05000341/LER-2012-004, Regarding Operation or Condition Prohibited by Technical Specification 3.3.3.1
| ML12296A081 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 10/19/2012 |
| From: | Conner J Detroit Edison, Co, DTE Energy |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| NRC-12-0066 LER 12-004-00 | |
| Download: ML12296A081 (4) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 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)(v), Loss of Safety Function |
| 3412012004R00 - NRC Website | |
text
J. Todd Coiner Director, Nuclear Production DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.5325 Fax: 734,586.5295 Email: connert@dteenergy con DTE Energy-10 CFR 50.73 October 19, 2012 NRC-12-0066 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. 2012-004 Pursuant to 10 CFR 50.73(a)(2)(i)(B), Detroit Edison is submitting the enclosed LER No. 2012-004, Operation Prohibited by Technical Specification 3.3.3.1.
No commitments are being made in this LER.
Should you have any questions or require additional information, please contact Mr. Zackary W. Rad of my staff at (734) 586-5076.
Sincerely, Enclosure cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 4, Region III Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: No. 3150-0104 Expires 10/31/2013 (10-2010)
, the NRC may digits/characters for each block) not conduct or sponsor, and a person is not required to respond to, the information collection.
- 3. PAGE Fermi 2 05000341 1 OF 3
- 4. TITLE Operation or Condition Prohibited by Technical Specification 3.3.3.1
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED SEUNIL RVFACILITY NAME DOCKET NUMBER MONTH DAY YEAR YEAR SEQUENTIAL REV MONTH DAY YEAR 05000 NUMBER NO.
105000 08 27 2012 2012 004 00 Oct 19 2012 FACILITYNAME DOCKET NUMBER 05000
- 9. OPERATING MODE
- 11. THIS REPORT SUBMITTED PURSU ANT TO THE REQUIREMENTS OF 10 CFR§: (Check all that apply) 20.2201(b)
J 20.2203(a)(3)(i) 50.73(a)(2)(i)(C) 50.73(a)(2)(vii) 1 E 20.2201(d) 20.2203(a)(3)(ii) 50.73(a)(2)(ii)(A) 50.73(a)(2)(viii)(A) 20.2203(a)(1) 20.2203(a)(4) 50.73(a)(2)(ii)(B) 50.73(a)(2)(viii)(B) 20.2203(a)(2)(i)
E 50.36(c)(1)(i)(A)
E 50.73(a)(2)(iii) 50.73(a)(2)(ix)(A)
- 10. POWER LEVEL 20.2203(a)(2)(ii) 50.36(c)(1)(ii)(A)
E 50.73(a)(2)(iv)(A)
J 50.73(a)(2)(x) 20.2203(a)(2)(iii) 50.36(c)(2) 0 50.73(a)(2)(v)(A)
Q 73.71(a)(4) 68 Percent 0 20.2203(a)(2)(iv) 50.46(a)(3)(ii) 50.73(a)(2)(v)(B) 73.71(a)(5) 20.2203(a)(2)(v) 50.73(a)(2)(i)(A) 50.73(a)(2)(v)(C) 0 OTHER 20.2203(a)(2)(vi)
E 50.73(a)(2)(i)(B) 50.73(a)(2)(v)(D)
Specify in abstract below or in NRC Form 366A
- 12. LICENSEE CONTACT FOR THIS LER FACILITY NAME FELEPHONE NUMBER (Include Area Code)
Fermi 2 / Robert J. Salmon - Supervisor, Nuclear Compliance (734) 586 - 4273CAUSE SYSTEM COMPONENT MANU-REPORTABLE H
CAUSE
SYSTEM COMPONENT MANU-REPORTABLE FACTURER TO EPIX FACTURER TO EPIX
- 14. SUPPLEMENTAL REPORT EXPECTED
- 15. EXPECTED MONTH DAY YEAR SUBMISSION Q
YES (If yes, complete 15. EXPECTED SUBMISSION DATE)
X NO DATE ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)
During an engineering review of Environmental Qualification & Surveillance, it was discovered that the cable connector assemblies connected to position indication limit switches for % inch valve B3100-FO19, Reactor Recirculation Sample Line Inboard Isolation Valve, had exceeded their Environmentally Qualified life. On August 27, 2012 at 11:45 hours position indication for the B3100-F019 was declared inoperable. Position indication of the B3100-FO19 is required by TS 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation." EQ subject matter experts could not assure the limit switch cable connector assemblies could have endured the design basis accident, had it occurred prior to discovery. It was determined that this condition existed for greater than the allowed completion time for TS 3.3.3.1 and was therefore an operation or condition prohibited by the TS. This event posed no significant risk to the health and safety of the public. The apparent cause was a failure to require peer or subject matter expert review for translating EQ requirements into Preventative Maintenance requirements. It is planned to replace the cable connector assemblies during the next refueling outage.
NRC FORM 366 (10-20101
Initial Plant Conditions
Mode 1
Reactor Power 68 percent Description of the Event During an engineering review of Environmental Qualification & Surveillance, it was discovered that the cable connector assemblies associated with the Primary Containment Isolation Valve (PCIV) position indication limit switches for the inboard Reactor Water Sample System valve, B3 1 00-FO 19, had exceeded their Environmentally Qualified (EQ) life.
On August 27, 2012 at 11:45 hours the inboard PCIV position indication was declared inoperable.
Position indication of the B3100-F019 is required by TS 3.3.3.1, "Post Accident Monitoring (PAM)
Instrumentation," in order to verify primary containment integrity during accident situations. TS 3.3.3.1 requires two channels of PCIV position indication per primary containment penetration. This inoperability resulted in entering Condition A of TS 3.3.3.1 for one PCIV position indication out of two required channels per penetration flow path inoperable, which requires restoration of the inoperable PAM instrumentation channel to operable status within 30 days; otherwise, Condition B is entered.
Action B requires a PAM Report be submitted in accordance with TS 5.6.7 within 14 days. A PAM Report has been issued to outline the action taken, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channel.
After the condition was identified and evaluated, EQ subject matter experts could not assure the limit switch cable connector assemblies could have endured the design basis accident, had it occurred prior to discovery. It was determined that this condition existed for greater than the allowed completion time for TS 3.3.3.1 and was therefore an operation or condition prohibited by the TS.
Significant Safety Consequences and Implications
This event posed no significant risk to the health and safety of the public because position indication for B3100-F020, the outboard PCIV for this penetration, remains operable and continues to provide Environmentally Qualified (EQ) position indication and isolation capability. Additionally, both the B3100-FO19 and B3100-F020 are % inch normally closed valves receiving accident related isolation signals on low reactor water level, high drywell pressure and high main steam line radiation.
This event is being reported under 10 CFR 50.73(a)(2)(i)(B), any operation or condition prohibited by TS.U.S. NUCLEAR REGULATORY COMMISSION (10-2010)
LICENSEE EVENT REPORT (LER)
CONTINUATION SHEET
- 1. FACILITY NAME
- 2. DOCKET
- 6. LER NUMBER
- 3. PAGE YEAR SEQUENTIAL REVISION Fermi 2 05000341 2012 I
NUMBER NUMBER 3 OF 3 202 -
004 00
Cause of the Event
The requirements of an EQ Maintenance and Surveillance (M&S) program were not correctly incorporated into the technical requirements of a Preventive Maintenance (PM) Event in 1994. The PM Event basis did not address the entire boundary of the limit switch EQ in the scope of the PM event.
The direct cause of the event was a failure to provide the necessary requirements for maintaining the EQ life for the cable connector assemblies limit switches for valve B3100-FO19 in a PM event. The apparent cause was a failure to require a subject matter expert review for translating EQ requirements into the PM requirements.
Corrective Actions
This event has been entered into the Fermi 2 Corrective Action Program. The cable connector assemblies will be replaced during Refueling Outage 16 when plant conditions allow access to the primary containment, currently scheduled for the first quarter of 2014. Procedures are to be revised to include requiring a Subject Matter Expert (EQ Engineer) PM Technical Requirements and Frequency review.
A review of the full scope of the current EQ for this type of cable connector assemblies on limit switches was performed. The condition is limited to the cable connector assemblies for valve B3100-F019.
Additional corrective actions may be identified as a result of this effort.
Additional Information
A.
Failed Component: None B.
Previous Similar Events
There are no similar previous events within the past five years.