ML090350417
| ML090350417 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 04/21/2008 |
| From: | Laura Smith NRC/RGN-IV/DRS/EB-2 |
| To: | Naslund C AmerenUE |
| References | |
| FOIA/PA-2009-0042, RIV-2007-A-0130 IR-08-006 | |
| Download: ML090350417 (38) | |
See also: IR 05000483/2008006
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
611 RYAN PLAZA DRIVE, SUITE 400
ARLINGTON, TEXAS 76011-4005
April 21, 2008
Charles D. Naslund, Senior Vice
President and Chief Nuclear Officer
AmerenUE
P.O. Box 620
Fulton, MO 65251
SUBJECT: CALLAWAY PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION
INSPECTION REPORT 05000483/2008006
Dear Mr. Naslund:
On March 14, 2008, the U. S. Nuclear Regulatory Commission completed a team inspection at
your Callaway Plant. The enclosed report documents the inspection findings, which the team
discussed on March 14, 2008, with Mr. A. Heflin, Vice President - Nuclear, and other members of
your staff during-the exit meeting.
The team examined activities conducted under your license as they relate to the identification and
resolution of problems, compliance with the Commission's rules and regulations, and the
conditions of your operating license. Within these areas, the inspection involved examination of
selected procedures and representative records, observations of activities, and interviews with
personnel. The team reviewed 246 Callaway Action Requests, associated root and apparent
cause evaluations, and other supporting documents. The team reviewed an additional
124 Callaway Action Requests related to specific areas - essential service water, component
cooling water, 480 Vac auxiliary contacts, and safety conscious work environment. The team
reviewed cross-cutting aspects of NRC findings and interviewed personnel regarding the condition
of your safety conscious work environment at.the Callaway Plant.
Based on the sample selected for review, the team concluded that your staff continued to have
challenges in the area of prioritization and evaluation, which need additional attention. The team
also noted that performance related to problem identification and resolution had improved. The
team determined that you're your staff had used the self-assessment process and quality
assurance organization to improve site performance. The team determined the improvement
resulted from corrective action process improvements implemented in January 2007, and
management oversight process changes implemented following receipt of substantive
cross-cutting issue'in problem identification and resolution.
Because of the increased number of allegations at your facility in Calendar Year 2007, especially _
the discrimination concerns, the team interviewed a large number of personnel related to the /
safety conscious work environment at the Callaway Plant. In addition, because of the nature of
the concerns expressed in the allegations, the team asked additional questions to gain insights
into the safety conscious work environment at your facility. The team documented the nature of
the concerns and the scope of the evaluations in Attachment 3. The team determined that not all
individuals were comfortable using all of the methods available to them for reporting concerns;
however, all personnel interviewed stated that they would have used at least one of the methods
AmerenUE -2-
available for reporting a safety concern. The team determined that our review results remained
consistent with other safety culture surveys that you had completed within the last year. The team
determined that some general culture and work environment issues continued to be present that
were outside NRC regulatory jurisdiction, which if not addressed could potentially affect the safety
conscious work environment at the Callaway Plant.
The team identified one finding for failure to determine whether you had a non-conservative
technical specification surveillance requirement. The team attributed this to improper processing
of operating experience. This finding violated NRC requirements. However, because of the
finding had very low safety significance and because the finding had been entered into your
corrective action program, the NRC is treating this findings as a noncited violation, in accordance
with Section VI.A.1 of the NRC's Enforcement Policy. In addition, one licensee-identified violation
of very low safety significance is listed in this report. If you contest the violations or the
significance of the violations, you should provide a response within 30 days of the date of this
inspection report. Include the basis for your denial, to the U. S. Nuclear Regulatory Commission,
ATTN: Document Control Desk, Washington, D.C. 20555-0001, with copies to the Regional
Administrator, U. S. Nuclear Regulatory Commission, Region IV,611 Ryan Plaza Drive, Suite 400,
Arlington, Texas, 76011; the Director, Office of Enforcement, U.S. Nuclear Regulatory
Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspector at the Callaway
Plant.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure will be 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.qov/readinq-rm/adams.html (the
Public Electronic Reading Room).
Sincerely,
IRA/
Linda J. Smith, Chief
Engineering Branch 2
Division of Reactor Safety
Docket: 50-483
License: NPF-30
Enclosure:
John O'Neill, Esq.
Pillsbury Winthrop Shaw Pittman LLP
2300 N. Street, N.W.
Washington, DC 20037
Scott A. Maglio, Assistant Manager
Regulatory Affairs
AmerenUE
P.O. Box 620
Fulton, MO 65251
AmerenUE -3-
Missouri Public Service Commission
Governor's Office Building
200 Madison Street
P.O. Box 360
Jefferson City, MO 65102-0360
H. Floyd Gilzow
Deputy Director for Policy
Missouri Department of Natural Resources
P. 0. Box 176
Jefferson City, MO 65102-0176
Rick A. Muench, President and
Chief Executive Officer
Wolf Creek Nuclear Operating Corporation
P.O. Box 411
Burlington, KS 66839
Kathleen Smith, Executive Director and
Kay Drey, Representative
Board of Directors Missouri Coalition
for the Environment
6267 Delmar Boulevard, Suite 2E
St. Louis City, MO 63130
Lee Fritz, Presiding Commissioner
Callaway County Courthouse
10 East Fifth Street
Fulton, MO 65251
.Les H, Kanuckel, Manager
Quality Assurance
AmerenUE
P.O. Box 620
Fulton, MO 65251
Director, Missouri State Emergency
Management Agency
P.O. Box 116
Jefferson City, MO 65102-0116
AmerenUE -4-
Scott Clardy, Director
Section for Environmental Public Health
Missouri Department of Health and
Senior Services
P.O. Box 570
Jefferson City, MO 65102-0570
Luke H. Graessle, Manager
Regulatory Affairs
AmerenUE
P.O. Box 620
Fulton, MO 65251
Thomas B. Elwood, Supervising Engineer
Regulatory Affairs and Licensing
AmerenUE
P.O. Box 620
Fulton, MO 65251
Certrec Corporation
4200 South Hulen, Suite 422
Fort Worth, TX 76109
Keith G. Henke, Planner III
Division of Community and Public Health
Office of Emergency Coordination
Missouri Department of Health and
Senior Services
930 Wildwood,
P.O. Box 570
Jefferson City, MO 65102
Technical Services Branch Chief
FEMA Region VII
2323 Grand Boulevard, Suite 900
Kansas City, MO 64108-2670
Ronald L. McCabe, Chief
Technological Hazards Branch
National Preparedness Division
DHS/FEMA
9221 Ward Parkway
Suite 300
Kansas City, MO 64114-3372
AmerenUE -5-
Electronic distribution by RIV:
Regional Administrator (EEC)
DRP Director (DDC)
DRS Director (RJC1)
DRS Deputy Director (TWP)
Senior Resident Inspector (DMD)
Branch Chief, DRP/B (VGG)
Senior Project Engineer, DRP/B (RWD)
Team Leader, DRP/TSS (CJP)
RITS Coordinator (MSH3)
JTAdams, OEDO RIV Coordinator (JTA)
ROPreports
CWY Site Secretary (DVY)
SUNSI Review Completed: GAP ADAMS: 4 Yes Initials: GAP
4 Publicly Available 4 Non-Sensitive
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OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
ENCLOSURE
U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket: 50-483
License: NPF-30
Report
Number:
Licensee: AmerenUE
Facility: Callaway Plant
Junction Highway CC and Highway 0
Location:
Fulton, Missouri
Dates: February 11 - 15, and March 10 - 14, 2008
Team Leader: G. Pick, Senior Reactor Inspector, Engineering Branch 2
Inspectors: R. Deese, Senior Project Engineer, Branch B, Division of Reactor Projects
J. Groom, Resident Inspector, Callaway Plant
S. Alferink, Reactor Inspector, Engineering Branch 2
P. Goldberg, Reactor Inspector, Engineering Branch 2
E. Uribe, Reactor Inspector, Engineering Branch 2
Approved By: Linda Smith, Chief
Engineering Branch 2
Division of Reactor Safety
- 1- Enclosure
SUMMARY OF ISSUES
IR 05000483/2008006; 2/11/2008 - 3/14/2008; Callaway Plant; Biennial inspection of the
identification and resolution of problems
One senior reactor inspector, one senior project engineer, three reactor inspectors, and a resident
inspector conducted the inspection. The team identified one noncited violation during this inspection.
The significance of most findings is indicated by their color (Green, White, Yellow, Red) using
Inspection Manual Chapter 0609, "Significance Determination Process." Findings for which the
Significance Determination Process does not apply may be Green or be assigned a severity level
after NRC management review. The NRC's program for overseeing the safe operation of
commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process,"
Revision 4, dated December 2006.
Identification and Resolution of Problems
The team reviewed 246 Callaway Action Requests, several job orders, engineering evaluations,
associated root and apparent cause evaluations, and other supporting documentation to assess
problem identification and resolution activities. The team reviewed an additional 124 Callaway Action
Requests related to specific areas - essential service water, component cooling water, 480 Vac
auxiliary contacts and safety conscious work environment. Based on the sample selected for review,
the team concluded the licensee continued to have challenges in the area of prioritization and
evaluation, which require additional effort. The team also noted that licensee performance related to
problem identification and resolution had improved. The team determined the licensee had used the
self-assessment process and quality assurance organization to improve site performance. The team
determined the improvement resulted from corrective action process improvements implemented in
January 2007, and management oversight changes implemented following receipt of substantive
cross-cutting issue in problem identification and resolution.
The team determined that the licensee had initiated actions that improved the quality of their
operability assessments, operational decision-making, and knowledge of the detailed design and
licensing basis since the last evaluation. The graduated approach to assigning cause evaluations for
conditions adverse to quality and the change that required the Callaway Action Request screening
committee to review-all Callaway Action Requests provided increased assurance in the ability of the
licensee to identify and effectively resolve conditions adverse to quality.
The team determined that the licensee properly evaluated industry operating experience when
performing root cause and higher tier cause evaluations; however, the licensee had continued
challenges effectively evaluating industry operating experience.
The team determined that licensee audits and assessments continued to be detailed, probing, and
self-critical. The licensee continued to use benchmarking of industry best practices and third party
evaluations that improved the corrective action program performance during this assessment period.
The licensee had effectively implemented performance improvements to address the substantive
cross-cutting issue (refer to March 2, 2007, End of Cycle letter) related to evaluating actions required
for conditions adverse to quality as demonstrated by the decreased number of findings in the latter
half of this assessment period and lower affect that poor evaluations had on the facility. However,
the licensee will need to apply additional effort to affect improvements. The improving performance
resulted from increased management involvement in the corrective action program and in daily
activities.
-2- Enclosure
Because of the increased number of allegations at the facility in Calendar Year 2007, including
several discrimination concerns, the team interviewed more personnel than normal to assess the
safety conscious work environment at the Callaway Plant. The team documented the nature of the
concerns and the increased scope of the evaluations in Attachment 3. The team determined that not
all individuals were comfortable using all of the methods available 'to them for reporting concerns;
however, all personnel would have used at least one of the methods available for reporting a safety
concern. In addition, the team determined that the employee concerns program requires more
visibility and that not all personnel had confidence in the employee concerns program. The team
determined that our review results remained consistent with other safety culture surveys that
Callaway Plant had completed within the last year. The team determined that some general culture
and work environment issues continued to be present from the last assessment that were outside
NRC regulatory jurisdiction, which if not addressed could potentially affect the safety conscious work
environment at the Callaway Plant.
A. Inspector-identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
Green. The team identified a Green noncited violation of 10 CER Part 50, Appendix B,
Criterion 1ll, "Design Control," because the licensee failed to ensure that Technical
Specification Surveillance Requirements for the NK1 1 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
NK1 1 and NK1 4 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 andiresolution associated with
operating experience because the licensee failed to evaluate in a timely manner relevant
internal and external operating experience P.2(a) (Section 40A2.e).
B. Licensee- Identified Violations
Violations of very low safety significance, which were identified by the licensee have been
reviewed by the inspectors. Corrective actions taken or planned by the licensee have been
entered into the licensee's corrective action program. These violations and corrective actions
are listed in Section 40A7 of this report.
-3- -3-
Enclosure
REPORT DETAILS
4 w-16i ACTViTnES (OA)
-..-4OA2 Identification and Resolution of Problems
The team based the following conclusions, in part, on all issues that the team reviewed
during the assessment period, which ranged from November 1, 2006, to March 14, 2008.
The team divided the issues into two groups. The first group (current issues) included
problems identified during the assessment period where at least one performance deficiency
occurred during the assessment period. The second group (historical issues) included issues
identified during the assessment period but had performance deficiencies that occurred
outside the assessment period.
a. Assessment of the Corrective Action Program Effectiveness
(1) Inspection Scope
The team reviewed items from across the seven cornerstones to verify that the licensee:
(1) identified problems at the proper threshold and entered them into the corrective action
system, (2) adequately prioritized and evaluated issues, and (3) established effective and
timely corrective actions to prevent recurrence. The team performed field walk downs of the
component cooling water system and the 480 Vac breakers to inspect for deficiencies that
personnel should have entered into the corrective action program. The team reviewed
operator logs and station job orders to ensure personnel entered conditions adverse to
quality into the corrective action program. Additionally, the team reviewed a sample of
self-assessments, trending reports, system health reports, and various other documents
related to the corrective action program.
The team interviewed station personnel, attended screening committee, leadership and
Corrective Action Review Board meetings, and evaluated corrective action documentation to
determine the threshold for entering problems into their corrective action program. The
meetings assisted the team with their assessment of the threshold of prioritization and
evaluation of identified issues. The team performed a historical review of Callaway Action
Requests written over the last 5 years that addressed the component cooling water system
and the 480 Vac breakers.
The team reviewed plant records, primarily Callaway Action Requests and job orders, to
verify that the licensee developed and implemented corrective actions for identified problems,
including corrective actions to address common cause or generic concerns. The team
sampled specific technical issues to evaluate the adequacy of operability determinations.
Additionally, the team reviewed Callaway Action Requests that addressed past
NRC-identified and self-identified violations to ensure that the corrective actions addressed
the issues as described in the inspection reports. The team reviewed a sample of corrective
actions closed to other Callaway Action Requests, job orders, or other processes
to ensure that the licensee had appropriately implemented the corrective actions in a timely
manner.
-4- Enclosure
(2) Assessments
(a) Assessment - Effectiveness of Problem Identification
The licensee identified deficiencies as conditions adverse to quality and entered them into tim
corrective action program. From the inspection sample, the team identified only one example
for failure to identify excessive nuisance alarms as a condition adverse to quality.
Consequently, the licensee did not resolve the nuisance alarms in a timely manner.
Otherwise, the team determined that the licensee had established an appropriate threshold,
for identifying adverse conditions. The team determined that the licensee had lowered their
identification threshold, which improved their ability to identify conditions adverse to quality
during this assessment period. In addition, the team verified that the screening committee
evaluated all Callaway Action Requests to ensure that they identified any related adverse
condition no matter the Callaway Action Request type (i.e., adverse condition, business
tracking, training request, or request for resolution).
In response to the previous inspection, the team verified that the licensee had eliminated
Action Notices, which had resulted in violations during the previous inspection for various
reasons. The team verified that the licensee had appropriately evaluated open Action Notice
Callaway Action Requests to verify whether any adverse conditions required a cause
evaluation and more timely corrective actions. The team evaluated and found no instances
of a Significance Level 6 Callaway Action Request tracking an adverse condition. The
licensee had replaced the Action Notices with the business tracking Significance Level 6
Callaway Action Requests.
The team determined that licensee quarterly trend reports appropriately discussed and
tracked resolution of identified trends. The licensee recently initiated actions to lower the
threshold for identifying adverse trends so they could better utilize this tool to improve their
performance. The team verified that the licensee identified and recognized their adverse
trends, which represented improved performance since the last corrective action program
inspection.
Current Issues
Example: From interviews with security officers, the team determined that audible alarms on
a security feature sounded too often and decreased the sensitivity of the officers to monitor
the alarms as expected. The team determined that, although the security personnel and the
system engineer knew about the issue, no one had initiated a Callaway Action Request
documenting the excessive number of nuisance alarms. Officers had verbally reported and
sent e-mails to the system engineer who had contacted the vendor and made adjustments,
which had reduced, the alarms; however, the alarms continued. The team determined that
this deficiency was minor since the security feature remained capable of performing its
intended function. The licensee documented this deficiency in Callaway Action
Request 200801877.
-5- -5-
Enclosure
Historical Issues
Example 1: Licensee personnel failed to initiate Callaway Action Requests for conditions
adverse to quality, as required by 10 CFR Part 50, Appendix B, Criterion XVI. Documenting
these degraded conditions may have prevented a main steam line water hammer event in
June 2006 and may have identified, in August 2005, an additional high point air trap in the
Train A safety injection discharge piping that could impact system operability (NRC Inspection
Report 05000483/2006012-01).
Example 2: The team considered two Action Notice Callaway Action Requests (200602989
and 200608806), identified during this inspection, as inappropriately classified conditions
adverse to quality contrary to 10 CFR Part 50, Appendix B, Criterion V, and their corrective
action program (NRC Inspection Report 05000483/2006012-02).
Example 3: The licensee failed to identify three Action Notice Callaway Action Requests as
conditions adverse to quality (200603636, 200604166 and 200605466); however, the team
determined these examples represented minor findings.
Example 4: During audits from January 2005 through October 9, 2006, the licensee identified
63 Callaway Action Requests that personnel had initiated as action notices rather than
conditions adverse to quality. Quality Assurance issued Callaway Action Request 200606131
to document that personnel incorrectly listed six deficiencies as Action Notice Callaway Action
Requests instead of conditions adverse to quality. During review of the third quarter audit
data, the team identified an additional eight Action Notice Callaway Action Requests that the
audit process should have identified. This represented a 33 percent increase. The team
confirmed that the licensee had appropriately determined that personnel had misclassified
0.5 percent of the Action Notice Callaway Action Requests; however, the team verified none
of the misclassified items documented significant deficiencies.
Example 5: Plant operations and security had several prior opportunities to identify a
degraded fire door indicating personnel did not have a low threshold for identifying issues
(Inspection Report 05000483/2006005-01).
(b) Assessment - Effectiveness of Prioritization and Evaluation of Issues
The licensee did not always appropriately prioritize and evaluate conditions adverse to
quality. The team identified a large number of examples of poor evaluation that indicated
additional effort is needed in this area. Specifically, the team determined the licensee had:
two examples related to poor prioritization (Examples 1 and 3), two examples resulting from
personnel not fully implementing plant processes (Examples 2 and 8), one example of failure
to evaluate longstanding design issues (Example 6); and six examples that resulted from
ineffective evaluations (Examples 4, 5, 7, 9, 10 and 11). The team verified that the Callaway
Action Request screening process resulted in appropriately reassigning the significance level
of Callaway Action Requests commensurate with their safety significance (Example 12).
Similar to the last assessment, outside organizations continued to identify that the licensee
did not always perform effective evaluations of conditions adverse to quality; consequently,
the licensee continued to emphasize and provide management oversight. The licensee had
implemented product quality evaluations in Engineering. and had developed tools to evaluate,
-6- Enclosure
grade, and provide feedback on the Significance Level 1, Level 2 and selected Level 3
adverse condition Callaway Action Requests.
The team specifically evaluated the corrective actions related to operability evaluations and
root cause evaluations, which the last biennial problem identification and resolution inspection
identified as deficient areas. The team concluded that the actions taken by the licensee (e.g.,
reinforced expectations, training of engineers and operators in design and license bases and
performance of operability evaluations, and improved tiered root cause evaluation guidance)
had improved the quality of operability evaluations. However, the team determined the large
number of current examples for failure to adequately evaluate issues indicates the licensee
will need to take additional action in this area.
In response to external organization evaluations and as corrective action to the substantive
cross-cutting issue related to problem identification and resolution for inadequate evaluations
(refer to March 2, 2007, End of Cycle letter), the licensee initiated numerous actions to
strengthen the screening committee and other aspects of the corrective action program. A
majority of the actions related to reinforcing expected behaviors through coaching.
Current Issues
Example 1: As of December 19, 2007, the licensee had not tested the essential service
water, component cooling water and containment spray pumps at 20 percent of full flow.
Subsequently, the licensee invoked Surveillance Requirement 3.10.2 and completed the
testing within the extended 25 percent surveillance interval. While no violation of
requirements resulted, the licensee had not implemented the requirements in a timely
manner. The licensee documented this deficiency in Callaway Action Request 200801400.
Example 2: The resident inspector s determined the licensee performed an inadequate
post-maintenance test after repairing a damaged trip breaker contact block. Specifically,
personnel failed to identify that the contacts affected the P-4 interlock; consequently, the
licensee restored the breaker to service without performing a post maintenance test of the
P-4 interlock. Although this test failed to meet the requirements of 10 CFR Part 50,
Appendix B, Criterion Xl, the inspectors determined the violation was minor because the
licensee adequately tested the breaker prior to exceeding the Technical Specifications
allowed outage time. The licensee documented this deficiency in Callaway Action
Request 200800811.
Example 3: Quality assurance auditors documented in Callaway Action Request 200711176
that personnel had not properly re-screened Significance Level 6 Callaway Action
Request 200700560 to an adverse condition Significance Level 4 nor was a new adverse
condition identified once personnel determined that external operating experience applied to
Callaway Plant. The team concluded the deficiency was minor since no identified deficiency
resulted from the, review.
Example 4: Engineering approved deviating from the established motor-driven auxiliary
feedwater pump coupling tolerances provided by the vendor without considering the impact
on the thrust bearing (Inspection Report 05000483/2007004-02).
-7- -7-
Enclosure
Example 5: The resident inspectors determined that the licensee failed to evaluate the extent
of condition for micro-biologically induced corrosion of essential service water piping.
Specifically, the licensee failed to perform ultrasonic testing under the American Society of
Mechanical Engineers Code identification bands (Inspection Report 05000483/2007003-03).
Example 6: The resident inspectors determined that the licensee failed to evaluate a
longstanding ultimate heat sink cooling tower design issue, which resulted in allowing water
to flow over the fill below freezing conditions contrary to vendor recommendations (inspection
Report 05000483/2007003-01).
Example 7: The resident inspectors determined that the licensee failed to evaluate
micro-biologically induced corrosion of essential service water large-bore piping to ensure
the resolutions addressed causes and extent of condition (Inspection Report
Example 8: After an operator could not locate a block switch during a surveillance test, the
control room supervisor revised *the procedure without verifying the correct block switch
identifier. Consequently, during the test when the operator defeated the identified (wrong)
train block feature, the opposite rain control room ventilation isolated (inspection
Report 05000483/2007002-01).
Example 9: Operations performed an inadequate review to establish compensatory actions of
an operator work around, which reflected a failure to thoroughly evaluate a problem to ensure
resolutions address causes and extent of condition (inspection Report 5000483/2006005-05).
Example 10: Engineering failed to thoroughly evaluate residual heat removal relief valve
problems to ensure resolutions addressed causes and extent of conditions (inspection
Report 05000483/2006009-06).
Example 11: Callaway Action Request 200801664 described that personnel failed to
document an adverse -condition that required evaluation. Specifically, after Quality Assurance
identified in Audit AP06-003 that the turbine-driven auxiliary feedwater pump exhaust line was
not adequately protected from missile hazards, Engineering initiated Request for
Resolution 2006006712; however, personnel failed to identify this as a potential
non-conforming condition in an adverse condition Callaway Action Request. Additionally, the
resident inspectors questioned if the current configuration was consistent with the licensing
basis.
Example 12: After reviewing significance level reassignments for Callaway Action Requests
that occurred during this assessment period, the team determined that the licensee had
appropriately classified the significance level for Callaway Action Requests and did not
identify a negative trend from this review. Specifically, for the population reviewed, the
licensee assigned a significance level to 65 items when no significance level had been
assigned, downgraded 25 items to a lower significance of which 15 received apparent cause
evaluations and 6 received a cause evaluation, and upgraded 53 items of which 34 received
cause evaluations.
-8- -8-
Enclosure
Historical Issues
Example 1: After questioning by the NRC, the licensee documented in Callaway Action
Requests 200609233 and 200500238 a less than adequate operability determination for a
degraded main steam isolation valve accumulator, which resulted in failure to implement the
required Technical Specification 3.7.2 actions (Inspection Report 05000483/2006012-03).
Example 2: The NRC determined that the licensee failed to properly evaluate and correct
inadequate emergency procedures for the design basis large break loss of coolant accident,
as documented in Callaway Action Requests 200602565 and 200608102. Specifically, the
licensee repeatedly missed opportunities that had presented themselves in Callaway Action
Requests, NRC findings, and vendor technical bulletins to uncover inadequate guidance in
Procedure E-1, "Loss of Reactor or Secondary Coolant" (Inspection
Report 05000483/2006011-01).
Example 3: The team determined that the licensee failed to evaluate all vulnerable
emergency core cooling system piping subject to voiding in response to a previous
NRC-identified violation for ineffective corrective actions. The team determined the licensee
failed to meet the requirements of 10 CFR Part 50, Appendix B, Criterion XVI. Specifically,
the licensee did not design and install vents for a significant length of horizontal piping
subject to the same deficiency and containing some high points, as documented in Callaway
Action Request 200608466 (Inspection Report 05000483/2006012-04)
Example 4: The Maintenance Rule Expert Panel failed to adequately review the failure of
safety-related motor-operated valves, which prevented thoroughly evaluating the problem to
ensure resolutions address causes and extent of conditions (Inspection
Report 05000483/2006005-02).
Example 5: Engineering performed an inadequate 10 CFR 50.59 safety evaluation, which
resulted in a less than thorough evaluation of the problem to ensure resolutions addressed
causes and extent of conditions (Inspection Report 05000483/2006005-04).
(c) Assessment - Effectiveness of Corrective Actions
The licensee implemented effective corrective actions to address conditions adverse to
quality because of process improvements. The team determined the improvements
addressed the weaknesses identified in the last biennial problem identification and resolution
inspection, as evidenced by only a single licensee-identified failure to implement effective
corrective actions. The team concluded that less than adequate past corrective action
program performance continued to result in the discovery of latent engineering issues; for
example, the ongoing challenges imposed by corrosion of the essential service water piping.
The team evaluated the planned actions for these corrosion deficiencies and concluded that
the licensee made appropriate operational decisions and took interim measures to ensure
that the system remained operable until the next refueling outage when they plan to
implement the permanent corrective actions.
The licensee had implemented a number of improvements in January 2007 that increased
the effectiveness of the corrective action program. The changes included, in part:
(1) improved definition of a condition adverse to quality in order to lower the threshold,
(2) more categories for adverse conditions to allow for broke-fix and relieve the burden of
-9- Enclosure
performing apparent causes for low significance conditions adverse to quality, (3) improved
guidance for performing cause evaluations, including a quality checklist, and (4)improved
guidance for performing immediate operability determinations. The team found that this
approach ensured the licensee applied the appropriate level of resources to identified issues
commensurate with their safety significance or impact on the facility. The team found the
procedure guidance clear, concise, and useful to personnel implementing the corrective.
action program. The team determined that many of these changes should address some of
the concerns identified during this inspection.
Current Issues
Example: The licensee determined that they had implemented ineffective corrective actions
for Callaway Action Request 200609621, which documented that personnel had failed to
secure Fire Door DSK1 5031. The corrective action involved communicating the importance
of reading and abiding to posted signs related to closing fire doors. Subsequently, additional
instances of the improperly secured fire door occurred (i.e., Callaway Action
Requests 200702037, 200702596, 200706810, and 200707100). After the license initiated
corrective actions for Callaway Action Request 200702596, which involved locking the door
pin to prevent unauthorized unlatching of the Fire Door DSK1 5031 stationary door, the
licensee had discovered two additional instances prior to implementing the modification., This
licensee-identified performance deficiency is documented in Section 40A7.
Historic Issues
Example 1: In Callaway Action Request 200609075, the licensee identified the failure to take
effective corrective actions in response to Callaway Action Request 200205928, which
documented missing sacrificial anodes in the emergency diesel generator heat exchangers.
The team determined the licensee had missed an opportunity to correct this deficiency in
October 2004. The failure to have all required sacrificial anodes installed was of minor safety
significance-since the heat exchanger remained operable.
Example 2: Callaway Action Request 200602995 described that personnel implemented
inappropriate corrective actions for Callaway Action Request 200602565. Specifically, the
NRC determined that the licensee made an ineffective procedure change related to
establishing component cooling water flow to the residual heat removal heat exchangers prior
to swap over to the containment recirculation sumps. The procedure change failed to prevent
a potential runout condition for the component cooling water pumps (inspection,
Report 05000483/2006011-02).
b. Assessment of the Use of Operating Experience
(1) Inspection Scope
The team examined licensee programs. for reviewing industry operating experience. The
team selected a number of operating experience notification documents (NRC bulletins,
information notices, generic letters, 10 CER Part 21 reports, licensee event reports, vendor
notifications, et cetera), which had been issued during the assessment period, to verify
whether the licensee had appropriately evaluated each notification for relevance to the
facility. The team then examined whether the licensee had entered those items, which had
been deemed relevant, into their corrective action program. Finally, the team reviewed a
_10- - 10 -Enclosure
number of significant conditions adverse to quality and conditions adverse to quality to verify
if the licensee had appropriately evaluated them for industry operating experience.
(2) Assessment
The team identified some weakness in licensee evaluation and processing of operating
experience. Specifically, failure to appropriately evaluate industry operating experience
contributed to two findings in this area. The team documented Example 1, which related to
untimely evaluation of applicable operating experience, in this inspection report. The team
determined that Example 2 documents failure to effectively evaluate operating experience
because the licensee did not consider all areas subject to flooding. Any finding that results
from the failure to perform an appropriate flood analysis will be documented in the resident
inspector integrated report. The team determined that the licensee continued to effectively
assess industry operating experience during root cause and apparent cause evaluations of
significant conditions adverse to quality and conditions adverse to quality, respectively.
Current Issues
Example 1: The team determined that the licensee failed to determine in a timely manner
whether the acceptance criteria for Technical Specification Surveillance Requirement 3.8.4.5
demonstrated that the NK1 1 and NK14 safety-related batteries could meet the design
requirements. The licensee initiated Callaway Action Request 200706268 in response to
operating experience on July 10, 2007. The licensee inappropriately requested extension
requests to complete their evaluation such that they had operated with this non-conservative
Technical Specification until challenged by the team -(refer to Section 40A2.e).
Example 2: In Callaway Action Requests 200502989 and 200607843, the licensee
concluded that the flooding analysis summary took no credit for flooding in areas above the
lower levels in each building. The team considered the evaluation inadequate because
several flooding analyses credit floor drains at elevations other than the-*basement. For
example, Calculation. M-FL-07, "Flooding of the Aux Bldg Rms EL. 2047'6",' evaluated the
impact of flooding in the Control Room heating, ventilation and air conditioning room.
Historical Issues
Example: The licensee's corrective measures inappropriately used instrument uncertainty to
increase design margin (inspection Report 05000483/2006009-05).
C. Assessment of Self-Assessments and Audits
(1) Inspection Scope
The team reviewed numerous audits, self-assessments, quality surveillances, and site
performance indicators. The team reviewed program procedures and interviewed process
managers related to the performance improvement group, the corrective action program, and
the Quality Assurance department. The team evaluated the use of self- and third party
assessments, the role of Quality Assurance, and the role of the performance improvement
group related to licensee performance.
- 11 - -11-
Enclosure
(2) Assessment
The licensee continued to perform self-critical assessments, audits and evaluations. The
team noted that the factors that influenced the improvement identified during the last
corrective action program evaluation continued during this assessment period. Specifically,
the licensee used directed assessments to evaluate suspect or known areas of weakness.
The licensee implemented the recommendations and findings of external self-assessments
that they requested. The licensee established processes to ensure increased management
oversight at all levels in the organization related to improved worker performance, adherence
to procedures, and conduct of root cause analyses.
Quality Assurance performed critical, detailed audits and surveillances of line
organizations (Example 2). The audit performance criteria had goals of excellence (e.g., third
party expectations and NRC inspection guidance) rather than compliance. The team
determined that the line organizations continued to use audits and surveillances as a tool to
improve their performance. For example, Quality Assurance performed three surveillances of
critical activities related to the corrective actions planned for the essential service water
system corrosion issues (Example 1).
The team verified that the licensee implemented performance indicators and trended data
that should allow the managers to evaluate the progress of their actions to improve
performance related to human performance and corrective action program deficiencies.
The licensee performed several self-assessments related to safety culture during this
assessment period. The team evaluated the self-assessments and concluded that the
licensee conducted critical evaluations of their safety culture and the safety conscious work
environment (Examples 3 and 4). The licensee initiated Callaway Action Request 200800944
to perform a higher tier apparent cause evaluation and to ensure that they addressed the
assessment recommendations. Recommendations included developing a differing
professional opinion process, developing a process to review proposed disciplinary actions
and performing benchmarking of other programs.
Current Issues
Example 1: Quality Assurance performed several critical surveillances related to corrosion in
the essential service water system, which related to the examination scope of the piping, the
repairs of the affected piping, and the suitability to operate during Cycle 16.
Example 2: Audit AP07-013, "Corrective Action Program," provided critical evaluations of the
corrective action program areas that previously had problems, which included operability
evaluations, prioritization, and management oversight. The team verified that the line
organization had implemented appropriate corrective actions to address the numerous
adverse conditions identified in the audit.
Example 3: The licensee performed a Synergy Safety Culture Assessment in February 2007.
The Safety Culture Survey included an assessment of the general culture and work
environment and the safety conscious work environment. The safety culture survey identified
that the licensee had significant challenges related to resources/work load and change
management that affected the trust of the workers in management. The survey identified that
no chilling effect or safety conscious work environment concerns existed. However, the
-12- Enclosure
results indicated, the general culture and work environment concerns could affect the nuclear
safety culture and the safety conscious work environment, if not addressed by management.
Example 4: Because of the large number of allegations at the facility in Calendar Year 2007,
the licensee requested an independent assessment to evaluate their safety conscious work
environment in February 2008. The assessment determined that the licensee had
maintained a safety conscious work environment and that no chilled work environment
existed. The assessment team concluded work environment and corrective action program
issues had the potential, if not addressed, to erode the willingness of individuals to bring
issues forward using the corrective action program.
d. Assessment of Safety Co nscious Work Environment
(1) Inspection Scove
The team evaluated this area by reviewing self-assessments and audits, interviewing
personnel regarding the safety conscious work environment at Callaway Plant using the
questions provided in Inspection Procedure 71 152B, and interviewing the Employee
Concerns Coordinator. Specifically, the-team reviewed the Independent Assessment of the
Callaway Plant Safety Conscious Work Enviro~nment performed in February 2008, the 2007
Safety Culture Assessment, and three department specific safety culture assessments.
The team conducted formal interviews with 93 personnel in response to the large number of
allegations received at Callaway Plant, which had identified concerns with the safety
conscious work environment. Normally, the inspection interviews 15 -25 personnel. The
team conducted the interviews with plant personnel to assess their willingness to raise safety
issues and use the corrective action program. Further, the team assessed whether
conditions existed that would challenge the establishment of a safety-conscience Work
environment. The team documented the details of the review in Attachment 3, "Concerns
Evaluated." Note: Examples 1 - 5 below have corresponding numbers in Attachment 3.
() Assessment
From interviews and review of safety conscious work environment assessments, the team
determined that the licensee maintained a safety conscious work environment. However,
there were some issues identified that were outside NRC regulatory jurisdiction that, if not
addressed by the licensee, could potentially affect the safety conscious work environment at
the Callaway Plant. Overall, interviewed employees felt free to enter issues into the
corrective action program as well as, raise nuclear safety concerns to their supervision, the
employee concerns program, and the NRC. During interviews, personnel generally
expressed confidence that the licensee had established an appropriate threshold for
documenting nuclear safety issues and that issues entered into the corrective action program
would be appropriately addressed.
The 2007 Safety Culture Assessment concluded that the licensee,, generally, has a solid
safety culture and that site personnel have nuclear safety as a core value. However, the
safety culture assessment identified several groups that required additional attention. The
assessment also identified areas that management needed to address related to the general
culture and work environment that included implementing appropriate change management,
better management of resources, workload, staffing and priorities. The team verified that the
-13- - 13-Enclosure
licensee had initiated Callaway Action Requests and had implemented appropriate corrective
actions for the identified deficiencies.
Consistent with the 2005 Safety Culture Assessment, the 2007 Safety Culture Assessment,
and the February 2008 Safety Conscious Work Environment self-assessment, the team
determined that, generally, employees expressed willingness to use the corrective action
program and raise nuclear safety concerns. The team determined that not all individuals
were comfortable using all of the methods available to them for reporting concerns; however,
all personnel would have used at least one of the methods available for reporting a safety
concern. Also, the licensee continues to have challenges related to visibility of the Employee
Concerns Program and the willingness of some people to use the Employee Concerns
Program (Examples 2 and 3).
In response to numerous concerns (Examples 1 - 3) the team evaluated whether the
licensee encourages personnel to identify problems. The team determined that management
encourages personnel to identify problems and raise concerns using the corrective action
program or through discussions with their supervisor. The team determined from this sample
that no chilled work environment existed at Callaway Plant. However, within the security
department, some individuals would not raise personal concerns. From review of two
technical concerns (Examples 4 and 5), the team determined that the licensee had resolved
the issues commensurate with their safety significance and regulatory requirements.
Current Issues
Example 1: The team evaluated whether the licensee had established a culture where
personnel did not feel comfortable raising concerns and where management did not want to
hear about problems. The team determined that management encouraged personnel to
raise concerns. During interviews, all personnel indicated that they would raise nuclear
safety concerns; however, some personnel indicated that they would not raise personal
issues unrelated to nuclear safety because they believed that management would take no
actions.
Example 2: The team evaluated how employees used the employee concerns program. The
team determined that most, but not all, employees would use the employee concerns
program if they did not get satisfaction from use of the corrective action program or from their
supervisor. However, two individuals did not trust the employee concerns program and would
rather talk to the NRC. The team determined that 30 percent of the personnel interviewed
had a misconception of the employee concerns program (e.g., did not know the program
coordinator had changed, did not know the purpose of the employee concerns program, did
not know the location of the coordinator's office, et cetera).
Example 3: The team evaluated whether a chilled work environment existed in any
department but focused particularly in the training, radiation protection, operations and
security organizations. From the interviews, the team determined that all individuals would
raise concerns by using one of the four methods - corrective action program, supervisor,
employee concerns program, or NRC. However, the team determined that not all individuals
would use all of the methods. Specifically, one individual would only talk with their supervisor.
Example 4: The team reviewed whether the licensee timely resolved the condition that
damaged to the residual heat removal pump suction relief valves. The licensee missed an
-14- Enclosure
opportunity to correct the error in March 2007 when a design error identified by a vendor
prevented issuing the modification in time for implementation. The team verified that the
licensee scheduled the modification for Refueling Outage 16 in October 2008. No violation
resulted since the licensee will implement the modification commensurate with its safety
significance.
Example 5: The team reviewed whether the licensee took the appropriate actions to not
pursue a license amendment specifically prohibiting plant operation with both cold
overpressure mitigation systems out of service with the reactor coolant system solid. Since
the licensee had no shutdown probabilistic safety \analysis, the team could not quantitatively
determine whether it was safer to operate without cold overpressure mitigation system valves
under solid plant conditions or saturated plant conditions. Further, the team determined that
the licensee took appropriate actions to request an extension of the period allowed for
establishing a reactor coolant system vent path from 8 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Example 6: As discussed. in the example in Section 40A2.a(2)(a), security officers had
identified that a specific security feature generated excessive nuisance alarms. The team
determined that the licensee had initiated Callaway Action Requests related to other security
organization issues that included a safety hazard while performing patrols and a health
hazard. The team determined during interviews that these deficiencies did not aff ect the
willingness of security officers to report deficiencies to their supervisor or to use the corrective
action program.
e. Specific Issues Identifiled During This Inspection
Introduction. The team identified a Green noncited violation of 10 CFR Part 50, Appendix B,
Criterion Ill, "Design Control," because the licensee failed to ensure that Technical
Specification Surveillance Requirements for the NK1 1 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. 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.
Description. The team reviewed Callaway Action Request 200706561 that the licensee
initiated July 10, 2007, to evaluate the adequacy of Technical Specifications 3.8.4 and 3.8.5
for the NK1 1 and NK1I 4 safety-related batteries. The licensee initiated Callaway Action
Request 200706561 because external industry operating experience had identified that some
licensees had not documented the basis for the 150 micro-ohm limit specified in Technical
Specification Surveillance Requirements 3.8.4.2 and 3.8.4.5 and, in some cases, challenged
the operability of the safety-related batteries when the limit was applied to each inter-cell
connection. Callaway Action Request 200706561, Action 4 requested an evaluation to
determine the appropriate maximum inter-cell resistance value for station batteries. The
team determined that the licensee had not completed their evaluation of Surveillance
Requirements 3.8.4.2 and 3.8.4.5 at the time of the inspection.
The team determined that Procedure APA-ZZ-01400, Attachment 4, "Industry Operating
Experience Screening Committee Guidelines," Section 4.b, states that Operating Experience
.Callaway Action Requests should be assigned due dates not to exceed 60 days to ensure a
timely determination of plant impact. The team determined that, while the licensee had
_15- - 15-Enclosure
assigned a completion date within 60 days, personnel had obtained several extensions that
prevented assessing the significance or facility impact within the initial 60 days specified in
Procedure APA-ZZ-01400. Consequently, these extensions delayed evaluating Surveillance
Requirements 3.8.4.2 and 3.8.4.5. Following discussion with the team, the licensee
evaluated the current design assumptions in Calculation NK-05, "Class 1E Battery Capacity;"
Revision 6, which the licensee had used to size the NK1 1 and NK14 safety-related batteries.
The licensee's evaluation found that the licensee based the battery sizing on an end
discharge voltage of 108.6 volts correlating to a maximum inter-cell resistance of 86.1
micro-ohms. Since the 86.1 micro-ohms limit was less than that allowed by Surveillance
Requirements 3.8.4.2 and 3.8.4.5 (indicating a nonconservative Technical Specification), the
licensee performed an additional calculation to determine an appropriate inter-cell resistance
to support battery operations. Upon completing Calculation NK-10, "NK1 1 Accident Case,"
Revision 1, the licensee would need to limit the maximum inter-cell resistance to
69 micro-ohms to assure battery operability.
Following discovery of the non-conservative inter-cell resistance, the licensee performed a
prompt operability determination and concluded the NK1 1 and NK1,4 safety-related batteries
remained operable since past surveillances had measured inter-cell resistances well below
69 micro-ohms. The licensee implemented compensatory measures as described in NRC
Administrative Letter 1998-10, "Dispositioning of Technical Specifications That Are
Insufficient to Assure Plant Safety," to assure the new inter-cell resistance limit of
69 micro-ohms would not be exceeded. The licensee intended to continue the interim
compensatory measures until they revised their Technical Specifications.
Analysis. The performance deficiency associated with this finding involved the failure to
ensure that the NK1 1 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 crosscutting 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).
Enforcement. Title Ten Code of Federal Regulations Part 50, Appendix B, Criterion Ill,
"Design Control," requires, in part, that the licensee establish measures to assure that
applicable regulatory requirements and the design basis for structures, systems and
components are correctly translated into specifications, drawings, procedures, and
instructions. Additionally, design control measures shall provide for verifying or checking the
adequacy of design, such as by the performance of design reviews, by the use of alternate or
simplified calculation methods, or by the performance of a suitable testing program. Contrary
to the above, prior to March 13, 2008, the licensee failed to verify that the 150 micro-ohm
criterion specified in Surveillance Requirement 3.8.4.2 and 3.8.4.5 would be sufficient to
ensure safety-related battery operability in accordance with the design basis. Once
challenged, the licensee determined that a maximum inter-cell resistance of 69 micro-ohm
could not be exceeded to ensure the battery remained operable. This finding is of very low.
-16- Enclosure
safety significance and has been entered into the corrective action program as Callaway
Action Request 200802195, this violation is being treated as a noncited violation consistent
with Section VI.A of the NRC Enforcement Policy: NCV 05000483/2008006-01,
"Nonconservative Technical Specification for battery inter-cell connection resistances."
40A6 Exit Meeting
On March 14, 2008, the team presented their inspection results to Mr. A.C. Heflin, Vice
President, and other members of his staff who acknowledged the findings. The inspectors
returned all proprietary and confidential information p~rovided during the inspection.
40A7 Licensee Identified Violations
The following violation of very low safety significance (Green) was identified by the licensee
and is a violation of NRC requirements that meets the criteria of Section VI of the NRC
Enforcement Policy, NUREG-1600, for being dispositioned as a noncited violation.
Technical Specification 5.4.1 .d requires that AmerenUE maintain a fire protection program.
Procedure APA-ZZ-0071, "Control of Impairments of Fire Protection Systems and
Components," requires personnel to maintain the integrity of plant fire doors. Contrary to
this, security officers identified during routine tours on March 6, March 20, July 18, and
July 31, 2007, which personnel failed to maintain the integrity of Fire Door 15031. This
licensee documented these deficiencies in Callaway Action Requests 200702037,
200702596, 200706810, and 200707100, respectively. This finding is of very low safety
significance because the exposed fire area contained no potential damage targets that are
unique from those in the exposing fire area.
Attachment: Supplemental Information
-17- Enclosure
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
B. Barton, Manager, Training
G. Belchik, Supervisor, Operations
M. Daly, Supervising Engineer, Corrective Action Program
F. Diya, Plant Director
M. Dunbar, Protective Services Supervisor
R. Farnam, Manager, Radiation Protection
L. Graessle, Manager, Regulatory Affairs
A. Heflin, Vice President - Nuclear
T. Herrmann, Vice President Engineering
T. Hermann, Manager, Maintenance
D. Hollabaugh, Superintendent Protective Services
L. Kanuckel, Manager, Quality Assurance
G. Kremer, Supervising Engineer
P. McKenna, Manager, Outage Planning and Scheduling
M. McLachlan, Manager, Engineering Services
S. Maglio, Assistant Manager, Regulatory Services
B. Miller, Supervisor, Performance Improvement
E. Olsen, Superintendent, Performance Improvement
S. Petzel, Engineer, Regulatory Affairs
J. Small, Superintendent, Chemistry and Radioactive Waste
T. Steele, Employee Concerns Program Coordinator
NRC
R. Caniano, Director, Division of Reactor Safety (telephonically)
J. Groom, Resident Inspector, Callaway Plant
L. Smith, Chief, Engineering Branch 2, Division of Reactor Safety
V. Watkins, Deputy Director, Division of Reactor Safety
LIST OF ITEMS OPENED AND CLOSED
Opened and Closed
05000483/2008006-01 NCV Nonconservative Technical Specification for Battery
Inter-cell Connection Resistances (Section 40A2.e)
A1-1 Attachment 1
LIST OF DOCUMENTS REVIEWED
Audits, Self-Assessments and Surveillances
AP07-013, "Quality Assurance Audit of Corrective Action," dated December 13, 2007
SA07-Pl-C02, "Closing Condition Reports (CARS) to a Procedure Change Process,"
dated August 28, 2007
SA07-PI-C06, "Trending Program Gap Analysis," dated August 2007
SA07-PI-F01, "Mid-Cycle Self-Assessment," dated September 10-21, 2007
SA07-PI-S01, "Gap Analysis between APA-ZZ-01 400 and INPO 05-005," dated June 6, 2007
SA07-PI-S02, "Prompt Human Performance Evaluation," dated May 23, 2007
SA07-PI-S05, "Assessment of the Self-Assessment Program during the Mid-Cycle
Self-Assessment," dated October 25, 2007
SP07-001, "Assess Engineering Dispositions of Significance Level 3 CARs,"
dated February 15, 2007
SP07-013, "Assure ESW Piping Has Been Determined Suitable for Continued Operations,"
dated April 3, 2007
SP07-015, "Assessment of Corrective Actions for ESW Pipe Support Removal,"
dated April 11, 2007
SP07-020, "Assess ESW Examination Plans and Methods during RF15 to Address Large Bore
Pipe Pitting and Ensure Reliability during Cycle 16," dated April 13, 2007
SP07-021, "Overview of the Refuel 15 Human Performance Area," dated June 6, 2007
SP07-025, "Evaluate Refuel 15 ESW Repair/Replacement Activities," dated May 21, 2007
SP07-035, "Evaluate Adequacy of Responses to Audit AP06-006, 'Design Control,"'
dated September 25, 2007
Calculations
EB-10, "Allowable MCC circuit lengths for circuits with auxiliary relay coils in parallel with the
starter coil," Addendum 1, Revision 0
EJ-039, "Maximum Vent Times for Points Vented in Procedure OSP-SA-00003," Revision 0
KJ-10, "Determine Tube Plugging Limits for DG Intercooler Heat Exchangers, DG Jacket Water
Heat Exchangers and the Lube Oil Coolers," Revision 0
All-2 Attachment 1
R-41 52-00-1, "Revised Maximum Vent Volumes for EMV0250, EMVO251, and EMV0252 vent
points," Revision 0
ZZ-1 79, "Plant AC Load List," Revision 7
Callaway Action Requests
200203882 200608956 200700284 200702529 200705936 200709330
200306252 200608979 200700286 200702568 200705968 200709522
200 502093 200609233 200700392 200702596 200706133 200709523
200505716 200609441 200700560 200702685 200706143 200709540
200509540 200609580 200700893 200702864 200706268 200709652
200600012 200609603 200700956 200702956 200706453 200709812
200602144 200609621 200701164 200703065 200706476 200709813
200602645 200609628 200701177 200703069 200706561 200709819
200603734 200609710 200701261 200703177 200706810 200709852
200603736 200609726 200701336 200703189 200706933 200710351
200604147 200609805 200701362 200703244 200707100 200710418
200604872 200609809 200701369 200703260 200707368 200710764
200604878 .200609809 200701371 200703317 200707375 200711084
200604991 200609812 200701372 200703901 200707468 200711176
200605025 200609813 200701406 200704101 200707485 200711177
200605046 200610010 200701407 200704113 200707490 200711227
200605143 200610048 200701559 200704169 200707508 200711235
200605179 200610063 200701573 200704176 200707518 200711236
200605252 200610112 200701591 200704226, 200707572 200711254
200605751 200610359, 200701654 200704366 200707628 200711257
200605879 200610423 200701660 200704472 .200707788 200711314
200606432 200610426 200701930 200704598 2007081 22 200711496
200606707 200700023 200701944 200704742 200708186 200711541
200607188 200700063 200702003 200704911 200708219 200711883
200607327 200700096 200702037 200704913 200708233 200711916
200607496 200700100 200702057 200705117 200708241 200800085
200607835 200700115 200702144 200705142 200708270 200800248
200607843 200700218 200702202 200705149 200708671 200800585
200607911 200700224 200702276 200705263 200708941 200800878
200607985 200700260 200702339 200705349 200709002 200801268
200608466 200700262 200702371 200705484 200709165 200801664
200608902 200700265 200702373 200705489 200709171 200801877
Jobs
05104004 05506731 06129999 07007930 07008908
Al -3 A1-3
Attachment 1
Requests for Resolution
200706500 200701932
Callawav Action Reauests Sionificance Level 4 Reviews
Ac
........... in ea t . e Leve
. .. 4.... . ..
Reviews.. .
.........
200700815 200706812 200708769 200709845 200711009 200711696
200700839 200707147 200708778 200709868 200711028 200711741
200702456 200707184 200708873 200709894 200711036 200711831
200703494 200707250 200708942 200709959 200711067 200711955
200705711 200707294 200709232 200710139 200711378 200712005
200706212 200708020 200709657 200710446 200711481 200800007
200706427 200708062 200709660 200710537 200711543 200800152
200706571 200708068 200709698 200710915 200711647 200800205
200706688 200708435 200709740 200710923 200711662 200800226
Callawav Action Reoue~t~ reviewed for comnonent . ..
coolina
.
water 55-year
... in i w ater. ...........
review
C allaw ay .......... o
Aci en ... t ... .. ... for .. . .. r-..
200300081 200302684 200402981 200500662 200509277 200800740
200300176 200306225 200407285 200502438 200510023
200300762 200306229 200408368 200504816 200601037
200300767 200306380 200408434 200507430 200602580
200300837 200307361 200408696 200507574 200604400
200301779 200401270 200500143 200507684 200710764
Callaway Action Requests related to essential service water
200600553 200702464 200703247 200703899 200704785 200707154
200608086 200702496 200703279 200704226 200705002 200710009
200701786 200702724 200703313 200704366 200705126 200710571
200702151 200702733 200703514 200704421 200705489
200702384 200703028 200703584 200704465 200705535
200702434 200703222 200703776 200704598 200706190
Information used to evaluate 480 Vac auxiliary contacts
200400789 200509628 200404059 200604013 200404301
200404392 200607324 200404486 200609726
200405034 200704719 200507793 200709688
Auxiliary Contacts Failure Trending
Replacement Timeline for NG 480 Vac Buckets
Project Plan MP01-1003/21130, "Replace Obsolete MCC Buckets (starters and aux contacts),"
dated February 5, 2008
Al1-4 Attachment 1
Procedure CC-74-14, "IEEE 323-1974, "Qualification and Test Summary Report for Class IE Motor
Control Centers," Revision 6
Procedures
APA-ZZ-00107, "Review of Current Industry Operating Experience," Revision 10
APA-ZZ-00304, "Control of Callaway Equipment List," Revision 23
APA-ZZ-00322, "Integrated Work Management Process Description," Revision 3
APA-ZZ-00500, "Corrective Action Program," Revisions 44 and 45
APA-ZZ-00500, Appendix 1, "Operability and Functionality Determinations," Revision 4
APA-ZZ-00500, Appendix 5, "Maintenance Rule (MR)," Revision 2
APA-ZZ-00500, Appendix 7, "Effectiveness Reviews," Revision 2
APA-ZZ-00500, Appendix 12, "Significant Adverse Condition - Significance Level 1," Revision 1
APA-ZZ-00500, Appendix 13, "Adverse Condition - Significance Level 2," Revision 1
APA-ZZ-00500, Appendix 14, "Adverse Condition - Significance Level 3," Revision 2
APA-ZZ-00500, Appendix 15, "Adverse Condition - Significance Level 4," Revision 3
APA-ZZ-00500, Appendix 16, "Adverse Condition - Significance Level 5," Revision 2
APA-ZZ-00500, Appendix 17, "Screening Process Guidelines," Revision 4
APA-Z7Z-00500, Appendix 21, "Other Issues - Significance Level 6," Revision 2
APA-ZZ-0500A, "Business Tracking Process," Revision 5
APA-ZZ-00604, "Requests for Resolution," Revision 20
APA-ZZ-00930, "Employee Concerns Program," Revision 10
APA-ZZ-01250, "Operational Decision Making," Revision 1
APA-ZZ-01400, "Performance Improvement Program," Revision 6
APA-ZZ-01400, Appendix E, "Operating Experience," Revision 3
APA-ZZ-01400, Appendix F, "Performance Indicators," Revision 2
APA-ZZ-01400, Appendix J, "Change Management," Revision 5
EDP-ZZ-01 112, "Heat Exchanger Predictive Performance Manual," Revision 13
EDP-ZZ-0 1128,. "Maintenance Rule Program," Revision 8
EDP-ZZ-01 131, "Callaway Plant Health Program," Revision 9
EDP-ZZ-05000, "Engineering Product Quality," Revision 3
LDP-ZZ-00500, "Corrective Action Review Board," Revision 10
ODP-ZZ-00001, Addendum 12, "Operator Burdens and Workarounds," Revision 0
TDP-ZZ-00076, "Training Department Self-Assessment Process," Revision 4
TDP-ZZ-00075, "Training Department CARB," Revision 5
Miscellaneous
Change Package MP 07-0066, "Replace Buried ESW Piping with HDPE Material," Revision 0
Callaway Plant 3d Quarter and 4 th Quarter Trend Reports
Health Risk EF-03-07, "Corrosion of Large Bore ESW Piping - ESW Flow Only (Includes
Underground)"
Letter ULNRC-05434, "10 CFR 50.55a Request: Proposed Alternative to ASME Section Xl
Requirements for Replacement of Class 3 Buried Piping," dated August 30, 2007
A1-5 Attachment 1
Letter ULNRC-05445, "Application for Amendment to Facility Operating License NPF-30,
One-Time Completion Extension for Essential Service Water (ESW) System,"
dated October 31, 2007
Proto-Power Corporation Letter to Alex Smith, "Callaway Plant Heat Exchange Engineer, RE:
Summary of GL 89-13 Program Review," dated December 21, 2006
Training Excellence Plan 2008- 2012, dated February 7, 2008
Safety Conscious Work Environment
Callaway Plant Business Plan 2008 -2012
Employee Concerns Program Pamphlet
NEI 97-05, "Nuclear Power Plant Personnel-Employee Concerns Program-Process Tools in a
Safety Conscious Work Environment," Revision 2
Nuclear Division Policy POLOO17, "Safety Conscious Work Environment Policy," Revision 2
Procedure SDP-PI-DEFNS, "Static Defensive Position," Revision 1
Procedure APA-ZZ-00930, "Resolving Quality Concerns," Revision 4 (10/30/2004)
Regulatory Issue Summary 2005-18, "Guidance for Establishing and Maintaining a Safety
Conscious Work Environment," dated August 25, 2005
Regulatory Issue Summary 2006-13, "Information on the Changes Made to the Reactor Oversight
Process to More Fully Address Safety Culture," dated July 31, 2006
SEGR 07-34, "QA Department Detailed Evaluation of SynergyNPO Results,"
dated November 2, 2007
SEGR 07-35, "INPO SOER 02-04 Davis Besse CBT," dated November 16, 2007
Understanding SCWE - A Handbook on Safety Conscious Work Environment
As the Turbine Turns Articles on Principles for a Strong Nuclear Safety Culture (dated November
and December 2006)
"An Independent Assessment of the Safety Conscious Work Environment at the Callaway Nuclear
Plant," dated February 1, 2008
2005 and 2006 Allegation Trends Report evaluations related to the Callaway Plant
2006 Operations, Engineering and Training department NEI/USA safety conscious work
environment questionnaires
A1-6 Attachment 1
2007 Safety Culture Survey
Callaway Action Reauests reviewed related to safety conscious work environment
200404503 200502693 200601951 200610290 200706425
200406409 200502722 200604086 200706407 200706429
200407284 200504133 200604672 200706417 200707744
200407480 200506261 200606421 200706418 200708271
200408626 200601104 200606424 200706420 200800944
200501049 200601108 200607472 200706421
200501953 200601377 200609882 200706423
Anonymous Callaway Action Requests
200500861 200502772 200600955 200701820 200711093
200500862 200503740 200604751 200709845 200711543
200500679 200504155 200605954 200710703
All-7 Attachment 1
Attachment 2
Initial Information Request - December 26, 2007
Callaway Problem Identification and Resolution Biennial Inspection
(IP 71152B; Inspection Report 05000483/2008006)
The inspection will cover the period of August 1, 2006, to February/March 2008. All requested
information should be limited to this period unless otherwise specified. As discussed, you can
upload the information to the Certrec inspection website. We would also like the information
provided on a CD prior to our preparation week. We will break down the request by required dates
to allow for effective preparation. Information provided in electronic media may also be in the form
of e-mail attachment(s), CDs, or thumb drives. The Agency has converted to MSOff ice. We have
document viewing capability for Adobe Acrobat (.pdf) files and other image files.
Please have the information uploaded to the Certrec Website by January 25, 2008, if possible.
Note: On summary lists please include a description of problem, status, initiating date, and
owner organization. Since you had a major conversion of your significance categories in
January 2007, the team would like to have the requests divided, as necessary so that the
information requested is compatible as far as significance. If you had existing CARS that
were converted from the old system to the new system a list of those converted would be
convenient.
1. Summary list of all Callaway Action Requests (CARS) of significant conditions adverse to
quality (Significant level 1 and 2) opened or closed from 08/01/2006 thru the conversion
implementation and (Significance Level 1, 2, and 3) after the conversion to the present.
2. Summary list of all CARS which were generated since 08/01/2006 separated by those prior
to the conversion and following the conversion
3. A list of all corrective action documents that aggregate or "roll-up" one or more smaller
issues for the period
4. Summary list of all action requests which were down-graded or up-graded in significance
since 08/01/2006
5. List of all root cause analyses completed since 08/01/2006. Include in this listing those root
causes considered as upper tier cause evaluations.
6. List of root cause analyses planned, but not complete at end of the period, include in this
list the upper tier cause evaluations.
7. List of all apparent cause analyses completed since 08/01/2006.
8. List of plant safety issues raised or addressed by the employee concerns program since
08/01/2006
A2-1 Attachment 2
9. List of action items generated or addressed by the plant safety review committees since
08/01/2006
10. All quality assurance audits and surveillances of corrective action activities completed since
08/01/2006
11. A list of all quality assurance audits and surveillances scheduled for completion since
08/01/2006, but which were not completed
12. All corrective action activity reports, functional area self-assessments, and non-NRC third
party assessments completed since 08/01/2006
13. Corrective action performance trending/tracking information generated since 08/01/2006
and broken down by functional organization. Quarterly reports are sufficient for this area if
they are broken down by organization and issue.
14. Current revisions of corrective action program procedures for: Condition Reporting,
Corrective Action Program, Root Cause Evaluation/Determination, Operator Work
Arounds, Work Requests, Requests for Engineering Resolution (RFR), Temporary
Modifications, Procedure Change Requests, Deficiency Reporting and Resolution,
Operating Experience Evaluation
15. A listing of all external events (OE) evaluated for applicability at Callaway since 08/01/2006
16. Action requests or other actions generated since 08/01/2006 for each of the items below:
Part 21 Reports:
[Applicable] NRC Information Notices:
All LERs issued by AmerenUE
NCVs and Violations issued to AmerenUE (including licensee-identified violations)
17. Safeguards event logs
18. Current system health reports or similar information
19. -Current predictive performance summary reports or similar information
20. Corrective action effectiveness review reports generated since 08/01/2006
21. List of risk significant components and systems
22. List of actions done and/or in the Human Performance Improvement Plan since the last
PIR inspection
23. Outage maintenance that was not done for whatever reason.
24. Any rework of maintenance performed from last outage
A2-2 Attachment 2
Attachment 3 - Concerns Evaluated
The NRC received a large number of allegations in Calendar Year 2007 at the Callaway Plant.
Consequently, Region IV management requested the biennial problem identification and resolution
inspection team to conduct a larger than normal number of safety conscious work environment
interviews. The team grouped these concerns into three major areas (Examples 1 - 3) that
reflected the types of statements made regarding the Callaway Plant. The team also reviewed two
technical concerns (Examples 4 and 5).
Example 1 - General Culture Concerns:
- Callaway Plant has a culture that discourages disagreement with upper management and
inhibits effective problem identification and resolution. (Operations)
" Management would prefer not to know about problems and is reluctant to fully investigate
them. (Operations)
- Workers do not enter issues into the corrective action program because they will be tasked
with resolving the issues. (Radiation Protection)
- Callaway does not have a healthy safety conscious work environment. (Radiation
Protection, Operations)
Example 2 - Employee Concerns Program Issues:
" The Employee Concerns Program does not maintain confidentiality. (Training)
" The Employee Concerns Program dismisses concerns without research. (Training)
- Two workers would not raise issues to the Employee Concerns Program for fear of
retaliation. (Operations, Engineering)
- The Employee Concerns Program was halted in the performance of an investigation.
(Maintenance)
Example 3 - Chilling Effects:
" A work environment where employees feel free to raise concerns does not exist within the
training and security departments, as well as the entire site in general. (Training, Security)
" A corrective action document was deleted from the corrective action program after the
plant manager chastised the originator for writing it. (Training)
" Workers do not feel comfortable raising issues to the NRC because several individuals who
have done so were terminated. (Radiation Protection)
Example 4 - The condition that caused damage to the residual heat removal pump suction relief
A3-1 Attachment 3
I C
valves has not been addressed in a timely manner. (Operations)
Example 5 - Callaway Plant was not recognizing and committing to doing the right thing with
regard to nuclear safety by not requesting a Technical Specification amendment that
restricted solid plant operations upon a loss of two cold overpressure mitigation
system relief. (Operations)
Evaluation - Examples 1, 2 and 3
The NRC provided in Ma 'nual Chapter 0305, "Operating Reactor Assessment Program," a
definition of a safety conscious work environment. Specifically, it is "an environment in which
employees feel free to raise safety concerns, both to their management and to the NRC, without
fear of retaliation and where such concerns are promptly reviewed, given their proper priority
based on their potential safety significance, and appropriately resolved with timely feedback to
employees."
Normally, an inspection team conducts 15 - 25 confidential intervie ws with employees to assess
the safety conscious work environment at plants during biennial problem identification and .
resolution inspections. To develop a comprehensive assessment of the safety conscious work
environment at Callaway Plant, the team interviewed 93 personnel in the operations, engineering,
maintenance, radiation protection, security, outage planning, radioactive waste management,
training, regulatory affairs and quality assurance organizations. The team used the questions
prescribed in Inspection Procedure 711 52B, "Identification and Resolution -of'Problems," to
determine employee attitudes regarding the safety conscious work environment at Callaway Plant.
The team informed the people selected by organizations who had expressed concern with the
safety conscious work environment and by the results of the Callaway Plant 2007 Safety Culture
Survey.
Generally, the team determined the following from the interviews:
" All personnel indicated that they would raise nuclear safety concerns by using one of the
four methods - corrective action program, supervisor, employee concerns program, or
NlRC. However, the team determined that not all individuals would use all of the methods
available to them. For example, one person indicated that he would not raise personal
issues unrelated to nuclear safety because he believed that management would take no
actions. Another individual indicated he would only talk to his supervisor.
" Not all employees would use the employee concerns program if they did not get
satisfaction from use of the corrective action program or from their supervisor. Specifically,
two individuals stated they did not trust the employee concerns program and would rather
talk to the NRC.
- Thirty percent of the personnel interviewed had a misconception of the employee concerns
program (e.g., did not know the program coordinator had changed, did not know the
purpose of the employee concerns program, did not know the location of the coordinator's
office, et cetera)
A3-2 A3-2
Attachment 3
I . .
In addition, the team asked additional questions that reflected the statements of concerned
individuals. For 52 of the 93 interviews, the team member asked the following specific questions
to address the statements from concerned individuals in the operations, engineering, t~raining, and
radioactive waste management organizations:
- Do you believe that you can readily disagree with your management?
" Does your management encourage differing views?
- Does the culture here promote or inhibit using the corrective action program?.
" Is management open to hearing problems?
- Is management reluctant to investigate problems fully?
- Does management recognize and commit to doing the right thing with regard to nuclear
safety?
.The team interviewed workers, supervisors, and managers. The individuals interviewed had a
broad mix of experience at Callaway, from relatively new individuals to individuals with over
20 years of experience. The team questioned personnel on all of the operating crews. Without
exception, the personnel interviewed responded to the above additional questions that: they felt
free to disagree with all levels of management, the current culture at Callaway promotes effective
problem identification and resolution, management encourages employees to raise nuclear safety
problems and other concerns, and management fully investigates nuclear safety problems and
other concerns.
The licensee had performed several assessments of their safety conscious work environment that
included:
- 2005 Synergy Safety Culture Survey
- 2007 Synergy Safety Culture Survey
- 2006 operations, engineering and training organization safety conscious work environment
surveys
- 2008 Independent Assessment of Safety Conscious Work Environment At Callaway
Generally, these assessments and surveys identified that the licensee maintained a safety
conscious work environment; however, each of the surveys identified that general culture and work
environment factors needed attention. The external surveys identified on site organizations that.
had poor responses relative to industry norms and to other onsite organizations that responded to
the survey. Finally, each of the external surveys identified that the licensee should address the
general culture and work environment factors so that a safety conscious work environment issue
does not emerge. In response to the 2008 Independent Assessment, the licensee had initiated a
Significance Level 2 Callaway Action Request to determine the root cause(s) and develop
appropriate corrective actions. Since the licensee had not finalized'their cause evaluation and
A3-3 A3-3
Attachment 3
a I)
developed corrective actions at the time of this inspection, the next biennial problem identification
and resolution inspection will evaluate the effectiveness of the corrective actions.
Because of the consistent responses among these assessments and our interviews, the team
concluded that Callaway had maintained a safety conscious work environment although some
areas and organizations required additional oversight.
Evaluation - Example 4
Previously, NRC had reviewed the timeline for development and implementation of this
modification. NRC had concluded that the licensee did not properly develop the modification;
therefore, the licensee could not implement the modification during Refueling Outage 15. From
review of actions following the failure to implement the modification, NRC challenged the licensee
regarding the ability of the relief valve discharge line to perform its function. From discussions with
the licensee, NRC concluded that leaving the line unmodified would not significantly increase the
risk to the plant, that the licensee planned to implement the modification in a manner
commensurate with its safety significance and that the licensee had violated no regulations.
During this inspection, the team reviewed documentation related to implementing the modification
and related to the modification and corrective actions. The team interviewed personnel familiar
with implementation of the modification for the relief valves in the residual heat removal system.
The team verified that the licensee had completed and scheduled the modification identified as a
corrective action in Callaway Action Request 200601188. Modification Package 07-0007, "Modify
the RHR Suction Relief Discharge Piping."
Evaluation - Example 5
The team evaluated this technical concern related to depressurizing the reactor coolant system
while in solid plant conditions. The team performed the evaluation by interviewing plant personnel
and reviewing applicable documents that included: Technical Specifications and Technical
Specification Bases, Standard Technical Specifications, Technical Specification Task Force
documents, a license amendment request, and internal e-mails on this topic.
Technical Specification 3.4.12.G states that with two required relief valve inoperable, action shall
be taken to depressurize the reactor coolant system and establish a reactor coolant system vent
greater than 2.0 square inches within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Given this specification, it would appear that
depressurizing with saturated conditions (a steam bubble) in the pressurizer would allow better
pressure control than depressurizing with a solid pressurizer. Depressurizing with a steam bubble
would reduce the risk of overpressurization because of better pressure control.
The industry, through an owner's group initiative, proposed to increase the Technical Specification
completion time with an inoperable cold overpressure mitigation system from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />
for all three PWR designs. The NRC agreed this was a more realistic time to plan and execute the
evolution and endorsed it by revising necessary Standard Technical Specifications to allow.
a 12-hour completion time with an inoperable cold overpressure mitigation system. The licensee
submitted a license amendment request on November 29, 2007, which requests extending the
completion time from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to depressurize the reactor coolant system and establish
a vent.
A3-4 Attachment 3
C , I -
The license amendment did not request a limitation that the Technical Specification be carried out
exclusive of solid plant operations. Requesting such a limitation would exceed and be more
restrictive than what NRC had previously reviewed as acceptable for Technical Specification
changes. The licensee would have to demonstrate such a change as risk beneficial as described
in Regulatory Guide 1.200, "An Approach for Determining the Technical Adequacy of Probabilistic
Risk Assessment Results for Risk-Informed Activities."
The team determined through interviews and reviewing documented e-mails, discovered that
Callaway Plant personnel had discussed this issue with their industry Technical Specifications
group and submitted their licensee amendment request without a provision to prohibit solid plant
operation. This change to a 12-hour completion time would likely address the concern as
evidenced by a senior reactor operator at the Callaway Plant writing that the 12-hours allowed
should be enough to comply with the Technical Specification while the pressurizer remains
saturated With a steam bubble.
The team concluded that Callaway Plant management made an acceptable decision to not exceed
what was considered as an acceptable path to ensure plant safety by not prohibiting solid plant
operations with respect to Technical Specification 3.4.12.G. Further, based upon the discussions
in Examples 1, 2, and 3 above in general and based upon this instance specifically, the team
determined that Callaway Plant recognized and committed to take appropriate actions.
Specifically, the licensee researched the issue and submitted a Technical Specification
amendment that requested the longest completion time allowed by Standard Technical
Specifications.
A3-5 Attachment 3
I . -
Callaway Plant PI&R Inspection
Inspection Report 2008006
2/11 - 3/14/2008
G. Pick (4660)
PIM NRC NA NA NA March 14, 2008 71152B NA
Biennial Problem Identification & Resolution Assessment
The team reviewed 246 Callaway Action Requests, several job orders, engineering evaluations,
associated root and apparent cause evaluations, and other supporting documentation to assess
problem identification and resolution activities. The team reviewed an additional 124 Callaway
Action Requests related to specific areas - essential service water, component cooling
water, 480 Vac auxiliary contacts and safety conscious work environment. Based on the sample
selected for review, the team concluded the licensee continued to have challenges in the area of
prioritization and evaluation, which require additional effort. The team also noted that licensee
performance. related to problem identification and resolution had improved. The team determined
the licensee had used the self-assessment process and quality assurance organization to improve
site performance. The team determined the improvement resulted from corrective action process
improvements implemented in January 2007, and management oversight changes implemented
following receipt of substantive cross-cutting issue in problem identification and resolution.
The team determined that the licensee had initiated actions that improved the quality of their
operability assessments, operational decision-making, and knowledge of the detailed design and
licensing basis since the last evaluation. The graduated approach to assigning cause evaluations
for conditions adverse to quality and the change that required the Callaway Action Request
screening committee to review all Callaway Action Requests provided increased assurance in the
ability of the licensee to identify and effectively resolve conditions adverse to quality.
The team determined that the licensee properly evaluated industry operating experience when
performing root cause andhigher tier cause evaluations; however, the licensee had continued
challenges effectively evaluating industry operating experience.
The team determined that licensee audits and assessments continued to be detailed, probing, and
self-critical. The licensee continued to use benchmarking of industry best practices and third party
evaluations that improved the corrective action program performance during this assessment
period. The licensee had effectively implemented performance improvements to address the
substantive cross-cutting issue (refer to March 2, 2007, End of Cycle letter) related to .evaluating
actions required for conditions adverse to quality as demonstrated by the decreased number of
findings in the latter half of this assessment period and lower affect that poor evaluations had on
the facility. However, the licensee will need to apply additional effort to affect improvements. The
improving performance resulted from increased management involvement in the corrective action
program and in daily activities.
Because of the increased number of allegations at the facility in Calendar Year 2007, including
several discrimination concerns, the team interviewed more personnel than normal to assess the
safety conscious work environment at the Callaway Plant. The team documented the nature of the
concerns and the increased scope of the evaluations in Attachment 3. The team determined that
not all individuals were comfortable using all of the methods available to them for reporting
I " , -
concerns; however, all personnel would have used at least one of the methods available for
reporting a safety concern. In addition, the team determined that the employee concerns program
requires more visibility and that not all personnel had confidence in the employee concerns
program. The team determined that our review results remained consistent with other safety
culture surveys that Callaway Plant had completed within the last year. The team determined that
some general culture and work envir6nment issues continued to be present from the last
assessment that were outside NRC regulatory jurisdiction, which if not addressed could potentially
affect the safety conscious work environment at the Callaway Plant.
A. Inspector-Identified and Self-Revealing Findinqs
Cornerstone: Mitigating Systems
J. Groom (4660)
PIM NRC NCV BI Green March 14, 2008 71152B P.2(a)
Nonconservative Technical Specification for Battery Inter-cell Connection Resistances
The team identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion Ill,
"Design Control," because the licensee failed to ensure that Technical Specification Surveillance
Requirements for the NK1 1 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
NK1 1 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 crosscutting 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).