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LER-2016-002, Regarding Both Residual Heat Removal Low Pressure Coolant Injection Divisions Inoperable Due to Inoperable Injection Valve
Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(v), Loss of Safety Function; 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)(i)(B), Prohibited by Technical Specifications; 10 CFR 50.73(a)(2)(i)
	3412016002R00 - NRC Website
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Regarding Both Residual Heat Removal Low Pressure Coolant Injection Divisions Inoperable Due to Inoperable Injection Valve
	ML16082A458
Person / Time
Site:	Fermi
Issue date:	03/22/2016
From:	Polson K; DTE Electric Company, DTE Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NRC-16-0016 LER 16-002-00
	Download: ML16082A458 (6)
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Keith J. Poison Site vice President D)TE Energy Company 6400 N, Dixie Highway, Newport, MI 48166 Te:a 734.586.4849 Fax: 734.586.4 172 Email, polsonk dteenrgy.com 10 CFR 50.73 March 22, 2016 NRC-16-0016 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Reference:

Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43 Subject: Licensee Event Report (LER) No. 2016-002 Pursuant to 10CFR50.73(a)(2)(v)(D) and 10CFR50.73(a)(2)(vii), DTE Electric Company (DTE) is submitting LER No. 2016-002, Both Residual Heat Removal Low Pressure Coolant Injection Divisions Inoperable Due to Inoperable Injection Valve.

Should you have any questions or require additional information, please contact Mr. Alan L Hassoun, Manager Nuclear Licensing of my staff at (734) 586-4287.

Sincerely, Keith J. Polson Site Vice President Enclosure: LER 2016-002, Both Residual Heat Removal Low Pressure Coolant Injection Divisions Inoperable Due to Inoperable Injection Valve cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Michigan Public Service Commission Regulated Energy Division (kindschl@michigan.gov)

Enclosure to NRC-16-0016 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 LER 2016-002, Both Residual Heat Removal Low Pressure Coolant Injection Divisions Inoperable Due to Inoperable Injection Valve

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 1013112018 (11-2015)

, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection, 3 PAGE Fermi 2 05000 341 1 OF 4

4. TITLE Both Residual Heat Removal Low Pressure Coolant Injection Divisions Inoperable Due to Inoperable Injection Valve

5. EVENT DATE

6. LER NUMBER

7. REPORT DATE

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

05000 01 22 2016 2016 -

002 00 03 22 2016 FAC0LTYNAME 500C E

9. OPERATING MODE

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)(ii)(A) 50.73(a)(2)(viii)(A) 20.2201(d) i 20.2203(a)(3)(ii) 50.73(a)(2)(ii)(B) 50.73(a)(2)(viii)(B)

E] 20.2203(a)(1) 20.2203(a)(4)

L 50.73(a)(2)(iii)

[

50.73(a)(2)(ix)(A) 20.2203(a)(2)(i) 50.36(c)(1)(i)(A) 50.73(a)(2)(iv)(A)

Fl 50.73(a)(2)(x)

10. POWER LEVEL j 20.2203(a)(2)(ii) 50.36(c)(1)(ii)(A)

Q 50.73(a)(2)(v)(A) 73 71(a)(4) 20.2203(a)(2)(iii)

Q 50.36(c)(2)

Q 50.73(a)(2)(v)(B)

E 73.71(a)(5) 20.2203(a)(2)(iv) 50.46(a)(3)(ii) 50.73(a)(2)(v)(C) 73.77(a)(1) 100 E] 20.2203(a)(2)(v) 50.73(a)(2)(i)(A)

/

50.73(a)(2)(v)(D) 73.77(a)(2)(i)

LI 20.2203(a)(2)(vi) 50.73(a)(2)(i)(B)

/

50.73(a)(2)(vii) 73.77(a)(2)(ii)

Q 50.73(a)(2)(i)(C)

[j OTHER Specify in Abstract below or in NRC Form 366A

12. LICENSEE CONTACT FOR THIS LER LICENSEE CONTACT TELEPHONE NUMBER (Include Area Code)

Alan 1. Hassoun, Manager Nuclear Licensing (734) 586-4287CAUSE SYSTEM COMPONENT MANU-REPORTABLE

CAUSE

SYSTEM COMPONENT MANU-REPORTABLE FACTURER TO EPIX FACTURER TOEI

14. SUPPLEMENTAL REPORT EXPECTED

15. EXPECTED MONTH DAY YEAR YES (If yes, complete 15. EXPECTED SUBMISSION DATE)

/

NO SUBMTION ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)

On January 22, 2016, at 1923 EST, both divisions of the Residual Heat Removal (RHR) system were declared inoperable for the Low Pressure Coolant Injection (LPCI) mode of operation due to a failure of the division 1 LPCI outboard injection motor operated valve (MOV), El 150F017A. While performing the division 1 RHR pump and valve operability surveillance test, El 150F017A closed properly but failed to open during its required stroke time test. With this valve closed and unable to automatically open, LPCI injection into the Reactor Pressure Vessel (RPV) from both divisions of RHR would be prevented if the LPCI loop select logic selected the division 1 recirculation loop for injection; therefore, this failure rendered both divisions of RHR inoperable for the LPCI function.

Technical Specification limiting condition for operation (LCO) 3.5.1, Condition K, was entered, which requires immediate entry into LCO 3.0.3. The cause of the failure was subsequently identified as a foreign material (screw) that affected the function of the MOV contactor. The root cause was determined to be less than adequate inspection procedures and susceptibility of the contactor to foreign material. Inspection of all other susceptible equipment is ongoing to tighten loose screws and a modification is planned to install Foreign Material Exclusion (FME) barriers.

NRC FORM 366 (11-20151

Page 2 of 4U.S. NUCLEAR REGULATORY COMMISSION (11-201 5)

LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET

3. LER NUMBER YEAR SEQUENTIAL REV 05000-NUMBER NO.

Fermi 2 341 2016 002 7

Initial Plant Conditions

Mode 1 Reactor Power 100 percent There were no inoperable Structures, Systems, or Components at the start of the event that contributed to the event.

Description of the Event On January 22, 2016, at 1923 EST, both divisions of Residual Heat Removal (RHR) [BO] were declared inoperable for the Low Pressure Coolant Injection (LPCI) mode of operation due to a failure of the division 1 LPCI outboard injection motor operated valve [ISV], El 150F017A. While performing the division 1 RHR pump and valve operability surveillance test, El 150F017A closed properly but failed to open during its required stroke time test.

The Fermi 2 accident analysis takes credit for the proper operation of the LPCI loop select logic during a loss of coolant accident (LOCA). The loss of coolant event involves the postulation of a spectrum of piping breaks inside the primary containment, varying in size, type, and location. The most severe nuclear system effects and the greatest release of material to the primary containment result from a complete circumferential break of one of the two reactor recirculation loop [AD] pipe lines. This is the design basis accident (DBA). Since the LPCI system injects water into the reactor vessel [RPV] through the discharge piping of one of the recirculation loops, a loop selection logic is provided to ensure that the water is injected into an unbroken loop. The loop selection logic compares pressure on the two recirculation loops. A broken loop will indicate a lower pressure than an unbroken loop. The loop selection logic directs the LPCI injection into the high pressure (unbroken) loop. The loop selection is effected through the operation of the RHR injection valves.

Valve El 150FOI 7A is a normally open RHR injection valve in series with the inboard E 1150F015A valve.

These valves control the RHR LPCI flow into reactor recirculation loop A. Because the valve failed in the closed position, flow would be inhibited into the A recirculation loop for scenarios where a break is detected in loop B.

Therefore, both divisions of RHR were declared inoperable for the LPCI function at 1923 EST on January 22, 2016. Technical Specification 3.5.1, Condition K was invoked and limiting condition for operation (LCO) 3.0.3 was immediately entered.

Trouble shooting determined that the control power [JS] closing contactor did not have full freedom of movement because of foreign material. The contactor was removed from the Motor Control Center (MCC) and was manually cycled on a workbench. While manually cycling the contactor, a screw fell out of the contactor.

The screw apparently fell into the contactor from a Control Relay (CR) located above the contactor in the MCC.

At approximately 2143 EST, the E1150F017A valve was re-tested satisfactorily. The valve properly closed and opened, meeting required Inservice Inspection (ISI) stroke time acceptance criteria. At 2145 EST, both divisions of RHR were declared operable for the LPCI and LCO 3.5.1, Condition K and LCO 3.0.3 were exited.

Page 3 of 4U.S. NUCLEAR REGULATORY COMMISSION (11-2015)

LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET

3. LER NUMBER YEAR SEQUENTIAL REV 05000-NUMBER NO.

Ferm12 341 2016 002 L3 Oi-i An 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months event notification 51676 was made pursuant to 10CFR50.72(b)(3)(v)(D) on January 23, 2016, 0020 EST, to the NRC Operations Center. Reactor Power was maintained at 100 percent throughout the event.

This report is being made pursuant to 1 0CFR50.73(a)(2)(v)(D) as a condition that could have prevented the fulfillment of a system safety function needed to mitigate the consequences of an accident. In addition, this report is being made pursuant to 10CFR50.73(a)(2)(vii) as an event where a single cause or condition caused at least one independent train or channel to become inoperable in multiple systems or two independent trains or channels to become inoperable in a single system designed to mitigate the consequences of an accident.

Significant Safety Consequences and Implications

The safety function of the LPCI mode of the RHR system is to inject water from the suppression pool into the reactor vessel via injection lines connected to the reactor recirculation piping following a large break LOCA.

Since a large break LOCA could occur in either one of the two reactor recirculation loops, the LPCI loop select logic function is designed to select the undamaged reactor recirculation loop for LPCI injection. Under the conditions of this event, with the Loop A outboard injection valve closed and unable to open, had a LOCA occurred in recirculation loop B or elsewhere in the reactor connected piping systems in containment, the automatic LPCI injection to the reactor vessel would have been prevented.

Inoperability of the El 150FOI7A valve, for approximately one hour and 50 minutes, rendered both divisions of LPCI inoperable. However, during that period of time the core spray and standby feedwater systems were available to address large break LOCA events. The high pressure coolant injection, reactor core isolation cooling, and standby feedwater systems were also available to address any small break LOCA scenarios that could have occurred at that time. The event was of low safety significance considering the short duration; therefore, the health and safety of the general public were not adversely impacted.

Cause of the Event

A Root Cause Evaluation determined that the technical requirements to check all fasteners for looseness were not adequately implemented into Maintenance work instructions (procedures) for MCC inspections during Preventative Maintenance. Additionally, the General Electric (GE) CR305 contactor orientation inside the MCC created a susceptibility to foreign material. When the contactor is mounted horizontally, an opening is created where foreign material can fall into the contactor.

The contributing cause was that previous Corrective Action Program documents/products did not adequately identify the cause of similar previous events and did not effectively implement corrective actions to minimize recurrence.

Page 4 of 4U.S. NUCLEAR REGULATORY COMMISSION (11-2015)

LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET

3. LER NUMBER YEAR SEQUENTIAL REV 05000-NUMBER NO.

Fermi 2 341

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r1iL 02~~~i 2

31.2016 002 00

Corrective Actions

The foreign material was removed and the MCC bucket was restored and tested satisfactorily. The MCC was independently inspected for additional foreign material and all other screws on the relay were tightened. Four procedures will be revised to include instructions to check accessible spare terminal screws for tightness. The revisions will be complete by May 31, 2016.

Additional corrective actions include personnel training and the inspection of Engineered Safety Feature (ESF)

MCC positions with CR120B relays for loose or missing screws and for susceptible contactor orientation. All screws will be tightened during the inspections and a Design Change will be implemented to modify the susceptible MCC contactors with a permanent FME barrier. Initial visual inspections are complete. All corrective actions will be completed by the next refueling outage (RF1 8), scheduled for spring 2017.

Additional Information

A. Failed Component Data:

None.

B. Previous Similar Events

LER 2005-004, "Both Residual Heat Removal Low Pressure Coolant Injection Divisions Inoperable Due to Valve Failure," was submitted when the El 150F01 7B, the Division 2 LPCI outboard injection valve, failed to open. The cause of the failure was high resistance on the open contactor auxiliary interlock contact. Therefore, the corrective actions for LER 2005-004 would not have prevented the current event.

Actions taken in response to Condition Assessment Resolution Document 06-22311, which identified a foreign material that impacted the operation of a similar contactor were not effective to prevent the occurrence of this event.