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| | issue date = 12/03/1997 | | | issue date = 12/03/1997 |
| | title = LER 97-006-00:on 971103,NIS Audible Count Rate Function Was Inoperable.Caused by Misinterpretation of Event Sequence Due to Not Verifying Boron Concentration.B Verification Occurred Every 12 H Per ITS LCO Action 3.9.2.C.3.W/971203 Ltr | | | title = LER 97-006-00:on 971103,NIS Audible Count Rate Function Was Inoperable.Caused by Misinterpretation of Event Sequence Due to Not Verifying Boron Concentration.B Verification Occurred Every 12 H Per ITS LCO Action 3.9.2.C.3.W/971203 Ltr |
| | author name = MECREDY R C, ST MARTIN J T | | | author name = Mecredy R, St Martin J |
| | author affiliation = ROCHESTER GAS & ELECTRIC CORP. | | | author affiliation = ROCHESTER GAS & ELECTRIC CORP. |
| | addressee name = VISSING G S | | | addressee name = Vissing G |
| | addressee affiliation = NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) | | | addressee affiliation = NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| | docket = 05000244 | | | docket = 05000244 |
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| =Text= | | =Text= |
| {{#Wiki_filter:CATEGORY1REGUZATOZNFORNATZON DZSTR1BUT1ON ISTEN(RZDS) | | {{#Wiki_filter:CATEGORY 1 REGUZATO ZNFORNATZON DZSTR1BUT1ON ISTEN (RZDS) |
| | ACCESSION NBR:9712100274 .DOC'.DATE:"97/12'/03 NOTARIZED: NO DOCKET 4 FACZZ:50-244 Robert 2Znaet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 AUTH.NAME ' 'UTHOR AFFILIATION ST.MARTIN,J.T. Rochester Gas & Electric Corp. |
| | MECREDY,R.C. Rochester Gas Ec Electric Corp. |
| | RECIP.NAME RECIPIENT AFFILIATION VISSING, G. S'.,"-; |
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| ==SUBJECT:== | | ==SUBJECT:== |
| LER97-006;-00:on!'971103,NIS audiblecountratefunctionwasinoperable.
| | LER 97-006;-00:on!'971103,NIS audible count rate function was inoperable. Caused by misinterpretation of event secpxence due to not verify3ng boron concentration.B verification .occurred every 12 h- per ITS LCO acti. on 3.9.2.C.3.W/971203 ltr. |
| Causedbymisinterpretation ofeventsecpxence duetonotverify3ng boronconcentration.B verification
| | 0 DISTRIBUTION:CODE: IE22T 'OPIES RECEIVED:LTR"J ENCL l" SIZE: |
| .occurred every12h-perITSLCOacti.on3.9.2.C.3.W/971203 ltr.0DISTRIBUTION:CODE: | | TITLE: '50.73/50.9 Li.censee Event Report (LER), Incident Rpt', etc. |
| IE22T'OPIESRECEIVED:LTR"J ENCLl"SIZE:TITLE:'50.73/50.9 Li.censee EventReport(LER),IncidentRpt',etc.4~'\I1NOTES:License Expdateinaccordance wi.th10CFR2,2.109(9/19/72). | | ~ '\ I 4 1 NOTES:License Exp date in accordance wi.th 10CFR2,2.109(9/19/72). 05000244 G RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID '.CODE/NAME LTTR ENCL, R PD1-1 PD 1 1 VISSING,G. 1 1 INTERNAL: AEO 2 2 AEOD/SPD/RRAB 1 1 E CENTE 1 1 NRR/DE/ECGB 1 1 NRR DE E LB 1 1 NRR/DE/EMEB 1 1 NRR/DRCH/HHFB 1 1 NRR/DRCH/HICB 1 1 NRR/DRCH/HOLB 1 1 NRR/DRCH/HQMB 1 1 NRR/DRPM/PECB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 RES/DET/EIB '1 1 RGN1 FILE 01 1 1 D |
| 05000244GACCESSION NBR:9712100274
| | EXTERNAL: L ST LOBBY WARD 1 1 LITCO BRYCE,J H 1 0 |
| .DOC'.DATE:"97/12'/03 NOTARIZED:
| | 1 NOAC POORE,W. 1 1 NOAC QUEENER,DS 1 1 NRC PDR 1 1 NUDOCS FULL TXT 1 1 U |
| NODOCKET4FACZZ:50-244 Robert2ZnaetGinnaNuclearPlant,Unit1,Rochester G05000244AUTH.NAME''UTHORAFFILIATION ST.MARTIN,J.T.
| | NOTE TO ALL "RIDS" RECIPIENTS: |
| Rochester Gas&ElectricCorp.MECREDY,R.C.
| | PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRZBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24 |
| Rochester GasEcElectricCorp.RECIP.NAME RECIPIENT AFFILIATION VISSING,G.S'.,"-;RECIPIENT IDCODE/NAME PD1-1PDINTERNAL:
| |
| AEOECENTENRRDEELBNRR/DRCH/HHFB NRR/DRCH/HOLB NRR/DRPM/PECB NRR/DSSA/SRXB RGN1FILE01EXTERNAL:
| |
| LSTLOBBYWARDNOACPOORE,W.NRCPDRCOPIESLTTRENCL112211111111111111111111RECIPIENT ID'.CODE/NAME VISSING,G.
| |
| AEOD/SPD/RRAB NRR/DE/ECGB NRR/DE/EMEB NRR/DRCH/HICB NRR/DRCH/HQMB NRR/DSSA/SPLB RES/DET/EIB LITCOBRYCE,JHNOACQUEENER,DS NUDOCSFULLTXTCOPIESLTTRENCL,11111111111111'11111111RD0UNOTETOALL"RIDS"RECIPIENTS: | |
| PLEASEHELPUSTOREDUCEWASTE.TOHAVEYOURNAMEORORGANIZATION REMOVEDFROMDISTRZBUTION LISTSORREDUCETHENUMBEROFCOPIESRECEIVEDBYYOUORYOURORGANIZATION, CONTACTTHEDOCUMENTCONTROLDESK(DCD)ONEXTENSION 415-2083FULLTEXTCONVERSION REQUIREDTOTALNUMBEROFCOPIESREQUIRED:
| |
| LTTR24ENCL24 ANDROCHESTER GASANDElECTRICCORPORATTON
| |
| ~89EASTAVENUE, ROCHESTER, MY.l4649-D001 AREACODE7I6546-270DROBERTC.MECREDYVicePresident Nuctearoperations December3,1997SubjectU.S.NuclearRegulatory Commission DocumentControlDeskAttn:GuyS.VissingProjectDirectorate I-1Washington, D.C.20555)LER97-006,Verification ofBoronConcentration NotPerformed DuetoMisinterpretation ofEventSequence, ResultedinCondition Prohibited byTechnical Specifications R.E.GinnaNuclearPowerPlantDocketNo.50-244
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| ==DearMr.Vissing:==
| | AND ROCHESTER GAS AND ElECTRIC CORPORATTON ~ 89 EASTAVENUE, ROCHESTER, M Y. l4649-D001 AREA CODE7I6 546-270D ROBERT C. MECREDY Vice President Nuctear operations December 3, 1997 U.S. Nuclear Regulatory Commission Document Control Desk Attn: Guy S. Vissing Project Directorate I-1 Washington, D.C. 20555 |
| Inaccordance with10CFR50.73,LicenseeEventReportSystem,item(a)(2)(i)(B),whichrequiresareportof,"Anyoperation orcondition prohibited bytheplant'sTechnical Specifications",
| | ) |
| theattachedLicenseeEventReportLER97-006isherebysubmitted.
| | Subject LER 97-006, Verification of Boron Concentration Not Performed Due to Misinterpretation of Event Sequence, Resulted in Condition Prohibited by Technical Specifications R.E. Ginna Nuclear Power Plant Docket No. 50-244 |
| Thiseventhasinnowayaffectedthepublic'shealthandsafety.Verytrulyyours,RobertC.Mecredyxc:Mr.GuyS.Vissing(MailStop14B2)PWRProjectDirectorate I-1Washington, D.C.20555U.S.NuclearRegulatory Commission RegionI475Allendale RoadKingofPrussia,PA19406GinnaSeniorResidentInspector
| |
| "(-aI0lllllllllllllllllllllllllllllllllllfllll 9'712i00274
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| 'st7i20SPDRADOCK050002448PDR
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| NRCFORM366(4-95)U.S.NRREGULATORY COMNIISSIO LXCENSEEEVENTREPORT,(LER) n(Seereverseforrequirednumber'fdigits/characters foreachblock)APEDBYOMBNO.3150%104EXPIRES04/30/98ESTIMATED BURDENPERRESPONSEToCOMPLYWITHTHISMANDATORY INFORMATION COLLECTION REQUEST:50.0HRS.REPORTEDLESSONSLEARNEDAREINCORPORATED INTOTHELICENSING PROCESSANDFEDBACKToINDUSTRY.
| | ==Dear Mr. Vissing:== |
| FORWARDCOMMENTSREGARDING BURDENESTIMATEToTHEINFORMATION ANDRECORDSMANAGEMENT BRANCHIT.6F33),U.S.NUCLEARREGULATORY COMMISSION, WASHINGTON, DC20555-0001, ANDToTHEPAPERWORK REDUCTION PROJECTFACIUTYNAMEIllTrrLEfa)R.E.GinnaNuclearPowerPlantDOCKETirVMSERf2)05000244PADEI3I1OF6Verification ofBof'onConcentration NotPerformed DuetoMisinterpretation ofEventSequence, ResultedinCondition Prohibited byTechnical Specifications EVENTDATE(5)LERNUMBER(6)REPORTDATE(7)OTHERFACILITIES INVOLVED(8)MONlHDAYYEARYEARSEQENTIALREVISOMONUMBERNUMBER~IDAYI:YEAR.FACILITYNAMEDOCKETNUMBER039797-006-001'2.03FACIUTYNAME97DOCKETNUMBEROPERATING MODE(9)THISREPORTISSUBMITTED PUBSUANTTOTHEREQUIREMENTS OF10CFRE:(Checkoneor50.73(a)(2)(i)20.2203(a)
| |
| (2)(v)20.2201(b)
| |
| Illore)(11)50.73(a)(2)(viii)POWERLEVEL(10)00020.2203(a)
| |
| (1)20.2203(a)
| |
| (2)(i)20.2203(a)
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| (2)(ii)20.2203(a)
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| (2)(iii)20.2203(a)(2)(lv)
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| .20.2203(a)
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| (3)(i)20.2203(a)
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| (3)(ii)20.2203(a)(4) 50.36(c)(1) 50.36(c)(2)50.73(a)(2)(ii) 50.73(a)(2)
| |
| (iii)50.73(a)(2)(iv)50.73(a)(2)(v) 50.73(a)(2)(vii)50.73(a)(2)(x) 73.71OTHERSpecifyinAbstractbeloworInNRCForm366ANAMELICENSEECONTACTFORTHISLER(12)TELEPHONE kUMBERBncrudeAreaCode)JohnT.St.Martin-Technical Assistant (716)771-3641COMPLETEONELINEFOREACHCOMPONENT FAILUREDESCRIBED INTHISREPORT(13)CAUSESYSTEMCOMPONENT MANUFACTURER REPORTABLE TONPRDSCAUSESYSTEMCOMPONENT MANUFACTURER REPORTABLE ToNPRDSSUPPLEMENTAL REPORTEXPECTED(14)YES(Ifyes,completeEXPECTEDSUBMISSION DATE).XNOEXPECTEDSUBMISSION DATE(15)MONTHDAYYEARABSTRACT(Limitto1400spaces,I.e.,approximately 15single-spaced typewritten lines)(16)OnNovember3,1997,atapproximately 1708EST,theplantwasinMode6,andrefueling activities hadbeencompleted twodaysearlier.Thereactorcoolantsystembeingmaintained atatemperature of75degreesF,andthereactorcavityfilledtogreaterthan23feet.Itwasdiscovered thatthenuclearinstrumentation systemaudiblecountratefunctionwasinoperable.
| |
| Immediate actionwastoensurefuturecompliance totheGinnaTechnical Specifications forlossofthisfunction.
| |
| Thisincludedverifying thatthemostrecentboronconcentration waswithinspecified limitsandformallytrackingthetimeforfutureverification ofboronconcentration.
| |
| Duetoamisinterpretation oftheeventsequence, thev'erification ofboronconcentration maynothavebeenperformed withinthetimeperiodspecified byGinnaTechnical Specifications RequiredActionsforthemostlimitingeventsequence.
| |
| Corrective actiontopreventrecurrence isoutlinedinSectionV.B.NRCFORM366(4-95)
| |
| I NRCFORM366A(4-95)LICENSEEEVENTREPORT(LER)TEXTCONTINUATION
| |
| .NUCLEARREGULATORY COMMISSION FACILITYNAME(1)R.E.GinnaNuclearPowerPlantDOCKET05000244LERNUMBER(6)YEARSEQUENTIAL REVISIONNUMBERNUMBER97-006-00PAGE(3)2OF6TEXT(Ifmorespaceisrequired, useadditional copiesofNRCForm366A/(17)PRE-EVENT PLANTCONDITIONS:
| |
| <~~.~'C~il~lil~OnNovember3,1997,theplantwasinMode6withthereactorcoolantsystem(RCS)beingmaintained atatemperature ofapproximately.75 degreesF,andthereactor,cavityfilledtogreaterthan23feet.Theplantwasshutdownfor'refueling, andrefueling activities (corealterations) hadalreadybeencompleted twodaysearlier,Atapproximately 0753EST,thenuclearinstrumentation system(NIS)Comparator andRatedrawerwasremovedfromserviceforcalibration perprocedure CPI-COMP/RATE-N46/37 (Calibration ofComparator andRateDrawerN46/37).Atthistime,theaudiblecountratefunctionwasoperable.
| |
| DESCRIPTION OFEVENT:DATESANDAPPROXIMATE TIMESOFMAJOROCCURRENCES:
| |
| November3,1997,0025EST:RCSboronconcentration verifiedat2463PPM.November3,1997,0753EST:NISComparator andRatedrawerisremovedfromservice.November3,1997,1300EST:RCSboronconcentration verifiedat2453PPM.November3,1997:Eventdate.November3,1997,1708EST:Discovery dateandtime.November4,1997,0100EST:RCSboronconcentration verifiedat2470PPM.November4,1997:NISaudiblecountrateisrestoredtooperablestatus.B.EVENT:Atthebeginning oftheafternoon shiftonNovember3,theoperability oftheNISaudiblecountratefunctionwasquestioned, sincethenormalaudiblebeepingdidnotseemtobeoccurring.
| |
| Atthistime,itwasassumedthattheaudiblecountratefunctionhadbeenmadeinoperable atthetimeprocedure CPI-COMP/RATE-N46/37 wasinitiated.
| |
| Forconvenience, thistimewasdocumented asthetimeadministrative trackinghadbeeninitiated fortheComparator andRateDrawer,atapproximately 0753ESTonNovember3.Therefore, usingthiseventsequenceandtheassumedtimeofinoperability, theinitialadministrative tracking(whichdidnotaddressthelossofaudiblecountratefunction) wassupplemented byadministrative procedure A-52.4(ControlofLimitingConditions forOperating Equipment) atapproximately 1708EST.TheA-52.4trackingwasinitiated effective at0753ESTasa"lateentry".NRCFORM366A(4-95) t NRCFORM36BA(4-95)LICENSEEEVENTREPORT(LER)TEXTCONTINUATION
| |
| .NUCLEAR'REGULATORY COMMISSION FACILITYNAME(1)R.E.GinnaNuclearPowerPlantDOCKET05000244LERNUMBER(6)YEARSEQUENTIAL REVISIONNUMBERNUMBER97-006-00PAGE(3)3OF6TEXTilfmorespeceisrequired, useedditionel copiesofNRCForm368AJ(17)Basedontheeventsequencethatinoperability occurredat0753EST,theControlRoomoperators concluded thattheplantcontinued tobeincompliance with'Ginna ImprovedTechnical Specifications (ITS)LimitingCondition forOperation (LCO)REQUIREDACTIONS3.9.2.C.1 and3.9.2.C.2, since,therehadbeennocorealterations orpositivereactivity additions duringthis.time.However,REQUIREDACTION-3.9.2.C.3, for'RCSboronconcentration verifiedtobewithinthelimitsspecified intheCoreOperating LimitsReport(COLR),hadonlybeenaccomplished atapproximately 0025ESTand1300ESTonNovember3.~i.XlThus,atapproximately 1708ESTonNovember3,itwasdiscovered thattheNISaudiblecountratewasinoperable.
| |
| 'Duetotheassumedeventsequence, itwasconcluded thatinoperability occurredat0753EST,andtheControlRoomoperators immediately enteredITSLCO3.9.2at,1708EST.TheRCSboronconcentration hadbeenverifiedatapproximately 1300EST.Sincetheoperators concluded thatRCSboronconcentration hadnotbeenverifiedwithin4hoursoftheassumedtimeofinoperability, the1300ESTboronconcentration wasusedtoinitiatethe12hourtimerequirement ofITSLCOREQUIREDACTION,3.9.2.C.3.
| |
| Subsequent RCSboronconcentration verification wouldberequiredevery12hours.ThenextRCSboronconcentration verification wasperformed atapproximately 0100EST,onNovember4,andtheNISaudiblecountratefunctionwasrestoredtooperablestatuslaterthatmorning.Uponfurtherreview,activities performed perprocedure CPI-COMP/RATE-N46/37 didnotrendertheNISaudiblecountrateinoperable.
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| Therefore, theeventsequenceconcluding thatinoperability occurredat0753ESTisincorrect.
| |
| TheprecisetimethattheNISaudiblecountratefunctionbecameinoperable onNovember3isnotknown,butthemostlimitingeventsequenceisifitoccurredafter1300EST,orbetween0753and0900EST.Ineitherofthesescenarios, ITSLCOREQUIREDACTION3.9.2.C.3 wasnotperformed within4hoursoftheevent.C.INOPERABLE STRUCTURES, COMPONENTS, ORSYSTEMSTHATCONTRIBUTED TOTHEEVENT:NoneD.OTHERSYSTEMSORSECONDARY FUNCTIONS AFFECTED:
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| NoneE.METHODOFDISCOVERY:
| |
| Thiseventwasindicated duringroutineoperations reviewofplantstatusduringashiftturnovermeeting,andwasformallydiscovered shortlyaftershiftturnover.
| |
| However,theactualeventsequence, including thefactthattheprecisetimeofinoperability isnotknown,wasnotdiscovered untilseveraldayslater.NRCFORM366A(4-95)
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| NRCFORM366A(4-95)LICENSEEEVENTREPORT(LER)TEXTCONTINUATION
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| .NUCLEARREGULATORY COMMISSION FACILITYNAME(1)DOCKETLERNUMBER(6)PAGE(3)R.E.GinnaNuclearPowerPlant.05000244YEARSEQUENTIAL REVISIONNUMBERNUMBER4OF697-006-00TEXTIifmorespeceisrequired, useeddirional copiesofNRCForm366AJ(17)F.OPERATORACTION:VTheControlRoombperators'identified thattherewasnoadministrative trackingoftheaudiblecount.ratefunction, andsubmitted administrative procedure A-52.4forformaltrackingofthe~audible'count.rate function.
| |
| Basedontheirassumedeventsequence, ITSLCOREQUIREDACTION~3.9.2.C.3 hadnotbeenperformed within4hoursofinoperability, butasubsequent (1300EST)boronconcentration verification wasusedtoinitiatethe12hourtimerequirement.
| |
| FutureRCSboronconcentration verification wouldbeperformed every12hours,perthisREQUIREDACTION.TheControlRoomoperators notifiedhighersupervision.
| |
| a~">,'}1<AControlRoomoperatormanuallyrestoredtheNISaudiblecountratefunctionduringthemidnightshiftonNovember4,1997.G.SAFETYSYSTEMRESPONSES:
| |
| NoneIII.CAUSE'OFEVENT:A.IMMEDIATE CAUSE;Theimmediate causeofthecondition prohibited byTechnical Specifications wasnotverifying RCSboronconcentration within4hoursafterdiscovering thattheaudiblecountratefunctionwasinoperable, usingthemostlimitingeventsequenceforlossofthisfunction.
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| B.INTERMEDIATE CAUSE:Theintermediate causeofnotverifying boronconcentration wasamisinterpretation oftheeventsequence.
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| ROOTCAUSE:Themisinterpretation oftheeventsequenceledtoadecisionthatwasincorrect.
| |
| NotethattheprecisetimethattheNISaudiblecountratefunctionbecameinoperable isnotknown.Thismisinterpretation wasmadepossiblebecausethereisnopositiveindication ofwhentheaudiblecountratefunctionbecameinoperable.
| |
| Procedures weredeficient inthattheapplicability ofITSLCO3,9.2atalltimeswhileinMode6wasnotaddressed inplantoperating procedures.
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| Procedures werealsodeficient inthatactionsneededtoverifytheoperability oftheNISaudiblecountratewerenotspecified incalibration andtestprocedures.
| |
| NACFOAM366A(4-95)
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|
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|
| NRCFORM366A(4-95)LXCENSEEEVENTREPORT(LER)TEXTCONTINUATION
| | In accordance with 10 CFR 50.73, Licensee Event Report System, item (a) (2) (i) (B), which requires a report of, "Any operation or condition prohibited by the plant's Technical Specifications", the attached Licensee Event Report LER 97-006 is hereby submitted. |
| .NUCLEARREGULATORY COMMISSION FACILITYNAME(1)R.E.GinnaNuclearPowerPlantDOCKET05000244LERNUMBER(6)YEARSEQUENTIAL REVISIONNUMBERNUMBER97-006-00PAGE(3)5OF6TEXTllfmorespaceisrequired, useadditional copiesofNRCForm366A/(17)IV.ANALYSISOFEVENTThiseventis"reportable inaccordance with10CFR50.73,LicenseeEventReportSystem,item(a)(2)(i)(B),,which. | | This event has in no way affected the public's health and safety. |
| requiresareportof,"Anyoperation orcondition prohibited bytheplant'sTechnical
| | Very truly yours, Robert C. Mecredy xc: Mr. Guy S. Vissing (Mail Stop 14B2) |
| 'pecifications": | | PWR Project Directorate I-1 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector |
| WiththeNISaudiblecountrateinoperable, notverifying RCSboronconcentration within4hoursafterdiscovery.
| | "(- lllllllllllllllllllllllllllllllllllfllll a I 0 9'712i00274 'st7i20S PDR ADOCK 05000244 8 PDR |
| isnotpermitted byITSLCOREQUIREDACTION3.9.2.C.3.
| | |
| Anassessment'was performed considering boththesafetyconsequences andimplications ofthiseventwiththefollowing resultsandconclusions:
| | NRC FORM 366 U.S. N R REGULATORY COMNIISSIO AP ED BY OMB NO. 3150%104 (4-95) EXPIRES 04/30/98 ESTIMATED BURDEN PER RESPONSE To COMPLY WITH THIS MANDATORY INFORMATION COLLECTION REQUEST: 50.0 HRS. |
| II'1"~Ili+~I'herewerenooperational orsafetyconsequences orimplications.
| | LXCENSEE EVENT n REPORT,(LER) REPORTED LESSONS LEARNED ARE INCORPORATED INTO THE LICENSING PROCESS AND FED BACK To INDUSTRY. FORWARD (See reverse for required number'f COMMENTS REGARDING BURDEN ESTIMATE To THE INFORMATION AND RECORDS MANAGEMENT BRANCH IT.6 F33), |
| attributed tothedelayedverification ofboronconcengration because:\~Nocorealterations andnopositivereactivity additions occurredduringthistimeperiod.~RCSboronconcentration verification wasbeingperformed every12hours.PreviousRCSboronsampleshadconfirmed consistent boronconcentrations thatwerewellwithinthelimitspecified intheCOLR.Basedontheabove,itcanbeconcluded thatthepublic'shealthandsafetywasassuredatalltimes.CORRECTIVE ACTION:A.ACTIONTAKENTORETURNAFFECTEDSYSTEMSTOPRE-EVENT NORMALSTATUS:~ThemostrecentRCSboronconcentration wasverifiedtobewithinthelimitspecified inthe,COLR.~Subsequent boronverification occurredevery12hours,asperITSLCORequiredAction3.9.2.C.3.
| | digits/characters for each block) U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555-0001, AND To THE PAPERWORK REDUCTION PROJECT FACIUTY NAME Ill DOCKET irVMSER f2) PAD E I3I R.E. Ginna Nuclear Power Plant 05000244 1 OF 6 TrrLE fa) |
| ~Afterinvestigation ofthecauseforlossofthisfunction, theaudiblecountratefunctionwasrestoredtooperablestatus.B.ACTIONTAKENORPLANNEDTOPREVENTRECURRENCE: | | Verification of Bof'on Concentration Not Performed Due to Misinterpretation of Event Sequence, Resulted in Condition Prohibited by Technical Specifications EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8) |
| ~Therequirement tohaveaudiblecountrateoperableatalltimeswhileinMode6appearstobeconservative. | | SEQ ENTIAL REVISO FACILITYNAME DOCKET NUMBER MONlH DAY YEAR YEAR NUMBER MO DAY I:YEAR. |
| TheHighFluxatShutdownalarmmayprovideadequateassurance ofnoadversechangesincorereactivity whileinMode6(andnocorealterations orpositivereactivity additions areoccurring).
| | NUMBER |
| NuclearSafetyandLicensing willberequested toevaluateaLicenseAmendment tochangethisrequirement inITS.NRCFORM366A(4-95)
| | ~ I FACIUTY NAME 03 97 97 006 00 1'2. 03 97 DOCKET NUMBER OPERATING THIS REPORT IS SUBMITTED PUBS UANT TO THE REQUIREMENTS OF 10 CFR E: (Check one or Illore) (1 1) |
| NRCFORM366A(4.95)LXCENSEEEVENTREPORT(LER)TEXTCONTINUATION
| | MODE (9) 20.2201(b) 20.2203(a) (2)(v) 50.73(a) (2) (i) 50.73(a) (2) (viii) |
| .NUCLEARREGULATORY COMMISSION FACILITYNAME(1)DOCKETLERNUMBER(6)PAGE(3)R.E.GinnaNuclearPowerPlant05000244YEARSEQUENTIAL REVISIONNUMBERNUMBER6OF6TEXTiifmorespaceisrequired, useadditional copiesofNRCForm366Aj(17)Vl~Appropriate calibration andtestprocedures willbereviewed, andchangedasnecessary, toensureaudiblecountrateoperability aftercompletion ofcalibrations ortests.Operating procedures willbereviewed, andchangedasnecessary, toensureaudiblecountrateoperability isverifi6dwhen..inMode6.',d(~~ADDITIONAL INFORMATION:
| | POWER 20.2203(a) (1) 20.2203(a) (3) (i) 50.73(a)(2)(ii) 50.73(a)(2)(x) |
| ~~IIA.FAILEDCOMPONENTS: | | LEVEL (10) 000 20.2203(a) (2) (i) 20.2203(a) (3)(ii) 50.73(a)(2) (iii) 73.71 20.2203(a) (2)(ii) 20.2203(a)(4) 50.73(a) (2) (iv) OTHER 20.2203(a) (2) (iii) 50.36(c)(1) 50.73(a)(2)(v) Specify in Abstract below or In NRC Form 366A 20.2203(a)(2)(lv) . 50.36(c) (2) 50.73(a) (2)(vii) |
| NoneB.PREVIOUSLERsONSIMILAREVENTS:AsimilarLEReventhistorical searchwasconducted withthefollowing results:Nodocumentation ofsimilarLEReventswiththesamerootcauseatGinnaStationcouldbeidentified.
| | LICENSEE CONTACT FOR THIS LER (12) |
| C.SPECIALCOMMENTS: | | NAME TELEPHONE kUMBER Bncrude Area Code) |
| NoneNRCFORM366A(4-95) 0I}}
| | John T. St. Martin - Technical Assistant (716) 771-3641 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13) |
| | CAUSE SYSTEM COMPONENT REPORTABLE REPORTABLE MANUFACTURER CAUSE SYSTEM COMPONENT MANUFACTURER TO NPRDS To NPRDS SUPPLEMENTAL REPORT EXPECTED (14) MONTH DAY YEAR EXPECTED YES SUBMISSION (If yes, complete EXPECTED SUBMISSION DATE). X NO DATE (15) |
| | ABSTRACT (Limit to 1400 spaces, I.e., approximately 15 single-spaced typewritten lines) (16) |
| | On November 3, 1997, at approximately 1708 EST, the plant was in Mode 6, and refueling activities had been completed two days earlier. The reactor coolant system being maintained at a temperature of 75 degrees F, and the reactor cavity filled to greater than 23 feet. It was discovered that the nuclear instrumentation system audible count rate function was inoperable. |
| | Immediate action was to ensure future compliance to the Ginna Technical Specifications for loss of this function. |
| | This included verifying that the most recent boron concentration was within specified limits and formally tracking the time for future verification of boron concentration. |
| | Due to a misinterpretation of the event sequence, the v'erification of boron concentration may not have been performed within the time period specified by Ginna Technical Specifications Required Actions for the most limiting event sequence. |
| | Corrective action to prevent recurrence is outlined in Section V.B. |
| | NRC FORM 366 (4-95) |
| | |
| | I NRC FORM 366A . NUCLEAR REGULATORY COMMISSION (4-95) |
| | LICENSEE EVENT REPORT (LER) |
| | TEXT CONTINUATION FACILITY NAME (1) DOCKET LER NUMBER (6) PAGE (3) |
| | YEAR SEQUENTIAL REVISION NUMBER NUMBER R.E. Ginna Nuclear Power Plant 2 OF 6 05000244 97 006 00 TEXT (Ifmore spaceis required, use additional copies of NRC Form 366A/ (17) |
| | PRE-EVENT PLANT CONDITIONS: < ~ ~ |
| | . ~ ' |
| | C ~ i l ~ |
| | lil ~ |
| | On November 3, 1997, the plant was in Mode 6 with the reactor coolant system (RCS) being maintained at a temperature of approximately.75 degrees F, and the reactor, cavity filled to greater than 23 feet. The plant was shut down for'refueling, and refueling activities (core alterations) had already been completed two days earlier, At approximately 0753 EST, the nuclear instrumentation system (NIS) Comparator and Rate drawer was removed from service for calibration per procedure CPI-COMP/RATE-N46/37 (Calibration of Comparator and Rate Drawer N46/37). At this time, the audible count rate function was operable. |
| | DESCRIPTION OF EVENT: |
| | DATES AND APPROXIMATE TIMES OF MAJOR OCCURRENCES: |
| | November 3, 1997, 0025 EST: RCS boron concentration verified at 2463 PPM. |
| | November 3, 1997, 0753 EST: NIS Comparator and Rate drawer is removed from service. |
| | November 3, 1997, 1300 EST: RCS boron concentration verified at 2453 PPM. |
| | November 3, 1997: Event date. |
| | November 3, 1997, 1708 EST: Discovery date and time. |
| | November 4, 1997, 0100 EST: RCS boron concentration verified at 2470 PPM. |
| | November 4, 1997: NIS audible count rate is restored to operable status. |
| | B. EVENT: |
| | At the beginning of the afternoon shift on November 3, the operability of the NIS audible count rate function was questioned, since the normal audible beeping did not seem to be occurring. At this time, it was assumed that the audible count rate function had been made inoperable at the time procedure CPI-COMP/RATE-N46/37 was initiated. For convenience, this time was documented as the time administrative tracking had been initiated for the Comparator and Rate Drawer, at approximately 0753 EST on November 3. Therefore, using this event sequence and the assumed time of inoperability, the initial administrative tracking (which did not address the loss of audible count rate function) was supplemented by administrative procedure A-52.4 (Control of Limiting Conditions for Operating Equipment) at approximately 1708 EST. The A-52.4 tracking was initiated effective at 0753 EST as a "late entry". |
| | NRC FORM 366A (4-95) |
| | |
| | t NRC FORM 36BA . NUCLEAR 'REGULATORY COMMISSION (4-95) |
| | LICENSEE EVENT REPORT (LER) |
| | TEXT CONTINUATION FACILITY NAME (1) DOCKET LER NUMBER (6) PAGE (3) |
| | YEAR SEQUENTIAL REVISION NUMBER NUMBER R.E. Ginna Nuclear Power Plant 05000244 3 OF 6 97 006 00 TEXT ilfmore speceis required, use edditionel copies of NRC Form 368AJ (17) |
| | Based on the event sequence that inoperability occurred at 0753 EST, the Control Room operators concluded that the plant continued to be in compliance with'Ginna Improved Technical Specifications (ITS) Limiting Condition for Operation (LCO) REQUIRED ACTIONS 3.9.2.C.1 and 3.9.2.C.2, since, there had been no core alterations or positive reactivity additions during this. time. |
| | However, REQUIRED ACTION-3.9.2.C.3, for'RCS boron concentration verified to be within the limits specified in the Core Operating Limits Report (COLR), had only been accomplished at approximately 0025 EST and 1300 EST on November 3. |
| | ~ i. Xl Thus, at approximately 1708 EST on November 3, it was discovered that the NIS audible count rate was inoperable. 'Due to the assumed event sequence, it was concluded that inoperability occurred at 0753 EST, and the Control Room operators immediately entered ITS LCO 3.9.2 at, 1708 EST. The RCS boron concentration had been verified at approximately 1300 EST. Since the operators concluded that RCS boron concentration had not been verified within 4 hours of the assumed time of inoperability, the 1300 EST boron concentration was used to initiate the 12 hour time requirement of ITS LCO REQUIRED ACTION,3.9.2.C.3. Subsequent RCS boron concentration verification would be required every 12 hours. The next RCS boron concentration verification was performed at approximately 0100 EST, on November 4, and the NIS audible count rate function was restored to operable status later that morning. |
| | Upon further review, activities performed per procedure CPI-COMP/RATE-N46/37 did not render the NIS audible count rate inoperable. Therefore, the event sequence concluding that inoperability occurred at 0753 EST is incorrect. The precise time that the NIS audible count rate function became inoperable on November 3 is not known, but the most limiting event sequence is if it occurred after 1300 EST, or between 0753 and 0900 EST. In either of these scenarios, ITS LCO REQUIRED ACTION 3.9.2.C.3 was not performed within 4 hours of the event. |
| | C. INOPERABLE STRUCTURES, COMPONENTS, OR SYSTEMS THATCONTRIBUTED TO THE EVENT: |
| | None D. OTHER SYSTEMS OR SECONDARY FUNCTIONS AFFECTED: |
| | None E. METHOD OF DISCOVERY: |
| | This event was indicated during routine operations review of plant status during a shift turnover meeting, and was formally discovered shortly after shift turnover. However, the actual event sequence, including the fact that the precise time of inoperability is not known, was not discovered until several days later. |
| | NRC FORM 366A (4-95) |
| | |
| | NRC FORM 366A . NUCLEAR REGULATORY COMMISSION (4-95) |
| | LICENSEE EVENT REPORT (LER) |
| | TEXT CONTINUATION FACILITY NAME (1) DOCKET LER NUMBER (6) PAGE (3) |
| | YEAR SEQUENTIAL REVISION NUMBER NUMBER R.E. Ginna Nuclear Power Plant . 05000244 4 OF 6 97 006 00 TEXT Iifmore speceis required, use eddirional copies of NRC Form 366AJ (17) |
| | F. OPERATOR ACTION: |
| | The Control Room bperators'identified that there was no administrative tracking of the audible count. rate function, and submitted administrative procedure A-52.4 for formal tracking of the |
| | ~ |
| | audible'count.rate function. Based on their assumed event sequence, ITS LCO REQUIRED ACTION |
| | ~ |
| | 3.9.2.C.3 had not been performed within 4 hours of inoperability, but a subsequent (1300 EST) boron concentration verification was used to initiate the 12 hour time requirement. Future RCS boron concentration verification would be performed every 12 hours, per this REQUIRED ACTION. |
| | The Control Room operators notified higher supervision. |
| | V a ~" >,'} 1< |
| | A Control Room operator manually restored the NIS audible count rate function during the midnight shift on November 4, 1997. |
| | G. SAFETY SYSTEM RESPONSES: |
| | None III. CAUSE'OF EVENT: |
| | A. IMMEDIATECAUSE; The immediate cause of the condition prohibited by Technical Specifications was not verifying RCS boron concentration within 4 hours after discovering that the audible count rate function was inoperable, using the most limiting event sequence for loss of this function. |
| | B. INTERMEDIATE CAUSE: |
| | The intermediate cause of not verifying boron concentration was a misinterpretation of the event sequence. |
| | ROOT CAUSE: |
| | The misinterpretation of the event sequence led to a decision that was incorrect. Note that the precise time that the NIS audible count rate function became inoperable is not known. |
| | This misinterpretation was made possible because there is no positive indication of when the audible count rate function became inoperable. Procedures were deficient in that the applicability of ITS LCO 3,9.2 at all times while in Mode 6 was not addressed in plant operating procedures. |
| | Procedures were also deficient in that actions needed to verify the operability of the NIS audible count rate were not specified in calibration and test procedures. |
| | NAC FOAM 366A (4-95) |
| | |
| | NRC FORM 366A . NUCLEAR REGULATORY COMMISSION (4-95) |
| | LXCENSEE EVENT REPORT (LER) |
| | TEXT CONTINUATION FACILITY NAME (1) DOCKET LER NUMBER (6) PAGE (3) |
| | YEAR SEQUENTIAL REVISION NUMBER NUMBER R.E. Ginna Nuclear Power Plant 05000244 5 OF 6 97 006 00 TEXT llfmore spaceis required, use additional copies of NRC Form 366A/ (17) |
| | IV. ANALYSIS OF EVENT This event is"reportable in accordance with 10 CFR 50.73, Licensee Event Report System, item (a) (2) (i) |
| | (B),,which. requires a report of, "Any operation or condition prohibited by the plant's Technical |
| | 'pecifications": With the NIS audible count rate inoperable, not verifying RCS boron concentration within 4 hours after discovery. is not permitted by ITS LCO REQUIRED ACTION 3.9.2.C.3. |
| | An assessment'was performed considering both the safety consequences and implications of this event with the following results and conclusions: |
| | I I' 1" ~ Ili + ~ |
| | were no operational or safety consequences or implications. attributed to the delayed I'here verification of boron concengration because: |
| | \ |
| | ~ No core alterations and no positive reactivity additions occurred during this time period. |
| | ~ RCS boron concentration verification was being performed every 12 hours. Previous RCS boron samples had confirmed consistent boron concentrations that were well within the limit specified in the COLR. |
| | Based on the above, it can be concluded that the public's health and safety was assured at all times. |
| | CORRECTIVE ACTION: |
| | A. ACTION TAKEN TO RETURN AFFECTED SYSTEMS TO PRE-EVENT NORMAL STATUS: |
| | ~ The most recent RCS boron concentration was verified to be within the limit specified in the, COLR. |
| | ~ Subsequent boron verification occurred every 12 hours, as per ITS LCO Required Action 3.9.2.C.3. |
| | ~ After investigation of the cause for loss of this function, the audible count rate function was restored to operable status. |
| | B. ACTION TAKEN OR PLANNED TO PREVENT RECURRENCE: |
| | ~ The requirement to have audible count rate operable at all times while in Mode 6 appears to be conservative. The High Flux at Shutdown alarm may provide adequate assurance of no adverse changes in core reactivity while in Mode 6 (and no core alterations or positive reactivity additions are occurring). Nuclear Safety and Licensing will be requested to evaluate a License Amendment to change this requirement in ITS. |
| | NRC FORM 366A (4-95) |
| | |
| | NRC FORM 366A . NUCLEAR REGULATORY COMMISSION (4.95) |
| | LXCENSEE EVENT REPORT (LER) |
| | TEXT CONTINUATION FACILITY NAME (1) DOCKET LER NUMBER (6) PAGE (3) |
| | YEAR SEQUENTIAL REVISION NUMBER NUMBER R.E. Ginna Nuclear Power Plant 05000244 6 OF 6 TEXT iifmore spaceis required, use additional copies of NRC Form 366A j (17) |
| | Appropriate calibration and test procedures will be reviewed, and changed as necessary, to ensure audible count rate operability after completion of calibrations or tests. |
| | Operating procedures will be reviewed, and changed as necessary, to ensure audible count rate operability is verifi6d when..in Mode 6. |
| | ( ~ ~ ',d Vl ~ ADDITIONALINFORMATION: ~ ~ |
| | II A. FAILED COMPONENTS: |
| | None B. PREVIOUS LERs ON SIMILAR EVENTS: |
| | A similar LER event historical search was conducted with the following results: No documentation of similar LER events with the same root cause at Ginna Station could be identified. |
| | C. SPECIAL COMMENTS: |
| | None NRC FORM 366A (4-95) |
| | |
| | 0 I}} |
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[Table view] Category:RO)
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Caused by Unanticipated High Frequency AC Voltage Ripple. Entered TS LCO 3.0.3.With 990602 Ltr ML17309A6541999-05-27027 May 1999 LER 99-008-00:on 990427,overtemperature Delta T Reactor Trip Occurred Due to Faulted Bistable During Calibr of Redundant Channel.Plant Was Stabilized in Mode 3 & Faulted Bistable Was Subsequently Replaced.With 990527 Ltr ML17265A6631999-05-24024 May 1999 LER 99-007-00:on 990423,technicians Inadvertently Pulled Fuses from Wrong Nuclear Instrument Cahnnel,Causing Reactor Trip,Due to High Range Flux Trip.Caused by Personnel Error. Labeling Scheme Improved ML17265A6601999-05-21021 May 1999 LER 99-006-00:on 990421,start of turbine-driven Auxiliary Feedwater Pump Was Noted.Caused by MOV Being Left in Open Position.Closed Manual Isolation Valve to Secure Steam to Pump.With 990521 Ltr ML17265A6441999-05-13013 May 1999 LER 99-005-00:on 990413,undervoltage Signal of Safeguards Bus During Testing Resulted in Automatic Start of B Edg. Caused by Personnel Error.Blown Fuse Was Replaced & Offsite Power Was Restored to Safeguards Bus 17.With 990513 Ltr ML17265A6431999-05-12012 May 1999 LER 99-004-00:on 990412,discovered That Containment Recirculation Fan Moisture Separator Vanes Were Incorrectly Installed,Per 10CFR21.Caused by Improper Assembly by Mfg. Subject Vanes Were Dismantled & Correctly re-installed ML17265A6141999-03-31031 March 1999 LER 99-003-00:on 990301,two Main Steam non-return Check Valves Were Declared Inoperable Due to Exceedance of Acceptance Criteria.Caused by Changes in Methodology & Matls.Packing Gland Torque Will Be Adjusted.With 990331 Ltr ML17265A6131999-03-29029 March 1999 LER 99-002-00:on 990227,discovered That Surveillance Had Not Been Performed at Frequency,Per Ts.Caused by Personnel Error.Procedure O-6.13 Will Be Evaluated for Enhancement Documentation of Completion of ITS Srs.With 990329 Ltr ML17265A6061999-03-24024 March 1999 LER 99-001-00:on 990222,plant Was Noted Outside Design Basis.Caused by Deficiencies in NSSS Vendor Slb Mass & Energy Release.Placed Temporary Administrative Restriction 40 Degrees F Max on Screenhouse Bay Temp ML17265A4951998-12-21021 December 1998 LER 98-005-00:on 981120,loss of 34.5 Kv Offsite Power Circuit 751,resulted in Automatic Start of B Edg.Caused by Faulted Cable Splice.Performed Appropriate Actions of Abnormal Procedure AP-ELEC.1.With 981221 Ltr ML17265A4931998-12-17017 December 1998 LER 98-004-00:on 971030,determined That Improperly Performed Surveillance Resulted in Condition Prohibited by Ts.Caused by Procedure non-adherence.Appropriate Calibr Procedures Were Properly Performed with 24 H of Condition Discovery ML17265A4691998-11-25025 November 1998 LER 98-003-01:on 980904,actuations of CR Emergency Air Treatment Systems (Creats) Occurred.Caused by Radon build-up During Temp Inversion.Creats Actuation Signal Was Reset & Normal Ventilation Was Restored to CR ML17265A4271998-10-0505 October 1998 LER 98-003-00:on 980904,actuations of CR Emergency Air Treatment Sys Occurred.Caused by Radon build-up During Temp Inversion.Air Samples Were Taken & Determined That Source of Radiation Was Naturally Occurring Radon.With 981005 Ltr ML17265A3671998-07-14014 July 1998 LER 98-002-00:on 971019,CR Emergency Air Treatment Sys Actuating Function Was Not Operable.Caused by Mispositioned Switch.Revised Procedure CPI-MON-R37.W/980714 Ltr ML17265A1921998-03-11011 March 1998 LER 98-001-00:on 980209,discovered That Boraflex Degradation in SPF Was Greater than Was Assumed.Caused by Dissolution of Boron on Boraflex Matrix,Per 10CFR50.21.Removed Spent Fuel Assemblies from Selected Degraded Storage Rack Cells ML17265A1641998-02-0606 February 1998 LER 97-007-01:on 971117,reactor Engineer Recognized That Neutron Flux Low Range Trip Circuitry for Channel Was Not in Tripped Condition as Required.Caused by Technical Inadequacies.Channel Defeat Will Be Identified ML17265A1601998-02-0606 February 1998 LER 97-006-01:on 971103,verification of B Concentration Was Not Performed Due to Misinterpretation of Event Sequence. Audible Count Rate Function Was Restored to Operable Status ML17264B1441997-12-17017 December 1997 LER 97-007-00:on 971117,NF Low Range Trip Circuitry for Channel N-44 Was Not Placed in Tripped Condition.Caused by Technical Inadequacies in Procedures.Implemented EWR 4862 to Resolve Design deficiency.W/971217 Ltr ML17264B1291997-12-0303 December 1997 LER 97-006-00:on 971103,NIS Audible Count Rate Function Was Inoperable.Caused by Misinterpretation of Event Sequence Due to Not Verifying Boron Concentration.B Verification Occurred Every 12 H Per ITS LCO Action 3.9.2.C.3.W/971203 Ltr ML17264B1271997-12-0101 December 1997 LER 97-005-00:on 971031,undetected Unblocking of SI Actuation Signal Occurred at Low Pressure Condition,Due to Faulty Bistable Which Resulted in Inadvertent SI Actuation Signal.Sias,Ci & CVI Signals Were Reset ML17264B1211997-11-24024 November 1997 LER 97-004-00:on 971024,radiation Monitor Alarm Were Noted Due to Higher than Normal Radioactive Gas Concentration Resulted in Cvi.New R-12 Alarm Setpoint Was Maintained for Duration of Refueling Outage ML17264B0461997-09-29029 September 1997 LER 97-003-01:on 970730,bistable Instrument Trip Setpoint Could Have Exceeded Allowable Value.Caused by Insufficient Existing Margin Between Trip Setpoint & Allowable Value. Held Switches in Tripped configuration.W/970929 Ltr ML17264B0111997-08-27027 August 1997 LER 97-003-00:on 970730,high Steam Flow Bistable Instrument Setpoint Plus Instrument Uncertainty Could Exceed Allowable Value in ITS Was Identified.Caused by Entry Into ITS LCO 3.0.3.Switches Placed in Tripped configuration.W/970827 Ltr ML17264A9941997-08-19019 August 1997 LER 97-002-00:on 970720,34.5 Kv Offsite Power Circuit 751 Was Lost.Caused by Automatic Actuation of B Emergency DG Due to Undervoltage on Safeguards Buses 16 & 17.Offsite Power Restored to Safeguards Buses 16 & 17.W/970819 Ltr ML17264A9911997-08-11011 August 1997 LER 96-009-02:on 960723,determined That Leak Rate Outside Containment Was Greater than Program Limit.Caused by Weld Defect.Isolated Leak & Cut Out & Replaced Leaking Pipe ML17264A8271997-03-0303 March 1997 LER 97-001-00:on 970131,discovered Service Water Temp Was Less than Specified Value.Caused by non-representative Method of Monitoring.Increased Water Temp in Screenhouse Bay to Greater than 35 Degrees F.W/970303 Ltr ML17264A8071997-01-22022 January 1997 LER 96-015-00:on 961223,discovered Thermally Induced Overpressure Transient Could Occur.Caused by Thermal Expansion of Fluid During Design Basis Accident Condition. Installed Relief Valve on Affected line.W/970122 Ltr ML17264A7471996-11-27027 November 1996 LER 96-013-00:on 961029,circuit Breakers Closed While in Mode 3 & Resulted in Condition Prohibited by TS Due to Personnel Error.Circuit Breakers for MOV-878B & MOV-878D Were re-opened.W/961127 Ltr ML17264A6051996-09-19019 September 1996 LER 96-012-00:on 960820,feedwater Transient Occurred,Due to Closure of Feedwater Regulating Valve,Causing Lo Lo Steam Generator Level Reactor Trip.Sgs Were Restored & Missing Screw in 1/P-476 Was replaced.W/960919 Ltr ML17264A6061996-09-19019 September 1996 LER 96-009-01:on 960723,leakage Outside Containment Occurred,Due to Weld Defect,Resulting in Leak Rate Greater than Program Limits.Source of Leakage Isolated from RWST by Freeze Seal,Allowing Exit from ITS LCO 3.0.3.W/960919 Ltr ML17264A5911996-09-0505 September 1996 LER 96-011-00:on 960807,improper Configuration of Circuit Breaker Occurred,Due to Undetected Internal Interference, Resulting in Automatic Start of Both Auxiliary Feedwater Pumps.Running AFW Pumps Were secured.W/960905 Ltr ML17264A5921996-09-0505 September 1996 LER 96-010-00:on 960806,latching of Main Turbine While in Mode 4 Occurred,Due to Defective Procedure,Resulting in Automatic Start of Auxiliary Feedwater Pump.Caused by Defective Maint Procedure.Procedure revised.W/960905 Ltr ML17264A5891996-08-22022 August 1996 LER 96-009-00:on 960723,determined Leak on Piping Sys Outside Containment Greater than Program Limit.Caused by Weld Defect.Pipe & Socket Welds Were Cut Out & Replaced. W/960822 Ltr ML17264A5781996-08-0606 August 1996 LER 96-008-00:on 960707,main Feedwater Pump Breakers Opened. Caused by Change in Seal Water Differential Pressure Occurred During Sys Realignment.Afw Flow Controlled as Desired to Maintain S/G level.W/960806 Ltr ML17264A5561996-07-12012 July 1996 LER 96-007-00:on 960612,CR Operators Identified Control Rods Misaligned & Not Moving in Proper Sequence.Caused by Faulty Firing Circuit Card in Rod Control Sys.Faulty Firing Circuit Card in 1BD Power Cabinet replaced.W/960712 Ltr ML17264A5421996-06-20020 June 1996 LER 96-006-00:on 960521,discovered Containment Penetration Not in Required Status.Caused by Personnel Error.Installed Flange Inside Containment Penetration 2.W/960620 Ltr ML17264A5411996-06-17017 June 1996 LER 96-005-00:on 960516,PORC Determined Deficient Procedures Do Not Meet SRs for Testing safety-related Logic Circuits. Caused by Inadequancies in Individual Testing Procedures. Procedures Re Improved TSs revised.W/960617 Ltr ML17264A5051996-05-17017 May 1996 LER 96-003-01:on 960308,identified That Both Pressurizer PORVs Inoperable Concurrently Due to Disconnection of Flex Hose to Both PORV Actuators to Install air-sets for Benchset & Limit Switch Activities.Hpes Completed ML17264A4481996-04-0808 April 1996 LER 96-003-00:on 960308,both Pressurizer Relief Valves Inoperable.Hpes Evaluation Is Being Conducted to Determined Cause of Event.C/As:Both PORVs restored.W/960408 Ltr ML17264A4471996-04-0808 April 1996 LER 96-002-00:on 960307,secondary Transient Occurred.Caused by Loss of B Condenser Circulating Water Pump.C/As: Thermography performed.W/960408 Ltr ML17264A4101996-03-18018 March 1996 LER 96-001-00:on 950504,inservice Test Not Performed During Refueling Outage.Caused by Inadequate Tracking of Surveillance Frequency.Valve Test Performed & Disassembled. W/960318 Ltr ML17264A2971995-12-14014 December 1995 LER 95-009-00:on 950817,surveillance Was Not Performed Due to Improper Application of TS Requirements Resulting in TS Violation.Testing of MOV-515 Was Performed on 951115.W/ 951214 Ltr ML17264A1711995-09-25025 September 1995 LER 95-008-00:on 950825,secondary Transient Occurred.Caused by Loss of B Condenser Circulating Water Pump That Resulted in Manual Rt.Returned S/G Levels to Normal Operating levels.W/950925 Ltr 1999-09-22
[Table view] Category:TEXT-SAFETY REPORT
MONTHYEARML17265A7601999-10-0505 October 1999 Part 21 Rept Re W2 Switch Supplied by W Drawn from Stock, Did Not Operate Properly After Being Installed on 990409. Switch Returned to W on 990514 for Evaluation & Root Cause Analysis ML17265A7621999-09-30030 September 1999 Monthly Operating Rept for Sept 1999 for Re Ginna Npp.With 991008 Ltr ML17265A7531999-09-23023 September 1999 Part 21 Rept Re Corrective Action & Closeout of 10CFR21 Rept of Noncompliance Re Unacceptable Part for 30-4 Connector. Unacceptable Parts Removed from Stock & Scrapped ML17265A7541999-09-22022 September 1999 LER 99-011-00:on 990823,small Tears Were Discovered in Flexible Duct Work Connector at Inlet of CR HVAC Sys Return Air Fan (AKF08).Caused by in-leakage Greater than That Assumed.Implemented Temporary Mod 99-029.With 990922 Ltr ML17265A7471999-08-31031 August 1999 Monthly Operating Rept for Aug 1999 for Re Ginna Npp.With 990909 Ltr ML17265A7431999-08-24024 August 1999 LER 99-004-01:on 990412,discovered That Containment Recirculation Fan Chevron Separator Vanes Were Installed Backwards.Caused by Improper Assembly by Mfg.Moisture Separator Vanes Were Dismantled & Correctly re-installed ML17265A7341999-07-31031 July 1999 Monthly Operating Rept for July 1999 for Re Ginna Npp.With 990806 Ltr ML17265A7291999-07-29029 July 1999 Interim Part 21 Rept Re safety-related DB-25 Breaker Mechanism Procured from W Did Not Pas Degradatin Checks When Drawn from Stock to Be Installed Into BUS15/03A.Holes Did Not line-up & Tripper Pan Bent ML17265A7181999-07-23023 July 1999 LER 99-007-01:on 990423,reactor Trip Occurred Due to Instrument & Control Technicians Inadvertently Pulling Fuses from Wrong Nuclear Instrument Channel.Setpoint Adjustments Were Completed by Different Crew of Technicians ML17265A7081999-07-22022 July 1999 LER 98-003-02:on 980904,actuations of CR Emergency Air Treatment Sys Was Noted Due to Invalid Causes.Caused by Various Degraded Components in CR RM Sys.Creats Actuation Signal Was Reset & Normal Ventilation Was Restored ML17265A7131999-07-22022 July 1999 Special Rept:On 990407,radiation Monitor RM-14A Was Declared Inoperable.Caused by Failed Communication Link from TSC to Plant Process Computer Sys.Communication Link Was re-established & RM-14A Was Declaed Operable on 990521 ML17265A7031999-07-19019 July 1999 LER 99-S01-00:on 990617,determined That Temporary Unescorted Access Had Been Granted to Contractor Employee.Caused by Incomplete Info Re Circumstances of Individual Military Separation.Individual Access Was Revoked.With 990719 Ltr ML17265A7211999-07-19019 July 1999 ISI Rept for Third Interval (1990-1999) Third Period, Second Outage (1999) at Re Ginna Npp. ML17265A7021999-07-15015 July 1999 LER 99-010-00:on 990615,ventilation Isolation of Auxiliary Bldg Occurred When Auxiliary Bldg Gas Radiation Monitor R-14 Reached High Alarm Setpoint.Cr Operators Rest Auxiliary Bldg Ventilation Isolation Signal.With 990715 Ltr ML17265A7661999-06-30030 June 1999 1999 Rept of Facility Changes,Tests & Experiments Conducted Without Prior NRC Approval for Jan 1998 Through June 1999, Per 10CFR50.59.With 991020 Ltr ML17265A7011999-06-30030 June 1999 Monthly Operating Rept for June 1999 for Re Ginna Npp.With 990712 Ltr ML17265A6851999-06-21021 June 1999 LER 99-001-01:on 990222,deficiencies in NSSS Vendor steam- Line Brake Mass & Energy Release Analysis Results in Plant Being Outside Design Bases Occurred.Caused by Deficiencies in W.Temporary Administrative Replaced.With 990621 Ltr ML17265A6761999-06-16016 June 1999 Part 21 Rept Re Defects & noncompliances,10CFR21(d)(3)(ii), Which Requires Written Notification to NRC on Identification of Defect or Failure to Comply. Relays Were Returned to Eaton for Evaluation & Root Cause Analysis ML17265A6661999-06-0202 June 1999 LER 99-009-00:on 990503,instrumentation Declared Inoperable in Multiple Channels Resulted in Condition Prohibited by Ts. Caused by Unanticipated High Frequency AC Voltage Ripple. Entered TS LCO 3.0.3.With 990602 Ltr ML17265A6681999-05-31031 May 1999 Monthly Operating Rept for May 1999 for Re Ginna Nuclear Power Plant.With 990608 Ltr ML17265A6651999-05-27027 May 1999 Interim Rept Re W2 Control Switch,Procured from W,Did Not Operate Satisfactorily When Drawn from Stock to Be Installed in Main Control Board for 1C2 Safety Injection Pump. Estimated That Evaluation Will Be Completed by 991001 ML17309A6541999-05-27027 May 1999 LER 99-008-00:on 990427,overtemperature Delta T Reactor Trip Occurred Due to Faulted Bistable During Calibr of Redundant Channel.Plant Was Stabilized in Mode 3 & Faulted Bistable Was Subsequently Replaced.With 990527 Ltr ML17265A6631999-05-24024 May 1999 LER 99-007-00:on 990423,technicians Inadvertently Pulled Fuses from Wrong Nuclear Instrument Cahnnel,Causing Reactor Trip,Due to High Range Flux Trip.Caused by Personnel Error. Labeling Scheme Improved ML17265A6601999-05-21021 May 1999 LER 99-006-00:on 990421,start of turbine-driven Auxiliary Feedwater Pump Was Noted.Caused by MOV Being Left in Open Position.Closed Manual Isolation Valve to Secure Steam to Pump.With 990521 Ltr ML17265A6591999-05-17017 May 1999 Part 21 Rept Re Relay Deficiency Detected During pre-installation Testing.Caused by Incorrectly Wired Relay Coil.Relays Were Returned to Eaton Corp for Investigation. Relays Were Repaired & Retested ML17265A6441999-05-13013 May 1999 LER 99-005-00:on 990413,undervoltage Signal of Safeguards Bus During Testing Resulted in Automatic Start of B Edg. Caused by Personnel Error.Blown Fuse Was Replaced & Offsite Power Was Restored to Safeguards Bus 17.With 990513 Ltr ML17265A6431999-05-12012 May 1999 LER 99-004-00:on 990412,discovered That Containment Recirculation Fan Moisture Separator Vanes Were Incorrectly Installed,Per 10CFR21.Caused by Improper Assembly by Mfg. Subject Vanes Were Dismantled & Correctly re-installed ML17265A6381999-05-0707 May 1999 Part 21 Rept Re Replacement Turbocharger Exhaust Turbine Side Drain Port Not Functioning as Design Intended.Caused by Manufacturing Deficiency.Turbocharger Was Reaasembled & Reinstalled on B EDG ML17265A6391999-04-30030 April 1999 Monthly Operating Rept for Apr 1999 for Re Ginna Nuclear Power Plant.With 990510 Ltr ML17265A6361999-04-23023 April 1999 Part 21 Rept Re Power Supply That Did Not Work Properly When Drawn from Stock & Installed in -25 Vdc Slot.Power Supply Will Be Sent to Vendor to Perform Failure Mode Assessment.Evaluation Will Be Completed by 991001 ML17265A6301999-04-18018 April 1999 Rev 1 to Cycle 28 COLR for Re Ginna Npp. ML17265A6251999-04-15015 April 1999 Special Rept:On 990309,halon Systems Were Removed from Svc & Fire Door F502 Was Blocked Open.Caused by Mods Being Made to CR Emergency Air Treatment Sys.Continuous Fire Watch Was Established with Backup Fire Suppression Equipment ML17265A6551999-04-0909 April 1999 Initial Part 21 Rept Re Mfg Deficiency in Replacement Turbocharger for B EDG Supplied by Coltec Industries. Deficiency Consisted of Missing Drain Port in Intermediate Casing.Required Oil Drain Port Machined Open ML17265A6291999-03-31031 March 1999 Rev 0 to Cycle 28 COLR for Re Ginna Npp. ML17265A6241999-03-31031 March 1999 Monthly Operating Rept for Mar 1999 for Ginna Station.With 990409 Ltr ML17265A6141999-03-31031 March 1999 LER 99-003-00:on 990301,two Main Steam non-return Check Valves Were Declared Inoperable Due to Exceedance of Acceptance Criteria.Caused by Changes in Methodology & Matls.Packing Gland Torque Will Be Adjusted.With 990331 Ltr ML17265A6131999-03-29029 March 1999 LER 99-002-00:on 990227,discovered That Surveillance Had Not Been Performed at Frequency,Per Ts.Caused by Personnel Error.Procedure O-6.13 Will Be Evaluated for Enhancement Documentation of Completion of ITS Srs.With 990329 Ltr ML17265A6061999-03-24024 March 1999 LER 99-001-00:on 990222,plant Was Noted Outside Design Basis.Caused by Deficiencies in NSSS Vendor Slb Mass & Energy Release.Placed Temporary Administrative Restriction 40 Degrees F Max on Screenhouse Bay Temp ML17265A5661999-03-0101 March 1999 Rev 26 to QA Program for Station Operation. ML17265A5961999-02-28028 February 1999 Monthly Operating Rept for Feb 1999 for Ginna Nuclear Power Plant.With 990310 Ltr ML17265A5371999-01-31031 January 1999 Monthly Operating Rept for Jan 1999 for Re Ginna Nuclear Power Plant.With 990205 Ltr ML17265A5951998-12-31031 December 1998 Rg&E 1998 Annual Rept. ML17265A5001998-12-21021 December 1998 Rev 26 to QA Program for Station Operation. ML17265A4951998-12-21021 December 1998 LER 98-005-00:on 981120,loss of 34.5 Kv Offsite Power Circuit 751,resulted in Automatic Start of B Edg.Caused by Faulted Cable Splice.Performed Appropriate Actions of Abnormal Procedure AP-ELEC.1.With 981221 Ltr ML17265A4931998-12-17017 December 1998 LER 98-004-00:on 971030,determined That Improperly Performed Surveillance Resulted in Condition Prohibited by Ts.Caused by Procedure non-adherence.Appropriate Calibr Procedures Were Properly Performed with 24 H of Condition Discovery ML17265A4761998-11-30030 November 1998 Monthly Operating Rept for Nov 1998 for Re Ginna Nuclear Power Plant.With 981210 Ltr ML17265A4691998-11-25025 November 1998 LER 98-003-01:on 980904,actuations of CR Emergency Air Treatment Systems (Creats) Occurred.Caused by Radon build-up During Temp Inversion.Creats Actuation Signal Was Reset & Normal Ventilation Was Restored to CR ML17265A4531998-10-31031 October 1998 Monthly Operating Rept for Oct 1998 for Re Ginna Nuclear Power Plant.With 981110 Ltr ML17265A4271998-10-0505 October 1998 LER 98-003-00:on 980904,actuations of CR Emergency Air Treatment Sys Occurred.Caused by Radon build-up During Temp Inversion.Air Samples Were Taken & Determined That Source of Radiation Was Naturally Occurring Radon.With 981005 Ltr ML17265A4291998-09-30030 September 1998 Monthly Operating Rept for Sept 1998 for Re Ginna Nuclear Power Plant.With 981009 Ltr 1999-09-30
[Table view] |
Text
CATEGORY 1 REGUZATO ZNFORNATZON DZSTR1BUT1ON ISTEN (RZDS)
ACCESSION NBR:9712100274 .DOC'.DATE:"97/12'/03 NOTARIZED: NO DOCKET 4 FACZZ:50-244 Robert 2Znaet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 AUTH.NAME ' 'UTHOR AFFILIATION ST.MARTIN,J.T. Rochester Gas & Electric Corp.
MECREDY,R.C. Rochester Gas Ec Electric Corp.
RECIP.NAME RECIPIENT AFFILIATION VISSING, G. S'.,"-;
SUBJECT:
LER 97-006;-00:on!'971103,NIS audible count rate function was inoperable. Caused by misinterpretation of event secpxence due to not verify3ng boron concentration.B verification .occurred every 12 h- per ITS LCO acti. on 3.9.2.C.3.W/971203 ltr.
0 DISTRIBUTION:CODE: IE22T 'OPIES RECEIVED:LTR"J ENCL l" SIZE:
TITLE: '50.73/50.9 Li.censee Event Report (LER), Incident Rpt', etc.
~ '\ I 4 1 NOTES:License Exp date in accordance wi.th 10CFR2,2.109(9/19/72). 05000244 G RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID '.CODE/NAME LTTR ENCL, R PD1-1 PD 1 1 VISSING,G. 1 1 INTERNAL: AEO 2 2 AEOD/SPD/RRAB 1 1 E CENTE 1 1 NRR/DE/ECGB 1 1 NRR DE E LB 1 1 NRR/DE/EMEB 1 1 NRR/DRCH/HHFB 1 1 NRR/DRCH/HICB 1 1 NRR/DRCH/HOLB 1 1 NRR/DRCH/HQMB 1 1 NRR/DRPM/PECB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 RES/DET/EIB '1 1 RGN1 FILE 01 1 1 D
EXTERNAL: L ST LOBBY WARD 1 1 LITCO BRYCE,J H 1 0
1 NOAC POORE,W. 1 1 NOAC QUEENER,DS 1 1 NRC PDR 1 1 NUDOCS FULL TXT 1 1 U
NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRZBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24
AND ROCHESTER GAS AND ElECTRIC CORPORATTON ~ 89 EASTAVENUE, ROCHESTER, M Y. l4649-D001 AREA CODE7I6 546-270D ROBERT C. MECREDY Vice President Nuctear operations December 3, 1997 U.S. Nuclear Regulatory Commission Document Control Desk Attn: Guy S. Vissing Project Directorate I-1 Washington, D.C. 20555
)
Subject LER 97-006, Verification of Boron Concentration Not Performed Due to Misinterpretation of Event Sequence, Resulted in Condition Prohibited by Technical Specifications R.E. Ginna Nuclear Power Plant Docket No. 50-244
Dear Mr. Vissing:
In accordance with 10 CFR 50.73, Licensee Event Report System, item (a) (2) (i) (B), which requires a report of, "Any operation or condition prohibited by the plant's Technical Specifications", the attached Licensee Event Report LER 97-006 is hereby submitted.
This event has in no way affected the public's health and safety.
Very truly yours, Robert C. Mecredy xc: Mr. Guy S. Vissing (Mail Stop 14B2)
PWR Project Directorate I-1 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector
"(- lllllllllllllllllllllllllllllllllllfllll a I 0 9'712i00274 'st7i20S PDR ADOCK 05000244 8 PDR
NRC FORM 366 U.S. N R REGULATORY COMNIISSIO AP ED BY OMB NO. 3150%104 (4-95) EXPIRES 04/30/98 ESTIMATED BURDEN PER RESPONSE To COMPLY WITH THIS MANDATORY INFORMATION COLLECTION REQUEST: 50.0 HRS.
LXCENSEE EVENT n REPORT,(LER) REPORTED LESSONS LEARNED ARE INCORPORATED INTO THE LICENSING PROCESS AND FED BACK To INDUSTRY. FORWARD (See reverse for required number'f COMMENTS REGARDING BURDEN ESTIMATE To THE INFORMATION AND RECORDS MANAGEMENT BRANCH IT.6 F33),
digits/characters for each block) U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555-0001, AND To THE PAPERWORK REDUCTION PROJECT FACIUTY NAME Ill DOCKET irVMSER f2) PAD E I3I R.E. Ginna Nuclear Power Plant 05000244 1 OF 6 TrrLE fa)
Verification of Bof'on Concentration Not Performed Due to Misinterpretation of Event Sequence, Resulted in Condition Prohibited by Technical Specifications EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8)
SEQ ENTIAL REVISO FACILITYNAME DOCKET NUMBER MONlH DAY YEAR YEAR NUMBER MO DAY I:YEAR.
NUMBER
~ I FACIUTY NAME 03 97 97 006 00 1'2. 03 97 DOCKET NUMBER OPERATING THIS REPORT IS SUBMITTED PUBS UANT TO THE REQUIREMENTS OF 10 CFR E: (Check one or Illore) (1 1)
MODE (9) 20.2201(b) 20.2203(a) (2)(v) 50.73(a) (2) (i) 50.73(a) (2) (viii)
POWER 20.2203(a) (1) 20.2203(a) (3) (i) 50.73(a)(2)(ii) 50.73(a)(2)(x)
LEVEL (10) 000 20.2203(a) (2) (i) 20.2203(a) (3)(ii) 50.73(a)(2) (iii) 73.71 20.2203(a) (2)(ii) 20.2203(a)(4) 50.73(a) (2) (iv) OTHER 20.2203(a) (2) (iii) 50.36(c)(1) 50.73(a)(2)(v) Specify in Abstract below or In NRC Form 366A 20.2203(a)(2)(lv) . 50.36(c) (2) 50.73(a) (2)(vii)
LICENSEE CONTACT FOR THIS LER (12)
NAME TELEPHONE kUMBER Bncrude Area Code)
John T. St. Martin - Technical Assistant (716) 771-3641 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)
CAUSE SYSTEM COMPONENT REPORTABLE REPORTABLE MANUFACTURER CAUSE SYSTEM COMPONENT MANUFACTURER TO NPRDS To NPRDS SUPPLEMENTAL REPORT EXPECTED (14) MONTH DAY YEAR EXPECTED YES SUBMISSION (If yes, complete EXPECTED SUBMISSION DATE). X NO DATE (15)
ABSTRACT (Limit to 1400 spaces, I.e., approximately 15 single-spaced typewritten lines) (16)
On November 3, 1997, at approximately 1708 EST, the plant was in Mode 6, and refueling activities had been completed two days earlier. The reactor coolant system being maintained at a temperature of 75 degrees F, and the reactor cavity filled to greater than 23 feet. It was discovered that the nuclear instrumentation system audible count rate function was inoperable.
Immediate action was to ensure future compliance to the Ginna Technical Specifications for loss of this function.
This included verifying that the most recent boron concentration was within specified limits and formally tracking the time for future verification of boron concentration.
Due to a misinterpretation of the event sequence, the v'erification of boron concentration may not have been performed within the time period specified by Ginna Technical Specifications Required Actions for the most limiting event sequence.
Corrective action to prevent recurrence is outlined in Section V.B.
NRC FORM 366 (4-95)
I NRC FORM 366A . NUCLEAR REGULATORY COMMISSION (4-95)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACILITY NAME (1) DOCKET LER NUMBER (6) PAGE (3)
YEAR SEQUENTIAL REVISION NUMBER NUMBER R.E. Ginna Nuclear Power Plant 2 OF 6 05000244 97 006 00 TEXT (Ifmore spaceis required, use additional copies of NRC Form 366A/ (17)
PRE-EVENT PLANT CONDITIONS: < ~ ~
. ~ '
C ~ i l ~
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On November 3, 1997, the plant was in Mode 6 with the reactor coolant system (RCS) being maintained at a temperature of approximately.75 degrees F, and the reactor, cavity filled to greater than 23 feet. The plant was shut down for'refueling, and refueling activities (core alterations) had already been completed two days earlier, At approximately 0753 EST, the nuclear instrumentation system (NIS) Comparator and Rate drawer was removed from service for calibration per procedure CPI-COMP/RATE-N46/37 (Calibration of Comparator and Rate Drawer N46/37). At this time, the audible count rate function was operable.
DESCRIPTION OF EVENT:
DATES AND APPROXIMATE TIMES OF MAJOR OCCURRENCES:
November 3, 1997, 0025 EST: RCS boron concentration verified at 2463 PPM.
November 3, 1997, 0753 EST: NIS Comparator and Rate drawer is removed from service.
November 3, 1997, 1300 EST: RCS boron concentration verified at 2453 PPM.
November 3, 1997: Event date.
November 3, 1997, 1708 EST: Discovery date and time.
November 4, 1997, 0100 EST: RCS boron concentration verified at 2470 PPM.
November 4, 1997: NIS audible count rate is restored to operable status.
B. EVENT:
At the beginning of the afternoon shift on November 3, the operability of the NIS audible count rate function was questioned, since the normal audible beeping did not seem to be occurring. At this time, it was assumed that the audible count rate function had been made inoperable at the time procedure CPI-COMP/RATE-N46/37 was initiated. For convenience, this time was documented as the time administrative tracking had been initiated for the Comparator and Rate Drawer, at approximately 0753 EST on November 3. Therefore, using this event sequence and the assumed time of inoperability, the initial administrative tracking (which did not address the loss of audible count rate function) was supplemented by administrative procedure A-52.4 (Control of Limiting Conditions for Operating Equipment) at approximately 1708 EST. The A-52.4 tracking was initiated effective at 0753 EST as a "late entry".
NRC FORM 366A (4-95)
t NRC FORM 36BA . NUCLEAR 'REGULATORY COMMISSION (4-95)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACILITY NAME (1) DOCKET LER NUMBER (6) PAGE (3)
YEAR SEQUENTIAL REVISION NUMBER NUMBER R.E. Ginna Nuclear Power Plant 05000244 3 OF 6 97 006 00 TEXT ilfmore speceis required, use edditionel copies of NRC Form 368AJ (17)
Based on the event sequence that inoperability occurred at 0753 EST, the Control Room operators concluded that the plant continued to be in compliance with'Ginna Improved Technical Specifications (ITS) Limiting Condition for Operation (LCO) REQUIRED ACTIONS 3.9.2.C.1 and 3.9.2.C.2, since, there had been no core alterations or positive reactivity additions during this. time.
However, REQUIRED ACTION-3.9.2.C.3, for'RCS boron concentration verified to be within the limits specified in the Core Operating Limits Report (COLR), had only been accomplished at approximately 0025 EST and 1300 EST on November 3.
~ i. Xl Thus, at approximately 1708 EST on November 3, it was discovered that the NIS audible count rate was inoperable. 'Due to the assumed event sequence, it was concluded that inoperability occurred at 0753 EST, and the Control Room operators immediately entered ITS LCO 3.9.2 at, 1708 EST. The RCS boron concentration had been verified at approximately 1300 EST. Since the operators concluded that RCS boron concentration had not been verified within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of the assumed time of inoperability, the 1300 EST boron concentration was used to initiate the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time requirement of ITS LCO REQUIRED ACTION,3.9.2.C.3. Subsequent RCS boron concentration verification would be required every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The next RCS boron concentration verification was performed at approximately 0100 EST, on November 4, and the NIS audible count rate function was restored to operable status later that morning.
Upon further review, activities performed per procedure CPI-COMP/RATE-N46/37 did not render the NIS audible count rate inoperable. Therefore, the event sequence concluding that inoperability occurred at 0753 EST is incorrect. The precise time that the NIS audible count rate function became inoperable on November 3 is not known, but the most limiting event sequence is if it occurred after 1300 EST, or between 0753 and 0900 EST. In either of these scenarios, ITS LCO REQUIRED ACTION 3.9.2.C.3 was not performed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of the event.
C. INOPERABLE STRUCTURES, COMPONENTS, OR SYSTEMS THATCONTRIBUTED TO THE EVENT:
None D. OTHER SYSTEMS OR SECONDARY FUNCTIONS AFFECTED:
None E. METHOD OF DISCOVERY:
This event was indicated during routine operations review of plant status during a shift turnover meeting, and was formally discovered shortly after shift turnover. However, the actual event sequence, including the fact that the precise time of inoperability is not known, was not discovered until several days later.
NRC FORM 366A (4-95)
NRC FORM 366A . NUCLEAR REGULATORY COMMISSION (4-95)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACILITY NAME (1) DOCKET LER NUMBER (6) PAGE (3)
YEAR SEQUENTIAL REVISION NUMBER NUMBER R.E. Ginna Nuclear Power Plant . 05000244 4 OF 6 97 006 00 TEXT Iifmore speceis required, use eddirional copies of NRC Form 366AJ (17)
F. OPERATOR ACTION:
The Control Room bperators'identified that there was no administrative tracking of the audible count. rate function, and submitted administrative procedure A-52.4 for formal tracking of the
~
audible'count.rate function. Based on their assumed event sequence, ITS LCO REQUIRED ACTION
~
3.9.2.C.3 had not been performed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of inoperability, but a subsequent (1300 EST) boron concentration verification was used to initiate the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time requirement. Future RCS boron concentration verification would be performed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, per this REQUIRED ACTION.
The Control Room operators notified higher supervision.
V a ~" >,'} 1<
A Control Room operator manually restored the NIS audible count rate function during the midnight shift on November 4, 1997.
G. SAFETY SYSTEM RESPONSES:
None III. CAUSE'OF EVENT:
A. IMMEDIATECAUSE; The immediate cause of the condition prohibited by Technical Specifications was not verifying RCS boron concentration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after discovering that the audible count rate function was inoperable, using the most limiting event sequence for loss of this function.
B. INTERMEDIATE CAUSE:
The intermediate cause of not verifying boron concentration was a misinterpretation of the event sequence.
ROOT CAUSE:
The misinterpretation of the event sequence led to a decision that was incorrect. Note that the precise time that the NIS audible count rate function became inoperable is not known.
This misinterpretation was made possible because there is no positive indication of when the audible count rate function became inoperable. Procedures were deficient in that the applicability of ITS LCO 3,9.2 at all times while in Mode 6 was not addressed in plant operating procedures.
Procedures were also deficient in that actions needed to verify the operability of the NIS audible count rate were not specified in calibration and test procedures.
NAC FOAM 366A (4-95)
NRC FORM 366A . NUCLEAR REGULATORY COMMISSION (4-95)
LXCENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACILITY NAME (1) DOCKET LER NUMBER (6) PAGE (3)
YEAR SEQUENTIAL REVISION NUMBER NUMBER R.E. Ginna Nuclear Power Plant 05000244 5 OF 6 97 006 00 TEXT llfmore spaceis required, use additional copies of NRC Form 366A/ (17)
IV. ANALYSIS OF EVENT This event is"reportable in accordance with 10 CFR 50.73, Licensee Event Report System, item (a) (2) (i)
(B),,which. requires a report of, "Any operation or condition prohibited by the plant's Technical
'pecifications": With the NIS audible count rate inoperable, not verifying RCS boron concentration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after discovery. is not permitted by ITS LCO REQUIRED ACTION 3.9.2.C.3.
An assessment'was performed considering both the safety consequences and implications of this event with the following results and conclusions:
I I' 1" ~ Ili + ~
were no operational or safety consequences or implications. attributed to the delayed I'here verification of boron concengration because:
\
~ No core alterations and no positive reactivity additions occurred during this time period.
~ RCS boron concentration verification was being performed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Previous RCS boron samples had confirmed consistent boron concentrations that were well within the limit specified in the COLR.
Based on the above, it can be concluded that the public's health and safety was assured at all times.
CORRECTIVE ACTION:
A. ACTION TAKEN TO RETURN AFFECTED SYSTEMS TO PRE-EVENT NORMAL STATUS:
~ The most recent RCS boron concentration was verified to be within the limit specified in the, COLR.
~ Subsequent boron verification occurred every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, as per ITS LCO Required Action 3.9.2.C.3.
~ After investigation of the cause for loss of this function, the audible count rate function was restored to operable status.
B. ACTION TAKEN OR PLANNED TO PREVENT RECURRENCE:
~ The requirement to have audible count rate operable at all times while in Mode 6 appears to be conservative. The High Flux at Shutdown alarm may provide adequate assurance of no adverse changes in core reactivity while in Mode 6 (and no core alterations or positive reactivity additions are occurring). Nuclear Safety and Licensing will be requested to evaluate a License Amendment to change this requirement in ITS.
NRC FORM 366A (4-95)
NRC FORM 366A . NUCLEAR REGULATORY COMMISSION (4.95)
LXCENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACILITY NAME (1) DOCKET LER NUMBER (6) PAGE (3)
YEAR SEQUENTIAL REVISION NUMBER NUMBER R.E. Ginna Nuclear Power Plant 05000244 6 OF 6 TEXT iifmore spaceis required, use additional copies of NRC Form 366A j (17)
Appropriate calibration and test procedures will be reviewed, and changed as necessary, to ensure audible count rate operability after completion of calibrations or tests.
Operating procedures will be reviewed, and changed as necessary, to ensure audible count rate operability is verifi6d when..in Mode 6.
( ~ ~ ',d Vl ~ ADDITIONALINFORMATION: ~ ~
II A. FAILED COMPONENTS:
None B. PREVIOUS LERs ON SIMILAR EVENTS:
A similar LER event historical search was conducted with the following results: No documentation of similar LER events with the same root cause at Ginna Station could be identified.
C. SPECIAL COMMENTS:
None NRC FORM 366A (4-95)
0 I