05000247/FIN-2013011-02
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Finding | |
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| Title | Failing to initiate a condition report or otherwise report the condition such that a Licensee Event Report could be written |
| Description | 10 CFR 50.73(a)(2)(8) requires the holder of an operating license to, within 60 days after discovery, submit a Licensee Event Report to the NRC for any operation or condition which was prohibited by the plant's Technical Specifications. IP2 TS 5.5.11/IP3 TS 5.5.12, Diesel Fuel Oil Testing Program, in part, require verification every 92 days that total particulate concentration of the fuel oil in the onsite and reserve storage tanks is less than or equal to 10 mg/!. IP2/3 TS 3.8, Electrical Power Systems, Section 3.8.3, Diesel Fuel Oil and Starting Air, requires that whenever the total particulate concentration of fuel oil in the reserve fuel oil storage tank (RFOST) exceeds the limit, it must be restored within limits within 30 days, otherwise, the associated diesel generators must be immediately declared inoperable. IP 2/3 TS 3.0.3 states that when a TS Limiting Condition of Operation is not met and the associated Actions are not met, action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in: MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />, MODE 4 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />, and MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />. TS 5.4, Procedures, Section 5.4.1, states, in part, that written procedures shall be established, implemented, and maintained covering the applicable requirements and recommendations of Appendix A of Regulatory Guide 1.33, Revision 2 (except as provided in the quality assurance program described or referenced in the Updated FSAR for Unit 2). RG 1.33, Rev.2, App A recommends chemical and radiochemical control procedures to prescribe the nature and frequency of sampling and analyses. Implementing Procedure ENCY- 101, Chemistry Activities, includes guidance related to chemistry sampling and analysis. Section 5.5 states that out of specification conditions should be identified and corrective actions initiated as quickly as possible. Implementing Procedure 0-CY-1210, Organization and Responsibilities of the Chemistry Department, includes guidance related to chemistry sampling and analysis. Step 4.1.4 requires a condition report to be initiated to report any condition exceeding any procedural limits. Contrary to the above, on or about February 2, 2012, ENO staff identified that, on two occasions: 1) fuel oil sample test results had been received indicating total particulate concentrations that exceeded TS limits of 10 mgtl; 2) the total particulate concentration for these systems had not been returned to within limits within the TS-required timeframe; and 3) the associated diesel generators had not been declared inoperable or the units placed in the appropriate operating modes. However, the ENO staff did not initiate condition reports or otherwise report the condition such that a Licensee Event Report could be written. Specifically the ENO staff identified that: 1) on July 13, 2011, Entergy received an RFOST sample result indicating total particulate concentration of 13.4 mgtl, and the parameter was not restored to within limits until September 2, 2011; and, 2) on December 30, 2011, Entergy received an RFOST sample result indicating total particulate concentration of 13.2 mgtl, and, as of February 5, the parameter had not been restored to within limits. The NRC was not informed via an LER that the plant was operating in a condition prohibited by its TS until August 20, 2012, more than 60 days after discovery by the ENO staff. |
| Site: | Indian Point  |
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| Report | IR 05000247/2013011 Section 4OA5 |
| Date counted | Mar 31, 2012 (2012Q1) |
| Type: | AV: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | |
| Inspectors (proximate) | C Sanders J Trapp M Scott R Lorson |
| INPO aspect | |
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Finding - Indian Point - IR 05000247/2013011 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Indian Point) @ 2012Q1
Self-Identified List (Indian Point)
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