05000285/LER-2012-008-01, Re Technical Specification Violation for Fuel Movement (VA-66)

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

ML12335A054
Person / Time
Site:	Fort Calhoun
Issue date:	11/29/2012
From:	Cortopassi L Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-12-0167 LER 12-008-01
Download: ML12335A054 (6)

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

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i)(8) 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 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
2852012008R01 - NRC Website

text

~~....

BjjjjB OmBh. Publie PowerDiIIrld 444 South 16th Street Mall Omaha, NE 68102-2247 LlC-12-0167 November 29, 2012 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Reference:

Docket No. 50-285

Subject:

Licensee Event Report 2012-008, Revision 1, for the Fort Calhoun Station Please find attached Licensee Event Report 2012-008, Revision 1, dated November 29, 2012. This report is being submitted pursuant to 10 CFR 50.73(a)(2)(i)(8). No commitments are being made in this letter.

If you should have any questions, please contact me.

Sincerely, LoUIs P. Cortopassi Site Vice President and CND LPC Irjr/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 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 sp onsor, and a person is not required to respond to, th e

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 -

1 11 29 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 on three occasions since October of 2009 while the Spent Fuel Pool Area ventilation charcoal filter (VA-66) was likely below the required adsorption capability, hence inoperable.

This LER documents the late reporting of a condition that was prohibited by TS originally identified in September of 2011, and not determined reportable until June 6, 2012. This was due to the belief that since the filters in VA-66 were not credited in the accident analysis, they were not required for operability of the SFP ventilation system.

CONCLUSION A cause analysis determined that a lack of management oversight and the failure of Engineering to take a pro-active approach in the prevention of future test failures lead to this event.

CORRECTIVE ACTIONS

The following actions were entered into the CAP and are complete. The corrective actions include 1) a revision of the applicable procedure to trend charcoal sample results and predict replacement 2) replacement of the depleted charcoal currently installed, and 3) change the frequency of the charcoal testing from eighteen months to 1 year.

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.

FORT CALHOUN STATION NOD-QP-9.2 QUALITY PROCEDURE FORM R0 LICENSING CORRESPONDENCE REVIEW FORM LIC-12-0167 Date Issued: 11/14/12 Requested Return Date:____11/19/12______

Review/Approval Information L. Cortopassi L. Smith T. Simpkin V. Naschansky S. Miller C. Cameron M. Ferm A. Hackerott B. Mierzejewski Subject LER 2012-008 Rev1, Technical Specification Violation for Fuel Movement (VA-66)

Please review and approve the attached draft correspondenc e (referenced above). In order to document your review for our records, please sign this form and return it to the Licensing Coordinator. If n o notification is received by the requested return date, your concurrence with no comment will be assumed.

Erick Matzke 6855 Technical Coordinator (Ext.) Licensing Coordinator (Ext.)

[ ] Approved with no comment. [ ] Approved pending resolution of comments as noted.

Comments:_______________________________________________________________________________

Reviewer's Signature Date

FORT CALHOUN STATION NOD-QP-9.2 QUALITY PROCEDURE FORM R0 LICENSING CORRESPONDENCE REVIEW FORM SUMMARY LIC-12-0167 Date Issued: 11/14/12 Requested Return Date: 11/19/12 Name Date Comments Received No Comments1 Comments - How Resolved2 L. Cortopassi None T. Simpkin 11/20/12 Eighteen corrected.

S. Miller 11/18/12 C. Cameron 11/20/12 X

verbal A. Hackerott 11/15/12 X

B. Mierzejewski none M. Ferm none L. Smith none V. Naschansky 11/14/12 X

Subject LER 2012-008 Rev1, Technical Specification Violation for Fuel Movement (VA-66)

NOTE - This submittal does ____ does not __X__ include documents/files on CD-ROM.3 NL Comment Coordinator Signature Date Responsible Dept. Manager (if required)

Date Review by Nuclear Licensing Supervisor Date 1 Attach only signed Licensing Correspondence Review Form.

2 Attach necessary documentation.

3 Ensure that the CD-ROM files are formatted properly for electronic information exchange (EIE) to the NRC. (Reference NL-17)