05000285/LER-2012-005-01, Regarding Technical Specification Violation Due to Inadequate Testing of Emergency Diesel Fuel Pumps

Regarding Technical Specification Violation Due to Inadequate Testing of Emergency Diesel Fuel Pumps

ML12157A127
Person / Time
Site:	Fort Calhoun
Issue date:	06/01/2012
From:	Goodell J Omaha Public Power District
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
LlC-12-0072 LER 12-005-01
Download: ML12157A127 (7)

LER-2012-005, Regarding Technical Specification Violation Due to Inadequate Testing of Emergency Diesel Fuel Pumps

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i)(8) 10 CFR 50.73(a)(2)(ii)(8) 10 CFR 50.73(a)(2)(v)(8) 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i) 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 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
2852012005R01 - NRC Website

text

L'lC-12-0072 June 1,2012 u.s. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Reference: Docket No. 50-285

Subject:

Licensee Event Report 2012-005, Revision 1, for the Fort Calhoun Station Please find attached Licensee Event Report 2012-005, Revision 1, dated June 1,2012.

This report is being submitted pursuant to 10 CFR 50.73(a)(2)(i)(8), 50.73(a)(2)(ii)(8),

50.73(a)(2)(v)(8) and (D), and 50.73(a)(2)(vii). If you shoul:d have any questions, please contact me.

The followin9' commitments are being made in this letter.

1. Prior to plant restart, the Emergency Diesel Generator (EDG) surveillance tests will be revised to perform a test of the fuel oil transfer pumps ensuring auto operation is verified on a monthly basis. This is an ongoing commitment.

2. Prior to plant restart, the EDG design basis document will be updated to include verification information for the diesel generator fuel oil transfer pumps. This is a one-time commitment.

Sincerely:,;

/

xf:~

I Division Manager Nuclear Perform Improvement & Support JDG/sds/epm Attachment c:

E. E. Collins, Jr., NRC Regional Administrator, Region IV l. E. Wilkins, NRC Project Manager J. C. Kirkland, NRC Senior Resident Inspector INPO Records Center NRC FORM 366 (10-2010)

NRC FORM 366 (10-2010)

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION (10-2010)

LICENSEE EVENT REPORT (LER)

(See reverse for required number of digits/characters for each block)

APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2013

, the NRC may not conduct or sp onsor, and a person is not required to respond to, th e

information collection.

1. FACILITY NAME Fort Calhoun Station

2. DOCKET NUMBER 05000285

3. PAGE 1 OF 4

4. TITLE Technical Specification Violation Due to Inadequate Testing of Emergency Diesel Fuel Pumps

5. EVENT DATE

6. LER NUMBER

7. REPORT DATE

8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR SEQUENTIAL NUMBER REV NO.

MONTH DAY YEAR FACILITY NAME DOCKET NUMBER 05000 02 21 2012 2012 - 005 -

1 06 01 2012 FACILITY NAME DOCKET NUMBER 05000

9. OPERATING MODE 5

11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply) 20.2201(b) 20.2203(a)(3)(i) 50.73(a)(2)(i)(C) 50.73(a)(2)(vii) 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) 50.36(c)(1)(i)(A) 50.73(a)(2)(iii) 50.73(a)(2)(ix)(A) 20.2203(a)(2)(ii) 50.36(c)(1)(ii)(A) 50.73(a)(2)(iv)(A) 50.73(a)(2)(x) 20.2203(a)(2)(iii) 50.36(c)(2) 50.73(a)(2)(v)(A) 73.71(a)(4) 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)

OTHER 20.2203(a)(2)(vi) 50.73(a)(2)(i)(B) 50.73(a)(2)(v)(D)

Specify in Abstract below or in LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET CONCLUSION Prior to 1989, fuel oil transfer pump testing was included in the EDG surveillance procedures. The cause evaluation identified that the specific procedure steps to test the automatic start of the fuel oil transfer pumps on low level was removed by a procedure revision made in May 1990. Fuel oil transfer pump trip on high level remained in the procedure. The procedure change was prompted by a modification that replaced the fuel transfer pumps and added pressure gauges and flow rate meters.

Other procedure changes not pertinent to the modification were made at the same time. The additional changes included fully removing steps to place the fuel oil transfer pump transfer switches in AUTO for the purpose of testing. By operating the fuel oil transfer pumps in HAND, the length of the monthly EDG run would be shortened. The procedure revision summary did not provide discussion on the changes made beyond the scope of the modification. The FCS EDG configuration results in unavailability hours under the maintenance rule during surveillance testing, so reducing EDG run time would reduce unavailability time. The change was made 22 years ago, making it very difficult to reconstruct thoughts and discussions surrounding the procedure change. Clearly, there was a lack of understanding surrounding the purpose of the testing of the auto start feature of the fuel oil transfer pump, but there is no indication that the change was made to violate or circumvent TS requirements.

Several historical organizational and/or programmatic defenses may have failed. The procedure revision process used in the 1990s did not have the technical rigor that is currently employed at FCS.

In addition, the surveillance test program does not clearly link surveillance requirements to specific surveillance tests. Furthermore, the design basis document for the EDGs does not currently contain sufficient information on fuel oil transfer pump testing and verification.

The procedure changes made in 1990 removed the test of the automatic start of the fuel oil transfer pumps on low level in the EDG day tank. Without full testing of the automatic functions of the fuel oil transfer pumps, they cannot be considered operable. Consequently, the EDGs cannot be considered operable because all auxiliary equipment to support operability has not demonstrated that it is fully capable of performing its safety function.

The apparent cause of this event is a lack of technical rigor in the procedure change process employed in the 1990s.

Contributing causes are a lack of documentation indicating which surveillance tests satisfy specific technical specification surveillance requirements, and a lack of design basis information on verification methods for the fuel oil transfer pumps.

LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET

CORRECTIVE ACTIONS

1. Prior to plant restart, the Emergency Diesel Generator (EDG) surveillance tests will be revised to perform a test of the fuel oil transfer pumps ensuring auto operation is verified on a monthly basis.

This is an ongoing commitment.

2. Prior to plant restart, the EDG design basis document will be updated to include verification information for the diesel generator fuel oil transfer pumps. This is a one-time commitment.

SAFETY SIGNIFICANCE

Failure to fully test the automatic functions of the fuel oil transfer pumps renders the pumps inoperable. Therefore, consistent with the definition of OPERABLE, the EDGs cannot be considered operable as they rely upon the fuel oil transfer pumps to ensure an adequate fuel supply when the EDGs are performing their safety function. The EDGs have been technically inoperable in excess of TS allowed times. However, there is reasonable assurance that the EDGs and fuel transfer pumps would function as required as the low level switches are calibrated on a refueling frequency.

SAFETY SYSTEM FUNCTIONAL FAILURE This event does result in a safety system functional failure in accordance with NEI-99-02.

PREVIOUS EVENTS No previous events of a similar nature have been identified.

FORT CALHOUN STATION NOD-QP-9.2 QUALITY PROCEDURE FORM R0 LICENSING CORRESPONDENCE REVIEW FORM LIC-12-0072 Date Issued: 5/23/12 Requested Return Date:____5/25/12______

Review/Approval Information Susan Baughn Dave Bannister John Herman Woody Goodell Steve Miller Brad Blome Mike Smith Mike Prospero Corey Cameron Scott Pallas Kevin Naser Subject___ LER 2012-005 Rev 1 TS violation due to inadequate testing of DG fuel pumps Please review and approve the attached draft correspondenc e (referenced above). In order to document your review for our records, please sign this form and return it to the Licensing Coordinator. If n o notification is received by the requested return date, your concurrence with no comment will be assumed.

Erick Matzke/Sue Simpson 6855 Technical Coordinator (Ext.) Licensing Coordinator (Ext.)

[ ] Approved with no comment. [ ] Approved pending resolution of comments as noted.

Comments:_______________________________________________________________________________

Reviewer's Signature Date

FORT CALHOUN STATION NOD-QP-9.2 QUALITY PROCEDURE FORM R0 LICENSING CORRESPONDENCE REVIEW FORM SUMMARY LIC-12-0072 Date Issued: 5/23/12 Requested Return Date: 5/25/12 Name Date Comments Received No Comments1 Comments - How Resolved2 Susan Baughn 5/23/12 Corrected John Herman none Steve Miller 5/27/12 X

Mike Smith none Corey Cameron 5/31/12 Corrected G. Papanic 5/24/12 Corrected Kevin Naser none Dave Bannister none Woody Goodell none Brad Blome none Mike Prospero none M. Cooper 5/31/12 Corrected M. Edwards 5/31/12 Corrected Subject: LER 2012-005 Rev 1 Failure to Perform Monthly EDG Fuel Oil Transfer Auto Test NOTE - This submittal does ____ does not __X__ include documents/files on CD-ROM.3 NL Comment Coordinator Signature Date Responsible Dept. Manager (if required)

Date Review by Nuclear Licensing Supervisor Date 1 Attach only signed Licensing Correspondence Review Form.

2 Attach necessary documentation.

3 Ensure that the CD-ROM files are formatted properly for electronic information exchange (EIE) to the NRC. (Reference NL-17)