ML20127M498

Special Rept SR-92-002-00:on 921023,component Cooling Water (CCW) A/B Radiation Monitor Was Inoperable for More than 30 Days.Ts Change Request NPF-38-127,dtd 921021 Submitted,Which Changes Operability Requirement

ML20127M498
Person / Time
Site:	Waterford
Issue date:	11/24/1992
From:	Packer D ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
SR-92-002-00, SR-92-2, W3F1-92-0372, W3F1-92-372, NUDOCS 9211300248
Download: ML20127M498 (5)

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its Ot e m AD' w '.13 W3F1-92-0372 A4.05 QA November 24, 1992 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-

Subject:

Waterford 3 SES Docket No. 50-382 License No. NPF-38 Reporting of Special Report Gentlemen:

Attached is Special Report Humber SR-92-002-00 for Waterford 3 Steam Electric Station Unit 3.

This Special Report is submitted per Technical Specification 6.9.2.

Yety truly yours, I

6.F. Packer General Manager - Plant Operations DFP/RWP/ssf Attachment cc:

J.L. Milhoan, NRC Region IV G.L. Florreich J.T. Wheelock, INP0 Records Center R.B. McGehee N.S. Reynolds NRC Resident Inspectors Office Administrator - LRPD

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t SPECIAL REPORT f

SR-92-002-00 Operatility of_ Component Cooling Water A/B Radiation Monitor ABSTRACT On October 23, 1992, Waterford 3 SES, Unit 3 was operating in Mode 5 (Cold Shutdown) when it was noted that the Component Cooling Water (CCW) A/B l

radiation monitor was inoperable for more than 30 days. Technical Spu.ification (TS) 3.3.3.1 and TS Table 3.3-6 and associated ' Action l

Statement 28 allows caeration of the plant for up to 30 days with this i

monitor inoperable, which is applicable to all modes of operation.

However, the TS acticn statement does not address ;onditions beyond 30 l

days, which is the reason this voluntary Special Report is being submitted.

Corrective action to prevent the recurrence of this situation during future outages was the submittal of Technical Specification Change Request NPF-38-127, dated October 21, 1992, which changes the operability requirement for monitor A/B from ALL MODES to MODES 3 through 4 and expands the action statement to require submittal of a Special Report if j-the man; tor is not restored to oprable :;l.atus within 30 days and to continue to take and analyze grab samples.

j SASIS FOR REPORT j

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On October 23, 1992, Waterford 3 SES, Unit 3 was operating in Mode 5 (Cold Shutdown) when it was noted that the Component Cooling Water (CCW) A/B radiation monitor was inoperable for more than 30 days. Technical Specification (TP 3.3.3.1 and TS Table 3.3-6 and associated Action Statement 28 allows operation of the plant for up to 30 days (provided i

grab samples are taken every eight hours and analyzed for gross activity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) with this monitor inoperable, which is applicable to all modes of operation. Also, the provisions of TS 3.0.3 and 3.0.4 are not l

applicable. The failure to re-instate the aperability status of the A/B monitor within 30 days does not represent a failure to comply with the Technical Specifications because the Technical Specific nions do not

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address the situation beyond 30 days.

Upon review of similar radiation monitor action statements, it was noted that a Special Report is required for like situations.

This requirement appears to have been mistakenly omitted from Action Statement 28, which lead to the decision to submit j

this Special Report.

Since the flow in the CCW liae associated with the A/B monitor is insufficient during Modes 5 and 6 because of containment isolation actions to facilitate refueling activities, the mnnitors are declared inoperable during these modes. The purpose of tha A/B monitor, a non-safety monitor, is to provide early detection of Reactor Coolant System (RCS) leakage from the Reactor Coolant Pump (RCP) seals. Although RCP seal leakage is highly unlikely during Modes 5 and 6, should such leakage occur, it could be identified by CCW continuous radiation monitors A and B, which would be operable. Therefore, the requirement for the A/B monitor to be operable during Modes 5 and 6 is not necessary.

Corrective action to prevent the recurrence of this situation during future outages vtas the submittal of Technical Specification Change Request NPF-38-127, dated October 21, 1992, which changes the operability requirement for monitor A/B from ALL MODES to MODES 1 through 4 and expands Action Statement 28 to require submittal of a Special Report if the monitor is not restored to operable status within 30 days and to continue to take and analyze grab samples.

INITIAL CONDITIONS Plant Power:

0 Mode:

5 Procedures Being Performed Specific to this Event:

None Tech. Spec. LC0's in Effect Specific to this Event:

3.3.3.1 Major Equipment Out of Service Specific to this Event:-

None 2

9 EVENT SE0VENCE On October 23, 992, Waterford 3 war operating in Mode 5 during the fifth refueling outage.

At 1130 hours0.0131 days <br />0.314 hours <br />0.00187 weeks <br />4.29965e-4 months <br />, it was noted that the CCW A/B radiation monitor was inoperable for more than 30 days. The monitor was initially declared inoperable on September 21, 1992, at 0054 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br />.

On November 4, 1992, at 0015 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> the A/B monitor was again declared operable, which was the result of the restoration of conditions that allowed sufficient flow in the line associated with the monitor.

Entry into Mode 4 occurred on November 4, 1992, at 1103 hours0.0128 days <br />0.306 hours <br />0.00182 weeks <br />4.196915e-4 months <br />. During the period the A/B monitor was inoperable, except for the event involving LER-92-Oll-00, grab samples were taken once per eight hours and analyzed for grcss activity within 24 4

hours.

CORRECTIVE MEASURES The measure to prevent recurrence of this situation in future refueling outages was to submit to the NF/ i Technical Specification Change Request (NpF-38-127) to delete the operability requirement for the CCW A/B radiation monitor when the plant is in Modes 5 and 6 and to require the submittal of a Special Report if the other two CCW continuous radiation monitors become inoperable and are not restored to the operable status within 30 days.

SAFET7 SIGNIFICrT11 This situation d',d not pose a threat to the health and safety of the p'iblic because two other safety-related radiation monitors were available in the CCW system providing continuous radiation monitoring in All Modes.

The Waterford 3 Component Cooling Water System includes three radiation monitors: two continuously operating safety-related monitors (the CCW A and B monitors) are provided for the CCW pump discharge headers while a third non-safety monitor is provided on the CCW return hender from containment. The non-safety CCW A/B return header monitor samples the CCW stream returning from containment where it cools the reactor coolant pumps, the reactor coolant pump seals, and the ccatrol element drive mechanisms. Therefore, with two redundant monitors on the CCW pump discharge header and another monitor on the pump suction header, the CCW radiation mor.itoring function is doubly redundant.

In addition, flow in 3

the line associated with the A/B monitor is insufficient _during Modes 5 and' 6 because of containment isolatiore actions to facilitate refueling activities; therefore, the monitor is mostly-inoperable during these irodes.

Because of these system characteristics and the'way tl.e CCW-system operates in Modes 5 and 6, Entergy Operations, Inc. has recently. requested a change to the Waterford 3 Technica1' Specifications to delete the operability requirement for the CCW A/B return header monitor when the plant'is in Modes 5 and 6.

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