05000220/LER-2009-001, Failure to Implement Required Technical Specification Actions Associated with Failed Surveillance Test
| ML090900513 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 03/25/2009 |
| From: | Belcher S Constellation Energy Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LER 09-001-00 | |
| Download: ML090900513 (8) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(v), Loss of Safety Function |
| 2202009001R00 - NRC Website | |
text
Sam Belcher Plant General Manager P.O. Box 63 Lycoming, New York 13093 315.349.5205 315.349.1321 Fax Constellation Energy Nine Mile Point Nuclear Station, LLC March 25, 2009 U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION:
SUBJECT:
Document Control Desk Nine Mile Point Nuclear Station Unit No. 1; Docket No. 50-220 Licensee Event Report 2009-001, Failure to Implement Required Technical Specification Actions Associated with Failed Surveillance Test In accordance with 10 CFR 50.73(a)(2)(i)(B), please find attached Licensee Event Report 2009-001, Failure to Implement Required Technical Specification Actions Associated with Failed Surveillance Test.
Should you have questions regarding the information in this submittal, please contact T. F. Syrell, Licensing Director, at (315) 349-5219.
Very truly yours, fe-ýý SLB/GNS
Attachment:
Licensee Event Report 2009-001, Failure to Implement Required Technical Specification Actions Associated with Failed Surveillance Test cc:
S. J. Collins, NRC R. V. Guzman, NRC Resident Inspector, NRC kA~A2~
ATTACHMENT LICENSEE EVENT REPORT 2009-001 FAILURE TO IMPLEMENT REQUIRED TECHNICAL SPECIFICATION ACTIONS ASSOCIATED WITH FAILED SURVEILLANCE TEST Nine Mile Point Nuclear Station, LLC March 25, 2009
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 08/31/2010 (9-2007)
, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.
- 3. PAGE Nine Mile Point Unit 1 05000220 1 OF 6
- 4. TITLE Failure to Implement Required Technical Specification Actions Associated with Failed Surveillance Test
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED FACILITY NAME DOCKET NUMBER MNH DY YA YERSEQUENTIAL REV MONTH DAY YEAR NA NUMBER NO.
None FACILITY NAME DOCKET NUMBER 1
26 2009 2009 001 00 03 25 2009 None NA
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR§: (Check all that apply)
El 20.2201(b)
El 20.2203(a)(3)(i)
El 50.73(a)(2)(i)(C)
El 50.73(a)(2)(vii)
NA El 20.2201(d)
El 20.2203(a)(3)(ii)
El 50.73(a)(2)(ii)(A)
El 50.73(a)(2)(viii)(A)
[I 20.2203(a)(1)
[E 20.2203(a)(4)
El 50.73(a)(2)(ii)(B)
El 50.73(a)(2)(viii)(B)
El 20.2203(a)(2)(i)
El 50.36(c)(1)(i)(A)
[I 50.73(a)(2)(iii)
El 50.73(a)(2)(ix)(A)
- 10. POWER LEVEL El 20.2203(a)(2)(ii)
El 50.36(c)(1)(ii)(A)
[I 50.73(a)(2)(iv)(A) 0l 50.73(a)(2)(x)
El 20.2203(a)(2)(iii)
El 50.36(c)(2)
El 50.73(a)(2)(v)(A)
El 73.71(a)(4)
El 20.2203(a)(2)(iv)
El 50.46(a)(3)(ii)
El 50.73(a)(2)(v)(B)
El 73.71(a)(5) 100 El 20.2203(a)(2)(v)
El 50.73(a)(2)(i)(A)
El 50.73(a)(2)(v)(C)
El OTHER El 20.2203(a)(2)(vi) 0 50.73(a)(2)(i)(B)
El 50.73(a)(2)(v)(D)
Specify in Abstract below or in C. INOPERABLE STRUCTURES, COMPONENTS, OR SYSTEMS THAT CONTRIBUTED TO THE EVENT:
The initiating event for the condition described in this LER was failure of MSIV 01-01 to fully re-open when required during a surveillance test. The failure of the valve to re-open was caused by a spring-loaded terminal on the MCC contactor in the circuit that opens MSIV 01-01 that was found disengaged.
D. DATES AND APPROXIMATE TIMES OF MAJOR OCCURRENCES
0000:
On January 26, 2009, permission was given for Operations to perform the required TS surveillance per TS 4.2.7.c.
0033:
MSIV 01-01 operates properly in the shut direction, but does not automatically return to the full open position as per design. Attempts to manually open MSIV 01-01 from the control room are also unsuccessful.
0136:
SM documents operability determination which concludes that MSIV 01-01 is operable based on a reasonable expectation that the valve can perform its safety function to close.
1134:
MSIV 01-01 de-energized for troubleshooting. MSIV 01-01 declared inoperable. 4-hour Limiting Condition for Operation (LCO) action 3.2.7.b entered.
1300:
It is recognized that MSIV 01-01 should have been declared inoperable at 0033.
1455:
Following repairs, MSIV 01-01 is re-energized and fully re-opened.
1529:
MSIV 01-01 declared operable and TS 3.2.7.b action is exited.
E. OTHER SYSTEMS OR SECONDARY FUNCTIONS AFFECTED
No other systems or secondary functions were affected by this condition.
F. METHOD OF DISCOVERY
Recognition that MSIV 01-01 should have been declared inoperable at 0033 was identified at approximately 1300 as a result of further assessment of the issue by operations and other on-site groups.
G. MAJOR OPERATOR ACTION:
The failure of the SM to adequately review the acceptance criteria of the relevant TS surveillance requirement when MSIV 01-01 failed to re-open during the performance of the surveillance procedure on January 26, 2009, resulted in failure to recognize that MSIV 01-01 was inoperable.
H. SAFETY SYSTEM RESPONSES:
Reactor Protection System Channel 11 tripped (1/2 scram) as per design when MSIV 01-01 was partially stroked closed in accordance with the surveillance procedure.
II. CAUSE OF EVENT
The primary cause for the delay in declaring MSIV 01-01 inoperable when it failed its surveillance test at 0033 on January 26, 2009, is that the SM became focused on assessing the safety function of the MSIV and did not fully evaluate the relevant TS surveillance requirements which required the valve to re-open as part of the surveillance test acceptance criteria. In addition, the leadership team and the operating crew did not provide adequate back-up in validating the Shift Manager's decision regarding the operability of MSIV 01-01. (Ref. CR 2009-000467)
I1l. ANALYSIS OF THE EVENT:
This event is reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as operation in a condition not allowed by Technical Specifications. Specifically, due to the failure to recognize MSIV 01-01 as inoperable, the requirement of TS 3.2.7.c to initiate a plant shutdown was not implemented at 0533 on January 26, 2009, under plant operating conditions that required such action. In addition, the requirement of TS 3.2.7.c to place the reactor in the cold shutdown condition within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> (by 1433) was also not implemented.
MSIV 01-01 was successfully stroked fully closed and re-opened during surveillance testing on November 16, 2008. It is postulated that the spring-loaded terminal became disengaged subsequent to this test. The period of time between declaring MSIV 01-01 inoperable (1134) and restoration of operability (1529) was 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and 55 minutes.
MSIV 01-01 retained its ability to perform its safety function to close until its power supply breaker was opened at 1134 on January 26, 2009. As a result of this event, NMP1 was in a half-scram condition for approximately 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> (between 0033 and 1455 on January 26, 2009).
Under certain accident conditions that result in MSIV closure, re-opening the MSIVs to reject decay heat to the condenser is identified as a potential success path. With MSIV 01-01 unable to re-open, the ability to reject decay heat via this path would have been eliminated. However, the redundant flow path through the other main steam line would have remained available for decay heat removal as would other success paths such as using the Emergency Condensers.
Based upon the above it is concluded that this event did not have a significant impact on nuclear, industrial, environmental, or radiological safety.
IV. CORRECTIVE ACTIONS
A. ACTION TAKEN TO RETURN AFFECTED SYSTEMS TO PRE-EVENT NORMAL STATUS:
The spring-loaded contact on the closing circuit for MSIV 01-01 was placed in its normal fully engaged position and the MSIV declared operable following successful completion of its surveillance test.
B. ACTION TAKEN OR PLANNED TO PREVENT RECURRENCE:
In response to this event the following actions have been completed:
0 Technical Specification required procedure steps in the surveillance test procedure have been annotated to match the associated TS surveillance requirements.
A "Night Order" was disseminated to operations shift crews to communicate the lessons learned from this event.
In addition, the following actions are planned:
Training will be provided for all Shift Managers, Control Room Supervisors, and Shift Technical Advisors at both units on the application of TS surveillance requirements and performing rigorous operability assessments.
The procedure used for response to operational conditions/events will be revised to include a flowchart for operability assessments, and an emergent issues checklist will be added to the Type 1 Operational Decision-Making Checklist.
V. ADDITIONAL INFORMATION
A. FAILED COMPONENTS:
MSIV 01-01 failed to re-open during surveillance testing due to a spring-loaded terminal on the MCC contactor in the circuit that opens MSIV 01-01 that was found disengaged.
B. PREVIOUS LERs ON SIMILAR EVENTS:
A review of Licensee Event Reports submitted by Nine Mile Point nuclear Station during the last five years did not identify any similar events (i.e., Operation in condition prohibited by TS caused by a failure to recognize a component had failed to meet an applicable TS Surveillance requirement during surveillance testing).
C. THE ENERGY INDUSTRY IDENTIFICATION SYSTEM (EIIS) COMPONENT FUNCTION IDENTIFIER AND SYSTEM NAME OF EACH COMPONENT OR SYSTEM REFERRED TO IN THIS LER:
COMPONENT IEEE 803 FUNCTION IDENTIFIER IEEE 805 SYSTEM IDENTIFICATION MSIV 01-01 MCC Contactor D. SPECIAL COMMENTS:
None SHV 4
SB SB