05000352/LER-2014-002
| Limerick Generating Station, Unit 1 | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(v)(C), Loss of Safety Function - Release of Radioactive Material |
| Initial Reporting | |
| ENS 49651 | 10 CFR 50.72(b)(3)(v)(C), Loss of Safety Function - Release of Radioactive Material |
| 3522014002R00 - NRC Website | |
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2. DOCKET
2014 - 002 00 Unit Conditions Prior to the Event Unit 1 was in Operational Condition (OPCON) 1 (Power Operation) at 100% power. There were no other structures, systems or components out of service that contributed to this event.
Description of the Event
On Wednesday, December 18, 2013, Limerick Unit 1 was operating at 100% power. At 0939 hours0.0109 days <br />0.261 hours <br />0.00155 weeks <br />3.572895e-4 months <br />, the main control room supervisor was notified that both doors (EIIS:DR) on one reactor enclosure airlock had been briefly opened. The reactor enclosure low pressure alarm (EIIS:ALM) did not actuate during the event and the reactor enclosure pressure did not drop below the Technical Specification limit of 0.25 inch of vacuum water gauge. However, reactor enclosure secondary containment (EIIS:NH) integrity was declared inoperable for the period when both doors were open.
An investigation confirmed that two workers had simultaneously opened the inboard and outboard doors on the reactor enclosure 217 foot elevation airlock for a period of less than 10 seconds. The workers estimated that the airlock door was open 3 inches for one second. The workers immediately re-closed both doors and the breach of secondary containment was terminated. The workers notified Operations shift management of the containment breach.
Technical Specification (TS) 3.6.5.1.1 Reactor Enclosure Secondary Containment Integrity surveillance requirement 4.6.5.1.1.a requires verification that reactor enclosure pressure is greater than or equal to 0.25 inch of vacuum water gauge on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> frequency. The TS surveillance requirement 4.6.5.1.1.b.2 requires at least one door in each access to the reactor enclosure be verified closed on a 31 day frequency. TS 3.6.5.1.1 is applicable in operational conditions (OPCON) 1, 2 and 3.
An 8-hour NRC ENS notification was performed per 10CFR50.72(b)(3)(v)(C) for a condition that at the time of discovery could have prevented fulfillment of a safety function of structures or systems needed to control the release of radioactive material. The ENS notification (#49651) was completed on Wednesday, December 18, 2013, at 1222 hours0.0141 days <br />0.339 hours <br />0.00202 weeks <br />4.64971e-4 months <br /> ET. This LER is being submitted pursuant to the requirements of 10CFR50.73(a)(2)(v)(C) for a condition that could have prevented the fulfillment of the safety function of structures or systems needed to control the release of radioactive material.
NEI 99-02 Revision 7, Regulatory Assessment Performance Indicator Guideline, section 2.2 Mitigating Systems Cornerstone, Safety System Functional Failures, Clarifying Notes, states the following:
Engineering analyses: events in which the licensee declared a system inoperable but an engineering analysis later determined that the system was capable of performing its safety function are not counted, even if the system was removed from service to perform the analysis.
This event will not be reported in the NRC performance indicator (PI) for safety system functional failures (SSFF) since an engineering analysis (technical evaluation) was performed which determined that the system was capable of performing its safety function during events when the airlock was open for less than 10 seconds. The post-LOCA dose calculation does not credit reactor enclosure secondary containment integrity for mitigation of on-site and off-site doses for the first 15.5 minutes of the event. Therefore, this event is bounded by the existing dose calculation.
Analysis of the Event
There was no actual safety consequence associated with this event.
The potential safety consequences of this event were minimal. Both doors on the airlock were open simultaneously for less than 10 seconds.
To prevent a breach of secondary containment each reactor enclosure airlock is equipped with door open indicating lights which are used to locally verify the door status. If both doors are opened simultaneously a local alarm is actuated. If both doors remain open for greater than 10 seconds an alarm is actuated in the main control room and operators are dispatched to verify the airlock doors are closed.
UFSAR 6.2.3.2.1 describes the secondary containment design. The reactor enclosure secondary containment (Zones I and II) are designed to limit the inleakage to 200% of their zone free volume per day, and the refueling area secondary containment (Zone III) is designed to limit the inleakage to 50% of its zone free volume per day. These inleakage rates are based on a negative interior pressure of 0.25 in wg, while operating the standby gas treatment system (SGTS). Following a LOCA the affected zone is maintained at this negative pressure by operation of the SGTS.
Cause of the Event
This event was not prevented by the design of the reactor enclosure airlocks since there is no mechanical interlock and the door open indicating light does not prevent simultaneous opening of both airlock doors.
Corrective Action Planned A modification is being evaluated for the airlock doors.
Previous Similar Occurrences Unit 1 LER 2014-001 was submitted due to a reactor enclosure airlock breach caused by a weakness in the airlock design. Unit 2 LER 2013- 003 was submitted due to a reactor enclosure airlock breach caused by a weakness in the airlock design. Unit 2 LER 2013-002 was submitted due to a reactor enclosure airlock breach caused by a non-functional airlock door open indicating light not providing the correct door status.