ML14216A691
ML14216A691 | |
Person / Time | |
---|---|
Site: | Callaway |
Issue date: | 08/04/2014 |
From: | O'Keefe N NRC/RGN-IV/DRP/RPB-B |
To: | Diya F Union Electric Co |
References | |
IR-14-003 | |
Download: ML14216A691 (49) | |
See also: IR 05000483/2014003
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
1600 E LAMAR BLVD
ARLINGTON, TX 76011-4511
August 4, 2014
Mr. Fadi Diya, Senior Vice
President and Chief Nuclear Officer
Union Electric Company
P.O. Box 620
Fulton, MO 65251
SUBJECT: CALLAWAY PLANT - NRC INTEGRATED INSPECTION
REPORT 05000483/2014003
Dear Mr. Diya:
On July 1, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at
the Callaway Plant. On July 1, 2014, the NRC inspectors discussed the results of this
inspection with you and members of your staff. Inspectors documented the results of this
inspection in the enclosed inspection report.
NRC inspectors documented two findings of very low safety significance (Green) in this report.
One of these findings involved a violation of NRC requirements. Further, inspectors
documented a licensee-identified violation, which was determined to be of very low safety
significance. The NRC is treating these violations as non-cited violation (NCV) consistent with
Section 2.3.2.a of the NRC Enforcement Policy.
If you contest the violation or significance of the NCV, you should provide a response within
30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear
Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with
copies to the Regional Administrator, Region IV; the Director, Office of Enforcement,
U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident
inspector at the Callaway Plant.
If you disagree with a cross-cutting aspect assignment or a finding not associated with a
regulatory requirement in this report, you should provide a response within 30 days of the date
of this inspection report, with the basis for your disagreement, to the Regional Administrator,
Region IV, and the NRC resident inspector at the Callaway Plant.
F. Diya -2-
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public
Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your
response (if any) will be available electronically for public inspection in the NRCs Public
Document Room or from the Publicly Available Records (PARS) component of the NRCs
Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible
from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic
Reading Room).
Sincerely,
/RA/
Neil OKeefe, Branch Chief
Project Branch B
Division of Reactor Projects
Docket Nos.: 50-483
License Nos: NPF-30
Enclosure:
Inspection Report 05000483/2014003
w/Attachments
1. Supplemental Information
2. Callaway SSPS Replacement Questions
cc w/ encl:
Electronic Distribution for Callaway Plant
SUNSI Review ADAMS Publicly Available Non-Sensitive Keyword:
By: N. O'Keefe Yes No Non-Publicly Available Sensitive NRC-002
OFFICE SRI/DRP/B RI/DRP/B SPE/DRP/B C:DRS/EB1 C:DRS/EB2 C:DRS/OB C:DRS/PSB1
NAME THartman/dch ZHollcraft DProulx TFarnholtz JDixon VGaddy MHaire
SIGNATURE E: CFO for E: CFO for /RA/ /RA/ /RA/ /RA/ /RA/
DATE 7/28/14 7/28/14 7/25/14 8/4/14 7/28/14 7/28/14 7/31/14
OFFICE C:DRS/PSB2 C:DRS/TSB C:DRP/B
NAME Gepford GMiller NOKeefe
SIGNATURE /RA/ /RA/ /RA/
DATE 7/28/14 7/31/14 8/4/14
Letter/Inspection Report to Fadi Diya from Neil OKeefe, dated August 4, 2014
SUBJECT: CALLAWAY PLANT - NRC INTEGRATED INSPECTION
REPORT 05000483/2014003
DISTRIBUTION:
Regional Administrator (Marc.Dapas@nrc.gov)
Deputy Regional Administrator (Kriss.Kennedy@nrc.gov)
Acting DRP Director (Troy.Pruett@nrc.gov)
Acting DRP Deputy Director (Michael.Hay@nrc.gov)
DRS Director (Anton.Vegel@nrc.gov)
DRS Deputy Director (Jeff.Clark@nrc.gov)
Senior Resident Inspector (Thomas.Hartman@nrc.gov)
Resident Inspector (Zachary.Hollcraft@nrc.gov)
Branch Chief, DRP/B (Neil.OKeefe@nrc.gov)
Senior Project Engineer, DRP/B (David.Proulx@nrc.gov)
Project Engineer, DRP/B (Fabian.Thomas@nrc.gov)
CW Administrative Assistant (Dawn.Yancey@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Public Affairs Officer (Lara.Uselding@nrc.gov)
Project Manager (Fred.Lyon@nrc.gov)
Branch Chief, DRS/TSB (Geoffrey.Miller@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
ACES (R4Enforcement.Resource@nrc.gov)
Regional Counsel (Karla.Fuller@nrc.gov)
Technical Support Assistant (Loretta.Williams@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov)
RIV/ETA: OEDO (Anthony.Bowers@nrc.gov)
ROPreports
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket: 05000483
License: NPF-30
Report: 05000483/2014003
Licensee: Union Electric Company
Facility: Callaway Plant
Location: Junction Highway CC and Highway O
Steedman, MO
Dates: March 22 through July 1, 2014
Inspectors: T. Hartman, Senior Resident Inspector
Z. Hollcraft, Resident Inspector
J. Braisted, Reactor Inspector
P. Elkmann, Senior Emergency Preparedness Inspector
G. George, Senior Reactor Inspector
P. Jayroe, Reactor Inspector
D. Proulx, Senior Project Engineer
R. Stroble, Resident Inspector
Approved By: N. OKeefe
Chief, Project Branch B
Division of Reactor Projects
-1- Enclosure
SUMMARY
IR 05000483/2014003; 03/22/2014 - 07/01/2014; Callaway Plant, Integrated Resident and
Regional Report; Operability Determinations and Functionality Assessments, and Other
Activities.
The inspection activities described in this report were performed between March 22 and
June 20, 2014, by the resident inspectors at the Callaway Plant and other inspectors from
Region IV. Two findings of very low safety significance (Green) are documented in this report.
One finding involved a violation of NRC requirements. The significance of inspection findings is
indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection
Manual Chapter 0609, Significance Determination Process. Their cross-cutting aspects are
determined using Inspection Manual Chapter 0310, Components Within the Cross-Cutting
Areas. Violations of NRC requirements are dispositioned in accordance with the NRC
Enforcement Policy. The NRCs program for overseeing the safe operation of commercial
nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.
Cornerstone: Mitigating Systems
- Green. The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to perform an
adequate extent of condition assessment. While performing an evaluation of pitting
corrosion identified on buried refueling water storage piping, the licensee failed to provide an
adequate technical justification for not expanding the scope of their review beyond the
specific piping when pitting corrosion was identified in the original sample selection.
Licensee procedural guidance for a Significance Level 3 adverse condition requires the
reviewer to identify other potentially susceptible systems or components and fully explain
the boundary for the extent of condition, but this was not done. This finding does not
represent an immediate safety concern. The licensee entered the finding into their
corrective action program as Callaway Action Request 201402168. This finding affected
safety-related piping in which pitting was observed and repaired prior to being returned to
service.
The licensees failure to perform an adequate extent of condition review of the pitting of the
buried 24-inch refueling water storage tank piping in the essential core cooling system
supply line is a performance deficiency. The performance deficiency is more than minor,
and therefore a finding, because if left uncorrected, it has the potential to lead to a more
significant safety concern if other welds on this same pipe render it susceptible to pitting
corrosion in the weld heat affected zone. The finding affects the Mitigating System
Cornerstone because the performance deficiency is related to the essential core cooling
systems ability to conduct short-term decay heat removal. The finding is of very low safety
significance (Green) because the finding is not a design or qualification deficiency, did not
result in the loss of operability or functionality of a single train for greater than the technical
specification allowed outage time, and did not represent an actual loss of safety function for
greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This finding has a cross-cutting aspect in the conservative bias
component of the human performance cross-cutting area because the licensee did not use
conservative decision-making practices that emphasize prudent choices over those that are
simply allowable [H.14]. (Section 4OA5)
-2-
Cornerstone: Barrier Integrity
- Green. The inspectors identified a finding for the licensees failure to properly install a flow
transmitter for the containment spray system. Specifically, since construction, Rosemount
Transmitter ENFT0005, which provides a signal for containment spray train A pump flow
rate, had a plastic shipping plug installed in the spare conduit port instead of the vendor-
required stainless steel plug. The licensee did not include this transmitter as part of an
operating experience extent of condition walkdown conducted in 2010 because the
transmitter provides indication only and does not have an active safety function. However,
the inspector determined that this transmitter provides operator post-accident monitoring
capability of containment spray pump performance. The licensee entered this issue into the
corrective action program as Callaway Action Request 201403300. The licensee reviewed
this deficiency and determined that although Transmitter ENFT0005 was degraded, the
containment spray system remained operable. The licensee promptly replaced the plastic
shipping plug with the required stainless steel plug.
Failure to properly install a Rosemount transmitter needed for post-accident monitoring to its
qualified configuration was a performance deficiency. This performance deficiency was
more than minor, and therefore a finding, because it adversely affected the configuration
control attribute and the Barrier Integrity Cornerstone objective to provide reasonable
assurance that physical design barriers (i.e., containment) protect the public from
radionuclide releases caused by accidents or events. Specifically, the improperly configured
containment spray flow transmitter could have resulted in erratic spray flow indication, which
could impede operators ability to monitor this parameter and act upon the indication. The
finding is of very low safety significance (Green) because containment spray is not a
significant contributor to large early release frequency. This finding does not have a
cross-cutting aspect because the transmitter was installed in this manner during original
construction and, thus, was not indicative of current licensee performance. (Section 1R15)
Licensee-Identified Violations
A violation of very low safety significance was identified by the licensee and has been reviewed
by the inspectors. Corrective actions taken or planned by the licensee have been entered into
the licensees corrective action program. This violation and associated corrective action
tracking numbers are listed in Section 4OA7 of this report.
-3-
PLANT STATUS
Callaway operated at 100 percent power for the duration of the inspection period with the
exception of planned power reductions for routine surveillances and post-maintenance testing.
REPORT DETAILS
1. REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection (71111.01)
Summer Readiness for Offsite and Alternate AC Power Systems
a. Inspection Scope
On May 16, 2014, the inspectors completed an inspection of the stations offsite and
alternate ac power systems. The inspectors inspected the material condition of these
systems, including transformers and other switchyard equipment, to verify that plant
features and procedures were appropriate for operation and continued availability of
offsite and alternate ac power systems. The inspectors reviewed open condition reports
for these systems. The inspectors walked down the switchyard to observe the material
condition of equipment providing offsite power sources. The inspectors assessed
corrective actions for identified degraded conditions and verified that the licensee had
considered the degraded conditions in its risk evaluations and had established
appropriate compensatory measures.
The inspectors verified that the licensees procedures included appropriate measures to
monitor and maintain availability and reliability of the offsite and alternate ac power
systems.
These activities constituted one sample of summer readiness of offsite and alternate ac
power systems, as defined in Inspection Procedure 71111.01.
b. Findings
No findings were identified.
1R04 Equipment Alignment (71111.04)
.1 Partial Walkdown
a. Inspection Scope
The inspectors performed partial system walkdowns of the following risk-significant
systems:
- April 22, 2014, residual heat removal system train B
- April 30, 2014, auxiliary feedwater system train B
- June 17, 2014, emergency exhaust system train B
-4-
The inspectors reviewed the licensees procedures and system design information to
determine the correct lineup for the systems. They visually verified that critical portions
of the trains were correctly aligned for the existing plant configuration.
These activities constituted three partial system walk-down samples as defined in
Inspection Procedure 71111.04.
b. Findings
No findings were identified.
.2 Complete Walkdown
a. Inspection Scope
On April 21, 2014, the inspectors performed a complete system walkdown inspection
of the control building heating, ventilation, and air conditioning system. The inspectors
reviewed the licensees procedures and system design information to determine the
correct system lineup for the existing plant configuration. The inspectors also reviewed
outstanding work orders, open condition reports, and other open items tracked by the
licensees operations and engineering departments. The inspectors then visually verified
that the system was correctly aligned for the existing plant configuration.
These activities constituted one complete system walk-down sample, as defined in
Inspection Procedure 71111.04.
b. Findings
No findings were identified.
1R05 Fire Protection (71111.05)
Quarterly Inspection
a. Inspection Scope
The inspectors evaluated the licensees fire protection program for operational status
and material condition. The inspectors focused their inspection on five plant areas
important to safety:
- April 16, 2014, transformers west of the turbine building, fire area T-14
- April 23, 2014, residual heat removal train A pump room, fire area A-2A
- May 19, 2014, access control and electrical equipment air conditioning unit
train A room, fire area C-14
- June 2, 2014, upper and lower cable spreading rooms, fire areas C-21 and C-22
- June 17, 2014, control building and communications corridor, fire area C-27
-5-
For each area, the inspectors evaluated the fire plan against defined hazards and
defense-in-depth features in the licensees fire protection program. The inspectors
evaluated control of transient combustibles and ignition sources, fire detection and
suppression systems, manual firefighting equipment and capability, passive fire
protection features, and compensatory measures for degraded conditions.
These activities constitute five quarterly fire protection inspection samples, as defined in
Inspection Procedure 71111.05.
b. Findings
No findings were identified.
1R06 Flood Protection Measures (71111.06)
a. Inspection Scope
On May 13, 2014, the inspectors completed an inspection of the stations ability to
mitigate flooding due to internal causes. After reviewing the licensees flooding analysis,
the inspectors chose the Class 1E ac electrical switchgear train A room plant area which
contains risk-significant structures, systems, and components that are susceptible to
flooding.
The inspectors reviewed plant design features and licensee procedures for coping with
internal flooding. The inspectors walked down the selected area to inspect the design
features, including the material condition of seals, drains, and flood barriers. The
inspectors evaluated whether operator actions credited for flood mitigation could be
successfully accomplished.
In addition, on June 5, 2014, the inspectors completed an inspection of underground
bunkers susceptible to flooding. The inspectors selected safety-related electrical
manhole MH01B that contained risk-significant cables whose failure could disable risk-
significant equipment. The inspectors observed the material condition of the cables and
splices contained in the manhole and looked for evidence of cable degradation due to
water intrusion. The inspectors verified that the cables and manhole met design
requirements.
These activities constitute completion of one flood protection measures sample and one
bunker/manhole sample, as defined in Inspection Procedure 71111.06.
b. Findings
No findings were identified.
1R07 Heat Sink Performance (71111.07)
a. Inspection Scope
On April 9, 2014, the inspectors completed an inspection of the readiness and availability
of risk-significant heat exchangers. The inspectors reviewed the data from eddy current
testing for emergency diesel lubricating oil heat exchanger train B and observed the
licensees inspection and the material condition of the heat exchanger internals.
-6-
Additionally, the inspectors walked down this heat exchanger to observe its performance
and material condition.
These activities constitute completion of one heat sink performance annual review
sample, as defined in Inspection Procedure 71111.07.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
(71111.11)
.1 Review of Licensed Operator Requalification
a. Inspection Scope
On May 6, 2014, the inspectors observed a portion of an annual requalification test for
licensed operators. The inspectors assessed the performance of the operators and the
evaluators critique of their performance. The inspectors also assessed the modeling
and performance of the simulator during the requalification activities.
These activities constitute completion of one quarterly licensed operator requalification
program sample, as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
.2 Review of Licensed Operator Performance
a. Inspection Scope
On April 27, 2014, the inspectors observed the performance of on-shift licensed
operators in the plants main control room. At the time of the observations, the plant was
in a period of heightened risk due to the turbine-driven auxiliary feedwater pump being
unavailable for testing.
In addition, the inspectors assessed the operators adherence to plant procedures,
including ODP-ZZ-00001, Operations Department - Code of Conduct, and other
operations department policies.
These activities constitute completion of one quarterly licensed operator performance
sample, as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
-7-
1R12 Maintenance Effectiveness (71111.12)
a. Inspection Scope
The inspectors reviewed three instances of degraded performance or condition of safety-
related structures, systems, and components:
- April 2, 2014, centrifugal charging pump train A room cooler faulty stop
pushbutton
torque switch set incorrectly
- May 27, 2014, ultimate heat sink cooling tower train A electrical room inlet
damper operator hydramotor failure
The inspectors reviewed the extent of condition of possible common cause structure,
system, and component failures and evaluated the adequacy of the licensees corrective
actions. The inspectors reviewed the licensees work practices to evaluate whether
these may have played a role in the degradation of the structures, systems, and
components. The inspectors assessed the licensees characterization of the
degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that
the licensee was appropriately tracking degraded performance and conditions in
accordance with the Maintenance Rule.
These activities constituted completion of three maintenance effectiveness samples, as
defined in Inspection Procedure 71111.12.
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
a. Inspection Scope
The inspectors reviewed three risk assessments performed by the licensee prior to
changes in plant configuration and the risk management actions taken by the licensee in
response to elevated risk:
- March 25, 2014, Yellow risk for emergency diesel generator train A, essential
service water train A, and ultimate heat sink train A planned maintenance,
Job 13512067
- April 9, 2014, elevated Green risk for emergency diesel generator train B,
essential service water train B, and ultimate heat sink train B planned
maintenance, Job 11504085
- April 30, 2014, Yellow risk for turbine-driven auxiliary feedwater pump planned
maintenance, Job 14501194
-8-
The inspectors verified that these risk assessments were performed timely and in
accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant
procedures. The inspectors reviewed the accuracy and completeness of the licensees
risk assessments and verified that the licensee implemented appropriate risk
management actions.
Additionally, on May 20, 2014, the inspectors observed portions of one emergent work
activity, replacement of a current to pneumatic converter on the turbine-driven auxiliary
feedwater flow control valve to steam generator B, Job 14002312, which had the
potential to affect the functional capability of mitigating systems.
The inspectors verified that the licensee appropriately developed and followed a work
plan for these activities. The inspectors verified that the licensee took precautions to
minimize the impact of the work activities on unaffected structures, systems, and
components.
These activities constitute completion of four maintenance risk assessments and
emergent work control inspection samples, as defined in Inspection Procedure 71111.13.
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments (71111.15)
a. Inspection Scope
The inspectors reviewed four operability determinations and functionality assessments
that the licensee performed for degraded or nonconforming structures, systems, or
components:
- April 3, 2014, functionality assessments of spent fuel pool pump train B room
cooler, Callaway Action Requests 201401683 and 201401587
- May 13, 2014, operability determination of containment spray train A pump
discharge flow transmitter, Callaway Action Request 201403300
- May 28, 2014, operability determination of engineered safety features switchgear
train A from improperly stored floor mats, Callaway Action Request 201401795
- June 17, 2014, functionality assessment of Class 1E switchgear room chiller
train A, Callaway Action Request 201403902
The inspectors reviewed the timeliness and technical adequacy of the licensees
evaluations. Where the licensee determined the degraded structures, systems, and
components to be operable or functional, the inspectors verified that the licensees
compensatory measures were appropriate to provide reasonable assurance of
operability or functionality. The inspectors verified that the licensee had considered the
effect of other degraded conditions on the operability or functionality of the degraded
structure, system, or component.
-9-
These activities constitute completion of four operability and functionality review
samples, as defined in Inspection Procedure 71111.15.
b. Findings
Shipping Plug Installed in Rosemount Transmitter
Introduction. The inspectors identified a Green finding for the failure to properly install a
flow transmitter for the containment spray system. Specifically, as of May 13, 2014,
Transmitter ENFT0005, which provides a signal for containment spray pump train A flow
rate, had a plastic shipping plug installed in the spare conduit port, instead of the vendor-
required stainless steel plug.
Description. Flow Transmitter ENFT0005 provides a signal for control room indication of
containment spray flow rate. It is a Rosemount 1153 Series B model transmitter, which
is used in several safety-related and nonsafety-related level or flow applications. It is
located in the emergency core cooling system train A room (which contains the
containment spray, centrifugal charging, safety injection pumps, and supporting
equipment).
On May 13, 2014, during a tour of the emergency core cooling system train A room, the
inspectors noted that a plastic shipping plug was installed in the spare conduit port for
Transmitter ENFT0005, on the bottom where it was not readily visible. The vendor
manual for the transmitter directed the user to discard the plastic plug upon installation
and install a stainless steel plug in the spare conduit hole using thread sealant to prevent
moisture intrusion. The inspectors informed the licensee, who initiated Callaway Action
Request 201403300 to enter this issue into the corrective action program. The licensee
reviewed this deficiency and determined that although Transmitter ENFT0005 was
degraded, the containment spray train remained operable. The licensee replaced the
plastic shipping plug with the vendor-recommended stainless steel plug in accordance
with Job 14002189.
The licensee investigation revealed that Transmitter ENFT0005 had been installed with
the plastic shipping plug during original construction. Using industry-operating
experience, the licensee had several previous opportunities to identify this issue. The
licensee had previously issued Callaway Action Request 201011748 to inspect similar
transmitter configurations at Callaway Plant. The scope of these inspections was limited
to transmitters that had an active safety function (e.g., actuation or trip signals).
Because Transmitter ENFT0005 provides indication only, it was not included in the
scope of the 2010 inspection. The inspectors noted that the containment spray flow
indication, although considered a nonsafety-related parameter, is listed in the Updated
Final Safety Analysis Report, Table 7-3A, Item D.6.1, as a passive post-accident
monitoring variable.
Although Transmitter ENFT0005 was not a 10 CFR Part 50, Appendix B, quality-related
component, the licensee did not meet the standard of having a fully qualified instrument
for post-accident monitoring, in that the transmitter did not conform to the vendor-
recommended configuration to prevent post-accident moisture intrusion. Reference
Manual 00809-0100-04302, Rosemount 1153 Series B Alphaline Pressure Transmitter,
Revision BA, January 2008, Section 2, Installation, directed the user to close off the
unused conduit hub with a stainless steel 1/2 - 14 NPT plug and seal all threads with pipe
- 10 -
thread sealant. Leaving the plastic shipping plug in place from initial construction until
May 13, 2014, did not meet this standard and was considered a finding.
Analysis. Failure to properly install a Rosemount transmitter needed for post-accident
monitoring to its qualified configuration was a performance deficiency. Specifically, the
licensee failed to replace a plastic shipping plug with a stainless steel plug to provide
protection from the environment. This performance deficiency was more than minor;
and therefore a finding, because it adversely affected the configuration control attribute
of the Barrier Integrity Cornerstone and affected the cornerstone objective to provide
reasonable assurance that physical design barriers (i.e., containment) protect the public
from radionuclide releases caused by accidents or events. Specifically, the improperly
configured containment spray flow transmitter could result in erratic spray flow indication,
which could impede operators ability to monitor this parameter and to act upon the
indication.
Using NRC Inspection Manual 0609, Appendix H, Containment Integrity Significance
Determination Process, issued May 6, 2004, the finding was determined to be of very
low safety significance because the containment spray system is not a significant
contributor to a large early release frequency. This finding does not have a cross-cutting
aspect because it was not indicative of current licensee performance since the
transmitter was installed during original construction.
Enforcement. This finding does not involve enforcement action because no violation of a
regulatory requirement was identified. Because this finding does not involve a violation
and is of very low safety significance, it is identified as FIN 05000483/2014003-01,
Plastic Shipping Plug in Rosemount Transmitter.
1R19 Post-Maintenance Testing (71111.19)
a. Inspection Scope
The inspectors reviewed five post-maintenance testing activities that affected risk-
significant structures, systems, or components:
- March 26, 2014, emergency diesel generator train A fast start, Job 13512067
- April 9, 2014, essential service water pump train B, Job 12511473
- April 9, 2014, ultimate heat sink cooling tower fans B and D, Jobs 12511470
and 12511471
- April 23, 2014, residual heat removal pump train A, Job 12512029
- June 18, 2014, emergency exhaust filter train A, Job 14001821
The inspectors reviewed licensing- and design-basis documents for the structures,
systems, and components and the maintenance and post-maintenance test procedures.
The inspectors observed the performance of the post-maintenance tests to verify that
the licensee performed the tests in accordance with approved procedures, satisfied the
established acceptance criteria, and restored the operability of the affected structures,
systems, and components.
- 11 -
These activities constitute completion of five post-maintenance testing inspection
samples, as defined in Inspection Procedure 71111.19.
b. Findings
No findings were identified.
1R22 Surveillance Testing (71111.22)
a. Inspection Scope
The inspectors observed six risk-significant surveillance tests and reviewed test results
to verify that these tests adequately demonstrated that the structures, systems, and
components were capable of performing their safety functions:
In-service tests:
- April 27, 2014, turbine-driven auxiliary feedwater pump valve inservice tests
Containment isolation valve surveillance tests:
- May 19, 2014, containment isolation damper test
Reactor coolant system leak detection tests:
- May 30, 2014, reactor coolant system inventory balance
Other surveillance tests:
- April 23, 2014, emergency exhaust system train A operability test
- May 27, 2014, motor-driven auxiliary feedwater pump train B test
- June 9, 2014, safety injection pump train A test
The inspectors verified that these tests met technical specification requirements, that the
licensee performed the tests in accordance with their procedures, and that the results of
the test satisfied appropriate acceptance criteria. The inspectors verified that the
licensee restored the operability of the affected structures, systems, and components
following testing.
These activities constitute completion of six surveillance testing inspection samples, as
defined in Inspection Procedure 71111.22.
b. Findings
No findings were identified.
- 12 -
Cornerstone: Emergency Preparedness
1EP2 Alert and Notification System Evaluation (71114.02)
a. Inspection Scope
The inspectors verified the adequacy of the licensees methods for testing the primary
and backup alert and notification system. The inspectors also reviewed the licensees
program for identifying emergency planning zone locations requiring tone alert radios
and for distributing the radios, and reviewed audits of distribution records. The
inspectors interviewed licensee personnel responsible for the maintenance of the
primary and backup alert and notification system and reviewed a sample of corrective
action system reports written for alert and notification system problems. The inspectors
compared the licensees alert and notification system testing program with criteria in
NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency
Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1;
FEMA Report REP-10, Guide for the Evaluation of Alert and Notification Systems for
Nuclear Power Plants; and the licensees current FEMA-approved alert and notification
system design report, Callaway Plant, Alert and Notification System Design Report,
dated January 2013. The inspectors also observed the licensee and offsite authorities
jointly conduct a scheduled weekly siren system test on April 22, 2014.
These activities constituted completion of one alert and notification system evaluation
sample as defined in Inspection Procedure 71114.02.
b. Findings
No findings were identified.
1EP3 Emergency Response Organization Staffing and Augmentation System (71114.03)
a. Inspection Scope
The inspectors verified the licensees emergency response organization on-shift and
augmentation staffing levels were in accordance with the licensees emergency plan
commitments. The inspectors reviewed documentation and discussed with licensee staff
the operability of primary and backup systems for augmenting the on-shift emergency
response staff to verify the adequacy of the licensees methods for staffing emergency
response facilities, including the licensees ability to staff pre-planned alternate facilities.
The inspectors also reviewed records of emergency response organization
augmentation tests and events to determine whether the licensee had maintained a
capability to staff emergency response facilities within emergency plan timeliness
commitments.
These activities constitute completion of one emergency response organization staffing
and augmentation testing sample as defined in Inspection Procedure 71114.03.
b. Findings
No findings were identified.
- 13 -
1EP4 Emergency Action Level and Emergency Plan Changes (71114.04)
a. Inspection Scope
The inspectors performed an on-site review of the Callaway Plant Radiological
Emergency Response Plan, Revision 44, implemented April 9, 2014. This revision:
- Assigned some of the duties of the Emergency Duty Officer to the Emergency
Coordinator, Technical Support Center (TSC)
- Changed the response time goal for activating the on-shift emergency response
organization staff from 15 minutes to immediate
This revision was compared to the previous revision, to the criteria of NUREG-0654,
Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and
Preparedness in Support of Nuclear Power Plants, Revision 1, and to the standards in
10 CFR 50.47(b) to determine if the revision adequately implemented the requirements
of 10 CFR 50.54(q)(3) and 50.54(q)(4). This review was not documented in a safety
evaluation report and did not constitute approval of licensee-generated changes;
therefore, this revision is subject to future inspection.
These activities constitute completion of one emergency action level and emergency
plan changes sample as defined in Inspection Procedure 71114.04.
b. Findings
No findings were identified.
1EP5 Maintenance of Emergency Preparedness (71114.05)
a. Inspection Scope
The inspectors reviewed the following for the period October 2012 through April 2014:
- After-action reports for emergency classifications and events
- After-action evaluation reports for licensee drills and exercises
- Independent audits and surveillances of the licensees emergency preparedness
program
- Self-assessments of the emergency preparedness program conducted by the
licensee
- Licensee evaluations of changes made to the emergency plan and emergency
plan implementing procedures
- Drill and exercise performance issues entered into the licensees corrective
action program
- Emergency preparedness program issues entered into the licensees corrective
action program
- 14 -
- Emergency response organization and emergency planner training records
- Maintenance records for equipment supporting the emergency preparedness
program
- Evaluations of the effect of changes to the emergency planning zone population
The inspectors reviewed summaries of 334 corrective action program reports associated
with emergency preparedness and selected 30 to review against program requirements
to determine the licensees ability to identify, evaluate, and correct problems in
accordance with Planning Standard 10 CFR 50.47(b)(14) and 10 CFR Part 50,
Appendix E, IV.F. The inspectors verified that the licensee accurately and appropriately
identified and corrected emergency preparedness weaknesses during critiques and
assessments.
The inspectors reviewed summaries of 70 licensee evaluations of the impact of changes
to the emergency plan and implementing procedures, and selected 12 to review against
program requirements to determine the licensees ability to identify reductions in the
effectiveness of the emergency plan in accordance with the requirements of
10 CFR 50.54(q)(3) and 50.54(q)(4). The inspectors verified that evaluations of
proposed changes to the licensee emergency plan appropriately identified the impact of
the changes prior to being implemented.
The inspectors toured the emergency response facility, the alternate TSC, and the
alternate operations support center to determine whether the licensee had adequately
implemented alternate emergency response facilities in accordance with the
requirements of 10 CFR Part 50, Appendix E, IV.E(8)(d).
These activities constitute completion of one sample of the maintenance of the
licensees emergency preparedness program as defined in Inspection
Procedure 71114.05.
b. Findings
No findings were identified.
1EP6 Drill Evaluation (71114.06)
Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors observed an emergency preparedness drill on May 8, 2014, to verify the
adequacy and capability of the licensees assessment of drill performance. The
inspectors reviewed the drill scenario, observed the drill from the TSC, and attended the
post-drill critique. The inspectors verified that the licensees emergency classifications,
off-site notifications, and protective action recommendations were appropriate and
timely. The inspectors verified that any emergency preparedness weaknesses were
appropriately identified by the licensee in the post-drill critique and entered into the
corrective action program for resolution.
- 15 -
These activities constitute completion of one emergency preparedness drill observation
sample, as defined in Inspection Procedure 71114.06-05.
b. Findings
No findings were identified.
4. OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency
Preparedness, Public Radiation Safety, Occupational Radiation Safety, and
Security
4OA1 Performance Indicator Verification (71151)
.1 Safety System Functional Failures (MS05)
a. Inspection Scope
For the period of second quarter 2013 through first quarter 2014, the inspectors
reviewed licensee event reports, Maintenance Rule evaluations, and other records that
could indicate whether safety system functional failures had occurred. The inspectors
used definitions and guidance contained in Nuclear Energy Institute Document 99-02,
Regulatory Assessment Performance Indicator Guideline, Revision 7, and
NUREG-1022, Event Reporting Guidelines: 10 CFR 50.72 and 50.73, Revision 3, to
determine the accuracy of the data reported.
These activities constituted verification of the safety system functional failures
performance indicator, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.2 Mitigating Systems Performance Index: Heat Removal Systems (MS08)
a. Inspection Scope
The inspectors reviewed the licensees mitigating system performance index data for
the period of second quarter 2013 through first quarter 2014 to verify the accuracy and
completeness of the reported data. The inspectors used definitions and guidance
contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment
Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported
data.
These activities constituted verification of the mitigating system performance index for
heat removal systems, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
- 16 -
.3 Reactor Coolant System Identified Leakage (BI02)
a. Inspection Scope
The inspectors reviewed the licensees records of reactor coolant system (RCS)
identified leakage for the period of second quarter 2013 through first quarter 2014 to
verify the accuracy and completeness of the reported data. The inspectors observed the
performance of Procedure OSP-BB-00009, RCS Inventory Balance, on May 30, 2014.
The inspectors used definitions and guidance contained in Nuclear Energy Institute
Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7,
to determine the accuracy of the reported data.
These activities constituted verification of the reactor coolant system leakage
performance indicator, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.4 Drill/Exercise Performance (EP01)
a. Inspection Scope
The inspectors reviewed the licensees emergency plan implementations, evaluated
exercises, and selected drill and training evolutions that occurred between the third
quarter 2013 and the first quarter 2014 to verify the accuracy of the licensees data for
classification, notification, and protective action recommendation opportunities. The
inspectors reviewed a sample of the licensees completed classifications, notifications,
and protective action recommendations to verify their timeliness and accuracy. The
inspectors used definitions and guidance contained in Nuclear Energy Institute
Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7,
to determine the accuracy of the data reported.
These activities constituted verification of the drill/exercise performance indicator as
defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.5 Emergency Response Organization Drill Participation (EP02)
a. Inspection Scope
The inspectors reviewed the licensees records for participation in drill and training
evolutions between the third quarter 2013 and the first quarter 2014 to verify the
accuracy of the licensees data for drill participation opportunities. The inspectors
verified that all members of the licensees emergency response organization in the
identified key positions had been counted in the reported performance indicator data.
The inspectors reviewed the licensees basis for reporting the percentage of emergency
response organization members who participated in a drill. The inspectors reviewed drill
attendance records and verified a sample of those reported as participating. The
- 17 -
inspectors used definitions and guidance contained in Nuclear Energy Institute
Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7,
to determine the accuracy of the data reported.
These activities constituted verification of the emergency response organization drill
participation performance indicator as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.6 Alert and Notification System Reliability (EP03)
a. Inspection Scope
The inspectors reviewed licensee and offsite agency records of alert and notification
system tests conducted between the third quarter 2013 and the first quarter 2014 to
verify the accuracy of the licensees data for siren system testing opportunities. The
inspectors reviewed procedural guidance on assessing alert and notification system
opportunities and the results of periodic alert and notification system operability tests.
The inspectors used definitions and guidance contained in Nuclear Energy Institute
Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7,
to determine the accuracy of the data reported.
These activities constituted verification of the alert and notification system reliability
performance indicator as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution (71152)
.1 Routine Review
a. Inspection Scope
Throughout the inspection period, the inspectors performed daily reviews of items
entered into the licensees corrective action program and periodically attended the
licensees condition report screening meetings. The inspectors verified that licensee
personnel were identifying problems at an appropriate threshold and entering these
problems into the corrective action program for resolution. The inspectors verified that
the licensee developed and implemented corrective actions commensurate with the
significance of the problems identified. The inspectors also reviewed the licensees
problem identification and resolution activities during the performance of the other
inspection activities documented in this report.
b. Findings
No findings were identified.
- 18 -
.2 Semiannual Trend Review
a. Inspection Scope
To verify that the licensee was taking corrective actions to address identified adverse
trends that might indicate the existence of a more significant safety issue, the inspectors
reviewed corrective action program documentation associated with the following
licensee-identified trends:
- Increased failure rate for hydramotors
Also, the inspectors identified the following trends that might indicate the existence of a
more significant safety issue and reviewed the licensees response to them:
- Inconsistent use of peer-checking human performance tools in the control room
- Increasing number of transient combustible permit issues
These activities constitute completion of one semiannual trend review sample, as
defined in Inspection Procedure 71152.
b. Observations and Assessments
The inspectors review of the trends identified above produced the following observations
and assessments:
The inspectors reviewed the licensees corrective action program, performance
indicators, system health reports, and other documentation to identify trends that might
indicate the existence of a more significant safety issue. The inspectors verified that the
licensee was taking corrective actions to address identified adverse trends.
While completing this trend review, the inspectors did note the following negative trends:
inconsistent use of peer-checking human performance tools in the control room,
technical specification application knowledge deficiencies, hydramotor failures, and an
increasing number of transient combustible permit issues. The licensee was aware of
these issues and has entered them into their corrective action program.
The inspectors did not review any cross-cutting theme because no cross-cutting theme
exists at the site.
c. Findings
No findings were identified.
.3 Annual Follow-up of Selected Issues
a. Inspection Scope
The inspectors selected one issue for an in-depth follow-up:
- 19 -
- On March 30, 2014, Callaway Action Request 201401530 identified that the
nuclear oversight group is not fully effective in driving station performance. This
issue was identified by the offsite nuclear safety review board.
The inspectors selected this issue because a lack of response to issues identified by the
internal nuclear oversight group can be an indicator of station performance. The
inspectors assessed the licensees problem statement, cause analyses, and extent of
condition review. The inspectors interviewed several members of the nuclear oversight
group and station line management. The inspectors determined that there are
departments at the station that are less receptive to comments from the nuclear
oversight group than others. The inspectors also determined that the nuclear oversight
group was not always clear when conveying their concerns. The inspectors concluded
that the completed and planned corrective actions were adequate to address the issue.
These activities constitute completion of one annual follow-up sample as defined in
b. Findings
No findings were identified.
4OA5 Other Activities
.1 (Closed) Temporary Instruction 2515/182: Review of the Industry Initiative to Control
Degradation of Underground Piping and Tanks
a. Inspection Scope
Leakage from buried and underground pipes has resulted in groundwater contamination
incidents with associated heightened NRC and public interest. The industry issued a
guidance document, Nuclear Energy Institute 09-14, Guideline for the Management of
Buried Piping Integrity, (ADAMS Accession No. ML1030901420) to describe the goals
and required actions (commitments made by the licensee) resulting from this
underground piping and tank initiative. On December 31, 2010, Nuclear Energy Institute
issued Revision 1 to Nuclear Energy Institute 09-14, Guidance for the Management of
Underground Piping and Tank Integrity, (ADAMS Accession No. ML110700122) with an
expanded scope of components which included underground piping that was not in
direct contact with the soil and underground tanks. On November 17, 2011, the NRC
issued Temporary Instruction 2515/182, Review of the Industry Initiative to Control
Degradation of Underground Piping and Tanks, to gather information related to the
industrys implementation of this initiative. The licensees buried piping and underground
piping and tanks program was inspected in accordance with paragraph 03.02a of the
temporary instruction and it was confirmed that activities which correspond to completion
dates specified in the program which have passed since the Phase 1 inspection have
been completed.
- 20 -
Additionally, the licensees buried piping and underground piping and tanks program was
inspected in accordance with paragraph 03.02.b of the temporary instruction and
responses to specific questions were submitted to the NRC headquarters staff. Based
upon the scope of the review described above, Temporary Instruction 2515/182 was
completed.
b. Findings
Introduction. Inspectors identified a finding of very low safety significance (Green) and
associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions,
Procedures, and Drawings, for the licensees failure to perform an adequate extent of
condition assessment for a Significance Level 3 adverse condition in accordance with
Callaways corrective action program. While performing an evaluation of pitting
corrosion identified on buried refueling water storage piping, the licensee failed to
provide an adequate technical justification for not expanding the scope of their review
beyond the specific piping when pitting corrosion was identified in the original sample
selection.
Description. In April 2013, the licensee performed an excavation and inspection of
several buried lines near the refueling water storage tank as part of the industry initiative
to control the degradation of buried piping and tanks. Among the buried lines inspected
were a 24-inch diameter supply line from the refueling water storage tank to emergency
core cooling system suction and a 4-inch diameter return line. Both runs of buried pipe
are type 304 stainless steel. Both lines were discovered to have pitting corrosion in the
heat-affected zones of butt-welded piping connections. The 4-inch return line had pitting
around four welds that encompassed the circumference of the pipe within the heat-
affected zones. The safety-related 24-inch supply line had fewer, but deeper pits in the
heat-affected zones of one weld. A subsequent dye penetrant test of these pits
identified a small crack in one pit. Analysis was performed to demonstrate effective wall
thickness of both pipes in the area affected by the pitting and the safety-related 24-inch
line was repaired under an ASME Section XI repair package.
The licensee performed a cause determination for the pitting in both pipes as specified in
Procedure APA-ZZ-00500, Appendix 14, Adverse Condition - Significance Level 3.
The licensee determined the cause was pitting attack accelerated by sensitization and
environmental conditions conducive to corrosion. The licensee concluded that
sensitization, which is likely the result of a failure to properly maintain interpass
temperature between weld passes, reduced the effectiveness of the passive oxide layer
in the stainless steel which, when combined with an electrolytically conducive
environment, left the piping vulnerable to pitting.
Licensee Procedure APA-ZZ-00500, Appendix 14, Adverse Condition - Significance
Level 3, required the reviewer to conduct an extent of condition review to identify other
potentially susceptible systems or components. The licensee concluded, based on the
extent of condition review for this issue, that the environmental conditions for these pipes
were unique due to poor soil drainage and specifically stated that the extent of condition
would be limited to the visually inspected areas.
- 21 -
The inspectors reviewed the cause evaluation and determined that the licensee
essentially failed to consider any potentially susceptible locations (adjacent to welds) in
the additional 50 feet of buried piping for each of these piping runs. Although welding
was implicated as a contributing factor in the cause evaluation, the licensee made no
effort to understand the extent to which past welding practices could have impacted
other portions of this same piping.
During the same approximate timeframe, the licensee performed guided wave testing of
the additional buried portion of the subject piping; however, the results of this testing
were not utilized in the cause or extent of condition evaluation. The guided wave testing
identified six minor, one medium, and one anomalous indication on the 24-inch piping.
The licensee also obtained soil samples as part of the excavation, but performed no
technical analysis identifying uniquely corrosion-conducive conditions in the immediate
area or ruled out the possibility of such conditions in adjacent areas.
The lack of an adequate technical justification for limiting the extent of condition to only
the inspected piping is not consistent with licensee guidance of performing an extent of
condition review and constitutes a performance deficiency. Specifically, licensee
Procedure APA-ZZ-00500, Appendix 14, Adverse Condition - Significance Level 3,
step 4.2.4, requires that an extent of condition review be performed which determines
the population of components or systems that have the potential to exhibit the same
undesired condition as the item being investigated.
Analysis. The failure to perform an adequate extent of condition review of the pitting of
the buried 24-inch refueling water storage tank to emergency core cooling system supply
line in accordance with their procedure was a performance deficiency. The performance
deficiency is more than minor and therefore a finding because, if left uncorrected, it has
the potential to lead to a more significant safety concern if other welds on this same pipe
render it susceptible to pitting corrosion in the weld heat-affected zones. The finding
affects the Mitigating System Cornerstone because the performance deficiency is related
to the emergency core cooling systems ability to conduct short-term decay heat
removal.
This finding was assessed using Inspection Manual Chapter 0609, Appendix A,
Exhibit 2, Mitigating Systems Screening Questions, and was determined to be of very
low safety significance because the finding is not a design or qualification deficiency; did
not result in the loss of operability or functionality of a single train for greater than the
technical specification allowed outage time; and did not represent an actual loss of
safety function for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This finding has a cross-cutting aspect in the
conservative bias component of the human performance cross-cutting area because the
licensee did not use conservative decision-making practices that emphasize prudent
choices over those that are simply allowable. Specifically, rather than expanding the
scope of the extent of condition to include other sections of the affected piping that could
have the same susceptibility to pitting due to poor welding practices, personnel limited
the scope of their review to what they observed [H.14].
Enforcement. Title 10 of the Code of Federal Regulations, Part 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities
affecting quality shall be accomplished in accordance with procedures.
Procedure APA-ZZ -00500, Appendix 14, Adverse Condition - Significance Level 3,
- 22 -
requires licensee personnel to conduct an extent of condition review that identifies
whether the potential exists for the problem being evaluated to cause further damage to
the structures, systems, or components in question. Contrary to the above, between
April and July 2013, the licensee did not accomplish activities affecting quality in
accordance with procedures. Specifically, licensee personnel did not evaluate the
possibility of further damage to the borated refueling water storage piping caused by
increased corrosion susceptibility as the result of improper welding practices, nor did
they eliminate the possibility that the environment conducive to corrosion could occur in
other locations. Because this finding is of very low safety significance and was entered
into the corrective action program as Callaway Action Request 201402168, this violation
is being treated as a non-cited violation, consistent with Section 2.3.2.a. of the NRC
Enforcement Policy: NCV 05000483/2014003-02 Inadequate Extent of Condition
Review.
.2 (Closed) Unresolved Item 05000483/2013005-01, Solid State Protection System
Modifications
During the fourth quarter of the 2013 inspection cycle, inspectors identified an
unresolved item associated with the implementation of the licensees process to comply
with 10 CFR 50.59 for a digital modification of the solid state protection system (SSPS)
logic and control boards. The SSPS logic and control boards provide the coincidence
logic to produce actuation signals for operation of the reactor protection system and the
engineered safety features actuation systems. Modification Package 10-0053, SSPS
Printed Circuit Board Replacement, Version 000.2, evaluated a digital modification to
the existing SSPS logic and control boards. This modification replaced existing obsolete
printed circuit boards using fixed logic devices (i.e., transistor-transistor logic) with
replacement boards using complex programmable logic devices (CPLD) supplied by
Westinghouse.
The inspectors reviewed the 10 CFR 50.59 evaluation and the Westinghouse supporting
information for the replacement cards. The inspectors identified various issues of
concern associated with the design, testing, and operation of the replacement circuit
boards, that had the possibility of creating a malfunction of the SSPS with a different
result as described in the updated final safety analysis report. The inspectors specific
issues of concern were:
- The 10 CFR 50.59 evaluation did not contain sufficient information to exclude the
data file from the definition of Base Software and the associated design
considerations in Nuclear Energy Institute 01-01, Guideline on Licensing Digital
Upgrades.
- Second party commercial vendors were involved in the manufacturing of the CPLDs
as well as the development of the data file software. The inspectors found that
there was not sufficient information in the 10 CFR 50.59 evaluation and supporting
vendor information to determine the level of quality assurance placed into the
development of the CPLDs to ensure reliable operation of this logic device.
Furthermore, licensee discussions with Westinghouse confirmed that the second
party commercial vendors were not qualified to 10 CFR Part 50, Appendix B, Quality
Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.
- 23 -
- The testing performed by the vendor for the development of the CPLDs only covered
the combinations of inputs and outputs (hardware functional testing) required for the
design function of the SSPS. However, the 50.59 evaluation and supporting vendor
information did not contain adequate information to determine if the testing
performed by the vendor was sufficient to cover other possible sequence of device
states due to the relative complexity of the CPLDs operation. This would include
software-induced states associated with the CPLDs themselves and the embedded
data file, which could result in malfunctions of the SSPS.
Following the issuance of the unresolved item, the inspectors reviewed additional
Westinghouse topical and test reports which supported the licensees 10 CFR 50.59
safety evaluation conclusion that a license amendment was not necessary for this digital
upgrade. The inspection results are as follows:
- The inspectors determined that the licensees modification package correctly
considered the internal CPLDs software configuration as an adverse change to the
design function of the SSPS; therefore, the licensee correctly completed the
10 CFR 50.59 safety evaluation for the change.
- In consultation with the Office of Nuclear Reactor Regulation, Instrumentation and
Controls Branch, the inspectors determined Westinghouse audited the manufacturer
under the Westinghouse 10 CFR Part 50, Appendix B quality assurance program.
- The inspectors determined that the testing was beyond the licensees normal
functional testing which only manipulated CPLD inputs which were necessary to
meet the safety function of SSPS. The test procedure manipulated all inputs
available to the CPLD to ensure the correct device output was correct.
Using the guidance contained in NRC Regulatory Guide 1.187, Guidance for
Implementation of 10 CFR 50.59, Changes, Tests, and Experiments, and NRC
Regulatory Issue Summary 2002-22, Use of EPRI/NEI Joint Task Force Report,
Guideline on Licensing Digital Upgrades, the inspectors did not identify a violation of
NRC requirements. Therefore, Unresolved Item URI 05000483/2013005-01, Solid
State Protection System Modifications, was closed.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On February 12, 2014, the inspector conducted a debrief of the review of the licensees buried
piping program. After additional in-office review, the inspector conducted an exit meeting with
Mr. G. Kramer, Director of Engineering Programs, on March 28, 2014. The licensee
acknowledged the issues presented. The inspector verified that no proprietary information was
reviewed.
On April 24, 2014, the inspector presented the results of the onsite inspection of the licensees
emergency preparedness program to Mr. D. Neterer, Vice President, Engineering, and other
members of the licensee staff. The licensee acknowledged the issues presented. The licensee
confirmed that any proprietary information reviewed by the inspectors had been returned or
destroyed.
- 24 -
On July 1, 2014, the inspectors presented the inspection results to Mr. F. Diya, Senior Vice
President and Chief Nuclear Officer, and other members of the licensee staff. The licensee
acknowledged the issues presented. The licensee confirmed that any proprietary information
reviewed by the inspectors had been returned or destroyed.
4OA7 Licensee-Identified Violations
The following violation of very low safety significance (Green) was identified by the licensee and
is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for
being dispositioned as a non-cited violation.
- Title 10 of the Code of Federal Regulations, Part 50.54(q)(2), requires in part, that a
reactor licensee follow an emergency plan meeting the requirements of 10 CFR Part 50,
Appendix E, and the 10 CFR 50.47(b) planning standards. Contrary to the above, on
July 26, 2013, Callaway Plant failed to follow an emergency plan meeting the
requirements of the 10 CFR 50.47(b) planning standards. Specifically, the licensee
failed to implement an emergency action level scheme meeting the requirements of
10 CFR 50.47(b)(4) during a plant event. The licensee classified a Notification of
Unusual Event on July 26, 2013, based on emergency action level HU2.1, Non-hostile
initiated fire not extinguished within 15 minutes of Control Room notification or valid
Control Room alarm. The licensee subsequently determined that the emergency action
level did not apply because the fire was not in a location listed on Table H-2 as required
by the technical basis document. The finding was more than minor because it affected
the Emergency Preparedness Cornerstone objective and the emergency response
organization performance cornerstone attribute. The finding was evaluated using
Manual Chapter 0609, Appendix B, Emergency Preparedness Significance
Determination Process, Attachment 2, Failure to Implement, and was determined to be
of very low safety significance (Green) because the classification was a Notification of
Unusual Event. The issue was entered into the licensees corrective action program as
Callaway Action Requests 201305943 and 201305944.
- 25 -
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
M. Daly, Supervisor, Corrective Action Program
F. Diya, Senior Vice President and Chief Nuclear Officer
R. Eickelman, Supervisor, Operations
T. Elwood, Supervising Engineer, Regulatory Affairs/Licensing
J. Geyer, Director, Nuclear Oversight
L. Graessle, Senior Director, Operations Support
J. Imhoff, System Engineer, NSSS Systems
J. Kovar, Engineer, Regulatory Affairs/Licensing
G. Kramer, Director, Engineering Programs
S. Maglio, Manager, Regulatory Affairs
P. McKenna, Assistant Manager, Protective Services (Emergency Preparedness)
J. McLaughlin, System Engineer, NSSS Systems
S. Petzel, Engineer, Regulatory Affairs/Licensing
D. Neterer, Vice President, Nuclear Operations
C. Smith, Manager, Radiation Protection
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
05000483/2014003-01 FIN Plastic Shipping Plug in Rosemount Transmitter (Section 1R15)05000483/2014003-02 NCV Inadequate Extent of Condition Review (Section 4OA5)
Closed
2515/182 TI Review of the Industry Initiative to Control Degradation of
Underground Piping and Tanks (Section 4OA5)05000483/2013005-01 URI Solid State Protection System Modifications (Section 4OA5)
LIST OF DOCUMENTS REVIEWED
Section 1R01: Adverse Weather Protection
Procedures
Number Title Revision
AUE-ADM-2222 Communication and Coordination 0
AUE-ADM-2223 Disturbance Reporting 0
AUE-ADM-2227 Reliability Coordination - Responsibility and Authorities 0
Attachment 1
Procedures
Number Title Revision
DTI-E-00009 Using Safety Monitor 3
DP-ZZ-01129 Callaway Energy Center Risk Assessment 40
PDP-ZZ-00027 Summer Reliability Program 4
ODP-ZZ-00002, Equipment Status Control 72
Attachment 4
OSP-NB-00001 Class 1E Electrical Source Verification 38
OSP-NE-00003 Technical Specification Actions - A.C. Sources 26
OTO-MA-00008 Rapid Load Reduction 29
OTO-ZZ-00012 Severe Weather 27
Callaway Action Requests
201305943 201308354 201400743 201402651 201207599
Section 1R04: Equipment Alignment
Procedures
Number Title Revision
OTN-GK-00001 Control Building Heating, Ventilation and Air Conditioning 42
System
OTN-GK-00001, Control Building Heating, Ventilation and Air Conditioning 13
Checklist 1 System Electrical Equipment Lineup
OTN-GK-00001, Control Building Heating, Ventilation and Air Conditioning 15
Checklist 2 System Normal Valve Lineup by Compartment
OTS-ZZ-00007 Plant Cold Weather 28
OTN-EJ-00001 Residual Heat Removal System 27
OTN-EJ-00001, Residual Heat Removal System - B RHR Electrical 19
Checklist 2 Equipment Standby Safety Injection Lineup
OTN-EJ-00001, Residual Heat Removal System - B RHR System Standby 20
Checklist 4 Safety Injection Valve Lineup (Includes Components on SIS
Hot Leg Recirc)
OTN-EJ-00001, Residual Heat Removal System - B RHR Train Main 19
Checklist 8 Control Board Standby Safety Injection Lineup
OTN-AL-00001 Auxiliary Feedwater System 32
OTN-AL-00001, Auxiliary Feedwater Valve Alignment 21
Checklist 1
OTN-GG-00001 Fuel Building HVAC System 28
A1-2
Procedures
Number Title Revision
OTN-GG-00001, Fuel Handling Building HVAC System Valve and Damper 15
Checklist 1 Lineup
OTN-GG-00001, Fuel Handling Building HVAC System Breaker Lineup 13
Checklist 2
OTN-GG-00001, Fuel Handling Building HVAC System Switch Lineup 13
Checklist 3
Drawings
Number Title Revision
M-22EJ01 Piping & Instrumentation Diagram - Residual Heat Removal 59
System
M-22GK01 Piping & Instrumentation Diagram Control Building Heating, 20
Ventilation and Air Conditioning
M-22GK02 Piping & Instrumentation Diagram Control Building Heating, 19
Ventilation and Air Conditioning
M-22GK03 Piping & Instrumentation Diagram Control Building Heating, 23
Ventilation and Air Conditioning
M-22GK04 Piping & Instrumentation Diagram Control Building Heating, 19
Ventilation and Air Conditioning
M-22AL01 Piping & Instrumentation Diagram, Auxiliary Feedwater 43
System
Callaway Action Requests
201300894 201402724 201403015 201401549
Job
14000300
Miscellaneous
Number Title Date
2013002 Vibration Induced Wear on SGK04A/B and SGK05A/B has May 26, 2013
Caused Unplanned Out-of-Service Time
A1-3
Section 1R05: Fire Protection
Procedures
Number Title Revision
Fire Preplan Manual 37
FPP-ZZ-00001, Pre-Plan/Fire Area #A-2A, Auxiliary Building, 1967 24
Attachment 2 Elevation
FPP-ZZ-00004, Pre-Plan/Fire Area #C-13, Control Building and 17
Attachment 17 Communications Corridor, 2016 Elevation
FPP-ZZ-00004, Pre-Plan/Fire Area #C-21, Control Building and 17
Attachment 26 Communications Corridor, 2032 Elevation
FPP-ZZ-00004, Pre-Plan/Fire Area #C-27, Control Building and 17
Attachment 32 Communications Corridor, 2047 Elevation
FPP-ZZ-00004, Pre-Plan/Fire Area #C-22, Control Building and 17
Attachment 43 Communications Corridor, 2032 Elevation
FPP-ZZ-00007, Pre-Plan/Fire Area #T-14, Transformers (West of Turbine 13
Attachment 4 Building - In Yard) 2000
Drawings
Number Title Revision
A-2802 Fire Delineation - Floor Plan, Elevation 2000-0 12
A-2804 Fire Delineation - Floor Plan, Elevation 2047-6 25
Miscellaneous
Number Title Date
RFR 14421 Approval of ABC Fire Extinguishers on Carts July 2, 1997
Section 1R06: Flood Protection Measures
Drawing
Number Title Revision
M-2G051 Equipment Locations - Control & Diesel Generator 39
Buildings and Communication Corridor Plan
Elevation 2000-0 and 2016-0
Callaway Action Requests
201401795 201203302 201403604 201403841
A1-4
Job
13514414
Miscellaneous
Number Title Date
RFR 018299A Use and Storage of Protective Mats October 7, 1997
Photos of Manhole MH01B December 12, 2013
Photos of Manhole MH01B June 5, 2014
Section 1R07: Heat Sink Performance
Jobs
09511826 09511945
Section 1R11: Licensed Operator Requalification Program
Procedures
Number Title Revision
ODP-ZZ-00001 Operations Department - Code of Conduct 89
OSP-AL-V001C Turbine Driven Auxiliary Feedwater Valve Inservice 53
Test
OTG-ZZ-00004, Reactor Control During Power Operations 1
Addendum 1
OTN-BG-00002 Reactor Makeup Control and Boron Thermal 44
Regeneration System
Miscellaneous
Number Title Date
CA2698 Procedure Controlled Temporary Modification April 27, 2014
Approval, Installation and Removal [OSP-AL-V001C
Jumper Hoses]
T61.0810.8 Dynamic Simulator Exam Scenario, DS-13 February 25, 2014
T61.0810.8 Dynamic Simulator Exam Scenario, DS-19 February 26, 2014
A1-5
Section 1R12: Maintenance Effectiveness
Procedures
Number Title Revision
APA-ZZ-00500 Operability and Functionality Determinations 21
Appendix 1
APA-ZZ-00500 Maintenance Rule (MR) 16
Appendix 5
EDP-ZZ-01114 Motor Operated Valve Program Guide 26
Drawing
Number Title Revision
E-23EF02 Essential Service Water to Service Water System 17
Isolation Valve EFHV23
Callaway Action Requests
201301108 201400933 201307915 201400092 201401116
Jobs
14000573 05510322 11000253 13006167 13509117
Miscellaneous
Number Title Revision/Date
M-GL-390 Callaway Auxiliary Building Essential Service Water- 1
Supplied Heating, Ventilation and Air Conditioning
OOA-SA-C066X Engineered Safety Feature (ESF) Status Panel 14
SA066X Alarm Information
OOA-SA-C066Y Engineered Safety Feature Status (ESF) Panel 15
SA066Y Alarm Information
RFR 16987 Jumper Close Torque Switch on Butterfly Motor February 13, 2007
Operated Valves with Close Safety Function
Section 1R13: Maintenance Risk Assessment and Emergent Work Controls
Procedures
Number Title Revision
EDP-ZZ-01129 Callaway Energy Center Risk Assessment 39
ODP-ZZ-00002 Equipment Status Control 74
A1-6
Procedures
Number Title Revision
ODP-ZZ-00002 Risk Management Actions for Planned Risk 8
Appendix 2 Significant Activities
ODP-ZZ-00002 Door Postings for A Train ESW and/or Emergency 1
Appendix 2 CL 1 Diesel Generator being Out-of-Service
ODP-ZZ-00002 Door Postings for TDAFP (PAL02) being 1
Appendix 2 CL 5 Out-of-Service
OTN-GK-00001 Control Building Heating, Ventilation and Air 30
Conditioning System
Callaway Action Requests
201402036 201403004 201403463 201403474 201403486
201308995 201110202 201307763 201400020 201309694
Jobs
13512067 14501172 14501233 14501194 14002312
Miscellaneous
Number Title Date
MG 10-2001 Energy Management Guide for Selection and 2001
Use of Fixed Frequency Medium AC Squirrel-Cage
Polyphase Induction Motors
Section 1R15: Operability Evaluations
Procedures
Number Title Revision
MTE-ZZ-NG001 Leak Control, Recovery, and Recycling of Refrigerant 13
MTE-GK-QC001 Control Room and Class 1E Air Conditioning Unit 9
Charging
OTN-EN-00001 Containment Spray System 23
Callaway Action Requests
201011748 201101473 201203302 201208791 201401278
201401587 201401683 201401795 201403300 201403604
201403902
A1-7
Jobs
14000139 14504911 07511235
Miscellaneous
Number Title Revision
M-GG-404 Fuel Building Cooling Load and Equipment Selection 0
M-GG-404, Change in Fuel Building Roof R Value 0
Addendum 4
Section 1R19: Post-Maintenance Testing
Procedures
Number Title Revision
APA-ZZ-00340 Surveillance Program Administration 35
APA-ZZ-00340, Surveillance Frequency Control Program 0
Appendix 1
APA-ZZ-00340, Surveillance Frequency Control Program Surveillance 2
Appendix 4 Test Interval List
ESP-GG-03004 FGG02A In-Place Bypass Leakage Test 16
ETP-ZZ-03005 In-Place Bypass Leakage Testing of HEPA Filters 9
ETP-ZZ-03005, HEPA Filter Leak Test Results 9
Attacment1
MSE-GG-QG001 Emergency Exhaust System Flow Rates - A Train 14
OSP-GG-0001A A Train Emergency Exhaust System Operability Test 10
OSP-NE-0001A Standby Diesel Generator A Periodic Tests 55
OSP-EF-P001B Essential Service Water Train B Inservice Test 68
OSP-EF-0003B Train B Ultimate Heat Sink Cooling Tower Fans Test 9
OSP-EJ-P001A Residual Heat Removal Train A Inservice Test - Group A 55
Drawings
Number Title Revision
M-22GG01(Q) Piping and Instrumentation Diagram, Fuel Building HVAC 15
M-22GG02(Q) Piping and Instrumentation Diagram, Fuel Building HVAC 13
A1-8
Callaway Action Requests
201402064 201402066 201402086 201402101 201402113
201402761 201402775 201402810 201404106
Jobs
11504452 11508685 12511470 12511471 12511473
12512029 12513399 13512067 14001821
Miscellaneous
Number Title Revision
FSAR 6.5.1 Engineered Safety Feature Filter Systems OL-19
FSAR Table 6.5-1 ESF Filtration Systems Input Parameters To OL-13
Chapter 15.0 Accident Analysis
FSAR Table 9.4-6 Design Data For Fuel Building HVAC System OL-17
Components
Technical Emergency Exhaust System Amendment
Specification 3.7.13 Number 198
Section 1R22: Surveillance Testing
Procedures
Number Title Revision
OSP-BB-00009 Reactor Coolant System Inventory Balance 35
OSP-GG-0001A A Train Emergency Exhaust System Operability Test 10
OSP-AL-V001C Turbine Driven Auxiliary Feedwater Valve Inservice Test 53
OSP-GT-00005 Containment Isolation Dampers Operational Test 18
OSP-AL-P001B Motor Driven Auxiliary Feedwater Pump B Inservice Test - 57
Group A
OSP-EM-P001A Safety Injection train A Inservice Test - Group B 48
Drawings
Number Title Revision
M-22AL01 Piping and Instrumentation Diagram, Auxiliary Feedwater 43
System
M-22KA05 Piping and Instrumentation Diagram, Compressed Air 16
System
A1-9
Drawings
Number Title Revision
M-22GT01 Piping and Instrumentation Diagram, Containment Purge 26
Systems HVAC
Callaway Action Request
201402889
Jobs
14502916 14501153 14001902 14501883 14502261
14505240 14502660
Miscellaneous
Number Title Date
CA2698 Procedure Controlled Temporary Modification Approval, April 27, 2014
Installation and Removal
[OSP-AL-V001C Jumper Hoses]
CA2698 Procedure Controlled Temporary Modification Approval, April 27, 2014
Installation and Removal
[OSP-EM-P001A Temporary Gauges]
Section 1EP2: Alert and Notification System Testing
Procedures
Number Title Revision
KSP-ZZ-00008 Tone Alert Radios 4-5
KSP-ZZ-00110 Siren Alerting System Testing 10-11
Callaway Action Requests
201206488 201206544 201306554 201306560 201207337
201208462 201208644 201208970 201300045 201300495
201300598 201302644 201302797 201303103 201304143
201304533 201307744 201400415
Miscellaneous
Number Title Date
Letters of Agreement, Callaway Electric Cooperative January 9, 2014,
and January 8, 2013
A1-10
Miscellaneous
Number Title Date
Letters of Agreement, Three Rivers Electric January 9, 2014,
Cooperative and January 8, 2013
Letters of Agreement, Ameren Energy Delivery January 9, 2014,
and January 8, 2013
Letters of Agreement, Missouri School for the Deaf January 9, 2014,
and January 8, 2013
Callaway Plant, Alert and Notification System Design April 2011
Report
Callaway Plant, Alert and Notification System Design January 2013
Report
Siren System Maintenance Logs, 2013, 2014
Siren System Semi-Annual Preventative
Maintenance and Repair Checklists, 2013, 2014
12501700/500 Annual Tone Alert Radio Audit Surveillance March 19, 2013
13503075/500 Annual Tone Alert Radio Audit Surveillance March 17, 2014
12512992 Monthly Distribution of Tone Alert Radios December 6, 2012
13503580 Monthly Distribution of Tone Alert Radios March 29, 2013
13509332 Monthly Distribution of Tone Alert Radios August 1, 2013
13512726 Monthly Distribution of Tone Alert Radios November 1, 2013
14501115 Monthly Distribution of Tone Alert Radios February 1, 2014
14502119 Monthly Distribution of Tone Alert Radios March 4, 2014
Section 1EP3: Emergency Response Organization Staffing and Augmentation System
Procedures
Number Title Revision
EIP-ZZ-00200 Activation of the Callaway Plant Emergency Callout 16
System
EIP-ZZ-A0001 Emergency Response Organization 15
KSP-ZZ-00201 Emergency Augmentation Drill / Test 6
Callaway Action Requests
201206366 201207063 201208031 201208673 201304680
A1-11
Miscellaneous
Number Title Date
Emergency Notification System (Everbridge Proposal) June 6, 2012
12506726 ERO Augmentation Drill/Test, Augmentation Testing September 27, 2012
Results
12510457 ERO Augmentation Drill/Test, Augmentation Testing November 14, 2012
Results
12512288 ERO Augmentation Drill/Test, Augmentation Testing March 1, 2013
Results
13502338 ERO Augmentation Drill/Test, Augmentation Testing June 10, 2013
Results
13507493 ERO Augmentation Drill/Test, Augmentation Testing August 29, 2013
Results
13510470 ERO Augmentation Drill/Test, Augmentation Testing November 20, 2013
Results
13513640 ERO Augmentation Drill/Test, Augmentation Testing January 15, 2014
Results
Section 1EP4: Emergency Action Level and Emergency Plan Changes
Miscellaneous
Title Date
50.54(q) Evaluation for the Radiological Emergency March 25, 2014
Response Plan, Revision 44
Section 1EP5: Maintenance of Emergency Preparedness
Procedures
Number Title Revision
Callaway Radiological Emergency Response Plan 42, 43
APA-ZZ-00500 Corrective Action Program 60
APA-ZZ-00500, Screen Process Guidelines 19-20
Appendix 17
EIP-ZZ-00260 Event Closeout and Plant Recovery 25
EIP-ZZ-A0020 Maintaining Emergency Preparedness 28
GDP-ZZ-01810 Nuclear Safety Oversight Assessment Coverage 51
KDP-ZZ-00013 Emergency Response Facility and Equipment 11
Evaluation
A1-12
Procedures
Number Title Revision
KDP-ZZ-00013, Equipment Import to Emergency Response Matrix 0
Appendix 1
KDP-ZZ-00400 RERP Impact Evaluations and Changes 21
KSP-ZZ-00602 Verification of Emergency Instruction Postings 2
KDP-ZZ-02001 Drill and Exercise Program 14
Callaway Action Requests
201206556 201207063 201207686 201208519 201300598
201300896 201304389 201304521 201304664 201305116
201306031 201306221 201306237 201306493 201306552
201306640 201306649 201307252 201307316 201307457
201307458 201307697 201307875 201308282 201308781
201400836 201401069 201401110 201401558
Miscellaneous
Number Title Date
AP12-008 Nuclear Oversight Audit of Emergency Preparedness August 27, 2012
AP-13-007 Nuclear Oversight Audit of Emergency September 5, 2013
Preparedness
SP12-023 Functional Area Assessment Report, March 13, 2013
October 16 to 31, 2012
SP12-024 Functional Area Assessment Report, March 18, 2013
November 1 to 15, 2012
SP12-025 Functional Area Assessment Report, April 1, 2013
November 16 to 30, 2012
SP13-001 Functional Area Assessment Report, July 13, 2013
January 1 to 31, 2013
SP13-020 Functional Area Assessment Report, October 31, 2013
September 1 to 30, 2013
SP14-002 Functional Area Assessment Report, March 25, 2014
February 1 to 28, 2014
After-Action Report: Radiological Monitoring Drill September 6, 2012
After-Action Report: Certification Drill September 28, 2012
A1-13
Miscellaneous
Number Title Date
After-Action Report: ERO Minimum Staffing Drill,
Cycle 12-5
After-Action Report: Health Physics Drill October 25, 2012
After-Action Report: Shift Manager Drill November 1, 2012
After-Action Report: Contaminated Injured Worker November 8, 2012
Drill
After-Action Report: ERO Training Tabletop Drill February 2013
After-Action Report: Team 3 Drill December 4, 2012
After-Action Report: Teams 1 and 2 Turnover Drill March 5, 2013
After-Action Report: Notification of Unusual Event July 26, 2013,
After-Action Report: Team 3 Rehearsal Exercise August 13, 2013
After-Action Report: Team 3 Biennial Exercise September 24, 2013
After-Action Report: Rapid Responder Drills November to
December 2013
After-Action Report: Health Physics Drill March 13, 2014
After-Action Report: Team Drill March 13, 2014
After-Action Report: Table Top Drills January to
February 2014
12507720 Callaway Plant, 2013 Population Update Analysis May 29, 2013
50.54(q) Evaluation for EIP-ZZ-00102 May 15, 2013
50.54(q) Evaluation for EIP-ZZ-01211 July 10, 2013
50.54(q) Evaluation for EIP-ZZ-PR020 May 17, 2013
50.54(q) Evaluation for KDP-ZZ-02001 March 20, 2013
50.54(q) Evaluation for KSP-ZZ-00110 January 17, 2014
50.54(q) Evaluation for RERP September 13, 2013
50.54(q) Evaluation for Procedure E-1, Revision 15 October 3, 2013
50.54(q) Evaluation for EIP-ZZ-00240 and EIP-ZZ- July 22, 2013
C0010
50.54(q) Evaluation for EIP-ZZ-PR020 October 16, 2013
50.54(q) Evaluation for KDP-ZZ-00300 April 15, 2013
50.54(q) Evaluation for KDP-ZZ02002 July 16, 2013
50.54(q) Evaluation for OTO-SK-00003, Revision 5 October 3, 2013
A1-14
Miscellaneous
Number Title Date
201200168-04 Self-Assessment: EP Field Monitoring and E Team October 15, 2012
Dispatch
2013000022-12 Self-Assessment: EP Program Assessment and September 25, 2013
Exercise Readiness
2013000024-19 Self-Assessment: Emergency Response November 27, 2013
Organization Training
1150946/500 Emergency Instruction Posting Locations July 16, 2012
12507973/500 Emergency Instruction Posting Locations July 19, 2013
Section 1EP6: Drill Evaluation
Callaway Action Requests
201403185 201403200 201403220
Miscellaneous
Number Title Date
Emergency Preparedness Team Drill May 8, 2014
Section 4OA1: Performance Indicator Verification
Procedures
Number Title Revision
EIP-ZZ-00101 Classification of Emergencies 48-49
EIP-ZZ-00101, Emergency Action Level Classification Matrix 3
Addendum 1
EIP-ZZ-00101, Emergency Action Level Technical Basis Document 6-7-8
Addendum 2
EIP-ZZ-00102 Emergency Implementing Actions 53-54-55-56
EIP-ZZ-00201 Notifications 49-50
EIP-ZZ-00201, Control Room Notification Package 20-21
Addendum A
EIP-ZZ-00201, EOF Notification Package 21
Addendum C
EIP-ZZ-00212 Protective Action Recommendations 24-25
KDP-ZZ-02000 NRC Performance Indicator Data Collection 15
A1-15
Callaway Action Requests
201207949 201306537 201309521 201309528 201401110
Miscellaneous
Number Title Date
2Q13 to 1Q14 OSP-BB-00009 results May 28, 2014
CA2567 NRC Performance Indicator Transmittal Report July 3, 2013
CA2567 NRC Performance Indicator Transmittal Report October 21, 2013
CA2567 NRC Performance Indicator Transmittal Report January 9, 2013
CA2567 NRC Performance Indicator Transmittal Report April 9, 2013
MSPI Derivation Report, Heat Removal System June 2013
MSPI Derivation Report, Heat Removal System September 2013
MSPI Derivation Report, Heat Removal System December 2013
MSPI Derivation Report, Heat Removal System March 2014
Section 4OA2: Identification and Resolution of Problems
Procedures
Number Title Revision
APA-ZZ-00007 Nuclear Oversight Organization, Responsibility and 31
Conduct of Operations
GDP-ZZ-01810 Nuclear Oversight Assessment Coverage 52
GDP-ZZ-01810 Nuclear Oversight Assessment Coverage 53
GDP-ZZ-01810 Nuclear Oversight Assessment Coverage 54
GDP-ZZ-01820 Nuclear Oversight Functional Area Assessment 4
GDP-ZZ-01820 Nuclear Oversight Functional Area Assessment 5
GDP-ZZ-01820 Nuclear Oversight Functional Area Assessment 6
Callaway Action Requests
201401350 201402093 201403604 201400020 201403868
Miscellaneous
Number Title Revision
DTI-002 Desktop Instruction - Performance Assessment 14
A1-16
Miscellaneous
Number Title Revision
DTI-011 Desktop Instruction - Nuclear Oversight Department 27
- Statement of Vision, Mission, Goals, and
Expectations
DTI-016 Desktop Instruction - NOS Performance 14
Management
DTI-029 Desktop Instruction - Nuclear Oversight Audit & 41
Surveillance Guide
DTI-029 Desktop Instruction - Nuclear Oversight Audit & 42
Surveillance Guide
Section 4OA5: Other Activities
Procedures
Number Title Revision
APA-ZZ-00500 Corrective Action Program 57
EDP-ZZ-01011 Buried Pipe inspection Program 8
QCP-ZZ-05000 Liquid Penetrant Examination 23
QCP-ZZ-05019 Ultrasonic Thickness Measurement 13
13514548.505 CPRQH1001 Track Two Month Cathodic Protection
Rectifier Survey
12508427.500 Annual Cathodic Protection Survey 1
MSM-KJ-QT0001 10 Year Emergency Diesel Generator Fuel Oil 10
Storage Tank Cleaning
APA-ZZ-00500, Adverse Condition - Significance Level 3 15
Appendix 14
Callaway Action Requests
200608046 200909892 201009242 201108240 201110490
201204441 201303200 201303205 201304105 201307568
Work Orders
08514026 10006447 10513868 10514536 11502794
11505576 11511955 1152530 13003026 13510911
13510912 13511349 13511350
A1-17
Miscellaneous
Number Title Revision/Date
M-2G006 Site Interface Underground Piping Location Drawing August 12,1995
M-23BN01 Piping Isometric: Borated Refueling Water Storage June 3, 1981
System Auxiliary Building
BOP-PT-13-048 Liquid Penetrant Examination Report April 26, 2013
BOP-PT-13-047 Liquid Penetrant Examination Report May 2, 2013
5019-13-140 Ultrasonic Thickness Report April 26, 2013
BN-29 Minwall Determination of Various Buried Piping for
Refueling Outage 19
Various Laboratory Tests on Soil Samples July 2009 -
May 2013
10006447-500 As Found Buried Piping Inspection Form May 23, 2013
1200481.401 Refueling Outage 19 GWT Assessment on November 7, 2013
Refueling Water Storage Tank Piping
Buried Pipe Program Health Report Third Quarter October 15, 2013
2013
Buried Pipe Program Health Report Fourth Quarter January 15, 2014
2013
Self-Assessment of the Buried Pipe Inspection July 28, 2009
Program
Self-Assessment of the Buried Pipe Inspection September 16, 2011
Program
Buried Pipe Simple Self-Assessment October 28, 2013
1000062.401 Site Specific Risk Report: Callaway Nuclear Plant September 29, 2010
Condition Assessment Plan December 10, 2012
12000962 As Found Buried Piping Inspection Form June 21, 2012
5019-10-250 Ultrasonic Thickness Report May 5, 2010
5019-10-251 Ultrasonic Thickness Report May 5, 2010
5019-12-011 Ultrasonic Thickness Report June 25, 2012
12508427/500 Annual Cathodic Protection System Survey June 24, 2013
Cathodic Protection System Health Report January 30, 2014
Buried Piping Long Term Asset Management Plan May 2013
2-BN-C1-F004 Weld Control Record November 2, 1979
Hydrostatic Pneumatic Test Report March 13, 1982
A1-18
Miscellaneous
Number Title Revision/Date
Hydrostatic Pneumatic Test Report January 28, 1982
MP 10-0053 Solid State Protection System Printed Circuit Board 000.2
Replacement
Evaluation 13-02 50.59 Evaluation of Modification Package 10-0053 April 7, 2013
WNA-TR-02644- Solid State Protection System New Design Circuit 0
SCP Board Final Logic Test Report
0 Westinghouse Solid State Protection System Board 0
Replacement Licensing Summary Report
WCAP-16769-P Westinghouse Universal Logic Board Replacement 0
Summary Report
A1-19
Callaway SSPS Replacement Questions (05/13/2014)
1. As described in USAR Section 3.10, the SSPS was tested in accordance with the criteria
specified in IEEE 344-1975. However, the replacement CLPDs were tested using the
criteria defined in IEEE 344-1987. How were the differences in these IEEE standards
reconciled?
2. What are the differences between the testing criteria used to seismically qualify the
CPLDs and those used to seismically qualify the original SSPS?
3. Did Westinghouse use the same test inputs for the qualification of the CPLDs that were
specified in WCAP-7817 for the original seismic design of the SSPS?
4. How does the seismic response spectra, used by Westinghouse in the development of
the CLPDs, envelope the required design basis response spectra for the SSPS
cabinets?
Attachment 2