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Callaway
2Q/2008 Plant Inspection Findings


Initiating Events

Significance:a graphic of the significance Sep 22, 2007
Identified By: Self-Revealing
Item Type: NCV NonCited Violation
Failure to Follow Maintenance Instructions Affecting the Letdown Backpressure Control Valve.
A self-revealing Green noncited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," was identified after the licensee failed to follow reassembly procedures for the letdown system backpressure control valve. In April 2007, during reassembly of letdown pressure control Valve BGPCV0131, Callaway maintenance personnel failed to install an alignment cage spacer. On September 7, 2007, a failed pressure transmitter combined with malfunctioning Valve BGPCV0131 caused upstream letdown relief Valve BG8117 to lift, diverting water into the pressurizer relief tank at a rate of 119 gpm until operators isolated letdown to stop the leakage.

This finding is greater than minor because, similar to Example 5b provided in Manual Chapter 0612, Appendix E, the licensee’s failure to follow assembly procedures resulted in Valve BGPCV0131 being returned to service with a missing part. This finding, involving reactor coolant system letdown, affected the initiating events cornerstone equipment performance attribute and affected the objective to limit the likelihood of those events that upset plant stability and challenged critical safety functions during power operations. The inspectors used the Manual Chapter 0609, "Significant Determination Process," Phase 1 worksheet to analyze this finding. The inspectors determined this finding is of very low safety significance because it did not result in exceeding the Technical Specification limit for identified reactor coolant system leakage and did not affect any mitigating systems. This finding has a crosscutting aspect in the area of human performance associated with the work practices component because licensee personnel failed to follow established procedures (H.4(b)). This issue was entered into the licensee's corrective action program as Callaway Action Request 200708233.
Inspection Report# : 2007004 (pdf)


Mitigating Systems

Significance:a graphic of the significance Mar 14, 2008
Identified By: NRC
Item Type: NCV NonCited Violation
Nonconservative Technical Specification for Battery Inter-cell Connection Resistances
The team identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," because the licensee failed to ensure that Technical Specification Surveillance Requirements for the NK11 and NK14 safety related batteries established limits that met the design requirements. Specifically, until questioned by the team the licensee failed to determine the required design value needed to assure plant safety as requested in Callaway Action Request 200706561. The licensee determined that 69 micro ohms should be the actual allowed inter cell voltage limit to meet the design requirements versus an allowed Technical Specification limit of 150 micro ohms.

The performance deficiency associated with this finding involved the failure to ensure that the NK11 and NK14 safety related batteries would remain operable if all the inter cell connections measured 150 micro ohms as allowed by Technical Specification Surveillance Requirements 3.8.4.2 and 3.8.4.5. This finding was greater than minor because it was associated with the Mitigating Systems cornerstone attribute of maintenance and testing and affects the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Manual Chapter 0609.04, "Phase 1 – Initial Screening and Characterization of Findings," the finding was determined to have very low safety significance because it was a design deficiency confirmed not to result in loss of operability. The finding had a cross cutting aspect in the area of problem identification and resolution associated with operating experience because the licensee failed to evaluate in a timely manner relevant internal and external operating experience P.2(a) (Section 4OA2.e).

Inspection Report# : 2008006 (pdf)

Significance:a graphic of the significance Dec 31, 2007
Identified By: NRC
Item Type: NCV NonCited Violation
Failure to Establish Needed Test Conditions to Satisfy Technical Specification Surveillance Requirement 3.8.1.18
The inspectors identified a Green noncited violation of 10 CFR 50, Appendix B, Criterion XI, “Test Control,” after AmerenUE confirmed that the load shedding emergency load sequencing test could not demonstrate that component cooling water pump breakers would perform satisfactorily in service. On November 19, 2007, AmerenUE determined that quantitative data did not exist to support that component cooling water pump breakers would be capable of closing at Step 1 (5 seconds) of the load shedding emergency load sequence. Technical Specification Surveillance Requirement 3.8.1.18, testing of the emergency load sequencing, required the licensee to verify that load blocks are actuated within +/-10 percent of the specified start time.

This finding, failure to correctly test 4 kV essential bus loading, is more than minor because it was associated with the reactor safety mitigating systems cornerstone attribute of equipment performance and affected the cornerstone objective to ensure availability and reliability of systems that respond to initiating events to prevent undesirable consequences. Using the Manual Chapter 0609, “Significance Determination Process,” Phase 1 worksheet, this finding was determined to have very low safety significance because it was not a design or qualification deficiency, did not represent a loss of system safety function, did not represent a loss of safety function of a single train for greater than its Technical Specification allowed outage time and did not affect seismic, flooding, or severe weather initiating events. This finding was evaluated as not having a crosscutting aspect because it was not reflective of current licensee performance.
Inspection Report# : 2007005 (pdf)

Significance:a graphic of the significance Dec 31, 2007
Identified By: NRC
Item Type: NCV NonCited Violation
Failure to Adequately Manage Increased Risk During a Maintenance Activity
The inspectors identified a Green noncited violation of 10 CFR 50.65(a)(4) after AmerenUE operating personnel failed to implement prescribed risk management actions associated with maintenance on the Train B emergency diesel generator. NRC inspectors performed a walkdown of the risk management actions prescribed and noted the omission of the measures to protect the turbine-driven auxiliary feedwater pump. AmerenUE’s review determined that operators failed to follow work instructions to post the p3rotective measure.

This finding is greater than minor because it was related to maintenance risk management, the overall plant risk assessed was greater than 1.0 E-6 and the licensee failed to implement some prescribed significant compensatory measures. Using Manual Chapter 0609, Appendix K, “Maintenance Risk Assessment and Risk Management Significance Determination Process,” Flowchart 2, “Assessment of Risk Management Actions,” the inspectors determined this finding to be of very low safety significance because other risk management actions were taken. This finding has a crosscutting aspect in the area of human performance associated with the work practices component because operating personnel did not follow instructions to implement the licensee’s prescribed risk management actions. [H.4(b)]
Inspection Report# : 2007005 (pdf)

Significance:a graphic of the significance Sep 22, 2007
Identified By: Self-Revealing
Item Type: NCV NonCited Violation
Failure to Promptly Correct a Condition Adverse to Quality for Train B Motor-driven Auxiliary Feedwater Pump
A self-revealing Green noncited violation of 10 CFR 50, Appendix B, Criteria XVI, “Corrective Action,” was identified after the licensee allowed the Train B motor-driven auxiliary feedwater pump to be returned to service even though maintenance personnel could not meet the coupling shaft separation tolerance during a maintenance activity on April 12, 2007. Engineering personnel approved deviating from the coupling shaft separation tolerance without considering the impact on the motor thrust bearing. On July 4, 2007, motor disassembly revealed that there was damage to the thrust bearing caused by the inadequate shaft separation distance.

This finding is greater than minor because, similar to Example 5b provided in Manual Chapter 0612, Appendix E, the licensee’s failure to address the impact of plant changes allowed the component to be returned to service prior to correcting the problem. This finding was associated with the mitigating systems cornerstone equipment performance attribute and affected the objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors used the Manual Chapter 0609, "Significant Determination Process," Phase 1 worksheet to analyze this finding. The inspectors determined this finding is of very low safety significance because it is not a design or qualification deficiency confirmed to result in loss of operability per Part 9900, Technical Guidance, “Operability Determination Process for Operability and Functional Assessment;” did not result in loss-of-safety function of a single train for greater than the Technical Specification allowed outage time; and was not a potentially risk significant seismic, flooding, or severe weather event. This finding has a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program component because engineering personnel did not thoroughly evaluate the apparent problem with the coupling (P.1(c)). This issue was entered into the licensee's corrective action program as Callaway Action Request 200708752.
Inspection Report# : 2007004 (pdf)


Barrier Integrity


Emergency Preparedness

Significance:a graphic of the significance Aug 10, 2007
Identified By: NRC
Item Type: NCV NonCited Violation
Licensee Practices Allow Protective Action Recommendations for Areas Where Protective Action Guides are not Exceeded.
The inspectors identified a noncited violation of 10 CFR 50.54(q), 50.47(b)(10), and 10 CFR Part 50, Appendix E, IV(B), for practices that require licensee protective action recommendations to be made for areas offsite that are not affected by the radiological release, contrary to federal guidance. Programmatic expectations (including on-the-job training) to recommend offsite protective actions for the public in areas where dose assessment has not identified that protective action guides are exceeded is a performance deficiency.

This finding is more than minor because it is not similar to the examples of Manual Chapter 0612, Appendix E, and has the potential to impact public safety. This finding is of very low safety significance because it is a failure to comply with NRC requirements, is associated with Emergency Preparedness Planning Standard 50.47(b)(10), is associated with a risk significant planning standard as defined in Manual Chapter 0609, Appendix B, and is not a risk significant planning standard functional failure or risk significant planning standard degraded function because appropriate licensee protective action recommendations in accordance with federal guidance would be issued for all areas of the emergency planning zone where Protective Action Guides are identified as exceeded. This finding is a noncited violation of 10 CFR 50.54(q) and 50.47(b)(10). The licensee has entered this issue into their corrective action system as Callaway Action Request 200707375. This finding was evaluated as not having a crosscutting aspect.
Inspection Report# : 2007005 (pdf)


Occupational Radiation Safety

Significance:a graphic of the significance Oct 05, 2007
Identified By: Self-Revealing
Item Type: NCV NonCited Violation
Failure to Adhere to a Radiation Work Permit Requirement
The inspectors reviewed a self-revealing, noncited violation of a Technical Specification 5.4.1.a. required procedure that resulted in the external contamination of a work group with two of the four workers receiving internal contamination. Specifically, a work group alarmed the personnel contamination monitors while exiting the Radiological Control Area. The licensee investigated the event and determined that the workers did not use the faceshields as required by their radiation work permit and that the radiation protection technician failed to recognize that the workers did not have them. As corrective action, the licensee developed a plant systems job aid for new and supplemental radiation protection technicians, added the event as operating experience to radiation protection and radiation worker training, and implemented disciplinary action.

The failure to adhere to a radiation work permit requirement is a performance deficiency. This finding is more than minor because it is associated with the occupational radiation safety exposure control attribute and affected the cornerstone objective to ensure the adequate protection of the worker health and safety from unnecessary exposure to radiation. The failure to adhere to a radiation work permit requirement lead to workers’ unintended and additional personnel exposure. The finding was determined to be of very low safety significance because it did not involve: (1) as low as reasonably achievable planning and controls, (2) an overexposure, (3) a substantial potential for overexposure, or (4) an impaired ability to assess dose. In addition, this finding has a human performance crosscutting component with an aspect of work practices in human error prevention techniques because the workers did not use peer- and self-checking to ensure the radiation work permit required protective equipment was used. [H.4(a)]
Inspection Report# : 2007005 (pdf)

Significance:a graphic of the significance Oct 05, 2007
Identified By: Self-Revealing
Item Type: NCV NonCited Violation
Failure to notify radiation protection of an electronic dosimeter alarm.
The inspectors reviewed a self-revealing, noncited violation of a Technical Specification 5.4.1.a. required procedure that resulted when mechanical maintenance workers did not report electronic dosimeter alarms when received. Specifically, during troubleshooting of a waste gas compressor failure, two mechanical maintenance workers received an electronic dosimeter dose rate alarm. The workers exited the room, checked their dosimeters for a dose alarm, determined the noise was due to the compressor and returned to work as no worker had a visible dose alarm. The workers failed to recognize that the electronic dosimeters would not hold and display a dose rate alarm once out of the elevated radiation field. The workers did not notify radiation protection of the electronic dosimeter alarms. When exiting the radiological control area, the electronic dosimeter system alerted the workers to the alarms and barred them from the radiological control area for further entries. As corrective action, the workers were coached on expected dosimeter alarm response and the mechanical maintenance supervisor discussed the event during their group meeting as a learning experience.

The failure to notify radiation protection of an electronic dosimeter alarm is a performance deficiency. This finding is more than minor because it is associated with the occupational radiation safety exposure control attribute and affected the cornerstone objective to ensure the adequate protection of the worker health and safety from unnecessary exposure to radiation. The failure to notify radiation protection in the event of an electronic dosimeter alarm could lead to a worker’s unintended and additional personnel exposure. The finding was determined to be of very low safety significance because it did not involve: (1) as low as reasonably achievable planning and controls, (2) an overexposure, (3) a substantial potential for overexposure, or (4) an impaired ability to assess dose. In addition, this finding has a human performance crosscutting component with an aspect of work practices in human error prevention techniques because the workers proceeded in the face of uncertainty or unexpected circumstances when dose rate alarms were received. [H.4(a)]
Inspection Report# : 2007005 (pdf)


Public Radiation Safety


Physical Protection

Although the NRC is actively overseeing the Security cornerstone, the Commission has decided that certain findings pertaining to security cornerstone will not be publicly available to ensure that potentially useful information is not provided to a possible adversary. Therefore, the cover letters to security inspection reports may be viewed.


Miscellaneous

Last modified : August 29, 2008