05000333/FIN-2011004-01
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Finding | |
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| Title | Unplanned Power Reduction PI Reporting |
| Description | The inspectors identified an unresolved item (URI) associated with FitzPatrick staff\\\'s interpretation of guidance for reporting unplanned power changes per 7,000 critical hours. Specifically, Entergy personnel did not report three power reductions during the second quarter of 2011 that the inspectors considered to have been reportable. The unplanned power changes per 7,000 critical hours performance indicator is defined as the number of unplanned changes in reactor power of greater than 20 percent of full-power, per 7,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of critical operation excluding manual and automatic scrams. On January 11, 2011, FitzPatrick operators performed a power reduction to 55 percent to plug a leaking condenser tube. This power reduction was reported in the first quarter performance indicators as an unplanned power change. The root cause evaluation of this event determined that additional condenser tube leaks could occur. As a result, an operational decision-making issue (ODMI) action plan was developed by Entergy staff, which established four action levels for chemistry parameters (condensate demineralizer influent (COl) conductivity, reactor water conductivity, and reactor water chloride concentration). These action levels provide guidance for operators to perform a range of actions, such as a power reduction to support condenser tube plugging. The action plan was established on April 4, 2011. On May 6, 2011, operators observed indications of a rapid increase in hotwell conductivity and determined that COl conductivity increased to above action level 3. In accordance with the ODMI action plan operators reduced power to 55 percent later that day to identify and plug the leaking main condenser tube. The inspectors reviewed the guidance for reporting performance indicators in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. Concerning unplanned power reductions per 7,000 critical hours, the guidance states, This indicator captures changes in reactor power that are initiated following the discovery of an offnormal condition. If a condition is identified that is slowly degrading and the licensee prepares plans to reduce power when the condition reaches a predefined limit, and 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> have elapsed since the condition was first identified, the power change does not count. If, however, the condition suddenly degrades beyond the predefined limits and requires rapid response, this situation would count. In follow-up questions regarding the May 6 down power Entergy staff indicated that the down power was planned as a contingency action in the ODMI action plan and that, because the initial condition for which the action plan was written occurred greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to the down power, the down power should not be counted. The inspectors considered that notwithstanding an action plan, the condition was best described as a suddenly degrading condition that resulted in operators decreasing power the same day to address the condition. Therefore, it appeared to be appropriate to report the May 6 down power as unplanned. In addition, the inspectors determined that FitzPatrick operators performed two power reductions to 75 percent on June 7, and June 9, 2011, to support cleaning main condenser water boxes. This cleaning was necessary to address fouling that occurred during planned maintenance on the lake intake travelling screens. The fouling was the result of operation of circulating water system gates which caused sediment to be ingested by the circulating water system. The inspectors determined that FitzPatrick staff did not report these two down powers as unplanned in the second quarter PI. The inspectors reviewed the applicable guidance in NEI 99-02 which indicated that Anticipated power changes greater than 20 percent in response to expected environmental problems (such as accumulation of marine debris, biological contaminants, animal intrusion, environmental regulations, or frazil icing) may qualify for an exclusion from the indicator. The licensee is expected to take reasonable steps to prevent intrusion of animals, marine debris, or other biological growth from causing power reductions. Intrusion events that can be anticipated as a part of a maintenance activity or as part of a predictable cyclic behavior would normally be counted, unless the down power was planned 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in advance ... FitzPatrick\\\'s staff indicated they considered this allowance to be applicable, in that they had taken reasonable steps to prevent intrusion by cleaning the lake water forebays prior to the maintenance. Because this activity had not been performed on line since the traveling screens had been replaced, station personnel also considered that they could not reasonably have anticipated the severity of the fouling that occurred. Finally, FitzPatrick staff included a contingency down power in the work week schedule, and noted in the applicable operating procedure that operation of the gates may require a power reduction to perform condenser cleaning. Notwithstanding an acknowledgement by FitzPatrick staff in their procedures and work week schedule as to the possibility of a need for a plant down power, the inspectors considered that these two down power conditions were anticipated as part of a maintenance activity and appeared to have not been planned 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in advance. Therefore the inspectors had questions as to the appropriateness of not reporting the plant down powers on June 7, and June 9,2011. FitzPatrick staff initiated a review of these issues as part of the NRC and industry performance indicator frequently asked questions (FAQ) process. This item remains unresolved pending further information from the FAQ process. (URI 05000333/2011004-01, Unplanned Power Reduction PI Reporting) |
| Site: | FitzPatrick  |
|---|---|
| Report | IR 05000333/2011004 Section 4OA1 |
| Date counted | Sep 30, 2011 (2011Q3) |
| Type: | URI: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71151 |
| Inspectors (proximate) | S Rutenkroger J Noggle J Furia M Gray E Knutson J Brand R Rolph K Cronkm Grayt Burns E Knutson B Sienel |
| INPO aspect | |
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Finding - FitzPatrick - IR 05000333/2011004 | |||||||||||||||||||||||||||||||||||||||||||||
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Finding List (FitzPatrick) @ 2011Q3
Self-Identified List (FitzPatrick)
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