05000321/LER-2012-001, Regarding Non-Compliance with Technical Specification 3.9.4 for Control Rod Position Indication During Shutdown
| ML12123A076 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 05/01/2012 |
| From: | Ajluni M Southern Co, Southern Nuclear Operating Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| NL-12-0911 LER 12-001-00 | |
| Download: ML12123A076 (6) | |
| 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)(8) 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)(8) 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)(8) |
| 3212012001R00 - NRC Website | |
text
Mark J. A;luni, P.E.
Nuclea r Li ce nsi ng Director Southern Nuclear Operating Company, Inc.
40 Invern ess Center Parkway Post Office Box 1295 Birm ingham, Alabama 35201 Tel 205992.7673 Fax 205.992.7885 May1, 2012 SOUTHERN'\\'
COMPANY Docket Nos.: 50-321 NL-12-0911 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant Licensee Event Report 2012-001-0 Non-Compliance with Technical Specification 3.9.4 for Control Rod Position Indication During Shutdown Ladies and Gentlemen:
In accordance with the requirements of 10CFR50.73(a)(2)(i)(B), Southern Nuclear Operating Company hereby submits the enclosed Licensee Event Report concerning an event of non-compliance with Technical Specification 3.9.4 for Control Rod Position Indication during a plant shutdown for refueling.
This letter contains no NRC commitments. If you have any questions, please contact Mr. B. D. McKinney at (205) 992-5982.
Respectfully submitted,
~~ or-'
M. J. Ajluni Nuclear Licensing Director MJAlWEBI Enclosure: LER 1-2012-000, Revision 0 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. D. R. Madison, Vice President - Hatch Mr. B. L. Ivey, Vice President - Regulatory Affairs Mr. B. J. Adams, Vice President - Fleet Operations RTYPE: CHA02.004
U. S. Nuclear Regulatory Commission NL-12-0911 Page 2 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. P. G. Boyle, NRR Senior Project Manager - Hatch Mr. E. D. Morris, Senior Resident Inspector - Hatch
Enclosure NL-12-0911 Edwin I. Hatch Nuclear Plant - Unit 1 Licensee Event Report 2012-001-0 Non-Compliance with Technical Specification 3.9.4 for Control Rod Position Indication During Shutdown
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION (9*2007)
LICENSEE EVENT REPORT (LER)
APPROVED BY OMB: NO. 3150*0104 EXPIRES: 10/31/2013 Estimated burden per response to comply with this mandatory collection request: 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />. Reported lessons learned are incorporated into the licensing process and fed back to industry. Send comments re~arding burden estimate to the Records and FOIAIPrivacy Service Branch
- 5 F53), U.S Nuclear Regulatory Commission, Washington, DC 20555*0001, or by internet e*mail to infocollects.resources@nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB*l0202, (3150*0104), Office of Mana~ement and Budget, Washington, DC 20503. If a means used to impose an in ormation collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to resDond to. the information collection.
- 1. FACILITY NAME Edwin I. Hatch Nuclear Plant Unit 1
- 2. DOCKET NUMBER r.
PAGE 05000321 1 OF 3
- 4. TITLE Non-Compliance with Technical Specification 3.9.4 for Control Rod Position Indication During Shutdown
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR SEQUENTIAL NUMBER REV NO.
MONTH DAY YEAR FACILI TY NAME DOCKET NUMBER 05000 02 28 2012 2012 -
01 -
0 I
05 01 2012 FACILITY NAME DOC KET NUMBER 05000
- 9. OPERATING MODE 5
11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR§: (Check al/ that apply)
D 20.2201(b)
D 20.2203(a)(3)(i)
D 50.73(a)(2)(i)(C)
D 50.73(a)(2)(vii)
D 20.2201 (d)
D 20.2203(a)(3)(ii)
D 50.73(a)(2)(ii)(A) 0 50.73(a)(2)(viii)(A) o 20.2203(a)(1)
D 20.2203(a)(4)
D 50.73(a)(2)(ii)(8)
D 50 73(a)(2)(viii)(8) o 20.2203(a)(2)(i) o 50.36(c)(1 )(i)(A)
D 50.73(a)(2)(iii)
D 50.73(a)(2)(ix)(A) o 20.2203(a)(2)(ii) o 50.36(c)(1 )(ii)(A)
D 50.73(a)(2)(iv)(A)
D 50.73(a)(2)(x) o 20.2203(a)(2)(iii) o 50.36(c)(2)
D 50.73(a)(2)(v)(A)
D 73.71 (a)(4) o 20.2203(a)(2)(iv) o 50,46(a)(3)(ii) o 50.73(a)(2)(v)(8) 0 73.71(a)(5) o 20.2203(a)(2)(v) o 50.73(a)(2)(i)(A) o 50.73(a)(2)(v)(C) 0 OTHER o 20.2203(a)(2)(vi)
~ 50.73(a)(2)(i)(8) o 50.73(a)(2)(v)(O)
Specify in Abstract below or in NRC Form 366A
- 10. POWER LEVEL 0
- 12. LICENSEE CONTACT FOR THIS LER FACILITY NAME fELEPHONE NUMBER (Include Area Code)
Edwin I. Hatch 1Steven Tipps - Principal Engineer - Licensing 912-537-5880 CAUSE SYSTEM COMPONENT MANU*
FACTURER REPORTABLE TO EPIX
CAUSE
SYSTEM COMPONENT MANU*
FACTURER REPORTABLE TO EPIX
- 14. SUPPLEMENTAL REPORT EXPECTED DYES (/fyes, complete 15. EXPECTED SUBMISSION DATE)
~NO
- 15. EXPECTED SUBMISSION DATE MONTH DAY YEAR ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)
On 2/25/2012, with the unit in Mode 5 for refueling, the "fUll-in" indication for Control Rod (CR) 22-27 was noted to be inoperable, and a required action statement(RAS) for TS 3.9.4 was entered. In accordance with the RAS the control room staff visually verified that the CR was fully inserted, action was taken to electrically disarm the associated CR drive, and a tag-out was conducted as part of the disarming action. A modified probe buffer card was installed to bypass the "fUll-in" indication signal in order to remove the rod block. Notation of the use of the modified probe buffer card was added to an existing TS RAS to track its installation and loss of the RPIS indication. At 2121 EST on 2/28/2012, the tag-out described above was I
cleared (i.e., removed) without removing the modified probe buffer card and without performing a functional test of the "full-in" indication prior to moving fuel in the reactor vessel.
Fuel movement occurred from the time the tag-out was removed until 0817 EST on 3/212012 when the error was discovered; resulting in a condition prohibited by TS for CR position indication. The cause of this event was attributed to less than adequate procedural controls and the failure of involved personnel to effectively "self check" as a human error prevention technique. A procedure change was implemented to require the shift supervisor to sign a tag-out if used to comply with a TS requirement.
NRC FORM 366 (9-2007)
PRINTED ON RECYCLED PAPER
PLANT AND SYSTEM IDENTIFICATION
General Electric - Boiling Water Reactor Energy Industry Identification System codes appear in the text as (EllS Code XX).
DESCRI PTION OF EVENT On 2/25/2012, with the unit in Mode 5 for refueling, the control rod "full-in" indication for Control Rod 22-27(AA) seen by the Rod Position Indicating System (RPIS) was noted to be inoperable, and a RAS for TS 3.9.4 was entered. In accordance with TS RAS 3.9.4.A.2.2 for the Condition in which one or more required control rod position indication channels is inoperable, action was taken to electrically disarm the Control Rod Drive (CRD) associated with Control Rod 22-27 after visual verification that the control rod drive was fully inserted. A suitable tag-out was conducted to assure the continuation of the disarming of CRD 22-27.
Subsequently, a modified probe buffer card was installed to bypass the "full-in" indication signal in order to remove the associated rod blocks to facilitate appropriate outage activities.
Notation of the use of the modified probe buffer card in the RPIS for Control Rod 22-27 was added to an existing TS RAS which was being used to track the loss of RPIS indications and similar buffer card installations for other control rods.
After completion of the associated work, at approximately 2121 EST on 2/28/2012, the tag out described above was cleared (i.e., removed) without removing the modified probe buffer card and without performing a functional test of the RPIS full-in indication prior to moving fuel in the reactor vessel, as required. Fuel movement occurred from the time the tag-out was removed until 0817 EST on 3/2/2012 when the error was discovered, resulting in a condition prohibited by TS LCO 3.9.4 for Control Rod 22-27 position indication.
CAUSE OF EVENT
The cause of this event was attributed to less than adequate procedural controls with respect to other administrative control documents (tag-outs, for example) for which credit is taken to ensure tag-outs are not removed prior to ciearing the conditions required by the associated required action statements. This lack of effective procedural control was exacerbated by the failure of involved personnel to effectively "self check" as a human error prevention technique. These concurrent deficiencies resulted in the failure of the on-shift management to account for the prior installation of the modified probe buffer card on Control Rod 22-27 RPIS when considering the removal of the tag-out for the CRD 22-27. Thus, the resultant failure to remove the modified probe buffer card inadvertently potentially impacted the "Refueling Equipment Interlocks" and the "Refuel Position One-Rod-Out Interlock" and was contrary to TS LCO 3.9.4.
REPORTABILITY ANALYSIS AND SAFETY ASSESSMENT Assessment Information:
Refueling equipment interlocks restrict the operation of the refueling equipment or the withdrawal of control rods to reinforce unit procedures that prevent the reactor from potentially achieving criticality during refueling. The refueling interlock circuitry senses the conditions of the refueling equipment and the control rods. Depending on the sensed conditions, interlocks are actuated to prevent the operation of the refueling equipment or the withdrawal of control rods. (10-2010)
LICENSEE EVENT REPORT (LER)
CONTINUATION SHEET u.s. NUCLEAR REGULATORY COMMISSION
- 1. FACILITY NAME
- 2. DOCKET
- 6. LER NUMBER
- 3. PAGE Edwin I. Hatch Nuclear Plant Unit 1 05000321 YEAR I
SEQUENTIAL I REVISION NUMBER NUMBER OF 3
3 2012 01 o
The RPIS full-in position indication channel for each control rod provides necessary information to the refueling interlocks to prevent such inadvertent criticalities during refueling operations. During refueling, the refueling interlocks (reference LCO 3.9.1 and LCO 3.9.2) use the full-in position indication channel to limit the operation of the refueling equipment and the movement of the control rods. The absence of the full-in position channel signal for any control rod removes the "all-rods-in" permissive for the refueling equipment interlocks and prevents fuel loading. Also, this condition causes the refuel position "one-rod-out interlock" to disallow the withdrawal of any other control rod.
The inoperability of the "control rod full-in indication" for Control Rod 22-27 which resulted from the failure to properly remove the modified probe buffer card on Control Rod 22-27 RPIS did not result in any personnel injuries, offsite radiological releases, or damage to safety related equipment. During the time frame that fuel was moved in the reactor vessel without having operable position indication for Control Rod 22-27, the installation of the probe buffer card would physically allow that control rod to be withdrawn with the reactor in a mode where this is not allowed. However, administrative controls were in place to preclude the withdrawal of any control rod and additional TS required action statements would have to be cleared as well to allow movement of a control rod. Even though this "as found" condition was contrary to the TS requirements, no change in reactivity resulted and no movement of the control rod occurred. Based on this information this reported condition had low safety significance.
These events comprised an operation or condition which was prohibited by TS 3.9.4, and are thus reportable under the requirements of 10CFR50.73(a)(2)(i)(B).
CORRECTIVE ACTIONS
Short-term corrective actions included "Beginning-of-Shift-Training", where direction was given in BOST 12-12, "Tag-out Released with Technical Specification RAS Still Active", that the Unit Shift Supervisor should sign as a "Tag-out Holder" for any tag-out being used for Technical Specification RAS configuration control compliance and should list the RAS number as a reason for being a "Tag-out Holder" on the tag-out.
Long-term corrective actions include the revision of procedure 31 GO-OPS-006-0 "Conditions, Required Actions, and Completion Times" and form OPS-1349 "Required Action Sheet" to include specific directions to reference and list Administrative Control Documents such as tag-outs or other required action tracking sheets on OPS-1349 "Required Action Sheet" to preclude an oversight such as that which occurred in the subject event.
Additionally, the shift supervisor will signon as the document holder for the tagout or "locked" the tagout as directed by procedure as an additional administrative control to preclude recurrence.
ADDITIONAL INFORMATION
Other Systems Affected: None
Failed Components Information
None Commitment Information: This report does not create any new permanent licensing
commitments
Previous Similar Events
No similar events have been noted.
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