IR 05000483/2015004

NRC Integrated Inspection Report 05000483/2015004

ML16043A051
Person / Time
Site:	Callaway
Issue date:	02/11/2016
From:	Nick Taylor NRC/RGN-IV/DRP/RPB-B
To:	Diya F Union Electric Co
Taylor N
References
IR 2015004
Download: ML16043A051 (50)

Text

UNITED STATES ary 11, 2016

SUBJECT:

CALLAWAY PLANT - NRC INTEGRATED INSPECTION REPORT 05000483/2015004

Dear Mr. Diya,

On December 31, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Callaway Plant. On January 11, 2015, the NRC inspectors discussed the results of this inspection with Mr. Tim E. Herrmann, Site Vice President, and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.

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

Two of these findings involved violations of NRC requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the NRC Enforcement Policy.

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

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) 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/

Nicholas H. Taylor, Branch Chief Project Branch B Division of Reactor Projects Docket No. 50-483 License No. NPF-30 Enclosure:

Inspection Report 05000483/2015004 w/Attachments:

1. Supplemental Information 2. Request for Information

ML16043A051 SUNSI Review ADAMS Non- Publicly Available Keyword:

By: NHT Yes No Sensitive Non-Publicly Available NRC-002 Sensitive OFFICE SRI/DRP/B RI/DRP/B C:DRS/PSB1 C:DRS/PSB C:DRS/EB1 C:DRS/EB2

NAME THartman MLangelier MHaire HGepford TFarnholtz GWerner SIGNATURE /RA/E- /RA/E- /RA/DHolman, /RA/ /RA/ /RA/

for DATE 2/11/16 2/9/16 1/29/16 1/29/16 1/28/16 1/29/16 OFFICE ATL/DRS/IPAT C/DRS/OB C/DRP/B NAME THipschman VGaddy NTaylor SIGNATURE /RA/ /RA/ /RA/

DATE 2/1/16 2/1/16 2/11/16

Letter to Fadi Diya from Nicholas H. Taylor dated February 11, 2016 SUBJECT: CALLAWAY PLANT - NRC INTEGRATED INSPECTION REPORT 05000483/2015004 DISTRIBUTION:

Regional Administrator (Marc.Dapas@nrc.gov)

Deputy Regional Administrator (Kriss.Kennedy@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 (Shawn.Money@nrc.gov)

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

CWY 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)

OEWEB Resource (OEWEB.Resource@nrc.gov)

OEWEB Resource (Sue.Bogle@nrc.gov)

RIV/ETA: OEDO (Raj.Iyengar@nrc.gov)

ROPreports (ROPreports.Resource@nrc.gov)

ROPAssessments (ROPassessment.Resource@nrc.gov)

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000483 License: NPF-30 Report: 05000483/2015003 Licensee: Union Electric Company Facility: Callaway Plant Location: Junction Highway CC and Highway O Steedman, MO Dates: September 20 through December 31, 2015 Inspectors: T. Hartman, Senior Resident Inspector M. Langelier, P.E., Resident Inspector P. Hernandez, Health Physicist J. ODonnell, CHP, Health Physicist Approved By: Nicholas H. Taylor Chief, Project Branch B Division of Reactor Projects-1- Enclosure

SUMMARY

IR 05000483/2015004; 09/20/2015 - 12/31/2015; Callaway Plant, Integrated Inspection Report;

Maintenance Effectiveness and Identification and Resolution of Problems The inspection activities described in this report were performed between September 20 and December 31, 2015, by the resident inspectors at the Callaway Plant and inspectors from the NRCs Region IV office. Three findings of very low safety significance (Green) are documented in this report. Two 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-revealing finding for the licensees failure to follow plant procedures for the unit reliability team. Specifically, after delaying a modification to the plants turbine control system, no compensatory measures were implemented to minimize or prevent failure of the system due to aging of the system beyond its evaluated service life as required by plant Procedure APA-ZZ-00549, Appendix E, Unit Reliability Team Operations.

The licensees failure to follow the plant procedure for the unit reliability team 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, as no compensatory measures were implemented after the digital upgrade to the turbine control system was deferred from the spring 2013 refueling outage to the spring 2016 refueling outage, the turbine control system malfunctioned causing a runback of the turbine and downpower transient on the plant.

Using Inspection Manual Chapter 0609, Appendix A, Exhibit 1, Initiating Events Screening Questions, 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 in the teamwork component of the human performance cross-cutting area because the licensee did not ensure that individuals and work groups communicate across organizational boundaries to ensure nuclear safety is maintained. Specifically, the outage leadership team identified the need for the compensatory measures, but did not communicate the priority nor the effect on nuclear safety to site leadership to gain the resources needed to implement these measures [H.4].

(Section 4OA2.3)

Cornerstone: Barrier Integrity

Green.

The inspectors reviewed a self-revealing, non-cited violation of 10 CFR Part 50,

Appendix B, Criterion XVI, Corrective Action, for the licensees failure to correct a condition adverse to quality. Specifically, after identifying boric acid deposits on the flange downstream of valve BBV0400, a reactor coolant system boundary valve, the licensee did not promptly take action to stop the reactor coolant system leakage before it worsened and caused a plant shutdown due to reactor coolant system leakage in excess of technical specification limits. The immediate corrective action was to torque the valve and flange to reduce leakage to within limits. The licensee entered this issue into their corrective action program as Callaway Action Request 201505308.

The licensees failure to correct the condition adverse to quality (i.e. leakage past valve BBV0400) in a timely manner was a performance deficiency. The performance deficiency is more than minor, and therefore a finding, because it is associated with the reactor coolant system equipment and barrier performance attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events.

Specifically, the failure to correct the reactor coolant system leakage through valve BBV0400 resulted in reactor coolant system leakage worsening and exceeding technical specification limits, and a plant shutdown. Using Inspection Manual Chapter 0609,

Appendix A, Exhibit 1, Initiating Events Screening Questions, dated June 19, 2012, the finding was determined to be of very low safety significance because after a reasonable assessment of degradation, it could not: 1) result in exceeding the reactor coolant system leak rate for a small loss of coolant accident, or 2) have likely affected other systems used to mitigate a loss of coolant accident resulting in a total loss of their function. This finding has a cross-cutting aspect in the work management component of the human performance cross-cutting area because the licensee failed to implement a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority.

Specifically, the licensee initially planned to address the reactor coolant leakage six months after the issue was identified, and then moved it out an additional three months, failing to prioritize the work commensurate with its safety significance [H.5]. (Section 1R12.1)

Green.

The inspectors reviewed a self-revealing, non-cited violation of Technical Specification 5.4.1, Procedures, for the licensees failure to establish, implement, and maintain a procedure recommended in Regulatory Guide 1.33, Revision 2, Appendix A,

February 1978. Specifically, Procedure ODP-ZZ-00022, Operations Preparation,

Performance, and Restoration from Refueling Outages, did not provide adequate guidance to ensure a blind flange located on the reactor coolant system was properly reinstalled resulting in reactor coolant system leakage into containment. The immediate corrective action taken by the licensee was to replace the gasket with a Flexitallic gasket and torque the flange. Additionally, the licensee implemented repetitive maintenance tasks in their work management program to identify flanges removed during an outage and to torque them properly upon reinstallation. The licensee entered this issue into their corrective action program as Callaway Action Request 201505702.

The licensees failure to properly establish and maintain Procedure ODP-ZZ-00022 was a performance deficiency. The performance deficiency is more than minor, and therefore a finding, because it is associated with the procedure quality performance attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. Specifically, Procedure ODP-ZZ-00022, did not provide adequate guidance to ensure the blind flange located downstream of valve BBV0400 was properly reinstalled.

Using Inspection Manual Chapter 0609, Appendix A, Exhibit 1, Initiating Events Screening Questions, dated June 19, 2012, the finding was determined to be of very low safety significance because after a reasonable assessment of degradation, it could not: 1) result in exceeding the reactor coolant system leak rate for a small loss of coolant accident, or 2) have likely affected other systems used to mitigate a loss of coolant accident resulting in a total loss of their function. This finding does not have a cross-cutting aspect because the performance deficiency is not representative of current licensee performance, in that the inadequate instructions were added to the procedure in 2003. (Section 1R12.2)

PLANT STATUS

Callaway operated at 100 percent power for the duration of the inspection period with the exception of planned power reductions for routine surveillances and post-maintenance testing.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Readiness for Seasonal Extreme Weather Conditions - Cold Weather Preparations

a. Inspection Scope

On December 10, 2015, the inspectors completed an inspection of the stations readiness for seasonal extreme weather conditions. The inspectors reviewed the licensees adverse weather procedures for cold weather and evaluated the licensees implementation of these procedures. The inspectors verified that prior to the onset of cold weather, the licensee had corrected or plans to correct weather-related equipment deficiencies identified during the previous cold weather season.

The inspectors selected two risk-significant systems that were required to be protected from cold weather:

• refueling water storage tank

• ultimate heat sink The inspectors reviewed the licensees procedures and design information to ensure the systems would remain functional when challenged by cold weather. The inspectors verified that operator actions described in the licensees procedures were adequate to maintain readiness of these systems. The inspectors walked down portions of these systems to verify the physical condition of the cold weather protection features.

These activities constituted one sample of readiness for seasonal adverse weather, as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

.2 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

On November 12, 2015, 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 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.

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

Partial Walkdown

a. Inspection Scope

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

• October 8, 2015, train A emergency diesel generator

• October 29, 2015, train B centrifugal charging pump 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 two partial system walk-down samples as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

1R05 Fire Protection

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 four plant areas important to safety:

• September 29, 2015, train B emergency diesel generator building, fire area D-2

• October 9, 2015, auxiliary feedwater valve B and C compartment, fire area A-30

• December 15, 2015, auxiliary feedwater valve A and D compartment, fire area A-29

• December 15, 2015, train A mechanical penetration room, fire area A-24 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 four quarterly inspection samples, as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

a. Inspection Scope

After reviewing the licensees flooding analysis, the inspectors chose one plant area containing risk-significant structures, systems, and components that were susceptible to flooding. On December 17, 2015, the inspectors completed an inspection of auxiliary building, elevation 1974 level to evaluate the stations ability to mitigate flooding due to internal causes.

The inspectors reviewed plant design features and licensee procedures for coping with internal flooding. The inspectors walked down the selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether operator actions credited for flood mitigation could be successfully accomplished.

In addition, the inspectors selected one underground bunker that contained risk-significant or multiple-train cables whose failure could disable risk-significant equipment. On November 4, 2015, the inspectors completed an inspection of train A essential service water electrical manhole (MH01A), Job 14508112, underground bunkers susceptible to flooding.

The inspectors observed the material condition of the cables and splices contained in the bunkers and looked for evidence of cable degradation due to water intrusion. The inspectors verified that the cables and vaults met design requirements.

These activities constitute completion of one flood protection measures sample and one bunker/manhole sample, as defined in Inspection Procedure 71111.06.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On November 16, 2015, the inspectors observed an evaluated simulator scenario performed by an operating crew. The inspectors assessed the performance of the operators and the evaluators critique of their performance.

These activities constitute completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

During the period, the inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened activity due to the activities listed below. The inspectors observed the operators performance of the following activities:

• December 15, 2015, control room turnover with isolation of train B containment spray pump

• December 29, 2015, at power moderator temperature coefficient measurement In addition, the inspectors assessed the operators adherence to plant procedures, including Procedure ODP-ZZ-00001, Operations Department - Code of Conduct, and other operations department policies.

These activities constitute completion of one quarterly licensed operator performance sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed three instances of degraded performance or condition of safety-related structures, systems, and components:

• September 1, 2015, reactor coolant system leakage

• October 21, 2015, train B emergency diesel generator air start system leakage

• November 3, 2015, control building heating ventilation and air conditioning system returned to a(2) status The inspectors reviewed the extent of condition of possible common cause structure, system, or component failures and evaluated the adequacy of the licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the structures, systems and components. The inspectors assessed the licensees characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.

These activities constituted completion of two maintenance effectiveness samples, as defined in Inspection Procedure 71111.12.

1.

Introduction.

Inspectors reviewed a self-revealing Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to correct a condition adverse to quality. Specifically, after identifying boric acid deposits on the flange downstream of valve BBV0400, a reactor coolant system boundary, the licensee did not promptly take action to stop the reactor coolant system leakage before it worsened and caused a plant shutdown due to reactor coolant system leakage in excess of technical specification limits.

Description.

On November 29, 2014, during a plant walkdown, the licensee identified boric acid buildup on the bolted flange downstream of valve BBV0400, a drain valve located on the auxiliary spray header. The boric acid corrosion control program owner entered this into the boric acid corrosion control program database. On January 31, February 13, March 11, April 15, and May 21, 2015, the licensee performed follow-up walkdowns on this flange and identified additional boric acid buildup. The licensee entered this issue into their corrective action program on March 2, 2015, after the third identification of boric acid buildup on the flange.

On March 2, 2015, the licensee initiated Job 15001126 to clean the residue off the flange and stop the source of the boric acid leakage. The licensee initially planned to work the job on September 23, 2015. On May 27, 2015, due to questions with personnel safety, the licensee rescheduled the job to December 3, 2015, when the environment inside containment would be cooler.

On July 22, 2015, leakage at the flange located downstream of valve BBV0400 increased to a rate of 1.2 gallons per minute which is in excess of the requirements of Technical Specifications 3.4.13, RCS [Reactor Coolant System] Operational Leakage, for unidentified leakage. This required the licensee to shut down and cool down the plant to repair the leak.

After the reactor coolant system was depressurized to around 900 psig, the leakage slowed to approximately 90 drops per minute allowing the location of the leak to be determined. Upon investigation, it was determined that the gasket inside the BBV0400 downstream flange had failed allowing the reactor coolant system to vent directly through the valve to the containment atmosphere. The licensee torqued the valve BBV0400 handwheel to 140 ft-lbs gaining an additional one-quarter turn closed.

Upon torqueing the valve, the leakage slowed to around 60 drops per minute. The licensee removed the flange, replaced the gasket with a different material, reinstalled the flange, and torqued the flange to its nominal torque value, which stopped the leakage into containment.

Analysis.

The licensees failure to correct the condition adverse to quality (i.e., leakage past valve BBV0400) in a timely manner was a performance deficiency. The performance deficiency is more than minor, and therefore a finding, because it is associated with the reactor coolant system equipment and barrier performance attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. Specifically, the failure to correct the reactor coolant system leakage through valve BBV0400 resulted in the reactor coolant system leakage worsening and exceeding technical specification limits, and a plant shutdown. Using Inspection Manual Chapter 0609, Appendix A, Exhibit 1, Initiating Events Screening Questions, dated June 19, 2012, the finding was determined to be of very low safety significance because after a reasonable assessment of degradation, it could not:

1) result in exceeding the reactor coolant system leak rate for a small loss of coolant accident, or 2) have likely affected other systems used to mitigate a loss of coolant accident resulting in a total loss of their function. This finding has a cross-cutting aspect in the work management component of the human performance cross-cutting area because the licensee failed to implement a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. Specifically, the licensee initially planned to address the reactor coolant leakage six months after the issue was identified, and then moved it out an additional three months, failing to prioritize the work commensurate with its safety significance [H.5].

Enforcement.

Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, states, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly corrected. Contrary to the above, on multiple occasions between November 29, 2014, and July 22, 2015, for the quality-related valve BBV0400, to which 10 CFR Part 50 Appendix B applies, the licensee failed to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly corrected. Specifically, when boric acid buildup was discovered on the flange downstream of valve BBV0400, a safety-related valve, the licensee failed to correct the condition in a timely manner. The licensee restored compliance by torqueing the valve and flange to reduce leakage to within limits.

Because this finding is of very low safety significance and was entered into the corrective action program as Callaway Action Request 201505308, this violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy: NCV 05000483/2015004-01 Failure to Promptly Correct a Condition Adverse to Quality on the Reactor Coolant System.

2.

Introduction.

Inspectors reviewed a Green, self-revealing non-cited violation of Technical Specification 5.4.1, Procedures, for the licensees failure to establish, implement, and maintain a procedure recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Specifically, Procedure ODP-ZZ-00022, Operations Preparation, Performance, and Restoration from Refueling Outages, did not provide adequate guidance to ensure a blind flange located on the reactor coolant system was properly reinstalled resulting in reactor coolant system leakage into containment.

Description.

On November 9, 2014, upon completion of a refueling outage, valve BBV0400, a drain valve located on the pressurizer auxiliary spray line, was closed and the flange downstream of valve BBV0400 was reinstalled in accordance with Workmans Protection Assurance 90470 restoration instructions. Operations personnel installed the gasket and flange then tightened the bolts, but did not torque them to a specific value. The operators tightened the flange to what they believed was an appropriate level of tightness based on their experience, inadvertently overtightening the flange bolts. As a result of overtightening the bolts, the licensee overcrushed the Goretex flange gasket to the point that it could no longer perform its design function.

The licensee later determined that had the gasket been crushed appropriately, the flange would not have leaked.

The licensee established Procedure ODP-ZZ-00022, Operations Preparation, Performance, and Restoration from Refueling Outages, to meet Regulatory Guide 1.33 requirements. Revision 11 of ODP-ZZ-00022 added instructions for torqueing flanged connections in October 2003. Specifically, step 3.20.1.e of this procedure requires that the workmans protection assurance coordinator review the refuel WPA [workmans protection assurance] to identify all blind flange connections that will be tagged open/flange removed that could affect RCS [reactor coolant system] leakage. The identified flanges will be torqued. This procedure does not, however, identify how to torque the flanges or what method will be used to track the torqueing. Additionally, the procedure does not identify that excessive torqueing might not be appropriate based on the gasket material being used.

On July 22, 2015, the flange located downstream of valve BBV0400, started leaking at a rate of 1.2 gallons per minute, which is in excess of the requirements of Technical Specifications 3.4.13, RCS [Reactor Coolant System] Operational Leakage, for unidentified leakage. This required the licensee to shut down and cool down the plant to repair the leak. The licensee determined that one of the contributing causes of the reactor coolant leak was that the flange was not properly torqued to obtain the appropriate crush depth on the Goretex gasket. As a corrective action, the licensee replaced the gasket with a Flexitallic gasket which was not susceptible to being overcrushed. Additionally, the licensee implemented repetitive maintenance tasks in their work management program to identify flanges removed during an outage and to torque them upon reinstallation.

Analysis.

The licensees failure to properly establish and maintain Procedure ODP-ZZ-00022 was a performance deficiency. The performance deficiency is more than minor, and therefore a finding, because it is associated with the procedure quality attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. Specifically, Procedure ODP-ZZ-00022 did not provide adequate guidance to ensure the blind flange located downstream of valve BBV0400 was properly reinstalled. Using Inspection Manual Chapter 0609, Appendix A, Exhibit 1, Initiating Events Screening Questions, dated June 19, 2012, the finding was determined to be of very low safety significance because after a reasonable assessment of degradation, it could not: 1) result in exceeding the reactor coolant system leak rate for a small loss of coolant accident, or 2) have likely affected other systems used to mitigate a loss of coolant accident resulting in a total loss of their function. This finding does not have a cross-cutting aspect because the performance deficiency is not representative of current licensee performance, in that the inadequate instructions were added to the procedure in 2003.

Enforcement.

Technical Specification 5.4.1 requires, in part, that procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2. Section 2.k of Appendix A to Regulatory Guide 1.33, Revision 2, requires procedures for preparations for refueling and refueling equipment operations. Contrary to the above, Procedure ODP-ZZ-00022, Operations Preparation, Performance, and Restoration from Refueling Outages, Revision 40, a procedure established to meet the Regulatory Guide 1.33 requirement, was not properly established or maintained. Specifically, Procedure ODP-ZZ-00022 required individuals to verify flanges that can affect reactor coolant system leakage that are disturbed during a refueling outage be torqued upon reinstallation but did not provide procedural controls for establishing torque values or gasket crush depth. The licensee entered this condition into their corrective action program as Callaway Action Request 201505702. The licensee restored compliance by adding repetitive maintenance tasks to their work management program to identify flanges that are removed during an outage and to torque the flanges upon reinstallation.

Because this finding is of very low safety significance and was entered into the corrective action program, this violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy:

NCV 05000483/2015004-02, Failure to Properly Establish and Maintain a Plant Procedure for Preparation for Refueling Outages.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed four risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:

• September 29, 2015, train A essential service water and emergency diesel generator planned maintenance outage

• October 6, 2015, steam generator A atmospheric dump valve planned maintenance outage

• October 20, 2015, train B emergency diesel generator planned maintenance outage

• November 5, 2015, train A emergency diesel generator planned outage to replace fuel oil day tank inlet check valve The inspectors verified that these risk assessment were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensees risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments.

These activities constitute completion of four maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed three operability determinations and functionality assessments that the licensee performed for degraded or nonconforming structures, systems, or components:

• September 29, 2015, functionality assessment of emergency lighting for train B essential service water pump room and auxiliary building room 1331, Callaway Action Request 201506951

• October 29, 2015, operability determination of load shedding and emergency load sequencing due to automatic test insertion alarms, Callaway Action Request 201507823

• December 10, 2015, operability determination of safety injection accumulator A pressure dropping at a faster rate than the other three accumulators, Callaway Action Request 201508832 The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded structures, systems, and components to be operable or functional, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability or functionality. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability or functionality of the degraded structures, systems, or components.

These activities constitute completion of three operability and functionality review samples, as defined in Inspection Procedure 71111.15.

b. Findings

No findings were identified.

1R18 Plant Modifications

a. Inspection Scope

The inspectors reviewed two permanent plant modifications that affected risk-significant structures, systems, and components:

• August 11, 2015, replace Modutronics card in valves ALHV0005 and ALHV0007

• September 23, 2014, screens added to floor drains in multiple rooms, Job 13006754 The inspectors reviewed the design and implementation of the modifications. The inspectors verified that work activities involved in implementing the modifications did not adversely impact operator actions that may be required in response to an emergency or other unplanned event. The inspectors reviewed the adequacy of the post-modification testing to establish the operability of the structure, system and component as modified.

These activities constitute completion of two samples of permanent modifications, as defined in Inspection Procedure 71111.18.

b. Findings

Several findings were identified for the ALHV0005 and ALHV0007 modification and are discussed in Callaway Plant - NRC Special Inspection Report 05000483/2015009 (ML16013A021).

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed five post-maintenance testing activities that affected risk-significant structures, systems, or components:

• September 30, 2015, train A emergency diesel generator planned maintenance

• October 6, 2015, steam generator A atmospheric dump valve and nitrogen accumulator planned maintenance

• October 21, 2015, train B emergency diesel generator planned maintenance

• November 4, 2015, turbine-driven auxiliary feed valve to steam generator D (ALHV0006) positioner replacement

• November 18, 2015, train B residual heat removal system planned maintenance The inspectors reviewed licensing-basis and design-basis documents for the systems, structures, and components and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected systems, structures, and components.

These activities constitute completion of five post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed three risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the structures, systems, and components were capable of performing their safety functions:

Other surveillance tests:

• November 9, 2015, train B load shedding and emergency load sequencing system automatic test injection surveillance

• November 19, 2015, boric acid control program inspection of rooms 1124, 1125, 1308A, 1308B, 1308C, 7119, 7134, and 7301, Job 15505065

• December 10, 2015, heat flux hot channel factor determination surveillance The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria.

These activities constitute completion of three surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors observed an emergency preparedness drill on October 29, 2015, to verify the adequacy and capability of the licensees assessment of drill performance. The inspectors reviewed the drill scenario, observed the drill from the Technical Support Center and simulator, and attended the post-drill critique. The inspectors verified that the licensees emergency classifications, off-site notifications, and protective action recommendations were appropriate and timely. The inspectors verified that any emergency preparedness weaknesses were appropriately identified by the licensee in the post-drill critique and entered into the corrective action program for resolution.

These activities constitute completion of one emergency preparedness drill observation sample, as defined in Inspection Procedure 71114.06.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS1 Radiological Hazard Assessment and Exposure Controls

a. Inspection Scope

The inspectors assessed the licensees performance in assessing the radiological hazards in the workplace associated with licensed activities. The inspectors assessed the licensees implementation of appropriate radiation monitoring and exposure control measures for both individual and collective exposures. The inspectors walked down various portions of the plant and performed independent radiation dose rate measurements. The inspectors interviewed the radiation protection manager, radiation protection supervisors, and radiation workers. The inspectors reviewed licensee performance in the following areas:

• the hazard assessment program, including a review of the licensees evaluations of changes in plant operations and radiological surveys to detect dose rates, airborne radioactivity, and surface contamination levels

• instructions and notices to workers, including labeling or marking containers of radioactive material, radiation work permits, actions for electronic dosimeter alarms, and changes to radiological conditions

• programs and processes for control of sealed sources and release of potentially contaminated material from the radiologically controlled area, including survey performance, instrument sensitivity, release criteria, procedural guidance, and sealed source accountability

• radiological hazards control and work coverage, including the adequacy of surveys, radiation protection job coverage and contamination controls, the use of electronic dosimeters in high noise areas, dosimetry placement, airborne radioactivity monitoring, controls for highly activated or contaminated materials (non-fuel) stored within spent fuel and other storage pools, posting and physical controls for high radiation areas and very high radiation areas

• radiation worker and radiation protection technician performance with respect to radiation protection work requirements

• audits, self-assessments, and corrective action documents related to radiological hazard assessment and exposure controls since the last inspection These activities constitute completion of one sample of radiological hazard assessment and exposure controls as defined in Inspection Procedure 71124.01.

b. Findings

No findings were identified.

2RS2 Occupational ALARA Planning and Controls

a. Inspection Scope

The inspectors assessed licensee performance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable (ALARA). During the inspection, the inspectors interviewed licensee personnel and reviewed licensee performance in the following areas:

• site-specific ALARA procedures and collective exposure history, including the current 3-year rolling average, site-specific trends in collective exposures, and source-term measurements

• ALARA work activity evaluations/post-job reviews, exposure estimates, and exposure mitigation requirements

• the methodology for estimating work activity exposures, the intended dose outcome, the accuracy of dose rate and man-hour estimates, and intended versus actual work activity doses and the reasons for any inconsistencies

• records detailing the historical trends and current status of tracked plant source terms and contingency plans for expected changes in the source term due to changes in plant fuel performance issues or changes in plant primary chemistry

• radiation worker and radiation protection technician performance during work activities in radiation areas, airborne radioactivity areas, or high radiation areas

• audits, self-assessments, and corrective action documents related to ALARA planning and controls since the last inspection These activities constitute completion of one sample of occupational ALARA planning and controls as defined in Inspection Procedure 71124.02.

b. Findings

No findings were identified.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security

4OA1 Performance Indicator Verification

.1 Mitigating Systems Performance Index: High Pressure Injection Systems (MS07)

a. Inspection Scope

The inspectors reviewed the licensees mitigating system performance index data for the period of fourth quarter 2014 through third quarter 2015 to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the mitigating system performance index for high pressure injection systems, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.2 Mitigating Systems Performance Index: Residual Heat Removal Systems (MS09)

a. Inspection Scope

The inspectors reviewed the licensees mitigating system performance index data for the period of fourth quarter 2014 through third quarter 2015 to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the mitigating system performance index for residual heat removal systems, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.3 Occupational Exposure Control Effectiveness (OR01)

a. Inspection Scope

The inspectors verified that there were no unplanned exposures or losses of radiological control over locked high radiation areas and very high radiation areas during the period of October 1, 2014, to September 30, 2015. The inspectors reviewed a sample of radiologically controlled area exit transactions showing exposures greater than 100 mrem. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the occupational exposure control effectiveness performance indicator as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.4 Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual

Radiological Effluent Occurrences (PR01)

a. Inspection Scope

The inspectors reviewed corrective action program records for liquid or gaseous effluent releases that occurred between October 1, 2014, and September 30, 2015, and were reported to the NRC to verify the performance indicator data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the radiological effluent technical specifications/offsite dose calculation manual radiological effluent occurrences performance indicator as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.

b. Findings

No findings were identified.

.2 Semiannual Trend Review

a. Inspection Scope

To verify that the licensee was taking corrective actions to address identified adverse trends that might indicate the existence of a more significant safety issue, the inspectors reviewed corrective action program documentation associated with the following licensee-identified trends:

• a negative trend involving malfunctions of the spent fuel building bridge crane (Callaway Action Request 201506172)

• a negative trend involving consequential failures of AP-913 equipment (Callaway Action Request 201506340)

These activities constitute completion of one semiannual trend review sample, as defined in Inspection Procedure 71152.

b. Observations and Assessments The inspectors review of the trends identified above produced the following observations and assessments:

• For the negative trend involving malfunctions of the spent fuel building bridge crane, the licensee performed an evaluation of the causes for the negative trend.

The licensee identified that some of the problems are attributed to out of date analog technology and has developed a health issue to evaluate upgrading the system to a digital platform. They also identified that some cabling is damaged due to normal wear and are working on creating a preventative maintenance task to replace the cable before it wears out.

The inspectors considered that in response to this trend the licensee had completed an appropriate evaluation and had developed appropriate planned corrective actions.

• For the negative trend involving consequential failures of AP-913 equipment, the licensee identified 21 failures of AP-913 equipment within the last two years.

With the help of an external organization, the licensee determined two primary drivers of the trend: Right Picture and Ownership. The licensee is focused on reestablishing the focus on equipment reliability, restrengthening the behaviors to drive equipment excellence, and implementing a communication plan for cross-department interactions. At the end of the inspection period, these actions were ongoing.

The inspectors considered that in response to this trend the licensee had developed appropriate planned corrective actions.

c. Findings

No findings were identified.

.3 Annual Follow-up of Selected Issues

a. Inspection Scope

On January 31, 2015, the inspectors selected unexpected load reject when changing turbine controls, Callaway Action Request 201500737, for an in-depth follow-up.

The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the condition.

These activities constitute completion of one annual follow-up sample as defined in Inspection Procedure 71152.

b. Findings

Introduction.

Inspectors reviewed a self-revealing Green finding for the licensees failure to follow the plant procedures for the unit reliability team. Specifically, after delaying a modification to the plants turbine control system, no compensatory measures were implemented to minimize or prevent failure of the system due to aging of the system beyond its evaluated service life.

Description.

On January 31, 2015, while performing turbine control testing, the turbine unexpectedly lowered electrical output from approximately 1250 MWe to approximately 780 MWe. This resulted in the condenser steam dumps opening due to a primary to secondary power mismatch. Operations personnel stabilized the plant and restored steam flow through the main turbine control valves, which allowed the condenser steam dumps to close as expected. The plant stabilized in a normal lineup at approximately 60 percent power. About an hour after the plant was stabilized, the turbine load starting reducing a second time. Operations personnel lowered the load limit setpoint until the load limit was limiting turbine load. The plant reached stable conditions at approximately 53 percent power.

On February 1, 2015, the licensee intentionally lowered power to approximately 46 percent power and placed the turbine control system in standby to support troubleshooting of the turbine control system. Troubleshooting identified intermittent noise in the load set circuitry caused by a +22 V permanent magnet generator power supply and a high resistance connection on the power supply bus due to the bad seating of a load limit and load set runback card.

The licensees investigation revealed that a decision was made in 2005 to upgrade the system to a digital platform because of aging and obsolescence of the system components. The system life at that time was approximately 25 years (2008) and technical justification was given to continue using the system for up to 30 years (through 2013). In 2012, the unit reliability team decided to delay the digital upgrade from the spring 2013 refueling outage, to the spring 2016 refueling outage, which effectively extended the operating life to 33 years. The decision to delay the design change was based on the resource requirements of the project and probability of system failure. This decision was made with the knowledge of the upgrade project engineer, but communication with the system engineer to ensure his awareness of the delay was lacking.

Procedure APA-ZZ-00549, Appendix E, Unit Reliability Team Operations, Revision 7, step 4.9.8 states, If implementation of an approved solution is delayed, URT Chair:

DIRECT the issue Owner/Project Sponsor to determine IF any intermediate or compensatory measures should be put in place to ensure continued reliability until the solution can be implemented.

In February 2014, the system engineer presented compensatory actions to the outage leadership team for inclusion in the fall 2014 refueling outage. This request to add the actions was denied by the outage leadership team due to lack of resources. The outage leadership team did not discuss the need for the compensatory measures with the unit reliability team to acquire the necessary resources. After that time, the upgrade was deferred to the spring 2019 refueling outage, effectively extending the operating life to 36 years without identification of any compensatory measures to reduce the probability of a failure in the plant.

Corrective actions include implementing a bridging strategy to lower the risk to the safe and reliable operation of the turbine control system until the system is replaced with a new digital control system. The bridging strategy includes replacing power supplies and cards within the system to increase the overall reliability of the system.

Analysis.

The licensees failure to follow the plant procedure for the unit reliability team 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, as no compensatory measures were implemented after the digital upgrade to the turbine control system was deferred from the spring 2013 refueling outage to the spring 2016 refueling outage, the turbine control system malfunctioned causing a runback of the turbine and downpower transient on the plant. Using Inspection Manual Chapter 0609, Appendix A, Exhibit 1, Initiating Events Screening Questions, 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 in the teamwork component of the human performance cross-cutting area because the licensee did not ensure that individuals and work groups communicate across organizational boundaries to ensure nuclear safety is maintained. Specifically, the outage leadership team identified the need for the compensatory measures, but did not communicate the priority nor the effect on nuclear safety to site leadership to gain the resources needed to implement these measures [H.4].

Enforcement.

This finding does not involve enforcement action because no violation of a regulatory requirement was identified. Because this finding does not involve a violation and is of very low safety significance, it is identified as FIN 05000483/2015004-03, Failure to Follow Plant Procedure for Unit Reliability Team.

4OA3 Follow-up of Events and Notices of Enforcement Discretion

.1 (Closed) Licensee Event Report 05000483/2014-002-00, Operation Outside of Pressure

and Temperature Limits Report Curve Required by Technical Specification 3.4.3 On January 14, 2014, the Callaway Plant discovered that on two occasions during the previous three years, Condition C of Technical Specifications 3.4.3, Reactor Coolant System Pressure and Temperature Limits, was not entered when the reactor coolant system pressure was below 0 pounds per square inch gauge (psig). This occurred while the reactor coolant system was vacuum filled during both of the refueling outages (Refueling Outage 18 and Refueling Outage 19) at Callaway in the three years prior to the discovery. The reactor pressure/temperature curves in the Callaway Pressure and Temperature Limits Report have a minimum pressure value of 0 psig referenced on the curve. All systems performed as designed during the time that reactor coolant system pressure was below 0 psig during the two vacuum fill evolutions.

The licensee evaluated the impacts of drawing a vacuum on the structural integrity of the reactor coolant system. The licensee determined the calculated minimum wall thickness for the reactor coolant system components to withstand full vacuum (0 pounds per square inch absolute (psia)) is below the existing wall thickness of the reactor vessel, pressurizer, steam generator tubes, and the reactor coolant system piping. Additionally, the licensee determined that the execution of the reactor coolant system vacuum fill and vent procedure to reduce reactor coolant system pressure up to and including full vacuum will not adversely affect the integrity of reactor coolant system components.

Licensee Event Report 2014-002-00 was submitted pursuant to Title 10 of the Code of Federal Regulations 50.73(a)(2)(i)(B) as a condition prohibited by technical specifications based on the reactor coolant system pressure being outside of the prescribed pressure and temperature limits. The inspectors reviewed the licensees submittal and determined that the report included the potential safety consequences and necessary corrective actions, and thoroughly documented the event.

The licensee conducted a causal analysis and determined the causes for this issue were the inaccurate perception that the pressure and temperature limits report curves only applied during reactor coolant system heat-up or cooldown and the reliance on an engineering evaluation of the reactor coolant system under vacuum conditions to allow continued operation.

As part of the licensees corrective actions, the licensee updated their engineering analysis basis for the pressure and temperature limits report to include reactor coolant system pressure down to 0 psia and updated the pressure and temperature limits report to allow operation down to 0 psia. The updated pressure and temperature limits report was provided to the NRC in accordance with the requirements of Technical Specification 5.6.6.c., Reporting Requirements.

The inspectors determined during their review of Licensee Event Report 2014-002-00 that the activities described in this licensee event report did not represent a violation of Technical Specification 3.4.3. However, the inspectors concluded that the operation of the reactor coolant system outside of the parameters of the pressure and temperature limits report analysis involved a minor violation of Technical Specification 5.4.1.a.

Technical Specification 5.4.1.a requires, in part, that procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2. Section 3.a of Appendix A to Regulatory Guide 1.33, Revision 2, requires procedures for filling and venting of the reactor coolant system. The licensee established Procedure OTN-BB-00001, Reactor Coolant System - IPTE, for the reactor coolant system vent and fill. This procedure was not appropriately maintained in that it allowed reactor coolant system pressure during the two reactor coolant system fill and vent evolutions (on November 15-16, 2011, and May 13, 2013) to be less than 0 psig, outside of the pressure parameter inputs to the analysis that is the basis for the pressure/temperature limit curves of Technical Specification 3.4.3. This violation was determined to be of minor safety significance because it could not reasonably be viewed as a precursor to a significant event; if left uncorrected, would not have the potential to lead to a more significant safety concern; it does not relate to a performance indicator; and it did not adversely affect a reactor oversight process cornerstone objective. Specifically, the licensees analysis showed that there is no impact on reactor coolant system integrity when the reactor coolant system is under vacuum conditions. This issue was entered into Callaway Plants corrective action program as Callaway Action Request 201400240. This failure to comply with Technical Specification 5.4.1.a constitutes a minor violation that is not subject to enforcement action in accordance with NRCs Enforcement Policy. This licensee event report is closed.

2. (Closed) Licensee Event Report 05000483/2014-003-02, Inverter NN11 Inadvertently

Transferred to its Alternate AC Source On June 9, 2014, Callaway Plant was in Mode 1 operating at 100 percent rated thermal power when, during a maintenance activity, inverter NN11 unexpectedly transferred from its normal direct current (DC) source to its bypass alternating current (AC) source.

Inspectors previously reviewed Licensee Event Report 05000483/2014-003-00 and 05000483/2014-003-01 associated with this event. Documentation of this review was provided in NRC Integrated Inspection Report 05000483/2015002 (ML15217A538).

The second revision to the licensee event report included additional information in the event description regarding the momentary deenergization of an instrumentation control power cabinet. No findings or violations of NRC requirements were identified associated with the revised event report. This licensee event report is closed.

3. (Closed) Licensee Event Report 05000483/2014-005-00/01, All ECCS [Emergency Core

Cooling System] Accumulator Isolation Valve Operator Breakers Closed in Mode 3 with RCS [Reactor Coolant System] Pressure Greater than 1000 PSIG On November 18, 2014, leak testing was being performed on the emergency core cooling system accumulator isolation valves (EPHV8808A, EPHV8808B, EPHV8808C, EPHV8808D) while the plant was in Mode 3 and reactor coolant system pressure was above 1000 psig. During the testing, at 5:34 p.m., the supply breakers for all four of the isolation valve motor-operators were closed. This action had the unintended result of rendering all four emergency core cooling system accumulators inoperable. The condition was identified at 7:00 p.m., and Technical Specifications 3.5.1, Accumulators, Limiting Condition for Operation, Condition D was entered. Per Required Action D.1, Technical Specification Limiting Condition for Operation 3.0.3 was immediately entered.

By 7:30 p.m., three emergency core cooling system accumulators had been restored to operable with their isolation valves open and power removed from the isolation valve motor-operators, and Technical Specifications Limiting Condition for Operation 3.0.3 was exited.

Licensee Event Reports 2014-005-00 and 2014-005-01 were submitted pursuant to 10 CFR 50.73(a)(2)(v)(A), 50.73(a)(2)(v)(B), 50.73(a)(2)(v)(D), and 50.73(a)(2)(vii) as a condition that could have prevented the fulfillment of a safety function needed to shut down the reactor and maintain it in a safe shutdown condition, remove residual heat, or mitigate the consequences of an accident; and as an event where a single cause or condition caused two independent trains to become inoperable in a single system designed to shut down the reactor and maintain it in a safe shutdown condition, remove residual heat, or mitigate the consequences of an accident. The inspectors reviewed the licensees submittal and determined that the report included the potential safety consequences and necessary corrective actions, and thoroughly documented the event.

The licensee conducted a causal analysis and determined the cause for this issue was the failure of operations personnel to comply verbatim with the leak testing procedure.

As part of the licensees corrective actions, requirements for verbatim compliance with continuous use procedures have been reinforced within Callaways Operations Department and the leak testing procedure has been revised to clearly specify that removal of power from the isolation valve motor-operator is required for operability of each emergency core cooling system accumulator.

A licensee-identified violation associated with this event is documented in Section 4OA7 of NRC Integrated Inspection Report 05000483/2014005 (ML15036A620). This licensee event report is closed.

These activities constitute completion of three event follow-up samples, as defined in Inspection Procedure 71153.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On October 30, 2015, the inspectors presented the radiation safety inspection results to Mr. B. Cox, Senior Director, Nuclear Operations, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On January 11, 2015, the inspectors presented the inspection results to Mr. T. Herrmann, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

F. Bianco, Director, Nuclear Operations

B. Cox, Senior Director, Nuclear Operations

K. Dolman, Senior, Technician, Radiation Protection

M. Fletcher, Engineer, Fire Protection

J. Geyer, Manager, Radiation Protection

J. Houston, Senior Health Physicist, Radiation Protection

G. Hurla, Supervisor, Radiation Protection

V. Miller, Supervising Health Physicist, Radiation Protection

S. Petzel, Engineer, Regulatory Affairs

N. Traub, Senior Technician, Radiation Protection

T. Trent, Health Physicist, Radiation Protection

D. Turley, Supervisor, Engineering Systems

T. Witt, Engineer, Regulatory Affairs

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000483/2015004-01 NCV Failure to Promptly Correct a Condition Adverse to Quality on the Reactor Coolant System (Section 1R12.1)

05000483/2015004-02 NCV Failure to Properly Establish and Maintain a Plant Procedure for Preparation for Refueling Outages (Section 1R12.2)

05000483/2015004-03 FIN Failure to Follow Plant Procedure for Unit Reliability Team (Section 4OA2.3)

Closed

05000483/2014-002-00 LER Operation Outside of Pressure and Temperature Limits Report Curve Required by Technical Specification 3.4.3 (Section 4OA3.1)

05000483/2014-003-02 LER Inverter NN11 Inadvertently Transferred to its Alternate AC Source (Section 4OA3.2)

05000483/2014-005-00/01 LER All ECCS Accumulator Isolation Valve Operator Breakers Closed in Mode 3 with RCS Pressure Greater than 1000 PSIG (Section 4OA3.3)

Attachment 1