ML103540382

Audit of the Licensee'S Management of Regulatory Commitments, Audit Performed October 13-15, 2010

ML103540382
Person / Time
Site:	Callaway
Issue date:	12/21/2010
From:	Thadani M Plant Licensing Branch IV
To:	Heflin A Union Electric Co
Polickoski J, NRR/DORL/LPL4, 415-5430
References
TAC ME4840
Download: ML103540382 (26)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 21, 2010 Mr. Adam C. Heflin Senior Vice President and Chief Nuclear Officer Union Electric Company P. O. Box 620 Fulton, MO 65251

SUBJECT:

CALLAWAY PLANT, UNIT 1 - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. ME4840)

Dear Mr. Heflin:

In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC.

The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.

An audit of the Callaway Plant, Unit 1, commitment management program was performed at the plant site during the period October 13-15, 2010. Based on the audit, the NRC staff concludes that Union Electric Company (the licensee) has implemented NRC commitments on a timely basis, with minor deficiencies noted and one commitment not implemented, and has implemented its program for managing NRC commitment changes with programmatic deficiencies noted. The details of the results of the audit are set forth in the enclosed audit report.

A. Heflin -2 If you have any questions, please contact me at 301-415-1476 or via e-mail at mohan.thadani@nrc.gov.

Sincerely, (b c~ ) ,--_~'l \C__61 ,,-.0 ~~ ./

Mohan C. Thadani, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483

Enclosure:

Audit Report cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483

1.0 INTRODUCTION AND BACKGROUND

In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML003741774), the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC.

The NRC Office of Nuclear Reactor Regulation (NRR) has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.

NEI-99-04 defines a "regulatory commitment" as an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC.

NRR guidelines direct the NRR Project Manager to audit the licensee's commitment management program by assessing the adequacy of the licensee's implementation of a sample of commitments made to the NRC in past licensing actions (amendments, relief requests, exemptions, etc.) and activities (bulletins, generic letters, etc.). The audit is to be performed every 3 years.

2.0 AUDIT PROCEDURE AND RESULTS An audit of the Callaway Plant, Unit 1, commitment management program was performed at the plant site during the period October 13-15, 2010, and discussed during a teleconference on December 16, 2010, with members of your staff. The audit reviewed commitments made by Union Electric Company (the licensee) since the previous audit on August 22-23,2007, which Enclosure

-2 was documented in an audit report dated October 31,2007 (ADAMS Accession No. ML072780002). The audit consisted of two major parts: (1) verification of the licensee's implementation of NRC commitments that have been completed, and (2) verification of the licensee's program for managing changes to NRC commitments.

2.1 Verification of Licensee's Implementation of NRC Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented commitments made to the NRC as part of past licensing actions/activities. For commitments not yet implemented, the NRC staff determines whether they have been captured in an effective program for future implementation.

2.1.1 Audit Scope The audit addressed a sample of commitments made during the review period. The audit focused on regulatory commitments (as defined above) made in writing to the NRC as a result of past licensing actions (amendments, relief requests, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.). Before the audit, the NRC staff performed a search in ADAMS for the licensee's submittals since the last audit and selected a representative sample for verification.

The audit excluded the following types of commitments that are internal to licensee processes:

(1) Commitments made on the licensee's own initiative among internal organizational components.

(2) Commitments that pertain to milestones of licensing actions/activities (e.g.,

respond to an NRC request for additional information by a certain date).

Fulfillment of these commitments was indicated by the fact that the subject licensing action/activity was completed.

(3) Commitments made as an internal reminder to take actions to comply with eXisting regulatory requirements such as regulations, Technical Specifications, and Updated Final Safety Analysis Reports. Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.

2.1.2 Audit Results The attached Audit Summary (Attachment 1) provides details of the audit and its results.

For reference, the licensee's commitments are tracked in the Commitment Tracking System (CTS) computer database and are managed in accordance with Callaway Plant procedure APA-ZZ-00540, "Commitment Management Program," Revision 013. For this audit, the NRC staff reviewed the selected sample of open and closed regulatory commitments to confirm that the licensee had implemented closed commitments appropriately, and that commitments still open had been captured in an effective program for future implementation as required by the Callaway Plant. The NRC staff reviewed relevant reports and summary sheets from the

-3 computer database and other sources (e.g., corrective action documentation, plant procedures, job numbers, night orders, documented training, etc.) providing the status of each commitment, form of implementation, and any pending further action. In addition, the NRC staff reviewed the licensee's "Commitment Tracking" self-assessment (SA09-RA-S02) dated July 9, 2009.

Based on the review of reports provided by the licensee as described above and on queries of the CTS database during the audit, the NRC staff found that the licensee has generally implemented commitments on a timely basis, but with the following specific implementation and programmatic deficiencies (as documented in Attachment 1):

(1) For Commitment 50123 for the one-time completion time extension for the Essential Service Water (ESW) system, formal training was not required nor tracked for non-licensed work control personnel authorized to control or release work. This lack of formalized training potentially contributed to four documented challenges in restricting work on the protected and/or opposite train of plant equipment (documented in the corrective action program and resident inspector integrated inspection report).

(2) For Commitment 50123 mentioned above, licensed operator training was performed without required training specifics as documented in a commitment for this license amendment. This commitment is documented here as not implemented.

(3) During the NRC staff review of the CTS database and other commitment documentation (most notably the corrective action program), commitments are generally not tracked for the discrete "explicit statement to take a specific action" level as described both in the licensee's procedure and the NEI 99-04 guidance.

Commitments are generally tracked holistically at the macro-topic level (at the licensing action level). The most notable example of this was for Commitment 50123, which comprised at least 26 discrete and distinct actions noted as regulatory commitments. Only one commitment tracking number was assigned for these 26 actions, and both the NRC and licensee staff had difficulty in reviewing many disparate databases (corrective action, training, procedures, job control, etc.) to aggregate the needed information to verify commitment implementation. This comment is also noteworthy in that it is a repeat comment from last Commitment Audit report for Callaway Plant dated October 31,2007, with no response from the licensee in the corrective action program.

2.2 Verification of the Licensee's Program for Managing NRC Commitment Changes The primary focus of this part of the audit is to verify that the licensee has established administrative controls for modifying or deleting commitments made to the NRC. The NRC staff compared the licensee's process for controlling regulatory commitments to the guidelines in NEI 99-04, which the NRC has found to be an acceptable guide for licensees to follow for managing and changing commitments. The process used at Callaway Plant is contained in APA-ZZ-00540, "Commitment Management Program," Revision 013 with accompanying change forms CA1571, "Commitment Revision, Initiation, Deletion, Request (CRIDR)," and CA2358, "Commitment Evaluation Summary." The auditors reviewed a sample of commitment changes

-4 that included changes that were or will be reported to the NRC, and changes that were not or will not be reported to the NRC. The auditors also verified that the licensee's commitment management system includes a mechanism to ensure traceability of commitments following initial implementation. This ensures that licensee personnel are able to recognize that future proposed changes to the affected design features or operating practices require evaluation in accordance with the commitment change control process.

2.2.1 Audit Results The attached Audit Summary (Attachment 2) provides details of this portion of the audit and its results.

The NRC staff reviewed procedure APA-ZZ-00540 and its required forms to determine whether the licensee had an effective program in place to identify, manage, and close commitments made to the NRC as part of licensing actions/activities. In addition, the NRC staff reviewed relevant reports and summary sheets from the computer database and other sources providing the status of each commitment, tracking and change forms, and other associated documentation.

The NRC staff compared the guidance in the Callaway Plant procedure APA-ZZ-00540 to the guidance in NEI 99-04. As a result of this comparison, the NRC staff found that the Callaway Plant procedure was consistent with the NEI guidance for identifying, managing, and closing commitments. The NRC staff also found that roles and responsibilities, processes, and metrics were clearly identified in the Callaway Plant procedure.

Based on the review of the reports provided by the licensee as described above, queries of the CTS database, and the accompanying change review and tracking forms provided during the audit, the NRC staff found that the licensee's implementation of its program for managing NRC commitment changes in accordance with its site procedure has programmatic deficiencies noted below and as documented in Attachment 2:

(1) The NRC staff reviewed 10 licensing actions documented in 29 separate correspondences to the NRC with multiple commitments contained within each licensing action. Of those 10 licensing actions reviewed, seven had missing or incorrect commitment change forms correlating to 13 of the 29 NRC correspondences not being documented properly per the licensee's commitment management program. Due to the number of discrepancies noted and the spectrum of commitments impacted, the NRC staff views this as a commitment management program programmatic deficiency.

(2) This above comment is also noteworthy in that it is a repeat comment from last Commitment Audit report for Callaway Plant dated October 31, 2007, with no response from the licensee in the corrective action program of the programmatic level concern.

-5

3.0 CONCLUSION

The NRC staff concludes, based on the audit, that (1) Callaway Plant (the licensee) has generally implemented NRC commitments on a timely basis with minor deficiencies noted and one commitment not implemented, and (2) Callaway Plant has implemented its program for managing NRC commitment changes with programmatic deficiencies noted.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Emily M. Fast Bert G. Yates Thomas B. Elwood Jeff D. Lancaster Principal Contributors: James T. Polickoski Mohan C. Thadani Date: December 21,2010 Attachments:

As stated

ATTACHMENT 1 IMPLEMENTATION OF COMMITMENTS

SUMMARY

OF AUDIT RESULTS OCTOBER 13-15, 2010 CALLAWAY PLANT, UNIT 1

IMPLEMENTATION OF COMMITMENTS

SUMMARY

OF AUDIT RESULTS OCTOBER 13-15, 2010 CALLAWAY PLANT, UNIT 1 Commitment Source Commitment Commitment Commitment Supporting Type Document Date Subject Number Description of Commitment Documents Implementation Status LAR ULNRC-05445 10/3112007 One-time 50123 Completion time (CT) extension PRAER 07-307 ULNRC-05476 2/21/2008 completion included the due date, requirements Rev. 1 ULNRC-05482 3/7/2008 time extension by PRAER 07-307 Rev. 1 for OL1282/

ULNRC-05500 5/6/2008 for essential OL1282/Amendment 186 to address Amendment 186 ULNRC-05520 7/10/2008 service water Tier 2 probabilistic risk assessment MP 07-0066 ULNRC-05563 12/1/2008 (ESW) (PRA) commitments to get one-time Amendment 191 system. 14-day ESW outage to implement MP 07-0066 and training on technical specification (TS) changes and implementation. The due date was extended by Amendment 191.

The commitment was closed at time of implementation.

50123-1 TS changes implemented by CLOSED - Commitment closed by 12/3/2008 and 4/16/2009. implementation of Amendment 186 on 11/1012008 and Amendment 191 on 2/26/2009.

50123-2-1 No PRA-modeled equipment, other CLOSED - Commitment closed via than out-of-service ESW train and CAR 200710836 Actions 2.0 and 2.2 supported systems rendered closed 12/1/2008; closed via two inoperable by that ESW train being Night Orders issued 11/28/2008.

out-of-service, will be voluntarily DISCREPANCIES NOTED taken out of service during the one Although specific, signature training time extended CT taken on each was provided to licensed operators train. via Night Orders, work control personnel (who are not all licensed operators) did not prescriptively receive this same training formally with a required signature. Minor findings documented in CAR 200602643 revealed vulnerabilities during the ESW modification in work control/management.

- 2 Commitment Source Commitment Commitment Commitment Supporting Type Document Date Subject Number Description of Commitment Documents Implementation Status 50123-2-2 No work will be allowed in the area CLOSED - Commitment closed via of equipment in the protected CAR 200710836 Actions 2.0 and 2.2 engineered safety feature (ESF) closed 12/1/2008; closed via two train (within 20 feet unless there is Night Orders issued 11/28/2008; an intervening barrier). Job Number 08006658.300 issued 11/30/2008.

DISCREPANCIES NOTED Although specific, signature training was provided to licensed operators via Night Orders, work control personnel (who are not all licensed operators) did not prescriptively receive this same training formally with a required signature. This contributed to non-cited violation (NCV)05000483/2009003-02, "Inadequate Controls of Crane Work Above the Protected Train of Essential Service Water" as noted by the site resident inspectors during the conduct of the ESW modification. Also, minor findings documented in CAR 200902661 revealed additional vulnerabilities during the ESW modification in work control/management.

50123-3 None of the PRA-modeled CLOSED - Commitment closed via equipment in either train will be CAR 200710836 Actions 2.2 and 3.6 voluntarily taken out of service closed 12/1/2008 and 11/1212008; during the time that normal service closed via two Night Orders issued water is available to supply the out 11/28/2008.

of-service ESW train loads. DISCREPANCIES NOTED Although specific, signature training was provided to licensed operators via Night Orders, work control personnel (who are not all licensed operators) did not prescriptively receive this same training formally with a required signature. Minor findings documented in CAR 200602643 revealed vulnerabilities during the ESW modification in work control/management.

- 3 Commitment Source Commitment Commitment Commitment Supporting Type Document Date Subject Number Description of Commitment Documents Implementation Status 50123-4-1 Access to the switchyard will be CLOSED - Commitment closed via limited to personnel with a Job Number 08006658.300/510 demonstratable need (operator issued 11/30/2008.

rounds involving no equipment manipulation and staff associated with performing 8-hour readiness checks on the temporary diesel generators (DGs>>.

50123-4-2 No pre-planned work or testing or CLOSED - Commitment closed via preventive maintenance will be CAR 200710836 Action 3.6 closed allowed in the switchyard, or other 11/12/2008.

areas of the plant, that could cause a loss of offsite power (LOOP) event during the 14-day extended CT).

50123-5 The one-time 14-day extended CT CLOSED - Commitment closed via will not be entered if, prior to entry, Job Number 08006658.200 issued inclement weather conditions are 11/1/2008; closed via CAR forecasted ( i.e., work under the 200710836 closed 11/12/2008.

extended CT will not be started if Severe Weather as defined in OTO-ZZ-00012 is forecasted to occur within 140 miles of the plant).

National Weather Service reports will be monitored prior to and throughout each ESW train limiting condition for operation (LCO) outage.

50123-6-1 The turbine-driven auxiliary CLOSED - Commitment closed via feedwater pump (TDAFP) will CAR 200710836 Action 3.7 closed remain operable. 11/1212008; closed via Job Number 08006658.300/310 issued 11/30/2008 and 12/1/2008.

- 4 Commitment Source Commitment Commitment Commitment Supporting Type Document Date Subject Number Description of Commitment Documents Implementati.on Status 50123-6-2 The TDAFP pump room and CLOSED - Commitment closed via associated valve rooms will be CAR 200710836 Action 3.7 closed posted as restricted access. 11/12/2008; closed via Job Number 08006658.300/310 issued 11/30/2008 and 12/1/2008.

DISCREPANCY NOTED - Minor findings documented in CAR 200902612 revealed vulnerabilities during the ESW modification in operations management of TDAFP pump room access.

50123-6-3 The protected train motor-driven CLOSED - Commitment closed via auxiliary feedwater pump (MDAFP) CAR 200710836 Action 3.7 closed pump room and associated valve 11/12/2008; closed via Job Number rooms will be posted as restricted 08006658.300/310 issued access. 11/3012008 and 12/1/2008.

50123-6-4 The condensate storage tank (CST) CLOSED - Commitment closed via will be posted as restricted access. CAR 200710836 Action 3.7 closed 11/12/2008; closed via Job Number 08006658.300/310 issued 11/30/2008 and 12/1/2008.

50123-6-5 No work will be allowed on the CLOSED - Commitment closed via Security Diesel. CAR 200710836 Action 3.7 closed 11/12/2008; closed via Job Number 08006658.300/31 0 issued 11130/2008 and 12/1/2008.

50123-7-1 During the portion of the extended CLOSED - Commitment closed via CT that normal service water is Job Number 08006658.600 issued supplying the ESW loads, the 12/3/2008.

normal service water to ESW supply and return cross-connect valves will be opened and power removed from the operators.

50123-7-2 The ESW return to ultimate heat CLOSED - Commitment closed via sink valves will be closed and power Job Number 08006658.610 issued removed from the operators during 12/9/2008.

this portion of the extended 14-day CTaswel1.

50123-8-1 Operations Department will verify CLOSED - Commitment closed via the availability of fire protection Job Number 08006658.150 issued equipment. 11/30/2008.

-5 Commitment Source Commitment Commitment Commitment Supporting Type Document Date Subject Number Description of Commitment Documents Implementation Status 50123-8-2 Operations Department will verify CLOSED - Commitment closed via the availability of flood mitigation Job Number 08006658.130/140 (drains, watertight doors) issued 11/30/2008 and 12/112008.

equipment.

50123-8-3 Prior to entering the extended ESW CLOSED - Commitment closed via CTs, a walkdown of the above Job Number 08006658.110/120 ground portion of the protected ESW issued 11/30/2008.

train will be performed for transient combustibles.

50123-8-4 This walkdown will also address the CLOSED - Commitment closed via seismic interaction commitments. Job Number 08006658.100 issued 12/1/2008.

50123-9-1 Continuous 1-hour and 8-hour fire CLOSED - Commitment closed via and flood watches will be instituted Job Number 08006658.400/410 on the protected ESW train ... issued 12/11/2008.

50123-9-2 The normal charging pump (NCP) CLOSED - Commitment closed via will remain functional and its room Job Number 08006658.300 issued will be posted as restricted access. 11/30/2008.

50123-9-3 If the NCP were to become non CLOSED - Commitment closed via functional during the 14-day LCO Night Order issued 11/28/2008.

outage such that the pump becomes unable to provide the required reactor coolant pump seal cooling, administrative controls will require plant shutdown to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

50123-10-1 Appropriate training will be provided CLOSED - Commitment closed via to operations personnel on this TS Licensed Operator Continuing change and the associated ESW Training (LOCT) Cycles 08-2 and modification. 08-4 closed on 4/11/2008 and 8/8/2008.

- 6 Commibnent Source Commibnent Commibnent Commibnent Supporting Type Document Date Subject Number Description of Commibnent Documents Implementation Status 50123-10-2 This training will identify dominant FAILED TO IMPLEMENT - The internal events, fire and internal LOCT Cycle 08-2 and 08-4 training flooding core scenarios, associated discussed above and credited for with the plant configuration during the above commitment did not the extended ESW CT, and include include the items listed in this a discussion of mitigation strategies commitment, and the licensee for these scenarios. cannot find a record that any training included the requirements of this commitment.

50123-11-1 A temporary alternate power source CLOSED - Commitment closed via consisting of DGs, with combined Job Number 08004308; closed via capacity equal to or greater than the CAR 200710836 Actions 1.4 and 3.4 capacity of either one of the installed closed on 8/2612008 and emergency DGs, will be available as 11/12/2008.

a backup power source.

50123-11-2 Prior to entering the extended 14 CLOSED - Commitment closed via day CT on each ESW train, these Job Number 08006658.500 issued temporary DGs will be load tested to 12/1/2008; Job Number provide a load equal to the 08004308.524 issued 12/2/2008; continuous rating of the inoperable and Night Order issued on DG. 11/28/2008.

50123-11-3 After entering the extended ESW CT CLOSED - Commitment closed via on each train, this source will be Job Number 08006658.510 issued verified available every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and 12/10/2008; closed via Night Order treated as protected equipment. and accompanying training as was issued on 11/28/2008.

RR ULNRC-05517 7/10/2008 Relief Request 50126 This commitment is for ESW 13R-10 PENDING - the licensee will for ESWpipe PE4710 Pipe to support Relief evaluate future industry Request 13R-10. The results will be investigations to confirm stress and submitted to the NRC prior to design factors as well as future submittal of Callaway's fourth 1D evolution of the fusion technique for year interval inservice inspection the installed joints. These results (lSI) plan, and will include, if will be completed and submitted to necessary, a fourth 1O-year interval the NRC per the commitment alternative request. This will be described by 6/20/2014.

completed prior to submittal of Callaway's lSI plan for the fourth 10-year interval with a due date of 6/20/2014.

-7 Commibnent Source Commibnent Commibnent Commibnent Supporting Type Document Date Subject Number Description of Commitment Documents Implementation Status GL ULNRC-05461 12/10/2007 Responds to 50109 Updates to actions originally ULNRC-05295 PENDING - actions related to this ULNRC-05521 6/24/2008 NRC Generic committed to in the 5/30/2006 letter commitment are ongoing.

ULNRC-05668 2/11/2009 Letter (GL) to NRC (ULNRC-05295) include a 2004-02 and status update and revision of associated commitment due dates (extensions).

containment sump evaluations GL ULNRC-05504 4/10/2008 GL 2008-01 50125 This commitment is to submit the Gas Accumulation PENDING - the first of two ULN RC-05551 10/13/2008 (Managing 50129 GL 2008-01 requested information Technical commitments is closed and ULNRC-05590 2/4/2009 Gas to the NRC within 90 days following Specifications Task documented in 50125 on 2/512009.

Accumulation the end of Refuel 16. Refuel 16 Force (TSTF) The second commitment is pending in Emergency ended 1117/2009. The requested Traveler/Consolidat the outcome of the industry/NRC Core Cooling, information was provided to the ed Line Item TSTF review.

Decay Heat NRC via ULNRC-05590 on Improvement Removal, and 2/4/2009. Process (CLlIP)

Containment Spray Systems)

NRC information request BL ULNRC-05253 1/25/2006 Inspection of 50094 Portions of the commitment are no ULNRC-05253 CLOSED - Commitment closed via ULNRC-05424 7/9/2007 Alloy longer applicable, and the remainder the following (2/1112005) :

82/182/600 of the commitment was met with

• installation of pressurizer nozzle materials used ULNRC-05253. full structural weld overlays in the

• the overlays have been fabrication of volumetrically examined pressurizer

• inspection reporting to the NRC penetrations is met via ULNRC-05253 and steam space piping connections at pressurized-water reactors (PWRs)

-8 Commitment Source Commitment Commitment Commitment Supporting Type Document Date Subject Number Description of Commitment Documents Implementation Status LAR ULNRC-05206 9/9/2005 Revision to TS 50124 This commitment is associated with OL 12581 CLOSED - Commitment closed via 3.7.3. Main the implementation of LAR OL-1258. Amendment 170 License Amendment 170 Feedwater revision to TS 3.7.3, Main implementation as follows Isolation Feedwater Isolation Valves, and (12/1512005):

Valves License Amendment 170 to include

• Amendment implemented no (MFIVs) implementation due date and later than Mode 3 (ascending) implementation of associated during startup from the changes. Refuel 15 Outage.

• Associated final safety analysis report (FSAR) and TS bases revisions were incorporated.

• Stroke time baseline testing of the MFIV LAR ULNRC-05269 5/22/2007 Boron dilution 50118 OL-1283 and ULNRC-05345. LA to OL-1283 CLOSED - Commitment closed via ULNRC-05345 amendment TS 3.9.2, "Unborated Water Source License Amendment 181 related to TS Isolation Valves" and TS 3.3.9, implementation as follows 3.9.213.3.9 "Boron Dilution Mitigation System (5/22/2007):

(BDMS)." Amendment, associated

• Implemented within 90 days procedure changes, associated

• Administrative controls via FSAR changes. and associated TS written procedures were Bases changes will be implemented established prior to within 90 days of NRC approval. implementation

• Associated FSAR and TS bases revisions were incorporated.

LAR ULNRC-05627 7/10/2009 Moving 50103 This commitment is to add the TS UFSAR Chapter 16 CLOSED - Commitment closed via Hydrogen requirement for Hydrogen License Amendment 199 Recombinerl Recombiners and monitors to FSAR implementation as follows Monitor TS to Chapter 16 upon implementation of (9/22/2010):

UFSAR the elimination of the TS

• The licensee verified its requirement. hydrogen monitoring system is capable of diagnosing beyond design-basis accidents

• The licensee will maintain the capability

• Hydrogen monitor requirements are included in FSAR Chapter 16.

- 9 Commibnent Source Commitment Commitment Commitment Supporting Type Document Date Subject Number Description of Commitment Documents Implementation Status Other ULNRC-05155 5/26/2005 B.5.b 50107 DISCREPANCY NOTED - it ULNRC-05258 2/24/2006 mitigation appears that credit is taken in OTO ULNRC-05357 1/4/2007 strategy for completion of Commitment implementatio 50107, but 50107 is not mentioned n in the references section of the OTO procedure.

50107-1 CLOSED - Commitment closed via Extensive Damage Mitigation Guidelines (EDMGS), OTO-SK 00003, Revision 003, Section 4a (8/22/07) 50107-2 CLOSED - Commitment closed via Extensive Damage Mitigation Guidelines (EDMGS), OTO-SK 00003, Revision 003, Attachment C (8/22/2007) 50107-3 CLOSED - Commitment closed via Extensive Damage Mitigation Guidelines (EDMGS), OTO-SK 00003, Revision 003, Attachment C (8/22/2007) 50107-4 CLOSED - closed as discussed in ULNRC-05258 50107-6 CLOSED - Commitment closed via Extensive Damage Mitigation Guidelines (EDMGS), OTO-SK 00003, Revision 003, Attachment D (8/22/2007) 50119 Five commitments that are security related and withheld from public disclosure in accordance with 10 CFR 2.390.

50119-1 Commitment #1 CLOSED - Commitment closed via Emergency Coordinator Supplemental Guide, Revision 008, Attachments JJ-QQ (8/22/2007)

- 10 Commitment Source Commitment Commitment Commitment Supporting Type Document Date Subject Number Description of Commitment Documents Implementation Status 50119-2 Commitment #2 CLOSED - Commitment closed via Extensive Damage Mitigation Guidelines (EDMGS), OTO-SK 00003, Revision 003, Section 4 (8/22/2007) 50119-3 Commitment #3 CLOSED - Commitment closed via Emergency Coordinator Supplemental Guide, Revision 008, Attachments B-D, V, X, Y, R, A, CC, DD, HH (8/22/2007) 50119-4 Commitment #4 CLOSED - Commitment closed via Emergency Coordinator Supplemental Guide, Revision 008, Attachments EE-GG, Z, AA, BB (8/22/2007) 50119-5 Commitment #5 CLOSED - Commitment closed via CAR 200601311, Actions 11,11.1, 11.2,11.3,11.4,12,12.1,12.2, 12.3, 12.4 (10/5/2007)

ATTACHMENT 2 MANAGEMENT OF CHANGES TO REGULATORY COMMITMENTS

SUMMARY

OF AUDIT RESULTS OCTOBER 13-15, 2010 CALLAWAY PLANT, UNIT 1

MANAGEMENT OF CHANGES TO REGULATORY COMMITMENTS

SUMMARY

OF AUDIT RESULTS OCTOBER 13-15,2010 CALLAWAY PLANT, UNIT 1 Commitment Source Commitment Commitment Commitment Original Description of Supporting Type Document Date Subject Number Commitment Revised Commitment Documents Change Status LAR ULNRC-05445 10/3112007 One-time 50123 CT extension included PRAER 07 DISCREPANCIES ULNRC-05476 2/21/2008 Completion the due date, 307 Rev. 1 NOTED-As ULNRC-05482 3/7/2008 Time (CT) requirements by OL 1282/ identified by the ULNRC-05500 5/6/2008 extension for PRAER 07-307 Rev. 1 for Amendment licensee during its ULNRC-05520 7/10/2008 essential OL1282/Amendment 186 186 Commitment Tracking ULNRC-05563 12/1/2008 service water to address Tier 2 MP 07-0066 Self-Assessment (ESW) system. probabilistic risk Amendment (SA09-RA-S02) dated assessment (PRA) 191 7/9/2009 and commitments to get one following commitment time 14-day ESW outage initiation with ULNRC to implement MP 07-0066 05445, no further and training on technical revision or deletion specification (TS) forms were submitted changes and for ULNRCs-05476, implementation. The due 05482,05500,05520, date was extended by 05563.

Amendment 191. The commitment was closed at time of implementation.

RR ULNRC-05517 7/1012008 Relief Request 50126 This commitment is for No new commitments 13R-10 Initiation Form for ESW pipe ESW PE4710 pipe to made. completed per support Relief Request procedure (CA1571 13R-10. The results will form on 08/25/2008).

be submitted to the NRC prior to submittal of Callaway's fourth 10-year interval inservice inspection (lSI) plan, and will include, if necessary, a fourth 1O-year interval alternative request. This will be completed prior to submittal of Callaway's lSI plan for the fourth 10 year interval with a due date of 6/20/2014.

-2 Commitment Source Commitment Commitment Commitment Original Description of Supporting Type Document Date Subject Number Commitment Revised Commitment Documents Change Status GL ULNRC-05124 31712005 Responds to 50109 Initial commitments were Updates to actions ULNRC DISCREPANCY ULNRC-05194 9/1/2005 NRC Generic provided in ULNRC- originally committed to in 05295 NOTED - An initiation ULNRC-05295 5/30/2006 Letter (GL) 05124 with additional the 5/30/2006 letter to form was not ULNRC-05408 5/112007 2004-02 and detail and commitments NRC (ULNRC-05295) submitted for the ULNRC-05461 12/10/2007 associated in ULNRC-05194. include a status update initial commitments of ULNRC-05521 612412008 containment and revision of ULNRC-05124 nor a ULNRC-05668 11/2412009 sump commitment due dates revision for the added evaluations (extensions). The detail and additional following ULRNC's have commitments in provided more updates to ULNRC-05194. The commitments: 05408, balance of revision 05461,05521,05668. forms through the current ULNRC-05668 are per procedure.

GL ULNRC-05504 4/10/2008 GL 2008-01 50125 This commitment is to Submit the GL 2008-01 Gas DISCREPANCY ULNRC-05551 10/1312008 (Managing Gas 50129 submit the GL 2008-01 requested information to Accumulation NOTED - Although an ULNRC-05590 2/4/2009 Accumulation in requested information to the NRC within 90 days TSTF initiation form was Emergency the NRC within 60 days following the end of Travelerl submitted for ULNRC Core Cooling, following the end of Refuel 16. Monitor CUIP 05504, a revision form Decay Heat Refuel 16. industry resolution and was not submitted for Removal, and submit LAR within 1 year the commitment Containment of NRC approval of changes in ULNRC Spray Systems) Technical Specifications 05551 as required per NRC Task Force (TSTF) and procedure for 50125 information Consolidated Line Item nor was a deletion request Improvement Process submitted following (CUIP). completion of the first commitment (noted in self-assessment).

Instead, the licensee initiated a new commitment (50129) to document the changed and new commitment in ULNRC-05551.

50129 was revised properly per procedure to update commitment status (although commitment wording remained unchanged).

-3 Commitment Source Commitment Commitment Commitment Original Description of Supporting Type Document Date Subject Number Commitment Revised Commitment Documents Change Status BL ULNRC-05031 7/27/2004 Inspection of 50094

• Perform bare metal The first commitment is ULNRC DISCREPANCY ULNRC-05253 1/25/2006 Alloy visual inspections no longer applicable, and 05253 NOTED- The ULNRC-05424 7/9/2007 82/182/600 near the beginning of the second commitment licensee did not follow materials used each outage was met with ULNRC- procedure by not in the

• Submit a report to the 05253. initiating a fabrication of NRC indicating the commitment per pressurizer inspections completed procedure for penetrations and the as-found ULNRC-05031 and steam condition of the containing the initial space piping pressurizer two commitments.

connections at Also, no revision or pressurized- initiation was water reactors . performed per procedure when ULNRC-05253 was submitted. Finally, the licensee documented a revision after commitment closure on 8/19/2009 when the commitment was closed 2/11/2005.

LAR ULNRC-05206 9/9/2005 Revision to TS 50124 This commitment is No new commitments OL1258/ Initiation Form ULNRC-05224 10/2412005 3.7.3, Main associated with the made. Amendment completed per Feedwater implementation of LAR 170 procedure (CA1571 Isolation Valves OL-1258, revision to TS form on 11/29/2007>>.

(MFIVs) 3.7.3, Main Feedwater Isolation Valves and License Amendment 170 to include implementation due date and implementation of associated changes.

-4 Commitment Source Commitment Commitment Commitment Original Description of Supporting Type Document Date Subject Number Commitment Revised Cc)mmitment Documents Change Status LAR ULNRC-05269 5/22/2007 Boron dilution 50118 OL-1283 and ULNRC ULNRC-05345 added a OL-1283 DISCREPANCY ULNRC-05345 amendment 05269, LA to TS 3.9.2, fifth commitment to NOTED- The related to TS "Unborated Water Source ensure written licensee did not follow 3.9.2/3.3.9 Isolation Valves" and TS procedures will ensure procedure by not 3.3.9, "Boron Dilution prompt verification that initiating a Mitigation System unborated water sources commitment per (BDMS)." Amendment, shall be secured in the procedure for associated procedure closed position. ULNRC-05269. The changes, associated final licensee instead safety analysis report initiated the (FSAR) changes, and commitment per the associated TS Bases fi nal Iist of changes will be commitments in implemented within ULNRC-05345 90 days of NRC approval. instead of what should have been a revision.

LAR ULNRC-05627 7/10/2009 Moving 50103 Original commitment was Detailed commitment UFSAR Commitment revision Hydrogen a placeholder awaiting within license amendment Chapter 16 form submitted per Recombiner/ submission of an LAR. request to add the TS procedure Monitor TS to requirement for Hydrogen completed per Updated Final Recombiners and CA1571 form Safety Analysis monitors to FSAR 3/23/2010.

Report Chapter 16 upon (UFSAR) implementation of the elimination of the TS requirement.

-5 Commitment Source Commitment Commitment Commitment Original Description of Supporting Type Document Date SUbject Number Commitment Revised Commitment Documents Change Staws Othe ULN RC-05155 5126/2005 B.5.b mitigation 50107 DISCREPANCY r ULNRC-05256 2/14/2006 strategy NOTED - the original ULNRC-05258 2/2412006 implementation commitment for 50107 ULNRC-05357 1/4/2007 was made via ULNRC-05155 and further clarified with 8 commitments via ULNRC-05258.

Although a commitment revision form exists for ULNRC-05258, no commitment initiation form exists for ULNRC-05155. This is against the licensee's commitment management program procedure requiring submittal of internal change forms to drive internal licensee review and/or track status.

-6 Commitment Source Commitment Commitment Commitment Original Description of Supporting Type Document Date Subject Number Commitment Revised Commitment Documents Change Status 50119 Five commitments that DISCREPANCY are security related and NOTED - the original withheld from public commitment for 50119 disclosure in accordance was made via with 10 CFR 2.390 ULNRC-05256 and further clarified with 5 commitments via ULNRC-05357.

Although a commitment initiation form exists for ULNRC-05357 (which should have been a commitment revision form), no commitment initiation form exists for ULNRC-05256.

This is against the licensee's commitment management program procedure requiring submittal of internal change forms to drive internal licensee review and/or track status.

ML103540382 OFFICE NRR/LPL4/PM NRR/LPL4/PM NRR/LPL4/LA NRR/LPL4/BC NRR/LPL4/PM MThadani MThadani NAME JPolickoski (.IRHall for) JBurkhardt MMarkley (BSingal for)

DATE 12/20/2010 12/21/10 12/21/10 12/21/10 12/21/10