Callaway Junk plant: Can't Put Lipstick On This Reverse Engineered Pig.

So they botched the replacement of a electronics controller on a emergency makeup water system for a steam generator. They were reverse engineering this card because of no replacements on the aux feed control to the Steam generator. You got to know everything in this system is aged out and obsolete.

Ameren owns this pig

So Callaway is having troubles replacing aged out equipment. As in my other Callaway article, they had plenty of opportunities to know they put in defective parts into nuclear safety systems and they neglected to fix fixed when the problem emerged.

When does the NRC get overwhelmed and exhausted by all by the degradation going on throughout the industry. The industry wide decline.  

Seven NRC violations on this one event. The magnitude of this speaks volumes.          

January 13, 2016

SUBJECT: CALLAWAY PLANT - NRC SPECIAL INSPECTION REPORT 05000483/2015009

• Green. The team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, “Design Control,” for the licensee’s failure to assure that the design of the replacement reverse-engineered Modutronics controller cards for the auxiliary feedwater control valves were suitable for their application. Specifically, as of August 11, 2015, the licensee failed to establish suitable interface requirements in procurement documents to Nuclear Logistics Incorporated (the vendor) and verify the adequacy of the design by either design reviews or testing. Specifically, the team identified that neither the licensee nor the vendor had performed a design review sufficient to assure that the Modutronics controller cards were suitable for their application. In addition, the licensee had not provided the vendor with sufficient information to reverse-engineer the controller cards. Lastly, neither the licensee nor the vendor performed testing sufficient to verify the adequacy of the design of the new Modutronics controller cards. As a result, the replacement cards were supplied with motor field current rectifier bridges that were undersized and marginal for their application, such that two of them failed in service, rendering these auxiliary feedwater system valves inoperable. Following performance of a root cause analysis, the licensee replaced the deficient controller cards with those of a higher current rating. The licensee initiated Callaway Action Request 201505796 to place this item into the corrective action program.

• Green. The team reviewed a self-revealing non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, “Instructions, Procedures, and Drawings,” for failure to prescribe activities affecting quality using procedures appropriate to the circumstances. Specifically, on November 18, 2009, the licensee revised Procedure MTE-ZZ-QA033, “MOVATS UDS [motor operated valve actuator test system universal diagnostic system] Testing of Torque Controlled Modutronics Limitorque Motor Operated Rising Stem Valves,” Revision 3, to incorporate a second method of valve testing, and introduced an error in bypassing a test of the Modutronics board setup feedback potentiometer. As a result, on July 23, 2015, the actuator misinterpreted the actual position of the valve, which subsequently failed to open when operators attempted to open the valve following a forced reactor shutdown. In response to this issue, the licensee has reviewed all maintenance and test activities that could affect the potentiometer and has revised the appropriate procedures. This finding was entered into the licensee’s corrective action program as Callaway Action Request 201505332.

• Green. The team reviewed a self-revealing non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, “Test Control,” for failure to ensure that testing demonstrated that structures, systems, and components will perform satisfactorily in service. Specifically, on October 24, 2014, the licensee failed to establish a suitable post-maintenance test program to demonstrate that the motor-driven auxiliary feedwater flow control valve Modutronics potentiometer had been set correctly after maintenance. The testing consisted of stroking the valve full open or full closed, and did not consider step changes in valve positioning and did not confirm the potentiometer feedback settings during valve positions that were not full open or full closed. In response to this issue, the licensee performed another calibration of the potentiometer, focusing on the potentiometer position during the valve stroke. The new post-maintenance test included opening the valve in discreet step changes to test the valve position feedback potentiometer. This finding was entered into the licensee’s corrective action program as Callaway Action Request 201505332.

• Green. The team identified two examples of a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, “Instructions, Procedures, and Drawings,” for the licensee’s failure to implement their corrective action program procedure. Specifically: (1) on November 20, 2014, the licensee designated the improper setting of the auxiliary feedwater flow control valve ALHV005 limit switches as Significance Level 5 (administrative close) instead of Significance Level 3 (lower tier cause evaluation) and (2) on December 9, 2014, the licensee downgraded the failure of the Modutronics card for valve ALHV0005 from Significance Level 1 (root cause analysis) to Significance Level 3 based on unverified assumptions of the failure mechanisms. Following failure of the Modutronics card for valve ALHV0005, the licensee assumed that the early failure was due to a manufacturing defect (infant mortality) without supporting data to prove this designation. The licensee entered these issues into the corrective action program as Callaway Action Requests 201506921 and 201507235.

• Green. The team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, “Corrective Action,” for the licensee’s failure to determine the cause and take corrective action to preclude repetition for a significant condition adverse to quality. Specifically, on May 21, 2015, the licensee received new information that refuted the previously assumed failure mechanism for AFW flow control valve ALHV0005 documented in December 2014, but failed to initiate a new Callaway action request to document the new information and report it to appropriate levels of management. As a result, the licensee failed to identify the failure of the valve as a significant condition adverse to quality, determine the cause, initiate a prompt operability assessment, and identify corrective action to preclude repetition until valve ALHV0007 failed, for the same reason, following a reactor trip on August 11, 2015. The licensee entered this issue into the corrective action program as Callaway action request 201506846.

• Green. The team reviewed a self-revealing non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, “Instructions, Procedures, and Drawings,” for failure to provide a procedure appropriate to the circumstances. Specifically, on March 4, 2014, the licensee performed Job 08505547, and had not correctly accounted for the differential pressure the valve would actually experience, and had incorrectly set and tested the close torque switch on valve ALHV0005. As a result, On November 15, 2015, during steam generator filling operations, Valve ALHV0005 failed to move in the closed direction when the torque switch opened. The incorrect close torque switch setting prevented the valve from going full closed. In response to this issue, the licensee, using Job 14005755, repaired the valve, and confirmed that the close torque switch settings were correct and successfully retested. This finding was entered into the licensee’s corrective action program as Callaway Action Report 201508399.

• Green. The team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, “Corrective Action,” for the licensee’s failure to identify and correct a condition adverse to quality. Specifically, as of September 23, 2015, the licensee had not taken corrective action, following previous identification of undersized field current rectifier bridges, to ensure that an independent review of the modified circuit design had been completed, or that the modified cards had been subjected to a sufficient testing and qualification program. Thus, following questioning by the team, the licensee identified additional components (two other rectifier bridges) on the newly modified circuit cards that were also potentially undersized. The licensee performed an operability evaluation and concluded that the new cards were operable, based on additional circuit analysis that was performed. This issue was entered into the corrective action program as Callaway Action Request 201506874.