IR 05000483/2005001

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Annual Assessment Letter - Callaway Plant (Report 05000483/2005001)
ML050610260
Person / Time
Site: Callaway Ameren icon.png
Issue date: 03/02/2005
From: Howell A
NRC/RGN-IV/DRP
To: Naslund C
Union Electric Co
References
IR-05-001
Download: ML050610260 (9)


Text

rch 2, 2005

SUBJECT:

ANNUAL ASSESSMENT LETTER - CALLAWAY PLANT (REPORT 05000483/2005001)

Dear Mr. Naslund:

On February 2, 2005, the NRC staff completed its end-of-cycle plant performance assessment of the Callaway Plant. The end-of-cycle review for Callaway Plant involved the participation of the reactor technical divisions in evaluating performance indicators (PIs) for the most recent quarter and inspection results for the period from January 1 through December 31, 2004. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility so that you will have an opportunity to prepare for these inspections and to inform us of any planned inspections that may conflict with your plant activities.

This performance review and enclosed inspection plan do not include physical protection information. A separate end-of-cycle performance review letter designated and marked as Exempt from Public Disclosure in Accordance with 10 CFR 2.390 will include the physical protection review and resultant inspection plan.

Overall, Callaway Plant operated in a manner that preserved public health and safety and fully met all cornerstone objectives. Plant performance for the most recent quarter was within the Licensee Response Column of the NRCs Action Matrix, based on all inspection findings being classified as having very low safety significance (Green) and all PIs indicating performance at a level requiring no additional NRC oversight (Green).

While plant performance for the most recent quarter was within the Licensee Response column of the Action Matrix, there were safety significant PIs identified during the second and third quarters of 2004. The PI for unplanned scrams per 7000 critical hours crossed the Green to White threshold in the second quarter of 2004 as a result of three reactor trips in the first quarter of 2004, and the PI remained White during the third quarter of 2004. A supplemental inspection was conducted between November 1-8, 2004, in accordance with Inspection Procedure 95001, Inspection for One or Two White Inputs in a Strategic Performance Area. We concluded that you had adequately evaluated the associated conditions and events.

Union Electric Company -2-Additionally, the NRC staff has identified a substantive crosscutting issue in the area of Human Performance. This assessment was based on seven findings with human performance aspects specifically related to personnel errors that occurred in the Initiating Events, Mitigating Systems, and Barrier Integrity cornerstones. These findings included instances of plant personnel failing to follow procedures that resulted in a reactor trip, a safety injection, an overspeed trip of the turbine-driven auxiliary feedwater pump following an automatic initiation during a plant transient, and an inadvertent transfer of water from the spent fuel pool to the refueling water storage tank.

Additionally, fire watches were not posted as required during welding activities, which resulted in a fire remaining undetected until the fire detection systems actuated. Also, a reflash watch was not posted following initial extinguishing of the fire, which allowed the fire to reignite without being quickly detected. This substantive crosscutting issue regarding human performance is of concern because failures to follow plant procedures resulted in increased challenges to plant equipment from preventable transients and events. Although your staff has taken actions to address human performance problems, these efforts have not been fully effective in preventing additional errors from occurring.

During baseline inspections, the NRC will focus on procedure adherence and corrective actions associated with human performance errors. Samples selected for Problem Identification and Resolution followup will specifically include the review of corrective actions implemented to address human performance issues. NRC will also review your actions with regard to documenting and tracking human performance issues during the semiannual trend review of your corrective action program. The substantive crosscutting issue will be closed when the assessment of performance, as determined by inspection findings, indicates that your actions have been effective in reducing the frequency, number, and impact of human performance issues.

On the basis of the results of an independent survey of the Callaway Plant work environment, your staff implemented a number of actions to address the findings identified during the survey.

Our inspection of your corrective action program, documented in NRC Inspection Report 05000483/2004006, dated April 2, 2004, noted that your corrective actions had not been completely effective in addressing some of the concerns raised in the survey. It is our understanding that a followup survey will be conducted in 2005. We will review the results of the followup survey as part of the baseline inspection program in order to determine whether any further action is necessary.

The enclosed inspection plan details the inspections, less those related to physical protection, scheduled through September 30, 2006. In addition to the baseline inspections, we will also be conducting inspections in accordance with Temporary Instruction 2515/160, Pressurizer Penetration Nozzles and Steam Space Piping Connections in U.S. Pressurized Water Reactors (NRC Bulletin 2004-01), and Inspection Procedure 50001, Steam Generator Replacement Inspection. The inspection plan is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature. The inspections in the last 9 months of the inspection plan are tentative and may be revised at the midcycle review meeting.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public

Union Electric Company -3-Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Mr. David N. Graves at (817) 860-8141 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

Arthur T. Howell III, Director Division of Reactor Projects Docket: 50-483 License: NPF-30 Enclosure:

Callaway Plant Inspection/Activity Plan cc w/enclosure:

Professional Nuclear Consulting, Inc. Ronald A. Kucera, Deputy Director 19041 Raines Drive for Public Policy Derwood, MD 20855 Department of Natural Resources P.O. Box 176 John ONeill, Esq. Jefferson City, MO 65102 Shaw, Pittman, Potts & Trowbridge 2300 N. Street, N.W. Rick A. Muench, President and Washington, DC 20037 Chief Executive Officer Wolf Creek Nuclear Operating Corporation Mark A. Reidmeyer, Regional P.O. Box 411 Regulatory Affairs Supervisor Burlington, KS 66839 Regulatory Affairs AmerenUE Dan I. Bolef, President P.O. Box 620 Kay Drey, Representative Fulton, MO 65251 Board of Directors Coalition for the Environment Missouri Public Service Commission 6267 Delmar Boulevard Governors Office Building University City, MO 63130 200 Madison Street P.O. Box 360 Jefferson City, MO 65102

Union Electric Company -4-Les H. Kanuckel, Manager Gabe Craighead Quality Assurance Eastern District Commissioner AmerenUE Callaway County Courthouse P.O. Box 620 10 East 5th Street Fulton, MO 65251 Fulton, MO 65251 Director Donald "Doc" Kritzer State Emergency Management Agency Western District Commissioner P.O. Box 116 Callaway County Courthouse Jefferson City, MO 65102-0116 10 East 5th Street Fulton, MO 65251 Scott Clardy, Director Section for Environmental Public Health The Honorable Robert Craghead P.O. Box 570 Mayor of Fulton Jefferson City, MO 65102-0570 Fulton City Hall P.O. Box 130 Keith D. Young, Manager Fulton, MO 65251 Regulatory Affairs AmerenUE William Johnson P.O. Box 620 Fulton City Administrator Fulton, MO 65251 Fulton City Hall P.O. Box 130 David E. Shafer Fulton, MO 65251 Superintendent, Licensing Regulatory Affairs Steve Myers AmerenUE Chief of Police P.O. Box 66149, MC 470 Fulton City Hall St. Louis, MO 63166-6149 P.O. Box 130 Fulton, MO 65251 Certrec Corporation 4200 South Hulen, Suite 630 Dennis Crane Fort Worth, TX 76109 Sheriff, Callaway County P.O. Box 817 Tim Diemler Fulton, MO 65251 Emergency Preparedness Director The Honorable Tom Shackelford Callaway County/Fulton Mayor of Mokane P.O. Box 817 P.O. Box 41 Fulton, MO 65251 Mokane, MO 65059 Lee Fritz Richard Hudson, Director Presiding Commissioner Emergency Management Callaway County Courthouse Gasconade County Courthouse 10 East 5th Street P.O. Box 295 Fulton, MO 65251 Hermann, MO 65041

Union Electric Company -5-Ron Jost Rich Daniels Presiding Commissioner First District Commissioner Gasconade County Courthouse Montgomery County Courthouse 119 East First Street 211 East Third Hermann, MO 65041 Montgomery City, MO 63361 Max Aubuchon John Noltensmeyer Northern District Commissioner Second District Commissioner Gasconade County Courthouse Montgomery County Courthouse 119 East First Street 211 East Third Hermann, MO 65041 Montgomery City, MO 63361 Jerry Lairmore Robert Davis Southern District Commissioner Sheriff, Montgomery County Gasconade County Courthouse Montgomery County Courthouse 119 East First Street 211 East Third Hermann, MO 65041 Montgomery City, MO 63361 Glenn Ebker The Honorable Steve Wehrle Sheriff, Gasconade County Mayor of Rhineland Gasconade County Courthouse P.O. Box 384 119 East First Street Rhineland, MO 65069 Hermann, MO 65041 Bradley Strope Fay Owsley Emergency Management Gasconade County Public Director Administrator Osage County Courthouse Gasconade County Courthouse P.O. Box 1011 119 East First Street Linn, MO 65051 Hermann, MO 65041 Russell J. Scheulen The Honorable Samuel Birk Presiding Commissioner Mayor of Morrison Osage County Courthouse Route 1 P.O. Box 826 Morrison, MO 65061 Linn, MO 65051 Bob Bishop Jerry G. Wolfe Emergency Management Director First District Commissioner Montgomery County Courthouse Osage County Courthouse 211 East Third P.O. Box 826 Montgomery City, MO 63361 Linn, MO 65051 Charles Korman Daryl L. Luecke Presiding Commissioner Second District Commissioner Montgomery County Courthouse Osage County Courthouse 211 East Third P.O. Box 826 Montgomery City, MO 63361 Linn, MO 65051

Union Electric Company -6-Carl Fowler Sheriff, Osage County Osage County Courthouse P.O. Box 826 Linn, MO 65051 The Honorable Vernon McKague Mayor of Chamois Star Route Chamois, MO 65024 Federal Emergency Management Agency Mr. Dick Hainje, Regional Director Region VII 2323 Grand Blvd., Suite 900 Kansas City, MO 64108-2670 Institute of Nuclear Power Operations (INPO)

Records Center 700 Galleria Parkway SE, Suite 100 Atlanta, GA 30339

Union Electric Company -7-Electronic distribution by RIV:

Regional Administrator (BSM1)

DRP Director (ATH)

DRS Director (DDC)

DRS Deputy Director (MRS)

Senior Resident Inspector (MSP)

Branch Chief, DRP/B (DNG)

Senior Project Engineer, DRP/B (RAK1)

Team Leader, DRP/TSS (RLN1)

RITS Coordinator (KEG)

RidsNrrDipmIipb V. Dricks, PAO (VLD)

W. Maier, RSLO (WAM)

C. Gordon (CJG)

DRS Branch Chiefs (LJS, MPS1, ATG, JAC)

S. Richards, Chief, NRR/DIPM/IIPB (SAR)

M. Case, Deputy Dir. for Inspection and Programs (MJC)

B. Sheron, Associate Dir. for Project Licensing and Technical Analysis (BWS)

B. Wetzel, Acting Chief, ROPMS, OEDO (BAW)

H. Berkow, Director, LPD4, NRR/DLPM (HNB)

R. Gramm, Chief, PDIV-2, NRR/DLPM (RAG)

J. Donohew, Project Manager (JND)

SISP Review Completed: ______ ADAMS: G Yes G No Initials: ______

G Publicly Available G Non-Publicly Available G Sensitive G Non-Sensitive S:\DRP\DRPDIR\EOC 04\Assessment Letters\CWY.wpd RIV:C:DRP/B D:DRS D:DRP DNGraves;df DDChamberlain ATHowell III

/RA/ /RA/ /RA/

2/28/05 2/25/05 2/28/05 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

Page 1 of 2 Callaway 03/01/2005 08:31:07 Inspection / Activity Plan Report 22 03/04/2005 - 09/30/2006 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type PEB-12B - MAINTENANCE EFFECTIVENESS REVIEW 1 1 IP 7111112B Maintenance Effectiveness 03/07/2005 03/11/2005 Baseline Inspections PEB-07B - HX PERFORMANCE 1 1 IP 7111107B Heat Sink Performance 04/25/2005 04/29/2005 Baseline Inspections ALARA2 - ALARA PLANNING AND CONTROLS 1 1 IP 7112102 ALARA Planning and Controls 04/25/2005 04/29/2005 Baseline Inspections OB-EP EX - EMERGENCY PREPAREDNESS EXERCISE 4 1 IP 7111401 Exercise Evaluation 05/02/2005 05/06/2005 Baseline Inspections 1 IP 7111404 Emergency Action Level and Emergency Plan Changes 05/02/2005 05/06/2005 Baseline Inspections 1 IP 71151 Performance Indicator Verification 05/02/2005 05/06/2005 Baseline Inspections RP TEAM - RADIATION SAFETY TEAM INSPECTION 3 1 IP 7112103 Radiation Monitoring Instrumentation and Protective Equipment 05/16/2005 05/20/2005 Baseline Inspections 1 IP 7112201 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems 05/16/2005 05/20/2005 Baseline Inspections 1 IP 7112202 Radioactive Material Processing and Transportation 05/16/2005 05/20/2005 Baseline Inspections 1 IP 7112203 Radiological Environmental Monitoring Program 05/16/2005 05/20/2005 Baseline Inspections OB-INIT - INITIAL EXAM 4 1 X02286 CALLAWAY (05/05) - INITIAL EXAM 08/01/2005 08/05/2005 Not Applicable 1 X02286 CALLAWAY (05/05) - INITIAL EXAM 08/22/2005 08/26/2005 Not Applicable S/G REP1 - STEAM GENERATOR REPLACEMENT 7 1 IP 50001 Steam Generator Replacement Inspection 07/03/2005 10/01/2005 Other Routine 1 IP 7111113 Maintenance Risk Assessments & Emergent Work Evaluation 07/03/2005 10/01/2005 Baseline Inspections 1 IP 7111119 Post Maintenance Testing 07/03/2005 10/01/2005 Baseline Inspections 1 IP 7111120 Refueling and Other Outage Activities 07/03/2005 10/01/2005 Baseline Inspections 1 IP 7111122 Surveillance Testing 07/03/2005 10/01/2005 Baseline Inspections 1 IP 7111123 Temporary Plant Modifications 07/03/2005 10/01/2005 Baseline Inspections OB-RQ - REQUAL INSPECTION 3 1 IP 7111111B Licensed Operator Requalification Program 08/01/2005 08/05/2005 Baseline Inspections EB02/17B - 50.59 & PERM PLANT MODS 2 1 IP 7111102 Evaluation of Changes, Tests, or Experiments 08/22/2005 08/26/2005 Baseline Inspections 1 IP 7111117B Permanent Plant Modifications 08/22/2005 08/26/2005 Baseline Inspections TI -160 - PRESSURIZER NOZZLE WELD INSPECTION 4 1 IP 2515/160 Pzr Pene Nozzles & Stm Space Piping Connections in U.S. PWRs [NRC Bulletin 2004-01] 09/20/2005 09/30/2005 Safety Issues EB08P - ISI - INCL VHP VOL (TI 150) AS REQ 1 1 IP 7111108P Inservice Inspection Activities - PWR 10/03/2005 10/07/2005 Baseline Inspections 1 IP 7111108P Inservice Inspection Activities - PWR 10/17/2005 10/21/2005 Baseline Inspections This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

Page 2 of 2 Callaway 03/01/2005 08:31:07 Inspection / Activity Plan Report 22 03/04/2005 - 09/30/2006 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type S/G REP2 - STEAM GENERATOR REPLACEMENT 7 1 IP 50001 Steam Generator Replacement Inspection 10/02/2005 12/31/2005 Other Routine 1 IP 7111113 Maintenance Risk Assessments & Emergent Work Evaluation 10/02/2005 12/31/2005 Baseline Inspections 1 IP 7111119 Post Maintenance Testing 10/02/2005 12/31/2005 Baseline Inspections 1 IP 7111120 Refueling and Other Outage Activities 10/02/2005 12/31/2005 Baseline Inspections 1 IP 7111122 Surveillance Testing 10/02/2005 12/31/2005 Baseline Inspections 1 IP 7111123 Temporary Plant Modifications 10/02/2005 12/31/2005 Baseline Inspections ACRSA - ACCESS CONTROL TO RAD SIGNIFICANT AREAS 1 1 IP 7112101 Access Control to Radiologically Significant Areas 10/17/2005 10/21/2005 Baseline Inspections ALARA3 - ALARA PLANNING AND CONTROLS 1 1 IP 7112102 ALARA Planning and Controls 12/05/2005 12/09/2005 Baseline Inspections ALARA1 - ALARA PLANNING AND CONTROLS 1 1 IP 7112102 ALARA Planning and Controls 03/20/2006 03/24/2006 Baseline Inspections OB-EP1 - EMERG PREP PROGRAM 1 1 IP 7111402 Alert and Notification System Testing 05/15/2006 05/19/2006 Baseline Inspections 1 IP 7111403 Emergency Response Organization Augmentation Testing 05/15/2006 05/19/2006 Baseline Inspections 1 IP 7111404 Emergency Action Level and Emergency Plan Changes 05/15/2006 05/19/2006 Baseline Inspections 1 IP 7111405 Correction of Emergency Preparedness Weaknesses and Deficiencies 05/15/2006 05/19/2006 Baseline Inspections 1 IP 71151 Performance Indicator Verification 05/15/2006 05/19/2006 Baseline Inspections PEB - CAL PIR INSPECTION 3 1 IP 71152B Identification and Resolution of Problems 07/17/2006 07/21/2006 Baseline Inspections 1 IP 71152B Identification and Resolution of Problems 07/31/2006 08/04/2006 Baseline Inspections EB21 - ENG-SSD&PC 5 1 IP 7111102 Evaluation of Changes, Tests, or Experiments 07/31/2006 08/04/2006 Baseline Inspections 1 IP 7111121 Safety System Design and Performance Capability 07/31/2006 08/04/2006 Baseline Inspections 1 IP 7111121 Safety System Design and Performance Capability 08/14/2006 08/18/2006 Baseline Inspections ACRSA - ACCESS CONTROL TO RAD SIGNIFICANT AREAS 1 1 IP 7112101 Access Control to Radiologically Significant Areas 08/21/2006 08/25/2006 Baseline Inspections PEB-05T - TRIENNIAL FIRE PROTECTION 4 1 IP 7111105T Fire Protection 09/11/2006 09/15/2006 Baseline Inspections 1 IP 7111105T Fire Protection 09/25/2006 09/29/2006 Baseline Inspections This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.