05000483/FIN-2006005-04
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Finding | |
|---|---|
| Title | Failure to Obtain Prior NRC Approval Before Removing a Technical Specification Limiting Condition for Operations |
| Description | On October 6, 2006, the inspectors identified a noncited (Severity Level IV) violation of 10 CFR 50.59 after AmerenUE failed to obtain prior NRC approval before removing the steam generator blowdown valve Limiting Condition for Operations requirement from the facility Technical Specifications. Section 50.36 of Title 10 of the Code of Federal Regulations, Technical Specifications, required AmerenUE to establish a limiting condition for operations for components that are required to mitigate a design basis accident. The Callaway Plant accident analysis required the steam generator blowdown valves to close to mitigate the steam line break accident and to ensure the auxiliary feedwater system safety function. AmerenUE met this requirement by including the blowdown valves in Technical Specification 3.6.3, Containment Isolation Valves, as referenced in Final Safety Analysis Report Table 16.6-1, Containment Isolation Valves. On May 10, 2006, AmerenUE implemented Final Safety Analysis Report Change Notice 02-012, which removed the blowdown valves from Table 16.6-1. This change removed the blowdown valves from within the scope of the Technical Specifications limiting condition for operations. The Section 50.59 safety evaluation supporting Change Notice 02-012 failed to identify that removal of the blowdown valves involved a change to the plant Technical Specifications and required prior NRC approval. This issue involved traditional enforcement because AmerenUE did not receive prior NRC approval before changing the facility Technical Specifications. The inspectors evaluated this issue using Manual Chapter 0612, Appendix B. This issue is more than minor because the mitigating systems cornerstone attribute of equipment performance, reliability, and capability is impacted based on removal of the blowdown valve out-ofservice time limits from the Technical Specifications. The inspectors used Manual Chapter 0609, Significance Determination Process, Phase 1, to analyze the safety significance of the violation. The inspectors concluded that the violation is of very low safety significance because the issue was not a design or qualification deficiency confirmed to result in loss of operability, did not represent a loss of system safety function or an actual loss of safety function of one or more non-Technical Specification risk-significant equipment trains, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The issue has a problem identification and resolution crosscutting aspect associated with the corrective action program because the licensee's safety evaluation did not thoroughly evaluate the change such that the resolutions address causes and extent of conditions, as necessary. The licensee entered this issue into the Corrective Action Program as Callaway Action Request 200608902 |
| Site: | Callaway  |
|---|---|
| Report | IR 05000483/2006005 Section 1R17 |
| Date counted | Dec 31, 2006 (2006Q4) |
| Type: | NCV: Green |
| cornerstone | Initiating Events |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.17 |
| Inspectors (proximate) | R Lantz D Dumbacher M Peck D Stearns M Runyan |
| CCA | P.2, Evaluation |
| INPO aspect | PI.2 |
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Finding - Callaway - IR 05000483/2006005 | |||||||||
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Finding List (Callaway) @ 2006Q4
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