05000461/FIN-2008005-02
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Finding | |
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Title | Maintenance Rule Scoping Question for Liquid Effluent Process Radiation Monitors |
Description | The inspectors reviewed equipment performance issues associated with radiation monitoring system instrumentation and found that Maintenance Rule evaluations were not being performed for liquid effluent process radiation monitor failures. The inspectors noted that liquid effluent process radiation monitors had not been included within the scope of the licensee s Maintenance Rule Monitoring Program and sufficient information or justification was not provided in the licensee s scoping determination documents to support the conclusion that was reached. The inspectors noted that in accordance with 10 CFR 50.65(b)(2)(i), non-safety-related SSCs that are used in plant Emergency Operating Procedures (EOPs) are required to be included in the scope of the licensee s Maintenance Rule Monitoring Program. The inspectors reviewed the plant s EOPs and discovered that the entry condition for EOP-9, Radioactivity Release Control, was any offsite liquid or gaseous release rate above the licensee s Emergency Plan Radiological Effluent Alert level. The inspectors reviewed EP-AA-1003, Exelon Nuclear Radiological Emergency Plan Annex for Clinton Station, Revision 13, and found that one of the three Emergency Action Level threshold values under the Emergency Plan Radiological Effluent Alert level was a valid reading on any effluent monitor > 200 times the high alarm setpoint established by a current radioactivity discharge permit for Y 15 minutes. The inspectors discussed this criterion with two licensed senior reactor operators at the plant (the Shift Operations Superintendent and a Shift Manager) to understand which liquid effluent monitors would be used by operators to evaluate this criterion since no specific monitors were listed in the Emergency Action Level Matrix. The following liquid effluent radiation monitors were identified: • 0RIX-PR040 C Liquid Radwaste Discharge Process Radiation Monitor (currently not an active discharge pathway) • 1RIX-PR036 C Plant Service Water Effluent Process Radiation Monitor • 1RIX-PR037 C Component Cooling Water Process Radiation Monitor • 1RIX-PR038 C Division 1 Shutdown Service Water Effluent Process Radiation Monitor • 1RIX-PR039 C Division 2 Shutdown Service Water Effluent Process Radiation Monitor • 1RIX-PR004 C Train A Fuel Pool Heat Exchanger Service Water Radiation Monitor • 1RIX-PR005 C Train B Fuel Pool Heat Exchanger Service Water Radiation Monitor The licensee wrote AR 00854497 to address questions raised by the inspectors regarding scoping of these liquid effluent process radiation monitors within its Maintenance Rule Monitoring Program. This issue is considered to be an Unresolved Item (URI 05000461/2008005-02) pending additional review |
Site: | Clinton |
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Report | IR 05000461/2008005 Section 1R12 |
Date counted | Dec 31, 2008 (2008Q4) |
Type: | URI: |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.12 |
Inspectors (proximate) | R Winter N Valos G Hausman B Kemker M Ring S Mischke D Lords N Feliz-Adomoa Scarbearyb Kemker D Lords J Bozga M Mitchell M Ring S Mischke |
INPO aspect | |
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Finding - Clinton - IR 05000461/2008005 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Clinton) @ 2008Q4
Self-Identified List (Clinton)
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