ML13004A321

Email March 8th

ML13004A321
Person / Time
Site:	Callaway
Issue date:	02/23/2010
From:	Lawrence Criscione NRC/RES/DRA
To:	John Monninger Office of Nuclear Reactor Regulation
Shared Package
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References
FOIA/PA-2012-0259
Download: ML13004A321 (11)

Text

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Criscione, Lawrence From: Criscione, Lawrence Sent: Tuesday, February 23, 2010 1:25 PM To: Monninger, John

Subject:

March 8th Attachments: Critical Parameters.pdf

John, Thanks for the follow up phone call. I sent Lisa Clark my concerns and suggestions regarding the ADR Process.

I plan on coming to see the Chairman at 3 pm on March 8th. If something changes in his schedule, please let me know and I will adjust my plans accordingly.

The email trail below is from 2007. It shows the various levels at Ameren (from the Quality Assurance supervisors to the utility CEO and Nuclear Safety Review Board) who were made aware of the October 21, 2003 Incident and failed to ensure it was properly investigated.

Not shown in the email trail below is the difficulties I have encountered since 2007 in trying to get Region IV to properly investigate the incident. Those difficulties were documented in Representative Oxford's letter to the Chairman.

I appreciate the interest you and the Chairman have shown in this issue. Integrity is the linch pin of the nuclear Safety Culture. A utility which covers up mistakes and retaliates against workers who "pursue the answer" to safety issues cannot be allowed to operate a nuclear reactor plant.

My specific concern regarding the October 21, 2003 Incident is that Region IV has not properly investigated it and held the licensee accountable for its actions. My general concern is that the US NRC no longer has any "back-up" to the regions. Without AEOD, a complaint regarding a region's inadequate investigation of an incident can now only be remitted back to the region (the same people who performed the original investigation) for determination on the investigation's adequacy.

AEOD was eliminated because some people considered its work as a duplication of effort. However, in the nuclear industry which we regulate, duplication of effort is recognized as "defense in depth" and is treated as a cornerstone of nuclear safety.

Thanks again for your assistance, Larry Criscione From: (b)(6)

To: aheflinam '-

CC: (b)(6) ggolmstead@ameren.com; fdiya@ameren.com; ghug es ameren.conr, Ikanuckel@ameren.'om; wjessop@ameren.com; tsteele@ameren.com

Subject:

Allegation RIV-2007-A-0028 Date: Tue, 13 Nov 2007 12:19:40 -0600

Adam, Allegation RIV-2007-A-0028 is the issue I wish to speak with you about before departing Callaway.

As you can see from the email trail below, I have unsuccessfully attempted to get this issue addressed at several levels of the Ameren organization, the US Nuclear Regulatory Commission and the staffs of members of congress,

On October 21, 2003 Callaway Plant was shutting down due to the expiration of a Technical Specification Limiting Condition of Operation for a failed safety related instrument bus inverter (NN11). Condition Aof the LCO expired at 0721, leaving the crew six hours (until 1321) to either have the inverter restored or be in MODE 3. While in Condition 8 of the LCO (6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to shut down to MODE 3 and 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> to cool down to MODE 5), the NRC has allowed plants to remain critical as long as repairs to the equipment are progressing and they do not exceed the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> limit. In the past (and still today) Callaway Plant has made use of this custom; while In the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> window, the plant is placed in a condition where it can be readily shutdown but, as long as repair of the equipment appears possible prior tothe expiration of the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> window, the plant remains critical. This is what the expectation of thel(b)(7)(c) J as on October 21, 2003.

Around 0938 on October 21, 2003 a secondary plant transient caused the crew to lose control of Reactor Coolant System temperature. RCS temperature dropped 10°F during the transient and exceeded the Minimum Temperature for Critical Operation for about 14 minutes. During this time, the crew tripped the turbine to mitigate the RCS temperature transient. Temperature rose 4=F over the next couple of minutes, resulting in an inadvertent reactor shutdown due to the negative reactivity inserted by the temperature rise. eDNA data indicates the plant shutdown around 1025.

Up until this point, I have no concerns with the crew's actions. Although their response to the temperature transient may not have been as timely as a more experienced crew's, their actions were appropriate nonetheless. However, for inexplicable reasons they did not document the transient in the Callaway Action Request System and failed to insert the control banks when they recognized the reactor had shutdown.

he crew did not document the temperature transient because.thel (b)(7)(C) hbelieve did not wish to draw attention to the event. There were some in Operations at the time (and, to some extent, currently who viewed the documentation of operator errors in the CAR System negatively. Although they recognized it was an expectation that such errors should be documented, they did not recognize the true value of documenting and analyzing mistakes. They did not recognize that documented mistakes were an opportunity from which the organization could learn valuable lessons; they instead viewed documented mistakes as instruments to bring unwanted scrutiny of the crew (and of the Operations Department) by upper management.

(b)(7)(C)

I have been told byl . the temperature transient, which was severe enough to result in a Letdown isolation, was not documented because 'Sur standards were different then". This is not true. Although it is true that "our standards were different then", it is not true that a secondary p tas* se-vere enough to result in a Letdown isolation did not meet "our standards". 7 (b)(7)(C) The event certainly meg(b)( )(C) standards; he documented it in CAR 200308555 38 days later after7 ,efused to. The event certainly met t e CAR Screening Committee's standards; they screened it as an Adverse ondition (however, in the tradition of "Midwest Nice", they did not question why it was 38 days old and being documented by an En gineering Department trainer vice the operating crew). The truth is, this event was not documented becaus and possibl )(C)" wanted to cover it up.

Although attempting to cover up a secondary plant transient by not documenting it in the Corrective Action Process is something an organization trusted with the operation of a nuclear power plant cannot allow of its leaders, it is not a concern which rises to the level of needing to be addressed by United States senators. However, the operating crew intentionally delaying the insertion of the Control Banks to cover up the transient, and then the organization and the Nuclear Regulatory Commission refusing to adequately address the issue once it has been uncovered, is a matter which demands the attention of our elected officials.

By 1025 on October 21, 2003 the reactor had inadvertently shutdown. The Control Banks were not inserted until 1204. In Action 5 of CAR 200702606, b)(7)(C) states that he recognized the reactor shutdown shortly after it occurred. Regardless of whether or not the shutdown was immediately recognized, it was certainly recognized w (b(7 the Source Range Nuclear Instruments energized at 1125 (causing a Main Control Board annunciator). In Action (c) 7

---

-ives several reasons for the 100 minute delay in inserting the Control Banks; none of the reasons are viable. He men*ions the confusion which was occurring in the Control Room due to the secondary plant transient and indication problems with one of the steam line drains handswitches; this distraction occurred prior to the 100 minute delay. He 2

mentions responding to the loss of Letdown; Letdown was restored by 1018. He mentions performance of OTO-NN-00001 in response to a loss of NN11 which occurred earlier in the day while troubleshooting; the procedure was merely awaiting the final close out steps and there were no control room steps being performed during the time the rods were withdrawn.

None of7( excuses provided in Action 5 of CAR 200702606 explain the delay in inserting the Control Banks(

rew inte Wionally delayed inserting the Control Banks to cover up the fact that the reactor inadvertently Litpown as a result of the plant response to the earlier secondary plant transient. The Control Banks were not inserted until 1204. This was around the time the organization expected the shutdown to occur had the attempts to repair NN11 not been successful.

Like you and 1I(b)(7)(C) Iserved in the nuclear navy. He was a highly trained reactor operator aboard a nuclear powered naval vessel, 'His exemplary knowledge of nuclear power earned him a position as a prototype instructor in the Navy's nuclear power training pipeline. He is well aware of the high standards of integrity that our nuclear navy inherited from Admiral Rickover. He understands that events are never to be covered up. He also is aware of the extreme importance Admiral Rickover placed upon conservatively controlling reactivity. He understands that the most important task for any nuclear watchstander is to ensure the reactor plant is actively controlled. On October 21, 2003 he undoubtedly recognized that his most important duty upon realizing the reactor had shut down was to ensure the reactor stayed shutdown by actively inserting negative reactivity through either insertion of the control banks or borating until adequate Shutdown Margin was calculated. b ( ) C (b )(7 )(C )

r ( ) C 1 eb He was promoted to (

Jhas been a Senior Reactor Operator at Callaway Plant for*

relativeýy earlydue to the regard which Operations management held his performance as an Operating Supervisor. As a

~b)(7)(C) Ihe was *7consistently ranked above most of his peers on his Performance Appraisals. Recently, he has been promoted to be thel(b)(7)(C) in recognition of his abilities.

I find it hard to believe that an individual witt, b I

ýbackground and ability would not recognize the importance of promotlv inserting the Control Banks to actively shutdown the reactor plant on October 21, 2003. I have had no dealings with) 7 )(c) hich lead me to question his abilities; I only question his integrity.

As you can see " from the email trail . below~(b)(7)(C)I.

,, not the first person I have approached . with this issue. Although Quality Assurance and representatives o ti(,j havesuposedly looked into this issue, I have yet to be interviewed (other than during the statement of my initial allegations to (b)(7)(C in the presence of Quality AsNo one investigating this matter from Callaway Plant have asked to see my evidence of why I am convinced,)( 7 )(c)I intentionally left the Control Banks withdrawn on October 21, 2003 to cover up a plant transient.

1 actions on October 21, 2003 are the actions taken by Operations in 2007 to suppress Equally disturbing as(b)(7)(C) investigation of this issue. From the beginning, CAR 200701278 and CAR 200702606 have been marginalized by the Operations Department. I was placed on a Performance Improvement Plan after attempting to address the j[2e )uate 0 to CAR 200701278 withl b)(7)(c) earlier this year. I have had two very heated discussions witt

()( 7)(LC-)*regarding access to the Main Control Room key card records for October 21, 2003; the first discussi n"started o wiht him asking me "Are you trying to get me fired?" deleted the actions I had drafted for CAR 200702606 (originally Action 4 but eventually sent out as Actions 5 and 6) and closed the CAR without speaking to me about it in August 2007. I was sternly counseled by Operations that I was taking a step backward on my Performance Improvement Plan when I re-opened CAR 200702606 to send my actions.

By our arbitration agreement last Friday (November 9, 2007) Ameren has fairly financially compensated me for the improper retaliation against me which occurred this summer for pursuing an answer to the events of October 21, 2003. However, Ameren has not yet adequately resolved all the issues surrounding the event. The personnel who originally covered up the transient in 2003, and those who wish to impede its investigation still, remain in important leadership positions in the company. Regardless of the Nuclear Regulatory Commission's actions (or inaction) on this event, you and the individuals copied on this email have a duty to ensure the cover up of the October 21, 2003 3

inadvertent shutdown is properly investigated and resolved. Individuals willing to jeopardize the proper shutdown of the reactor plant to cover up their mistakes and individuals willing to jeopardize the careers of those who would properly investigate the issue cannot be allowed to retain leadership positions at a utility trusted with safely operating a nuclear reactor.

I am meeting with you afternoon. If necessary, I can still be available for interview after my separation from Ameren if the company ever decides to properly investigate th eventsofOctoe r 21, 2003 and the retaliation against me this summer. I can be reached at this email address or air Very respectfully, Larry Criscione From: Criscione, Larry S.

Seto Thursday. N r 2007 2:00 AM Toi(b)(6)

CC: 1(b)(6) JVos ,oma-sA Su p: RE: FW: CA 200702606, CAR 200701278 and CAR 200704911 Mr. Merschoff, Thank you for your prompt response.

I have already attempted to address this concern with my immediate supervision at Callaway (Operations management),

with the Employee Concerns Program, with the Quality Assurance organization and with theL{7 )(c I I have also attempted to address this concern with Region IV of the US NRC. My original Allegation (RIV-2007-A-0028) was closed without a proper investigation. Following a letter to my US Senator (Richard'Durbin, IL)the NRC has supposedly re-opened the investigation. I have not yet been interviewed by the NRC (either during the original investigation or since it has been re-opened).

I agree that you and Mr. Franz are not part of the formal process to investigate this concern. I believe it is in the best interest of the company for you, Mr. Franz and Mr. Voss to meet with me to discuss this issue, but I must concede that you are the better judge of this than I.

I appreciate your response and I thank you for your advice.

V/r, Larry Criscione Sent: Tuesday, October 30, 2007 4:21 PM To: Iristditram ISn*

CcF7(bj) j Voss, Thomas R Sulect: Re: FW:(F;200702606, CAR 200701278 and CAR 200704911 Mr. Criscione, Thank you for coming forward with this issue. Your belief that a "cover-up" has occurred needs to be addressed. You have several options relative to getting your concern into a formal process for resolution. I encourage you to use any and all of them as necessary.

First, I encourage you to work with your management to assure the event is understood and appropriate action has been taken. Considering the management changes that have occurred since 2003, you have many managers in responsible positions that were not involved and can address the issue objectively.

Second, you can take the issue to the Employee Concerns Program. I understand a new Employee Concerns Coordinator is being selected. This will provide an opportunity to bring a fresh set of eyes on your concern.

4

Third, The NRC has the ability to look objectively at issues such as this by engineers from the Regional Office or Headquarters, and professional investigators from The NRC Office of Investigations (0I). These 01 investigators are often former US Secret Service Agents or US Naval Investigative Service Agents and are very good at investigating allegations of wrongdoing.

Fourth, If you have concerns that the NRC has not taken your concerns seriously, you can contact the Office of the Inspector General. This is an organization that reports to Congress and has the responsibility of assuring that the NRC employees meet their Federal mandate of assuring public health and safety. The OIG's phone number is on the NRC Form posted in various locations in the plant, or can be obtained from the NRC's web site at www.NRC.GOV.

Finally, Mr. Franz and I are not part of the formal processes that I have described which are available for resolution of your concerns. The NRC expects the person with the concerns and the facts to come forward in order for the issue to be investigated if the problem is not being addressed by the licensee. Waiting for the next NSRB meeting to discuss this issue with Mr. Franz and me is not in the best interest of you or the plant.

Regards, Ellis W. Merschoff, PE President, CGE, LLC From: Criscione, Larry S.

Senta Tuesdav. October30 2007 2:14 PM ToD (b)(6) 1 CcV(b)(6) Voss, Thomas K Su ect: FW: CAR 20702606, CAR 200701278 and CAR 200704911 Mr. Merschoff, At 0100 on October 21, 2003 Callaway Plant commenced a down power from 100% power due to the failure of inverter NN1 1. The plant was 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> and 39 minutes into the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> LCO for T/S 3.8.7.A.

At 0721 the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> shut down Limiting Condition for Operation of T/S 3.8.7.B was entered. The plant was at 38% power and the LCO required either NN11 to be restored or the plant to be shutdown to MODE 3 by 1321. The LCO also required the plant to be cooled down to MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> if NNI 1 was not restored.

At 0938 with the plant around 8% power a temperature transient occurred due to the opening of the Main Turbine and MSR drains per an inappropriate procedure step. It is my opinion this transient was caused by a procedure error and not a procedure use error on the part of the Operating crew.

Over the next 25 minutes, temperature fell nearly 10°F resulting in a Letdown Isolation on low Pressurizer Level and operation of the reactor below the Minimum Temperature for Criticality.

The Letdown Isolation occurred at around 1000 and restoration commenced around 1010. Letdown flow was completely restored by 1015.

At 1013 the crew declared MODE 2 and the main turbine was tripped.

Upon tripping the main turbine, a 70 F temperature rise occurred as steam pressure built up to the Steam Pressure setpoint of the condenser steam dumps. The negative reactivity inserted by this temperature rise immediately resulted in a negative startup rate (approximately -116 dpm). By 1023 reactor power was past the Point of Adding Heat and startup rate was approximately -1/3 dpm.

The (b)(7)(C) - as stated in Action 5 to CAR 200702606 that he recognized the reactor shutdown shortly after tripping the turbine.

Around 1204 the crew began inserting the control banks. Between the time of the inadvertent shutdown and the initiation of control rod insertion 100 minutes later, no boration or any other deliberate insertion of negative reactivity occurred.

At 1255 the Shutdown Margin calculation was completed and MODE 3 was declared.

5

The operating crew never documented the RCS temperature transient or the inadvertent shutdown in the Corrective Action Process. A Callaway Action Request was written 38 days after the event by an Engineering Department trainer to document the temperature transient (CAR 200308555).

I came across the inadvertent shutdown and apparent cover up while analyzing data for CAR 200701278 in February 2007. As you can see from the email trail below, I have unsuccessfully attempted to address this issue via several avenues.

I brought this issue to the attention of Mr. Franz via email two weeks ago and have not received a response.

If possible, I would like to discuss the October 21, 2003 transient and apparent cover up with you and Mr. Franz. As you can see from the email trail below, I am not bringing this issue to you as my first choice: you and Mr. Franz are my last resort internal to the company.

You may contact me at work regarding this issue via this email address or at I would appreciate a response as to whether or not you intend to look into this matter.

Thank you, Lawrence S. Criscione, PE From: Crisdone, Larry S.

Sent: Frday, October 19, 2007 8:47 AM To (b)(6).

Subject:

CAR 20070 06, CAR 200701278 and CAR 200704911 Mr. Franz, I am sorry I was unable to meet with you yesterday; I was ou I appreciate the advice you gave me on this issue. Be assured, I am not bringing this issue to you as my first course of action.

The October 1, 2007 email to Fadi Diya below essentially explains the issue.

I first came across it in mid-February 2007. During the remainder of February, I attempted to get Operations to pay attention to it. Co-incidentally in late February the company tried to force me to work unpaid overtime. Part of the discussions revolving around the unpaid overtime issue pertained to the amount of unauthorized (by my supervisor) time I had spent researching and writing CAR 200701278. At this point, I took the issue I had uncovered while researching CAR 200701278 to the NRC as Allegation RIV-2007-A-0028.

I am a Professional Engineer and as such I have an obligation to my employer to first addre . I attempted to do this in February 2007 and have continued to do so. In May 2007 I met withl('b'( 7))', on this issue. I have also met with Dr. Hughes, Les Kanuckel and Fadi Diya as well as multiple meetings with Opera ions.

I have been disappointed with the Nuclear Regulatory Commissions' handling of this issue and addressed it in a letter to Senator Richard Durbin (I am an Illinois resident) on August 16, 2007. I am meeting with Senator Durbin's office on October 26, 2007.

Like me, you draw a paycheck from Ameren. Although certain employees at Ameren wish to cover up this problem, it is in the interest of the share holders that it be addressed. You are my last hope internal to the company. I do not know how much help Senator Durbin's staff will be.

As a professional engineer I have an obligation to the public. People in responsible positions at a commercial nuclear plant intentionally delaying the insertion of the control banks to cover up a transient is serious business; refusing to investigate the matter is equally serious. After you and Senator Durbin, my remaining re-course is public action groups and the press. I prefer to avoid that route if possible.

I have additional data I can send you on this matter (e.g. correspondence with the NRC and Senator Durbin).

Very respectfully, 6

Larry Criscione From: Crisdone, Larry S.

Sent: Wednesday, October 17, 2007 12:27 PM To: Belsky, Luanna M.

Subject:

FW: CAR 200704911 Luanna, If possible, could you please schedule a time for me to meet with Mr. Franz. I am the Shift Engineer today and can be reached at 68459 (this is not the same number as in Outlook).

Thank you, Larry Criscione Original Messa qe - ----

From: (b)(7)(C)

Sent: Wednesday, October 17, 2007 12:14 PM To: Criscione, Larry S.; Mclaughlin, Sharon S.

Subject:

Re: CAR 200704911 Larry - I am offsite on business until Fren NSRB will be gone, so I can't really help you. You might check with Sharon.

From: Hughes, Gary A.

Sent: Wednesday, October 17, 2007 11:41 AM To: Criscione, Larry S.

Subject:

RE: CAR 200704911 Talk to L Belsky. She is the keeper of the schedule for Mr Frantz.

From: Criscione, Larry S.

eTo(7Wp ctoer17, 2007 10:59 AM Cc: Mclaughlin, Sharon S.; Kanuckel, Leslie H.; Hughes, Gary A.

Subject:

CAR 200704911 1(b)(7)(C)

I was hoping to speak with Mr. Franz regarding the October 21, 2003 incident of leaving the control banks withdrawn for 100 minutes following an unplanned shutdown.

I am unable to find his contact information in Outlook (or that of any of the NSRB members). I would appreciate any assistance you might provide me in obtaining a meeting with Mr. Franz or Mr. Merschoff.

Thank you, Larry Criscione From: Criscione, Larry S.

Sent: Monday, October 01, 2007 9:21 AM To. iviA FArfM~

To:(b)(7)(C) Kanuckel, Leslie H.; Mclaughlin, Sharon S.[;(b)(7)(C) Hughes, Gary A.; Cunningham, James L.

Subject:

CAR 200702606 Fadi,

%6R2DQ726rJbsbeen closed. I would like to meet with you at your convenience to discuss this CAR. It was written bj)( 7 )(C) in March.

7

I would have liked to seen the Corrective Action Program handle this CAR differently, but quite frankly I believe the real issue is beyond the Corrective Action Process. For this reason, I can accept the closure of CAR 200702606 (CAR 200704911 has been more appropriately assigned, is still InProcess and addresses some of the same issues). This is an issue I would like to personally discuss with you, however. I have discussed CAR 200702606 several times with my supervisors in Operations since March.

On May 14, 2007 I met in~b) ZIZc J office wit, I() pharon McLaughlin and Quality Assurance. I believe Jim Cunningham, Dr. Hughes and Les Kanuckel were all prese-ntbut I am not certain. Sharon McLaughlin took notes and should be able to tell you who was present. Regardless of their presence at the meeting, I have discussed this issue separately at some point with Jim, Gary and Les.

The May 14, 2007 meeting concerned CAR 200704911 and a QA Audit which was in progress on Operations. At the meeting I expressed my concern that on October 21, 2003 the Operating Crew intentionally left the control banks withdrawn to cover up the fact that the reactor inadvertently shutdown on them shortly after tripping the turbine.

In their responses to Actions 5 & 6 of CAR 200702606, thel(b)(7)(C) /both claim the following:

1. They were aware the reactor would go subcritical when the turbine was tripped.

2. The shutdown was not inadvertent and there was no intention to maintain MODE 2.

3. The Control Banks were not immediately inserted due to higher priority activities.

Regarding item 1: Although I am not convinced the control room staff recognized that the reactor would go subcritical upon tripping the turbine, I have no means to refute the claim that they did recognize it and will have to accept them at their word.

Regarding item 2: It has been my experience at Callaway Plant that if there is any hope that Tech Spec required equipment might be restored prior to the expiration of the Completion Time for the Limiting Condition for Operation, then the plant will remain in the LCO until just prior to the expiration of the Completion Time. Based on this experience, I believe that Plant Management expected the reactor to remain critical until the time limit for LCO 3.8.7.8 was within an hour of expiring (around noon). Shutting down the reactor was the right course of action given the circumstances (the 10'F temperature excursion which brought the reactor below the Minimum Temperature for Criticality). Although the control room staff did not attempt to maintain the reactor critical after the temperature transient (a correct response to the plant conditions), they did not actively shutdown the reactor (continuation of the correct response). They allowed the reactor to passively shutdown on temperature and Xenon but took no active action (increasing boron concentration or inserting rods) for 100 minutes. As a result of their inaction, they inserted the control banks at about the time Plant Management was expecting them to. I believe this was not a co-incidence. I believe insertion of the Control Banks was intentionally delayed to avoid having to explain to Plant Management why the reactor was not maintained critical while repairs to inverter NN11 were still in progress.

Regarding item 3: I have talked to several Senior Reactor Operators and Reactor Operators regarding this event. None of them (other than the two involved) would have allowed anything to delay them in inserting the Control Banks. The "higher priority activities" which prevented the crew from promptly inserting control banks on October 21, 2003 were: the final steps of OTO-NN-00001 (page 5 of OTO-NN-00001, Rev. 006), the final step of OTO-BG-00001 (VERIFY pressurizer level being maintained at program level in automatic) and the four l&C surveillance on the Power Range Nuclear Instruments (the last of which was performed while inserting the control banks which begs the question why these surveillances delayed the insertion of the control banks).

I did not take notes at the May 14 meeting and have qaoie I Shqron, Jim, Gary and Les to ensure I have not misstated any facts oorng this meeting. I copied((b)(7j)Cj jbecause he Is the Originator of CAR 200702606. Although I5LL as accepted the closure of CAR 200702606, it is my understanding he does not believe this issue has, as yet, been sa-tisfactorily resolved.

V/r, Larry Criscione 8

From: Criscione, Larry S.

Seqt: Monday. Ma14.J2007 5:39 AM To4(b)(7)(c) l Cunningham, James L.

Subject:

RE: QA Audit and CARS 200704911

• 7nd Jim, Please let me know when you have time to meet today.

I have some concerns with CARS 200704911 which I intend to address with the NRC on Friday. Although the company has been made aware of all the issues in CARS 200704911 on several occasions, I want to ensure the company understands the importance of these issue before I meet with the regulators.

Thanks, Larry Cnscione From: Kanuckel, Leslie H.

Sent: Friday, May 11, 2007 11:11 AM To: Criscione, Larry S. b 7 C Cc: Cunningham, James L.;

Subject:

RE: QA Audit and CARS 200704911 I'll let you, Jim, and ( ork out a time. Les From: Criscione, Larry S.

Sent: Friday, May 11, 2007 11:04 AM To: Kanuckel, Leslie H.

Cc: Cunningham, James L.; (b)(7)(C)

Subject:

RE: QA Audit and CARS 200704911 I'll take whatever you can give me on Monday.

From: Kanuckel, Leslie H.

Sent: Friday, May 11, 2007 11:00 AM To: Criscione, Larry S. '[b)(7)(C" Cc: Cunningham, James L.

Subject:

RE: QA Audit and CARS 200704911 Larry, I am willing to meet with you but I can't support a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> meeting. If you want to meet at 0900-1000 or 1000-1100 on Monday, I can support that. If this meeting would be to pass on info that you have put together as part of your audit preparations and that you still want factored into the audit, that is Jim Cunningham's job as an Audit Team Leader. I have full confidence that Jim would consider this info objectively and I wouldn't need to be involved in the specifics at this point. Let me know what you want to do. Les From: Criscione, Larry S.

Sent: Friday, May 11, 2007 9:46 AM To: Kanuckel, Leslie H.

Cc: Cunningham, James L.])(7)

Subject:

QA Audit and CARS 200704911

Les, I was informed b(b)(7)(C)

Ftoday that I am no longer available to assist Jim Cunningham with the QA Audit on Operations. The reason given was that I am needed to assist in working down the Operations Corrective Action backlog.

9

I believe the real reason is related to our discussion last week concerning CARS 200704911 - that Operations is not really interested in identifying adverse trends.

I have two CARS which I was planning to discuss with Jim Cunninkit next week, I would like to set up a time on Monday when I can meet with you, Jim unninham andl.....jC I will need approximately three hours. This is a separate from topic from the oneL 7)(C) lJand I have already made plans to meet about on Monday.

Thank you, Larry Criscione From: Cunningham, James L.

Sent: Sunday, May 06, 2007 6:26 AM To: Criscione, Larry S.

Subject:

RE: CARS 200703391 Larry, attached is the verification plan that I want you to use to guide reviews. See you May 14-16.

Thanks, Jim Cunningham From: Criscione, Larry S.

Sent: Sunday, May 06, 2007 6:21 AM To; Cunnineham.James L.

CcJ )()(C) t

Subject:

RE: CARS 200703391 Jim, Thanks for the review. The Late Entries were added by Keith Duncan and I did verify they were present.

Several weeks ago I was toId you needed me to participate during the week of May 14. As far as I know, I am working for you on May 14, 15 and 16. (b)(7)(C) ýagreed to this prior to the outage and has not told me anything to the contrary since that time, I am attending LOCT with Steve Kochert's crew on May 10, 11 and 12 in order to be free to support the QA audit during the following week. I am working nights through May 9 so I am unavailable prior to May 14.

Somewhere in my inbox I have a schedule for the audit which you sent me. If you could forward me the latest schedule for the week of May 14 I would appreciate it.

Thanks, Larry From: Cunningham, James L.

Sent: Saturday, May 05, 2007 6:11 AM To: Criscione, Larry S.

Subject:

RE: CARS 200703391 Larry, did we actually make the changes that you reference in the CAR response? If so, great job and I concur with your response. Changing the subject, are you still going to be able to participate in the Ops Audit for a couple of days between May 7-18?

Corrective Actions:

The following have ammended (,-misspelled) the logs:

CAR 200703391 resolution to be more specific for Log entries; PEM01A, SI PMP A stopped due to no indicated discharge pressure. Job 05515515.485 in progress.

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• CAR 200703391 resolution to be more specific for Log entries; It was determined that the MCB discharge pressure indication was isolated due to manual isolation closed to support COMS and ESFAS testing. PEMOlA, SI PMP A started to support Job 05515515.485.

• CAR 200703391 resolution to be more specific for Log entries; PEM01A, SI PMP A stopped no leak-by observed, Job 05515515.485 complete SAT.

From: Criscione, Larry S.

Sent: Saturday, May 05, 2007 1:21 AM To: Cunningham, James L.

Subject:

CARS 200703391

Jim, Please review the response for CARS 200703391 and let me know of any comments.

Thank you, Larry Cnscione 11