ML073270117
| ML073270117 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/20/2007 |
| From: | NRC Region 4 |
| To: | |
| References | |
| FOIA/PA-2008-0011 | |
| Download: ML073270117 (7) | |
Text
NRC's Assessment of the Callawav Plant's Corrective Action Program A concerned individual has questioned an instance where the Corrective Action Program at Callaway failed to address a plant issue. Inspectors did not pursue the issue because it did not involve safety-related equipment, risk-significant equipment, or equipment which could cause an initiating event While the inspectors did not pursue the issue highlighted by the individual, the NRC considered the issue of another instance where the corrective action program at Callaway was deficient. The following outlines the NRC assessment and inspection history with the Callaway Plant corrective action program.
First, since 2003 NRC inspectors have identified 33 violations or findings at the Callaway Plant which have been documented with crass-cutting aspects related to problem identification and resolution. By noting these cross-cutting aspects, inspectors have determined the main cause of the finding involved deficiencies with the licensee's identification and resolution of problems.
This number of findings is a large number when compared-to other plants in the same time frame. The large number has drawn NRC management attention which has led to greater scrutiny of the corrective action program by inspectors.
Next, three different teams of inspectors have visited Callaway and performed focused inspection of the Callaway corrective action program since 2003. The most recent one In 2006 noted numerous weaknesses. Examples of program weaknesses included failures to initiate condition reports, inappropriate classification of condition reports, poor quality of operability determinations associated with condition reports, poor documentation of operability determinations, and a lack of understanding of detailed design and licensing bases.
Based on the large number of problem identification and resolution related findings and the latest weaknesses discovered in the 2006 problem identification and resolution, discussions were held at Region IVs midcycle assessment meeting in August 2007. 'These discussions yielded concern with the licensee's action to upgrade their corrective action program since a deficient corrective action program could lead to much more serious issues at the plant.
Regional management therefore decided to continue application of a substantive cross-cutting issue in the area of problem identification and resolution. From this, inspectors have been instructed to focus their inspection to look for issues stemming from poor problem identification and resolution. Of note, Callaway has carried this substantive cross-cutting Issue for five of the last six semi-annual assessments, highlighting the NRC's concern for the program.
From the NRC's concerns, numerous interactions with Callaway plant management have occurred. As recently as September 12, 2007, the Callaway Plant Manager and Regulatory Affairs Manager have visited the Region IV offices to discusses their current program to improve their corrective action program. Additionally, senior Callaway plant management, including the site Vice President, will be coming to Region IV to discuss, among other things, the state of their corrective action program and their plans to upgrade it with NRC senior management.
Summarizing, the NRC has had concerns with the corrective action program at Callaway for' several years as evidenced through the identification of problem identification and resolution related problems, through highlighting programmatic weaknesses in team inspections focused on problem identification and resolution, through repeated assessment of substantive cross-cutting issues in problem identification and resolution to the licensee, and engagement with management in the past to ascertain plans to upgrade the corrective action program. Passing Information in this record was deia.*d in accordance with the Freedom of information Act, exemptions FOIA- ---
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on one issue which does not have a regulatory nexus is not indication that the NRC does not have concerns about the Callaway corrective action program, but is a result of the NRC addressing issues within the regulatory framework. Engagement by the NRC within our framework will strive to ensure all problems, both safety and non-safety related including the concerned Individual's issue, are properly resolved by the licensee.
Chronoloav of Relevant Facts of the Callawav Employee's Alleaation Pertainina to the October 2003 Reactor Shutdown Event In October 2003, after responding to the loss of an instrument bus, operators manipulated and/or allowed the plant to operate such that the Minimum Temperature for Criticality was exceeded. The plant shut down before the Technical Specification allowed time was exceeded.
Control rods were left withdrawn for an extended period of time (around 90 minutes). The on-shift crew did not log the entry Into the Technical Specification conditions nor did they Initiate a corrective action program document, both of which were required by Callaway plant procedures at the time. The alleger asserts that these failures to report the conditions per procedure were intentional omissions.
Chronoloav (all dates are in 2007)
March 2 Allegation received March 3-18 Concerns Ust developed. There were more than 2 concerns; only the pertinent ones are listed.
Concer 1 On October 23, 2003, while shutting down to Mode 3, the RCS temperature dropped below the Minimum Temperature for Crdttcal Operation. However, the temperature transient was not documented In a condition report until 38 days later when Identified by a training Instructor. This condition report did not address why the control rods were not Inserted until 90 minutes following the reactor shutting down. A later condition report documenting the Issue (CARS 200701278) 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.
Concern 2 The operating crew waited 90 minutes to fully Insert control rods following shutting down the reactor. The CI believes 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 Cl 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 an dishonest and negligent omissions.
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March 19 Allegation discussed at ARB. The following was decided:
June 18 Concern 1:
DRP-B to inspect Concern 2:
DRP-B to Inspect non-willful aspects and identify any potential violations. Re-ARB to discuss 01 followup of potential willfulness.
ARB to discuss results of DRP-B inspection of Concerns 1 and 2. Summarized as follows:
11 ARS Meeting ACES 06&07/2007 06111/2007 F0818/2007I To discuss whether there were indications of willfulness In Concern 2. - Based upon discussion* with the Inspector(s) conducting review of the technical issue of Concern 2, the ARB did not find evidence of willful misconduct In addition, the ARS concluded that there was no violation of regulatory requirements to warrant an 01 Investigation.
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June 19 E-mail from DRP-B to Senior Allegation Coordinator.
Allegation RIV-2007-A-0028 - Concern 2 The NRC inspector that was assigned Concern 2 came to the following conclusions based on interviews and reviewed plant technical data:
The licensee failed to log the entry into Technical Specification Action Statement 3.4.2, the reactor critical below 551 OF as required by their procedures. The inspector did not believe it was a willful act. His Impression was that the operators didn't know what was actually going on. At the time the plant had experienced a loss of a vital bus and the operators had ramped power down to approximately 2 percent. Xenon then drove the temperature and neutron flux level down. The reactor went below the 551 OF for about 15 minutes at which time the operators tripped the turbine as part of their shutdown procedure. This placed the steam dumps in service which regulated the temperature at 5570F.
The inspector determined that the licensee did not violate any TS requirements.
The inspector did not find any evidence that any licensee actions or omissions were willful.
The lIcensee wrote a CAR and has taken corrective actions to preclude this from recurring.
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. August 7 Closure Letter. Closure of Concerns 1 and 2 shown below:
Concern 1 On October 23, 2003, while shutting down to Mode 3, the 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 instuctor. This condition report did not address why the control rods were not inserted until 90 minutes following the reactor shutting down. A later condition report documenting the issue (CARS 200704278) was assigned a significance Level 4. The concern individual (Ci) expressed concern that this significance level was too low. The condition also was not documented in the shift supervisor log.
Rslutdan 1-Subsantated In your ltier datedb)(77 You advisd thaE7l)c CARS 200701278r tha the cb7s significance was nod at Level 3.
The NRC reviewed computer point trend data, operator logs, Technical Specification requirements, corrective action documents and operator procedural guidance.
The October 23, 2003, plant transient resulted In RCS temperature decreasing approximately 2 degrees F. below the Technical Specification 3.4.2 minimum allowed RCS temperature while crttical. Fifteen minutes late a mode change from Mode 2 (Startup) to Mode 3 (Hot Standby) occurred. This Technical Specification limiting condition for operation entry and mode change were not documented per requirements. The operators procedural guidance expected to be able to control RCS temperature and reactor power stable using control of steam loads to establish a reactor critical condition of about 5 E -6 amps.. The reactor did become subcritical without immediate operator action and did transition through five decades of power decrease due to the transient in a 20-minute period. No attempts were made to restore power and after 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, the procedural requirement to insert control rods was implemented. Thirty-eight days later a corrective action document (CAR) Identified the discrepancy.
The licensee recently initiated CARs 200702601 and 200702806 which highlighted the need to re-review the 2003 event to ensure procedural content and operator training was adequate to respond to future events. These corrective action documents have been assigned significance Level 3 and the actions prescribed have the potential to address the 2003 inadequacies.
The concerns described in Allegatlon RIV-2007-A-0028, and confirmed by inspection, were contrary to the requirements of the licensee's Technical Specification bases and operating procedures and were an initiating events reactor restart concern. The NRC plans to document this violation In NRC Inspection Report 2007-003.
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Resolution of Concerns RIV-2007-A-0028
_Concern 2 The operating crew waited 90 minutes to fully insert control rods following shutting down the reactor. [The CI believes this delay may have been intentional to avoid scrutiny of the crew's actions, since the crew was supposed to maintain Mode 2 in case the equipment necessitating the shutdown was repaired. The Cl states that purposefully delaying inserting the control rods, not logging entry Into Technical Specifications and not documenting significant operational transients Inthe corrective action program are dishonest and negligent omissions.]
Resolution 2-Partially Substantiated The NRC technical staff reviewed computer point trend data, operator logs, Technical Specification requirements, corrective action documents and operator procedural guidance as they related to the first sentence of Concern 2. The technical staff also reviewed the Information to determine whether there were Indications of misconduct that would warrant an investigation by the Office of Investigations.
The technical staff determined that the reactor did become subcitical without immediate operator action and did transition through five decades of power decrease due to the tanslent In a 20-minute period. No attempts were made to restore power and after 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, the procedural requirement to insert control rods was Implemented. This time delay was not prudent.and did suggest that the operators may not have exercised optimum reactivity management and may not have had adequate plant awareness. The Inspector's review of operating procedures did not find any timeliness guidance on performing the steps to insert the control rods.
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