ML042440533

Midcycle Performance Review and Inspection Plan - Callaway Plant

ML042440533
Person / Time
Site:	Callaway
Issue date:	08/30/2004
From:	Howell A NRC/RGN-IV/DRP
To:	Randolph G Union Electric Co
References
Download: ML042440533 (8)

Text

August 30, 2004 Garry L. Randolph, Senior Vice President and Chief Nuclear Officer Union Electric Company P.O. Box 620 Fulton, MO 65251

SUBJECT:

MIDCYCLE PERFORMANCE REVIEW AND INSPECTION PLAN -

CALLAWAY PLANT

Dear Mr. Randolph:

On August 5, 2004, the NRC staff completed its midcycle plant performance assessment of Callaway Plant. The midcycle review for Callaway Plant involved the participation of all technical divisions in evaluating performance for the first half of the calendar year 2004 assessment cycle. The process included a review of performance indicators (PIs) for the most recent quarter and inspection results over the previous 12 months. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility so that you will have an opportunity to prepare for these inspections and to inform us of any planned inspections that may conflict with your plant activities.

This performance review and inspection plan does not include physical protection information.

A separate letter designated and marked as Exempt from Public Disclosure in Accordance with 10 CFR 2.390 will include the physical protection review and resultant inspection plan.

Plant performance for the most recent quarter was within the Regulatory Response Column of the NRCs Action Matrix. During the second quarter of the assessment cycle, a performance indicator in the Initiating Events cornerstone for Unplanned Scrams per 7000 Critical Hours was White. When you have completed your evaluation of the issues that led to the performance indicator exceeding the White threshold, a supplemental inspection, performed in accordance with Inspection Procedure 95001, Inspection for One or Two White Inputs in a Strategic Performance Area, will be conducted. In particular, we will focus on understanding whether the corrective actions for these reactor trips will be effective in preventing similar types of operator performance issues that were associated with these initiating events.

In our midcycle assessment letter dated August 27, 2002, we advised you of a substantive crosscutting issue in the area of Problem Identification and Resolution. Common themes identified in this and subsequent assessment letters included weaknesses with problem recognition and inadequate corrective actions for known problems. In our annual assessment letter dated March 3, 2004, we acknowledged the actions you had taken to address this issue.

These actions included a number of organizational and programmatic changes, including

Union Electric Company implementation of a Corrective Action Review Board and expanded training activities. Despite these improvements, we noted continuing instances of ineffective problem identification and corrective action effectiveness. As a result, we informed you of our plans to further monitor your actions to address this issue during the implementation of the baseline inspection program, including the conduct of a problem identification and resolution team inspection. We also requested that you discuss your actions to address this issue during the public meeting discussion of NRCs assessment of Callaway Plant performance.

At the public meeting, which was conducted on April 7, 2004, your staff discussed other actions taken in response to this substantive crosscutting issue, including the development of PIs.

Your staff indicated that these improvements have resulted in more organizational involvement, reduced completion time with improved quality, reduced backlogs, and improved management oversight. A number of future areas of emphasis were also discussed. We agree that the actions you have taken have been effective in enhancing the overall effectiveness of your corrective action program. Therefore, we no longer have identified a substantive crosscutting issue in this area and will discontinue our increased oversight.

In a March 21, 2003, letter to NRC, you stated that you had contracted with a professional survey firm to conduct a nuclear safety cultural assessment at the Callaway Plant. On the basis of results of that survey, you implemented a number of actions to address the findings identified during the survey. Our inspection of your corrective action program, documented in NRC Inspection Report 05000483/2004006, dated April 2, 2004, noted that your corrective actions had not been completely effective in addressing some of the concerns raised in the independent survey. It is our understanding that a followup survey will be conducted in November 2004. We will review the results of the followup survey as part of the baseline inspection program in order to determine whether any further action is necessary.

The enclosed inspection plan details the inspections, except those related to physical protection, scheduled through March 31, 2006. In addition to the baseline inspection program, inspections focusing on steam generator replacement activities will be conducted in accordance with NRC Inspection Procedure 50001, Steam Generator Replacement Inspection. As previously discussed, a supplemental inspection will also be conducted to review your evaluation associated with the Performance Indicator that crossed the White threshold. Also, we will conduct a followup inspection of the actions you have taken in response to a 2001 Notice of Violation and Civil Penalty (EA-01-05) involving a violation of 10 CFR 50.7, Employee Protection, requirements. The inspection plan is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite. Routine resident inspections are not listed because of their ongoing and continuous nature. The inspections in the last 12 months of the inspection plan are tentative and may be revised at the end-of-cycle review meeting.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Union Electric Company If circumstances arise which cause us to change the inspection plan, we will contact you to discuss the change as soon as possible. Please contact Mr. David N. Graves at 817-860-8141 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

Arthur T. Howell III, Director Division of Reactor Projects Dockets: 50-483 Licenses: NPF-30

Enclosure:

Callaway Plant Inspection/Activity Plan cc:

Professional Nuclear Consulting, Inc.

19041 Raines Drive Derwood, MD 20855 John ONeill, Esq.

Shaw, Pittman, Potts & Trowbridge 2300 N. Street, N.W.

Washington, DC 20037 Mark A. Reidmeyer, Regional Regulatory Affairs Supervisor Regulatory Affairs AmerenUE P.O. Box 620 Fulton, MO 65251 Manager - Electric Department Missouri Public Service Commission 301 W. High P.O. Box 360 Jefferson City, MO 65102 Ronald A. Kucera, Deputy Director for Public Policy Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102

Union Electric Company Rick A. Muench, President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839 Dan I. Bolef, President Kay Drey, Representative Board of Directors Coalition for the Environment 6267 Delmar Boulevard University City, MO 63130 Chris R. Younie, Manager Quality Assurance AmerenUE P.O. Box 620 Fulton, MO 65251 Jerry Uhlmann, Director State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102-0116 Scott Clardy, Director Section for Environmental Public Health P.O. Box 570 Jefferson City, MO 65102-0570 Keith D. Young, Manager Regulatory Affairs AmerenUE P.O. Box 620 Fulton, MO 65251 David E. Shafer Superintendent, Licensing Regulatory Affairs AmerenUE P.O. Box 66149, MC 470 St. Louis, MO 63166-6149 Certrec Corporation 4200 South Hulen, Suite 630 Fort Worth, TX 76109

Union Electric Company Institute of Nuclear Power Operations (INPO)

Records Center 700 Galleria Parkway SE, Suite 100 Atlanta, GA 30339

Union Electric Company Electronic distribution by RIV:

Regional Administrator (BSM1)

DRP Director (ATH)

DRS Director (DDC)

Senior Resident Inspector (MSP)

Branch Chief, DRP/B (DNG)

Senior Project Engineer, DRP/B (RAK1)

Staff Chief, DRP/TSS (PHH)

RITS Coordinator (KEG)

RidsNrrDipmLipb V. Dricks, PAO (VLD)

W. Maier, RSLO (WAM)

C. Gordon (CJG)

DRS Branch Chiefs (LJS, MPS1, ATG, JAC)

L. Reyes, EDO (LAR1)

S. Richards, Chief, NRR/DIPM/IIPB (SAR)

R. Frahm, PPR Program Manager, NRR/DIPM/IIPB (RKF)

C. Carpenter, Deputy Dir. for Inspection and Programs (CAC)

B. Sheron, Associate Dir. for Project Licensing and Technical Analysis (BWS)

T. Bergman, Chief, ROPMS, OEDO (TAB)

H. Berkow, Director, LPD4, NRR/DLPM (HNB)

R. Gramm, Chief, PDIV-1A, NRR/DLPM (RAG)

T. Alexion, NRR Project Manager (TWA)

ADAMS: / Yes G No Initials: ______

/ Publicly Available G Non-Publicly Available G Sensitive / Non-Sensitive S:\DRP\DRPDIR\MIDCYCLE 2004\CWY RIV:DRP:C\B D:DRS D:DRP DRA RA DNGraves;mjs;dlf DDChamberlain ATHowell TPGwynn BSMallett

/RA/ VLOrdaz for /RA/ /RA/ /RA/

8/13/04 8/25/04 8/28/04 8/27/04 8/27/04 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

Page 1 of 2 Callaway 08/30/2004 16:12:33 Inspection / Activity Plan Report 22 08/01/2004 - 03/31/2006 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type EB-21/02 - SSD&PCI AND 50.59 7 1 IP 7111102 Evaluation of Changes, Tests, or Experiments 08/30/2004 09/03/2004 Baseline Inspections 1 IP 7111121 Safety System Design and Performance Capability 08/30/2004 09/03/2004 Baseline Inspections 1 IP 7111121 Safety System Design and Performance Capability 09/13/2004 09/17/2004 Baseline Inspections ALARA1 - ALARA PLANNING AND CONTROLS 1 1 IP 7112102 ALARA Planning and Controls 10/04/2004 10/08/2004 Baseline Inspections SUP01 - 95001 SUPPLEMENTAL INSPECTION 1 1 IP 95001 Supplemental Inspection For One Or Two White Inputs In A Strategic Performance Area 10/25/2004 10/29/2004 Supplemental Progra PEB-07B - HX PERFORMANCE 1 1 IP 7111107B Heat Sink Performance 03/07/2005 03/11/2005 Baseline Inspections PEB-12B - MAINTENANCE EFFECTIVENESS REVIEW 1 1 IP 7111112B Maintenance Effectiveness 03/07/2005 03/11/2005 Baseline Inspections ALARA2 - ALARA PLANNING AND CONTROLS 1 1 IP 7112102 ALARA Planning and Controls 04/25/2005 04/29/2005 Baseline Inspections OB-EP EX - EMERGENCY PREPAREDNESS EXERCISE 3 1 IP 7111401 Exercise Evaluation 05/02/2005 05/06/2005 Baseline Inspections 1 IP 7111404 Emergency Action Level and Emergency Plan Changes 05/02/2005 05/06/2005 Baseline Inspections 1 IP 71151 Performance Indicator Verification 05/02/2005 05/06/2005 Baseline Inspections RP TEAM - RADIATION SAFETY TEAM INSPECTION 4 1 IP 7112103 Radiation Monitoring Instrumentation and Protective Equipment 05/16/2005 05/20/2005 Baseline Inspections 1 IP 7112201 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems 05/16/2005 05/20/2005 Baseline Inspections 1 IP 7112202 Radioactive Material Processing and Transportation 05/16/2005 05/20/2005 Baseline Inspections 1 IP 7112203 Radiological Environmental Monitoring Program 05/16/2005 05/20/2005 Baseline Inspections OB-INIT - INITIAL EXAM 4 1 X02286 CALLAWAY (05/05) - INITIAL EXAM 08/01/2005 08/05/2005 Not Applicable 1 X02286 CALLAWAY (05/05) - INITIAL EXAM 08/22/2005 08/26/2005 Not Applicable OB-RQ - REQUAL INSPECTION 2 1 IP 7111111B Licensed Operator Requalification Program 08/01/2005 08/05/2005 Baseline Inspections EB02/17B - 50.59 & PERM PLANT MODS 2 1 IP 7111102 Evaluation of Changes, Tests, or Experiments 08/22/2005 08/26/2005 Baseline Inspections 1 IP 7111117B Permanent Plant Modifications 08/22/2005 08/26/2005 Baseline Inspections EB08P - ISI - INCL VHP VOL (TI 150) AS REQ 1 1 IP 7111108P Inservice Inspection Activities - PWR 10/03/2005 10/07/2005 Baseline Inspections 1 IP 7111108P Inservice Inspection Activities - PWR 10/17/2005 10/21/2005 Baseline Inspections This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

Page 2 of 2 Callaway 08/30/2004 16:12:33 Inspection / Activity Plan Report 22 08/01/2004 - 03/31/2006 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type ACRSA - ACCESS CONTROL TO RAD SIGNIFICANT AREAS 1 1 IP 7112101 Access Control to Radiologically Significant Areas 10/17/2005 10/21/2005 Baseline Inspections ALARA3 - ALARA PLANNING AND CONTROLS 1 1 IP 7112102 ALARA Planning and Controls 12/05/2005 12/09/2005 Baseline Inspections This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.