05000219/LER-2009-004
| Oyster Creek | |
| Event date: | 10-25-2008 |
|---|---|
| Report date: | 11-12-2009 |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 2192009004R01 - NRC Website | |
Plant Condition Prior to Event Event Date:�Refueling outage 1 R22 (Fall 2008) Unit 1 Mode: Shutdown/Refueling Power Level: 0%
Description of Event
During the 1 R22 Refueling Outage (Fall 2008), a Temporary Modification was made to the secondary containment so that the trunnion room door could be left open to support maintenance activities. The Temporary Modification moved the barrier for secondary containment from the outer walls and door of the trunnion room to the inner walls, ceiling, floor, and associated penetrations in the trunnion room. A 10 CFR 50.59 Evaluation supported the Temporary Modification based on the determination that secondary containment integrity could be maintained separate from the trunnion room door and concluded that a Technical Specification (TS) change was not needed.
During the NRC Plant Modification Inspection (May 4 through 15, 2009), the determination was made that the Temporary Modification to open the trunnion room door for extended periods of time during 1R22 was in noncompliance with Oyster Creek's Technical Specifications. The supporting 10 CFR 50.59 Evaluation inappropriately determined that prior approval from the NRC was not needed in that the secondary containment integrity required by Technical Specification Limiting Condition of Operation (TS LCO) 3.5.B was maintained.
The 10 CFR 50.59 Evaluation reviewed the TS LCO and the TS bases as part of the 10 CFR 50.59 review. The evaluation concluded that the Temporary Modification of re-establishing the containment boundary to no longer rely on the trunnion room door maintained integrity of the secondary containment, that access to the reactor building was not created, and that a change of the TS was not required. However, the evaluator and reviewers did not recognize that re-establishing the secondary containment to not rely upon the trunnion room door was a change to the note associated with the TS definition and as such was a change to TS and requiring prior NRC approval.
Analysis of Event:
This event is reportable under the provisions of 10CFR50.73(a)(2)(i)(B) as a condition which is prohibited by the plant's Technical Specifications.
There were no safety consequences impacting the plant or public safety as a result of this event. All safety systems, structures, and components operated normally during this event. This event did not result in any safety system functional failure.
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Cause of Event:
The apparent cause of this event was that the Technical Specification definition note was in a confusing format. Due to the vagueness of the relationship of a note to Technical Specification Definition 1.14, Secondary Containment Integrity, and the Technical Specification LCO 3.5.B, Secondary Containment, the preparer and reviewers of the associated 10 CFR 50.59 Evaluation did not recognize that re-establishing the secondary boundary to not rely upon the trunnion room door was a literal change in the Technical Specification.
Corrective Actions:
A License Amendment Request will be submitted to revise Technical Specification Definition 1.14 to enable moving secondary containment boundary to trunnion room walls, ceiling, floor, and associated penetrations during refueling outages and to reformat the definition not to use a non-standard note.
A briefing on the lessons learned from this event will be provided to all 50.59 qualified personnel and incorporated in future 50.59 training.
Previous Occurrences
There have been no similar Licensee Event Reports events at Oyster Creek in the last three years, where technical specifications were changed by plant permanent or temporary modifications without prior NRC approval.
Component Failure Data
None