05000348/LER-2015-003, Cancellation of LER 15-003-00, Failure to Meet a Technical Specification Completion Time for Reportability
| ML15254A477 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 09/11/2015 |
| From: | Gayheart C Southern Co, Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-15-1685 LER 15-003-00 | |
| Download: ML15254A477 (4) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 3482015003R00 - NRC Website | |
text
Cheryl A. Gayheart Vice President
- Farley Southern Nuclear Operating Company, Inc.
Farley Nuclear Plant Post Office Drawer 470 Ashford, Alabama 36312 Tel334.814.4511 Fax 334.814.4575 September 11, 2015 Docket Nos.: 50-348.
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant-Unit 1 Notice of Cancellation Licensee Event Report 2015-003-00 SOUTHERN<<\\
COMPANY NL-15-1685 Failure to Meet a Technical Specification Completion Time for Reportabilitv Ladies and Gentlemen:
The subject Unit 1 Licensee Event Report (LEA) 2015-003-00, submitted July 16, 2015 under Southern Nuclear Operating Company (SNC) letter NL-15-1288, is being canceled pursuant to the requirements of 10 CFR 50.73(d) and per the guidance of NUREG 1022, Revision 3, Section 5.1.2.
The condition was not reportable under 10 CFR 50.73(a)(2)(i)(B). The basis for the cancellation is provided in the attached Justification of Cancellation for Unit 1 Licensee Event Report 2015-003-00.
It is requested that the Unit 1 LER 2015-003-00 be removed from the LEA data base.
This letter contains no NRC commitments. If you have any questions regarding the submittal, please contact Greg Bell at (334) 814-4765.
Sincerely, Ms. C.
yheart Vice Presi ent - Farley CAG/JAC Enclosure: Justification of Cancellation for Unit 1 Licensee Event Report 2015-003-00
U. S. Nuclear Regulatory Commission NL-15-1685 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. M. D. Meier, Vice President-Regulatory Affairs Mr. D. A. Madison, Vice President-Fleet Operations Mr. B. J. Adams, Vice President - Engineering Mr. C. A. Pierce, Regulatory Affairs Director Ms. B. L. Taylor, Regulatory Affairs Manager-Farley Mr. J. E. Purcell, Operating Experience Coordinator - Farley RTYPE: CFA04.054 U.S. Nuclear Requlatorv Commission Mr. V. M. McCree, Regional Administrator Mr. S. A. Williams, NRR Project Manager-Farley Mr. P. K. Niebaum, Senior Resident Inspector-Farley
Joseph M. Farley Nuclear Plant - Unit 1 Notice of Cancellation Licensee Event Report 2015-003-00 Failure to Meet a Technical Specification Completion Time for Reportability Enclosure Justification of Cancellation for Unit 1 Licensee Event Report 2015-003-00
Enclosure to NL-15-1685 Justification of Cancellation for Unit 1 Licensee Event Report 2015-003-00 The subject Unit 1 Licensee Event Report (LER) 2015-003-00, submitted July 16, 2015 under Southern Nuclear Operating Company {SNC) letter NL-15-1288, reported that the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time for placing the Reactor Coolant System (RCS) B Train Delta T instrumentation in the trip position per Technical Specification (TS) 3.3.1 Limiting Condition for Operation (LCO) Condition E was exceeded. This apparent oversight of not meeting the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time occurred when the entry time for the action statement was not properly tied to the initial collection of scaling data.
However, it has been determined upon further evaluation that SNC had, in fact, met the requirements of the TS and was never in a condition prohibited by TS.
Although the Delta T channel was not placed in the trip position until after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from the initial collection of scaling data, it was placed in the trip position prior to the 78 hour9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br /> shutdown time.
TS 3.3.1 LCO Condition E states:
CONDITION REQUIRED ACTION COMPLETION TIME E. One channel
NOTE------------------
The inoperable channel may be bypassed tor up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> tor surveillance testing of other channels.
E. 1 Place channel in trip.
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> OR E.2 Be in MODE 3.
78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br /> NUREG 1022, Revision 3, Section 3.2.2 on page 19, Limiting Conditions for Operation states, in part:
An LER is required if a condition existed tor a time longer than permitted by TS (i.e., greater than the total allowed restoration and shutdown outage time (or completion time in STS))...
Using this guidance, the allowed restorative time is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; placing the channel in trip is considered restorative since there are no additional actions required once the channel is placed in trip. The shutdown outage time is the additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to be in MODE 3 and the total completion time is 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br />. Therefore, since the channel was placed in the trip condition prior to exceeding the completion time of 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br />, an LER is not required.