ML093210487

Summary of Regulatory Conference with Ameren UE Regarding Callaway Plant

ML093210487
Person / Time
Site:	Callaway
Issue date:	11/17/2009
From:	Geoffrey Miller NRC/RGN-IV/DRP/RPB-B
To:	Heflin A AmerenUE
References
Download: ML093210487 (24)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION R EG IO N I V 612 EAST LAMAR BLVD, SUITE 400 ARLINGTON, TEXAS 76011-4125 November 17, 2009 Mr. Adam C. Heflin, Senior Vice President and Chief Nuclear Officer AmerenUE P.O. Box 620 Fulton, MO 65251

SUMMARY

OF REGULATORY CONFERENCE WITH AMEREN UE REGARDING CALLAWAY PLANT

Dear Mr. Heflin:

This refers to the public meeting conducted at the U.S. Nuclear Regulatory Commission Region IV office on November 9, 2009 during which a regulatory conference was held.

Topics discussed during the meeting included the significance, cause, and corrective action associated with an apparent violation involving the inoperability of the turbine driven auxiliary feedwater pump. The apparent violation is discussed in NRC Inspection Report 05000483/2009009 (ADAMS ML092730656). Members of the public present at the meeting were allowed to ask questions and comment on the proceedings.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosures will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs 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).

Should you have any questions concerning this matter, I will be pleased to discuss them with you.

Sincerely,

/RA/

Geoffrey Miller, Chief Project Branch B Division of Reactor Projects Docket: 50-483 License: NPF-30

Enclosures:

1. Attendance List

2. Presentation Slides

AmerenUE cc w/

Enclosures:

Mr. Luke H. Graessle Director, Operations Support AmerenUE P.O. Box 620 Fulton, MO 65251 E. Hope Bradley Manager, Protective Services AmerenUE P.O. Box 620 Fulton, MO 65251 Mr. Scott Sandbothe, Manager Plant Support AmerenUE P.O. Box 620 Fulton, MO 65251 R. E. Farnam Assistant Manager, Technical Training AmerenUE P.O. Box 620 Fulton, MO 65251 J. S. Geyer Radiation Protection Manager AmerenUE P.O. Box 620 Fulton, MO 65251 John ONeill, Esq.

Pillsbury Winthrop Shaw Pittman LLP 2300 N. Street, N.W.

Washington, DC 20037 Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102-0360 Deputy Director for Policy Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102-0176 Institute of Nuclear Power Operations (INPO)

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

AmerenUe Mr. Rick A. Muench, President and Chief Executive officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839 Kathleen Logan Smith, Executive Director and Kay Drey, Representative, Board of Directors Missouri Coalition for the Environment 6267 Delmar Boulevard, Suite 2E St. Louis, MO 63130 Mr. Lee Fritz, Presiding Commissioner Callaway County Courthouse 10 East Fifth Street Fulton, MO 65251 Director, Missouri State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102-0116 Mr. Scott Clardy, Administrator Section for Disease Control Missouri Department of Health and Senior Services P.O. Box 570 Jefferson City, MO 65102-0570 Certrec Corporation 4200 South Hulen, Suite 422 Fort Worth, TX 76109 Mr. Keith G. Henke, Planner II Division of Community and Public Health Office of Emergency Coordination Missouri Department of Health and Senior Services 930 Wildwood Drive P.O. Box 570 Jefferson City, MO 65102 Chief, Technological Hazards Branch FEMA Region VII 9221 Ward Parkway, Suite 300 Kansas City, MO 64114-3372

AmerenUe Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov)

Deputy Regional Administrator (Chuck.Casto@nrc.gov)

DRP Director (Dwight.Chamberlain@nrc.gov)

DRP Deputy Director (Anton.Vegel@nrc.gov)

DRS Director (Roy.Caniano@nrc.gov)

DRS Deputy Director (Troy.Pruett@nrc.gov)

Senior Resident Inspector (David.Dumbacher@nrc.gov)

Resident Inspector (Jeremy.Groom@nrc.gov)

Branch Chief, DRP/ (Geoffrey.Miller@nrc.gov)

Senior Project Engineer, DRP/ (Peter.Jayroe@nrc.gov)

Project Engineer, DRP / (Greg.Tutak@nrc.gov)

Site Secretary, DRP/ (Dawn.Yancy@nrc.gov)

Public Affairs Officer (Victor.Drocls@nrc.gov)

Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov RITS Coordinator (Marisa.Herera@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

OEMail Resource OEDO RIV Coordinator, (Leigh.Trocine@nrc.gov)

ROPreports R:\\_REACTORS\\_CW\\2009\\CW REG CONF MS 110909.doc SUNSI Rev Compl.

Yes No ADAMS

Yes No Reviewer Initials GM Publicly Avail

Yes No Sensitive Yes ; No Sens. Type Initials GM SPE

DRP/PBB BC:DRP/PBB PAJayroe GBMiller

/RA/

/RA/ JClark for 11/12/2009 11/12/2009 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

1 NRC Regulatory Conference NRC Regulatory Conference Callaway Plant Callaway Plant TDAFP Failure to Start 5/25/09 TDAFP Failure to Start 5/25/09 November 9, 2009 2

Regulatory Conference Presentation Outline Introduction Fadi Diya Risk Assessment Dave Shafer Qualitative Evaluations Fred Bianco Risk Assessment Quantification Dave Shafer Summary Greg Bradley Corrective Actions Les Kanuckel Closing Fadi Diya

3 Introduction Circumstances leading up to the event are unacceptable May 25, 2009 failure of the Turbine Driven Auxiliary Feedwater Pump (TDAFP) to start o The valve actuator was manually operated in the as found condition o Following lubrication the valve tested satisfactorily The performance deficiencies constitute violations of Federal Regulations (September 30, 2009 Special Inspection Report)

Ameren is not contesting the violations We will provide information relative to the risk assessment We will describe our extensive corrective actions 4

Risk Assessment Areas of Agreement:

Quantification of unrecovered internal events risk Quantification of external events risk (fires & flooding)

Trip throttle valve can be locally operated manually

5 Risk Assessment We will provide additional information in the following areas:

Ergonomics

Available Time o Diagnosis phase o Action phase 6

Narrative May 25, 2009 at 1141, Operations commenced Surveillance Testing

Auxiliary Feedwater Actuation Signal (AFAS) relays actuated as expected

Main Steam supply valves opened as expected

The TDAFP failed to start

Initial investigation determined the actuator had stopped just prior to latching the valve o Main Control Board (MCB) indications o Local observations o Review of drawings

7 Narrative (Cont)

Investigation and Repair Torque switch stopped valve movement o

Manually operated actuator (as found condition) o It would have taken 2-3 turns to latch valve and make-up limit switch.

The actuator would then have opened the valve (in an actual station blackout event)

Lubricated the trip throttle valve spindle and sliding nut and stroked the valve actuator several times Successfully performed post maintenance testing and the TDAFP was declared operable 5/25/09 at 2056 8

Ergonomics Factors Important to Ergonomics:

Equipment displays & controls Instrumentation information (quality, quantity and diversity)

Interaction of the operator with the equipment Equipment layout Environmental conditions

9 Ergonomics - Qualitative Evaluation Actions for recovery of the TDAFP with a station blackout (SBO) place additional challenges on the Operations crew Training The use of diverse indications Procedures We will restore auxiliary feedwater flow from the TDAFP prior to Steam Generator (S/G) dryout 10 10 Ergonomics - Training Licensed Operator Auxiliary Feedwater Initial Licensed Training Continuing Training o ECA 0.0, Loss of All Alternating Current (AC) Power

- 24 month frequency o Critical Safety Function (CSF) - 12 month frequency Non Licensed Operator - Operations Technician (OT)

Auxiliary Feedwater Initial Training - Secondary Classroom Continuing Training - 36 month frequency On the Job Training

11 11 Ergonomics - Control Room Indication - Normal Operation Pump Speed and Setpoint Steam Supply Steam Supply Trip Throttle Valve Position Overspeed Reset Lamp Pump Discharge Pressure Trip Throttle Valve Hand Switch 12 12 Ergonomics - Control Room Indication - SBO No TDAFP

13 13 Ergonomics - Training Trip throttle valve is a unique valve, the only one like it in the plant Actuator must go in the closed direction to latch the valve, then will reverse direction and open the valve o Operators are trained specifically on this valve o Manually operate the trip throttle valve to start the TDAFP 14 14 Ergonomics - Indication - Trip Throttle Valve Latch Up Lever Trip Hook

15 15 Ergonomics - Governing Procedures - SBO ECA 0.0, Loss of All Alternating Current (AC) Power Directs the operator to check AFW flow Gives the guidance for restoring the TDAFP CSF-1, Critical Safety Functions Red Path on Heat Sink - maintains the priority of the control room staff to restore flow from the TDAFP to restore a heat sink 16 16 Ergonomics - Governing Procedures Multiple priorities during a SBO:

Loss of AFW flow - Failure of TDAFP to start Loss of Offsite Power Two Emergency Diesel Generators (EDG) failure to start LOSS of ALL AC Power (ECA 0.0) MANAGES these priorities Step 4 Response Not Obtained (RNO) ECA 0.0 dispatch secondary Operations Technician (OT) to the TDAFP Step 5 ECA 0.0 Reactor Operator will start process of Restoration of Offsite Power, then Step 7 will dispatch OTs to EDGs Step 13 RNO requires MAINTAIN AFW flow Step 16 requires CHECK of SG level above 7% and MAINTAIN AFW flow Step 23 requires CHECK AC emergency buses and RNO loops back to Step 11 Procedure use drives priorities

17 17 Ergonomics - Governing Procedures (cont)

Loss of all AC Power procedure 18 18 Ergonomics - Governing Procedures (cont)

CSF-1, Critical Safety Functions Continuously monitored when in Emergency Procedure Red Path on Heat Sink - maintains the priority of the control room staff to restore flow from the TDAFP to restore a heat sink

19 19 Ergonomics - Staffing Available for Recovery Assumptions for response time:

Operations normal shift complement for back shifts and weekends o Normal Control Room Staffing 6

o Normal Field Staffing 7

One OT would be dispatched to the TDAFP Two OTs would be dispatched to the EDGs Staffing allows for additional OTs and a Field Supervisor that would be dispatched to assist at the TDAFP and EDGs 20 20 Ergonomics - Multiple Priorities There would be multiple priorities during a Station Blackout (SBO) with failure of TDAFP to start:

TDAFP failure to start Loss of Offsite Power Two Emergency Diesel Generators (EDG) failure to start ECA 0.0 is designed and written to manage these priorities

21 21 Ergonomics - Pump Room Conditions:

Room temperature averages 90 -110 deg F

No Emergency Lighting in the room - only Emergency Lighting was in the hallway

Trip throttle valve accessibility OTs:

Tour the room at least once per shift

All carry and routinely use flashlights on rounds

Are very familiar with the room layout

Know how to access all areas of the room

Inspect mechanical overspeed trip linkage each shift 22 22 Ergonomics - Plant West Add pictures of room

23 23 Ergonomics - Plant East Add pictures of room 24 24 Ergonomics - SBO - Lighting

25 25 Ergonomics - Summary

Equipment displays & controls o

Control Room indications and displays allow for quick and accurate diagnosis o

Procedures and displays maintain focus on priorities

Equipment layout o

OTs are familiar with room o

Trip Throttle Valve can be accessed from either side of the pump

Instrumentation information (quality, quantity and diversity) o Control Room information provides direct indication of trip throttle valve position (high quality) o Allows for timely diagnosis

Interaction of the operator with the equipment o

OTs are familiar with the room o

OTs are trained on valve operation o

Valve actuator was manually operated with near normal effort

Environmental conditions o

OTs carry a flashlight o

Flashlight provides adequate lighting to access and operate o

Room is hot, but this is the normal condition and not unlike other plant areas o

OTs have trained in more severe conditions 26 26 Ergonomics - Risk Assessment PSFs PSF Levels NRC CALLAWAY Multiplier Ergonomics/

HMI Missing/Misleading X

50 Poor X

10 Nominal 1

Good 0.5 Poor - the design of the plant negatively impacts task performance (e.g. poor labeling, instrumentation, computer interfaces)

Control room indications are clear GOOD Spindle not properly lubricated, but operated with near normal effort POOR Thermal overloads - Not relevant, SBO scenario Unique valve design, however training addresses POOR Access (design) not ideal POOR Control room priorities & focus is on heat sink restoration GOOD

27 27 Available Time - Risk Assessment Factors Important to Available Time:

Time to S/G dryout (before core damage)

Time for the crew/operator to diagnose the fail-to-start condition Time available to act and manually start the TDAFP Time available for repeat actions 28 28 Available Time - Operator Response Timing Three different crews response time tested for SBO w/loss of TDAFP

All 3 crews took less than 5 minutes to reach step 4 of ECA 0.0

Dispatch an OT to the TDAFP Three different OTs were response time tested

From the time they were contacted, given a brief of conditions, to the time they entered the room was less than 5 min These response tests validate the times used in the Callaway Timeline Following EOPs: 6 min

[Total 6 min]

Contact OT: 5 min Brief OT and Travel to the Pump Room: 5 min OT Assesses Condition: 5 min Contact MCR for Instructions and receive second direction to open valve: 5 min

[Total 20 min]

Manipulation Time: 5 min

[Total 5 min]

(Total Time: 31 min)

[49 Minutes remain for repeated attempts to open the trip throttle valve]

Total Time Available:

80 min Callaway Revised SPAR-H Timeline

29 Available Time - Risk Assessment Time to S/G dryout is 80 minutes o Based on thermodynamic heat balance for Callaway

• Actual S/G secondary inventory

• Decay heat based on Cycle 17 burnup conditions o Conservative assumptions

• Decay heat uncertainty added

• RCS is instantly in thermal equilibrium with S/Gs

• Cycling of the Atmospheric Steam Dumps was not credited o A significant portion of the RCS must boil away after S/G dryout for actual core damage to occur 30 30 Available Time - Timeline Comparison

31 31 Available Time - Summary Time to S/G dryout (before core damage) o S/G dryout is conservatively determined to be 80 minutes Time for the crew/operator to diagnose the fail-to-start condition o Control Room diagnosis performed within 6 minutes Time available to act and manually start the TDAFP o Communication and transit (10)

• Contact and brief

• Transit o Assess and manipulate (15)

• Assess and communicate

• Manipulation Time available for repeat actions 32 32 Available Time - Risk Assessment - Diagnoses PSFs PSF Levels NRC CALLAWAY Multiplier Available Time

- Diagnoses Inadequate Time P(failure) = 1.0 Barely adequate time (~ 2/3 x nominal) 10 Nominal time 1

Extra time (between 1 and 2 x nominal and > 30 min)

X 0.1 Expansive time (> 2 x nominal and > 30 min)

X 0.01 Based on Callaways timeline, which includes an elapsed time of 6 minutes for control room diagnosis and 5 minutes to assess valve conditions, leads to a diagnosis of EXPANSIVE TIME

33 33 Available Time - Risk Assessment - Action PSFs PSF Levels NRC CALLAWAY Multiplier Available Time -

Action Inadequate Time P(failure) = 1.0 Time available is ~ the time required 10 Nominal time X

1 Time available >= 5x the time required X

0.1 Time available >= 50x the time required 0.01 Based on Callaways timeline, which includes an elapsed time of 31 minutes for the action and 5 minutes per valve manipulation, leads to a diagnosis of TIME AVAILABLE >= 5x 34 34 Risk Assessment Summary We have discussed:

Procedures that establish our priorities

Indications that maintain our focus

Training (CR and field personnel) that shape how we react to events

Staffing that allow us to handle multiple priorities

Timing that allows multiple attempts to open the trip throttle valve

Room conditions that with a flashlight are suitable for opening the valve We have provided basis for:

Ergonomics shaping factor

Available Time shaping factor These performance shaping factors lead to the risk being <1.0E-6 Very Low Risk Significance (Green)

Our operating crews would open the trip throttle valve in these postulated conditions prior to the onset of core damage

35 35 Hardware Corrective Actions Approved use of a more effective high temperature grease for the trip throttle valve Correct valve stem lubrication type and preventive maintenance frequency for other important motor operated valves are being verified Installed emergency lighting in TDAFP room Installed an access platform for the trip throttle valve Adequate emergency lighting, access, and tooling to support other critical operator recovery actions are being verified 36 36 Process Corrective Actions Revised work instructions for trip throttle valve replacement to verify lubrication as a critical step and made numerous other work instruction improvements Developed a stand alone preventive maintenance document for trip throttle valve lubrication and changed lubrication frequency Developed a more rigorous review process for preventive maintenance basis changes

37 37 Organizational Corrective Actions Continue to reinforce written instruction use and adherence Communicated expectations and providing training to personnel who establish lubrication preventive maintenance bases and frequency intervals Dedicated work coordinators will be assigned for major Auxiliary Feedwater System activities during refueling outages Lowered threshold for use of Event Review Teams to investigate issues Strengthened management support for root cause analyses and associated teams 38 38 Closing Failure of TDAFP to start is NOT ACCEPTABLE Implemented extensive corrective actions with broad extent of cause/condition resulted in:

o Hardware changes o Process changes o Organizational behavior changes We have a high confidence that we would have opened the trip throttle valve when needed We ask that you consider the information we have provided today