ML073270079

ARB Summary - Discuss Follow-up for Potential Willfulness

ML073270079
Person / Time
Site:	Callaway
Issue date:	06/18/2007
From:	NRC Region 4
To:
References
FOIA/PA-2008-0011, RIV-2007-A-0028
Download: ML073270079 (7)

Text

.1 ARB

SUMMARY

Responsible RPBB RIV-2007-A-0028 Branch Facility Name Callaway ARB Date: June 18, 2007 Docket Number 050-483 01 Case No.:

ARB DECISION Purpose of ARB Discuss follow-up for potential willfulness.

Previous. Concern 3- RPBB to inspect.

Decisions Concern 4- ACES to offer early ADR, if ADR fails, 01 to investigate high priority.

Today's Decision Based upon discussion with the inspector(s) conducting review of the technical issue of Concern 2, the ARB did not find evidence of willful misconduct. In addition, the ARB concluded that there was no violation of regulatory requirements to warrant an 01 Investigation.

RPBB to document review of issue more fully including whether failure to log entry into TS 3.4.2 or time to document issue in CAR violated an NRC reguirement.

Basis for If review finds that there were violation(s) of NRC requirements.

Another ARB REFERRAL Refer to: Criteria Reviewed?

Referral Rationale 01 INVESTIGATION Priority Rationale High- Level of management involved DOL Deferral Rationale ARB PARTICIPANTS (* denotes ARB Chairman Approval)

AVegel WBJones DWhite KClayton GMVasquez HAFreeman KDFuller FBrush

On October 23, 2003, while shutting down to Mode 3, the Criterion V, TSs RCS temperature dropped below the Minimum Temperature for Critical Operation. However, the temperature transient was not documented in a condition report until 38 days later when identified by a training instructor. At the time the condition report was assigned a significance level 4. The concern individual (Cl) expressed concern that this significance level was too low. The condition also was not documented in the shift supervisor log.

RPBB Inspect 5/19/07 N N 2 The operating crew waited 90 minutes to fully insert control Criterion V, TSs rods following shutting down the reactor. The Cl believes this delay may have been intentional to avoid scrutiny of crews actions, since the crew was supposed to maintain Mode 2 in case the equipment necessitating the shutdown was repaired. The Cl states that purposefully delaying inserting the control rods, not logging entry into Technical Specifications and not documenting significant operational transients in the corrective action program are dishonest and

.negligent omissions.

RPBB Inspect N N 3 The licensee does not have a healthy SCWE. The SCWE environment for raising concerns was poor for three events

[October 2003 below RCS Minimum Temperature for Critical Operation, June 2005 slow to isolate SI accumulator during shutdown transient, August 2005 slow to isolate SI accumulator during shutdown for ESW pin hole leak down power]. As a result problems were not promptly identified and corrected by the operations shift manager, the operations manager, the employee concerns program manager, or quality assurance organization or regulatory affairs.

RPBB Inspect N N 4 Alleger claims discrimination for having raised safety 10 CFR 50.7 concerns in the form of having his SRO license terminated.

ACES Offer Early ADR N N Revised 5/22/02

June 7, 2007 MEMORANDUM TO: Harry Freeman, Senior Allegations Coordinator FROM: Vincent Gaddy, Chief, Projects Branch B, Division Reactor Projects, Region IV

SUBJECT:

ALLEGATION RIV- 2007-A-0028 CLOSURE MEMO This memorandum provides information to address the alleger's concerns regarding the subject allegation. The NRC has completed its follow-up and inspection of these concerns. The enclosed "Resolution of Concerns" documents the concerns and summarizes the NRC resolution. The NRC performed an onsite inspection between the dates of April 5, 2007 to April 30, 2007. Both concerns were substantiated. However Concern Number 1 was determined to be a more than minor violation as it would be an initiating events precursor. The NRC plans to document this violation in NRC Inspection Report 2007-003. Although Concern 2 was substantiated, it will not be documented since there is no regulatory requirement.

Unless the NRC receives additional information that suggests that these conclusions should be altered, Branch B plans no further action and considers these concerns closed.

Resolution of Concerns Concern 1:

On October 23, 2003, the RCS temperature dropped below the minimum temperature for critical operation. This was not documented in a condition report for 38 days. Once documented the' condition report assigned significance level 4 was too low.

Resolution 1:

As a result of the inspection, this concern was substantiated. The NRC reviewed computer point trend data, operator logs, Technical Specification requirements, corrective action documents and operator procedural guidance.

The October. 23, 2003, plant transient resulted in RCS temperature decreasing approximately 2 degrees F. below the Technical Specification 3.4.2 minimum allowed RCS temperature while critical. Fifteen minutes late a mode change from Mode 2 (Startup) to Mode 3 (Hot Standby) occurred. This Technical Specification limiting condition for operation entry and mode change were not documented per requirements. The operators procedural guidance expected to be able to control RCS temperature and reactor power stable using control of steam loads to establish a reactor critical condition of about 5 E -6 amps. The reactor did become subcritical without immediate operator action and did transition through five decades of power decrease due to the transient in a 20 minute period. No attempts were made to restore power and after two hours the procedural requirement to insert control rods was implemented. Thirty eight days later a corrective action document (CAR) identified the discrepancy.

The licensee recently has initiated CARs 200702601 and 200702606 which highlighted the need to re-review the 2003 event to ensure procedural content and operator training was adequate to respond to future events. These corrective action documents have been assigned significance level 3 and the actions prescribed have the potentialto address the 2003 inadequacies.

The concerns described in Allegation RIV- 2007-A-0028, and confirmed by inspection, were contrary to the requirements of the licensee's Technical Specification bases and operating procedures and were an initiating events reactor restart concern. The NRC plans to document this violation in NRC Inspection Report 2007-003.

Concern 2 The operating crew waited 90 minutes to fully insert control rods following shutting down the reactor.

Resolution 2:

As a result of the inspection, this aspect of Concern 2 was substantiated. The NRC reviewed computer point trend data, operator logs, Technical Specification requirements, corrective action documents and operator procedural guidance.

The reactor did become subcritical without immediate operator action and did transition through

Resolution of Concerns five decades of power decrease due to the transient in a 20 minute period. No attempts were made to restore power and after two hours the procedural requirement to insert control rods was implemented. This time delay was not prudent and did suggest that the operators may not have exercised optimum reactivity management and may not have had adequate plant awareness. The inspector's review of operating procedures did not find any timeliness guidance on performing the steps to insert the control rods.

June 13, 2007 MEMORANDUM TO: Harry Freeman, Senior Allegations Coordinator FROM: Vincent Gaddy, Chief, Projects Branch B, Division Reactor Projects, Region IV

SUBJECT:

ALLEGATION RIV- 2007-A-0028 CLOSURE MEMO, CONCERN 3 This memorandum provides information to address the alleger's concerns regarding the subject allegation. The NRC has completed its follow-up and inspection of the Concern Number 3.

The enclosed "Resolution of Concerns" documents the concern and summarizes-the NRC resolution. The NRC performed an onsite inspection between the dates of April 5, 2007 to April 30, 2007. This concern was not substantiated.

Unless the NRC receives additional information that suggests that these conclusions should be altered, Branch B plans no further action and considers this concern closed.

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RESOLUTION OF CONCERNS Concern 3 The licensee does not have a healthy SCWE. The environment for raising concerns was poor for three events [October 2003 below RCS Minimum Temperature for Critical Operation, June 2005 slow to isolate SI accumulator during shutdown transient, August 2005 slow to isolate SI accumulator during shutdown for ESW pin hole leak down power]. As a result problems were not promptly identified and corrected by the operations shift manager, the operations manager, the employee concerns program manager, or quality assurance organization or regulatory affairs.

Resolution 3:

This concern was not substantiated. As followup to this concern, the inspectors interviewed several Operations first line supervisors, reviewed computer point trend data, operator logs, CARs 200505434 and 200501122, FSAR Section 5.2.2.10.4 and Technical Specification requirements, corrective action documents and operator procedure guidance.

To determine whether a healthy environment exists today the inspectors interviewed several Operations department first line supervisors. All responses indicated that the Operations shift manager, operations managers, ECP manager and other managers were not a factor in their likelihood to self identify and follow through actions to correct discovered problems.

Each also stated that problem identification highlighting their own or crew errors would also not be a factor in their likelihood to participate in the corrective action program. Two individuals stated they had recently made personal errors yet were encouraged to develop the corrective actions. The individuals interviewed believed that the SCWE had improved since 2003 and 2005. The licensee had an independent contractor, Synergy, perform SCWE surveys in 2003, 2005, and 2007. The 2003 and 2005 survey results were completed prior to the respective events provided by the alleger. These did provide a focus on the Operations department but did not indicate an unhealthy environment for raising concerns. The surveys showed that overall plant SCWE had improved to be "very good to strong" in 2005 and 2007. Several departments were noted as needing improvement but Operations department was not one of them.