05000285/LER-2016-001

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LER-2016-001, Technical Specification Violation due to Installation of an Unqualified Part in a Radiation Monitor
Fort Calhoun Station
Event date: 02-10-2016
Report date: 04-08-2016
Reporting criterion: 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications

10 CFR 50.73(a)(2)(v)(C), Loss of Safety Function - Release of Radioactive Material
2852016001R00 - NRC Website
LER 16-001-00 for Fort Calhoun, Unit 1 Regarding Technical Specification Violation due to Installation of an Unqualified Part in a Radiation Monitor
ML16099A274
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 04/08/2016
From: Marik S M
Omaha Public Power District
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-16-0027 LER 16-001-00
Download: ML16099A274 (4)


BACKGROUND

Fort Calhoun Station (FCS) is a two-loop reactor coolant system (RCS) of Combustion Engineering design.

RM-052, Containment and Auxiliary Building Stack Gaseous Swing Radiation Monitor, is part of the Process Radiation Monitoring System to provide surveillance of the plant effluent and critical process streams. The safety related function of the Process Radiation Monitoring Function is to provide a signal to initiate a Containment Radiation High Signal (CRHS) when radiation high alarm setpoint values are exceeded. During normal operation RM-052 is normally lined up to monitor the Vent Stack along with Auxiliary Building Vent Stack Monitor, RM-062.

RM-052 also acts as a back up to the dedicated Containment Monitor RM-051. During abnormal or emergency operation of the Process Monitoring System RM-51, RM-052 or RM-062 will provide a signal to actuate a CRHS which activates a Ventilation Isolation Actuation Signal (VIAS) when any of the three monitors is in High Alarm.

EVENT DESCRIPTION

On February 10, 2016, FCS became aware of the Canberra 10 CFR 21.21 notification related to the three separate POs to OPPD that had commercial grade items that were not properly dedicated as basic components per the PO requirements. The three POs are 185091, 185157, and 191479. (NOTE: The letter calls out PO 185167 - which is incorrect, further research identified the correct PO to be 185157). An investigation was performed by FCS staff and on February 12, 2016 determined that Catalog ID 27019-1 (PO #185157) was installed in RM-052 under Work Order 399904. At that time the control room was notified and Condition Report 2016-01409 was initiated. RM-052 was declared inoperable and the additional components identified in the notification were quarantined.

At the time the Control room was notified, RM-051 remained operable and in service sampling containment.

RM-062 also remained operable and in service sampling the Auxiliary Build ventilation stack satisfying TS 2.15.

A review of past operability identified instances when RM-051 and RM-062 were out of service for periods longer than allowed by TS. Specifically,

  • 2.15.1 (1) requires within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of RM-052 or RM-062 going inoperable containment purge and relief valves must be closed (bypass condition). After 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> the CRHS would need to be locked in.
  • 2.15.1 (3) requires within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of RM-052 or RM-062 going inoperable the reactor must be placed in hot shutdown or ventilation isolation valves are closed.

This event is reportable per 10 CFR 50.73(a)(2)(i)(B) operation or condition prohibited by Technical Specifications and 10 CFR 50.73(a)(2)(v)(C) Event or Condition that could have prevented fulfillment of a safety condition to control the release of radioactive material.

CONCLUSION

Canberra failed to establish adequate measures for the selection and review for sustainability for purchase orders 185091, 185157, and 191479. The parts are critical to the safety-related functions of the components and Canberra failed to identify and verify the appropriate critical characteristics and failed to ensure that the components met/enveloped the applicable qualification reports as required by the POs. All three POs had seismically, environmentally or electromagnetic interference (EMI)/electromagnetic compatibility (EMC) qualified related items that were not appropriately verified or evaluated. (Nonconformance 99901461/2015-261-01) This resulted in a Technical Specification violation due to installation of an unqualified part in radiation monitor RM-052.

CORRECTIVE ACTIONS

As previously stated the Time Delay Relay was replaced on 03/19/2016 with qualified part (WO 578335) and RM-052 was returned to service following successful surveillance testing. Other equipment identified in PO 185091, 185157 and 191479 was quarantined awaiting resolution through the Over, Short, Damaged and Discrepant (OSDD) process at FCS.

SAFETY SIGNIFICANCE

The safety related function of the Process Radiation Monitoring Function is to provide a signal to initiate a Containment Radiation High Signal (CRHS) when radiation high alarm setpoint values are exceeded. During normal operation RM-052 is lined up to monitor the Vent Stack along with Auxiliary Building Vent Stack Monitor RM-062. RM-052 can also acts as a back up to the dedicated Containment Monitor RM-051. During abnormal or emergency operation of the Process Monitoring System RM-051, RM-052 or RM-062 will provide a signal to actuate a CRHS which activates a Ventilation Isolation Actuation Signal (VIAS) when any of the three monitors is in High Alarm. During the time when RM-052 contained an unqualified part, one of the three radiation monitors was available to respond to an unlikely event that would require VIAS.

SAFETY SYSTEM FUNCTIONAL FAILURE

This event does represent a safety system function failure in accordance with NEI 99-02.

PREVIOUS SIMILAR EVENTS

There were no previous LERs identified in the past three years for unqualified parts installed in a radiation monitor.

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