05000327/LER-2004-002, Regarding Failure to Comply

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Regarding Failure to Comply
ML043640205
Person / Time
Site: Sequoyah 
(DPR-077)
Issue date: 12/27/2004
From: Pace P
Tennessee Valley Authority
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LER 04-002-00
Download: ML043640205 (7)


LER-2004-002, Regarding Failure to Comply
Event date:
Report date:
Reporting criterion: 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications

10 CFR 50.73(a)(2)(v), Loss of Safety Function
3272004002R00 - NRC Website

text

December 27, 2004 U.S. Nuclear Regulatory Commission 10 CFR 50.73 ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

TENNESSEE VALLEY AUTHORITY - SEQUOYAH NUCLEAR PLANT UNIT 1 -

DOCKET NO. 50-327 - FACILITY OPERATING LICENSE DPR LICENSEE EVENT REPORT (LER) 50-327/2004-002-00 The enclosed LER provides details concerning a failure to initiate an immediate boration of the reactor coolant system when the boron concentration was determined to be below the technical specification limit. This event is being reported, in accordance with 10 CFR 50.73(a)(2)(i)(B), as an operation prohibited by technical specifications.

Sincerely, Original signed by:

P. L. Pace Manager, Site Licensing and Industry Affairs Enclosure cc (Enclosure)

INPO Records Center Institute of Nuclear Power Operations 700 Galleria Parkway Atlanta, Georgia 30339-5957

Abstract

On November 11, 2004, it was determined that there was a failure to comply with Technical Specification (TS) 3.9.1. TS 3.9.1 requires immediately initiating boration of the RCS after it is determined that the reactor coolant system (RCS) boron concentration is below TS limits. TVA personnel reviewed Operations logs and determined that compliance with TS had not been performed as required. On October 28, 2004, at approximately 0418 Eastern daylight time (EDT), Chemistry personnel notified Operations personnel that the Unit 1 RCS boron concentration had been at 1999 parts per million (ppm) as early as 0010. Operations personnel entered TS Limiting Condition for Operation (LCO) 3.9.1 action because the RCS boron concentration was below the TS limit of 2000 ppm. Operations personnel immediately initiated boration of Unit 1 RCS. This event is being reported as an operation prohibited by TS since the TS requires immediately suspending all operations involving core alterations or positive reactivity changes and initiate and continue boration at greater than or equal to 35 gallons per minute (gpm). Operations did not initiate boration of the RCS earlier because Chemistry personnel did not inform Operations of the out-of-limits condition. Chemistry personnel were unaware that Unit 1 had entered Mode 6 at 2357 on October 27, thus requiring a minimum RCS boron concentration of 2000 ppm. The cause of the event was failure to establish adequate margin to the RCS boron concentration limit prior to entering Mode 6. The personnel involved in the transition to Mode 6 were counseled on establishing adequate margins, anticipating changes in plant conditions and adequately communicating within and between departments; and appropriate procedures are being revised to provide provisions for requiring a margin to the 2000 ppm limit.

NRC FORM 366 (7-2001)

(If more space is required, use additional copies of (If more space is required, use additional copies of (If more space is required, use additional copies of (If more space is required, use additional copies of (If more space is required, use additional copies of NRC Form 366A) (17) VII.

ADDITIONAL INFORMATION

A.

Failed Components:

None B.

Previous LERs on Similar Events:

A review of previous reportable events for the past three years did not identify any

previous similar events

C.

Additional Information

None.

D.

Safety System Functional Failure:

This event did not result in a safety system functional failure in accordance with 10 CFR 50.73(a)(2)(v).

E.

Loss of Normal Heat Removal Consideration This event did not result in a loss of normal heat sink because the plant was in Mode 6.

VIII.

COMMITMENTS

None.