January 29, 2011
211 E. Dunklin Street Jefferson City, MO 65101
The Honorable Jay Nixon Governor State of Missouri
P.O. Box 720 Jefferson City, MO 65102
Dear Governor Nixon:
I am writing you concerning your support for a second nuclear reactor plant in Callaway County.
I am a nuclear engineer. I was an officer aboard a nuclear powered fleet ballistic missile submarine for 42 months. I have worked in either the commercial nuclear power industry or as a government regulator for over a decade. Counting my navy time, I have been associated with nuclear power in one way or another since 1993.
I believe that nuclear fission is an excellent source of energy. It is clean. It is safe. It is the future. Nuclear jobs are on average 25% higher paying than similar industrial work. Nuclear reactors typically employ four times as many workers per megawatt as coal plants and eight times as many as natural gas plants. When you buy electricity from a nuclear plant, you are paying for wages and salaries – not fuel. Nuclear power can be generated as cheaply as power from coal and much cheaper than power from natural gas and renewables (other than hydro). And unlike renewables, nuclear power is available on demand – day or night, windy or calm.
I applaud your decision to support the expansion of nuclear power. But be careful to whom you trust Missouri’s nuclear future.
Nuclear power can be dangerous. You do not need to be a nuclear engineer to know this. It has been proven to the public on multiple occasions: the meltdown of the unit 1 reactor at Fermi plant in Michigan in 1966, the meltdown of the unit 2 reactor at Three Mile Island in Pennsylvania in 1979, the explosion of the unit 4 reactor at Chernobyl in 1986, etc.
The operation of a nuclear reactor plant cannot be trusted to just anyone or any organization. Nuclear power requires a special commitment to the public trust. Not all organizations have that commitment.
Nuclear power requires honesty. It requires conservative decision making. It requires openness. It requires a commitment to admitting to mistakes. It requires a commitment to protecting workers who uncover problems and attempt to get those problems addressed. It requires a commitment to proactively uncover and fix weaknesses instead of merely reactively responding to failures. Without these characteristics in the organization, well designed plants will slowly lose their safety margins and degrade to the point at which an accident becomes likely. It’s happened in the past. It will happen in the future. I am writing to you to minimize it ever happening in Missouri.
For half a decade I was a nuclear engineer at Ameren. I held a Senior Reactor Operator license at Callaway Plant. Most of the employees I worked with are still employed at Callaway. Nearly all of them are decent, honest people who conscientiously perform their jobs and warrant the trust which the public places in them. However, there are key people in the upper management at Callaway Plant whom I do not trust with the operation of a nuclear plant. They have performed dishonestly in the past and to this day refuse to admit their past mistakes.
On October 21, 2003 Callaway Plant was shutting down because of a broken piece of safety-related electrical equipment. At 09:35 am the operating crew attempted to stabilize reactor power at 10% rated power in order to give the electricians a chance to fix the broken equipment and avoid shutting down the reactor. However, the operators failed to recognize the effect that a radioactive nuclear waste gas (Xenon-135) was having on the reactor. Xenon-135 has a high tendency to absorb neutrons which causes the average coolant temperature of the reactor to lower. Since the operators did not properly address the rising Xenon-135 levels, the coolant temperature of the reactor uncontrollably lowered 9°F over a 25 minute period, resulting in reactor operation below the plant’s minimum temperature for criticality and resulting in the reactor’s letdown system isolating.
To counteract the lowering temperature, at 10:13 am the operators manually tripped the plant’s main turbine. Tripping the main turbine had the desired effect on plant temperature: it quickly rose 4°F in a matter of a few minutes. In the United States, commercial reactors are designed such that a sharp rise in reactor temperature will cause them to shut down. And that is what occurred: around 10:18 am the reactor passively shut down due to a combination of the 4°F temperature spike and the increase in Xenon-135.
In terms of reactor safety, what I have described in the preceding two paragraphs was a “nonevent”. The operators made honest mistakes. The reactor behaved as designed and safely shut itself down passively. None of this troubles me. Error is not sin. Humans make errors. Nuclear reactors can be designed so that minor human errors do not cause unsafe conditions.
Keep in mind, Three Mile Island and Chernobyl were not caused by “minor human errors”. They were the result of gross misunderstandings on the part of the operators. Minor human errors do not trouble me. But gross incompetence does.
Although Ameren claims otherwise, it is my professional opinion that the passive reactor shutdown went unnoticed by the operating crew. I say this because from 10:18 to 10:39 am, as reactor power lowered from the power range into the source range, the operators took no action to actively shut down the reactor by inserting the control banks. Instead, they performed routine
(i.e. non emergent) operations on ancillary plant equipment: raised letdown flow from 75 to 120 gpm, placed cooling tower blowdown in service, lowered intake flow. Ask a Senior Reactor Operator or a nuclear engineer if they would prioritize any of those items over actively controlling the nuclear fission reaction in the reactor core. They will tell you that no competent operator would prioritize any activity over taking active measures to ensure the nuclear fission reaction was shut down and would not inadvertently restart.
From 10:39 to 11:25 am the reactor was in the source range with no Source Range Nuclear Instruments energized and with the control rods still at their last critical rod heights. This is a highly abnormal condition to be in and one in which the designers of the plant never intended for the operators to intentionally operate. Despite all this, the public was not in any imminent danger because Xenon-135, the same radioactive nuclear waste gas which had caused the plant to passively shut down, was absorbing enough neutrons to keep the reactor from inadvertently restarting. However, Xenon-135 is radioactive. It decays. It does not last forever. Without the control banks inserted, at some point enough Xenon-135 might decay causing the reactor to inadvertently restart and rise in power on its own.
There are situations when commercial reactors rely on Xenon-135 to keep the reactor from restarting. Whenever this is done, a formal calculation is performed (called a Shutdown Margin surveillance at Callaway Plant) to verify the point at which Xenon-135 levels can no longer be counted on to absorb enough neutrons to keep the reactor shutdown. On October 21, 2003 there was never any Shutdown Margin calculation performed to justify maintaining the control rods withdrawn with the reactor shutdown. If they knew the reactor was shutdown (which I do not believe they did) then the US NRC licensed operators were relying on an informal estimation that Xenon-135 levels would remain high enough to prevent the reactor from restarting. Although they were lucky and the reactor did not inadvertently restart, relying on “luck” is not a strategy most Missourians view as acceptable.
At 11:25 am the operators received an alarm in the reactor control room indicating that the reactor was in the source range. This should have immediately prompted them to insert the control banks. Instead they dragged their feet for another 39 minutes. Since, by procedure, the only way to shut down the reactor at Callaway Plant is by inserting the control banks, by delaying until 12:05 pm to commence insertion of the control banks the operators effectively gave upper management the impression that they were shutting the reactor down shortly after noon. Since plant upper management expected the reactor to be shut down at noon, the operators were able to cover up the fact that the reactor had actually passively shut down 106 minutes earlier. That is, at 12:05 pm no one outside of the main control room was aware that instead of using the control banks to shut down the reactor the operators were inserting the control banks on a reactor that had passively shut down 106 minutes earlier.
The events I just detailed in the preceding paragraphs were reviewed and analyzed by the Union of Concerned Scientists in November 2010 and are documented in an issue brief located at:
Missourians cannot accept reactor operators who cover up mistakes. In nuclear power, mistakes must be admitted to, documented and learned from.
The October 21, 2003 passive reactor shut down was successfully covered up until February 2007, when I accidently uncovered it during an unrelated review of past reactor shutdowns to support a revision to the Reactor Shutdown procedure. As was my duty as a professional engineer, I documented the incident in the plant’s Corrective Action Program.
In 2007 I spent from February through November attempting to get the October 21, 2003 passive reactor shutdown investigated at Ameren. Although a nominal investigation was performed, I was unsuccessful in getting the utility to do a proper analysis of the incident. I was unsuccessful because of two men: the Operations Manager and the Operations Training Manager.
The Operations Training Manager was (and is) a man named David Lantz. On October 21, 2003 Mr. Lantz was the Shift Manager responsible for shutting down the reactor plant. It was his crew that for over an hour failed to recognize the reactor had passively shut down. It was his crew that inappropriately delayed inserting the control banks an additional 39 minutes in order to cover up the incident from plant upper management.
The Operations Manager was a man named David Neterer. In 2008, Mr. Neterer was promoted to Plant Director (the highest position at Callaway Plant) and still holds that position today. At
11:25 am on October 21, 2003 Mr. Neterer was observing the plant shutdown in the reactor control room when the channel 2 Source Range Nuclear Instrument energized and the operators first recognized that the reactor had passively shut down. It was Mr. Neterer’s responsibility to ensure the unrecognized passive shutdown was documented and addressed but he failed to do so.
When the October 21, 2003 passive reactor shutdown was documented in the Callaway Action Request System in 2007, Mr. Neterer had a duty to ensure it was thoroughly investigated but instead actively impeded the investigation.
While still a Callaway Plant employee in 2007 I brought my concerns regarding the October 21, 2003 passive reactor shutdown to the Operations department, the Performance Improvement department, the Quality Assurance department, the Employee Concerns Program manager (David Hollabaugh), the Plant Director (Fadi Diya who is now the Site Vice President), the Site Vice President (Adam Heflin who is now the Chief Nuclear Officer) and the corporate Nuclear Safety Review Board (headed by former NRC Regional Administrator Ellis Merschoff). None of these organizations saw to it that the October 21, 2003 passive reactor shutdown was investigated.
The culture at Ameren is inadequate for entrusting with the responsibility of operating a commercial nuclear reactor plant. The highest company officer on site at Callaway Plant (Dave Neterer, the Plant Director) was complacent in covering up a significant human performance incident in 2003 (the October 21, 2003 passive reactor shutdown) and he is still directly involved in keeping the incident from being properly addressed. The Chief Nuclear Officer (Adam Heflin) and the Site Vice President (Fadi Diya) are both aware of the incident and yet have failed to address it.
In 2005 Ameren operators overtopped the upper reservoir at Taum Sauk causing it to fail and nearly kill the Toops family. During that incident, Ameren operators were continuing to fill the upper reservoir from over 100 miles away despite knowing that the level indications for the reservoir were suspect. Ameren engineers and technicians who had brought the faulty level indications to their management were too fearful of losing their jobs to aggressively confront their management on the unsafe continued operation of the plant. The previous governor called the Taum Sauk upper reservoir failure the worst disaster ever to occur in Missouri. Having worked at Callaway Plant for over five years, I can attest to you that the same culture flaws which enabled the Taum Sauk disaster are rampant at Callaway Plant. And nothing has changed since I left in 2007 other than dishonest individuals have been promoted to even higher levels of responsibility.
Admiral Rickover once said: Any one detail, followed through to its source, will usually reveal the general state of readiness of the whole organization. Enclosed with this letter are two essays which I wrote in 2009 and emailed to some members of the Missouri legislature. One concerns Ameren’s failure to adequately retire its sulfuric acid systems and the other concerns Ameren’s failure to adequately staff its Fire Brigade at Callaway Plant. Although both issues occurred in the 2004 to 2006 time frame, the managers for this poor “general state of readiness” are for the most part still around today or have been promoted to even higher levels within the organization.
Please note, I am not divulging this information to you to dissuade you from promoting the expansion of nuclear power in Missouri. I firmly believe that a second reactor at Callaway Plant would be a great benefit to not only the taxpayers and merchants of Callaway County, but also to the economies of the surrounding counties, the treasury of the State of Missouri, and the national electric grid. Not only that, but expansion of nuclear power in Missouri is greatly beneficial to our nation’s economic and military security as it reduces our dependence on foreign energy sources and keeps US energy dollars in the hands of highly trained US workers. Nuclear power is something a responsible governor supports. However, nuclear SAFETY is also something a responsible governor supports.
Nuclear power plants can be operated safely, but as a former Senior Reactor Operator, who worked at Callaway Plant for nearly six years and who has spent a total of eleven years in various roles at four different nuclear utilities, I can assure you that it is ONLY because of federal government regulations that nuclear utilities maintain their reactors’ safety systems in an adequate state of readiness. Hydro has no similar government regulation and look what happened at Taum Sauk. Likewise, at Callaway Plant the sulfuric acid systems detailed in the attached essay debatably fell outside of the purview of the US NRC and look how they were maintained. And more recently, look what happened in the Gulf of Mexico on the barely regulated Deepwater Horizon oil platform. Without vigilant government regulation nuclear utilities would allow their safety systems to degrade to the point that we (the public) would be relying on LUCK to prevent accidents and not on engineered safety features.
Please keep in mind what “vigilant government regulation” entails. The “government regulation” part is easy. It’s already been there since the first commercial reactor plants came on line in the 1960s. It requires nothing of you. There are plenty of Washington bureaucrats taking care of it for you. It is the “vigilant” part which requires your attention, and that is why I am writing you this letter.
Currently the regulations ensuring nuclear safety at Callaway Plant are enforced by federal bureaucrats headquartered in Arlington, TX. Most of these bureaucrats have never worked for a nuclear utility, let alone actually operated a commercial nuclear reactor. And, to my knowledge, NONE of them have ever operated the reactor at Callaway Plant. Yet they are whom Missourians must rely upon to enforce federal regulations at Callaway Plant.
Luckily, however, the Texas bureaucrats are not our only guardians to ensure the profit driven officers of Ameren do not neglect nuclear safety in pursuit of their multi-million dollar annual bonuses. There are two other very important sources: Missouri union tradesmen and Missouri professional engineers. Every day conscientious workers at Callaway Plant come across latent flaws. These can be anything from errors in recently revised procedures to improperly installed equipment dating from the plant’s construction. And Ameren management is usually thankful that their workers find these errors. That is, as long as the problems that are found don’t jeopardize those million dollar bonuses. And that’s where you come in.
Ameren is a corporation. But corporations aren’t really anything other than mere pieces of paper. It is the people, that run and work for the corporation, who run power plants. And people are flawed. They like money. They hold grudges. They make errors. When confronted with decisions they sometimes choose poorly.
It is relatively easy at Callaway Plant to document a problem. It is often easy to find a solution to that problem. However, sometimes the solution is not easy. And when the solution is not easy, it is NEVER easy to stand up for nuclear safety and ensure the right course of action is taken. It is never easy for the common worker to risk his job for a mere nuclear safety concern. And that is what they are doing at Ameren – risking their job – if they stand in the way of those million dollar bonuses.
Some people will tell you that there are federal laws which protect these employees. I can tell you from personal experience that, although those laws on the surface might seem adequate, they are nearly impossible for the federal bureaucrats from Texas to implement in any meaningful way.
A nuclear utility, which is dumb enough to state in writing to a worker that he will be fired if he pursues a nuclear safety concern, will certainly be punished by the federal bureaucrats. But how often do utilities behave that recklessly? These utilities employ law firms (such as Pillsbury Winthrop Shaw Pittman – the law firm Ameren uses) to train their employees on how not to violate work place discrimination laws.
Retaliation at nuclear plants is much more subtle than blatantly threatening an employee, in writing, with loss of his job. And although retaliation against “problem” nuclear workers is likely not endorsed by the Ameren board of directors, it occurs nonetheless – because it is usually personal. Remember, corporations only exist on paper. It is PEOPLE who operate nuclear reactors. And, unfortunately, it is people who retaliate against “troublesome” subordinates. Retaliation against a worker usually occurs when the worker’s superiors have had to answer to THEIR superiors for problems at the plant which might jeopardize bonuses. Retaliation is personal. And it is done in a way that is easily defensible.
It is not difficult to retaliate in a manner in which the federal bureaucrats cannot (or refuse to) detect. All that is required is to place the troublesome employee on a “Performance Improvement Plan”. Once on the “Performance Improvement Plan” the employee either “gets the message” or is fired because he failed to improve. Although common citizen can see right through these tactics, federal bureaucrats have different standards than common citizens. Bureaucrats cannot use reason and rational thought. They can only follow the letter of the regulations. So as long as the utility’s trained retaliators did not violate a strict compliance of the regulations, the bureaucrats can do nothing but claim the retaliation complaint was “not substantiated”.
It has been reported on several occasions in the Missouri media that I was paid over half a million dollars by Ameren to resign from my job for attempting to get the October 21, 2003 passive reactor shutdown investigated. But what has not been reported is where that money came from. One hundred percent of that $550,000 payment was passed onto Ameren’s rate payers. The same can be said for the six-figure settlements paid to Jim Gloe, Clark Fuhlage and Julia Forbes in 2006. And the same can be said for the settlement paid to Gerry Bergeron in 2008, and for the multi-million dollar settlement paid to the Toops family.
Why is Ameren allowed to pass these settlements onto the rate payers? Think about it. These are NOT legal judgments which are ordered by a court to compensate for wrongdoing. In fact, in the contracts awarding these settlements Ameren specifically denies wrongdoing. These are merely business expenses – business expenses to AVOID going to court, but business expenses nonetheless. So the cost of Ameren’s retaliation against the workers brave enough to take a stand on nuclear safety is added to the rates paid by the rate payers instead of being withdrawn from the multi-million dollar bonuses paid to the executives.
What can you do about this? Plenty can be done. The State of Missouri should have laws protecting its professional engineers and reactor plant workers from retaliation. Citizen jurors from the local Missouri community (not federal bureaucrats from Texas) should evaluate if their peers have been retaliated against for looking out for public safety.
A worker protection law is needed in Missouri for two reasons: (1) the federal regulations against worker retaliation are nearly impossible for the bureaucrats at the Nuclear Regulatory Commission to use in any meaningful way due to the “level of evidence” which the NRC requires to prove a violation and (2) nuclear utilities, which typically gross over $1 million/day in electricity sales at each reactor plant, view five-figure NRC fines as nothing more than a cost of doing business. Our nuclear workers need to be protected by state laws which allow state juries to evaluate their claims and which award settlements which are great enough to be punitive to the utilities.
I am not a fan of trial lawyers. And I am certainly not a fan of multi-million dollar settlements being passed onto the rate payers. I recognize that there are those who oppose jury trials because the settlement amounts are often exorbitant and, in some way or another, those costs are passed onto society. But there are ways around this dilemma: limit the court awards paid to workers (and their attorneys) and minimize punitive awards to a range which will punish the utility but not inhibit the utility from financially being able to meet its stewardship responsibilities.
My suggestion would be to break the award into two distinct elements: just compensation to the worker and punitive punishment to the utility. The payment made to the worker and his lawyer (who typically receives 1/3 of the award) should be limited. A reasonable limit would be a minimum of one year’s salary and a maximum of 10 years’ salary and this award should be paid from the corporate profits. A limit of this type would place the award in the $100,000 to $1 million range. The punitive settlement, however, needs a much higher limit. My suggestion would be to have this component equal the total annual compensation paid to the top five utility executives. This would thereby ensure the punitive settlement is within a range that we know the utility could afford to pay from its net profits. This punitive settlement could be paid into the state coffers (such as into an emergency management fund to help defray the cost of man-made disasters like the collapse of the Taum Sauk upper reservoir) or rebated back to the state’s taxpayers.
Having a Missouri Law which protects our courageous nuclear workers from retaliation is necessary for ensuring the safety of Missouri’s current reactor plant and any possible future ones. Missourians cannot solely rely on federal bureaucrats, most of whom have never operated commercial reactor plants, to ensure Missouri’s current and future reactor plants are operated safely. Missourians must be able to also rely on their local nuclear workers – the workers trained and experienced on operating the nuclear reactor which powers the electric generating plant they work at. But these workers must be protected from retaliation. Electricity generation is big business with big profits to be had. Multi-million dollar bonuses have a way of swaying decisions in the direction of generation over safety, and sometimes, unfortunately, result in utility executives not valuing the conscientious workers who at times demand their money making plants unexpectedly shut down to correct safety problems. I urge you, the Governor who is supporting an expansion of nuclear power in Missouri, to tie a worker protection law to new plant construction. Ameren showed us at Taum Sauk the corrupting influence its million dollar bonuses have on good decision making. A nuclear “Taum Sauk” in Callaway County will not only kill nuclear power in Missouri – like Three Mile Island in 1979 it will kill nuclear plants across the nation.
If you have any questions regarding the information I have provided, please call me at 573-230-3959.
Lawrence S. Criscione, PE
Cc: Chairman Robert M. Clayton III, Missouri Public Service Commission
Lewis R. Mills, Jr., Missouri Public Counsel
Representative Darrell Pollock, District 146
Representative Jake Zimmerman, District 083
Representative Jeanette Mott Oxford, District 059
Representative Anne Zerr, District 018
Improper Retirement of Sulfuric Acid systems at Callaway Plant Leads to Contamination of Ground Water and Acid Leaking through Ceiling Tiles in the Control Room for Radioactive Waste Processing
Despite repeated problems with abandoned acid systems, management at Ameren’s Callaway Nuclear Plant failed to commit resources to properly retire the systems until leaks occurred which either jeopardized the safety of plant workers or resulted in uncontrolled release of acid into the ground water.
According to an internal Callaway Plant Action Request (CAR), on September 24, 2001 approximately 200 gallons of sulfuric acid spilled near the cooling tower when an acid storage and delivery system failed. As a result of the September 2001 incident, in 2002 a new system was installed to deliver acid to the Cooling Tower. To save money, the original acid system was abandoned in place with residual acid remaining in the tanks and piping. Within a year, the piping corroded to the point that, on June 26, 2003 an Equipment Operator refused to perform work in the area of the old acid piping. To appease the concerns of the operators, Job C713235 was created for a “Vendor to neutralize the acid tanks of the abondon [sic] acid system at the Circ & Service Bldg.” It would take another 40 months of recurring problems with the abandoned acid piping before Job C713235 was performed.
In the picture at right, the salt complex to the left of the piping tee used to be a piece of piping; it corroded due to residual sulfuric acid left in it. This piping is part of the same system which, on July 31, 2004 developed a piping breach that caused a 30 gallon acid spill. Again plant operators reported the need to flush the residual acid from the system, but Ameren management refused to commit the necessary resources to the task.
Much of the piping, which was abandoned in place with acid still in the lines, is buried
(i.e. underground) pipe. In September 2004, during hard rains pH 1 acid was discovered leaching into the basement of the building which houses the cooling tower support equipment. Water with an acidity of pH 1 is one million times as acidic as neutral water. As rain water made its way through the ground around the Circ and Service building, it became one million times more acidic due to the sulfuric acid present in the soil around the building. Ameren management was informed of this problem in a Callaway Action Request but again failed to take action to properly flush the abandoned acid piping.
The picture at right was attached to the Callaway Action Request which was written concerning the acid leaching into the basement of the Circ and Service building. The sign in the foreground reads “Acid from ground leaks through piping penetrations with hard rains.” The location of the acid leaching can be seen on the wall in the background where the elbowed piping enters the wall. This picture is from the lower level of the Circ and Service building and there is abandoned underground acid piping in the earth on the other side of the wall. Highly acidic ground water leaking in from the earth caused the damage to the concrete which is visible below the piping elbow. The residual acid in this piping was never neutralized or flushed out when the system was abandoned.
On May 20, 2006 another acid leak developed in the abandoned piping. The leak was documented in yet another Callaway Action Request which noted “A spool piece … has been corroded away and acid is leaking out onto the floor. This is residual acid that has been in the system for years.” The Screening Committee, which reviews all Callaway Action Requests for proper assignment and resolution, did not forward this CAR onto an engineer for evaluation; instead it closed the CAR during screening to “The screening committee has reviewed this CAR and concluded that a Job is adequate to correct the adverse condition. No additional actions are needed.” On August 8, 2006 a job was worked that merely removed the leaking valve and replaced it with a blank flange; again, no effort was made to flush the residual acid from the retired piping.
By July 2006 the chemistry technicians at Callaway Plant were fed up with working around sulfuric acid contamination. On July 20, 2006 a Chemistry staffer wrote Callaway Action Request 200605860, entitled “Retired Acid System at Circ/Service presents a concern w/ Acid Leaks”. In this report it was noted the retired system contained enough old acid that it “presents a safety concern to Chemistry personnel and others in the building” and “will continue to manifest as acid leaks within deteriorating components”. On October 25, 2006 this corrective action document was closed with the residual acid still remaining in the system. In the closure statement it was stated that “job C713235 has been issued to flush the system.” Job C713235 was the job originated 38 months earlier in response to the concerns of the Equipment Operator who had refused to work in the area of the old acid piping. On October 25, 2006 Job C713235 was still not even planned when it was used to close out the concerns of the chemistry technicians.
On November 7, 2006 a leak developed at the bottom of the retired Acid Day Tank at the Circ and Service building. Because of the location of this leak, it could not be isolated. The operators would either have to allow the contents of the tank to slowly drip out and be absorbed into the ground, or they would have to patch the hole at the bottom of the tank, from which highly concentrated sulfuric acid was actively leaking.
The Field Supervisor documented the November 7, 2006 leak in a Callaway Action Request. The next morning, the CAR Screening Committee attempted to close the Field Supervisor’s CAR to Job C713235 – the job to neutralize the acid tank which, although now over 38 months old, was still not planned.
The Shift Technical Advisor, who was assigned to the Control Room on November 7, 2006 when the operators discovered the unisolable acid leak, attended the CAR Screening Committee meeting on November 8, 2006 and got into an argument with the members of the Screening Committee who wanted to close the Field Supervisor’s CAR (documenting the unisolable leak on the old acid tank) without taking any positive action to ensure Job C713235 would actually be worked.
Following the CAR Screening Committee meeting, the Shift Technical Advisor documented the five year history of leaks on the old acid system in Callaway Action Request 200609296, “Closing CARS Prior to Completion of Work Causes Recurring Acid Leaks”. This document was written with the hope that by writing a “big picture” overview of the problems experienced over the past several years, the management at Callaway Plant would recognize that they not only had a problem with their retired acid systems, but that their Corrective Action Process was also deeply flawed – flawed in that the Callaway Action Requests written to address acid leaks were being closed to a job which was neither scheduled nor even planned.
As a result of CAR 200609296 a team was assembled to address the issue of the abandoned acid systems and in December 2006 the residual acid was flushed from the leaking tank outside the Circ and Service building. However, no attempt has yet been made to clean up the acid contamination in the earth around the Circ and Service building.
The leaking acid tank at the Circ and Service building was brought to the attention of the US Nuclear Regulatory Commission Resident Inspectors at Callaway Plant in mid-November 2006. The Resident Inspectors refused to investigate the issue because the acid system at the Cooling Tower is not a “safety related” system (i.e. equipment required to prevent or mitigate a reactor accident). The Resident Inspectors did not notify OSHA or the EPA for an assessment of whether industrial safety or environmental laws were being violated at Callaway Plant because of the leaking acid tank.
During the same time period in which chronic problems were resulting due to the improperly abandoned acid system at the Cooling Tower, a similar acid system in the Radwaste Building was causing its own problems. Ninety-three percent Sulfuric Acid had been left in the Radiological Waste Acid Addition tank (pictured at right) when it was retired in place and by October 2004 the acid had eaten its way through the wall of the tank. The bulging areas in the picture of the tank are where the acid has eaten its way through the structural steel of the tank and is travelling down the wall of the tank beneath the paint layer.
The Radwaste Building is where the equipment is housed for the processing of gaseous, liquid and solid radioactive wastes. Callaway Plant was designed to be a “zero discharge” plant, meaning all radioactive liquid waste would be processed on-site (vice being discharged to the Missouri River) and the solid waste derived from the liquid waste would be shipped out of state for disposal. In order to cut costs, Ameren curtailed the labor-intensive processing of liquid radioactive wastes in the 1980’s and instead discharges several hundred gallons a day of radioactive reactor coolant into the Missouri River. Much of the old liquid radioactive waste processing equipment has been allowed to fall into disrepair, including the sulfuric acid tank above the Radwaste Control Room.
Several years after being abandoned in place, the concentrated acid left in the Radiological Waste Acid Addition tank ate a hole in the wall of the tank and leaked onto the bermed area at the base of the tank. Despite noticing the leak in October 2004, no action was taken to resolve the problem and by June 22, 2005 the acid had eaten its way through piping penetrations in the floor below the tank and was causing a sulfur smell in the area below.
On June 25, 2005 the Reactor Operators were notified that an acid leak was occurring in the Radwaste Control Room – the controlling station for the equipment which processes gaseous, liquid and solid radioactive wastes. The description of the incident documented in CAR 200504427 reads like it could have been taken from a scene at Mr. Burn’s nuclear power plant on the Simpsons:
Upon arriving at the scene the Field Supervisor found the acid leak was still active, but was being contained in a stainless steel bucket that the Radwaste operator had placed to catch the leakage. Acid had eaten a hole through the ceiling tile and was slowly dripping through. The estimated leak amount was one tablespoon visible on the carpet (more may have soaked into the carpet). There was also a small amount pooled on top of the ceiling tile. The Rad waste operator stated that an unidentified odor had been noted the previous day, but the cause could not be found. Apparently the acid had been leaking onto the ceiling tile and finally had eaten through.
The source of the acid was from the berm around tank THC10. The tank has significant corrosion and appears to have an active leak in its side. Seepage could be seen through the corrosion, but no active dripping was noted. The quantity of acid in the berm is estimated at 2 gallons. The leakage from the berm is occurring at a floor penetration for instrument tubing at the north end. The acid is seeping through the penetration and running down the tubing until it drips off onto the ceiling tile below. No open Job could be found in EMPRV for the acid leak. The sign on the caution tape around the acid berm indicates the leak has been occurring since 10-28-04.
The picture at right is of the control air lines for equipment used in the processing of solid radiological waste. The acid leaking from the Radiological Waste Acid Addition tank entered the ceiling through the penetration for these lines. Although damaged, these lines were not breached. The picture was taken in February 2007; twenty months after the acid leak, the acid had still not been cleaned from these lines.
The history of recurring acid problems in the Radwaste Building was documented in Callaway Action Request 200609328. As with the acid problems at the Circ and Service building, the Resident Inspectors of the US NRC refused to look into the problems in the Radwaste building because none of the equipment in that building is “safety related”. Although failure of equipment used in the processing of radioactive waste could result in a spill of radioactive material, the US NRC is only concerned with equipment required to mitigate nuclear accidents.
In August 2007, a Shift Engineer at Callaway Plant wrote a letter to US Senator Durbin
discussing, among other topics, the failure of the US NRC to address Ameren’s practice
of deferring the retirement of acid systems for financial reasons. In the letter, it was pointed out:
It should be noted that similar acid systems exist at Ameren fossil plants. If Ameren does not properly retire equipment at the Callaway Nuclear Plant (arguably the “jewel” in its regulated Missouri market), it is likely neglecting similar equipment at its de-regulated Illinois fossil plants.
It is not known what action Senator Durbin’s office has taken with regard to this issue.
Staffing Concerns at Callaway Plant
On September 18, 2004 there was a small fire on the roof of the Communications Corridor at the Callaway Nuclear Plant, adjacent to the building which houses the reactor plant Control Room. The fire was extinguished by the Fire Brigade but then “re-flashed” over an hour later, requiring the Fire Brigade to be activated a second time to put out the fire.
An Event Review Team meeting was held on September 20, 2004 to analyze the Fire Brigade’s response to the roof fire. At that meeting the Equipment Operators expressed concerns that the Fire Brigade was not adequately staffed. Their specific concern was with crediting the Outside Equipment Operator watch station as a Fire Brigade responder, as expressed by one of the Equipment Operators:
Before this fire I had no idea how limited our resources are. We got four people.
This was a really tiny fire and we used up all kinds of [oxygen] bottles and air
packs. Man, if we have any kind of fire out here at all we’re going to need help.
And I knew that before but it really drove the point home yesterday…
Although the summary for the September 20, 2004 Event Review Team meeting thoroughly documented several process and equipment concerns, the concerns of the Equipment Operators, regarding the assignment of the Outside Equipment Operator watch station to the Fire Brigade, were not captured.
When the Callaway Nuclear Plant was licensed by the US Nuclear Regulatory Commission, Ameren committed to staffing the Fire Brigade such that “at least five members shall be maintained onsite at all times.” For twenty years, the company staffed the operating crews with watch standers who might not be “onsite” in the event of a fire.
On November 15, 2004 the Equipment Operators who fought the September 2004 roof fire expressed their concerns, to a Fire Brigade Leader, that the company was inadequately staffing the Fire Brigade and had intentionally omitted their concerns from the September 20th Event Review Team summary. The Fire Brigade Leader documented their concerns in the Callaway Action Request system as an Adverse Condition. Ignoring a request by the Fire Brigade Leader that he be assigned the task of resolving the Adverse Condition, the Assistant Operation Manager downgraded the concerns to a Business Tracking item and dismissed them with an argument that:
The Intake and other outlying buildings are part of Callaway. The FS [Field
Supervisor who also serves as the Fire Brigade Leader] and Outside EO can be at
any of these locations…
Although the Intake structure is technically “onsite” since it is Ameren property, it was not the original intent of the US NRC to allow the Fire Brigade Leader to be 20 minutes away from the reactor plant. Also, applying Ameren’s own literal interpretation of its licensing requirements, since the Outside Equipment Operator is travelling on a county road to go between the Intake structure and the main plant, he is not “onsite” during this time period and the company is not meeting its commitment to have five Fire Brigade members “maintained onsite at all times.”
The Callaway Nuclear Plant is sited on a plateau, about five miles from the Missouri River, where the town of Reform, MO used to be located. Its cooling tower is supplied with water pumped from an Intake structure which is over 7½ miles from the plant, most of which is along a county gravel road. The image at right was captured from “Google Earth”. The red dot east of balloon “B” is the approximate location of the fire brigade locker. The red dot south of balloon “A” is the location of the Intake structure on the Missouri River. The Outside Equipment Operator spends the majority of his 12-hour watch “outside” the security fence which surrounds the main area of the plant, and during his watch he makes at least one trip to the Intake structure which is more than a 20 minute drive from the main plant.
On March 29, 2005 the US Nuclear Regulatory Commission’s Resident Inspector at the Callaway Nuclear Plant timed an Ameren employee to determine how long it actually took to get from the Intake structure to the Fire Brigade locker. The trip was made in 21 minutes.
Even after receiving scrutiny from the Resident Inspector, Ameren continued to flaunt their licensing basis for another month. After being issued a finding in the US NRC’s first quarter 2005 inspection report for not properly staffing the Fire Brigade, on April 28, 2005 the Operations Manager at the Callaway Nuclear Plant ordered the operating crews to:
maintain four (4) Fire Brigade qualified Equipment Operators on each shift
excluding the Primary EO and Outside EO.
At the time of the policy change to no longer credit the Outside Equipment Operator as a Fire Brigade member, half of the operating crews did not have enough Equipment Operators to meet the Fire Brigade commitments without overtime support from Equipment Operators on other crews. Thirty months later, when the understaffing issue was brought to the attention of Senator Claire McCaskill, the Equipment Operator manning had only gotten worse with a total shortfall of nine Equipment Operators. Ameren’s explanation to Senator McCaskill’s staff was that since it is allowed to use overtime to cover the required short fall of Equipment Operators, no staffing increases are required.
Since 2007 the Fire Brigade and Main Control Room staffing levels at Callaway Plant have continued to degrade. In 2004 there were three licensed Senior Reactor Operators per crew. One SRO was the Shift Manager, one was the Control Room Supervisor and one was the Field Supervisor who also served as the Fire Brigade Leader. Currently at Callaway Plant, only two of the six operating crews have three Senior Reactor Operators. Although only two Senior Reactor Operators are required, it is standard practice at most single unit nuclear plants to have three SRO’s on each shift.
Other staffing concerns exist at Callaway Plant. Since the Three Mile Island nuclear accident, the US NRC has required a degreed engineer to be present at all times to support the Control Room as the Shift Technical Advisor. The Shift Technical Advisor’s role is to back up the decisions of the Control Room Supervisor and Shift Manager during a reactor accident. Currently at Callaway Plant, during the backshifts, the Shift Technical Advisor role is fulfilled by requiring that either the Shift Manager or Control Room Supervisor possess a Shift Technical Advisor qualification (have an engineering degree plus some additional training). Apparently, by possessing a Shift Technical Advisor qualification, these individuals are able to advise themselves and do not require the additional input of a third person. Although, amazingly, this practice is allowed by the US NRC, at most nuclear plants the Shift Technical Advisor is a separate (i.e. third) person from the two people he is advising.
Saving money by short staffing can have dangerous consequences. On December 13, 2005 Ameren overtopped the Taum Sauk upper reservoir in Reynolds County Missouri, flooding Johnson Shut-ins State Park and nearly killing the superintendent, his wife and three young children when their house was destroyed by a wall of water. Assigning a $10/hour night watchman to watch the filling evolution from the top of the upper reservoir could have prevented the entire accident. Instead, Ameren relied on instrumentation, which was known to be damaged but not repaired, to ensure the upper reservoir was never overtopped while filling it.
Since he had been told that his family would receive 12 minutes notice if there was ever a reservoir break, the Johnson Shut-ins superintendent was surprised to learn that there was never anyone assigned to watch the reservoir during filling evolution and that the whole process was controlled remotely, 100 miles away, from Bagnell Dam. After his home was destroyed by the rush of water, the superintendent’s five-year-old son was found unconscious and not breathing, but was able to be revived by the emergency responders. Had the incident occurred on a typical early morning in July, vice December, it is likely that hundreds of campers would have died as the wall of water ripped through the very popular Johnson Shut-ins campground on its way to the lower reservoir.
The Callaway Nuclear Plant generates more than $50,000 worth of electricity every hour; Ameren can afford to properly staff its reactor plant Control Room as well as other facilities it operates.