05000341/LER-2015-007, Regarding Operation with the Potential to Drain the Reactor Vessel with Secondary Containment Inoperable

Regarding Operation with the Potential to Drain the Reactor Vessel with Secondary Containment Inoperable

ML15328A425
Person / Time
Site:	Fermi
Issue date:	11/24/2015
From:	Kaminskas V DTE Electric Company, DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-15-0097 LER 15-007-00
Download: ML15328A425 (5)

LER-2015-007, Regarding Operation with the Potential to Drain the Reactor Vessel with Secondary Containment Inoperable

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(v), Loss of Safety Function 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)(iii) 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)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i)
3412015007R00 - NRC Website

text

Vito A. Kaminskas Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.6515 Fax: 734.586.4172 Email: kaminskasv@dteenergy.com DTE Energy-10 CFR 50.73 November 24, 2015 NRC-15-0097 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C.

20555-0001

Reference:

Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

Subject:

Licensee Event Report (LER) No. 2015-007 Pursuant to 10 CFR 50.73 (a)(2)(v)(C) and (a)(2)(i)(B) DTE Electric Company (DTE) is submitting LER No. 2015-007, Operation with the Potential to Drain the Reactor Vessel with Secondary Containment Inoperable.

If you have any questions or require additional information, please contact Mr.

Christopher R. Robinson of my staff at (734) 586-5076.

Sincerely, Vito A. Kaminskas Site Vice President Enclosure cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Michigan Public Service Commission Regulated Energy Division (kindschl@michigan.gov)

Enclosure to NRC-15-0097 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 LER 2015-007, Operation with the Potential to Drain the Reactor Vessel with Secondary Containment Inoperable

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10131/2018 (11-2015)

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

3. PAGE Fermi 2 05000 05000341 1 OF 3

4. TITLE Operation with the Potential to Drain the Reactor Vessel with Secondary Containment Inoperable

5. EVENT DATE

6. LER NUMBER

7. REPORT DATE

8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR SEQUENTIAL REV MONTH DAY YEAR FACILITY NAME DOCKETNUMBER MOTNA ER 2

UMBE

~ NO.__

N/A 05000 N/A FACILITY NAME DOCKET NUMBER 10 04 2015 2015 007 0

11 24 2015 N/A 05000 N/A

9. OPERATING MODE

11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply) 20.2201(b)

[

20.2203(a)(3)(i)

El 50.73(a)(2)(ii)(A) 50.73(a)(2)(viii)(A) 5

[]20.2201(d)

Q 20.2203(a)(3)(ii)

[

50.73(a)(2)(ii)(B) 50.73(a)(2)(viii)(B)

[

20.2203(a)(1) 20.2203(a)(4)

[

50.73(a)(2)(iii) 50.73(a)(2)(ix)(A)

Q 20.2203(a)(2)(i) 50.36(c)(1)(i)(A) 50.73(a)(2)(iv)(A) 50.73(a)(2)(x)

10. POWER LEVEL 20.2203(a)(2)(ii) 50.36(c)(1)(ii)(A) 50.73(a)(2)(v)(A) 73.71(a)(4) 20.2203(a)(2)(iii) 50.36(c)(2) 50.73(a)(2)(v)(B) 73.71(a)(5) 20.2203(a)(2)(iv) 50.46(a)(3)(ii)

[

50.73(a)(2)(v)(C) 73.77(a)(1) 0 20.2203(a)(2)(v) 50.73(a)(2)(i)(A)

E 50.73(a)(2)(v)(D) 73.77(a)(2)(i) 20.2203(a)(2)(vi)

/

50.73(a)(2)(i)(B)

El 50.73(a)(2)(vii)

E 73.77(a)(2)(ii) 50.73(a)(2)(i)(C)

El OTHER Specify in Abstract below or in NRC Form 366A

12. LICENSEE CONTACT FOR THIS LER LICENSEE CONTACT TELEPHONE NUMBER (Include Area Code)

Christopher R. Robinson - Manager Nuclear Licensing (734) 586-5076CAUSE SYSTEM COMPONENT FACURER REPORTABLE

CAUSE

SYSTEM COMPONENT FACTURER REPORTABLE

14. SUPPLEMENTAL REPORT EXPECTED

15. EXPECTED MONTH DAY YEAR E YES (If yes, complete 15. EXPECTED SUBMISSION DATE)

[

NO SUBMISSION ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)

On October 4, 2015 at approximately 0956 EDT, an Operation with the Potential to Drain the Reactor Vessel (OPDRV) was unintentionally initiated without secondary containment operable. Plant personnel were starting work to isolate the Reactor Recirculation (RR) pump seal flow switch and rotameter for replacement. The RR pump seal cavity drain valves were opened in accordance with the Safety Tagging Record (STR). Shortly after the valves were opened, the Control Room staff identified a lowering Fuel Pool Skimmer Surge Tank level and an increase in Drywell Floor drain sump level and initiated actions to isolate the RR pump seal cavity. At approximately 1120 EDT, the RR pump seal drain valves were successfully closed and the OPDRV was terminated.

The RR pump seal drain flow was approximately 12 gallons per minute and lasted for approximately 84 minutes. Reactor cavity water level and spent fuel pool level remained constant throughout the OPDRV. Personnel who developed the STR failed to recognize that the activity would result in an OPDRV and; therefore, did not require that Secondary Containment be Operable in accordance with Technical Specifications. The event was entered into the corrective action program. This Licensee Event Report is written in accordance with 10CFR50.73(a)(2)(v)(C) and 50.73(a)(2)(i)(B).

NRC FORM 366 (11-2015)

Page 2 of 3U.S. NUCLEAR REGULATORY COMMISSION (11-2015)

LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET

3. LER NUMBER YEAR SEQUENTIAL REV Fermi 2 05000-341 NUMBER NO.

Fernu 2 41 2015 0

Initial Plant Conditions

Mode: 5 Reactor Power: 0 percent Description of the Event On October 4, 2015 at approximately 0956 EDT, an Operation with the Potential to Drain the Reactor Vessel (OPDRV) was unintentionally initiated without secondary containment [NH] operable. Plant personnel were starting work to isolate the Reactor Recirculation (RR) [AD] pump seal flow switch and rotameter for replacement. The RR pump seal cavity drain [DRN] valves were opened in accordance with the Safety Tagging Record (STR). Shortly after the valves were opened, the Control Room staff identified a lowering Fuel Pool Skimmer Surge Tank [TK] level and an increase in Drywell Floor drain sump level and initiated actions to isolate the RR pump seal cavity. At approximately 1120 EDT, the RR pump seal drain valves [V] were successfully closed and the OPDRV was terminated. The RR pump seal drain flow was approximately 12 gallons per minute and lasted for approximately 84 minutes. The Reactor Pressure Vessel (RPV) level was maintained by Control Rod Drive (CRD) [AA] flow. This event occurred during the 17 th refueling outage (RF 17) with the reactor cavity flooded up and fuel pool gates removed. Reactor cavity water level and spent fuel pool level remained constant throughout the OPDRV evolution without Secondary Containment being operable.

This event (No. 51449) was reported in accordance with 10CFR50.72(b)(3)(v)(C) as an eight hour non-emergency report to the NRC Operations Center. The criterion used for the report was any event or condition that at the time of discovery could have prevented the fulfillment of the safety function of structures or systems that are needed to control the release of radioactive material. This Licensee Event Report is written in accordance with 10CFR50.73(a)(2)(v)(C).

The NRC issued Enforcement Guidance Memorandum (EGM) 11-003 to provide guidance on how to disposition boiling water reactor licensee noncompliance with Technical Specifications (TS) containment requirements during OPDRV operations; however, at the time of this event, the EGM was not invoked and the OPDRV was not recognized until the Control Room staff identified a lowering Fuel Pool Skimmer Surge Tank level and increase in Drywell Floor drain sump level. This LER is also written in accordance with 1 OCFR50.73(a)(2)(i)

(B), as an operation or condition which was prohibited by plant TS. Secondary Containment was required in Mode 5, Refueling, during OPDRV.

Significant Safety Consequences and Implications

There were no safety consequences during this OPDRV activity. Evaluation of the OPDRV activity determined that the time to drain down the RPV to the top of the RPV flange was greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with no make-up.

At the time of the event, the mitigating measures of EGM 11-003 were met by the practices and processes in place for the Refueling Outage defense in depth measures.

Page 3 of 3U.S. NUCLEAR REGULATORY COMMISSION (11-2015)

LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET

3. LER NUMBER YEAR SEQUENTIAL REV Fermi 2 050-341 7

50 NUMBER NO.

All Control Rods were inserted with one Rod interlock operable. Division I of the Residual Heat Removal system was operating in Shutdown Cooling for decay heat removal. Division I Core Spray and Condensate Make-up to the Fuel Pool Skimmer Surge Tank were available to add inventory. On site and off site electrical systems were also operable.

Cause of the Event

Investigation determined that the tag out (STR) configuration established for the maintenance activity did not include closing the RR pump suction or discharge valves which resulted in the RR loop being in direct communication with the reactor coolant system.

The Apparent Cause of the event was that lack of self-checking resulted in OPDRVs, or the potential for OPDRVs, for systems that interface with the RPV coolant system, not being identified during the preparation and review of the STR.

Corrective Actions

The event was entered into the Corrective Action Program and an Operations Department standdown was performed.

The list of valves that have the potential to create an OPDRV condition was enhanced to include boundary isolation valves. The list will be utilized to ensure appropriate controls are established for STR development and review.

The remaining RF17 STRs for systems that interface with the RPV coolant system were reviewed to ensure appropriate configuration control. There were no OPDRV vulnerabilities identified.

A Shift Manager review and authorization of all RF17 manipulations associated with systems interfacing with the RPV coolant system was added to existing processes. This review will validate that isolation boundaries will be established prior to opening of vent and drain valves. Operations Department Expectations documents, Conduct Manual and Operator Training will be revised to incorporate those requirements.

Additional Information

A. Failed Components: None B. Previous LERs for Similar Events: None.

Vito A. Kaminskas Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.6515 Fax: 734.586.4172 Email: kaminskasv@dteenergy.com DTE Energy-10 CFR 50.73 November 24, 2015 NRC-15-0097 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C.

20555-0001

Reference:

Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

Subject:

Licensee Event Report (LER) No. 2015-007 Pursuant to 10 CFR 50.73 (a)(2)(v)(C) and (a)(2)(i)(B) DTE Electric Company (DTE) is submitting LER No. 2015-007, Operation with the Potential to Drain the Reactor Vessel with Secondary Containment Inoperable.

If you have any questions or require additional information, please contact Mr.

Christopher R. Robinson of my staff at (734) 586-5076.

Sincerely, Vito A. Kaminskas Site Vice President Enclosure cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Michigan Public Service Commission Regulated Energy Division (kindschl@michigan.gov)

Enclosure to NRC-15-0097 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 LER 2015-007, Operation with the Potential to Drain the Reactor Vessel with Secondary Containment Inoperable

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10131/2018 (11-2015)

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

3. PAGE Fermi 2 05000 05000341 1 OF 3

4. TITLE Operation with the Potential to Drain the Reactor Vessel with Secondary Containment Inoperable

5. EVENT DATE

6. LER NUMBER

7. REPORT DATE

8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR SEQUENTIAL REV MONTH DAY YEAR FACILITY NAME DOCKETNUMBER MOTNA ER 2

UMBE

~ NO.__

N/A 05000 N/A FACILITY NAME DOCKET NUMBER 10 04 2015 2015 007 0

11 24 2015 N/A 05000 N/A

9. OPERATING MODE

11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply) 20.2201(b)

[

20.2203(a)(3)(i)

El 50.73(a)(2)(ii)(A) 50.73(a)(2)(viii)(A) 5

[]20.2201(d)

Q 20.2203(a)(3)(ii)

[

50.73(a)(2)(ii)(B) 50.73(a)(2)(viii)(B)

[

20.2203(a)(1) 20.2203(a)(4)

[

50.73(a)(2)(iii) 50.73(a)(2)(ix)(A)

Q 20.2203(a)(2)(i) 50.36(c)(1)(i)(A) 50.73(a)(2)(iv)(A) 50.73(a)(2)(x)

10. POWER LEVEL 20.2203(a)(2)(ii) 50.36(c)(1)(ii)(A) 50.73(a)(2)(v)(A) 73.71(a)(4) 20.2203(a)(2)(iii) 50.36(c)(2) 50.73(a)(2)(v)(B) 73.71(a)(5) 20.2203(a)(2)(iv) 50.46(a)(3)(ii)

[

50.73(a)(2)(v)(C) 73.77(a)(1) 0 20.2203(a)(2)(v) 50.73(a)(2)(i)(A)

E 50.73(a)(2)(v)(D) 73.77(a)(2)(i) 20.2203(a)(2)(vi)

/

50.73(a)(2)(i)(B)

El 50.73(a)(2)(vii)

E 73.77(a)(2)(ii) 50.73(a)(2)(i)(C)

El OTHER Specify in Abstract below or in NRC Form 366A

12. LICENSEE CONTACT FOR THIS LER LICENSEE CONTACT TELEPHONE NUMBER (Include Area Code)

Christopher R. Robinson - Manager Nuclear Licensing (734) 586-5076CAUSE SYSTEM COMPONENT FACURER REPORTABLE

CAUSE

SYSTEM COMPONENT FACTURER REPORTABLE

14. SUPPLEMENTAL REPORT EXPECTED

15. EXPECTED MONTH DAY YEAR E YES (If yes, complete 15. EXPECTED SUBMISSION DATE)

[

NO SUBMISSION ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)

On October 4, 2015 at approximately 0956 EDT, an Operation with the Potential to Drain the Reactor Vessel (OPDRV) was unintentionally initiated without secondary containment operable. Plant personnel were starting work to isolate the Reactor Recirculation (RR) pump seal flow switch and rotameter for replacement. The RR pump seal cavity drain valves were opened in accordance with the Safety Tagging Record (STR). Shortly after the valves were opened, the Control Room staff identified a lowering Fuel Pool Skimmer Surge Tank level and an increase in Drywell Floor drain sump level and initiated actions to isolate the RR pump seal cavity. At approximately 1120 EDT, the RR pump seal drain valves were successfully closed and the OPDRV was terminated.

The RR pump seal drain flow was approximately 12 gallons per minute and lasted for approximately 84 minutes. Reactor cavity water level and spent fuel pool level remained constant throughout the OPDRV. Personnel who developed the STR failed to recognize that the activity would result in an OPDRV and; therefore, did not require that Secondary Containment be Operable in accordance with Technical Specifications. The event was entered into the corrective action program. This Licensee Event Report is written in accordance with 10CFR50.73(a)(2)(v)(C) and 50.73(a)(2)(i)(B).

NRC FORM 366 (11-2015)

Page 2 of 3U.S. NUCLEAR REGULATORY COMMISSION (11-2015)

LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET

3. LER NUMBER YEAR SEQUENTIAL REV Fermi 2 05000-341 NUMBER NO.

Fernu 2 41 2015 0

Initial Plant Conditions

Mode: 5 Reactor Power: 0 percent Description of the Event On October 4, 2015 at approximately 0956 EDT, an Operation with the Potential to Drain the Reactor Vessel (OPDRV) was unintentionally initiated without secondary containment [NH] operable. Plant personnel were starting work to isolate the Reactor Recirculation (RR) [AD] pump seal flow switch and rotameter for replacement. The RR pump seal cavity drain [DRN] valves were opened in accordance with the Safety Tagging Record (STR). Shortly after the valves were opened, the Control Room staff identified a lowering Fuel Pool Skimmer Surge Tank [TK] level and an increase in Drywell Floor drain sump level and initiated actions to isolate the RR pump seal cavity. At approximately 1120 EDT, the RR pump seal drain valves [V] were successfully closed and the OPDRV was terminated. The RR pump seal drain flow was approximately 12 gallons per minute and lasted for approximately 84 minutes. The Reactor Pressure Vessel (RPV) level was maintained by Control Rod Drive (CRD) [AA] flow. This event occurred during the 17 th refueling outage (RF 17) with the reactor cavity flooded up and fuel pool gates removed. Reactor cavity water level and spent fuel pool level remained constant throughout the OPDRV evolution without Secondary Containment being operable.

This event (No. 51449) was reported in accordance with 10CFR50.72(b)(3)(v)(C) as an eight hour non-emergency report to the NRC Operations Center. The criterion used for the report was any event or condition that at the time of discovery could have prevented the fulfillment of the safety function of structures or systems that are needed to control the release of radioactive material. This Licensee Event Report is written in accordance with 10CFR50.73(a)(2)(v)(C).

The NRC issued Enforcement Guidance Memorandum (EGM) 11-003 to provide guidance on how to disposition boiling water reactor licensee noncompliance with Technical Specifications (TS) containment requirements during OPDRV operations; however, at the time of this event, the EGM was not invoked and the OPDRV was not recognized until the Control Room staff identified a lowering Fuel Pool Skimmer Surge Tank level and increase in Drywell Floor drain sump level. This LER is also written in accordance with 1 OCFR50.73(a)(2)(i)

(B), as an operation or condition which was prohibited by plant TS. Secondary Containment was required in Mode 5, Refueling, during OPDRV.

Significant Safety Consequences and Implications

There were no safety consequences during this OPDRV activity. Evaluation of the OPDRV activity determined that the time to drain down the RPV to the top of the RPV flange was greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with no make-up.

At the time of the event, the mitigating measures of EGM 11-003 were met by the practices and processes in place for the Refueling Outage defense in depth measures.

Page 3 of 3U.S. NUCLEAR REGULATORY COMMISSION (11-2015)

LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET

3. LER NUMBER YEAR SEQUENTIAL REV Fermi 2 050-341 7

50 NUMBER NO.

All Control Rods were inserted with one Rod interlock operable. Division I of the Residual Heat Removal system was operating in Shutdown Cooling for decay heat removal. Division I Core Spray and Condensate Make-up to the Fuel Pool Skimmer Surge Tank were available to add inventory. On site and off site electrical systems were also operable.

Cause of the Event

Investigation determined that the tag out (STR) configuration established for the maintenance activity did not include closing the RR pump suction or discharge valves which resulted in the RR loop being in direct communication with the reactor coolant system.

The Apparent Cause of the event was that lack of self-checking resulted in OPDRVs, or the potential for OPDRVs, for systems that interface with the RPV coolant system, not being identified during the preparation and review of the STR.

Corrective Actions

The event was entered into the Corrective Action Program and an Operations Department standdown was performed.

The list of valves that have the potential to create an OPDRV condition was enhanced to include boundary isolation valves. The list will be utilized to ensure appropriate controls are established for STR development and review.

The remaining RF17 STRs for systems that interface with the RPV coolant system were reviewed to ensure appropriate configuration control. There were no OPDRV vulnerabilities identified.

A Shift Manager review and authorization of all RF17 manipulations associated with systems interfacing with the RPV coolant system was added to existing processes. This review will validate that isolation boundaries will be established prior to opening of vent and drain valves. Operations Department Expectations documents, Conduct Manual and Operator Training will be revised to incorporate those requirements.

Additional Information

A. Failed Components: None B. Previous LERs for Similar Events: None.