05000461/LER-2016-010

LER-2016-000, 1 OF 3

Clinton Power Station, Unit 1
Event date:	10-14-2016
Report date:	03-06-2017
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
4612016000R01 - NRC Website

LER 16-010-01 for Clinton Power Station, Unit 1 RE: Failure to Complete Technical Specification Required Actions within the Completion Time Resulted in a Condition Prohibited by Technical Specifications

ML17067A413
Person / Time
Site:	Clinton
Issue date:	03/06/2017
From:	Stoner T R Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
U-604334 LER 16-010-01
Download: ML17067A413 (4)

comments regardng burden estimate to the FOIA, Privacy and Information Collections Branch (T-5 F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e-mail to used to impose an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

PLANT AND SYSTEM IDENTIFICATION

General Electric—Boiling Water Reactor, 3473 Megawatts Thermal Rated Core Power Energy Industry Identification System (El IS) codes are identified in the text as [XX]

EVENT IDENTIFICATION

Failure to Complete Technical Specification Required Actions within the Completion Time Resulted in a Condition Prohibited by Technical Specifications A. Plant Operating Conditions before the Event

B. DESCRIPTION OF EVENT

On October 14, 2016, Clinton Power Station (CPS) determined subsequent to the 3rd Quarter NRC Exit Meeting that a condition prohibited by, Technical Specification (TS) 3.7.6, "Main Turbine Bypass System," had occurred associated with a failure to complete a TS Required Action within the associated Completion Time. Specifically, on June 6, 2016, the TS Limiting Condition for Operations (LCO) Surveillance Requirement (SR) 3.0.2 grace period of 1.25 times the normal required Frequency (31 days) for completing testing of the Main Steam Bypass Valves per SR 3.7.6.1 was exceeded for the Main Turbine Bypass System. Turbine Bypass Valves (TBV) 4, 5, and 6 were not tested within the required Frequency and the valves were declared inoperable as required by TS SR 3.0.1.Thermal Limit penalties were applied as required by LCO 3.7.6.

On . July 7, 2016, a Surveillance Frequency Change was processed in accordance with TS Program 5.5.16, "Surveillance Frequency Control Program," for TS SR 3.7.6.1 to change the required Frequency from 31 days to 12 months. The last performance credit date of the TBV test was April 28, 2016. This new revision changed the due date for testing the TBVs to April 28, 2017.

With TBV testing performed within the new required interval, the valves were declared OPERABLE and the Thermal Limit penalties removed without performing the required SR 3.7.6.1. It was subsequently determined, however, that in accordance with TS SR 3.0.1 Bases, the Surveillance had to be met and performed in accordance with SR 3.0.2 prior to returning equipment to OPERABLE status.

The failure to perform the TS SR within the test interval without applying the Actions of TS 3.7.6 was a condition prohibited by TS.

I LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET

2016 - 01 comments regarding burden estimate to the FOIA, Privacy and Information Collections Branch (T-5 F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e-mail to used to impose an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the inforrnation collection.

3. LER NUMBER

2016 - 01 010 A surveillance test for TBVs 4, 5, and 6 was satisfactorily completed on September 28, 2016 using an alternate methodology.

C. CAUSE OF EVENT

No specific requirement exists in either Exelon administrative procedures or NEI 04-10, "Risk Informed Technical Specifications," which prohibits declaring a component or system OPERABLE based solely on an extension of the required surveillance test interval. Licensed operator staff incorrectly interpreted TS SR 3.0.1 Bases based on the guidance provided in OP-AA-108-106, "Equipment Return to Service.

D. SAFETY ANALYSIS

There were no safety consequences associated with the event described in this report since no thermal limits were exceeded during the time the thermal limit penalty was not invoked. A subsequent surveillance test of TBVs 4, 5, and 6 was satisfactorily completed on September 26, 2016, using an alternate test method, demonstrating that the TBVs would have properly responded to an event. The ability of the plant to safely shutdown was not affected as a result of the conditions described in this report.

E. CORRECTIVE ACTIONS

Turbine Bypass Valves 4, 5, and 6 were satisfactorily tested on September 28, 2016 using an alternate test methodology. The insight gained from this event was shared with on-shift licensed operators and the Exelon Operations peer group. Operating procedure changes are being made to ensure the requirements of SR 3.0.1 are clear regarding implementation of surveillance frequency changes.

F. PREVIOUS SIMILAR OCCUR ENCES

There were no previous occurrences associated with this event.

G. COMPONENT FAILURE DATA

There was not a component failure associated with this event.