05000285/LER-2009-002, Technical Specification Violation Due to Installation of an Unqualified Part in a Radiation Monitor
| ML092230341 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 08/03/2009 |
| From: | Reinhart J Omaha Public Power District |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LIC-09-0052 LER 09-002-00 | |
| Download: ML092230341 (5) | |
| 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 |
| 2852009002R00 - NRC Website | |
text
UHHU Omaha Public Power District Fort Calhoun Station P.O. Box 550, Fort Calhoun, NE 68023 LIC-09-0052 August 3, 2009 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
Reference:
Docket No. 50-285
Subject:
Licensee Event Report 2009-002 Revision 0 for the Fort Calhoun Station Please :findattached ULicensee Event Report:2009-0092, Rpeision 0, dated August 3, 2009.
This report is being submitted pursuant to 10CFR50.73(a)(2)(i)(B).
The following commitment is contained in this submittal:
Appropriate station documents will be revised to clearly establish management expectations to verify the safety classification of replacement components. This will be completed by November 1, 2009. (AR 43565)
If you should have any questions, please contact me.
U-1I L JAR /eprn Attachment.1-.r E.
. Collins, NR Regional.Administrator, ;Regio I A. B. Wang, NRC Senior Project Manager SJ C. Kirkland, NRC,Senior. Resident Inspector.:,-,,-,.,,,
INPO Records Center Employment with Equal Opportunity flia24 17 1
NRC FORM 366 U.S. NUCLEAR REGULATORYCOMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 08/31/2010 (9-2007)
, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.
- 3. PAGE Fort Calhoun Station 05000285 1
OF 4
- 4. TITLE Technical Specification Violation due to Installation of an Unqualified Part in a Radiation Monitor
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED SEQUENTI R
FACILITY NAME DOCKET NUMBER MONTH DAY YEAR YEAR AL RE MONTH DAY YEAR NUMBER NO 05000 FACtLITY NAME05 0
4 14 2009 2009
- - 002-00 08 03 2009 05000
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply) o 20.2201 (b) 0 20.2203(a)(3)(i)
El 50.73(a)(2)(i)(C)-
El 50.73(a)(2)(vii) 01 0
20.2201 (d)-
El 20.2203(a)(3)(ii) 0l 50.73(a)(2)(ii)(A)
El 50.73(a)(2)(viii)(A) 0l 20.2203(a)(1)
El 20.2203(a)(4) 0 50.73(a)(2)(ii)(B) 0 50.73(a)(2)(viii)(B) o 20.2203(a)(2)(i) 0l 50.36(c)(1)(i)(A) 0 50.73(a)(2)(iii)
Cl 50.73(a)(2)(ix)(A)
- 10. POWER LEVEL 0
20.2203(a)(2)(ii) 0l 50.36(c)(1)(ii)(A)
El 50.73(a)(2)(iv)(A) 0 50.73(a)(2)(x) 0 20.2203(a)(2)(iii) 0 50.36(c)(2) 0E 50.73(a)(2)(v)(A) 0 73.71 (a)(4) 100 El 20.2203(a)(2)(iv) 0 50.46(a)(3)(ii)
El 50.73(a)(2)(v)(B) 0 73.71 (a)(5)
El 20.2203(a)(2)(v)
El 50.73(a)(2)(i)(A)
El 50.73(a)(2)(v)(C)
El OTHER El 20.2203(a)(2)(vi)
X 50.73(a)(2)(i)(B)
El 50.73(a)(2)(v)(D)
Specify in Abstract below or in
EVENT DESCRIPTION
On November 21, 2008, Work Request (WR) 129600 was initiated because the sample pump for process radiation monitors RM-050/051 (containment particulate and noble gas) tripped off during restoration from a surveillance test.
The WR was converted to Work Order (WO) 32409 1-01. This WO was prepared by a maintenance planner. The system engineer reviewed and approved the WO. This work order authorized instrument and control technicians to replace the KI and K2 relays in the pump control unit of RM-050/05 1-P (radiation monitor sample pump for RM-050/05 1). Two replacement parts were obtained for WO 324091-01; Ki relay (non-qualified) and K2 relay (qualified).
WO 324091-01 was created for component RM-050/05 1-P (sample pump). The information contained in the Equipment/Component panels in Passport (an equipment database) indicates the relay is a qualified safety class component. Drawing 801498-001 (Interconnection Diagram for RM-050) was listed in the documents section of the work order. This drawing is not stamped as indicating there were qualified components on the drawing. In addition, relay KI does not appear as a specific component in Passport. With this information, the maintenance planner could not determine the qualification classification for the relays directly from Passport. When confronted with conflicting or incomplete information as to whether the item should be considered qualified, the maintenance planner contacted a system engineer for assistance. The system engineer reviewed design documents and consulted with the maintenance planner and an instrument and control technician. Based on this review/consultation, the safety classification of the K1 relay was incorrectly determined to be non-qualified. As directed, the instrument and control technician installed a non-qualified replacement for the qualified KI relay in the pump control unit of RM-050/05 1-P later in the day on November 21, 2008.
On April 13, 2009, this condition was discovered by the system engineer while reviewing a WO to replace a pump control relay for RM-052 (Containment/Vent Stack Radiation Monitor). It was documented with condition report 2009-1770. In response to this discovery, the non-qualified K1 relay was replaced with a qualified K1 relay on April 14, 2009.
On May 29, 2009, it was discovered that the condition documented in CR 2009-1770 may be reportable under 10 CFR 50.73 because RM-062 (Auxiliary Building Vent Stack Radiation Monitor) and RM-051 (Containment Noble Gas Radiation Detector) were inoperable at the same time in violation of TS 2.15, Instrumentation and Control Systems.
On June 3, 2009, it was determined that in fact TS 2.15 had been violated for failure to take actions when having RM-051 and RM-062 both inoperable for approximately 17 days (March 29 - April 14, 2009) during which time several containment pressure reductions were performed. On April 12, 2009, at 1302, all three monitors were inoperable while a containment pressure reduction was in progress. The containment pressure reduction was secured at 1311, as required by TS 2.0.1. This event is being reported pursuant to 10 CFR50.73 (a)(2)(i)(B).
CONCLUSION A root cause analysis was performed to determine why a non-qualified replacement for the K 1 relay was installed in the control circuit for the pump for radiation monitor RM-050/051 per WO 324091-01. The root cause was determined to be management expectations are not clearly established to verify the safety classification of replacement components as required by Standing Order M-101, Maintenance Work Control. A thorough review of plant operating experience was conducted and it was determined that this was an isolated event.
CORRECTIVE ACTIONS
Immediate Corrective Actions The non-qualified K1 relay was replaced with a qualified K1 relay on April 14, 2009.
Long Term Corrective Actions Appropriate station documents will be revised to clearly establish management expectations to verify the safety classification of replacement components. This will be completed by November 1, 2009.
SAFETY SIGNIFICANCE
RM-052 is a swing monitor that can be used as a back-up to RM-051 when RM-051 is out of service. During the period that the non-qualified relay was installed in RM-051 (November 21, 2008, to April 14, 2009), RM-052 was out of service 7 times for a total of about 27 days. During the approximately 17 days when RM-052 was the only operable monitor, RM-051 was functioning and monitoring the containment atmosphere with the unqualified part installed. If a loss of coolant accident had occurred at this time, either RM-051 or RM-052 would likely have responded to the event and initiated 'a ventilation isolation actuation signal (VIAS) as required.
TS 2.15 requires that at least two of three radiation monitors must be OPERABLE to initiate a containment high radiation signal to VIAS. The margin of safety was reduced during the times that either RM-052 or RM-062 was inoperable. This would have reduced the number of operable monitors to only 1 of the 3 radiation monitors available to perform the engineered safety feature initiation function. On April 12, 2009, at 1302, all three monitors were inoperable while a containment pressure reduction was in progress' The containment pressure reduction was secured at 1311, as required by TS 2.0.1. While the requirements for safety related equipment were not met for this brief period of time it is likely that the unqualified component would have operated as designed and the required' safety function of isolating the containment would have occurred. In addition the probability of a design basis accident occurring during this brief period was very low. Therefore this event has very little impact. on the health and safety of the public.
SAFETY SYSTEM FUNCTIONAL FAILURE This event does not result in a safety system functional failure in accordance with NEI-99-02.
PREVIOUS SIMILAR EVENTS
LER 2006-002 "Inadequate Design Control Results in Potentially Insufficient Auxiliary Feedwater Flow,"
documents a similar event in that, an unqualified power supply was used for a component that had an impact on the flow capability of the safety related auxiliary feedwater system.PRINTED ON RECYCLED PAPERPRINTED ON RECYCLED PAPER