05000416/LER-2012-001, Regarding Surveillance Test Procedure Inadequate to Meet the Requirements of Technical Specifications

Regarding Surveillance Test Procedure Inadequate to Meet the Requirements of Technical Specifications

ML12074A084
Person / Time
Site:	Grand Gulf  (NPF-029)
Issue date:	03/13/2012
From:	Richey M Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GNRO-2012/00013 LER 12-001-00
Download: ML12074A084 (7)

LER-2012-001, Regarding Surveillance Test Procedure Inadequate to Meet the Requirements of Technical Specifications

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)(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
4162012001R00 - NRC Website

text

~Entergy GNRO-2012/00013 March 13,2012 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, DC ?0555-0001 Entergy Operations, Inc.

P. O. Box 756 Port Gibson, MS 39150 Marty L. Richey Director, Nuclear Safety Assurance Grand Gulf Nuclear Station Tel. (601) 437-6787

SUBJECT:

LER 2012-001-00 Surveillance Test Procedure Inadequate to meet the requirements of Technical Specifications.

Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

Dear Sir or Madam:

Attached is Licensee Event Report (LER) 2012-001-00 which is a final report. This report is submitted in accordance with 10 CFR 50.73(a)(2)(i)(B)

This letter does not contain any commitments. Should you have any questions regarding the attached report, please call Christina L. Perino at 601-437-6299.

Respectfully, MLRlJAS Attachments:

cc: (see next page) 1.

Licensee Event Report (LER) 2012-001-00

GNRO-2012/00013 Page 2 of2 cc:

Mr. Elmo Collins Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington, TX 76011-4511 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 U. S. Nuclear Regulatory Commission ATTN: Mr. A. B. Wang, NRRlDORL (w/2)

Mail Stop OWFN 8 B1 Washington, DC 20555-0001

Attachment To GNRO-2012/00013 Licensee Event Report (LER) 2012-001-00

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2013 (10-2010) digits/characters for each block) the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

13. PAGE Grand Gulf Nuclear Station, Unit 1 05000416 10F4

4. TITLE Surveillance Test Procedure Inadequate to meet the requirements of Technical Specifications.

5. EVENT DATE

6. LER NUMBER

7. REPORT DATE

8. OTHER FACILITIES INVOLVED YEAR I SEQUENTIAL I REV FACILITY NAME DOCKET NUMBER MONTH DAY YEAR NUMBER NO.

MONTH DAY YEAR N/A N/A FACILITY NAME DOCKET NUMBER 11 19 2009 2012 - 001 - 00 03 14 2012 N/A N/A

9. OPERATING MODE

11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply) o 20.2201(b) o 20.2203(a)(3)(i) o 50.73(a)(2)(i)(C) o 5O.73(a)(2)(vii) 1 o 20.2201 (d) o 20.2203(a)(3)(ii) o 5O.73(a)(2)(ii)(A) o 5O.73(a)(2)(viii)(A) o 20.2203(a)(1) o 20.2203(a)(4) o 50.73(a)(2)(ii)(B) o 50.73(a)(2)(viii)(B) o 20.2203(a)(2)(i) o 50.36(c)(1)(i)(A) o 50.73(a)(2)(iii) o 50.73(a)(2)(ix)(A)

10. POWER LEVEL o 20.2203(a)(2)(ii) o 50.36(c)(1)(ii)(A) o 50.73(a)(2)(iv)(A) o 50.73(a)(2)(x) o 20.2203(a)(2)(iii) o 50.36(c)(2) o 50.73(a)(2)(v)(A) o 73.71 (a)(4) 100 percent o 20.2203(a)(2)(iv) o 50.46(a)(3)(ii) o 50.73(a)(2)(v)(B) o 73.71(a)(5) o 20.2203(a)(2)(v) o 50.73(a)(2)(i)(A) o 5O.73(a)(2)(v)(C) o OTHER o 20.2203(a)(2)(vi)

~ 5O.73(a)(2)(i)(B) o 50.73(a)(2)(v)(D)

Specify in Abstract below or in 2. DOCKET 05000416

6. LER NUMBER YEAR ISEQUENTIAL I NUMBER 2012 - 001 -

00 REV.

NO.

3. PAGE 30F4 the NRC first raised the RCIC venting concern, GGNS provided a bases (calculation) for the venting but failed to determine whether the surveillance acceptance criteria was adequate. In 2009, GGNS determined that the surveillance was satisfactorily performed, however, as an enhancement to the procedure, Surveillances 06-0P-1 E51-M-0001 (RCIC System Operability Verification) and 06-0P-1 E51-Q-0003 (RCIC System Quarterly Pump Operability Verification) were revised to incorporate ultrasonic testing (UT) to ensure the piping was full of water.

In 2009, GGNS did not identify this procedure as an inadequate surveillance test and considered the TS SR met and that the RCIC system had successfully completed the required surveillance testing. As GGNS did not consider this an inadequate surveillance, GGNS failed to utilize TS SR 3.0.3 to address the inadequate TS surveillance as a missed surveillance. TS SR 3.0.3 states that if the surveillance was not performed within an allowed delay period, the limiting condition for operation (LCO) must immediately be declared not met. The LCO was not declared not met for this condition. LCO 3.5.3 requires the RCIC system to be operable in mode 1 and in modes 2 and 3 with reactor steam dome pressure greater than 150 psig. The TS Actions for an inoperable RCIC system require verification within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> that HPCS is operable and restoration of RCIC to operable status within 14 days. If those Actions are not met, then the plant must be placed in mode 3 with reactor pressure less than 150 psig. There were limited occasions where the HPCS system was inoperable for maintenance resulting in other TS required actions to be entered for those situations.

GGNS performed UT testing February 5, 2010 which verified the piping was full of water and restored full compliance with TS SR 3.5.3.1.

E.

Cause of Occurrence The cause of the occurrence was an inadequate surveillance procedure acceptance criterion which resulted in the reqUirements of SR 3.5.3.1 not being met.

The contributing factor was the lack of technical rigor in evaluation of a potential inadequate surveillance procedure.

F.

Corrective Actions

1.

When identified in the 2009 PI&R Inspection, Surveillance 06-0P-1 E51-M-0001 (RCIC System Operability Verification), and 06-0P-1E51-Q-0003 (RCIC System Quarterly Pump Operability Verification) were revised to incorporate UT to verify the piping was full of water.

2.

UT testing of the affected piping was performed to verify piping was full of water.

The corrective actions were developed as required by the GGNS Corrective Action Program under Condition Report (CR) GGN-2009-6249 on November 24,2009 and were implemented on February 5, 2010 for the UT testing and March 17,2010 for the procedure changes.

G.

Safety Assessment

2. DOCKET 05000416

6. LER NUMBER YEAR ISEQUENTIAL I NUMBER 2012 - 001 -

00 REV.

NO.

3. PAGE 40F4 RCIC is credited in the Control Rod Drop Accident (CRDA) and is an ESF system for this event only. The rod pattern controller (EIIS:AA) and reactor protection system (RPS) (EIIS:JC) average power range monitoring (APRM)(EIIS:IG) flux scram are the mitigating functions credited in the CRDA (short-term).

Core cooling is required for long-term mitigation of this accident (decay heat removal). The available core cooling systems are RCIC and HPCS. RCIC is also the only system available for providing cooling water to the core in the event of a station black out (S80) and is used to demonstrate GGNS compliance to 10 CFR 50.63 requirements.

At no time during this issue resolution was RCIC unable to perform its safety function. The RCIC system has successfully completed the required surveillance runs. The RCIC surveillance running from condensate storage tank (CST) to CST would have been ideal conditions for the formation of an isolated bubble at the injection valve to cause pressure oscillations due to the RCIC system running in this mode.

An evaluation done for condition report (CR) CR-GGN-2007-03818 determined there was enough pressure from the CST to prevent gas from disassociating from the water and analysis indicated that two minute vent time was enough time to vent the RCIC discharge line volume from the pump discharge check valve to the injection valve. The system surveillance testing was performed per procedure and the system is vented every 31 days. As explained above, the two minute vent time was adequate to ensure the RCIC discharge piping at the injection valve was adequately vented and the condition would not have prevented the fulfillment of a safety function.

There were no actual adverse safety consequences as a result of this condition.

H.

Additionallnformation Previous Occurrences - There has not been any occurrence of a failure to submit an Licensee Event Report (LER) in the past three years at Grand Gulf Nuclear Station involving reportability under 10CFR50.73(a)(2)(i)(B) or involving these same conditions.