05000272/LER-2010-004

LER-2010-004, Technical Specification 3.0.4.b Non-Compliance

Docket Number
Event date:
Report date:
2722010004R00 - NRC Website

PLANT AND SYSTEM IDENTIFICATION

Westinghouse — Pressurized Water Reactor (PWR/4) Chilled Water System/Chillers {KM/CHU} * Energy Industry Identification System {EMS} codes and component function identifier codes appear as {SS/CCC}

IDENTIFICATION OF OCCURRENCE

Event Date: September 20, 2010 Discovery Date: September 29, 2010

CONDITIONS PRIOR TO OCCURRENCE

Salem Unit 1 was in Operational Mode 1 at 100% reactor power.

DESCRIPTION OF OCCURRENCE

In September 2010, Salem Unit 1 was in the process of an initial campaign to move 'aged' irradiated fuel from the Spent Fuel Pool to a Dry Cask Storage facility.

On the evening of September 19, Spent Fuel Pool Manipulations procedural (10P-10) reviews commenced for the dry cask number 2 loading. All chillers were operable.

On September 20 at 0407, the 13 Chiller {KM/CHU} was tagged out of service for scheduled maintenance. Technical Specification (TS) Limited Condition for Operation (LCO) 3.7.10.a was entered for Modes 1-4. With a single chiller inoperable, the TS required action is to remove non-essential heat loads and restore the chiller to operable status within 14 days OR suspend movement of irradiated fuel.

A review on September 20, prior to authorizing the fuel movement, was performed and it was recognized that an inoperable 13 chiller was a new condition from the previously briefed 10P-10 reviews. The authorizing CRS reviewed the TS 3.7.10 action for Modes 5-6 or during movement of irradiated fuel assemblies and believed all required actions (14 day allowable action time until suspension of movement of irradiated fuel assemblies) were met for a single chiller inoperable. TS 3.7.10 for Mode 1-4 requires restoration of the inoperable chiller within 14 days or be in Hot Standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

It was not recognized that movement of irradiated fuel was also an entry into a specified condition in the Applicability section of TS 3.7.10, making the requirements outlined in TS 3.0.4 applicable prior to commencing movement of irradiated fuel.

�NRC FORM 366 (10-2010) PRINTED ON RECYCLED PAPER DESCRIPTION OF OCCURRENCE (cont'd) spent fuel pool to support dry cask storage. Movement of irradiated fuel commenced without meeting TS 3.0.4.b requirements. TS 3.0.4.b requires a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the specified condition and establishment of risk management actions prior to commencing movement of irradiated fuel. This risk assessment was not completed.

On September 24 at 2350 the 13 Chiller was declared operable and TS 3.7.10.a was exited.

On September 29 an independent review by Operations in preparation for the next cask loading questioned whether movement of irradiated fuel should have commenced without the performance of a TS 3.0.4.b risk assessment with a chiller out of service. The TS non-compliance was identified as a result of this review.

This report is being made in accordance with 10CFR50.73 (a)(2)(i)(B), "any operation ... prohibited by the plant's Technical Specification.

CAUSE OF OCCURRENCE

The apparent causes were a failure to recognize TS 3.0.4.b applicability when a specified condition of the TS applicability was entered and inattention to detail during the evaluation of the effects of out-of- service equipment when reviewing procedural controls for movement of irradiated fuel.

PREVIOUS OCCURRENCES

A review of LERs for Salem Units 1 and 2 back to 2006 identified the following previous occurrence. Salem Unit 1 LER 272/2010-003-00 was issued for the failure to re-establish the automatic start circuitry for the start of the motor driven Auxiliary Feedwater pumps on a trip of the Steam Generator Feedwater pumps.

The cause of the failure to re-establish the automatic start circuitry for the start of the motor driven AFW pumps on a trip of the SGFPs was due to operators performing the incorrect section of a procedure to re-establish the start circuitry during mode ascension. The corrective actions associated with this event were specific to this event and would not have prevented the current event from occurring.

SAFETY CONSEQUENCES AND IMPLICATIONS

There was no actual or potential safety consequences associated with this event. The fuel handling accident analysis considers a dropped irradiated fuel assembly that has just been removed from the core, assuming an operating Control Area Ventilation (CAV) filtration system with one train in service.

This analysis demonstrates that control room, Exclusion Area Boundary (EAB), and Low Population Zone (LPZ) doses meet all 10CFR50.67 limits. The EAB and LPZ dose analysis was not altered by the inoperability of the 13 chiller.

The potential loss of an additional chiller would not have impacted the consequences of this event. The fuel assemblies that were being loaded into dry cask number 2 were at least 9.4 years old. These fuel assemblies had virtually no fission gas. This is significantly less than the calculation design input using recently irradiated fuel; therefore there was no risk of exceeding the analyzed dose values to the control room operators.

A review of this event determined that a Safety System Functional Failure (SSFF) as defined in NEI 99­ 02, Regulatory Assessment Performance Indicator Guidelines, did not occur. There was no condition that alone could have prevented the fulfillment of a safety function of a system needed to mitigate the consequences of an accident.

CORRECTIVE ACTIONS

1. A standing order (SO) was issued to increase shift management oversight of operability screenings, TS tracking and decision-making activities.

2. A TS 3.0.4.b Risk Assessment for the remaining Dry Cask Storage irradiated fuel movement activities, assuming the loss of one (or two) chillers, was completed.

3. Spent Fuel Pool Manipulations procedure was enhanced to ensure that the requirements of T/S 3.0.4 (and other Technical Specification cross-references) are not overlooked during the performance of the procedure.

4. Personnel involved with this event were held accountable in accordance with PSEG policies.

5. An apparent cause evaluation is in progress; any additional corrective actions associated with this event will be tracked in the PSEG Corrective Action Program.

COMMITMENTS

No commitments are made in this LER.