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NRC Integrated Inspection Report 05000483/2018001
	ML18123A395
Person / Time
Site:	Callaway
Issue date:	05/03/2018
From:	Nick Taylor; NRC/RGN-IV/DRP/RPB-B
To:	Diya F; Ameren Missouri
	Taylor N
References
	IR 2018001
	Download: ML18123A395 (30)
	v • d • e

SUBJECT:

CALLAWAY PLANT - NRC INTEGRATED INSPECTION REPORT 05000483/2018001

Dear Mr. Diya:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Callaway Plant. On April 4, 2018, the NRC inspectors discussed the results of this inspection with Mr. Tim Herrmann, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violation or significance of this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the Callaway Plant.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Callaway Plant. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 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 05000483/2018001 w/Attachment 1: Supplemental Information Attachment 2: Request for Information

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number: 05000483 License Number: NPF-30 Report Number: 05000483/2018001 Enterprise Identifier: I-2018-001-0006 Licensee: Union Electric Company Facility: Callaway Plant Location: 8315 County Road 459 Steedman, MO 65077 Inspection Dates: January 1, 2018, to March 31, 2018 Inspectors: D. Bradley, Senior Resident Inspector S. Janicki, Resident Inspector S. Alferink, Reactor Inspector D. Dodson, Senior Resident Inspector R. Kopriva, Senior Reactor Inspector S. Makor, Reactor Inspector J. Melfi, Project Engineer Approved By: N. Taylor Chief, Project Branch B Division of Reactor Projects Enclosure

SUMMARY

The NRC continued monitoring 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. NRC-identified and self-revealed findings, violations, and additional items are summarized in the tables below. A NRC-identified non-cited violation is documented in report section 71111.11.

List of Findings and Violations Failure to Maintain Emergency Operating Procedures Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Green [H.3] - Human 71111.11 Systems NCV 05000483/2018001-01 Performance, Licensed Closed Change Operator Management Performance The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a,

"Procedures," for the licensee's failure to maintain emergency operating procedures for aligning auxiliary feedwater suction sources. Specifically, the licensee added continuous action steps to emergency operating procedures that placed both motor-driven auxiliary feedwater pumps in pull-to-lock and isolated their associated recirculation lines after depleting the two non-safety-related suction sources. These actions cause two of the three safety-related auxiliary feedwater pumps to be rendered inoperable prior to aligning the safety-related suction source of essential service water which is credited in accident analysis.

Additional Tracking Items Type Issue number Title Report Status Section URI 05000483/2016001-01 Possible Incorrect Screening 71111.05AQ Closed of the Spent Fuel Pool Decay Heat Removal Key Safety Function LER 05000483/2013-009-00 Appendix R Unanalyzed 71153 Closed Condition - Direct Current Ammeter Circuits Without Overcurrent Protection LER 05000483/2014-004-00 Postulated Hot Short Fire 71153 Closed Event that Could Adversely Impact Shutdown Equipment LER 05000483/2017-001-00 Violation of Technical 71153 Closed 05000483/2017-001-01 Specification 3.7.9 Due to Ultimate Heat Sink Cooling Tower Train Inoperability

LER 05000483/2017-002-01 Inadequate Protection from 71153 Closed Tornado Missiles Identified due to Nonconforming Design LER 05000483/2017-003-00 Violation of Technical 71153 Closed Specification 3.6.3,

Containment Isolation Check Valve Found in Open Position NOV 05000483/2017007-01 Not Verifying the Operation 92702 Closed and Timing of the Engineered Safety Feature Transformer XNB01 Load Tap Changer

PLANT STATUS

Callaway Plant began the inspection period at full power. On March 14, 2018, the licensee reduced power to 45 percent to replace a reactor coolant system flow transmitter, commenced ascending in power upon completion of testing, and returned to full power on the same day.

The licensee 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 website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.

Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 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

71111.01 - Adverse Weather Protection

Impending Severe Weather

Main article: IP 71111.01

The inspectors evaluated readiness for impending adverse weather conditions for:

(1) Severe winter weather on January 11, 2018

71111.04 - Equipment Alignment

Partial Walkdown

Main article: IP 71111.04

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Component cooling water train B on January 10, 2018

(2) Control room filtration unit FGK02B on January 25, 2018

(3) Battery charger NK26 on February 7, 2018

Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of:

(1) Instrument AC power (NN) system on January 18, 2018

71111.05AQ - Fire Protection Annual/Quarterly

Quarterly Inspection

Main article: IP 71111.05AQ

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Control building 2016 elevation, fire area C-15 on January 12, 2018

(2) Auxiliary feedwater pipe chase 1988 elevation, fire area A-1 on February 16, 2018

(3) Control room air conditioning and filtration units, fire areas A-21 and A-22 on March 6, 2018

(4) Electrical penetration rooms, fire areas A-17 and A-18 on March 11, 2018

(5) Intake structure, fire area IS-1 on March 28, 2018

71111.06 - Flood Protection Measures

Internal Flooding

Main article: IP 71111.06

The inspectors evaluated internal flooding mitigation protection:

(1) Control building 2016 elevation on January 9, 2018

71111.07 - Heat Sink Performance

Heat Sink

Main article: IP 71111.07

The inspectors evaluated:

(1) Emergency diesel generator jacket water heat exchanger train A on March 22, 2018

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification

Main article: IP 71111.11

The inspectors observed and evaluated simulator training for operating crews:

(1) Electrical faults on February 6, 2018

Operator Performance (1 Sample)

The inspectors observed and evaluated:

(1) Surveillance testing for the auxiliary feedwater system on February 20, 2018

(2) Surveillance testing for the emergency diesel generator train B and reactor coolant flow transmitter troubleshooting on March 7, 2018

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness

Main article: IP 71111.12

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) 125 VDC system (NK) on January 17, 2018

(2) Instrument AC power system (NN) on February 14, 2018

71111.13 - Maintenance Risk Assessments and Emergent Work Control

===

Main article: IP 71111.13

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Elevated risk actions due to planned centrifugal charging pump B and component cooling water equipment outage on January 30, 2018

(2) Elevated risk actions due to planned switchyard maintenance on February 5, 2018

(3) Elevated risk actions due to planned safety injection train A equipment outage on February 13, 2018

(4) Emergent risk actions due to auxiliary feedwater pump door failure on February 20, 2018

(5) Elevated risk actions due to planned turbine-driven auxiliary feedwater pump equipment outage on February 27, 2018

71111.15 - Operability Determinations and Functionality Assessments

Main article: IP 71111.15

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Rising level trend in safety injection accumulators on January 8, 2018

(2) Reactor building service air header supply containment isolation valve KAV0118 out of position on January 15, 2018

(3) Battery charger NK25 equalize potentiometer failure on January 16, 2018

(4) Spent fuel pool calculation assumptions on February 13, 2018

(5) Turbine-driven auxiliary feedwater pump room door DSK13311 failure on March 2, 2018

71111.18 - Plant Modifications

Main article: IP 71111.18

The inspectors evaluated the following permanent modification:

(1) MP 12-0020 electrical tie-ins for FLEX on March 29, 2018

71111.19 - Post Maintenance Testing

Main article: IP 71111.19

The inspectors evaluated the following post maintenance tests:

(1) Control room air conditioning unit SGK04B equipment outage on January 10, 2018

(2) Class 1E battery charger NK25 equipment outage on January 22, 2018

(3) Class 1E battery charger NK21 equipment outage on January 29, 2018

(4) Turbine-driven auxiliary feedwater pump equipment outage on February 28, 2018

(5) Emergency diesel generator and essential service water train A equipment outage on March 23, 2018

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine===

Main article: IP 71111.13

(1) OSP-NE-0001A, standby diesel generator A periodic tests on January 24, 2018

In-service (2 Samples)

(1) OSP-BG-P005A, centrifugal charging pump A inservice test - Group B on February 15, 2018

(2) OSP-EG-P01BD, component cooling water train B pump and valve inservice test -

group A on March 29, 2018

Containment Isolation Valve (1 Sample)

(1) OSP-KC-LL067, containment isolation valve leak rate test and results of check valve internal inspection under Condition Report 201706233 on March 15, 2018

71114.06Drill Evaluation Emergency Planning Drill

Main article: IP 71114.06

The inspectors evaluated the radiological emergency response plan drill:

(1) Team 4 on March 8, 2018

Drill/Training Evolution (1 Sample)

The inspectors evaluated annual emergency response organization training evolution:

(1) Team 4 on February 1,

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

Main article: IP 71151

The inspectors verified licensee performance indicators submittals listed below:

(1) MS06: Emergency AC Power Systems (01/01/2017-12/31/2017)

(2) MS10: Cooling Water Support Systems (01/01/2017-12/31/2017)

(3) BI01: Reactor Coolant System (RCS) Specific Activity Sample (01/01/2017-12/31/2017)

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues

Main article: IP 71152

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Safety injection pump oil leak, Condition Report 201704706

(2) Ultimate heat sink cooling tower shroud bolting, Condition Report 201010236

71153 - Follow-up of Events and Notices of Enforcement Discretion Licensee Event Reports

Main article: IP 71153

The inspectors evaluated the following licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) Licensee Event Report 05000483/2013-009-00, Appendix R Unanalyzed Condition -

Direct Current Ammeter Circuits Without Overcurrent Protection, on October 9, 2013

(2) Licensee Event Report 05000483/2014-004-00, Postulated Hot Short Fire Event that Could Adversely Impact Shutdown Equipment, on September 19, 2014

(3) Licensee Event Reports 05000483/2017-001-00 and 05000483/2017-001-01, Violation of Technical Specification 3.7.9 Due to Ultimate Heat Sink (UHS) Cooling Tower Train Inoperability, on June 16, 2017

(4) Licensee Event Report 05000483/2017-002-01, Inadequate Protection from Tornado Missiles Identified due to Nonconforming Design, on August 15, 2017

(5) Licensee Event Report 05000483/2017-003-00, Violation of Technical Specification 3.6.3, Containment Isolation Check Valve Found in Open Position, on October 31, 2017

92702 - Followup on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, Confirmatory Orders, and Alternative Dispute Resolution Confirmatory Orders Notice of Violation

Main article: IP 92702

The inspectors reviewed the licensees response to Notice of Violation 05000483/2017007-01, Not Verifying the Operation and Timing of the Engineered Safety Feature Transformer XNB01 Load Tap Changer, and determined that the reason, corrective actions taken and planned to address recurrence, and the date when full compliance was achieved for this violation is adequately addressed and captured on the docket.

INSPECTION RESULTS

Failure to Maintain Emergency Operating Procedures Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems Green [H.3]Human 71111.11 NCV 05000483/2018001-01 Performance, Change Licensed Closed Management Operator Performance The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a, "Procedures," for the licensee's failure to maintain emergency operating procedures for aligning auxiliary feedwater suction sources. Specifically, the licensee added continuous action steps to emergency operating procedures that placed both motor-driven auxiliary feedwater pumps in pull-to-lock and isolated their associated recirculation lines after depleting the two non-safety-related suction sources. These actions cause two of the three safety related auxiliary feedwater pumps to be rendered inoperable prior to aligning the safety related suction source of essential service water which is credited in accident analysis.

Description:

On March 7, 2018, the inspectors performed an observation of licensed control room operators and reviewed the use of auxiliary feedwater pumps (AFW or AFPs) in Emergency Operating Procedures (EOPs). The AFW system provides a reliable source of water to the steam generators and removes thermal energy from the reactor coolant system through the release of secondary steam to the atmosphere. The AFW pumps are comprised of two motor-driven (MD) pumps and one turbine-driven (TD) pump. Each pump has recirculation lines to provide a constant discharge pathway and prevent pump damage. These AFW pumps can be supplied with the following three suction sources:

(1) Condensate storage tank (CST) - non-safety-related and normally aligned

(2) Hardened CST (HCST) - non-safety-related

(3) Essential service water (ESW) - safety-related In their review of EOPS, the inspectors noted that the following continuous action step was found in several EOPs and titled AFW Supply Switchover Criteria:

If CST to AFP suction header pressure lowers to less than 11.5 PSIG, THEN PERFORM EOP Addendum 42, HCST Alignment.

If CST to AFP suction header pressure lowers to less than 2.75 PSIG, THEN PERFORM EOP Addendum 19, Aligning ESW to AFW Suction.

The inspectors reviewed EOP Addendum 42, HCST Alignment, Revision 1, which states the following and accomplishes it in step 1 of the addendum:

When the HCST is supplying AFW, ONLY the TDAFW will be used, since it can be aligned to recirc back to the HCST. Therefore, the MDAFPs will be placed in Pull-to-Lock prior to isolating MDAFP recirc lines back to the CST.

The inspectors noted that EOP Addendum 19, Aligning ESW to AFW Suction, Revision 3, did not restore the isolated and disabled motor-driven AFW pumps. Instead, EOP Addendum 19 refers only to the ESW valve lineup. As written, the discussed EOP addenda would leave the control room staff with only the turbine-driven AFW pump available.

The inspectors then reviewed accident analysis including section 15.2.8, Feedwater System Pipe Break, of the Final Safety Analysis Report which states:

For the auxiliary feedwater system, the worst case configuration has been used, i.e., only three intact steam generators receive auxiliary feedwater following the break . . . one motor-driven AFW pump to the intact steam generatorthe turbine-driven AFW pump has been assumed to fail . . . the second motor-driven AFW pump is assumed to deliverequally split to the two remaining intact steam generators . . .

The inspectors noted that the accident analysis of Final Safety Analysis Report chapter 15 does not refer to use of the HCST and does not refer to operator action to manually un-isolate motor-driven AFW pumps to reach and maintain safe shutdown.

The inspectors reviewed the extent of condition for the AFW Supply Switchover Criteria continuous action steps and found it in the following EOPs:

(1) E-0, Reactor Trip or Safety Injection, Revision 19

(2) E-1, Loss of Reactor or Secondary Coolant, Revision 19

(3) E-3, Steam Generator Tube Rupture, Revision 22

(4) ES-0.1, Reactor Trip Response, Revision 18

(5) FR-H.1, Response To Loss of Secondary Heat Sink, Revision 18 The inspectors noted the HCST Alignment addendum was created in February 2016 and modified in October 2016 to the current Revision 1. The procedure review process noted the non-safety HCST is a useful water source prior to using the ESW . . . the HCST is maintained at a higher cleanliness. Further, the procedure review noted the HCST:

does not have a recirculation line from the Motor Drive Aux Feed pumps to the HCST . . . EOP Add 42 allows for the alignment of the recirc valves and stops the Motor Drive Aux Feedwater Pumps to prevent possible damage from overheating. Since this overall modification has been evaluated previously, this procedure change does not require further 50.59 review.

The inspectors concluded the licensee failed to maintain EOPs for aligning auxiliary feedwater suction sources. Specifically, the EOPs placed both motor-driven auxiliary feedwater pumps in pull-to-lock and isolated their associated recirculation lines prior to aligning the safety-related suction source of essential service water. This configuration and operator actions are not supported by the accident analysis in the Final Safety Analysis Report.

Further, the licensee did not provide an adequate procedure for restoring the motor-driven AFW pumps from this configuration. Since the continuous action steps are pervasive across EOPs, it is plausible that an operating crew would enact the AFW supply switchover actions prior to fully diagnosing the accident and contrary to the goal of the EOP they were utilizing.

Corrective Actions: The licensee issued a night order clarifying the requirements for auxiliary feedwater in the EOPs and revised EOP Addendum 42, HCST Alignment.

Corrective Action Reference: Condition Reports 201801260 and 201801570.

Performance Assessment:

Performance Deficiency: The failure to maintain Emergency Operating Procedures for aligning auxiliary feedwater suction sources was a performance deficiency.

Screening: This performance deficiency was more than minor, and therefore a finding, because it adversely affected the procedure quality attribute of the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee added continuous action steps to EOPs that placed both motor-driven auxiliary feedwater pumps in pull-to-lock and isolated their associated recirculation lines after depleting the two non-safety-related suction sources. These actions cause two of the three safety related auxiliary feedwater pumps to be rendered inoperable prior to aligning the safety related suction source of essential service water which is credited in accident analysis.

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 2, Mitigating Systems Screening Questions, dated June 19, 2012, the inspectors determined that the finding was of very low safety significance (Green) because

(1) the finding was not a deficiency affecting the design or qualification of a mitigating system;

(2) the finding did not represent a loss of system and/or function;

(3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and

(4) the finding does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensee's maintenance rule program for greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Cross-Cutting Aspect: The finding had a cross-cutting aspect in the area of human performance associated with change management because the licensee failed to use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. Specifically, the licensee prioritized the motor-driven AFW pumps health due to a lack of recirculation ability over the accident analysis by not adequately screening the procedure changes into 50.59 review in 2016.

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 6 of Appendix A to Regulatory Guide 1.33, Revision 2, requires procedures for combating emergencies and other significant events. The licensee established EOP Addendum 42, HCST Alignment, Revision 1, in part, to meet the regulatory requirement. Step 1 of EOP Addendum 42 placed both motor-driven auxiliary feedwater pumps in pull-to-lock and isolated their associated recirculation lines.

Contrary to the above, prior to March 7, 2018, the licensee failed to maintain procedures for combating emergencies and other significant events. Specifically, the licensee failed to maintain EOPs for aligning auxiliary feedwater suction sources. The licensee added continuous action steps to EOPs that placed both motor-driven auxiliary feedwater pumps in pull-to-lock and isolated their associated recirculation lines after depleting the two non-safety-related suction sources. These actions cause two of the three safety related auxiliary feedwater pumps to be rendered inoperable prior to aligning the safety related suction source of essential service water which is credited in accident analysis.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy.

Unresolved Item Possible Incorrect Screening of the Spent Fuel Pool 71111.05AQ (Closed) Decay Heat Removal Key Safety Function Quarterly URI 05000483/2016001-01 Inspection

Description:

In Unresolved Item 05000483/2016001-01, the inspectors documented an issue of concern with the licensees National Fire Protection Association (NFPA) Standard 805, Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating Plants, non-power operations assessment. Specifically, the inspectors developed an issue of concern because the licensee screened the potential loss of spent fuel pool cooling from further consideration for any fire event during non-power operations based on adequate procedural guidance and time when the procedures would not maintain the fuel in a safe and stable condition.

To address this unresolved item, the inspectors requested that the Office of Nuclear Reactor Regulation (NRR) work with the Nuclear Energy Institute NFPA 805 Task Force in accordance with the NFPA 805 Frequently Asked Questions (FAQ) Program to review and update the guidance in FAQ 07-0040, Non-Power Operations Clarifications, Revision 4. The inspectors documented this request in a memo, dated March 31, 2016 (ML16091A152). The updated guidance was issued in FAQ 07-0040, Revision 5 on May 20, 2016 (ML17331B109). This revision was accepted by NRR staff in a memo, dated November 28, 2017 (ML17331B108).

The revised guidance provided clarification for the treatment of spent fuel pool cooling during non-power operations. The revised guidance stated that, Spent fuel pool configurations are not considered to be risk-significant and are not treated as a higher risk evolution. In the approval memo, the NRR staff agreed with the revised guidance, stating, The NRC staff agrees that the loss of spent fuel pool cooling does not need to be considered a higher risk evolution.

The licensee documented the non-power operations assessment in Calculation KC-26, Appendix 1, NFPA 805 Non-power Operations Assessment, Revision 3. The licensee performed this assessment based, in part, on guidance in FAQ 07-0040, Revision 4.

During the current inspection, the inspectors reviewed the licensees non-power operations assessment and the revised guidance in FAQ 07-0040, Revision 5. In accordance with the revised guidance, the licensee did not need to perform additional analyses (Steps F.2 and F.3. of FAQ 07-0040) associated with spent fuel pool cooling because the staff agreed that the normal fire protection program defense-in-depth actions provide reasonable assurance that the spent fuel pool remains less than boiling. Based on the licensees non-power operations assessment and the revised guidance, the inspectors determined that no performance deficiency existed.

Corrective Action Reference: Condition Report 201600726 Observation 92702Followup on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, Confirmatory Orders, and Alternative Dispute Resolution Confirmatory Orders Discussion: The inspection team determined that the licensee had not: 1) adequately performed a timing test of the transformer XNB01 load tap changer to ensure proper operation; and 2) periodically performed a timing test of the transformer XNB01 load tap changer to ensure proper operation to maintain the operability of the offsite power sources.

Since the issuance of the violation in 2014, the licensee had opportunities to perform a timing test of transformer XNB01 load tap changer (refueling outages in fall 2014 and spring 2016).

Corrective Steps Taken and Results Achieved: The timing test of the XNBO1 load tap changer was successfully tested on October 20, 2017. Timing testing of the XNBO1 and XNB02 load tap changers will continue to be performed on a routine basis, going forward.

Also, Callaway work management procedure will be revised to establish schedule dates for jobs associated with addressing NRC violations. Rescheduling jobs beyond the scheduled date would require justification as well as approval by management. The licensee will review any NRC violations received since October 2015 for jobs that are credited for restoring compliance. The basis for selecting October 2015 was that it coincided with the last time a comprehensive pre-Problem Identification and Resolution inspection self-assessment was performed. In that assessment, the timeliness of corrective actions for NRC violations prior to October 2015 was evaluated. 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 were complete by February 28, 2018.

The inspectors reviewed the licensees response to the Notice of Violation along with corrective action documents. All findings were documented in NRC Inspection Report 05000483/2017007, ADAMS accession number ML17283A392. Notice of Violation 0500483/2017007-01 is closed.

MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.

On April 4, 2018, the inspectors presented the integrated quarterly resident inspection results to Mr. Tim Herrmann, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Procedure 71111.01: Adverse Weather Protection

Procedures

Number Title Revision

OTN-QJ-00003 Plant Freeze Protection Heat Tracing Procedure 3

OTO-ZZ-00012 Severe Weather 39

Condition Reports

201800054 201800255

Inspection Procedure 71111.04: Equipment Alignment

Procedures

Number Title Revision

OTN-NK-00001 Class 1E 125 VDC Electrical System 15

OTN-NN-00001 120 V Vital AC Instrument Power - Class 1E (Channel 1) 21

OTN-EG-00001 Component Cooling Water System 61

Calculations

Number Title Revision

E-H-18 System NN Relay Settings - Calculate Settings for NN 1

Protective Relays

GK-11 Electrical Heat Loads in the Control Building During Normal 4

and ESFAS Conditions

GL-10 Add 2 Evaluate Tube Plugging Limits for SGL 15 A/B 1

EG-54 Allowable Gas Void Volume for each Train of the

Component Cooling Water Suction Piping

M-EG-20 Max CCW Temperature Post LOCA

Miscellaneous

Number Title Revision

10466-M-612 Design Specification for Room Coolers 8

M-618.2 Spec for Q-Listed HVAC Ductwork (Installation) 12

RFR 180048 Evaluate Non-Safety Accessories in Safety HVAC Systems

Miscellaneous

Number Title Revision

M-22EG01 Piping and Instrumentation Diagram Component Cooling 11

Water System

ULDBD-EG-01 Component Cooling Water System 1

M-082-00039 Instruction Manual for Component Cooling Water Pumps 24

Condition Reports

201707171 201706754 201800235 201800933 201801160

201800157 201800176 201303691

Inspection Procedure 71111.05: Fire Protection

Procedures

Number Title Revision

Fire Preplan Manual 38

FPP-ZZ-00000 Guidelines for Writing Prefire Strategy Procedures and 8

Preplans

APA-ZZ-00700 Fire Protection Program 24

Condition Reports

201706984 201801219 201801220 200910299 200505787

200809214 201604688

Inspection Procedure 71111.06: Flood Protection Measures

Procedures

Number Title Revision

Fire Preplan Manual 38

OTO-ZZ-00005 Flooding 2

Calculations

Number Title Revision

AMN-010-CALC-002 Flood Levels in Control Building Rooms Due to Pipe

Break or Crack

Condition Reports

201609311 201800649

Inspection Procedure 71111.07A: Heat Exchanger Performance

Procedures

Number Title Revision

HX-1.PMB Heat Exchangers 42

APA-ZZ-00801 Foreign Material Exclusion 45

EDP-ZZ-01112 Heat Exchanger Predicative Performance Manual 22

Calculations

Number Title Revision

KJ-20 Evaluate Tube Plugging Limits for EKJ03A/B,

EKJ04A/B, and EKJ06A/B

M-1196-00002 Jacket Water Cooler Performance Evaluation

Jobs

13511907 09512424

Condition Reports

201500625 201600703 201800394 201801456 200803533

200909091 200204569

Inspection Procedure 71111.11: Licensed Operator Requalification Program and

Licensed Operator Performance

Procedures

Number Title Revision

AL-30 Auxiliary Feedwater System Performance During a Loss of 6

Normal Feedwater Flow and Non-Emergency A/C Power

E-0 Reactor Trip or Safety Injection 19

ISF-AL-00P37 CST to AFP Suction Header Pressure Channel Operational 16

Test

ISL-BB-0F434 RCS Flow Channel Cal Loop 3 Protection 1 29

OSP-AL-00003 Auxiliary Feedwater LSP CST to ESW Valve Operability 17

Procedures

Number Title Revision

T61.0810 8 Licensed Operator Continuing Training - Simulator Training January 23,

Scenario Guide 2018

Condition Reports

201707139 201102329 201801260

Inspection Procedure 71111.12: Maintenance Effectiveness

Procedures

Number Title Revision

APA-ZZ-00395 Significant Operator Response Timing 27

EDP-ZZ-01128 Maintenance Rule Program 25

EDP-ZZ-01128, SSCs in the Scope of the Maintenance Rule at Callaway 11

Appendix 1

EDP-ZZ-01128, Summary of SSC Performance Criteria 32

Appendix 2

EDP-ZZ-01128, Maintenance Rule Shutdown Performance Criteria 3

Appendix 3

EDP-ZZ-01128, Maintenance Rule System Functions 18

Appendix 4

OSP-SA-2413A Train A Diesel Generator and Sequencer Testing 26

Miscellaneous

Number Title Revision

E-051C-00010 Qualification Report for Class 1E 125 VDC Electronically

Controlled Manual Switches

E-1061 Specification for Class 1E AC Vital Bus Inverters and Swing

Inverters

MP-130020 Modification to Install Class 1E Swing Inverters 7

Condition Reports

200805033 201303158 201307777 20143898 201407350

201505907 201602855 201603286 201603312 201604824

201605545 201607358 201702520 201705797 201706481

201800216

Miscellaneous

Number Title Revision/

Date

LER 2014-003-00 Inverter NN11 Inadvertently Transferred to Its Alternate August 7,

Source 2014

LER 2014-003-02 Inverter NN11 Inadvertently Transferred to Its Alternate August 6,

Source 2015

ODMI 15-0006 Thermography Indicated Elevated Temperatures on 2

Disconnect NN0311

Inspection Procedure 71111.13: Maintenance Risk Assessments and Emergent Work

Control

Procedures

Number Title Revision

APA-ZZ-00750 Hazard Barrier Program 40

ODP-ZZ-00002, Risk Management Actions For Planned Risk Significant 13

Appendix 2 Activities

EDP-ZZ-01129 Callaway Energy Center Risk Assessment 47

APA-ZZ-00322 Integrated Work Management Process Description 20

APA-ZZ-00322, Online Work Integrated Risk Management 16

Appendix F

APA-ZZ-00315 Configuration Risk Management Program 14

ODP-ZZ-00002, Protected Equipment Program 27

Appendix 1

OTN-BG-00001 Chemical and Volume Control System 56

MPE-ZZ-QY054 Inspection and Test of Protective Lockout Relays, General 5

Electric Type HEA

OTN-MD-00001 Switchyard Breakers and Disconnects 28

MTM-AL-QP002 Turbine Driven Auxiliary Feedwater Pump 13

Jobs

16513469 16508486 18000148 16508306 14504707

16514154 15503300 17500047

Condition Reports

201800516 201106906 200604069 201605319 201705780

201505319 201800176 201800157 200000661

Inspection Procedure 71111.15: Operability Determinations and Functionality

Assessments

Procedures

Number Title Revision

APA-ZZ-00391 Beyond Design Basis Program 4

APA-ZZ-00391, Sequence of Events Timeline

Appendix 2

OSP-KC-00015 Fire Door Inspections 18

APA-ZZ-00750 Hazard Barrier Program 40

OTG-ZZ-00006 Plant Cooldown Hot Standby to Cold Shutdown 78

OSP-GT-00003 Containment Closure 21

OSP-GP-00001 Containment Isolation Verification 23

Miscellaneous

Number Title Revision

M-22FC02 Auxiliary Feedwater Pump Turbine P&ID 24

M-FC-03 Auxiliary Feedwater Pump Turbine Room Analysis 1

M-YY-49, Additional HELB Scenarios 1

Addendum 4

2 Auxiliary & Reactor Building Elevation 2000 Floor Plan 15

Westinghouse Clarification on the Basis for the Boil Off 1

Time of the Callaway Energy Center Spent Fuel Pool

ULNRC-06421 Licensee Event Report 2018-001-00 Violation of Technical Specification 3.6.3 Containment Isolation Manual Valve

Found in Open Position

M-22KA02 Compressed Air System P&ID 27

Jobs

18000323 13511394 09501018 18000249 18000735

Condition Reports

201800066 201800235 201800194

Inspection Procedure 71111.18: Plant Modifications

Miscellaneous

Number Title Revision

MP 12-0020 Field Change Notice 4

Seismic II/I Hazard Analysis Review for MP 12-0020

STARS ENG-5001-8.3, Section 13 FP Review

Inspection Procedure 71111.19: Post Maintenance Testing

Procedures

Number Title Revision

MTM-AL-QP002 Turbine Driven Auxiliary Feedwater Pump 13

MPE-NK-QB004 NK Class 1E Battery Charger Inspection 10

OSP-GK-0002B Train B Control Room Ventilation and Pressure Test 18

OSP-NE-0001A Standby Diesel Generator A Periodic Tests 64

OSP-NE-00003 Technical Specification Actions - A/C Sources 31

OTN-EF-00001 Essential Service Water System 75

Miscellaneous

Number Title Revision

M-22FC02 Auxiliary Feedwater Pump Turbine P&ID 24

MP 15-0020 Install Fuses in 250Vdc Control Circuits 4

E-23NK11 125 Volt DC Class 1E Power System Schematic Diagram 3

Jobs

17004200 16002592 15505343 16509603 18000735

14000994 18000457 17503253 13511907 17004111

16511918

Condition Reports

201706923 201800442 201704649 201704899 201800145

201700177 201800206 201705121 201604537 201110062

201800926 201820013 201800874 200801131 201703920

200811040

Inspection Procedure 71111.22: Surveillance Testing

Procedures

Number Title Revision

OSP-BG-P005A Centrifugal Charging Pump A Inservice Test 49

APA-ZZ-00340 Surveillance Program Administration 44

OSP-BG-00001 Boron Injection Flow Paths Modes 1, 2 and 3 24

ODP-ZZ-00036 Technical Specification Application for Containment Isolation 7

Valves

EDP-ZZ-01128 Summary of SSC Performance Criteria 32

APA-ZZ-00549, Guidelines used to determine functional importance for a 13

Appendix B component

Miscellaneous

Number Title Revision/

Date

M-721-00093 Instruction Manual for Centrifugal Charging/Safety-Injection 33

Pumps Operation and Maintenance

M-22BG01 Chemical and Volume Control System P&ID 33

MP 12-0020 Field Change Notice 4

Night Order Condition Report 201706233/Condition Report 201706926, January 31,

KCV0478 may stick open during flow through 2018

penetrations P067

ULDBD-BB-001 Reactor Coolant System 2

Jobs

17514632 05504483 17004820

Condition Reports

201800330 201800423 200702585 200901841 200306153

200502806 201706233 201706926 201800323

Inspection Procedure 71114.06: Drill Evaluation

Procedures

Number Title Revision

APA-ZZ-00925 Training and Qualification of Plant Personnel 39

Procedures

Number Title Revision

EIP-ZZ-A0066 Radiological Emergency Response Plan Training 24

EIP-ZZ-A0001 Emergency Response Organization 19

Condition Reports

201801245 201801251 201801252 2000800921 201008419

200808431

Inspection Procedure 71151: Performance Indicator Verification

Procedures

Number Title Revision

CSP-ZZ-02550 Pressurized Reactor Coolant Sample 30

CSP-ZZ-07600 RCS Activity Determinations 41

Miscellaneous

Number Title Revision

Date

MSPI Derivation Reports (Cooling Water Systems) Various

Control Room Log Various

NRC Performance Indicator Transmittal Report, First April 11, 2018

Quarter 2015, Mitigating Systems Cornerstone

NRC Performance Indicator Transmittal Report, Second July 18,

Quarter 2015, Mitigating Systems Cornerstone 2018

NRC Performance Indicator Transmittal Report, Third October 25,

Quarter 2015, Mitigating Systems Cornerstone 2018

NRC Performance Indicator Transmittal Report, Fourth January 16,

Quarter 2015, Mitigating Systems Cornerstone 2018

Condition Reports

201101025 201004284

Inspection Procedure 71152: Problem Identification and Resolution

Procedures

Number Title Revision

APA-ZZ-00500 Corrective Action Program 68

ESP-EF-0001A Ultimate Heat Sink Train A Cooling Tower Fill Inspection 3

Miscellaneous

Number Title Revision

EM-04 Safety Injection System (Cold Leg Recirculation Phase) 1

Fault Tree Model

BG-32 High Pressure Coolant Injection System (Cold Leg 0

Recirculation Phase) Fault Tree Model

BN-28 RWST Drain Down Time and Volume Loss During SBLOCA 0

M-015-U012-08 Specification for Ultimate Heat Sink Cooling Tower 1

Condition Reports

201706900 201707137 201704706 201010236

Inspection Procedure 71153: Follow-up of Events and Notices of Enforcement Discretion

Drawings

Number Title Revision

E-21NK02(Q) Class IE 125V dc System Meter and Relay Diagram 11

J-200-00075 Main Control Board RL025 and RL026 Wiring Diagram 15

E-21NK01(Q) Class IE 125V dc System Meter and Relay Diagram 11

E-051-00079 Battery Chargers Wiring Diagram 9

E-23NK11(Q) 125 Volt dc Class IE Power System Schematic 3

E-23CD02 Schematic Diagram Emergency Seal Oil Pump 3

E-23FC02 Schematic Diagram Feed Pump Turbine Emergency 5

Bearing Oil Pumps

E-21NK02(Q) Class IE 125V dc System Meter and Relay Diagram 17

E-23CB03 Schematic Diagram Emergency Bearing Oil Pump 8

M-840-00014 Hydrogen and Water Cooling Wiring Diagram 10

M-840-00023 Schematic Diagram (Hydrology and Stator Cooling) 10

E-21NK01(Q) Class IE 125V dc System Meter and Relay Diagram 11

Drawings

Number Title Revision

E-21NK01(Q) Class IE 125V dc System Meter and Relay Diagram 17

M-830-00015 Emergency Bearing Oil Pump 14

IC-4061-T1 dc Magnetic Starter

M-012-00079 Wiring Diagram (Emergency Oil Pump Starter Circuit) 7

E-051-00058 3 SCR Controlled Battery Charger Schematic 12

M-835-00014 D.C. Magnetic Starter 72-13 (CD01) (Counter - 5

Electromotive Force) Emergency Seal Oil Pump Motor

J-200-00081 Main Control Board RL025 and RL026 Wiring Diagram 26

Miscellaneous

Number Title Revision/

Date

FR-087114 Bimetallic Thermal Overload Relays December 13,

2017

Calculation KC-26 Nuclear Safety Capability Assessment Calculations: 1

KC-26

MP 15-0020 Install Fuses in 250 Vdc Control Circuits To Address

NFPA805 Concerns

Condition Reports

201706133 201706233 201706924 201706926 201801657

Initial Request for Information

Quarterly Baseline Inspection

Callaway Plant

Inspection Report: 05000483/2018001

Inspection Dates: January 1 - March 31, 2018

Inspection Procedure: IP 71111 series, IP 71152

Lead Inspector: Dan Bradley, Senior Resident Inspector

Information Requested For 1st Quarter 2018

The following information should be sent to the resident office in hard copy or electronic format

(Certrec IMS preferred) to the attention of Dan Bradley by January 15, 2018. These items shall

be available and ready for review on the day indicated in this request. Please provide

requested documentation electronically in pdf files, Excel, or other searchable formats, if

possible. The information should contain descriptive names and be indexed and hyperlinked to

facilitate ease of use. If requested documents are large and/or only hard copy formats are

available, please inform the inspector and provide subject documentation.

Please provide the following information for the 125 VDC (NK) and Instrument AC Power (NN)

systems:

1. A list of all calculations and drawings associated with the selected systems.

2. A list of condition reports associated with the selected systems for the last 3 years.

3. A list of work orders associated with the selected systems for the last 3 years, including

all open work orders.

4. An Excel spreadsheet list of equipment basic events (with definitions), including

importance measures sorted by risk achievement worth and Fussell-Vesely from your

internal events probabilistic risk assessment. Include basic events with a risk

achievement value of 1.3 or greater.

5. A list of any pre-existing evaluations or calculations with low design margins for the

selected systems.

6. A list of maintenance rule components and functions; based on engineering or expert

panel judgment, for the selected systems.

7. A list of maintenance rule functional failure evaluations for the last 3 years for the

selected systems.

8. A list of operating experience evaluations for the last 3 years for the selected systems.

9. A list of all procedures and calculations that involve time-critical operator actions.

10. A list of permanent and temporary modifications performed in the past 3 years for the

selected systems. 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.

11. A list of the design calculations that provide the design margin information for the

selected systems.

2. A list of root cause evaluations associated with component failures or design issues

initiated/completed in the last 3 years for the selected systems.

13. A list of any common-cause failures of components in the last 3 years for the selected

systems.

14. An electronic copy of the design bases documents for the selected systems.

15. An electronic copy of the system health notebooks for the selected systems.

Inspector Contact Information:

Dan Bradley

Senior Resident Inspector

573-676-3181

Dan.Bradley@nrc.gov

Mailing Address:

U.S. NRC Resident Inspector Office

201 NRC Road

Steedman, MO 65077

ML18123A395

SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: NHT/rdr Yes No Publicly Available Sensitive NRC-002

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 /RA/ /RA/ /RA/ /RA/ /RA/ /RA/

DATE 5/2/18 5/2/18 4/25/18 4/29/18 4/25/18 4/30/18

OFFICE TL:DRS/IPAT C:DRP/B

NAME GGeorge NTaylor

SIGNATURE /RA/ /RA/

DATE 4/25/18 5/3/18

May 3, 2018

Mr. Fadi Diya, Senior Vice President

and Chief Nuclear Officer

Ameren Missouri

Callaway Plant

P. O. Box 620

Fulton, MO 65251

SUBJECT: CALLAWAY PLANT - NRC INTEGRATED INSPECTION

REPORT 05000483/2018001

Dear Mr. Diya:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

at your Callaway Plant. On April 4, 2018, the NRC inspectors discussed the results of this

inspection with Mr. Tim Herrmann, Site Vice President, and other members of your staff. The

results of this inspection are documented in the enclosed report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. The NRC is treating this violation as a

non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violation or significance of this NCV, you should provide a response within

days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with

copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the

NRC resident inspector at the Callaway Plant.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a

response within 30 days of the date of this inspection report, with the basis for your

disagreement, to the

U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,

Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the

NRC resident inspector at the Callaway Plant.

F. Diya 2

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 05000483/2018001

w/Attachment 1: Supplemental Information

2: Request for Information

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number: 05000483

License Number: NPF-30

Report Number: 05000483/2018001

Enterprise Identifier: I-2018-001-0006

Licensee: Union Electric Company

Facility: Callaway Plant

Location: 8315 County Road 459

Steedman, MO 65077

Inspection Dates: January 1, 2018, to March 31, 2018

Inspectors:

D. Bradley, Senior Resident Inspector

S. Janicki, Resident Inspector

S. Alferink, Reactor Inspector

D. Dodson, Senior Resident Inspector

R. Kopriva, Senior Reactor Inspector

S. Makor, Reactor Inspector

J. Melfi, Project Engineer

Approved By: N. Taylor

Chief, Project Branch B

Division of Reactor Projects

SUMMARY

The NRC continued monitoring 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. NRC-identified and self-revealed findings, violations, and additional items are

summarized in the tables below. A NRC-identified non-cited violation is documented in report

section 71111.11.

List of Findings and Violations

Failure to Maintain Emergency Operating Procedures

Cornerstone Significance Cross-cutting Report

Aspect Section

Mitigating Green [H.3] - Human 71111.11

Systems NCV 05000483/2018001-01 Performance, Licensed

Closed Change Operator

Management Performance

The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a,

"Procedures," for the licensee's failure to maintain emergency operating procedures for

aligning auxiliary feedwater suction sources. Specifically, the licensee added continuous

action steps to emergency operating procedures that placed both motor-driven auxiliary

feedwater pumps in pull-to-lock and isolated their associated recirculation lines after depleting

the two non-safety-related suction sources. These actions cause two of the three

safety-related auxiliary feedwater pumps to be rendered inoperable prior to aligning the

safety-related suction source of essential service water which is credited in accident analysis.

Additional Tracking Items

Type Issue number Title Report Status

Section

URI 05000483/2016001-01 Possible Incorrect Screening 71111.05AQ Closed

of the Spent Fuel Pool Decay

Heat Removal Key Safety

Function

LER 05000483/2013-009-00 Appendix R Unanalyzed 71153 Closed

Condition - Direct Current

Ammeter Circuits Without

Overcurrent Protection

LER 05000483/2014-004-00 Postulated Hot Short Fire 71153 Closed

Event that Could Adversely

Impact Shutdown Equipment

LER 05000483/2017-001-00 Violation of Technical 71153 Closed

05000483/2017-001-01 Specification 3.7.9 Due to

Ultimate Heat Sink Cooling

Tower Train Inoperability

LER 05000483/2017-002-01 Inadequate Protection from 71153 Closed

Tornado Missiles Identified

due to Nonconforming

Design

LER 05000483/2017-003-00 Violation of Technical 71153 Closed

Specification 3.6.3,

Containment Isolation Check

Valve Found in Open

Position

NOV 05000483/2017007-01 Not Verifying the Operation 92702 Closed

and Timing of the

Engineered Safety Feature

Transformer XNB01 Load

Tap Changer

PLANT STATUS

Callaway Plant began the inspection period at full power. On March 14, 2018, the licensee

reduced power to 45 percent to replace a reactor coolant system flow transmitter, commenced

ascending in power upon completion of testing, and returned to full power on the same day.

The licensee 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 website at

http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.

Samples were declared complete when the IP requirements most appropriate to the inspection

activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor

Inspection Program - Operations Phase. The inspectors performed plant status activities

described in IMC 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

71111.01 - Adverse Weather Protection

Impending Severe Weather (1 Sample)

The inspectors evaluated readiness for impending adverse weather conditions for:

(1) Severe winter weather on January 11, 2018

71111.04 - Equipment Alignment

Partial Walkdown (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

(1) Component cooling water train B on January 10, 2018

(2) Control room filtration unit FGK02B on January 25, 2018

(3) Battery charger NK26 on February 7, 2018

Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of:

(1) Instrument AC power (NN) system on January 18, 2018

71111.05AQ - Fire Protection Annual/Quarterly

Quarterly Inspection (5 Samples)

The inspectors evaluated fire protection program implementation in the following selected

areas:

(1) Control building 2016 elevation, fire area C-15 on January 12, 2018

(2) Auxiliary feedwater pipe chase 1988 elevation, fire area A-1 on February 16, 2018

(3) Control room air conditioning and filtration units, fire areas A-21 and A-22 on March 6,

2018

(4) Electrical penetration rooms, fire areas A-17 and A-18 on March 11, 2018

(5) Intake structure, fire area IS-1 on March 28, 2018

71111.06 - Flood Protection Measures

Internal Flooding (1 Sample)

The inspectors evaluated internal flooding mitigation protection:

(1) Control building 2016 elevation on January 9, 2018

71111.07 - Heat Sink Performance

Heat Sink (1 Sample)

The inspectors evaluated:

(1) Emergency diesel generator jacket water heat exchanger train A on March 22, 2018

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (1 Sample)

The inspectors observed and evaluated simulator training for operating crews:

(1) Electrical faults on February 6, 2018

Operator Performance (1 Sample)

The inspectors observed and evaluated:

(1) Surveillance testing for the auxiliary feedwater system on February 20, 2018

(2) Surveillance testing for the emergency diesel generator train B and reactor coolant flow

transmitter troubleshooting on March 7, 2018

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness (2 Samples)

The inspectors evaluated the effectiveness of routine maintenance activities associated

with the following equipment and/or safety significant functions:

(1) 125 VDC system (NK) on January 17, 2018

(2) Instrument AC power system (NN) on February 14, 2018

71111.13 - Maintenance Risk Assessments and Emergent Work Control (5 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent

work activities:

(1) Elevated risk actions due to planned centrifugal charging pump B and component

cooling water equipment outage on January 30, 2018

(2) Elevated risk actions due to planned switchyard maintenance on February 5, 2018

(3) Elevated risk actions due to planned safety injection train A equipment outage on

February 13, 2018

(4) Emergent risk actions due to auxiliary feedwater pump door failure on February 20, 2018

(5) Elevated risk actions due to planned turbine-driven auxiliary feedwater pump equipment

outage on February 27, 2018

71111.15 - Operability Determinations and Functionality Assessments (5 Samples)

The inspectors evaluated the following operability determinations and functionality

assessments:

(1) Rising level trend in safety injection accumulators on January 8, 2018

(2) Reactor building service air header supply containment isolation valve KAV0118 out of

position on January 15, 2018

(3) Battery charger NK25 equalize potentiometer failure on January 16, 2018

(4) Spent fuel pool calculation assumptions on February 13, 2018

(5) Turbine-driven auxiliary feedwater pump room door DSK13311 failure on March 2, 2018

71111.18 - Plant Modifications (1 Sample)

The inspectors evaluated the following permanent modification:

(1) MP 12-0020 electrical tie-ins for FLEX on March 29, 2018

71111.19 - Post Maintenance Testing (5 Samples)

The inspectors evaluated the following post maintenance tests:

(1) Control room air conditioning unit SGK04B equipment outage on January 10, 2018

(2) Class 1E battery charger NK25 equipment outage on January 22, 2018

(3) Class 1E battery charger NK21 equipment outage on January 29, 2018

(4) Turbine-driven auxiliary feedwater pump equipment outage on February 28, 2018

(5) Emergency diesel generator and essential service water train A equipment outage on

March 23, 2018

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine (1 Sample)

(1) OSP-NE-0001A, standby diesel generator A periodic tests on January 24, 2018

In-service (2 Samples)

(1) OSP-BG-P005A, centrifugal charging pump A inservice test - Group B on February 15,

2018

(2) OSP-EG-P01BD, component cooling water train B pump and valve inservice test -

group A on March 29, 2018

Containment Isolation Valve (1 Sample)

(1) OSP-KC-LL067, containment isolation valve leak rate test and results of check valve

internal inspection under Condition Report 201706233 on March 15, 2018

71114.06Drill Evaluation

Emergency Planning Drill (1 Sample)

The inspectors evaluated the radiological emergency response plan drill:

(1) Team 4 on March 8, 2018

Drill/Training Evolution (1 Sample)

The inspectors evaluated annual emergency response organization training evolution:

(1) Team 4 on February 1, 2018

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification (3 Samples)

The inspectors verified licensee performance indicators submittals listed below:

(1) MS06: Emergency AC Power Systems (01/01/2017-12/31/2017)

(2) MS10: Cooling Water Support Systems (01/01/2017-12/31/2017)

(3) BI01: Reactor Coolant System (RCS) Specific Activity Sample (01/01/2017-12/31/2017)

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program

related to the following issues:

(1) Safety injection pump oil leak, Condition Report 201704706

(2) Ultimate heat sink cooling tower shroud bolting, Condition Report 201010236

71153 - Follow-up of Events and Notices of Enforcement Discretion

Licensee Event Reports (5 Samples)

The inspectors evaluated the following licensee event reports which can be accessed at

https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) Licensee Event Report 05000483/2013-009-00, Appendix R Unanalyzed Condition -

Direct Current Ammeter Circuits Without Overcurrent Protection, on October 9, 2013

(2) Licensee Event Report 05000483/2014-004-00, Postulated Hot Short Fire Event that

Could Adversely Impact Shutdown Equipment, on September 19, 2014

(3) Licensee Event Reports 05000483/2017-001-00 and 05000483/2017-001-01, Violation

of Technical Specification 3.7.9 Due to Ultimate Heat Sink (UHS) Cooling Tower Train

Inoperability, on June 16, 2017

(4) Licensee Event Report 05000483/2017-002-01, Inadequate Protection from Tornado

Missiles Identified due to Nonconforming Design, on August 15, 2017

(5) Licensee Event Report 05000483/2017-003-00, Violation of Technical Specification 3.6.3, Containment Isolation Check Valve Found in Open Position, on

October 31, 2017

2702 - Followup on Traditional Enforcement Actions Including Violations, Deviations,

Confirmatory Action Letters, Confirmatory Orders, and Alternative Dispute Resolution

Confirmatory Orders

Notice of Violation (1 Sample)

The inspectors reviewed the licensees response to Notice of

Violation 05000483/2017007-01, Not Verifying the Operation and Timing of the Engineered

Safety Feature Transformer XNB01 Load Tap Changer, and determined that the reason,

corrective actions taken and planned to address recurrence, and the date when full

compliance was achieved for this violation is adequately addressed and captured on the

docket.

INSPECTION RESULTS

Failure to Maintain Emergency Operating Procedures

Cornerstone Significance Cross-cutting Aspect Report Section

Mitigating Systems Green [H.3]Human 71111.11

NCV 05000483/2018001-01 Performance, Change Licensed

Closed Management Operator

Performance

The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a,

"Procedures," for the licensee's failure to maintain emergency operating procedures for

aligning auxiliary feedwater suction sources. Specifically, the licensee added continuous

action steps to emergency operating procedures that placed both motor-driven auxiliary

feedwater pumps in pull-to-lock and isolated their associated recirculation lines after depleting

the two non-safety-related suction sources. These actions cause two of the three safety

related auxiliary feedwater pumps to be rendered inoperable prior to aligning the safety

related suction source of essential service water which is credited in accident analysis.

Description:

On March 7, 2018, the inspectors performed an observation of licensed control room

operators and reviewed the use of auxiliary feedwater pumps (AFW or AFPs) in Emergency

Operating Procedures (EOPs). The AFW system provides a reliable source of water to the

steam generators and removes thermal energy from the reactor coolant system through the

release of secondary steam to the atmosphere. The AFW pumps are comprised of two

motor-driven (MD) pumps and one turbine-driven (TD) pump. Each pump has recirculation

lines to provide a constant discharge pathway and prevent pump damage. These AFW

pumps can be supplied with the following three suction sources:

(1) Condensate storage tank (CST) - non-safety-related and normally aligned

(2) Hardened CST (HCST) - non-safety-related

(3) Essential service water (ESW) - safety-related

In their review of EOPS, the inspectors noted that the following continuous action step was

found in several EOPs and titled AFW Supply Switchover Criteria:

If CST to AFP suction header pressure lowers to less than 11.5 PSIG,

THEN PERFORM EOP Addendum 42, HCST Alignment.

If CST to AFP suction header pressure lowers to less than 2.75 PSIG,

THEN PERFORM EOP Addendum 19, Aligning ESW to AFW Suction.

The inspectors reviewed EOP Addendum 42, HCST Alignment, Revision 1, which states the

following and accomplishes it in step 1 of the addendum:

When the HCST is supplying AFW, ONLY the TDAFW will be used, since it

can be aligned to recirc back to the HCS

T. Therefore, the MDAFPs will be

placed in Pull-to-Lock prior to isolating MDAFP recirc lines back to the

CS

T.

The inspectors noted that EOP Addendum 19Property "Contact" (as page type) with input value "T.The inspectors noted that EOP Addendum 19" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Aligning ESW to AFW Suction, Revision 3,

did not restore the isolated and disabled motor-driven AFW pumps. Instead, EOP

Addendum 19 refers only to the ESW valve lineup. As written, the discussed EOP addenda

would leave the control room staff with only the turbine-driven AFW pump available.

The inspectors then reviewed accident analysis including section 15.2.8, Feedwater System

Pipe Break, of the Final Safety Analysis Report which states:

For the auxiliary feedwater system, the worst case configuration has been

used, i.e., only three intact steam generators receive auxiliary feedwater

following the break . . . one motor-driven AFW pump to the intact steam

generatorthe turbine-driven AFW pump has been assumed to fail . . . the

second motor-driven AFW pump is assumed to deliverequally split to the

two remaining intact steam generators . . .

The inspectors noted that the accident analysis of Final Safety Analysis Report chapter 15

does not refer to use of the HCST and does not refer to operator action to manually un-isolate

motor-driven AFW pumps to reach and maintain safe shutdown.

The inspectors reviewed the extent of condition for the AFW Supply Switchover Criteria

continuous action steps and found it in the following EOPs:

(1) E-0, Reactor Trip or Safety Injection, Revision 19

(2) E-1, Loss of Reactor or Secondary Coolant, Revision 19

(3) E-3, Steam Generator Tube Rupture, Revision 22

(4) ES-0.1, Reactor Trip Response, Revision 18

(5) FR-H.1, Response To Loss of Secondary Heat Sink, Revision 18

The inspectors noted the HCST Alignment addendum was created in February 2016 and

modified in October 2016 to the current Revision 1. The procedure review process noted the

non-safety HCST is a useful water source prior to using the ESW . . . the HCST is

maintained at a higher cleanliness. Further, the procedure review noted the HCST:

does not have a recirculation line from the Motor Drive Aux Feed pumps to

the HCST . . . EOP Add 42 allows for the alignment of the recirc valves and

stops the Motor Drive Aux Feedwater Pumps to prevent possible damage

from overheating. Since this overall modification has been evaluated

previously, this procedure change does not require further 50.59 review.

The inspectors concluded the licensee failed to maintain EOPs for aligning auxiliary feedwater

suction sources. Specifically, the EOPs placed both motor-driven auxiliary feedwater pumps

in pull-to-lock and isolated their associated recirculation lines prior to aligning the

safety-related suction source of essential service water. This configuration and operator

actions are not supported by the accident analysis in the Final Safety Analysis Report.

Further, the licensee did not provide an adequate procedure for restoring the motor-driven

AFW pumps from this configuration. Since the continuous action steps are pervasive across

EOPs, it is plausible that an operating crew would enact the AFW supply switchover actions

prior to fully diagnosing the accident and contrary to the goal of the EOP they were utilizing.

Corrective Actions: The licensee issued a night order clarifying the requirements for auxiliary

feedwater in the EOPs and revised EOP Addendum 42, HCST Alignment.

Corrective Action Reference: Condition Reports 201801260 and 201801570.

Performance Assessment:

Performance Deficiency: The failure to maintain Emergency Operating Procedures for

aligning auxiliary feedwater suction sources was a performance deficiency.

Screening: This performance deficiency was more than minor, and therefore a finding,

because it adversely affected the procedure quality attribute of the Mitigating Systems

Cornerstone objective of ensuring the availability, reliability, and capability of systems that

respond to initiating events to prevent undesirable consequences. Specifically, the licensee

added continuous action steps to EOPs that placed both motor-driven auxiliary feedwater

pumps in pull-to-lock and isolated their associated recirculation lines after depleting the two

non-safety-related suction sources. These actions cause two of the three safety related

auxiliary feedwater pumps to be rendered inoperable prior to aligning the safety related

suction source of essential service water which is credited in accident analysis.

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 2, Mitigating Systems Screening Questions, dated June 19, 2012, the

inspectors determined that the finding was of very low safety significance (Green) because

(1) the finding was not a deficiency affecting the design or qualification of a mitigating system;

(2) the finding did not represent a loss of system and/or function; (3) the finding did not

represent an actual loss of function of a single train for greater than its technical specification

allowed outage time; and (4) the finding does not represent an actual loss of function of one

or more non-technical specification trains of equipment designated as high safety-significant

in accordance with the licensee's maintenance rule program for greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Cross-Cutting Aspect: The finding had a cross-cutting aspect in the area of human

performance associated with change management because the licensee failed to use a

systematic process for evaluating and implementing change so that nuclear safety remains

the overriding priority. Specifically, the licensee prioritized the motor-driven AFW pumps

health due to a lack of recirculation ability over the accident analysis by not adequately

screening the procedure changes into 50.59 review in 2016.

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 6 of Appendix A to Regulatory

Guide 1.33, Revision 2, requires procedures for combating emergencies and other significant

events. The licensee established EOP Addendum 42, HCST Alignment, Revision 1, in part,

to meet the regulatory requirement. Step 1 of EOP Addendum 42 placed both motor-driven

auxiliary feedwater pumps in pull-to-lock and isolated their associated recirculation lines.

Contrary to the above, prior to March 7, 2018, the licensee failed to maintain procedures for

combating emergencies and other significant events. Specifically, the licensee failed to

maintain EOPs for aligning auxiliary feedwater suction sources. The licensee added

continuous action steps to EOPs that placed both motor-driven auxiliary feedwater pumps in

pull-to-lock and isolated their associated recirculation lines after depleting the two

non-safety-related suction sources. These actions cause two of the three safety related

auxiliary feedwater pumps to be rendered inoperable prior to aligning the safety related

suction source of essential service water which is credited in accident analysis.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with

Section 2.3.2.a of the Enforcement Policy.

Unresolved Item Possible Incorrect Screening of the Spent Fuel Pool 71111.05AQ

(Closed) Decay Heat Removal Key Safety Function Quarterly

URI 05000483/2016001-01 Inspection

Description: In Unresolved Item 05000483/2016001-01, the inspectors documented an issue

of concern with the licensees National Fire Protection Association (NFPA) Standard 805,

Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating

Plants, non-power operations assessment. Specifically, the inspectors developed an issue of

concern because the licensee screened the potential loss of spent fuel pool cooling from

further consideration for any fire event during non-power operations based on adequate

procedural guidance and time when the procedures would not maintain the fuel in a safe and

stable condition.

To address this unresolved item, the inspectors requested that the Office of Nuclear Reactor

Regulation (NRR) work with the Nuclear Energy Institute NFPA 805 Task Force in accordance

with the NFPA 805 Frequently Asked Questions (FAQ) Program to review and update the

guidance in FAQ 07-0040, Non-Power Operations Clarifications, Revision 4. The inspectors

documented this request in a memo, dated March 31, 2016 (ML16091A152). The updated

guidance was issued in FAQ 07-0040, Revision 5 on May 20, 2016 (ML17331B109). This

revision was accepted by NRR staff in a memo, dated November 28, 2017 (ML17331B108).

The revised guidance provided clarification for the treatment of spent fuel pool cooling during

non-power operations. The revised guidance stated that, Spent fuel pool configurations are

not considered to be risk-significant and are not treated as a higher risk evolution. In the

approval memo, the NRR staff agreed with the revised guidance, stating, The NRC staff

agrees that the loss of spent fuel pool cooling does not need to be considered a higher risk

evolution.

The licensee documented the non-power operations assessment in Calculation KC-26,

Appendix 1, NFPA 805 Non-power Operations Assessment, Revision 3. The licensee

performed this assessment based, in part, on guidance in FAQ 07-0040, Revision 4.

During the current inspection, the inspectors reviewed the licensees non-power operations

assessment and the revised guidance in FAQ 07-0040, Revision 5. In accordance with the

revised guidance, the licensee did not need to perform additional analyses (Steps F.2

and F.3. of FAQ 07-0040) associated with spent fuel pool cooling because the staff agreed

that the normal fire protection program defense-in-depth actions provide reasonable

assurance that the spent fuel pool remains less than boiling. Based on the licensees

non-power operations assessment and the revised guidance, the inspectors determined that

no performance deficiency existed.

Corrective Action Reference: Condition Report 201600726

Observation 92702Followup on Traditional

Enforcement Actions Including

Violations, Deviations,

Confirmatory Action Letters,

Confirmatory Orders, and

Alternative Dispute Resolution

Confirmatory Orders

Discussion: The inspection team determined that the licensee had not: 1) adequately

performed a timing test of the transformer XNB01 load tap changer to ensure proper

operation; and 2) periodically performed a timing test of the transformer XNB01 load tap

changer to ensure proper operation to maintain the operability of the offsite power sources.

Since the issuance of the violation in 2014, the licensee had opportunities to perform a timing

test of transformer XNB01 load tap changer (refueling outages in fall 2014 and spring 2016).

Corrective Steps Taken and Results Achieved: The timing test of the XNBO1 load tap

changer was successfully tested on October 20, 2017. Timing testing of the XNBO1 and

XNB02 load tap changers will continue to be performed on a routine basis, going forward.

Also, Callaway work management procedure will be revised to establish schedule dates for

jobs associated with addressing NRC violations. Rescheduling jobs beyond the scheduled

date would require justification as well as approval by management. The licensee will review

any NRC violations received since October 2015 for jobs that are credited for restoring

compliance. The basis for selecting October 2015 was that it coincided with the last time a

comprehensive pre-Problem Identification and Resolution inspection self-assessment was

performed. In that assessment, the timeliness of corrective actions for NRC violations prior to

October 2015 was evaluated. 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 were complete by February 28, 2018.

The inspectors reviewed the licensees response to the Notice of Violation along with

corrective action documents. All findings were documented in NRC Inspection

Report 05000483/2017007, ADAMS accession number ML17283A392. Notice of

Violation 0500483/2017007-01 is closed.

MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On April 4, 2018, the inspectors presented the integrated quarterly resident inspection results to

Mr. Tim Herrmann, Site Vice President, and other members of the licensee staff.