ML103540382

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

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

Text

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)

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__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 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

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. 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.

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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 IMPLEMENTATION OF

SUMMARY

OF AUDIT OCTOBER 13-15, CALLAWAY PLANT, UNIT IMPLEMENTATION OF

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.

The due date was extended by Amendment 191. The commitment was closed at time of implementation.

Amendment 191 50123-1 TS changes implemented by 12/3/2008 and 4/16/2009.

CLOSED -Commitment closed by 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.

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.

-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).

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.

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.

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.

-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.

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 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.

50123-6-1 The turbine-driven auxiliary feedwater pump (TDAFP) will remain operable.

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.

-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.

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.

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.

50123-7-1 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.

CLOSED -Commitment closed via Job Number 08006658.600 issued 12/3/2008.

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.

CLOSED -Commitment closed via Job Number 08006658.610 issued 12/9/2008.

50123-8-1 Operations Department will verify the availability of fire protection equipment.

CLOSED -Commitment closed via Job Number 08006658.150 issued 11/30/2008.

-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.

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.

CLOSED -Commitment closed via Job Number 08006658.110/120 issued 11/30/2008.

50123-8-4 This walkdown will also address the seismic interaction commitments.

CLOSED -Commitment closed via Job Number 08006658.100 issued 12/1/2008.

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.

50123-9-2 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.

50123-9-3 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 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 />. CLOSED -Commitment closed via Night Order issued 11/28/2008.

50123-10-1 Appropriate training will be provided to operations personnel on this TS change and the associated ESW modification.

CLOSED -Commitment closed via Licensed Operator Continuing Training (LOCT) Cycles 08-2 and 08-4 closed on 4/11/2008 and 8/8/2008.

-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.

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.

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.

50123-11-2 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.

50123-11-3 After entering the extended ESW CT on each train, this source will be verified available every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and treated as protected equipment.

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.

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.

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.

-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.

The requested information was provided to the NRC via ULNRC-05590 on 2/4/2009.

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.

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.

The second commitment is pending the outcome of the industry/NRC TSTF review. CLOSED -Commitment closed via the following (2/1112005)

installation of pressurizer nozzle full structural weld overlays the overlays have been volumetrically examined inspection reporting to the NRC is met via ULNRC-05253

-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.

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.

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.

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.

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.

-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

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

-Type Commitment Source Document Commitment Date Commitment Subject Commitment Number Description of Commitment Supporting Documents Implementation Status 50119-2 Commitment

1. 2 CLOSED -Commitment closed via Extensive Damage Mitigation Guidelines (EDMGS), 00003, Revision 003, Section 4 (8/22/2007) 50119-3 Commitment

1. 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

1. 4 CLOSED -Commitment closed via Emergency Coordinator Supplemental Guide, Revision 008, Attachments EE-GG, Z, AA, BB (8/22/2007) 50119-5 Commitment

1. 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 MANAGEMENT OF CHANGES TO REGULATORY

SUMMARY

OF AUDIT OCTOBER 13-15, CALLAWAY PLANT, UNIT MANAGEMENT OF CHANGES TO REGULATORY

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.

The due date was extended by 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.

No new commitments made. 13R-10 Initiation Form completed per procedure (CA 1571 form on 08/25/2008).

-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).

The following ULRNC's have provided more updates to commitments:

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.

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

• 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.

connections at pressurizer 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.

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.

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.

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 Hydrogen Recombiner/

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 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.

-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.

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:

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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