05000387/LER-2006-002

LER-2006-002, DMissed Technical Specification surveillance requirement

Docket Number
Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3872006002R00 - NRC Website

PLANT CONDITIONS AT TIME OF EVENT

Unit 1, Mode 5, 0% Unit 2, Mode 1, 100%

EVENT DESCRIPTION

On March 10, 2006 with Unit 1 in Mode 5 for a refuel outage, Maintenance workers breached a containment electrical penetration (EIIS:PEN) to install coax cable as part of a planned modification. The station Containment Leakage Rate Testing Program requires a LLRT prior to performing any maintenance or modification to Appendix J penetrations that may alter the leakage rate of the penetration during an Integrated Leak Rate Test (ILRT) outage. An ILRT was planned as part of the outage. Because the existing conditions no longer existed, the pre-modification leakrate for the penetration could no longer be quantified.

In accordance with plant Technical Specification surveillance requirement SR 3.6.1.1.1, this constituted a missed surveillance and is reportable under 10CFR 50.73(a)(2)(i)(B) as a violation of Tech Specs.

This event did not result in any actual adverse consequences to the health and safety of the public.

CAUSE OF THE EVENT

The apparent cause was a mis-application of the Appendix J Program requirements by the program engineer.

During a pre-outage review of the modification, the program engineer made an assessment that the leak rate values from the last performed LLRT could be utilized for the pre-modification leak rate. This decision was based on the fact that the penetration was a passive barrier and had an excellent history for leakrate results (it was on an extended test frequency). The program requirements for an ILRT outage clearly mandate a pre­ modification LLRT to confirm the integrity of the peneration, even for penetrations on an extended test frequency. This pre-outage review also did not have a peer review to evaluate the scope of outage work activities.

ANALYSIS / SAFETY SIGNIFICANCE

Actual Consequences There were no actual consequences to this event. Based on previous LLRT results, the penetration has historically met its administrative limits and was on an extended test frequency. The reactor was shutdown in mode 5 when the event occurred. The penetration was not required to be operable at the time of the event.

Potential Consequences The potential existed that the penetration would have been degraded, resulting in a test failure. Failure to maintain the primary containment leakage limits within the 10CFR 50 Appendix J requirements could result in exceeding the calculated radiological limits under 10CFR 100.

CORRECTIVE ACTIONS

Completed Actions

1) Because the penetration was disturbed during the modification, the periodic testing requirement was re- established at a 30 month interval.

Planned Actions

1) Review scheduled work on similar containment penetrations governed by the Appendix J Program for the 2007 Unit 2 Refuel Outage.

2) Provide for a peer review of final LLRT/ILRT outage plans and testing requirements prior to future outages.

ADDITIONAL INFORMATION

Past similar events: Docket 50-387 LER 00-001-00