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| number = ML103540382
| number = ML103540382
| issue date = 12/21/2010
| issue date = 12/21/2010
| title = Callaway Plant, Unit 1 - Audit of the Licensee'S Management of Regulatory Commitments, Audit Performed October 13-15, 2010 (TAC ME4840)
| title = Audit of the Licensee'S Management of Regulatory Commitments, Audit Performed October 13-15, 2010
| author name = Thadani M C
| author name = Thadani M
| author affiliation = NRC/NRR/DORL/LPLIV
| author affiliation = NRC/NRR/DORL/LPLIV
| addressee name = Heflin A C
| addressee name = Heflin A
| addressee affiliation = Union Electric Co
| addressee affiliation = Union Electric Co
| docket = 05000483
| docket = 05000483
| license number = NPF-030
| license number = NPF-030
| contact person = Polickoski J T, NRR/DORL/LPL4, 415-5430
| contact person = Polickoski J, NRR/DORL/LPL4, 415-5430
| case reference number = TAC ME4840
| case reference number = TAC ME4840
| document type = Letter, Audit Report
| document type = Letter, Audit Report
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 December 21, 2010 Mr. Adam C. Heflin Senior Vice President and Chief Nuclear Officer Union Electric Company P. O. Box 620 Fulton, MO 65251 CALLAWAY PLANT, UNIT 1 -AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. ME4840)  
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 21, 2010 Mr. Adam C. Heflin Senior Vice President and Chief Nuclear Officer Union Electric Company P. O. Box 620 Fulton, MO 65251
 
==SUBJECT:==
CALLAWAY PLANT, UNIT 1 - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. ME4840)


==Dear Mr. Heflin:==
==Dear Mr. Heflin:==
In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC. The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.
 
In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC.
The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.
An audit of the Callaway Plant, Unit 1, commitment management program was performed at the plant site during the period October 13-15, 2010. Based on the audit, the NRC staff concludes that Union Electric Company (the licensee) has implemented NRC commitments on a timely basis, with minor deficiencies noted and one commitment not implemented, and has implemented its program for managing NRC commitment changes with programmatic deficiencies noted. The details of the results of the audit are set forth in the enclosed audit report.
An audit of the Callaway Plant, Unit 1, commitment management program was performed at the plant site during the period October 13-15, 2010. Based on the audit, the NRC staff concludes that Union Electric Company (the licensee) has implemented NRC commitments on a timely basis, with minor deficiencies noted and one commitment not implemented, and has implemented its program for managing NRC commitment changes with programmatic deficiencies noted. The details of the results of the audit are set forth in the enclosed audit report.
A. Heflin -2 If you have any questions, please contact me at 301-415-1476 or via e-mail at mohan.thadani@nrc.gov.
 
Sincerely, (b )  
A. Heflin                                   -2 If you have any questions, please contact me at 301-415-1476 or via e-mail at mohan.thadani@nrc.gov.
\C__61 ,,-.0  ./ Mohan C. Thadani, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483  
Sincerely, (b c~    ) ,--_~'l \C__61 ,,-.0  ~~ ./
Mohan C. Thadani, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483


==Enclosure:==
==Enclosure:==


Audit Report cc w/encl: Distribution via Listserv UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483  
Audit Report cc w/encl: Distribution via Listserv
 
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483
 
==1.0      INTRODUCTION AND BACKGROUND==
 
In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML003741774), the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC.
The NRC Office of Nuclear Reactor Regulation (NRR) has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.
NEI-99-04 defines a "regulatory commitment" as an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC.
NRR guidelines direct the NRR Project Manager to audit the licensee's commitment management program by assessing the adequacy of the licensee's implementation of a sample of commitments made to the NRC in past licensing actions (amendments, relief requests, exemptions, etc.) and activities (bulletins, generic letters, etc.). The audit is to be performed every 3 years.
2.0    AUDIT PROCEDURE AND RESULTS An audit of the Callaway Plant, Unit 1, commitment management program was performed at the plant site during the period October 13-15, 2010, and discussed during a teleconference on December 16, 2010, with members of your staff. The audit reviewed commitments made by Union Electric Company (the licensee) since the previous audit on August 22-23,2007, which Enclosure
 
                                                -2 was documented in an audit report dated October 31,2007 (ADAMS Accession No. ML072780002). The audit consisted of two major parts: (1) verification of the licensee's implementation of NRC commitments that have been completed, and (2) verification of the licensee's program for managing changes to NRC commitments.
2.1      Verification of Licensee's Implementation of NRC Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented commitments made to the NRC as part of past licensing actions/activities. For commitments not yet implemented, the NRC staff determines whether they have been captured in an effective program for future implementation.
2.1.1    Audit Scope The audit addressed a sample of commitments made during the review period. The audit focused on regulatory commitments (as defined above) made in writing to the NRC as a result of past licensing actions (amendments, relief requests, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.). Before the audit, the NRC staff performed a search in ADAMS for the licensee's submittals since the last audit and selected a representative sample for verification.
The audit excluded the following types of commitments that are internal to licensee processes:
(1)    Commitments made on the licensee's own initiative among internal organizational components.
(2)    Commitments that pertain to milestones of licensing actions/activities (e.g.,
respond to an NRC request for additional information by a certain date).
Fulfillment of these commitments was indicated by the fact that the subject licensing action/activity was completed.
(3)    Commitments made as an internal reminder to take actions to comply with eXisting regulatory requirements such as regulations, Technical Specifications, and Updated Final Safety Analysis Reports. Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.
2.1.2    Audit Results The attached Audit Summary (Attachment 1) provides details of the audit and its results.
For reference, the licensee's commitments are tracked in the Commitment Tracking System (CTS) computer database and are managed in accordance with Callaway Plant procedure APA-ZZ-00540, "Commitment Management Program," Revision 013. For this audit, the NRC staff reviewed the selected sample of open and closed regulatory commitments to confirm that the licensee had implemented closed commitments appropriately, and that commitments still open had been captured in an effective program for future implementation as required by the Callaway Plant. The NRC staff reviewed relevant reports and summary sheets from the
 
                                                -3 computer database and other sources (e.g., corrective action documentation, plant procedures, job numbers, night orders, documented training, etc.) providing the status of each commitment, form of implementation, and any pending further action. In addition, the NRC staff reviewed the licensee's "Commitment Tracking" self-assessment (SA09-RA-S02) dated July 9, 2009.
Based on the review of reports provided by the licensee as described above and on queries of the CTS database during the audit, the NRC staff found that the licensee has generally implemented commitments on a timely basis, but with the following specific implementation and programmatic deficiencies (as documented in Attachment 1):
(1)    For Commitment 50123 for the one-time completion time extension for the Essential Service Water (ESW) system, formal training was not required nor tracked for non-licensed work control personnel authorized to control or release work. This lack of formalized training potentially contributed to four documented challenges in restricting work on the protected and/or opposite train of plant equipment (documented in the corrective action program and resident inspector integrated inspection report).
(2)    For Commitment 50123 mentioned above, licensed operator training was performed without required training specifics as documented in a commitment for this license amendment. This commitment is documented here as not implemented.
(3)    During the NRC staff review of the CTS database and other commitment documentation (most notably the corrective action program), commitments are generally not tracked for the discrete "explicit statement to take a specific action" level as described both in the licensee's procedure and the NEI 99-04 guidance.
Commitments are generally tracked holistically at the macro-topic level (at the licensing action level). The most notable example of this was for Commitment 50123, which comprised at least 26 discrete and distinct actions noted as regulatory commitments. Only one commitment tracking number was assigned for these 26 actions, and both the NRC and licensee staff had difficulty in reviewing many disparate databases (corrective action, training, procedures, job control, etc.) to aggregate the needed information to verify commitment implementation. This comment is also noteworthy in that it is a repeat comment from last Commitment Audit report for Callaway Plant dated October 31,2007, with no response from the licensee in the corrective action program.
2.2    Verification of the Licensee's Program for Managing NRC Commitment Changes The primary focus of this part of the audit is to verify that the licensee has established administrative controls for modifying or deleting commitments made to the NRC. The NRC staff compared the licensee's process for controlling regulatory commitments to the guidelines in NEI 99-04, which the NRC has found to be an acceptable guide for licensees to follow for managing and changing commitments. The process used at Callaway Plant is contained in APA-ZZ-00540, "Commitment Management Program," Revision 013 with accompanying change forms CA1571, "Commitment Revision, Initiation, Deletion, Request (CRIDR)," and CA2358, "Commitment Evaluation Summary." The auditors reviewed a sample of commitment changes
 
                                                -4 that included changes that were or will be reported to the NRC, and changes that were not or will not be reported to the NRC. The auditors also verified that the licensee's commitment management system includes a mechanism to ensure traceability of commitments following initial implementation. This ensures that licensee personnel are able to recognize that future proposed changes to the affected design features or operating practices require evaluation in accordance with the commitment change control process.
2.2.1    Audit Results The attached Audit Summary (Attachment 2) provides details of this portion of the audit and its results.
The NRC staff reviewed procedure APA-ZZ-00540 and its required forms to determine whether the licensee had an effective program in place to identify, manage, and close commitments made to the NRC as part of licensing actions/activities. In addition, the NRC staff reviewed relevant reports and summary sheets from the computer database and other sources providing the status of each commitment, tracking and change forms, and other associated documentation.
The NRC staff compared the guidance in the Callaway Plant procedure APA-ZZ-00540 to the guidance in NEI 99-04. As a result of this comparison, the NRC staff found that the Callaway Plant procedure was consistent with the NEI guidance for identifying, managing, and closing commitments. The NRC staff also found that roles and responsibilities, processes, and metrics were clearly identified in the Callaway Plant procedure.
Based on the review of the reports provided by the licensee as described above, queries of the CTS database, and the accompanying change review and tracking forms provided during the audit, the NRC staff found that the licensee's implementation of its program for managing NRC commitment changes in accordance with its site procedure has programmatic deficiencies noted below and as documented in Attachment 2:
(1)    The NRC staff reviewed 10 licensing actions documented in 29 separate correspondences to the NRC with multiple commitments contained within each licensing action. Of those 10 licensing actions reviewed, seven had missing or incorrect commitment change forms correlating to 13 of the 29 NRC correspondences not being documented properly per the licensee's commitment management program. Due to the number of discrepancies noted and the spectrum of commitments impacted, the NRC staff views this as a commitment management program programmatic deficiency.
(2)    This above comment is also noteworthy in that it is a repeat comment from last Commitment Audit report for Callaway Plant dated October 31, 2007, with no response from the licensee in the corrective action program of the programmatic level concern.


==1.0 INTRODUCTION==
                                            -5


AND BACKGROUND In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML003741774), the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC. The NRC Office of Nuclear Reactor Regulation (NRR) has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.
==3.0     CONCLUSION==
NEI-99-04 defines a "regulatory commitment" as an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC. NRR guidelines direct the NRR Project Manager to audit the licensee's commitment management program by assessing the adequacy of the licensee's implementation of a sample of commitments made to the NRC in past licensing actions (amendments, relief requests, exemptions, etc.) and activities (bulletins, generic letters, etc.). The audit is to be performed every 3 years. 2.0 AUDIT PROCEDURE AND RESULTS An audit of the Callaway Plant, Unit 1, commitment management program was performed at the plant site during the period October 13-15, 2010, and discussed during a teleconference on December 16, 2010, with members of your staff. The audit reviewed commitments made by Union Electric Company (the licensee) since the previous audit on August 22-23,2007, which Enclosure 
-2 was documented in an audit report dated October 31,2007 (ADAMS Accession No. ML072780002).
The audit consisted of two major parts: (1) verification of the licensee's implementation of NRC commitments that have been completed, and (2) verification of the licensee's program for managing changes to NRC commitments. Verification of Licensee's Implementation of NRC Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented commitments made to the NRC as part of past licensing actions/activities.
For commitments not yet implemented, the NRC staff determines whether they have been captured in an effective program for future implementation. Audit Scope The audit addressed a sample of commitments made during the review period. The audit focused on regulatory commitments (as defined above) made in writing to the NRC as a result of past licensing actions (amendments, relief requests, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.). Before the audit, the NRC staff performed a search in ADAMS for the licensee's submittals since the last audit and selected a representative sample for verification.
The audit excluded the following types of commitments that are internal to licensee processes: Commitments made on the licensee's own initiative among internal organizational components. Commitments that pertain to milestones of licensing actions/activities (e.g., respond to an NRC request for additional information by a certain date). Fulfillment of these commitments was indicated by the fact that the subject licensing action/activity was completed. Commitments made as an internal reminder to take actions to comply with eXisting regulatory requirements such as regulations, Technical Specifications, and Updated Final Safety Analysis Reports. Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements. Audit Results The attached Audit Summary (Attachment
: 1) provides details of the audit and its results. For reference, the licensee's commitments are tracked in the Commitment Tracking System (CTS) computer database and are managed in accordance with Callaway Plant procedure APA-ZZ-00540, "Commitment Management Program," Revision 013. For this audit, the NRC staff reviewed the selected sample of open and closed regulatory commitments to confirm that the licensee had implemented closed commitments appropriately, and that commitments still open had been captured in an effective program for future implementation as required by the Callaway Plant. The NRC staff reviewed relevant reports and summary sheets from the 
-3 computer database and other sources (e.g., corrective action documentation, plant procedures, job numbers, night orders, documented training, etc.) providing the status of each commitment, form of implementation, and any pending further action. In addition, the NRC staff reviewed the licensee's "Commitment Tracking" self-assessment (SA09-RA-S02) dated July 9, 2009. Based on the review of reports provided by the licensee as described above and on queries of the CTS database during the audit, the NRC staff found that the licensee has generally implemented commitments on a timely basis, but with the following specific implementation and programmatic deficiencies (as documented in Attachment 1): For Commitment 50123 for the one-time completion time extension for the Essential Service Water (ESW) system, formal training was not required nor tracked for non-licensed work control personnel authorized to control or release work. This lack of formalized training potentially contributed to four documented challenges in restricting work on the protected and/or opposite train of plant equipment (documented in the corrective action program and resident inspector integrated inspection report). For Commitment 50123 mentioned above, licensed operator training was performed without required training specifics as documented in a commitment for this license amendment.
This commitment is documented here as not implemented. During the NRC staff review of the CTS database and other commitment documentation (most notably the corrective action program), commitments are generally not tracked for the discrete "explicit statement to take a specific action" level as described both in the licensee's procedure and the NEI 99-04 guidance.
Commitments are generally tracked holistically at the macro-topic level (at the licensing action level). The most notable example of this was for Commitment 50123, which comprised at least 26 discrete and distinct actions noted as regulatory commitments.
Only one commitment tracking number was assigned for these 26 actions, and both the NRC and licensee staff had difficulty in reviewing many disparate databases (corrective action, training, procedures, job control, etc.) to aggregate the needed information to verify commitment implementation.
This comment is also noteworthy in that it is a repeat comment from last Commitment Audit report for Callaway Plant dated October 31,2007, with no response from the licensee in the corrective action program. Verification of the Licensee's Program for Managing NRC Commitment Changes The primary focus of this part of the audit is to verify that the licensee has established administrative controls for modifying or deleting commitments made to the NRC. The NRC staff compared the licensee's process for controlling regulatory commitments to the guidelines in NEI 99-04, which the NRC has found to be an acceptable guide for licensees to follow for managing and changing commitments.
The process used at Callaway Plant is contained in APA-ZZ-00540, "Commitment Management Program," Revision 013 with accompanying change forms CA 1571, "Commitment Revision, Initiation, Deletion, Request (CRIDR)," and CA2358, "Commitment Evaluation Summary." The auditors reviewed a sample of commitment changes 
-4 that included changes that were or will be reported to the NRC, and changes that were not or will not be reported to the NRC. The auditors also verified that the licensee's commitment management system includes a mechanism to ensure traceability of commitments following initial implementation.
This ensures that licensee personnel are able to recognize that future proposed changes to the affected design features or operating practices require evaluation in accordance with the commitment change control process. Audit Results The attached Audit Summary (Attachment
: 2) provides details of this portion of the audit and its results. The NRC staff reviewed procedure APA-ZZ-00540 and its required forms to determine whether the licensee had an effective program in place to identify, manage, and close commitments made to the NRC as part of licensing actions/activities.
In addition, the NRC staff reviewed relevant reports and summary sheets from the computer database and other sources providing the status of each commitment, tracking and change forms, and other associated documentation.
The NRC staff compared the guidance in the Callaway Plant procedure APA-ZZ-00540 to the guidance in NEI 99-04. As a result of this comparison, the NRC staff found that the Callaway Plant procedure was consistent with the NEI guidance for identifying, managing, and closing commitments.
The NRC staff also found that roles and responsibilities, processes, and metrics were clearly identified in the Callaway Plant procedure.
Based on the review of the reports provided by the licensee as described above, queries of the CTS database, and the accompanying change review and tracking forms provided during the audit, the NRC staff found that the licensee's implementation of its program for managing NRC commitment changes in accordance with its site procedure has programmatic deficiencies noted below and as documented in Attachment 2: The NRC staff reviewed 10 licensing actions documented in 29 separate correspondences to the NRC with multiple commitments contained within each licensing action. Of those 10 licensing actions reviewed, seven had missing or incorrect commitment change forms correlating to 13 of the 29 NRC correspondences not being documented properly per the licensee's commitment management program. Due to the number of discrepancies noted and the spectrum of commitments impacted, the NRC staff views this as a commitment management program programmatic deficiency. This above comment is also noteworthy in that it is a repeat comment from last Commitment Audit report for Callaway Plant dated October 31, 2007, with no response from the licensee in the corrective action program of the programmatic level concern. 
-5


==3.0 CONCLUSION==
The NRC staff concludes, based on the audit, that (1) Callaway Plant (the licensee) has generally implemented NRC commitments on a timely basis with minor deficiencies noted and one commitment not implemented, and (2) Callaway Plant has implemented its program for managing NRC commitment changes with programmatic deficiencies noted.
4.0     LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Emily M. Fast Bert G. Yates Thomas B. Elwood Jeff D. Lancaster Principal Contributors: James T. Polickoski Mohan C. Thadani Date: December 21,2010 Attachments:
As stated


The NRC staff concludes, based on the audit, that (1) Callaway Plant (the licensee) has generally implemented NRC commitments on a timely basis with minor deficiencies noted and one commitment not implemented, and (2) Callaway Plant has implemented its program for managing NRC commitment changes with programmatic deficiencies noted. 4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Emily M. Fast Bert G. Yates Thomas B. Elwood Jeff D. Lancaster Principal Contributors:
ATTACHMENT 1 IMPLEMENTATION OF COMMITMENTS
James T. Polickoski Mohan C. Thadani Date: December 21,2010 Attachments:
As stated ATTACHMENT IMPLEMENTATION OF  


==SUMMARY==
==SUMMARY==
OF AUDIT OCTOBER 13-15, CALLAWAY PLANT, UNIT IMPLEMENTATION OF  
OF AUDIT RESULTS OCTOBER 13-15, 2010 CALLAWAY PLANT, UNIT 1
 
IMPLEMENTATION OF COMMITMENTS


==SUMMARY==
==SUMMARY==
OF AUDIT OCTOBER 13-15, CALLAWAY PLANT, UNIT Commitment Source Commitment Commitment Commitment Supporting Type Document Date Subject Number Description of Commitment Documents Implementation Status LAR ULNRC-05445 10/3112007 One-time 50123 Completion time (CT) extension PRAER 07-307 ULNRC-05476 2/21/2008 completion included the due date, requirements Rev. 1 ULNRC-05482 3/7/2008 time extension by PRAER 07-307 Rev. 1 for OL 1282/ ULNRC-05500 5/6/2008 for essential OL 1282/Amendment 186 to address Amendment 186 ULNRC-05520 7/10/2008 service water Tier 2 probabilistic risk assessment MP 07-0066 ULNRC-05563 12/1/2008 (ESW) system. (PRA) commitments to get one-time 14-day ESW outage to implement MP 07-0066 and training on technical specification (TS) changes and implementation.
OF AUDIT RESULTS OCTOBER 13-15, 2010 CALLAWAY PLANT, UNIT 1 Commitment Source   Commitment Commitment   Commitment                                           Supporting Type Document       Date     Subject       Number       Description of Commitment           Documents         Implementation Status LAR ULNRC-05445 10/3112007 One-time       50123       Completion time (CT) extension       PRAER 07-307 ULNRC-05476 2/21/2008 completion                 included the due date, requirements Rev. 1 ULNRC-05482 3/7/2008   time extension             by PRAER 07-307 Rev. 1 for           OL1282/
The due date was extended by Amendment 191. The commitment was closed at time of implementation.
ULNRC-05500 5/6/2008   for essential               OL1282/Amendment 186 to address     Amendment 186 ULNRC-05520 7/10/2008 service water               Tier 2 probabilistic risk assessment MP 07-0066 ULNRC-05563 12/1/2008 (ESW)                       (PRA) commitments to get one-time   Amendment 191 system.                    14-day ESW outage to implement MP 07-0066 and training on technical specification (TS) changes and implementation. The due date was extended by Amendment 191.
Amendment 191 50123-1 TS changes implemented by 12/3/2008 and 4/16/2009.
The commitment was closed at time of implementation.
CLOSED -Commitment closed by implementation of Amendment 186 on 11/1012008 and Amendment 191 on 2/26/2009.
50123-1     TS changes implemented by                          CLOSED - Commitment closed by 12/3/2008 and 4/16/2009.                           implementation of Amendment 186 on 11/1012008 and Amendment 191 on 2/26/2009.
50123-2-1 No PRA-modeled equipment, other than out-of-service ESW train and supported systems rendered inoperable by that ESW train being out-of-service, will be voluntarily taken out of service during the time extended CT taken on each train. CLOSED -Commitment closed via CAR 200710836 Actions 2.0 and 2.2 closed 12/1/2008; closed via two Night Orders issued 11/28/2008.
50123-2-1   No PRA-modeled equipment, other                     CLOSED - Commitment closed via than out-of-service ESW train and                   CAR 200710836 Actions 2.0 and 2.2 supported systems rendered                         closed 12/1/2008; closed via two inoperable by that ESW train being                 Night Orders issued 11/28/2008.
DISCREPANCIES NOTED Although specific, signature training was provided to licensed operators via Night Orders, work control personnel (who are not all licensed operators) did not prescriptively receive this same training formally with a required signature.
out-of-service, will be voluntarily                 DISCREPANCIES NOTED taken out of service during the one                Although specific, signature training time extended CT taken on each                     was provided to licensed operators train.                                             via Night Orders, work control personnel (who are not all licensed operators) did not prescriptively receive this same training formally with a required signature. Minor findings documented in CAR 200602643 revealed vulnerabilities during the ESW modification in work control/management.
Minor findings documented in CAR 200602643 revealed vulnerabilities during the ESW modification in work control/management.
 
-Type Commitment Source Document Commitment Date Commitment Subject Commitment Number Description of Commitment Supporting Documents Implementation Status 50123-2-2 No work will be allowed in the area of equipment in the protected engineered safety feature (ESF) train (within 20 feet unless there is an intervening barrier).
                                                            - 2 Commitment Source   Commitment Commitment Commitment                                      Supporting Type  Document     Date     Subject     Number     Description of Commitment         Documents         Implementation Status 50123-2-2 No work will be allowed in the area             CLOSED - Commitment closed via of equipment in the protected                   CAR 200710836 Actions 2.0 and 2.2 engineered safety feature (ESF)                  closed 12/1/2008; closed via two train (within 20 feet unless there is            Night Orders issued 11/28/2008; an intervening barrier).                        Job Number 08006658.300 issued 11/30/2008.
CLOSED -Commitment closed via CAR 200710836 Actions 2.0 and 2.2 closed 12/1/2008; closed via two Night Orders issued 11/28/2008; Job Number 08006658.300 issued 11/30/2008.
DISCREPANCIES NOTED Although specific, signature training was provided to licensed operators via Night Orders, work control personnel (who are not all licensed operators) did not prescriptively receive this same training formally with a required signature. This contributed to non-cited violation (NCV) 05000483/2009003-02, "Inadequate Controls of Crane Work Above the Protected Train of Essential Service Water" as noted by the site resident inspectors during the conduct of the ESW modification. Also, minor findings documented in CAR 200902661 revealed additional vulnerabilities during the ESW modification in work control/management.
DISCREPANCIES NOTED Although specific, signature training was provided to licensed operators via Night Orders, work control personnel (who are not all licensed operators) did not prescriptively receive this same training formally with a required signature.
50123-3   None of the PRA-modeled                         CLOSED - Commitment closed via equipment in either train will be               CAR 200710836 Actions 2.2 and 3.6 voluntarily taken out of service                 closed 12/1/2008 and 11/1212008; during the time that normal service             closed via two Night Orders issued water is available to supply the out            11/28/2008.
This contributed to non-cited violation (NCV) 05000483/2009003-02, "Inadequate Controls of Crane Work Above the Protected Train of Essential Service Water" as noted by the site resident inspectors during the conduct of the ESW modification.
of-service ESW train loads.                     DISCREPANCIES NOTED Although specific, signature training was provided to licensed operators via Night Orders, work control personnel (who are not all licensed operators) did not prescriptively receive this same training formally with a required signature. Minor findings documented in CAR 200602643 revealed vulnerabilities during the ESW modification in work control/management.
Also, minor findings documented in CAR 200902661 revealed additional vulnerabilities during the ESW modification in work control/management.
 
50123-3 None of the PRA-modeled equipment in either train will be voluntarily taken out of service during the time that normal service water is available to supply the of-service ESW train loads. CLOSED -Commitment closed via CAR 200710836 Actions 2.2 and 3.6 closed 12/1/2008 and 11/1212008; closed via two Night Orders issued 11/28/2008.
                                                          - 3 Commitment Source   Commitment Commitment Commitment                                        Supporting Type  Document     Date     Subject     Number       Description of Commitment         Documents       Implementation Status 50123-4-1 Access to the switchyard will be                   CLOSED - Commitment closed via limited to personnel with a                       Job Number 08006658.300/510 demonstratable need (operator                     issued 11/30/2008.
DISCREPANCIES NOTED Although specific, signature training was provided to licensed operators via Night Orders, work control personnel (who are not all licensed operators) did not prescriptively receive this same training formally with a required signature.
rounds involving no equipment manipulation and staff associated with performing 8-hour readiness checks on the temporary diesel generators (DGs>>.
Minor findings documented in CAR 200602643 revealed vulnerabilities during the ESW modification in work control/management.
50123-4-2 No pre-planned work or testing or                 CLOSED - Commitment closed via preventive maintenance will be                     CAR 200710836 Action 3.6 closed allowed in the switchyard, or other               11/12/2008.
-Type Commitment Source Document Commitment Date Commitment Subject Commitment Number Description of Commitment Supporting Documents Implementation Status 50123-4-1 Access to the switch yard will be limited to personnel with a demonstratable need (operator rounds involving no equipment manipulation and staff associated with performing 8-hour readiness checks on the temporary diesel generators (DGs>>. CLOSED -Commitment closed via Job Number 08006658.300/510 issued 11/30/2008.
areas of the plant, that could cause a loss of offsite power (LOOP) event during the 14-day extended CT).
50123-4-2 No pre-planned work or testing or preventive maintenance will be allowed in the switchyard, or other areas of the plant, that could cause a loss of offsite power (LOOP) event during the 14-day extended CT). CLOSED -Commitment closed via CAR 200710836 Action 3.6 closed 11/12/2008.
50123-5   The one-time 14-day extended CT                   CLOSED - Commitment closed via will not be entered if, prior to entry,           Job Number 08006658.200 issued inclement weather conditions are                   11/1/2008; closed via CAR forecasted ( i.e., work under the                 200710836 closed 11/12/2008.
50123-5 The one-time 14-day extended CT will not be entered if, prior to entry, inclement weather conditions are forecasted ( i.e., work under the extended CT will not be started if Severe Weather as defined in OTO-ZZ-00012 is forecasted to occur within 140 miles of the plant). National Weather Service reports will be monitored prior to and throughout each ESW train limiting condition for operation (LCO) outage. CLOSED -Commitment closed via Job Number 08006658.200 issued 11/1/2008; closed via CAR 200710836 closed 11/12/2008.
extended CT will not be started if Severe Weather as defined in OTO-ZZ-00012 is forecasted to occur within 140 miles of the plant).
50123-6-1 The turbine-driven auxiliary feedwater pump (TDAFP) will remain operable.
National Weather Service reports will be monitored prior to and throughout each ESW train limiting condition for operation (LCO) outage.
CLOSED -Commitment closed via CAR 200710836 Action 3.7 closed 11/1212008; closed via Job Number 08006658.300/310 issued 11/30/2008 and 12/1/2008.
50123-6-1 The turbine-driven auxiliary                       CLOSED - Commitment closed via feedwater pump (TDAFP) will                       CAR 200710836 Action 3.7 closed remain operable.                                  11/1212008; closed via Job Number 08006658.300/310 issued 11/30/2008 and 12/1/2008.
-Type Commitment Source Document Commitment Date Commitment Subject Commitment Number Description of Commitment Supporting Documents Implementati.on Status 50123-6-2 The TDAFP pump room and associated valve rooms will be posted as restricted access. CLOSED -Commitment closed via CAR 200710836 Action 3.7 closed 11/12/2008; closed via Job Number 08006658.300/310 issued 11/30/2008 and 12/1/2008.
 
DISCREPANCY NOTED -Minor findings documented in CAR 200902612 revealed vulnerabilities during the ESW modification in operations management of TDAFP pump room access. 50123-6-3 The protected train motor-driven auxiliary feedwater pump (MDAFP) pump room and associated valve rooms will be posted as restricted access. CLOSED -Commitment closed via CAR 200710836 Action 3.7 closed 11/12/2008; closed via Job Number 08006658.300/310 issued 11/3012008 and 12/1/2008.
                                                            - 4 Commitment Source   Commitment Commitment Commitment                                      Supporting Type  Document     Date     Subject     Number       Description of Commitment       Documents         Implementati.on Status 50123-6-2 The TDAFP pump room and                         CLOSED - Commitment closed via associated valve rooms will be                 CAR 200710836 Action 3.7 closed posted as restricted access.                    11/12/2008; closed via Job Number 08006658.300/310 issued 11/30/2008 and 12/1/2008.
50123-6-4 The condensate storage tank (CST) will be posted as restricted access. CLOSED -Commitment closed via CAR 200710836 Action 3.7 closed 11/12/2008; closed via Job Number 08006658.300/310 issued 11/30/2008 and 12/1/2008.
DISCREPANCY NOTED - Minor findings documented in CAR 200902612 revealed vulnerabilities during the ESW modification in operations management of TDAFP pump room access.
50123-6-5 No work will be allowed on the Security Diesel. CLOSED -Commitment closed via CAR 200710836 Action 3.7 closed 11/12/2008; closed via Job Number 08006658.300/31 0 issued 11130/2008 and 12/1/2008.
50123-6-3 The protected train motor-driven               CLOSED - Commitment closed via auxiliary feedwater pump (MDAFP)               CAR 200710836 Action 3.7 closed pump room and associated valve                 11/12/2008; closed via Job Number rooms will be posted as restricted             08006658.300/310 issued access.                                        11/3012008 and 12/1/2008.
50123-7-1 During the portion of the extended CT that normal service water is supplying the ESW loads, the normal service water to ESW supply and return cross-connect valves will be opened and power removed from the operators.
50123-6-4 The condensate storage tank (CST)               CLOSED - Commitment closed via will be posted as restricted access.           CAR 200710836 Action 3.7 closed 11/12/2008; closed via Job Number 08006658.300/310 issued 11/30/2008 and 12/1/2008.
CLOSED -Commitment closed via Job Number 08006658.600 issued 12/3/2008.
50123-6-5 No work will be allowed on the                 CLOSED - Commitment closed via Security Diesel.                                CAR 200710836 Action 3.7 closed 11/12/2008; closed via Job Number 08006658.300/31 0 issued 11130/2008 and 12/1/2008.
50123-7-2 The ESW return to ultimate heat sink valves will be closed and power removed from the operators during this portion of the extended 14-day CTaswel1.
50123-7-1 During the portion of the extended             CLOSED - Commitment closed via CT that normal service water is                 Job Number 08006658.600 issued supplying the ESW loads, the                   12/3/2008.
CLOSED -Commitment closed via Job Number 08006658.610 issued 12/9/2008.
normal service water to ESW supply and return cross-connect valves will be opened and power removed from the operators.
50123-8-1 Operations Department will verify the availability of fire protection equipment.
50123-7-2  The ESW return to ultimate heat                CLOSED - Commitment closed via sink valves will be closed and power           Job Number 08006658.610 issued removed from the operators during               12/9/2008.
CLOSED -Commitment closed via Job Number 08006658.150 issued 11/30/2008.
this portion of the extended 14-day CTaswel1.
-5 Type Commitment Source Document Commitment Date Commitment Subject Commitment Number Description of Commitment Supporting Documents Implementation Status 50123-8-2 Operations Department will verify the availability of flood mitigation (drains, watertight doors) equipment.
50123-8-1 Operations Department will verify               CLOSED - Commitment closed via the availability of fire protection             Job Number 08006658.150 issued equipment.                                      11/30/2008.
CLOSED -Commitment closed via Job Number 08006658.130/140 issued 11/30/2008 and 12/112008.
 
50123-8-3 Prior to entering the extended ESW CTs, a walkdown of the above ground portion of the protected ESW train will be performed for transient combustibles.
                                                            -5 Commitment Source   Commitment Commitment Commitment                                      Supporting Type  Document    Date      Subject     Number       Description of Commitment       Documents         Implementation Status 50123-8-2 Operations Department will verify               CLOSED - Commitment closed via the availability of flood mitigation             Job Number 08006658.130/140 (drains, watertight doors)                      issued 11/30/2008 and 12/112008.
CLOSED -Commitment closed via Job Number 08006658.110/120 issued 11/30/2008.
equipment.
50123-8-4 This walkdown will also address the seismic interaction commitments.
50123-8-3 Prior to entering the extended ESW               CLOSED - Commitment closed via CTs, a walkdown of the above                     Job Number 08006658.110/120 ground portion of the protected ESW             issued 11/30/2008.
CLOSED -Commitment closed via Job Number 08006658.100 issued 12/1/2008.
train will be performed for transient combustibles.
50123-9-1 Continuous 1-hour and 8-hour fire and flood watches will be instituted on the protected ESW train ... CLOSED -Commitment closed via Job Number 08006658.400/410 issued 12/11/2008.
50123-8-4  This walkdown will also address the              CLOSED - Commitment closed via seismic interaction commitments.                Job Number 08006658.100 issued 12/1/2008.
50123-9-2 The normal charging pump (NCP) will remain functional and its room will be posted as restricted access. CLOSED -Commitment closed via Job Number 08006658.300 issued 11/30/2008.
50123-9-1 Continuous 1-hour and 8-hour fire               CLOSED - Commitment closed via and flood watches will be instituted             Job Number 08006658.400/410 on the protected ESW train ...                   issued 12/11/2008.
50123-9-3 If the NCP were to become functional during the 14-day LCO outage such that the pump becomes unable to provide the required reactor coolant pump seal cooling, administrative controls will require plant shutdown to MODE 3 within 6 hours and to MODE 4 within 12 hours. CLOSED -Commitment closed via Night Order issued 11/28/2008.
50123-9-2 The normal charging pump (NCP)                   CLOSED - Commitment closed via will remain functional and its room             Job Number 08006658.300 issued will be posted as restricted access.             11/30/2008.
50123-10-1 Appropriate training will be provided to operations personnel on this TS change and the associated ESW modification.
50123-9-3 If the NCP were to become non                  CLOSED - Commitment closed via functional during the 14-day LCO                 Night Order issued 11/28/2008.
CLOSED -Commitment closed via Licensed Operator Continuing Training (LOCT) Cycles 08-2 and 08-4 closed on 4/11/2008 and 8/8/2008.
outage such that the pump becomes unable to provide the required reactor coolant pump seal cooling, administrative controls will require plant shutdown to MODE 3 within 6 hours and to MODE 4 within 12 hours.
-Commibnent Source Commibnent Commibnent Commibnent Supporting Type Document Date Subject Number Description of Commibnent Documents Implementation Status 50123-10-2 This training will identify dominant internal events, fire and internal flooding core scenarios, associated with the plant configuration during the extended ESW CT, and include a discussion of mitigation strategies for these scenarios.
50123-10-1 Appropriate training will be provided            CLOSED - Commitment closed via to operations personnel on this TS               Licensed Operator Continuing change and the associated ESW                   Training (LOCT) Cycles 08-2 and modification.                                    08-4 closed on 4/11/2008 and 8/8/2008.
FAILED TO IMPLEMENT
 
-The LOCT Cycle 08-2 and 08-4 training discussed above and credited for the above commitment did not include the items listed in this commitment, and the licensee cannot find a record that any training included the requirements of this commitment.
                                                                - 6 Commibnent Source   Commibnent Commibnent   Commibnent                                           Supporting Type Document       Date     Subject       Number       Description of Commibnent             Documents         Implementation Status 50123-10-2 This training will identify dominant                 FAILED TO IMPLEMENT - The internal events, fire and internal                   LOCT Cycle 08-2 and 08-4 training flooding core scenarios, associated                   discussed above and credited for with the plant configuration during                   the above commitment did not the extended ESW CT, and include                     include the items listed in this a discussion of mitigation strategies                 commitment, and the licensee for these scenarios.                                 cannot find a record that any training included the requirements of this commitment.
50123-11-1 A temporary alternate power source consisting of DGs, with combined capacity equal to or greater than the capacity of either one of the installed emergency DGs, will be available as a backup power source. CLOSED -Commitment closed via Job Number 08004308; closed via CAR 200710836 Actions 1.4 and 3.4 closed on 8/2612008 and 11/12/2008.
50123-11-1 A temporary alternate power source                   CLOSED - Commitment closed via consisting of DGs, with combined                     Job Number 08004308; closed via capacity equal to or greater than the                 CAR 200710836 Actions 1.4 and 3.4 capacity of either one of the installed               closed on 8/2612008 and emergency DGs, will be available as                   11/12/2008.
50123-11-2 Prior to entering the extended day CT on each ESW train, these temporary DGs will be load tested to provide a load equal to the continuous rating of the inoperable DG. CLOSED -Commitment closed via Job Number 08006658.500 issued 12/1/2008; Job Number 08004308.524 issued 12/2/2008; and Night Order issued on 11/28/2008.
a backup power source.
50123-11-3 After entering the extended ESW CT on each train, this source will be verified available every 8 hours and treated as protected equipment.
50123-11-2 Prior to entering the extended 14                    CLOSED - Commitment closed via day CT on each ESW train, these                       Job Number 08006658.500 issued temporary DGs will be load tested to                 12/1/2008; Job Number provide a load equal to the                          08004308.524 issued 12/2/2008; continuous rating of the inoperable                  and Night Order issued on DG.                                                  11/28/2008.
CLOSED -Commitment closed via Job Number 08006658.510 issued 12/10/2008; closed via Night Order and accompanying training as was issued on 11/28/2008.
50123-11-3 After entering the extended ESW CT                   CLOSED - Commitment closed via on each train, this source will be                   Job Number 08006658.510 issued verified available every 8 hours and                 12/10/2008; closed via Night Order treated as protected equipment.                      and accompanying training as was issued on 11/28/2008.
RR ULNRC-05517 7/10/2008 Relief Request for ESWpipe 50126 This commitment is for ESW PE4 710 Pipe to support Relief Request 13R-10. The results will be submitted to the NRC prior to submittal of Callaway's fourth 1year interval inservice inspection (lSI) plan, and will include, if necessary, a fourth 1 O-year interval alternative request. This will be completed prior to submittal of Callaway's lSI plan for the fourth 10-year interval with a due date of 6/20/2014.
RR   ULNRC-05517 7/10/2008 Relief Request 50126     This commitment is for ESW             13R-10        PENDING - the licensee will for ESWpipe              PE4710 Pipe to support Relief                         evaluate future industry Request 13R-10. The results will be                   investigations to confirm stress and submitted to the NRC prior to                         design factors as well as future submittal of Callaway's fourth 1D                    evolution of the fusion technique for year interval inservice inspection                   the installed joints. These results (lSI) plan, and will include, if                     will be completed and submitted to necessary, a fourth 1O-year interval                 the NRC per the commitment alternative request. This will be                     described by 6/20/2014.
13R-10 PENDING -the licensee will evaluate future industry investigations to confirm stress and design factors as well as future evolution of the fusion technique for the installed joints. These results will be completed and submitted to the NRC per the commitment described by 6/20/2014. 
completed prior to submittal of Callaway's lSI plan for the fourth 10-year interval with a due date of 6/20/2014.
-7 Commibnent Source Commibnent Commibnent Commibnent Supporting Type Document Date Subject Number Description of Commitment Documents GL ULNRC-05461 12/10/2007 Responds to 50109 Updates to actions originally ULNRC-05295 ULNRC-05521 6/24/2008 NRC Generic committed to in the 5/30/2006 letter ULNRC-05668 2/11/2009 Letter (GL) 2004-02 and associated containment sump evaluations to NRC (ULNRC-05295) include a status update and revision of commitment due dates (extensions).
 
GL ULNRC-05504 4/10/2008 GL 2008-01 50125 This commitment is to submit the Gas Accumulation U LN R C-05551 10/13/2008 (Managing 50129 GL 2008-01 requested information Technical ULNRC-05590 2/4/2009 Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems) NRC information request to the NRC within 90 days following the end of Refuel 16. Refuel 16 ended 1117/2009.
                                                                -7 Commibnent Source    Commibnent  Commibnent    Commibnent                                          Supporting Type  Document        Date      Subject      Number      Description of Commitment            Documents              Implementation Status GL  ULNRC-05461 12/10/2007  Responds to   50109      Updates to actions originally        ULNRC-05295        PENDING - actions related to this ULNRC-05521 6/24/2008  NRC Generic              committed to in the 5/30/2006 letter                    commitment are ongoing.
The requested information was provided to the NRC via ULNRC-05590 on 2/4/2009.
ULNRC-05668 2/11/2009  Letter (GL)              to NRC (ULNRC-05295) include a 2004-02 and              status update and revision of associated                commitment due dates (extensions).
Specifications Task Force (TSTF) Traveler/Consolidat ed Line Item Improvement Process (CLlIP) BL ULNRC-05253 ULNRC-05424 1/25/2006 7/9/2007 Inspection of Alloy 82/182/600 materials used in the fabrication of pressurizer penetrations and steam space piping connections at pressurized-water reactors (PWRs) 50094 Portions of the commitment are no longer applicable, and the remainder of the commitment was met with ULNRC-05253.
containment sump evaluations GL  ULNRC-05504 4/10/2008   GL 2008-01    50125      This commitment is to submit the    Gas Accumulation    PENDING - the first of two ULN RC-05551 10/13/2008 (Managing      50129      GL 2008-01 requested information    Technical          commitments is closed and ULNRC-05590 2/4/2009    Gas                      to the NRC within 90 days following  Specifications Task documented in 50125 on 2/512009.
ULNRC-05253 Implementation Status PENDING -actions related to this commitment are ongoing. PENDING -the first of two commitments is closed and documented in 50125 on 2/512009.
Accumulation              the end of Refuel 16. Refuel 16      Force (TSTF)       The second commitment is pending in Emergency              ended 1117/2009. The requested      Traveler/Consolidat the outcome of the industry/NRC Core Cooling,            information was provided to the      ed Line Item        TSTF review.
The second commitment is pending the outcome of the industry/NRC TSTF review. CLOSED -Commitment closed via the following (2/1112005)  
Decay Heat                NRC via ULNRC-05590 on              Improvement Removal, and              2/4/2009.                            Process (CLlIP)
: installation of pressurizer nozzle full structural weld overlays the overlays have been volumetrically examined inspection reporting to the NRC is met via ULNRC-05253 
Containment Spray Systems)
-8 Commitment Source Commitment Commitment Commitment Supporting Type Document Date Subject Number Description of Commitment Documents LAR ULNRC-05206 9/9/2005 Revision to TS 3.7.3. Main Feedwater Isolation Valves 50124 This commitment is associated with the implementation of LAR OL-1258. revision to TS 3.7.3, Main Feedwater Isolation Valves, and License Amendment 170 to include OL 12581 Amendment 170 (MFIVs) implementation due date and implementation of associated changes. LAR ULNRC-05269 ULNRC-05345 5/22/2007 Boron dilution amendment related to TS 3.9.213.3.9 50118 OL-1283 and ULNRC-05345.
NRC information request BL  ULNRC-05253 1/25/2006  Inspection of  50094      Portions of the commitment are no    ULNRC-05253        CLOSED - Commitment closed via ULNRC-05424 7/9/2007    Alloy                    longer applicable, and the remainder                    the following (2/1112005) :
LA to TS 3.9.2, "Unborated Water Source Isolation Valves" and TS 3.3.9, "Boron Dilution Mitigation System (BDMS)." Amendment, associated procedure changes, associated FSAR changes. and associated TS Bases changes will be implemented within 90 days of NRC approval.
82/182/600                of the commitment was met with
OL-1283 LAR ULNRC-05627 7/10/2009 Moving Hydrogen Recombinerl Monitor TS to UFSAR 50103 This commitment is to add the TS requirement for Hydrogen Recombiners and monitors to FSAR Chapter 16 upon implementation of the elimination of the TS requirement.
* installation of pressurizer nozzle materials used           ULNRC-05253.                                                  full structural weld overlays in the
UFSAR Chapter 16 Implementation Status CLOSED -Commitment closed via License Amendment 170 implementation as follows (12/1512005): Amendment implemented no later than Mode 3 (ascending) during startup from the Refuel 15 Outage. Associated final safety analysis report (FSAR) and TS bases revisions were incorporated. Stroke time baseline testing of the MFIV CLOSED -Commitment closed via License Amendment 181 implementation as follows (5/22/2007): Implemented within 90 days Administrative controls via written procedures were established prior to implementation Associated FSAR and TS bases revisions were incorporated.
* the  overlays have been fabrication of                                                                         volumetrically examined pressurizer
CLOSED -Commitment closed via License Amendment 199 implementation as follows (9/22/2010): The licensee verified its hydrogen monitoring system is capable of diagnosing beyond design-basis accidents The licensee will maintain the capability Hydrogen monitor requirements are included in FSAR Chapter 16.
* inspection reporting to the NRC penetrations                                                                           is met via ULNRC-05253 and steam space piping connections at pressurized-water reactors (PWRs)
-Commibnent Source Commitment Commitment Commitment Supporting Type Document Date Subject Number Description of Commitment Documents Implementation Status Other ULNRC-05155 ULNRC-05258 ULNRC-05357 5/26/2005 2/24/2006 1/4/2007 B.5.b mitigation strategy implementatio n 50107 DISCREPANCY NOTED -it appears that credit is taken in OTO for completion of Commitment 50107, but 50107 is not mentioned in the references section of the OTO procedure.
 
50107-1 CLOSED -Commitment closed via Extensive Damage Mitigation Guidelines (EDMGS), 00003, Revision 003, Section 4a (8/22/07) 50107-2 CLOSED -Commitment closed via Extensive Damage Mitigation Guidelines (EDMGS), 00003, Revision 003, Attachment C (8/22/2007) 50107-3 CLOSED -Commitment closed via Extensive Damage Mitigation Guidelines (EDMGS), 00003, Revision 003, Attachment C (8/22/2007) 50107-4 CLOSED -closed as discussed in ULNRC-05258 50107-6 CLOSED -Commitment closed via Extensive Damage Mitigation Guidelines (EDMGS), 00003, Revision 003, Attachment D (8/22/2007) 50119 Five commitments that are security related and withheld from public disclosure in accordance with 10 CFR 2.390. 50119-1 Commitment
                                                                -8 Commitment Source    Commitment  Commitment    Commitment                                        Supporting Type  Document        Date      Subject      Number      Description of Commitment          Documents          Implementation Status LAR  ULNRC-05206 9/9/2005  Revision to TS 50124      This commitment is associated with OL 12581        CLOSED - Commitment closed via 3.7.3. Main              the implementation of LAR OL-1258. Amendment 170    License Amendment 170 Feedwater                revision to TS 3.7.3, Main                          implementation as follows Isolation                Feedwater Isolation Valves, and                    (12/1512005):
#1 CLOSED -Commitment closed via Emergency Coordinator Supplemental Guide, Revision 008, Attachments JJ-QQ (8/22/2007)
Valves                    License Amendment 170 to include
-Type Commitment Source Document Commitment Date Commitment Subject Commitment Number Description of Commitment Supporting Documents Implementation Status 50119-2 Commitment
* Amendment implemented no (MFIVs)                  implementation due date and                              later than Mode 3 (ascending) implementation of associated                            during startup from the changes.                                                Refuel 15 Outage.
#2 CLOSED -Commitment closed via Extensive Damage Mitigation Guidelines (EDMGS), 00003, Revision 003, Section 4 (8/22/2007) 50119-3 Commitment
* Associated final safety analysis report (FSAR) and TS bases revisions were incorporated.
#3 CLOSED -Commitment closed via Emergency Coordinator Supplemental Guide, Revision 008, Attachments B-D, V, X, Y, R, A, CC, DD, HH (8/22/2007) 50119-4 Commitment
* Stroke time baseline testing of the MFIV LAR   ULNRC-05269 5/22/2007  Boron dilution 50118      OL-1283 and ULNRC-05345. LA to     OL-1283          CLOSED - Commitment closed via ULNRC-05345            amendment                TS 3.9.2, "Unborated Water Source                  License Amendment 181 related to TS            Isolation Valves" and TS 3.3.9,                    implementation as follows 3.9.213.3.9               "Boron Dilution Mitigation System                   (5/22/2007):
#4 CLOSED -Commitment closed via Emergency Coordinator Supplemental Guide, Revision 008, Attachments EE-GG, Z, AA, BB (8/22/2007) 50119-5 Commitment
(BDMS)." Amendment, associated
#5 CLOSED -Commitment closed via CAR 200601311, Actions 11,11.1, 11.2,11.3,11.4,12,12.1,12.2, 12.3, 12.4 (10/5/2007)
* Implemented within 90 days procedure changes, associated
ATTACHMENT MANAGEMENT OF CHANGES TO REGULATORY  
* Administrative controls via FSAR changes. and associated TS                         written procedures were Bases changes will be implemented                       established prior to within 90 days of NRC approval.                          implementation
* Associated FSAR and TS bases revisions were incorporated.
LAR   ULNRC-05627 7/10/2009 Moving         50103     This commitment is to add the TS   UFSAR Chapter 16 CLOSED - Commitment closed via Hydrogen                  requirement for Hydrogen                           License Amendment 199 Recombinerl              Recombiners and monitors to FSAR                   implementation as follows Monitor TS to            Chapter 16 upon implementation of                   (9/22/2010):
UFSAR                    the elimination of the TS
* The licensee verified its requirement.                                             hydrogen monitoring system is capable of diagnosing beyond design-basis accidents
* The licensee will maintain the capability
* Hydrogen monitor requirements are included in FSAR Chapter 16.
 
                                                              - 9 Commibnent Source    Commitment  Commitment  Commitment                                    Supporting Type  Document        Date      Subject      Number      Description of Commitment      Documents        Implementation Status Other ULNRC-05155 5/26/2005  B.5.b        50107                                                    DISCREPANCY NOTED - it ULNRC-05258 2/24/2006  mitigation                                                            appears that credit is taken in OTO ULNRC-05357 1/4/2007  strategy                                                              for completion of Commitment implementatio                                                          50107, but 50107 is not mentioned n                                                                      in the references section of the OTO procedure.
50107-1                                                  CLOSED - Commitment closed via Extensive Damage Mitigation Guidelines (EDMGS), OTO-SK 00003, Revision 003, Section 4a (8/22/07) 50107-2                                                 CLOSED - Commitment closed via Extensive Damage Mitigation Guidelines (EDMGS), OTO-SK 00003, Revision 003, Attachment C (8/22/2007) 50107-3                                                  CLOSED - Commitment closed via Extensive Damage Mitigation Guidelines (EDMGS), OTO-SK 00003, Revision 003, Attachment C (8/22/2007) 50107-4                                                  CLOSED - closed as discussed in ULNRC-05258 50107-6                                                  CLOSED - Commitment closed via Extensive Damage Mitigation Guidelines (EDMGS), OTO-SK 00003, Revision 003, Attachment D (8/22/2007) 50119      Five commitments that are security related and withheld from public disclosure in accordance with 10 CFR 2.390.
50119-1    Commitment #1                                CLOSED - Commitment closed via Emergency Coordinator Supplemental Guide, Revision 008, Attachments JJ-QQ (8/22/2007)
 
                                                      - 10 Commitment Source  Commitment Commitment Commitment                            Supporting Type  Document    Date      Subject    Number    Description of Commitment Documents        Implementation Status 50119-2    Commitment #2                          CLOSED - Commitment closed via Extensive Damage Mitigation Guidelines (EDMGS), OTO-SK 00003, Revision 003, Section 4 (8/22/2007) 50119-3    Commitment #3                          CLOSED - Commitment closed via Emergency Coordinator Supplemental Guide, Revision 008, Attachments B-D, V, X, Y, R, A, CC, DD, HH (8/22/2007) 50119-4    Commitment #4                          CLOSED - Commitment closed via Emergency Coordinator Supplemental Guide, Revision 008, Attachments EE-GG, Z, AA, BB (8/22/2007) 50119-5    Commitment #5                          CLOSED - Commitment closed via CAR 200601311, Actions 11,11.1, 11.2,11.3,11.4,12,12.1,12.2, 12.3, 12.4 (10/5/2007)
 
ATTACHMENT 2 MANAGEMENT OF CHANGES TO REGULATORY COMMITMENTS


==SUMMARY==
==SUMMARY==
OF AUDIT OCTOBER 13-15, CALLAWAY PLANT, UNIT MANAGEMENT OF CHANGES TO REGULATORY  
OF AUDIT RESULTS OCTOBER 13-15, 2010 CALLAWAY PLANT, UNIT 1
 
MANAGEMENT OF CHANGES TO REGULATORY COMMITMENTS


==SUMMARY==
==SUMMARY==
OF AUDIT OCTOBER CALLAWAY PLANT, UNIT Commitment Source Commitment Commitment Commitment Original Description of Supporting Type Document Date Subject Number Commitment Revised Commitment Documents Change Status LAR ULNRC-05445 10/3112007 One-time 50123 CT extension included PRAER DISCREPANCIES ULNRC-05476 2/21/2008 Completion the due date, 307 Rev. 1 NOTED-As ULNRC-05482 3/7/2008 Time (CT) requirements by OL 1282/ identified by the ULNRC-05500 5/6/2008 extension for PRAER 07-307 Rev. 1 for Amendment licensee during its ULNRC-05520 7/10/2008 essential OL 1282/Amendment 186 186 Commitment Tracking ULNRC-05563 12/1/2008 service water (ESW) system. to address Tier 2 probabilistic risk assessment (PRA) commitments to get time 14-day ESW outage to implement MP 07-0066 and training on technical specification (TS) changes and implementation.
OF AUDIT RESULTS OCTOBER 13-15,2010 CALLAWAY PLANT, UNIT 1 Commitment Source   Commitment Commitment     Commitment Original Description of                         Supporting Type   Document       Date       Subject       Number         Commitment           Revised Commitment Documents       Change Status LAR ULNRC-05445 10/3112007 One-time       50123       CT extension included                           PRAER 07  DISCREPANCIES ULNRC-05476 2/21/2008   Completion                 the due date,                                   307 Rev. 1 NOTED-As ULNRC-05482 3/7/2008   Time (CT)                 requirements by                                 OL 1282/   identified by the ULNRC-05500 5/6/2008   extension for             PRAER 07-307 Rev. 1 for                         Amendment   licensee during its ULNRC-05520 7/10/2008   essential                 OL1282/Amendment 186                           186         Commitment Tracking ULNRC-05563 12/1/2008   service water             to address Tier 2                              MP 07-0066  Self-Assessment (ESW) system.             probabilistic risk                             Amendment  (SA09-RA-S02) dated assessment (PRA)                               191        7/9/2009 and commitments to get one                                    following commitment time 14-day ESW outage                                     initiation with ULNRC to implement MP 07-0066                                     05445, no further and training on technical                                   revision or deletion specification (TS)                                         forms were submitted changes and                                                 for ULNRCs-05476, implementation. The due                                     05482,05500,05520, date was extended by                                       05563.
The due date was extended by Amendment 191. The commitment was closed at time of implementation.
Amendment 191. The commitment was closed at time of implementation.
MP 07-0066 Amendment 191 Self-Assessment (SA09-RA-S02) dated 7/9/2009 and following commitment initiation with 05445, no further revision or deletion forms were submitted for ULNRCs-05476, 05482,05500,05520, 05563. RR ULNRC-05517 7/1012008 Relief Request for ESW pipe 50126 This commitment is for ESW PE4710 pipe to support Relief Request 13R-10. The results will be submitted to the NRC prior to submittal of Callaway's fourth 10-year interval inservice inspection (lSI) plan, and will include, if necessary, a fourth 1 O-year interval alternative request. This will be completed prior to submittal of Callaway's lSI plan for the fourth year interval with a due date of 6/20/2014.
RR   ULNRC-05517 7/1012008   Relief Request 50126       This commitment is for      No new commitments  13R-10      Initiation Form for ESW pipe              ESW PE4710 pipe to         made.                          completed per support Relief Request                                     procedure (CA1571 13R-10. The results will                                   form on 08/25/2008).
No new commitments made. 13R-10 Initiation Form completed per procedure (CA 1571 form on 08/25/2008). 
be submitted to the NRC prior to submittal of Callaway's fourth 10-year interval inservice inspection (lSI) plan, and will include, if necessary, a fourth 1O-year interval alternative request. This will be completed prior to submittal of Callaway's lSI plan for the fourth 10 year interval with a due date of 6/20/2014.
-2 Commitment Source Commitment Commitment Commitment Original Description of Supporting Type Document Date Subject Number Commitment Revised Commitment Documents Change Status GL ULNRC-05124 31712005 Responds to 50109 Initial commitments were Updates to actions DISCREPANCY ULNRC-05194 9/1/2005 NRC Generic provided in ULNRC-originally committed to in 05295 NOTED -An initiation ULNRC-05295 5/30/2006 Letter (GL) 05124 with additional the 5/30/2006 letter to form was not ULNRC-05408 5/112007 2004-02 and detail and commitments NRC (ULNRC-05295) submitted for the ULNRC-05461 12/10/2007 associated in ULNRC-05194.
 
include a status update initial commitments of ULNRC-05521 612412008 containment and revision of ULNRC-05124 nor a ULNRC-05668 11/2412009 sump evaluations commitment due dates (extensions).
                                                                -2 Commitment Source   Commitment Commitment     Commitment Original Description of                             Supporting Type   Document       Date       Subject       Number           Commitment         Revised Commitment       Documents       Change Status GL   ULNRC-05124 31712005   Responds to     50109       Initial commitments were Updates to actions         ULNRC      DISCREPANCY ULNRC-05194 9/1/2005   NRC Generic                 provided in ULNRC-       originally committed to in 05295       NOTED - An initiation ULNRC-05295 5/30/2006   Letter (GL)                 05124 with additional   the 5/30/2006 letter to                 form was not ULNRC-05408 5/112007   2004-02 and                 detail and commitments   NRC (ULNRC-05295)                       submitted for the ULNRC-05461 12/10/2007 associated                 in ULNRC-05194.         include a status update                 initial commitments of ULNRC-05521 612412008   containment                                         and revision of                         ULNRC-05124 nor a ULNRC-05668 11/2412009 sump                                                 commitment due dates                   revision for the added evaluations                                          (extensions). The                       detail and additional following ULRNC's have                 commitments in provided more updates to               ULNRC-05194. The commitments: 05408,                     balance of revision 05461,05521,05668.                     forms through the current ULNRC-05668 are per procedure.
The following ULRNC's have provided more updates to commitments:
GL   ULNRC-05504 4/10/2008   GL 2008-01     50125       This commitment is to   Submit the GL 2008-01     Gas         DISCREPANCY ULNRC-05551 10/1312008 (Managing Gas 50129         submit the GL 2008-01   requested information to   Accumulation NOTED - Although an ULNRC-05590 2/4/2009   Accumulation in             requested information to the NRC within 90 days    TSTF        initiation form was Emergency                  the NRC within 60 days   following the end of       Travelerl    submitted for ULNRC Core Cooling,              following the end of     Refuel 16. Monitor         CUIP        05504, a revision form Decay Heat                  Refuel 16.              industry resolution and                 was not submitted for Removal, and                                        submit LAR within 1 year               the commitment Containment                                          of NRC approval of                     changes in ULNRC Spray Systems)                                      Technical Specifications               05551 as required per NRC                                                  Task Force (TSTF) and                   procedure for 50125 information                                          Consolidated Line Item                 nor was a deletion request                                              Improvement Process                     submitted following (CUIP).                                 completion of the first commitment (noted in self-assessment).
05408, 05461,05521,05668.
revision for the added detail and additional commitments in ULNRC-05194.
The balance of revision forms through the current ULNRC-05668 are per procedure.
GL ULNRC-05504 4/10/2008 GL 2008-01 50125 This commitment is to Submit the GL 2008-01 Gas DISCREPANCY ULNRC-05551 10/1312008 (Managing Gas 50129 submit the GL 2008-01 requested information to Accumulation NOTED -Although an ULNRC-05590 2/4/2009 Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems) NRC information request requested information to the NRC within 60 days following the end of Refuel 16. the NRC within 90 days following the end of Refuel 16. Monitor industry resolution and submit LAR within 1 year of NRC approval of Technical Specifications Task Force (TSTF) and Consolidated Line Item Improvement Process (CUIP). TSTF Travelerl CUIP initiation form was submitted for 05504, a revision form was not submitted for the commitment changes in 05551 as required per procedure for 50125 nor was a deletion submitted following completion of the first commitment (noted in self-assessment).
Instead, the licensee initiated a new commitment (50129) to document the changed and new commitment in ULNRC-05551.
Instead, the licensee initiated a new commitment (50129) to document the changed and new commitment in ULNRC-05551.
50129 was revised properly per procedure to update commitment status (although commitment wording remained unchanged).
50129 was revised properly per procedure to update commitment status (although commitment wording remained unchanged).
-3Commitment Commitment Commitment Original Description of Supporting Type Subject Number Commitment Revised Commitment Date Documents Change Status Document 7/27/2004 I nspection of 50094 The first commitment is DISCREPANCY ULNRC-05253 BL ULNRC-05031
 
* Perform bare metal no longer applicable, and NOTED-The ULNRC-05424 1/25/2006 Alloy 05253 visual inspections 7/9/2007 82/182/600 the second commitment licensee did not follow materials used near the beginning of was met with ULNRC-procedure by not in the each outage 05253. initiating a fabrication of
                                                                -3 Commitment Source    Commitment  Commitment       Commitment Original Description of                             Supporting Type   Document      Date        Subject       Number         Commitment           Revised Commitment       Documents         Change Status BL  ULNRC-05031 7/27/2004   Inspection of   50094
* Submit a report to the commitment per pressurizer NRC indicating the procedure for penetrations inspections completed ULNRC-05031 and steam and the as-found containing the initial space piping condition of the two commitments.
* Perform bare metal    The first commitment is   ULNRC        DISCREPANCY ULNRC-05253 1/25/2006  Alloy                            visual inspections    no longer applicable, and 05253        NOTED- The ULNRC-05424 7/9/2007   82/182/600                       near the beginning of  the second commitment                   licensee did not follow materials used                   each outage            was met with ULNRC-                     procedure by not in the
connections at pressurizer Also, no revision or pressurized-initiation was water reactors . performed per procedure when ULNRC-05253 was submitted.
* Submit a report to the 05253.                                 initiating a fabrication of                   NRC indicating the                                             commitment per pressurizer                     inspections completed                                          procedure for penetrations                     and the as-found                                              ULNRC-05031 and steam                       condition of the                                               containing the initial space piping                     pressurizer                                                    two commitments.
Finally, the licensee documented a revision after commitment closure on 8/19/2009 when the commitment was closed 2/11/2005.
connections at                                                                                 Also, no revision or pressurized-                                                                                   initiation was water reactors                                                                               . performed per procedure when ULNRC-05253 was submitted. Finally, the licensee documented a revision after commitment closure on 8/19/2009 when the commitment was closed 2/11/2005.
Initiation Form ULNRC-05224 No new commitments OL 1258/ LAR ULNRC-05206 9/9/2005 Revision to TS 50124 This commitment is Amendment completed per Feedwater 10/2412005 3.7.3, Main associated with the made. implementation of LAR 170 procedure (CA 1571 Isolation Valves OL-1258, revision to TS form on 11/29/2007>>. (MFIVs) 3.7.3, Main Feedwater Isolation Valves and License Amendment 170 to include implementation due date and implementation of associated changes.
LAR ULNRC-05206 9/9/2005   Revision to TS 50124         This commitment is         No new commitments        OL1258/      Initiation Form ULNRC-05224 10/2412005 3.7.3, Main                 associated with the       made.                     Amendment    completed per Feedwater                    implementation of LAR                               170           procedure (CA1571 Isolation Valves             OL-1258, revision to TS                                           form on 11/29/2007>>.
Commitment Source Commitment Commitment Commitment Original Description of Supporting Type Document Date Subject Number Commitment Revised Cc)mmitment Documents Change Status LAR ULNRC-05269 ULNRC-05345 5/22/2007 Boron dilution amendment related to TS 3.9.2/3.3.9 50118 OL-1283 and 05269, LA to TS 3.9.2, "Unborated Water Source Isolation Valves" and TS 3.3.9, "Boron Dilution Mitigation System (BDMS)." Amendment, associated procedure changes, associated final safety analysis report (FSAR) changes, and associated TS Bases changes will be implemented within 90 days of NRC approval.
(MFIVs)                     3.7.3, Main Feedwater Isolation Valves and License Amendment 170 to include implementation due date and implementation of associated changes.
ULNRC-05345 added a fifth commitment to ensure written procedures will ensure prompt verification that unborated water sources shall be secured in the closed position.
 
OL-1283 DISCREPANCY NOTED-The licensee did not follow procedure by not initiating a commitment per procedure for ULNRC-05269.
                                                                -4 Commitment Source   Commitment Commitment     Commitment Original Description of                           Supporting Type   Document       Date       Subject       Number         Commitment           Revised Cc)mmitment   Documents       Change Status LAR ULNRC-05269 5/22/2007   Boron dilution 50118       OL-1283 and ULNRC        ULNRC-05345 added a      OL-1283    DISCREPANCY ULNRC-05345            amendment                  05269, LA to TS 3.9.2,   fifth commitment to                  NOTED- The related to TS              "Unborated Water Source   ensure written                      licensee did not follow 3.9.2/3.3.9                Isolation Valves" and TS procedures will ensure              procedure by not 3.3.9, "Boron Dilution   prompt verification that            initiating a Mitigation System         unborated water sources              commitment per (BDMS)." Amendment,       shall be secured in the              procedure for associated procedure     closed position.                    ULNRC-05269. The changes, associated final                                     licensee instead safety analysis report                                         initiated the (FSAR) changes, and                                           commitment per the associated TS Bases                                           fi nal Iist of changes will be                                               commitments in implemented within                                             ULNRC-05345 90 days of NRC approval.                                       instead of what should have been a revision.
The licensee instead initiated the commitment per the fi nal I ist of commitments in ULNRC-05345 instead of what should have been a revision.
LAR ULNRC-05627 7/10/2009   Moving         50103       Original commitment was   Detailed commitment      UFSAR      Commitment revision Hydrogen                    a placeholder awaiting   within license amendment Chapter 16  form submitted per Recombiner/                submission of an LAR. request to add the TS               procedure Monitor TS to                                        requirement for Hydrogen             completed per Updated Final                                        Recombiners and                     CA1571 form Safety Analysis                                      monitors to FSAR                     3/23/2010.
LAR ULNRC-05627 7/10/2009 Moving Hydrogen Recombiner/
Report                                                Chapter 16 upon (UFSAR)                                              implementation of the elimination of the TS requirement.
Monitor TS to Updated Final Safety Analysis Report (UFSAR) 50103 Original commitment was a placeholder awaiting submission of an LAR. Detailed commitment within license amendment request to add the TS requirement for Hydrogen Recombiners and monitors to FSAR Chapter 16 upon implementation of the elimination of the TS requirement.
 
UFSAR Chapter 16 Commitment revision form submitted per procedure completed per CA1571 form 3/23/2010. 
                                                                -5 Commitment Source     Commitment Commitment       Commitment Original Description of                   Supporting Type  Document        Date      SUbject        Number        Commitment         Revised Commitment Documents     Change Staws Othe ULN RC-05155 5126/2005   B.5.b mitigation 50107                                                             DISCREPANCY r   ULNRC-05256 2/14/2006   strategy                                                                           NOTED - the original ULNRC-05258 2/2412006   implementation                                                                     commitment for 50107 ULNRC-05357 1/4/2007                                                                                       was made via ULNRC-05155 and further clarified with 8 commitments via ULNRC-05258.
-5 Type Commitment Source Document Commitment Date Commitment SUbject Commitment Number Original Description of Commitment Revised Commitment Supporting Documents Change Staws Othe ULN RC-05155 5126/2005 B.5.b mitigation 50107 DISCREPANCY r ULNRC-05256 2/14/2006 strategy NOTED -the original ULNRC-05258 2/2412006 implementation commitment for 50107 ULNRC-05357 1/4/2007 was made via ULNRC-05155 and further clarified with 8 commitments via ULNRC-05258.
Although a commitment revision form exists for ULNRC-05258, no commitment initiation form exists for ULNRC-05155. This is against the licensee's commitment management program procedure requiring submittal of internal change forms to drive internal licensee review and/or track status.
Although a commitment revision form exists for ULNRC-05258, no commitment initiation form exists for ULNRC-05155.
 
This is against the licensee's commitment management program procedure requiring submittal of internal change forms to drive internal licensee review and/or track status.
                                                        -6 Commitment Source   Commitment Commitment Commitment Original Description of                   Supporting Type  Document    Date      Subject    Number        Commitment         Revised Commitment Documents       Change Status 50119       Five commitments that                                 DISCREPANCY are security related and                               NOTED - the original withheld from public                                   commitment for 50119 disclosure in accordance                               was made via with 10 CFR 2.390                                     ULNRC-05256 and further clarified with 5 commitments via ULNRC-05357.
-6 Type Commitment Source Document Commitment Date Commitment Subject Commitment Number Original Description of Commitment Revised Commitment Supporting Documents Change Status 50119 Five commitments that are security related and withheld from public disclosure in accordance with 10 CFR 2.390 DISCREPANCY NOTED -the original commitment for 50119 was made via ULNRC-05256 and further clarified with 5 commitments via ULNRC-05357.
Although a commitment initiation form exists for ULNRC-05357 (which should have been a commitment revision form), no commitment initiation form exists for ULNRC-05256.
Although a commitment initiation form exists for ULNRC-05357 (which should have been a commitment revision form), no commitment initiation form exists for ULNRC-05256.
This is against the licensee's commitment management program procedure requiring submittal of internal change forms to drive internal licensee review and/or track status.
This is against the licensee's commitment management program procedure requiring submittal of internal change forms to drive internal licensee review and/or track status.
A. Heflin -2 If you have any questions, please contact me at 301-415-1476 or via e-mail at mohan.thadani@nrc.gov.
Sincerely, IRA by Balwant K. Singal forI Mohan C. Thadani, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483
==Enclosure:==


Audit Report cc w/encl: Distribution via Listserv DISTRIBUTION:
ML103540382 OFFICE   NRR/LPL4/PM       NRR/LPL4/PM     NRR/LPL4/LA     NRR/LPL4/BC       NRR/LPL4/PM MThadani                                          MThadani NAME     JPolickoski       (.IRHall for)   JBurkhardt       MMarkley         (BSingal for)
PUBLIC LPLIV Reading RidsAcrsAcnwJVlailCTR Resource RidsNrrDorlLpl4 Resource RidsNrrPMCallaway Resource RidsNrrLAJBurkhardt Resource RidsOgcRp Resource RidsRgn4MailCenter Resource JPolickoski, NRR/DORLlLPL4 ADAMS Accession No. ML 103540382 OFFICE NRR/LPL4/PM NRR/LPL4/PM NRR/LPL4/LA NRR/LPL4/BC NRR/LPL4/PM NAME JPolickoski MThadani (.IRHall for) JBurkhardt MMarkley MThadani (BSingal for) DATE 12/20/2010 12/21/10 12/21/10 12/21/10 12/21/10 OFFICIAL RECORD}}
DATE     12/20/2010       12/21/10       12/21/10         12/21/10         12/21/10}}

Latest revision as of 06:22, 13 November 2019

Audit of the Licensee'S Management of Regulatory Commitments, Audit Performed October 13-15, 2010
ML103540382
Person / Time
Site: Callaway Ameren icon.png
Issue date: 12/21/2010
From: Thadani M
Plant Licensing Branch IV
To: Heflin A
Union Electric Co
Polickoski J, NRR/DORL/LPL4, 415-5430
References
TAC ME4840
Download: ML103540382 (26)
v • d • e


Text

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

SUBJECT:

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

Dear Mr. Heflin:

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

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

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

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

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

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

Enclosure:

Audit Report cc w/encl: Distribution via Listserv

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

1.0 INTRODUCTION AND BACKGROUND

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

-5

3.0 CONCLUSION

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

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

As stated

ATTACHMENT 1 IMPLEMENTATION OF COMMITMENTS

SUMMARY

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

IMPLEMENTATION OF COMMITMENTS

SUMMARY

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

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

The commitment was closed at time of implementation.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

this portion of the extended 14-day CTaswel1.

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

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

equipment.

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

train will be performed for transient combustibles.

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

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

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

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

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

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

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

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

a backup power source.

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

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

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

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

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

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

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

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

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

Containment Spray Systems)

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

82/182/600 of the commitment was met with

  • the overlays have been fabrication of volumetrically examined pressurizer
  • inspection reporting to the NRC penetrations is met via ULNRC-05253 and steam space piping connections at pressurized-water reactors (PWRs)

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

Valves License Amendment 170 to include

  • Amendment implemented no (MFIVs) implementation due date and later than Mode 3 (ascending) implementation of associated during startup from the changes. Refuel 15 Outage.
  • Associated final safety analysis report (FSAR) and TS bases revisions were incorporated.
  • Stroke time baseline testing of the MFIV LAR ULNRC-05269 5/22/2007 Boron dilution 50118 OL-1283 and ULNRC-05345. LA to OL-1283 CLOSED - Commitment closed via ULNRC-05345 amendment TS 3.9.2, "Unborated Water Source License Amendment 181 related to TS Isolation Valves" and TS 3.3.9, implementation as follows 3.9.213.3.9 "Boron Dilution Mitigation System (5/22/2007):

(BDMS)." Amendment, associated

  • Implemented within 90 days procedure changes, associated
  • Administrative controls via FSAR changes. and associated TS written procedures were Bases changes will be implemented established prior to within 90 days of NRC approval. implementation
  • Associated FSAR and TS bases revisions were incorporated.

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

UFSAR the elimination of the TS

  • The licensee verified its requirement. hydrogen monitoring system is capable of diagnosing beyond design-basis accidents
  • The licensee will maintain the capability
  • Hydrogen monitor requirements are included in FSAR Chapter 16.

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

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

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

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

ATTACHMENT 2 MANAGEMENT OF CHANGES TO REGULATORY COMMITMENTS

SUMMARY

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

MANAGEMENT OF CHANGES TO REGULATORY COMMITMENTS

SUMMARY

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

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

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

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

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

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

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

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

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

  • Perform bare metal The first commitment is ULNRC DISCREPANCY ULNRC-05253 1/25/2006 Alloy visual inspections no longer applicable, and 05253 NOTED- The ULNRC-05424 7/9/2007 82/182/600 near the beginning of the second commitment licensee did not follow materials used each outage was met with ULNRC- procedure by not in the
  • Submit a report to the 05253. initiating a fabrication of NRC indicating the commitment per pressurizer inspections completed procedure for penetrations and the as-found ULNRC-05031 and steam condition of the containing the initial space piping pressurizer two commitments.

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

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

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

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

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

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

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

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

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

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

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

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

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

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