IR 05000483/2025010
| ML25266A043 | |
| Person / Time | |
|---|---|
| Site: | Callaway |
| Issue date: | 09/25/2025 |
| From: | Greg Warnick NRC/RGN-IV/DORS/EB2 |
| To: | Karenina Scott Union Electric Co |
| Drake J | |
| References | |
| IR 2025010 | |
| Download: ML25266A043 (1) | |
Text
September 25, 2025
SUBJECT:
CALLAWAY PLANT - FIRE PROTECTION TEAM INSPECTION REPORT 05000483/2025010
Dear Kent Scott:
On September 11, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Callaway Plant and discussed the results of this inspection with Shane Grotewiel, Fire Protection Manager and other members of your staff. The results of this inspection are documented in the enclosed report.
Three findings of very low safety significance (Green) are documented in this report. Three of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, 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; 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 205550001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at the Callaway Plant. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Gregory G. Warnick, Chief Engineering Branch 2 Division of Operating Reactor Safety Docket No. 05000483 License No. NPF-30
Enclosure:
As stated
Inspection Report
Docket Number:
05000483
License Number:
Report Number:
Enterprise Identifier:
I-2025-010-0014
Licensee:
Union Electric Company
Facility:
Callaway Plant
Location:
Steedman, MO
Inspection Dates:
August 25, 2025 to September 11, 2025
Inspectors:
J. Drake, Senior Reactor Inspector
A. Lee, Fire Protection Engineer
J. Mejia, Reactor Inspector
Approved By:
Gregory G. Warnick, Chief
Engineering Branch 2
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a fire protection team inspection at Callaway Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to correct degraded nonconforming conditions in the fire water system in a timely manner Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000483/2025010-01 Open/Closed
[H.1] -
Resources 71111.21N.
The inspectors reviewed a self-revealed Green finding and associated non-cited violation of License Condition 2.C.(5), Fire Protection Program, for the licensees failure to implement the fire protection program. Specifically, the licensee failed to ensure the availability and reliability of fire protection systems as the fire water system has been inoperable but functional since April 12, 2014, due to an inability to satisfactorily complete surveillance requirements and numerous degraded and nonconforming conditions were not corrected in a timely manner.
A nonconservative calculation was used to justify not implementing compensatory measures during control room ventilation isolation system testing Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000483/2025010-02 Open/Closed
[P.2] -
Evaluation 71111.21N.
The inspectors identified a Green finding and associated non-cited violation of License Condition 2.C.(5), Fire Protection Program, associated with the licensee's use of a nonconservative calculation to justify not implementing compensatory measures for the ESF (engineered safety feature) switchgear room 3301 halon system during testing of the control room ventilation isolation system (CRVIS).
Failure to properly evaluate changes to the ventilation system fans for impact on the fire protection program Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000483/2025010-03 Open/Closed
[H.3] - Change Management 71111.21N.
The inspectors identified a Green finding and associated non-cited violation of Technical Specification 5.4.1.a for the licensees failure to implement procedures associated with design control. Specifically, the licensee implemented a design modification to various safety-related ventilation fans that changed their flow rates but did not perform an engineering evaluation using relevant technical requirements or standards to confirm that the design change did not adversely affect the fire protection program.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.21N.05 - Fire Protection Team Inspection (FPTI) Structures, Systems, and Components (SSCs) Credited for Fire Prevention, Detection, Suppression, or Post-Fire Safe Shutdown Review (IP Section 03.01)
The inspectors verified that components and/or systems will function as required to support the credited functions stated for each sample. Additional inspection considerations are located in the fire hazards analysis (FHA) or safe shutdown analysis (SSA).
(1)halon suppression system for ESF (engineered safety features) switchgear room 3301 (2)fire water suppression system, including yard header (3)post-fire safe shutdown systems used during a control room fire/evacuation
Fire Protection Program Administrative Controls (IP Section 03.02) (1 Sample)
The inspectors verified that the selected control or process is implemented in accordance with the licensees current licensing basis. If applicable, ensure that the licensees fire protection program (FPP) contains adequate procedures to implement the selected administrative control. Verify that the selected administrative control meets the requirements of all committed industry standards.
(1)reviewed the fire brigade training/qualification program and observed the announced drill, and the administrative control of fire impairments and operating experience
Fire Protection Program Changes/Modifications (IP Section 03.03) (1 Sample)
The inspectors verified the following:
- changes to the approved FPP do not constitute an adverse effect on the ability to safely shutdown
- the adequacy of the design modification process
- assumptions and performance capability stated in the SSA have not been degraded through changes or modifications
- the FPP documents, such as the Updated Final Safety Analysis Report, fire protection report, FHA, and SSA were updated consistent with the FPP or design change
- post-fire safe shutdown (SSD) operating procedures, such as abnormal operating procedures, affected by the modification were updated
- (1) Design Change Package CA4600B, RFR 210038 - Modification Request for Speed Changes for Safety Related Belt Driven Fans, revision
INSPECTION RESULTS
Failure to correct degraded nonconforming conditions in the fire water system in a timely manner Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000483/2025010-01 Open/Closed
[H.1] -
Resources 71111.21N.0 The inspectors reviewed a self-revealed Green finding and associated non-cited violation of License Condition 2.C.(5), Fire Protection Program, for the licensees failure to implement the fire protection program. Specifically, the licensee failed to correct conditions adverse to quality in the fire water system in a timely manner as required by the corrective action program.
Description:
The inspectors identified that per the EOSL (equipment out of service log) 19797, the fire water system has been inoperable but functional since April 12, 2014, due to an inability to satisfactorily complete section 6.4.2 of surveillance procedure OSP-KC-00003, Fire Suppression Water System Valve Cycling. Additionally, the inspectors noted multiple condition reports documenting degraded and nonconforming conditions, such as excessive valve seat leakage, through wall leaks on pipes, and valves that were installed in the wrong orientation per vendor design manuals. NFPA 805, section 2.6 requires that a monitoring program shall be established to ensure that the availability and reliability of the fire protection systems and features are maintained and to assess the performance of the fire protection program in meeting the performance criteria. Monitoring shall ensure that the assumptions in the engineering analysis remain valid. However, the licensee failed to meet these requirements by not correcting degraded and nonconforming conditions in the fire water system in a timely manner as required by the corrective action program.
As a result of the licensees failure to correct the degraded and nonconforming conditions a portion of the yard loop was isolated due to system leakage beyond the capacity of the jockey pump to maintain system pressure. Specifically, on June 10, 2025, when attempting to restore the system from C-factor fire main testing per procedure OSP-KC-03003, the electric fire pump could not be secured due to header pressure not being maintained by the jockey pump. Multiple attempts were made with the jockey pump and air compressor running in hand to maintain header pressure unsuccessfully. Leakage was determined to be 40-45 gallons per minute (gpm) from the fire system. Remedial actions were taken to isolate the leak and FPIP (fire protection improvement plan) 33277 was created for additional monitoring of the electric fire pump temperatures. All compensatory actions required by procedure APA-ZZ-00703, Fire Protection Operability Criteria and Surveillance Requirements were implemented. The licensee completed multiple isolations of the main loop and identified the leak on the branch line from valve VKC1001K to the warehouse maintenance building or the loop going to the training center. These isolations reduced total system leakage to 3 gpm based on accumulator tank usage. Leak detection dye was used to aid in the leak identification and determined fire water was entering sump PLUB2003 (MH59-12) as well as multiple ground spots in the yard. A visual inspection of the loop piping using a remote camera was unsuccessful in locating the flaws and the licensee considered additional methods to locate and repair the degraded condition and restore the system.
Corrective Actions: The licensee has entered the issue into their corrective action program, isolated portions of the yard loop and continued inspections to locate the piping flaws.
Corrective Action References: Condition reports 201805199, 201901474, 202002787, 202100107, 202205480, 202300344, 202503613, 202504140, 202503422
Performance Assessment:
Performance Deficiency: The licensees failure to correct degraded and nonconforming conditions in the fire water system in a timely manner to ensure compliance with License Condition 2.C.(5) was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to correct degraded nonconforming conditions in the fire water system in a timely manner to ensure the availability and reliability of the fire protection systems and features were maintained.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The inspectors assigned the finding a fire category 1.4.2 using IMC 0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, dated May 2, 2018, because the finding involved fixed fire suppression systems. The inspectors determined that the finding had very low safety significance (Green) because the finding:
- (1) did not increase the likelihood of a fire, delay detection of a fire, or result in a more significant fire than previously analyzed such that credited safe shutdown strategy could be adversely impacted; and
- (2) the degraded fire suppression element continued to provide adequate fire suppression to prevent fire propagation through the fire confinement element given the combustible loading and location of equipment important to safe shutdown in the fire area of concern.
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety. The licensee failed to allocate sufficient funding to repair degraded and nonconforming conditions in the fire water system.
Enforcement:
Violation: License Condition 2.C.(5), Fire Protection Program, requires the licensee to implement the fire protection program as set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c).
Title 10 CFR 50.48(c) endorses the use of NFPA 805. NFPA 805 section 2.6 requires that a monitoring program shall be established to ensure that the availability and reliability of the fire protection systems and features are maintained and to assess the performance of the fire protection program in meeting the performance criteria. The fire protection program utilizes the corrective action program to document and respond to any issue, concern, or condition discovered at the Callaway Plant. Procedure APA-ZZ-00500 Corrective Action Program, revision 082, section 3.15.1.a requires that leaders and supervisors ensure conditions adverse to quality identified are resolved in a timely manner.
Contrary to the above, from April 12, 2014, until September 11, 2025, the licensee failed to implement the fire protection program to effectively use a monitoring program to ensure the availability and reliability of the fire protection systems and features were maintained and to assess the performance of the fire protection program in meeting the performance criteria, such that conditions adverse to quality were identified but not resolved in a timely manner.
Specifically, the fire water system has been inoperable but functional since April 12, 2014, due to an inability to satisfactorily complete surveillance requirements and the failure to correct numerous degraded and nonconforming conditions in a timely manner.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
A nonconservative calculation was used to justify not implementing compensatory measures during control room ventilation isolation system testing Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000483/2025010-02 Open/Closed
[P.2] -
Evaluation 71111.21N.0 The inspectors identified a Green finding and associated non-cited violation of License Condition 2.C.(5), Fire Protection Program, associated with the licensee's use of a nonconservative calculation to justify not implementing compensatory measures for the ESF (engineered safety feature) switchgear room 3301 halon system during testing of the control room ventilation isolation system (CRVIS).
Description:
Operating experience identified that the halon systems protecting both ESF switchgear rooms were rendered inoperable when the CRVIS was in operation. Two ventilation dampers in parallel through the common fire wall separating these rooms open when CRVIS starts. The inspectors identified that these dampers do not automatically shut when the halon system actuates if CRVIS is actuated and air is exhausted from the room.
The halon system design assumes no exhaust flow is present and that all dampers are in the assumed position during actuation to reach the required 5% halon concentration and maintain it for 10 minutes. The concern was that the system would not be capable of reaching the required concentration to suppress a fire in either switchgear room under these conditions because halon would be allowed to escape. A technical specification surveillance requires that CRVIS be run for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> on a monthly periodicity. During this period when the halon system was inoperable, the licensee was required to establish a continuous fire watch with backup fire suppression capability in the affected area within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. This requirement should have been implemented during each monthly CRVIS surveillance, as well as any other time the system was run for longer than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. However, the licensee elected to demonstrate through calculations that even with the pressurization fans running and the dampers open the halon system would still reach the 5% halon concentration and maintain it for at least 10 minutes. The inspectors identified nonconservative values were used in the calculations for halon quantities, room volume, fan flow rates and the length of time the dilution occurred, such that there were concerns that the initial halon concentration would not reach and be maintained at the design required 5% for 10 minutes for all scenarios. The margin of excess halon quantity was significantly reduced when corrections to the calculations were made, although it was determined that the system would still function to suppress the fire and coupled with the 100% capacity reserve bank of halon, fire brigade response, and 3-hour fire rated barrier separation between ESF switchgear rooms 3301 and 3302. Thus, the defense-in-depth fire protection strategy was maintained for the ESF switchgear rooms.
Corrective Actions: The licensee entered the issue into the corrective action program and recalculated the halon concentration levels for the rooms.
Corrective Action References: Condition report 202505515
Performance Assessment:
Performance Deficiency: The licensees use of a nonconservative calculation to justify not implementing compensatory measures for the ESF switchgear rooms during CRVIS actuation was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to use conservative values and assumptions when calculating impact of the forced ventilation in the ESF switchgear rooms during CRVIS operations resulted in significant reductions in the operational margins for the halon systems.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The inspectors assigned the finding a fire category 1.4.2 using IMC 0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, dated May 2, 2018, because the finding involved fixed fire suppression systems. The inspectors determined that the finding had very low safety significance (Green) because the finding:
- (1) did not increase the likelihood of a fire, delay detection of a fire, or result in a more significant fire than previously analyzed such that credited safe shutdown strategy could be adversely impacted; and
- (2) the degraded fire suppression element continued to provide adequate fire suppression to prevent fire propagation through the fire confinement element given the combustible loading and location of equipment important to safe shutdown in the fire area of concern.
Cross-Cutting Aspect: P.2 - Evaluation: The organization thoroughly evaluates issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, the licensee failed to thoroughly review and understand the values used in the calculation that justified not implementing compensatory measures when the control room ventilation isolation system was active.
Enforcement:
Violation: License Condition 2.C.(5), Fire Protection Program, requires the licensee to implement and maintain in effect all provisions of the approved fire protection program. The licensee established procedures APA-ZZ-00750, Hazard Barrier Program, and APA-ZZ-00703, Fire Protection Operability Criteria and Surveillance Requirements, to identify compensatory measures to be implemented during performance of surveillances that impact the fire protection program.
Contrary to this requirement, from November 9, 2015, until September 11, 2025, the licensee failed to implement provisions of the approved fire protection program to identify compensatory measures to be implemented during performance of surveillances that impact the fire protection program. Specifically, the licensee failed to follow procedures since they improperly used a nonconservative calculation to justify not implementing compensatory measures for the ESF switchgear rooms when CRVIS was in operation and the halon systems were impacted.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to properly evaluate changes to the ventilation system fans for impact on the fire protection program Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000483/2025010-03 Open/Closed
[H.3] - Change Management 71111.21N.0 The inspectors identified a Green finding and associated non-cited violation of Technical Specification 5.4.1.a for the licensees failure to implement procedures associated with design control. Specifically, the licensee implemented a design modification to various safety-related ventilation fans that changed their flow rates but did not perform an engineering evaluation using relevant technical requirements or standards to confirm that the design change did not adversely affect the fire protection program.
Description:
While reviewing an issue with halon concentrations for the ESF switchgear rooms, the inspectors identified that a modification had been completed on various safety-related ventilation fans that resulted in a change to their flow rates. NFPA 805 chapter 3.2.3(1) requires that procedures be established to accomplish inspection, testing and maintenance for fire protection systems and features credited by the fire protection program.
The licensee has the following procedures for modification implementation and screening: IP-ENG-001, Standard Design Process, APA-ZZ-00323, Configuration Management Process, APA-ZZ-00600, Design Change Control, APA-ZZ-00604, Request for Resolution, EDP-ZZ-04023, Calculations, and EDP-ZZ-04600, Engineering Change Control. Contrary to the requirements in the preceding procedures for screening of modification packages for impacts on the fire protection program and associated systems, the licensee failed to review the impact of design modification package MP 21-0011, "Speed Changes for Safety Related Belt Driven Fans" on calculations that use ventilation flow rates as design inputs. The changes in ventilation flow rates impacted the halon suppression systems.
Corrective Actions: The issue was entered into the corrective action program.
Corrective Action References: Condition report 202505527
Performance Assessment:
Performance Deficiency: The failure to ensure that changes to the facility were subject to design control measures commensurate with those applied to the original design and did not impact the fire protection program was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Configuration Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to recognize and evaluate the impact of changing ventilation flow rates on the halon suppression systems.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The inspectors assigned the finding a fire category 1.4.2 using IMC 0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, dated May 2, 2018, because the finding involved fixed fire suppression systems. The inspectors determined that the finding had very low safety significance (Green) because the finding:
- (1) did not increase the likelihood of a fire, delay detection of a fire, or result in a more significant fire than previously analyzed such that credited safe shutdown strategy could be adversely impacted; and
- (2) the degraded fire suppression element continued to provide adequate fire suppression to prevent fire propagation through the fire confinement element given the combustible loading and location of equipment important to safe shutdown in the fire area of concern.
Cross-Cutting Aspect: H.3 - Change Management: Leaders use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority.
Specifically, the licensee failed to use a process to adequately screen a design change to ventilation fans for its impact on the fire protection program.
Enforcement:
Violation: Technical Specification 5.4.1.a requires that the licensee develop and implement procedures to ensure design changes are subject to design control measures commensurate with those applied to the original design. The licensee developed the following procedures for modification implementation and screening: IP-ENG-001, Standard Design Process, APA-ZZ-00323, Configuration Management Process, APA-ZZ-00600, Design Change Control, APA-ZZ-00604, Request for Resolution, EDP-ZZ-04023, Calculations, and EDP-ZZ-04600, Engineering Change Control.
Contrary to the above, on June 27, 2024, the licensee failed to properly implement the preceding procedures for modification implementation and screening of a design change package for impacts on the fire protection program and associated systems. Specifically, the licensee failed to follow procedures and review the impact of modification MP 21-0011, "Speed Changes for Safety Related Belt Driven Fans" on calculations that use ventilation flow rates as design inputs. As a result, the licensee implemented a modification to various safety-related ventilation fans that changed their flow rates but did not perform an engineering evaluation using relevant technical requirements or standards to confirm that the design change did not adversely affect the fire protection program.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified that no proprietary information was retained or documented in this report.
- On September 11, 2025, the inspectors presented the fire protection team inspection results to Shane Grotewiel, Fire Protection Manager and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.21N.05
Calculations
KC-11
Halon Concentration in ESF (Engineered Safety Features)
RM (Room)
71111.21N.05
Calculations
KC-11 Add. 1
Halon Concentration in ESF (Engineered Safety Features)
RM (Room)
71111.21N.05
Calculations
KC-162
Performance Based Fire Protection Surveillance
Frequency Program
001
71111.21N.05
Calculations
KC-222
Halon Concentrations Calculations
000
71111.21N.05
Calculations
KC-26
Nuclear Safety Capability Assessment
003
71111.21N.05
Calculations
KC-27
NFPA Code Conformance Review Calc
003
71111.21N.05
Calculations
KC-61
Fire Modeling Report for Fire Area C-10
71111.21N.05
Calculations
M-KC-285 Add. 2
ESF (Engineered Safety Features) Room Volume
Correction
71111.21N.05
Corrective Action
Documents
Resulting from
Inspection
CR
2505238, 202505257, 202505259, 202505263,
2505301, 202505312, 202505314, 202505315,
2505317, 202505466, 202505475, 202505502,
2505515, 202505527, 202505645. 202505646,
2505647, 202505648, 202505649
71111.21N.05
Miscellaneous
10466-M-658
Technical Specifications for Halon System
01/27/1986
71111.21N.05
Miscellaneous
CA2913
Ska-Pak Proficiency Demonstration
71111.21N.05
Miscellaneous
KC-162
Performance Based Fire Protection Surveillance
Frequency Program
001
71111.21N.05
Miscellaneous
LOCT 23-1 C-7
Licensed Operator Continuing Training Cycle 23-1 Control
Room Inaccessibility
01/11/2023
71111.21N.05
Miscellaneous
MP 21-0006
RFR 200136 - KCV0013 and KCV0457 Updates to
Support OSP-KC-00003, Section 6.4.2
0000
71111.21N.05
Miscellaneous
MSM-KC-FT001
Halon Fire Protection Cylinder Inspection
038
71111.21N.05
Miscellaneous
RFR 23170 A
Compensatory Measures - Dampers Between ESF SG
RMS (Engineered Safety Features Switchgear Rooms)
11/26/2003
71111.21N.05
Miscellaneous
T61.0810 8
C-2 Control Room Operations with Fire
07/11/2024
71111.21N.05
Miscellaneous
T61.0810 8
Licensed Operator Continuing Training
220823
71111.21N.05
Miscellaneous
T61.0810.8
Licensed Operator Continuing Training
20110814
71111.21N.05
Procedures
APA-ZZ-00101
Processing Procedures, Manuals, And Desktop
084
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Instructions
71111.21N.05
Procedures
APA-ZZ-00320
Work Execution
084
71111.21N.05
Procedures
APA-ZZ-00322
Integrated Work Management Process Description
Administrative Correction
23
71111.21N.05
Procedures
APA-ZZ-00323
Configuration Management Process Administrative
Correction
23
71111.21N.05
Procedures
APA-ZZ-00340
Surveillance Program procedure
059
71111.21N.05
Procedures
APA-ZZ-00395
Significant Operator Response Timing
2, 033,
034, 035
71111.21N.05
Procedures
APA-ZZ-00500
Corrective Action Program Administrative Correction
2
71111.21N.05
Procedures
APA-ZZ-00500
APP5
Maintenance Rule
039
71111.21N.05
Procedures
APA-ZZ-00500
Appendix 10
Trending Program
25
71111.21N.05
Procedures
APA-ZZ-00600
Design Change Control
2
71111.21N.05
Procedures
APA-ZZ-00604
Requests For Resolution
2
71111.21N.05
Procedures
APA-ZZ-00605
Temporary System Modifications
045
71111.21N.05
Procedures
APA-ZZ-00700
030, 032,
033
71111.21N.05
Procedures
APA-ZZ-00701
Control Of Fire Protection Impairments Administrative
Correction
28, 029,
030
71111.21N.05
Procedures
APA-ZZ-00703
Fire Protection Operability Criteria And Surveillance
Requirements
035
71111.21N.05
Procedures
APA-ZZ-00741
Control of Combustible Materials
71111.21N.05
Procedures
APA-ZZ-00741
Appendix 1 Flammable Liquid Cabinet Locations
030, 031,
2, 033
71111.21N.05
Procedures
CDP-ZZ-01100
Atmospheric Hazard Control Program
21
71111.21N.05
Procedures
CW-AMP-
B2.1.13
Fire Protection
000
71111.21N.05
Procedures
CW-AMP-
B2.1.14
Fire Water System
000
71111.21N.05
Procedures
CW-AMP-
B2.1.15
Aboveground Metallic Tanks
000
71111.21N.05
Procedures
CW-AMP-
Buried and Underground Piping and Tanks
000
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
B2.1.25
71111.21N.05
Procedures
EDP-ZZ-01101
Fire Protection Monitoring Program Administrative
Correction
004
71111.21N.05
Procedures
EDP-ZZ-04023
Calculations
2
71111.21N.05
Procedures
EDP-ZZ-04600
Engineering Change Control
20, 021
71111.21N.05
Procedures
Fire Protection Training Program
040, 041
71111.21N.05
Procedures
HDP-ZZ-08000
Respiratory Protection Program
25
71111.21N.05
Procedures
MDP-ZZ-LR001
Temporary Repair Of Leaks
007
71111.21N.05
Procedures
ODP-ZZ-00001
Operations Department - Code Of Conduct
115
71111.21N.05
Procedures
Fire Suppression Water System Valve Cycling
23, 024,
25
71111.21N.05
Procedures
Fire Water Main Drain Testing
000
71111.21N.05
Procedures
OTO-KC-00001
Fire Response
71111.21N.05
Procedures
OTO-ZZ-00001
Control Room Inaccessibility
049
71111.21N.05
Procedures
OTO-ZZ-00002
Control Room Operations With Fire
009
71111.21N.05
Procedures
WDP-ZZ-00018
Upgrade of Parts, Materials and Supplies (Commercial
Grade)
015
71111.21N.05
Work Orders
Job
21004074, 22001441, 22003968, 22005021