05000247/LER-2016-005, Regarding Technical Specification (TS) Prohibited Condition Due to a Surveillance Requirement Never Performed for Testing the Trip of the Main Boiler Feedwater Pumps

Regarding Technical Specification (TS) Prohibited Condition Due to a Surveillance Requirement Never Performed for Testing the Trip of the Main Boiler Feedwater Pumps

ML16159A297
Person / Time
Site:	Indian Point
Issue date:	05/25/2016
From:	Coyle L Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-16-056 LER 16-005-00
Download: ML16159A297 (6)

LER-2016-005, Regarding Technical Specification (TS) Prohibited Condition Due to a Surveillance Requirement Never Performed for Testing the Trip of the Main Boiler Feedwater Pumps

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
2472016005R00 - NRC Website

text

• ===* Entergx NL-16-056 May 25, 2016 U.S. Nuclear Regulatory Commission Document Control Desk 11545 Rockville Pike, TWFN-2 F1 Rockville, MD 20852-2738

\\

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, N.Y. 10511-0249 Tel (914) 254-6700 Lawrence Coyle Site Vice President

SUBJECT:

Licensee Event Report# 2016-005-00, "Technical Specification (TS)

Prohibited Condition Due to a Surveillance Requirement Never Performed for Testing the Trip of the Main Boiler Feedwater Pumps" Indian Point Unit No. 2 Docket No. 50-247 DPR-26

Dear Sir or Madam:

Pursuant to 10 CFR 50. 73(a)(1 ), Entergy Nuclear Operations Inc. (ENO) hereby provides Licensee Event Report (LER) 2016-005-00. The attached LER identifies an event where there was a Technical Specification (TS) Prohibited Condition due to a TS surveillance Requirement never performed for trip of the Main Boiler Feedwater Pumps (MBFP). This condition is reportable under 10 CFR 50.73(a)(2)(i)(B) as a TS prohibited condition due to a surveillance requirement never performed. This condition was recorded in the Entergy Corrective Action Program as Condition Report CR-IP2-2016-02247.

r-

NL-16-056 Page 2 of 2 There are no new commitments identified in this letter. Should you have any questions regarding this submittal, please contact Mr. Robert Walpole, Manager, Regulatory Assurance at (914) 254-6710.

Sincerely, LC/cb Attachment: LER-2016-005 cc:

Mr. Daniel H. Dorman, Regional Administrator, NRC Region I NRC Resident Inspector's Office Ms. Bridget Frymire, New York State Public Service Commission

Abstract

On March 26, 2016, during a refueling outage, an NRC inspector identified that the trip of the MBFPs is not tested in accordance with Technical Specification 3. 7.. 3 (Main Feedwater System) Surveillance Requirement (SR) 3.7.3.3.

This was discovered as a result of an assessment of the failure of the Main Boiler Feedwater Pumps (MBFPs) steam stop valves to close after the reactor trip on December 5, 2015.

TS SR 3.7.3.3 requires testing the MBFP trip function every 24 months on an actual or simulated actuation signal.

Surveillance tests 2-PT-V024DS60 *and 2-PT-V24DS61 are performed every 24 months, but only test up to the limit switch contact that actuates the MBFP turbine.trip solenoid valves and does not include the trip of the pump.

A review determined the requ~rement to verify the trip of the MBFPs was added to the TS during the implementation of the improved TS (ITS) conversion program in 2004 but the corresponding testing was not added to the surveillance tests.

The dfrect cause was human error for failure to ensure testing was established to meet new ITS.. SRs.

The apparent cause of the error is indeterminate due to the time passed since TS conversion by Amendment 238 on November 21, 2003.

Corrective actions include revision of Surveillance tests 2-PT-V024DS60 and 2-PT-V24DS61 to test tripping of the MBFPs.

The MBFPs will be tested per the revised procedures prior to startup from the.outage.

The event had no significant effect on I

public health and safety.

(If more space is required, use additional copies of (If more space is required, use additional copies of NRG Form 366A) (17)

Past Similar Events LER NUMBER (6)

I SEQUENTIAL I REVISION NUMBER NUMBER 005 00 PAGE (3) 4 OF 4

A review was performed of the past three years of Licensee Event Reports (LERs) for events reporting a TS violation due to inoperable MBFPs trip function.

No LERs were identified.

Safety Significance

This event had no effect on the health and safety of the public. There were no actual safety consequences for the event because there were no accidents or events during the degraded condition.

Isolation of the main FW.system is necessary to mitigate accident and transient conditions [Main Steam Line Breaks (SLB), SG Tube Ruptures, and Excessive Heat Removal Due to FW System Malfunction].

Main FW must be isolated to prevent excessive reactor coolant system cooldown, containment overpressure, and steam line overfill..

Main FW isolation is initiated by either an Engineered Safety Feature Actuation System (ESFAS) safety injection (SI) signal or a high steam generator water level signal.

Main FW isolation to all four SGs is provided by either 1) Closure of all four main FW regulating valves (MFRVs) and all four Low Flow Main FW Bypass Valves (FBVs), or 2)

Closure of* both MBFP discharge valves which initiates closure of all eight FW Isolation Valves (MFIVs), and the trip of both MBFPs.

Either of these combinations is capable of achieving main.FW isolation to all four SGs within the time limits assumed in the accident analysis.

If all eight valv.es referenced in item 1 close, main FW isolation to all four SGs is completed within time limits that satisfy accident analysis assumptions.

To establish redundancy for main FW isolation safety function, the SI ESFAS or High SG Level signal also provides a direct signal that closes the two MBFP discharge valves.

Wheri both MBFP discharge valves move off the open seat, the relay actuates and generates a signal that initiates closure of the four main FW isolation valves * (MFIVs) and the four Low Flow FIVs.

For this event, one of the FW isolation capabilities was operable as the post transient report for the reactor trip on December 5,. 2015, recorded FW isolated.

This event was bounded by the analyzed event described in FSAR Section 14.1.10, (Excessive Heat Removal Due to Feedwater System Malfunctions).

Excessive FW additions is an analyzed event postulated to occur from a malfunction of the FW control system or an operator error which results in the opening of a FW control valve.

The analysis assumes one FW valve opens fully resulting in the excessive FW flow to one SG.

For the FW system malfunction at full power, the FW flow resulting from a fully open control valve is terminated by the SG high level signal that closes all FW control valves and trips the MBFPs.

The SG high water level signal also produces a signal to trip the mqin turbine which initiates a reactor trip.

The analysis for all cases of the excessive FW addition initiated, at full power conditions with and without automatic rod control, show that the minimum DNBR. remains above the applicable safety analysis DNBR limit.

In the case of excessive FW flow with the reactor at zero power, the resulting transient is similar to, but less severe than the hypothetical steamline break transient and is bounded by the analysis in UFSAR Section 14.2.5 (Rupture of a Steam Pipe).