05000461/LER-2010-004, For Clinton Power Station, Unit 1, Regarding OPDRV Requirements Not Met During Control Rod Drive Mechanism Replacements
| ML110330197 | |
| Person / Time | |
|---|---|
| Site: | Clinton  (NPF-062) |
| Issue date: | 01/25/2011 |
| From: | Kearney F Exelon Nuclear |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| SRRS 5A.108, U-603998 LER 10-004-00 | |
| Download: ML110330197 (6) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(v), Loss of Safety Function |
| 4612010004R00 - NRC Website | |
text
Exelon.
Nuclear Clinton Power Station 8401 Power Road Clinton, IL 61727 U-603998 SRRS 5A.108 January 25, 2011 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461
Subject:
Licensee Event Report 2010-004-00 Enclosed is Licensee Event Report (LER) No. 2010-004-00: Operations with the Potential for Draining the Reactor Vessel (OPDRV) Requirements Not Met During Control Rod Drive Mechanism Replacements. This report is being submitted in accordance with 10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by the Technical Specifications.
This letter contains one regulatory commitment as identified in Attachment 1.
Should you have any questions concerning this report, please contact Mr. T. D. Chalmers at (217) 937-2200.
Respectfully, F.. Kearn/y' Site Vice President Clinton Power Station RSF/blf
Enclosures:
Licensee Event Report 2010-004-00 Attachment cc:
Regional Administrator - NRC Region III NRC Senior Resident Inspector - Clinton Power Station Office of Nuclear Facility Safety - IEMA Division of Nuclear Safety S12AL SUMMARY OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)
COMMITTED COMMITMENT TYPE
COMMITMENT
DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)
(Yes/No)J 10 CFR 50.59 evaluation CL-2010-E-001 that reviewed procedure CPS 3711.01 will March 31, 2011 YES NO be revised to show that NRC review and approval is required for implementing the procedure.
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2013 (10-2010)
, the NRC may e for each block) not conduct or sponsor, and a person is not required to respond to, the digits/characters finformation collection.
- 3. PAGE Clinton Power Station, Unit 1 05000461 1 OF 4
- 4. TITLE OPDRV Requirements Not Met During Control Rod Drive Mechanism Replacements
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED FACILITY NAME DOCKET NUMBER MONTH DAY YEAR YEAR SEQUENTIAL REV MONTH DAY YEAR 05000 j
NUMBER NO
__l FACILITY NAME DOCKET NUMBER 01 17 2010 2010
- - 004 -
00 01 25 2011 05000
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)
El 20.2201(b)
El 20.2203(a)(3)(i)
El 50.73(a)(2)(i)(C)
El 50.73(a)(2)(vii)
E[ 20.2201(d)
El 20.2203(a)(3)(ii) 0l 50.73(a)(2)(ii)(A)
El 50.73(a)(2)(viii)(A)
[I 20.2203(a)(1)
El 20.2203(a)(4)
El 50.73(a)(2)(ii)(B)
El 50.73(a)(2)(viii)(B)
El 20.2203(a)(2)(i)
El 50.36(c)(1)(i)(A)
El 50.73(a)(2)(iii)
El 50.73(a)(2)(ix)(A)
- 10. POWER LEVEL El 20.2203(a)(2)(ii)
El 50.36(c)(1)(ii)(A)
El 50.73(a)(2)(iv)(A) 17 50.73(a)(2)(x)
[I 20.2203(a)(2)(iii)
E3 50.36(c)(2)
El 50.73(a)(2)(v)(A)
El 73.71 (a)(4) 000 [1 20.2203(a)(2)(iv)
El 50.46(a)(3)(ii)
El 50.73(a)(2)(v)(B)
El 73.71 (a)(5)
El 20.2203(a)(2)(v)
El 50.73(a)(2)(i)(A)
El 50.73(a)(2)(v)(C)
El OTHER [I 20.2203(a)(2)(vi) 0 50.73(a)(2)(i)(B)
El 50.73(a)(2)(v)(D)
Specify in Abstract below or in The following TS and actions applicable during OPDRVs were not met as the CRDM replacement work was not immediately suspended as required by the actions in the limiting conditions for operations (LCOs).
LCO 3.3.6.1 states that the primary containment and drywell isolation instrumentation for each Function in Table 3.3.6.1-1 shall be OPERABLE. With required instrumentation channels not operable, the Required Action is to isolate the affected penetration or initiate action to suspend OPDRVs immediately. This LCO was not met for the leak detection function with both divisions of Reactor Water Cleanup [CE] isolation bypassed.
LCO 3.6.1.2 states that each primary containment air lock [AL] shall be OPERABLE. With any primary containment air lock inoperable during movement of recently irradiated fuel assemblies in the primary or secondary containment, or during OPDRVs, the Required Action is to initiate action to suspend OPDRVs immediately. This LCO was not met with the upper containment airlock not operable.
LCO 3.6.4.1 states that the secondary containment shall be OPERABLE. With secondary containment inoperable during OPDRVs, the Required Action is to initiate action to suspend OPDRVs immediately. This LCO was not met with the railway inner door [DR] not in an operable condition.
Since LCO 3.3.6.1 and LCO 3.6.1.2 were not met, the requirements of LCO 3.0.4 were also not met. LCO 3.0.4 requires the LCO (namely LCO 3.3.6.1 and LCO 3.6.1.2) to be met prior to entry into the MODE or other specified condition (namely the OPDRV activity).
Other activities that used Procedure CPS 3711.01 during refueling outage C1 R12 were draining of the Reactor Recirculation [AD] piping loops and Reactor Water Cleanup [CE] piping replacement. Both of these activities were evaluated as not being OPDRV, and this evaluation was consistent with previous plant decisions prior to the existence of Procedure 3711.01.
C. CAUSE OF EVENT
The cause for this event was the 10 CFR 50.59 evaluation concluded that the change did not require prior NRC approval. The station did not use conservative decision-making before proceeding with implementation of the OPDRV procedure.
D. SAFETY CONSEQUENCES
This event is reportable under the provisions of 10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by the station TSs as certain TSs were not met as discussed in the Description of Event Section of this report. During the less than 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of CRDM replacement activities from 1929 hours0.0223 days <br />0.536 hours <br />0.00319 weeks <br />7.339845e-4 months <br /> on 1/17/10 to 0511 hours0.00591 days <br />0.142 hours <br />8.449074e-4 weeks <br />1.944355e-4 months <br /> on 1/18/10, the reactor cavity was flooded with at least 22 feet 8 inches of water above the Reactor Pressure Vessel [RPV]
flange and two trains (B and C) of Residual Heat Removal [BO], and the Low Pressure Core Spray [BM]
systems were available to maintain water level in the event a CRDM opening was not secured. Therefore, this event had minimal safety significance.
E. CORRECTIVE ACTIONS
Station procedure CPS 3711.01, as well as Exelon Standard Procedure OP-AB-1 17-101, "Operations with the Potential to Drain the Reactor Vessel (OPDRV)," were suspended from use on 7/13/10 and 12/27/10, respectively.
10 CFR 50.59 evaluation CL-201 0-E-001 that reviewed procedure CPS 3711.01 will be revised to show that NRC review and approval is required for implementing the procedure.
The details of this event will be presented during 10 CFR 50.59 requalification classes and to applicable personnel who do not have 10 CFR 50.59 qualifications.
F.
PREVIOUS OCCURRENCES
None
G. COMPONENT FAILURE DATA
None