ML18058A288

From kanterella
Jump to navigation Jump to search
LER 92-012-00:on 920214,determined That Main Steam Line Radiation Elements Not Environmentally Qualified.Caused by Personnel Error.Main Steam Line Radiation Elements Will Be Modified or Justification Will Be provided.W/920316 Ltr
ML18058A288
Person / Time
Site: Palisades Entergy icon.png
Issue date: 03/16/1992
From: Hillman C, Slade G
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-92-012, LER-92-12, NUDOCS 9203230375
Download: ML18058A288 (5)
v • d • e


Text

consumers Pow_er. GB Slade .

General Manager .

  • POWERiNii

.. /llllUllliAN-S PllOliRE.SS PaliSades Nuclear Plant: *. 27780 Blue Star Memorial Highway, Covert, Ml 49043

  • March 16, 1992 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE .DPR PALISADES PLANT - * . .
  • LICENSEE EVENT REPORT.92-012; LACK OF ENVIRONMENTAL QUALIFICATION FOR THE.MAIN STEAM LINE RADIATION ELEMENTS RE-2323 AND RE-2324 Licensee Event Report (LER)92-012 is attached. This event is reportable to the NRC per 10CFR50.73(a)(2)(ii)(B) as a condition outside the ~esign basfs of

. the pl ant.

  • .~/~4</~*-*

Gerald B Slade General Manager CC Administrator, Region Ill, USNRC NRC Resident Inspector - Palisades Attachment

,...... -~ ("'. **: *f .........

'- 0 U' J__ :_ ()

75 920316 .

9~032 303 05000255 PDR ADOC~ PDR A CM5 ENERGY COMPANY s

NRC . . . . . U.I . ..CLIAR *IGULAToilY CI .....19-831 a-ov10 Diii NO. :t11D-010I IXl'IRll: I/JI -

LICENSEE EVENT REPORT CLER)

'AC,ILITY _._Ill ' IDOCICIT __. .. l:tl

  • I - - 1:111 Palisades Plant 0 115 I 0 I 0 I 0 12 1' 51 5 , IOF. 0 14 TITLI "' LACK. OF ENVIRONMENTAL QUALiFICATION. FOR THE MAIN STEAM LINE RAnIATION ELEMENTS RE-2J23 AND RE-2324 VINT DATI Ill LIRN~Rlll* *ll'OflTDATll71 OTMIR PllCILITIU !NV 'I
  • FACl~ITY NAMU OQCIC.IT NUMllRlll H QAY. YIAR N/A 01 2 114 9 ~ 2- . ~* 11 2~ q0 0 13 11 6 9 I 2 NI A n NT TO THI RIQUIHMINTI OF 10 C'll §: fo.dt - .of Ille '91~

111 -

°"""""°

....._.---~........--- IO.Cl(~I I _*

....._.____ IO.Glol 111.f:ttlllllllwl 71.711111

~~ .-1a11111** 111.ac.1111 111.nlllllllwl 71.71lal

-.1101. 0 10 I *.-1a1111111 111.a1111:t1 111.nlallllMll OTMIR 11-1'1- I n - *

- M d In r ..r. NflC , _

lll!llllltf:~ =~:~ -

. lll.71WllllUI 111.'PllllllUwlllllAI .u.J

~

x

  • lll.71c.lllllMI 111.71191111111111111 lll.7:tCllllll1111 lil.nc.11211.1 LICINIH CONTACT '011 TMll Liii llJI lllAME TILll'HOllll ARIA CODE Cris T Hillman, Staff Licensing Engineer ~ I l I 6 71 6 14 I - I 8 19 I 11
  • COMl'LITI Ollll.LINI '011 1ACM .U II llD . Ill llflC ( Ill MAlllUFAC* ~ El'ORT AB LE :;:: ::::: :;:;: :;:: :;:: ;.;.:;::::::::::<:

CAUSE SYSTEM COMl'OlllElllT TUR ER TO. lllPRDS -:::* *:*:* :*:*: :*:* :::* .;.: -:-:-:-:-: :::- CAUSE SYSTEM COM.'°llllllT.

. *>:**:*:**>:*.:*:**:*:* *=*=*

I I I. I I I I  ::::*:.:*:.:.:*::::::::::.:-: I *. I I* I I I I I . I I . I I I I I I I I I** I . I

  • .I II rAI II I 'I 'I IXPICTED
  • 9UIMllS10111 MOlllT DAY 1J

~~ES (If l'W......... llX/llCTllD llJllllSSION DATii! DATE f151 I I I ABSTRACT On February 14, 1992, at approximately 0800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br />, it was determined that the

  • main st~am lirie radiation elements (RE-2323 and RE-2324} were not environmentally qualified as required by Regulatory Guide 1.97 and 10 CFR 50.49. At the time the determination was made, the plant was in* cold*

. shutdown for the 1992 refueling o~tage.

Th~ root cause of this event appears to be pers6nnel error in that ther~ was a lack of attention to detail in both the modification which installed the main steam line radiation elements and the development of the list of RG 1;97

  • variables. *
  • The corrective action for this event is to either modify the main steam line radiation elements to meet.the requirements of RG 1.97, Category 2 or provide justification fo~ an exemption to the requirements of RG 1.97 for these instruments.

NllCF--

19.. 31

." i ""'C~U.* *ICl\,,AT:l** ::.Mo**Oli!

LICENSEE E T REPORT ILEA! TEXT CONTINUAT "-0\'IO OWi "0 J*to~;a.*

          • u *...,,"

OOClllT ~** IJI Palisades Plant 0 . s 0 0 0 2 5 5 9 2 ~ 0 1 2 - 0 0 0 2 011 0 . 4 EVENT DESCRIPTION On February 14, 1992, at approximately *oaori hours, it was determined that the mairi steam line radiation elemehts (RE-2323 ~nd RE-2324) [SB;RE] were not environmentally qualified as required by Regulatory Guide (RG) 1.97 and 10 CFR 50.49. At the time the determination was made, the plant was in cold shutdown for the 1992 refu~ling outage. RE-2323 and RE-2324 are designated as.

the radiation elements which fulfill the NUREG 0737 requirement for post accident ~onitoring of radioactive noble gas as described in the* Palisades Final Safety Analysis Report (FSAR), Appendix 7C, Item E03B. -

This event is reportable to the NRC per 10CFR50.73(a)(2)(ii)(B) as a cbndition outside the ~esign basis of the plant~ *

  • CAUSE OF THE .EVENT The roQt cause of this deviation app~*ars to be personnel error in that there was a lack of attentiori to detail in both the modification which installed the main steam line radiation elements and the development of the list of RG 1.97

. variables. During th~ early.1980s there were a significant numbe~ of*

initiativ~s underway which resulted from the TMI accident. These initiative~

included incorporating design changes mandated by NUREG-0737, performing the Palisade_s Systematic Evaluation Program (SEP) and developing the environmental qualification program. *There appear~ to have been a lack of coordination and communication between the various individualS performing these activities.

I. This lack of coordination and communication appears to have resulted in the Ii individuals not being cognizant of the fact that the roo~ where the main steam line elements were located was considered a harsh environment.

I i

This event did not involve the.failure of any equipment important to safety.

I ANALYSIS OF THE EVENT I . . I The mai~ steam line radiation elements (RE-2323 and RE-2324) were installed in I 1981 in response NUREG-0737, Item II.F.l "Additional Accident Monitoring I . Instrumentation," to provide indication of releases of radioactive fission product gases from the plant. The main steam line radiation elements were II *specifically provided to monitor potenti~l releases *via the atmospheric steam:.

dumps and/or secondary system safety relief valves. The design requirements for the post accident effluent radiation monitors were provided in Table II~F~l-1 of NUREG-0737. This table required that the radiation instrumentation be qualified to " ... provide sufficient7j accurate responses to

  • _*} perform the intended function in the environment to which they wi77. be exposed during accidents." *
  • ,i The main steam line radiation elem~nts are installed in the m~in stea~ line I penetration room which is located directly above the *component cooling w~ter I* (CCW) room. This area is defined as a h~rsh environmerit for a main steam line

! break MSLB accident outside -Of containment~. Althoug~ the radiation elements

,*c *0*11,._

~-.UI

...c ......... .

iMJI. ", .* ..,c~u* *IQ*""'~** ::.-1 .,°"'

  • -01110 owt "o i*to~*~

.~ . *****u ,,.,, u OOClllT ....,_,. 111

~** ~. '" *&QI 'JI

  • Palisades. Plant

.!!'!' ,. _ - * .--. - __ ,. ......." 1171

. were installed in a harsh environment, the facility change {FC-494-5) ~hich incorporated th~se instruments into.the plant made no mention of special .

envir6nmental conditjons to be .considered as. part of the design. As a re$ult, the radiation elem~nts were procured as non-Class lf equipment. No *

. environmental qualification de$ign features were discussed in*the purchase documentation. * . *

  • NUREG-0737-Requirements for Emergency Response Capability." This generic letter required that each licensee pro~ide instrumentation meeting the I.

requirements of RG 1.9? to assess plant and environs tonditions during and following an accident. RG l*.97, Table 3, provides a list of variables to* be included in pressuriz~d water reactor (PWR) designs. In this table, stea~

generator safety relief valves and/or atmospheric dump valves. are listed as locations where airborne radioactive material~ which could potentially be released froili the plant are to be monitored. *Table 3 bf RG 1.97 classifies the main steam line radiation element$ as Category 2. Category 2 instruments are to be environmentally qualified a~ defined by lable 2, Item 1, of the RG 1.97.

Ori September 13, 1983, Consumers Power Company provided to the NRC i~for~ation

  • related tb Palisade~ conformance to* the requirements of RG .1.97. 'This letter indicated that the main steam line radiation elements (RE-2323 and RE-2324) c*omp lied with the requirements of RG 1. 97, Category *2, including requirements.

related to environmental qualification. Information provided in this and subseq~~nt letters to the NRC formed the basis fbr the de~elopment of the Palisades Final Safety Analysis Report. (FSAR), Appendix 7C, which indicates the extent of Palisades compliance with RG 1.97.

The main-steam line radiation. monitors are required to be operable above 325°F*

by Technical Specification Table 3 .. 24-2, Item 5. Due to the requirements relat~d to the locatton of the electronics in relation to the detector, the main steam lin~ radiation elements (RE-2323 and RE-2324) cannot be relocated outside of the area where they are presently located .. As these elements are not qualified as descrtb~d in the FSAR, they were declared inoper~ble. For I this condition, the Palisades Technical Specifications, Table 3.24-2, Item Sa, I requires that the pre-planned alternate method of monitoring main steam line I radiation be implemented and that a special report be provided to.the NRC within 30 days of the event. The alternate method of ~onitoring post accident I! main st~am line radiation is to utilize radiation ~onitors iristall~d on the

  • auxiliary build-Ing roof. .This 11lternative method of monitoring radibactive effluent nob 1e gases wil 1. be employed until the corrective action for this event can be implemented.
  • I I CORRECTIVE ACTION I The corrective action for this event is to either modify the main steam line radiation elements to meet the requirements of RG 1.97, Category 2 or provide.

iI justification for an exemption to the requirements of RG 1.97 for these**.

instruments. This activity will be completed in the 1993 refueling outage.

...c .......

  • MJI .

LICENSEE . T REPORT ILERI TEXT.CONTINUA.

"1 *wc~u.a '°""':i** :~***o

..-ov10 ~wi ..o i*1e...,**:>o OOCUT ""'91* IJI

~** ~. '" *AOI !JI "Palisades Plant*

~'*--*.-.--lflC,.... .. *111111 A complete review of all RG.l.97, Category 2; variables was performed by the Configuration Control -Project in response to this and other deviation reports

  • where non-environmentally qualified instruments were identified. This review identified a*total of three RG 1.97, Category 2 instruments located in harsh
  • environments* which were not adequately envi~onmentally qualifi~d. As this revie_w identified_ all potential problems associated with environmental qualification of RG 1.97 instrumentatiqn, no further reviews are recommended.

ADDITIONAL INFORMATION This licensee event report fulfills the technical specifications requi~ement to provide a special report to the NRC within 30 days of the event. This requirement is.described in Palisades Technical S~ecificatio~s Table 3.24-2, It.em .Sa.

i I

I I

Retrieved from "https://kanterella.com/w/index.php?title=ML18058A288&oldid=2506891"