Text

NRC Integrated Inspection Report 05000483/2016002 and Notice of Violation
	ML16225A577
Person / Time
Site:	Callaway
Issue date:	08/12/2016
From:	Nick Taylor; NRC/RGN-IV/DRP/RPB-B
To:	Diya F; Union Electric Co
	Taylor N
References
	IR 2016002
	Download: ML16225A577 (81)
	v • d • e

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E. LAMAR BLVD.

ARLINGTON, TX 76011-4511

August 12, 2016

Mr. Fadi Diya, Senior Vice President

and Chief Nuclear Officer

Union Electric Company

P.O. Box 620

Fulton, MO 65251

SUBJECT: CALLAWAY PLANT - NRC INTEGRATED INSPECTION

REPORT 05000483/2016002 AND NOTICE OF VIOLATION

Dear Mr. Diya,

On June 30, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at

your Callaway Plant. On July 19, 2016, the NRC inspectors discussed the results of this

inspection with you and other members of your staff. Inspectors documented the results of this

inspection in the enclosed inspection report.

NRC inspectors documented five findings of very low safety significance (Green) in this report.

Four of these findings involved violations of NRC requirements. The NRC evaluated these

violations in accordance Section 2.3.2.a of the NRC Enforcement Policy, which appears on the

NRCs Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The

NRC is treating three violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of

the NRC Enforcement Policy. We determined that one violation did not meet the criteria to be

treated as an NCV because compliance has not been restored within a reasonable period after

the violation was originally identified. Specifically, NRC inspectors identified and documented a

noncompliance in NRC Integrated Inspection Report 05000483/2010006 dated December 17,

2010. This finding was a violation of Title 10 of the Code of Federal Regulations (10 CFR)

Part 50, Appendix B, Criterion XVI, for the failure to take timely corrective actions for water

hammer transients and corrosion on essential service water system components. As of the end

of this inspection (more than 65 months later), compliance had still not been restored. The

inspectors determined that the licensee did not provide an adequate justification for the delay.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice of Violation (Notice) when preparing your response. If you have additional

information that you believe the NRC should consider, you may provide it in your response to

the Notice. The NRCs review of your response to the Notice will also determine whether further

enforcement action is necessary to ensure your compliance with regulatory requirements.

If you contest the NCVs or their significance 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, 1600 East Lamar Blvd., Arlington, Texas 76011-4511; the

Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington,

DC 20555-0001; and the NRC resident inspector at the Callaway Plant.

F. Diya -2-

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 Regional Administrator,

Region IV; and the NRC resident inspector at the Callaway Plant.

In accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding,

a copy of this letter, its enclosure, and your response will be available electronically for public

inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS)

component of the NRC's Agencywide Documents Access and Management System (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the

Public Electronic Reading Room).

Sincerely,

/RA David Proulx Acting for/

Nicholas H. Taylor, Branch Chief

Project Branch B

Division of Reactor Projects

Docket No. 50-483

License No. NPF-30

Enclosures:

1. Notice of Violation

2. Inspection Report 05000483/2016002

w/ Attachment 1: Supplemental Information

Attachment 2: Request for Information

cc w/ encl: Electronic Distribution

ML16225A577

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By: DLP Yes No Sensitive Non-Publicly Available NRC-002

Sensitive

OFFICE SRI/DRP/B RI/DRP/B C:DRS/OB C:DRS/PSB2 C:DRS/EB1 C:DRS/EB2

NAME THartman MLangelier VGaddy RDeese TFarnholtz SGraves

SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/

DATE 8/8/16 8/8/16 8/1/2016 8/1/2016 8/1/2016 8/1/2016

OFFICE C:DRS/IPAT SRI:DRS/EB2 SRI:DRP/D TL:ACES D:DRP C:DRP/B

NAME THipschman JDrake JJosey JKramer TWPruett NTaylor

SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA DProulx

Acting, for/

DATE 8/1/2016 8/5/16 8/9/16 8/3/2016 8/12/16 8/12/16

Letter to Fadi Diya from Nicholas H. Taylor August 12, 2016

SUBJECT: CALLAWAY PLANT - NRC INTEGRATED INSPECTION

REPORT 05000483/2016002 AND NOTICE OF VIOLATION

DISTRIBUTION:

Regional Administrator (Kriss.Kennedy@nrc.gov)

Deputy Regional Administrator (Scott.Morris@nrc.gov)

DRP Director (Troy.Pruett@nrc.gov)

DRP Deputy Director (Ryan.Lantz@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

DRS Deputy Director (Jeff.Clark@nrc.gov)

Senior Resident Inspector (Thomas.Hartman@nrc.gov)

Resident Inspector (Michael.Langelier@nrc.gov)

Branch Chief, DRP/B (Nick.Taylor@nrc.gov)

Senior Project Engineer, DRP/B (David.Proulx@nrc.gov)

Project Engineer, DRP/B (Steven.Janicki@nrc.gov)

Administrative Assistant (Dawn.Yancey@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Project Manager (John.Klos@nrc.gov)

Team Leader, DRS/TSS (Thomas.Hipschman@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

RIV Congressional Affairs Officer (Angel.Moreno@nrc.gov)

RIV/ETA: OEDO (Jeremy.Bowen@nrc.gov)

RIV RSLO (Bill.Maier@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

ROPreports.Resource@nrc.gov

ROPassessment.Resource@nrc.gov

NOTICE OF VIOLATION

Union Electric Company Docket No. 50-483

Callaway Plant License No. NPF-30

During an NRC inspection conducted June 6-30, 2016, a violation of NRC requirements was

identified. In accordance with the NRC Enforcement Policy, the violation is listed below:

10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that

conditions adverse to quality are promptly identified and corrected.

Contrary to the above, from November 2010 through June 2016, the licensee failed to

promptly correct a condition adverse to quality. Specifically, the licensee failed to

adequately resolve water hammer and corrosion issues which were previously identified

by the NRC as non-cited violation 05000483/2010006-01. The failure to resolve these

issues resulted in subsequent safety-related equipment failures.

This violation is associated with a Green Significance Determination Process finding.

Pursuant to the provisions of 10 CFR 2.201, Union Electric Company is hereby required to

submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001 with a copy to the Regional

Administrator, Region IV, 1600 East Lamar Blvd., Arlington, Texas 76011-4511 and a copy to

the NRC Senior Resident Inspector at the facility that is the subject of this Notice, within 30 days

of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly

marked as a Reply to a Notice of Violation, and should include: (1) the reason for the

violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective

steps that have been taken and the results achieved, (3) the corrective steps that will be taken,

and (4) the date when full compliance will be achieved. Your response may reference or

include previous docketed correspondence if the correspondence adequately addresses the

required response. If an adequate reply is not received within the time specified in this Notice,

an order or a Demand for Information may be issued as to why the license should not be

modified, suspended, or revoked, or why such other action as may be proper should not be

taken. Where good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response, with

the basis for your denial, to the Director, Office of Enforcement, United States Nuclear

Regulatory Commission, Washington, DC 20555-0001.

Because your response will be made available electronically for public inspection in the NRC

Public Document Room or from the NRCs Agencywide Documents Access and Management

System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-

rm/adams.html, to the extent possible, it should not include any personal privacy, proprietary, or

safeguards information so that it can be made available to the public without redaction. If

personal privacy or proprietary information is necessary to provide an acceptable response,

then please provide a bracketed copy of your response that identifies the information that

should be protected and a redacted copy of your response that deletes such information. If you

request withholding of such material, you must specifically identify the portions of your response

that you seek to have withheld and provide in detail the bases for your claim of withholding

(e.g., explain why the disclosure of information will create an unwarranted invasion of personal

privacy or provide the information required by 10 CFR 2.390(b) to support a request for

-1- Enclosure 1

withholding confidential commercial or financial information). If safeguards information is

necessary to provide an acceptable response, please provide the level of protection described

in 10 CFR 73.21.

In accordance with 10 CFR 19.11, you may be required to post this Notice within two working

days of receipt.

Dated this 12th day of August 2016

-2-

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000483

License: NPF-30

Report: 05000483/2016002

Licensee: Union Electric Company

Facility: Callaway Plant

Location: Junction Highway CC and Highway O

Steedman, MO

Dates: April1 through June 30, 2016

Inspectors: T. Hartman, Senior Resident Inspector

M. Langelier, P.E., Resident Inspector

J. Drake, Senior Reactor Inspector

P. Hernandez, Health Physicist

J. Josey, Senior Resident Inspector, Comanche Peak

R. Kopriva, Senior Reactor Inspector

J. ODonnell, Health Physicist

Approved By: Nicholas H. Taylor

Chief, Project Branch B

Division of Reactor Projects

-1- Enclosure 2

SUMMARY

IR 05000483/2016002; 04/01/2016 - 06/30/2016; Callaway Plant, Equipment Alignment, Heat

Sink Performance, Operability Determinations and Functionality Assessments, Problem

Identification and Resolution, Follow-up of Events and Notices of Enforcement Discretion.

The inspection activities described in this report were performed between April 1 and June 30,

2016, by the resident inspectors at the Callaway Plant and inspectors from the NRCs Region IV

office. Five findings of very low safety significance (Green) are documented in this report. Four

of these findings involved violations of NRC requirements. The significance of inspection

findings is indicated by their color (Green, White, Yellow, or Red), which is determined using

Inspection Manual Chapter 0609, Significance Determination Process. Their cross-cutting

aspects are determined using Inspection Manual Chapter 0310, Aspects within the

Cross-Cutting Areas. Violations of NRC requirements are dispositioned in accordance with the

NRC Enforcement Policy. The NRCs program for overseeing the safe operation of commercial

nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

Cornerstone: Initiating Events

Green. The inspectors reviewed a self-revealed finding for the licensees failure to follow

the plant procedure for foreign material exclusion. Specifically, after finding foreign material

(broken cable ties) within the main generator excitation transformer, established as a foreign

material exclusion Level 2 area, the licensee failed to determine the reason for the foreign

material and enter the issue into the corrective action program for resolution as required by

Procedure APA-ZZ-00801, Foreign Material Exclusion, Revision 32.

The licensees failure to follow the plant procedure for foreign material exclusion was a

performance deficiency. The performance deficiency is more than minor, and therefore a

finding, because it is associated with the equipment performance attribute of the Initiating

Events Cornerstone and adversely affected the cornerstone objective to limit the likelihood

of events that upset plant stability and challenge critical safety functions during shutdown as

well as power operations. Specifically, after identifying several broken cable ties on the floor

inside a foreign material exclusion Level 2 area the licensee did not determine the reason

for the foreign material nor enter the condition into the corrective action program as required

by Procedure APA-ZZ-00801. Because the licensee failed to understand what caused the

cable tie degradation, a subsequent cable tie failure resulted in a plant trip. Using

Inspection Manual Chapter 0609, Appendix A, The Significance Determination

Process (SDP) for Findings At-Power, dated June 19, 2012, the finding was determined to

be of very low safety significance because it did not cause a reactor trip and the loss of

mitigation equipment relied upon to transition the plant from the onset of the trip to a stable

shutdown condition. This finding has a cross-cutting aspect of training in the human

performance area because the organization did not provide training and ensure knowledge

transfer to maintain a knowledgeable, technically competent workforce and instill nuclear

safety values. Specifically, several groups within the licensees organization were unaware

the excitation transformer cabinet was classified as a foreign material exclusion Level 2 area

nor the requirements if foreign material is found within the foreign material exclusion area

[H.9]. (Section 4OA3)

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Cornerstone: Mitigating Systems

Green. The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B,

Criterion III, Design Control, for the licensees failure to account for the essential service

water pipe stresses caused by pressure fluctuations of the known column closure water

hammer phenomenon. The licensee failed to properly account for essential service water

piping membrane stress and impact loads as required by the 1974 ASME Code,Section III,

paragraphs ND-3112.4 and ND-3111. Specifically, the licensees design calculations for the

essential service water system did not account for the pressure fluctuations caused by a

known column closure water hammer phenomenon that occurs during a loss of off-site

power or load sequencer testing. The licensee completed a prompt operability

determination assuring the system was operable under the current conditions and was

completing engineering evaluations of the data collected to demonstrate the operability of

the system under design conditions. The licensee entered this issued into the corrective

action program as Callaway Action Requests 201603472 and 201603819.

The inspectors determined that the licensees failure to account for the pressure fluctuations

caused by a known column closure water hammer phenomenon in the design calculations

for the essential service water system was a performance deficiency. The performance

deficiency is more than minor, and therefore a finding, because it is associated with the

design control attribute of the Mitigating Systems Cornerstone and adversely affected the

associated objective to ensure availability, reliability, and capability of systems that respond

to initiating events to prevent undesirable consequences. Using Inspection Manual

Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings

At-Power, dated June 19, 2012, inspectors determined that this finding was of very low

safety significance (Green) because the finding: (1) was not a deficiency affecting the

design and qualification of a mitigating structure, system, or component, and did not result in

a loss of operability or functionality, (2) did not represent a loss of system and/or function,

(3) did not represent an actual loss of function of at least a single train for longer than its

allowed outage time, or two separate safety systems out-of-service for longer than their

technical specification allowed outage time, and (4) does not represent an actual loss of

function of one or more non-technical specification trains of equipment designated as high

safety significant for greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in accordance with the licensees maintenance

rule program. This finding has a cross-cutting aspect of conservative bias in the human

performance area because the licensee failed to demonstrate that a proposed action was

safe in order to proceed, rather than unsafe in order to stop. Specifically, when the licensee

recognized that the column separation water hammer phenomenon was occurring in the

essential service water system, they only applied the forces to the containment coolers, not

the entire system [H.14]. (Section 1R04)

Green. The inspectors identified a non-cited violation of 10 CFR 50.55a, Codes and

Standards, for the licensees failure to repair various ASME Code Class 3 components in

accordance with ASME Code,Section XI requirements. Specifically, the licensee did not

follow the applicable ASME Code requirements when making repairs to various components

in the ASME Code Class 3 essential service water system. The licensee reasonably

determined the essential service water system remained operable, and completed the

necessary repairs and testing to restore compliance with ASME Code. The licensee

entered this issue into their corrective action program as Callaway Action

Requests 201603640 and 201604282.

-3-

The inspectors determined that the programmatic failure to repair various ASME Code

Class 3 components in the essential service water system in accordance with ASME Code

was a performance deficiency. The performance deficiency is more than minor, and

therefore a finding, because it is associated with the design control attribute of the Mitigating

Systems cornerstone and adversely affected the associated objective to ensure availability,

reliability, and capability of systems that respond to initiating events to prevent undesirable

consequences. Using Inspection Manual Chapter 0609, Appendix A, The Significance

Determination Process (SDP) for Findings At-Power, dated June 19, 2012, inspectors

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

(1) was not a deficiency affecting the design and qualification of a mitigating structure,

system, or component, and did not result in a loss of operability or functionality, (2) did not

represent a loss of system and/or function, (3) did not represent an actual loss of function of

at least a single train for longer than its allowed outage time, or two separate safety systems

out-of-service for longer than their technical specification allowed outage time, and (4) does

not represent an actual loss of function of one or more non-technical specification trains of

equipment designated as high safety significant for greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in accordance with

the licensees maintenance rule program. Specifically, the licensee performed a historical

system health review and reasonably determined the essential service water system

remained operable because periodic system walkdowns by the system owner and shiftly

rounds by operations had not identified significant system leaks, and the appropriate repairs

and testing were completed on the affected components. This finding has a cross-cutting

aspect of training in the human performance area because the organization did not provide

training and ensure knowledge transfer to maintain a knowledgeable, technically competent

workforce and instill nuclear safety values. Specifically, the licensee failed to ensure training

of the personnel was adequate to recognize that the repair of the leaks constituted repairs in

accordance with ASME Code,Section XI and thus failed to include the necessary ASME

testing requirements in the work performance packages to ensure adequate performance of

an activity which affected testing of a safety-related modification/repair to risk-significant

systems, and thereby ensure nuclear safety [H.9]. (Section 1R07)

Green. The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B,

Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to perform an

adequate operability assessment when a degraded or nonconforming condition was

identified. Specifically, after the licensee identified that a severe water hammer transient

would occur following a loss of off-site power, the licensee generated an operability

evaluation that relied on judgement and inaccurate information which failed to establish a

reasonable expectation of operability. Following questions from inspectors the licensee

determined that this judgement was not correct and performed a new evaluation to ensure

operability of the essential service water system. The licensee entered this issue into their

corrective action program as Callaway Action Request 201605488.

The licensees failure to properly assess and document the basis for operability when a

severe water hammer occurred in the essential service water system was a performance

deficiency. The performance deficiency is more than minor, and therefore a finding,

because it is associated with the equipment performance attribute of the Mitigating Systems

Cornerstone and adversely affected the cornerstone objective to ensure availability,

reliability, and capability of systems that respond to initiating events to prevent undesirable

consequences. Specifically, severe water hammer transients in the essential service water

system due to a loss of off-site power, result in a condition where structures, systems, and

components necessary to mitigate the effects of accidents may not have functioned as

required. Using Inspection Manual Chapter 0609, Appendix A, The Significance

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Determination Process (SDP) for Findings At-Power, dated June 19, 2012, inspectors

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

did not involve the loss or degradation of equipment or function specifically designed to

mitigate a seismic event, and (1) was not a deficiency affecting the design and qualification

of a mitigating structure, system, or component, and did not result in a loss of operability or

functionality, (2) did not represent a loss of system and/or function, (3) did not represent an

actual loss of function of at least a single train for longer than its allowed outage time, or two

separate safety systems out-of-service for longer than their technical specification allowed

outage time, and (4) does not represent an actual loss of function of one or more

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

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

finding has a cross-cutting aspect of conservative bias in the human performance area

because the licensee failed to demonstrate that a proposed action was safe in order to

proceed, rather than unsafe in order to stop. Specifically, the licensees use of unsupported

judgement and incorrect data resulted in an evaluation that failed to demonstrate a

reasonable expectation of operability [H.14]. (Section 1R15)

Green. The inspectors identified a cited violation of 10 CFR Part 50, Appendix B,

Criterion XVI, Corrective Action, associated with the licensees failure to take timely

corrective action for a previously identified condition adverse to quality. Specifically, the

licensee failed to adequately resolve water hammer and corrosion issues that were

previously identified by the NRC as non-cited violation 05000483/2010006-01 and the failure

to resolve these issues resulted in subsequent safety-related equipment failures. The

licensee performed an operability determination that established a reasonable expectation

of operability pending implementation of corrective actions. The licensee entered this issue

into their corrective action program as Callaway Action Request 201604440.

The licensees failure to take timely and adequate corrective actions to correct a condition

adverse to quality was a performance deficiency. The performance deficiency is more than

minor, and therefore a finding, because it is associated with the equipment performance

attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone

objective to ensure availability, reliability, and capability of systems that respond to initiating

events to prevent undesirable consequences. Specifically, the failure to correct water

hammer and corrosion issue resulted in the licensee declaring safety-related room coolers

and chillers inoperable until an analysis of system operability was completed. This affected

their capability to respond to initiating events to prevent undesirable consequences Using

Inspection Manual Chapter 0609, Appendix A, The Significance Determination

Process (SDP) for Findings At-Power, dated June 19, 2012, inspectors determined that this

finding was of very low safety significance (Green) because the finding: (1) was not a

deficiency affecting the design and qualification of a mitigating structure, system, or

component, and did not result in a loss of operability or functionality, (2) did not represent a

loss of system and/or function, (3) did not represent an actual loss of function of at least a

single train for longer than its allowed outage time, or two separate safety systems out-of-

service for longer than their technical specification allowed outage time, and (4) does not

represent an actual loss of function of one or more non-technical specification trains of

equipment designated as high safety-significant for greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in accordance

with the licensees maintenance rule program. This finding has a cross-cutting aspect of

resources in the human performance area because the licensee did not ensure that

personnel, equipment, procedures, and other resources were available and adequate to

support nuclear safety. Specifically, by failing to address water hammer and corrosion

issues, station management failed to ensure that the essential service water system was

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available and adequately maintained to respond during a loss of off-site power event [H.1].

(Section 4OA2.3)

-6-

PLANT STATUS

Callaway began the inspection period at 86 percent power while coasting down at the end of the

operating cycle and on April 2, 2016, the licensee shut the plant down to start Refueling

Outage 21. The reactor was restarted on May 9. On May 14, at approximately 90 percent

power (during power ascension), the plant reduced power to approximately 65 percent to

address a main feedwater pump issue. The licensee repaired the feedwater pump on May 15

and recommenced power ascension. The plant returned to 100 percent power on May 16. The

plant remained at full power for the remainder of the inspection period.

REPORT DETAILS

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection (71111.01)

.1 Summer Readiness for Off-site and Alternate AC Power Systems

a. Inspection Scope

On June 7, 2016, the inspectors completed an inspection of the stations off-site and

alternate-ac power systems. The inspectors inspected the material condition of these

systems, including transformers and other switchyard equipment to verify that plant

features and procedures were appropriate for operation and continued availability of

off-site and alternate-ac power systems. The inspectors reviewed outstanding work

orders and open Callaway action requests for these systems. The inspectors walked

down the switchyard to observe the material condition of equipment providing off-site

power sources.

The inspectors verified that the licensees procedures included appropriate measures to

monitor and maintain availability and reliability of the off-site and alternate-ac power

systems.

These activities constituted one sample of summer readiness of off-site and alternate-ac

power systems, as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

.2 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

On April 26, 2016, the inspectors completed an inspection of the stations readiness for

impending adverse weather conditions. The inspectors reviewed plant design features,

the licensees procedures to respond to severe weather including thunderstorms,

tornadoes and high winds, and the licensees implementation of these procedures. The

inspectors evaluated operator staffing and accessibility of controls and indications for

those systems required to control the plant.

-7-

These activities constituted one sample of readiness for impending adverse weather

conditions, as defined in Inspection Procedure 71111.01

b. Findings

No findings were identified.

1R04 Equipment Alignment (71111.04)

Partial Walk-Down

a. Inspection Scope

The inspectors performed partial system walk-downs of the following risk-significant

systems:

May 24, 2016, train A motor-driven auxiliary feedwater system

June 2, 2016, train B class 1E switchgear

June 8, 2016, train A essential service water

June 9, 2016, train B essential service water

The inspectors reviewed the licensees procedures and system design information to

determine the correct lineup for the systems. They visually verified that critical portions

of the trains were correctly aligned for the existing plant configuration.

These activities constituted four partial system walk-down samples as defined in

Inspection Procedure 71111.04.

b. Findings

Introduction. The inspectors identified a Green non-cited violation of 10 CFR Part 50,

Appendix B, Criterion III, Design Control, for the licensees failure to account for the

essential service water pipe stresses caused by pressure fluctuations of the known

column closure water hammer phenomenon.

Description. With the current essential service water system design, every loss of

off-site power at Callaway would result in a water column separation and subsequent

re-pressurization by the loss of normal service water pumps and the sequencing start of

the essential service water pumps. This phenomenon was not specifically described in

the licensees Updated Final Safety Analysis Report, however, it had been clearly

identified in previous Callaway Action Requests 199800739, 199800740, 199800741,

200207750, 200404532, 200703197, 200703247, 200703257, 200703491, 200810348,

200810384, 200811050, 201003386, 201109846, 201303346, 201303370, 201303451,

201303502, 201303702, 201303736, 201407222, 201407245, 201407246, 201407248,

201602824, 201603472, 201603484, 201604058, and 201604063. This system

characteristic was also described in Callaways response to NRC Generic Letter 96-06,

Assurance of Equipment Operability and Containment Integrity during Design-Basis

Accident Conditions, January 28, 1997. Additionally, there was external operating

experience concerning water hammer phenomena and the impact on system piping.

-8-

Callaway is designed to ASME Code,Section III Nuclear Power Components, 1974

and 1974 winter addenda and ANSI B31.1 1973 piping code including the 1973 summer

addendum. Piping analyses are performed to ensure that design Class II and III piping

systems perform their safety-related functions during plant normal, upset, and faulted

conditions. Pipes are subject to various loading conditions like pressures, dead load,

thermal, earthquake, and seismic/thermal anchor motions. The 1974 ASME Code,

Section III, paragraph ND-3112.4, Design Allowable Stress Values, part c states, in

part,

The wall thickness of a component computed by these rules shall be

determined so that the maximum direct membrane stress due to any

combination of loadings that are expected to occur simultaneously does

not exceed the maximum allowable stress permitted at the temperature

that is expected to be maintained in the metal under the condition of

loading being considered.

Section III, paragraph ND-3111, Loading Criteria, of the ASME Code, states in part,

The loading that shall be taken into account in designing a component shall include, but

are not limited to, the following: (b) Impact loads, including rapidly fluctuating

pressures.

Calculation 0096-020-CALC-01, Revision 0, Callaway Water Hammer Load

Calculation, Section 2.0 states in part,

... both Wolf Creek and Callaway are SNUPPS plants, many similarities

exist. This calculation compares the conditions which can affect the

impact velocity and the amount of air in the system, and adjusts the

results from the Wolf Creek pressure vs. time data to account for those

differences.

Even though Callaway recognized the similarities between Wolf Creek and their unit,

they failed to reevaluate their essential service water when Wolf Creek recognized that

their initial assumptions regarding water hammer phenomena were incorrect.

WCN005-PR-0, a report from ENERCON, which addressed water hammer phenomena

in the essential service water system, stated on page 6,

The results shown in the Table in Section 5.1 of the ALTRAN

Report 96225-TR02 were evaluated by an ENERCON structural expert.

His opinion was that the loads shown were significant enough in every

case to warrant further detailed analysis. This analysis requires the

generation of a detailed FTH (Force Time History) that would result from

the CCWH (column closure water hammer) generated in the ESW

(essential service water) for a LOOP (loss of off-site power) event. The

report recommended that these FTHs would then be evaluated using a

structural piping program and the results added to the existing stresses.

Ultimately a new stress analysis of record would be generated. This

would be a revision of the existing one. Modifications to supports may be

required to qualify the system.

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The analysis later stated, To perform the reanalysis for the startup of the ESW pumps

following a LOOP requires that Force Time Histories (FTH) be generated. These are

required for the structural analysis.

The ALTRAN report referenced by ENERCON was report number 09-0223-TR-001,

Revision 0. This report, on page 6 of 14, stated in part, The water hammer pressures

calculated are to be used for preliminary structural assessment of the piping systems

ability to withstand this loading and to determine if a more detailed force time history

needs to be generated. On page 7 the report continued, Experience has shown that

the concerns resulting from water hammer events are: (1) Over-pressure of pipes and

components, e.g., ruptured tubes in heat exchangers, and (2) Pipe and component

nozzle stress due to bending moments created by the CCWH force time history (FTH).

Despite the internal and external operating experience, the licensee only updated the

design calculation for the containment coolers to include the pressures associated with

the water hammer phenomena, but did not included these stresses in the design

calculations for the remainder of the essential service water system. The basic

engineering disposition written to address the potential effects of water hammer impact

loads on the structural integrity of the pressure boundary did not include the pressure

stresses induced in the pipe due to the water hammer phenomenon. It stated, in part,

This Basic Engineering Disposition is to document that the potential

effects of water hammer impact loads on the structural integrity of the

pressure boundary have been evaluated for piping affected by pitting

corrosion. Because water hammer pressure waves are of short duration

and are self-limiting (secondary) loads, assuring that the pitted pipe

meets ASME Boiler and Pressure Vessel Code (Code) requirements for

design loads is sufficient to conclude that the pressure boundary has

sufficient margin to withstand impact from water hammer.

This engineering evaluation failed to meet the requirements of ASME Code Section III,

paragraph ND-3111, Loading Criteria,, which states in part, The loading that shall be

taken into account in designing a component shall include, but are not limited to, the

following: ... (b) Impact loads, including rapidly fluctuating pressures. In addition,

operating experience at Callaway has consistently demonstrated that the pressure

boundary lacks sufficient margin to withstand the impact from the water hammer as

documented in the multiple Callaway action requests concerning system leaks after a

water hammer event has occurred.

Although this was a deficiency affecting the design and qualification of the essential

service water system, the licensee was able to demonstrate that the operability and

function of the essential service water system had not been lost because the leaks that

occurred were less than the allowable losses from the ultimate heat sink. The spray

from the leaks did not adversely impact any other equipment, and the components

affected maintained structural integrity.

Analysis. The inspectors determined that the licensees failure to account for the

pressure fluctuations caused by a known column closure water hammer phenomenon in

the design calculations for the essential service water system was a performance

deficiency. The performance deficiency is more than minor, and therefore a finding,

because it is associated with the design control attribute of the Mitigating Systems

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Cornerstone and adversely affected the associated objective to ensure availability,

reliability, and capability of systems that respond to initiating events to prevent

undesirable consequences.

Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination

Process (SDP) for Findings At-Power, dated June 19, 2012, inspectors determined that

this finding was of very low safety significance (Green) because the finding: (1) was not

a deficiency affecting the design and qualification of a mitigating structure, system, or

component, and did not result in a loss of operability or functionality, (2) did not

represent a loss of system and/or function, (3) did not represent an actual loss of

function of at least a single train for longer than its allowed outage time, or two separate

safety systems out-of-service for longer than their technical specification allowed outage

time, and (4) does not represent an actual loss of function of one or more non-technical

specification trains of equipment designated as high safety significant for greater

than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in accordance with the licensees maintenance rule program. This finding

has a cross-cutting aspect of conservative bias in the human performance area because

the licensee failed to demonstrate that a proposed action was safe in order to proceed,

rather than unsafe in order to stop. Specifically, when the licensee recognized that the

column separation water hammer phenomenon was occurring in the essential service

water system, they only applied the forces to the containment coolers, not the entire

system [H.14].

Enforcement. Title 10 CFR Part 50 Appendix B, Criterion III, Design Control, states, in

part, that for those structures, systems and components to which this appendix applies,

design control measures shall provide for verifying or checking the adequacy of designs.

Contrary to the above, from June 4, 1985, to the present, for the safety-related essential

service water system, to which 10 CFR Part 50 applies, the licensee failed to provide for

verifying or checking the adequacy of designs. Specifically, the licensee did not include

the pressures induced by the water hammer phenomenon in the design calculation for

the essential service water system as required by the 1974 ASME Code, which the

licensee is committed to follow. The licensee performed a historical system health

review and reasonably determined the essential service water system remained

operable because periodic system walkdowns by the system owner and shiftly rounds by

operations had not identified significant system leaks, and the appropriate repairs and

testing were completed on the affected components. In addition, the licensee conducted

an instrumented run of the system simulating a loss of off-site power and collected data

on the pressure spikes experienced by the system. Following the completion of the test

the licensee conducted a system walkdown to inspection for indications of damage to

the system. Based on the results of this evolution, the licensee completed a prompt

operability determination assuring the system was operable under the current conditions,

and was completing engineering evaluations of the data collected to demonstrate the

operability of the system under design conditions. This violation is being treated as a

non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy because it

was of very low safety significance, and was entered into the licensees corrective action

program as Callaway Action Requests 201603472 and 201603819:

NCV 05000483/2016002-01, Failure to Account for Water Hammer Stresses in

Essential Service Water System Calculations.

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1R05 Fire Protection (71111.05)

Quarterly Inspection

a. Inspection Scope

The inspectors evaluated the licensees fire protection program for operational status

and material condition. The inspectors focused their inspection on five plant areas

important to safety:

May 12, 2016, train B battery and switchboard rooms (C-15)

June 2, 2016, train A electrical penetration room (A-18)

June 3, 2016, boric acid tank rooms (A-3)

June 9, 2016, train A control room air conditioning room (A-22)

June 9, 2016, train A battery and switchboard rooms (C-16)

For each area, the inspectors evaluated the fire plan against defined hazards and

defense-in-depth features in the licensees fire protection program. The inspectors

evaluated control of transient combustibles and ignition sources, fire detection and

suppression systems, manual firefighting equipment and capability, passive fire

protection features, and compensatory measures for degraded conditions.

These activities constituted five quarterly inspection samples, as defined in Inspection

Procedure 71111.05.

b. Findings

No findings were identified.

1R07 Heat Sink Performance (71111.07)

a. Inspection Scope

The inspectors completed an inspection of the readiness and availability of

risk-significant heat exchangers. The inspectors verified the licensee used the industry

standard periodic maintenance method outlined in EPRI NP-7552 for the heat

exchangers. Additionally, the inspectors walked down the heat exchangers to observe

the performance and material condition and/or verified that the heat exchangers were

correctly categorized under the Maintenance Rule and were receiving the required

maintenance.

April 3, 2016, emergency core cooling system room coolers

June 9, 2016, control room chillers

These activities constituted completion of two heat sink performance annual review

samples, as defined in Inspection Procedure 71111.07.

b. Findings

Introduction. The inspectors identified a Green non-cited violation of 10 CFR 50.55a,

Codes and Standards, for the licensees failure to repair various ASME Code Class 3

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components in accordance with ASME Code,Section XI requirements. Specifically, the

licensee did not follow the applicable ASME Code requirements when making repairs to

various components in the ASME Code Class 3 essential service water system.

Description. The inspectors identified a programmatic issue with the licensees inservice

inspection and repair program because the engineering department personnel lacked

adequate training and knowledge of the ASME Code to recognize activities that

constituted repair activities per ASME Section XI. Specifically, the licensee had been

repairing leaking tubes on various ASME Code Class 3 room coolers (SGL09B - B

Safety Injection Pump Room Cooler, SGL10A - A Residual Heat Removal Pump Room

Cooler, SGL10B - B Residual Heat Removal Pump Room Cooler, and SGL13B - B

Containment Spray Pump Room Cooler) as a simple maintenance evolution, and failed

to recognized that this constituted a repair activity per ASME Code,Section XI. The

maintenance activities of concern were repairs to plug tube leaks which consisted of

cutting a tube in order to remove a defect (pinhole), then mechanically installing (no

brazing or welding) a Swagelok cap to plug the tube. Use of Swagelok caps to repair

heat exchanger tube leaks is allowed by ASME Code and licensee procedures. These

jobs were planned and performed as a maintenance activity in accordance with

applicable licensee procedures.

Callaway is currently committed to the 2007 Edition/2008 Addenda of ASME Code,

Section XI. ASME Code,Section XI, IWA-4120(b)(7) exempts ASME Class 2 and 3

mechanical tube plugging; however, the repairs to these components are considered an

ASME Code,Section XI Repair/Replacement Activity. Per footnote 1 in IWA-4110

alterations are considered a repair/replacement activity per Section XI of ASME Code.

This is because the tubes that had the Swagelok fittings installed still see system

pressure: flow through the tube was not isolated. Therefore, the pressure boundary

was altered and the licensee is required to ensure it meets the requirements for ASME

Code Class 3 pressure boundaries.

The physical work that was performed met the requirements of Section XI.

Safety-related Swagelok caps were installed and ASME Code,Section III (the

construction code) sections ND-3646 and ND-3674.1(e) allow the use of caps, so the

repairs met the applicable construction code requirements.

The licensee did not consider the work as a repair activity per ASME Code,Section XI,

therefore, requirements were not documented in the work packages and were not

completed. These requirements were:

ANII notification

Traceability of code pressure retaining parts

Performance of required pressure test - VT-2

The licensee documented these deficiencies under Callaway Action

Request 201603640, verified and documented the use of code pressure retaining parts,

and completed the required VT-2 pressure tests to correct these issues.

The repair performed on SGL13A (Containment Spray Pump A Room Cooler) utilized

brazing to build up base metal of a pinhole leak. This resulted in a repair that was not an

approved method by the ASME Code,Section XI. To correct this condition, the licensee

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generated Job 16002356-500, "Repair Tubing that was Improperly Repaired under

Job 10506915."

This job was completed in accordance with ASME Code requirements and a successful

VT-2 was performed. In addition, the engineering department received training on

ASME Code repair recognition and requirements.

Analysis. The inspectors determined that the programmatic failure to repair various

ASME Code Class 3 components in the essential service water system in accordance

with ASME Code was a performance deficiency. The performance deficiency is more

than minor, and therefore a finding, because it is associated with the design control

attribute of the Mitigating Systems cornerstone and adversely affected the associated

objective to ensure availability, reliability, and capability of systems that respond to

initiating events to prevent undesirable consequences.