05000305/LER-2004-004

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LER-2004-004,
Docket Numberrev
Event date: 11-18-2004
Report date: 01-17-2005
Reporting criterion: 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3052004004R00 - NRC Website

FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6 PAGE (3) Kewaunee Nuclear Power Plant 05000305 YEAR I� SEQUENTIAL I REVISION

DESCRIPTION

On November 18, 2004 at approximately 1630 hours0.0189 days <br />0.453 hours <br />0.0027 weeks <br />6.20215e-4 months <br /> during Kewaunee Nuclear Power Plant (KNPP) refueling shutdown (KR27), control room personnel were performing a refueling checklist and discovered that R-12 (Containment Radiation Monitor) [MON] would not automatically isolate Reactor Building Ventilation [VA].

Further investigation revealed that performance of Surveillance Procedure, SP-55-155C, "Engineered Safeguards [JEJ Features Prestartup Logic Test", had been initiated at 0750 hours0.00868 days <br />0.208 hours <br />0.00124 weeks <br />2.85375e-4 months <br />. SP-55-155C placed the Safeguards Train A into test mode at 0803 hours0.00929 days <br />0.223 hours <br />0.00133 weeks <br />3.055415e-4 months <br /> and Safeguards Train B into test mode at 0804 hours0.00931 days <br />0.223 hours <br />0.00133 weeks <br />3.05922e-4 months <br />, thereby defeating Safeguards Train A and Train B automatic signals to containment ventilation isolation.

During the time that both safeguards trains were out of service, the upper internals were installed in the reactor [RCT] and control rod [ROD] latching had been completed. Technical Specifications TS 3.8.a.8 requires that automatic containment ventilation isolation is operable during refueling operations. When this event was discovered, no reactivity manipulations were occurring and further manipulations were restricted until automatic containment ventilation isolation capability could be restored.

CAUSE OF THE EVENT

The cause of the event was attributed to a lack of adequate procedure guidance. In the Operational Consideration section of SP 55-155C, affected Technical Specifications TS 3.8.a.8 was not listed.

Additionally, the Initial Conditions section did not delineate that this procedure should not be performed when refueling containment integrity was required. However, in the General Instructions section, Step 4.1.2, Containment Isolation and Containment Vent Isolation were listed as equipment affected by this procedure.

The lack of information in the Initial Conditions along with Technical Specification TS 3.8.a.8 not being listed led to the occurrence of this event. Contributing factors to the event were that the procedure was not properly coordinated with Refueling Containment Integrity requirements to prevent this occurrence. Additionally, when the Senior Reactor Operator authorized the work in the control room, he did not recognize how the procedure affected Technical Specifications compliance.

ANALYSIS OF THE EVENT

This event is being reported under 10CFR50.73(a)(2)(i)(B), operation that was prohibited by Technical Specifications. This event does not involve any equipment failures.

The safety significance of this event was minimal. While the upper internals were being installed and when control rod latching was occurring, Radiation Monitors R-12 and R-21 continued to provide indication of radiation levels in the containment atmosphere. The monitors would have alarmed in the control room had a fuel handling radiological event occurred.

Upon receipt of an R-12 or R-21 alarm in the control room, the abnormal operating procedure for the Radiation Monitoring system directs operator actions to isolate containment ventilation. Manual isolation of containment ventilation was available at all times, and the manual operator actions allow for prompt isolation of containment ventilation.

FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6 PAGE (3) Kewaunee Nuclear Power Plant 05000305

CORRECTIVE ACTIONS

1. Procedure changes have been initiated to revise procedure SP-55-155C. The changes include enhancements to the initial conditions and operational considerations sections along with the addition of a sign-off step stating that this procedure cannot be performed if Refueling Containment Integrity is required.

2. A corrective action has been initiated to ensure that performance of SP-55-155C is properly coordinated with Refueling Containment Integrity requirements.

SIMILAR EVENTS

None.