ML12255A394
| ML12255A394 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 09/11/2012 |
| From: | Ray Kellar Division of Reactor Safety IV |
| To: | Heflin A Union Electric Co |
| References | |
| IR-12-008 | |
| Download: ML12255A394 (29) | |
See also: IR 05000483/2012008
Text
September 11, 2012
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 PROBLEM IDENTIFICATION AND RESOLUTION
INSPECTION REPORT 05000483/2012008
Dear Mr. Heflin:
On July 13, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem
Identification and Resolution biennial inspection at your Callaway Plant. The enclosed
inspection report documents the inspection results, which the inspection team discussed on
July 13, 2012, with you and members of your staff.
This inspection was an examination of activities conducted under your license as they relate to
problem identification and resolution and to compliance with the Commissions rules and
regulations and the conditions of your license. Within these areas, the inspection involved
examination of selected procedures and representative records, observations of activities, and
interviews with personnel.
Based on the inspection sample, the inspection team concluded that the implementation of the
corrective action program and overall performance related to identifying, evaluating, and
resolving problems at Callaway Plant was effective. Your staff generally identified problems and
entered them into the corrective action program at a low threshold, though the team noted some
exceptions, as described in the attached report. Problems were effectively prioritized and
evaluated commensurate with the safety significance of the problems. Appropriate corrective
actions were identified for most problems and were generally implemented in a timely manner,
commensurate with their safety significance. Most corrective actions addressed the causes of
identified problems, though the team noted some exceptions. Lessons learned from industry
operating experience were generally reviewed and applied when appropriate. Audits and self-
assessments were effectively used to identify problems and appropriate corrective actions.
Finally, the team determined that the station maintains a safety conscious work environment
where employees feel free to raise nuclear safety concerns without fear of retaliation.
Two NRC-identified and two self-revealing findings of very low safety significance (Green) were
identified during this inspection. All four of these findings involved violations of NRC
requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent
with Section 2.3.2.a of the NRCs Enforcement Policy.
UNITED STATES
NUCLEAR REGULATORY COMMISSION
RE G IO N I V
1600 EAST LAMAR BLVD
ARLINGTON, TEXAS 76011-4511
A. Heflin
- 2 -
If you contest these non-cited violations, you should provide a response within 30 days of the
date of this inspection report, with the basis for your denial, to the Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the
Regional Administrator, Region IV; the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at
Callaway Plant.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a
response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the Regional Administrator, Region IV, and the NRC Resident Inspector at
Callaway Plant
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response (if any) will be available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records (PARS) component of
NRC's Agencywide Document Access and Management System (ADAMS). ADAMS is
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public
Electronic Reading Room).
Sincerely,
/RA/
Ray L. Kellar, P.E., Chief
Technical Support Branch
Division of Reactor Safety
Docket No.: 50-483
License No.: NPF-30
Enclosure: Inspection Report 05000483/2012008
w/attachments
cc w/ encl: Electronic Distribution
A. Heflin
- 3 -
DISTRIBUTION:
Electronic distribution by RIV:
Regional Administrator (Elmo.Collins@nrc.gov)
Deputy Regional Administrator (Art.Howell@nrc.gov)
DRP Director (Kriss.Kennedy@nrc.gov)
Acting DRP Deputy Director (Allen.Howe@nrc.gov)
Acting DRS Director (Tom.Blount@nrc.gov)
Acting DRS Deputy Director (Patrick.Louden@nrc.gov)
Senior Resident Inspector (Thomas.Hartman@nrc.gov)
Resident Inspector (Zachary.Hollcraft@nrc.gov)
Branch Chief, DRP/B (Neil.OKeefe@nrc.gov)
Senior Project Engineer, DRP/B (Leonard.Willoughby@nrc.gov)
Project Engineer, DRP/B (Nestor.Makris@nrc.gov)
CW Administrative Assistant (Dawn.Yancey@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Public Affairs Officer (Lara.Uselding@nrc.gov)
Project Manager (Fred.Lyon@nrc.gov)
Branch Chief, DRS/TSB (Ray.Kellar@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
Regional Counsel (Karla.Fuller@nrc.gov)
Technical Support Assistant (Loretta.Williams@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov)
OEMail Resource
ROPreports
RIV/ETA: OEDO (Silas.Kennedy@nrc.gov)
DRS/TSB STA (Dale.Powers@nrc.gov)
R:\\REACTORS\\CWY 2012008 RP EAR DRAFT.docx ML
SUNSI Rev Compl.
Yes No
Yes No
Reviewer Initials
EAR
Publicly Avail.
Yes No
Sensitive
Yes No
Sens. Type Initials
RIV/DRS/TSB
NRR/DRA/AHPB RIV/DRS/EB1
DRP/PBA
DRP/PBB
C:DRP/PBB
C:DRS/TSB
EARuesch
MJKeefe
CMDenissen MOHayes
ZRHollcraft
NFOKeefe
RLKellar
/RA/
/RA-E/
/RA-E/
/RA-T/
/RA-E/
/RA/
/RA/
9/10/12
7/31/12
8/2/12
8/20/12
8/20/12
9/10/12
9/11/12
OFFICIAL RECORD COPY
- 1 -
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket:
50-483
License:
Report:
Licensee:
Union Electric Company
Facility:
Callaway Plant
Location:
Junction Hwy CC and Hwy O
Fulton, MO
Dates:
June 25 through July 13, 2012
Team Leader:
E. Ruesch, Senior Reactor Inspector
Inspectors:
C. Denissen, Reactor Inspector
M. Hayes, Resident Inspector
Z. Hollcraft, Resident Inspector
M. Keefe, Human Factors Specialist
Accompanying
Personnel:
R. Telson, Reactor Operations Engineer
K. Watanabe, Chief Inspector, Japan Nuclear Energy
Safety Organization (JNES)
Approved By:
R. Kellar, P.E., Chief
Technical Support Branch
Division of Reactor Safety
- 2 -
SUMMARY OF FINDINGS
IR 05000483/2012008; June 25, 2012 - July 13, 2012; Callaway Plant "Biennial Baseline
Inspection of the Identification and Resolution of Problems"
The team inspection was performed by one senior reactor inspector, one reactor inspector, two
resident inspectors, and one human factors specialist. Four Green non-cited violations of
significance were identified during this inspection. The significance of most findings is indicated
by their color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609, "Significance
Determination Process". Findings for which the significance determination process does not
apply may be Green or be assigned a severity level after NRC management review. The NRC's
program for overseeing the safe operation of commercial nuclear power reactors is described in
NUREG 1649, "Reactor Oversight Process," Revision 4, dated December 2006.
Identification and Resolution of Problems
The team reviewed approximately 200 condition reports, work orders, engineering evaluations,
root and apparent cause evaluations, and other supporting documentation to determine if
problems were being properly identified, characterized, and entered into the corrective action
program for evaluation and resolution. The team reviewed a sample of system health reports,
self-assessments, trending reports and metrics, and various other documents related to the
corrective action program. The team concluded that with limited exceptions, the licensee
maintained a corrective action program in which issues were generally identified at an
appropriately low threshold. Issues entered into the corrective action program were
appropriately evaluated and timely addressed, commensurate with their safety significance.
Corrective actions were generally effective, addressing the causes and extents of condition of
problems.
The licensee appropriately evaluated industry operating experience for relevance to the facility
and entered applicable items in the corrective action program. The licensee used industry
operating experience when performing root cause and apparent cause evaluations. The
licensee performed effective quality assurance audits and self-assessments, as demonstrated
by its self-identification of some minimally effective corrective action program performance and
identification of ineffective corrective actions.
The licensee maintained a safety-conscious work environment in which personnel felt free to
raise safety concerns without fear of retaliation. All individuals interviewed by the team were
willing to raise these concerns by at least one of the several methods available.
A. NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
Green. The team reviewed a Green self-revealing non-cited violation of 10 CFR Part 50,
Appendix B, Criterion XVI, Corrective Action, for the licensees failure to promptly
identify and correct a condition adverse to quality. During troubleshooting, the licensee
incorrectly identified a failed circuit card as the cause of an essential service water pump
room fan damper failure. The licensee returned the damper to service and declared the
associated pump operable without identifying the actual failurepinched wires
introduced during previous maintenance. This resulted in a subsequent failure.
- 3 -
The failure to identify that pinched wires had caused the damper failure and to correct
the condition before replacing the circuit card and declaring the system operable was a
performance deficiency. This performance deficiency was more than minor because it
adversely affected the equipment performance attribute of the Mitigating Systems
cornerstone objective to ensure the availability, reliability, and capability of systems that
respond to initiating events to prevent undesirable consequences. Using Inspection
Manual Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings,
the team determined the finding to be of very low safety significance (Green) because it
did not result in the loss of the safety function of any system or train and did not screen
as potentially risk significant due to seismic, flooding, or severe weather initiating events.
This finding had a cross-cutting aspect in the decision-making component of the human
performance cross-cutting area because the licensee failed to conduct an effectiveness
review of safety-significant decisions to verify the validity of the underlying
assumptions or identify possible unintended consequences (H.1(b)).
(Section 4OA2.5.a)
Green. The team reviewed a non-cited violation of Technical Specification 5.4.1.a,
Procedures, for the licensees failure to provide maintenance instructions appropriate
for repair of the Train B emergency diesel generator supply fan. These inadequate
instructions resulted in maintenance technicians routing and restraining electrical cables
inappropriately during maintenance in July 2006. These cables later came loose and, in
August 2011, caused a failure of the Train B emergency diesel generator supply fan to
start on demand.
The failure to provide maintenance procedures appropriate to the circumstance was a
performance deficiency. This finding was more than minor because it affected the
equipment performance attribute of the Mitigating Systems Cornerstone objective to
ensure the availability, reliability, and capability of systems that respond to initiating
events to prevent undesirable consequences. Using Inspection Manual Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the team
determined that the finding was of very low safety significance (Green) because it did not
result in the loss of the safety function of any system or train and did not screen as
potentially risk significant due to seismic, flooding, or severe weather initiating events.
The team determined that this performance deficiency was not indicative of current plant
performance because it was the result of repair instructions written and implemented in
2006. Therefore, no cross-cutting aspect was assigned. (Section 4OA2.5.b)
Green. The team identified a non-cited violation of 10 CFR Part 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings, for the licensees failure, upon
discovery of an adverse condition, to initiate a Callaway Action Request, to notify the
shift manager, and to review the condition for, operability, functionality, and reportability
in accordance with APA-ZZ-00500, Corrective Action Program, revision 54. During
planned testing of tornado dampers for the emergency diesel generator rooms, the as-
found breakaway torque for the dampers was high out-of-specification. The licensee
failed to document this adverse condition in its corrective action program to evaluate it
for significance and to determine whether the operability of the emergency diesel
generator was adversely affected.
The failure to satisfy the guidance in APA-ZZ-00500 upon identification of high out-of-
specification torque measurements on safety-related tornado dampers by initiating a
Callaway Action Request, informing the shift manager, and evaluating the condition for
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operability, functionality, and reportability was a performance deficiency. This
performance deficiency was more than minor because if left uncorrected, the licensees
continued failure to conform to APA-ZZ-00500 upon discovery of an adverse condition
impacting the EDG tornado protection system had the potential to lead to a more
significant safety concern. Using Inspection Manual Chapter 0609.04, Phase 1 - Initial
Screening and Characterization of Findings, the team determined that the finding was of
very low safety significance (Green) because it did not result in the loss of the safety
function of any system or train and did not screen as potentially risk significant due to
seismic, flooding, or severe weather initiating events. This finding had a cross-cutting
aspect in the corrective action program component of the problem identification and
resolution cross-cutting area because the licensee failed to completely, accurately, and
in a timely manner identify and fully evaluate an issue potentially impacting nuclear
safety (P.1(a)). (Section 4OA2.5.c)
Green. The team identified a Green non-cited violation of 10 CFR Part 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to fully
implement the requirements of its fluid leak management procedure. The team identified
two instances where the licensee had not hung a fluid leak management tag on an
active fluid leak and several examples of fluid leak management tags not indicating
whether individual leaks were monitored. Further, the team found no evidence that
leakage indications were actively monitored and trended, as required by procedure both
before and after repairs were made. The licensee had previously determined that the
extent of condition of weaknesses in its boric acid corrosion control program included the
fluid leak management program. However, corrective actions only addressed the boric
acid corrosion control program.
The licensees failure to implement the requirements of its fluid leak management
procedure was a performance deficiency. The team determined that the performance
deficiency was more than minor because if left uncorrected, it had the potential to
become a more significant safety concern. Specifically, if the licensee continued to fail
to implement its fluid leak management procedure, leaks that adversely affect safety-
related equipment could go unmonitored, resulting in equipment degradation. Using
Inspection Manual Chapter 0609.04, Phase 1 - Initial Screening and Characterization of
Findings, the team determined the finding to be of very low safety significance (Green)
because it did not result in the loss of the safety function of any system or train and did
not screen as potentially risk significant due to seismic, flooding, or severe weather
initiating events. The team determined that the finding had a cross-cutting aspect in the
corrective action program component of the problem identification and resolution cross-
cutting area because the licensee failed to fully evaluate a problem such that the
resolution addressed the causes and extent of condition (P.1(c)). (Section 4OA2.5.d)
B. Licensee-Identified Violations
None
- 5 -
REPORT DETAILS
4.
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution (71152)
The team based the following conclusions on the sample of corrective action documents
that were initiated during the assessment period, which ranged from October 18, 2010,
to the end of the on-site portion of this inspection on July 13, 2012.
.1
Assessment of the Corrective Action Program Effectiveness
a. Inspection Scope
The team reviewed approximately 200 Callaway Action Requests (CARs), including
associated root cause, apparent cause, and direct cause evaluations, from
approximately 13,000 that had been issued between October 18, 2010, and July 13,
2012, to determine if problems were being properly identified, characterized, and
entered into the corrective action program for evaluation and resolution. The team
reviewed a sample of system health reports, operability determinations,
self-assessments, trending reports and metrics, and various other documents related to
the corrective action program. The team evaluated the licensees efforts in establishing
the scope of problems by reviewing selected logs, work orders (Jobs), self-assessment
results, audits, system health reports, action plans, and results from surveillance tests
and preventive maintenance tasks. The team reviewed daily CARs and Jobs, and
attended the licensees daily CAR screening and leadership meetings to assess the
reporting threshold, prioritization efforts, and significance determination process, as well
as observing the interfaces with the operability assessment and work control processes
when applicable. The teams review included verification that the licensee considered
the full extent of cause and extent of condition for problems, as well as a review of how
the licensee assessed generic implications and previous occurrences. The team
assessed the timeliness and effectiveness of corrective actions, completed or planned,
and looked for additional examples of similar problems. The team conducted interviews
with plant personnel to identify other processes that may exist where problems may be
identified and addressed outside the corrective action program.
The team reviewed corrective action documents that addressed past NRC-identified
violations to ensure that corrective actions addressed the issues as described in the
inspection reports. The team reviewed a sample of corrective actions closed to other
corrective action documents to ensure that corrective actions remained appropriate and
timely.
The team considered risk insights from both the NRCs and Callaway Plants risk
assessments to focus the sample selection and plant tours on risk significant systems
and components. The team focused its sample on emergency core cooling systems and
selected the emergency diesel generator system for a five-year in-depth review. The
samples reviewed by the team focused on, but were not limited to, these systems. The
team conducted walkdowns of these systems to assess whether problems were
identified and entered into the corrective action program.
- 6 -
b. Assessments
1. Effectiveness of Problem Identification
The team concluded that in most cases, the licensee identified issues and adverse
conditions in accordance with its corrective action program guidance and with NRC
requirements. The team determined that the licensee generally identified these
problems at a low threshold and entered them into the corrective action program.
However, the team found several examples of deficiencies and received several
comments during interviews that indicated a reluctance of some plant personnel to
use the corrective action program to evaluate and resolve problems that they
perceived as minor.
During the 22-month inspection period, approximately 13,000 CARs were generated.
The licensees CAR generation rate of approximately 8000-8500 per year during
outage years and 6500-7000 per year during non-outage years had been relatively
constant over the previous four years. The team noted that because the licensee
maintained a separate system for the initiation of Jobs, not all problems were
required by licensee procedures to be entered into the corrective action program.
Lower-level conditions that did not meet the licensees requirement for initiation of a
CAR were addressed as Jobs. The team identified that most conditions that required
generation of a CAR by APA-ZZ-00500, Corrective Action Program, Revision 054,
and associated attachments were being appropriately entered into the corrective
action program. However, the team noted several exceptions:
In April 2012, as-found EDG building tornado damper torque measurements
were found high out of specification. The system engineer failed to write a
CAR for this condition as required by procedure. This performance deficiency
is further discussed in Section 4OA2.5.b of this report.
During observations of control room operations on June 28, 2012, the team
noted an under-instruction operator at the controls viewing photographs on his
mobile phone and sharing these photographs with a maintenance technician.
The team disagreed with the licensees assessment that this was not
distracting conduct, prohibited by ODP-ZZ-0001, Addendum 11, Control
Room Decorum. The licensee did not initiate a CAR related to this
observation.
During a plant walk-down on June 29, 2012, the team identified potential fluid
leaks that the licensee had not identified or documented in its corrective action
program. The licensee did not enter these conditions into its corrective action
program until July 11, 2012, after being questioned by the team.
Additionally, during other inspections conducted during the inspection period, the
NRC had documented three findings that were evaluated to have P.1(a) cross-
cutting aspects. These indicated potential deficiencies in the licensees effective
identification of problems:
On August 21, 2011, the number 3 alternate emergency power supply (AEPS)
diesel output breaker tripped open due to incorrect breaker relay settings.
- 7 -
Further investigation by the licensee revealed that all four of the diesel output
breakers had incorrect settings. The incorrect settings occurred due to the
limited range of the relay chosen for the application and the engineering
recommendations that prioritized protecting the diesel over limiting the margin
to unintended breaker trips. This was documented as FIN 2011004-02.
Following a trip of the supply breaker to an emergency diesel generator jacket
water keep warm pump on November 6, 2010, the NRC found that a previous
evaluation had shown a decrease in motor insulation resistance at a sufficient
rate such that there was a reasonable doubt that the motor would continue to
be reliable until the next performance evaluation. The licensee failed to
recognize this degradation and, as a result, did not enter the condition into the
corrective action program. This was documented as NCV 2010005-03.
On February 8 and March 16, 2011, the NRC identified two locations where
scaffold poles and a scaffold pin were less than the procedurally required 1
inch from the auxiliary building vent line, the train B emergency diesel lube oil
drain line, and the essential service water system piping in the Train B diesel
room. The licensee failed to properly install and inspect these scaffolds and did
not exhibit a low threshold for identifying scaffold issues. This was documented
as NCV 2011002-04.
The team concluded that these exceptions indicated a higher-than-normal threshold
for the formal identification of problems and entry into the corrective action problem
for evaluation. Nonetheless, the team noted that most problems were adequately
addressed through one of the licensees programs for the identification and
resolution of problems.
2. Assessment - Effectiveness of Prioritization and Evaluation of Issues
Once the licensee enters issues into the corrective action program, they are
generally screened to the appropriate level as required by APA-ZZ-00500,
Corrective Action Program, Revision 054, and associated attachments. While the
team noted some issues with the timeliness of corrective actions for issues, such as
inadequate plant lighting, actions were generally completed by their due dates; due
date extensions were generally reasonable and were not overused. However, the
team noted some issues with the licensees implementation of its program to identify
trends and with its evaluation of some identified adverse conditions:
The team identified a minor performance deficiency associated with the
licensees trending program. For adverse trends identified outside of the
quarterly trending program, including trends identified through audits, the
licensee failed to establish success criteria used to terminate performance
monitoring. This created the potential for a trend to be closed without
consideration for new data points and the possible need for continued
performance monitoring. This could adversely impact the stations ability to
use adverse trends as a prediction tool to address issues at a low level, prior to
escalating into a significant event. The licensee documented this observation
in CAR 201204897.
- 8 -
The past operability for the August 2011 essential service water train A fan
damper failure (CAR 201106551) declared the essential service water pump
operable based on a calculation of maximum room temperatures. In
performing this calculation, the licensee considered ambient temperatures for
the period from a previous failure in July until the August failure. The licensee
had identified that the degraded condition had been introduced during
maintenance in May 2011. However, the evaluation of past operability did not
consider the period from this time until the July failure. The licensee initiated
CAR 201204890 to update the past operability evaluation and to document the
issue.
MDP-ZZ-LM001, Fluid Leak Management, Revision 011, directs that for all
leakage indication other than boric acid, fluid leak management tags be
generated and hung on the leaking equipment and that the leaks be monitored.
During several walk-downs of safety-related plant equipment, the team noted
fluid leaks where either no tag was hanging or where it was unclear which of
multiple leaks was identified by a hanging tag. The team noted that in January
2012, a CAR had been written recommending the development of a program-
level procedure to govern plant response to leakage, but no action had been
taken. This performance deficiency is further discussed in Section 4OA2.5.d of
this report.
Additionally, during other inspections conducted during the inspection period, the
NRC had documented three findings that were evaluated to have a P.1(c) cross-
cutting aspects. These indicated potential deficiencies in the licensees prioritization
and evaluation of problems:
In September 2011, the NRC identified that Callaway Plant did not have
procedures that ensured that hand files and wire brushes designated for
stainless steel weld preparation were stored separately from hand files and
wire brushes used on carbon steel. The licensee previously identified
contaminated tools as the cause of rusting on the motor-driven auxiliary feed
pump room cooler stainless steel piping, but took no further action to identify
the cause of the contamination. This was documented as NCV 2011005-01.
On April 19, 2011, the NRC identified that the Callaway Plant failed to maintain
an adequate design control calculation for the flooding analysis of control
building room 3101. The licensee did not update the flooding analysis of
record to consider potential failures in new piping installed in 2009 as part of a
modification that replaced essential service water carbon steel piping with high
density polyethylene piping. This was documented as NCV 2011003-01.
Overall, the team determined that the licensee had a strong process for screening
and prioritizing issues that were entered into the corrective action program. All
departments were represented at CAR screening meetings. The departments took
clear ownership of the issues discussed and set appropriate due dates for evaluation
of the issues identified in the CARs, in accordance with APA-ZZ-00500, Corrective
Action Program, Revision 054, and associated attachments. The issues noted
above were related to the subsequent evaluation of these issues and the
prioritization of corrective actions.
- 9 -
3. Assessment - Effectiveness of Corrective Actions
When appropriate corrective actions were implemented, they were generally
effective. However, the team identified some examples of corrective actions not
addressing the entire cause or extent of condition.
After a failure of ESW room supply fan dampers in July 2011, the licensee
incorrectly evaluated the condition. The licensees evaluation presumed,
based on industry operating experience, that a circuit card had failed. The
licensee replaced the circuit card and returned the dampers to service.
However, the failure was the result of pinched wires; the circuit card was fully
functional. The failure recurred in August 2011. This performance deficiency is
further discussed in Section 4OA2.5.c of this report.
Root cause evaluation AUCA 12-002 (CAR 201104707) identified that
inadequate corrective actions from previous self-assessments contributed to a
security event in 2011. The corrective action for this condition was to require
subsequent self-assessments to review trends from previous self-assessments.
The licensee implemented a procedure modification to APA-ZZ-01400,
Appendix A, Callaway Self-Assessment and Benchmarking Program. The
team noted that Revision 014 to this procedure included prior self-assessments
as one of the considerations for topics to be included within the scope of
subsequent self-assessments. However, this review was not a requirement
and the procedure step was not referenced to the CAR or the root cause
evaluation. (A similar corrective action to add operating experience reviews to
a procedure had been implemented as designed.)
The team noted that corrective actions to address the sample of NRC non-cited
violations and findings since the last problem identification and resolution inspection
had been timely and effective.
Overall, the team concluded that the licensee generally developed appropriate
corrective actions to address identified problems. The licensee generally
implemented these corrective actions in a timely manner, commensurate with their
safety significance. Except for the issue with the trending program noted in Section
4OA2.1.b.2 above, the licensee generally had performed timely effectiveness
reviews of significant corrective actions to verify their adequacy.
.2
Assessment of the Use of Operating Experience
a. Inspection Scope
The team examined the licensee's program for reviewing industry operating experience,
including governing procedures and self-assessments and interviewed individuals
responsible for managing the operating experience and vendor equipment technical
information review programs. The team reviewed a sample of CARs compared to
operating experience documents issued by the NRC and the industry during the
assessment period to assess whether the licensee had entered those items into their
corrective action program. The team also examined whether the licensee had
appropriately evaluated external operating experience for relevance to the facility,
assigned appropriate and timely actions to address the issues, and performed
- 10 -
effectiveness reviews to ensure the actions were adequate. The team reviewed a
sample of root cause evaluations and significant condition reports to determine if the
licensee had appropriately reviewed industry operating experience for relevance. The
team observed management meetings and pre-job briefs that included internal and
external operating experience discussions and reviewed cause evaluations and event
review team meeting summaries that considered pertinent operating experience.
b. Assessment
The team noted that the licensee incorporated both internal and external operating
experience into lessons learned for training and into pre-job briefs, and the licensee
included a review of operating experience in its cause evaluations. However, the team
noted three indications of potential issues with the use of operating experience, one of
which the licensee had identified and corrected prior to this inspection:
In the licensees root cause evaluation for a security event in 2011, it identified that
weaknesses in the assessment and use of security-related operating experience
may have resulted in a failure to implement barriers that may have prevented the
event. The licensee identified this weakness, documented it in CAR 201104707,
and took corrective action to improve its use of security operating experience.
Two non-cited violations from the most recent integrated inspection report,
05000483/20120003, were related to the proper application of operating
experience. One had a cross-cutting aspect of P.2(b) for failure to properly
implement operating experience and the second involved failing to consider/take
appropriate action on an NRC Information Notice during the periodic Maintenance
Rule assessment.
During focus group interviews, some licensee personnel expressed frustrations
with the implementation of operating experience in day-to-day work package
preparation and briefing. Some interviewees indicated that applicable operating
experience was not always provided or, when it was, it was sometimes limited.
Overall, the team determined that the licensee had appropriately evaluated industry and
vendor operating experience for relevance to the facility, had entered applicable items
into the corrective action program, and where appropriate, had incorporated lessons
learned into station programs, processes, or procedures.
.3
Assessment of Self-Assessments and Audits
a. Inspection Scope
The team reviewed a sample of licensee self-assessments and audits to assess whether
the licensee was regularly identifying performance trends and effectively addressing
them. The team also reviewed audit reports to assess the effectiveness of assessments
in specific areas. The self-assessments and audits reviewed are listed in the attachment.
b. Assessment
The team concluded that the licensee had an effective self-assessment process.
Licensee management was involved in developing the topics and objectives of self-
- 11 -
assessments. Attention was given to assigning team members with the proper skills and
experience to perform effective self-assessments and to include people from outside
organizations. Audits were self-critical, thorough, and identified new performance
deficiencies in addition to evaluating known performance deficiencies across key
functional areas. Callaway Action Requests were generated to document deficiencies
and improvement opportunities identified through audits and corrective actions were
implemented. The team identified one weakness in individual departments missing
opportunities to identify adverse trends, as evidenced in the high number of adverse
trends identified by Nuclear Oversight through audits. However, the team did not identify
any significant adverse trends that had not been identified by at least one licensee
process.
.4
Assessment of Safety-Conscious Work Environment
a. Inspection Scope
The team interviewed forty-three individuals in seven focus groups to evaluate their
willingness to raise nuclear safety issues. These individuals were from the Operations,
Maintenance, Security, Engineering, Radiation Protection, Chemistry, and Nuclear
Oversight departments. The individuals were selected randomly based on availability
from these departments. Additionally, the team interviewed the Employee Concerns
Program (ECP) manager to assess her perception of the site employees willingness to
raise nuclear safety concerns. The team also reviewed selected documents to assess
the safety-conscious work environment (SCWE) at the site.
b. Assessment
1. Willingness to Raise Nuclear Safety Issues
The individuals interviewed indicated they did not have any hesitancy in raising
nuclear safety issues. Most feel that their management is receptive to the concerns,
and is willing to address them. Most of the interviewees also stated that if they were
not satisfied with the response from their immediate supervisor, they would feel free
to escalate the concern. In most cases, interviewees had raised issues and
concerns to their supervisors and then followed the supervisors recommendation,
which often involved entering the issue into the corrective action program. All the
individuals interviewed expressed positive experiences for bringing issues to their
supervisors and could name several other avenues for raising concerns. The
majority of interviewees explained that going through the supervisor and using the
corrective action program had been effective in their experience. Therefore, they
had not had the need to use other avenues.
2. Employee Concerns Program
All the interviewees were aware of the Employee Concerns Program. Most
explained that they have heard about the program through various means, such as
posters, ECP mailers, presentations, and discussion by supervisors or management
at meetings. Most did not have any personal experience with the ECP because, as
noted above, they felt free to raise safety concerns to their supervisors; they did not
need to use the ECP in these cases. However, there was a favorable impression of
the program: everyone interviewed stated that they would use the program if they
- 12 -
felt they needed to. Of those who had brought issues to the ECP in the past, all
indicated that the experience was positive and that they would use the ECP again if
needed. Everyone interviewed also stated that they had not heard of any issues
dealing with breaches of confidentiality.
3. Preventing or Mitigating Perceptions of Retaliation
When asked if there have been any instances where individuals experienced
retaliation or other negative reaction for raising issues, all individuals interviewed
stated that they had neither experienced nor heard of any issues of retaliation,
harassment, intimidation or discrimination at the site. The team determined that the
processes in place to mitigate these issues were being successfully implemented.
.5
Findings
a. Failure to identify and correct the failure mode of an essential service water pump
Introduction. The team reviewed a green self-revealing non-cited violation of
10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure
to promptly identify and correct a condition adverse to quality. During troubleshooting,
the licensee incorrectly identified a failed circuit card as the cause of an essential service
water pump room fan damper failure. The licensee returned the damper to service and
declared the associated pump operable without identifying the actual failurepinched
wires introduced during previous maintenance. This resulted in a subsequent failure.
Description. On July 13, 2011, an air damper associated with the essential service
water train A supply fan failed to open as required during pump operation. The licensee
declared the associated pump inoperable, took compensatory actions to manually
reposition and de-energize the damper in its safety-related position, and declared the
pump operable. The licensee then performed troubleshooting on the Foxboro circuit
card associated with the damper per Job 11003848. The licensee failed to use
troubleshooting procedure MDP-ZZ-TR001, Planning and Execution of Troubleshooting
Activities, Revision 7, as guidance in preparing and conducting the troubleshooting. A
technician initially identified an intermittent ground and postulated that it may have been
associated with the field wiring. However, a second technician retested the field wiring
and determined that no ground existed. Based on these readings and on operating
experience indicating a history of problems with these cards, the cognizant engineer
elected to replace the Foxboro circuit card. Contrary to the instructions in
Job 11003848, the licensee performed no testing on the removed card to confirm it was
the cause and to document that cause. The licensee replaced the card and retested the
damper satisfactorily.
On August 17, 2011, the damper failed again. The licensee identified this as a repeat
occurrence and performed formal troubleshooting on this second failure in accordance
with procedure MDP-ZZ-TR001. The licensee again identified the ground on the field
wires initially detected following the July failure. The licensee inspected these wires and
discovered that two pinched field wires inside the hydramotor junction box, causing the
ground. In 2005, the licensee had removed this hydramotor actuator, refurbished it, and
placed it in storage. The licensee determined that during the refurbishment, the terminal
board had been positioned too close to the junction box housing. As a result, when the
licensee removed the actuator from storage and installed it back into the plant on
- 13 -
May 24, 2011, a threaded cap pinched the wires on the terminal board. Following this
discovery, the circuit was rewired and retested satisfactorily. The licensee performed an
evaluation of past operability that demonstrated, given the ambient temperatures during
the time of the failure, the essential service water pump had been operable despite the
damper failure.
Analysis. The failure to identify that pinched wires had caused the damper failure and to
correct the condition before replacing the circuit card and declaring the system operable
was a performance deficiency. This performance deficiency was more than minor
because it adversely affected the equipment performance attribute of the Mitigating
Systems cornerstone objective to ensure the availability, reliability, and capability of
systems that respond to initiating events to prevent undesirable consequences. Using
Inspection Manual Chapter 0609.04, Phase 1 - Initial Screening and Characterization of
Findings, the team determined the finding to be of very low safety significance (Green)
because it did not result in the loss of the safety function of any system or train and did
not screen as potentially risk significant due to seismic, flooding, or severe weather
initiating events. This finding has a cross-cutting aspect in the decision-making
component of the human performance cross-cutting area because the licensee failed to
conduct an effectiveness review of safety-significant decisions to verify the validity of
the underlying assumptions or identify possible unintended consequences (H.1(b)).
Enforcement. Title 10 of the Code of Federal Regulations Part 50, Appendix B,
Criterion XVI, Corrective Actions, requires, in part, that measures shall be established
to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies,
deviations, defective material and equipment, and nonconformances are promptly
identified and corrected. Contrary to the above, between July 13 and August 17, 2011,
the licensee failed to establish measures to assure that conditions adverse to quality
were promptly identified and corrected. Specifically, the licensee failed to identify that
pinched wires were causing grounds on the train A essential service water pump room
fan damper resulting in the pump being inoperable. Because it was of very low safety
significance and had been entered into the licensees corrective action program as
Callaway Action Requests 201106551 and 201110845, this violation is being treated as
a non-cited violation consistent with Section 2.3.2 of the Enforcement Policy:
NCV 05000483/2012008-01, Failure to identify and correct the failure mode of an
essential service water pump.
b. Failure to Provide Adequate Maintenance Instructions
Introduction: The team reviewed a non-cited violation of Technical Specification 5.4.1.a,
Procedures, for the licensees failure to provide maintenance instructions appropriate
for repair of the Train B emergency diesel generator supply fan. These inadequate
instructions resulted in maintenance technicians routing and restraining electrical cables
inappropriately during maintenance in July 2006. These cables later came loose and, in
August 2011, caused a failure of the train B emergency diesel generator supply fan to
start on demand.
Description: On August 30, 2011, while performing scheduled emergency diesel
generator surveillances, the train B emergency diesel generator ventilation supply fan
breaker tripped unexpectedly resulting in the licensee declaring the train B emergency
diesel generator inoperable. The licensee performed troubleshooting activities and
determined the supply fan motor stator winding lead grounded to the rotor shaft shorting
- 14 -
the 480 volt supply leads to ground. The leads had been extended in July 2006 in
response to a failure of the fan while running. The cause of the failure in 2006 was due
to the motor leads pulling apart due to tension in the wires. During initial construction,
the leads were cut too short which caused undue tension. The remedy for this 2006
event was to cut off and extend the motor leads. These new extended leads were then
tucked inside the airspace between the stator and the motor housing within the end-bell
of the motor. Between July 2006 and August 2011 the motor leads inside the end-bell
came out of their tucked position and draped across the motor shaft. During operation of
the fan, the rotor shaft rubbed a hole in the motor lead insulation. On August 31, 2011,
the bare copper leads contacted the shaft and went to ground. The team reviewed the
work package used to extend the motor leads in 2006 and noted there were no specific
steps to route the extended cables. The cables should have been routed underneath
the stator and this would have prevented the failure on August 30, 2011.
Analysis: The failure to provide maintenance procedures appropriate to the
circumstance is a performance deficiency. This finding was more than minor because it
affected the equipment performance attribute of the Mitigating Systems Cornerstone
objective to ensure the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. Using Inspection Manual
Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the
team determined that the finding was of very low safety significance (Green) because it
did not result in the loss of the safety function of any system or train and did not screen
as potentially risk significant due to seismic, flooding, or severe weather initiating events.
The team determined that this performance deficiency was not indicative of current plant
performance because it was the result of repair instructions written and implemented in
2006. Therefore, no cross-cutting aspect was assigned.
Enforcement: Technical Specification 5.4.1.a requires, in part, that written procedures
shall be established, implemented, and maintained covering the applicable procedures
recommended in Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978.
Paragraph 9.a of this appendix requires, in part, that maintenance that can affect the
performance of safety-related equipment should be properly pre-planned and performed
in accordance with written procedures appropriate to the circumstances. Contrary to the
above, on July 11, 2006, the licensee failed to properly plan and perform maintenance
that could affect the performance of safety-related equipment with written procedures
appropriate for the circumstance. Specifically, the inadequate instructions resulted in
maintenance technicians routing and restraining electrical cables inappropriately during
maintenance in July 2006, which later caused a failure of the train B emergency diesel
generator supply fan to start on demand. Because this finding is of very low safety
significance and was entered into the licensees corrective action program as
Callaway Action Request 201106905, this violation is being treated as a non-cited
violation consistent with Section 2.3.2 of the NRC Enforcement Policy:
NCV 05000483/2012008-02, Failure to provide adequate maintenance instructions.
c. Failure to Initiate a Corrective Action Document
Introduction. The team identified a non-cited violation of 10 CFR Part 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings, for the licensees failure, upon
discovery of an adverse condition, to initiate a Callaway Action Request, to notify the
shift manager, and to review the condition for, operability, functionality, and reportability
as required by APA-ZZ-00500, Corrective Action Program, revision 054.
- 15 -
Description. Emergency diesel generator tornado dampers are safety-related
components. They have an active safety function to automatically reposition during
tornado conditions to protect the emergency diesel generator. During the licensees
performance of Job 05514809.500, Lubricate and Inspect Damper GMD0004, on April
24, 2012, the as-found breakaway torque measurement for the train A emergency diesel
generator tornado dampers was 25.7 percent higher than the shop value. This
exceeded the vendor-recommended torque range of plus-or-minus 20 percent for a
properly functioning damper.
Procedure APA-ZZ-00500 Appendix 22, Corrective Action Program Definitions,
revision 007, includes in its definition of condition adverse to quality, a non-
conformance of safety-related equipment or the potential inability of safety-related
equipment to perform its safety function. In addition, APA-ZZ-00500 Appendix 22
defines adverse condition as an encompassing term that includes, among other
examples, a condition that could credibly impact nuclear safety, a condition not in
compliance with design specifications, or a condition adverse to quality.
Procedure APA-ZZ-00500, Corrective Action Program, revision 054, requires that any
individual discovering an adverse condition promptly initiate a CAR; promptly is defined
to be within the same shift. Further, when initiating a CAR for an equipment issue, APA-
ZZ-00500 requires the originator to notify the shift manager, and requires the shift
manager to review the condition for operability, functionality, and reportability.
On April 24, 2012, the as-found breakaway torque of the train A emergency diesel
generator tornado damper exceeded the vendor-recommended torque range. This
represented a non-conformance of safety-related equipment, in that it was not in
compliance with design specifications, and a potential inability of safety-related
equipment to perform its safety function. The identification of this adverse condition
required the initiation of a CAR, notification of the shift manager, and evaluation of the
condition by the shift manager. Upon discovery of this condition, the licensee failed to
initiate a CAR, notify the shift manager, or review the condition for operability,
functionality, or reportability.
On June 27, 2012, after identification of this condition by the team, licensee engineering
staff analyzed the as-found breakaway torque for the emergency diesel generator
tornado damper. This analysis determined that though the breakaway torque was
outside the acceptance band provided by the vendor, it was below the maximum
breakaway torque under which the dampers could successfully close against the
maximum differential pressure the ductwork is designed to withstand. The operations
department subsequently declared the train A emergency diesel generators operable
and performed an extent of condition review, determining the opposite train tornado
dampers to be operable as well. The licensee documented the teams concerns in CAR
201204571.
Analysis. The failure to satisfy the requirements of APA-ZZ-00500 upon identification of
high out-of-specification torque measurements on safety-related tornado dampers by
initiating a Callaway Action Request, informing the shift manager, and evaluating the
condition for operability, functionality, and reportability was a performance deficiency
related to the mitigating systems cornerstone. This performance deficiency was more
than minor because if left uncorrected, the licensees continued failure to conform to
- 16 -
APA-ZZ-00500 upon discovery of an adverse condition impacting the EDG tornado
protection system would have the potential to lead to a more significant safety concern.
Using Inspection Manual Chapter 0609.04, Phase 1 - Initial Screening and
Characterization of Findings, the team determined that the finding was of very low
safety significance (Green) because it did not result in the loss of the safety function of
any system or train and did not screen as potentially risk significant due to seismic,
flooding, or severe weather initiating events. This finding had a cross-cutting aspect in
the corrective action program component of the problem identification and resolution
cross-cutting area because the licensee failed to completely, accurately, and in a timely
manner identify and fully evaluate an issue potentially impacting nuclear safety (P.1(a)).
Enforcement. Title 10 of the Code of Federal Regulations, Part 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities
affecting quality shall be prescribed by documented instructions, procedures, or
drawings of a type appropriate to the circumstances and shall be accomplished in
accordance with these instructions, procedures, or drawings. Procedure APA-ZZ-00500,
Corrective Action Program, revision 54, required initiation of a Callaway Action
Request within the same shift as the identification of an adverse condition. Further,
APA-ZZ-00500 required that the shift manager be notified of all adverse conditions
affecting equipment and that the shift manager review the condition for operability,
functionality, and reportability.
Contrary to the above, from April 24, 2012 until June 26, 2012, licensee staff failed to
accomplish an activity affecting quality in accordance with documented procedures.
Specifically, the licensee failed to initiate a CAR within a shift after discovery of an
adverse condition, as required by APA-ZZ-00500, failed to notify the shift manager of an
adverse condition affecting plant equipment, and failed to evaluate the condition for
operability, functionality, and reportability. Because this finding is of very low safety
significance and was entered into the licensees corrective action program as Callaway
Action Request 201204571, the violation is being treated as a non-cited violation
consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000483/2012008-
03, Failure to initiate a corrective action document.
d. Failure to Implement Procedure Requirements
Introduction. The team identified a Green non-cited violation of 10 CFR Part 50,
Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees
failure to fully implement the requirements of its fluid leak management procedure. The
team identified two instances where the licensee had not hung a fluid leak management
tag on an active fluid leak and several examples of fluid leak management tags not
indicating whether individual leaks were monitored. Further, the team found that the
licensee did not always document leakage monitoring, making trending difficult.
Description. Procedure MDP-ZZ-LM001, Fluid Leak Management, revision 011, was
established by the licensee as its process for the timely identification, investigation, and
repair of fluid leaks in plant systems and components, including those involving nuclear
safety, fire hazards, spread of contamination, and equipment damage. For all
indications of leakage of non-boric-acid fluids (except in the reactor building), this
procedure directed that a Job be initiated and a fluid leak management tag be generated
and hung for monitoring and trending purposes. The procedure further directed that,
- 17 -
once repairs were accomplished, repaired leaks be monitored for two months to ensure
the leak was corrected. During walk-downs of safety-related plant equipment on June
27 and June 29, 2012, the team noted four examples of fluid leak indications that were
not being managed in accordance with this procedure:
Safety injection pump B (PEM01B) had multiple small oil leaks that appeared to
be coming from threaded fittings. No fluid leak management tag was hanging
and no Job had been initiated for evaluation and repair. The licensee stated that
recent repairs had been made to this piping and a previously hanging fluid leak
management tag had been removed upon completion of those repairs, prior to
the end of the two-month monitoring window required by procedure.
Fire protection valve KCV0084 had a packing leak with a catch device in place to
collect the leaking fluid. No fluid leak management tag was hanging, though the
licensee had initiated Job 12003073 to adjust the packing.
Component cooling water pump B (PEG01B) had water leaks from both pump
bearing housings and evidence of an oil leak in the pump skid. One fluid leak
management tag related to Job 06114561, to replace the pump bearing
housings, was hanging on the pump motor identifying an oil leak; other leaks
were not tracked.
Containment spray pump B (PEN01B) had a puddle of oil on top of the pump
flange, inside the motor housing. No fluid leak management tag was hanging
and no Job had been initiated to evaluate the source of the oil. The licensee
stated that the oil appears to be residual spill from oil changes on the motor in
December 2011. Job 12003518 was initiated to clean the oil; no Job was
initiated to confirm the source of the oil or to monitor for potential leakage.
In discussions with the team on June 29, 2012, an individual responsible for the
implementation of the fluid leak management program acknowledged some inconsistent
adherence to the fluid leak management program procedure by station personnel.
Further, though the team discussed the safety injection pump B oil leaks with the
licensee on June 29, 2012, the licensee did not document these leaks at the earliest
possible stages in accordance with MDP-ZZ-LM001 instructions. During follow-up
discussions on July 9, 2012, the team questioned why this leak had not yet been
documented. On July 11, 2012, the licensee initiated Job 12003542 and CAR
201204882 to evaluate and track the leak. The team concluded that the inconsistent
application of procedural requirements and inconsistent identification of the source of
leaks when fluid leak management tags were hung, indicated programmatic deficiencies
in the licensees process for identifying, investigating, and repairing fluid leaks.
The team further noted that in September 2011, the licensee completed a self-
assessment of its boric acid corrosion control program, which at the time was part of the
fluid leak management program. In its self-assessment, the licensee noted similar
weaknesses in implementation of the boric acid corrosion control program. The licensee
documented in CAR 201107657 that the extent of condition of these weaknesses
included both the boric acid corrosion control program and the fluid leak management
program for non-boric acid leaks. The licensee took corrective actions to address the
deficiencies in the boric acid corrosion control program, but did not address the fluid leak
management program deficiencies. On January 10, 2012, the licensee initiated CAR
201200272, recommending the development of a program-level procedure to govern
- 18 -
plant response to leakage. At the conclusion of this inspection, this CAR remained open
with no actions taken.
Analysis. The licensees failure to fully implement the requirements of its fluid leak
management procedure was a performance deficiency. The team determined that the
performance deficiency was more than minor because if left uncorrected, it had the
potential to become a more significant safety concern. Specifically, if the licensee
continued to fail to implement its fluid leak management procedure, leaks that adversely
affect safety-related equipment could go unmonitored, resulting in undetected equipment
degradation. Using Inspection Manual Chapter 0609.04, Phase 1 - Initial Screening
and Characterization of Findings, the team determined the finding to be of very low
safety significance (Green) because it did not result in the loss of the safety function of
any system or train and did not screen as potentially risk significant due to seismic,
flooding, or severe weather initiating events. The team determined that the finding had a
cross-cutting aspect in the corrective action program component of the problem
identification and resolution cross-cutting area because the licensee failed to fully
evaluate a problem such that the resolution addressed the causes and extent of
condition (P.1(c)).
Enforcement. Title 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and
Drawings, requires in part that activities affecting quality be prescribed by documented
instructions, procedures, or drawings, and be accomplished in accordance with these
instructions, procedures, and drawings. Contrary to this requirement, on June 27, 2012,
the licensee failed to accomplish activities affecting quality in accordance with prescribed
instructions, procedures, and drawings. Specifically, the licensee failed to fully
implement the requirements of MDP-ZZ-LM001, Fluid Leak Management Program,
Revision 011, to identify, evaluate, document, mitigate, and monitor leakage from safety-
related structures, systems, and components. Because this finding was of very low
safety significance (Green) and was entered into the licensees corrective action
program as Callaway Action Request 201204929, the violation is being treated as a non-
cited violation consistent with Section 2.3.2 of the Enforcement Policy: NCV 05000483/2012008-04, Failure to fully implement fluid leak management program.
4OA6 Meetings
.1
Exit Meeting Summary
On July 13, 2012, the team presented the inspection results to Mr. Adam C. Heflin,
Senior Vice President and Chief Nuclear Officer, and other members of the licensee
staff. The licensee acknowledged the issues presented. The team noted that
proprietary information had been included electronically in the response to the initial
information request and that this information would be destroyed. The licensee
acknowledged that other proprietary information that the team reviewed had been
returned.
.2
Other Management Meetings
On August 1, 2012, August 21, 2012, and September 11. 2012, Mr. Scott Maglio and
other licensee personnel discussed NCV 05000483/2012008-04 with the team lead and
the Branch Chief, Technical Support Branch. Licensee management reiterated its
position that the Fluid Leak Management program was being fully implemented. The
- 19 -
team acknowledged and considered the licensees position and discussed it with NRR
Program Office personnel, but for the reasons listed in Section 4OA5.5.d above, did not
agree.
ATTACHMENTS:
1. Supplemental Information
2. Information Request
3. Supplemental Information Request
Attachment 1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
F. Bianco, Assistant Operations Manager (Support)
M. Daly, Corrective Action Program Supervisor
M. Dunbar, Manager, Maintenance (Acting)
S. Edwards, Employee Concerns Manager
S. Enloe, Mechanical Maintenance Technician
T. Fugate, Manager, Maintenance
S. Maglio, Regulatory Affairs Manager
B. Miller, Performance Improvement Manager (Acting)
H. Osborn, Regulatory Affairs Specialist
D. Rickard, Root Cause Coordinator
L. Sandbothe, Manager Plant Support
A. Schnitz, Engineer, Regulatory Affairs
NRC personnel
D. Powers, Senior Technical Advisor, Technical Support Branch
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED
Opened and Closed 05000483/2012008-01
Failure to identify and correct the failure mode of an
essential service water pump (Section 4OA2.5.a)05000483/2012008-02
Failure to provide adequate maintenance instructions
(Section 4OA2.5.b)05000483/2012008-03
Failure to initiate a corrective action document (Section
4OA2.5.c)05000483/2012008-04
Failure to fully implement fluid leak management program
(Section 4OA2.5.d)
Discussed
None
LIST OF DOCUMENTS REVIEWED
CALLAWAY ACTION REQUESTS (CARS)
200409580
200901515
201005401
201102588
201107460
201201587
201203507
200700100
200901831
201005616
201103219
201107657
201201652
201203559
200701415
200903102
201005654
201104132
201107679
201201712
201203562
200702872
200903204
201006376
201104403
201107759
201201790
201203576
200703247
200905171
201007711
201104475
201107761
201201851
201203586
200703260
200906859
201008001
201104654
201107762
201202058
201203593
200703313
200908108
201008153
201104707
201107763
201202157
201203637
200703331
200908133
201008230
201104775
201108091
201202169
201203709
200705117
200908262
201009423
201104836
201108586
201202224
201203767
200705410
200909091
201009719
201105121
201108775
201202273
201204094
200706042
200909120
201009922
201105137
201109194
201202333
201204467
200706307
200909455
201010145
201105210
201109257
201202340
201204482
200706804
200909951
201010266
201105273
201109259
201202561
201204529
200706892
200910153
201010432
201105282
201109441
201202632
201204542
200707394
201001515
201010472
201105331
201109490
201202717
201204548
200709539
201001529
201010530
201105365
201109521
201202909
201204571
200709540
201002281
201010634
201105477
201109562
201202922
201204586
200711788
201002456
201010635
201105534
201109569
201203103
201204692
200800175
201002599
201011161
201105601
201109621
201203140
201204702
200801069
201002675
201011278
201105700
201109732
201203144
201204777
200801146
201002916
201100526
201105727
201109894
201203223
201204803
200801270
201003236
201101042
201105768
201109948
201203232
201204805
200804103
201003472
201101192
201105831
201110797
201203319
201204882
200804164
201003813
201101583
201105861
201110845
201203347
201204885
200804337
201004071
201101755
201105886
201110929
201203434
201204890
200805586
201004250
201101769
201105927
201200272
201203453
201204896
200810335
201004294
201101835
201105965
201200336
201203469
201206157
200810902
201004687
201102064
201106369
201200577
201203484
200812985
201005233
201102129
201106551
201200905
201203501
200900986
201005328
201102329
201106905
201201245
201203502
JOBS
11003848
11004803
11006688
PROCEDURES
NUMBER
TITLE
REVISION
APA-ZZ-00101
Processing Procedures, Manuals, and Desktop
Instructions
061
APA-ZZ-00101 App. D
Manuals, Desktop Instructions, Handbooks, Forms
and Policies
011
APA-ZZ-00107
Review of Current Industry Operating Experience
015
APA-ZZ-00203
Forms Management
013
APA-ZZ-00303
Classification of Systems
013
APA-ZZ-00303 App. 1
Callaway Director Plant System Classification Data
010
APA-ZZ-00304
Control of Callaway Equipment List
035
APA-ZZ-00500
Corrective Action Program
054
APA-ZZ-00500 App. 1
Operability and Functionality Determinations
017
APA-ZZ-00500 App. 10
Trending Program
005
APA-ZZ-00500 App. 11
Regulatory Issue Summary 2005-20 Degraded and
Nonconforming Condition Resolution
006
APA-ZZ-00500 App. 12
Significant Adverse Condition - Significance Level 1
014
APA-ZZ-00500 App. 13
Adverse Condition - Significance Level 2
014
APA-ZZ-00500 App. 14
Adverse Condition - Significance Level 3
012
APA-ZZ-00500 App. 15
Adverse Condition - Significance Level 4
012
APA-ZZ-00500 App. 16
Adverse Condition - Significance Level 5
009
APA-ZZ-00500 App. 17
Screening Process Guidelines
014
APA-ZZ-00500 App. 18
Equipment Performance Evaluation
006
APA-ZZ-00500 App. 2
Non-Conforming Materials Report (NMR)
012
APA-ZZ-00500 App. 21
Other Issues - Significance Level 6
012
APA-ZZ-00500 App. 3
Past Operability & Reportability Evaluations (REPO)
014
APA-ZZ-00500 App. 5
Maintenance Rule (MR)
012
APA-ZZ-00500 App. 7
Effectiveness Reviews
009
APA-ZZ-00500 App. 9
Mitigating Systems Performance Index (MSPI)
004
NUMBER
TITLE
REVISION
APA-ZZ-00542
Event Review and Post Transient Evaluation
016
APA-ZZ-00542 App. 1
Event Review Team
011
APA-ZZ-00605
Temporary System Modifications
028
APA-ZZ-00905
Limitation of Callaway Plant Staff Working Hours
15
APA-ZZ-00911
Fatigue Management
2
APA-ZZ-00930
Employee Concerns Program
014
APA-ZZ-00932
Nuclear Safety Culture Monitoring
000
APA-ZZ-01400
Performance Improvement Program
013
APA-ZZ-01400 App. A
Callaway Self-Assessment and Benchmarking
Program
014
APA-ZZ-01400 App. E
Operating Experience
010
APA-ZZ-01400 App. H
Performance Review Group
013
APA-ZZ-01400 App. N
006
EDP-ZZ-04100
Review, Planning, Implementation & Closure Of
Modification Packages
022
EDP-ZZ-06000
Vendor Equipment Technical Information Review
Program
017
GDP-ZZ-01810
Nuclear Oversight Assessment Coverage
044
ITL-KJ-00P24
LOOP-PRESS; Diesel Engine (KKJ01A) Crankcase
Exit Pressure
4
ITP-KJ-00001
Emergency DG A Trip Checks
8
LDP-ZZ-00500
Corrective Action Review Board
021
MDP-ZZ-LM001
Fluid Leak Management Program
011
MDP-ZZ-TR001
Planning and Execution of Troubleshooting Activities 007
MDP-ZZ-TR001
Planning and Execution of Troubleshooting Activities 009
MPE-ZZ-QY210
Emergency Diesel Generator NE01 and NE02
Protective Relay Inspection, Test and Calibration
6
MSE-NB-QY002
Operational Test Sequence of 4.16KV Diesel
Generator NE01 Air Circuit Breaker 152NB0111
11
ODP-ZZ-00001
Operations Department - Code of Conduct
076
ODP-ZZ-00001 Add. 04
Operating Experience
002
ODP-ZZ-00001 Add. 11
Control Room Decorum
011
OTHER
NUMBER
TITLE
REVISION
1Q11 Quarterly Trend Report Attachment 1
5/17/2011
1Q12 Quarterly Trend Report Attachment 1
4/24/2012
2Q11 Quarterly Trend Report Attachment 1
8/23/2011
3Q11 Quarterly Trend Report Attachment 1
11/29/2011
4Q11 Quarterly Trend Report Attachment 1
2/17/2012
Brochure: Employee Concerns Program
08/24/11
Callaway Procedure Writers Manual
012
Nuclear Safety Culture Assessment
Operating Quality Assurance Manual (OQAM)
028c
Plant Status Control Events List
Surveillance Report SP12-010
5/31/2012
Surveillance Report SP12-011
6/18/2012
Surveillance Report SP12-013
6/22/2012
201200167-05
Employee Concerns Program Self-Assessment
AP11-001
Radiation Protection Audit
1/4/2011
AP11-002
Operations Audit
4/28/2011
AP11-003
Information Management Audit
3/15/2011
AP11-004
Operations Training Audit
6/13/2011
AP11-005
Access Authorization Audit
8/11/2011
AP11-006
Maintenance Audit
8/24/2011
AP11-007
Independent Quality Program Audit
8/2/2011
AP11-008
Emergency Preparedness Audit
8/15/2011
AP11-009
Corrective Action Program Audit
11/5/2011
AP12-001
Material Services Audit
3/6/2012
AP12-002
Configuration Management Audit
3/28/2012
AP12-003
Fire Protection Program Audit
5/7/2012
POL0017
Safety Conscious Work Environment Policy
007
POL0048
Executive Review Board Policy
004
SP12-007
Functional Area Performance Assessment Report for
March 1 to March 15, 2012
3/29/12
NUMBER
TITLE
REVISION
SP12-008
Functional Area Performance Assessment Report for
February 23 to March 31, 2012
4/29/12
SP12-010
Functional Area Performance Assessment Report for
April 15 to 30, 2012
4/31/12
T51.0092 6
Safety Conscious Work Environment and Managing
Protected Employees- training slide presentation
05/31/2012
TM 08-0004
Temporary Modification Request and Authorization
11/3/2008
TM 09-0002
Temporary Modification Request and Authorization
2/6/2009
Attachment 2
Information Request
May 4, 2012
Biennial Problem Identification and Resolution Inspection
June 25 - July 13, 2012
Callaway Plant
Inspection Report 50-483/2012-008
This inspection will cover the period from October 18, 2010 to July 13, 2012. All requested
information should be limited to this period or to the date of this request unless otherwise
specified. To the extent possible, the requested information should be provided electronically in
Adobe PDF or Microsoft Office format. Lists of documents should be provided in Microsoft
Excel or a similar sortable format.
Please provide the following no later than June 1, 2012:
1.
Document Lists
Note: For these summary lists, please include the document/reference number, the
document title, initiation date, current status, and long-text description of the issue.
a.
Summary list of all corrective action documents related to significant conditions
adverse to quality that were opened, closed, or evaluated during the period
b.
Summary list of all corrective action documents related to conditions adverse to
quality that were opened or closed during the period
c.
Summary lists of all corrective action documents which were upgraded or
downgraded in priority/significance during the period
d.
Summary list of all corrective action documents that subsume or roll up one or
more smaller issues for the period
e.
Summary lists of operator workarounds, engineering review requests and/or
operability evaluations, temporary modifications, and control room and safety
system deficiencies opened, closed, or evaluated during the period
f.
Summary list of plant safety issues raised or addressed by the Employee
Concerns Program (or equivalent)
g.
Summary list of all Apparent Cause Evaluations completed during the period
h.
Summary list of all Root Cause Evaluations planned or in progress but not
complete at the end of the period
2.
Full Documents with Attachments
a.
Root Cause Evaluations completed during the period
b.
Quality assurance audits performed during the period
c.
All audits/surveillances performed during the period of the Corrective Action
Program, of individual corrective actions, and of cause evaluations
d.
Corrective action activity reports, functional area self-assessments, and non-
NRC third party assessments completed during the period (do not include INPO
assessments)
e.
Corrective action documents generated during the period for the following:
i.
All Cited and Non-Cited Violations issued to Callaway Plant
ii.
All Licensee Event Reports issued by Callaway Plant
f.
Corrective action documents generated for the following, if they were determined
to be applicable to Callaway Plant (for those that were evaluated but determined
not to be applicable, provide a summary list):
i.
NRC Information Notices, Bulletins, and Generic Letters issued or
evaluated during the period
ii.
Part 21 reports issued or evaluated during the period
iii.
Vendor safety information letters (or equivalent) issued or evaluated
during the period
iv.
Other external events and/or Operating Experience evaluated for
applicability during the period
g.
Corrective action documents generated for the following:
i.
Emergency planning drills and tabletop exercises performed during the
period
ii.
Maintenance preventable functional failures which occurred or were
evaluated during the period
iii.
Adverse trends in equipment, processes, procedures, or programs which
were evaluated during the period
iv.
Action items generated or addressed by plant safety review committees
during the period
3.
Logs and Reports
a.
Corrective action performance trending/tracking information generated during the
period and broken down by functional organization
b.
Corrective action effectiveness review reports generated during the period
c.
Current system health reports or similar information
d.
Radiation protection event logs during the period
e.
Security event logs and security incidents during the period (sensitive information
can be provided by hard copy during first week on site)
f.
Employee Concern Program (or equivalent) logs (sensitive information can be
provided by hard copy during first week on site)
g.
List of Training deficiencies, requests for training improvements, and simulator
deficiencies for the period
4.
Procedures
a.
Corrective action program procedures, to include initiation and evaluation
procedures, operability determination procedures, apparent and root cause
evaluation/determination procedures, and any other procedures which implement
the corrective action program at Callaway Plant
b.
Quality Assurance program procedures
c.
Employee Concerns Program (or equivalent) procedures
d.
Procedures which implement/maintain a Safety Conscious Work Environment
5.
Other
a.
List of risk significant components and systems
b.
Organization charts for plant staff and long-term/permanent contractors
Note: Corrective action documents refers to condition reports, notifications, action requests,
cause evaluations, and/or other similar documents, as applicable to Callaway Plant.
All requested documents should be provided electronically. Regardless of whether they are
uploaded to an internet-based file library (e.g., Certrecs IMS), please provide copies on CD or
DVD. Four copies of the CD or DVD should be sent to the team lead at the following address,
to arrive no later than June 1, 2012:
Eric A. Ruesch
U.S. NRC Region IV
1600 East Lamar Blvd.
Arlington, TX 76011-4511
Attachment 3
Supplemental Information Request
June 21, 2012
Biennial Problem Identification and Resolution Inspection
June 25 - July 13, 2012
Callaway Plant
Inspection Report 50-483/2012-008
This request supplements the original information request. Where possible, the information
should be available to the inspection team immediately following the entrance meeting. This
inspection will cover the period from October 18, 2010 to July 13, 2012. All requested
information should be limited to this period unless otherwise specified.
Please provide the following:
1. Electronic copies of the FSAR, technical specifications, and technical specification bases
2. For each week the team is on site,
Planned work/maintenance schedule for the station
Schedule of management or corrective action review meetings (e.g., CARB,
MRM, CAR screening meetings, etc.)
Agendas for these meetings
3. As part of the inspection, the team will do a five-year in-depth review of emergency
diesel generator issues and corrective actions. The following documents are to support
this review (electronic format preferred):
Copies of upper and lower tier cause evaluations performed on emergency diesel
generators and alternate emergency diesel generators within the last 5 years
List of all surveillances run on the emergency diesel generators within the last
five years, sortable by individual diesel generator and including acceptance
criteria
List of all corrective maintenance work orders performed on the emergency
diesel generators and alternate emergency diesel generators within the last
5 years
List of maintenance rule functional failure assessmentsregardless of the
resultperformed on the emergency diesel generators and alternate emergency
diesel generators within the last 5 years
System training manual for emergency diesel generators and alternate
4. The team will also review the stations implementation of the fatigue rule. These
documents support this review:
List of all fatigue assessments performed during the inspection period separated
by department
List of all work hour rule waivers and violations during the inspection period
separated by department
Fatigue rule implementing procedures
5. Specific documents:
Conduct of Operations procedure
APA-ZZ-00605 Temporary Modifications
APA-ZZ-00107 OE Review
APA-ZZ-00520, Reporting Requirements and Responsibilities
APA-ZZ-00152, Emergent Issue Response
Job 10006321
Job 10006322
Job 10007548
Job 10007549
HI 2007013
CA2847 Long Term Corrective Action (LTCA) Request Form
Callaway Action Requests (CARs):
o 201107759
o 201107761
o 201107762
o 201003813
o 201105331
o 201105768
o 201105273
Temporary modification packages:
o 08-0004
o 09-0001
o 09-0002
o 09-0072
o 10-0003
o 10-0004
o 10-0007
o 10-0008