05000364/FIN-2018001-02: Difference between revisions

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| finding integer = 02
| finding integer = 02
| quarter = 2018Q1
| quarter = 2018Q1
| IR section = NO CC AREA
| IR section = 4OA3
| finding type = Violation
| finding type = Violation
| significance =  
| significance = Severity level Enforcement Discretion
| cornerstone = Mitigating Systems
| cornerstone = Mitigating Systems
| violation of = Technical Specification
| violation of = Technical Specification
| identified by = NRC
| identified by = NRC
| Inspection procedure = IP 4OA3
| Inspection procedure = IP 71153
| Inspector = 7115
| Inspector = P Niebaum, K Miller, J Parent, R Cureton, D Mas, J Munday
| CCA = N/A for ROP
| CCA =  
| INPO aspect = Enforcement Discretion
| INPO aspect =  
| description = On October 26, 2017, MSSV Q2N11V0012E was removed from service at Farley Nuclear Plant Unit 2 during a refueling outage, and on November 1, 2017 the valve was tested with steam at an offsite facility.  As-found lift testing determined that the valve opened at 1171 psig steam pressure, which was 9 psig high outside the plant technical specification (TS) allowable lift setting range of 1096 psig to 1162 psig.  The valve had been in service prior to the plant beginning commercial operation on July 30, 1981, until it was removed from the main steam system on October 26, 2017.  The licensee last tested the valve, while installed on the main steam system, on April 5, 2016.  The test results indicated the lift pressure was within +/- 1% of the TS 3.7.1 required set pressure of 1129 psig, and no set pressure adjustment was necessary for the valve.  The licensee determined that the MSSV high as-found lift set-point did not have an adverse impact on the main steam system over-pressurization protection, since the valve as-found lift setpoint was lower than 110% of steam generator design pressure (1194 psig), and this condition would not have resulted in a loss of safety function.  Therefore, the plant remained bounded by the accident analysis in the Final Safety Analysis Report (FSAR), based on the as-found condition.  Corrective Action(s):  The valve was replaced with an operable MSSV during the refueling outage prior to plant startup.Corrective Action Reference(s): The licensee entered this issue into their Corrective Action Program (CAP) as condition report (CR) 10426186  as found test results for MSSV Q2N11V0012E. Violation:  Farley Nuclear Plant, Unit 2 Technical Specifications (TS) limiting condition for operation (LCO) 3.7.1, Main Steam Safety Valves (MSSVs), required five MSSVs per steam generator to be operable.  Per TS Table 3.7.1-2, MSSV Q2N11V0012E must have a lift setting within the range of 1096 psig to 1162 psig, while the Unit was in modes 1, 2, and 3.  With one MSSV inoperable and the Moderator Temperature Coefficient (MTC) zero or negative at all power levels, Action Statement, Condition A, Required Action A.1, required reducing thermal power to 87% RTP within 4 hours.  If the required action and associated completion time is not met, Action Statement, Condition C, required that the unit be in mode 3 within 6 hours.Contrary to the above, the licensee determined the MSSV setting was outside the TS limits longer than 10 hours during the operating cycle between May 11, 2016 and October 15, 2017, while the Unit was in modes 1, 2, and 3.  Severity/Significance:  The inspection assessed the severity of the violation using Section 6.1 of the Enforcement Policy and determined the significance is appropriately characterized at Severity Level IV, due to the inappreciable potential safety consequences.  The significance of this violation was informed, in part, using IMC 0609, Appendix A, The Significance Determination Process (SDP) for findings at Power, dated June 19, 2012.  Basis for Discretion:  The NRC exercised enforcement discretion in accordance with Section3.10 of the Enforcement Policy because the MSSV as-found lift pressure issue was not reasonably foreseeable and preventable.  The inspectors reached this conclusion due to the fact that the licensee last tested the valve satisfactorily, while installed on the main steam system, on April 5, 2016, and during the period of time that the valve was in service, following May 11, 2016, there was no indication of valve degradation (e.g. seat leakage)
| description = On October 26, 2017, MSSV Q2N11V0012E was removed from service at Farley Nuclear Plant Unit 2 during a refueling outage, and on November 1, 2017 the valve was tested with steam at an offsite facility.  As-found lift testing determined that the valve opened at 1171 psig steam pressure, which was 9 psig high outside the plant technical specification (TS) allowable lift setting range of 1096 psig to 1162 psig.  The valve had been in service prior to the plant beginning commercial operation on July 30, 1981, until it was removed from the main steam system on October 26, 2017.  The licensee last tested the valve, while installed on the main steam system, on April 5, 2016.  The test results indicated the lift pressure was within +/- 1% of the TS 3.7.1 required set pressure of 1129 psig, and no set pressure adjustment was necessary for the valve.  The licensee determined that the MSSV high as-found lift set-point did not have an adverse impact on the main steam system over-pressurization protection, since the valve as-found lift setpoint was lower than 110% of steam generator design pressure (1194 psig), and this condition would not have resulted in a loss of safety function.  Therefore, the plant remained bounded by the accident analysis in the Final Safety Analysis Report (FSAR), based on the as-found condition.  Corrective Action(s):  The valve was replaced with an operable MSSV during the refueling outage prior to plant startup.Corrective Action Reference(s): The licensee entered this issue into their Corrective Action Program (CAP) as condition report (CR) 10426186  as found test results for MSSV Q2N11V0012E. Violation:  Farley Nuclear Plant, Unit 2 Technical Specifications (TS) limiting condition for operation (LCO) 3.7.1, Main Steam Safety Valves (MSSVs), required five MSSVs per steam generator to be operable.  Per TS Table 3.7.1-2, MSSV Q2N11V0012E must have a lift setting within the range of 1096 psig to 1162 psig, while the Unit was in modes 1, 2, and 3.  With one MSSV inoperable and the Moderator Temperature Coefficient (MTC) zero or negative at all power levels, Action Statement, Condition A, Required Action A.1, required reducing thermal power to 87% RTP within 4 hours.  If the required action and associated completion time is not met, Action Statement, Condition C, required that the unit be in mode 3 within 6 hours.Contrary to the above, the licensee determined the MSSV setting was outside the TS limits longer than 10 hours during the operating cycle between May 11, 2016 and October 15, 2017, while the Unit was in modes 1, 2, and 3.  Severity/Significance:  The inspection assessed the severity of the violation using Section 6.1 of the Enforcement Policy and determined the significance is appropriately characterized at Severity Level IV, due to the inappreciable potential safety consequences.  The significance of this violation was informed, in part, using IMC 0609, Appendix A, The Significance Determination Process (SDP) for findings at Power, dated June 19, 2012.  Basis for Discretion:  The NRC exercised enforcement discretion in accordance with Section3.10 of the Enforcement Policy because the MSSV as-found lift pressure issue was not reasonably foreseeable and preventable.  The inspectors reached this conclusion due to the fact that the licensee last tested the valve satisfactorily, while installed on the main steam system, on April 5, 2016, and during the period of time that the valve was in service, following May 11, 2016, there was no indication of valve degradation (e.g. seat leakage)
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Latest revision as of 08:59, 30 May 2018

02
Site: Farley Southern Nuclear icon.png
Report IR 05000364/2018001 Section 4OA3
Date counted Mar 31, 2018 (2018Q1)
Type: Violation: Severity level Enforcement Discretion
cornerstone Mitigating Systems
Identified by: NRC identified
Inspection Procedure: IP 71153
Inspectors (proximate) P Niebaum
K Miller
J Parent
R Cureton
D Mas
J Munday
Violation of: Technical Specification
INPO aspect
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