ML11355A107

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And Reactor Oversight Process
ML11355A107
Person / Time
Site: Callaway 
Issue date: 12/20/2011
From: Frederick Brown
Division of Inspection and Regional Support
To: Oxford J
State of MO, State of MO, State Representative, 59th MO House District
Brown F
References
Download: ML11355A107 (2)


Text

From: Brown, Frederick Sent: Tuesday, December 20, 2011 4:38 PM To: Jeanette Oxford

Subject:

RE: Callaway Plant and Reactor Oversight Process

Dear State Representative Oxford,

Thank you for providing me your views regarding how issues of low risk significance are handled in the NRCs Reactor Oversight Process (ROP).

We are currently conducting a biennial survey of external stakeholders views regarding the effectiveness of the ROP (the survey can be accessed at http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/program-evaluations.html).

My staff will treat your e-mail as a formal submission to the survey.

A summary of the survey results will be included in the annual ROP self-assessment report to the Commission (normally issued in April), and a consolidated response to survey comments will be publicly available in the summer of 2012.

Thank you again for your comments, we appreciate the feedback from our stakeholders.

Fred Frederick Brown, Director, Division of Inspection and Regional Support Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission From: Jeanette Oxford [1]

Sent: Monday, November 28, 2011 9:16 PM To: Brown, Frederick

Subject:

Callaway Plant and Reactor Oversight Process Mr. Brown, Thank you for the email concerning the Reactor Oversight Process.

In your email you state:

The ROP focuses inspection on areas of greatest risks, applies greater regulatory attention where there are plant performance problems, uses objective measurements of performance, give the public timely and understandable assessments of plant performance, and provides responses to violations in a predictable and consistent manner that corresponds to the safety significance of the problem.

For the past three years, I have been attempting to assist Larry Criscione in addressing an incident which occurred at Amerens Callaway Plant. Attached to this email is an article about the incident which Larry wrote for the Professional Reactor Operator Society.

According to Mr. Criscione, on October 21, 2003 Callaway Plant was shutting down for a forced outage when the NRC licensed operators lost control of reactor temperature due to a build-up of a radioactive gas called Xenon-135. The falling temperature caused the plants filtering system to automatically isolate.

During the confusion of responding to the falling temperature and the loss of the filtration system, the operators failed to notice the reactor passively shutting down.

At our November 8, 2011 meeting, representatives from the NRC (Tony Vegel and Dave Dumbacher) confirmed that the NRCs agrees with Mr. Crisciones assessment that from 10:18 to 11:25 am on October 21, 2003 the NRC licensed operators at Callaway Plant were not aware that the reactor they were supposed to be monitoring had passively shut down.

At 11:25 am an alarm annunciated on the reactor plants Main Control Board, indicating to the personnel in the control room that reactor power had lowered into the Source Range. At this point, according to Mr.

Criscione, any competent operator should have known that his/her duty was to: (1) promptly insert the reactors control rods to ensure it stayed shutdown once the xenon decayed away, (2) notify the plants upper management that the reactor was no longer operating, and (3) document in the plants Corrective Action Process that the crew had failed to notice the reactor passively shutting down. None of these items were done (the control rods were not inserted for another 40 minutes). It is Mr. Crisciones belief (which he has alleged to the US NRC on multiple occasions) that the crew failed to perform these actions because of dishonesty - that is, they knew their obligations yet failed to comply because they wished to cover up their mistakes from the sites upper management. It is also Mr. Crisciones contention that the Plant Director (Dave Neterer, who at the time was the Operations Manager) was in the Main Control Room at 11:25 am and that Neterer was involved in covering up the incident.

Mr. Criscione claims that the NRC has refused to adequately investigate his concerns because, under the Reactor Oversight Process, incidents for which the risk of a reactor accident were low are not pursued. I have a concern with this. As a member of the public and as an elected representative of the public, it is troubling to me that the uppermost management of at a nuclear plant would allow the insertion of the reactors control rods to be delayed for 40 minutes in order to keep his operators from looking bad - if that is indeed what happened here. I have looked at the incident from many angles, and the only conclusions that make sense to me are dishonesty and/or incompetence. Regardless of what the risk of a reactor accident was, I expect an allegation such as this to be thoroughly investigated. A year ago, Mr. Criscione submitted a 10CFR2.206 petition requesting the NRC obtain answers from Ameren regarding why it took them 40 minutes to insert the control rods after recognizing the reactor was in the source range. The NRC rejected Mr. Crisciones petition. In my opinion, with regard to the October 21, 2003 passive reactor shutdown at Callaway Plant the NRC has failed to: give the public timely and understandable assessments of plant performance.

Mr. Crisciones latest petition (concerning Amerens practice of disabling one of its safety systems in violation of its operating license) is an example of yet another important issue with little direct risk of a reactor accident. It is evident from the email trail which Mr. Criscione provided in his petition that Ameren had ample opportunity to recognize the need to amend their operating license but through a combination of mismanagement and disregard for professional engineering opinions failed to take the necessary steps to operate the plant in accordance with their license. Yet, because there was no significant risk of an accident, the NRC is unlikely to address the matter. However, as a member of the public and as an elected representative of the public, it troubles me greatly that the operators of a nuclear plant would fail to live up to the commitments they made to the US Nuclear Regulatory Commission when they obtained a license to operate their plant.

JMO Jeanette Mott Oxford State Representative, 59th MO House District 2910 Lemp, St. Louis, MO 63118 573-751-4567 (Jefferson City) 314-771-8882 (St. Louis)