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Category:Letter type:ULNRC
MONTHYEARULNRC-06891, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00052024-06-26026 June 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0005 ULNRC-06892, Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC00062024-06-26026 June 2024 Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC0006 ULNRC-06884, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00022024-06-12012 June 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0002 ULNRC-06885, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00032024-06-12012 June 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0003 ULNRC-06886, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00042024-06-12012 June 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0004 ULNRC-06882, Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC00122024-05-16016 May 2024 Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC0012 ULNRC-06877, Final Safety Analysis Report Revision OL-27 and Technical Specification Bases Revision 252024-05-0606 May 2024 Final Safety Analysis Report Revision OL-27 and Technical Specification Bases Revision 25 ULNRC-06856, CFR 50.59 and 10 CFR 72.48 Summary Report2024-05-0101 May 2024 CFR 50.59 and 10 CFR 72.48 Summary Report ULNRC-06869, Submittal of Callaway, Unit 1, 2023 Annual Radiological Environmental Operating Report2024-04-30030 April 2024 Submittal of Callaway, Unit 1, 2023 Annual Radiological Environmental Operating Report ULNRC-06876, Registration of Dry Spent Fuel Storage Canister HGMPC00102024-04-25025 April 2024 Registration of Dry Spent Fuel Storage Canister HGMPC0010 ULNRC-06866, Submittal of Cycle 26 Commitment Change Summary Report2024-04-17017 April 2024 Submittal of Cycle 26 Commitment Change Summary Report ULNRC-06871, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00072024-04-17017 April 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0007 ULNRC-06872, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00082024-04-17017 April 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0008 ULNRC-06863, Submittal of Annual Exposure Report for 20232024-03-20020 March 2024 Submittal of Annual Exposure Report for 2023 ULNRC-06852, Owners Activity Reports (OAR-1 Forms) for Cycle/Refuel 262024-03-0505 March 2024 Owners Activity Reports (OAR-1 Forms) for Cycle/Refuel 26 ULNRC-06858, Completion of License Renewal Activities Prior to Entering the Period of Extended Operation2024-02-21021 February 2024 Completion of License Renewal Activities Prior to Entering the Period of Extended Operation ULNRC-06853, Submittal of 2023 Fitness for Duty Performance Data Per Per 10 CFR 26.7172024-01-29029 January 2024 Submittal of 2023 Fitness for Duty Performance Data Per Per 10 CFR 26.717 ULNRC-06847, Supplement to Relief Request from Requirements of ASME BPV Code, Section XI, Subsection Iwl Regarding Examination and Testing of the Unbonded Post-Tensioning System (Relief Request C3R-01)2023-12-21021 December 2023 Supplement to Relief Request from Requirements of ASME BPV Code, Section XI, Subsection Iwl Regarding Examination and Testing of the Unbonded Post-Tensioning System (Relief Request C3R-01) ULNRC-06849, License Renewal Resolution for Commitments 34 and 35 Perform Evaluation of Crack Initiation and Propagation in Steam Generator Divider Plate and Tube-To-Tubesheet Welds2023-12-20020 December 2023 License Renewal Resolution for Commitments 34 and 35 Perform Evaluation of Crack Initiation and Propagation in Steam Generator Divider Plate and Tube-To-Tubesheet Welds ULNRC-06844, Request for Exemption from Specific Requirements in 2023 Security Rule, Enhanced Weapons, Firearms Background Checks, and Security Event Notification2023-12-0707 December 2023 Request for Exemption from Specific Requirements in 2023 Security Rule, Enhanced Weapons, Firearms Background Checks, and Security Event Notification ULNRC-06827, Supplement to License Amendment Request Regarding Support System Requirements for Residual Heat Removal and Control Room Air Conditioning Systems Under Technical Specifications 3.4.8, 3.7.11, and 3.9.6 (LDCN 22-0029)2023-11-20020 November 2023 Supplement to License Amendment Request Regarding Support System Requirements for Residual Heat Removal and Control Room Air Conditioning Systems Under Technical Specifications 3.4.8, 3.7.11, and 3.9.6 (LDCN 22-0029) ULNRC-06824, Response to Request for Additional Information Regarding Operating Quality Assurance Manual (Oqam) Revision 36A2023-08-17017 August 2023 Response to Request for Additional Information Regarding Operating Quality Assurance Manual (Oqam) Revision 36A ULNRC-06830, Transmittal of Updated Technical Specification Markup and Clean Pages for License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak2023-08-15015 August 2023 Transmittal of Updated Technical Specification Markup and Clean Pages for License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak ULNRC-06223, Minor Correction to License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Test Frequencies (LDCN 2020-0004)2023-07-25025 July 2023 Minor Correction to License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Test Frequencies (LDCN 2020-0004) ULNRC-06799, Submittal of Licensee Event Report 2022-003-01, Class 1E Electrical Air Conditioning System Thermal Expansion Valve Failure Resulted in Condition Prohibited by Technical Specifications2023-07-13013 July 2023 Submittal of Licensee Event Report 2022-003-01, Class 1E Electrical Air Conditioning System Thermal Expansion Valve Failure Resulted in Condition Prohibited by Technical Specifications ULNRC-06821, Post-Audit Follow-Up Information in Support of Callaway'S License Amendment Request and Proposed Exemption to Allow Use of Framatome Gaia Fuel (LDCN 22-0002) (EPID L-2022-LLA-0150 and EPID L-2022-LLE-00301)2023-06-21021 June 2023 Post-Audit Follow-Up Information in Support of Callaway'S License Amendment Request and Proposed Exemption to Allow Use of Framatome Gaia Fuel (LDCN 22-0002) (EPID L-2022-LLA-0150 and EPID L-2022-LLE-00301) ULNRC-06822, Additional Information Regarding Request for NRC Approval of Operating Quality Assurance Manual (Oqam) Revision 36a2023-06-14014 June 2023 Additional Information Regarding Request for NRC Approval of Operating Quality Assurance Manual (Oqam) Revision 36a ULNRC-06815, Request for NRC Approval of Operating Quality Assurance Manual, Revision 36a2023-06-0505 June 2023 Request for NRC Approval of Operating Quality Assurance Manual, Revision 36a ULNRC-06818, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate .2023-06-0505 June 2023 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate . ULNRC-06816, Withdrawal of Previously Submitted Enclosures Regarding License Amendment Request for Adoption of Alternative Source Term and Revision of Technical Specifications (LDCN 21-0015)2023-05-0909 May 2023 Withdrawal of Previously Submitted Enclosures Regarding License Amendment Request for Adoption of Alternative Source Term and Revision of Technical Specifications (LDCN 21-0015) ULNRC-06812, Submittal of 2022 Annual Radiological Environmental Operating Report2023-04-27027 April 2023 Submittal of 2022 Annual Radiological Environmental Operating Report ULNRC-06806, Submittal of Radiological Emergency Response Plan, Revision 552023-04-12012 April 2023 Submittal of Radiological Emergency Response Plan, Revision 55 ULNRC-06807, Submittal of Single Positive Test Forms2023-04-0303 April 2023 Submittal of Single Positive Test Forms ULNRC-06801, CFR 50.46 Annual Report Regarding ECCS Evaluation Model Revisions2023-03-30030 March 2023 CFR 50.46 Annual Report Regarding ECCS Evaluation Model Revisions ULNRC-06798, Submittal of Status of Plant Decommissioning Funding and ISFSI Decommissioning Funding Plan2023-03-30030 March 2023 Submittal of Status of Plant Decommissioning Funding and ISFSI Decommissioning Funding Plan ULNRC-06803, Submittal of Response to Request for Additional Information Regarding Results of Steam Generator Tube In-Service Inspection2023-03-29029 March 2023 Submittal of Response to Request for Additional Information Regarding Results of Steam Generator Tube In-Service Inspection ULNRC-06751, Application to Revise Technical Specifications to Adopt TSTF-501-A, Rev. 1, Relocate Stored Oil & Lube Oil Volume Values to Licensee Control2023-03-29029 March 2023 Application to Revise Technical Specifications to Adopt TSTF-501-A, Rev. 1, Relocate Stored Oil & Lube Oil Volume Values to Licensee Control ULNRC-06804, Submittal of Nuclear Property Insurance Reporting2023-03-29029 March 2023 Submittal of Nuclear Property Insurance Reporting ULNRC-06805, Transmittal of Special Report 2023-02 Non-Functionality of Containment Hydrogen Analyzer Channel for Greater than 30 Days2023-03-21021 March 2023 Transmittal of Special Report 2023-02 Non-Functionality of Containment Hydrogen Analyzer Channel for Greater than 30 Days ULNRC-06802, Special Report 2023-01 (PAM Report); Non-Functionality of a Post-Accident Monitoring Instrument2023-03-0909 March 2023 Special Report 2023-01 (PAM Report); Non-Functionality of a Post-Accident Monitoring Instrument ULNRC-06795, Submittal of Fitness for Duty Reports for 2022, Including Single Positive Test Forms2023-01-24024 January 2023 Submittal of Fitness for Duty Reports for 2022, Including Single Positive Test Forms ULNRC-06794, Submittal of Fitness for Duty Program Data for 20222023-01-24024 January 2023 Submittal of Fitness for Duty Program Data for 2022 ULNRC-06787, Response to Request for Additional Information Regarding License Amendment Request for Adoption of Alternate Source Term and Revision of Technical Specifications (LDCN 21-0015)2022-12-0808 December 2022 Response to Request for Additional Information Regarding License Amendment Request for Adoption of Alternate Source Term and Revision of Technical Specifications (LDCN 21-0015) ULNRC-06781, License Amendment Request to Clarify Support System Requirements for the Residual Heat Removal System and Control Room Air Conditioning System Under Technical Specifications 3.4.8, 3.7.11, and 3.9.6 (LDCN 22-0029)2022-12-0101 December 2022 License Amendment Request to Clarify Support System Requirements for the Residual Heat Removal System and Control Room Air Conditioning System Under Technical Specifications 3.4.8, 3.7.11, and 3.9.6 (LDCN 22-0029) ULNRC-06780, Additional Supplement to License Amendment Request to Adopt TSTF-439 and TSTF-505, LDCN 20-0072022-11-30030 November 2022 Additional Supplement to License Amendment Request to Adopt TSTF-439 and TSTF-505, LDCN 20-007 ULNRC-06772, 10 CFR 50.59 and 10 CFR 72.48 Summary Report2022-11-23023 November 2022 10 CFR 50.59 and 10 CFR 72.48 Summary Report ULNRC-06777, Operating Quality Assurance Manual (Oqam) Revision 362022-11-16016 November 2022 Operating Quality Assurance Manual (Oqam) Revision 36 ULNRC-06779, ULNRC-06779: Contesting of Green NCV 05000483/2022010-03, Failure to Perform Required Inservice Testing of Residual Heat Removal Heat Exchanger Pneumatically (Air) Operated Outlet and Bypass Valves2022-11-14014 November 2022 ULNRC-06779: Contesting of Green NCV 05000483/2022010-03, Failure to Perform Required Inservice Testing of Residual Heat Removal Heat Exchanger Pneumatically (Air) Operated Outlet and Bypass Valves ULNRC-06765, License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Testing Frequencies (LDCN 2020-0004)2022-11-0303 November 2022 License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Testing Frequencies (LDCN 2020-0004) ULNRC-06773, Results of Steam Generator Tube In-Service Inspection2022-11-0101 November 2022 Results of Steam Generator Tube In-Service Inspection 2024-06-26
[Table view] Category:Licensee Response to Notice of Violation
MONTHYEARULNRC-06779, ULNRC-06779: Contesting of Green NCV 05000483/2022010-03, Failure to Perform Required Inservice Testing of Residual Heat Removal Heat Exchanger Pneumatically (Air) Operated Outlet and Bypass Valves2022-11-14014 November 2022 ULNRC-06779: Contesting of Green NCV 05000483/2022010-03, Failure to Perform Required Inservice Testing of Residual Heat Removal Heat Exchanger Pneumatically (Air) Operated Outlet and Bypass Valves ML22318A1892022-11-14014 November 2022 Enclosure 1 - Ameren Missouri'S Response to Green NCV 05000483/2022010-03 ULNRC-06493, Supplemental Response to Notice of Violation, Inspection Report No. 50-483/20160022019-04-11011 April 2019 Supplemental Response to Notice of Violation, Inspection Report No. 50-483/2016002 IR 05000483/20170072017-11-0101 November 2017 Reply to Notice of Violation 05000483/2017007-01 ULNRC-06394, Reply to Notice of Violation 05000483/2017007-012017-11-0101 November 2017 Reply to Notice of Violation 05000483/2017007-01 ULNRC-06378, Supplemental Response to Notice of Violation Inspection Report No. 50-483/20160022017-06-27027 June 2017 Supplemental Response to Notice of Violation Inspection Report No. 50-483/2016002 ULNRC-06365, Updated Response to Notice of Violation Inspection Report 50-483/20160022017-04-27027 April 2017 Updated Response to Notice of Violation Inspection Report 50-483/2016002 ULNRC-06326, Reply to a Notice of Violation Inspection Report 05000-483/20160022016-09-0909 September 2016 Reply to a Notice of Violation Inspection Report 05000-483/2016002 IR 05000483/20080032008-09-0404 September 2008 Reply to Notice of Violation: EA-08-190, Inspection Report No. 50-483/2008003 ULNRC-05528, Reply to Notice of Violation: EA-08-190, Inspection Report No. 50-483/20080032008-09-0404 September 2008 Reply to Notice of Violation: EA-08-190, Inspection Report No. 50-483/2008003 ML0608304122006-03-14014 March 2006 IR 05000483-05-005, Union Electric Co., Reply to Notice of Violation IR 05000483/20050052006-03-14014 March 2006 IR 05000483-05-005, Union Electric Co., Reply to Notice of Violation ML0535702612005-12-14014 December 2005 Reply to Inspection No 50-483/05-004 IR 05000483/20050042005-12-14014 December 2005 Callaway, Reply to Inspection No 50-483/05-004 ULNRC-04867, Reply to Notice of Violation Inspection Report No. 50-483/2003-0082003-07-21021 July 2003 Reply to Notice of Violation Inspection Report No. 50-483/2003-008 ULNRC-04848, Reply to Preliminary White Finding Regarding Inspection Report No. 50-483/2003-0082003-06-10010 June 2003 Reply to Preliminary White Finding Regarding Inspection Report No. 50-483/2003-008 ULNRC-04653, Reply to Notice of Violation for Inspection Report 50-483/2002-007, Enforcement Action EA-02-0462002-05-0808 May 2002 Reply to Notice of Violation for Inspection Report 50-483/2002-007, Enforcement Action EA-02-046 ML0202903752002-01-22022 January 2002 Response to Enforcement Action (EA-01-005) from Union Electric Co 2022-11-14
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AmerenUE PO Box 620 Callaway Plant Fulton, MO 65251 September 4, 2008 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 ULNRC-05528 1Ameren wd Ladies and Gentlemen:
1/I/
REPLY TO NOTICE OF VIOLATION: EA-08-190 INSPECTION REPORT NO. 50-483/2008003 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.
This letter from AmerenUE (Union Electric) transmits our response to Mr. Vincent G.
Gaddy's letter dated August 5, 2008, which transmitted a Notice of Violation for events discussed in Inspection Report 50-483/2008003. The response is provided in the attachment to this letter.
This letter contains a new commitment.
If you have any questions regarding this response, or if additional information is required, please contact me at (573) 676-8129.
Sincerely, Luke H. Graessle Manager, Regulatory Affairs CSP/nls Attachment 1: Response to Violation (EA-08-190)
Attachment 2: List of Commitments a subsidiary of Ameren Corporation
ULNRC-05528 September 4, 2008 Page 2 cc: Mr. Elmo E. Collins, Jr.
Regional Administrator U.S. Nuclear Regulatory Commission Region IV 612 East Lamar Drive, Suite 400 Arlington, TX 76011-4125 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Mohan C. Thadani (2 copies)
Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O-8G14 Washington, DC 20555-2738
ULNRC-05528 September 4, 2008 Page 3 Index and send hardcopy to QA file(s):
A160.0761 A170.0103 Hardcopy:
Certrec Corporation 4200 South Hulen, Suite 422 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)
Electronic distribution for the following can be made via NOV ULNRC Distribution:
A. C. Heflin F. M. Diya.
T. E. Herrmann D. W. Neterer L. H. Graessle G. L. Bradley S. A. Maglio T. B. Elwood C. S. Petzel S. L. Gallagher L. M. Belsky (NSRB)
Ms. Diane M. Hooper (WCNOC) w/o Mr. Dennis Buschbaum (TXU) w/o Mr. Scott Bauer (Palo Verde) w/o Mr. Stan Ketelsen (PG&E) w/o Mr. Scott Head (STP) w/o Mr. John OQNeill (Pillsbury Winthrop Shaw Pittman LLP) w/o Missouri Public Service Commission w/o to ULNRC-05528 Page 1 of 4 Response to Violation (EA-08-190)
Statement of Violation During an NRC inspection conducted March 24 through June 24, 2008, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action,"
requires, in part, that "measures shall be established to ensure that, for significant conditions adverse to quality, the cause of the condition is determined and corrective action taken to preclude repetition."
Contrary to this, from December 26, 2006, through May 21, 2008, the licensee failed to take corrective actions to preclude repetition of safety-related emergency core cooling system pipe voiding, and the licensee determined that this condition was a significant condition adverse to quality.
This violation is associated with a Green Significance Determination Process finding.
Reason For The Violation, Or If Contested, The Basis For Disputing The Violation Or Severity Level The Safety Injection System was drained to support maintenance activities during Refuel 15 in spring 2007. Workman's Protection Assurance (WPA) HoldoffH66255 was placed to perform the scheduled work on the system. The work included a job on valve EM8858A, Safety Injection Pump A Suction Pressure Relief to Recycle Hold-Up Tank.
This master WPA used procedure OTN-EM-00001, Safety Injection System, to fill and vent the system. The Reactor Operator (RO) who planned this WPA included valve EMV0179, Safety Injection Pump A from Residual Heat Removal (RHR) Heat Exchanger (IX) A Suction Vent, as a vent point since this WPA drained more of the system than assumed in procedure OTN-EM-00001. The scheduled work on EM8858A, Safety Injection Pump A Suction Pressure Relief to Recycle Hold-Up Tank, was not performed during the time H66255 was placed, and was subsequently rescheduled for later in the refuel outage.
WPA H69141 was subsequently generated to support the work on EM8858A. The new WPA referred only to procedure OTN-EM-00001. The WPA writer referred to OTN-EM-00001 and determined that the procedure provided instructions on filling and venting the section of piping that was to be drained for work on EM8858A. This section of piping had to be drained and refilled two (2) additional times to support the work on EM8858A. WPA H69199 and WPA H69228 supporting this work also referred only to OTN-EM-00001 to fill and vent the system.
to ULNRC-05528 Page 2 of 4 During spring of 2008, in response to NRC Generic Letter 2008-01 and Wolf Creek Operating Experience, Callaway developed and implemented a plan to verify that the Emergency Core Cooling System (ECCS) is full of water. On May 21, 2008, while implementing this plan, line EM-023--BC-6", Safety Injection Pump A/B Common Suction Header from RHR 'A' During ECCS Recirculation, at the 1989' elevation, was found to contain a void approximately 6.6 cubic feet in volume. This exceeded the allowable void fraction of 2.105 cubic feet as determined by Nuclear Engineering and documented in Request for Resolution (RFR) 200803669 for this section of piping. At 1430 on May 21, 2008, PEM01A, Safety Injection Pump A, was declared INOPERABLE pursuant to Technical Specification 3.5.2.A. The line was then vented at EMV0179 and declared OPERABLE at 2050 on May 21, 2008.
The investigation into why the void was present determined that the fill and vent section of OTN-EM-00001 did not utilize valve EMV0179 as a vent point. This vent is needed to vent the section of piping between the "A" SI Pump suction and EMHV8807B, RHR HX A to SI Pumps Suction Downstream Isolation Valve B (Line EM-023-HCB-6").
The issue of voiding in.systems at Callaway was previously addressed in a February 2005 Significance Level 2 CAR 200501092, Potential Adverse Trend - Recurrence of Voiding in Safety-Related Systems. The adverse trend was evaluated and determined to be caused by inadequate fill and vent instructions. At that time, the normal operating procedures did not contain fill and vent instructions. The Corrective Action to Prevent Recurrence (CATPR) for this adverse trend was to add fill and vent sections to the appropriate ECCS normal system operating procedures. This CATPR, if correctly implemented, would have prevented this event. However, the revision (Rev 022) that was made to OTN-EM-00001 in the Fall 2005 timeframe did not include EMVO 179 as a vent point due to inadequate self checking during procedure revision process. Neither the procedure writer nor the procedure reviewers identified the need to vent from EMVO 179.
Root Cause Process The Root Cause Analysis Team for the CAR that addressed the void condition discovered on May 21, 2008, developed the following causal factor and root cause:
Causal Factor Procedure OTN-EM-00001, Safety Injection System, Rev 22 did not include EMV0179 as a vent location for suction line EM-023-HCB-6". Subsequent revisions up to Revision 27 have not included EMV0179 as a vent location. The inadequate procedure is considered to be a flawed defense.
to ULNRC-05528 Page 3 of 4 Root Cause The procedure writer and reviewers did not identify that EMVO 179 needed to be included in OTN-EM-0000 1 as a vent point due to inadequate self checking during procedure revision process.
There were no latent organizational weaknesses identified with either the Causal Factor or the Root Cause.
Corrective Steps Taken and Results Achieved
- Line EM-023-HCB-6" was vented at EMV0179 on May 21, 2008, and verified to be full of water (no unacceptable voids).
- All ECCS fill and vent sections of the procedures were reviewed. The evaluation determined that all the other ECCS fill and vent instructions were adequate to ensure that the piping was full of water.
- The individuals that revised and reviewed OTN-EM-00001 have been coached on the need to self-check their work and ensuring the adequacy of the procedure reviews.
Corrective Steps Taken to Avoid Further Violations
- OTN-EM-00001 has been revised to include EMV0179 as a vent point in the Fill and Vent section of the procedure.
- OSP-SA-00003, Emergency Core Cooling System Flow Path Verification and Venting, has been revised to include EMV0 175, RHR HIX A to SI Pump A Vent, EMVO 179, SI Pump A from RHR HX A Suction Vent, and EMV0 199, SI Pumps Suction Cross Connect Header Vent, as vent locations. This surveillance procedure is used to verify that the ECCS is full of water on a monthly basis.
- APA-ZZ-00101, Processing Procedures, Manuals, and Desktop Instructions, was revised in November 2007 (Revision 045) to require at least two (2) Technical Reviews. This change in the procedure review and approval process will help minimize the possibility of one Technical Review making an error as occurred in Revision 22 of procedure OTN-EM-00001.
- Callaway personnel are currently conducting an additional detailed review of the fill and vent procedures that were previously evaluated or revised as corrective action for the previous corrective action document, CAR 200501092. There were ten systems reviewed as part of that corrective action. The systems are as follows:
to ULNRC-05528 Page 4 of 4 Auxiliary Feedwater Chemical and Volume Control Borated Water Storage Service Water Essential Service Water Component Cooling Water Residual Heat Removal Safety Injection Containment Spray Accumulator Safety Injection Date when Full Compliance will be Achieved Callaway will be in full compliance after completion of any procedure revisions that may be necessitated by the ongoing review of procedures for the ten systems identified above.
The procedure revisions will be completed by October 15, 2008.
to ULNRC-05528 LIST OF COMMITMENTS The following table identifies those actions committed to by AmerenUE in this document. Any other statements in this document are provided for information purposes and are not considered commitments. Please direct questions regarding these commitments to: Tom Elwood, Supervising Engineer, Regulatory Affairs and Licensing at 573-676-6479.
COMMITMENT Due Date/Event Callaway will complete procedure revisions that may be October 15, 2008 necessitated by the ongoing review of procedures for the ten systems identified in ULNRC05528. The procedure revisions, if necessary, will be completed by October 15, 2008.