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Callaway Action Request System

Action Request

cars Number cars Ty12e Status Discover Date Due Date 201005073 Adverse Condition aosed 05/22/2010 02/24/2011

Originator De12artment Phone Ptasznik, Elizabeth (63242) NETP 314/225-1720

Lead De12artment Phone Ptasznik, Elizabeth (63242) NETP 314/225-1720

SS Notified NMR ASME Now S & d Per E . P __ a.eguar s Safetv QUIRment rogram

False False False

Summarv Description

Absence of monitoring wells near SSCs containing radioactive fluids

DescriRtion

Condition Description (Problem Statement)

False False

There is an absence of monitoring wells adjacent to Callaway Plant systems, structures and components (SSCs) containing radioactive fluids, as required by NEI 07-07, Groundwater Protection Initiative.

Details of the Condition One requirement of NEI 07-07, Industry Groundwater Protection Initiative, is the installation of an effective network of groundwater monitoring wells to allow the identification of inadvertant releases of licensed material to groundwater. The placement of wells within the flow path of contaminants emanating from a source is fundamental to identifying the source. The following SSCs require additional monitoring wells for enhanced detection .

• Liquid radwaste effluent piping to Radwaste Manhole o HB-001-F35-6"

• Buried piping associated with DMTs o HB-505-HCD-6" 8 DMT recirculation o HB-504-HCD-6" A DMT recirculation o HB-503-HCD-6" B DMT inlet o HB-502-HCD-6" A DMT inlet o HB-501-HCD-6" B DMT to B DMT tank pump suction o HB-500-HCD-6" A DMT to A DMT tank pump suction

• RWST discharge piping to ECCS pumps suction header in Aux Bldg o BN-007-HCB-24"

• Buried piping associated with Fuel Pool Cooling/Cleanup System o EC-070-HCD-4"

Recommended Actions to Resolve this Issue

• Budget for new wells in 2011 • Identify exact location of the wells • Confirm location of new wells with GPI Team

Document Immediate Actions Taken in the Immediate Actions Box below

http://cars2-prd/Reports/CarPrint.asp?CarsNumber=201005073

False False False

11/3/2010

Immediate Actions This has no immediate impact on plant equipment or operation. The SM was not notified.

Lead Response

Problem Statement: DISCUSS the concern with the originator to ensure problem is understood. State the object, deviation, and impact on plant (if applicable), other impact (as appropriate). (APA-ZZ-00500, Appendix 15, Section 4.2.1) Callaway does not have monitoring wells strategically placed near buried piping which contains licensed material . This gap could result in an unmonitored release to the environment which initiates communications to the state and the NRC.

Remedial Actions Taken: Ba~ed on risk and consequence, document the Remedial Actions to address deficient conditions temporarily until permanent Corrective Actions can be implemented. (Section 4.2.2) None

Extent of Condition: Accurately identify the Extent of the Condition as it relates to impacts on other plant systems, components, structures, programs, procedures, processes, or organizations. (Section 4.2.3) This applies to buried piping which contains licensed material:

• Liquid radwaste effluent piping to Radwaste Manhole o HB-001-F35-6"

• Buried piping associated with DMTs o HB-505-HCD-6" B DMT recirculation o HB-504-HCD-6" A DMT recirculation o HB-503-HCD-6" B DMT inlet o HB-502-HCD-6" A DMT inlet o HB-501-HCD-6" B DMT to B DMT tank pump suction o HB-500-HCD-6" A DMT to A DMT tank pump suction

• RWST discharge piping to ECCS pumps suction header in Aux Bldg o BN-007-HCB-24"

Buried piping associated with Fuel Pool Cooling/Cleanup System o EC-070-HCD-4"

Corrective Actions: List the SMART Corrective Actions (CAs) implemented or planned to be implemented to correct each cause. Verify that the Corrective Action scope addresses the Extent of Condition. (Sections 4.2.4 & 4.2.7 & 4.2.3.c) If Corrective Actions will not be taken, describe the basis supporting the acceptability of not correcting the condition. (Step 4.3.2)

1.) Hold a meeting with the Callaway Groundwater Protection Team (Engineering, RP, Environmental) to discuss the location of current wells, and propose the placement of additional wells near buried piping which contain licensed material.

-Engineering, RP, and Environmental met on 6/3/2010 to discuss the location of current monitoring wells, and proposed that 8 additional wells be installed. This would enhance leak detection from buried pipe carrying licensed radioactive material.

2.) Identify which department will budget for the placement of these new wells.

- RP has identified funds for well installation in Fall2010. The work will be performed under PO 493922.

3.) Install additional wells.

-Job 10006653 was created to install new wells.

4.) Identify which department will be responsible for budgeting for monitoring well maintenance and installation beyond 2011.

- Engineering will be responsible for budgeting a set amount of funds for maintaining and inspecting monitoring wells each year. HDP-ZZ-07000 clearly defines this responsibility.

Closure Statement: Describe specific completion of all Corrective Actions which resolved the concern. Corrective Actions closed to other processes should be well-documented and appropriate cross-references made. (Sections 4.7.4 & 4.7.8)

http:/ I cars2-prd/Reports/CarPrint.asp?CarsNumber=20 1005073

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Corrective actions have either been completed or transfered to to an EMPRV Job to track completion of Corrective Action. CAR number added to EMPRV Job and EMPRV Job is flagged with CA code.

This CAR is complete and ready for closure. EMP, 10/03/2010.

Justification for due date extension from 2010-06-22 to 2011-02-24: Liz Ptasznik. CAR extended to allow for completion of Corrective Actions. ·

Justification for due date extension from 2010-Q6-22 to 2011-02-24: Liz. Ptasznik. Car extended for completion of Corrective Actions.

Screening Worksheet

Performance Code Significance Committee: ORC SAFE PARC CARB MREP

51 4 False False False False False

Evaluations: MER MCR 9MR Closures: Noted Admin Close

False False False False False

Dispositions: MR MSPI MRAJ Repo Trans NMR Oper ASME 007R PHPE EPE CCE RWRK PROC

False False False False False False False False False False False False False False

Screening Comments More information action assigned to D. Brownawell. tlw-Q5/23/10 and again on 05/24/10.

Keywords

Keyword Description

GROUND WATER GROUND WATER

MORE INFO 5CRN

PIPE

More Info needed - screening responsible for lacking info.

PIPE- Pipe

WELL WELL- Well

Trend Codes

Trend Type

Event Type

Event Type

Trend Code

RE001SAA

REOOlEOE

Description

SELF ASSESSMENT ADVERSE CONDITION INDENTIFIED

EXTERNAL OE APPLIES TO CALLAWAY

Activity

cause

ER002RWC

ME005PMF

RAW WATER SYSTEMS (CORROSION PREVENTION)

PREVENTATIVE MAINTENANCE FREQUENCY NOT ADEQUATE

Type Description

H

H

H

H

H

H

H

H

car Status changed from Initiate to Screening by Ptasznik, Elizabeth (63242) on May 22 2010 10:37AM

RISDEGR created by Daly, Mary (1386) on May 22 2010 12:57PM

OPS Worksheet created by Gruer, Walter (2338) on May 22 2010 1:33PM

Initial Action Release by Belsky, Luanna (13566) on May 25 2010 !0:27AM

car Status changed from Screening to Evaluate by Belsky, Luanna (13566) on May 25 2010 10:27AM

Car Lead changed from to Kiefer, Christopher (13580) by Belsky, Luanna (13566) on May 25 2010 10:27AM

car Lead changed from Kiefer, Christopher (13580) to Ptasznik, Elizabeth (63242) by Kiefer, Christopher (13580) on May 25 2010 10:09PM

car Status changed from Evaluate to InProcess by Ptasznik, Elizabeth (63242) on Jun 16 2010 7:32AM

car Due Date changed from Jun 22 2010 12:00AM to Feb 24 2011 12:00AM by Ptasznik,

http:/ /cars2-prd/Reports/CarPrint.asp ?CarsNumber=20 1005073

User Pin

63242

1386

2338

13566

13566

13566

13580

63242

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1113/2010

H

H

H

H

H

Elizabeth (63242) on Jun 16 2010 7:32AM

car Lead changed from ptasznik, Elizabeth (63242) to Fink, Mary (8328) by ptasznik, Elizabeth (63242) on Sep 30 2010 2:11PM

63242

63242

car Lead changed from Fink, Mary (8328) to Kiefer, Christopher (13580) by Fink, Mary (8328) on 8328 Oct 13 2010 1:21PM

car Lead changed from Kiefer, Christopher (13580) to ptasznik, Elizabeth (63242) by Kiefer, Christopher (13580) on Oct 19 2010 4:01PM

car Status changed from InProcess to dosed by ptasznik, Elizabeth (63242) on Nov 3 2010 8:34AM

13580

63242

1 - Ptasznik, Elizabeth (63242)- NETP- 90- RMDL- 06/22/2010- Document Remedial actions to comply w~h NEI 07-07

2- Fink, Mary (8328)- MSU- 90- -10/21/2010 -ln~iatiate pre-excavation reviews

3- Ptasznik, Elizabeth (63242) - NETP - 90 - - 02/24/2011 - Provide location drawings

http://cars2-prd/Reports/CarPrint.asp?CarsNumber=201005073

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11/3/2010