05000397/LER-2012-002, Regarding Technical Specification Non-Compliance Due to Inadequate Procedure Guidance

Regarding Technical Specification Non-Compliance Due to Inadequate Procedure Guidance

ML12088A035
Person / Time
Site:	Columbia
Issue date:	03/15/2012
From:	Sawatzke B Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-12-039 LER 12-002-00
Download: ML12088A035 (4)

LER-2012-002, Regarding Technical Specification Non-Compliance Due to Inadequate Procedure Guidance

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
3972012002R00 - NRC Website

text

Bradley J. Sawatzke Columbia Generating Station ENERGY PO o 6,P0 i;

• _*Richland, WA 99352-0968 NORTH EST Ph. 509.377.43001 F. 509.377.4150 bjsawatzke @energy-northwest.com March 15, 2012 G02-12-039 10 CFR 50.73 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 LICENSEE EVENT REPORT NO. 2012-002-00

Dear Sir or Madam:

Transmitted herewith is Licensee Event Report No. 2012-002-00 for Columbia Generating Station. This report is submitted pursuant to 10 CFR 50.73(a)(2)(i)(B).

There are no commitments being made to the NRC herein. If you have any questions or require additional information, please contact Mr. ZK Dunham at (509) 377-4735.

Respectfully, BJ awtk Vice President, Nuclear Generation & Chief Nuclear Officer

Enclosure:

Licensee Event Report 2012-002-00 cc: NRC Region IV Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C RN Sherman - BPN1 399 WA Horin - Winston & Strawn

T4 NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-01104 EXPIRES 10/31/2013 (10-2010)

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

3. PAGE Columbia Generating Station 05000397 1 OF3

4. TITLE Technical Specification Non-Compliance Due to Inadequate Procedure Guidance

5. EVENT DATE

6. LER NUMBER

7. REPORT DATE

8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR SEQUENTIAL I REV MONTH DAY YEAR FACILITY NAME DOCKET NUMBER NUMBER NO.

05000 FACILITY NAME DOCKET NUMBER 01 17 2012 2012 - 002 - 00 03 15 2012 05000

9. OPERATING MODE

11. THIS REPORT IS SUBMITTED PURSUANT TO THE RgEUIREMENTS OF 10 CFR §: (Check all that apply) 1 El 20.2201(b)

El 20.2203(a)(3)(i)

[I 50.73(a)(2)(i)(C)

[I 50.73(a)(2)(vii)

El 20.2201(d)

El 20.2203(a)(3)(ii)

[l 50.73(a)(2)(ii)(A)

El 50.73(a)(2)(viii)(A)

El 20.2203 (a)(1)

El 20.2203(a)(4)

[I 50.73(a)(2)(ii)(B)

[I 50.73(a)(2)(viii)(B) 20.2203(a)(2)(i)

Cl 50.36(c)(1)(i)(A)

[I 50.73(a)(2)(iii)

El 50.73(a)(2)(ix)(A)

10. POWER LEVEL El 20.2203(a)(2)(ii)

[I 50.36(c)(1)(ii)(A)

[I 50.73(a)(2)(iv)(A)

El 50.73(a)(2)(x) 100 El 20.2203(a)(2)(iii)

El 50.36(c)(2) 0l 50.73(a)(2)(v)(A)

El 73.71 (a)(4)

El 20.2203(a)(2)(iv)

El 50.46(a)(3)(ii)

El 50.73(a)(2)(v)(B)

El 73.71 (a)(5)

El 20.2203(a)(2)(v)

El 50.73(a)(2)(i)(A)

El 50.73(a)(2)(v)(C)

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

El 50.73(a)(2)(v)(D)

Specify in Abstract below or in Further Corrective Actions Planned corrective actions include clarifying the requirements for continuous communication and the duties of the dedicated individual and specifying a maximum timeframe for restoring the CRE boundary as supported by the existing DBA calculations. Those work activities that may not be able to meet the restoration time requirements will be evaluated to determine the required actions prior to being worked. Other planned corrective actions include revising PPM 1.3.57 and providing training to affected personnel.

A review was performed on other barrier impairments which were opened since TSTF-448 was implemented at Columbia and which affected the control room ventilation boundary. No other cases were found in which the Required Actions and Completion Times of TSAS 3.7.3.B were not met.

Assessment of Safety Consequences

There were no actual safety consequences associated with this event since no events involving radiological hazards were experienced during the work activities. If a radiological event had occurred during the maintenance activities, the Division 2 CREF system would have started as required. Since there was communication between the two divisions of CREF on the outlet side during the maintenance, there would be a delay in pressurizing the control room due to air flow out the breach. However, there would not be an increase in unfiltered in-leakage. Engineering calculations establish that adequate time was available to close the access panel prior to control room occupant exposures reaching the 10 CFR 50.67 limit of 5 rem TEDE. In addition, engineering analysis indicates that the access panel could be installed with a minimum of four bolts to restore the CRE boundary.

Similar Events

LER 2004-001 -00 reported the unanticipated inoperability of both CREF subsystems when common ducts for both CREF subsystems were breached multiple times by removing duct access panels to install and remove test equipment. The cause is attributed to inadequate guidance in the Columbia Generating Station barrier impairment procedure. The cause of the inadequate guidance in the procedure was a lack of understanding of regulatory guidance associated with barrier impairments.

LER 2003-012-00 reported unanticipated inoperability of both CREF subsystems when the normal and both remote outside air intakes for the CREF system were manually isolated for a period of approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during testing to measure control room in-leakage. The cause of this event is attributed to inadequate preparation and review of the test procedure used to measure control room in-leakage.

Energy Industry Identification System (EIIS) Information EIIS codes are bracketed [ ] where applicable in the narrative.

26158 R5