ML19354D599

LER 89-029-00:on 891117,heater Bay/Turbine Bldg Vent Gaseous Effluent Particulate & Iodine Samples Not Continuously Collected as Required by Tech Spec 3.3.7.10.Caused by Procedure Deficiency.Procedure revised.W/891217 Ltr

ML19354D599
Person / Time
Site:	Perry
Issue date:	12/17/1989
From:	Hegrat H, Kaplan A CLEVELAND ELECTRIC ILLUMINATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-89-029, LER-89-29, PY-CEI-NRR-1112, NUDOCS 8912280195
Download: ML19354D599 (4)

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kTHE CLEVELAND ELECTRIC ILLUMINATING' COMPANY  !

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g. P.O. box 97 5 PERRY OHIO 44081 5 TELEPHONE - (216) 259 3737- 3 ADDRESS 10 CENTER ROAD

!L' FROM CLEVELAND: 479-1260 3 TELEX: 241599 ANSWERBACK: CElPRYO Al Kaplan . Serving The Best location in the Nation PERRY NUCLEAR POWER PLANT VICE PRESIDENT

-December 19, 1989 PY-CEI/NRR-1112 L ,

U.S.' Nuclear Regulatory Commission Document ~ Control Desk Washington, D.C. 20555 a

Perry Nuclear Power Plant Docket No. 50-440 LER 89-029

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-Enclosed is Licensee Event Report 89-029 for the Perry Nuclear Power Plant.

Very truly ours, 4

Al Kaplan Vice President Nuclear Group AK/nje

Enclosure:

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On November 17, 1989, between approximately 1859 and 1909, Heater Bay / Turbine Building Vent gaseous effluent particulate and iodine samples were not continuously collected as required by Technical Specification 3.3.7.10.

-Alternate sampling equipment, which had been placed into service on November 17, 1989 at 0305 was secured by Instrument and Controls (I&C) Technicians who were performing calibration procedures on the permanently installed radiation monitor.

Upon discovery, the temporary sampling equipment was promptly restarted.

The root cause of this event was procedure deficiency in that tiie procedure for installing the alternate sample rig (pump included) did not ensure identification of the alternate sample rig as an item required by Technical Specifications. A contributing factor was personnel error. The I&C Technicians failed to recognize the alternate sample rig as equipment installed to support plant operation and temporarily secured the pump while troubleshooting the permanent plant sampling equipment.

Corrective actions to prevent recurrence include revision of the procedure governing installation of the alternate sampling equipment, counseling of the technicians involved in the event, and review of this event with all I&C and Chemistry Technicians during periodic training.

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On November 17, 1989, between approximately 1859 and 1909, Heater Bay / Turbine Building Vent gaseous effluent particulate and iodine samples were not continuously collected as required by Technical Specification 3.3.7.10. The plant was in Operational Condition 1 (Power Operation) at approximately 100 percent of rated thermal power. The Reactor Pressure Vessel [RPV) was at saturated conditions at approximately 1000 psig. Alternate sampling equipment had been placed into service on November 17, 0305, in support of maintenance activities- on the Heater Bay / Turbine Building Vent Radiation Monitor [RT} in  !

accordance with Technical Specifications Table 3.3.7.10 Action 122, which requires samples to be continuously collected using alternate sampling methodology.

On November 17, Instrument and Controls (I&C) Technicians were performing troubleshooting on the Heater Bay / Turbine Building Vent Radiation Monitor. After encountering difficulties in troubleshooting at 1859, the technicians secured the alternate sampler in order to continue troubleshooting. Approximately 5 minutes after the I&C Technicians turned off the alternate sampling equipment, a Chemistry Technician discovered the equipment turned off. As directed by Chemistry Technicians, the I&C Technicians completed their troubleshooting and promptly returned the alternate sampling equipment to service. The alternate sampling equipment was turned off for a total of approximately 5 to 10 minutes.

The I&C Technicians stated, as a rc9 son for turning of f the alternate sampling equipment, that the alternate sample pump operation interfered with troubleshooting of pressure switches '.nside the permanent sampling equipment enclosure. Chemistry section was directed to have the permanent sampling i

equipment enclosure isolation valves tagged closed, which was accomplished on November 18, 1989, in order to support the troubleshooting and maintenance activities without requiring the disruption of flow to the alternate sampler.

The root cause of this event is procedural deficiency. Chemistry Instruction (CHI-42) Miscellaneous Sampling Systems did not provide the necessary assurance that the temporary sample rig was adequately tagged or labeled to identify it as

an item required by Technical Specifications. A contributing factor was personnel error. The technicians performing the activities failed to recognize the sample rig as equipment installed to support plant operation and temporarily secured the pump while troubleshooting the permanent plant sampling equipment.

A provious similar event occurred on November 3, 1986, in which an unknown person unplugged a temporary sample rig to use the extension cord (reference LER 86-075). In that event, sampling was interrupted for approximately three and one half hours. Corrective actions included installing longer power cords on temporary sample pumps to preclude the use of extension cord and tagging the ends of the power cords with lamicold tags which read "Do Not Decnergize Tech Spec Equipment." In the November 17, 1989 event, because the technicians did not unplug the equipment, they did not see the attached warning labels.

Additionally, General Employee Training was enhanced, at the time of the 1986 event, to specifically include guidance with respect to equipment operation.

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This guidance has been provided since that time, and the technicians were aware of the requirement to operate equipment in accordance with approved instructions.

The corrective actions from the previous event, therefore, could not have prevented the failure to follow procedure which caused the event of November 17, 1989.

Technical Specification Table 3.3.7.10-1 Action 122 requires samples to be continuously collected within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> with auxiliary sampling equipment for ef fluent releases to continue with the number of- channels OPERABLE less than required by the Minimum channels OPERABLE requirement. This action ensures that sampling methods implemented are adequatu to ensure that the dose rate limitations of Technical Specification 3/4.11.2.1 are not exceeded. Interruption of this sampling violated Action Statement 122.

Heater Bay / Turbine Building vent releases have remained constant since August, 1989. Prior to and subsequent to this event, releases remained average, routine, and below Technical Specification values. No occurrences, during the time the sample pump was turned off, would lead to the conclusion that the releases were not average, routine, and below Technical Specification values. The sample time lost, in this event, due to the pump being turned off (5 to 10 minutes) was similar to the time duration required to change out a sample cartridge and does not have a significant adverse effect on the accuracy of the continuous sampling.

For samples which are analyzed on a weekly basis, a ten-minute period represents less than 0.001 times the total sample period. Additionally, because the eight-hour allowance provided by the action statement provides for minor scheduled or unscheduled losses of the permanent monitors without alternate measures, this event is not considered to be safety significant.

To prevent recurrence, Chemistry will revise CHI-42 to improve labeling on temporary sample equipment to ensure its proper identification at the pump and not just on the power cord. The I&C technicians who turned off the sample pump shall be counseled on the importanca of contacting the Control Room for guidance when unexpected conditions are discovered during troubleshooting activities.

Additionally, all I&C and Chemistry Technicians will be trained on this event during periodic training.

The reportability of the event is based on interpretation of Technical Specification 3.3.7.10. Originally, the event was considered not to be reportable as a Technical Specification violation under 10CFR50.73.

Determination of reportability occurred on December 14, 1989 after discussions with the NRC Senior Resident regarding the intent of Technical Specification 3.3.7.10. As a result, the available time for LER preparation and approval was insufficient to transmit this report within the required thirty day period as specified under 10CFR50.73.

Energy Industry Identification System Codes are identified in the text as [XX].

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