ML113140385
| ML113140385 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/09/2011 |
| From: | Thadani M Plant Licensing Branch IV |
| To: | Lawrence Criscione NRC/RES/DRA/OEGIB |
| Thadani, M C, NRR/DORL/LP4, 415-1476 | |
| References | |
| Download: ML113140385 (2) | |
Text
From:
Thadani, Mohan Sent:
Wednesday, November 09, 2011 7:44 AM To:
Markley, Michael; Lund, Louise; Evans, Michele; Bahadur, Sher; Blount, Tom; Rosenberg, Stacey; Banic, Merrilee; Lent, Susan
Subject:
Public Petition, dated October 7, 2011, Submitted by Lawrence Criscione Larry:
Neither James Polickoski nor I received your 10 CFR 2.206 petition submittal on October 7, 2011. Our names appeared to have been pasted in your email, but no emails appeared in our email boxes.
I will incorporate into your petition request the additional 18 pages that were included in the petition version attached to your email dated November 08, 2011. They were missing from the submittal distributed on October 14, 2011. The additional 18 pages will be reviewed with the submittal as you have requested.
Thank you for the update on your request, Please feel free to contact me if any other issues arise on your petition.
Mohan From: Lawrence Criscione [1]
Sent: Tuesday, November 08, 2011 6:29 PM To: Thadani, Mohan; Polickoski, James
Subject:
Please respond Mohan/Jim:
Please see the attached 10CFR2.206 petition which was copied to you on October 7, 2011.
It took me until October 14, 2011 to get a certificate so that I could electronically submit the attached request. Once I received this certificate an uploaded the petition, the NRC refused to accept it because some of the pages were scans. As a result, I re-uploaded the petition with the last 18 pages left out (i.e.
I uploaded the first 40 of 58 pages).
The purpose of this email is to ensure that you are processing my FULL petition. The petition should be 58 pages long (a one page cover letter and a 57 page enclosure). If you have only processed the first 40 pages of my petition (i.e. the electronic submission from October 14th) then please add the last 18 pages of the attached document to my petition.
Please note, the attached document is what was copied to you on October 7, 2011. If you have already processed the Oct. 7 document, then there is nothing you need to do with this attachment.
Please respond to this email so that I know you have the entire petition. I am sorry for any confusion this has caused, but some of the documents included in the attachment were only available to me as scans.
- Thanks, Larry Lawrence S. Criscione (573) 230-3959 From: lscriscione@hotmail.com To: bill.borchardt@nrc.gov CC: jmo4rep@juno.com; jeanette.oxford@house.mo.gov; mohan.thadani@nrc.gov; james.polickoski@nrc.gov
Subject:
FW: P-4/564°F FWIS at Wolf Creek and Callaway Plant Date: Fri, 7 Oct 2011 23:00:31 -0400 Mr. Borchardt:
In late Spring 2010 I read Revision 01 to LER 482-2009-009. Because of work I spearheaded at Callaway Plant, upon reading the Wolf Creek Licensee Event Report I was concerned about the acceptability of the Reactor Shutdown procedure at Callaway Plant. In the summer of 2010 I wrote most of the attached 10CFR2.206 Request, which I did not submit since I believed that there was some likelihood that either Region IV or Callaway Plant would adequately respond to the Wolf Creek LER by revising Table 3.3.2-1 of the Callaway Plant Technical Specifications in a similar manner as Wolf Creek had applied to revise the same table in their Technical Specifications. However, it has now been 11/2 years and I no longer think it is likely that Region IV or Callaway Plant are going to correct the issues with the Reactor Shutdown procedure and Callaway Plant will likely be again violating their Technical Specifications by bypassing the P-4/564°F FWIS in MODE 1 as part of their reactor shutdown plan for their upcoming refueling outage.
My request is:
The US NRC prevent Callaway Plant from bypassing the P-4/564°F FWIS in MODEs 1 through 3 until their Technical Specifications are revised to allow this practice.
I would like a preliminary evaluation of the steps in Callaway Plant's Reactor Shutdown procedure (which allow bypassing of the P-4/564°F FWIS) performed prior to Callaway Plant using that procedure to shut down the reactor for their upcoming refueling outage. The attached document provides the justification for this request as well as some less eminent issues which need to be looked into.
A Senior Reactor Operator (SRO) at Callaway Plant (Pat Shannon) wrote a condition report (CARS 200703001) in March 2007 questioning whether or not the plant's Technical Specifications allowed the P-4/564°F FWIS to be bypassed in MODEs 1 & 2. Because this condition report was written just days prior to Refueling Outage 15, plant management pressured the Senior Reactor Operator to withdraw his condition report. Because the condition report was deleted prior to it being sent to the plant's Screening Committee, it does not appear in the Callaway Action Request System's database; however, I have a hard copy of the original report.
Enclosed with the attached letter is some background information regarding this issue. Included in the enclosure are some internal Callaway Plant emails concerning the plant's decision to allow bypassing the P-4/564°F FWIS in MODEs 1 & 2. From the emails it is apparent that there was much discussion regarding the decision of whether or not the plant's Technical Specifications allowed this safety function to be bypassed. The decision by Ameren to not pursue a change to Callaway Plant's Technical Specifications was a conscious decision by its Licensing Department. I am requesting that the US NRC review this decision and determine whether or not it is their opinion that a change to Callaway Plant's Technical Specifications is needed.
As a former submarine officer, I assume you are familiar with the following quote from Admiral Rickover:
A major flaw in our system of government, and even in industry, is the latitude allowed to do less than is necessary. Too often officials are willing to accept and adapt to situations they know to be wrong. The tendency is to downplay problems instead of actively trying to correct them.
I believe that if you choose to look into this issue, you will find that the tendency to "downplay problems instead of actively trying to correct them" was not only present within Ameren when they consciously chose not to revise their Technical Specifications prior to blocking P-4/564°F in MODE 1, but is also present in our own Region IV where they have allowed Callaway Plant to conduct practices, for which they cited Wolf Creek, because Ameren was able to get a less than adequate safety evaluation past NRR in the mid-1990s (a safety evaluation which only addressed bypassing the P-4/546°F FWIS in MODE 3 and was silent on MODEs 1 & 2).
I've copied Missouri legislator Jeanette Oxford on this email and the attached 10CFR2.206 Request.
Representative Oxford has been assisting me with getting Safety Culture issues addressed at Callaway Plant, and she is also concerned with ensuring the ratepayers in the State of Missouri are not unnecessarily burdened with operating expenses stemming from poor stewardship of generating facilities (although the Wolf Creek Nuclear Operating Company is in Kansas, there may be some Missourians in the Kansas City area who fall into WCNOC's rate base since it is partially owned by Kansas City Power &
Light). The Citizen's Utility Ratepayer Board in Kansas may be interested in the outcome of this request since this issue obviously concerns their ratepayers. It is my opinion that Callaway Plant has not been meeting Technical Specification 3.3.2; however, if I am wrong about Callaway Plant, then it is my opinion that Wolf Creek unnecessarily incurred expenses responding to the errors of NRC inspectors in 2009 and 2010. These expenses included protesting a noncited violation (NCV 05000482/2009004-04), writing and revising a Licensee Event Report (LER 482-2009-009, revisions 0 and 1), and processing a Technical Specification amendment (LA 194).
V/r, Larry Lawrence S. Criscione (573) 230-3959 Human experience shows that people, not organizations or management systems, get things done.
From: Mohan.Thadani@nrc.gov To: lscriscione@hotmail.com; James.Polickoski@nrc.gov Date: Tue, 6 Sep 2011 08:19:07 -0400
Subject:
RE: P-4/564°F FWIS at Wolf Creek and Callaway Plant Larry:
I have not seen an amendment request, similar to the subject Wolf Creek Amendment, for Callaway Plant, Unit 1.
Mohan From: Lawrence Criscione [2]
Sent: Friday, September 02, 2011 8:27 PM To: Thadani, Mohan; Polickoski, James
Subject:
P-4/564°F FWIS at Wolf Creek and Callaway Plant Jim/Mohan, Please see the attached document (ML110550846) concerning the P-4/564°F FWIS at Wolf Creek.
Both Wolf Creek and Callaway Plant have a ESFAS feature wherein a Feed Water Isolation Signal is generated under the following conditions:
- 1. The reactor trip breakers are open (as read by permissive P-4) with P-4 not reset AND
- 2. Reactor Coolant Temperature less than 564°F (Lo-Tavg).
On April 13, 2010 Wolf Creek Nuclear Operating Company a request (ML101100391) to amend its operating license such that the P-4/564°F FWIS was no longer required during MODE 3.
On March 30, 2011 we approved Wolf Creek's requested amendment (ML110550846).
To your knowledge, has Callaway Plant submitted a similar amendment? That is, to your knowledge, do the Technical Specifications at Callaway Plant allow it to block the P-4/564°F FWIS (function 8.a) during MODE 3?
Larry Lawrence S. Criscione (573) 230-3959