ML081120557
| ML081120557 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 04/21/2008 |
| From: | Smith L J NRC/RGN-IV/DRS/EB2 |
| To: | Naslund C D AmerenUE |
| References | |
| IR-08-006 | |
| Download: ML081120557 (38) | |
See also: IR 05000483/2008006
Text
UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION IV611 RYAN PLAZA DRIVE, SUITE 400ARLINGTON, TEXAS 76011-4005
April 21, 2008
Charles D. Naslund, Senior Vice
President and Chief Nuclear Officer
AmerenUE
P.O. Box 620
Fulton, MO 65251
SUBJECT: CALLAWAY PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION
INSPECTION REPORT 05000483/2008006
Dear Mr. Naslund:
On March 14, 2008, the U. S. Nuclear Regulatory Commission completed a team inspection at
your Callaway Plant. The enclosed report documents the inspection findings, which the team
discussed on March 14, 2008, with Mr. A. Heflin, Vice President - Nuclear, and other members of
your staff during the exit meeting.
The team examined activities conducted under your lic
ense as they relate to the identification and
resolution of problems, compliance with the Commission's rules and regulations, and the
conditions of your operating license. Within these areas, the inspection involved examination of
selected procedures and representative records, observations of activities, and interviews with
personnel. The team reviewed 246 Callaway Action Requests, associated root and apparent
cause evaluations, and other supporting documents. The team reviewed an additional
124 Callaway Action Requests related to specific areas - essential service water, component
cooling water, 480 Vac auxiliary contacts, and sa
fety conscious work environment. The team
reviewed cross-cutting aspects of NRC findings and interviewed personnel regarding the condition
of your safety conscious work environment at the Callaway Plant.
Based on the sample selected for review, the team concluded that your staff continued to have
challenges in the area of prioritization and evaluation, which need additional attention. The team
also noted that performance related to problem identification and resolution had improved. The
team determined that you're your staff had used the self-assessment process and quality
assurance organization to improve site perfo
rmance. The team determined the improvement
resulted from corrective action process
improvements implemented in January 2007, and
management oversight process changes implem
ented following receipt of substantive
cross-cutting issue in problem identification and resolution.
Because of the increased number of allegations at your facility in Calendar Year 2007, especially
the discrimination concerns, the team interviewed
a large number of personnel related to the safety
conscious work environment at the Callaway Plant. In addition, because of the nature of the
concerns expressed in the allegations, the team asked additional questions to gain insights into the
safety conscious work environment at your fa
cility. The team documented the nature of the
concerns and the scope of the evaluations in Attachment 3. The team determined that not all
individuals were comfortable using all of the methods available to them for reporting concerns;
however, all personnel interviewed stated that they would have used at least one of the methods
AmerenUE
- 2 -available for reporting a safety concern. The team determined that our review results remained
consistent with other safety culture surveys that
you had completed within the last year. The team
determined that some general culture and work environment issues continued to be present that
were outside NRC regulatory jurisdiction, which if not addressed could potentially affect the safety
conscious work environment at the Callaway Plant.
The team identified one finding for failure to determine whether you had a non-conservative
technical specification surveillance requirement.
The team attributed this to improper processing of
operating experience. This finding violated NRC requirements. However, because of the finding
had very low safety significance and because the finding had been entered into your corrective
action program, the NRC is treating this findings as a noncited violation, in accordance with
Section VI.A.1 of the NRC's Enforcement Policy. In addition, one licensee-identified violation of
very low safety significance is listed in this repor
t. If you contest the violations or the significance
of the violations, you should provide a response within 30 days of the date of this inspection report.
Include the basis for your denial, to the U. S. Nuclear Regulatory Commission, ATTN: Document
Control Desk, Washington, D.C. 20555-0001, with copies to the Regional Administrator, U. S.
Nuclear Regulatory Commission, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas,
76011; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington,
D.C. 20555-0001; and the NRC Resident Inspector at the Callaway Plant.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public
inspection in the NRC Public Document Room
or from the Publicly Available Records (PARS)
component of NRC's document system (ADAMS).
ADAMS is accessible from the NRC web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Linda J. Smith, Chief
Engineering Branch 2
Division of Reactor Safety
Docket: 50-483
License: NPF-30
Enclosure:
John O'Neill, Esq. Pillsbury Winthrop Shaw Pittman LLP
2300 N. Street, N.W.
Washington, DC 20037
Scott A. Maglio, Assistant Manager
Regulatory Affairs
AmerenUE
P.O. Box 620
Fulton, MO 65251
Missouri Public Service Commission
AmerenUE
- 3 -Governor's Office Building
200 Madison Street
P.O. Box 360
Jefferson City, MO 65102-0360
H. Floyd Gilzow
Deputy Director for Policy
Missouri Department of Natural Resources
P. O. Box 176
Jefferson City, MO 65102-0176
Rick A. Muench, President and
Chief Executive Officer
Wolf Creek Nuclear Operating Corporation
P.O. Box 411
Burlington, KS 66839
Kathleen Smith, Executive Director and
Kay Drey, Representative
Board of Directors Missouri Coalition
for the Environment
6267 Delmar Boulevard, Suite 2E
St. Louis City, MO 63130
Lee Fritz, Presiding Commissioner
Callaway County Courthouse
10 East Fifth Street
Fulton, MO 65251
Les H. Kanuckel, Manager
Quality Assurance
AmerenUE
P.O. Box 620
Fulton, MO 65251
Director, Missouri State Emergency
Management Agency
P.O. Box 116
Jefferson City, MO 65102-0116
AmerenUE
- 4 -Scott Clardy, Director Section for Environmental Public Health
Missouri Department of Health and
Senior Services
P.O. Box 570
Jefferson City, MO 65102-0570
Luke H. Graessle, Manager
Regulatory Affairs
AmerenUE
P.O. Box 620
Fulton, MO 65251
Thomas B. Elwood, Supervising Engineer
Regulatory Affairs and Licensing
AmerenUE
P.O. Box 620
Fulton, MO 65251
Certrec Corporation
4200 South Hulen, Suite 422
Fort Worth, TX 76109
Keith G. Henke, Planner III
Division of Community and Public Health
Office of Emergency Coordination
Missouri Department of Health and
Senior Services
930 Wildwood,
P.O. Box 570
Jefferson City, MO 65102
Technical Services Branch Chief
FEMA Region VII
2323 Grand Boulevard, Suite 900
Kansas City, MO 64108-2670
Ronald L. McCabe, Chief
Technological Hazards Branch
National Preparedness Division
DHS/FEMA
9221 Ward Parkway
Suite 300
Kansas City, MO 64114-3372
AmerenUE
- 5 -Electronic distribution by RIV:
Regional Administrator (EEC) DRP Director (DDC)
DRS Director (RJC1) DRS Deputy Director (TWP) Senior Resident Inspector (DMD) Branch Chief, DRP/B (VGG) Senior Project Engineer, DRP/B (RWD) Team Leader, DRP/TSS (CJP) RITS Coordinator (MSH3) DRS STA (DAP) JTAdams, OEDO RIV Coordinator (JTA) ROPreports
CWY Site Secretary (DVY)
SUNSI Review Completed:
GAP ADAMS: Yes Initials:
GAP
Publicly Available Non-Sensitive
S:\_REPORTS\CW2008-06PI&R-gap.wpd
SRI:EB2 RI:PBB RI:EB2 RI:EB2 RI:EB2 GAPick/tek
JRGroom PAGoldberg
SMAlferink
EDUribe /RA/ /RA/ /RA/ /RA/ /RA/ 04/ 8 /08
04/8/08 04/7/08 04/ 9/08 04/8/08 SPE:PBB C:EB2 ACES C:PBB C:EB2 RWDeese LJSmith HAFreeman
VGGaddy LJSmith /RA/ /RA/ /RA/ /RA/ /RA/ 04/ 9/08 04/14/08 04/9/08 04/14/08 04/21/08 OFFICIAL RECORD COPY
T=Telephone E=E-mail F=Fax
- 1 - Enclosure
ENCLOSURE U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket: 50-483 License: NPF-30
Report Number:
Licensee:
AmerenUE
Facility: Callaway Plant
Location:
Junction Highway CC and Highway O
Fulton, Missouri
Dates: February 11 - 15, and March 10 - 14, 2008
Team Leader:
G. Pick, Senior Reactor Inspector, Engineering Branch 2
Inspectors:
R. Deese, Senior Project Engineer, Branch B, Division of Reactor Projects
J. Groom, Resident Inspector, Callaway Plant
S. Alferink, Reactor Inspector, Engineering Branch 2
P. Goldberg, Reactor Inspector, Engineering Branch 2
E. Uribe, Reactor Inspector, Engineering Branch 2
Approved By:
Linda Smith, Chief
Engineering Branch 2
Division of Reactor Safety
- 2 - Enclosure
SUMMARY OF ISSUES
IR 05000483/2008006; 2/11/2008 - 3/14/2008; Callaway Plant; Biennial inspection of the
identification and resolution of problems
One senior reactor inspector, one senior project engineer, three reactor inspectors, and a resident
inspector conducted the inspection. The team identified one noncited violation during this inspection.
The significance of most findings is indicated by their color (Green, White, Yellow, Red) using
Inspection Manual Chapter 0609, "Significance Determination Process." Findings for which the
Significance Determination Process does not apply may be Green or be assigned a severity level
after NRC management review. The NRC's program for overseeing the safe operation of
commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process,"
Revision 4, dated December 2006.
Identification and Resolution of Problems
The team reviewed 246 Callaway Action Requests, several job orders, engineering evaluations,
associated root and apparent cause evaluations, and other supporting documentation to assess
problem identification and resolution activities. The team reviewed an additional 124 Callaway Action
Requests related to specific areas - essential service water, component cooling water, 480 Vac
auxiliary contacts and safety conscious work envir
onment. Based on the sample selected for review, the team concluded the licensee continued to have challenges in the area of prioritization and
evaluation, which require additional effort. The team also noted that licensee performance related to
problem identification and resolution had improved. The team determined the licensee had used the
self-assessment process and quality assurance organiza
tion to improve site performance. The team
determined the improvement resulted from correct
ive action process impr
ovements implemented in
January 2007, and management oversight changes impl
emented following receipt of substantive
cross-cutting issue in problem identification and resolution.
The team determined that the licensee had initiated actions that improved the quality of their
operability assessments, operational decision-making, and knowledge of the detailed design and
licensing basis since the last evaluation. The graduated approach to assigning cause evaluations for
conditions adverse to quality and the change that required the Callaway Action Request screening
committee to review all Callaway Action Requests provided increased assurance in the ability of the
licensee to identify and effectively resolve conditions adverse to quality.
The team determined that the licensee properly evaluated industry operating experience when
performing root cause and higher tier cause evaluations; however, the licensee had continued
challenges effectively evaluating industry operating experience.
The team determined that licensee audits and assessments continued to be detailed, probing, and
self-critical. The licensee continued to use benchmarking of industry best practices and third party
evaluations that improved the corrective action pr
ogram performance during this assessment period.
The licensee had effectively implemented performanc
e improvements to address the substantive
cross-cutting issue (refer to March 2, 2007, End of Cycle letter) related to evaluating actions required
for conditions adverse to quality as demonstrated by the decreased number of findings in the latter
half of this assessment period and lower affect that poor evaluations had on the facility. However, the licensee will need to apply additional effort to a
ffect improvements.
The improving performance
resulted from increased management involvement in
the corrective action program and in daily
activities.
- 3 - Enclosure
Because of the increased number of allegations at the facility in Calendar Year 2007, including
several discrimination concerns, the team interviewed more personnel than normal to assess the
safety conscious work environment at the Callaway Plant. The team documented the nature of the
concerns and the increased scope of the evaluations in Attachment 3. The team determined that not
all individuals were comfortable using all of the methods available to them for reporting concerns;
however, all personnel would have used at least one of
the methods available for reporting a safety
concern. In addition, the team determined that the employee concerns program requires more
visibility and that not all personnel had confidence in the employee concerns program. The team
determined that our review results remained consistent with other safety culture surveys that
Callaway Plant had completed within the last year. The team determined that some general culture
and work environment issues continued to be present from the last assessment that were outside
NRC regulatory jurisdiction, which if not addressed could potentially affect the safety conscious work
environment at the Callaway Plant.
A. Inspector-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green. The team identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," because the licensee failed to ensure that Technical
Specification Surveillance Requirements for the NK11 and NK14 safety-related batteries
established limits that met the design requirements. Specifically, until questioned by the team
the licensee failed to determine the required design value needed to assure plant safety as
requested in Callaway Action Request 200706561. The licensee determined
that 69 micro-ohms should be the actual allowed inter-cell voltage limit to meet the design
requirements versus an allowed Technical Specification limit of 150 micro-ohms.
The performance deficiency associated with this finding involved the failure to ensure that the
NK11 and NK14 safety-related batteries would remain operable if all the inter-cell connections
measured 150 micro-ohms as allowed by
Technical Specification Surveillance
Requirements 3.8.4.2 and 3.8.4.5. This finding was greater than minor because it was
associated with the Mitigating Systems cornerstone attribute of maintenance and testing and
affects the associated cornerstone objective to ensure the availability, reliability, and
capability of systems that respond to initiating events to prevent undesirable consequences.
Using Manual Chapter 0609.04, "Phase 1 - Initial Screening and Characterization of
Findings," the finding was determined to have very low safety significance because it was a
design deficiency confirmed not to result in loss of operability. The finding had a cross-cutting
aspect in the area of problem identification and resolution associated with operating
experience because the licensee failed to evaluate
in a timely manner relevant internal and
external operating experience P.2(a) (Section 4OA2.e).
B. Licensee-Identified Violations
Violations of very low safety significance, which were identified by the licensee have been
reviewed by the inspectors. Corrective actions taken or planned by the licensee have been
entered into the licensee's corrective action program. These violations and corrective actions
are listed in Section 4OA7 of this report.
- 4 - Enclosure
REPORT DETAILS
4 OTHER ACTIVITIES (OA)
4OA2 Identification and Resolution of Problems
The team based the following conclusions, in part, on all issues that the team reviewed during
the assessment period, which ranged from November 1, 2006, to March 14, 2008. The team
divided the issues into two groups. The first group (current issues) included problems
identified during the assessment period where at least one performance deficiency occurred
during the assessment period. The second group (historical issues) included issues identified
during the assessment period but had performance deficiencies that occurred outside the
assessment period.
a. Assessment of the Corrective Action Program Effectiveness
(1) Inspection Scope
The team reviewed items from across the seven
cornerstones to verify that the licensee:
(1) identified problems at the proper threshold and entered them into the corrective action
system, (2) adequately prioritized and evaluated issues, and (3) established effective and
timely corrective actions to prevent recurrence.
The team performed field walk downs of the
component cooling water system and the 480 Vac breakers to inspect for deficiencies that
personnel should have entered into the corrective action program. The team reviewed
operator logs and station job orders to ensure personnel entered conditions adverse to quality
into the corrective action program. Additionally, the team reviewed a sample of
self-assessments, trending reports, system health reports, and various other documents
related to the corrective action program.
The team interviewed station personnel, attended screening committee, leadership and
Corrective Action Review Board meetings, and
evaluated corrective action documentation to
determine the threshold for entering problems into their corrective action program. The
meetings assisted the team with their assessment of the threshold of prioritization and
evaluation of identified issues. The team performed a historical review of Callaway Action
Requests written over the last 5 years that addressed the component cooling water system
and the 480 Vac breakers.
The team reviewed plant records, primarily Callaway Action Requests and job orders, to verify
that the licensee developed and implemented corrective actions for identified problems,
including corrective actions to address common cause or generic concerns. The team
sampled specific technical issues to evaluate the adequacy of operability determinations.
Additionally, the team reviewed Callaway Action Requests that addressed past
NRC-identified and self-identified violations to ensure that the corrective actions addressed
the issues as described in the inspection reports. The team reviewed a sample of corrective
actions closed to other Callaway Action Requests, job orders, or other processes
to ensure that the licensee had appropriately im
plemented the corrective actions in a timely
manner.
- 5 - Enclosure
(2) Assessments
(a) Assessment - Effectiveness of Problem Identification
The licensee identified deficiencies as conditions adverse to quality and entered them into the
corrective action program. From the inspecti
on sample, the team identified only one example
for failure to identify excessive nuisance alarms as a condition adverse to quality.
Consequently, the licensee did not resolve the nuisance alarms in a timely manner.
Otherwise, the team determined that the licensee had established an appropriate threshold
for identifying adverse conditions. The team determined that the licensee had lowered their
identification threshold, which improved their ability to identify conditions adverse to quality
during this assessment period. In addition, the team verified that the screening committee
evaluated all Callaway Action Requests to ensure that they identified any related adverse
condition no matter the Callaway Action Request type (i.e., adverse condition, business
tracking, training request, or request for resolution).
In response to the previous inspection, the team verified that the licensee had eliminated
Action Notices, which had resulted in violations during the previous inspection for various
reasons. The team verified that the licensee had appropriately evaluated open Action Notice
Callaway Action Requests to verify whether any adverse conditions required a cause
evaluation and more timely corrective actions. The team evaluated and found no instances of
a Significance Level 6 Callaway Action Request tracking an adverse condition. The licensee
had replaced the Action Notices with the business tracking Significance Level 6 Callaway
Action Requests.
The team determined that licensee quarterly trend reports appropriately discussed and
tracked resolution of identified trends. The licensee recently initiated actions to lower the
threshold for identifying adverse trends so they could better utilize this tool to improve their
performance. The team verified that the licensee identified and recognized their adverse
trends, which represented improved performance
since the last corrective action program
inspection.
Current Issues
Example: From interviews with security officers, the team determined that audible alarms on
a security feature sounded too often and decreased the sensitivity of the officers to monitor
the alarms as expected. The team determined that, although the security personnel and the
system engineer knew about the issue, no one had initiated a Callaway Action Request
documenting the excessive number of nuisance
alarms. Officers had verbally reported and
sent e-mails to the system engineer who had contacted the vendor and made adjustments,
which had reduced the alarms; however, the alarms continued. The team determined that
this deficiency was minor since the security feature remained capable of performing its
intended function. The licensee documented this deficiency in Callaway Action
Request 200801877.
- 6 - Enclosure
Historical Issues
Example 1: Licensee personnel failed to initiate Callaway Action Requests for conditions adverse to quality, as required by 10 CFR Part 50, Appendix B, Criterion XVI. Documenting
these degraded conditions may have prevented a main steam line water hammer event in
June 2006 and may have identified, in August 2005, an additional high point air trap in the
Train A safety injection discharge piping that could impact system operability (NRC Inspection
Report 05000483/2006012-01).
Example 2: The team considered two Action Notice Callaway Action Requests (200602989
and 200608806), identified during this inspection, as inappropriately classified conditions
adverse to quality contrary to 10 CFR Part 50, Appendix B, Criterion V, and their corrective
action program (NRC Inspection Report 05000483/2006012-02).
Example 3: The licensee failed to identify three Action Notice Callaway Action Requests as
conditions adverse to quality (200603636, 200604166 and 200605466); however, the team
determined these examples represented minor findings.
Example 4: During audits from January 2005 through October 9, 2006, the licensee identified
63 Callaway Action Requests that personnel had initiated as action notices rather than
conditions adverse to quality. Quality Assurance issued Callaway Action Request 200606131
to document that personnel incorrectly listed six deficiencies as Action Notice Callaway Action
Requests instead of conditions adverse to quality. During review of the third quarter audit
data, the team identified an additional eight Action Notice Callaway Action Requests that the
audit process should have identified. This represented a 33 percent increase. The team
confirmed that the licensee had appropriately determined that personnel had misclassified
0.5 percent of the Action Notice Callaway Action Requests; however, the team verified none
of the misclassified items documented significant deficiencies.
Example 5: Plant operations and security had several prior opportunities to identify a
degraded fire door indicating personnel did not have a low threshold for identifying issues
(Inspection Report 05000483/2006005-01).
(b) Assessment - Effectiveness of Prioritization and Evaluation of Issues
The licensee did not always appropriately prioritize and evaluate conditions adverse to
quality. The team identified a large number of examples of poor evaluation that indicated
additional effort is needed in this area. Specifically, the team determined the licensee had:
two examples related to poor prioritization (E
xamples 1 and 3), two examples resulting from
personnel not fully implementing plant processe
s (Examples 2 and 8), one example of failure
to evaluate longstanding design issues (Example 6); and six examples that resulted from
ineffective evaluations (Examples 4, 5, 7, 9, 10 and 11). The team verified that the Callaway
Action Request screening process resulted in appropriately reassigning the significance level
of Callaway Action Requests commensurate with their safety significance (Example 12).
Similar to the last assessment, outside organizations continued to identify that the licensee
did not always perform effective evaluations
of conditions adverse to quality; consequently, the licensee continued to emphasize and prov
ide management oversight. The licensee had
implemented product quality evaluations in E
ngineering and had developed tools to evaluate,
- 7 - Enclosure
grade, and provide feedback on the Significance Level 1, Level 2 and selected Level 3
adverse condition Callaway Action Requests.
The team specifically evaluated the corrective
actions related to operability evaluations and
root cause evaluations, which the last biennial problem identification and resolution inspection
identified as deficient areas. The team concluded that the actions taken by the licensee (e.g.,
reinforced expectations, training of engineers and operators in design and license bases and
performance of operability evaluations, and impr
oved tiered root cause evaluation guidance)
had improved the quality of operability evaluations. However, the team determined the large
number of current examples for failure to adequately evaluate issues indicates the licensee
will need to take additional action in this area.
In response to external organization evaluations and as corrective action to the substantive
cross-cutting issue related to problem identification and resolution for inadequate evaluations
(refer to March 2, 2007, End of Cycle letter), the licensee initiated numerous actions to
strengthen the screening committee and other aspects of the corrective action program. A
majority of the actions related to reinforcing expected behaviors through coaching.
Current Issues
Example 1: As of December 19, 2007, the licensee had not tested the essential service
water, component cooling water and containment spray pumps at 20 percent of full flow.
Subsequently, the licensee invoked Surveillance Requirement 3.0.2 and completed the
testing within the extended 25 percent surveillance interval. While no violation of
requirements resulted, the licensee had not im
plemented the requirements in a timely
manner. The licensee documented this deficiency in Callaway Action Request 200801400.
Example 2: The resident inspectors determined the licensee performed an inadequate
post-maintenance test after repairing a damaged trip breaker contact block. Specifically,
personnel failed to identify that the contacts affected the P-4 interlock; consequently, the
licensee restored the breaker to service without performing a post maintenance test of the P-4
interlock. Although this test failed to meet the requirements of 10 CFR Part 50, Appendix B,
Criterion XI, the inspectors determined the violation was minor because the licensee
adequately tested the breaker prior to exceeding the Technical Specifications allowed outage
time. The licensee documented this deficiency in Callaway Action Request 200800811.
Example 3: Quality assurance auditors documented in Callaway Action Request 200711176
that personnel had not properly re-screened Significance Level 6 Callaway Action
Request 200700560 to an adverse condition Significance Level 4 nor was a new adverse
condition identified once personnel determined that external operating experience applied to
Callaway Plant. The team concluded the deficiency was minor since no identified deficiency
resulted from the review.
Example 4: Engineering approved deviating from
the established motor-driven auxiliary
feedwater pump coupling tolerances provided by
the vendor without considering the impact
on the thrust bearing (Inspection Report 05000483/2007004-02).
- 8 - Enclosure
Example 5: The resident inspectors determined that the licensee failed to evaluate the extent
of condition for micro-biologically induced corrosion of essential service water piping.
Specifically, the licensee failed to perform ultrasonic testing under the American Society of
Mechanical Engineers Code identification bands (Inspection Report 05000483/2007003-03).
Example 6: The resident inspectors determined that the licensee failed to evaluate a
longstanding ultimate heat sink cooling tower design issue, which resulted in allowing water to
flow over the fill below freezing conditions
contrary to vendor recommendations (Inspection
Report 05000483/2007003-01).
Example 7: The resident inspectors determined that the licensee failed to evaluate
micro-biologically induced corrosion of essential service water large-bore piping to ensure
the resolutions addressed causes and extent of condition (Inspection Report 05000483/2007002-03).
Example 8: After an operator could not locate a block switch during a surveillance test, the
control room supervisor revised the procedure without verifying the correct block switch
identifier. Consequently, during the test when the operator defeated the identified (wrong)
train block feature, the opposite rain control room ventilation isolated (Inspection
Report 05000483/2007002-01).
Example 9: Operations performed an inadequate review to establish compensatory actions of an
operator work around, which reflected a failure to thoroughly evaluate a problem to ensure
resolutions address causes and extent of condition (Inspection Report 5000483/2006005-05). Example 10
- Engineering failed to thoroughly evaluate residual heat removal relief valve
problems to ensure resolutions addressed causes and extent of conditions (Inspection
Report 05000483/2006009-06).
Example 11
- Callaway Action Request 200801664 described that personnel failed to document an adverse condition that required evaluation. Specifically, after Quality Assurance
identified in Audit AP06-003 that the turbine-
driven auxiliary feedwater pump exhaust line was
not adequately protected from missile hazards, Engineering initiated Request for
Resolution 2006006712; however, personnel failed to identify this as a potential
non-conforming condition in an adverse condition Callaway Action Request. Additionally, the
resident inspectors questioned if the current configuration was consistent with the licensing
basis.
Example 12
- After reviewing significance level reassignments for Callaway Action Requests
that occurred during this assessment period, the team determined that the licensee had
appropriately classified the significance level for Callaway Action Requests and did not
identify a negative trend from this review. Specifically, for the population reviewed, the
licensee assigned a significance level to 65 items when no significance level had been
assigned, downgraded 25 items to a lower significance of which 15 received apparent cause
evaluations and 6 received a cause evaluation, and upgraded 53 items of which 34 received
cause evaluations.
- 9 - Enclosure
Historical Issues
Example 1: After questioning by the NRC, the licensee documented in Callaway Action
Requests 200609233 and 200500238 a less than adequate operability determination for a
degraded main steam isolation valve accumulator, which resulted in failure to implement the
required Technical Specification 3.7.2 actions (Inspection Report 05000483/2006012-03).
Example 2: The NRC determined that the licensee failed to properly evaluate and correct
inadequate emergency procedures for the design basis large break loss of coolant accident,
as documented in Callaway Action Requests 200602565 and 200608102. Specifically, the
licensee repeatedly missed opportunities that had presented themselves in Callaway Action
Requests, NRC findings, and vendor technical bulletins to uncover inadequate guidance in
Procedure E-1, "Loss of Reactor or Secondary Coolant" (Inspection
Report 05000483/2006011-01).
Example 3: The team determined that the licensee failed to evaluate all vulnerable
emergency core cooling system piping subject to voiding in response to a previous
NRC-identified violation for ineffective corrective actions. The team determined the licensee
failed to meet the requirements of 10 CFR Part 50, Appendix B, Criterion XVI. Specifically,
the licensee did not design and install vents for a significant length of horizontal piping subject
to the same deficiency and containing some high points, as documented in Callaway Action
Request 200608466 (Inspection Report 05000483/2006012-04)
Example 4: The Maintenance Rule Expert Panel failed to adequately review the failure of
safety-related motor-operated valves, which prevented thoroughly evaluating the problem to
ensure resolutions address causes and extent of conditions (Inspection
Report 05000483/2006005-02).
Example 5: Engineering performed an inadequate 10 CFR 50.59 safety evaluation, which
resulted in a less than thorough evaluation of the problem to ensure resolutions addressed
causes and extent of conditions (Inspection Report 05000483/2006005-04).
(c) Assessment - Effectiveness of Corrective Actions
The licensee implemented effective corrective ac
tions to address conditions adverse to
quality because of process improvements.
The team determined the improvements
addressed the weaknesses identified in the last biennial problem identification and resolution
inspection, as evidenced by only a single licens
ee-identified failure to implement effective
corrective actions. The team concluded that less than adequate past corrective action
program performance continued to result in the discovery of latent engineering issues; for
example, the ongoing challenges imposed by corrosion of the essential service water piping.
The team evaluated the planned actions for these corrosion deficiencies and concluded that
the licensee made appropriate operational decisions and took interim measures to ensure
that the system remained operable until the next refueling outage when they plan to
implement the permanent corrective actions.
The licensee had implemented a number of improv
ements in January 2007 that increased the
effectiveness of the corrective action program. The changes included, in part: (1) improved
definition of a condition adverse to quality in order to lower the threshold, (2) more categories
for adverse conditions to allow for broke-fix and relieve the burden of performing apparent
- 10 - Enclosure
causes for low significance conditions adverse to quality, (3) improved guidance for
performing cause evaluations, including a quality checklist, and (4) improved guidance for
performing immediate operability determinations. The team found that this approach ensured
the licensee applied the appropriate level of resources to identified issues commensurate with
their safety significance or impact on the facility. The team found the procedure guidance
clear, concise, and useful to personnel implementing the corrective action program. The
team determined that many of these changes should address some of the concerns identified
during this inspection.
Current Issues
Example: The licensee determined that they had implemented ineffective corrective actions
for Callaway Action Request 200609621, which documented that personnel had failed to
secure Fire Door DSK15031. The corrective action involved communicating the importance
of reading and abiding to posted signs related to closing fire doors. Subsequently, additional
instances of the improperly secured fire door occurred (i.e., Callaway Action
Requests 200702037, 200702596, 200706810, and 200707100). After the license initiated
corrective actions for Callaway Action Request 200702596, which involved locking the door
pin to prevent unauthorized unlatching of the Fire Door DSK15031 stationary door, the
licensee had discovered two additional instances prior to implementing the modification. This
licensee-identified performance deficiency is documented in Section 4OA7.
Historic Issues
Example 1: In Callaway Action Request 200609075, the licensee identified the failure to take
effective corrective actions in response to Callaway Action Request 200205928, which
documented missing sacrificial anodes in the emergency diesel generator heat exchangers.
The team determined the licensee had missed an opportunity to correct this deficiency in
October 2004. The failure to have all required sacrificial anodes installed was of minor safety
significance since the heat exchanger remained operable.
Example 2: Callaway Action Request 200602995 described that personnel implemented
inappropriate corrective actions for Callaway Action Request 200602565. Specifically, the
NRC determined that the licensee made an ineffective procedure change related to
establishing component cooling water flow to the residual heat removal heat exchangers prior
to swap over to the containment recirculation sumps. The procedure change failed to prevent
a potential runout condition for the component cooling water pumps (Inspection
Report 05000483/2006011-02).
b. Assessment of the Use of Operating Experience
(1) Inspection Scope
The team examined licensee programs for revi
ewing industry operating experience. The
team selected a number of operating experience notification documents (NRC bulletins,
information notices, generic letters, 10 CFR Part 21 reports, licensee event reports, vendor
notifications, et cetera), which had been issued during the assessment period, to verify
whether the licensee had appropriately evaluated each notification for relevance to the facility.
The team then examined whether the licensee had entered those items, which had been
deemed relevant, into their corrective action progr
am. Finally, the team reviewed a number of
- 11 - Enclosure
significant conditions adverse to quality and conditions adverse to quality to verify if the
licensee had appropriately evaluated them for industry operating experience.
(2) Assessment
The team identified some weakness in licensee evaluation and processing of operating
experience. Specifically, failure to appropr
iately evaluate industry operating experience
contributed to two findings in this area. The team documented Example 1, which related to
untimely evaluation of applicable operating experience, in this inspection report. The team
determined that Example 2 documents failure to
effectively evaluate operating experience
because the licensee did not consider all areas subject to flooding. Any finding that results
from the failure to perform an appropriate flood analysis will be documented in the resident
inspector integrated report. The team determined that the licensee continued to effectively
assess industry operating experience during root cause and apparent cause evaluations of
significant conditions adverse to quality and conditions adverse to quality, respectively.
Current Issues
Example 1: The team determined that the licensee failed to determine in a timely manner
whether the acceptance criteria for Technical Specification Surveillance Requirement 3.8.4.5
demonstrated that the NK11 and NK14 safety-related batteries could meet the design
requirements. The licensee initiated Callaway Action Request 200706268 in response to
operating experience on July 10, 2007. The
licensee inappropriately requested extension
requests to complete their evaluation such that they had operated with this non-conservative
Technical Specification until challenged by the team (refer to Section 4OA2.e).
Example 2: In Callaway Action Requests 200502989 and 200607843, the licensee concluded
that the flooding analysis summary took no credit for flooding in areas above the lower levels
in each building. The team considered the evaluation inadequate because several flooding
analyses credit floor drains at elevations other than the basement. For example,
Calculation M-FL-07, "Flooding of the Aux Bldg Rms EL. 2047'6"," evaluated the impact of
flooding in the Control Room heating, ventilation and air conditioning room.
Historical Issues
Example: The licensee's corrective measures inappropr
iately used instrument uncertainty to
increase design margin (Inspection Report 05000483/2006009-05).
c. Assessment of Self-Assessments and Audits
(1) Inspection Scope
The team reviewed numerous audits, self-assessments, quality surveillances, and site
performance indicators. The team reviewed
program procedures and interviewed process
managers related to the performance improvem
ent group, the corrective action program, and
the Quality Assurance department. The team
evaluated the use of self- and third party
assessments, the role of Quality Assurance, and the role of the performance improvement
group related to licensee performance.
- 12 - Enclosure
(2) Assessment
The licensee continued to perform self-critical assessments, audits and evaluations. The
team noted that the factors that influenced the improvement identified during the last
corrective action program evaluation continued dur
ing this assessment period. Specifically,
the licensee used directed assessments to evaluate suspect or known areas of weakness.
The licensee implemented the recommendations and
findings of external self-assessments
that they requested. The licensee established processes to ensure increased management
oversight at all levels in the organization related to improved worker performance, adherence
to procedures, and conduct of root cause analyses.
Quality Assurance performed critical, detailed audits and surveillances of line
organizations (Example 2). The audit performance criteria had goals of excellence (e.g., third
party expectations and NRC inspection guidance) rather than compliance. The team
determined that the line organizations continued to use audits and surveillances as a tool to
improve their performance. For example, Qua
lity Assurance performed three surveillances of
critical activities related to the corrective actions planned for the essential service water
system corrosion issues (Example 1).
The team verified that the licensee implemented performance indicators and trended data that
should allow the managers to evaluate the progress of their actions to improve performance
related to human performance and corrective action program deficiencies.
The licensee performed several self-assessments related to safety culture during this
assessment period. The team evaluated the self-assessments and concluded that the
licensee conducted critical evaluations of their safety culture and the safety conscious work
environment (Examples 3 and 4). The licensee initiated Callaway Action Request 200800944
to perform a higher tier apparent cause evaluation and to ensure that they addressed the
assessment recommendations. Recommendations included developing a differing
professional opinion process, developing a process to review proposed disciplinary actions
and performing benchmarking of other programs.
Current Issues
Example 1: Quality Assurance performed several critical surveillances related to corrosion in
the essential service water system, which related to the examination scope of the piping, the
repairs of the affected piping, and the suitability to operate during Cycle 16.
Example 2: Audit AP07-013, "Corrective Action Program
," provided critical evaluations of the corrective action program areas that previously had problems, which included operability
evaluations, prioritization, and management oversight. The team verified that the line
organization had implemented appropriate corrective actions to address the numerous
adverse conditions identified in the audit.
Example 3: The licensee performed a Synergy Safety
Culture Assessment in February 2007.
The Safety Culture Survey included an assessment of the general culture and work
environment and the safety conscious work envir
onment. The safety culture survey identified
that the licensee had significant challenges related to resources/work load and change
management that affected the trust of the workers in management. The survey identified that
no chilling effect or safety conscious work environment concerns existed. However, the
- 13 - Enclosure
results indicated, the general culture and work environment concerns could affect the nuclear
safety culture and the safety conscious work
environment, if not addressed by management.
Example 4: Because of the large number of allegations at the facility in Calendar Year 2007, the licensee requested an independent assessment to evaluate their safety conscious work
environment in February 2008. The assessment determined that the licensee had maintained
a safety conscious work environment and that no chilled work environment existed. The
assessment team concluded work environment
and corrective action program issues had the
potential, if not addressed, to erode the willingness of individuals to bring issues forward
using the corrective action program.
d. Assessment of Safety Conscious Work Environment
(1) Inspection Scope
The team evaluated this area by reviewi
ng self-assessments and audits, interviewing
personnel regarding the safety conscious work environment at Callaway Plant using the
questions provided in Inspection Procedure 71152B, and interviewing the Employee
Concerns Coordinator. Specifically, the
team reviewed the Independent Assessment of the
Callaway Plant Safety Conscious Work Environment performed in February 2008, the 2007
Safety Culture Assessment, and three department
specific safety culture assessments.
The team conducted formal interviews with 93 personnel in response to the large number of
allegations received at Callaway Plant, which had identified concerns with the safety
conscious work environment. Normally, the inspection interviews 15 - 25 personnel. The
team conducted the interviews with plant personnel to assess their willingness to raise safety
issues and use the corrective action program. Further, the team assessed whether conditions
existed that would challenge the establishment
of a safety-conscience work environment.
The team documented the details of the review in Attachment 3, "Concerns Evaluated." Note:
Examples 1 - 5 below have correspondi
ng numbers in Attachment 3.
(2) Assessment
From interviews and review of safety con
scious work environment assessments, the team
determined that the licensee maintained a safety conscious work environment. However,
there were some issues identified that were outside NRC regulatory jurisdiction that, if not
addressed by the licensee, could potentially affect
the safety conscious work environment at
the Callaway Plant. Overall, interviewed employees felt free to enter issues into the
corrective action program as well as, raise nuclear safety concerns to their supervision, the
employee concerns program, and the NRC.
During interviews, personnel generally
expressed confidence that the licensee had established an appropriate threshold for
documenting nuclear safety issues and that iss
ues entered into the corrective action program
would be appropriately addressed.
The 2007 Safety Culture Assessment concluded that the licensee, generally, has a solid
safety culture and that site personnel have nuclear safety as a core value. However, the
safety culture assessment identified several groups that required additional attention. The
assessment also identified areas that management needed to address related to the general
culture and work environment that incl
uded implementing appropriate change management, better management of resources, workload, staffing and priorities. The team verified that the
- 14 - Enclosure
licensee had initiated Callaway Action Requests and had implemented appropriate corrective
actions for the identified deficiencies.
Consistent with the 2005 Safety Culture A
ssessment, the 2007 Safety Culture Assessment,
and the February 2008 Safety Conscious Work Environment self-assessment, the team
determined that, generally, employees express
ed willingness to use the corrective action
program and raise nuclear safety concerns. The team determined that not all individuals
were comfortable using all of the methods available to them for reporting concerns; however,
all personnel would have used at least one of the methods available for reporting a safety
concern. Also, the licensee continues to have challenges related to visibility of the Employee
Concerns Program and the willingness of some people to use the Employee Concerns
Program (Examples 2 and 3).
In response to numerous concerns (Examples 1 - 3) the team evaluated whether the licensee
encourages personnel to identify problems. The team determined that management
encourages personnel to identify problems and raise concerns using the corrective action
program or through discussions with their supervisor. The team determined from this sample
that no chilled work environment existed at Callaway Plant. However, within the security
department, some individuals would not raise personal concerns. From review of two
technical concerns (Examples 4 and 5), the team determined that the licensee had resolved
the issues commensurate with their safety significance and regulatory requirements.
Current Issues
Example 1: The team evaluated whether the licensee had established a culture where
personnel did not feel comfortable raising concerns and where management did not want to
hear about problems. The team determined that management encouraged personnel to raise
concerns. During interviews, all personnel indicated that they would raise nuclear safety
concerns; however, some personnel indicated that they would not raise personal issues
unrelated to nuclear safety because they belie
ved that management would take no actions.
Example 2: The team evaluated how employees us
ed the employee concerns program. The
team determined that most, but not all, em
ployees would use the employee concerns
program if they did not get satisfaction from us
e of the corrective action program or from their
supervisor. However, two individuals did not trust the employee concerns program and would
rather talk to the NRC. The team determined that 30 percent of the personnel interviewed
had a misconception of the employee concerns program (e.g., did not know the program
coordinator had changed, did not know the purpose of the employee concerns program, did
not know the location of the coordinator's office, et cetera).
Example 3: The team evaluated whether a chill
ed work environment existed in any
department but focused particularly in the training, radiation protection, operations and
security organizations. From the interviews, the team determined that all individuals would
raise concerns by using one of the four methods - corrective action program, supervisor,
employee concerns program, or NRC. However, the team determined that not all individuals
would use all of the methods. Specifically, one indi
vidual would only talk with their supervisor.
Example 4: The team reviewed whether the licensee timely resolved the condition that
damaged to the residual heat removal pump suction relief valves. The licensee missed an
opportunity to correct the error in March 2007 when a design error identified by a vendor
- 15 - Enclosure
prevented issuing the modification in time for implementation. The team verified that the
licensee scheduled the modification for Refueling Outage 16 in October 2008. No violation
resulted since the licensee will implement the
modification commensurate with its safety
significance.
Example 5: The team reviewed whether the licensee took the appropriate actions to not
pursue a license amendment specifically prohibiting plant operation with both cold
overpressure mitigation systems out of service
with the reactor coolant system solid. Since
the licensee had no shutdown probabilistic safety analysis, the team could not quantitatively
determine whether it was safer to operate without cold overpressure mitigation system valves
under solid plant conditions or saturated plant conditions. Further, the team determined that
the licensee took appropriate actions to request an extension of the period allowed for
establishing a reactor coolant system vent path from 8 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Example 6: As discussed in the example in Section 4OA2.a(2)(a), security officers had
identified that a specific security feature generated excessive nuisance alarms. The team
determined that the licensee had initiated Callaway Action Requests related to other security
organization issues that included a safety hazard while performing patrols and a health
hazard. The team determined during interviews that these deficiencies did not affect the
willingness of security officers to report deficiencies to their supervisor or to use the corrective
action program.
e. Specific Issues Identified During This Inspection
Introduction. The team identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," because the licensee failed to ensure that Technical
Specification Surveillance Requirements for the NK11 and NK14 safety-related batteries
established limits that met the design requirements. Specifically, until questioned by the team
the licensee failed to determine the required design value needed to assure plant safety. The
licensee determined that 69 micro-ohms should be the actual allowed inter-cell voltage limit to
meet the design requirements versus an allowed Technical Specification limit of
150 micro-ohms.
Description. The team reviewed Callaway Action Request 200706561 that the licensee
initiated July 10, 2007, to evaluate the adequacy of Technical Specifications 3.8.4 and 3.8.5
for the NK11 and NK14 safety-related batteries. The licensee initiated Callaway Action
Request 200706561 because external industry operating experience had identified that some
licensees had not documented the basis for the 150 micro-ohm limit specified in Technical
Specification Surveillance Requirements 3.8.4.2 and 3.8.4.5 and, in some cases, challenged
the operability of the safety-related batteries when the limit was applied to each inter-cell
connection. Callaway Action Request 200706561, Action 4 requested an evaluation to
determine the appropriate maximum inter-cell resistance value for station batteries. The team
determined that the licensee had not completed their evaluation of Surveillance
Requirements 3.8.4.2 and 3.8.4.5 at the time of the inspection.
The team determined that Procedure APA-ZZ-01400, Attachment 4, "Industry Operating
Experience Screening Committee Guidelines," Section 4.b, states that Operating Experience
Callaway Action Requests should be assigned due dates not to exceed 60 days to ensure a
timely determination of plant impact. The team determined that, while the licensee had
assigned a completion date within 60 days, personnel had obtained several extensions that
- 16 - Enclosure
prevented assessing the significance or facility impact within the initial 60 days specified in
Procedure APA-ZZ-01400. Consequently, these ext
ensions delayed evaluating Surveillance
Requirements 3.8.4.2 and 3.8.4.5. Following discussion with the team, the licensee
evaluated the current design assumptions in Calculation NK-05, "Class 1E Battery Capacity,"
Revision 6, which the licensee had used to size the NK11 and NK14 safety-related batteries.
The licensee's evaluation found that the licensee based the battery sizing on an end
discharge voltage of 108.6 volts correlating to a maximum inter-cell resistance of 86.1
micro-ohms. Since the 86.1 micro-ohms limit
was less than that allowed by Surveillance
Requirements 3.8.4.2 and 3.8.4.5 (indicating a nonconservative Technical Specification), the
licensee performed an additional calculation to determine an appropriate inter-cell resistance
to support battery operations. Upon completing Calculation NK-10, "NK11 Accident Case,"
Revision 1, the licensee would need to limit the maximum inter-cell resistance to
69 micro-ohms to assure battery operability.
Following discovery of the non-conservative inter-cell resistance, the licensee performed a
prompt operability determination and concluded the NK11 and NK14 safety-related batteries
remained operable since past surveillances had measured inter-cell resistances well below
69 micro-ohms. The licensee implemented compensatory measures as described in NRC
Administrative Letter 1998-10, "Dispositioning of Technical Specifications That Are Insufficient
to Assure Plant Safety," to assure the new inter-cell resistance limit of 69 micro-ohms would
not be exceeded. The licensee intended to continue the interim compensatory measures until
they revised their Technical Specifications.
Analysis. The performance deficiency associated with this finding involved the failure to
ensure that the NK11 and NK14 safety-related batteries would remain operable if all the
inter-cell connections measured 150 micro-ohms as allowed by Technical Specification
Surveillance Requirements 3.8.4.2 and 3.8.4.5. This finding was greater than minor because
it was associated with the Mitigating Systems cornerstone attribute of maintenance and
testing and affects the associated cornerstone objective to ensure the availability, reliability,
and capability of systems that respond to initiating events to prevent undesirable
consequences. Using Manual Chapter 0609.04, "Phase 1 - Initial Screening and
Characterization of Findings," the finding was determined to have very low safety significance
because it was a design deficiency confirmed not to result in loss of operability. The finding
had a crosscutting aspect in the area of problem identification and resolution associated with
operating experience because the licensee failed to
evaluate in a timely manner relevant
internal and external operating experience P.2(a).
Enforcement. Title Ten Code of Federal Regulations Part 50, Appendix B, Criterion III, "Design Control," requires, in part, that the licensee establish measures to assure that
applicable regulatory requirements and the design basis for structures, systems and
components are correctly translated into specifications, drawings, procedures, and
instructions. Additionally, design control measur
es shall provide for verifying or checking the
adequacy of design, such as by the performance of design reviews, by the use of alternate or
simplified calculation methods, or by the performance of a suitable testing program. Contrary
to the above, prior to March 13, 2008, the licensee failed to verify that the 150 micro-ohm
criterion specified in Surveillance Requirement 3.8.4.2 and 3.8.4.5 would be sufficient to
ensure safety-related battery operability in accordance with the design basis. Once
challenged, the licensee determined that a maximum inter-cell resistance of 69 micro-ohm
could not be exceeded to ensure the battery remained operable. This finding is of very low
safety significance and has been entered into the corrective action program as Callaway
- 17 - Enclosure
Action Request 200802195, this violation is being treated as a noncited violation consistent
with Section VI.A of the NRC Enforcement Policy: NCV 05000483/2008006-01,
"Nonconservative Technical Specification for battery inter-cell connection resistances."
4OA6 Exit Meeting
On March 14, 2008, the team presented their inspection results to Mr. A.C. Heflin, Vice
President, and other members of his staff who acknowledged the findings. The inspectors
returned all proprietary and confidential information provided during the inspection.
4OA7 Licensee Identified Violations
The following violation of very low safety significance (Green) was identified by the licensee
and is a violation of NRC requirements that meets the criteria of Section VI of the NRC
Enforcement Policy, NUREG-1600, for being dispositioned as a noncited violation.
Technical Specification 5.4.1.d requires that AmerenUE maintain a fire protection program.
Procedure APA-ZZ-0071, "Control of Impairments of Fire Protection Systems and
Components," requires personnel to maintain the integrity of plant fire doors. Contrary to this,
security officers identified during routine tours on March 6, March 20, July 18, and
July 31, 2007, which personnel failed to maintain the integrity of Fire Door 15031. This
licensee documented these deficiencies in Callaway Action Requests 200702037, 200702596, 200706810, and 200707100, respectively. This finding is of very low safety
significance because the exposed fire area contained no potential damage targets that are
unique from those in the exposing fire area.
Attachment: Supplemental Information
A1-1 Attachment
1 SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee B. Barton, Manager, Training
G. Belchik, Supervisor, Operations
M. Daly, Supervising Engineer, Corrective Action Program
F. Diya, Plant Director
M. Dunbar, Protective Services Supervisor
R. Farnam, Manager, Radiation Protection
L. Graessle, Manager, Regulatory Affairs
A. Heflin, Vice President - Nuclear
T. Herrmann, Vice President Engineering
T. Hermann, Manager, Maintenance
D. Hollabaugh, Superintendent Protective Services
L. Kanuckel, Manager, Quality Assurance
G. Kremer, Supervising Engineer
P. McKenna, Manager, Outage Planning and Scheduling
M. McLachlan, Manager, Engineering Services
S. Maglio, Assistant Manager, Regulatory Services
B. Miller, Supervisor, Performance Improvement
E. Olsen, Superintendent, Performance Improvement
S. Petzel, Engineer, Regulatory Affairs
J. Small, Superintendent, Chemistry and Radioactive Waste
T. Steele, Employee Concerns Program Coordinator
NRC
R. Caniano, Director, Division of Reactor Safety (telephonically)
J. Groom, Resident Inspector, Callaway Plant
L. Smith, Chief, Engineering Branch 2, Division of Reactor Safety
V. Watkins, Deputy Director, Division of Reactor Safety
LIST OF ITEMS OPENED AND CLOSED
Opened and Closed
NCV Nonconservative Technical Specification for Battery
Inter-cell Connection Resistances (Section 4OA2.e)
A1-2 Attachment
1 LIST OF DOCUMENTS REVIEWED
Audits, Self-Assessments and Surveillances
AP07-013, "Quality Assurance Audit of Corrective Action," dated December 13, 2007
SA07-PI-C02, "Closing Condition Reports (CARS) to a Procedure Change Process,"
dated August 28, 2007
SA07-PI-C06, "Trending Program Gap Analysis," dated August 2007
SA07-PI-F01, "Mid-Cycle Self-Assessment," dated September 10-21, 2007
SA07-PI-S01, "Gap Analysis between APA-ZZ-01400 and INPO 05-005," dated June 6, 2007
SA07-PI-S02, "Prompt Human Performance Evaluation," dated May 23, 2007
SA07-PI-S05, "Assessment of the Self-Assessment Program during the Mid-Cycle
Self-Assessment," dated October 25, 2007
SP07-001, "Assess Engineering Dispositions of Significance Level 3 CARs,"
dated February 15, 2007
SP07-013, "Assure ESW Piping Has Been Determined Suitable for Continued Operations,"
dated April 3, 2007
SP07-015, "Assessment of Corrective Actions for ESW Pipe Support Removal,"
dated April 11, 2007
SP07-020, "Assess ESW Examination Plans and Methods during RF15 to Address Large Bore
Pipe Pitting and Ensure Reliability during Cycle 16," dated April 13, 2007
SP07-021, "Overview of the Refuel 15 Human Performance Area," dated June 6, 2007
SP07-025, "Evaluate Refuel 15 ESW Repair/Replacement Activities," dated May 21, 2007
SP07-035, "Evaluate Adequacy of Responses to Audit AP06-006, 'Design Control,'"
dated September 25, 2007
Calculations
EB-10, "Allowable MCC circuit lengths for circuits with auxiliary relay coils in parallel with the
starter coil," Addendum 1, Revision 0
EJ-039, "Maximum Vent Times for Points Vented in Procedure OSP-SA-00003," Revision 0
KJ-10, "Determine Tube Plugging Limits for DG Intercooler Heat Exchangers, DG Jacket Water
Heat Exchangers and the Lube Oil Coolers," Revision 0
A1-3 Attachment
1 R-4152-00-1, "Revised Maximum Vent Volume
s for EMV0250, EMV0251, and EMV0252 vent
points," Revision 0
ZZ-179, "Plant AC Load List," Revision 7
Callaway Action Requests
200203882
200306252
200502093
200505716
200509540
200600012
200602144
200602645
200603734
200603736
200604147
200604872
200604878
200604991
200605025
200605046
200605143
200605179
200605252
200605751
200605879
200606432
200606707
200607188
200607327
200607496
200607835
200607843
200607911
200607985
200608466
200608902
200608956
200608979
200609233
200609441
200609580
200609603
200609621
200609628
200609710
200609726
200609805
200609809
200609809
200609812
200609813
200610010
200610048
200610063
200610112
200610359
200610423
200610426
200700023
200700063
200700096
200700100
200700115
200700218
200700224
200700260
200700262
200700265
200700284
200700286
200700392
200700560
200700893
200700956
200701164
200701177
200701261
200701336
200701362
200701369
200701371
200701372
200701406
200701407
200701559
200701573
200701591
200701654
200701660
200701930
200701944
200702003
200702037
200702057
200702144
200702202
200702276
200702339
200702371
200702373
200702529
200702568
200702596
200702685
200702864
200702956
200703065
200703069
200703177
200703189
200703244
200703260
200703317
200703901
200704101
200704113
200704169
200704176
200704226
200704366
200704472
200704598
200704742
200704911
200704913
200705117
200705142
200705149
200705263
200705349
200705484
200705489
200705936
200705968
200706133
200706143
200706268
200706453
200706476
200706561
200706810
200706933
200707100
200707368
200707375
200707468
200707485
200707490
200707508
200707518
200707572
200707628
200707788
200708122
200708186
200708219
200708233
200708241
200708270
200708671
200708941
200709002
200709165
200709171
200709330
200709522
200709523
200709540
200709652
200709812
200709813
200709819
200709852
200710351
200710418
200710764
200711084
200711176
200711177
200711227
200711235
200711236
200711254
200711257
200711314
200711496
200711541
200711883
200711916
200800085
200800248
200800585
200800878
200801268
200801664
200801877
Jobs 05104004 05506731 06129999 07007930 07008908
A1-4 Attachment
1 Requests for Resolution
200706500
200701932
Callaway Action Requests Significance Level 4 Reviews
200700815
200700839
200702456
200703494
200705711
200706212
200706427
200706571
200706688
200706812
200707147
200707184
200707250
200707294
200708020
200708062
200708068
200708435
200708769
200708778
200708873
200708942
200709232
200709657
200709660
200709698
200709740
200709845
200709868
200709894
200709959
200710139
200710446
200710537
200710915
200710923
200711009
200711028
200711036
200711067
200711378
200711481
200711543
200711647
200711662
200711696
200711741
200711831
200711955
200712005
200800007
200800152
200800205
200800226
Callaway Action Requests reviewed for component cooling water 5-year review
200300081
200300176
200300762
200300767
200300837
200301779
200302684
200306225
200306229
200306380
200307361
200401270
200402981
200407285
200408368
200408434
200408696
200500143
200500662
200502438
200504816
200507430
200507574
200507684
200509277
200510023
200601037
200602580
200604400
200710764
200800740
Callaway Action Requests related to essential service water
200600553
200608086
200701786
200702151
200702384
200702434
200702464
200702496
200702724
200702733
200703028
200703222
200703247
200703279
200703313
200703514
200703584
200703776
200703899
200704226
200704366
200704421
200704465
200704598
200704785
200705002
200705126
200705489
200705535
200706190
200707154
200710009
200710571
Information used to evaluate 480 Vac auxiliary contacts
200400789
200404392
200405034
200509628
200607324
200704719
200404059
200404486
200507793
200604013
200609726
200709688
200404301
Auxiliary Contacts Failure Trending
Replacement Timeline for NG 480 Vac Buckets
Project Plan MP01-1003/21130, "Replace Obsolete MCC Buckets (starters and aux contacts),"
dated February 5, 2008
A1-5 Attachment
1 Procedure CC-74-14, "IEEE 323-1974, "Qualification and Test Summary Report for Class IE Motor
Control Centers," Revision 6
Procedures
APA-ZZ-00107, "Review of Current Industry Operating Experience," Revision 10
APA-ZZ-00304, "Control of Callaway Equipment List," Revision 23
APA-ZZ-00322, "Integrated Work Management Process Description," Revision 3
APA-ZZ-00500, "Corrective Action Program," Revisions 44 and 45
APA-ZZ-00500, Appendix 1, "Operability and Functionality Determinations," Revision 4
APA-ZZ-00500, Appendix 5, "Maintenance Rule (MR)," Revision 2
APA-ZZ-00500, Appendix 7, "Effectiveness Reviews," Revision 2
APA-ZZ-00500, Appendix 12, "Significant Adverse C
ondition - Significance Level 1," Revision 1
APA-ZZ-00500, Appendix 13, "Adverse Condition - Significance Level 2," Revision 1
APA-ZZ-00500, Appendix 14, "Adverse Condition - Significance Level 3," Revision 2
APA-ZZ-00500, Appendix 15, "Adverse Condition - Significance Level 4," Revision 3
APA-ZZ-00500, Appendix 16, "Adverse Condition - Significance Level 5," Revision 2
APA-ZZ-00500, Appendix 17, "Screening Process Guidelines," Revision 4
APA-ZZ-00500, Appendix 21, "Other Issues - Significance Level 6," Revision 2
APA-ZZ-0500A, "Business Tracking Process," Revision 5
APA-ZZ-00604, "Requests for Resolution," Revision 20
APA-ZZ-00930, "Employee Concerns Program," Revision 10
APA-ZZ-01250, "Operational Decision Making," Revision 1
APA-ZZ-01400, "Performance Improvement Program," Revision 6
APA-ZZ-01400, Appendix E, "Operating Experience," Revision 3
APA-ZZ-01400, Appendix F, "Performance Indicators," Revision 2
APA-ZZ-01400, Appendix J, "Change Management," Revision 5
EDP-ZZ-01112, "Heat Exchanger Predictive Performance Manual," Revision 13
EDP-ZZ-01128, "Maintenance Rule Program," Revision 8
EDP-ZZ-01131, "Callaway Plant Health Program," Revision 9
EDP-ZZ-05000, "Engineering Product Quality," Revision 3
LDP-ZZ-00500, "Corrective Action Review Board," Revision 10
ODP-ZZ-00001, Addendum 12, "Operator Burdens and Workarounds," Revision 0
TDP-ZZ-00076, "Training Department Self-Assessment Process," Revision 4
TDP-ZZ-00075, "Training Department CARB," Revision 5
Miscellaneous
Change Package MP 07-0066, "Replace Buried ESW Piping with HDPE Material," Revision 0
Callaway Plant 3
rd Quarter and 4
th Quarter Trend Reports
Health Risk EF-03-07, "Corrosion of Large Bore ESW Piping - ESW Flow Only (Includes
Underground)"
Letter ULNRC-05434, "10 CFR 50.55a Request: Proposed Alternative to ASME Section XI
Requirements for Replacement of Class 3 Buried Piping," dated August 30, 2007
Letter ULNRC-05445, "Application for Amendment to Facility Operating License NPF-30,
A1-6 Attachment
1 One-Time Completion Extension for Essential Service Water (ESW) System,"
dated October 31, 2007
Proto-Power Corporation Letter to Alex Smith, "Callaway Plant Heat Exchange Engineer, RE:
Summary of GL 89-13 Program Review," dated December 21, 2006
Training Excellence Plan 2008 - 2012, dated February 7, 2008
Safety Conscious Work Environment
Callaway Plant Business Plan 2008 - 2012
Employee Concerns Program Pamphlet
NEI 97-05, "Nuclear Power Plant Personnel-Employee Concerns Program-Process Tools in a
Safety Conscious Work Environment," Revision 2
Nuclear Division Policy POL0017, "Safety Consci
ous Work Environment Policy," Revision 2
Procedure SDP-PI-DEFNS, "Static Defensive Position," Revision 1
Procedure APA-ZZ-00930, "Resolving Quality Concerns," Revision 4 (10/30/2004)
Regulatory Issue Summary 2005-18, "Guidance for Establishing and Maintaining a Safety
Conscious Work Environment," dated August 25, 2005
Regulatory Issue Summary 2006-13, "Information on the Changes Made to the Reactor Oversight
Process to More Fully Address Safety Culture," dated July 31, 2006
SEGR 07-34, "QA Department Detailed Ev
aluation of Synergy/VPO Results," dated November 2, 2007
SEGR 07-35, "INPO SOER 02-04 Davis Besse CBT," dated November 16, 2007
Understanding SCWE - A Handbook on Safety Conscious Work Environment
As the Turbine Turns Articles on Principles for a Strong Nuclear Safety Culture (dated November
and December 2006)
"An Independent Assessment of the Safety Conscious Work Environment at the Callaway Nuclear
Plant," dated February 1, 2008
2005 and 2006 Allegation Trends Report evaluations related to the Callaway Plant
2006 Operations, Engineering and Training department NEI/USA safety conscious work
environment questionnaires
2007 Safety Culture Survey
A1-7 Attachment
1 Callaway Action Requests reviewed related to safety conscious work environment
200404503
200406409
200407284
200407480
200408626
200501049
200501953
200502693
200502722
200504133
200506261
200601104
200601108
200601377
200601951
200604086
200604672
200606421
200606424
200607472
200609882
200610290
200706407
200706417
200706418
200706420
200706421
200706423
200706425
200706429
200707744
200708271
200800944 Anonymous Callaway Action Requests
200500861
200500862
200500679
200502772
200503740
200504155
200600955
200604751
200605954
200701820
200709845
200710703
200711093
200711543