05000305/LER-2007-010, Allowed Outage Time of the Function for Automatic Initiation of the Control Room Post-Accident Recirculation System on a High Radiation Signal Not Met

Allowed Outage Time of the Function for Automatic Initiation of the Control Room Post-Accident Recirculation System on a High Radiation Signal Not Met

ML073320165
Person / Time
Site:	Kewaunee
Issue date:	11/20/2007
From:	Scace S Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
07-0763 LER 07-010-00
Download: ML073320165 (6)

LER-2007-010, Allowed Outage Time of the Function for Automatic Initiation of the Control Room Post-Accident Recirculation System on a High Radiation Signal Not Met

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(x) 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)(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)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(B)
3052007010R00 - NRC Website

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DominioW Dominion Energy Kewaunee, Inc.

N490 Highway 42, Kewaunee, WI 54216-9511 NOV 2 0 2007 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Serial No.

KPS/LIC/JG:

Docket No.

License No.

07-0763 RO 50-305 DPR-43 DOMINION ENERGY KEWAUNEE. INC.

KEWAUNEE POWER STATION LICENSEE EVENT REPORT 2007-010-00

Dear Sirs:

Pursuant to 10 CFR 50.73, Dominion Energy Kewaunee, Inc., hereby submits the following Licensee Event Report applicable to Kewaunee Power Station.

Report No. 50-305/2007-010-00 This report has been reviewed by the Plant Operating Review Committee and will be forwarded to the Management Safety Review Committee for its review.

If you have any further questions, please contact Mr. Jack Gadzala at (920) 388-8604.

Very truly yours, Stephen E. Scace Site Vice President, Kewaunee Power Station Attachment Commitments made by this letter: NONE o l4K

- 1 Serial No. 07-0763 Page 2 of 2 cc:

Regional Administrator, Region III U.S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Mr. P. D. Milano Project Manager U.S. Nuclear Regulatory Commission Mail Stop O-8-H-4a Washington, DC 20555-0001 NRC Senior Resident Inspector Kewaunee Power Station

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104 EXPIRES 6-30-2007 (6-2004)

Estimated burden per response to comply with this mandatory collection request: 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br />.

Reported lessons learned are incorporated into the licensing process and fed back to industry.

LICENSEE EVENT REPORT (LER)

Send comments regarding burden estimate to the Records and FOIA/Privacy Service Branch (T-5 F52), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by internet e-(See reverse for required number of mail to infocollects@nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, (3150-0066), Office of Management and Budget, Washington, DC 20503.

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If a means used to impose an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

FACILITY NAME (1)

DOCKET NUMBER (2)

PAGE (3)

Kewaunee Power Station 05000305 1

1 of 4

TITLE (4)

Allowed Outage Time of the Function for Automatic Initiation of the Control Room Post-Accident Recirculation System on a High Radiation Signal Not Met EVENT DATE (5)

LER NUMBER (6)

REPORT DATE (7)

OTHER FACILITIES INVOLVED (8)

SEQUENTIAL I REV FACILITY NAME DOCKET NUMBER MO DAY YEAR YEAR NUMBER NO MO DAY YEAR 09 21 2007 2007

-- 010 00 11 20 2007 FACILITY NAME DOCKET NUMBER OPERATING N

THIS REPORT IS SUBMITrED PURSUANT TO THE REQUIREMENTS OF 10 CFR (Check all that apply) (11)

MODE (9) 20.2201 (b) 20.2203(a)(3)(ii) 50.73(a)(2)(ii)(B) 50.73(a)(2)(ix)(A)

POWER 100 20.2201 (d) 20.2203(a)(4) 50.73(a)(2)(iii) 50.73(a)(2)(x)

LEVEL (10) 20.2203(a)(1) 50.36(c)(1 )(i)(A) 50.73(a)(2)(iv)(A) 73.71 (a)(4) 20.2203(a)(2)(i) 50.36(c)(1)(ii)(A) 50.73(a)(2)(v)(A) 73.71(a)(5) 20.2203(a)(2)(ii) 50.36(c)(2) 50.73(a)(2)(v)(B)

OTHER 20.2203(a)(2)(iii) 50.46(a)(3)(ii) 50.73(a)(2)(v)(C)

Specify in Abstract below or in 20.2203(a)(2)(iv) 50.73(a)(2)(i)(A) 50.73(a)(2)(v)(D) 20.2203(a)(2)(v)

X 50.73(a)(2)(i)(B) 50.73(a)(2)(vii) 20.2203(a)(2)(vi) 50.73(a)(2)(i)(C) 50.73(a)(2)(viii)(A) 20.2203(a)(3)(i) 50.73(a)(2)(ii)(A) 50.73(a)(2)(viii)(B)

I LICENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER (Include Area Code)

Joseph A Ruttar (920) 388-8654 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

MANU-REPORTABLE MANU-REPORTABLE

CAUSE

SYSTEM COMPONENT FACTURER TO EPIX

CAUSE

SYSTEM COMPONENT FA CTURER TO EPIX SUPPLEMENTAL REPORT EXPECTED (14)

EXPECTED MONTH DAY YEAR I

SUBMISSION YES (If yes, complete EXPECTED SUBMISSION DATE).

X NO DATE (15)

ABSTRACT On September 21, 2007, during performance of an evaluation of the control room radiation monitor (R-23) failure mode, Dominion Energy Kewaunee.(DEK) staff identified that the 12-hour shutdown requirement in Technical Specification (TS) 3.12, "Control Room Post-Accident Recirculation System", had been exceeded on previous occasions during performance of R-23 troubleshooting. R-23 provides a signal for automatic initiation of control room recirculation on high radiation.

This event occurred during past performances of corrective maintenance on R-23 when the monitor's trip function was disabled in excess of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with the reactor critical. Under conditions when R-23 is isolated from the system, the control room post-accident recirculation system cannot meet its surveillance requirement specified in TS 4.17. Kewaunee Power Station (KPS) Technical Specifications require that such a condition constitutes failure to meet the operability requirements for the associated limiting condition for operation (LCO).

Therefore, TS 3.12 is not met under such conditions, even if the control room post-accident recirculation system is placed in operation to meet its safety function.

This event is being reported in accordance with 10 CFR 50.73(a)(2)(i)(B), "Any operation or condition which was prohibited by the plant's Technical Specifications."U.S. NUCLEAR REGULATORY COMMISSION (1-2001)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME 1)

DOCKET NUMBER 2)

LER NUMBER (6)

PAGE (3)

A SEQUENTIAL NREVSON Kewaunee Power Station 05000305 YEAR NUMBER NUMBER 2 of 4 2007 010 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

Event Description

On September 21, 2007, during performance of an evaluation of the control room radiation monitor (R-23) failure mode, Dominion Energy Kewaunee (DEK) staff identified that the 12-hour shutdown requirement in Technical Specification (TS) 3.12, "Control Room Post-Accident Recirculation System", had been exceeded on previous occasions during performance of R-23 troubleshooting. R-23 provides a signal for automatic initiation of control room recirculation on high radiation.

This event occurred during past performances of corrective maintenance on R-23 when the monitor's trip function was disabled in excess of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with the reactor critical. Under conditions when R-23 is isolated from the system, the control room post-accident recirculation system cannot meet its surveillance requirement specified in TS 4.17. Kewaunee Power Station (KPS) Technical Specifications require that such a condition constitutes failure to meet the operability requirements for the associated limiting condition for operation (LCO). Therefore, TS 3.12 is not met under such conditions, even if the control room post-accident recirculation system is placed in operation to meet its safety function.

TS 4.0 states:

Failure to meet a surveillance requirement, whether such failure is experienced during the performance of the surveillance or between performances of the surveillances, shall be failure to meet the OPERABILITY requirements for the LCO.

TS 4.17 states:

Applies to testing and surveillance requirements for the Control Room Post-accident Recirculation System in TS 3.12.

...the following conditions shall be demonstrated:...Automatic initiation of the system on a high radiation signal....

These two TSs, taken together, necessitate that when the capability for automatic initiation of control room post-accident recirculation on a high radiation signal cannot be demonstrated (by R-23 or an equivalent component), then the surveillance requirement is not met; and therefore, TS 3.12 is not met (per TS by defi nition). When TS 3.12 is not met, a 12-hour shutdown requirement comes into effect.

A review of this condition identified that two partial performances of Procedure SP-45-050.23, "RMS Channel R-23 Control Room Ventilation Radiation Monitor Calibration", were conducted during November 2006 to troubleshoot and repair R-23 while the reactor was critical. Jumpers were installed, per procedure, to disable R-23 trip functions. Installation of jumpers across R-23, as prescribed in Procedure SP-45-050.23, disables the R-23 trip function and places the system in a condition where the surveillance requirement of TS 4.17 is not met.

On two occasions between November 19 and November 30, 2006, jumpers were installed across R-23 for longer than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The lengths of time that these jumpers were installed on these two occasions were approximately 57 hours6.597222e-4 days <br />0.0158 hours <br />9.424603e-5 weeks <br />2.16885e-5 months <br />, and 191 hours0.00221 days <br />0.0531 hours <br />3.158069e-4 weeks <br />7.26755e-5 months <br />. The reactor remained critical throughout these occurrences.

'>1~U.S. NUCLEAR REGULATORY COMMISSION (1-2001)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DOCKET NUMBER (21 LER NUMBER (6)

PAGE (3)

I EQUENTIAL RVSO Kewaunee Power Station 05000305 YEAR NUMSERNUMBER 3 of 4 2007 010 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

The jumpers were subsequently removed and the system restored to operable status.

This event is being reported in accordance with 10 CFR 50.73(a)(2)(i)(B), "Any operation or condition which was prohibited by the plant's Technical Specifications."

Event and Safety Consequence Analysis:

The Control Room Post-Accident Recirculation System is designed to filter the Control Room atmosphere during Control Room isolation conditions. It is part of the Control Room Air Conditioning System and is normally not in operation. Following a postulated accident, the Control Room Post-Accident Recirculation System is designed to automatically start upon safety injection or high radiation signal. R-23 is the radiation monitor at the outlet of the air conditioning unit and serves to automatically provide an initiation signal on high radiation.

If the system is found to be inoperable, there is no immediate threat to the Control Room and reactor operation may continue for a limited period of time while repairs are being made. If one of the two trains of the system cannot be repaired within 7 days, the reactor is placed in hot standby until the repairs are made. If both trains are inoperable, the reactor shall be shut down within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

When the Control Room Post-Accident Recirculation System is in operation, the safety function of R-23, to start the system, is fulfilled. During the periods referenced above when R-23 was isolated from the system in excess of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the Control Room Post-Accident Recirculation System had been placed in operation to meet its safety function (prior to initiation of the work activity). Therefore, the Control Room Post-Accident Recirculation System itself was operating (and fulfilling its safety function) as intended by the TS.

Although the safety function of R-23 was met, the KPS TS are not properly structured to recognize this condition and provide the appropriate allowances. This incongruity was introduced when the rules of usage in TS 4.0 were revised by License Amendment 163 in September 2002. This amendment added the requirement that failure to meet a surveillance requirement, whether such failure is experienced during the performance of the surveillance or between performances of the surveillances, shall be failure to meet the operability requirements for the LCO.

Prior to implementation of License Amendment 163, operators relied on a backup radiation monitor, if R-23 was inoperable, to provide indication of high radiation so that manual initiation of the Control Room Post-Accident Recirculation System could be accomplished if needed. This compensatory measure was based on NRC acceptance of manual initiation of this system, as discussed in the NRC's letter dated July 7, 1983.

Operators would also place the Control Room Post-Accident Recirculation System in a condition where the high radiation initiation signal was fulfilled (i.e., the system was placed in operation). This condition thus satisfied the operability requirements of TS 3.12, allowing the plant to continue power operation. This practice continued following implementation of License Amendment 163 because the effect of the revised rules of usage upon TS 3.12 was not recognized. Although the safety function of the Control Room Post-Accident Recirculation System continued to be fulfilled, the revised TS 4.0 nevertheless states that the operability requirements for the LCO are not met. As such, the 12-hour shutdown requirement is invoked.

There were no events or conditions that could have prevented the fulfillment of the safety function of the Control Room Post-Accident Recirculation System. Since the system was in operation and fulfilling its safetyU.S. NUCLEAR REGULATORY COMMISSION (1-2001)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME 1)

DOCKET NUMBER (21 LER NUMBER (6)

PAGE (3)

SEQUENTIAL REVISION en5000305 YEAR NUMBER NUMBER 4 of 4 2007 010 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17) function during the periods of R-23 inoperability, there was minimal safety significance associated with this event.

Cause

The cause of this condition was a lack of recognition, during implementation of License Amendment 163, that the revised TS 4.0 could render the operability requirements for the LCO in TS 3.12 not met, even when the Control Room Post-Accident Recirculation System was operating and fulfilling its safety function.

Corrective Actions

Administrative controls were implemented to ensure appropriate TS requirements are met during any inoperability of the automatic initiation function of R-23.

A license amendment request was submitted to the NRC on September 14, 2007, which proposed a revision to the KPS TS to address the initiation function of the Control Room Post-Accident Recirculation System, consistent with NUREG-1431, Standard Technical Specifications.

Similar Events

A review of Licensee Event Reports covering the past three years identified the following similar events.

LER 2006-007-00, RCS RTD Cross Calibration Procedure Has The Potential To Exceed The TS LCO Allowed Time Limit LER 2005-015-00, Both Component Cooling Pumps Inoperable When Shifting Running Equipment LER 2005-014-00, Technical Specification LCO Not Entered for Diesel Generators Inoperable While in Refueling Shutdown LER 2004-005-00, Safety Injection Accumulator Isolation Valve Position During Heatup Violates Technical Specifications - Procedure Deficiency LER 2004-004-00, Procedural Deficiency Results in Automatic Containment Ventilation Isolation Being Disabled Contrary to Technical Specifications LER 2004-002-00, Missed Technical Specification Surveillance for Leak Testing In-Core Detectors Prior to Use or Transfer, Due to Inadequate Procedural Guidance