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

UNITE D S TATES NUC LEAR RE GULATOR Y C OMMIS SI ON R EG IO N I V 6 12 EAST LAMAR BLVD , SU ITE 4 00 AR L I N GTON , TEXAS 7 601 1- 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

Regulatory Conference Presentation Outline Introduction Fadi Diya Risk Assessment Dave Shafer NRC Regulatory Conference Qualitative Evaluations Fred Bianco Risk Assessment Quantification Dave Shafer Callaway Plant Summary Greg Bradley TDAFP Failure to Start 5/25/09 Corrective Actions Les Kanuckel Closing Fadi Diya November 9, 2009 1 2

Introduction Risk Assessment Circumstances leading up to the event are unacceptable May 25, 2009 failure of the Turbine Driven Auxiliary Areas of Agreement:

Feedwater Pump (TDAFP) to start o The valve actuator was manually operated in the as found condition Quantification of unrecovered internal events risk o Following lubrication the valve tested satisfactorily Quantification of external events risk (fires & flooding)

The performance deficiencies constitute violations of Federal Regulations (September 30, 2009 Special Trip throttle valve can be locally operated manually Inspection Report)

Ameren is not contesting the violations We will provide information relative to the risk assessment We will describe our extensive corrective actions 3 4

Risk Assessment Narrative May 25, 2009 at 1141, Operations commenced Surveillance Testing We will provide additional information in the following areas: Auxiliary Feedwater Actuation Signal (AFAS) relays actuated as expected Ergonomics Main Steam supply valves opened as expected Available Time o Diagnosis phase The TDAFP failed to start o Action phase 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 5 6

Narrative (Cont) Ergonomics Investigation and Repair Factors Important to Ergonomics:

Torque switch stopped valve movement o Manually operated actuator (as found condition) Equipment displays & controls 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 Instrumentation information (quality, quantity and blackout event) diversity)

Lubricated the trip throttle valve spindle and sliding nut Interaction of the operator with the equipment and stroked the valve actuator several times Equipment layout Successfully performed post maintenance testing and the TDAFP was declared operable 5/25/09 at 2056 Environmental conditions 7 8

Ergonomics - Qualitative Evaluation Ergonomics - Training Licensed Operator Actions for recovery of the TDAFP with a station Auxiliary Feedwater blackout (SBO) place additional challenges on the Initial Licensed Training Operations crew Continuing Training o ECA 0.0, Loss of All Alternating Current (AC) Power

- 24 month frequency Training o Critical Safety Function (CSF) - 12 month frequency The use of diverse indications Procedures Non Licensed Operator - Operations Technician (OT)

Auxiliary Feedwater We will restore auxiliary feedwater flow from the TDAFP Initial Training - Secondary Classroom prior to Steam Generator (S/G) dryout Continuing Training - 36 month frequency On the Job Training 9 10

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

Ergonomics - Training Ergonomics - Indication - Trip Throttle Valve Trip throttle valve is a unique valve, the only one like it in the plant Trip Hook 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 Latch Up Lever 13 14

Ergonomics - Governing Procedures - SBO Ergonomics - Governing Procedures Multiple priorities during a SBO:

Loss of AFW flow - Failure of TDAFP to start ECA 0.0, Loss of All Alternating Current (AC) Power Loss of Offsite Power Two Emergency Diesel Generators (EDG) failure to start Directs the operator to check AFW flow LOSS of ALL AC Power (ECA 0.0) MANAGES these priorities Step 4 Response Not Obtained (RNO) ECA 0.0 dispatch secondary Gives the guidance for restoring the TDAFP Operations Technician (OT) to the TDAFP Step 5 ECA 0.0 Reactor Operator will start process of Restoration of CSF-1, Critical Safety Functions Offsite Power, then Step 7 will dispatch OTs to EDGs Step 13 RNO requires MAINTAIN AFW flow Red Path on Heat Sink - maintains the priority of the Step 16 requires CHECK of SG level above 7% and MAINTAIN AFW control room staff to restore flow from the TDAFP to flow restore a heat sink Step 23 requires CHECK AC emergency buses and RNO loops back to Step 11 Procedure use drives priorities 15 16

Ergonomics - Governing Procedures (cont) Ergonomics - Governing Procedures (cont)

Loss of all AC Power procedure 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 17 18

Ergonomics - Staffing Available for Recovery Ergonomics - Multiple Priorities Assumptions for response time: There would be multiple priorities during a Station Operations normal shift complement for back shifts Blackout (SBO) with failure of TDAFP to start:

and weekends o Normal Control Room Staffing 6 TDAFP failure to start o Normal Field Staffing 7 Loss of Offsite Power One OT would be dispatched to the TDAFP Two OTs would be dispatched to the EDGs Two Emergency Diesel Generators (EDG) failure to start Staffing allows for additional OTs and a Field ECA 0.0 is designed and written to manage these Supervisor that would be dispatched to assist at priorities the TDAFP and EDGs 19 20

Ergonomics - Pump Room Ergonomics - Plant West Add pictures of 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 21 22

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

Ergonomics - Summary Ergonomics - Risk Assessment Equipment displays & controls PSFs PSF Levels NRC CALLAWAY Multiplier o Control Room indications and displays allow for quick and accurate diagnosis o Procedures and displays maintain focus on priorities Missing/Misleading X 50 Equipment layout Poor X 10 o OTs are familiar with room Ergonomics/

HMI Nominal 1 o Trip Throttle Valve can be accessed from either side of the pump Instrumentation information (quality, quantity and diversity) Good 0.5 o Control Room information provides direct indication of trip throttle valve position (high quality) Poor - the design of the plant negatively impacts task performance o Allows for timely diagnosis (e.g. poor labeling, instrumentation, computer interfaces)

Interaction of the operator with the equipment o OTs are familiar with the room o OTs are trained on valve operation Control room indications are clear GOOD o Valve actuator was manually operated with near normal effort Spindle not properly lubricated, but operated with near normal effort POOR Environmental conditions Thermal overloads - Not relevant, SBO scenario --------

o OTs carry a flashlight Unique valve design, however training addresses POOR 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 Access (design) not ideal POOR o OTs have trained in more severe conditions Control room priorities & focus is on heat sink restoration GOOD 25 26

Available Time - Risk Assessment Available Time - Operator Response Timing Callaway Revised SPAR-H Timeline Following EOPs: 6 min

[Total 6 min]

Contact OT: 5 min Three different crews response time Brief OT and Travel to the Pump Room: 5 min tested for SBO w/loss of TDAFP Factors Important to Available Time: OT Assesses Condition: 5 min All 3 crews took less than 5 minutes to Contact MCR for Instructions and receive second direction to open valve: 5 min

[Total 20 min] reach step 4 of ECA 0.0 Time to S/G dryout (before core damage) Manipulation Time: 5 min

[Total 5 min] Dispatch an OT to the TDAFP (Total Time: 31 min)

Three different OTs were response time Time for the crew/operator to diagnose the fail-to-start tested condition From the time they were contacted,

[49 Minutes remain for repeated attempts to given a brief of conditions, to the time Time available to act and manually start the TDAFP open the trip throttle valve]

they entered the room was less than 5 min Time available for repeat actions These response tests validate the times used in the Callaway Timeline Total Time Available:

80 min 27 28

Available Time - Risk Assessment Available Time - Timeline Comparison 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 29 30

Available Time - Summary Available Time - Risk Assessment - Diagnoses Time to S/G dryout (before core damage) PSFs PSF Levels NRC CALLAWAY Multiplier o S/G dryout is conservatively determined to be 80 minutes Inadequate Time P(failure) = 1.0 Time for the crew/operator to diagnose the fail-to-start Barely adequate time (~ 2/3 x condition nominal) 10 o Control Room diagnosis performed within 6 minutes Available Time Nominal time 1

- Diagnoses Extra time (between 1 and 2 x X 0.1 Time available to act and manually start the TDAFP nominal and > 30 min) o Communication and transit (10) Expansive time (> 2 x X

• Contact and brief nominal and > 30 min) 0.01

• Transit o Assess and manipulate (15)

• Assess and communicate

• Manipulation Based on Callaways timeline, which includes an elapsed time of 6 minutes for control room diagnosis and 5 minutes to assess valve conditions, leads Time available for repeat actions to a diagnosis of EXPANSIVE TIME 31 32

Available Time - Risk Assessment - Action Risk Assessment Summary We have discussed:

PSFs PSF Levels NRC CALLAWAY Multiplier Procedures that establish our priorities Inadequate Time P(failure) = 1.0 Indications that maintain our focus Training (CR and field personnel) that shape how we react to events Time available is ~ the time required 10 Staffing that allow us to handle multiple priorities Nominal time X 1 Timing that allows multiple attempts to open the trip throttle valve Available Time -

Room conditions that with a flashlight are suitable for opening the Time available >= 5x the X 0.1 Action valve time required Time available >= 50x the We have provided basis for:

time required 0.01 Ergonomics shaping factor Available Time shaping factor These performance shaping factors lead to the risk being <1.0E-6 Based on Callaways timeline, which includes an elapsed time of 31 minutes Very Low Risk Significance (Green) for the action and 5 minutes per valve manipulation, leads to a diagnosis of TIME AVAILABLE >= 5x Our operating crews would open the trip throttle valve in these postulated conditions prior to the onset of core damage 33 34

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

Organizational Corrective Actions Closing Continue to reinforce written instruction use and adherence Failure of TDAFP to start is NOT ACCEPTABLE Communicated expectations and providing training to Implemented extensive corrective actions with personnel who establish lubrication preventive broad extent of cause/condition resulted in:

maintenance bases and frequency intervals o Hardware changes o Process changes Dedicated work coordinators will be assigned for major o Organizational behavior changes Auxiliary Feedwater System activities during refueling outages We have a high confidence that we would have opened the trip throttle valve when needed Lowered threshold for use of Event Review Teams to investigate issues We ask that you consider the information we have provided today Strengthened management support for root cause analyses and associated teams 37 38