05000387/LER-2004-004, Regarding Radiation Monitors Inoperable During Spent Fuel Cask Transport

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Regarding Radiation Monitors Inoperable During Spent Fuel Cask Transport
ML043140278
Person / Time
Site: Susquehanna Talen Energy icon.png
Issue date: 10/18/2004
From: Richard Anderson
Susquehanna
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
PLA-5822 LER 04-004-00
Download: ML043140278 (6)


LER-2004-004, Regarding Radiation Monitors Inoperable During Spent Fuel Cask Transport
Event date:
Report date:
Reporting criterion: 10 CFR 50.73(a)(2)(v), Loss of Safety Function

10 CFR 50.73(a)(2)(i)

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)(i)(B), Prohibited by Technical Specifications
3872004004R00 - NRC Website

text

R. L. Anderson Vice President - Nuclear Operations PPL Susquehanna, LLC 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3883 Fax 570.542-1504 rlanderson~pplweb.com P

Ij T

OCT 1 8 2004 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop OP1-17 Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC.STATION LICENSEE EVENT REPORT 50-387/2004-004-00 PLA-5822 Docket 50-387 Attached is Licensee Event Report 50-387/2004-004-00. This event was determined reportable per 10 CFR 50.73(a)(2)(v)(C) in that radiation monitors in the Unit 1 Railroad Access Shaft were disabled during transport of two Spent Fuel Storage Casks. The disabled monitors would not have initiated automatic re-alignment of the Reactor Building Ventilation System and automatic starts of both the Standby Gas Treatment System and the Control Room Emergency Outside'Air Supply System in response to an actual high radiation condition in the Railroad Shaft. This constitutes a condition that could have prevented the fulfillment of safety functions needed to control the release of radioactive material. Jumpers that had defeated the radiation monitor actuation capability have since been removed. There were no actual consequences to the health and safety of the public as a result of this event.

No new regulatory commitments have been created through issuance of this report.

6EL Richard L. Anderson Vice President - Nuclear Operations Attachment J6 gl,)-

Document Control Desk PLA-5822 cc:

Mr. S. J. Collins Regional Administrator U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19408 Mr. A. J. Blamey Sr. Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 35 Bernvick, PA 18603-0035 Mr. R. Osborne Allegheny Electric Cooperative P. 0. Box 1266 Harrisburg, PA 17108-1266 Mr. R. R. Janati Bureau of Radiation Protection Rachel Carson State Office Building P. 0. Box 8469 Harrisburg, PA 17105-8469

I NRC FORM 366 U.S. NUCLEAR REGULATORY APPROVED BY OMB: NO. 3150-0104 EXPIRES: 06/30/2007

6-2004)

Esimated, the NRC (See reverse for required number of may not conduct or sponsor, and a person Is not required to respond to, the digits/characters for each block) nformation collection.

1. FACILITY NAME Susquehanna Steam Electric Station - Unit 1
2. DOCKET NUMBER PAGE 05000387 1 OF4
4. TITLE Radiation Monitors Inoperable During Spent Fuel Cask Transport
5. EVENT DATE
6. LER NUMBER
7. REPORT DATE
8. OTHER FACILMES INVOLVED MONTH DAY YEAR YEAR SENUENTIAL REV MONTH DAY YEAR FACILITY NAME OCKETNUMBER NUMBER NO. l" 1

I SUSq. SES - Unit 2 500O0388 FACILITY NAME OCKET NUMBER 08 20 2004 2004 -004 00 10 18 2004 5000

9. OPERATING MODE 11.THIS REPORTIS SUBMI tED PURSUANTTOTHE REQUIREMENTS OF10CFR 5: (Checkall thatapply) 1 0 20.2201(b) 0 20.2203(a)(3)(i) 0 50.73(a)(2)(i)(C) 0 50.73(a)(2Xvii)
10. POWER LEVEL El 20.2201(d) 0 20.2203(a)(3)(ii)

[I 50.73(a)(2)(ii)(A) 0 50.73(a)(2)(viii)(A) 100 0 20.2203(a)(1) a 20.2203(a)(4)

E 50.73(a)(2)(ii)(B) 0 50.73(a)(2)(viii)(B) 0 20.2203(a)(2)(i) 0 50.36(c)(1)(i)(A) a 50.73(a)(2)(iii) 0 50.73(a)(2)(ix)(A) 0 20.2203(a)(2)(ii)

El 50.36(c)(1)(ii)(A)

G 50.73(a)(2)(iv)(A) 0 50.73(a)(2)(x) 0 20.2203(a)(2)(iii) 0 50.36(c)(2) 0 50.73(a)(2)(v)(A) 0 73.71 (a)(4) 0 20.2203(a)(2)(iv)

[I 50.46(a)(3)(ii) 0 50.73(a)(2)(v)(B) 0 73.71 (a)(5) o 20.2203(a)(2)(v) 0 50.73(a)(2)(i)(A)

M 50.73(a)(2)(v)(C)

El OTHER El 20.2203(a)(2)(vi) 0 50.73(a)(2)(i)(B)

O 50.73(a)(2)(v)(D)

Specify In abstract below or In (if more space is required, use addtiioaI copies of NRC Fom 3664)

EVENT DESCRIPTION

On 8/20/2004, while performing a surveillance on the Railroad Access Shaft Radiation Monitors (EIIS Code:

IL), Instrumentation & Control (I&C) technicians (Utility, Non-Licensed) discovered that the Secondary Containment Zone III isolation relays (EI1S Code: JM) of both process radiation monitors in the Railroad Access Shaft were disabled. Investigation determined that the instrumentation trip outputs had been bypassed on 7/16/2004 through inappropriate jumper installation. I&C technicians tasked to defeat the local audible alarm on a separate area radiation monitor mistakenly executed steps of a plant procedure that also defeated the trip outputs of the two process radiation monitors in question. This discovery was significant because two Spent Fuel Storage Casks (EIIS Code: DF) containing irradiated fuel had been lowered from the Refueling Floor during this period of time (8/2/2004 and 8/16/2004). Plant Technical Specifications (TS) 3.3.6.2 and 3.3.7.1 require the Railroad Access Shaft radiation monitors to be operable during movement of irradiated fuel assemblies within the Railroad Access Shaft. Because actual transfer times for both lifts were less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, TS Required Action completion times were not exceeded. In the event of an actual radioactive material release, the disabled radiation monitors would not have, however, initiated automatic re-alignment of the Reactor Building Zone III Ventilation System (EIIS Code: VA), automatic start of the Standby Gas Treatment System (SGTS; EH1S Code: BH) and automatic start of the Control Room Emergency Outside Air Supply System (CREOASS; EIIS Code: VI). The inability of these systems to respond to radiological conditions in the Railroad Access Shaft constitutes a condition that could have prevented the fulfillment of safety functions needed to control the release of radioactive material and is reportable per 10 CER 50.73(a)(2)(v)(C). Actual radiological conditions observed in the Railroad Shaft during movement of the casks did not approach levels necessary for system actuation. All other Reactor Building ventilation instrumentation capable of actuating these systems was operable as required by TS. The jumpers that defeated the actuation capability of the Railroad Access Shaft Process Radiation Monitors were removed on 8/20/2004. No radioactive releases resulted from this event.

CAUSE OF EVENT

Two root causes have been identified for this event:

  • Less-Than-Adequate Work Practices - Bypass of the process radiation monitor trip functions was outside the scope and instructions of the work plan. Neither a pre-job walkdown nor a supervised pre-job briefing was conducted.
  • Less-Than-Adequate Procedural Direction - The controlling procedure assumes that the local alarm horn on the area radiation monitor must be disabled during movement of the Spent Fuel Cask and incorporates a prerequisite to confirm task completion. This prerequisite is not confirmed by the work group that performs the task but by an operator (Utility, Licensed) who verifies work completion through status control logs.

When work was performed beyond the intended work scope, the occurrence was not adequately captured in the status control log. Further, the need to bypass the local alarm is suspect as observations made during actual cask movement suggest that radiation levels do not approach the area radiation monitor alarm setpoint.

(if more space s required wse addbccnal ccpies of (If rore space is required, use adclonal ccpies of NRC For 364)

ADDITIONAL INFORMATION

Failed Component Information:

None

Previous Similar Events

LER 2002-002-00, Docket No. 388 / License No. NPF-22, "Loss of Control Structure Safety Function When 4.16 kV Breakers Found Racked-Out" LER 2003-003-00, Docket No. 387 / License No. NPF-14, "Both Trains of Standby Gas Treatment Inoperable Due to Inadequate Maintenance and Inadequate Operability Testing"