IR 05000483/2018002
| ML18221A398 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 08/08/2018 |
| From: | Nick Taylor NRC Region 4 |
| To: | Diya F Ameren Corp, Union Electric Co |
| References | |
| IR 2018002 | |
| Download: ML18221A398 (46) | |
Text
August 8, 2018
SUBJECT:
CALLAWAY PLANT - NRC INTEGRATED INSPECTION REPORT 05000483/2018002
Dear Mr. Diya:
On June 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Callaway Plant. On July 10, 2018, the NRC inspectors discussed the results of this inspection with Mr. M. McLachlan, Senior Director, and other members of your staff. The results of this inspection are documented in the enclosed report.
NRC inspectors documented four findings of very low safety significance (Green) in this report.
All 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 of the Enforcement Policy.
If you contest the violations or significance of 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, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the Callaway Plant.
If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Callaway Plant. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Nicholas H. Taylor, Branch Chief Project Branch B Division of Reactor Projects
Docket No. 50-483 License No. NPF-30
Enclosure:
Inspection Report 05000483/2018002 w/Attachments:
1: Documents Reviewed 2. Request for Information Quarterly Baseline Inspection 3: Request for Information O
Inspection Report
Docket Number:
05000483
License Number:
Report Number:
Enterprise Identifier: I-2018-002-0006
Licensee:
Union Electric Company
Facility:
Callaway Plant
Location:
8315 County Road 459
Steedman, MO 65077
Inspection Dates:
April 1 to June 30, 2018
Inspectors:
D. Bradley, Senior Resident Inspector
S. Janicki, Resident Inspector
P. Elkmann, Senior Emergency Preparedness Inspector
N. Greene, PhD, Senior Health Physicist
P. Hernandez, Health Physicist
D. You, Resident Inspector
Approved By:
N. Taylor
Chief, Project Branch B
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at the Callaway Plant in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. Findings and violations being considered in the NRCs assessment are summarized in the tables below.
List of Findings and Violations
Failure to Adequately Assess and Manage Risk Associated with Switchyard Work During a Planned Risk Significant Turbine-Driven Auxiliary Feedwater Pump Equipment Outage Cornerstone Significance Cross-cutting Aspect Report Section Initiating Events Green NCV 05000483/2018002-01 Closed H.12 Avoid Complacency 71111.12 Maintenance Effectiveness The inspectors identified a Green, non-cited violation of 10 CFR 50.65(a)(4), Requirements for monitoring the effectiveness of maintenance at Nuclear Power Plants, for the licensees failure to adequately assess and manage risk associated with switchyard work during a planned risk significant turbine-driven auxiliary feedwater pump equipment outage. Specifically, the licensee failed to properly classify switchyard work and manage the risk as required by Procedures APA-ZZ-00322, Appendix F, Online Work Integrated Risk Management,
Revision 16, and ODP-ZZ-00002, Appendix 2, Risk Management Actions for Planned Risk Significant Activities, Revision 13.
Failure to Establish Maintenance Procedures for Doors that Provide Safety-Related Functions Cornerstone Significance Cross-cutting Aspect Report Section Barrier Integrity Green NCV 05000483/2018002-02 Closed H.4 Teamwork 71111.12 Maintenance Effectiveness The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a,
Procedures, for the licensees failure to establish, implement, and maintain procedures associated with door maintenance. Specifically, the licensee failed to establish, implement, and maintain maintenance procedures for doors that provide safety-related functions such as ventilation pressure boundaries. As a result, 15 safety-related doors were identified that either had degraded conditions or that did not have a periodic maintenance task to inspect the doors.
Failure to Critique an Inaccurate Emergency Classification During a Simulator Training Scenario Cornerstone Significance Cross-cutting Aspect Report Section Emergency Preparedness Green NCV 05000483/2018002-03 Closed P.6 Self-Assessment 71114.05 Maintenance of Emergency Preparedness The inspectors identified a non-cited violation of 10 CFR 50.47(b)(14) for the licensees failure to critique an inaccurate emergency classification made during licensed operator training.
Failure of an Analysis of the Impact of Changes to Emergency Action Levels to Demonstrate the Changes Did Not Reduce the Effectiveness of the Emergency Plan Cornerstone Significance Cross-cutting Aspect Report Section Emergency Preparedness Green NCV 05000483/2018002-04 Closed H.14 Conservative Bias 71114.05 Maintenance of Emergency Preparedness The inspectors identified a non-cited violation of 10 CFR 50.54(q)(3) for the failure of an analysis of the impact of changes to licensee emergency action levels to demonstrate that the changes did not reduce the effectiveness of the emergency plan.
Additional Tracking Items
Type Issue number Title Report Section Status LER 05000483/2018-001-00 Violation of Technical Specification 3.6.3, Containment Isolation Manual Valve Found in Open Position 71153 Closed
PLANT STATUS
Callaway Plant began the inspection period at full power and remained at this power level through the end of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public Web site at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.
Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in Inspection Manual Chapter 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01Adverse Weather Protection Summer Readiness
The inspectors evaluated summer readiness of offsite and alternate alternating current power systems on May 3, 2018.
71111.04Equipment Alignment Partial Walkdown
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Safety injection pump train B on April 27, 2018
- (2) Emergency diesel generator train B, including related essential service water on May 1, 2018
- (3) Motor-driven auxiliary feedwater train A and train B on May 8, 2018
- (4) Emergency diesel generator train A on May 29, 2018
71111.05AQFire Protection Annual/Quarterly Quarterly Inspection
The inspectors evaluated the fire protection program implementation in the following selected areas:
- (1) Containment spray train A, fire area A-2, on April 10, 2018
- (2) Emergency diesel generator train A, fire area D-1, on April 10, 2018
- (3) Auxiliary feedwater pump and valve rooms, fire areas A-13, A-14, A-15, A-29, and A-30, on June 12, 2018
- (4) Fuel Handling Building, fire area FB-1, on June 28, 2018
71111.11Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification
The inspectors observed and evaluated simulator training for operating crews annual exam activities on May 31, 2018.
Operator Performance (1 Sample)
The inspectors observed and evaluated control rod positioning in the control room on May 11, 2018.
71111.12Maintenance Effectiveness Routine Maintenance Effectiveness
The inspectors evaluated the effectiveness of routine maintenance activities associated with the turbine-driven auxiliary feedwater system on May 9, 2018.
Quality Control (1 Sample)
The inspectors evaluated maintenance and quality control activities associated with the safety-related door preventive maintenance, including quality control, for hazard barriers on April 17, 2018.
71111.13Maintenance Risk Assessments and Emergent Work Control
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) Elevated risk actions due to planned containment spray train A equipment outage on April 11, 2018
- (2) Elevated risk actions due to planned emergency diesel generator train B and essential service water train B equipment outage on May 1, 2018
- (3) Elevated risk actions due to planned main turbine control oil system equipment outage on May 28, 2018
- (4) Elevated risk actions due to emergent work on the emergency diesel generator train A lube oil system on June 21, 2018
71111.15Operability Determinations and Functionality Assessments
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) Residual heat removal valve interlocks on April 2, 2018
- (2) Auxiliary transformer gas testing on April 12, 2018
- (3) Air conditioning units, SGK04 and SGK05 series, restart capability on April 17, 2018
- (4) Containment sump indications on April 24, 2018
- (5) Emergency operating procedures for natural circulation cooldown on May 7, 2018
- (6) Atmospheric steam dump and auxiliary feedwater nitrogen accumulators, including operator workaround review, on May 18, 2018
- (7) Emergency diesel generator train B fuel rack displacement on May 22, 2018
- (8) Safety injection tank C accumulator vent valve reseating on June 15, 2018
71111.19Post Maintenance Testing
The inspectors evaluated the following post maintenance tests:
- (1) Essential service water cross-connect valve EFHV0026 equipment outage on April 23, 2018
- (2) Essential service water cross-connect valve EFHV0040 equipment outage on April 25, 2018
- (3) Containment cooler trains B and D after equipment outage on May 22, 2018
- (4) Emergency diesel generator train B after equipment outage on May 30, 2018
- (5) Control room air conditioning unit SGK04A equipment outage on June 5, 2018
- (6) Circuit breaker NG02BJF2 after equipment outage on June 19, 2018
71111.22Surveillance Testing The inspectors evaluated the following surveillance tests: Routine
- (1) ISF-AL-00P37, condensate storage tank to auxiliary feedwater suction header pressure channel test on April 17, 2018
- (2) OSP-NB-00001, class 1E electrical source verification on May 14, 2018
- (3) OSP-AL-V001B, train B auxiliary feedwater valve in-service test on April 24, 2018
- (4) OSP-NE-0001A, emergency diesel generator train A periodic tests on June 13, 2018
In-service (1 Sample)
The inspectors evaluated OSP-EN-P001A, containment spray pump train A in-service test on April 11, 2018.
Reactor Coolant System Leak Detection (1 Sample)
The inspectors evaluated OSP-BB-00009, reactor coolant system inventory balance on May 15, 2018.
71114.02Alert and Notification System Testing
The inspectors evaluated maintenance and testing of the alert and notification system on April 25, 2018.
71114.03Emergency Response Organization Staffing and Augmentation System
The inspectors evaluated readiness of the emergency preparedness organization on April 26, 2018.
71114.04Emergency Action Level and Emergency Plan Changes
The inspectors evaluated submitted emergency action level and emergency plan changes on April 26, 2018. This evaluation does not constitute NRC approval.
71114.05Maintenance of Emergency Preparedness
The inspectors evaluated maintenance of the emergency preparedness program between April 23 and April 25, 2018.
71114.06Drill Evaluation Drill/Training Evolution
The inspectors evaluated the full participation drill, Team 5 on May 24,
RADIATION SAFETY
71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls
Radiological Work Planning (1 Sample)
The inspectors evaluated the licensees radiological work planning by reviewing the following activities:
- (1) RF22 crane valve work
- (2) R22-55320 reactor building head lift
- (3) R22-56321 remove/reinstall reactor vessel lower internals
- (4) R22-50101 radiation Protection Routine Activities Reactor Building
- (5) R22-55220 reactor building head removal
Verification of Dose Estimates and Exposure Tracking Systems (1 Sample)
The inspectors evaluated dose estimates and exposure tracking.
71124.04 - Occupational Dose Assessment
Source Term Characterization (1 Sample)
The inspectors evaluated the licensees source term characterization.
External Dosimetry (1 Sample)
The inspectors evaluated the licensees external dosimetry program.
Internal Dosimetry (1 Sample)
The inspectors evaluated the licensees internal dosimetry program.
Special Dosimetry Situations (1 Sample)
The inspectors evaluated the licensees performance for special dosimetry situations.
OTHER ACTIVITIES - BASELINE
71151Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
- (1) MS05: Safety System Functional Failures Sample (04/01/2017 - 03/31/2018)
- (2) MS08: Heat Removal Systems (04/01/2017 - 03/31/2018)
- (3) BI02: Reactor Coolant System Leak Rate Sample (04/01/2017 - 03/31/2018)
- (4) EP01: Drill/Exercise Performance Sample (04/01/2017 - 03/31/2018)
- (5) EP02: Emergency Response Organization (ERO) Drill Participation Sample (04/01/2017 - 03/31/2018)
- (6) EP03: Alert and Notification System Reliability Sample (04/01/2017 - 03/31/2018)
71152Problem Identification and Resolution Semiannual Trend Review
The inspectors reviewed the licensees corrective action program for trends that might be indicative of a more significant safety issue.
71153Follow-up of Events and Notices of Enforcement Discretion Licensee Event Reports
The inspectors evaluated Licensee Event Report 05000483/2018-001-00, Violation of Technical Specification 3.6.3, Containment Isolation Manual Valve Found in Open Position on March 12, 2018, which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx.
A minor violation was documented in the inspection results section of this report.
INSPECTION RESULTS
Failure to Adequately Assess and Manage Risk Associated with Switchyard Work During a Planned Risk Significant Turbine-driven Auxiliary Feedwater Pump Equipment Outage Cornerstone Significance Cross-cutting Aspect Report Section Initiating Events
Green NCV 05000483/2018002-01 Closed H.12 Avoid Complacency 71111.12 Maintenance Effectiveness The inspectors identified a Green, non-cited violation of 10 CFR 50.65(a)(4), Requirements for monitoring the effectiveness of maintenance at nuclear power plants, for the licensees failure to adequately assess and manage risk associated with switchyard work during a planned risk significant turbine-driven auxiliary feedwater (TDAFW) pump equipment outage.
Specifically, the licensee failed to properly classify switchyard work and manage the risk as required by Procedures APA-ZZ-00322, Appendix F, Online Work Integrated Risk Management, Revision 16, and ODP-ZZ-00002, Appendix 2, Risk Management Actions for Planned Risk Significant Activities, Revision 13.
Description:
On February 20, 2018, the licensee was contacted by Ameren corporate regarding an issue with one of Callaways offsite power lines, Callaway-Bland-1. Ameren identified a likely failure of the trip tone transmitter, a programmable logic controller that communicates grid information between substations. The trip tone transmitter protects downline equipment during a grid transient by tripping the breaker prior to the transient reaching the breaker.
Condition Report 201800866 and Job 18000724 were written to document and correct this issue.
On February 27, 2018, the licensee commenced a scheduled technical specification equipment outage for the TDAFW pump. Risk management actions were briefed and established per Procedure ODP-ZZ-00002, Appendix 2, Risk Management Actions for Planned Risk Significant Activities, which included a requirement to NOT allow work in the switchyard that could cause a Loss of Offsite Power.
Later on February 27, 2018, the Ameren corporate relay team arrived on site to replace the Callaway-Bland-1 trip tone transmitter. This job required the relay team to access the switchyard and to replace the trip tone transmitter for Callaway-Bland-1 at switchyard breaker MDV44. This job was not listed on the weekly work schedule or incorporated into the sites overall risk management plan in the previous weeks. Callaways electrical maintenance team and the Ameren corporate relay team briefed operations on the job requirements, how the maintenance would be controlled, and the required switchyard entry. The brief also covered a precaution in the work package warning that work could result in a trip of the Callaway-Bland-1 line. While the precaution was covered during the brief, the maintenance team discussed that a loss of offsite power was unlikely, the precaution was automatically entered into the work package based on location, and the precaution was not because of an actual risk.
The inspectors reviewed the licensees assessment and management of risk.
Procedure APA-ZZ-00322, Appendix F, Section 4.4.9, MD system (switchyard circuit breaker)work was required to be evaluated at a minimum as Medium Risk in Nuclear Safety/Operational Risk... because of the potential consequence to nuclear safety.
Operations, however, updated the job risk to low, authorized vehicles in the switchyard, and gave permission for the work to proceed. Operations did not correctly re-perform the TDAFW pump risk assessment based on the new in-plant conditions as required by Procedure APA-ZZ-00322, Appendix F, Section 4.1.4.
Corrective Action: Since the switchyard work was complete when the issue was identified, the licensee initiated a condition report and calculated the increase in risk incurred as a result of this issue. The incremental core damage probability deficit (ICDPD) was found to be 3E-8 using the licensees safety monitor software.
Corrective Action Reference: Condition Report 201800866
Performance Assessment:
Performance Deficiency: Failure to adequately assess and manage risk associated with switchyard work during a risk-significant TDAFW pump maintenance period was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it adversely affected the protection against external factors attribute of the Initiating Event Cornerstone to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, Procedure ODP-ZZ-00002, Appendix 2, Risk Management Actions for Planned Risk Significant Activities, included a requirement to NOT allow work in the switchyard that could cause a Loss of Offsite Power.
Significance: Because the finding affects the licensees assessment of risk associated with performing maintenance activities, NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, dated June 19, 2012, directs significance determination via the use of NRC Inspection Manual Chapter 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, dated May 19, 2005. The inspectors used Inspection Manual Chapter 0609, Appendix K, to determine that the performance deficiency was of very low safety significance (Green). Specifically, the finding was not related to risk management actions only since the licensee failed to adequately assess risk. Since the finding involved approximately four hours of switchyard work with TDAFW pump out of service, the finding had a risk deficit of 3E-8 (<1E-6 ICDPD)determined from the licensees safety monitor software.
Cross-cutting Aspect: The finding had a cross-cutting aspect in the area of human performance associated with avoid complacency because the licensee failed to ensure individuals recognize and plan for the possibility of mistakes and ensure individuals implement the appropriate error reduction tools [H.12]. Specifically, the team assumed the switchyard work would be successful in the planning and briefing of the job. Although a vehicle was authorized in the switchyard and the work occurred in the relay room where offsite power can be tripped, the team decided that a loss of offsite power was unlikely and did not recognize the possibility of mistakes that could lead to inadvertent tripping of offsite power.
Enforcement:
Violation: Title 10 CFR 50.65(a)(4) states, in part, Before performing maintenance activities (including, but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from proposed maintenance activities. The licensee established procedures APA-ZZ-00322, Appendix F, Online Work Integrated Risk Management, Revision 16, and ODP-ZZ-00002, Appendix 2, Risk Management Actions for Planned Risk Significant Activities, Revision 13, in part, to meet this requirement.
Contrary to the above, on February 27, 2018, the licensee failed to adequately assess and manage the associated increase in risk from the switchyard work during risk significant TDAFW pump maintenance. Specifically, Procedure ODP-ZZ-00002, Appendix 2, Risk Management Actions for Planned Risk Significant Activities, included a requirement to NOT allow work in the switchyard that could cause a Loss of Offsite Power. The licensee failed to correctly update the original TDAFW pump risk assessment based on the new plant configuration with switchyard work in progress. As a result, the licensee incorrectly updated the job risk to low, authorized vehicles in the switchyard, and allowed work in the switchyard that could have resulted in a trip of the Callaway-Bland-1 line.
Disposition: This violation is being treated as a non-cited violation consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Establish Maintenance Procedures for Doors that Provide Safety-Related Functions Cornerstone Significance Cross-cutting Aspect Report Section Barrier Integrity
Green NCV 05000483/2018002-02 Closed H.4 Teamwork 71111.12 Maintenance Effectiveness The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a, Procedures, for the licensees failure to establish, implement, and maintain procedures associated with door maintenance. Specifically, the licensee failed to establish, implement, and maintain maintenance procedures for doors that provide safety-related functions such as ventilation pressure boundaries. As a result, 15 safety-related doors were identified that either had degraded conditions or that did not have a periodic maintenance task to inspect the doors.
Description:
On March 7, 2018, the inspectors toured the Auxiliary Building 2047 elevation and identified a degraded door seal on door DSK15121, associated with control room air conditioning units.
The inspectors shared their observations with the licensee and Condition Report 201801220 was written to document and correct this issue. The inspectors noted that some doors in this area of the plant interface with the control room ventilation boundary and serve a safety-related barrier function for ventilation to the control room during postulated accidents.
The inspectors reviewed licensee Procedure MPM-SK-QW001, Service and Inspection of Plant Doors, Revision 0, and challenged the licensee on preventative maintenance inspections for safety-related and non-safety doors.
As a result, the licensee performed an extent of condition review for door degradations. The inspectors, in parallel and independently of the licensee, performed a review of preventative maintenance on doors that provide safety-related functions. These reviews revealed 33 safety-related and non-safety related doors had degraded conditions or that did not have a periodic maintenance task to inspect the doors. Note that the degraded conditions included deficiencies that were not previously identified prior to this extent of condition review. The degraded conditions varied from missing seals, gaps due to door deformation, loose hardware, and other low level issues across several safety-related areas of the plant. These areas included the auxiliary building, the control building, and the fuel building. Of those 33 doors, 15 were safety-related with the remainder predominantly serving as fire barriers.
The summary of these issues are included in the table below.
Door DSKnnnnn
[S] safety-related Degraded condition No periodic maintenance CR Numbers 20180nnnn 11021 [S]
X
1394 11194 [S]
X
1364 11195 [S]
X X
1394, 1773 11273 [S]
X
1394 13011 [S]
X 1773 13012 [S]
X X
1394, 1773 13291 [S]
X
1394 14031 X
1591 14052 X
1591 14081 [S]
X
1364 14091 X
1591 14102 X
1591 14133 X
1358 15012 X
1591, 1219 15031 X
1363 15041 [S]
X
1394 15071 [S]
X
1364 15121 X
1220, 1315, 1581 15131 X
1329, 1581 21011 [S]
X
1394 31041 [S]
X
1394 32013 [S]
X 1773 32242 X
X 1394, 1773 33011 X
1591 33023 X
1591 33044 [S]
X
1394 34041 X
1591 36161 X
1331 36092 X
1331 41011 [S]
X
1394 61011 X
X 1364, 1773 61021 X
1364 61022
X 1773 Further, the licensee initiated Condition Report 201801513, to document design discrepancies in the definition of air tight across various plant doors.
In each safety-related case, the licensee entered the issue into the corrective action program and was able to demonstrate operability of the associated structures, systems, and components.
The inspectors concluded the licensee failed to establish, implement, and maintain maintenance procedures for doors that provide safety-related functions such as ventilation pressure boundaries. Further, the inspectors determined the issue was programmatic across several safety-related areas of the plant and functions performed by the doors.
As an example of the failure to maintain door maintenance procedures, step 2 of Procedure MPM-SK-QW001, Addendum 5, Service and Inspection of Pressure Doors, Revision 0, states, the procedure applies to doors listed in Attachment 1 of this procedure.
Safety-related door DSK11195 is listed in Attachment 1 but the requirement to perform preventative maintenance was not translated to a recurring job. As a result, there was no preventative maintenance task assigned to inspect the door; although, the program required it. This issue was captured under Condition Report 201801773. When the lack of preventative maintenance was identified, the licensee inspected the door and found material deficiencies. This issue was captured under Condition Report 201801394. This is one example of the issues summarized in the table above.
The inspectors noted that the procedural guidance for maintenance technicians working on doors did not match up to engineerings threshold for identifying issues that could be adverse.
For example, Section 5.1 of Addendum 5 of Procedure MPM-SK-QW001 allows maintenance technicians to perform minor maintenance to correct deficiencies found and only requires a condition report be written if a condition is identified which affects the capability of the door to function as designed. Further, a sampling of jobs to perform safety-related door maintenance, such as Job 17513036, have a generic note stating, minor door seal damage is acceptable. Conversely, engineering tracks openings in ventilation pressure boundaries to the units of 0.1 inches squared under equipment out of service logs (EOSLs) such as EOSL 16429. This EOSL is a living document that aggregates known deficiencies in ventilation pressure boundaries in order to preserve the calculated margin of design basis heating, ventilation, and air conditioning (HVAC) systems. The inspectors determined there was inadequate communication across engineering and maintenance in order to preserve design assumptions for safety-related HVAC.
Corrective Actions: The licensee performed a walk-down of safety-related and non-safety doors, a review of safety-related door maintenance procedures, and entered issues into the corrective action program.
Corrective Action Reference: Condition Report 201803204
Performance Assessment:
Performance Deficiency: The failure to establish, implement, and maintain maintenance procedures for doors that provide safety-related functions such as ventilation pressure boundaries was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor, and therefore a finding, because it adversely affected the structure, system, and component, and the barrier performance attribute of the Barrier Integrity Cornerstone objective of providing reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. Specifically, the licensee identified 15 safety-related doors that either had deficiencies that were not previously identified during inspections or that did not have a periodic preventative maintenance task to inspect the doors. Further, the inspectors determined the issue was programmatic across several safety-related areas of the plant and functions performed by the doors.
Significance: Using Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 3, Mitigating Systems Screening Questions, dated June 19, 2012, the inspectors determined that the finding was of very low safety significance (Green) because the finding only represented a degradation of the radiological barrier function provided for the control room, or auxiliary building, or spent fuel pool.
Cross-cutting Aspect: The finding had a cross-cutting aspect in the area of human performance associated with teamwork because the licensee failed to ensure individuals and work groups communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained [H.4].
Enforcement:
Violation: Technical Specification 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2. Section 9.a of Appendix A to Regulatory Guide 1.33, Revision 2, requires maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
The licensee established Procedure MPM-SK-QW001, Service and Inspection of Plant Doors, Revision 0, and associated addendums, in part, to meet the regulatory requirement.
Step 2 of Procedure MPM-SK-QW001, Addendum 5, Service and Inspection of Pressure Doors, Revision 0, states the procedure applies to doors listed in Attachment 1 of this procedure.
Contrary to the above, prior to March 7, 2018, the licensee failed to apply the procedure to doors listed in Attachment 1 of Procedure MPM-SK-QW001, Addendum 5. As a result, the licensee failed to establish, implement, and maintain procedures for preventative maintenance that can affect the performance of safety-related pressure doors. Consequently, 15 safety-related doors were identified that either had degraded conditions or that did not have a periodic maintenance task to inspect the doors.
Disposition: This violation is being treated as a non-cited violation consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Critique an Inaccurate Emergency Classification During a Simulator Training Scenario Cornerstone Significance Cross-cutting Aspect Report Section Emergency Preparedness Green NCV 05000483/2018002-03 Closed P.6 Self-Assessment 71114.05 Maintenance of Emergency Preparedness The inspectors identified a non-cited violation of 10 CFR 50.47(b)(14) for the licensees failure to critique an inaccurate emergency classification made during licensed operator training.
Description:
The inspectors reviewed records from a licensed operator training session conducted in the control room simulator on May 31, 2017. The inspectors determined that the scenario was designed to provide conditions leading to emergency action level SA9.1, hazards affecting a safety system. The records indicated that the shift manager incorrectly declared emergency action level FA1.1, loss of one fission product barrier, based on a belief that a reactor coolant system leak was in progress. When the shift manager informed the operations crew of the declaration, the crew informed the shift manager that the leak was not from the reactor coolant system. The shift manager reassessed conditions and subsequently declared emergency action level SA9.1. The correct classification was made within 15 minutes of conditions occurring which required classification and notifications made to offsite authorities.
The licensee evaluated the shift managers performance as accurate and reported the associated drill and exercise performance indicator opportunity to the NRC as a success.
The inspectors determined that the shift managers performance was not accurate and the declaration of emergency action level FA1.1 should have been determined to be a performance weakness in accordance with Emergency Preparedness Frequently Asked Question 13-07, dated April 1, 2014. The frequently asked question states that the initial declaration at an emergency classification level is to be evaluated for accuracy and that a subsequent correction does not negate an inaccurate initial declaration.
Corrective Actions: The licensee plans to correct the performance indicator submission to the NRC for Second Quarter 2017 and perform a human performance analysis for shift managers and emergency operations facility emergency coordinators.
Corrective Action Reference: Condition Report 201802099
Performance Assessment:
Performance Deficiency: The failure to critique an inaccurate emergency classification made during licensed operator training was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it adversely affected the Emergency Preparedness Cornerstone attribute of the emergency response organizations performance. The licensee may not be capable of taking adequate measures to protect the health and safety of the public if they do not maintain the emergency response organizations ability to recognize emergency classifications.
Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, dated September 22, 2015. The finding was determined to be of very low safety significance (Green) because it was a failure to comply with NRC requirements, was not a lost or degraded risk-significant planning standard function, and was not a loss of planning standard function. The finding was not a loss of planning standard function because the failure to critique occurred in a drill with limited evaluation.
Cross-cutting Aspect: The licensee failed to routinely conduct self-critical and objective assessments of its practices. Specifically, evaluators for a licensed operator training session were not self-critical about the classification of emergency events. The evaluators failed to recognize that the initial declaration of an emergency classification was required to be evaluated and that subsequent correction of an inaccurate declaration did not create a successful performance indicator opportunity [P.6].
Enforcement:
Violation: Title 10 CFR 50.47(b)(14) requires, in part, that deficiencies identified as a result of drills or exercises will be corrected.
Contrary to the above, on May 31, 2017, the licensee failed to correct a deficiency occurring in a drill. Specifically, the licensee failed to identify the declaration of an emergency classification as inaccurate and subsequently failed to correct the inaccurate performance.
Disposition: This violation is being treated as a non-cited violation consistent with Section 2.3.2 of the Enforcement Policy.
Failure of an Analysis of the Impact of Changes to Emergency Action Levels to Demonstrate the Changes did not Reduce the Effectiveness of the Emergency Plan Cornerstone Significance Cross-cutting Aspect Report Section Emergency Preparedness Green NCV 05000483/2018002-04 Closed H.14 Conservative Bias 71114.05 Maintenance of Emergency Preparedness The inspectors identified a non-cited violation of 10 CFR 50.54(q)(3), for the failure of an analysis of the impact of changes to licensee emergency action levels to demonstrate that the changes did not reduce the effectiveness of the emergency plan.
Description:
The inspectors reviewed analysis in 5054Q Assessment 2017027 for the impacts of a change to the emergency plan Procedure EIP-ZZ-00101, Addendum 2, Emergency Action Level Technical Bases Document, Revision 13, dated December 12, 2017. The licensee implemented the emergency action level changes on March 29, 2018. The inspectors noted that, in part, the emergency action level changes included a revised threshold for radiation monitors GT-RE-59 and GT-RE-60 in the fission product barrier initiating conditions.
The analysis of the change identified that the licensee used NUREG-1940, RASCAL 4:
Description of Models and Methods, dated December 2012 as the basis for the calculations which determined the revised radiation monitor thresholds. The analysis also identified that previous calculations for these radiation monitors were based on the licensees Final Safety Analysis Report (FSAR). The licensees stated basis for using NUREG-1940 was that it provided a source term that was more averaged over a spectrum of accidents and core conditions than a source term derived from the FSAR.
The inspectors discussed Assessment 2017027 with the licensee. The licensee stated that NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 6, dated November 2012 did not specify how to develop the source term(s) used to calculate radiological emergency action levels. Also, the use of NUREG-1940 to develop the radiological source term did not need to be justified because it was an NRC authored document. In addition, the licensee believes that the use of NUREG-1940 was acceptable to the NRC because other licensees had used NUREG-1940 to develop emergency action levels and those emergency action levels were approved as license amendments.
The inspectors reviewed a comparison of the assumed concentration of 15 isotopes listed in the FSAR to the assumed concentration of the same isotopes in the source term derived from NUREG-1940 and identified minor differences not likely to result in significant inaccuracies in the calculated radiation monitor thresholds. However, the source term used by the licensee also included radioactive isotopes not present in the FSAR, in the form of radioactive particulates. The licensees analysis did not address the effect of including these additional isotopes in calculations.
The inspectors concluded that the licensee could not adopt radiological source terms derived from NUREG-1940 without justifying why the derived radiological source term resulted in a more accurate calculation of emergency action levels than calculations derived from the source term specified in the FSAR. Further, the inspectors did not identify a valid justification for the use of NUREG-1940 in the regulatory analysis, dated December 12, 2017. As a result, the licensee failed to demonstrate the proposed change would not be a decrease in effectiveness.
Corrective Actions: The issue is not an immediate safety concern because the revisions to radiation monitor thresholds in the emergency action levels do not differ significantly from what the thresholds would have been had the FSAR source term been used as the basis for the calculation. The licensee will evaluate appropriate corrective actions in Condition Report 201802128.
Corrective Action Reference: Condition Report 201802128
Performance Assessment:
Performance Deficiency: The failure of the licensees 5054Q Assessment 2017027 to demonstrate the proposed emergency plan change did not reduce the effectiveness of the emergency plan was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it adversely affected the Emergency Preparedness Cornerstone attribute of procedure quality (emergency action level changes, plan changes). A licensee may not be capable of implementing adequate measures to protect the health and safety of the public if the licensee fails to demonstrate that changes made to its emergency plan and emergency action levels do not reduce the effectiveness of the emergency plan.
Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, dated September 22, 2015. The finding was determined to be of very low safety significance (Green) because it was a failure to comply with NRC requirements not associated with the emergency preparedness planning standards.
Cross-cutting Aspect: The licensee failed to demonstrate a conservative bias in making the choice of radiological source terms to use as the basis for calculating emergency action level thresholds. Specifically, the licensee did not demonstrate that use of a radiological source term deviating from its approved site FSAR provided a more accurate calculational basis before performing the calculation [H.14].
Enforcement:
Violation: Title 10 CFR 50.54(q)(3) requires, in part, that a licensee make changes to its emergency plan without NRC approval only if the licensee performs an analysis demonstrating that changes do not reduce the effectiveness of the plan.
Contrary to the above, on December 12, 2017, the licensee made changes to its emergency plan without NRC approval, but failed to perform an analysis demonstrating the changes did not reduce the effectiveness of the plan. Specifically, the licensees analysis of changes to Procedure EIP-ZZ-00101, Addendum 2, Emergency Action Level Technical Bases Document, Revision 13, did not demonstrate that use of a radiological source term derived from NUREG-1940 resulted in a more accurate calculation of emergency action level thresholds than would a calculation based on the approved site FSAR.
Disposition: This violation is being treated as a non-cited violation consistent with Section 2.3.2 of the Enforcement Policy.
Observation 71152Problem Identification and Resolution The inspectors reviewed the licensees corrective action program, performance indicators, system health reports, and other documentation to identify trends that might be indicative of a more significant safety issue for the emergency diesel generators.
The inspectors reviewed adverse issues for the safety-related emergency diesel generators (EDGs) identified between July 1, 2017, and June 30, 2018. During this period, 181 EDG condition reports were generated. Of these, 129 condition reports were related to program concerns, such as knowledge transfer, benchmarking, industry operating experience, Part 21 evaluations, review of industry inspection findings, procedural enhancements, reportability, and documentation of other items, such as chemistry results.
The inspectors focused on the remaining 52 condition reports that documented adverse material conditions and planning/scheduling issues. As one example of the adverse material condition reports, the inspectors reviewed 10 condition reports related to the crack discovery on the train B EDG #6 main saddle bearing identified in the fall 2017 refueling outage:
- Condition Report 201706169 identified excessive bearing clearance with the train B EDG #6 main saddle bearing and evaluated reportability
- Condition Report 201706217 generated to track degraded and non-conforming conditions identified during Refueling Outage 22
- Condition Report 201706244 documented the crack discovery on the train B EDG #6 main saddle bearing
- Condition Report 201706386 documented damage to the train B EDG from rigging gear during the bearing saddle replacement
- Condition Report 201706399 identified loose fasteners as a possible contributing factor to the cracked saddle bearing
- Condition Report 201706768 documented a water leak during the hydrostatic test following the train B main saddle bearing replacement
- Condition Report 201706884 identified maintenance trends on the train B EDG during Refueling Outage 22
- Condition Report 201706935 documented liquid dye penetrant testing on EDG bearings
- Condition Report 201707356 identified EDG indications for input to the operational decision making process
- Condition Report 201800907 documented Fairbanks-Morse evaluation of the cracked main saddle bearing Similarly, the inspectors reviewed the remaining adverse material condition reports which covered a wide range of issues such as jacket water leakage, fuel oil leakage, fuel injector damage, degraded gaskets/o-rings, engine balancing, and foreign material exclusion in support systems.
In the work planning category, the licensee documented two issues with scheduling maintenance and one for work not ready to commence.
The inspectors verified that all issues were addressed within the scope of the corrective action program and that the completed and planned actions were appropriate to correct the identified causes. The inspectors noted that several of the adverse conditions identified were legacy issues or problems that the licensee corrected in order to restore the system. The inspectors did not identify any trends or concerns that might be indicative of a more significant safety issue for the EDGs.
Minor Violation 71153Follow-up of Events and Notices of Enforcement Discretion Minor Violation: Contrary to Technical Specification 3.6.3, Containment Isolation Valves, the licensee failed to maintain each containment isolation valve operable or enter applicable conditions and required actions for an inoperable containment isolation valve in Modes 1, 2, 3, and 4.
Specifically, the licensee failed to shut the reactor building service air header supply outer containment isolation valve KAV0118 after the fall 2017 refueling outage. As a result, isolation valve KAV0118 was left open from November 25, 2017, through January 11, 2018, which rendered the valves containment isolation function inoperable. The as-found testing demonstrated that the overall containment isolation function, for that penetration, was met with inner containment isolation valve KAV0039 in the normally shut position. Additional information can be found in Licensee Event Report 05000483/2018-001-00, Violation of Technical Specification 3.6.3, Containment Isolation Manual Valve Found in Open Position (ADAMS Accession Number ML18071A208).
The licensees failure to comply with Technical Specification 3.6.3, Containment Isolation Valves, and maintain each containment isolation valve operable or enter applicable conditions and required actions for an inoperable containment isolation valve in Modes 1, 2, 3, and 4 was a performance deficiency.
Screening: The inspectors determined the performance deficiency was minor because it was not a precursor to a significant event, did not have the potential to lead to a more significant safety concern, did not relate to a performance indicator that would have exceeded a threshold and did not adversely impact any of the cornerstone objectives. Specifically, the as-found local leak rate testing demonstrated that containment isolation function was met with inner containment isolation valve KAV0039 in the normally shut position.
Enforcement:
The failure to comply with Technical Specification 3.6.3, Containment Isolation Valves, and maintain each containment isolation valve operable or enter applicable conditions and required actions for an inoperable containment isolation valve in Modes 1, 2, 3, and 4 constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On April 27, 2018, the inspector presented the onsite emergency preparedness inspection results to Mr. T. Herrmann, Site Vice President, and other members of the licensee staff
On May 24, 2018, the inspectors presented the occupational radiation protection inspection results to Mr. B. Cox, Senior Director of Nuclear Operations, and other members of the licensee staff.
On July 10, 2018, the inspectors presented the integrated quarterly resident inspection results to Mr. M. McLachlan, Senior Director, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Procedure 71111.01: Adverse Weather Protection
Procedures
Number
Title
Revision
APA-ZZ-00322,
Appendix D
Work Control Center Organization and Operation
AUE-SWP-000001 Electrical Safe Work Practices Manual
Class 1E Electrical Source Verification
OTA-RK-00016,
Add 18A
NB01 Bus Lockout
OTA-RK-00016,
Addendum 18B
NB01 Bus Undervoltage
OTN-NB-0001A,
Addendum 5
NB01 Loss of Power Recovery
OTO-NB-00001
Loss of Power to NB01
Condition Reports
201701792
201703756
201704460
201801310
201801801
201802663
Inspection Procedure 71111.04: Equipment Alignment
Procedures
Number
Title
Revision
Auxiliary Feedwater Flow Paths Valve Alignment
Safety Injection Train B Inservice Test
OTN-EF-00001
Essential Service Water System
OTN-EM-00001
Safety Injection System
OTN-NE-0001A
Standby Diesel Generation System - Train A
OTN-NE-0001B
Standby Diesel Generation System - Train B
Drawings
Number
Title
Revision
M-22EM01
High Pressure Coolant Injection Sheet 2
M-22EM02
High Pressure Coolant Injection Sheet 3
Condition Reports
201304555
201304556
201701643
201702416
201703110
201704176
201704872
201706589
201706812
201800063
201800516
201800747
201801015
201802184
201802218
201802593
201802598
Jobs
16512414
16512503
17500445
17002539
Miscellaneous
Number
Title
Revision
RFR 15822
Evaluation of Safety Injection Test Line Valves Effects on
System
A
Inspection Procedure 71111.05AQ: Fire Protection Annual/Quarterly
Condition Reports
201801761
201801925
201801983
201802068
201802161
201802699
201802736
Miscellaneous
Number
Title
Revision
Callaway Plant NFPA 805 Transition Report
Fire Preplan Manual
Inspection Procedure 71111.11: Licensed Operator Requalification Program and
Licensed Operator Performance
Procedures
Number
Title
Revision
OTS-SF-00001
Control Rod Positioning
Condition Reports
201007073
201509093
201801808
201801994
201802028
Jobs
18504417
Miscellaneous
Number
Title
18-3
Annual exam scenarios and JPMs: Week of May 28, 2018
Inspection Procedure 71111.12: Maintenance Effectiveness
Procedures
Number
Title
Revision
APA-ZZ-00322
Integrated Work Management Process Description
APA-ZZ-00322,
Appendix B
Work Week Schedule and Execution
APA-ZZ-00322,
Appendix F
Online Work Integrated Risk management
APA-ZZ-00750
Hazard Barrier Program
MPM-SK-QW001 Service and Inspection of Plant Doors
Drawings
Number
Title
Revision
8618-X-95564
Interconnection Diagram Yard Startup Posn V42 Volt
XFMR & 345KV Line Posn-V44
Condition Reports
201302050
201504242
201701364
201701738
201801120
201801329
201801394
201801773
201802057
201802749
Jobs
17501498
Miscellaneous
Number
Title
Revision
100073
IM JZ-72.6 Line Coupling Tuner
Inspection Procedure 71111.13: Maintenance Risk Assessment and Emergent Work
Control
Procedures
Number
Title
Revision
APA-ZZ-00322
Integrated Work Management Process Description
Procedures
Number
Title
Revision
APA-ZZ-00322,
Appendix F
Online Work Integrated Risk Management
APA-ZZ-00801
ETP-CH-ST001
EHC System Flush
OTN-CH-00001
Main Turbine Control Oil System
Drawings
Number
Title
Revision
M-22CH01
Main Turbine Hydraulic Control System Sheet 11
Condition Reports
201605024
201801712
201801754
201802018
201802052
201802080
201802284
Jobs
15509648
15509653
Inspection Procedure 71111.15: Operability Determinations and Functionality
Assessments
Procedures
Number
Title
Revision
APA-ZZ-00500
Operability and Functionality Determinations
BD-ES-0.2
Natural Circulation Cooldown
6, 7
DIESLE-EMER-0022
KJ Engine Fuel Rack Adjustment
Natural Circulation Cooldown
Natural Circulation Cooldown
MSM-KJ-QK001
Emergency Diesel Generator Inspection
MTM-KJ-QK001
Emergency Diesel Engine Disassembly, Inspection,
and Reassembly
MTT-ZZ-00264
Removal and Replacement of ITT General Controls
Hydramotor Actuators
ODP-ZZ-00001
Operator Burdens and Workarounds
ODP-ZZ-00027
Safety Function Determination Program
Procedures
Number
Title
Revision
Nitrogen Accumulator Inservice Leak Rate Test
OTN-GK-00001
Control Building HVAC System
OTO-GK-00001
Loss of Control Room HVAC
Drawings
Number
Title
Revision
E-23KJ07
Diesel Generator KKJ01B Governor Control
M-622.1-00023
Condensing Unit
Condition Reports
200706594
200900842
200903033
201007822
201408077
201704701
201801302
201801822
201802284
201802296
201802938
Jobs
15004983
18001143
Miscellaneous
Number
Title
Revision
BB-175
Reactor Coolant System Cooldown Rate EOP Action
Value 4
BB-175,
Addendum 1
Maximum Cooldown Rate During a Natural Circulation
Cooldown to Address Flow Stagnation Issues
KA-37
Backup Nitrogen Supply System Design Pressure Losses
M-018-00309
IM Emergency Diesel Generator System
138
M-622.1-00061,
Table 001
Vendor manual: SGK04/SGK05
ZZ-179
Plant AC Bus Load List
98-1031
Modification: Controllers for SGK05A and B
A
Inspection Procedure 71111.19: Post Maintenance Testing
Procedures
Number
Title
Revision
OTN-GK-00001
Control Building HVAC System
Condition Reports
201706582
201800921
201802463
201802854
201802895
201802071
201802090
201802093
201802114
201802123
Jobs
11506485
2500205
16510841
16511475
11513141
2002430
14508639
Miscellaneous
Number
Title
Revision
GK-19
Calculation of DC and Engineered Safety Features
Switchgear Room Heatup
0C
ULDBD-GK-001
Control Building HVAC System
Inspection Procedure 71111.22: Surveillance Testing
Procedures
Number
Title
Revision
ODP-ZZ-00029
RCS Leakage Action Level Guideline
RCS Inventory Balance
Standby Diesel Generator A Periodic Tests
OTO-BB-00003
RCS Excessive Leakage
RRA-ZZ-00001
NRC Performance Indicator Program
Condition Reports
201503444
201707272
71114.02: Alert and Notification System Testing
Condition Reports
201700320
201700758
201702367
201703790
201704390
201707404
201707681
201800242
201800372
201800854
Procedures
Number
Title
Revision
KSP-ZZ-00008
KSP-ZZ-00110
Siren Alerting System Testing
Miscellaneous
Number
Title
Date
Annual Siren Maintenance Records for 2016
Annual Siren Maintenance Records for 2017
Callaway Plant Alert and Notification System
Design Report
January 2017
2017 Tone Alert Radio Provider Audit
March 30, 2017
2017 Annual Tone Alert Radio Battery
Distribution
March 28, 2017
Monthly Distribution of Tone Alert Radios
February 27, 2017
2018 Tone Alert Radio Provider Audit
February 12, 2018
Monthly Distribution of Tone Alert Radios
January 26, 2018
71114.03: Emergency Response Organization Staffing and Augmentation System
Condition Reports
201609198
201700307
201700316
201703154
201704382
Miscellaneous
Number
Title
Revision/Date
EIP-ZZ-00200
Augmentation of the Emergency Response
Organization
KSP-ZZ-00201
Emergency Augmentation Drill, Test
ERO Augmentation Test for May 24, 2016
May 25, 2016
ERO Augmentation Test for September 8,
2016
September 8, 2016
ERO Augmentation Test for December 5, 2016 December 6, 2016
ERO Augmentation Test for December 12,
2016
December 13,
2016
ERO Augmentation Test for March 10, 2017
March 13, 2017
ERO Augmentation Test for June 13, 2017
June 15, 2017
ERO Augmentation Test for August 6, 2017
August 7, 2017
ERO Augmentation Test for December 11,
2017
December 12,
2017
ERO Augmentation Test for February 19, 2018 February 20, 2018
71114.04: Emergency Action Level and Emergency Plan Changes
Condition Reports
201802128
Miscellaneous
Number
Title
Date
EPCI 17-01
Calculation: Emergency Action Level Bases
for Fuel Clad and Reactor Coolant System
Barrier Loss, and Containment Barrier Potential
Loss, Revision 1
November 22,
2017
71114.05 - Maintenance of Emergency Preparedness
Condition Reports
201700110
201700307
201700316
201700777
201700937
201701166
201701250
201701281
201701426
201702193
201702223
201702225
201702280
201702286
201702289
201702299
201702327
201702736
201703430
201703570
201703778
201703986
201704138
201704382
201705732
201802054
201802061
201802099
201802095
201802096
201802127
201802128
Work Orders
15505575
16501542
16502178
16506313
16508073
16510372
16510907
16511006
16512796
16513033
16513811
17501138
17503441
17503557
17507733
Miscellaneous
Number
Title
Revision/Date
Callaway Plant Radiological Emergency Response
Plan
Evaluation Report for the Radiation Monitoring Drill
conducted June 16, 2016
Evaluation Report for the Radiological Monitoring
Drill conducted September 1, 2016
Evaluation Report for the Health Physics Drill
conducted September 8, 2016
Evaluation Report for the Contaminated Victim Drill
conducted November 8, 2016
Evaluation Report for the Health Physics Drill
conducted March 7, 2017
Evaluation Report for Exercises conducted First
Quarter 2017 (January 19, January 26, February 2,
February 9, February 16, February 23)
March 28, 2017
Evaluation Report for the Exercise conducted
March 7, 2017
May 10, 2017
Evaluation Report for the Exercise conducted
April 25, 2017
June 30, 2017
Evaluation Report for the Exercise conducted
June 29, 2017
August 23, 2017
Evaluation Report for the Health Physics Drill
conducted August 2, 2017
Evaluation Report for the Contaminated Victim Drill
conducted August 31, 2017
Evaluation Report for Exercises conducted
Third Quarter 2017 (July 20, July 27, August 3,
August 10, August 17, and August 24)
October 5, 2017
Evaluation Report for Exercises conducted
First Quarter 2018 (January 18, January 25,
February 1, February 8, and February 15)
April 10, 2018
A210.0012
Operating Quality Assurance Manual
2A
ADCN 2-201702736
(AUCA2017002)
Performance Deficiencies with Emergency
Classifications and Notifications
July 2017
CR201704138
Common Cause Evaluation
CR201700937
Common Cause Analysis of Sentry Failures
September 8, 2017
DTI-040
NOS Performance Assessments
EIP-ZZ-A0020
Maintaining Emergency Preparedness
EIP-ZZ-A0066
RERP Training Program
KDP-ZZ-00013
Emergency Response Facility and Equipment
Evaluation
KDP-ZZ-00013,
Appendix 1
Equipment Important to Emergency Response
Matrix
KDP-ZZ-00400
RERP Impact Evaluations and Changes
KDP-ZZ-02001
Drill and Exercise Program
KSP-ZZ-00004
Emergency Response Facilities
KSP-ZZ-00007
Offsite Effectiveness of the Emergency
Preparedness Program
KSP-ZZ-00102
Monthly Emergency Communications Testing
KSP-ZZ-00103
Quarterly Emergency Communications Testing
KSP-ZZ-00602
Verification of Emergency Instruction Postings
OQC20170006
First Trimester 2017 Nuclear Oversight
Performance Report
June 19, 2017
OQC20170013
Second Trimester 2017 Nuclear Oversight
Performance Report
October 6, 2017
OQC20170017
Third Trimester Nuclear Oversight Performance
Report
January 31, 2018
SBM-201720060-01
Benchmark Trip Report: Palo Verde JIC
Operations
February 8, 2017
SBM-201820044-011
Benchmark Trip Report: Peer Evaluator for the
Diablo Canyon QV Audit
April 4, 2018
SP17004
Emergency Preparedness 12-month Program
Review
October 24, 2017
SSA-201600059-51
Simple Self-Assessment: Pre-NRC Program
Inspection, IPX Exercise
March 13, 2017
SSA-201720039-009
Simple Self-Assessment: Implementation of
ACAD-15-010, Guidelines for the Training and
Qualification of Emergency Response Personnel
2017 Annual ETE Update
April 19, 2017
2018 Annual ETE Update
April 10, 2018
Annual Media Briefing Program
August 9, 2017
2017 Annual Review of EALS with State
August 28, 2017
Monthly Emergency Communications Testing
March 1, 2017
Monthly Emergency Communications Testing
November 3, 2016
Annual Radio Communications Test
October 27, 2017
Monthly Source Checks
December 2, 2017
Monthly Emergency Communications Testing
(BURS Retest)
November 10, 2016
Monthly Process Radiation Monitor Source Checks December 28, 2016
Evaluation Report for the Radiological Monitoring
Drill conducted June 29, 2017
Monthly Emergency Communications Testing
January 4 2017
Emergency Facility Readiness Inspection
April 10, 2017
Callaway County Hospital Inventory/Inspection
July 26, 2017
SGTR Monitor Source Checks
May 1, 2017
Monthly Emergency Communications Testing
June 7, 2017
Saint Marys Hospital Inventory/Inspection
December 27, 2017
Monthly Emergency Communications Testing
October 4, 2017
Monthly Emergency Communications Testing
January 3, 2018
5054Q Assessment
2017010
KSP-ZZ-00008, Revision 8
March 16, 2017
5054Q Assessment
2017016
EIP-ZZ-PR020, Revision 40
May 19, 2017
5054Q Assessment
2017017
KDP-ZZ-00013, Appendix 1, Revision 5
October 3, 2017
5054Q Assessment
2017018
KDP-ZZ-02001, Revision 23
August 8, 2017
5054Q Assessment
2017019
KDP-ZZ-02001, Revision 23
August 8, 2017
5054Q Assessment
2017024
RERP Revision 49
August 23, 2017
5054Q Assessment
2017026
ERO Duty Responders
August 23, 2017
5054Q Assessment
2017027
EIP-ZZ-00101, Addendum 2, Revision 13
November 28, 2017
5054Q Assessment
2017036
EIP-ZZ-00101, Revision 54
September 26, 2017
5054Q Assessment
2017055
EIP-ZZ-00101, Addendum 2, Revision 14
March 19, 2018
5054Q Assessment
2017088
EIP-ZZ-00245, Addendum B, Revision 4
March 23, 2018
5054Q Assessment
2018010
CR-201800454
February 7, 2018
5054Q Assessment
2018013
EIP-ZZ-00101, Addendum 2, Revision 14
March 19, 2018
5054Q Assessment
2018014
EIP-ZZ-00101, Addendum 2, Revision 14
March 19, 2018
5054Q Assessment
2018015
EDP-ZZ-00005, Revision 14
March 21, 2018
Inspection Procedure 71114.06: Drill Evaluation
Procedures
Number
Title
Revision
EIP-ZZ-A0001
Emergency Response Organization
EIP-ZZ-A0066
Radiological Emergency Response Plan Training
EIP-ZZ-00101
Classifications of Emergencies
OTO-MA-00008
Rapid Load Reduction
OTG-ZZ-00004
Power Operations
OTO-ZZ-00012
Severe Weather
Condition Reports
200500736
200711355
201105132
Miscellaneous
Number
Title
Revision
Event Reporting Guidelines 10CFR50.72 and 50.73
71124.02: Occupational ALARA Planning and Controls
Procedures
Number
Title
Revision
APA-ZZ-00014
Conduct of Operations - Radiation Protection
APA-ZZ-00014
Appendix A - Radiation Protection Skill of the Craft
APA-ZZ-01000
Callaway Energy Center Radiation Protection Program
APA-ZZ-01001
Callaway Plant ALARA Program
APA-ZZ-01004
Radiological Work Standards
APA-ZZ-01004
Appendix D - General instruction for Use of DLR
APA-ZZ-01400
Performance Improvement Program Appendix H -
Performance Review Group
HDP-ZZ-01100
ALARA Planning and Review
HDP-ZZ-01200
Radiation Work Permits
Audits and Self-Assessments
Number
Title
Date
Radiation Protection Performance Review Group
Meeting
February 28, 2018
Callaway Energy Center Refuel 22 Dose and Source
Term Comparison Report
January 10, 2018
SP17006
Nuclear Oversight Performance Assessment of
RF22
February 14, 2018
Condition Reports
201705692
201705803
201706722
201801083
201802051
201800459
Radiation Work Permits
Number
Title
Revision
18502032
Change SFP Clean-Up Filter 2018
17507741
Change SFP Clean-Up Filter 2017
16511578750
RF22 Scaffold All
R22RPCOVRB
Refuel 22 Radiation Protection Job Coverage
R22HDLIPREP
Refuel 22 Support Lower Core Barrel Movements
13004049
Replace Valve Packing in BGHV8160
13004049EM
Emergent Work to Replace Solenoid and Testing
R221124AOV
AOV Re-Work and Tests
R22AMHDLIFT
Ameren Personnel Head Lift
R22AMHDSET
Ameren Personnel Head Set
R22HDLIFT
Perform Reactor Vessel Head Lift
R22AMHDPREP
Ameren Personnel UI and Head Lift/Set Preps
ALARA Planning, In-Progress Reviews, and Post-Job Reviews
Number
Title
Date
R22-50101
Radiation Protection Routine Activities Reactor
Building
March 1, 2018
R22-56321
Remove/Reinstall Reactor Vessel Lower Internals
March 12, 2018
R22-55320
Reactor Building Head Lift
March 12, 2018
R22 CRANEVLV
WORK
Crane Valve Work
March 12, 2018
R22-55220
Ameren Work in Cavity
March 12, 2018
Miscellaneous
Callaway Energy Center Long Range Dose and Source Term Reduction Plan
Callaway Energy Center Long Range Dose and Source Term Reduction Plan Completed
Initiatives
71124.04 - Occupational Dose Assessment
Procedures
Number
Title
Revision
APA-ZZ-00014
Conduct of Operations - Radiation Protection
APA-ZZ-01000
Callaway Energy Center Radiation Protection
Program
APA-ZZ-01001
Callaway Plant ALARA Program
HDMZZ-01300
Callaway Internal Dose Assessment Guidelines
HDP-ZZ-01300
Internal Dosimetry Program
HDP-ZZ-04700
Count Room and Whole Body Counter Quality
Control Program
HDP-ZZ-08000
Respiratory Protection Program
HTP-ZZ-01302-DTI-
Response to Positive In Vivo Count for Declared
Pregnant Woman
HTP-ZZ-01433
Personnel Exposure Records
HTP-ZZ-04175-DTI-
PM12-OP
Thermo Scientific Model PM-12 Personal Monitor
Operation
HTP-ZZ-04564
APEX Suite Operations
RP-DTI-In Vitro
Bioassay
In-Vitro Bioassay Sample Collection
RP-DTI-TRU
Assessment
Alpha Monitoring Facility Characterization
Audit and Self-Assessments
Number
Title
Date
SP17006
Nuclear Oversight Performance Assessment of
Refuel 22 Execution
February 14, 2018
AP17001
Nuclear Oversight Audit of Radiation Protection
February 28, 2017
SR-2016-30
Exelon Supplier Audit: Landauer, Inc.
August 26, 2016
Condition Reports
201700049
201700086
201700188
201700455
201700459
201700831
201700894
201702031
201702125
201702131
201702338
201702649
201702839
20173330
201703773
201703856
201707727
201800454
201800852
201801083
201801132
Calibration Records
Number
Title
Date
FS-5301-HP
Canberra FastScan WBC System (at CPF)
September 21,
2016
FS-5300-HP
Canberra FastScan WBC system (at Annex
Building)
September 22,
2016
PM-4053-HP
ThermoFisher PM-12
July 5, 2017
PM-4046-HP
ThermoFisher PM-12
September 2, 2017
WBC-6000-HP
Canberra In Vivo Chair Counter
July 14, 2017
FS-5300-HP
Canberra FastScan WBC System Confirmation
Count
March 12, 2018
PM-4047-HP
ThermoFisher PM-12
April 11, 2018
Radiological Surveys
Number
Title
Date
CA-M-20180319-5
NS-1 Neutron Source - Quarterly Routine
March 19, 2018
CA-M-20180507-12 1311 SJ Room Monthly Routine Survey
May 7, 2018
Miscellaneous
Number
Title
Date
NVLAP Certificate of Accreditation: Landauer, Inc.
January 1, 2018
DAW CYC 21
WMG Nuclide Distribution Report
November 13,
2017
HPCI 0202-02
Callaway Electronic Dosimeter Calibration
Adjustment Factor
April 18, 2016
H230.0078
Personnel Dosimetry Data: SMD/TLD Results
January 1 - December 31, 2017
January 3, 2018
H230.0078
Personnel Dosimetry Data: SMD/TLD Results
January 22 - March 5, 2018
March 14, 2018
Inspection Procedure 71151: Performance Indicator Verification
Procedures
Number
Title
Revision
EIP-ZZ-00101
Classification of Emergencies
EIP-ZZ-00201
Notifications
EIP-ZZ-00212
Protective Action Recommendations
KDP-ZZ-02000
NRC Performance Indicator Data Collection
KSP-ZZ-00110
Siren Alerting System Testing
Condition Reports
201700346
201702225
201702367
201702891
201703430
201703986
201704380
201707404
201707681
201800242
201800372
Miscellaneous
Number
Title
Date
NRC Performance Indicator Transmittal Reports, Mitigating
Systems Cornerstone
2017-2018
NRC Performance Indicator Transmittal Reports, Barrier
Integrity Cornerstone
2017-2018
Inspection Procedure 71153: Follow-up of Events and Notices of Enforcement Discretion
Procedures
Number
Title
Revision
Date
APA-ZZ-00099
Appendix 2
Plant Status Control Investigations
OTG-ZZ-00001
Plant Heatup Cold Shutdown to Hot Standby
OTG-ZZ-00001
Plant Heatup Cold Shutdown to Hot Standby
OTG-ZZ-00006
Plant Cooldown Hot Standby to Cold Shutdown
Containment Isolation Verification
ODP-ZZ-00014
Operational Mode Change Requirements
ODP-ZZ-00036
Technical Specification Application for Containment Isolation
Valves
Containment Closure
Drawings
Number
Title
Revision
M-22KA02
Piping and Instrumentation Diagram Compressed Air
System (Service Air)
Condition Reports
201800194
201802608
201408376
201800202
Jobs
18000323
Miscellaneous
Number
Title
Revision
AUCA 2018-0001
Root Cause Analysis for CAR 201800194 KAV0118 Found
Open
Initial Request for Information
Quarterly Baseline Inspection
Callaway Plant
Inspection Report: 05000483/2018002
Inspection Dates: April 1 - June 30, 2018
Inspection Procedure: IP 71111 series, IP 71151, IP 71152
Lead Inspector: Dan Bradley, Senior Resident Inspector
Information Requested For 2nd Quarter 2018
The following information should be sent to the resident office in electronic format (Certrec IMS
preferred) to the attention of Dan Bradley by April 13, 2018. Please provide requested
documentation electronically in pdf files, Excel, or other searchable formats, if possible. The
information should contain descriptive names and be indexed or hyperlinked to facilitate ease of
use. If requested documents are large and/or only hard copy formats are available, please
inform the inspector for clarification.
Please provide the following information for the Auxiliary Feedwater (AL) system:
1.
A list of all calculations and drawings associated with the selected system.
2.
A list of condition reports associated with the selected system for the last 3 years.
3.
A list of work orders associated with the selected system for the last 3 years, including
all open work orders.
4.
A list of any pre-existing evaluations or calculations with low design margins for the
selected system.
5.
A list of maintenance rule components and functions; based on engineering or expert
panel judgment, for the selected system.
6.
A list of maintenance rule functional failure evaluations for the last 3 years for the
selected system.
7.
A list of operating experience evaluations for the last 3 years for the selected system.
8.
A list of all procedures and calculations that involve time-critical operator actions.
9.
A list of permanent and temporary modifications performed in the past 3 years for the
selected system. Include a list of any documents associated with modifications such as:
calculations, specifications, vendor manuals, Final Safety Analysis Report, Technical
Specifications and Bases updates, updated procedures, and maintenance and
surveillance activities and procedures.
10. A list of root cause and apparent cause evaluations associated with component failures
or design issues initiated/completed in the last 3 years for the selected system.
11. A list of any common-cause failures of components in the last 3 years for the selected
system.
2. An electronic copy of the design bases documents for the selected system.
13. An electronic copy of the system health notebooks for the selected system.
Additionally, please provide the basis documents used to compute or establish the following
NRC Performance Indicators (PIs) for the most recent 4 quarters which data is available:
a) MS-05: Safety System Functional Failures (SSFF)
b) MS-08: MSPI Heat Removal Systems
c) BI-02: Reactor Coolant System Leak Rate Sample
Inspector Contact Information:
Senior Resident Inspector
573-676-3181
Dan.Bradley@nrc.gov
Mailing Address:
U.S. NRC Resident Inspector Office
201 NRC Road
Steedman, MO 65077
The following items are requested for the
Occupational Radiation Safety Inspection
at Callaway
(May 21 - 25, 2018)
Integrated Report 2018002
Inspection areas are listed in the attachments below.
Please provide the requested information on or before
April 30, 2018.
Please submit this information using the same lettering system as below. For example, all
contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled
1-A, applicable organization charts in file/folder 1-B, etc.
If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at
least 30 days later than the onsite inspection dates, so the inspectors will have access to the
information while writing the report.
In addition to the corrective action document lists provided for each inspection procedure listed
below, please provide updated lists of corrective action documents at the entrance meeting.
The dates for these lists should range from the end dates of the original lists to the day of the
entrance meeting.
If more than one inspection procedure is to be conducted and the information requests appear
to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which
file the information can be found.
If you have any questions or comments, please contact Natasha Greene at (817) 200-1154 or
natasha.greene@nrc.gov. The other inspector is undetermined at this time.
PAPERWORK REDUCTION ACT STATEMENT
This letter does not contain new or amended information collection requirements subject
to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information
collection requirements were approved by the Office of Management and Budget,
control number 3150-0011.
2.
Occupational ALARA Planning and Controls (71124.02)
Date of Last Inspection:
October 16, 2017
A.
List of contacts and telephone numbers for ALARA program personnel
B.
Applicable organization charts
C.
Copies of audits, self-assessments, and LERs, written since date of last inspection,
focusing on ALARA
D.
Procedure index for ALARA Program
E.
Please provide specific procedures related to the following areas noted below.
Additional Specific Procedures may be requested by number after the inspector reviews
the procedure indexes.
1. ALARA Program
2. ALARA Committee
3. Radiation Work Permit Preparation
F.
A summary list of corrective action documents (including corporate and sub-tiered
systems) written since date of last inspection, related to the ALARA program. In addition
to ALARA, the summary should also address Radiation Work Permit violations,
Electronic Dosimeter Alarms, and RWP Dose Estimates
NOTE: The lists should indicate the significance level of each issue and the search
criteria used. Please provide in document formats which are searchable so that
the inspector can perform word searches.
G.
List of work activities greater than 1 rem, since date of last inspection,
Include original dose estimate and actual dose.
H.
Site dose totals and 3-year rolling averages for the past 3 years (based on dose of
record)
I.
Outline of source term reduction strategy
J.
If available, provide a copy of the ALARA outage report for the most recently completed
outages for each unit
K.
Please provide your most recent Annual ALARA Report.
4. Occupational Dose Assessment (Inspection Procedure 71124.04)
Date of Last Inspection:
November 7, 2016
A.
List of contacts and telephone numbers for the following areas:
1. Dose Assessment personnel
B.
Applicable organization charts
C.
Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs
written since date of last inspection, related to:
1. Occupational Dose Assessment
D.
Procedure indexes for the following areas:
1. Occupational Dose Assessment
E.
Please provide specific procedures related to the following areas noted below.
Additional Specific Procedures will be requested by number after the inspector reviews
the procedure indexes.
1. Radiation Protection Program
2. Radiation Protection Conduct of Operations
3. Personnel Dosimetry Program
4. Radiological Posting and Warning Devices
5. Air Sample Analysis
6. Performance of High Exposure Work
7. Declared Pregnant Worker
8. Bioassay Program
F.
List of corrective action documents (including corporate and sub-tiered systems) written
since date of last inspection, associated with:
1. National Voluntary Laboratory Accreditation Program (NVLAP)
2. Dosimetry (TLD/OSL, etc.) problems
3. Electronic alarming dosimeters
4. Bioassays or internally deposited radionuclides or internal dose
5. Neutron dose
NOTE: The lists should indicate the significance level of each issue and the search
criteria used. Please provide in document formats which are searchable so that
the inspector can perform word searches.
G.
List of positive whole body counts since date of last inspection, names redacted if
desired
H.
Part 61 analyses/scaling factors
I.
The most recent National Voluntary Laboratory Accreditation Program (NVLAP)
accreditation report or, if dosimetry is provided by a vendor, the vendors most recent
results
SUNSI Review:
ADAMS:
Non-Publicly Available
Non-Sensitive
Keyword:
By: NTaylor
Yes No
Publicly Available
Sensitive
OFFICE
SRI/DRP/B
RI/DRP/B
C:DRS/EB1
C:DRS/EB2
C:DRS/OP
C:DRS/PSB2
NAME
DBradley
SJanicki
TFarnholtz
JDrake
VGaddy
HGepford
SIGNATURE
DSB
SMJ
TRF
jfd
vgg
hjg
DATE
8/6/18
8/5/18
07/27/2018
7/26/18
7/26718
07/26/18
OFFICE
TL:DRS/IPAT
C:DRP/B
NAME
GGeorge
NTaylor
SIGNATURE
HAF for
NHT
DATE
07/31/18
8/8/18