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05000483/FIN-2017002-0230 June 2017 23:59:59CallawayNRC identifiedFailure to Analyze the Effect of Changes to Maintaining the Gaitronics SystemSeverity Level IV. The inspectors identified a Severity Level IV non- cited violation for the licensees failure to perform an analysis of a change to processes supporting the emergency preparedness program that demonstrated the change did not reduce the effectiveness of the emergency plan in accordance with the requirements of 10 CFR 50.54(q)(3). There were no immediate safety concerns associated with this violation because less than 10 percent of the public address speakers were determined to be degraded or non- functional. This issue has been placed in the licensees corrective action system as Condition Report 201702343. The failure to perform an analysis of the effect of changes in processes supporting emergency preparedness is a performance deficiency within the licensees ability to foresee and correct. The finding was more than minor because the finding was associated with the Facilities and Equipment Cornerstone attribute and adversely affected the Emergency Preparedness Cornerstone objective. The finding was assessed using traditional enforcement because the licensees failure to perform a required analysis impacted the regulatory process . The finding was evaluated using the NRCs Enforcement Policy, dated November 1, 2016, Section 6.6(d) , and was determined to be a Severity Level IV violation because the violation did not affect radiological assessment or offsite notification. Traditional enforcement violations are not assessed for cross -cutting aspects.
05000483/FIN-2017403-0130 June 2017 23:59:59CallawayNRC identifiedSecurity
05000483/FIN-2013403-0131 December 2013 23:59:59CallawayNRC identifiedSecurity
05000483/FIN-2013301-0131 March 2013 23:59:59CallawayNRC identifiedFailure to Maintain Initial Operator Licensing Examination IntegrityThe examination team identified a Severity Level IV, non-cited Violation (NCV), of Title 10 CFR Part 55.49, Integrity of Examination and Tests. Specifically, the licensee failed to ensure that Door 143, Entrance to Simulator Instructor Booth, remained closed/latched upon personnel exiting the simulator. This resulted in the failure to ensure examination security requirements were met as required by procedures TDP-ZZ-00019, NRC License Examination Security and Integrity, Revision 019, and TDP-ZZ-00019, Appendix A, Simulator Security Guidelines, Revision 027. The examination compromise existed because personnel not signed onto the examination security agreement could have gained access to the simulator where examination materials were in plain view. Therefore, unauthorized personnel could have gained knowledge of initial license examination materials during the conduct of the operating test portion of the initial license examination. The failure to ensure the requirements of procedures TDP-ZZ-00019 and TDP-ZZ-00019, Appendix A, were met resulted in the failure to establish proper examination security. Failure to meet the requirements of approved examination security procedures is a performance deficiency. This performance deficiency was determined to be Severity Level IV because it fits the SL-IV example of Enforcement Policy Section 6.4.d, Violation Examples: Licensed Reactor Operators. This section states, Severity Level IV violations involve, for example: a non-willful compromise ... of an application, test, or examination required by 10 CFR Part 55. The performance deficiency could have impacted the regulatory process if licensing decisions were made with applicants having prior knowledge of examination materials. However, since the simulator door was only unlatched for a short period of time and all applicants were sequestered under the supervision of licensee examination team personnel, it is deemed that there was no actual effect on the equitable and consistent administration of the exam as a result of the compromise. This is a violation of 10 CFR 55.49, Integrity of Examination and Tests. There are no cross-cutting aspects assigned to traditional enforcement violations.
05000483/FIN-2012005-0231 December 2012 23:59:59CallawayNRC identifiedFailure to Comply with Technical Specification 5.5.14, Technical Specifications (TS) Bases Control ProgramThe inspectors identified a non-cited violation for failure to comply with Technical Specification 5.5.14, Technical Specifications (TS) Bases Control Program. Specifically, the licensee made a change to the technical specification bases that altered the application of Technical Specification 3.6.3, Containment Isolation Valves, for the hydrogen monitoring system without receiving prior approval from the NRC. The licensee issued a night order to disregard the statement in the technical specification bases and declare the valves inoperable in accordance with Technical Specification 3.6.3 pending a change to the bases. The licensee entered the issue into their corrective action program as Callaway Action Request 201208045. The inspectors determined that the violation was more than minor because in order to perform its regulatory function, the NRC relies on licensees to comply with their licensing basis documents and request prior approval for changes that may affect these documents. Because this issue affected the NRC\'s ability to perform its regulatory function, it was evaluated using the traditional enforcement process. This violation was classified as a Severity Level IV violation because it was not willful and was consistent with the guidance in Section 6.1, Paragraph d., of the NRC Enforcement Policy. Cross-cutting aspects are not assigned to traditional enforcement violations.
05000483/FIN-2011003-0530 June 2011 23:59:59CallawayNRC identifiedFailure to Periodically Update the Final Safety Analysis ReportThe inspectors identified a noncited violation of 10 CFR 50.71 Maintenance of Records, because the licensee failed to update their Final Safety Analysis Report with submittals that include the effects of a change made to the facility. Specifically, the licensee built the old steam generator storage facility on the owner controlled area for long-term radwaste storage of four decommissioned steam generators and failed to update the Final Safety Analysis Report to include these changes to the facility. This issue was entered in the licensees corrective action program as Callaway Action Request 201104434. This issue was dispositioned using traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. The finding is more than minor because it has a material impact on licensed activities in that the four decommissioned steam generators, with a significant radioactive source term, have been relocated from the plant radiological controlled area to the owner controlled area. In addition, the radwaste management program has been affected because the licensee determined that this low-level radwaste facility will store these large components until an appropriate facility for disposal can be determined. The finding is characterized as a Severity Level IV noncited violation in accordance with NRC Enforcement Policy, Section 6.1, and was treated as a noncited violation consistent with Section 2.3.2.a of the NRC Enforcement Policy (Section 2RS08).
05000483/FIN-2011006-0131 March 2011 23:59:59CallawayNRC identifiedFailure to Update the Updated Safety Analysis ReportThe team identified a Severity Level IV, noncited violation of 10 CFR 50.71, Maintenance of records, making of reports, paragraph (e) which states, in part, Each person licensed to operate a nuclear power reactor shall update periodically the updated safety analysis report originally submitted as part of the application for the license, to assure that the information included in the report contains the latest information developed. Specifically, the licensee incorporated numerous errors in the updated safety analysis report associated with the descriptions of the onsite electrical power systems. The licensee has entered this violation into their corrective action program as Condition Reports 201101335 and 201102064. The inspectors determined that the failure to update the updated safety analysis report as required by 10 CFR 50.71(e), Maintenance of records, making of reports was a performance deficiency. This finding was evaluated using traditional enforcement because it had the potential for impacting the NRC\'s ability to perform its regulatory function. The inspectors used the NRC Enforcement Policy, dated September 30, 2010, to evaluate the significance of this violation. Consistent with the NRC Enforcement Policy, this finding was determined to be a Severity Level IV noncited violation. This finding has no crosscutting aspect as it was associated with a traditional enforcement violation.
05000483/FIN-2011002-0231 March 2011 23:59:59CallawayNRC identifiedFailure to Report Inoperability of Class 1E Electrical Equipment for a Period Greater than Allowed by the Plant\'s Technical SpecificationsThe inspectors identified a IV noncited violation of 10 CFR 50.73(a)(2)(v), Licensee Event Report System, for failure to report inoperability of Class 1E electrical equipment for a period greater than allowed by the plants technical specifications. The licensee determined there were no prior instances where the Class 1E electrical equipment air conditioning units were inoperable greater than the technical specification allowed completion time of the supported equipment. The inspectors reviewed the licensees reportability evaluation and identified that the event described in Callaway Action Request 200800615 resulted in a period where the Class 1E electrical equipment air conditioning unit train B was inoperable for approximately 37 hours which exceeded the technical specification allowed completion time of the equipment supported by the Class 1E electrical equipment and constituted a condition which was prohibited by the plant\'s technical specifications and should have been reported in a licensee event report. This issue was entered into the licensees corrective action program as Callaway Action Request 201011132. This finding affects the Mitigating Systems Cornerstone and is greater than minor because in order to perform its regulatory function, the NRC relies on licensees to identify and report conditions or events meeting the criteria specified in the regulations. Because this issue affected the NRC\'s ability to perform its regulatory function, it was evaluated using the traditional enforcement process. Consistent with the guidance in Section 6.9, Paragraph d.9, of the NRC Enforcement Policy, this finding was determined to be a Severity Level IV noncited violation. This finding has no crosscutting aspect as it was strictly associated with a traditional enforcement violation (Section 1R15).
05000483/FIN-2010004-0230 September 2010 23:59:59CallawayNRC identifiedFailure to Accurately Report a Condition that Could Have Prevented Fulfillment of a Safety Function

The inspectors identified a Severity Level IV noncited violation of 10 CFR 50.73(a)(2)(v), Licensee Event Report System, for failure to report simultaneous inoperability of two steam generator atmospheric steam dump valves as a condition that could have prevented fulfillment of a safety function. On February 8, 2010, AmerenUE submitted Licensee Event Report 05000483/2009-005-00 to document that steam generator atmospheric steam dump valve ABPV0002 was out of service longer than allowed by Technical Specification 3.7.4, Atmospheric Steam Dump Valves (ASDs). The licensee event report also documented a period where valve ABPV0002 inoperability overlapped the inoperability of steam generator atmospheric steam dump valve ABPV0003. Callaway Final Safety Analysis Report Section 15.6.3.2.2.p. stated that all three intact steam generator atmospheric steam dump valves are credited in the cool down for a steam generator tube rupture. The inspectors determined that the licensee failed to adequately evaluate the reportability of having simultaneous inoperability of two steam generator atmospheric steam dump valves as a safety system functional failure. This issue was entered into the licensees corrective action program as Callaway Action Request 201006086 and on September 29, 2010, the licensee submitted Licensee Event Report 05000483/2009-005-001 to correct the reporting error.

This finding affects the Mitigating Systems Cornerstone and is greater than minor because the NRC relies on licensees to identify and report conditions or events meeting the criteria specified in the regulations in order to perform its regulatory function. Because this issue affected the NRC\'s ability to perform its regulatory function, it was evaluated with the traditional enforcement process. Consistent with the guidance in Section IV.A.3 and Supplement I, Paragraph D.4, of the NRC Enforcement Policy, this finding was determined to be a Severity Level IV noncited violation. This finding has no crosscutting aspect as it was strictly associated with a traditional enforcement violation (Section 4OA3).

05000483/FIN-2009004-0230 September 2009 23:59:59CallawayNRC identifiedFailure to Correctly Identify Safety System Functional Failures in a Licensee Event ReportThe inspectors identified a Severity Level IV noncited violation of 10 CFR 50.73(a)(2)(v), Licensee Event Report System, for a failure to report two examples of safety system functional failures in licensee event reports within 60 days after discovery of events requiring a report. The two examples were: March 26, 2008, discovery that operation of containment air coolers in fast speed, during a period of higher than normal containment pressure, could open the air coolers fast speed thermal overload device rendering all the coolers incapable of automatically restarting in slow speed May 21, 2008, discovery of a 6.6 cubic foot void of air in the common suction piping capable of affecting the function of both of the safety injection system pumps For each example, the inspectors reviewed the licensees reportability evaluation and associated past operability reviews and determined each event was reportable per 10 CFR 50.73(a)(2)(v) since each example resulted in a condition which affected both trains of a system described in the Final Safety Analysis Report that was needed to mitigate the consequences of an accident. Alternate safety systems accident mitigation is not permitted as a reason to not report the discovery of the conditions. The licensee also failed to report these failures to the NRC performance indicator database because of the failure to include the safety system functional failure in each respective licensee event report. This finding affects the Mitigating Systems Cornerstone and is greater than minor because the NRC relies on licensees to identify and report conditions or events meeting the criteria specified in the regulations in order to perform its regulatory function. Consistent with the guidance in Section IV.A.3 and Supplement VII, Paragraph D.1 of the NRC Enforcement Policy, this finding was determined to be a Severity Level IV noncited violation. The licensee planned to update the associated license event reports as described in Callaway Action Request 200904980. This finding has a crosscutting aspect in the area of human performance associated with the resources component because the licensee failed to ensure, through adequate training, that its staff understood the guidance documents pertaining to the 10 CFR 50.73 rule (H.2.(b)
05000483/FIN-2009003-0130 June 2009 23:59:59CallawayNRC identifiedFailure to Submit Complete and Accurate Risk Information for a Requested License AmendmentThe inspectors identified a noncited violation of 10 CFR 50.9, Completeness and Accuracy of Information, when AmerenUE failed to submit complete and accurate quantification of risk contributors associated with a license amendment supporting a modification to replace the underground portion of the essential service water system Train B piping with high density polyethylene pipe. The inspectors questioned the risk impact of a possible control room fire which led to the discovery that the licensee had not followed their process for screening out fire areas. The licensee entered this item into their corrective action program as Callaway Action Request 200902810 and also submitted an update to License Amendment 191 to correctly account for the control room fire risk. This finding affects the Mitigating Systems cornerstone and is greater than minor because the NRC relies on licensees to identify and report conditions or events meeting the criteria specified in the regulations in order to perform its regulatory function. Consistent with the guidance in Section IV.A.3 and Supplement VII, Paragraph D.1 of the NRC Enforcement Policy, this finding was determined to be a Severity Level IV noncited violation. This finding has no crosscutting aspect because the licensees failure to thoroughly review and submit the risk for control room fires was not part of a corrective action process, but instead an oversight by the licensing review process
05000483/FIN-2008004-0230 September 2008 23:59:59CallawayNRC identifiedFailure to Submit a Licensee Event Report for a Condition Prohibited by the PLANT\'S Technical SpecificationsThe inspectors identified a Severity Level IV noncited violation of 10 CFR 50.73(a)(1) for a failure to submit a required licensee event report within 60 days after discovery of an event requiring a report. On May 21, 2008, Callaway Plant personnel discovered a 6.6 cubic foot void of air within the safety injection system common suction piping. The voided piping, determined to have existed for over a year, was caused by relief valve maintenance on Valve EM8858A that occurred on May 7, 2007. Callaway Plant licensing staff performed a reportability evaluation and determined that the discovery of the void was not required to be reported to the NRC. The inspectors reviewed the licensees reportability evaluation and associated past operability and determined the event was reportable since a postulated single failure had the potential to disable both emergency core cooling system trains during cold leg recirculation. Since the emergency core cooling system was inoperable from May 7, 2007, until May 21, 2008, the event resulted in an operation or condition which was prohibited by the plants Technical Specifications as well as an event where a single cause or condition caused two independent trains to become inoperable in a single system. This finding is greater than minor because the NRC relies on licensees to identify and report conditions or events meeting the criteria specified in the regulations in order to perform its regulatory function. This finding affected the mitigating systems cornerstone. Because this issue affected the NRC\'s ability to perform its regulatory function, it was evaluated with the traditional enforcement process. Consistent with the guidance in Section IV.A.3 and Supplement I, Paragraph D.4, of the NRC Enforcement Policy, this finding was determined to be a Severity Level IV, noncited violation. This issue was entered into the licensee\'s corrective action program as Callaway Action Request 200810199. This finding has a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee failed to thoroughly evaluate a void discovered in the emergency core cooling system for operability and reportability (P.1(c)
05000483/FIN-2007005-0631 December 2007 23:59:59CallawayLicensee-identifiedLicensee-Identified Violation10 CFR 50.83 requires, in part, that prior to releasing part of a facility or site for unrestricted use, the licensee shall obtain NRC approval. Contrary to this, in January 2007, the licensee identified that on April 20, 2004, it had sold two parcels of land totaling 0.83 acres near the Highway 94 bridge at Logan Creek to the State of Missouri without obtaining NRC approval of the release of the land for unrestricted use. This was entered in the licensees corrective action program as CAR 200700893. On May 15, 2007, the licensee submitted a request, consistent with 10 CFR 50.83, seeking approval to release these parcels of land. This finding is of very low safety significance because the property meets the definition of non-impacted areas in accordance with 10 CFR 50.2, and the property has no reasonable potential for residual radioactivity in excess of natural background. In accordance with the NRC Enforcement Policy, because the violation impacted the regulatory process, it was not suitable for evaluation under the Significance Determination Process and, therefore, was categorized at Severity Level IV.
05000483/FIN-2005005-1031 December 2005 23:59:59CallawayNRC identifiedChange in EAL 3E Decreased the Effectiveness of the Emergency Plan

The inspectors identified a violation of 10 CFR 50.54(q) for implementing a change to emergency action levels which decreased the effectiveness of the emergency plan. Emergency Implementing Plan Procedure EIP-ZZ-00101, Classifying the Emergency, Revision 33, limited application of emergency action Level 3E, Fire within Protected Area Boundary NOT Extinguished with 15 minutes of Verification, so that fires in some plant areas which would be classified under the previous revision may no longer be classifiable.

Implementation of changes to emergency action levels which decreased the effectiveness of the emergency plan was a performance deficiency. The finding is more than minor because removal of a classifiable condition from licensee emergency action levels has the potential to impact safety, and licensee implementation of a change to their emergency plan, which decreases the effectiveness of the plan without prior NRC approval, impacts the regulatory process. This finding is a violation of 10 CFR 50.54(q). The licensee has entered this issue into their corrective action system as Corrective Action Report 200510162.