ML15096A094

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Notification of Inspection (NRC Inspection Report 05000483/2015003) and Request for Information
ML15096A094
Person / Time
Site: Callaway Ameren icon.png
Issue date: 04/06/2015
From: Vincent Gaddy
Operations Branch IV
To: Diya F
Union Electric Co
References
IR 2015003
Download: ML15096A094 (9)


See also: IR 05000483/2015003

Text

April 6, 2015

Mr. Fadi Diya, Senior Vice President

and Chief Nuclear Officer

Union Electric Company

P.O. Box 620

Fulton, MO 65251

SUBJECT:

CALLAWAY PLANT - NOTIFICATION OF INSPECTION (NRC INSPECTION

REPORT 05000483/2015003) AND REQUEST FOR INFORMATION

Dear Mr. Diya:

From June 15 through June 19, 2015, inspectors from the Nuclear Regulatory

Commissions (NRC) Region IV office will perform the baseline biennial requalification program

inspection at the Callaway Plant, using NRC Inspection Procedure 71111.11, Licensed

Operator Requalification Program and Licensed Operator Performance. Experience has

shown that this inspection is a resource intensive inspection, both for the NRC inspectors and

your staff. In order to minimize the impact to your on-site resources and to ensure a productive

inspection, we have enclosed a request for documents needed for this inspection. These

documents have been divided into three groups. The first group (Section A of the enclosure)

identifies information to be provided prior to the inspection to ensure that the inspectors are

adequately prepared. The second group (Section B of the enclosure) identifies the information

the inspectors will need upon arrival at the site. The third group (Section C of this enclosure)

identifies the items which are necessary to close out the inspection and are usually sent a few

weeks after the team has left the site. It is important that all of these documents are up to date

and complete in order to minimize the number of additional documents requested during the

preparation and/or the on-site portions of the inspection.

We have discussed the schedule for these inspection activities with your staff and understand

that our regulatory contact for this inspection will be Mr. Steve Petzel of your licensing

organization. Our inspection dates are subject to change based on your updated schedule of

examination activities. If there are any questions about this inspection or the material

requested, please contact the lead inspector Mr. Sean Hedger at (817) 200-1556

(Sean.Hedger@nrc.gov), Mr. Michael Kennard at (817) 200-1244 (Michael.Kennard@nrc.gov),

or Mr. Chris Cowdrey at (817) 200-1545 (Christian.Cowdrey@nrc.gov).

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E. LAMAR BLVD

ARLINGTON, TX 76011-4511

F. Diya

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This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget, control

number 3150-0018. The NRC may not conduct or sponsor, and a person is not required to

respond to, a request for information or an information collection requirement unless the

requesting document displays a currently valid Office of Management and Budget control

number.

In accordance with 10 CFR 2.390 of the NRCs "Agency Rules of Practice and Procedure," a

copy of this letter and its enclosure will be available electronically for public inspection in the

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

NRC's 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/

Vincent G. Gaddy, Chief

Operations Branch

Division of Reactor Safety

Docket No. 50-483

License No. NPF-30

Enclosure:

Biennial Requalification Program Inspection Document Request

cc w/enclosure:

Electronic Distribution for the Callaway Plant

ML15096A094

SUNSI Review

By: SHedger

ADAMS

Yes No

Publicly Available

Non-Publicly Available

Non-Sensitive

Sensitive

Keyword:

RGN-002

OFFICE

OE:OB

C:OB

NAME

SHedger/dch

VGaddy

SIGNATURE

/RA/

/RA/

DATE

4/6/2015

4/6/2015

Letter to Fadi Diya from Vincent G. Gaddy, dated April 6, 2015

SUBJECT:

CALLAWAY PLANT - NOTIFICATION OF INSPECTION (NRC INSPECTION

REPORT 05000483/2015003) AND REQUEST FOR INFORMATION

Electronic distribution by RIV:

Regional Administrator (Marc.Dapas@nrc.gov)

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

DRP Director (Troy.Pruett@nrc.gov)

Acting DRP Deputy Director (Thomas.Farnholtz@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

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

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

Resident Inspector (Michael.Langelier@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)

Project Engineer, DRP/B (Steven.Janicki@nrc.gov)

CWY 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 Congressional Affairs Officer (Angel.Moreno@nrc.gov)

RIV/ETA: OEDO (Michael.Waters@nrc.gov)

Enclosure

BIENNIAL REQUALIFICATION PROGRAM INSPECTION DOCUMENT REQUEST

FROM:

Mr. Sean Hedger

Operations Engineer, NRC RIV

817-200-1556

TO:

Mr. Daniel Harris

Senior Training Supervisor - Initial Training

Callaway Plant

573-239-0023

SUBJECT:

INFORMATION REQUEST TO SUPPORT JUNE 15-19, 2015, LICENSED

OPERATOR REQUALIFICATION PROGRAM INSPECTION (IP 71111.11B)

A. The following information is requested in order to support inspection preparation

activities. These items are listed by section as they appear in the inspection module

(i.e., 2.02, 2.04, etc.). Requested materials should be sent either electronically or

hardcopy in order to arrive at the Region IV office no later than May 26, 2015.

Electronically: via IMS Certrec or email (to Sean.Hedger@nrc.gov,

Michael.Kennard@nrc.gov, and Christian.Cowdrey@nrc.gov )

Hardcopy to: U.S. Nuclear Regulatory Commission, Region IV

1600 E. Lamar Blvd

Arlington, TX 76011

ATTN: Sean D. Hedger

General Requests:

List of licensed operators, both senior reactor operator (SRO) and reactor

operator (RO), by crew (operating and staff).

Training and Operations Department organization charts (with qualified licensed

operator requalification (LOR) evaluators identified).

Procedures that identify process for revising and maintaining licensed operator

continuing training program up-to-date.

List of outstanding LOR program changes.

List of plant events and industry operating experience incorporated into LOR

program since last biennial requalification (BRQ) inspection.

Audits and/or self-assessment reports addressing the licensed operator

requalification training program.

Last two years of simulator review committee (or equivalent) meeting minutes.

Last two years of curriculum review committee (or equivalent) meeting minutes.

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02.03: Biennial Requalification Written Examination Quality

The current and approved biennial written examination schedule.

The current requalification cycle written examination results for both SRO and RO

that have already been administered up to the week prior to the inspection team

arrival on-site.

All written examinations that have been approved for administration up to and

including the week before the inspection team is on site. (This will need to have

adequate password protection if e-mailed or double envelope protection if mailed via

regular mail per NUREG-1021.)

The current requalification cycle examination methodology (sample plan).

02.04: Annual Requalification Operating Test Quality

The schedule for the operating tests (job performance measures (JPMs) and

scenarios) to be given the week of June 15, 2015 (week team is on-site).

The operating tests (JPMs & scenarios) (password protected and provide separately

via telephone at later date) to be given the week of June 15, 2015 (week team is on-

site).

Current requalification cycle operating tests (SRO and RO) and results up to the

week prior to the inspection team arrival on-site.

All of the previous years NRC required annual operating tests.

Current requalification cycle operating test methodology (sample plan).

All portions of the Updated Final Safety Analysis Report that identify operator

response times for time critical operator actions.

02.05: Licensee Admin of Requalification Exams

All procedures used to administer the annual operating test.

All procedures used to assess operator performance.

All procedures that describe conduct of simulator training.

All procedures used to test, operate, and maintain the simulator.

02.06: Requalification Examination Security

Submit any tracking tools that you use as a means to prevent excessive overlap on

the written examinations and also meet the intent of sampling all required topics on a

periodic basis.

Submit any tracking tools that you use as a means to prevent excessive overlap on

the operating tests and also meet the intent of sampling all required malfunctions

(including major events, instrument/component malfunctions, technical specification

calls, etc.) on a periodic basis.

All procedures that describe examination security, including procedures used to

develop the examinations that include guidelines on overlap between examinations

in current exam cycle tests and prior year examinations.

List of all condition reports since the last biennial requalification inspection related to

examination security and overlap.

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02.07: Licensee Remedial Training Program

List of remedial training conducted or planned since last requalification exams

(includes training provided to operators to enable passing requalification exams and

training provided to correct generic or individual weaknesses observed during

previous requalification exam cycle).

Remediation plans (lesson plans, reference materials, and attendance

documentation).

02.08: Conformance with Operator License Conditions

All procedures and program documentation for maintaining active operator licenses,

tracking training attendance, and ensuring medical fitness of licensed operators.

All procedures and associated documentation that supports reactivation of any

SRO/RO license (operating or staff crew) since the last biennial inspection.

02.09: Simulator Performance

For the following cases, send the most recent transient test packages, which may

be electronic or in paper single test packages and shall be complete with test

procedures for each test, the acceptance criteria, and results. For each transient

test, the reference chart should be included or an equivalent subject matter expert

review versus the simulator results with a write-up for any differences beyond the

American National Standards Institute (ANSI) 3.5 standard requirements. Based

on the input that the licensee implements simulator testing standards per

ANSI/ANS-3.5-2009, provide this information for the following Transient and Steady

State tests:

o Transient test 2, Simultaneous trip of all feedwater pumps.

o Transient test 6, Main turbine trip from maximum power level which does not

result in immediate reactor trip.

o Transient test 10, Slow primary system depressurization to saturated condition

with pressurizer relief or safety valve stuck open (inhibit activation of high

pressure emergency core cooling system).

o Steady State tests for medium power test.

All simulator management and configuration procedures if not already provided for

Section 02.05 above.

Simulator Discrepancy Report (DR) summary list for all open DRs. For closed DRs,

summary list for those items closed between June 2013 and May 2015.

Malfunction tests for loss of condenser vacuum and loss of normal feedwater normal

feedwater system failure. If these are in a scenario based training package then the

review of that package would be acceptable.

Primary parameters tested in order to verify core physics parameters [such as

moderator temperature coefficient (MTC), integral rod worth (IRW)]. The applicable

reference graphs from the Plant physics data book (electronic or other means as

available) should also be included as well as the test procedures used and the

acceptance criteria with results.

- 4 -

02.10: Problem Identification and Resolution

A summary report of all condition reports related to operator actions/errors in the

control room.

Any revised requalification training that was based on licensed operator performance

issues.

Copies of Callaway Action Requests 2013-01940, 2013-06740, 2014-09327, and

2015-02152.

Simulator Information Formal Tracking (SIFT) Number 20140094

Copies of condition reports related to Licensee Event Reports (LERs) 2014-002-00

and 2014-005-00.

Any other corrective action documentation resulting from the review of the 2014

simulator issue dealing with a Safety Injection (SI) signal during an anticipated

transient without scram (ATWS) scenario identified during the that years initial

licensing examination.

B. The following information is requested in order to support the on-site inspection

activities. Requested materials should be available to the inspection team, either

electronically or hardcopy, upon site arrival on June 15, 2015.

02.02: Exam Results / 02.03 and 02.04: Written Exam and Op Test Quality

All Operating tests (JPMs & scenarios) to be given in all subsequent weeks after

on-site week.

All results up to the day the team leaves the site.

02.08: Conformance with Operator License Conditions

Access to licensed operators records (operating and staff crews).

Access to licensed operators training attendance records.

Access to licensed operators medical records.

02.09: Simulator Performance

Simulator discrepancies from June 2013 to June 2015. This should include all open

DRs and DRs that have been closed, including the documentation/justification for

closure.

Acceptance test documentation, including hardware and software model revisions at

the time of acceptance (as available).

Documentation that validates current models, including the thermal-hydraulics and

neutronics models, to the actual plant.

All current model deficiencies, including Final Safety Analysis Report vs. Design

differences in the simulator (any documentation on this).

Summary list of modifications from June 2013 to June 2015.

Plant Modifications (both hardware and software) completed on the Simulator by due

date from June 2013 to June 2015.

Simulator Differences Lesson plan used in training (current to June 15, 2015).

The complete book of all Simulator annual performance test packages (usually in a

single book, but may be electronic or in single test packages), complete with all

transient tests, steady state tests, and malfunction tests. This should also include

the test procedures for each test, the acceptance criteria, and results. For each

transient test, the reference chart should be included or an equivalent subject matter

- 5 -

expert review versus the simulator results with a write-up for any differences beyond

the ANSI standard requirements.

All test packages used to verify core physics parameters (such as MTC, IRW). The

applicable reference graphs from the Plant physics data book (electronic or other

means as available) should also be included as well as the test procedures used and

the acceptance criteria with results.

All simulator test, configuration management, and related documents available in the

room for inspectors to review. This includes training needs analysis packages,

simulator review committee meeting minutes, etc.

Current copy of ANSI/ANS-3.5 standard you are committed to for simulator testing.

02.10: Problem Identification and Resolution

All condition reports related to operator actions/errors in the control room.

C. Callaway Plant is required to send the final results summary and any remaining

exams and operating tests that have not been reviewed to the regional office lead

inspector for this inspection for final review and comparison against the Significance

Determination Tools in order to communicate the exit results for the inspection.