05000354/LER-2004-007, Regarding Technical Specification Noncompliance - Radiation Effluent Monitor on North Plant Vent
| ML043010060 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 10/18/2004 |
| From: | Hutton J Public Service Enterprise Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LR-N04-0467 LER 04-007-00 | |
| Download: ML043010060 (4) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2) 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 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)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(v), Loss of Safety Function |
| 3542004007R00 - NRC Website | |
text
PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 OCT 1 8 2D00 ON PSEG NuclearLLC LR-N04-0467 U.S. Regulatory Commission Document Control Desk Washington, DC 20555 LER 354104-007-00 HOPE CREEK GENERATING STATION - UNIT I FACILITY OPERATING LICENSE NO. NPF-57 DOCKET NO. 50-354 This Licensee Event Report entitled, Technical Specification - Inoperable Radiation Effluent Monitor On North Plant Vent, submitted pursuant to the requirements of 1 OCFR50.73(a)(2)(i)(B).
Sincerely, 0
Lames utn Jlant Manager - Hope Creek Attachment RFY C
Distribution LER File 3.7 I--
~2-.I 95-2168 REV. 7199
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSIO APPROVED BY OMB: NO. 3150-0104 EXPIRES: 06/30/2007 6-2004) the NRC may not conduct or sponsor, and a person Is not required to respond to, the digits/characters for each block)_
- 3. PAGE Hope Creek Generating Station 05000 354 1 OF 3
- 4. TITLE Technical Specification Noncompliance - Radiation Effluent Monitor On North Plant Vent
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED MOT A
ER YA SEQUENTIAL lREV MONTH lDAY lYEAR FACILlTY NAME lDOCKET NUMBER FACILITY NAME DOCKET NUMBER 8
19 2004 2004 - 007 -
00 1 0 18 2004
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANTTO THE REQUIREMENTS OF 10 CFR§: (Check allthatapply) 0 20.2201(b) 0 20.2203(a)(3)(i) 0 50.73(a)(2)(i)(C) 0 50.73(a)(2)(v0i) 1 0 20.2201(d) 0 20.2203(a)(3)(ii) a 50.73(a)(2)(ii)(A) 0 50.73(a)(2)(viii)(A) 0 20.2203(a)(1) 0 20.2203(a)(4) 0 50.73(a)(2)(ii)(B) 0 50.73(a)(2)(viii)(B) 0 20.2203(a)(2)(i) 0 50.36(c)(1)(D(A) 0 50.73(a)(2)(iii) 0 50.73(a)(2)(ix)(A)
- 10. POWER LEVEL 0 20.2203(a)(2)(ii) 0 50.36(c)(1)(ii)(A) 0 50.73(a)(2)(iv)(A) 0 50.73(a)(2)(x)
Cl 20.2203(a)(2)(iii) 0 50.36(c)(2) 0 50.73(a)(2)(v)(A) 0 73.71(a)(4) o 20.2203(a)(2)(iv) 0 50.46(a)(3)(ii) 0 50.73(a)(2)(v)(B) 0 73.71(a)(5) 98 0 20.2203(a)(2)(v) 0 50.73(a)(2)(i)(A) 0 50.73(a)(2)(v)(C) 0 OTHER 0 20.2203(a)(2)(vi)
E 50.73(a)(2)(i)(B) 0 50.73(a)(2)(v)(D)
Specify In Abstract below A, In NR r' Fnrm 3)AFA
- 12. LICENSEE CONTACT FOR THIS LER FACILUY NAME TELEPHONE NUMBER (Include Area Code)
R. Yewdall, Licensing Engineer 856-339-2469MANU-REPORTABLE CAS YSE OMOET MANU-REPORTABLE CAUSE SYST EM COMPONENT FACTURER TO EPIX
CAUSE
T E
COMPONENT FACUETO EPIX
- 14. SUPPLEMENTAL REPORT EXPECTED
- 15. EXPECTED MONTH DAY YEAR SUBMISSION 0 YES (If yes, complete 15. EXPECTED SUBMISSION DATE) 0 NO DATE ABSTRACT (Umit to 1400 spaces, le., approximately 15 single-spaced typewritten lines)
On August 24, 2004 at 1310 while completing a weekly sample collection activity on the North Plant Vent (NPV) radiation monitor skid, a test connection valve was found open. With the valve in the open position, air being monitored by the NPV radiation monitoring system was drawn locally from the room diluting process flow from the NPV. This configuration issue appears to have occurred sometime on August 19, 2004 following corrective maintenance on the NPV monitor skid. With the effluent monitoring system in this condition, required sampling for radioiodine, radioactive particulates and noble gases would have been affected. Inability of proper sampling and monitoring of the NPV radiation monitor is a non-compliance with Technical Specification (TS) 3.3.7.5, Accident Monitoring, and Offsite Dose Calculation Manual (ODCM) 3.3.7.11.
During the period from August19 to August 24, 2004 neither required sampling nor the preplanned alternate monitoring was implemented. The preplanned alternate monitoring was not implemented because the position of the test connection valve which caused this condition was not apparent.
There were no safety consequences associated with this event because the system is not safety related or required for shutdown of the unit. Corrective actions included realignment of the valves to the correct position and capping the test connection and performing a vacuum test to ensure sampling system integrity.
This event is being reported in accordance with I OCFR50.73 (a) (2) (i) (B), Any operation or condition which was prohibited by the plant's Technical Specifications.
NRC FORM 366 (6-2004)U.S. NUCLEAR REGULATORY COMMISSION (1-2001)
LICENSEE EVENT REPORT (LER)
FACILITY NAME (1)
DOCKET (2)
LER NUMBER 6)
PAGE (3)
SEQUENTIAL REVISION YEAR NUMBER NUMBER Hope Creek Generating Station 05000354 2 OF 3 l
._ 2004
- - 007 -
00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)
PLANT AND SYSTEM IDENTIFICATION
General Electric - Boiling Water Reactor (BWR/4)
Radiation Monitoring System {RM/-)*
- Energy Industry Identification System [EIIS) codes and component function identifier codes appear as {SS/CCC)
IDENTIFICATION OF OCCURRENCE Event Date: August 19, 2004 Discovery Date: August 24, 2004 CONDITIONS PRIOR TO OCCURRENCE Hope Creek was in Operating Condition 1 (Power Operation), at the time of discovery. No other required structures, systems or components were inoperable at the start of this event that contributed to the event.
DESCRIPTION OF OCCURRENCE On Tuesday August 24, 2004 at 1310 hours0.0152 days <br />0.364 hours <br />0.00217 weeks <br />4.98455e-4 months <br />, while completing a weekly sample evolution on the North Plant Vent (NPV) radiation monitor {RM) skid, it was observed that the skid was not able to pass the system integrity vacuum test.
Upon investigation it was discovered that valve 1 SPV-081, a sample test connection valve, had been inadvertently left open apparently during corrective maintenance that had been performed on August 19, 2004.
With this valve open, the process flow path for the skid was effectively diluted as room air was drawn into the normal process flow from the North Plant Ventilation ductwork. The physical location of the valve left open on the skid was such that the high, mid and low noble gas monitors, iodine and particulate sampler would have been affected by this oversight. Technical Specification (TS) Section 3.3.7.5 for Accident Monitoring as well as Offsite Dose Calculation Manual (ODCM) Section 3.3.7.11 would have been applicable for the condition described. The preplanned alternate method of monitoring of periodic grab sampling and analysis of the effluent release stream was not established. This is contrary to the requirements of TS 3.3.7.5 and the ODCM.
Upon discovery the condition was rectified by closing the sample test connection valve and installing the end cap. The North Plant Vent radiation monitor system was then declared operable. Though alternate sampling capability was available, it was not recognized that it was required.
During the condition review it was determined that the valve was apparently left open while performing maintenance and calibration using Hope Creek NPV radiation monitor maintenance procedure HC.IC-CC.SP-0015 (Q), Process Radiation Monitoring. The work was managed under Workorder 50061401. The maintenance procedure requires that the test valve be fully closed following maintenance or sampling. Because the sample valve was found open this is a procedure noncompliance problem and not a system component failure.
This event is being reported in accordance with 1 OCFR50.73 (a) (2) (i) (B), Any event or condition which was prohibited by the plant's Technical Specifications. Also requirements of the Hope Creek ODCM section 3.3.7.11 were not complied with.U.S. NUCLEAR REGULATORY COMMISSION (1-2001)
LICENSEE EVENT REPORT (LER)
FACILITY NAME (1)
DOCKE (2)
LER NUMBER (6)
PAGE (3) l SEQUENTIAL REVISION II YEAR NUMBER NUMBER Hope Creek Generating Station 05000354 3 OF 3 l
l 2004
- - 007-00 CAUSE OF OCCURRENCE The cause of this occurrence was due to lack of procedure compliance. Specifically, procedure requirements to isolate the test connection by closing the valve and capping the test connection were not performed. In addition, verification of this activity was not performed.
PREVIOUS OCCURRENCES
A review of LERs for the two prior years at Hope Creek and Salem was performed to determine if similar events had occurred. There were 3 LERs reporting inoperable conditions involving the NPV radiation monitoring system but none were similar to that which caused this event. LER 354103-009 which reported an inoperable condition of the high range monitoring capability of the NPV radiation monitoring condition was related to a nonconforming design condition. While that event did not involve procedure noncompliance it may have been prevented had a full system retest been performed following maintenance on the system.
SAFETY CONSEQUENCES AND IMPLICATIONS
There were no safety consequences associated with this event since it has been determined that during the period of inoperability there were no unplanned or uncontrolled releases from the NPV. During the period of inoperability, inline radiation detectors that monitor potential sources of airborne radioactivity exhausted to the NPV did not detect elevated levels. Had an elevated radiological effluent release occurred from the NPV, the vent sample would have been diluted, thus reducing the assessment capability. However, potential sources of airborne radioactivity that exit by way of the NPV are equipped with inline radiation detection duct monitors. Potential design basis accident sources are monitored by the reactor building ventilation monitoring system and the Filtration, Recirculation, Ventilation System (FRVS) which were not affected by this incident.
A review of this event determined that a Safety System Functional Failure (SSFF) as defined in Nuclear Energy Institute (NEI) 99-02 has not occurred.
CORRECTIVE ACTION
Corrective actions included:
Immediate closure of the sample test connection; A vacuum test on the sampling system skid was performed to ensure system integrity; Human performance issues being addressed in accordance with policies.
COMMITMENTS
This LER contains no Commitments.