05000348/LER-2014-001, Regarding Failure to Comply with Technical Specification 3.4.3 During Reactor Coolant System Vacuum Refill
| ML14107A333 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 04/15/2014 |
| From: | Gayheart C Southern Co, Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-14-0311 LER 14-001-00 | |
| Download: ML14107A333 (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) 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 |
| 3482014001R00 - NRC Website | |
text
CherylA. Gayheart Southern Nuclear Vice President - Farley Operating Company, Inc.
Farley Nuclear Plant Post Office Drawer 470 Ashford,Alabama 36312 Tel 334.814.4511 Fax 334.814.4575 A
SOUTHERNJeL COMPANY April 15, 2014 Docket Nos.:
50-348 NL-14-0311 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 2014-001-00 Failure to Comply withTechnical Specification 3.4.3 During Reactor Coolant Svstem Vacuum Refill Ladies and Gentlemen:
This Licensee Event Report, "Failureto ComplywithTechnical Specification 3.4.3 during Reactor CoolantSystem Vacuum Refill," is beingsubmittedpursuant to the requirements ofthe Code of Federal Regulations, 10 CFR50.73(a)(2)(i)(B) as an operation or condition prohibited byTechnical Specifications.
This letter contains no NRCcommitments. If you have any questions regarding the submittal, please contact Mr. Bill Arens at (334) 814-4765.
Sincerely, Ms. C. A. Sayheart Vice President - Farley CAG/JAC Enclosure: Units 1 and 2 Licensee Event Report 2014-001-00
U. S. Nuclear Regulatory Commission NL-14-0311 Page 2 cc:
Southern Nuclear Operating Company Mr. S. E. Kuczynskl, Chairman, President &CEO Mr. D. G. Bost, Executive Vice President &Chief Nuclear Officer Mr. B. L. Ivey, Vice President - Regulatory Affairs Mr. C. R. Pierce, Regulatory Affairs Director Mr. D. R. Madison, Vice President - Fleet Operations Mr. J. G. Horn, Regulatory AffairsManager - Farley Mr. J. E. Purcell, Nuclear Technical Specialist - Farley Ms. K.A.Walker, Senior Engineer - Farley RTYPE: CFA04.054 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. S. A. Williams, Licensing Project Manager - Farley Mr. P. K. Niebaum, Senior Resident Inspector - Farley Mr. J. R. Sowa, Resident Inspector - Farley Mr. R. E. Martin, Senior Project Manager-Farley
Joseph M. Fariey Nuclear Plant - Units 1 and 2 NL-14-0311 Failure to Comply with Technical Specification 3.4.3 During Reactor Coolant System Vacuum Refill Enclosure Units 1 and 2 Licensee Event Report 2014-001-00
NRC FORM 366 [02-2014)
U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO.31S0-0104 EXPIRES: 01/31/2017 LICENSEE EVENT REPORT (LER)
(See Page 2 for required number of digits/characters for eacli block)
Estimated Iwrden per response to comply with tiiis 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 Ifcensing process andfed back to industry.
Send comments regarding burden estimate to the FOIA, Privacy and Information Collections Branch (T-5 F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by internet e-mail to lnfocollects.Resource@nrc.gov, andtothe DeskOfficer, Office ofInformation and Regulatory Affairs, NEOB-10202, (3150-0104), Office ofManagement andBudget, Washington. DC 20503. Ifa means usedtoimpose an information cdleclion doesnotdisplay a currently vgdid OMB control number, theNRC may notconduct orsponsor, anda person is notrequired to respond to, the information collection.
- 1. FACILITY NAME Joseph M. Farley Nuclear Plant, Unit 1
- 2. DOCKET NUMBER 05000 348
- 3. PAGE Page 1 of 3
- 4. TITLE Failure to Comply with Technical Specification 3.4.3 during Reactor Coolant System Vacuum Refill
- 6. EVENT DATE MONTH DAY YEAR 02 18 2014
- 9. OPERATING MODE
- 10. POWER LEVEL 100
- 6. LER NUMBER YEAR SEQUENTIAL NUMBER REV NO.
2014 001 00
- 7. REPORT DATE MONTH DAY YEAR 04 17 2014
- 8. OTHER FACILITIES INVOLVED FACIUTY NAME Farley Nuclear Plant - Unit 2 FACILITY NAME DOCKET NUMBER 05000 364 DOCKET NUMBER
- 11. THIS REPORT IS SUBMITTEDPURSUANT TO THE REQUIREMENTSOF 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)(viil)(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(0(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) 13 50.73(a)(2)(i)(B) 50.73(a)(2){v)(D)
Specify in Abstract below or in NRC Fomi 366A
- 12. LICENSEE CONTACT FOR THIS LER LICENSEE CONTACT William N. Arens - Licensing Supervisor TELEPHONE NUMBER (Include Area Code)
(334) 814-4765CAUSE SYSTEM COMPONENT MANU FACTURER REPORTABLE TO EPIX
CAUSE
SYSTEM COMPONENT MANU FACTURER REPORTABLE TO EPIX
- 14. SUPPLEMENTAL REPORT EXPECTED YES (Ifyes, complete 15. EXPECTED SUBMISSION DATE)
^
NO
- 15. EXPECTED SUBMISSION DATE MONTH DAY YEAR ABSTRACT (Limitto 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)
On February 18, 2014 with FNP Units 1 and 2 operating at 100 percent thermal power, a review of industry operating experience determined that both units were in non-compliance with Technical Specification 3.4.3, Reactor Coolant System (RCS) Pressure and Temperature (P/T) Limits, during several previous refueling outages on each unit due to placing the RCS under vacuum conditions during RCS vacuum refill operations. From October 1995 through April2012, 12 refueling outages have been conducted on Unit 1 and 11 on Unit 2 during which the RCS was placed under vacuum to perform vacuum refill operations. Technical Specification 3.4.3, applicable at all times, requires that RCS pressure, RCS temperature, and RCS heatup and cooldown rates be maintained within the limits specified in the Pressure Temperature LimitReport (PTLR). Although RCS temperature and heatup rates were maintained within limits, RCS pressure was lowered below zero pounds per square inch gage (psig), the lowest RCS pressure value identified on the curve.
The cause of not entering the required action for Technical Specification 3.4.3 was due to a failure to recognize that a negative RCS pressure is not allowed by Technical Specifications. An engineering review in support of the implementation of vacuum refill operations had previously determined that stress margins of the reactor pressure vessel and related components were not challenged. The station's P/T Limitcurve is being revised to encompass RCS vacuum conditions.
NRC FORM 366 (02-2014)
Westinghouse - Pressurized Water Reactor Energy Industry Identification Codes are identified in the text as [XX].
Requirement for Report This report is required per 10 CFR50.73(a)(2)(i)(B) for an operation or condition which was prohibited by Technical Specifications Limiting Condition of Operation (LCO) 3.4.3, RCS Pressure and Temperature Limits, during vacuum refill of the reactor coolant system (RCS) when RCS pressure was lowered below zero pounds per square inch gage (psig).
Unit Status at Time of Event At the time of discovery of the issue, both units were operating in Mode 1 at 100% reactor power.
Previous vacuum refilloperations were conducted with the applicable unit in Mode 5. There were no additional inoperable structures, systems, or components at the time of discovery that contributed to this event. This event is considered a discovery of an existing but previously unrecognized condition.
Description of Event
On February 18, 2014 with Farley Nuclear Plant (FNP) Units 1 and 2 operating at 100 percent thermal power, a review of industry operating experience determined that both units were in non-compliance with Technical Specification 3.4.3, RCS Pressure and Temperature (P/T) Limits, during 23 previous refueling outages due to placing the RCS under vacuum conditions during RCS vacuum refill operations. From October 1995 through April 2012,12 refueling outages have been conducted on Unit 1 and 11 on Unit 2 during which the RCS was placed under vacuum to perform vacuum refill operations. Technical Specification 3.4.3, applicable at all times, requires that RCS pressure, RCS temperature, and RCS heatup and cooldown rates be maintained within the limitsspecified in the Pressure Temperature Limit Report (PTLR). Although RCS temperature and heatup rates were maintained within limits, RCS pressure was lowered below 0 psig, the lowest RCS pressure value identified on the curve.
InOctober, 1995 the system operating procedure to perform RCS fill and vent under vacuum conditions was developed in accordance with an approved safety evaluation to facilitate RCS vacuum refill and eliminate the need to perform multiple reactor coolant pump sweeps of the RCS for removal of non-condensable gases. The safety evaluation for this procedure properly evaluated the impact of vacuum conditions on the reactor pressure vessel [RPV], the RCS, and related components. Itwas not recognized that this evolution would be in non-compliance withTechnical Specification 3.4.3. Upon review of industry operating experience, the non-compliance was identified and corrective action initiated to update the PTLR curves to account for operation under vacuum conditions.
These events are of very lowsafety significance and resulted in no adverse effects on the health or safety of the public.
Cause of Event
The direct cause of not entering the required action for Technical Specification 3.4.3 was a failure to recognize that a negative RCS pressure is not allowed by Technical Specifications. Establishing vacuum
conditions in the RCS was not recognized to be a condition that required entry into the required action statement.
Safety Assessment
As determined in the safety evaluation for the vacuum refillimplementing procedure, there were no challenges to any design or safety limit. Nuclear safety was not compromised because the negative (vacuum) internal pressures identified did not cause any concerns with applicable material stresses or analysis for the reactor pressure vessel or RCS piping. There was no impact to the safety of the public, industrial safety, or radiological safety as a result of the vacuum refill operations.
Corrective Action
Corrective Action to revise the FNP Pressure and Temperature Limit Report (PTLR) for Units 1 and 2 to address establishing a negative pressure (vacuum) in the reactor vessel has been initiated and will be completed prior to the next vacuum refill operation. A review of Technical Specifications for similar or related issues with other Technical Specification curves has been initiated.
Additional Information
A review of internal Operating Experience was performed, and no previous events were identified in which a curve referenced by Technical Specifications was inaccurately applied leading to violation of a Technical Specifications.