05000352/LER-2012-006, Regarding Valid Manual Actuation of the Reactor Protection System Due to a Personnel Error and Surveillance Test Weakness

Regarding Valid Manual Actuation of the Reactor Protection System Due to a Personnel Error and Surveillance Test Weakness

ML12261A415
Person / Time
Site:	Limerick
Issue date:	09/17/2012
From:	Dougherty T Exelon Generation Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
LER 12-006-00
Download: ML12261A415 (4)

LER-2012-006, Regarding Valid Manual Actuation of the Reactor Protection System Due to a Personnel Error and Surveillance Test Weakness

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(iv)(A), System Actuation 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)(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)(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 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3522012006R00 - NRC Website

text

10CFR50.73 September 17, 2012 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Unit 1 Facility Operating License No. NPF-39 NRC Docket No. 50-352

Subject:

LER 2012-006-00, Valid Manual Actuation of the Reactor Protection System This Licensee Event Report (LER) addresses a valid manual actuation of the reactor protection system during an outage with all control rods inserted. The actuation was initiated when the mode switch was placed in the "Shutdown" position when it was identified that the required nuclear instrumentation surveillance tests were not in surveillance.

This LER is being submitted pursuant to the requirements of 10CFR50.73(a)(2)(iv)(A).

There are no commitments contained in this letter.

If you have any questions, please contact Robert B. Dickinson at (610) 718-3400.

Respectfully, Original signed by Thomas J. Dougherty Vice President - Limerick Exelon Generation Company, LLC cc: Administrator Region I, USNRC USNRC Senior Resident Inspector, LGS

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION (10-2010)

LICENSEE EVENT REPORT (LER)

(See reverse for required number of digits/characters for each block)

APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2013

, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

1. FACILITY NAME Limerick Generating Station, Unit 1

2. DOCKET NUMBER 05000352

3. PAGE 1 OF 3

4. TITLE Valid Manual Actuation of the Reactor Protection System due to a Personnel Error and Surveillance Test Weakness

5. EVENT DATE

6. LER NUMBER

7. REPORT DATE

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

MONTH DAY YEAR FACILITY NAME DOCKET NUMBER 05000 07 19 2012 2012 - 006 - 00 09 17 2012 FACILITY NAME DOCKET NUMBER 05000

9. OPERATING MODE 4

10. POWER LEVEL 0

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)(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)(viii)(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(c)(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) 50.73(a)(2)(i)(B) 50.73(a)(2)(v)(D)

Specify in Abstract below or in LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET Check and CRD Exercise OPCONs 3,4 With No Core Alterations" surveillance test Attachment 2 was completed. Tests that are verified to be in surveillance are to be circled in Attachment B. The error occurred when two expired tests were circled by the STC.

Cause of the Event

The cause of the event was a personnel error caused by a test weakness. The "Pre-control Rod Withdrawal Check and CRD Exercise OPCONs 3,4 With No Core Alterations" surveillance test does not have verification steps to ensure that the STC input is accurate.

Corrective Action Planned The "Pre-control Rod Withdrawal Check and CRD Exercise OPCONs 3,4 With No Core Alterations" surveillance test Attachment 2 will be revised to add an additional Work Management signoff for a peer check of the STC input. The notes and body of Attachment 2 will be revised to improve human factoring.

Previous Similar Occurrences There were no similar occurrences of valid manual actuation of the reactor protection system due to surveillance test status control errors in the previous three years.