05000285/LER-2012-008, Regarding Technical Specification Violation for Fuel Movement (VA-66)

Regarding Technical Specification Violation for Fuel Movement (VA-66)

ML12212A334
Person / Time
Site:	Fort Calhoun
Issue date:	07/27/2012
From:	Bannister D Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-12-0097 LER 12-008-00
Download: ML12212A334 (4)

LER-2012-008, Regarding Technical Specification Violation for Fuel Movement (VA-66)

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
2852012008R00 - NRC Website

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jjjjjjjj Omaha l'llblic Power Oislrlcl 444 South 161h Street Mall Omaha, NE 68102-2247 LIC-12-0097 July 27, 2012 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Reference:

Docket No. 50-285

Subject:

Licensee Event Report 2012-oos, Revision 0, for the Fort Calhoun Station Please find attached Licensee Event Report 2012-008, Revision 0, dated July 27, 2012.

This report is being submitted pursuant to 10 CFR 50.73(a)(2)(i)(B). No commitments are being made in this letter.

If you should have any questions, please contact me.

Sincerely, JL~

D. J. Bannister Vice President and CNO DJB /sds/epm Attachment c:

E. E. Collins, Jr., NRC Regional Administrator, Region IV L. E. Wilkins, NRC Project Manager J. C. Kirkland, NRC Senior Resident Inspector INPO Records Center Employment with Equal Opportunity

NRC FORM 366 (10-2010)

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION (10-2010)

LICENSEE EVENT REPORT (LER)

(See reverse for required number of digits/characters for each block)

APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2013

, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

1. FACILITY NAME Fort Calhoun Station

2. DOCKET NUMBER 05000285

3. PAGE 1 OF 3

4. TITLE Technical Specification Violation for Fuel Movement (VA-66)

5. EVENT DATE

6. LER NUMBER

7. REPORT DATE

8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR SEQUENTIAL NUMBER REV NO.

MONTH DAY YEAR FACILITY NAME DOCKET NUMBER 05000 9

28 2011 2012 - 008 -

0 7

27 2012 FACILITY NAME DOCKET NUMBER 05000

9. OPERATING MODE 5

11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply) 20.2201(b) 20.2203(a)(3)(i) 50.73(a)(2)(i)(C) 50.73(a)(2)(vii) 20.2201(d) 20.2203(a)(3)(ii) 50.73(a)(2)(ii)(A) 50.73(a)(2)(viii)(A) 20.2203(a)(1) 20.2203(a)(4) 50.73(a)(2)(ii)(B) 50.73(a)(2)(viii)(B) 20.2203(a)(2)(i) 50.36(c)(1)(i)(A) 50.73(a)(2)(iii) 50.73(a)(2)(ix)(A) 20.2203(a)(2)(ii) 50.36(c)(1)(ii)(A) 50.73(a)(2)(iv)(A) 50.73(a)(2)(x) 20.2203(a)(2)(iii) 50.36(c)(2) 50.73(a)(2)(v)(A) 73.71(a)(4) 20.2203(a)(2)(iv) 50.46(a)(3)(ii) 50.73(a)(2)(v)(B) 73.71(a)(5) 20.2203(a)(2)(v) 50.73(a)(2)(i)(A) 50.73(a)(2)(v)(C)

OTHER 20.2203(a)(2)(vi) 50.73(a)(2)(i)(B) 50.73(a)(2)(v)(D)

Specify in Abstract below or in LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET questioned as a condition prohibited by TS in May 2012, the engineering review agreed with the December 2009 station position, and a new reportability evaluation was not promptly completed. The station paradigm inappropriately concluded that reportability could be evaluated at a later date since current operating conditions were not challenged, and that the 60-day reporting window commenced when the event was determined to be reportable. FCS has been systematically addressing issues that have been identified since June 2011, in response to the flooding conditions, switchgear fire, and increased oversight. This LER is being submitted beyond the 60-day regulatory reporting requirement due to non-conservative decisions with respect to procedural and regulatory reportability requirements and resource constraints caused by the operating challenges which began in June 2011.

CONCLUSION A cause analysis is in progress. The conclusions of the analysis will be presented in a supplement to this LER.

CORRECTIVE ACTIONS

Corrective actions included a revision of the applicable procedure to ensure that charcoal life is predicted and charcoal filter change out is performed before the charcoal expires.

Additional actions will be tracked in the stations corrective action system.

SAFETY SIGNIFICANCE

FCS TS require the SFP area ventilation to be in operation during operations in the SFP to mitigate the consequences of a fuel handling accident. However, the FCS accident analysis for a fuel handling accident in the SFP assumes the activity is collected by the SFP area ventilation system and released, unfiltered, to the environment, via the auxiliary building vent stack. Since there is no means of isolating the SFP area, all of the airborne activity resulting from the fuel handling accident is assumed to be exhausted out of the auxiliary building in a period of two hours. The SFP area ventilation has no safety function as it is not credited for mitigating the radiological consequences of a fuel handling accident even though actual tests have demonstrated the effectiveness of VA-66 in reducing radiation doses. Therefore, there is no safety significance associated with fuel movement when VA-66 is inoperable and this event had no impact on the health and safety of the public.

SAFETY SYSTEM FUNCTIONAL FAILURE This event does not result in a safety system functional failure in accordance with NEI-99-02.

PREVIOUS EVENTS The station has had two similar events (movement of fuel with VA-66 inoperable) as documented in LER 90-05 and LER 94-006.