NL-04-010, Report on Inoperable Post Accident Monitoring Instrument LT-3301
| ML040290807 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 01/22/2004 |
| From: | Dacimo F Entergy Nuclear Northeast |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-04-010 | |
| Download: ML040290807 (3) | |
Text
Entergy Nuclear Northeast Indian Point Energy Center 295 Broadway, Suite 1 PO. Box 249
- En tergy Buchanan, NY 10511-0249 Tel 9147345340 Fax 914 734 5718 Fred Dacimo Vice President, Operations January 22, 2004 Indian Point Unit 2 Docket No. 50-247 NL-04-010 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station O-Pl-17 Washington, DC 20555-0001
Subject:
Report on Inoperable Post Accident Monitoring Instrument LT-3301
References:
- 1)
Technical Specification 3.3.3, Post Accident Monitoring (PAM)
Instrumentation
- 2)
Technical Specification 5.6.6, Post Accident Monitoring Report
Dear Sir:
Pursuant to Technical Specification 5.6.6, this letter satisfies the requirement to submit a report within 14 days outlining the alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring Post Accident Monitoring Instrument LT-3301 to operable status.
Technical Specification LCO 3.3.3 requires that the Post Accident Monitoring (PAM)
Instrumentation for containment sump water level (Recirculation Sump), listed in Table 3.3.3-1 as Function 5, be operable in Modes 1, 2, and 3. This LCO is satisfied by the operability of two instrumentation channels. A magnetic switch/float type detector, LT-939, provides a series of five lights each energized from the associated instrument as a preset level is exceeded. A differential pressure transmitter, LT-3301, provides a calibrated sump level span that is continuously indicated.
Technical Specification SR 3.3.3.1 requires that a channel check be performed for each of these instrumentation channels at a frequency of 31 days. LT-3301 has been declared inoperable and cannot meet this surveillance requirement, which first became effective on December 12, 2003 with the implementation of the Improved Technical Specifications (ITS). The previous custom Technical Specifications did not contain this
I Docket No. 50-247 NL-04-01 0 Page 2 of 3 requirement. Failure to meet a surveillance within the specified frequency, in accordance with SR 3.0.1, constitutes a failure to meet an LCO. Therefore, since one or more Functions with one required channel or train was inoperable, Condition 3.3.3.A was entered on December 12, 2003. Required Action 3.3.3.A.1 to restore the channel to operable status in a Completion Time of 30 days (January 11) could not be accomplished due to the location of the instrument. Per Condition 3.3.3.B, if the Required Action and associated Completion Time of Condition A are not met, action must be initiated in accordance with Specification 5.6.6 per Required Action 3.3.3.B.1.
Specification 5.6.6 requires the report contained herein.
The cause of the inoperability of LT-3301 is indeterminate. Past history has required a plant outage to facilitate repairs to this instrument. It is, therefore, anticipated that repair will not be able to be performed until the next refueling outage. As required by the Technical Specifications, the second instrument channel (LT-939) is operable. Although not qualified to Regulatory Guide 1.97 requirements for a Type A, Category 1 instrument, there is a second magnetic switch/float type detector (LT-938) that is also in service.
No regulatory commitments are being made by Entergy in this correspondence.
Should you or your staff have any questions regarding this matter, please contact Mr.
T.R. Jones, Acting Manager, Licensing at (914) 734-6668.
Sincerely, Vice President Operations Indian Point Energy Center cc: see page 3
Docket No. 50-247 NL-04-010 Page 3 of 3 cc:
Mr. Hubert J. Miller Regional Administrator - Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. Patrick D. Milano, Project Manager Project Directorate I Division Of Reactor Projects I U.S. Nuclear Regulatory Commission Mail Stop 0-8-C2 Washington, DC 20555-0001 Resident Inspector's Office Indian Point Unit 2 U.S. Nuclear Regulatory Commission PO Box 38 Buchanan, NY 10511-0038