View source for 05000457/LER-1997-004, Forwards LER 97-004-00 from Braidwood Generating Station IAW Requirement of 10CFR50.73(a)(2)(iv),which Requires 30-day Rept.Ler Was Originally Transmitted W/Error in Reportability Requirements of Cover Ltr Only

{{Adams
| number = ML20199G302
| issue date = 11/14/1997
| title = Forwards LER 97-004-00 from Braidwood Generating Station IAW Requirement of 10CFR50.73(a)(2)(iv),which Requires 30-day Rept.Ler Was Originally Transmitted W/Error in Reportability Requirements of Cover Ltr Only
| author name = Schwartz G
| author affiliation = COMMONWEALTH EDISON CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000457
| license number = 
| contact person = 
| document report number = BW-97-0060, BW-97-60, NUDOCS 9711250149
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 1
}}
{{LER
| Title = Forwards LER 97-004-00 from Braidwood Generating Station IAW Requirement of 10CFR50.73(a)(2)(iv),which Requires 30-day Rept.Ler Was Originally Transmitted W/Error in Reportability Requirements of Cover Ltr Only
| Plant = 
| Reporting criterion = 
| Power level = 
| Mode = 
| Docket = 05000457
| LER year = 2097
| LER number = 4
| LER revision = 
| Event date = 
| Report date = 
| ENS = 
| abstract = 
}}

=text=
{{#Wiki_filter:naidunod <.cocutiny sution
.}'.- ,      stoute a1. Ikn M lincts ille,11. (W IO?>Xil9 Tel HI 54 %M 2801 November 14,1997 BW/97-0060 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C.
To Whom It May Concern:
The enclosed Licensee Event Report from Braldwtxx! Generating Station is being transmitted in accordance with the requirement of 10 CFR 30.73(a)(2)(iv), which requires a 30-day report. This was originally transmitted with an error in the reportability requirements on the cover letter only.
This report is Number 97-0044)0, Docket No. 50-457.
Yours truly,
                             , f      r^
                              .M G. K. Schwartz Station Manager Braidwood Nucicar Station GKS/PSAak ta mr.4 min %970060.aw Encl.: Licensee Event Report No. 457-97-0044)0 cc: - NRC Region 111 Admin':trator NRC Resident inspector                                                                          , p INPO Record Center Confd Distsibution Center 1.D.N.S.
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  . NRC FORM M6                              U.E NUCLEAR RELL'LATL.Y CUMMISSION                                                   APPROVED BY OMB NO. 31504104 (4-95)                                                                                                                                             F.XPIRES 04/3035 l                                                                                                          ES'I1 MATED BURDEN PER RESPONSE TO COMPLY %TFil Tills
) e'                                                                                                       INFORMATION CO11F4 TION REQUEST: $0.0 llRS REPORTED LESS NS LEARNED ARE INCORPORATED INTO Tile llCENSINO LICENSEE EVENT REPORT (LER)                                                       PROCESS AND FED BACK TO INDUSTRY. FORWARD COMMENTS
                    ,          .                                                                           REGARDING BURDEN ESTIMATE TO Ti!E INFORMAT10N AND RECORDS MAN AGEMENT BRANCil(MNBB 7714). U.S. NUCLLG REOULATORY COMMIS$10N, WASilINGTON, DC 20$$34001. AND TO TitF PAPFRWORK REDtlC'llON PROJFCT 7ACllJTY N AME (t):                                                                                   DOCKET NUMiiER (2) 0$000457                                              PAGE (3)
Braidwood Unit 02                                                                                                                        1 of 4 TIFLE(4)            Containment Fuel Handling Incident Radiation Monitor 2AR11J Alarm Setpoints Were Set Incorrectly Due to Personnel Error Resulting in an Inadvertent Containment Vent Isolation EVENT DATF.(s)                        I.r.R NUM BER (6)         l  REPORT DATE(7) l                                      OTIIER FACILITIES INVolNED(W) uom             oAv     nam          nam l swuiunAL           amsnm         6n*rru      DAr    nan      FACIllTY NAhE                                                 DOCKET NUMBER wuwwn        wwa 10           14         97          97         004           00            11        12      97      FACILITY NAME                                                 DOCKET NUhBER Qty                  Defueled        Tills REPORT IS SUBMITTED PURSUANT TO Tile REQUIREMENTS OF 10 CFR i: (Check one or more)(II) rumta               000 t nT1 (te; x
                  ,                        [     20.220l(b)                     [     20.2203(aX3 Xi)                O 50.73(=X2Xia)                                        :     73.71(b) s         .m  MW              .            20.2203(aX1)                         20 2203(aX3 Xu)                X             S0.7)(aX2 Xav)                                 73.71(c)
[I g       < V                     20.2203(ax2 Xi)                      20.2203(aM4)                                 50.73(aX2 Xv)                            J OTitER Mh@ . ,[
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Y6J             [     20.2203(a K2 rv)               [     30.73(aX2Xu)                    [            50.73(ax2Xx)                            NRC Form 366A)
I_,1CENNEE (UNT A(7 FOR TillN 1.EH (12)
NAME                                                                                                                         TELEPilONE NUMBER (include Area Code)
P. Studdard, Root Cause Team (815) 458-2801 Extension 3110 (4ntPIETE ON E I.INE FOR EACll(4ntPONENT Fall.URE DESCRillED IN Tills REPORT (13)
CAWE              SYMM              COMPONLMT       MAW AL%RiR           RLPORIABLk                <      CAUM                &YMM               COMPQNbbri   MANUF ACTURER      LINKT ABLE m wpa ns        *
                                                                                                         .                                                                                 m wpans 4M M%
M'PPIIM ENT A1. kEPORT EX PE(7ED (14)                                                                    EXPELTED           MOS          D'        EAR YES                                                              X      NO                                                          SUBMISSION (if ses, complete F.XPFCTFD StTinflSSION D ATF)                                                                                         D ATE (15)
AILSTRAcT (Lamit to I 400 spaces, i e , apprommately littaen smgle-space typewntten imes 16)
On 10/14/97, preparations were being made to reload fuel into Unit 2.                                                                                    Alarm setpoints for the Containment Fuel Handling Incident Radiation Monitors were being changed for loading fuel into the react                                  vessel. A containment release was in progress. When the Nuclear Station Operator (licensed reactor operator) entered the change for the first radiation monitor he entered an incorrect (more conservative) value resulting in a High Alarm for the radiation monitor and a containment vent isolation. All required isolation valves closed and the release was automatically secured.
The cause of the event was personnel error due to inattention to detail and a failure to self-check. Corrective actions included verifying proper response of equipment to the containment vent isolation signal, entering the correct setpoints, counseling the operator, tailgating the event with operating crews, and initiating a procedure for the evolution. There has been one previous event involving incorrect setpoints for these monitors. There were no safety consequences for this event. The monitor alarm setpoints were set more conservatively resulting in a containment vent isolation thereby preventing an unmonitored release.
This event is being reported pursuant to 10CFR50.73 (a) (2) (iv) .
l 0

  ,  hkC FORA. 3MA                   U.E NUCLEAK RECUL ATORY CDMMISMON                                 APPROVED BY OMB h0. 3150-0104 (4 95)                                                                                                                                       EXPIRES OW3498 i          =
ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS
! .'                                                                          INFCMATION COL 15A. TION REQUEST: 50 0 HRS. REPORTED LESS NS 15.ARNED ARE INCORPORATED !NTO THE LICENSING LICENSEE EVENT REPORT (LER)                              PROCESS AND FED BACK TO INDUSTRY. FORWARD COMMENTS
                ^      *
* TEXT CONTINUATION                              REGARDING BURDEN ESTIMATE TO THE INFORMATION AND RECORDS MANAGEMENT BRANCH (T 6 F33). U.S. NUCLI.AR
              ,                                                               REOULATORY COMMISSION. WASHINGTON. DC 20555 0001. AND TO THE PAPERWORK REDUCTION PROJECT F ACII.ITY NAM / 0)                  IMCKET NUMBER G)                1.ER NUMitER (O                                                                                                             PAGE (3) sN Braidwood Unit 02                         0d000457             97                                              004                                                       00                       2 of 4 (if rnore space is required, use additional copies of NRC Fonn 366A)(17)
A.          P_LANT CODIDITIObl5 PRIOR TO EVENT:
Unit (s): 02                          Event Date: 10/14/97           Event Time: 1547 Hours Reactor Mode (s) Defueled            Power Level (s): 000%          RCS [AB) Temp./ Press.                                                                                                      N/A D.          DESCRIPTION OF EVENT:
There were no systems or components inoperable at the beginning of this event that contributed to the severity of the event.
On 10/14/97, during a scheduled refueling outage, preparations were being made to reload fuel into Unit 2. A continuous containment release was in progress at this time. Alarm setpoints for the Containment Fuel Handling Incident Radiation Monitors (2AR011J and 2AR012J) were being changed per BwRP 5820-5T3, Refuel Outage Setpoint Chr.nge Record for 2AR011J and 2AR012J.                                       This setpoint change was required before loading fuel into the reactor vessel. The new setpoints had been correctly calculated utilizing BwRP 5820-5T3 and approved by Health Physics.                                                                                                                        The correct setpoints for both radiation monitors were determined to be 13 mR/hr for the High Alarm setpoint and 8 mR/hr for the Alert Alarm setpoint.                                                                                                   These values are entered by Nuclear Station Operators (NSO, licensed reactor operators) utilizing the RM-23 (Control / Display module for safety related radiation monitors).       Two NSos are required to make the necessary changes - one to enter the change and one for independent verification. The NSO started the change process at approximately 1532. The changes for the 2AR0llJ radiation monitor were entered with an incorrect sign convention (skill based error).                                                                                                             Instead of 1.30E+1 mR/hr, the value entered was 1.30E-1 mR/hr.
As soon as the change was entered, and before the independent verification could be performed, a High Alarm for the 2AR011J radiation monitor was received. This resulted in a containment vent isolation signal. All required containment isolation valves closed and this also secured the Unit 2 containment release that was in progress. The NSO entering the change realized immediately upon receiving the alarm that he had inadvertently hit the wrong key resulting in the event.
Proper equipment response to the containment vent isolation was verified. The correct setpoints were then entered for the 2AR011J radiation monitor and the changes were entered for the 2AR012J radiation monitor.
The event was reviewed for reportability and a determination made that it was not reportable based on the fact that it was not considered a valid actuation signal.
This was a mis-interpretation of 10CFR50.72, Immediate notification requirements for operating nuclear power reactors, and the required ENS phone call was not made. On 10/25/97, after further review and discussions with the NRC, the Event Screening Meeting determined that the ESF actuation was valid and that the event was reportable. Additionally, a determination was made that the reportability guidance was in error.
This event is being reported pursuant to 10CFR50.73 (a) (2) (iv), any event or condition that resulted in a manual or automatic actuation of any engineered safety feature (ESF) including the reactor protection system (RPS).
C.          CAUSE OF EVENT
* The cause of this event was an inadequate work practice (skill based error)due to inattention to detail (failure to adequately self-check) by the operator entering the setpoint changes. There is currently not a procedure for performing the evolution of entering radiation monitor setpoint changes utilizing the RM-23.

q   NRC PORM 346A                  U.S. NUCLEAR REOULATORY COMMsSSION                    APPROVED BY OMB No.3tSO4104 (4-93)                                                                                       EXPIRES 04'3698 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITil Tills e*                                                                         INFORMATION COLLECTON REQUEST: 50 0 llRS. REPORTED LESSONS tEARNED ARE INCORPORATED INTO Tile LICENSING LICENSEE EVENT REPORT (LER)                             PROCESS AND FED BACK TO INDUSTRY, IURWARD COMMENTS TEXT CONTINUATION                             REGARDING BURDEN ESTIMATE TO'IllE INFORMATION AND RECORDS MANAGEMENT BRANCII(T-6 F331 U.S. NUCLEAR
             ,                                                             REOULATORY COMMISSION. WASit!NO ION. DC 20$55 0001. AND TO l THE PAPERWORK REDUCTION PROJECT l
FACILITY N AME 0)                     IMGET NUMBER G)            IIR NUMBER (6)                     PAGE (3) nAR        MyUENnA4,      RDum M MBFR        M NBFR Braidwood Unit 02                           05000457          97          004            00           3 of 4 (If more space is required, use additional copies of NRC Fonn 366AX17)
D.-       AssassteneT or SAFETY CostsEQUENCEs The setpoints for the radiation monitor were set conservatively and actually resulted in a containment vent isolation thereby preventing an unmonitored release.
Since the containment fuel handling incident area radiation monitor's primary function is to automatically isolate purge in the event of an incident, had the setpoint changes been less conservative this safety function would have been
            . adversely impacted.
The containment effluent purge monitor (2PR001), the aux building vent stack effluent monitor (2PR28J), and the wide range gas monitor (2PR30J) would have provided alarms at the required leval which would alert the operators to the abnormal situation.
Under worst case conditions, assuming an incident occurred in containment and the 2ARO11J and 2AR012J were set to less conservatively and did not alarm with a purge in progress and other radiation monitoring not available, the impact to public dose would be minimal. Using the dose model to evaluate the environmental consequences of an accident as indicated in UFSAR Attachment 15A, offsite doses to the whole body and thyroid gland were obtained from Table 15.0-12.                            These results are 0.986 Rem of whole body dose and 33 Rem to the thyroid gland. These are small fractions of the 10CFR100 dose criteria of 25 Rem whole body and 300 Sem to the thyroid gland.
E.       CORRECTIVE ACTIONS e       Inunediate actions Immediate actions were to verify proper response of equipment to the containment vent isolation and then enter the correct setpoints for the radiation monitor.
* Corrective Actions to Prevent Recurrence When it was identified that the reportability guidance was in error, the other affected Comed facilities were notified of the error and advised to not apply the erroneous guidance to containment Ventilation Isolation actuations which may be experienced.
A revision to the reportability guidance was initiated to accurately reflect the provisions of 10CFR50.72 for the reporting of these actuations.
Additionally, a review of the reporting guidance has been undertaken to confirm that the guidance is consistent with all reporting requirements of 10CFR50.72.      This will be tracked by NTS item #457-180-97-SCAQ0000401.
The operator entering the change was counseled concerning his actions and the expectations for self checking and attention to detail.
Shift Managers will tailgate this event with their crews.                     This will be tracked by NTS item #457-180-97-SCAQ0000402.
A procedure will be written for performing setpoint checks and changes utilizing the RM-23. This will be tracked by NTS item #457-180                    SCAQ0000403.

   ,    NRC PORM .M6A                 U.8. NUCIIAR RF4ULAlORY COMMIEMON                                            APPROVED BY OMB NO.31SO4804
(&95)                                                                                                                                EXPIRES 04/349e ES11 MATED BURDEN PER RESPONSE TO COMPLY %Tril THIS e'                                                                           INFC2M ATION COLLECTION REQUEST: 30.0 llRS. REPORTID LESS NS LEARNED ARE INCORPORATED INTO TIIE LICENSINO LICENSEE EVENT REPORT (LER)                                PROCESS AND FED BACK TO INDUSTRY. FORWARD COMMENTS TEXT CONITNUATION                               REGARDINO BURDEN ESTIMATE TO11[E INFORMATION AND RECORDS MANAGEMENT BRANCll(T 6 F33), U.S. NUCLEAR
                ,                                                               REOULATORY COMMISSION, % A$lilNOTON, DC 20$$$M1, AND TO THE PAPERWORK REDUCTION PROJECT FACl!.ITY N AME 0)                   DOCKET NUMBER Q)                                lek NUMBER (6)                                                                PAGE (3) na                                 uutumn.                                        u va*.
M MBF9                                      MMBF9 Braidwood Unit 02                          05000457              97                                       004                                           00            4 of 4 (If more space is required, use additional copies of NRC Fonn 366A)(17)
An effectiveness review will be performed on the corrective actions for this event. This will be tracked by NTS item #457-180-97-SCAQ00004ER.
F.        PREVIOUS OCCURRENCES:
LER N0MBER                          TITLE 456-180-96-013                     Area Radiation Monitor Setpoints Incorrect Due to Personnel Error Resulting in a Violation of Technical Specifications.        During an On Site Review of the Improved Technical Specifications, a problem was ioentified in that the containment fuel handling incident radiation monitor (1/2AR0llJ and 1/2AR012J) high alarm setpointe were incorrect.        These setpoint.1 had been in place since initial plant startup.         The cause of this event was personnel error due to inadequate work practices and inattention to detail. Corrective actions included correcting the setpoints, reviewing all Technical specification radiation monitor setpoints, evaluating the processes for updating and tracking monitor setpoints, and      vising the UFSAR.
Corrective actions for the event were specific to the event and would not have prevented this event.
;              A search was performed of the OPEX database and no other similar events were found within the last two years.
O.       COMPONENT FAILURE DATA:
MANUFACTURER -----NOMENCLATURE                      MODEL           MFG. PART NO.
Since no component failure occurred, this section ir not applicable, d
'l A.
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