IR 05000483/2006001

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Annual Assessment Letter - Callaway Plant (NRC Inspection Report 05000483-06-001)
ML060610333
Person / Time
Site: Callaway Ameren icon.png
Issue date: 03/02/2006
From: Jones W B
NRC/RGN-IV/DRP/RPB-B
To: Naslund C D
Union Electric Co
References
IR-06-001
Download: ML060610333 (8)


Text

March 2, 2006

Charles D. Naslund, Senior Vice President and Chief Nuclear Officer

Union Electric Company

P.O. Box 620

Fulton, MO 65251

SUBJECT: ANNUAL ASSESSMENT LETTER - CALLAWAY PLANT (NRC INSPECTION REPORT 05000483/2006001)

Dear Mr. Naslund:

On February 7, 2006, the NRC staff completed its performance review of the Callaway Plant.

Our technical staff reviewed performance indicators (PIs) for the most recent quarter and

inspection results for the period from January 1 through December 31, 2005. 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.

This performance review and enclosed inspection plan do not include physical protection information. A separate letter designated and marked as "Official Use Only - Security-Related

Information" will include the physical protection review and resultant inspection plan.

Overall, the 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, as well as

for the first three quarters of the assessment cycle, was within the Licensee Response column

of the NRC's 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). Therefore, we plan to conduct reactor oversight process baseline

inspections at your facility.

In our March 2, 2005, annual assessment letter and as updated in our August 30, 2005,midcycle assessment letter, we informed you of a substantive crosscutting issue in human

performance, which principally involved pers onnel errors that had an impact on plant equipment from preventable events and transients. These e rrors stemmed from instances of failing to follow procedures and from inadequate procedures. The NRC recognizes that progress has

been made by AmerenUE in addressing human perform ance issues, particularly with respect to procedure implementation, as measured by t he an overall decrease in the human performance error rate. However, the NRC has noted that continuing problems have occurred with

procedural and instruction adequacy, including those procedures that have been enhanced as

part of your improvement initiatives in this area, as well as instructions developed during the past year. The procedural improvements and instru ctions developed over the last year have not been fully effective in preventing human performance errors, which indicates that further Union Electric Company- 2 -

improvement in addressing this issue is warranted. There were multiple Green findings affecting the Initiating Events and Mitigating Systems cornerstones. Examples include an inadequate operations procedure that contributed to a reactor trip signal and an unplanned

auxiliary feedwater actuation while shut down, an inadequate surveillance procedure that

resulted in the inadvertent isolation of all plant fire water suppression, an unplanned reactor trip

that occurred because of an inadequate work instruction for work on a power supply, and

inadequate instructions involving the conduct of continuous fire watches. Some of these

examples involved upgraded procedures or an inst ruction that was developed this past year.

Accordingly, the NRC will continue to focus inspection activities within this area in order to assess the effectiveness of your improvement initiatives in reducing operational events and conditions caused by inadequate procedures and instructions. The NRC will use, in part, as its

basis for closure, an assessment of the number of findings that are identified involving

procedural adequacy problems and whether the plant staff recognizes and corrects procedure

and work instruction problems before the plant is challenged. The NRC's review will be

accomplished as a followup inspection item in accordance with applicable baseline inspection

procedures. Additionally, because this substantive crosscutting issue has been open for more

than two assessment letters, the NRC requests that a public meeting be held to discuss

AmerenUE's progress in addressing the adequacy of human performance at the Callaway

Plant. We will coordinate with your staff to schedule this meeting.

The enclosed inspection plan details the inspections, except those related to physical protection, scheduled through September 30, 2007. Routine resident inspections are not listed

due to their ongoing and continuous nature. In addition to the baseline inspections, the NRC

will also be conducting inspections related to Temporary Instruction 2515/150, "Reactor

Pressure Vessel Head Penetration Nozzles (NRC Order EA-03-009)." The inspection plan is

provided to allow for the resolution of any scheduling conflicts and personnel availability issues

well in advance of inspector arrival onsite. The inspections in the last 9 months of the

inspection plan are tentative and may be revised at the midcycle review.

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

Document Room or from the Publicly Ava ilable 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 me at 817-860-8141 with any

questions you may have regarding this letter or the inspection plan.

Sincerely,/RA/William B. Jones, Chief Project Branch B

Division of Reactor Projects Union Electric Company- 3 -

Docket: 50-483 License: NPF-30

Enclosure:

Callaway Plant Inspection/Activity Plan cc w/enclosure:

Professional Nuclear Consulting, Inc.

19041 Raines Drive

Derwood, MD 20855 John O'Neill, Esq.

Pillsbury Winthrop Shaw Pittman LLP

2300 N. Street, N.W.

Washington, DC 20037 Mark A. Reidmeyer, Regional Regulatory Affairs Supervisor

Regulatory Affairs

AmerenUE P.O. Box 620

Fulton, MO 65251 Missouri Public Service Commission Governor's Office Building

200 Madison Street

P.O. Box 360

Jefferson City, MO 65102 H. Floyd Gilzow Deputy Director for Policy

Missouri Department of Natural Resources

P. O. Box 176

Jefferson City, MO 65102-0176 Rick A. Muench, President and Chief Executive Officer

Wolf Creek Nuclear Operating Corporation

P.O. Box 411

Burlington, KS 66839 Dan I. Bolef, President Kay Drey, Representative

Board of Directors Coalition

for the Environment

6267 Delmar Boulevard

University City, MO 63130 Les H. Kanuckel, Manager Quality Assurance

AmerenUE P.O. Box 620

Fulton, MO 65251 Director, Missouri State Emergency Management Agency

P.O. Box 116

Jefferson City, MO 65102-0116 Keith D. Young, Manager Regulatory Affairs

AmerenUE P.O. Box 620

Fulton, MO 65251 David E. Shafer Superintendent, Licensing

Regulatory Affairs

AmerenUE P.O. Box 66149, MC 470

St. Louis, MO 63166-6149 Certrec Corporation 4200 South Hulen, Suite 630 Fort Worth, TX 76109 Keith G. Henke, Planner Division of Community and Public Health

Office of Emergency Coordination

930 Wildwood, P.O. Box 570

Jefferson City, MO 65102 Tim Diemler Emergency Preparedness

Director

Callaway County/Fulton

P.O. Box 817

Fulton, MO 65251 Union Electric Company- 4 -

Lee Fritz Presiding Commissioner

Callaway County Courthouse

10 East 5th Street

Fulton, MO 65251 Gabe Craighead Eastern District Commissioner

Callaway County Courthouse

10 East 5th Street

Fulton, MO 65251 Donald "Doc" Kritzer Western District Commissioner

Callaway County Courthouse

10 East 5th Street

Fulton, MO 65251 The Honorable Robert Craghead Mayor of Fulton

Fulton City Hall

P.O. Box 130

Fulton, MO 65251 William Johnson Fulton City Administrator

Fulton City Hall

P.O. Box 130

Fulton, MO 65251 Steve Myers Chief of Police

Fulton City Hall

P.O. Box 130

Fulton, MO 65251 Dennis Crane Sheriff, Callaway County

P.O. Box 817

Fulton, MO 65251 The Honorable Tom Shackelford Mayor of Mokane

P.O. Box 41

Mokane, MO 65059 Richard Hudson, Director Emergency Management

Gasconade County Courthouse

P.O. Box 295

Hermann, MO 65041 Ron Jost Presiding Commissioner

Gasconade County Courthouse

119 East First Street

Hermann, MO 65041 Max Aubuchon Northern District Commissioner

Gasconade County Courthouse

119 East First Street

Hermann, MO 65041 Jerry Lairmore Southern District Commissioner

Gasconade County Courthouse

119 East First Street

Hermann, MO 65041 Randy Esphorst Sheriff, Gasconade County

Gasconade County Courthouse

119 East First Street

Hermann, MO 65041 Fay Owsley Gasconade County Public

Administrator

Gasconade County Courthouse

119 East First Street

Hermann, MO 65041 The Honorable Samuel Birk Mayor of Morrison

Route 1 Morrison, MO 65061 Bob Bishop Emergency Management Director

Montgomery County Courthouse

211 East Third

Montgomery City, MO 63361 Union Electric Company- 5 -

Charles Korman Presiding Commissioner

Montgomery County Courthouse

211 East Third

Montgomery City, MO 63361 Rich Daniels First District Commissioner

Montgomery County Courthouse

211 East Third

Montgomery City, MO 63361 John Noltensmeyer Second District Commissioner

Montgomery County Courthouse

211 East Third

Montgomery City, MO 63361 Robert Davis Sheriff, Montgomery County

Montgomery County Courthouse

211 East Third

Montgomery City, MO 63361 The Honorable Steve Wehrle Mayor of Rhineland

P.O. Box 384

Rhineland, MO 65069 Bradley Strope Emergency Management

Director

Osage County Courthouse

P.O. Box 1011

Linn, MO 65051 Russell J. Scheulen Presiding Commissioner

Osage County Courthouse

P.O. Box 826

Linn, MO 65051 Jerry G. Wolfe First District Commissioner

Osage County Courthouse

P.O. Box 826

Linn, MO 65051 Vince Sampson Second District Commissioner

Osage County Courthouse

P.O. Box 826

Linn, MO 65051 Carl Fowler Sheriff, Osage County

Osage County Courthouse

P.O. Box 826

Linn, MO 65051 The Honorable Gary Reynolds Mayor of Chamois

Star Route

Chamois, MO 65024 Federal Emergency Management Agency Mr. Dick Hainje, Regional Director

Region VII

9221 Ward Parkway, Suite 300

Kansas City, MO 64114-3372 Dr. William Miller NSEI, University of Missouri-Columbia

E2433 Engineering Building East

Columbia, MO 62511 Dr. Mark Prelas NSEI, University of Missouri-Columbia

E2433 Engineering Building East

Columbia, MO 62511 Ronald M. Reynolds, Director State Emergency Management Agency

P.O. Box 116

Jefferson City, MO 65102 Institute of Nuclear Power Operations (INPO)

Records Center

700 Galleria Parkway SE, Suite 100

Atlanta, GA 30339 Union Electric Company- 6 -

Electronic distribution by RIV:

Regional Administrator (BSM1)DRP Director (ATH)DRS Director (DDC)DRS Deputy Director (RJC1)Senior Resident Inspector (MSP)Branch Chief, DRP/B (WBJ)Senior Project Engineer, DRP/B (RAK1)Team Leader, DRP/TSS (RLN1)RITS Coordinator (KEG)V. Dricks, PAO (VLD)W. Maier, RSLO (WAM)C. Gordon (CJG)DRS Branch Chiefs (JAC, ATG, LJS, MPS1)

T. Bergman, Chief, TRPS, OEDO (TAB)S. Richards, Deputy Director, DIRS, NRR (SAR)C. Holden, Deputy Director, DORL, NRR (CFH)C. Haney, Director, DORL, NRR (CXH)D. Terao, Chief, LPLG, DORL, NRR (DXT)J. Donohew, Project Manager for Callaway (JND)RidsNrrDirsIpab SUNSI Review Completed: _wbj____ADAMS: Yes G No Initials: _wbj Publicly Available G Non-Publicly Available G Sensitive Non-Sensitive S:\DRP\DRPDIR\EOC 05\Assessment Letters\CWY.wpdRIV:C:DRP/BD:DRSD:DRPSignatureRA WBJones;dfDDChamberlainATHowell IIIWBJonesBSMallett /RA/ RJCaniano for /RA/ /RA/ /RA/2/22/062/23/062/27/062/28/062/28/06OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax Callaway Inspection / Activity Plan 03/01/2006

-09/30/2007 Inspection Type Inspection Activity Planned Dates Start End No. of Staff on Site Title Unit Number Page 1 of 2 03/01/2006 08:30:13 Report 22 1 RP-ORS-OCCUPATIONAL RADIATION SAFETY Baseline Inspections 04/03/2006 04/07/2006 1 7112101 IP Access Control to Radiologically Significant Areas Baseline Inspections 04/03/2006 04/07/2006 1 7112102 IP ALARA Planning and Controls Baseline Inspections 04/03/2006 04/07/2006 1 71151 IP Performance Indicator Verification 2 EP2-EMERG PREP PROGRAM Baseline Inspections 05/15/2006 05/19/2006 1 7111402 IP Alert and Notification System Testing Baseline Inspections 05/15/2006 05/19/2006 1 7111403 IP Emergency Response Organization Augmentation Testing Baseline Inspections 05/15/2006 05/19/2006 1 7111404 IP Emergency Action Level and Emergency Plan Changes Baseline Inspections 05/15/2006 05/19/2006 1 7111405 IP Correction of Emergency Preparedness Weaknesses and Deficiencies Baseline Inspections 05/15/2006 05/19/2006 1 71151 IP Performance Indicator Verification 1 RP-ORS-OCCUPATIONAL RADIATION SAFETY Baseline Inspections 08/28/2006 09/01/2006 1 7112101 IP Access Control to Radiologically Significant Areas Baseline Inspections 08/28/2006 09/01/2006 1 7112102 IP ALARA Planning and Controls Baseline Inspections 08/28/2006 09/01/2006 1 71151 IP Performance Indicator Verification 3 EB2-52B-CAL PIR INSPECTION Baseline Inspections 10/16/2006 10/20/2006 1 71152B IP Identification and Resolution of Problems Baseline Inspections 10/30/2006 11/03/2006 1 71152B IP Identification and Resolution of Problems 5 EB2-05T-TRIENNIAL FIRE PROTECTION Baseline Inspections 11/13/2006 11/17/2006 1 7111105T IP Fire Protection [Triennial]

Baseline Inspections 11/27/2006 12/01/2006 1 7111105T IP Fire Protection [Triennial]

1 RP-ORS-OCCUPATIONAL RADIATION SAFETY Baseline Inspections 10/23/2006 10/27/2006 1 7112101 IP Access Control to Radiologically Significant Areas Baseline Inspections 10/23/2006 10/27/2006 1 7112102 IP ALARA Planning and Controls Baseline Inspections 10/23/2006 10/27/2006 1 71151 IP Performance Indicator Verification 7 EB1-21-CDB PART 1 Baseline Inspections 12/11/2006 12/15/2006 1 7111121 IP Component Design Bases Inspection 2 REQUAL-BIENNIAL REQUAL Baseline Inspections 01/08/2007 01/12/2007 1 7111111B IP Licensed Operator Requalification Program 6 EB1-21-CDB PART 2 Baseline Inspections 01/02/2007 01/12/2007 1 7111121 IP Component Design Bases Inspection 2 TI - 150-RPV AND VHP NOZZLES Safety Issues 04/15/2007 05/10/2007 1 2515/150 IP Reactor Pressure Vessel Head and Vessel Head Penetration Nozzles (NRC ORDER EA-03-009)

1 PR-ORS-OCCUPATIONAL RADIATION SAFETY Baseline Inspections 04/16/2007 04/20/2007 1 7112101 IP Access Control to Radiologically Significant Areas Baseline Inspections 04/16/2007 04/20/2007 1 7112102 IP ALARA Planning and Controls This report does not include INPO and OUTAGE activities.

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

Callaway Inspection / Activity Plan 03/01/2006

-09/30/2007 Inspection Type Inspection Activity Planned Dates Start End No. of Staff on Site Title Unit Number Page 2 of 2 03/01/2006 08:30:13 Report 22 1 PR-ORS-OCCUPATIONAL RADIATION SAFETY Baseline Inspections 04/16/2007 04/20/2007 1 71151 IP Performance Indicator Verification 1 EB1-08P-ISI Baseline Inspections 04/23/2007 05/04/2007 1 7111108P IP Inservice Inspection Activities - PWR 5 RP TEAM-RADIATION SAFETY TEAM Baseline Inspections 06/04/2007 06/08/2007 1 7112103 IP Radiation Monitoring Instrumentation and Protective Equipment Baseline Inspections 06/04/2007 06/08/2007 1 7112201 IP Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems Baseline Inspections 06/04/2007 06/08/2007 1 7112202 IP Radioactive Material Processing and Transportation Baseline Inspections 06/04/2007 06/08/2007 1 7112203 IP Radiological Environmental Monitoring Program (REMP) And Radioactive Material Control Program 2 EB2-07B-HEAT SINK INSPECTION Baseline Inspections 06/18/2007 06/22/2007 1 7111107B IP Heat Sink Performance 3 EB1-2/17-50.59 & PERMANENT PLANT MODS Baseline Inspections 07/23/2007 07/27/2007 1 7111102 IP Evaluation of Changes, Tests, or Experiments Baseline Inspections 07/23/2007 07/27/2007 1 7111117B IP Permanent Plant Modifications 2 EP1-EMERG PREP EXERCISE Baseline Inspections 08/06/2007 08/10/2007 1 7111401 IP Exercise Evaluation Baseline Inspections 08/06/2007 08/10/2007 1 7111404 IP Emergency Action Level and Emergency Plan Changes Baseline Inspections 08/06/2007 08/10/2007 1 71151 IP Performance Indicator Verification 1 BRQ SIM-BIENNIAL RQ SIM ONLY Baseline Inspections 08/20/2007 08/24/2007 1 7111111B IP Licensed Operator Requalification Program 1 RP-ORS-OCCUPATIONAL RADIATION SAFETY Baseline Inspections 08/27/2007 08/31/2007 1 7112101 IP Access Control to Radiologically Significant Areas Baseline Inspections 08/27/2007 08/31/2007 1 7112102 IP ALARA Planning and Controls Baseline Inspections 08/27/2007 08/31/2007 1 71151 IP Performance Indicator Verification 3 EXAM-INITIAL EXAM Not Applicable 09/10/2007 09/14/2007 1 X02355 CALLAWAY - INITIAL EXAM (10/07)

This report does not include INPO and OUTAGE activities.

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