05000220/LER-2019-002, Condition Prohibited by Technical Specification Due to Vacuum Breaker Not Locked Closed

Condition Prohibited by Technical Specification Due to Vacuum Breaker Not Locked Closed

ML19203A121
Person / Time
Site:	Nine Mile Point
Issue date:	06/24/2019
From:	Kreider R Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NMP1L3291 LER 2019-002-00
Download: ML19203A121 (6)

LER-2019-002, Condition Prohibited by Technical Specification Due to Vacuum Breaker Not Locked Closed

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 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)(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)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i)
2202019002R00 - NRC Website

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~- Exelon Generation 10 CFR 50.73 NMP1L3291 June 24, 2019 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Nine Mile Point Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-63 Docket No. 50-220 NMP1 Licensee Event Report 2019-002, Condition Prohibited by Technical Specifications due to Vacuum Breaker not Locked Closed In accordance with the reporting requirements contained in 1 O CFR 50.73(a)(2)(i)(B), please find enclosed NMP1 Licensee Event Report (LER) 2019-002, Condition Prohibited by Technical Specifications due to Vacuum Breaker not Locked Closed.

There are no regulatory commitments contained in this letter.

Should you hq.ve any questions regarding the information in this submittal, please contact Brandon Shultz, Site Regulatory Assurance Manager, at (315) 349-7012.

Respectfully, Robert E. Kreider Jr.

Plant Manager, Nine Mile Point Nuclear Station Exelon Generation Company, LLC REK/KJK

Enclosure:

NMP1 Licensee Event Report 2019-002, Condition Prohibited by Technical Specifications due to Vacuum Breaker not Locked Closed cc:

NRC Regional Administrator, Region I NRC Resident Inspector NRC Project Manager

Enclosure NMP1 Licensee Event 2019-002, Condition Prohibited by Technical Specifications due to Vacuum Breaker not Locked Closed Nine Mile Point Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-63

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NR~ FORl\\/l":-S66.~*'.*

U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY 0MB: NO. 3150-0104 EXPIRES: 03/31/2020 (04-2017)

, the htt12://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1022/r3/)

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

3. PAGE Nine Mile Point Unit 1 05000220 1 OF 4

4. TITLE Condition Prohibited by Technical Specifications due to Vacuum Breaker not Locked Closed

5. EVENT DATE

6. LEA NUMBER

7. REPORT DATE

8. OTHER FACILITIES INVOLVED I

SEQUENTIAL I REV FACILITY NAME DOCKET NUMBER MONTH DAY YEAR YEAR NUMBER NO.

MONTH DAY YEAR N/A N/A FACILITY NAME DOCKET NUMBER 04 25 2019 2019 - 002

- 00 06 24 2019 N/A N/A

9. OPERATING MODE

11. THIS REPORT 15 SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)

D 20.2201 (bl D 20.22os(a)(3)(il D 50.73(a)(2)(ii)(A)

D 50.73(a)(2)(viii)(A)

N D 20.2201 (dl D 20.22os(a)(s)(ii)

D 50.73(a)(2)(ii)(B)

D 50.73(a)(2)(viii)(B)

D 20.22os(aJ(1 l D 20.22os(a)(4l D so.?s(a)(2)(iiil D 50.73(a)(2)(ix)(A)

D 20.22os(a)(2)(il D 50.36(c)(1)(i)(A)

D 50.73(a)(2)(iv)(A)

D 50.73(a)(2)(x)

10. POWER LEVEL D 20.22os(a)(2)(ii)

D 50.36(c)(1 )(ii)(A)

D 50.73(a)(2)(v)(A)

D 1s.11(a)(4l D 20.22os(a)(2)(m)

D so.s6(c)(2)

D 50.73(a)(2)(v)(B)

D 1s.11 (a)(s)

D 20.2203(a)(2)(iv)

D so.46(a)(3)(iil D 50.73(a)(2)(v)(C)

D 1s.?1(a)(1) 000 D 20.2203(a)(2)(v)

D 50.73(a)(2)(i)(A)

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

D 1s.1?(a)(2)(il D 20.2203(a)(2)(vi)

[81 50.73(a)(2)(i)(B)

D 50.73(a)(2)(vii)

D 1s.1?(a)(2)(ii)

A

J; D 50.73(a)(2)(i)(C)

D OTHER Specify in Abstract below or in April 12, 2019 at 16:32-Exited mode of applicability when Primary Containment Integrity no longer required. (Reactor declctred Sub-Critical, Reactor Coolant Temp

= 211 degrees F)

April 12, 2019 at 17:54-Entered mode of applicability when Primary Containment Integrity is required. (Reactor Criticality established, Reactor Coolant Temp= 205 degrees F)

April 14, 2019 at 16:24 - Exited mode of applicability when Primary Containment Integrity no longer required. (Reactor Coolant Temp= 214 degrees F)

April 14, 2019 at 22:38 - Entered mode of applicability when Primary Containment Integrity is required. (Reactor Criticality established, Reactor Coolant Temp= 204 degrees F)

April 16, 2019 at 13: 14 - Exited mode of applicability when Primary Containment Integrity no longer required. (Reactor Coolant Temp= 214 degrees F)

April 25, 2019 - Discovered condition April 25, 2019 at 19:40 - Vacuum Breaker locked closed to comply with TS 3.3.6.f.(2)

April 26, 2019 at 10:22 - Entered mode of applicability when Primary Containment Integrity is required. (Reactor Criticality established, Reactor Coolant Temp= 148 degrees F).

April 28, 2019 at 00:36 - Vacuum breaker repaired and declared Operable.*

April 28, 2019 at 02:05-Vacuum Breaker lock removed, TS LCO 3.3.6.f.(2) Exited.

E. METHOD OF DISCOVERY

This event was discovered by station personnel when preparing for plant startup.

F. SAFETY SYSTEM RESPONSES:

None. No operational conditions occurre~ requiring the response of safety systems.

II. CAUSE OF EVENT

The cause of the event is Operations personnel have not consistently implemented the Degraded Equipment Log (DEL)/Equipment Status Log (ESL) to track operability concerns of systems and components.

III. ANALYSIS OF THE EVENT

This event is reportable in accordance with 10 CFR 50.73 (a)(2)(i)(B), as an operation or condition which was prohibited by the plant's Technical Specifications.

The NMP1 TS 3.3.6.f.(2) requires an inoperable Pressure Suppression Chamber to Reactor

• Building Vacuum Breaker to be immediately locked closed. NMP1 design includes 3 Pressure Suppression Chamber - Reactor Building Vacuum Breakers. One vacuum breaker is allowed to be locked closed, per TS 3.3.6.f.(2). Two vacuum breakers are required to perform the function of relieving pressure. Two vacuum breakers were operable when required.

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 Indicators.

IV. CORRECTIVE ACTIONS

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

Vacuum Breaker, IV-68-08, was repaired.

B. ACTION TAKEN OR PLANNED TO PREVENT RECURRENCE:

Action to prevent recurrence is reinforce implementation of the process to institutionalize use of the DEUESL into day to day operations.

V. ADDITIONALINFORMATION:

A. FAILED COMPONENTS:

Vacuum Breaker, IV-68-08.

B. PREVIOUS LERs ON SIMILAR EVENTS:

None C. THE ENERGY INDUSTRY IDENTIFICATION SYSTEM (EIIS) COMPONENT FUNCTION IDENTIFIER AND SYSTEM NAME OF EACH COMPONENT OR SYSTEM REFERRED TO INTHISLER:

COMPONENT Vacuum Breaker Primary Containment Containment Vacuum Relief System Reactor Building IEEE 803 FUNCTION IDENTIFIER PCV N/A N/A N/A IEEE 805 SYSTEM IDENTIFICATION BF JB BF NG Page _4_ of _4_

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