05000368/LER-2009-002, Containment Building Penetration Isolation Valves Open During Core Alterations W/O Application of Administrative Controls Required by Technical Specifications Due to Inadequate Procedure Instructions

Containment Building Penetration Isolation Valves Open During Core Alterations W/O Application of Administrative Controls Required by Technical Specifications Due to Inadequate Procedure Instructions

ML093090687
Person / Time
Site:	Arkansas Nuclear
Issue date:	11/05/2009
From:	David Bice Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2CAN110903 LER 09-002-00
Download: ML093090687 (8)

LER-2009-002, Containment Building Penetration Isolation Valves Open During Core Alterations W/O Application of Administrative Controls Required by Technical Specifications Due to Inadequate Procedure Instructions

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)(vii), Common Cause Inoperability 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
3682009002R00 - NRC Website

text

2CAN110903 November 5, 2009 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Licensee Event Report 50-368/2009-002-00 Arkansas Nuclear One - Unit 2 Docket No. 50-368 License No. NPF-6

Dear Sir or Madam:

In accordance with 10CFR50.73(a)(2)(i)(B), enclosed is the subject report concerning a condition prohibited by Technical Specifications.

A commitment contained in this submittal is documented in the attachment.

Sincerely, DBB/fpv Enclosure - LER 50-368/2009-002-00 Attachment - List of Regulatory Commitments Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-4710 David B. Bice Acting Manager, Licensing Arkansas Nuclear One

2CAN110903 Page 2 of 2 cc:

Mr. Elmo Collins Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 NRC Senior Resident Inspector Arkansas Nuclear One P.O. Box 310 London, AR 72847 Institute of Nuclear Power Operations 700 Galleria Parkway Atlanta, GA 30339-5957 LEREvents@inpo.org

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION (9-2007)

LICENSEE EVENT REPORT (LER)

(See reverse for required number of digits/characters for each block)

APPROVED BY OMB NO. 3150-0104 EXPIRES 8/31/2010

, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

3. PAGE Arkansas Nuclear One, Unit 2 05000368 1

OF 4

4. TITLE Containment Building Penetration Isolation Valves Open during Core Alterations without Application of Administrative Controls Required by Technical Specifications due to Inadequate Procedure Instructions.

5. EVENT DATE

6. LER NUMBER

7. REPORT DATE

8. OTHER FACILITIES INVOLVED FACILITY NAME MONTH DAY YEAR YEAR SEQUENTIAL NUMBER REV NO MONTH DAY YEAR DOCKET NUMBER FACILITY NAME 09 07 2009 2009 - 002 - 00 11 06 2009 DOCKET NUMBER

9. OPERATING MODE

11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply) 20.2201(b) 20.2203(a)(3)(i) 50.73(a)(2)(i)(C) 50.73(a)(2)(vii) 20.2201(d) 20.2203(a)(3)(ii) 50.73(a)(2)(ii)(A) 50.73(a)(2)(viii)(A) 20.2203(a)(1) 20.2203(a)(4) 50.73(a)(2)(ii)(B) 50.73(a)(2)(viii)(B) 6 20.2203(a)(2)(i) 50.36(c)(1)(i)(A) 50.73(a)(2)(iii) 50.73(a)(2)(ix)(A)

10. POWER LEVEL 20.2203(a)(2)(ii) 50.36(c)(1)(ii)(A) 50.73(a)(2)(iv)(A) 50.73(a)(2)(x) 20.2203(a)(2)(iii) 50.36(c)(2) 50.73(a)(2)(v)(A) 73.71(a)(4) 20.2203(a)(2)(iv) 50.46(a)(3)(ii) 50.73(a)(2)(v)(B) 73.71(a)(5) 20.2203(a)(2)(v) 50.73(a)(2)(i)(A) 50.73(a)(2)(v)(C)

OTHER-Specify in Abstract below or in

D. Corrective Actions

Immediate action was taken to verify that all Containment Atmosphere Monitoring System penetration isolation valves were closed and to apply appropriate containment closure controls.

Caution cards were installed on valves used to align the system for oxygen and pressure control with instructions to verify that containment closure requirements are determined prior to opening.

To maintain continuous containment atmosphere sample flow, the penetration isolation valves for this system remain open when in their normal alignment. During plant operations in Modes 1-4, these isolation valves receive automatic closure signals from the Containment Isolation Actuation System or Safety Injection Actuation System [JE]. Procedure changes are in progress that will establish a containment to containment flow path as the normal system valve alignment, rather than the alignment for oxygen and pressure control. This change will provide an explicit system alignment to be established following testing activities that will restore containment closure for penetrations in this system.

E. Safety Significance

At the time of this event, ANO-2 was in mode 6 for refueling, and the reactor had been shutdown for greater than 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />. There was no actual failure or degradation of equipment and no safety concern due to the small diameter of the piping involved. Additionally, normal ventilation systems were in service providing a filtered and monitored pathway for effluents from the auxiliary building atmosphere. It has been determined that there was no potential for a release resulting from a fuel handling accident that would exceed the limits of 10CFR100 at the site boundary.

F. Basis for Reportability ANO-2 Technical Specification 3.9.4 requires that, during core alterations, each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be closed by a manual or automatic isolation valve, blind flange, or equivalent. This requirement is modified by a note stating that penetration flow path(s) providing direct access from the containment atmosphere to the outside atmosphere may be un-isolated under administrative controls. The aforementioned condition resulted in an open containment penetration pathway during core alterations that existed without application of the administrative controls required by the Technical Specification. Therefore, this event is reportable pursuant to 10CFR50.73(a)(2)(i)(B) as a condition prohibited by Technical Specifications.

G. Additional Information

There have been no previous similar events reported by ANO.

Energy Industry Identification System (EIIS) codes are identified in the text as [XX].

Attachment to 2CAN110903 List of Regulatory Commitments

Attachment to 2CAN110903 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

COMMITMENT

TYPE (Check One)

SCHEDULED COMPLETION DATE (If Required)

ONE TIME ACTION CONTINUING COMPLIANCE Revise procedure OP-2104.044 Containment Hydrogen Control Operations to establish the normal valve lineup for the Containment Atmosphere Monitoring System to be configured for Containment-to-Containment sample flow rather than aligned for oxygen and pressure control.

X 3/1/2010