ML073270101

ARB Summary, RIV-2007-A-0028, Callaway

ML073270101
Person / Time
Site:	Callaway
Issue date:	03/19/2007
From:	NRC Region 4
To:
References
RIV-2007-A-0028, FOIA/PA-2008-0011
Download: ML073270101 (8)

Text

,ARB

SUMMARY

Responsible RPBB RIV-2007-A-0028 Facility Name Callaway ARB Date: March 19, 2007 Docket Number 050-483 01 Case No.:

-AB ECISION Purpose of ARB Initial Previous N/A Decisions Today's Decision Concern 1- RPBB to inspect.

Concern 2- RPBB to inspect non-willful aspects and identify any potential violations. Re-ARB to discuss 01 followup of potential willfulness.

.Concerns 3-6, ACES/RPBB/EB2- to contact alleger, regarding objection to referral and to get clarification regarding concerns.

Basis for Another ARB Refer to: Crteria Reviewed.?

Referral Rationale 01INVESTIGATION' Priority Rationale DOL Deferral Rationale ARB PARTICIPANTS:(* de-otes.ARB.Chairman Approval)

JWalker HFreeman KFuller MVasquez SGraves RCaniano AVegel,* DWhite VGaddy MShannon Information in this record was deleted in accordance with the Freedom of Information Act, exemptions *2.

FOIA- C;00'?

o -, )

[CONCERNS UST RIV,-007-A.0028 Concern (BrietStatement) Regulatory"Requ.iremet Branch Action (InspectlReter, Planned ISlgnitic-ance 01 Priority Iinvestigate, .Nd Action) -ICompletion I (Hfgh, (1-1, N,L)

On October 23, 2003, while shutting down to Mode 3, the Criterion V, TSs RCS temperature dropped below the Minimum Temperature for Critical Operation. However, the temperature transient was not documented in a condition report until 38 days later when identified by a training instructor. At the time the condition report was assigned a significance level 4. The concern individual (Cl) expressed concern that this significance level was too low. The condition also was not documented in the shift supervisor log.

RPBB Inspect 5/19/07 N N 2 The operating crew waited 90 minutes to fully insert control Wrong doing (50.5),

rods following shutting down the reactor. The Cl believes Criterion V/TSs this delay may have been intentional to avoid scrutiny of crews actions, since the crew was supposed to maintain Mode 2 in case the equipment necessitating the shutdown was repaired. The CI states that purposefully delaying inserting the control rods, not logging entry into Technical Specifications and not documenting significant operational transients in the corrective action program are dishonest and negligent omissions.

RPBB Inspect N N 3 Based on past history, the Cl is unimpressed with the ability SCWE of the ECP to pursue issues. The Cl views the Callaway ECP as merely a program to placate employees who have indicated they have concerns they intend to address with the NRC. The Cl has no confidence that the ECP will appropriately address this issue ACES Contact alleger N N RPBB/

EB2 4 The Cl had unfgygrab1e*Leling in the pastIwith senior SCWE managemenfb(c I_ Iand feels uncomfortable addressing these concerns with his management.

ACES .Contact alleger N N RPBB/

EB2

[CONCERNSLIST RtV.2007-A-0028 Concern (Brie? Statement) .- Rgltr eurmn

________. . . . . . . . .<1 .. JlNormal) -

5 The Cl has no confidence that anyone in Callaway's SCWE corrective action program has the interrogation skills to competently conduct interviews with the involved individuals.

ACES Contact alleger N N RPBB/

EB2 6 The CLdoes not believe, the Zb)(7)c SCWE F)(7iJywill adequately investigate this concern due his relationship with ____

ACES Contact alleger N N RPBB/

EB2 Revised 5/22/02

ALLEGATION RECEIPT FORM Page 11 Received By: Michael Peck Receipt Date: March 2, 2007 Receipt Method (meeting, phone call, letter, Resident Office drop in/letter FACILITY Facility Name Callaway Plant Location Fulton, MO Docket(s) 05000483 CONCERN Summay toe ot Concerns Mbebriefi

1. Unnecessary delay completing a Technical Specification required Shutdown

.(see attached letter).

2. Failure to document a significant operational transient (see attached letter).

3. Less than adequate safety culture (see attached letter).

Obtain concern sectfics. What Is the.concewr, when did It occur, who was Involved. etc. ft the omnce Ivolves discrimination. till In the lat section of the forei.

Please see attached letter.

What Is the 1ototoil safety impact? Is this an ongoing concern?

Indication of poor plant safety culture.

Problems with Corrective Action and Employee Concerns Program.

What Veourem ulation mvers this concern?

10 CFR 50, Appendix B, Criteria XVI and Plant Technical Specifications (Mode)

What records should the NRC review?

CARs 2007012798& 200308555, plant computer data from October 21, 2003 What other individuals could the NRC contact tor information?

Duff Bottorf and Glen Pruitt How did the individual find out about the concern?

Review of a condition adverse to quality record.

Was the concern broumht to management's attention? If so. what actions have been taken, if not, Why not?

Yes- Entered into the Corrective Action Program as "Level 4" CAR (trend only)

Why was the concern brought to the NRC'S attention?

The concerned individual has lost confidence in Corrective Action and Employee Concerns Proarams.

ALLEGATION RECEIPT FORM Page 12 ALLEGER INFORMATION Full Name [Redacted] )PI AmerenUE Mailing Address (Home) fRedacted Occupi Engineer Telephone (Daytime) [Redacted) Relationship to facility Employee (Home)

(Other)

Preference for method and time Phone/mail Was the Individual advised of Yes of contact identity protection Referral Explain that Ifthe concerns are referred to the licensee, that allegersIdentity will not be revealed and Mhatthe NRC will review and evaluate the thoroughness and adequacy of the licensee's response. If the concerns are an agreement state Issue or the jurisdiction of another agency, explain that we will refer the concern to the appropriate agency, and Ifthe alieger agrees, we will provide the alleger's Identify for followup.

Does the individual object to the Yes Does the individuall object to No referral? Ireleasing their Identify?

Regulations prohibit NRC licensees (Including contractors and subcontractors) from discriminating against Individuals who engage in protected activities (alleging violations of regulatory requirements, refusing to engage in practices made unlawful by statues, etc.).

Does the concern Winove No Was the Individual advised of the Yes discrimination? DOL process?

What was the protected activity?

Review of a condition adverse to quality record.

What adverse actions have been taken? When?

None Why does the individual believe the actions were taken as a result of engaqing in a protected activWtt?

N/A Revised 9/3/03

March 1, 2007 Mr. Michael Peck Senior Resident Inspector Nuclear Regulatory Commission Mr. Peck:

On October 21, 2003 Callaway Plant was shutting down to MODE 3 to comply with T/S 3.8.7. At approximately 0938, with the plant in MODE Ii 8% power, a secondary plant transient began when the Turbine and MSR Drains were opened per OTN-AC-00001. This transient lasted approximately 25 minutes and resulted in RCS temperature dropping below the Minimum Temperature for Critical Operation for approximately 10 minutes between 1000 and 1013. The resulting pressurizer level transient caused a letdown isolation and entry into OTO-BG-00001. Note the following:

The cause of the temperature transient was not captured in the Callaway Action Request System on the day the event occurred. The event was eventually documented in the Callaway Action Request System 38 days later by an Engineering Training Instructor (Vincent "Duff' Bottorf) as Adverse Condition 200308555. This training instructor stated to me that the Shift Supervisor for the event was very defensive about the event and did not want the issue documented with a CAR.

There is no record in the Shift Supervisor Log nor in the Callaway Action Request System of passing below the Minimum Temperature for Critical Operation or of entering T/S 3.4.2.

At 1013 the turbine was tripped and the crew logged entry into MODE 2; Delta T Power was 4.9%, Tavg was 552 0 F, IRNI power was 1.4E-5 ica and SUR was -0.01 dpm. One minute later (1014) Delta T Power was 4%, Tavg was 5557F, IRNI power was IE-5 ica and SUR was -0.16 dpm. The 3*F temperature rise resulted in a negative reactivity insertion which caused the reactor to shutdown. At 1018, OTO-BG-00001 was exited; Delta T power was 2.4%, Tavg was 5577F, IRNI power was 2.4E-6 ica and SUR was -0.16 dpm.

By 1025 Delta T power was approximately stable, indicating reactor power had lowered below the Point of Adding Heat; Delta T power was 1.8%, Tavg was 560°F, IRNI power was 7.34E-8 ica and SUR was -0.28 dpm. By the time IE-8 ica was reached (1028) the maximum negative start up rate (for the transient) of -0.29 dpm had already been reached; Delta T Power was 1.8%,

Tavg was 560 0F. By 1046 reactor power was approximately stable (power would drop less than halfa decade in the next 75 minutes) at 6.22E-11 ica. At 1125 the Channel 2 SRNI energized, reading 3044 cps and at 1138 the Channel 1 SRNI energizes reading 2593 cps. Control Rods were not inserted until 1204.

t9f 260- 4 6)

. I There is no indication in the control room log as to what prevented control rod insertion in the 106 minutes between exiting OTO-BG-00001 and finally beginning control rod insertion. There is a log entry at 1137 for exiting OTO-NN-00001. OTO-NN-00001 had been entered earlier in the shift due to problems with invcrter NN 11. It is unlikely the remaining actions of OTO-NN--00001 were distracting the crew from inserting control rods. Several routine entries were being made during this time period such as starting and completing I&C surveillances or starting and stopping secondary plant equipment.

Ib)I)c with Mr. Bradley, Mr. Ganz, Mr. Weekley and Mr. Olmstead regarding what activities might possibly delay inserting the control rods for over 90 minutes. None of these Shift Managers could think of any evolution which would delay inserting the control rods. All of these individuals did state, in some manner, that they could not evaluate whether or not the delay was appropriate without knowing what all was occurring on shift that day. I have not spoken with any of the crew members on shift at the time (Lantz, Rauch or Alderman). The Reactor Operator is deceased.

At the time the reactor shutdown (it was unrecoverable by 1025) the crew was supposed to be maintaining MODE 2 in the event NN 11 was repaired and a shutdown was not necessary. It appears the control rods remained out because the crew did not want the Outage Control Center to know they bad lost control of reactor power.

It is not my intent to allege that reactor safety was violated on October 21, 2003. Nor is it my intent to allege that plant operating procedures were not followed. Note the following:

• After the reactor shut down because of the negative reactivity inserted by the +3°F upon tripping the turbine, the reactor was in a stable condition.

a Although shutdown margin was not yet met, negative reactivity was increasing the entire time due to Xenon buildup and the control and shutdown banks were trippable in the event of a transient induced positive reactivity insertion.

• Although all the steps of OTG-ZZ-00005 prior to the step for inserting "control rod banks into the core" implicitly assume the reactor is still critical and although some steps of OTG-ZZ-00005 were not performed (e.g. taking 1E-8 data), there was no explicit deviation from plant operating procedures.

Based on my personal experience with the individuals involved, it appears to me there was an intentional 90 minute delay in inserting control rods to avoid scrutiny of the crew's actions.

Purposefully delaying insertion of the control banks, not logging entry into T/S 3.4.2 and not documenting significant operational transients in the Corrective Action Program are dishonest and negligent omissions. This behavior is contrary to the cornerstone of Problem Identification and Resolution.

I am not certain the above events rise to a level which warrant NRC investigation since nuclear safety does not appear to have been in jeopardy. If they do, I would like the NRC to investigate these events as I am not capable of investigating them further. Note the following:

" The events were documented as part of CARS 200701278. The specific allegation above was not as strongly stated in CARS 200701278. At the time CARS 200701278 was written, I was unaware of Mr. Bottorfts problems in getting CARS 200308555 documented.

• CARS 200701278 was screened as aSig 4 (Corrective Action Only) meaning the Lead Responder need not investigate anything - his task is merely to develop corrective actions to improve our poor performance of MODE 2 operations. At the CARS Screening Committee meeting which assigned this significance level, I expressed my concern that the events of the 2003 NN 11 outage needed additional investigation.

" I do not have a good relationship with[(7 I] and I do not feel comfortable interviewing him concerning these events.

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• d iey LI:FU*

• S personal relationship Wi-db)(7 )c " do not feel confiden b)(7).

would give this matter a fair investigaon.7 I1 have consulted the Employee Concerns Program at Callaway Pl b)(7)c the past (on separate issues) and was unimpressed with their performance and their pursuit of the issues. I view the ECP process at Callaway as merely a program to placate employees who have indicated they have concerns which they intend to address with the NRC and have no confidence they would appropriately address this issue.

I have no reason to doubt the integrity of the Plant Manager, Mr. Diya, and the Site Vice J =sd=LML fhp. However, I have had unfavorable dealings in the past with their bFor this reason, I do not feel comfortable addressing these concerns with my managen ent above Operations.

• Finally, I have no confidence that anyone in the Callaway Corrective Action Program has the requisite interrogation skills to competently conduct the interviews with the involved individuals.

I can be reached away from the plant at*M lI Duff Bottorf is unaware I am bringing this allegation to you. If you wish to contact him, he can be reached at 1 Glen Pruitt was the Shift Engineer for the NN I I shutdown. He is un'awareI this allegation to you. If you wish to contact him, he can be reached a Very respectfully,

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