ML14216A691

IR 05000483-14-003; 03/22/2014 - 07/01/2014; Callaway Plant, Integrated Resident and Regional Report; Operability Determinations and Functionality Assessments, and Other Activities

ML14216A691
Person / Time
Site:	Callaway
Issue date:	08/04/2014
From:	O'Keefe N NRC/RGN-IV/DRP/RPB-B
To:	Diya F Union Electric Co
References
IR-14-003
Download: ML14216A691 (49)

See also: IR 05000483/2014003

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E LAMAR BLVD

ARLINGTON, TX 76011-4511

August 4, 2014

Mr. Fadi Diya, Senior Vice

President and Chief Nuclear Officer

Union Electric Company

P.O. Box 620

Fulton, MO 65251

SUBJECT: CALLAWAY PLANT - NRC INTEGRATED INSPECTION

REPORT 05000483/2014003

Dear Mr. Diya:

On July 1, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at

the Callaway Plant. On July 1, 2014, the NRC inspectors discussed the results of this

inspection with you and members of your staff. Inspectors documented the results of this

inspection in the enclosed inspection report.

NRC inspectors documented two findings of very low safety significance (Green) in this report.

One of these findings involved a violation of NRC requirements. Further, inspectors

documented a licensee-identified violation, which was determined to be of very low safety

significance. The NRC is treating these violations as non-cited violation (NCV) consistent with

Section 2.3.2.a of the NRC Enforcement Policy.

If you contest the violation or significance of the NCV, you should provide a response within

30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with

copies to the Regional Administrator, Region IV; the Director, Office of Enforcement,

U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident

inspector at the Callaway Plant.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a

regulatory requirement in this report, you should provide a response within 30 days of the date

of this inspection report, with the basis for your disagreement, to the Regional Administrator,

Region IV, and the NRC resident inspector at the Callaway Plant.

F. Diya -2-

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public

Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your

response (if any) will be available electronically for public inspection in the NRCs Public

Document Room or from the Publicly Available Records (PARS) component of the NRCs

Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible

from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic

Reading Room).

Sincerely,

/RA/

Neil OKeefe, Branch Chief

Project Branch B

Division of Reactor Projects

Docket Nos.: 50-483

License Nos: NPF-30

Enclosure:

Inspection Report 05000483/2014003

w/Attachments

1. Supplemental Information

2. Callaway SSPS Replacement Questions

cc w/ encl:

Electronic Distribution for Callaway Plant

ML14216A691

SUNSI Review ADAMS Publicly Available Non-Sensitive Keyword:

By: N. O'Keefe Yes No Non-Publicly Available Sensitive NRC-002

OFFICE SRI/DRP/B RI/DRP/B SPE/DRP/B C:DRS/EB1 C:DRS/EB2 C:DRS/OB C:DRS/PSB1

NAME THartman/dch ZHollcraft DProulx TFarnholtz JDixon VGaddy MHaire

SIGNATURE E: CFO for E: CFO for /RA/ /RA/ /RA/ /RA/ /RA/

DATE 7/28/14 7/28/14 7/25/14 8/4/14 7/28/14 7/28/14 7/31/14

OFFICE C:DRS/PSB2 C:DRS/TSB C:DRP/B

NAME Gepford GMiller NOKeefe

SIGNATURE /RA/ /RA/ /RA/

DATE 7/28/14 7/31/14 8/4/14

Letter/Inspection Report to Fadi Diya from Neil OKeefe, dated August 4, 2014

SUBJECT: CALLAWAY PLANT - NRC INTEGRATED INSPECTION

REPORT 05000483/2014003

DISTRIBUTION:

Regional Administrator (Marc.Dapas@nrc.gov)

Deputy Regional Administrator (Kriss.Kennedy@nrc.gov)

Acting DRP Director (Troy.Pruett@nrc.gov)

Acting DRP Deputy Director (Michael.Hay@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

DRS Deputy Director (Jeff.Clark@nrc.gov)

Senior Resident Inspector (Thomas.Hartman@nrc.gov)

Resident Inspector (Zachary.Hollcraft@nrc.gov)

Branch Chief, DRP/B (Neil.OKeefe@nrc.gov)

Senior Project Engineer, DRP/B (David.Proulx@nrc.gov)

Project Engineer, DRP/B (Fabian.Thomas@nrc.gov)

CW Administrative Assistant (Dawn.Yancey@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (Fred.Lyon@nrc.gov)

Branch Chief, DRS/TSB (Geoffrey.Miller@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

RIV/ETA: OEDO (Anthony.Bowers@nrc.gov)

ROPreports

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000483

License: NPF-30

Report: 05000483/2014003

Licensee: Union Electric Company

Facility: Callaway Plant

Location: Junction Highway CC and Highway O

Steedman, MO

Dates: March 22 through July 1, 2014

Inspectors: T. Hartman, Senior Resident Inspector

Z. Hollcraft, Resident Inspector

J. Braisted, Reactor Inspector

P. Elkmann, Senior Emergency Preparedness Inspector

G. George, Senior Reactor Inspector

P. Jayroe, Reactor Inspector

D. Proulx, Senior Project Engineer

R. Stroble, Resident Inspector

Approved By: N. OKeefe

Chief, Project Branch B

Division of Reactor Projects

-1- Enclosure

SUMMARY

IR 05000483/2014003; 03/22/2014 - 07/01/2014; Callaway Plant, Integrated Resident and

Regional Report; Operability Determinations and Functionality Assessments, and Other

Activities.

The inspection activities described in this report were performed between March 22 and

June 20, 2014, by the resident inspectors at the Callaway Plant and other inspectors from

Region IV. Two findings of very low safety significance (Green) are documented in this report.

One finding involved a violation of NRC requirements. The significance of inspection findings is

indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection

Manual Chapter 0609, Significance Determination Process. Their cross-cutting aspects are

determined using Inspection Manual Chapter 0310, Components Within the Cross-Cutting

Areas. Violations of NRC requirements are dispositioned in accordance with the NRC

Enforcement Policy. The NRCs program for overseeing the safe operation of commercial

nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

Cornerstone: Mitigating Systems

• Green. The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B,

Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to perform an

adequate extent of condition assessment. While performing an evaluation of pitting

corrosion identified on buried refueling water storage piping, the licensee failed to provide an

adequate technical justification for not expanding the scope of their review beyond the

specific piping when pitting corrosion was identified in the original sample selection.

Licensee procedural guidance for a Significance Level 3 adverse condition requires the

reviewer to identify other potentially susceptible systems or components and fully explain

the boundary for the extent of condition, but this was not done. This finding does not

represent an immediate safety concern. The licensee entered the finding into their

corrective action program as Callaway Action Request 201402168. This finding affected

safety-related piping in which pitting was observed and repaired prior to being returned to

service.

The licensees failure to perform an adequate extent of condition review of the pitting of the

buried 24-inch refueling water storage tank piping in the essential core cooling system

supply line is a performance deficiency. The performance deficiency is more than minor,

and therefore a finding, because if left uncorrected, it has the potential to lead to a more

significant safety concern if other welds on this same pipe render it susceptible to pitting

corrosion in the weld heat affected zone. The finding affects the Mitigating System

Cornerstone because the performance deficiency is related to the essential core cooling

systems ability to conduct short-term decay heat removal. The finding is of very low safety

significance (Green) because the finding is not a design or qualification deficiency, did not

result in the loss of operability or functionality of a single train for greater than the technical

specification allowed outage time, and did not represent an actual loss of safety function for

greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This finding has a cross-cutting aspect in the conservative bias

component of the human performance cross-cutting area because the licensee did not use

conservative decision-making practices that emphasize prudent choices over those that are

simply allowable [H.14]. (Section 4OA5)

-2-

Cornerstone: Barrier Integrity

• Green. The inspectors identified a finding for the licensees failure to properly install a flow

transmitter for the containment spray system. Specifically, since construction, Rosemount

Transmitter ENFT0005, which provides a signal for containment spray train A pump flow

rate, had a plastic shipping plug installed in the spare conduit port instead of the vendor-

required stainless steel plug. The licensee did not include this transmitter as part of an

operating experience extent of condition walkdown conducted in 2010 because the

transmitter provides indication only and does not have an active safety function. However,

the inspector determined that this transmitter provides operator post-accident monitoring

capability of containment spray pump performance. The licensee entered this issue into the

corrective action program as Callaway Action Request 201403300. The licensee reviewed

this deficiency and determined that although Transmitter ENFT0005 was degraded, the

containment spray system remained operable. The licensee promptly replaced the plastic

shipping plug with the required stainless steel plug.

Failure to properly install a Rosemount transmitter needed for post-accident monitoring to its

qualified configuration was a performance deficiency. This performance deficiency was

more than minor, and therefore a finding, because it adversely affected the configuration

control attribute and the Barrier Integrity Cornerstone objective to provide reasonable

assurance that physical design barriers (i.e., containment) protect the public from

radionuclide releases caused by accidents or events. Specifically, the improperly configured

containment spray flow transmitter could have resulted in erratic spray flow indication, which

could impede operators ability to monitor this parameter and act upon the indication. The

finding is of very low safety significance (Green) because containment spray is not a

significant contributor to large early release frequency. This finding does not have a

cross-cutting aspect because the transmitter was installed in this manner during original

construction and, thus, was not indicative of current licensee performance. (Section 1R15)

Licensee-Identified Violations

A violation of very low safety significance was identified by the licensee and has been reviewed

by the inspectors. Corrective actions taken or planned by the licensee have been entered into

the licensees corrective action program. This violation and associated corrective action

tracking numbers are listed in Section 4OA7 of this report.

-3-

PLANT STATUS

Callaway operated at 100 percent power for the duration of the inspection period with the

exception of planned power reductions for routine surveillances and post-maintenance testing.

REPORT DETAILS

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection (71111.01)

Summer Readiness for Offsite and Alternate AC Power Systems

a. Inspection Scope

On May 16, 2014, the inspectors completed an inspection of the stations offsite and

alternate ac power systems. The inspectors inspected the material condition of these

systems, including transformers and other switchyard equipment, to verify that plant

features and procedures were appropriate for operation and continued availability of

offsite and alternate ac power systems. The inspectors reviewed open condition reports

for these systems. The inspectors walked down the switchyard to observe the material

condition of equipment providing offsite power sources. The inspectors assessed

corrective actions for identified degraded conditions and verified that the licensee had

considered the degraded conditions in its risk evaluations and had established

appropriate compensatory measures.

The inspectors verified that the licensees procedures included appropriate measures to

monitor and maintain availability and reliability of the offsite and alternate ac power

systems.

These activities constituted one sample of summer readiness of offsite and alternate ac

power systems, as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

1R04 Equipment Alignment (71111.04)

.1 Partial Walkdown

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant

systems:

• April 22, 2014, residual heat removal system train B

• April 30, 2014, auxiliary feedwater system train B

• June 17, 2014, emergency exhaust system train B

-4-

The inspectors reviewed the licensees procedures and system design information to

determine the correct lineup for the systems. They visually verified that critical portions

of the trains were correctly aligned for the existing plant configuration.

These activities constituted three partial system walk-down samples as defined in

Inspection Procedure 71111.04.

b. Findings

No findings were identified.

.2 Complete Walkdown

a. Inspection Scope

On April 21, 2014, the inspectors performed a complete system walkdown inspection

of the control building heating, ventilation, and air conditioning system. The inspectors

reviewed the licensees procedures and system design information to determine the

correct system lineup for the existing plant configuration. The inspectors also reviewed

outstanding work orders, open condition reports, and other open items tracked by the

licensees operations and engineering departments. The inspectors then visually verified

that the system was correctly aligned for the existing plant configuration.

These activities constituted one complete system walk-down sample, as defined in

Inspection Procedure 71111.04.

b. Findings

No findings were identified.

1R05 Fire Protection (71111.05)

Quarterly Inspection

a. Inspection Scope

The inspectors evaluated the licensees fire protection program for operational status

and material condition. The inspectors focused their inspection on five plant areas

important to safety:

• April 16, 2014, transformers west of the turbine building, fire area T-14

• April 23, 2014, residual heat removal train A pump room, fire area A-2A

• May 19, 2014, access control and electrical equipment air conditioning unit

train A room, fire area C-14

• June 2, 2014, upper and lower cable spreading rooms, fire areas C-21 and C-22

• June 17, 2014, control building and communications corridor, fire area C-27

-5-

For each area, the inspectors evaluated the fire plan against defined hazards and

defense-in-depth features in the licensees fire protection program. The inspectors

evaluated control of transient combustibles and ignition sources, fire detection and

suppression systems, manual firefighting equipment and capability, passive fire

protection features, and compensatory measures for degraded conditions.

These activities constitute five quarterly fire protection inspection samples, as defined in

Inspection Procedure 71111.05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures (71111.06)

a. Inspection Scope

On May 13, 2014, the inspectors completed an inspection of the stations ability to

mitigate flooding due to internal causes. After reviewing the licensees flooding analysis,

the inspectors chose the Class 1E ac electrical switchgear train A room plant area which

contains risk-significant structures, systems, and components that are susceptible to

flooding.

The inspectors reviewed plant design features and licensee procedures for coping with

internal flooding. The inspectors walked down the selected area to inspect the design

features, including the material condition of seals, drains, and flood barriers. The

inspectors evaluated whether operator actions credited for flood mitigation could be

successfully accomplished.

In addition, on June 5, 2014, the inspectors completed an inspection of underground

bunkers susceptible to flooding. The inspectors selected safety-related electrical

manhole MH01B that contained risk-significant cables whose failure could disable risk-

significant equipment. The inspectors observed the material condition of the cables and

splices contained in the manhole and looked for evidence of cable degradation due to

water intrusion. The inspectors verified that the cables and manhole met design

requirements.

These activities constitute completion of one flood protection measures sample and one

bunker/manhole sample, as defined in Inspection Procedure 71111.06.

b. Findings

No findings were identified.

1R07 Heat Sink Performance (71111.07)

a. Inspection Scope

On April 9, 2014, the inspectors completed an inspection of the readiness and availability

of risk-significant heat exchangers. The inspectors reviewed the data from eddy current

testing for emergency diesel lubricating oil heat exchanger train B and observed the

licensees inspection and the material condition of the heat exchanger internals.

-6-

Additionally, the inspectors walked down this heat exchanger to observe its performance

and material condition.

These activities constitute completion of one heat sink performance annual review

sample, as defined in Inspection Procedure 71111.07.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

(71111.11)

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On May 6, 2014, the inspectors observed a portion of an annual requalification test for

licensed operators. The inspectors assessed the performance of the operators and the

evaluators critique of their performance. The inspectors also assessed the modeling

and performance of the simulator during the requalification activities.

These activities constitute completion of one quarterly licensed operator requalification

program sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

On April 27, 2014, the inspectors observed the performance of on-shift licensed

operators in the plants main control room. At the time of the observations, the plant was

in a period of heightened risk due to the turbine-driven auxiliary feedwater pump being

unavailable for testing.

In addition, the inspectors assessed the operators adherence to plant procedures,

including ODP-ZZ-00001, Operations Department - Code of Conduct, and other

operations department policies.

These activities constitute completion of one quarterly licensed operator performance

sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

-7-

1R12 Maintenance Effectiveness (71111.12)

a. Inspection Scope

The inspectors reviewed three instances of degraded performance or condition of safety-

related structures, systems, and components:

• April 2, 2014, centrifugal charging pump train A room cooler faulty stop

pushbutton

• May 14, 2014, boron injection header train B outlet to cold legs isolation valve

torque switch set incorrectly

• May 27, 2014, ultimate heat sink cooling tower train A electrical room inlet

damper operator hydramotor failure

The inspectors reviewed the extent of condition of possible common cause structure,

system, and component failures and evaluated the adequacy of the licensees corrective

actions. The inspectors reviewed the licensees work practices to evaluate whether

these may have played a role in the degradation of the structures, systems, and

components. The inspectors assessed the licensees characterization of the

degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that

the licensee was appropriately tracking degraded performance and conditions in

accordance with the Maintenance Rule.

These activities constituted completion of three maintenance effectiveness samples, as

defined in Inspection Procedure 71111.12.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)

a. Inspection Scope

The inspectors reviewed three risk assessments performed by the licensee prior to

changes in plant configuration and the risk management actions taken by the licensee in

response to elevated risk:

• March 25, 2014, Yellow risk for emergency diesel generator train A, essential

service water train A, and ultimate heat sink train A planned maintenance,

Job 13512067

• April 9, 2014, elevated Green risk for emergency diesel generator train B,

essential service water train B, and ultimate heat sink train B planned

maintenance, Job 11504085

• April 30, 2014, Yellow risk for turbine-driven auxiliary feedwater pump planned

maintenance, Job 14501194

-8-

The inspectors verified that these risk assessments were performed timely and in

accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant

procedures. The inspectors reviewed the accuracy and completeness of the licensees

risk assessments and verified that the licensee implemented appropriate risk

management actions.

Additionally, on May 20, 2014, the inspectors observed portions of one emergent work

activity, replacement of a current to pneumatic converter on the turbine-driven auxiliary

feedwater flow control valve to steam generator B, Job 14002312, which had the

potential to affect the functional capability of mitigating systems.

The inspectors verified that the licensee appropriately developed and followed a work

plan for these activities. The inspectors verified that the licensee took precautions to

minimize the impact of the work activities on unaffected structures, systems, and

components.

These activities constitute completion of four maintenance risk assessments and

emergent work control inspection samples, as defined in Inspection Procedure 71111.13.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments (71111.15)

a. Inspection Scope

The inspectors reviewed four operability determinations and functionality assessments

that the licensee performed for degraded or nonconforming structures, systems, or

components:

• April 3, 2014, functionality assessments of spent fuel pool pump train B room

cooler, Callaway Action Requests 201401683 and 201401587

• May 13, 2014, operability determination of containment spray train A pump

discharge flow transmitter, Callaway Action Request 201403300

• May 28, 2014, operability determination of engineered safety features switchgear

train A from improperly stored floor mats, Callaway Action Request 201401795

• June 17, 2014, functionality assessment of Class 1E switchgear room chiller

train A, Callaway Action Request 201403902

The inspectors reviewed the timeliness and technical adequacy of the licensees

evaluations. Where the licensee determined the degraded structures, systems, and

components to be operable or functional, the inspectors verified that the licensees

compensatory measures were appropriate to provide reasonable assurance of

operability or functionality. The inspectors verified that the licensee had considered the

effect of other degraded conditions on the operability or functionality of the degraded

structure, system, or component.

-9-

These activities constitute completion of four operability and functionality review

samples, as defined in Inspection Procedure 71111.15.

b. Findings

Shipping Plug Installed in Rosemount Transmitter

Introduction. The inspectors identified a Green finding for the failure to properly install a

flow transmitter for the containment spray system. Specifically, as of May 13, 2014,

Transmitter ENFT0005, which provides a signal for containment spray pump train A flow

rate, had a plastic shipping plug installed in the spare conduit port, instead of the vendor-

required stainless steel plug.

Description. Flow Transmitter ENFT0005 provides a signal for control room indication of

containment spray flow rate. It is a Rosemount 1153 Series B model transmitter, which

is used in several safety-related and nonsafety-related level or flow applications. It is

located in the emergency core cooling system train A room (which contains the

containment spray, centrifugal charging, safety injection pumps, and supporting

equipment).

On May 13, 2014, during a tour of the emergency core cooling system train A room, the

inspectors noted that a plastic shipping plug was installed in the spare conduit port for

Transmitter ENFT0005, on the bottom where it was not readily visible. The vendor

manual for the transmitter directed the user to discard the plastic plug upon installation

and install a stainless steel plug in the spare conduit hole using thread sealant to prevent

moisture intrusion. The inspectors informed the licensee, who initiated Callaway Action

Request 201403300 to enter this issue into the corrective action program. The licensee

reviewed this deficiency and determined that although Transmitter ENFT0005 was

degraded, the containment spray train remained operable. The licensee replaced the

plastic shipping plug with the vendor-recommended stainless steel plug in accordance

with Job 14002189.

The licensee investigation revealed that Transmitter ENFT0005 had been installed with

the plastic shipping plug during original construction. Using industry-operating

experience, the licensee had several previous opportunities to identify this issue. The

licensee had previously issued Callaway Action Request 201011748 to inspect similar

transmitter configurations at Callaway Plant. The scope of these inspections was limited

to transmitters that had an active safety function (e.g., actuation or trip signals).

Because Transmitter ENFT0005 provides indication only, it was not included in the

scope of the 2010 inspection. The inspectors noted that the containment spray flow

indication, although considered a nonsafety-related parameter, is listed in the Updated

Final Safety Analysis Report, Table 7-3A, Item D.6.1, as a passive post-accident

monitoring variable.

Although Transmitter ENFT0005 was not a 10 CFR Part 50, Appendix B, quality-related

component, the licensee did not meet the standard of having a fully qualified instrument

for post-accident monitoring, in that the transmitter did not conform to the vendor-

recommended configuration to prevent post-accident moisture intrusion. Reference

Manual 00809-0100-04302, Rosemount 1153 Series B Alphaline Pressure Transmitter,

Revision BA, January 2008, Section 2, Installation, directed the user to close off the

unused conduit hub with a stainless steel 1/2 - 14 NPT plug and seal all threads with pipe

- 10 -

thread sealant. Leaving the plastic shipping plug in place from initial construction until

May 13, 2014, did not meet this standard and was considered a finding.

Analysis. Failure to properly install a Rosemount transmitter needed for post-accident

monitoring to its qualified configuration was a performance deficiency. Specifically, the

licensee failed to replace a plastic shipping plug with a stainless steel plug to provide

protection from the environment. This performance deficiency was more than minor;

and therefore a finding, because it adversely affected the configuration control attribute

of the Barrier Integrity Cornerstone and affected the cornerstone objective to provide

reasonable assurance that physical design barriers (i.e., containment) protect the public

from radionuclide releases caused by accidents or events. Specifically, the improperly

configured containment spray flow transmitter could result in erratic spray flow indication,

which could impede operators ability to monitor this parameter and to act upon the

indication.

Using NRC Inspection Manual 0609, Appendix H, Containment Integrity Significance

Determination Process, issued May 6, 2004, the finding was determined to be of very

low safety significance because the containment spray system is not a significant

contributor to a large early release frequency. This finding does not have a cross-cutting

aspect because it was not indicative of current licensee performance since the

transmitter was installed during original construction.

Enforcement. This finding does not involve enforcement action because no violation of a

regulatory requirement was identified. Because this finding does not involve a violation

and is of very low safety significance, it is identified as FIN 05000483/2014003-01,

Plastic Shipping Plug in Rosemount Transmitter.

1R19 Post-Maintenance Testing (71111.19)

a. Inspection Scope

The inspectors reviewed five post-maintenance testing activities that affected risk-

significant structures, systems, or components:

• March 26, 2014, emergency diesel generator train A fast start, Job 13512067

• April 9, 2014, essential service water pump train B, Job 12511473

• April 9, 2014, ultimate heat sink cooling tower fans B and D, Jobs 12511470

and 12511471

• April 23, 2014, residual heat removal pump train A, Job 12512029

• June 18, 2014, emergency exhaust filter train A, Job 14001821

The inspectors reviewed licensing- and design-basis documents for the structures,

systems, and components and the maintenance and post-maintenance test procedures.

The inspectors observed the performance of the post-maintenance tests to verify that

the licensee performed the tests in accordance with approved procedures, satisfied the

established acceptance criteria, and restored the operability of the affected structures,

systems, and components.

- 11 -

These activities constitute completion of five post-maintenance testing inspection

samples, as defined in Inspection Procedure 71111.19.

b. Findings

No findings were identified.

1R22 Surveillance Testing (71111.22)

a. Inspection Scope

The inspectors observed six risk-significant surveillance tests and reviewed test results

to verify that these tests adequately demonstrated that the structures, systems, and

components were capable of performing their safety functions:

In-service tests:

• April 27, 2014, turbine-driven auxiliary feedwater pump valve inservice tests

Containment isolation valve surveillance tests:

• May 19, 2014, containment isolation damper test

Reactor coolant system leak detection tests:

• May 30, 2014, reactor coolant system inventory balance

Other surveillance tests:

• April 23, 2014, emergency exhaust system train A operability test

• May 27, 2014, motor-driven auxiliary feedwater pump train B test

• June 9, 2014, safety injection pump train A test

The inspectors verified that these tests met technical specification requirements, that the

licensee performed the tests in accordance with their procedures, and that the results of

the test satisfied appropriate acceptance criteria. The inspectors verified that the

licensee restored the operability of the affected structures, systems, and components

following testing.

These activities constitute completion of six surveillance testing inspection samples, as

defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

- 12 -

Cornerstone: Emergency Preparedness

1EP2 Alert and Notification System Evaluation (71114.02)

a. Inspection Scope

The inspectors verified the adequacy of the licensees methods for testing the primary

and backup alert and notification system. The inspectors also reviewed the licensees

program for identifying emergency planning zone locations requiring tone alert radios

and for distributing the radios, and reviewed audits of distribution records. The

inspectors interviewed licensee personnel responsible for the maintenance of the

primary and backup alert and notification system and reviewed a sample of corrective

action system reports written for alert and notification system problems. The inspectors

compared the licensees alert and notification system testing program with criteria in

NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency

Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1;

FEMA Report REP-10, Guide for the Evaluation of Alert and Notification Systems for

Nuclear Power Plants; and the licensees current FEMA-approved alert and notification

system design report, Callaway Plant, Alert and Notification System Design Report,

dated January 2013. The inspectors also observed the licensee and offsite authorities

jointly conduct a scheduled weekly siren system test on April 22, 2014.

These activities constituted completion of one alert and notification system evaluation

sample as defined in Inspection Procedure 71114.02.

b. Findings

No findings were identified.

1EP3 Emergency Response Organization Staffing and Augmentation System (71114.03)

a. Inspection Scope

The inspectors verified the licensees emergency response organization on-shift and

augmentation staffing levels were in accordance with the licensees emergency plan

commitments. The inspectors reviewed documentation and discussed with licensee staff

the operability of primary and backup systems for augmenting the on-shift emergency

response staff to verify the adequacy of the licensees methods for staffing emergency

response facilities, including the licensees ability to staff pre-planned alternate facilities.

The inspectors also reviewed records of emergency response organization

augmentation tests and events to determine whether the licensee had maintained a

capability to staff emergency response facilities within emergency plan timeliness

commitments.

These activities constitute completion of one emergency response organization staffing

and augmentation testing sample as defined in Inspection Procedure 71114.03.

b. Findings

No findings were identified.

- 13 -

1EP4 Emergency Action Level and Emergency Plan Changes (71114.04)

a. Inspection Scope

The inspectors performed an on-site review of the Callaway Plant Radiological

Emergency Response Plan, Revision 44, implemented April 9, 2014. This revision:

• Assigned some of the duties of the Emergency Duty Officer to the Emergency

Coordinator, Technical Support Center (TSC)

• Changed the response time goal for activating the on-shift emergency response

organization staff from 15 minutes to immediate

This revision was compared to the previous revision, to the criteria of NUREG-0654,

Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and

Preparedness in Support of Nuclear Power Plants, Revision 1, and to the standards in

10 CFR 50.47(b) to determine if the revision adequately implemented the requirements

of 10 CFR 50.54(q)(3) and 50.54(q)(4). This review was not documented in a safety

evaluation report and did not constitute approval of licensee-generated changes;

therefore, this revision is subject to future inspection.

These activities constitute completion of one emergency action level and emergency

plan changes sample as defined in Inspection Procedure 71114.04.

b. Findings

No findings were identified.

1EP5 Maintenance of Emergency Preparedness (71114.05)

a. Inspection Scope

The inspectors reviewed the following for the period October 2012 through April 2014:

• After-action reports for emergency classifications and events

• After-action evaluation reports for licensee drills and exercises

• Independent audits and surveillances of the licensees emergency preparedness

program

• Self-assessments of the emergency preparedness program conducted by the

licensee

• Licensee evaluations of changes made to the emergency plan and emergency

plan implementing procedures

• Drill and exercise performance issues entered into the licensees corrective

action program

• Emergency preparedness program issues entered into the licensees corrective

action program

- 14 -

• Emergency response organization and emergency planner training records

• Maintenance records for equipment supporting the emergency preparedness

program

• Evaluations of the effect of changes to the emergency planning zone population

The inspectors reviewed summaries of 334 corrective action program reports associated

with emergency preparedness and selected 30 to review against program requirements

to determine the licensees ability to identify, evaluate, and correct problems in

accordance with Planning Standard 10 CFR 50.47(b)(14) and 10 CFR Part 50,

Appendix E, IV.F. The inspectors verified that the licensee accurately and appropriately

identified and corrected emergency preparedness weaknesses during critiques and

assessments.

The inspectors reviewed summaries of 70 licensee evaluations of the impact of changes

to the emergency plan and implementing procedures, and selected 12 to review against

program requirements to determine the licensees ability to identify reductions in the

effectiveness of the emergency plan in accordance with the requirements of

10 CFR 50.54(q)(3) and 50.54(q)(4). The inspectors verified that evaluations of

proposed changes to the licensee emergency plan appropriately identified the impact of

the changes prior to being implemented.

The inspectors toured the emergency response facility, the alternate TSC, and the

alternate operations support center to determine whether the licensee had adequately

implemented alternate emergency response facilities in accordance with the

requirements of 10 CFR Part 50, Appendix E, IV.E(8)(d).

These activities constitute completion of one sample of the maintenance of the

licensees emergency preparedness program as defined in Inspection

Procedure 71114.05.

b. Findings

No findings were identified.

1EP6 Drill Evaluation (71114.06)

Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors observed an emergency preparedness drill on May 8, 2014, to verify the

adequacy and capability of the licensees assessment of drill performance. The

inspectors reviewed the drill scenario, observed the drill from the TSC, and attended the

post-drill critique. The inspectors verified that the licensees emergency classifications,

off-site notifications, and protective action recommendations were appropriate and

timely. The inspectors verified that any emergency preparedness weaknesses were

appropriately identified by the licensee in the post-drill critique and entered into the

corrective action program for resolution.

- 15 -

These activities constitute completion of one emergency preparedness drill observation

sample, as defined in Inspection Procedure 71114.06-05.

b. Findings

No findings were identified.

4. OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency

Preparedness, Public Radiation Safety, Occupational Radiation Safety, and

Security

4OA1 Performance Indicator Verification (71151)

.1 Safety System Functional Failures (MS05)

a. Inspection Scope

For the period of second quarter 2013 through first quarter 2014, the inspectors

reviewed licensee event reports, Maintenance Rule evaluations, and other records that

could indicate whether safety system functional failures had occurred. The inspectors

used definitions and guidance contained in Nuclear Energy Institute Document 99-02,

Regulatory Assessment Performance Indicator Guideline, Revision 7, and

NUREG-1022, Event Reporting Guidelines: 10 CFR 50.72 and 50.73, Revision 3, to

determine the accuracy of the data reported.

These activities constituted verification of the safety system functional failures

performance indicator, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.2 Mitigating Systems Performance Index: Heat Removal Systems (MS08)

a. Inspection Scope

The inspectors reviewed the licensees mitigating system performance index data for

the period of second quarter 2013 through first quarter 2014 to verify the accuracy and

completeness of the reported data. The inspectors used definitions and guidance

contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment

Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported

data.

These activities constituted verification of the mitigating system performance index for

heat removal systems, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

- 16 -

.3 Reactor Coolant System Identified Leakage (BI02)

a. Inspection Scope

The inspectors reviewed the licensees records of reactor coolant system (RCS)

identified leakage for the period of second quarter 2013 through first quarter 2014 to

verify the accuracy and completeness of the reported data. The inspectors observed the

performance of Procedure OSP-BB-00009, RCS Inventory Balance, on May 30, 2014.

The inspectors used definitions and guidance contained in Nuclear Energy Institute

Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7,

to determine the accuracy of the reported data.

These activities constituted verification of the reactor coolant system leakage

performance indicator, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.4 Drill/Exercise Performance (EP01)

a. Inspection Scope

The inspectors reviewed the licensees emergency plan implementations, evaluated

exercises, and selected drill and training evolutions that occurred between the third

quarter 2013 and the first quarter 2014 to verify the accuracy of the licensees data for

classification, notification, and protective action recommendation opportunities. The

inspectors reviewed a sample of the licensees completed classifications, notifications,

and protective action recommendations to verify their timeliness and accuracy. The

inspectors used definitions and guidance contained in Nuclear Energy Institute

Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7,

to determine the accuracy of the data reported.

These activities constituted verification of the drill/exercise performance indicator as

defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.5 Emergency Response Organization Drill Participation (EP02)

a. Inspection Scope

The inspectors reviewed the licensees records for participation in drill and training

evolutions between the third quarter 2013 and the first quarter 2014 to verify the

accuracy of the licensees data for drill participation opportunities. The inspectors

verified that all members of the licensees emergency response organization in the

identified key positions had been counted in the reported performance indicator data.

The inspectors reviewed the licensees basis for reporting the percentage of emergency

response organization members who participated in a drill. The inspectors reviewed drill

attendance records and verified a sample of those reported as participating. The

- 17 -

inspectors used definitions and guidance contained in Nuclear Energy Institute

Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7,

to determine the accuracy of the data reported.

These activities constituted verification of the emergency response organization drill

participation performance indicator as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.6 Alert and Notification System Reliability (EP03)

a. Inspection Scope

The inspectors reviewed licensee and offsite agency records of alert and notification

system tests conducted between the third quarter 2013 and the first quarter 2014 to

verify the accuracy of the licensees data for siren system testing opportunities. The

inspectors reviewed procedural guidance on assessing alert and notification system

opportunities and the results of periodic alert and notification system operability tests.

The inspectors used definitions and guidance contained in Nuclear Energy Institute

Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7,

to determine the accuracy of the data reported.

These activities constituted verification of the alert and notification system reliability

performance indicator as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution (71152)

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items

entered into the licensees corrective action program and periodically attended the

licensees condition report screening meetings. The inspectors verified that licensee

personnel were identifying problems at an appropriate threshold and entering these

problems into the corrective action program for resolution. The inspectors verified that

the licensee developed and implemented corrective actions commensurate with the

significance of the problems identified. The inspectors also reviewed the licensees

problem identification and resolution activities during the performance of the other

inspection activities documented in this report.

b. Findings

No findings were identified.

- 18 -

.2 Semiannual Trend Review

a. Inspection Scope

To verify that the licensee was taking corrective actions to address identified adverse

trends that might indicate the existence of a more significant safety issue, the inspectors

reviewed corrective action program documentation associated with the following

licensee-identified trends:

• Increased failure rate for hydramotors

Also, the inspectors identified the following trends that might indicate the existence of a

more significant safety issue and reviewed the licensees response to them:

• Inconsistent use of peer-checking human performance tools in the control room

• Increasing number of transient combustible permit issues

These activities constitute completion of one semiannual trend review sample, as

defined in Inspection Procedure 71152.

b. Observations and Assessments

The inspectors review of the trends identified above produced the following observations

and assessments:

The inspectors reviewed the licensees corrective action program, performance

indicators, system health reports, and other documentation to identify trends that might

indicate the existence of a more significant safety issue. The inspectors verified that the

licensee was taking corrective actions to address identified adverse trends.

While completing this trend review, the inspectors did note the following negative trends:

inconsistent use of peer-checking human performance tools in the control room,

technical specification application knowledge deficiencies, hydramotor failures, and an

increasing number of transient combustible permit issues. The licensee was aware of

these issues and has entered them into their corrective action program.

The inspectors did not review any cross-cutting theme because no cross-cutting theme

exists at the site.

c. Findings

No findings were identified.

.3 Annual Follow-up of Selected Issues

a. Inspection Scope

The inspectors selected one issue for an in-depth follow-up:

- 19 -

• On March 30, 2014, Callaway Action Request 201401530 identified that the

nuclear oversight group is not fully effective in driving station performance. This

issue was identified by the offsite nuclear safety review board.

The inspectors selected this issue because a lack of response to issues identified by the

internal nuclear oversight group can be an indicator of station performance. The

inspectors assessed the licensees problem statement, cause analyses, and extent of

condition review. The inspectors interviewed several members of the nuclear oversight

group and station line management. The inspectors determined that there are

departments at the station that are less receptive to comments from the nuclear

oversight group than others. The inspectors also determined that the nuclear oversight

group was not always clear when conveying their concerns. The inspectors concluded

that the completed and planned corrective actions were adequate to address the issue.

These activities constitute completion of one annual follow-up sample as defined in

Inspection Procedure 71152.

b. Findings

No findings were identified.

4OA5 Other Activities

.1 (Closed) Temporary Instruction 2515/182: Review of the Industry Initiative to Control

Degradation of Underground Piping and Tanks

a. Inspection Scope

Leakage from buried and underground pipes has resulted in groundwater contamination

incidents with associated heightened NRC and public interest. The industry issued a

guidance document, Nuclear Energy Institute 09-14, Guideline for the Management of

Buried Piping Integrity, (ADAMS Accession No. ML1030901420) to describe the goals

and required actions (commitments made by the licensee) resulting from this

underground piping and tank initiative. On December 31, 2010, Nuclear Energy Institute

issued Revision 1 to Nuclear Energy Institute 09-14, Guidance for the Management of

Underground Piping and Tank Integrity, (ADAMS Accession No. ML110700122) with an

expanded scope of components which included underground piping that was not in

direct contact with the soil and underground tanks. On November 17, 2011, the NRC

issued Temporary Instruction 2515/182, Review of the Industry Initiative to Control

Degradation of Underground Piping and Tanks, to gather information related to the

industrys implementation of this initiative. The licensees buried piping and underground

piping and tanks program was inspected in accordance with paragraph 03.02a of the

temporary instruction and it was confirmed that activities which correspond to completion

dates specified in the program which have passed since the Phase 1 inspection have

been completed.

- 20 -

Additionally, the licensees buried piping and underground piping and tanks program was

inspected in accordance with paragraph 03.02.b of the temporary instruction and

responses to specific questions were submitted to the NRC headquarters staff. Based

upon the scope of the review described above, Temporary Instruction 2515/182 was

completed.

b. Findings

Introduction. Inspectors identified a finding of very low safety significance (Green) and

associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions,

Procedures, and Drawings, for the licensees failure to perform an adequate extent of

condition assessment for a Significance Level 3 adverse condition in accordance with

Callaways corrective action program. While performing an evaluation of pitting

corrosion identified on buried refueling water storage piping, the licensee failed to

provide an adequate technical justification for not expanding the scope of their review

beyond the specific piping when pitting corrosion was identified in the original sample

selection.

Description. In April 2013, the licensee performed an excavation and inspection of

several buried lines near the refueling water storage tank as part of the industry initiative

to control the degradation of buried piping and tanks. Among the buried lines inspected

were a 24-inch diameter supply line from the refueling water storage tank to emergency

core cooling system suction and a 4-inch diameter return line. Both runs of buried pipe

are type 304 stainless steel. Both lines were discovered to have pitting corrosion in the

heat-affected zones of butt-welded piping connections. The 4-inch return line had pitting

around four welds that encompassed the circumference of the pipe within the heat-

affected zones. The safety-related 24-inch supply line had fewer, but deeper pits in the

heat-affected zones of one weld. A subsequent dye penetrant test of these pits

identified a small crack in one pit. Analysis was performed to demonstrate effective wall

thickness of both pipes in the area affected by the pitting and the safety-related 24-inch

line was repaired under an ASME Section XI repair package.

The licensee performed a cause determination for the pitting in both pipes as specified in

Procedure APA-ZZ-00500, Appendix 14, Adverse Condition - Significance Level 3.

The licensee determined the cause was pitting attack accelerated by sensitization and

environmental conditions conducive to corrosion. The licensee concluded that

sensitization, which is likely the result of a failure to properly maintain interpass

temperature between weld passes, reduced the effectiveness of the passive oxide layer

in the stainless steel which, when combined with an electrolytically conducive

environment, left the piping vulnerable to pitting.

Licensee Procedure APA-ZZ-00500, Appendix 14, Adverse Condition - Significance

Level 3, required the reviewer to conduct an extent of condition review to identify other

potentially susceptible systems or components. The licensee concluded, based on the

extent of condition review for this issue, that the environmental conditions for these pipes

were unique due to poor soil drainage and specifically stated that the extent of condition

would be limited to the visually inspected areas.

- 21 -

The inspectors reviewed the cause evaluation and determined that the licensee

essentially failed to consider any potentially susceptible locations (adjacent to welds) in

the additional 50 feet of buried piping for each of these piping runs. Although welding

was implicated as a contributing factor in the cause evaluation, the licensee made no

effort to understand the extent to which past welding practices could have impacted

other portions of this same piping.

During the same approximate timeframe, the licensee performed guided wave testing of

the additional buried portion of the subject piping; however, the results of this testing

were not utilized in the cause or extent of condition evaluation. The guided wave testing

identified six minor, one medium, and one anomalous indication on the 24-inch piping.

The licensee also obtained soil samples as part of the excavation, but performed no

technical analysis identifying uniquely corrosion-conducive conditions in the immediate

area or ruled out the possibility of such conditions in adjacent areas.

The lack of an adequate technical justification for limiting the extent of condition to only

the inspected piping is not consistent with licensee guidance of performing an extent of

condition review and constitutes a performance deficiency. Specifically, licensee

Procedure APA-ZZ-00500, Appendix 14, Adverse Condition - Significance Level 3,

step 4.2.4, requires that an extent of condition review be performed which determines

the population of components or systems that have the potential to exhibit the same

undesired condition as the item being investigated.

Analysis. The failure to perform an adequate extent of condition review of the pitting of

the buried 24-inch refueling water storage tank to emergency core cooling system supply

line in accordance with their procedure was a performance deficiency. The performance

deficiency is more than minor and therefore a finding because, if left uncorrected, it has

the potential to lead to a more significant safety concern if other welds on this same pipe

render it susceptible to pitting corrosion in the weld heat-affected zones. The finding

affects the Mitigating System Cornerstone because the performance deficiency is related

to the emergency core cooling systems ability to conduct short-term decay heat

removal.

This finding was assessed using Inspection Manual Chapter 0609, Appendix A,

Exhibit 2, Mitigating Systems Screening Questions, and was determined to be of very

low safety significance because the finding is not a design or qualification deficiency; did

not result in the loss of operability or functionality of a single train for greater than the

technical specification allowed outage time; and did not represent an actual loss of

safety function for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This finding has a cross-cutting aspect in the

conservative bias component of the human performance cross-cutting area because the

licensee did not use conservative decision-making practices that emphasize prudent

choices over those that are simply allowable. Specifically, rather than expanding the

scope of the extent of condition to include other sections of the affected piping that could

have the same susceptibility to pitting due to poor welding practices, personnel limited

the scope of their review to what they observed [H.14].

Enforcement. Title 10 of the Code of Federal Regulations, Part 50, Appendix B,

Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities

affecting quality shall be accomplished in accordance with procedures.

Procedure APA-ZZ -00500, Appendix 14, Adverse Condition - Significance Level 3,

- 22 -

requires licensee personnel to conduct an extent of condition review that identifies

whether the potential exists for the problem being evaluated to cause further damage to

the structures, systems, or components in question. Contrary to the above, between

April and July 2013, the licensee did not accomplish activities affecting quality in

accordance with procedures. Specifically, licensee personnel did not evaluate the

possibility of further damage to the borated refueling water storage piping caused by

increased corrosion susceptibility as the result of improper welding practices, nor did

they eliminate the possibility that the environment conducive to corrosion could occur in

other locations. Because this finding is of very low safety significance and was entered

into the corrective action program as Callaway Action Request 201402168, this violation

is being treated as a non-cited violation, consistent with Section 2.3.2.a. of the NRC

Enforcement Policy: NCV 05000483/2014003-02 Inadequate Extent of Condition

Review.

.2 (Closed) Unresolved Item 05000483/2013005-01, Solid State Protection System

Modifications

During the fourth quarter of the 2013 inspection cycle, inspectors identified an

unresolved item associated with the implementation of the licensees process to comply

with 10 CFR 50.59 for a digital modification of the solid state protection system (SSPS)

logic and control boards. The SSPS logic and control boards provide the coincidence

logic to produce actuation signals for operation of the reactor protection system and the

engineered safety features actuation systems. Modification Package 10-0053, SSPS

Printed Circuit Board Replacement, Version 000.2, evaluated a digital modification to

the existing SSPS logic and control boards. This modification replaced existing obsolete

printed circuit boards using fixed logic devices (i.e., transistor-transistor logic) with

replacement boards using complex programmable logic devices (CPLD) supplied by

Westinghouse.

The inspectors reviewed the 10 CFR 50.59 evaluation and the Westinghouse supporting

information for the replacement cards. The inspectors identified various issues of

concern associated with the design, testing, and operation of the replacement circuit

boards, that had the possibility of creating a malfunction of the SSPS with a different

result as described in the updated final safety analysis report. The inspectors specific

issues of concern were:

• The 10 CFR 50.59 evaluation did not contain sufficient information to exclude the

data file from the definition of Base Software and the associated design

considerations in Nuclear Energy Institute 01-01, Guideline on Licensing Digital

Upgrades.

• Second party commercial vendors were involved in the manufacturing of the CPLDs

as well as the development of the data file software. The inspectors found that

there was not sufficient information in the 10 CFR 50.59 evaluation and supporting

vendor information to determine the level of quality assurance placed into the

development of the CPLDs to ensure reliable operation of this logic device.

Furthermore, licensee discussions with Westinghouse confirmed that the second

party commercial vendors were not qualified to 10 CFR Part 50, Appendix B, Quality

Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.

- 23 -

• The testing performed by the vendor for the development of the CPLDs only covered

the combinations of inputs and outputs (hardware functional testing) required for the

design function of the SSPS. However, the 50.59 evaluation and supporting vendor

information did not contain adequate information to determine if the testing

performed by the vendor was sufficient to cover other possible sequence of device

states due to the relative complexity of the CPLDs operation. This would include

software-induced states associated with the CPLDs themselves and the embedded

data file, which could result in malfunctions of the SSPS.

Following the issuance of the unresolved item, the inspectors reviewed additional

Westinghouse topical and test reports which supported the licensees 10 CFR 50.59

safety evaluation conclusion that a license amendment was not necessary for this digital

upgrade. The inspection results are as follows:

• The inspectors determined that the licensees modification package correctly

considered the internal CPLDs software configuration as an adverse change to the

design function of the SSPS; therefore, the licensee correctly completed the

10 CFR 50.59 safety evaluation for the change.

• In consultation with the Office of Nuclear Reactor Regulation, Instrumentation and

Controls Branch, the inspectors determined Westinghouse audited the manufacturer

under the Westinghouse 10 CFR Part 50, Appendix B quality assurance program.

• The inspectors determined that the testing was beyond the licensees normal

functional testing which only manipulated CPLD inputs which were necessary to

meet the safety function of SSPS. The test procedure manipulated all inputs

available to the CPLD to ensure the correct device output was correct.

Using the guidance contained in NRC Regulatory Guide 1.187, Guidance for

Implementation of 10 CFR 50.59, Changes, Tests, and Experiments, and NRC

Regulatory Issue Summary 2002-22, Use of EPRI/NEI Joint Task Force Report,

Guideline on Licensing Digital Upgrades, the inspectors did not identify a violation of

NRC requirements. Therefore, Unresolved Item URI 05000483/2013005-01, Solid

State Protection System Modifications, was closed.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On February 12, 2014, the inspector conducted a debrief of the review of the licensees buried

piping program. After additional in-office review, the inspector conducted an exit meeting with

Mr. G. Kramer, Director of Engineering Programs, on March 28, 2014. The licensee

acknowledged the issues presented. The inspector verified that no proprietary information was

reviewed.

On April 24, 2014, the inspector presented the results of the onsite inspection of the licensees

emergency preparedness program to Mr. D. Neterer, Vice President, Engineering, and other

members of the licensee staff. The licensee acknowledged the issues presented. The licensee

confirmed that any proprietary information reviewed by the inspectors had been returned or

destroyed.

- 24 -

On July 1, 2014, the inspectors presented the inspection results to Mr. F. Diya, Senior Vice

President and Chief Nuclear Officer, and other members of the licensee staff. The licensee

acknowledged the issues presented. The licensee confirmed that any proprietary information

reviewed by the inspectors had been returned or destroyed.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (Green) was identified by the licensee and

is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for

being dispositioned as a non-cited violation.

• Title 10 of the Code of Federal Regulations, Part 50.54(q)(2), requires in part, that a

reactor licensee follow an emergency plan meeting the requirements of 10 CFR Part 50,

Appendix E, and the 10 CFR 50.47(b) planning standards. Contrary to the above, on

July 26, 2013, Callaway Plant failed to follow an emergency plan meeting the

requirements of the 10 CFR 50.47(b) planning standards. Specifically, the licensee

failed to implement an emergency action level scheme meeting the requirements of

10 CFR 50.47(b)(4) during a plant event. The licensee classified a Notification of

Unusual Event on July 26, 2013, based on emergency action level HU2.1, Non-hostile

initiated fire not extinguished within 15 minutes of Control Room notification or valid

Control Room alarm. The licensee subsequently determined that the emergency action

level did not apply because the fire was not in a location listed on Table H-2 as required

by the technical basis document. The finding was more than minor because it affected

the Emergency Preparedness Cornerstone objective and the emergency response

organization performance cornerstone attribute. The finding was evaluated using

Manual Chapter 0609, Appendix B, Emergency Preparedness Significance

Determination Process, Attachment 2, Failure to Implement, and was determined to be

of very low safety significance (Green) because the classification was a Notification of

Unusual Event. The issue was entered into the licensees corrective action program as

Callaway Action Requests 201305943 and 201305944.

- 25 -

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

M. Daly, Supervisor, Corrective Action Program

F. Diya, Senior Vice President and Chief Nuclear Officer

R. Eickelman, Supervisor, Operations

T. Elwood, Supervising Engineer, Regulatory Affairs/Licensing

J. Geyer, Director, Nuclear Oversight

L. Graessle, Senior Director, Operations Support

J. Imhoff, System Engineer, NSSS Systems

J. Kovar, Engineer, Regulatory Affairs/Licensing

G. Kramer, Director, Engineering Programs

S. Maglio, Manager, Regulatory Affairs

P. McKenna, Assistant Manager, Protective Services (Emergency Preparedness)

J. McLaughlin, System Engineer, NSSS Systems

S. Petzel, Engineer, Regulatory Affairs/Licensing

D. Neterer, Vice President, Nuclear Operations

C. Smith, Manager, Radiation Protection

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000483/2014003-01 FIN Plastic Shipping Plug in Rosemount Transmitter (Section 1R15)05000483/2014003-02 NCV Inadequate Extent of Condition Review (Section 4OA5)

Closed

2515/182 TI Review of the Industry Initiative to Control Degradation of

Underground Piping and Tanks (Section 4OA5)05000483/2013005-01 URI Solid State Protection System Modifications (Section 4OA5)

LIST OF DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

Procedures

Number Title Revision

AUE-ADM-2222 Communication and Coordination 0

AUE-ADM-2223 Disturbance Reporting 0

AUE-ADM-2227 Reliability Coordination - Responsibility and Authorities 0

Attachment 1

Procedures

Number Title Revision

DTI-E-00009 Using Safety Monitor 3

DP-ZZ-01129 Callaway Energy Center Risk Assessment 40

PDP-ZZ-00027 Summer Reliability Program 4

ODP-ZZ-00002, Equipment Status Control 72

Attachment 4

OSP-NB-00001 Class 1E Electrical Source Verification 38

OSP-NE-00003 Technical Specification Actions - A.C. Sources 26

OTO-MA-00008 Rapid Load Reduction 29

OTO-ZZ-00012 Severe Weather 27

Callaway Action Requests

201305943 201308354 201400743 201402651 201207599

Section 1R04: Equipment Alignment

Procedures

Number Title Revision

OTN-GK-00001 Control Building Heating, Ventilation and Air Conditioning 42

System

OTN-GK-00001, Control Building Heating, Ventilation and Air Conditioning 13

Checklist 1 System Electrical Equipment Lineup

OTN-GK-00001, Control Building Heating, Ventilation and Air Conditioning 15

Checklist 2 System Normal Valve Lineup by Compartment

OTS-ZZ-00007 Plant Cold Weather 28

OTN-EJ-00001 Residual Heat Removal System 27

OTN-EJ-00001, Residual Heat Removal System - B RHR Electrical 19

Checklist 2 Equipment Standby Safety Injection Lineup

OTN-EJ-00001, Residual Heat Removal System - B RHR System Standby 20

Checklist 4 Safety Injection Valve Lineup (Includes Components on SIS

Hot Leg Recirc)

OTN-EJ-00001, Residual Heat Removal System - B RHR Train Main 19

Checklist 8 Control Board Standby Safety Injection Lineup

OTN-AL-00001 Auxiliary Feedwater System 32

OTN-AL-00001, Auxiliary Feedwater Valve Alignment 21

Checklist 1

OTN-GG-00001 Fuel Building HVAC System 28

A1-2

Procedures

Number Title Revision

OTN-GG-00001, Fuel Handling Building HVAC System Valve and Damper 15

Checklist 1 Lineup

OTN-GG-00001, Fuel Handling Building HVAC System Breaker Lineup 13

Checklist 2

OTN-GG-00001, Fuel Handling Building HVAC System Switch Lineup 13

Checklist 3

Drawings

Number Title Revision

M-22EJ01 Piping & Instrumentation Diagram - Residual Heat Removal 59

System

M-22GK01 Piping & Instrumentation Diagram Control Building Heating, 20

Ventilation and Air Conditioning

M-22GK02 Piping & Instrumentation Diagram Control Building Heating, 19

Ventilation and Air Conditioning

M-22GK03 Piping & Instrumentation Diagram Control Building Heating, 23

Ventilation and Air Conditioning

M-22GK04 Piping & Instrumentation Diagram Control Building Heating, 19

Ventilation and Air Conditioning

M-22AL01 Piping & Instrumentation Diagram, Auxiliary Feedwater 43

System

Callaway Action Requests

201300894 201402724 201403015 201401549

Job

14000300

Miscellaneous

Number Title Date

2013002 Vibration Induced Wear on SGK04A/B and SGK05A/B has May 26, 2013

Caused Unplanned Out-of-Service Time

A1-3

Section 1R05: Fire Protection

Procedures

Number Title Revision

Fire Preplan Manual 37

FPP-ZZ-00001, Pre-Plan/Fire Area #A-2A, Auxiliary Building, 1967 24

Attachment 2 Elevation

FPP-ZZ-00004, Pre-Plan/Fire Area #C-13, Control Building and 17

Attachment 17 Communications Corridor, 2016 Elevation

FPP-ZZ-00004, Pre-Plan/Fire Area #C-21, Control Building and 17

Attachment 26 Communications Corridor, 2032 Elevation

FPP-ZZ-00004, Pre-Plan/Fire Area #C-27, Control Building and 17

Attachment 32 Communications Corridor, 2047 Elevation

FPP-ZZ-00004, Pre-Plan/Fire Area #C-22, Control Building and 17

Attachment 43 Communications Corridor, 2032 Elevation

FPP-ZZ-00007, Pre-Plan/Fire Area #T-14, Transformers (West of Turbine 13

Attachment 4 Building - In Yard) 2000

Drawings

Number Title Revision

A-2802 Fire Delineation - Floor Plan, Elevation 2000-0 12

A-2804 Fire Delineation - Floor Plan, Elevation 2047-6 25

Miscellaneous

Number Title Date

RFR 14421 Approval of ABC Fire Extinguishers on Carts July 2, 1997

Section 1R06: Flood Protection Measures

Drawing

Number Title Revision

M-2G051 Equipment Locations - Control & Diesel Generator 39

Buildings and Communication Corridor Plan

Elevation 2000-0 and 2016-0

Callaway Action Requests

201401795 201203302 201403604 201403841

A1-4

Job

13514414

Miscellaneous

Number Title Date

RFR 018299A Use and Storage of Protective Mats October 7, 1997

Photos of Manhole MH01B December 12, 2013

Photos of Manhole MH01B June 5, 2014

Section 1R07: Heat Sink Performance

Jobs

09511826 09511945

Section 1R11: Licensed Operator Requalification Program

Procedures

Number Title Revision

ODP-ZZ-00001 Operations Department - Code of Conduct 89

OSP-AL-V001C Turbine Driven Auxiliary Feedwater Valve Inservice 53

Test

OTG-ZZ-00004, Reactor Control During Power Operations 1

Addendum 1

OTN-BG-00002 Reactor Makeup Control and Boron Thermal 44

Regeneration System

Miscellaneous

Number Title Date

CA2698 Procedure Controlled Temporary Modification April 27, 2014

Approval, Installation and Removal [OSP-AL-V001C

Jumper Hoses]

T61.0810.8 Dynamic Simulator Exam Scenario, DS-13 February 25, 2014

T61.0810.8 Dynamic Simulator Exam Scenario, DS-19 February 26, 2014

A1-5

Section 1R12: Maintenance Effectiveness

Procedures

Number Title Revision

APA-ZZ-00500 Operability and Functionality Determinations 21

Appendix 1

APA-ZZ-00500 Maintenance Rule (MR) 16

Appendix 5

EDP-ZZ-01114 Motor Operated Valve Program Guide 26

Drawing

Number Title Revision

E-23EF02 Essential Service Water to Service Water System 17

Isolation Valve EFHV23

Callaway Action Requests

201301108 201400933 201307915 201400092 201401116

Jobs

14000573 05510322 11000253 13006167 13509117

Miscellaneous

Number Title Revision/Date

M-GL-390 Callaway Auxiliary Building Essential Service Water- 1

Supplied Heating, Ventilation and Air Conditioning

OOA-SA-C066X Engineered Safety Feature (ESF) Status Panel 14

SA066X Alarm Information

OOA-SA-C066Y Engineered Safety Feature Status (ESF) Panel 15

SA066Y Alarm Information

RFR 16987 Jumper Close Torque Switch on Butterfly Motor February 13, 2007

Operated Valves with Close Safety Function

Section 1R13: Maintenance Risk Assessment and Emergent Work Controls

Procedures

Number Title Revision

EDP-ZZ-01129 Callaway Energy Center Risk Assessment 39

ODP-ZZ-00002 Equipment Status Control 74

A1-6

Procedures

Number Title Revision

ODP-ZZ-00002 Risk Management Actions for Planned Risk 8

Appendix 2 Significant Activities

ODP-ZZ-00002 Door Postings for A Train ESW and/or Emergency 1

Appendix 2 CL 1 Diesel Generator being Out-of-Service

ODP-ZZ-00002 Door Postings for TDAFP (PAL02) being 1

Appendix 2 CL 5 Out-of-Service

OTN-GK-00001 Control Building Heating, Ventilation and Air 30

Conditioning System

Callaway Action Requests

201402036 201403004 201403463 201403474 201403486

201308995 201110202 201307763 201400020 201309694

Jobs

13512067 14501172 14501233 14501194 14002312

Miscellaneous

Number Title Date

MG 10-2001 Energy Management Guide for Selection and 2001

Use of Fixed Frequency Medium AC Squirrel-Cage

Polyphase Induction Motors

Section 1R15: Operability Evaluations

Procedures

Number Title Revision

MTE-ZZ-NG001 Leak Control, Recovery, and Recycling of Refrigerant 13

MTE-GK-QC001 Control Room and Class 1E Air Conditioning Unit 9

Charging

OTN-EN-00001 Containment Spray System 23

Callaway Action Requests

201011748 201101473 201203302 201208791 201401278

201401587 201401683 201401795 201403300 201403604

201403902

A1-7

Jobs

14000139 14504911 07511235

Miscellaneous

Number Title Revision

M-GG-404 Fuel Building Cooling Load and Equipment Selection 0

M-GG-404, Change in Fuel Building Roof R Value 0

Addendum 4

Section 1R19: Post-Maintenance Testing

Procedures

Number Title Revision

APA-ZZ-00340 Surveillance Program Administration 35

APA-ZZ-00340, Surveillance Frequency Control Program 0

Appendix 1

APA-ZZ-00340, Surveillance Frequency Control Program Surveillance 2

Appendix 4 Test Interval List

ESP-GG-03004 FGG02A In-Place Bypass Leakage Test 16

ETP-ZZ-03005 In-Place Bypass Leakage Testing of HEPA Filters 9

ETP-ZZ-03005, HEPA Filter Leak Test Results 9

Attacment1

MSE-GG-QG001 Emergency Exhaust System Flow Rates - A Train 14

OSP-GG-0001A A Train Emergency Exhaust System Operability Test 10

OSP-NE-0001A Standby Diesel Generator A Periodic Tests 55

OSP-EF-P001B Essential Service Water Train B Inservice Test 68

OSP-EF-0003B Train B Ultimate Heat Sink Cooling Tower Fans Test 9

OSP-EJ-P001A Residual Heat Removal Train A Inservice Test - Group A 55

Drawings

Number Title Revision

M-22GG01(Q) Piping and Instrumentation Diagram, Fuel Building HVAC 15

M-22GG02(Q) Piping and Instrumentation Diagram, Fuel Building HVAC 13

A1-8

Callaway Action Requests

201402064 201402066 201402086 201402101 201402113

201402761 201402775 201402810 201404106

Jobs

11504452 11508685 12511470 12511471 12511473

12512029 12513399 13512067 14001821

Miscellaneous

Number Title Revision

FSAR 6.5.1 Engineered Safety Feature Filter Systems OL-19

FSAR Table 6.5-1 ESF Filtration Systems Input Parameters To OL-13

Chapter 15.0 Accident Analysis

FSAR Table 9.4-6 Design Data For Fuel Building HVAC System OL-17

Components

Technical Emergency Exhaust System Amendment

Specification 3.7.13 Number 198

Section 1R22: Surveillance Testing

Procedures

Number Title Revision

OSP-BB-00009 Reactor Coolant System Inventory Balance 35

OSP-GG-0001A A Train Emergency Exhaust System Operability Test 10

OSP-AL-V001C Turbine Driven Auxiliary Feedwater Valve Inservice Test 53

OSP-GT-00005 Containment Isolation Dampers Operational Test 18

OSP-AL-P001B Motor Driven Auxiliary Feedwater Pump B Inservice Test - 57

Group A

OSP-EM-P001A Safety Injection train A Inservice Test - Group B 48

Drawings

Number Title Revision

M-22AL01 Piping and Instrumentation Diagram, Auxiliary Feedwater 43

System

M-22KA05 Piping and Instrumentation Diagram, Compressed Air 16

System

A1-9

Drawings

Number Title Revision

M-22GT01 Piping and Instrumentation Diagram, Containment Purge 26

Systems HVAC

Callaway Action Request

201402889

Jobs

14502916 14501153 14001902 14501883 14502261

14505240 14502660

Miscellaneous

Number Title Date

CA2698 Procedure Controlled Temporary Modification Approval, April 27, 2014

Installation and Removal

[OSP-AL-V001C Jumper Hoses]

CA2698 Procedure Controlled Temporary Modification Approval, April 27, 2014

Installation and Removal

[OSP-EM-P001A Temporary Gauges]

Section 1EP2: Alert and Notification System Testing

Procedures

Number Title Revision

KSP-ZZ-00008 Tone Alert Radios 4-5

KSP-ZZ-00110 Siren Alerting System Testing 10-11

Callaway Action Requests

201206488 201206544 201306554 201306560 201207337

201208462 201208644 201208970 201300045 201300495

201300598 201302644 201302797 201303103 201304143

201304533 201307744 201400415

Miscellaneous

Number Title Date

Letters of Agreement, Callaway Electric Cooperative January 9, 2014,

and January 8, 2013

A1-10

Miscellaneous

Number Title Date

Letters of Agreement, Three Rivers Electric January 9, 2014,

Cooperative and January 8, 2013

Letters of Agreement, Ameren Energy Delivery January 9, 2014,

and January 8, 2013

Letters of Agreement, Missouri School for the Deaf January 9, 2014,

and January 8, 2013

Callaway Plant, Alert and Notification System Design April 2011

Report

Callaway Plant, Alert and Notification System Design January 2013

Report

Siren System Maintenance Logs, 2013, 2014

Siren System Semi-Annual Preventative

Maintenance and Repair Checklists, 2013, 2014

12501700/500 Annual Tone Alert Radio Audit Surveillance March 19, 2013

13503075/500 Annual Tone Alert Radio Audit Surveillance March 17, 2014

12512992 Monthly Distribution of Tone Alert Radios December 6, 2012

13503580 Monthly Distribution of Tone Alert Radios March 29, 2013

13509332 Monthly Distribution of Tone Alert Radios August 1, 2013

13512726 Monthly Distribution of Tone Alert Radios November 1, 2013

14501115 Monthly Distribution of Tone Alert Radios February 1, 2014

14502119 Monthly Distribution of Tone Alert Radios March 4, 2014

Section 1EP3: Emergency Response Organization Staffing and Augmentation System

Procedures

Number Title Revision

EIP-ZZ-00200 Activation of the Callaway Plant Emergency Callout 16

System

EIP-ZZ-A0001 Emergency Response Organization 15

KSP-ZZ-00201 Emergency Augmentation Drill / Test 6

Callaway Action Requests

201206366 201207063 201208031 201208673 201304680

A1-11

Miscellaneous

Number Title Date

Emergency Notification System (Everbridge Proposal) June 6, 2012

12506726 ERO Augmentation Drill/Test, Augmentation Testing September 27, 2012

Results

12510457 ERO Augmentation Drill/Test, Augmentation Testing November 14, 2012

Results

12512288 ERO Augmentation Drill/Test, Augmentation Testing March 1, 2013

Results

13502338 ERO Augmentation Drill/Test, Augmentation Testing June 10, 2013

Results

13507493 ERO Augmentation Drill/Test, Augmentation Testing August 29, 2013

Results

13510470 ERO Augmentation Drill/Test, Augmentation Testing November 20, 2013

Results

13513640 ERO Augmentation Drill/Test, Augmentation Testing January 15, 2014

Results

Section 1EP4: Emergency Action Level and Emergency Plan Changes

Miscellaneous

Title Date

50.54(q) Evaluation for the Radiological Emergency March 25, 2014

Response Plan, Revision 44

Section 1EP5: Maintenance of Emergency Preparedness

Procedures

Number Title Revision

Callaway Radiological Emergency Response Plan 42, 43

APA-ZZ-00500 Corrective Action Program 60

APA-ZZ-00500, Screen Process Guidelines 19-20

Appendix 17

EIP-ZZ-00260 Event Closeout and Plant Recovery 25

EIP-ZZ-A0020 Maintaining Emergency Preparedness 28

GDP-ZZ-01810 Nuclear Safety Oversight Assessment Coverage 51

KDP-ZZ-00013 Emergency Response Facility and Equipment 11

Evaluation

A1-12

Procedures

Number Title Revision

KDP-ZZ-00013, Equipment Import to Emergency Response Matrix 0

Appendix 1

KDP-ZZ-00400 RERP Impact Evaluations and Changes 21

KSP-ZZ-00602 Verification of Emergency Instruction Postings 2

KDP-ZZ-02001 Drill and Exercise Program 14

Callaway Action Requests

201206556 201207063 201207686 201208519 201300598

201300896 201304389 201304521 201304664 201305116

201306031 201306221 201306237 201306493 201306552

201306640 201306649 201307252 201307316 201307457

201307458 201307697 201307875 201308282 201308781

201400836 201401069 201401110 201401558

Miscellaneous

Number Title Date

AP12-008 Nuclear Oversight Audit of Emergency Preparedness August 27, 2012

AP-13-007 Nuclear Oversight Audit of Emergency September 5, 2013

Preparedness

SP12-023 Functional Area Assessment Report, March 13, 2013

October 16 to 31, 2012

SP12-024 Functional Area Assessment Report, March 18, 2013

November 1 to 15, 2012

SP12-025 Functional Area Assessment Report, April 1, 2013

November 16 to 30, 2012

SP13-001 Functional Area Assessment Report, July 13, 2013

January 1 to 31, 2013

SP13-020 Functional Area Assessment Report, October 31, 2013

September 1 to 30, 2013

SP14-002 Functional Area Assessment Report, March 25, 2014

February 1 to 28, 2014

After-Action Report: Radiological Monitoring Drill September 6, 2012

After-Action Report: Certification Drill September 28, 2012

A1-13

Miscellaneous

Number Title Date

After-Action Report: ERO Minimum Staffing Drill,

Cycle 12-5

After-Action Report: Health Physics Drill October 25, 2012

After-Action Report: Shift Manager Drill November 1, 2012

After-Action Report: Contaminated Injured Worker November 8, 2012

Drill

After-Action Report: ERO Training Tabletop Drill February 2013

After-Action Report: Team 3 Drill December 4, 2012

After-Action Report: Teams 1 and 2 Turnover Drill March 5, 2013

After-Action Report: Notification of Unusual Event July 26, 2013,

After-Action Report: Team 3 Rehearsal Exercise August 13, 2013

After-Action Report: Team 3 Biennial Exercise September 24, 2013

After-Action Report: Rapid Responder Drills November to

December 2013

After-Action Report: Health Physics Drill March 13, 2014

After-Action Report: Team Drill March 13, 2014

After-Action Report: Table Top Drills January to

February 2014

12507720 Callaway Plant, 2013 Population Update Analysis May 29, 2013

50.54(q) Evaluation for EIP-ZZ-00102 May 15, 2013

50.54(q) Evaluation for EIP-ZZ-01211 July 10, 2013

50.54(q) Evaluation for EIP-ZZ-PR020 May 17, 2013

50.54(q) Evaluation for KDP-ZZ-02001 March 20, 2013

50.54(q) Evaluation for KSP-ZZ-00110 January 17, 2014

50.54(q) Evaluation for RERP September 13, 2013

50.54(q) Evaluation for Procedure E-1, Revision 15 October 3, 2013

50.54(q) Evaluation for EIP-ZZ-00240 and EIP-ZZ- July 22, 2013

C0010

50.54(q) Evaluation for EIP-ZZ-PR020 October 16, 2013

50.54(q) Evaluation for KDP-ZZ-00300 April 15, 2013

50.54(q) Evaluation for KDP-ZZ02002 July 16, 2013

50.54(q) Evaluation for OTO-SK-00003, Revision 5 October 3, 2013

A1-14

Miscellaneous

Number Title Date

201200168-04 Self-Assessment: EP Field Monitoring and E Team October 15, 2012

Dispatch

2013000022-12 Self-Assessment: EP Program Assessment and September 25, 2013

Exercise Readiness

2013000024-19 Self-Assessment: Emergency Response November 27, 2013

Organization Training

1150946/500 Emergency Instruction Posting Locations July 16, 2012

12507973/500 Emergency Instruction Posting Locations July 19, 2013

Section 1EP6: Drill Evaluation

Callaway Action Requests

201403185 201403200 201403220

Miscellaneous

Number Title Date

Emergency Preparedness Team Drill May 8, 2014

Section 4OA1: Performance Indicator Verification

Procedures

Number Title Revision

EIP-ZZ-00101 Classification of Emergencies 48-49

EIP-ZZ-00101, Emergency Action Level Classification Matrix 3

Addendum 1

EIP-ZZ-00101, Emergency Action Level Technical Basis Document 6-7-8

Addendum 2

EIP-ZZ-00102 Emergency Implementing Actions 53-54-55-56

EIP-ZZ-00201 Notifications 49-50

EIP-ZZ-00201, Control Room Notification Package 20-21

Addendum A

EIP-ZZ-00201, EOF Notification Package 21

Addendum C

EIP-ZZ-00212 Protective Action Recommendations 24-25

KDP-ZZ-02000 NRC Performance Indicator Data Collection 15

A1-15

Callaway Action Requests

201207949 201306537 201309521 201309528 201401110

Miscellaneous

Number Title Date

2Q13 to 1Q14 OSP-BB-00009 results May 28, 2014

CA2567 NRC Performance Indicator Transmittal Report July 3, 2013

CA2567 NRC Performance Indicator Transmittal Report October 21, 2013

CA2567 NRC Performance Indicator Transmittal Report January 9, 2013

CA2567 NRC Performance Indicator Transmittal Report April 9, 2013

MSPI Derivation Report, Heat Removal System June 2013

MSPI Derivation Report, Heat Removal System September 2013

MSPI Derivation Report, Heat Removal System December 2013

MSPI Derivation Report, Heat Removal System March 2014

Section 4OA2: Identification and Resolution of Problems

Procedures

Number Title Revision

APA-ZZ-00007 Nuclear Oversight Organization, Responsibility and 31

Conduct of Operations

GDP-ZZ-01810 Nuclear Oversight Assessment Coverage 52

GDP-ZZ-01810 Nuclear Oversight Assessment Coverage 53

GDP-ZZ-01810 Nuclear Oversight Assessment Coverage 54

GDP-ZZ-01820 Nuclear Oversight Functional Area Assessment 4

GDP-ZZ-01820 Nuclear Oversight Functional Area Assessment 5

GDP-ZZ-01820 Nuclear Oversight Functional Area Assessment 6

Callaway Action Requests

201401350 201402093 201403604 201400020 201403868

Miscellaneous

Number Title Revision

DTI-002 Desktop Instruction - Performance Assessment 14

A1-16

Miscellaneous

Number Title Revision

DTI-011 Desktop Instruction - Nuclear Oversight Department 27

- Statement of Vision, Mission, Goals, and

Expectations

DTI-016 Desktop Instruction - NOS Performance 14

Management

DTI-029 Desktop Instruction - Nuclear Oversight Audit & 41

Surveillance Guide

DTI-029 Desktop Instruction - Nuclear Oversight Audit & 42

Surveillance Guide

Section 4OA5: Other Activities

Procedures

Number Title Revision

APA-ZZ-00500 Corrective Action Program 57

EDP-ZZ-01011 Buried Pipe inspection Program 8

QCP-ZZ-05000 Liquid Penetrant Examination 23

QCP-ZZ-05019 Ultrasonic Thickness Measurement 13

13514548.505 CPRQH1001 Track Two Month Cathodic Protection

Rectifier Survey

12508427.500 Annual Cathodic Protection Survey 1

MSM-KJ-QT0001 10 Year Emergency Diesel Generator Fuel Oil 10

Storage Tank Cleaning

APA-ZZ-00500, Adverse Condition - Significance Level 3 15

Appendix 14

Callaway Action Requests

200608046 200909892 201009242 201108240 201110490

201204441 201303200 201303205 201304105 201307568

Work Orders

08514026 10006447 10513868 10514536 11502794

11505576 11511955 1152530 13003026 13510911

13510912 13511349 13511350

A1-17

Miscellaneous

Number Title Revision/Date

M-2G006 Site Interface Underground Piping Location Drawing August 12,1995

M-23BN01 Piping Isometric: Borated Refueling Water Storage June 3, 1981

System Auxiliary Building

BOP-PT-13-048 Liquid Penetrant Examination Report April 26, 2013

BOP-PT-13-047 Liquid Penetrant Examination Report May 2, 2013

5019-13-140 Ultrasonic Thickness Report April 26, 2013

BN-29 Minwall Determination of Various Buried Piping for

Refueling Outage 19

Various Laboratory Tests on Soil Samples July 2009 -

May 2013

10006447-500 As Found Buried Piping Inspection Form May 23, 2013

1200481.401 Refueling Outage 19 GWT Assessment on November 7, 2013

Refueling Water Storage Tank Piping

Buried Pipe Program Health Report Third Quarter October 15, 2013

2013

Buried Pipe Program Health Report Fourth Quarter January 15, 2014

2013

Self-Assessment of the Buried Pipe Inspection July 28, 2009

Program

Self-Assessment of the Buried Pipe Inspection September 16, 2011

Program

Buried Pipe Simple Self-Assessment October 28, 2013

1000062.401 Site Specific Risk Report: Callaway Nuclear Plant September 29, 2010

Condition Assessment Plan December 10, 2012

12000962 As Found Buried Piping Inspection Form June 21, 2012

5019-10-250 Ultrasonic Thickness Report May 5, 2010

5019-10-251 Ultrasonic Thickness Report May 5, 2010

5019-12-011 Ultrasonic Thickness Report June 25, 2012

12508427/500 Annual Cathodic Protection System Survey June 24, 2013

Cathodic Protection System Health Report January 30, 2014

Buried Piping Long Term Asset Management Plan May 2013

2-BN-C1-F004 Weld Control Record November 2, 1979

Hydrostatic Pneumatic Test Report March 13, 1982

A1-18

Miscellaneous

Number Title Revision/Date

Hydrostatic Pneumatic Test Report January 28, 1982

MP 10-0053 Solid State Protection System Printed Circuit Board 000.2

Replacement

Evaluation 13-02 50.59 Evaluation of Modification Package 10-0053 April 7, 2013

WNA-TR-02644- Solid State Protection System New Design Circuit 0

SCP Board Final Logic Test Report

0 Westinghouse Solid State Protection System Board 0

Replacement Licensing Summary Report

WCAP-16769-P Westinghouse Universal Logic Board Replacement 0

Summary Report

A1-19

Callaway SSPS Replacement Questions (05/13/2014)

1. As described in USAR Section 3.10, the SSPS was tested in accordance with the criteria

specified in IEEE 344-1975. However, the replacement CLPDs were tested using the

criteria defined in IEEE 344-1987. How were the differences in these IEEE standards

reconciled?

2. What are the differences between the testing criteria used to seismically qualify the

CPLDs and those used to seismically qualify the original SSPS?

3. Did Westinghouse use the same test inputs for the qualification of the CPLDs that were

specified in WCAP-7817 for the original seismic design of the SSPS?

4. How does the seismic response spectra, used by Westinghouse in the development of

the CLPDs, envelope the required design basis response spectra for the SSPS

cabinets?

Attachment 2