05000348/LER-2012-001, Seismically Qualified RWST Aligned to Non-Seismic Piping

Seismically Qualified RWST Aligned to Non-Seismic Piping

ML12101A280
Person / Time
Site:	Farley
Issue date:	04/09/2012
From:	Lynch T Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NL-12-0557 LER 12-001-00
Download: ML12101A280 (7)

LER-2012-001, Seismically Qualified RWST Aligned to Non-Seismic Piping

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) 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v)(6) 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(6)
3482012001R00 - NRC Website

text

Thomas A. lynch Southam Nuclear Vice President* Farley Operating Company. Inc.

Farley Nuclear Plant Post Office Drawer 470 Ashford, Alabama 36312 Tel 334.814.4511 Fax 334.814.4728 SOUTHERN 'rd COMPANY April 9, 2012 Docket Nos.: 50-348 NL 0557 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant - Units 1 and 2 Licensee Event Report 2012-001-00 Seismically Qualified RWST Aligned to Non-Seismic Piping Ladies and Gentlemen:

In accordance with the requirements of 10 CFR 50.73 (a)(2)(i)(8), Southern Nuclear Operating Company (SNC) is submitting the enclosed Licensee Event Report. This letter contains no NRC commitments. If you have any questions, please contact Doug McKinney at (205) 992-5982.

Sincerely, 0~

T. A. Lynch Vice President - Farley TALlWDO Enclosure: Units 1 and 2 Licensee Event Report 2012-001-00

U. S. Nuclear Regulatory Commission NL 0557 Page 2 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President &Chief Nuclear Officer Mr. B. L. Ivey, Vice President - Regulatory Affairs Mr. B. J. Adams, Vice President - Fleet Operations Ms. P. M. Marino, Vice President - Engineering Mr. M. J. Ajluni, Director - Nuclear Licensing RTYPE: CFA04.054 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Project Manager - Farley Mr. E. L. Crowe, Senior Resident Inspector - Farley

Joseph M. Farley Nuclear Plant - Units 1 and 2 Licensee Event Report 2012-001-00 Seismically Qualified RWST Aligned to Non-Seismic Piping Enclosure Units 1 and 2 Licensee Event Report 2012-001-00

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMS: NO. 3150-0104 EXPIRES: 1013112013 H>-2010)

, the NRC may nOI conduct or sponsor, and a person is not required 10 respond to, the In/ormation collection.

13. PAGE Joseph M. Farley Nuclear Plant, Unit 1 05000348 1 OF 4

4. TITLE Seismically Qualified RWST Aligned to Non-Seismic Piping

5. EVENT DATE

6. LER NUMBER

7. REPORT DATE

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

MONTH DAY YEAR FACILITY NAME Farley Nuclear Plant, Unit 2 DOCKET NUMBER 05000364 FACILITY NAME DOCKET NUMBER 02 15 2012 2012 - 001 - 00 04 09 2012

9. OPERATING MODE

11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR§: (Check all that apply) o 20.2201 (b) o 20.2203(a)(3)(1) o 50.73(a)(2)(i)(C) o 50. 73(a)(2)(vii) 1 o 20.2201 (d) o 20.2203(a)(3)(11) o 50.73(a)(2)(Ii)(A) o 50.73(a)(2)(viii)(A) o 20.2203(a)(l) o 20.2203(a)(4) o 50.73(a)(2)(11)(6) o 50.73(a)(2)(vlil)(6) o 20.2203(a)(2)(1) o 50.36(c)(1 )(I)(A) o 5O.73(a)(2)(1I1) o 50. 73(a)(2)(lx)(A)

10. POWER LEVEL o 20.2203(a)(2)(11) o 50.36(c)(1 )(Ii)(A) o 50.73(a)(2)(lv)(A) o 50. 73(a)(2)(x) o 20.2203(a)(2)(111) o 50.36(c)(2) o 50.73(a)(2)(v)(A) o 73.71 (a)(4) o 20.2203(a)(2)(lv) o 5O.46(a)(3)(1I) o 50.73(a)(2)(v)(6) o 73.71 (a)(5) 100 o 20.2203(a)(2)(v) o 50. 73(a)(2)(i)(A) o 50.73(a)(2)(v)(C) o OTHER o 20.2203(a)(2)(vl) 181 50.73(a)(2)(i)(8) o 50.73(a)(2)(v)(O)

Specify in Abstract below or in NRC Form 3BBA

12. LICENSEE CONTACT FOR THIS LER FACILITY NAME fELEPHONE NUMBER (Indude Area Code)

J.M. Farley Nuclear Plant, W. D. Oldfield - Principal Licensing Engineer (334) 814-4765 MANU-REPORTABLE MANU-REPOATABLE

CAUSE

SYSTEM COMPONENT

CAUSE

SYSTEM COMPONENT FACTURER TO EPIX FACTUAER TO EPIX

14. SUPPLEMENTAL REPORT EXPECTED

15. EXPECTED MONTH DAY YEAR SUBMISSION o YES (If yes, complete 15. EXPECTED SUBMISSION DATE) 181 NO DATE ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 slngle*spaced typewriNen lines)

On February 15, 2012, with both Units 1 and 2 operating 100 percent power, it was determined that opening the boundary valve between the safety related and seismically qualified Refueling Water Storage Tank (RWST) and the non-safety related and non-seismically qualified Spent Fuel Pool Purification (SFPP) system in Modes 1-4, renders the RWST inoperable. Plant procedures had been revised in 2009 to allow opening this boundary valve in Modes 1-4 under administrative controls. The 10 CFR 50.59 safety evaluation that had been performed to support the procedure change had concluded that the administrative controls would allow the RWST to remain operable.

However, in consideration of the new interpretation provided in NRC Information Notice 2012-01, it was judged that the RWST would be considered to be inoperable regardless of the administrative controls established when the RWST was aligned to non-seismic piping in Modes 1 - 4. Since the boundary valve had been opened in Mode 1 under administrative controls and the one hour completion time of Technical Specification 3.5.4 Condition 8 was not entered, under this recent interpretation, this represented a condition prohibited by Technical Specifications and is reportable pursuant to 10 CFR 50.73(a)(2)(i)(8). This event had no significant safety consequence since a seismic event had not occurred while the SFPP system was in service on the RWST.

NRC FORM 366 (10-2010)

4 Westinghouse -- Pressurized Water Reactor Energy Industry Identification Codes are identified in the text as [XX]

Description of Event

On February 15, 2012, with both Units 1 and 2 operating 100 percent power, during review of the new interpretation provided in NRC Information Notice 2012-01, it was determined that one of the items described in the information notice was applicable to the Farley Nuclear Plant (FNP).

Specifically, the information notice identified a utility that had received a non-cited violation (NCV) for crediting administrative controls to close a boundary valve to isolate the non-seismic piping system from the seismically qualified Refueling Water Storage Tank (RWST) [BP and BO]. During the review, it was recognized that, considering the information provided in NRC Information Notice 2012-01, the RWST would be considered inoperable regardless of the administrative controls established when the RWST was aligned to non-seismic piping in Modes 1 - 4.

At FNP, the RWST is seismically qualified, safety related and within the scope of the plant Technical Specifications (TS). The plant design includes the capability to align the Spent Fuel Pool Purification (SFPP) system [DA] for cleanup of the RWST. The SFPP system is a non-safety, non seismic system that is normally isolated from the RWST by a normally closed, safety related manually operated valve.

A review of system operating procedures identified that FNP allowed the SFPP system boundary valve to be opened under administrative controls while the unit was operating in Modes 1-4 without declaring the RWST inoperable per TS LCO 3.5.4 Condition B. TS LCO 3.5.4 Condition B requires that the RWST be returned to operable status with a completion time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. If the RWST is not returned to operable status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, TS LCO 3.5.4 Condition C requires that the unit be placed in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Mode 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. FNP had a previous practice of aligning the seismically qualified RWST to the non-seismic SFPP system and a skid mounted Boric Acid Recovery System (6ARS) for silica removal prior to refueling outages while in Modes 1 - 4. In addition, the RWST was also aligned to the non-seismic SFPP system piping during routine recirculation of the RWST to support TS required boron concentration verification. The BARS was placed in service for a period of approximately 22 days, on average, prior to each outage over the last five refueling cycles for each unit. The RWST on each unit was aligned to the SFPP system for recirculation on approximately a weekly basis for sampling purposes. Since the RWST was not declared inoperable during these periods, TS LCO actions were not entered. This resulted in operation of the units, which under the interpretation provided by NRC Information Notice 2012-01, is considered to be a condition prohibited by TS and is reportable pursuant to 10 CFR 50.73(a)(2)(i)(6).

NRC FOAM 366A {I 0-201 0)

4

Cause of Event

The direct cause of this event was an incorrect application of compensatory measures (Le., manual operator actions) when placing the non-seismic SFPP system in service on seismically qualified systems/components (RWST) during modes of operation when they are needed to perform their safety function. Prior to the issuance of NRC Information Notice 2012-01, manual operator actions had been evaluated and deemed acceptable in accordance with procedures in place at that time.

However, it has been determined that licensees cannot use compensatory measures when compromising the seismic qualification of a system/component.

Safety Assessment

This event had no significant safety consequence since a seismic event had not occurred while the SFPP system was in service on the RWST. Additionally this event did not involve a safety system functional failure since administrative controls were established and a designated operator was assigned to close the valve within a short period of time. This ensured the minimum required inventory in the RWST would have been available for accident mitigation requirements. This event would be considered low risk based on the following mitigating factors: very low frequency for a seismic initiating event; very low frequency of an accident requiring the use of the RWST safety function; operator action to isolate the non-seismic piping after a seismic initiating event; and a relatively small exposure time. The operator had sufficient response time based on a documented engineering analysis, had multiple cues, and had simple, proceduralized actions. Therefore, the health and safety of the public were not affected by this event.

It should be noted that subsequent to the NRC Information Notice 2012-01, a proposed Technical Specification (TS) was submitted that approved use of the alternate controls which were in place at the time of the event.

Corrective Action

The BARS, in service for Silica removal prior to the upcoming refueling outage, was isolated from the Unit 1 RWST. All RWST alignment to non-seismic piping was suspended for both units.

Procedures on both units were revised to use the seismically qualified Containment Spray system as an alternate means of recirculating the RWST prior to sampling.

Causal analysis was initiated and corrective action to strengthen procedure guidance related to 10 CFR 50.59 implementation was entered into the corrective action program (CAP). An additional condition report was entered into the CAP to resolve this seismic issue on a permanent basis.

NRC FORM 36M (10-2010) U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)

(1()'2010)

1. FACIUTY NAME CONTINUATION SHEET

2. DOCKET

6. LER NUMBER YEAR r SEQUENTIAL 1 REVISION NUMBER NUMBER

~_.__~________-L____~

Joseph M. Farley Nuclear Plant, Unit 1 05000348 2012 001 00 NARRAnVE 4

3. PAGE of 4

Additional Information

Similar Events:

None NRC FORM 36M 00-2010)