarterly resident inspector observation of security force personnel and activities
did not constitute any additional inspection samples. Rather, they were considered an
integral part of the inspectors normal plant status review and inspection activities.
b. Findings
No findings of significance were identified.
.2 (Closed) NRC Temporary Instruction 2515/166: Pressurized Water Reactor
Containment Sump Blockage
a. Inspection Scope
From March 17-19, 2008, the inspectors reviewed the licensees implementation of plant
modifications and design modification packages associated with their response to
Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency
Recirculation During Design Basis Accidents at Pressurized Water Reactors. The
inspectors reviewed various aspects of the on-going procedural changes. Those
changes that have been completed were verified to be properly documented in
accordance with the requirements of 10 CFR 50.59. At the completion of this inspection,
the licensee had completed the installation stage of the new sump strainers; many of the
procedural changes associated with the modifications had not been completed.
The inspectors compared and evaluated the recirculation sump modifications to the
original design basis using Temporary Instruction 2515/166 and referred to Regulatory
Guide 1.82, Revision 0, Water Sources for Long-Term Recirculation Cooling Following
a Loss-of-Coolant Accident.
Status of the implementation of the plant modifications and procedure changes
committed to by the licensee in their Generic Letter 2004-02 response is:
1. Containment walkdown to provide current assessment of Callaway's containment
coatings and latent debris.
The licensee completed a containment walkdown and latent debris assessment
during Refueling Outage 14. The resident inspectors completed a walkdown of
the containment prior to reactor startup following the outage. The licensee
report, Containment Building Latent Debris Assessment Refuel 14 Fall 2005,
was reviewed by the inspectors.
- 35 - Enclosure 2
2. The following corrective action activities will be completed:
a. Replacement sump strainer structural analysis.
The strainers were not built in accordance with the design. As a result,
calculations needed to be revised due to the deviations of the as built
condition from design and errors in temperature correction values used in
the initial calculations. Completion date: June 30, 2008
b. Downstream effects evaluation
Completion date: June 30, 2008
c. Upstream effects evaluation
Completion date: June 30, 2008
d. Resolution of debris generation calculation unverified assumption of 5D
ZOI for qualified coatings (via coatings testing)
Completion date: June 30, 2008
e. Replacement sump screen head loss testing
Completion date: June 30, 2008
3. Provide an update of the information contained in Section 2(c) regarding analysis
methodology.
Completion date: June 30, 2008
4. The following evaluations and testing will be completed.
a. Industry chemical effects testing
Completion date: June 30, 2008
b. Nuclear Energy Institute 04-07 debris generation calculation
Completion date: June 30, 2008
c. Evaluation of chemical effects impact on sump-strainer head loss
Completion date: June 30, 2008
d. Confirmation that the replacement sump strainer design provides for
available Net Positive Suction Head (NPSH) to be in excess of required
Completion date: June 30, 2008
- 36 - Enclosure 2
e. Completion of the final site acceptance review of the Westinghouse team
analysis summary report
Completion date: June 30, 2008
5. Callaway Plant will complete the following items during Refueling Outage15:
a. Replacement of containment recirculation sump strainers
Completed. As noted in the previous Temporary Instruction 166 report,
the resident inspectors had observed the installation of sump strainers
and debris barriers during their containment walkdown; however, the
strainers were not built in accordance with the design. The licensee has
completed their initial determination of operability and was finalizing their
acceptance calculations.
b. Modification of containment debris barriers and interceptors as required
Completed. As noted in the previous Temporary Instruction 166 report,
the resident inspectors had observed the installation of sump strainers
and debris barriers during their containment walkdown.
c. Evaluation and implementation of potential modification to the safety
injection system to address downstream effects
Completion date: June 30, 2008
6. Callaway Plant will complete removal of containment spray system pump cyclone
separators, if required, based on the results of the downstream effects
evaluation.
Completion date: June 30, 2008
7. The following programs and controls will be implemented at Callaway Plant to
control debris sources:
a. Changes to design change process procedures to ensure that necessary
engineering evaluations will be performed for plant design that either
directly or indirectly affects containment, ECCS, or CSS.
Changes are being processed.
b. Changes to containment entry and material control procedure
requirements for control of materials during work activities conducted in
the containment
c. The following procedures were reviewed and completed as of
December 2007:
APA-ZZ-01004, Radiological Work Standards, Revision 9
HDP-ZZ-06100, Reactor Building Access, Revision 7
- 37 - Enclosure 2
MDP-ZZ-S0001, Scaffolding Installation and Evaluation, Revision 22
OSP-EJ-00003, Containment Recirculation Sump Inspection, Revision 6
OSP-SA-00004, Visual Inspection of Containment for Loose Debris,
Revision 19
OTS-ZZ-06032, Addendum 1, Debris and Particulate Control Devices,
Revision 2
d. Changes to programs and procedures that have the potential to add tags
and labels inside containment
Completed: December 2007
The following documents were reviewed:
APA-ZZ-01004, Radiological Work Standards, Revision 9
HDP-ZZ-06100, Reactor Building Access, Revision 7
MDP-ZZ-S0001, Scaffolding Installation and Evaluation, Revision 22
OSP-EJ-00003, Containment Recirculation Sump Inspection, Revision 6
OSP-SA-00004, Visual Inspection of Containment for Loose Debris,
Revision 19
OTS-ZZ-06032, Addendum 1, Debris and Particulate Control Devices,
Revision 2
e. Implementation of a containment coatings assessment program
Licensee reported as complete. The inspectors reviewed SWE07848,
Containment Coating Condition Assessment. A preventative
maintenance item has been scheduled to perform containment coating
assessments with a periodicity of each refueling cycle.
f. Implementation of a containment latent debris assessment program
Licensee reported as complete. The inspectors reviewed report,
Containment Building Latent Debris Assessment Refuel 14 Fall 2005,
and Procedure OSP-SA-00004, Visual Inspection of Containment for
Loose Debris, Revision 019. A preventative maintenance item has been
scheduled for a visual inspection of containment for loose debris with a
periodicity of each refueling cycle.
g. Implementation of changes to the inspection processes for the installed
sump strainers
Licensee reported as complete. Reviewed Procedure OSP-EJ-00003,
Containment Recirculation Sump Inspection, Revision 6
- 38 - Enclosure 2
8. A final response will be submitted to the NRC to provide a final status of actions
requested by Generic Letter 2004-02.
Completion date: June 30, 2008
The Office of Nuclear Reactor Regulation will determine the adequacy of the sump
modifications with respect to Generic Safety Issue 191. This temporary instruction is
closed.
Documents reviewed by the inspectors are listed in the attachment.
b. Findings
No findings of significance were identified.
4OA6 Management Meetings
Exit Meeting Summary
On April 25, 2008, the health physics inspector presented the occupational radiation
safety inspection results to Mr. T. Herrmann and other members of his staff who
acknowledged the findings. The inspector confirmed that proprietary information was
not provided or examined during the inspection.
On June 18, 2008, the Temporary Instruction 2515/166 inspector presented the
inspection results to Mr. S. Maglio and other members of his staff who acknowledged the
findings. The inspector confirmed that proprietary information provided or examined
during the inspection had been returned.
On June 24, 2008, the resident inspectors presented the inspection results to
Mr. C. Naslund, Senior Vice President and Chief Nuclear Officer, and other members of
the licensee staff. The licensee acknowledged the issues presented. The inspectors
understood and acknowledged that proprietary information reviewed would not be
retained following report issuance.
4OA7 Licensee-Identified Violations
The following violations of very low safety significance (Green) were identified by the
licensee and were violations of NRC requirements which meet the criteria of Section VI
of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as NCVs.
- 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part,
that applicable regulatory requirements and the design basis are correctly
translated into specifications, drawings, procedures, and instructions.
Contrary to the above, on March 5, 2008, the licensee identified that a 4-foot
section of suction piping within containment spray system, Train A was
approximately 50 percent voided. Voiding within the containment spray
system was due to a design deficiency that did not allow for a proper fill and
vent of the system. This was entered in the licensees corrective action
program as CAR 200803462. This finding is greater than minor because it is
similar to the Example 3j in Manual Chapter 0612, Appendix E, "Examples of
- 39 - Enclosure 2
Minor Issues," in that the presence of air within the containment spray system
suction header resulted in a condition where there was reasonable doubt on
the operability of the system. This finding is of very low safety significance
because it was a design or qualification deficiency confirmed not to result in
loss of operability.
- 10 CFR Part 50, Appendix B, Criterion III, requires measures be established
to assure that applicable regulatory requirements and design basis be
correctly translated into specifications, drawings, procedures, and
instructions. Technical Specifications 3.5.2 and 3.6.6 require that residual
heat removal and containment spray system components remain operable.
Contrary to this, measures were not adequate to assure installed center tube
diameters for the containment recirculation sump modification were correctly
accounted for by an accurate net positive suction head calculation.
The vendor supplying AmerenUE the containment recirculation sump strainer
identified that associated Vendor Calculation TDI-6002-05 for clean strainer
head loss did not account for the installed orifices located in the strainer
support plate. The size of the orifice beneath each strainer was smaller than
assumed in head loss calculations and was not large enough to prevent head
loss in excess of the net positive suction head required as defined in the
purchase specification supplied to the strainer vendor. The additional head
loss due to the calculation translation error was 2.28 feet. This resulted in
required net positive suction head being less than available. AmerenUE
performed three separate operability determination reviews to demonstrate
that the head loss margin could be recovered. The initial operability
determination on January 22, 2008, addressed the smaller support plate
orifice holes by using a separate vendor's flow analysis of the residual heat
removal and containment spray piping systems to demonstrate lower flow
and head losses than described in the FSAR. This operability determination
resulted in the limiting case flow path being the hot leg recirculation flow path.
Another operability review on March 12, 2008, addressed a nonconservative
temperature correction through the orifices. Subsequent to this, the licensee
informed the NRC that the additional nonconservative inputs were used in
the January 22, 2008, flow re-analysis of the residual heat removal system.
Additional analyses were performed to regain margin. This resulted in the
limiting case flow path changing from hot leg recirculation to cold leg
recirculation.
This example of inadequate design control was captured in the licensees
corrective action program as CARs 200800461 and 200802618. These
corrective action reviews documented three causes related to the following
design error:
- Time pressure to address Generic Letter 2004-02
- A complex design with parallel sequencing of different parts of the
design
- AmerenUE not independently verifying the vendor's design due to
perceived expertise and an approved 10 CFR Part 50, Appendix B,
- 40 - Enclosure 2
Quality Assurance program. AmerenUE did not perform a review of
the design, nor did they contract to have a third party engineering
review of the design.
This finding is greater than minor because it is similar to the Example 3j in
Manual Chapter 0612, Appendix E, Examples of Minor Issues, in that the
contractor error translating the design to the calculations resulted in a
condition where there was reasonable doubt on the operability of the ECCS.
This finding is of very low safety significance because it was a design or
qualification deficiency confirmed not to result in loss of operability. This
licensee-identified violation closes out Unresolved
Item 05000483/2008002-01.
ATTACHMENT: SUPPLEMENTAL INFORMATION
- 41 - Enclosure 2
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
B. Barton, Training Manager
M. Brandes, Consulting Engineer, Nuclear Engineering - Major Modifications
K. Bruckerhoff, Supervisor, Emergency Preparedness
F. Diya, Plant Director
T. Elwood, Supervising Engineer, Licensing
R. Farnam, Manager, Radiation Protection
K. Gilliam, Supervisor, Radiation Protection
L. Graessle, Manager, Regulatory Affairs
A. Heflin, Vice President, Nuclear
T. Herrmann, Vice President, Engineering
B. Holderness, Senior Health Physicist, Environmental Services
L. Kanuckel, Manager, Quality Assurance
D. Lantz, Superintendent of Operations Training
S. Maglio, Assistant Manager, Regulatory Affairs
R. Myatt, Supervisor, Engineering
K. Mills, Manager, Engineering
D. Neterer, Manager, Nuclear Operations
T. Parker, Trainer, Radiation Protection
S. Petzel, Engineer, Regulatory Affairs
J. Pitts, Component Engineer
V. Rider, ALARA Specialist, Radiation Protection
LIST OF ITEMS OPENED AND CLOSED
Opened
05000483/2008003-05 VIO Failure to Prevent Recurrence of Voids in ECCS Cold Leg
Recirculation Piping (Section 4OA2)
Opened and Closed
05000483/2008003-01 NCV Failure to Ensure the Suitability of the Design of the
Containment Air Cooler Control Circuitry (Section 1R15)05000483/2008003-02 NCV Inadequate Surveillance Procedure Resulted in an
Inoperable ECCS (Section 1R15)05000483/2008003-03 NCV Failure to Correct a Condition Adverse to Quality for
Diesel Generator Jacket Water O-Rings (Section 1R19)05000483/2008003-04 NCV Failure to Maintain an Adequate Technical Specification
Bases Change Process (Section 1R22)
Closed
05000483/2008001-00 LER Containment Cooler Inoperability (Section 4OA3)05000483/2008002-01 URI Containment Recirculation Sump Operability
(Section 4OA7)
A-1 Attachment
LIST OF DOCUMENTS REVIEWED
The following is a partial list of documents reviewed during the inspection. Inclusion on this list
does not imply that the NRC inspector reviewed the documents in their entirety, but rather that
selected sections or portions of the documents were evaluated as part of the overall inspection
effort. Inclusion of a document on this list does not imply NRC acceptance of the document or
any part of it, unless this is stated in the body of the inspection report.
Section 1R01: Adverse Weather Protection
Procedures
ODP-ZZ-00001, Operations Department - Code of Conduct, Revision 41
OSP-NB-00001, Class 1E Electrical Source Verification, Revision 032
OTN-NB-0001A, 4.16 KV Vital (Class 1E) Electrical System - A Train, Revision 12
OTN-NB-0001A, Addendum 5, NB01 Loss of Power Recovery, Revision 0
OTO-ZZ-00012, Severe Weather, Revision 10
Miscellaneous
AmerenUE Response to Generic Letter 2006-02, Grid Reliability and the Impact on Plant Risk
and the Operability of Offsite Power
Training Lesson Plan LP-01, Systems, Switchyard MD
Training Lesson Plan T61.0110.6, Systems, Switchyard MD
Section 1RO4: Equipment Alignment
Drawings
M-22AL01A, Piping and Instrumentation Diagram Auxiliary Feedwater System, Revision 33
M-22BB01(Q), Piping and Instrumentation Diagram Reactor Coolant System, Revision 30
M-22BB03A(Q), Piping and Instrumentation Diagram Reactor Coolant System, Revision 9
M-22BB03B(Q), Piping and Instrumentation Diagram Reactor Coolant System, Revision 9
M-22BB03C(Q), Piping and Instrumentation Diagram Reactor Coolant System, Revision 7
M-22BB03D(Q), Piping and Instrumentation Diagram Reactor Coolant System, Revision 7
M-22BG01(Q), Piping and Instrumentation Diagram Chemical and Volume Control System,
Revision 28
M-22BG03(Q), Piping and Instrumentation Diagram Chemical and Volume Control System,
Revision 52
A-2 Attachment
M-22EJ01(Q), Piping and Instrumentation Diagram Residual Heat Removal System,
Revision 57
M-22EM01(Q), Piping and Instrumentation Diagram High Pressure Coolant Injection System,
Revision 33
M-22EM02(Q), Piping and Instrumentation Diagram High Pressure Coolant Injection System,
Revision 19
M-22EP01(Q), Piping and Instrumentation Diagram Accumulator and Safety Injection,
Revision 16
Section 1RO5: Fire Protection
Miscellaneous
Drill Number 08-01, Evaluate Fire Brigade Response in a Radiation Area, dated March 27, 2008
Drill Critique Number 08-01, Unannounced Fire Drill, dated March 27, 2008
FSAR, Appendix 9.5B, Fire Hazard Analysis
Section 1R11: Licensed Operator Requalification Program
Procedures
OTA-RK-00024, Addendum 98D, Seismic Event, Revision 0
OTO-SG-0001, Design Basis Earthquake, Revision 13
Section 1R12: Maintenance Effectiveness
Procedures
EDP-ZZ-01128, Maintenance Rule Program, Revision 8
NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear
Power Plants, Revision 3
Callaway Action Requests
200706892 200801644 200802854
Section 1R13: Maintenance Risk Assessment and Emergent Work Controls
Procedure
EDP-ZZ-01129, Callaway Plant Risk Assessment, Revision 14
Section 1R15: Operability Evaluations
Calculations
ARC-687, AFT Fathom 6.0 Output, Revision 0
A-3 Attachment
M-FL-18, LOCA and MSLB Containment Flood Level, Revision 1
WES-009-CALC-001, Wolf Creek/Callaway Post-LOCA Containment Water Level Calculation,
Revision 0
Callaway Action Requests
200800461 200802352 200803462
200802231 200802365 200804000
200802264 200802618
200802348 200803252
Drawings
E-018-00141, Sz. 5 2SP-1WD Schematic, Revision 19
E-018-00214, Wiring Diagram 2SP-1WD (Size 5), Revision 19
E-018-00273, Motor Control Center Ambient Compensated Overload Relay Heater Chart,
Revision 3
E-018-00847, Overload Relay Time Current Characteristics, Revision 4
E-018-00852, Sz. 5 2SP-1WD Schematic, Revision 11
E-018-00853, Wiring Diagram 2SP 1WD (Size 5), Revision 12
E-22NF01, Load Shedding and Emergency Load Sequencing Logic, Revision 5
E-23GN02, Schematic Diagram Containment Cooler Fans A and C, Revision 12
E-23GN02A, Schematic Diagram Containment Cooler Fans B and D, Revision 13
J-22GN02A, Containment Cooling System Containment Cooling Fans SGN01A and SGN01C,
Revision 2
J-22GN02C, Containment Cooling System Containment Cooling Fans SGN01B and SGN01D,
Revision 1
M-018-00943, 206 Ez-Flo Expansion Joint, Revision 0
M-22BG03, Piping and Instrumentation Diagram Chemical and Volume Control System,
Revision 52
M-22EM01, Piping and Instrumentation Diagram High Pressure Coolant Injection System,
Revision 33
M-23BG02, Piping Isometric CVCS-Max Charging Flow A and B Train Auxiliary Building,
Revision 12
A-4 Attachment
Procedures
ECA-0.1, Loss of All AC Power Recover Without Safety Injection Required, Revision 8
ECA-1.1, Loss of Emergency Coolant Recirculation, Revision 8
EDP-ZZ-04021, Review of Supplier Documents, Revision 5
ISF-SE-00N32, FCTNAL-NUC INSTM SOURCE RANGE N32, Revision 20
OSP-EJ-PV04A, Train A RHR and RCS Check Valve Inservice Test -IPTE, Revision 0
OSP-EJ-PV04B, Train B RHR and RCS Check Valve Inservice Test -IPTE, Revision 1
OTN-EN-00001, Containment Spray System, Revision 14
OTN-GN-00001, Containment Cooling and CRDM Cooling, Revision 1
Miscellaneous
Job 07513275 for SEN0032
Letter ULNRC-04884, Docket Number 50-483, Callaway Plant Unit 1, Union Electric Co.,
Facility Operating License NPF-30, Response to NRC Bulletin 2003-01, Potential Impact of
Debris Blockage on Emergency Sump Recirculation at Pressurized Water Reactor, dated
August 3, 2003
Letter ULNRC-05481, Docket Number 50-483, Callaway Plant Unit 1, Union Electric Co.,
Facility Operating License NPF-30 Response to Request for Additional Information, Response
to NRC Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency
Recirculation During Design Basis Accidents at Pressurized Water Reactors, dated
February 29, 2008
Garlock Sealing Technologies Customer Requested Test 206 Ez-Flo Expansion Test, dated
November 15, 2006
Section 1R18: Plant Modifications
Procedure
OTN-KA-00001, Compressed Air System, Revision 18
Drawings
E-018-00141, Sz. 5 2SP-1WD Schematic, Revision 19
E-018-00214, Wiring Diagram 2SP-1WD (Size 5), Revision 19
E-018-00852, Sz. 5 2SP-1WD Schematic, Revision 11
E-018-00853, Wiring Diagram 2SP 1WD (Size 5), Revision 12
E-22NF01, Load Shedding and Emergency Load Sequencing Logic, Revision 5
A-5 Attachment
E-23GN02, Schematic Diagram Containment Cooler Fans A and C, Revision 12
E-23GN02A, Schematic Diagram Containment Cooler Fans B and D, Revision 13
J-22GN02A, Containment Cooling System Containment Cooling Fans SGN01A and SGN01C,
Revision 2
J-22GN02C, Containment Cooling System Containment Cooling Fans SGN01B and SGN01D,
Revision 1
M-22KA01, Piping and Instrumentation Diagram Compressed Air System, Revision 016A
M-22KA06, Piping and Instrumentation Diagram Instrument Air Filter/Dryer Turbine, Building,
Revision 30A
Miscellaneous
Modification Package 08-0013, Containment Coolers DSGN01A/B/C/D Control Circuit Change,
Revision 0
Job
08003842
Section 1R19: Postmaintenance Testing
Procedures
APA-ZZ-00330, Preventative Maintenance Program, Revision 29
OTN-GN-00001, Containment Cooling and CRDM Cooling, Revision 14
Callaway Action Requests
200801270 200802810 200804164
Jobs
06524419 08001080 08002765
07006905 08002676 08003910
Drawings
E-018-00141, Sz. 5 2SP-1WD Schematic, Revision 19
E-018-00214, Wiring Diagram 2SP-1WD (Size 5), Revision 19
E-018-00853, Wiring Diagram 2SP 1WD (Size 5), Revision 12
E-018-00852, Sz. 5 2SP-1WD Schematic, Revision 11
E-22NF01, Load Shedding and Emergency Load Sequencing Logic, Revision 5
A-6 Attachment
E-23GN02, Schematic Diagram Containment Cooler Fans A and C, Revision 12
E-23GN02A, Schematic Diagram Containment Cooler Fans B and D, Revision 13
J-22GN02A, Containment Cooling System Containment Cooling Fans SGN01A and SGN01C,
Revision 2
J-22GN02C, Containment Cooling System Containment Cooling Fans SGN01B and SGN01D,
Revision 1
Miscellaneous
Modification Package 08-0013, Containment Coolers DSGN01A/B/C/D Control Circuit Change,
Revision 0
Simple Surveillance SP08-017, Containment Cooler Control Circuit Changes, dated April 16,
2008
Section 1R22: Surveillance Testing
Procedures
EDP-ZZ-04107, HVAC Pressure Boundary Control, Revision 19
FDP-ZZ-00101, Technical Specification Bases Control Program, Revision 6
OSP-GL-0001A, Auxiliary Building Train A Negative Pressure Test, Revision 6
OSP-EJ-P001A, RHR Train A inservice Test - Group A, Revision 44
OSP-EJ-V001B, Residual heat removal Train B valve inservice test, Revision 21
OSP-NE-0001B, Standby Diesel Generator B Periodic Tests, Revision 29
OSP-SA-00003, Emergency Core Cooling System Flow Path Verification and Venting,
Revision 30
Section 2OS1: Access Controls to Radiologically Significant Areas and
Section 2OS2: ALARA Planning and Controls
Callaway Action Requests
200703726 200800631 200800991
200703956 200800632 200801135
200710799 200800633 200801390
200711181 200800727 200801430
200711846 200800838 200802003
200711875 200800887 200802280
200711880 200800888 200803141
200711881 200800891 200803204
200711883 200800957 200803205
200800219 200800973 200803208
200800438 200800988
A-7 Attachment
Audits and Self-Assessments
Quality Assurance Audit of Radiation Protection AP08-001, February 28, 2008
Quality Assurance Supplemental Audit of Radwaste AP07-012, October 30, 2007
Simple Self-assessment Report SA07-RP-S06, January 9, 2008
Radiation Work Permits/ALARA Reviews
RWP 803321RESIN, Transfer Spent Resin from Primary Tank to Liner
ALARA Package 07-03120, Reinstall Bladders into the Recycle Hold Up Tanks
Other/Meetings/Training/Work Review
ALARA Simulator Class
Callaway Plant Long Range Dose and Source Term Reduction Plan, Revision 2
Hot Spot and Shielding Log
Job 08000834 Transfer Spent Resin from Primary Tank to Liner
Plant ALARA Review Committee Meeting
Procedures
APA-ZZ-00405, Special Nuclear Material Control and Accounting, Revision 20
APA-ZZ-01000, Callaway Plant Radiation Protection Program, Revision 26
APA-ZZ-01001, Callaway Plant ALARA Program, Revision 11
APA-ZZ-01106, Lock and Key Control, Revision 16
HDP-ZZ-01100, ALARA Planning and Review, Revision 6
HDP-ZZ-01200, Radiation Work Permits, Revision 9
HTP-ZZ-01203, Radiological Area Access Control, Revision 36
HTP-ZZ-06001, High Radiation/Very High Radiation Area Access, Revision 31
HTP-ZZ-06028, Radiological Controls for Pools that Contain or Store Spent Fuel, Revision 5
RTS-HC-00350, Primary Spent Resin Storage Tank Transfer to Bulk Waste Disposal Station,
Revision 3
Section 4OA1: Performance Indicator Verification
Procedure
NOD-QP-40, NRC Performance Indicator Program, Revision 2
Miscellaneous
Various Callaway Control Room Logs, dated March 2007 through March 2008
Callaway Integrated Inspection Report 05000483/2007002
A-8 Attachment
Callaway Integrated Inspection Report 05000483/2007003
Callaway Integrated Inspection Report 05000483/2007004
Callaway Integrated Inspection Report 05000483/2008002
Section 4OA2: Identification and Resolution of Problems
Inspection Findings
Callaway Action Requests
200501192 200800355 200804000
200709819 200800522 200804164
200711496 200801270 200805049
200800246 200801529 200805122
200800298 200801830 200808956
Generic Communications
NRC Information Notice 2006-21, OE Regarding Entrainment of Air into Emergency Core
Cooling and Containment Spray Systems, September 21, 2006
Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat
Removal , and Containment Spray Systems, January 11, 2009
Procedures
OTN-EM0001, Safety Injection System, Revision 27
OSP-SA-00003, Emergency Core Cooling System Flow Path Verification and Venting,
Revision 27
Section 4OA5: Other
Procedures
APA-ZZ-01004, Radiological Work Standards, Revision 9
HDP-ZZ-06100, Reactor Building Access, Revision 7
MDP-ZZ-S0001, Scaffolding Installation and Evaluation, Revision 22
OSP-EJ-00003, Containment Recirculation Sump Inspection, Revision 6
OSP-SA-00004, Visual Inspection of Containment for Loose Debris, Revision 19
OTS-ZZ-06032, Addendum 1, Debris and Particulate Control Devices, Revision 2
Calculations
Calculation BG-75, Impact of MP 06-0003, Replacement Containment Recirculation Sump
Strainers, and MP 06-0027, TSP Basket Relocation, Revision 0
Calculation BN-21, Impact of MP 06-0003, Replacement Containment Recirculation Sump
Strainer on BN21, Revision 0
A-9 Attachment
Calculation BN-22, Impact of MP 06-0003, Replacement Containment Recirculation Sump
Strainer on BN22, Revision 0
Calculation EJ-29, NPSH Margin for RHR Pumps at Transition to Recirculation When NPSH
Margin is at its Minimum Value, Revision 1
Calculation TDI-6002-05/TDI-6003-05, Clean Head Loss - Wolf Creek/Callaway, Revision 0
Callaway Action Request
200800461, Prompt Operability Determination for Containment Spray and Residual Heat
Removal Systems, Revision 0
Miscellaneous
Ameren/UE comments on ECI-PCI-WC-CAL-6002-6003-1001
Callaway Plant Containment Building Latent Debris Assessment Report Refuel 14 Fall 2005
EC-PCI-WC/CAL-6002/6003-1001, AES Calculation No. PCI-5304-S01 Structural Evaluation of
the Containment Sump Strainers, Revision 1
MP 06-0003-EC-PCI-WC-CAL-6002-6003- (000) AES Document No. PCI-5304-S01 Structural
Evaluation of the Containment Sump Strainers, Revision 1
NUREG/CR-6914, Vol. 4, Integrated Chemical Effects Test, Revision 0
SWE07848, Containment Coating Condition Assessment
TDI-6002/TDI-6003, Sure-Flow Suction Strainer Qualification Report and Addendums, Wolf
Creek/Callaway
ULNRC-05124, Docket Number 50-483 Callaway Plant Unit 1 Union Electric Co. Facility
Operating License NPF-30 Response To Generic Letter 2004-02, Potential Impact of Debris
Blockage On Emergency Recirculation During Design Basis Accidents At Pressurized-Water
Reactors.
ULNRC-05194, Docket Number 50-483 Callaway Plant Unit 1 Union Electric Co. Facility
Operating License NPF-30 September 1, 2005, Response To Generic Letter 2004-02, Potential
Impact of Debris Blockage On Emergency Recirculation During Design Basis Accidents At
Pressurized-Water Reactors.
ULNRC-05295, Docket Number 50-483 Callaway Plant Unit 1 Union Electric Co. Facility
Operating License NPF-30 Response Update To Generic Letter 2004-02, Potential Impact of
Debris Blockage On Emergency Recirculation During Design Basis Accidents At
Pressurized-Water Reactors.
ULNRC-05408, Docket Number 50-483 Callaway Plant Unit 1 Union Electric Co. Facility
Operating License NPF-30 Update For Response To Generic Letter 2004-02, Potential Impact
of Debris Blockage On Emergency Recirculation During Design Basis Accidents At
Pressurized-Water Reactors.
A-10 Attachment
ULNRC-05461, Docket Number 50-483 Callaway Plant Unit 1 Union Electric Co. Facility
Operating License NPF-30 Request for Extension Of Completion Date For Corrective Actions
Associated with NRC Generic Letter 2004-02, Potential Impact of Debris Blockage On
Emergency Recirculation During Design Basis Accidents At Pressurized-Water Reactors.
ULNRC-05465, Docket Number 50-483 Callaway Plant Unit 1 Union Electric Co. Facility
Operating License NPF-30 Supplement to Request for Extension of Corrective Actions
Completion Date For NRC Generic Letter 2004-02, Potential Impact of Debris Blockage On
Emergency Recirculation During Design Basis Accidents At Pressurized-Water Reactors.
WCAP-16568-P, Jet Impingement Testing to Determine the Zone of Influence (ZOI) for
BAQualified/Acceptable Coatings (Proprietary)
Wolf Creek/Callaway Comments on Calculation PCI-5304-S01, Structural Evaluation of the
Containment Sump Strainers.
Section 4OA7: Licensee-Identified Violations
Callaway Action Requests
200802618 200803462 200800461
Generic Communication
Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation
During Design Basis Accidents at Pressurized Water Reactors, dated September 13, 2004
Calculation
TDI-6002-05
Correspondence
Amendment 180 to Facility Operating License NPF-30 from Mr. J. Donohew, Senior Project
Manager, Office of Nuclear Reactor Regulation to Mr. C. Naslund, AmerenUE
Procedure
APA-ZZ-00408, Professional Service Agreements and Nuclear Fuel Contracts, Revision 12
AmerenUE Callaway Plant Nuclear Plant Operating Quality Assurance Manual, Section 3,
Revision 25
Audits
Quality Assurance Audit of Design Control AP08-003
Independent Technical Review Report, SEGR 08-012, Temperature Correction Factor for
Strainer Stack Orifice Head Losses
A-11 Attachment