IR 05000483/2017007

Reply to Notice of Violation 05000483/2017007-01

ML17306A103
Person / Time
Site:	Callaway
Issue date:	11/01/2017
From:	Herrmann T E Ameren Missouri, Union Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
IR 2017007, ULNRC-06394
Preceding documents:	ML17341B170 (7 December 2017)
Download: ML17306A103 (5)

Text

W Ameren MISSOURI November 1, 2017 ULNRC-06394 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Ladies and Gentlemen:

10 CFR 2.201 DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO. RENEWED FACILITY OPERATING LICENSE NPF-30 REPLY TO NOTICE OF VIOLATION 05000483/2017007-01 Callaway Plant This letter provides Ameren Missouri's response to the Notice of Violation identified for the Callaway Plant in NRC's letter dated October 6, 2017, "Callaway Plant -NRC Design Bases Assurance Inspection Report 05000483/2017007 and Notice of Violation," from Thomas R. Famholtz to Fadi Diya. The response to the violation is presented in the attachment to this letter. None of the material in the response is considered proprietar This letter does not contain new commitment Please contact me for any questions you may have or for any additional infonnation you may require in regard to this respons Attachment 1: Response to Violation

................... ****** .............................

..................... . ..........................

..........................

.... .. **************

......................................

........................ . ********************

..... ***********-*****************

• • • • • • • • • • • • • • • • • • • • • • • • • • • • -*******************

• .......................................... . *************

......................

• • • • • • ********************************************

Sincerely,-, J J ~-£ Ir ,____ __ P.O. Box 620 T. E. Hemnann Site Vice President Fulton, MO 65251 AmerenMissouri.com ULNRC-06394 November 1, 2017 Page 2 of3 cc: Mr. Kriss M. Kennedy Regional Administrator U.S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 820 I NRC Road Steedman, MO 65077 Mr. L. John Klos Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 08H4 Washington, DC 20555-0001

...........................................................................

.; ... ................................................................................................................................................ . *********************************************************************************************************-**************************-*****************-*************************************************************************

................................................................................................................................................................................................................................

................................................................................................................................................................................................................................

................................................................................................................................................................................................................................

ULNRC-06394 November I, 2017 Page 3 of3 Index and send hardcopy to QA file(s): Al60.0761 Al 70.0103 Hardcopy:

Certrec Corporation 6100 Western Place, Suite I 050 Fort Worth, TX 76107 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.) Electronic distribution for the following can be made via NOV ULNRC Distribution:

F. M. Diya T. E. Hemnann B. L. Cox S. P. Banker R. C. Wink T. B. Elwood Corporate Communications NSRB Secretary RRA Department File STARS Regulatory Affairs Mr. Jay Silberg (Pillsbury Winthrop Shaw Pittman LLP) Missouri Public Service Commission

..................................................................................................................................................................................................................................

................................................................................................................................................................................................................................

Attachment to ULNRC-06394 November 1, 2017 Page 1 of 2 Statement of Violation Response to Violation During the Design Bases Assurance inspection conducted by the NRC at the Callaway Plant from July 17 through August 28, 2017, three violations of NRC requirements were identifie One of the violations was documented in the Notice of Violation provided as Enclosure 1 to the NRC's letter "Callaway Plant -NRC Design Bases Assurance Inspection Report 05000483/2017007 and Notice of Violation," dated October 6, 2017. The violation was identified as follows: 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, February 1978. Regulatory Guide 1.33, Appendix A, Section 9, "Procedures for Performing Maintenance," requires, in part, that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with documented instructions appropriate to the circumstance Contrary to the above, from May 2014 through August 4, 2017, the licensee failed to ensure that maintenance that can affect the performance of safety-related equipment be properly planned and performed in accordance with documented instructions appropriate to the circumstance Specifically, as a result of ineffective corrective action of Callaway Action Requests CAR-201402827 and CAR-201405312, the licensee failed to perform preventative maintenance procedures to verify the operation and timing of the engineered safety feature transformer XNBOl load tap changer. This violation is associated with a Green Significance Determination Process finding. Reason for the Violation The violation described in the Notice of Violation stems from the failure to adequately address a previous non-cited violation (NCV) that was identified for Callaway during the 2014 Component Design Basis Inspection

{CDBI) at the facility, for failure to establish adequate preventative maintenance (PM) procedures for testing of the load tap changers (LTCs) on engineered safety feature (ESF) transformers XNBOl and XNB02. Mainly, it was noted that the PM procedures did not ensure or include instructions for the performance of timing testing of the LTCs. At the time when the NCV was identified in 2014, PMs for the ESF transformers and their LTCs were already being performed at 6-year intervals (i.e., every fourth refueling outage). The PM for XNBOl, in particular, was last completed in 2013 (during Refuel 19). These PMs, however, lacked timing testing of the load tap changers, as noted in the 2014 NCV, and following identification of the non-cited violation in 2014, the PMs for XNBOl and XNB02 were promptly revised. Additionally, timing testing of the XNB02 LTC was successfully completed on November 6, 2014, during Refuel 20. Timing testing for the XNBOl LTC was scheduled to be performed in April 2016 during Refuel 21. During the refueling outage scoping process, however, the PM job for performing the timing test was Attachment to ULNRC-06394 November 1, 2017 Page 2 of 2 rescheduled to Refuel 23 (2019). This was likely done without knowledge or understanding of the NCV timing testing issue for XNBOl and with the thought that the XNBOl PM was on track with respect to its 6-year interva The untimely scheduling of the timing testing was identified during a self-assessment and was entered into the Callaway corrective action program in November 2015. The XNBOl LTC timing testing was then rescheduled for Refuel 22. Conducting the test in Refuel 21 (Spring 2016) was not considered prudent because there were no plans to de-energize XNBOl during that outage and adding it to the schedule 120 days prior to the outage was judged to present unreasonable risk. Based on the extended timeframe for completing the LTC timing testing for XNBOl, as described above, management did not effectively leverage the work management process to ensure that performance of the required timing testing was appropriately scheduled and completed in order to restore compliance with requirements in a timely manner, in light of the 2014 NCV. Corrective Steps Taken and Results Achieved:

The timing of the XNBOl load tap changer was successfully tested on October 20, 2017. Timing testing of the XNBOl and XNB02 LTCs will continue to be performed on a routine basis, going forward. Corrective Steps That Will Be Taken: The Callaway work management procedure will be revised to establish schedule dates for jobs associated with addressing NRC violation Rescheduling jobs beyond the scheduled date will require justification as well as approval by management. The station will review any NRC violations received since October 2015 for jobs that we are crediting for restoring complianc The basis for selecting October 2015 is that this is the last time a comprehensive pre-Problem Identification and Resolution (Pl&R) inspection self-assessment was performe In that assessment, the timeliness of corrective actions for NRC violations prior to October 2015 was evaluate Lessons learned in connection with this Notice of Violation will be communicated by station leadership. This will include expectations on identifying and adhering to the scheduled date for jobs addressing violations, as mentioned above. Both actions will be complete by February 28, 2018. Date when Full Compliance will be Achieved:

The load tap changer for ESF transformer XNBOl was successfully tested on October 20, 2017, thus resolving the technical issue associated with the violation for not previously verifying the operation and timing of the load tap changer.