Event Notification Report for November 02, 2016

SWITCHGEAR CABINET DESIGN MODIFICATION REQUIRED

"In accordance with 10CFR52.99(c)(2), V.C. Summer Units 2 and 3 Construction is making this notification to NRC for determining that Inspection, Test, Analysis, and Acceptance Criteria (ITAAC) 2.6.01.02.ii (Seismic Qualification of Reactor Coolant Pump Switchgear) for both units requires additional actions to restore its completed status. The Closure Notification for this ITAAC (NRC Index No. 580) was originally submitted on February 29, 2016 (reference ML16060A344 and ML16060A345).

"On November 2, 2016, it was determined that modifications to the RCP switchgear cabinet design were required to ensure compliance with the applicable portions of IEEE 384, Standard Criteria for Independence of Class 1E Equipment and Circuits. The modification involved an engineering change which adds different equipment to the RCP Switchgear cabinet which function to trip the RCP. The new components were not previously seismically qualified for use in the RCP switchgear cabinet assembly. The additional components have now undergone seismic qualification testing for use in the RCP switchgear. The Equipment Qualification Data Package and Equipment Qualification Summary Report for the RCP switchgear will be revised based on the results of the testing to confirm the switchgear withstands seismic design basis loads. The revised testing report has been completed on November 8 2016."

The licensee notified the NRC Resident Inspector.

AGREEMENT STATE REPORT - RADIOGRAPHY CAMERA SOURCE DID NOT RETRACT CAUSING DOSIMETER ALARM

The following report was received from the Texas Department of State Health Services via email:

"On November 3, 2016, the Agency [Texas Department of State Health Services] was contacted by the licensee's radiation safety officer (RSO). The RSO was reporting that two radiographers had experienced a radiation dose causing pocket dosimeters to go off scale. The crew were working at a temp job site on a power plant. The camera had a 36 curie Ir-192 source. The crew could not hear the alarming rate meters due to excessive noise. The radiographers noticed the source had not retracted completely into the camera while trying to disconnect the guide tube to move the camera to another location. The radiographer reported to the RSO that the source was retracted immediately after finding the source extended. The time reported to the RSO with the source exposing the radiographer was less than 3 minutes. The pocket dosimeters were checked outside the area and found off scale. The RSO stopped all work, requested radiographers return to the shop and he checked the camera to find no defects. The RSO has sent the monitoring badges in for processing and is in the process of completing an investigation to determine exposure dose. A complete report will be provided by the RSO. Updates will be provided in accordance with SA 300 guidelines."

Texas Incident #: I 9437

* * * UPDATE FROM IRENE CASARES TO JOHN SHOEMAKER AT 1613 EST ON 12/13/16 * * *

"On November 3, 2016, the Agency received a call stating that a radiography crew had experienced an incident on November 2, 2016. The crew had been working at a Power Plant near Franklin, Texas when they experienced an incident involving a possible overexposure. The radiographers were working in a noisy area with all monitoring devices on their person. They had performed several exposure shots and were completing the last shot on a pipe before moving the camera to the next weld area. The radiographer had cranked in the source and both walked to the weld to discuss the next shot position. They were about five feet from the camera and behind the camera which was partially shielded by conduit and piping. Then one radiographer walked to the camera and using the quick disconnect, disconnected the guide tube. When he did this he noticed he source protruding from the camera about six inches and yelled at the other radiographer to get back away from the area. Both ran to the crank, one grabbed the survey meter and the other then cranked in the source, about a turn and half on the crank to secure the source in the camera. The source was in the camera. Both checked their alarming rate meters which were alarming and the pocket dosimeters were off scale. They called the RSO and then packed up their equipment for the day. An incident report was completed at the power plant before leaving the site. Once back at the radiography headquarters the badges were collected and mailed for processing. Both radiographers were interviewed by the RSO and then suspended until monitoring results were received. The RSO calculated the dose to be 1593 mrem for the one radiographer's hand dose.

"Monitoring badge results were reported to the Agency on November 10, 2016, with a whole body dose of 309 mrem and a whole body dose of 317 mrem. The annual dose for both radiographers was provided with results of 2053 mrem and 2761 mrem. The November badges had been worn for two days when the incident occurred.

"A re-enactment investigation was conducted on November 29, 2016, due to limited details on the report provided by the RSO and the calculations appeared to be short in dose. The investigation and interviews with the radiographers on November 29, 2016, revealed the dose to the hand, foot, gonads, knee, and whole body were slightly higher dose but still under the limits for an overexposure. We had calculated the dose to the hand to be approximately 29 rem instead of 15.9 rem reported by the RSO. The distance of the hand dose was provide by the RSO at 4 inches, during the re- enactment, a smaller distance of one half inch during the time the radiographer removed the guide tube was more accurate. His hand passed directly over the source when he pulled the guide tube over the source when it was extended from the camera. The shorter distance increased the dose, however was still under the 50 rem limit for an overexposure. The radiographer has not experienced any redness, blisters or soreness to his hand. He has been viewing his hands daily and has not notice any radiation burn or injury. During the investigation his hands were viewed and no noticeable damage was seen (26 days after the incident).

"The cause of the incident was not retracting the source completely into the shielded position and not using a survey meter to ensure the source was shielded. The two radiographers had changed positions during this job. One usually worked the crank and the other collected the film. Neither radiographer heard the alarms on the rate meters due to the noise. Both radiographers commented during the investigation, that they weren't using the meter like they should and it was their fault for not doing the required survey. Violations were cited to company and radiographers."

Notified R4DO (Kellar) and NMSS Events Notification via email.

* * * RETRACTION FROM IRENE CASARES TO VINCE KLCO ON 4/10/17 AT 1253 EDT * * *

The following information was received from the State of Texas via email:

"[The Texas Department of State Health Services] would like to retract NRC event number 52345. At the initial reporting from the regulated entity, it was believed two radiographers had received an overexposure from a non-retractable source. After further investigation, it was not a non-retractable source, such as equipment failure. It was human error and the source was retracted by the radiographer. There was no equipment failure. It was operator error and the dose that both radiographers received was not over the reporting limits. Please retract this event.

"Summary:
On November 3, 2016, the Agency was contacted by the licensee's radiation safety officer (RSO). The RSO was reporting that two radiographers had experienced a radiation dose causing pocket dosimeters to go off scale. The crew were working at a temp job site on a power plant. The device was a Spec 150, serial 1500, Spec source G60, serial XG2601 with of Ir-192 with 36 curies of activity. The monitoring badges were sent for processing with results of 317 and 309 mrem doses. The annual dose for both radiographers was below the 5 rem limit. The calculations for the extremity dose (hand, foot, and knee) were below the 50 rem overexposure limit. The annual dose for both radiographers was provided with results of 2053 mrem and 2761 mrem. A re-enactment investigation was conducted on November 29, 2016 due to limited details provided by the RSO. The dose was calculated at 29 rem to the extremities which is under the limit 50 rem for reportable event. The cause of the incident was not retracting the source completely into the shielded position and not using a survey meter to ensure the source was shielded. To prevent recurrence, the company had a meeting (training) with employees stressing the importance of safety, following procedures, and being aware of surroundings. One violation cited to the company and each radiographer."

Notified the R4DO (Kramer) and NMSS Events Notification via email

UNANALYZED CONDITION FOR CONTROL ROD DROP ACCIDENT AT LOW POWER

"On November 2, 2016, while performing a re-evaluation of the radiological consequences of the Fermi 2 control rod drop accident (CRDA), DTE Electric Company (DTE) identified a non-conservatism in the current Fermi 2 design and licensing basis of the CRDA. As described in the Updated Final Safety Analysis Report (UFSAR) Section 15.4.9, the current design and licensing basis assumes that the post-CRDA release pathway consists of carryover with steam to the turbine condenser. The re-evaluation has identified that a forced release from the gland seal exhausters (GSEs) could also occur which could result in post-CRDA radiological consequences that exceed the current 10 CFR 100.11 offsite dose limits and Standard Review Plan 6.4 (General Design Criterion 19) main control room dose limits when operating at low power conditions.

"The unanalyzed condition described above only applies to low power operating conditions (i.e. less than 10% power) since the fuel damage postulated as a result of a CRDA is only credible under low power operating conditions when an individual control rod worth is high. Fermi 2 is currently at 97% power and, therefore, the plant condition is currently bounded by the design and licensing basis such that the condition currently does not exist and no immediate actions are required.

"However, Fermi 2 has operated at low power levels several times in the past three years. Those periods of operation at low power represent unanalyzed conditions that significantly degraded plant safety since the occurrence of a CRDA during those periods could have resulted in offsite and main control room doses exceeding regulatory limits. Therefore, this 8-hour notification is being reported in accordance with 10 CFR 50.72(b)(3)(ii)(B). There was no adverse impact to public health and safety or to plant employees.

"The licensee has notified the NRC Resident Inspector."

RESIDUAL HEAT REMOVAL VALVE INOPERABLE FOR CONTAINMENT ISOLATION

"During panel walkdown, it was discovered that a tag out for the 'C' Residual Heat Removal pump suction valve was active and the valve was open with its breaker open. This rendered the valve inoperable and Technical Specification 3.6.1.3 Action C for penetration with one inoperable PCIVs was entered. The action was to isolate the penetration by closing the valve within (4) hours or restore power. The event was discovered at 0845 [EDT] and the breaker was closed at 0925 [EDT]. Technical Specification 3.6.1.3 Action C (Isolate penetration within 4 hrs.) was entered at 0130 [EDT] (time breaker was opened per tagout) and exited at 0925 [EDT]. This condition of non-compliance existed from 0530 [EDT] on 11/02/16 until 0925 [EDT] on 11/02/16. This event is being reported under 10CFR50.72 (b)(3)(v)(C).

"NRC Resident has been notified."

* * * RETRACTION AT 1653 EST ON 1/3/2017 FROM MARK HAWES TO MARK ABRAMOVITZ * * *

"In accordance with Technical Specification (TS) 3.6.1.3, Primary Containment Isolation Valves, the TS Basis states that one or more barriers are provided for each penetration so that no single credible failure or malfunction of an active component can result in a loss of isolation or leakage that exceeds limits assumed in the safety analyses. When two or more barriers are provided, one of these barriers may be a closed system.

"During this event, one of the barriers in the penetration became inoperable: 'C' Residual Heat Removal (RHR) pump suction valve 10MOV-13C. After the initial NRC notification, it was confirmed that the RHR system piping is classified as a closed system outside containment. The integrity of the closed-loop RHR system is verified by monitoring the keep-full system. Since the piping is maintained full of water during normal and post-accident modes of operation, a barrier against post-accident, gaseous, containment leakage is provided. Therefore, the affected penetration could have performed its intended safety function since there was redundant equipment in the same system which was operable. This event is not reportable under 10 CFR 50.72(b)(3)(v)(C) and the original notification may be retracted.

"Finally, the primary containment penetration with 10MOV-13C is with a closed system and the completion time per TS 3.6.1.3 Required Action C is 72 hours. The valve was restored to operable prior to exceeding this time."

The licensee notified the NRC Resident Inspector.

Notified the R1DO (Dentel).

PART 21 - POTENTIAL TRANSDUCER COMPONENT DEFECT

The following information was received via fax:

"The ITT Conoflow models GT25CA1826 and GT25CD1826 current to pressure (l/P) transducers produce a calibrated 3.0 to 15.0 psi output pressure from a 4.0 to 20.0 mA DC (input) signal. On November 2, 2016, a discovery was made of unqualified electrical component substitutions on the internal circuit board. Supplier and internal record reviews indicate these unqualified components were used as early as May 10, 2013, as the previously qualified PCB components are no longer available. Environmental qualification of the suspect circuit boards is planned for early 2017. If any component falls to meet requirements, nuclear facilities which use this product will be advised to examine their product for unqualified printed circuit boards via notification and visual references. Qualified replacement components will be provided to all affected customers.

"Customer Name / Item Number / No.: Units
Calvert Cliffs Nuclear / GT25CD1826 / 30
Control Components Inc. / GT2SCD 1826 / 3
Duke Energy Carolinas LLC / GT25CA1826 / 8
Duke Energy Carolinas LLC / GTI:SCD1826 / 4
Enertech Curtiss-Wright / GT25CA1816 / 19
Enertech Curtiss-Wright / GT25CD1826 / 4
Ergytech Inc. / GT25CA1826 / 3
Ergytech Inc. / GT25CD1826 / 3
Gefran Benelux NV / GT25CD1826 / 2
Ontario Power Generation / GT25CD1826 / 31
SPX Flow Technology / GT25CA1826 / 2
Weir Valves & Controls UK / GT25CA1826 / 78"

* * * UPDATE ON 2/28/17 AT 0918 EST FROM RAY SMITH TO DONG PARK VIA FAX* * *

"On November 2, 2016 a discovery was made of unqualified electrical component substitutions on the internal circuit board. Supplier and internal record reviews indicate these unqualified components were used as early as May 10, 2013, as the previously qualified PCB components are no longer available. Environmental qualification of test samples containing the suspect circuit boards has been completed. The subject parts continued to operate and perform their intended safety function throughout all EQ [Equipment Qualification] tests."

Notified R1DO (DeFrancisco), R2DO (Bartley), R3DO (Jeffers), R4DO(Deese), NMSS Events Resource, and Part 21 Group via email.