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{{#Wiki_filter:SSINS No.: 6835IN 86-42UNITED STATESNUCLEAR REGULATORY COMMISSIONOFFICE OF INSPECTION AND ENFORCEMENTWASHINGTON, D.C. 20555June 9, 1986IE INFORMATION NOTICE NO. 86-42: IMPROPER MAINTENANCE OF RADIATIONMONITORING SYSTEMS
{{#Wiki_filter:SSINS No.: 6835 IN 86-42 UNITED STATES NUCLEAR REGULATORY
 
COMMISSION
 
OFFICE OF INSPECTION
 
===AND ENFORCEMENT===
WASHINGTON, D.C. 20555 June 9, 1986 IE INFORMATION
 
NOTICE NO. 86-42: IMPROPER MAINTENANCE
 
OF RADIATION MONITORING
 
SYSTEMS


==Addressees==
==Addressees==
:All nuclear power reactor facilities holding an operating license (OL) or aconstruction permit (CP).
:
All nuclear power reactor facilities
 
holding an operating
 
license (OL) or a construction
 
permit (CP).


==Purpose==
==Purpose==
and Summary:This notice is issued to alert licensees to the potential for defeating thesafety function associated with radiation monitoring systems by not properlyadhering to established surveillance and maintenance procedures. A recentevent at a BWR, when an electrical jumper was inadvertently left in place aftera planned surveillance, led to failure to maintain secondary containmentintegrity during irradiated fuel movement.It is expected that recipients will review the information for applicability totheir maintenance and surveillance program and consider actions, if appropriate,to preclude similar problems at their facility. However, suggestions containedin this notice do not constitute NRC requirements; therefore, no specific actionor written response is required.Previous Related CorrespondenceIE Information Notice No. 83-23, "Inoperable Containment AtmosphereSensing Systems," April 25, 1983.INPO Significant Event Report, 35-83, "Compromise of Secondary ContainmentIntegrity," June 9, 1983.IE Information Notice No. 83-52, "Radioactive Waste Gas System Events,"August 9, 1983.IE Information Notice No. 84-37, "Use of Lifted Leads and Jumpers DuringMaintenance or Surveillance Testing," May 10, 1984.
and Summary: This notice is issued to alert licensees
 
to the potential
 
for defeating
 
the safety function associated
 
with radiation
 
monitoring
 
systems by not properly adhering to established
 
surveillance
 
and maintenance
 
procedures.
 
A recent event at a BWR, when an electrical
 
jumper was inadvertently
 
left in place after a planned surveillance, led to failure to maintain secondary
 
containment
 
integrity
 
during irradiated
 
fuel movement.It is expected that recipients
 
will review the information
 
for applicability
 
to their maintenance
 
and surveillance
 
program and consider actions, if appropriate, to preclude similar problems at their facility.
 
However, suggestions
 
contained in this notice do not constitute
 
NRC requirements;  
therefore, no specific action or written response is required.Previous Related Correspondence
 
IE Information
 
Notice No. 83-23, "Inoperable
 
Containment
 
Atmosphere
 
Sensing Systems," April 25, 1983.INPO Significant
 
Event Report, 35-83, "Compromise
 
of Secondary
 
Containment
 
Integrity," June 9, 1983.IE Information
 
Notice No. 83-52, "Radioactive
 
Waste Gas System Events," August 9, 1983.IE Information
 
Notice No. 84-37, "Use of Lifted Leads and Jumpers During Maintenance
 
or Surveillance
 
Testing," May 10, 1984.Description
 
of Circumstances:
On November 18, 1985 the Cooper Nuclear Station was in a shutdown condition (reactor coolant temperature
 
less than 212 0 F and vented) with acceptance
 
testing for a plant design change in progress.
 
When this testing failed to provide for the required Group VI isolation (various containment
 
isolation
 
and Copies to: Withers, Yundt, Lentsch, Orser, Steele, E. Burton, E. Jordan, A. Holm, iLIS;.j. A. Olmstead, S. Hoag, S. Sautter, TNP:GOV REL F:NRC CHRONO, TNiPGOV REL F:NRC IE Information
 
Notice 86-42 PGE OAR Action -M. H. Halmros (Due 8/12/86)NSRD Action -M. H. Malmros
 
IN 86-42 June 9, 1986 engineered
 
safety feature (ESF) initiations), the licensee investigated
 
and discovered
 
that electrical
 
jumpers were installed
 
in the reactor building (RB)ventilation
 
radiation
 
monitors (VRM) auxiliary
 
trip units. These jumpers prohibited
 
a Group VI isolation
 
by a high radiation
 
signal from the RB VRM.The jumpers were immediately
 
removed and the NRC was promptly notified as required by 10 CFR 50.72.The licensee's
 
subsequent
 
investigation
 
revealed that the electrical
 
jumpers had been installed
 
on November 13, 1985 by an instrument
 
and control technician
 
during a routine surveillance
 
procedure
 
to functionally
 
test the VRM. These jumpers are used to prevent trip and equipment
 
operations
 
during the required functional/calibration
 
testing. The technician
 
had signed off the procedural
 
step requiring
 
jumper removal (before actually removing the electrical
 
jumper)and then started checking control room annunciator
 
and trip signal status. The technician
 
then became involved in other unrelated
 
craft work and forgot to go back and remove the jumpers.On November 18, 1986, before discovery
 
of the jumpers, 18 irradiated
 
fuel bundles were loaded into a spent fuel shipping cask. Failure to properly implement
 
the surveillance
 
procedure
 
for operability
 
checks of radiation monitors rendered inoperable
 
the automatic
 
initiation
 
of the standby gas treatment
 
system (SBGTS) and automatic
 
isolation
 
of the reactor building upon receipt of a high radiation
 
signal. This degraded condition
 
lasted approxi-mately 5 days. However, control room annunciators
 
and instrumentation
 
that would provide warning to operators
 
of any high radiation
 
problems remained operational
 
during the 5 days. Manual-start
 
of the SBGTS and reactor building isolation
 
capabilities
 
from the control room remained available
 
during the event.Discussion:
This event clearly demonstrates
 
that the level of attention
 
given to the procedural
 
controls for the maintenance
 
of radioactive
 
monitoring
 
systems providing
 
ESF actuation
 
can be significantly
 
improved.
 
While there were no actual radiological
 
consequences
 
of this event, the NRC took escalated
 
enforce-ment actions (issued civil penalty) to emphasize
 
the importance
 
of correctly performing
 
surveillance
 
procedures
 
on systems designed to mitigate or prevent accidents.
 
Attachment
 
No. 1 contains 6 summaries
 
of related events taken from the Licensee Event Report files. Further examples of how improper maintenance
 
practices
 
have degraded radiation
 
monitoring
 
systems are provided in the listed Previous Related Correspondence
 
section.The Cooper Station initiated
 
the following
 
corrective
 
actions to prevent recurrence:
1. All temporary
 
modifications (e.g., electrical
 
jumpering, fuse removal)performed
 
by the involved technician
 
since October 5, 1985 were indepen-dently verified.2. Site management
 
stressed the importance
 
of procedural
 
adherence--sign
 
off the procedural
 
step after completing
 
the required action.
 
IN 86-42 June 9, 1986 3. All surveillance
 
procedures
 
requiring
 
temporary
 
modifications
 
to system or plant components
 
were reviewed for deficiencies, and these procedures
 
will be modified to provide for independent
 
verification
 
to ensure that tempo-rary modifications
 
are removed and the system/component
 
is fully restored to operational
 
status.No specific action or written response is required by this information
 
notice.If you have any questions
 
about this matter, please contact the Regional Administrator
 
of the appropriate
 
regional office or this office.4'-CJ1ward
 
L. Jord, Director Division of Edergency
 
===Preparedness===
and Engineering
 
Response Office of Inspection
 
and Enforcement
 
Technical
 
Contacts:
James E. Wigginton, IE (301) 492-4967 Roger L. Pedersen, IE (301) 492-9425 Attachments:
1. Event Summaries 2. List of Recently Issued IE Information
 
Notices
 
Attachment
 
1 IN 86-42 June 9, 1986 EVENT SUMMARIES Unplanned
 
Gaseous Release (Connecticut
 
Yankee, PWR)LER 85-025 Event Date: 9/19/85 Cause: Personnel
 
Maintenance
 
Error Abstract:
With the plant operating
 
at 100 percent power, a main stack high radiation
 
alarm was received during routine scheduled
 
maintenance
 
on a pressure actuated valve in the gaseous waste stream. The unplanned
 
release occurred through an isolation
 
valve inadvertently
 
left open, allowing the on-line waste gas decay tank a release path.The maintenance
 
tag-out procedure
 
correctly
 
required the isolation valve to be isolated, but the operator shut the wrong valve. The total noble gas release was approximately
 
20 curies (about 14 percent of technical
 
specification
 
limit). Licensee corrective
 
action included clearly relabeling
 
associated
 
valves and discussion
 
of the event with operation
 
staff.Containment
 
Radiation
 
Monitor Isolated (Byron 1, PWR)LER 85-026 Event Date: 2/28/85 Cause: Improper Valve Position Abstract:
With the reactor at zero percent power, a containment
 
radiation monitor used for required reactor coolant leakage detection
 
was inadvertently
 
left isolated for 72 hours from containment
 
after maintenance
 
on an associated
 
valve. Abnormal in-leakage
 
at the monitor caused normal-range
 
readings on RM-li console in the main control room (leakage was later repaired).
 
===Licensee corrective===
action included implementing
 
administrative
 
controls to ensure system integrity/proper
 
restoration
 
after completion
 
of maintenance
 
activities.
 
Liquid Radwaste Effluent Monitor Isolated (Cooper, BWR)LER 84-008 Event Date: 6/09/84 Cause: Monitor Discharge
 
Valve Shut Abstract:
A liquid discharge
 
occurred without required continuous
 
radiation
 
monitoring
 
because the liquid effluent radiation
 
monitor was isolated.
 
No discharge
 
limits were exceeded.
 
Two days before the event, a technician
 
apparently
 
shut the radiation
 
monitor outlet valve during maintenance
 
without permission
 
or knowledge
 
of operations
 
personnel.
 
As corrective
 
actions, the licensee revised controlling
 
procedures
 
and informed all plant operators
 
of the event.
 
Attachment
 
1 IN 86-42 June 9, 1986 Off-Gas Stack Monitor Inoperable (Cooper, BWR)LER 84-006 Event Date: 4/18/84 Cause: Personnel
 
Error Abstract:
With the reactor at 70 percent power, the off-gas stack effluent sampler was found inoperable.
 
The sampler was drawing air from the surrounding
 
off-gas filter building ambient atmosphere
 
instead of sampling the plant stack effluent.
 
The event resulted from a chemistry
 
technician
 
failing to follow the approved procedure
 
for changing the inline particulate
 
filter/iodine
 
cartridge (routine operation).
 
In addition to making appropriate
 
supervisors
 
and all chemistry
 
technicians
 
aware of the event, the licensee revised and clarified
 
the governing
 
procedure
 
to prevent recurrence.
 
Liquid Radwaste Auto-Isolation
 
Valve Inoperative (Hatch 1, BWR)LER 82-093 Event Date: 11/07/82 Cause: Jumper Installed Abstract:
During a liquid radwaste discharge, the licensee discovered
 
that the radiation
 
monitor auto control (provides
 
isolation
 
signal upon high radiation)
to the discharge
 
isolation
 
valve was inoperable.
 
However, the monitor's
 
alarm function remained operable.
 
An electrical
 
jumper used during corrective
 
maintenance
 
had not been removed after the work was completed.
 
Containment
 
Atmosphere
 
Radiation
 
Monitors Isolated (FitzPatrick
 
1, BWR)LER 81-061 (Rev 1 Event Date: 8/21/81 Cause: Containment
 
Isolation
 
Valve Isolated Abstract:
The NRC resident inspector
 
discovered
 
that during normal 85 percent power operations
 
the containment
 
isolation
 
valves for the containment
 
atmosphere
 
gaseous and particulate
 
monitoring
 
system had been shut for approximately
 
22 hours. With this loss of monitoring
 
capability, the technical
 
specifications
 
require a reactor hot shutdown within 12 hours. The event occurred because a surveillance
 
procedure
 
did not direct the operator to re-open the isolation
 
valves following'
the surveillance
 
activities.
 
As a corrective
 
action, the licensee corrected
 
the subject procedure
 
and reviewed all other surveillance
 
procedures
 
for similar deficiencies.
 
4'Attachment
 
2 IN 86-42 June 9, 1986 LIST OF RECENTLY ISSUED IE INFORMATION
 
NOTICES Information
 
Date of Notice No. Subject Issue Issued to 86-41 86-32 Sup. 1 86-40 86-39 86-38 86-37 86-36 86-35 86-34 Evaluation
 
===Of Questionable===
Exposure Readings Of Licensee Personnel
 
Dosimeters
 
Request For Collection
 
===Of Licensee Radioactivity===
Measurements
 
Attributed
 
To The Chernobyl
 
Nuclear Plant Accident Degraded Ability To Isolate The Reactor Coolant System From Low-Pressure
 
Coolant Systems in BWRS Failures Of RHR Pump Motors And Pump Internals Deficient
 
Operator Actions Following
 
Dual Function Valve Failures Degradation
 
Of Station Batteries Change In NRC Practice Regarding
 
Issuance Of Confirming
 
Letters To Principal
 
Contractors
 
6/9/86 6/6/86 6/5/86 5/20/86 5/20/86 5/16/86 5/16/86 All byproduct material licensees All power reactor facilities
 
holding an OL or CP All power reactor facilities
 
holding an OL or CP All power reactor facilities
 
holding an OL or CP All power reactor facilities
 
holding an OL or CP All power reactor facilities


==Description of Circumstances==
holding an OL or CP All power reactor facilities
:On November 18, 1985 the Cooper Nuclear Station was in a shutdown condition(reactor coolant temperature less than 2120F and vented) with acceptancetesting for a plant design change in progress. When this testing failed toprovide for the required Group VI isolation (various containment isolation andCopies to: Withers, Yundt, Lentsch, Orser, Steele, E. Burton, E. Jordan, A. Holm,iLIS;.j. A. Olmstead, S. Hoag, S. Sautter, TNP:GOV REL F:NRC CHRONO,TNiPGOV REL F:NRC IE Information Notice 86-42PGE OAR Action -M. H. Halmros (Due 8/12/86)NSRD Action -M. H. Malmros


IN 86-42June 9, 1986 engineered safety feature (ESF) initiations), the licensee investigated anddiscovered that electrical jumpers were installed in the reactor building (RB)ventilation radiation monitors (VRM) auxiliary trip units. These jumpersprohibited a Group VI isolation by a high radiation signal from the RB VRM.The jumpers were immediately removed and the NRC was promptly notified asrequired by 10 CFR 50.72.The licensee's subsequent investigation revealed that the electrical jumpershad been installed on November 13, 1985 by an instrument and control technicianduring a routine surveillance procedure to functionally test the VRM. Thesejumpers are used to prevent trip and equipment operations during the requiredfunctional/calibration testing. The technician had signed off the proceduralstep requiring jumper removal (before actually removing the electrical jumper)and then started checking control room annunciator and trip signal status. Thetechnician then became involved in other unrelated craft work and forgot to goback and remove the jumpers.On November 18, 1986, before discovery of the jumpers, 18 irradiated fuelbundles were loaded into a spent fuel shipping cask. Failure to properlyimplement the surveillance procedure for operability checks of radiationmonitors rendered inoperable the automatic initiation of the standby gastreatment system (SBGTS) and automatic isolation of the reactor building uponreceipt of a high radiation signal. This degraded condition lasted approxi-mately 5 days. However, control room annunciators and instrumentation thatwould provide warning to operators of any high radiation problems remainedoperational during the 5 days. Manual-start of the SBGTS and reactor buildingisolation capabilities from the control room remained available during theevent.Discussion:This event clearly demonstrates that the level of attention given to theprocedural controls for the maintenance of radioactive monitoring systemsproviding ESF actuation can be significantly improved. While there were noactual radiological consequences of this event, the NRC took escalated enforce-ment actions (issued civil penalty) to emphasize the importance of correctlyperforming surveillance procedures on systems designed to mitigate or preventaccidents. Attachment No. 1 contains 6 summaries of related events taken fromthe Licensee Event Report files. Further examples of how improper maintenancepractices have degraded radiation monitoring systems are provided in the listedPrevious Related Correspondence section.The Cooper Station initiated the following corrective actions to preventrecurrence:1. All temporary modifications (e.g., electrical jumpering, fuse removal)performed by the involved technician since October 5, 1985 were indepen-dently verified.2. Site management stressed the importance of procedural adherence--sign offthe procedural step after completing the required action.
holding an OL or CP All power reactor facilities


IN 86-42June 9, 1986 . All surveillance procedures requiring temporary modifications to system orplant components were reviewed for deficiencies, and these procedures willbe modified to provide for independent verification to ensure that tempo-rary modifications are removed and the system/component is fully restoredto operational status.No specific action or written response is required by this information notice.If you have any questions about this matter, please contact the RegionalAdministrator of the appropriate regional office or this office.4'-CJ1ward L. Jord, DirectorDivision of Edergency Preparednessand Engineering ResponseOffice of Inspection and EnforcementTechnical Contacts: James E. Wigginton, IE(301) 492-4967Roger L. Pedersen, IE(301) 492-9425Attachments:1. Event Summaries2. List of Recently Issued IE Information Notices
holding an OL or CP All power reactor facilities


Attachment 1IN 86-42June 9, 1986 EVENT SUMMARIESUnplanned Gaseous Release (Connecticut Yankee, PWR)LER 85-025Event Date: 9/19/85Cause: Personnel Maintenance ErrorAbstract: With the plant operating at 100 percent power, a main stack highradiation alarm was received during routine scheduled maintenanceon a pressure actuated valve in the gaseous waste stream. Theunplanned release occurred through an isolation valve inadvertentlyleft open, allowing the on-line waste gas decay tank a release path.The maintenance tag-out procedure correctly required the isolationvalve to be isolated, but the operator shut the wrong valve. Thetotal noble gas release was approximately 20 curies (about 14 percentof technical specification limit). Licensee corrective actionincluded clearly relabeling associated valves and discussion of theevent with operation staff.Containment Radiation Monitor Isolated (Byron 1, PWR)LER 85-026Event Date: 2/28/85Cause: Improper Valve PositionAbstract: With the reactor at zero percent power, a containment radiationmonitor used for required reactor coolant leakage detection wasinadvertently left isolated for 72 hours from containment aftermaintenance on an associated valve. Abnormal in-leakage at themonitor caused normal-range readings on RM-li console in the maincontrol room (leakage was later repaired). Licensee correctiveaction included implementing administrative controls to ensuresystem integrity/proper restoration after completion of maintenanceactivities.Liquid Radwaste Effluent Monitor Isolated (Cooper, BWR)LER 84-008Event Date: 6/09/84Cause: Monitor Discharge Valve ShutAbstract: A liquid discharge occurred without required continuousradiation monitoring because the liquid effluent radiation monitorwas isolated. No discharge limits were exceeded. Two days beforethe event, a technician apparently shut the radiation monitor outletvalve during maintenance without permission or knowledge ofoperations personnel. As corrective actions, the licensee revisedcontrolling procedures and informed all plant operators of theevent.
holding an OL or CP -Fire In Compressible


Attachment 1IN 86-42June 9, 1986 Off-Gas Stack Monitor Inoperable (Cooper, BWR)LER 84-006Event Date: 4/18/84Cause: Personnel ErrorAbstract: With the reactor at 70 percent power, the off-gas stack effluentsampler was found inoperable. The sampler was drawing air fromthe surrounding off-gas filter building ambient atmosphere insteadof sampling the plant stack effluent. The event resulted from achemistry technician failing to follow the approved procedure forchanging the inline particulate filter/iodine cartridge (routineoperation). In addition to making appropriate supervisors and allchemistry technicians aware of the event, the licensee revised andclarified the governing procedure to prevent recurrence.Liquid Radwaste Auto-Isolation Valve Inoperative (Hatch 1, BWR)LER 82-093Event Date: 11/07/82Cause: Jumper InstalledAbstract: During a liquid radwaste discharge, the licensee discovered thatthe radiation monitor auto control (provides isolation signal uponhigh radiation) to the discharge isolation valve was inoperable.However, the monitor's alarm function remained operable. Anelectrical jumper used during corrective maintenance had not beenremoved after the work was completed.Containment Atmosphere Radiation Monitors Isolated (FitzPatrick 1, BWR)LER 81-061 (Rev 1Event Date: 8/21/81Cause: Containment Isolation Valve IsolatedAbstract: The NRC resident inspector discovered that during normal 85 percentpower operations the containment isolation valves for the containmentatmosphere gaseous and particulate monitoring system had been shutfor approximately 22 hours. With this loss of monitoring capability,the technical specifications require a reactor hot shutdown within12 hours. The event occurred because a surveillance procedure didnot direct the operator to re-open the isolation valves following'the surveillance activities. As a corrective action, the licenseecorrected the subject procedure and reviewed all other surveillanceprocedures for similar deficiencies.
Material 5/15/86 At Dresden Unit 3 Improper Assembly, Material 5/13/86 Selection, And Test Of Valves And Their Actuators OL = Operating


4'Attachment 2IN 86-42June 9, 1986LIST OF RECENTLY ISSUEDIE INFORMATION NOTICESInformation Date ofNotice No. Subject Issue Issued to86-4186-32Sup. 186-4086-3986-3886-3786-3686-3586-34Evaluation Of QuestionableExposure Readings Of LicenseePersonnel DosimetersRequest For Collection OfLicensee RadioactivityMeasurements Attributed ToThe Chernobyl Nuclear PlantAccidentDegraded Ability To IsolateThe Reactor Coolant SystemFrom Low-Pressure CoolantSystems in BWRSFailures Of RHR Pump MotorsAnd Pump InternalsDeficient Operator ActionsFollowing Dual Function ValveFailuresDegradation Of StationBatteriesChange In NRC PracticeRegarding Issuance OfConfirming Letters ToPrincipal Contractors6/9/866/6/866/5/865/20/865/20/865/16/865/16/86All byproductmaterial licenseesAll power reactorfacilities holdingan OL or CPAll power reactorfacilities holdingan OL or CPAll power reactorfacilities holdingan OL or CPAll power reactorfacilities holdingan OL or CPAll power reactorfacilities holdingan OL or CPAll power reactorfacilities holdingan OL or CPAll power reactorfacilities holdingan OL or CPAll power reactorfacilities holdingan OL or CP -Fire In Compressible Material 5/15/86At Dresden Unit 3Improper Assembly, Material 5/13/86Selection, And Test Of ValvesAnd Their ActuatorsOL = Operating LicenseCP = Construction Permit
License CP = Construction


}}
Permit}}


{{Information notice-Nav}}
{{Information notice-Nav}}

Revision as of 12:59, 31 August 2018

Improper Maintenance of Radiation Monitoring Systems
ML031250045
Person / Time
Site: Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, University of Lowell, 05000000, Zimmer, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Skagit, Marble Hill
Issue date: 06/09/1986
From: Jordan E L
NRC/IE
To:
References
IN-86-042, NUDOCS 8606040007
Download: ML031250045 (6)


SSINS No.: 6835 IN 86-42 UNITED STATES NUCLEAR REGULATORY

COMMISSION

OFFICE OF INSPECTION

AND ENFORCEMENT

WASHINGTON, D.C. 20555 June 9, 1986 IE INFORMATION

NOTICE NO. 86-42: IMPROPER MAINTENANCE

OF RADIATION MONITORING

SYSTEMS

Addressees

All nuclear power reactor facilities

holding an operating

license (OL) or a construction

permit (CP).

Purpose

and Summary: This notice is issued to alert licensees

to the potential

for defeating

the safety function associated

with radiation

monitoring

systems by not properly adhering to established

surveillance

and maintenance

procedures.

A recent event at a BWR, when an electrical

jumper was inadvertently

left in place after a planned surveillance, led to failure to maintain secondary

containment

integrity

during irradiated

fuel movement.It is expected that recipients

will review the information

for applicability

to their maintenance

and surveillance

program and consider actions, if appropriate, to preclude similar problems at their facility.

However, suggestions

contained in this notice do not constitute

NRC requirements;

therefore, no specific action or written response is required.Previous Related Correspondence

IE Information

Notice No. 83-23, "Inoperable

Containment

Atmosphere

Sensing Systems," April 25, 1983.INPO Significant

Event Report, 35-83, "Compromise

of Secondary

Containment

Integrity," June 9, 1983.IE Information

Notice No. 83-52, "Radioactive

Waste Gas System Events," August 9, 1983.IE Information

Notice No. 84-37, "Use of Lifted Leads and Jumpers During Maintenance

or Surveillance

Testing," May 10, 1984.Description

of Circumstances:

On November 18, 1985 the Cooper Nuclear Station was in a shutdown condition (reactor coolant temperature

less than 212 0 F and vented) with acceptance

testing for a plant design change in progress.

When this testing failed to provide for the required Group VI isolation (various containment

isolation

and Copies to: Withers, Yundt, Lentsch, Orser, Steele, E. Burton, E. Jordan, A. Holm, iLIS;.j. A. Olmstead, S. Hoag, S. Sautter, TNP:GOV REL F:NRC CHRONO, TNiPGOV REL F:NRC IE Information

Notice 86-42 PGE OAR Action -M. H. Halmros (Due 8/12/86)NSRD Action -M. H. Malmros

IN 86-42 June 9, 1986 engineered

safety feature (ESF) initiations), the licensee investigated

and discovered

that electrical

jumpers were installed

in the reactor building (RB)ventilation

radiation

monitors (VRM) auxiliary

trip units. These jumpers prohibited

a Group VI isolation

by a high radiation

signal from the RB VRM.The jumpers were immediately

removed and the NRC was promptly notified as required by 10 CFR 50.72.The licensee's

subsequent

investigation

revealed that the electrical

jumpers had been installed

on November 13, 1985 by an instrument

and control technician

during a routine surveillance

procedure

to functionally

test the VRM. These jumpers are used to prevent trip and equipment

operations

during the required functional/calibration

testing. The technician

had signed off the procedural

step requiring

jumper removal (before actually removing the electrical

jumper)and then started checking control room annunciator

and trip signal status. The technician

then became involved in other unrelated

craft work and forgot to go back and remove the jumpers.On November 18, 1986, before discovery

of the jumpers, 18 irradiated

fuel bundles were loaded into a spent fuel shipping cask. Failure to properly implement

the surveillance

procedure

for operability

checks of radiation monitors rendered inoperable

the automatic

initiation

of the standby gas treatment

system (SBGTS) and automatic

isolation

of the reactor building upon receipt of a high radiation

signal. This degraded condition

lasted approxi-mately 5 days. However, control room annunciators

and instrumentation

that would provide warning to operators

of any high radiation

problems remained operational

during the 5 days. Manual-start

of the SBGTS and reactor building isolation

capabilities

from the control room remained available

during the event.Discussion:

This event clearly demonstrates

that the level of attention

given to the procedural

controls for the maintenance

of radioactive

monitoring

systems providing

ESF actuation

can be significantly

improved.

While there were no actual radiological

consequences

of this event, the NRC took escalated

enforce-ment actions (issued civil penalty) to emphasize

the importance

of correctly performing

surveillance

procedures

on systems designed to mitigate or prevent accidents.

Attachment

No. 1 contains 6 summaries

of related events taken from the Licensee Event Report files. Further examples of how improper maintenance

practices

have degraded radiation

monitoring

systems are provided in the listed Previous Related Correspondence

section.The Cooper Station initiated

the following

corrective

actions to prevent recurrence:

1. All temporary

modifications (e.g., electrical

jumpering, fuse removal)performed

by the involved technician

since October 5, 1985 were indepen-dently verified.2. Site management

stressed the importance

of procedural

adherence--sign

off the procedural

step after completing

the required action.

IN 86-42 June 9, 1986 3. All surveillance

procedures

requiring

temporary

modifications

to system or plant components

were reviewed for deficiencies, and these procedures

will be modified to provide for independent

verification

to ensure that tempo-rary modifications

are removed and the system/component

is fully restored to operational

status.No specific action or written response is required by this information

notice.If you have any questions

about this matter, please contact the Regional Administrator

of the appropriate

regional office or this office.4'-CJ1ward

L. Jord, Director Division of Edergency

Preparedness

and Engineering

Response Office of Inspection

and Enforcement

Technical

Contacts:

James E. Wigginton, IE (301) 492-4967 Roger L. Pedersen, IE (301) 492-9425 Attachments:

1. Event Summaries 2. List of Recently Issued IE Information

Notices

Attachment

1 IN 86-42 June 9, 1986 EVENT SUMMARIES Unplanned

Gaseous Release (Connecticut

Yankee, PWR)LER 85-025 Event Date: 9/19/85 Cause: Personnel

Maintenance

Error Abstract:

With the plant operating

at 100 percent power, a main stack high radiation

alarm was received during routine scheduled

maintenance

on a pressure actuated valve in the gaseous waste stream. The unplanned

release occurred through an isolation

valve inadvertently

left open, allowing the on-line waste gas decay tank a release path.The maintenance

tag-out procedure

correctly

required the isolation valve to be isolated, but the operator shut the wrong valve. The total noble gas release was approximately

20 curies (about 14 percent of technical

specification

limit). Licensee corrective

action included clearly relabeling

associated

valves and discussion

of the event with operation

staff.Containment

Radiation

Monitor Isolated (Byron 1, PWR)LER 85-026 Event Date: 2/28/85 Cause: Improper Valve Position Abstract:

With the reactor at zero percent power, a containment

radiation monitor used for required reactor coolant leakage detection

was inadvertently

left isolated for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from containment

after maintenance

on an associated

valve. Abnormal in-leakage

at the monitor caused normal-range

readings on RM-li console in the main control room (leakage was later repaired).

Licensee corrective

action included implementing

administrative

controls to ensure system integrity/proper

restoration

after completion

of maintenance

activities.

Liquid Radwaste Effluent Monitor Isolated (Cooper, BWR)LER 84-008 Event Date: 6/09/84 Cause: Monitor Discharge

Valve Shut Abstract:

A liquid discharge

occurred without required continuous

radiation

monitoring

because the liquid effluent radiation

monitor was isolated.

No discharge

limits were exceeded.

Two days before the event, a technician

apparently

shut the radiation

monitor outlet valve during maintenance

without permission

or knowledge

of operations

personnel.

As corrective

actions, the licensee revised controlling

procedures

and informed all plant operators

of the event.

Attachment

1 IN 86-42 June 9, 1986 Off-Gas Stack Monitor Inoperable (Cooper, BWR)LER 84-006 Event Date: 4/18/84 Cause: Personnel

Error Abstract:

With the reactor at 70 percent power, the off-gas stack effluent sampler was found inoperable.

The sampler was drawing air from the surrounding

off-gas filter building ambient atmosphere

instead of sampling the plant stack effluent.

The event resulted from a chemistry

technician

failing to follow the approved procedure

for changing the inline particulate

filter/iodine

cartridge (routine operation).

In addition to making appropriate

supervisors

and all chemistry

technicians

aware of the event, the licensee revised and clarified

the governing

procedure

to prevent recurrence.

Liquid Radwaste Auto-Isolation

Valve Inoperative (Hatch 1, BWR)LER 82-093 Event Date: 11/07/82 Cause: Jumper Installed Abstract:

During a liquid radwaste discharge, the licensee discovered

that the radiation

monitor auto control (provides

isolation

signal upon high radiation)

to the discharge

isolation

valve was inoperable.

However, the monitor's

alarm function remained operable.

An electrical

jumper used during corrective

maintenance

had not been removed after the work was completed.

Containment

Atmosphere

Radiation

Monitors Isolated (FitzPatrick

1, BWR)LER 81-061 (Rev 1 Event Date: 8/21/81 Cause: Containment

Isolation

Valve Isolated Abstract:

The NRC resident inspector

discovered

that during normal 85 percent power operations

the containment

isolation

valves for the containment

atmosphere

gaseous and particulate

monitoring

system had been shut for approximately

22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />. With this loss of monitoring

capability, the technical

specifications

require a reactor hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The event occurred because a surveillance

procedure

did not direct the operator to re-open the isolation

valves following'

the surveillance

activities.

As a corrective

action, the licensee corrected

the subject procedure

and reviewed all other surveillance

procedures

for similar deficiencies.

4'Attachment

2 IN 86-42 June 9, 1986 LIST OF RECENTLY ISSUED IE INFORMATION

NOTICES Information

Date of Notice No. Subject Issue Issued to 86-41 86-32 Sup. 1 86-40 86-39 86-38 86-37 86-36 86-35 86-34 Evaluation

Of Questionable

Exposure Readings Of Licensee Personnel

Dosimeters

Request For Collection

Of Licensee Radioactivity

Measurements

Attributed

To The Chernobyl

Nuclear Plant Accident Degraded Ability To Isolate The Reactor Coolant System From Low-Pressure

Coolant Systems in BWRS Failures Of RHR Pump Motors And Pump Internals Deficient

Operator Actions Following

Dual Function Valve Failures Degradation

Of Station Batteries Change In NRC Practice Regarding

Issuance Of Confirming

Letters To Principal

Contractors

6/9/86 6/6/86 6/5/86 5/20/86 5/20/86 5/16/86 5/16/86 All byproduct material licensees All power reactor facilities

holding an OL or CP All power reactor facilities

holding an OL or CP All power reactor facilities

holding an OL or CP All power reactor facilities

holding an OL or CP All power reactor facilities

holding an OL or CP All power reactor facilities

holding an OL or CP All power reactor facilities

holding an OL or CP All power reactor facilities

holding an OL or CP -Fire In Compressible

Material 5/15/86 At Dresden Unit 3 Improper Assembly, Material 5/13/86 Selection, And Test Of Valves And Their Actuators OL = Operating

License CP = Construction

Permit