Event Notification Report for October 02, 2012

UNANALYZED CONDITIONS MAY LEAD TO INTERMEDIATE CONSEQUENCE EVENTS

"On Friday 9/28/2012, while completing ISA [Integrated Safety Analysis] meetings on a new process, several accident sequences were identified that had the potential for creating ocular exposures that could lead to intermediate consequences in accordance with 10CFR70. The sequences involved uranyl nitrate (UN) solutions. IROFS [Item Relied On For Safety] were identified for the new process.

"As a follow-up to this activity, on 10/02/2012, plant safety personnel reviewed existing ISA accident sequences for other process systems where UN solution is present and at 0730 [PDT], reported to the EHS&L Manager that similar loss of containment accident sequences in other process systems were determined to be 10CFR70 low consequence events within the approved existing ISA.

"This report is being made under 10CFR70 Appendix A, criterion (b)(1) which states, 'Any event or condition that results in the facility being in a state that was not analyzed, was improperly analyzed, or is different from that analyzed in the Integrated Safety Analysis, and which results in failure to meet the performance requirements of 10CFR70.61.'

"10CFR70.61 (4)(e) states in part, '...Each engineered or administrative control or control system necessary to comply with paragraphs (b), (c), or (d) of this section shall be designated as an item relied on for safety.'

"While this report is being made based on the treatment of UN sprays to the eye, this scenario can be applied to other hazardous chemicals falling under the scope of the ISA treatment.

"Based on information obtained during the ISA activities for this new process, two other types of accident sequences documented in the existing facility ISA as 10CFR70 low consequence events need to be re-evaluated with respect to the 10CFR70 consequences of concern thresholds. These types of accident sequences are dermal contact and inhalation of liquid aerosols. These two types of accident sequences are being re-evaluated throughout the plant. The status of this re-evaluation effort will be reported in a 30-day follow-up report to this initial notification.

"The personal protective equipment (PPE) that is used to provide protection to workers during work evolutions and the safety protocols for limiting exposures to UN are not categorized as IROFS for some of the existing processes. The PPE and safety protocols used by AREVA based on 40 years experience for these types of scenarios are considered to be adequate. AREVA's re-evaluation of these scenarios will be utilized to confirm their adequacy, or if applicable, to identify needed enhancements.

"This discrepancy has potentially existed since 10/18/2004. This report does not involve potential criticality accident scenarios.

"Corrective Actions in Progress:

1) verify that appropriate spray shields/deflectors are in place,
2) verify existing safety protocols that are in place are adequate, and
3) update the safety analysis and implementing documents to declare as IROFS the appropriate PPE and safety protocol."

The licensee will be notifying Region 2.

INVALID ACTUATION SIGNAL OF THE PRIMARY CONTAINMENT ISOLATION LEVEL TRANSMITTER

"This 60-day telephone notification is being made in accordance with the reporting requirements specified in 10 CFR 50.73(a)(2)(iv)(A) to describe an invalid actuation signal of the primary containment isolation level transmitter (02-3LT-101A).

"Status of SSC's that were inoperable and contributed to the event:

"The B Reactor Protection System (RPS) was inoperable due to performance of Emergency Diesel Generator (EDG) B & D Load Sequencing test and 4KV Emergency Power System voltage relay instrument functional test. Therefore, the B RPS was deenergized and associated B RPS channels were tripped.

"Narrative:

"On 10/2/2012 at 09:37 hours, James A. Fitzpatrick Nuclear Station received a full reactor scram actuation from reactor vessel level transmitter 02-3LT-101A, containment Isolation. The full scram was due to an equipment malfunction, no low level condition was actually present at the time.

"It was determined that the replacement of refueling water level transmitter 02-3LT-61 on 09/30/12 was incorrectly performed by not properly venting the sensing line after installation. The common sensing line contains a local high point inside the drywell. The mechanism is air displaces the water in the line causing pressure to momentarily drop which causes the instrument to trip as if reactor water level had actually dropped. Air propagation in one sensing line can have an impact on all of the instruments attached to the common sensing line.

"Corrective Actions:

"A back flush was performed for instrument rack 25-5. Applicable I&C Post maintenance testing procedures will be updated to include a back flush or forward flush to ensure that instrument lines are properly vented prior to returning the instrument lines to service.

"The following additional information is provided:

"On 10/2/2012 at 09:45 hours, shift performed OP-18 to reset the scram that occurred at 0937 EST. The procedure provided guidance to install jumpers to allow the scram discharge instrument volume (SDIV) high level scram signal to be bypassed. The jumpers were required since one channel of the RPS was inoperable due to performance of EDG B & D Load Sequencing test and 4KV Emergency Power System voltage relay instrument functional test.

"On 10/2/2012 at 10:07 hours, James A. Fitzpatrick Nuclear Station received another full reactor SCRAM actuation of the SDIV B hi-level trip. The safety function of the actuation had already been completed as a result of the previous scram due to the RPS B bus being de-energized, the SDIV B could not be drained. The SDIV A was also not yet drained, and the high level signal was still technically a valid signal that was present. AOP-1 contained steps to verify that the SDIV A or B 'not drained' annunciators are clear before placing the SDIV by-pass switch to normal position. This step was not performed. It was therefore determined to be an invalid signal based on NUREG-1022 guidance: 'actuations initiated for reasons other than to mitigate an event need not be reported.' The signal was actuated during an attempt to reset the previous SCRAM per OP-18, the occurrence of the signal was due to inadequate work planning, and a procedural deficiency which caused the jumpers to be removed prior to draining the SDIV A. Therefore this event did not meet the criteria for being a valid actuation.

"Additional Corrective Actions:

"Revise OP-18 to provide adequate guidance how to reset a SCRAM with one RPS bus de-energized."

The licensee informed the NRC Resident Inspector.

AGREEMENT STATE REPORT - LOST TRITIUM EXIT SIGN

The following information was provided by the State of Colorado via email:

"The Colorado Department of Public Health and Environment received notification on 10-2-12 from Westin Hotel - Westminster, 10600 Westminster Blvd., Westminster, CO 80030. Phillip McDonald, Engineering Manager, reported a contractor removed and disposed of one exit sign during a remodel project when a new front entrance was completed, (no date given on project).

"Maker of Sign: Isolite
Model Number: SLX60
Serial Number: 12-02897
Activity (Curies of H-3): 6.2 Curies
Date Manufacture Shipped: 1/31/2012
Date of Loss: No Date Reported for project.
Location of Sign When Lost: Front entrance

"Other Details: Per the letter submitted by Phillip McDonald, he states 'I do remember this device being installed, but I was unaware it had radioactive material inside or the responsibility of tracking this device. Our restaurant was remodeled this year and the contractor removed the device and disposed of it'."

THIS MATERIAL EVENT CONTAINS A "LESS THAN CAT 3" LEVEL OF RADIOACTIVE MATERIAL

Sources that are "Less than IAEA Category 3 sources," are either sources that are very unlikely to cause permanent injury to individuals or contain a very small amount of radioactive material that would not cause any permanent injury. Some of these sources, such as moisture density gauges or thickness gauges that are Category 4, the amount of unshielded radioactive material, if not safely managed or securely protected, could possibly - although it is unlikely - temporarily injure someone who handled it or were otherwise in contact with it, or who were close to it for a period of many weeks. For additional information go to http://www-pub.iaea.org/MTCD/publications/PDF/Pub1227_web.pdf

This source is not amongst those sources or devices identified by the IAEA Code of Conduct for the Safety & Security of Radioactive Sources to be of concern from a radiological standpoint. Therefore is it being categorized as a less than Category 3 source