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LER-2004-002, Regarding Non Conservative Technical Specifications - Containment Fan Coil Units |
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10 CFR 50.73(a)(2)(v), Loss of Safety Function |
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| 2722004002R00 - NRC Website |
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PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 0 PSEG ANuclear LLC MAY 2 0 2004 LRN 0207 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
LER 272/04-002-00 SALEM - UNIT I FACILITY OPERATING LICENSE NO. DPR-70 DOCKET NO. 50-272 This Licensee Event Report, "Non-conservative Technical Specifications - Containment Fan Coil Units," is being submitted pursuant to the requirements of the Code of Federal Regulations 10CFR50.73(a)(2)(v).
The attached LER contains no commitments.
- - Salem Attachment
/EHV C
Distribution LER File 3.7 95-2168 REV. 7/99
Abstract
On April 25, 2004, a review of the control room operator's logs was completed as a result of a discrepancy identified on February 24 between the Salem Units 1 and 2 Technical Specifications (TS) 3.6.3.2 and the current licensing basis analyses assumptions.
Specifically, PSEG identified that TS 3.6.3.2 Action b (for both Salem Units) was non-conservative. TS 3.6.3.2 Action b contains an allowable outage time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> whenever three or more Containment Fan Coil Units {BK}(CFCU) are inoperable provided that two Containment Spray {BE)(CS) pumps are operable. Current design analyses do not support the plant configuration allowed by TS 3.6.3.2 Action b. The control room operators log review identified at least two occasions (September 3, 2002 and July 3, 2003 for Salem Units 1 and 2 respectively) where T.S. 3.6.3.2 Action b had been entered.
The cause of this event was determined to be the existence of the non-conservative Technical Specification. The reason for failing to identify the condition earlier was determined to be an inadequate review for an Updated Final Safety Analysis Report (UFSAR) change related to NSAL 00-010 'Containment Safeguards Heat Removal Capability.' Corrective actions taken were: (1) In accordance with Administrative Letter 98-10, Salem Operations established guidance to enter Technical Specification 3.0.3 when more than two Containment Fan Coil Units are inoperable regardless of the number of operable Containment Spray pumps until the Technical Specifications are revised, (2) A license change request to correct the Technical Specification was submitted on April 15, 2004, (3) Other similar generic technical correspondence will be reviewed for proper closure and the event will be shared with engineering personnel.
This is being reported under the requirement of 10CFR50.73(a)(2)(v)(C) and (D), as a condition that could have prevented the fulfillment of a safety function of a system needed to remove heat, or control the release of radioactive material, or mitigate the consequences of an accident.
NMU. FUKM 366 (1v.=u)
(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)
CORRECTIVE ACTIONS
- 1. In accordance with Administrative Letter 98-10, Salem Operations has established guidance to enter Technical Specification 3.0.3 when more than 2 Containment Fan Coil Units are inoperable regardless of the number of operable Containment Spray pumps. (As committed in LCR S03-07, dated April 15, 2004)
- 2. A Technical Specification change to TS 3.6.2.3 Action b was submitted on April 15, 2004.
- 3. This event will be reviewed by the Engineering Training Review Group for inclusion in the Engineering Continuing Training Program.
- 4. Other generic technical correspondence similar to NSALs will be reviewed for appropriate disposition.
COMMITMENTS
Except as stated in corrective action 1 above, the remaining corrective actions cited in this LER are voluntary enhancements and do not constitute commitments.
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| 05000272/LER-2004-001, Regarding as Found Value for Main Steam Safety Value Lift Setpoint Exceeds Technical Specification Allowable Limit | Regarding as Found Value for Main Steam Safety Value Lift Setpoint Exceeds Technical Specification Allowable Limit | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications | | 05000311/LER-2004-001, Failure to Take Proper Compensatory Containment Air Samples | Failure to Take Proper Compensatory Containment Air Samples | 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 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)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2) | | 05000272/LER-2004-002, Regarding Non Conservative Technical Specifications - Containment Fan Coil Units | Regarding Non Conservative Technical Specifications - Containment Fan Coil Units | 10 CFR 50.73(a)(2)(v), Loss of Safety Function | | 05000311/LER-2004-002, Regarding Failure to Comply with Technical Specifications During Reactor Protection Instrument Calibration | Regarding Failure to Comply with Technical Specifications During Reactor Protection Instrument Calibration | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications | | 05000272/LER-2004-003, Regarding Completion of Plant Shutdown to Comply with Technical Specifications - 3.6.1.1 Containment Integrity | Regarding Completion of Plant Shutdown to Comply with Technical Specifications - 3.6.1.1 Containment Integrity | 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown | | 05000311/LER-2004-003, Regarding Control Room Emergency Air Conditioning System Unable to Mitigate the Consequences of an Accident | Regarding Control Room Emergency Air Conditioning System Unable to Mitigate the Consequences of an Accident | 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 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)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ix)(A), Prevented Safety Function in Multiple System | | 05000272/LER-2004-004, Regarding Non-essential Loads Not Isolated with One Chiller Inoperable as Required by Technical Specifications | Regarding Non-essential Loads Not Isolated with One Chiller Inoperable as Required by Technical Specifications | 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)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2) | | 05000311/LER-2004-004, Regarding Technical Specification Required Plant Shutdown Following Loss of 2B 230-Volt Vital Bus | Regarding Technical Specification Required Plant Shutdown Following Loss of 2B 230-Volt Vital Bus | 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown | | 05000272/LER-2004-005, ECCS Leakage Outside Containment Exceeds Dose Analysis Limits (11 RHR Heat Exchanger) | ECCS Leakage Outside Containment Exceeds Dose Analysis Limits (11 RHR Heat Exchanger) | 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ix)(A), Prevented Safety Function in Multiple System 10 CFR 50.73(a)(2)(viii)(A) | | 05000311/LER-2004-005, Regarding Auto Safety Injection Signal Not Unblocked Prior to Mode Change from 5 to 4 | Regarding Auto Safety Injection Signal Not Unblocked Prior to Mode Change from 5 to 4 | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications | | 05000311/LER-2004-006, Re Reactor Trip Due to a Malfunction of Main Feedwater Regulating Valve (21 BF1 9) | Re Reactor Trip Due to a Malfunction of Main Feedwater Regulating Valve (21 BF1 9) | 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 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)(iii) 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown | | 05000272/LER-2004-006, Operation in a Condition Prohibited by Technical Specification - Containment Isolation Valves | Operation in a Condition Prohibited by Technical Specification - Containment Isolation Valves | 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(ix)(A), Prevented Safety Function in Multiple System 10 CFR 50.73(a)(2) | | 05000272/LER-2004-007, Re Operation in a Condition Prohibited by Technical Specification - Technical Specification 3.3.2.1 | Re Operation in a Condition Prohibited by Technical Specification - Technical Specification 3.3.2.1 | 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 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)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 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)(x) 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(ix)(A), Prevented Safety Function in Multiple System 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(viii)(B) | | 05000311/LER-2004-007, Manual Reactor Trip Due to a Malfunction of a Main Feedwater Regulating Valve (23BF19) | Manual Reactor Trip Due to a Malfunction of a Main Feedwater Regulating Valve (23BF19) | 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown | | 05000311/LER-2004-008, Unplanned Reactor Trip Due to Main Generator Exciter Brush Failure | Unplanned Reactor Trip Due to Main Generator Exciter Brush Failure | 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2) | | 05000311/LER-2004-009, Re ECCS Leakage Outside Containment Exceeds Dose Analysis Limits (23 Charging Pump) | Re ECCS Leakage Outside Containment Exceeds Dose Analysis Limits (23 Charging Pump) | 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(v), Loss of Safety Function 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)(iii) 10 CFR 50.73(a)(2) |
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