05000483/LER-2003-001, Re Improper Administrative Controls Result in Technical Specification Violation
| ML030770584 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/10/2003 |
| From: | Witt W AmerenUE |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| ULNRC-04815 LER 03-001-00 | |
| Download: ML030770584 (6) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 4832003001R00 - NRC Website | |
text
AmerenUE Callaway Plant PO Box 620 Fulton, MlO 65251 March 10, 2003 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 WAmeren UE ULNRC-048 15 Ladies and Gentlemen:
DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.
FACILITY OPERATING LICENSE NPF-30 LICENSEE EVENT REPORT 2003-001-00 Improper Administrative Controls Result in Technical Specification Violation The enclosed licensee event report is submitted in accordance with I OCFR50.73(a)(2)(i)(B) to report a condition which was prohibited by the plant's Technical Specifications.
Very truly yours, fax 6
U Warren A. Witt Manager, Callaway Plant WAW/slk Enclosure a subsidiary of Ameren Corporation
ULNRC-04815 March 10, 2003 Page 2 cc:
Mr. Ellis W. Merschoff Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Jack N. Donohew (2 copies)
Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 7E1 Washington, DC 20555-2738 Manager, Electric Department Missouri Public Service Commission PO Box 360 Jefferson City, MO 65102 Records Center Institute of Nuclear Power Operations 700 Galleria Parkway Atlanta, GA 30339
A
Abstract
On 01/07/03, with the Plant in Mode 1 at 100 percent Reactor Power, valve EGHV0061 (Component Cooling Water from Reactor Coolant Pump Thermal Barrier Outer Containment Isolation Valve) failed to stroke fully closed, during Containment Isolation Valve Inservice Testing. EGHV0061 was declared inoperable at 2012 and Technical Specification (TIS) 3.6.3.A.1 was entered. At 2020, EGHV0133 (the bypass valve for EGHV0061) was opened and then EGHV0061 valve was fully closed with power removed from the valve in order to satisfy TIS 3.6.3 A.1 for the EGHV0061 penetration flow path. The T/S required position for valve EGHV0133 is closed with power removed, except when opened under administrative controls. Later it was determined that EGHV0133 and EGHV0062 (the inner containment isolation valve) were both powered from Bus NG02B. This discovery revealed that the administrative controls were inadequate. This was a condition prohibited by the Plant's TIS. This condition existed until 01/10/03 when EGHV0061 was returned to service. The root cause of the event was a failure to recognize the common power source for both valves. Corrective actions included revising the test procedure to establish the requirement for local operation of these valves when administrative controls are required.
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- - rn woo S-.u (If more space is required, use additional copies of SUMMARY OF THE EVENT, INCLUDING DATES AND APPROXIMATE TIMES On 01/07/03, with Callaway Plant in Mode 1 at 100 percent power, the Operations Department was performing a Component Cooling Water (CCW) Train "A" Containment Isolation Valve Test. During the performance of the test, valve EGHV0061 (Component Cooling Water from Reactor Coolant Pump Thermal Barrier Outer Containment Isolation Valve) failed to stroke to the fully closed position. EGHV0061 was stroked a second time with the same result. EGHV0061 was declared inoperable at 20:12 and Technical Specification (T/S) 3.6.3.A 1 was entered. T/S 3.6 3 A 1 requires the isolation of the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured. The Bases Section includes the statement " The method of isolation must include the use of at least one leak rate isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, a closed manual valve (this includes power operated valves with the power removed), a blind flange, and a check valve with flow through the valve secured. (A remote manual valve's Main Control Board power isolate switch may be used to de-activate the valve.)". At 20.20, EGHV0061 was fully closed and power was removed from the valve to satisfy T/S 3 6.3 A.1.
The return flowpath from the Reactor Coolant Pump Thermal Barrier was established through EGHV0062 (the inner Containment Isolation Valve) and EGHV0133 (the bypass valve for EGHV0061) with administrative controls, which consisted of a dedicated Control Room Operator. This action was performed to satisfy T/S 3.6.3.A.1 for this flowpath. Later it was determined that EGHV0133 and EGHV0062 were both powered from Bus NG02B. This discovery revealed that the administrative controls were inadequate.
This was a condition prohibited by the Plant's T/S.
The root cause of the event was a failure to recognize the common power source for both valves.
(If more space is required, use additional copies of NRC Forn 366A) (17)
E. METHOD OF DISCOVERY OF EACH COMPONENT, SYSTEM FAILURE, OR PROCEDURAL ERROR The failure of EGHV0061 was discovered during scheduled testing.
The NRC Senior Resident Inspector noted that EGHV0133 and EGHV0062 have a common power source II.
EVENT DRIVEN INFORMATION A. SAFETY SYSTEMS THAT RESPONDED Not applicable for this event.
B. DURATION OF SAFETY SYSTEM INOPERABILITY
The total out of service time was 71 hours8.217593e-4 days <br />0.0197 hours <br />1.173942e-4 weeks <br />2.70155e-5 months <br /> and 58 minutes from January 7, 2003 at 20:12, until January 10, 2003 at 20:10.
C. SAFETY CONSEQUENCES AND IMPLICATIONS OF THE EVENT.
A probabilistic risk assessment was conducted to evaluate the failure of EGHV0061, and the subsequent reliance on valves EGHV0062 and EGHV0133 for containment isolation. The risk assessment took into account that both of the aforementioned valves are powered from the same safety-related bus (NG02B) and the assessment assumed that operator action to close a valve was necessary for containment isolation. The risk assessment is considered to be a reasonable estimate of the impact on large early release. The assessment determined that this event was not risk significant with respect to the health and safety of the public.
III.
CAUSE OF THE EVENT
The root cause of the event was a failure to recognize the common power source for both valves IV.
CORRECTIVE ACTIONS
The test procedure was revised to establish a dedicated local operator in communication with the Control Room as the required administrative control when EGHV01 33 is open. This administrative control meets the requirement of T/S 3 6.3 Note 1 with consideration for the common power source to EGHV0062 and EGHV0133.
V.
PREVIOUS SIMILAR EVENTS
A review of Callaway's Corrective action Program and LERs for the last three years identified one LER.
LER 2000-004-00 documented the inoperability of a containment isolation valve. The cause was a design error (If more space is required, use additional copies of NRC Form 366A) (17) during a modification that was performed to resolve NRC Information Notice 92-18 concerns.
VI.
ADDITIONAL INFORMATION
The system and component codes listed below are from the IEEE Standard 805-1984 and IEEE Standard 803A-1984 respectively.
System: CC Component: ISV I-l.
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