Event Notification Report for November 22, 2004

PORTION OF PRIMARY INSTRUMENT LINES NOT ALIGNED TO SECONDARY CONTAINMENT

"At 15:10 on 11/22/2004 Operations was notified of a condition that could have prevented the ability of Secondary Containment to control and monitor the release of radioactive material.

"Three primary system instrument lines have approximately a 20-foot run in an area that is not normally aligned to Secondary Containment. This area has been realigned to Secondary Containment until an analysis of this design can be completed. This has been determined to be reportable under 10CFR50.72(b)(3)(v)(C).

"Unit 1 is at 15% power with the main generator off line for unrelated repairs."

The licensee notified the NRC Resident Inspector.

INADVERTENT ISOLATION OF THE REACTOR CORE ISOLATION COOLING SYSTEM

"This ENS notification is made to report that on November 22, 2004 at 17:30 PST the Reactor Core Isolation Cooling (RCIC) system was rendered inoperable when its inboard steam supply containment isolation valve inadvertently closed during the performance of a routine surveillance procedure. The surveillance procedure was stopped and plant operators entered the appropriate Technical Specification Action Statements. The RCIC system was restored to its normal standby lineup and declared operable two hours and three minutes after the isolation.

"NRC guidance in NUREG 1022 (Rev. 2), 'Event Reporting Guidelines,' and NRC Regulatory Issue Summary (RIS) 2001-14, 'Position on Reportability Requirements for Reactor Core Isolation Cooling System Failure,' indicates that RCIC failures are not reportable unless the RCIC system is specifically credited in the plant's Final Safety Analysis Report for mitigating the consequences of a Control Rod Drop Accident (CRDA). Columbia Generating Station has determined that the current licensing basis and docketed correspondence is not clear regarding RCIC credit for CRDA mitigation. Proposed FSAR changes were recently submitted by Energy Northwest to the NRC that would clarify that RCIC is not credited for CRDA mitigation. However, the NRC staff has not yet approved these proposed changes. Therefore, Columbia Generating Station has decided to conservatively report this event under 10 CFR 50.72(b)(3)(v)(D). A follow-up LER will be issued under 10 CFR 50.73(a)(2)(v)(D)."

The licensed has notified the NRC Resident Inspector.

POTENTIAL NON-CONSERVATISM IN BUTTERFLY VALVE TORQUE PREDICTIONS UNDER COMPRESSIBLE FLOW CONDITIONS.

Issue:
By letter dated October 26, 2004, Electric Power Research Institute (EPRI) notified affected members in accordance with 10 CPR 21.21(b), of a non-conservatism in the [software product of] EPRI Motor Operated Valve Performance Prediction Methodology (PPM), Versions 1.0 through 3.2, to predict total required dynamic torque under compressible flow conditions for actuators for butterfly valves with single disc offset designs. As explained in the error notice, the non-conservatism could be as much as 45 percent. This non-conservatism could potentially jeopardize the design basis operation of associated safety related applications.

Southern Nuclear Company (SNC) subsequently performed an engineering evaluation based on the EPRI notification as it related to Vogtle Electric Generating Plant (VEGP). The assessment did not identify any instances where the PPM had actually been used for such purposes at VEGP.

Corrective Action:
This issue has been entered into the SNC Corrective Action Program. SNC will evaluate the restrictions, adjustments, and recommendations regarding use of the EPRI MOV PPM, Versions 1.0 through 3.2, that were communicated in EPRI PPM Software Error Notice 2004-2.