05000286/LER-2012-003, Regarding Technical Specification Prohibited Condition Due to a Pressurizer Safety Valve Discovered Outside Its As- Found Lift Set Point Test Acceptance Criteria

Regarding Technical Specification Prohibited Condition Due to a Pressurizer Safety Valve Discovered Outside Its As- Found Lift Set Point Test Acceptance Criteria

ML12198A005
Person / Time
Site:	Indian Point
Issue date:	06/28/2012
From:	Ventosa J Entergy Nuclear Operations, Indian Point
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-12-095 LER 12-003-00
Download: ML12198A005 (5)

LER-2012-003, Regarding Technical Specification Prohibited Condition Due to a Pressurizer Safety Valve Discovered Outside Its As- Found Lift Set Point Test Acceptance Criteria

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(1), Submit an LER, Invalid Actuation 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
2862012003R00 - NRC Website

text

SEntergy Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, N.Y. 10511-0249 Tel (914) 254-6700 John A. Ventosa Site Vice President NL-12-095 June 28, 2012 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop O-P1-17 Washington, D.C. 20555-0001

SUBJECT:

Licensee Event Report # 2012-003-00, "Technical Specification Prohibited Condition Due to a Pressurizer Safety Valve Discovered Outside its As-Found Lift Set Point Test Acceptance Criteria" Indian Point Unit No. 3 Docket No. 50-286 DPR-64

Dear Sir or Madam:

Pursuant to 10 CFR 50.73(a)(1), Entergy Nuclear Operations Inc. (ENO) hereby provides Licensee Event Report (LER) 2012-003-00. The attached LER identifies an event where there was a Technical Specification prohibited condition for an inoperable Pressurizer Safety Valve, which is reportable under 10 CFR 50.73(a)(2)(i)(B). This condition was recorded in the Entergy Corrective Action Program as Condition Report CR-IP3-2012-01403.

There are no new commitments identified in this letter. Should you have any questions regarding this submittal, please contact Mr. Robert Walpole, Manager, Licensing at (914) 254-6710.

Sincerely, JAV/cbr cc:

Mr. William Dean, Regional Administrator, NRC Region I NRC Resident Inspector's Office, Indian Point 3 Mrs. Bridget Frymire, New York State Public Service Commission LEREvents@lNPO.org

Abstract

On May 1, 2012, Engineering was notified by Wyle Laboratories that one of three Pressurizer Code Safety Valves (RC-PCV-468) was outside its As-Found lift set point test acceptance criteria (2411 -

2559 psig).

The As-Found set pressure testing acceptance criterion for operability is 2485 psig +/-3%.

The SVs were removed during the last refueling outage (RO) in the spring of 2011 and sent offsite for testing.

Testing was performed within one year of removal as required by the Inservice Testing Program.

SV RC-PCV-468 lifted at 2617 psig which is outside its set pressure range.

The initial As-Found lift was 5.3% above the 2485 set pressure therefore, the 110% design pressure limitation provided by the ASME code was not exceeded.

The remaining two SVs both tested satisfactorily.

During the RO all three SVs were removed and replaced with certified pre-tested spare SVs.

All three SVs were found with zero seat leakage.

The SVs installed during the RO were As-Left tested to 2485 psig +/-1% with zero seat leakage in accordance with surveillance procedure 3-PT-R5A.

Technical Specification (TS) 3.4.10 (Pressurizer Safety Valves), requires three pressurizer safety valves to be operable with lift settings set at greater than 2460 psig and less than 2510 psig.

TS Surveillance Requirement (SR) 3.4.10.1 requires each PSV to be verified operable in accordance with the Inservice Testing Program.

The most probable cause of SV RC-PCV-468 lifting greater than 3% of its nominal set point was internal friction within the valve.

Corrective action will be to perform a valve disassembly and inspection to determine the cause of the failure.

The event had no effect on public health and safety.

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

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 events that required the pressurizer SVs.

An evaluation was performed on the potential impact of the condition on the accident analysis in the UFSAR and realistic plant response.

The realistic plant response to transients would not be impacted, since the pressurizer pressure control system would be available for relieving RCS pressure which includes the pressure spray valves and power operated relief valves (PORVs).

The non-Loss of Coolant Accident (non-LOCA) analyses in the UFSAR that could be impacted by the condition were: 1) Loss of load/Turbine Trip (LOL/TT),

2)

Loss of normal feedwater/loss of non-emergency AC power (LONF/LOAC),

3)

Loss of flow/locked rotor (LOF/LR),

4)

Rod withdrawal at power (RWAP).

An assessment of the impact of the condition on these non-LOCA transients concluded they are either negligible or insignificant.

Pressurizer SV RC-PCV-468 lifted at approximately 2617 psig, which is 5.31% above the nominal set point of 2485 psig.

Before RC-PCV-468 reaches its opening set point of 5.31% (2617 psig),

the other two pressurizer SVs (RC-PCV-464, RC-PCV-466) will lift at +0.32% (2493 psig) and +1.69%

(2527 psig) and relieve pressure from the RCS.

The non-LOCA UFSAR transients all conservatively assume a +4% opening set point, instead of the +/-

3% testing acceptance criterion.

A 1.31% increase in RC-PCV-468 opening set point over what was assumed in the UFSAR analysis would be compensated by approximately a 3.6% and 2.3% margin in the other two pressurizer SVs.

Thus, the UFSAR Chapter 14 analysis remains valid with the SV condition.