05000410/LER-2013-005, Regarding Secondary Containment Inoperabilities Due to Differential Pressure Not Meeting Technical Specification Surveillance Requirement 3.6.4.1.1

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Regarding Secondary Containment Inoperabilities Due to Differential Pressure Not Meeting Technical Specification Surveillance Requirement 3.6.4.1.1
ML14049A147
Person / Time
Site: Nine Mile Point Constellation icon.png
Issue date: 01/31/2014
From: John Stanley
Constellation Energy Nuclear Group, EDF Group, Nine Mile Point
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LER 13-005-00
Download: ML14049A147 (7)


LER-2013-005, Regarding Secondary Containment Inoperabilities Due to Differential Pressure Not Meeting Technical Specification Surveillance Requirement 3.6.4.1.1
Event date:
Report date:
Reporting criterion: 10 CFR 50.73(a)(2)(v), Loss of Safety Function

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)(i)(B), Prohibited by Technical Specifications
4102013005R00 - NRC Website

text

James J. Stanley Plant General Manager Office: 315.349.5205 Fax: 315.349.1321 E-mail: James.Stanley@cengllc.com CENG.

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NINE MILE POINT NUCLEAR STATION January 31,2014 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION:

SUBJECT:

Document Control Desk Nine Mile Point Nuclear Station Unit 2 Renewed Facility Operating License No. NPF-69 Docket No. 50-410 Licensee Event Report 2013-005, Secondary Containment Inoperabilties Due to Differential Pressure Not Meeting Technical Specification Surveillance Requirement 3.6.4.1.1 In accordance with 10 CFR 50.73(a)(2)(v)(C), please find attached Licensee Event Report 2013-005, Secondary Containment Inoperabilities Due to Differential Pressure Not Meeting Technical Specification Surveillance Requirement 3.6.4.1.1.

There are no regulatory commitments in this submittal.

Should you have questions regarding the information in this submittal, please contact Everett (Chip)

Perkins, Director Licensing, at (315) 349-5219.

Sincerely, JJS/JBH

Attachment:

Licensee Event Report 2013-005, Secondary Containment Inoperabilties Due to Differential Pressure Not Meeting Technical Specification Surveillance Requirement 3.6.4.1.1 cc:

NRC Project Manager NRC Resident Inspector NRC Regional Administrator Nine Mile Point Nuclear Station, LLC P.O. Box 63, Lycoming, NY 13093

I ATTACHMENT LICENSEE EVENT REPORT 2013-005 SECONDARY CONTAINMENT INOPERABILTIES DUE TO DIFFERENTIAL PRESSURE NOT MEETING TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENT 3.6.4.1.1 Nine Mile Point Nuclear Station, LLC January 31, 2014

NRC FM 366 U.S. NUCLEAR REGULATORY COMMISSION 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.

13. PAGE Nine Mile Point Unit 2 05000410l 1 OF 5
4. TITLE Secondary Containment Inoperabilities Due to Differential Pressure Not Meeting Technical Specification Surveillance Requirement 3.6.4.1.1
5. EVENT DATE
6. LER NUMBER
7. REPORT DATE
8. OTHER FACILITIES INVOLVED FACILITY NA*RE DOCKET NUMBER MONTH DAY YEAR YEAR SEQUENTIAL REV MONTH DAY YEAR NA NA NUMBER NO.NAA

____I____

_FACILITY NAME DOCKET NUMBER 12 11 2013 2013 005 00 1

31 2014 1NA NA

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)

[I 50.73(a)(2)(vii)

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)

[I 50.73(a)(2)(ii)(B)

El 50.73(a)(2)(viii)(B)

10. POWER LEVEL El 20.2203(a)(2)(i)

[I 50.36(c)(1)(i)(A)

El 50.73(a)(2)(iii)

El 50.73(a)(2)(ix)(A)

El 20.2203(a)(2)(ii)

[I 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)

[I 50.36(c)(2)

El 50.73(a)(2)(v)(A)

El 73.71(a)(4) 100 El 20.2203(a)(2)(iv)

El 50.46(a)(3)(ii)

El 50.73(a)(2)(v)(B)

El 73.71 (a)(5)

El 20.2203(a)(2)(v)

El 50.73(a)(2)(i)(A) 0 50.73(a)(2)(v)(C)

El OTHER El 20.2203(a)(2)(vi)

[E 50.73(a)(2)(i)(B)

El 50.73(a)(2)(v)(D)

Specify in Abstract below or in

E. OTHER SYSTEMS OR SECONDARY FUNCTIONS AFFECTED

No other systems or secondary functions were affected.

F. METHOD OF DISCOVERY

On December 11, 2013 during review of industry Operating Experience (OE) it was identified that NMP2 has not been reporting occurrences of Secondary Containment inoperability when the Secondary Containment differential pressure (dP) drops below the required Technical Specification (TS) minimum of negative 0.25 inches water gauge.

G. MAJOR OPERATOR ACTION:

No operator actions were required as a result of the identification of this condition.

H. SAFETY SYSTEM RESPONSES:

No operational conditions requiring the response of safety systems occurred as a result of this condition.

II. CAUSE OF EVENT

The apparent cause of these occurrences is that training has not been effective in providing operations personnel the level of understanding required in order to consistently recognize when the failure of safety systems are reportable under 10 CFR 50.72(b)(3)(v)(C) and 50.73(a)(2)(v)(C).

This event has been entered into the Nine Mile Point Nuclear Station corrective action program as condition report number CR-2013-010111.

III. ANALYSIS OF THE EVENT

This event is reportable in accordance with 10 CFR 50.73(a)(2)(v)(C) as any event or condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to control the release of radioactive material.

There were no actual nuclear safety consequences associated with this event. The times when Secondary Containment was declared inoperable in the past three years, when required to be operable, were due to Secondary Containment differential pressure dropping below the required TS minimum value of negative 0.25 inches water gauge.

NRC FORM 366 (10-2010)

The direct causes of the Secondary Containment dP dropping below the required TS minimum value have been attributed predominantly due to changes in outdoor environmental conditions (changing wind direction and velocity) and secondarily due to changing of lineups or equipment failures associated with the normal non-safety related Reactor Building Ventilation System. In each case the required TS Limiting Condition for Operation (LCO) action was entered and subsequently exited once the Secondary Containment dP was restored to above the required TS minimum value. In all cases the TS required completion time was not exceeded.

In all cases, the Secondary Containment structural integrity, the ability to automatically isolate the non-safety related Reactor Building Ventilation System, and the Standby Gas Treatment System operability were not impacted. As a result, the ability of the Secondary Containment to perform its safety function was not impacted.

Based on the above discussion, it is concluded that the safety significance of this event is low and the event did not pose a threat to the health and safety of the public or plant personnel.

This event does not affect the NRC Regulatory Oversight Process (ROP) Indicators.

IV. CORRECTIVE ACTIONS

A. ACTION TAKEN TO RETURN AFFECTED SYSTEMS TO PRE-EVENT NORMAL STATUS:

In each of the occurrences within the past three years the Secondary Containment was declared operable following the restoration of the Secondary Containment differential pressure to at least the required TS minimum value.

B. ACTION TAKEN OR PLANNED TO PREVENT RECURRENCE:

1.

Senior Reactor Operators have been provided a briefing on the guidance in NUREG-1022 (Revision 3) associated with 10 CFR 50.72(b)(3)(v)(C) and 50.73(a)(2)(v)(C) reporting requirements relative to Secondary Containment inoperability.

2.

Detailed training on 10 CFR 50.72(b)(3)(v)(C) and 50.73(a)(2)(v)(C) reporting requirements will be conducted for Senior Reactor Operators and Licensed Operator Training Instructors.

NRC FORM 366 (10-2010)

NRC FORM 36A U.S. NUCLEAR REGULATORY COMMISSION

10-201%9.i LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET

1. FACILITY NAME
2. DOCKET
6. LER NUMBER
3. PAGE 00 1 1SEQUENTIAL REVISION YEAR NUMBER NUMBER Nine Mile Point Unit 2 05000410 5

OF 5

2013 005 00 NARRATIVE

V. ADDITIONAL INFORMATION

A. FAILED COMPONENTS:

There were no other failed components that contributed to this event.

B. PREVIOUS LERs ON SIMILAR EVENTS:

Nine Mile Point (NMP) has had previous LERs associated with not initially identifying reportable conditions under 10 CFR 50.72(b)(3)(v) and 10 CFR 50.73(a)(2)(v). Specifically at Nine Mile Point I (NMPI) LER 2012-003 was issued when Shutdown Cooling Primary Containment Isolation Valves were de-energized in an open position effectively defeating the isolation safety function. At NMP2, LER 2011-004 was issued when during trouble-shooting, Reactor Water Cleanup System delta-flow Isolation Instrumentation was defeated.

C. THE ENERGY INDUSTRY IDENTIFICATION SYSTEM (EIIS) COMPONENT FUNCTION IDENTIFIER AND SYSTEM NAME OF EACH COMPONENT OR SYSTEM REFERRED TO IN THIS LER:

IEEE 803 FUNCTION IDENTIFIER IEEE 805 SYSTEM IDENTIFICATION COMPONENT Reactor Building (BWR)

Reactor Building Ventilation System D. SPECIAL COMMENTS:

None BLDG PDIC NG VA NRC FORM 366 (10-2010)