05000483/LER-2010-007, Regarding Violation of Technical Specification 3.6.3, Containment Isolation Valves

Regarding Violation of Technical Specification 3.6.3, Containment Isolation Valves

ML102810512
Person / Time
Site:	Callaway
Issue date:	10/07/2010
From:	Diya F Ameren Corp, Union Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ULNRC-05735 LER 10-007-00
Download: ML102810512 (9)

LER-2010-007, Regarding Violation of Technical Specification 3.6.3, Containment Isolation Valves

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
4832010007R00 - NRC Website

text

~~

~Ameren MISSOURI Fadi M. Diva Vice President Nuclear Operations Ameren Missouri Callaway Plant T 573.676.6411 F 573.676.4056 October 7,2010 ULNRC-05735 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Ladies and Gentlemen:

10 CFR 50.73(a)(2)(i)(B)

DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

FACILITY OPERATING LICENSE NPF-30 LICENSEE EVENT REPORT 2010-007-00 VIOLATION OF TECHNICAL SPECIFICATION 3.6.3, "CONTAINMENT ISOLATION VALVES" The enclosed licensee event report is submitted in accordance with 10 CFR 50.73(a)(2)(i)(B) to report a violation of Technical Specification 3.6.3, "Containment Isolation Valves."

This letter does not contain commitments.

EMF/nls Enclosure

_,S1ilm Fadi M Diya Vice President, Nuclear Operations Junction CC & Hwy 0 PO Box 620, MC CA-460 Fulton, MO 65251 AmerenMissouri.com

ULNRC-05735 October 7, 2010 Page 2 cc:

Mr. Elmo E. Collins, Jr.

Regional Administrator U.S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., 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)

Senior Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8G 14 Washington, DC 20555-2738 Mr. James Polickoski Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8B 1A Washington, DC 20555-2738

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 0813112010 (9-2007)

, the NRC may digits/characters for 'each block) not conduct or sponsor, and a person is not required to respond to, the information collection.

13. PAGE Callaway Plant Unit 1 05000483 1 OF 7

4. TITLE Violation of Technical Specification 3.6.3, "Containment Isolation Valves"

5. EVENT DATE

6. LER NUMBER

7. REPORT DATE

8. OTHER FACILITIES INVOLVED SEQUENTIAL REV FACILITY NAME DOCKET NUMBER MONTH DAY YEAR YEAR NUMBER NO.

MONTH DAY YEAR FACILITY NAME DOCKET NUMBER 08 11 2010 2010 - 007 -

00 10 07 2010

9. OPERATING MODE

11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR§: (Check all that apply) o 20.2201 (b) o 20.2203(a)(3)(i) o 50.73(a)(2)(i)(C) o 50.73(a)(2)(vii) 1 o 20.2201 (d) o 20.2203(a)(3)(ii) o 50.73(a)(2)(ii)(A) o 50.73(a)(2)(viii)(A) o 20.2203(a)(1) o 20.2203(a)(4) o 50.73(a)(2)(ii)(B) o 50.73(a)(2)(viii)(B) o 20.2203(a)(2)(i) o 50.36(c)(1 )(i)(A) o 50.73(a)(2)(iii) o 50.73(a)(2)(ix)(A)

10. POWER LEVEL o 20.2203(a)(2)(ii) o 50.36(<:)(1 )(ii)(A) o 50.73(a)(2)(iv)(A) o 50.73(a)(2)(x) o 20.2203(a)(2)(iii) o 50.36(c)(2) o 50.73(a)(2)(v)(A) o 73.71(a)(4) 100 o 20.2203(a)(2)(iv) o 50.46(a)(3)(ii) o 50.73(a)(2)(v)(B) o 73.71(a)(5) o 20.2203(a)(2)(v) o 50.73(a)(2)(i)(A) o 50.73(a)(2)(v)(C) o OTHER o 20.2203(a)(2)(vi) l8I 50.73(a)(2)(i)(B) o 50.73(a)(2)(v)(D)

Specify in Abstract below or in (If more space is required, use additional copies of (If more space is required, use additional copies of (If more space is required, use additional copies of (If more space is required, use additional copies of (If more space is required, use additional copies of NRC Form 366A) (17)

6. LER NUMBER I

SEQUENTIAL I REVISION NUMBER NUMBER 007 00

3. PAGE 7

OF TS Bases; establishing a standard (or clarifying existing expectation) for unacceptability or acceptability of using any procedure as "guidance" versus entering the procedure; and providing training as requested to (1) explain "administrative controls" and the definition of "dedicated," "at the valve controls," and "continuous communications" as outlined in TS 3.6.3 Bases; (2) explain the differences in administrative controls with respect to the TS Action sections and the TS Surveillance Requirements section for TS 3.6.3; and (3) explain how the single active failure criteria is met with respect to TS 3.6.3 and what procedure steps are implemented to ensure this is met when a CCW CIV bypass valve is opened.

8.

PREVIOUS SIMILAR EVENTS

A search of the Callaway Action Request System (CARS) identified one occurrence similar to the event described in this LER:

200300176 - A potential noncompliance with TS 3.6.3 caused by the lack of understanding of how to conservatively or properly apply the administrative control provisions of TS 3.6.3 due to an unrecognized change in the basis behind the administrative controls for these valves.

Corrective actions included revising applicable procedures to incorporate instructions for ensuring that when any of the CIVs associated with P-75 and P-76 are opened under administrative controls and which are otherwise required to be closed, that a plant operator who is in continuous communication with the control room is stationed at or near the local valve controls for proper implementation of administrative controls; and providing training to plant staff/management personnel regarding proper implementation of administrative controls for the subject containment penetrations. This previous event did not prevent recurrence due to the corrective actions being only partially adequate. The changes made to the procedures did not specify in all the procedures that a local operator was required to be stationed and did not clarify what administrative control consisted of (Le., define "dedicated," "at the valve controls," and "continuous communication"). Also, in some cases the operator is identified to be stationed locally in the event the valve cannot be closed from the MCR, which is contrary to the corrective action stated in the Root Cause Report for this CAR. Also, there is no record of the training that was conducted. 7