05000354/LER-2010-001, Technical Specification Surveillance Requirement Not Met
| ML102240178 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 08/05/2010 |
| From: | Wagner L Public Service Enterprise Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LR-N10-0296 LER 10-001-00 | |
| Download: ML102240178 (7) | |
| 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)(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)(v), Loss of Safety Function |
| 3542010001R00 - NRC Website | |
text
- P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 0 PSEG Nuclear LLC AUG 0:5 2010 LR-N10-0296 10CFR50.73 United StatesNuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-001 Hope Creek Generating Station Unit 1 Facility Operating License No. NPF-57 Docket No. 50-354
Subject:
Licensee Event Report 2010-001 In accordance with 50.73(a)(2)(i)(B), PSEG Nuclear LLC is submitting Licensee Event Report (LER) Number 2010-001.
Should you have any questions concerning this letter, please contact Mr. Timothy R. Devik at (856) 339-3108.
No regulatory commitments are contained in the LER.
Sincerely, Lawrence M. Wagner Plant Manager Hope Creek Generating Station Attachmer6t: Licensee Event Report 2010-001 95-2168 REV. 7/99
Page 2 LR-N10-0296 Document Control Desk cc:
Mr. M. Dapas, Acting Administrator - Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. R. Ennis, Project Manager Salem and Hope Creek U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 B1A 11555 Rockville Pike Rockville, MD 20852 USNRC Senior Resident Inspector - Hope Creek (X24)
P. Mulligan, Manager IV Bureau of Nuclear Engineering PO Box 415 Trenton, NJ 08625 Hope Creek Commitment Tracking Coordinator
Page 3 LR-N10-0296 Document Control Desk (The be list di~ould no K:,iimtdas part of theb DCDsubmittal-rem-ove this page prior to SuII111tta
ýand make the bcl-c dl, tbitioin accordingly)
President and Chief Nuclear Officer Site Vice President - Salem Site Vice President - Hope Creek Vice President, Operations Support Director - Nuclear Oversight Director - Regulatory Affairs Plant Manager - Salem Plant Manager - Hope Creek Regulatory Assurance Manager - Salem Regulatory Assurance Manager - Hope Creek Licensing Manager Commitment Coordinator - Salem Document Control
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 8/31/2010 (9-2007)
, the NRC may not conduct or sponsor, and a person is not required to respond to, the digits/characters for each block) information collection.
- 3. PAGE Hope Creek Generating Station
- 05000354, 1 OF4
- 4. TITLE Technical Specification Surveillance Requirement Not Met
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR SEQUENTIAL REV MONTH DAY YE FACILITY NAME DOCKET NUMBER YER NUMBER NO.
MOT A
ER N/A FACILITY NAME DOCKET NUMBER 06 08 2010 2010 - 001 - 000 08 05 2010 N/A
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR§: (Check all that apply)
El 20.2201(b)
El 20.2203(a)(3)(i)
El 50.73(a)(2)(i)(C)
El 50.73(a)(2)(vii) 1 El 20.2201(d)
El 20.2203(a)(3)(ii)
El 50.73(a)(2)(ii)(A)
El 50.73(a)(2)(viii)(A)
El 20.2203(a)(1)
[I 20.2203(a)(4)
El 50.73(a)(2)(ii)(B)
[I 50.73(a)(2)(viii)(B)
El 20.2203(a)(2)(i)
El 50.36(c)(1)(i)(A)
[I 50.73(a)(2)(iii)
[I 50.73(a)(2)(ix)(A)
- 10. POWER LEVEL El 20.2203(a)(2)(ii)
[j 50.36(c)(1)(ii)(A)
El 50.73(a)(2)(iv)(A)
El 50.73(a)(2)(x)
El 20.2203(a)(2)(iii)
El 50.36(c)(2)
El 50.73(a)(2)(v)(A)
El 73.71(a)(4)
[E 20.2203(a)(2)(iv)
El 50.46(a)(3)(ii)
[E 50.73(a)(2)(v)(B)
El 73.71(a)(5) 100 El 20.2203(a)(2)(v)
E] 50.73(a)(2)(i)(A)
El 50.73(a)(2)(v)(C)
E] OTHER [E 20.2203(a)(2)(vi)
Z 50.73(a)(2)(i)(B)
El 50.73(a)(2)(v)(D)
Specify in Abstract below or in
SAFETY CONSEQUENCES AND IMPLICATIONS
When the SR satisfaction was questioned for the 2457A/B valves, the valves were conservatively declared INOPERABLE and were closed, securing the HX bypass flow. Engineering and Operations personnel reviewed plant data, design basis documents, surveillance tests, inservice test procedures and other data to determine if the 2457A/B should be tested in accordance with TS SR 4.7.1.1.b and whether or not the existing testing performed on the 2457A/B and associated circuitry was adequate to meet SR 4.7.1.1.b.
During the mid to late 1990s, Hope Creek Generating Station (HCGS) conducted a Technical Specification Surveillance Improvement Program (TSSIP) as a corrective action to LER 95-017 that reviewed TS SRs against existing procedures and processes to ensure compliance with the TS SRs. LERs were generated (95-035,95-034, 95-033 and supplements) to document areas where the SRs were not being met.
Although LER 95-033-02 documented the SACS HX inlet valves as not being adequately tested for SR 4.7.1.1.b, no documentation could be located regarding the 2457A/B valves.
HCGS UFSAR section 9.2.2.2, SACS System Description, states "...the SACS loop coolant supply temperature is continuously monitored and controlled to the designed temperature range...In the event of excessive temperature rise, the heat exchanger bypass valves are automatically closed to provide maximum cooling...". Engineering calculations for the SACS during design basis accidents assumes the HX bypass line is isolated to maintain SACS temperature less than 100 degrees F.
During the review of plant data from 07/01/2007 to 07/31/2010, it was noted that the 2457A/B have automatically closed multiple times every year in response to a rising SACS temperature. The valves closed prior to SACS temperature reaching 90 deg F. The automatic closure was thus demonstrated by actual plant system response and provides a reasonable assurance of operability for these valves.
Because the plant historical data indicates the valves closed automatically when the SACS temperatures rose at least once per year from 2007 to the present, there is reasonable assurance that the HX bypass line would have been isolated upon an accident condition prior to the SACS temperatures exceeding the design bases temperature (100 deg F). Thus, the SACS systems remained operable.
A review of this event determined that a Safety System Functional Failure (SSFF) did not occur as defined in Nuclear Energy Institute (NEI) 99-02.
CAUSE OF OCCURRENCE The cause of this event was inadequate documentation and analysis of the surveillance procedures used to satisfy TS SR 4.7.1.1.b. The documentation and analysis occurred in the 1995 to 1997 timeframe during the TSSIP program that was instituted as a response to LER 95-017.
PREVIOUS OCCURRENCES
A review of Licensee Event Reports for the past three years at Hope Creek was performed to determine if a similar event had occurred. No similar events were noted.
CORRECTIVE ACTIONS
(1) Surveillance test procedures will be written to adequately test the EG-HV-2457A/B valves to the standard of TS SR 4.7.1.1.b.
(2) The surveillance will be performed for the EG-HV-2457A/B valves prior to returning the valves to service.
(3) An extent of condition review is being performed to validate the SACS automatic valves that service safety related equipment are included and tested to TS SR 4.7.1.1.b requirements. If additional valves are discovered as requiring to be in the SR population, a supplement to this LER will be submitted.
(4) The TSs will be reviewed to determine if there are similar SR statements in other systems that require "all automatic valves that service safety related equipment" to be tested.
COMMITMENTS
This LER contains no commitments.PRINTED ON RECYCLED PAPERPRINTED ON RECYCLED PAPER