05000244/LER-2013-001, For R.E. Ginna Nuclear Power Plant, Regarding Unanalyzed Condition Due to Missing Barrier

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For R.E. Ginna Nuclear Power Plant, Regarding Unanalyzed Condition Due to Missing Barrier
ML13157A045
Person / Time
Site: Ginna 
Issue date: 05/31/2013
From: Dean E
Constellation Energy Group, EDF Group, Ginna
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
LER 13-001-00
Download: ML13157A045 (6)


LER-2013-001, For R.E. Ginna Nuclear Power Plant, Regarding Unanalyzed Condition Due to Missing Barrier
Event date:
Report date:
Reporting criterion: 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

10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
2442013001R00 - NRC Website

text

Sonny Dean Plant General Manager CENG.

a joint venture of cntertv io eDF R.E. Ginna Nuclear Power Plant, LLC 1503 Lake Road Ontario, New York 14519-9364 585.771.5205 585.771.3943 Fax sonny.dean(,cenqlic.com R.E. GINNA NUCLEAR POWER PLANT May 31, 2013 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION:

SUBJECT:

Document Control Desk R.E. Ginna Nuclear Power Plant Docket No. 50-244 LER 2013-001, Unanalyzed Condition Due to Missing Barrier The attached Licensee Event Report (LER) 2013-001 is submitted under the provisions of NUREG-1022, Event Reporting Guidelines. There are no new commitments contained in this submittal. Should you have any questions regarding the information in this letter, please contact Mr. Thomas Harding at (585) 771-5219.

Very truly yours, Edwin D. Dean III Attachments: (1) LER 2013-001 cc:

W.M. Dean, NRC M.C. Thadani, NRC Resident Inspector, NRC (Ginna) toPL-iVkc- -/00A2 70-7

ATTACHMENT 1 LER 2013-001

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2013 (10-2010) the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

1. FACILITY NAME R.E. Ginna Nuclear Power Plant
2. DOCKET NUMBER
3. PAGE 1 05000 244 1 OF 4
4. TITLE Unanalyzed Condition Due to Missing Barrier
5. EVENT DATE
6. LER NUMBER
7. REPORT DATE
8. OTHER FACILITIES INVOLVED SEQUENTIAL FACILITY NAME DOCKET NUMBER MONTH DAY YEAR YEAR NUMBER REV MONTH DAY YEAR 05000 FACILITY NAME DOCKET NUMBER 04 12 2013 2013-001
- 0 05 31 2013 05000
9. OPERATING MODE
11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR§: (Check all that apply)

El 20.2201(b)

[I 20.2203(a)(3)(i) 0l 50.73(a)(2)(i)(C)

El 50.73(a)(2)(vii) 1E 20.2201(d)

El 20.2203(a)(3)(ii)

[I 50.73(a)(2)(ii)(A)

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

El 20.2203(a)(1)

[1 20.2203(a)(4)

ED 50.73(a)(2)(ii)(B)

El 50.73(a)(2)(viii)(B)

El 20.2203(a)(2)(i)

El 50.36(c)(1)(i)(A)

[I 50.73(a)(2)(iii)

El 50.73(a)(2)(ix)(A)

10. POWER LEVEL El 20.2203(a)(2)(ii)

El 50.36(c)(1)(ii)(A)

[I 50.73(a)(2)(iv)(A)

El 50.73(a)(2)(x)

El 20.2203(a)(2)(iii)

El 50.36(c)(2)

El 50.73(a)(2)(v)(A)

El 73.71(a)(4)

El 20.2203(a)(2)(iv)

El 50.46(a)(3)(ii)

El 50.73(a)(2)(v)(B)

El 73.71(a)(5) 100%

El 20.2203(a)(2)(v)

El 50.73(a)(2)(i)(A)

El 50.73(a)(2)(v)(C)

El OTHER El 20.2203(a)(2)(vi)

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

[E 50.73(a)(2)(v)(D)

Specify in Abstract below or in NRC Form 366A

12. LICENSEE CONTACT FOR THIS LER FACILITY NAME TELEPHONE NUMBER (include Area Code)

Thomas Harding, Licensing Director (585) 771-5219MANU-REPORTABLE C

MANU-REPORTABLE

CAUSE

SYSTEM COMPONENT FACTURER TO EPIX C

FACTURER TO EPIX

14. SUPPLEMENTAL REPORT EXPECTED
15. EXPECTED MONTH DAY YEAR SUBMISSION El YES (If yes, complete 15. EXPECTED SUBMISSION DATE) 0 NO DATE ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)

On April 12, 2013, a system engineer performing a walkdown of backflow prevention devices discovered that the check valve that was expected to be found installed in a floor drain in the Intermediate Building Basement had been removed. The check valve was designed as a barrier to prevent the flow of flammable liquid from the Turbine Building Basement to the Intermediate Building Basement where safe shutdown equipment is located.

In accordance with the Technical Requirements Manual (TRM), immediate compensatory actions were initiated. These actions were a fire detector operability verification and an hourly fire watch inspection.

Additionally, a plug was installed in the floor drain to prevent the backflow of flammable liquid.

The apparent cause of this event is removal of the check valve due to housekeeping issues because it would not allow water to pass due to the unique design of the valve. The check valve appears to have been removed at some point in the past to prevent water accumulation in the floor drain without sufficient review of the impact. This event was entered into the Station's Corrective Action Program and a plant modification will be performed to replace the valve, addressing the original design deficiencies.

NRC FORM 366 (10-2010)

1.

DESCRIPTION OF EVENT

A. PRE-EVENT PLANT CONDITIONS:

The reactor was in Operational Mode 1 at 100% power, 2235 psig and 574 degrees F.

B. EVENT:

On April 12, 2013, a system engineer performing a walkdown of backflow prevention devices discovered that the check valve that was expected to be found installed in the floor drain in the Intermediate Building Basement had been removed. The check valve was designed as a barrier to prevent the flow of flammable liquid from the Turbine Building Basement to the Intermediate Building Basement where safe shutdown equipment is located.

C. INOPERABLE STRUCTURES, COMPONENTS OR SYSTEMS THAT CONTRIBUTED TO THE EVENT:

No other inoperable structures, systems, or components contributed to the event. The only issue was the removal of the check valve in the floor drain between Turbine and Intermediate Buildings.

D. DATES AND APPROXIMATE TIMES OF MAJOR OCCURRENCES

April 12, 2013, 1010 Engineering personnel discover that a check valve in a floor drain between the Turbine and Intermediate Buildings is no longer installed.

April 12, 2013, 1100 Compensatory actions initiated - fire detector operability verification and an hourly fire watch inspection.

April 12, 2013, 1445 Notification of Unanalyzed Condition, event # 48918 under 10 CFR 50.72(b)(3)(ii)(B).

April 12, 2013, 1500 Plug installed in drain line as compensatory action to prevent flammable liquid from flowing from Turbine to Intermediate Building.

E. OTHER SYSTEMS OR SECONDARY FUNCTIONS AFFECTED

None

F. METHOD OF DISCOVERY

Discovered by system engineer walking down backflow prevention devices.U.S. NUCLEAR REGULATORY COMMISSION (10-2010)

LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET

1. FACILITY NAME
2. DOCKET
6. LER NUMBER
3. PAGE SEQUENTIAL REV R.E. Ginna Nuclear Power Plant 05000244 YEAR NUMBER NO.

3 OF 4 2013 001 0

G. MAJOR OPERATOR ACTION:

On-shift Operations Crew initiated a fire detector operability verification and an hourly fire watch inspection as compensatory actions in accordance with TRM.

H. SAFETY SYSTEM RESPONSES:

None I1. CAUSE OF EVENT:

A review of past maintenance history identified that blockage of this line was a concern and a design review identified that the valve type required a significant amount of water to pass flow. Normal or expected water accumulation would not have passed through the check valve, creating a housekeeping concern. Based on the historical information available, it is concluded that the check valve was most likely removed to prevent water accumulation, without sufficient review of the impact on the design or licensing basis. This condition has been evaluated in the site corrective action program. (CR-2013-002437)

III ANALYSIS OF THE EVENT:

This event is reportable under 10CFR50.73(a)(2)(ii)(B), operation in an unanalyzed condition. This check valve is considered a barrier between the Turbine Building and the Intermediate Building. It connects a floor drain from a safety-related area to a sump in an area that contains a large quantity of potentially flammable liquid, i.e. the turbine lube-oil system. A backflow prevention device is required to prevent possible spread of a liquid fire via the drain system. The Ginna Fire Protection Program does not analyze for simultaneous fires in two or more fire areas. Therefore, this condition is reportable under the above criteria.

The effect of flooding has been evaluated and is not considered to be a concern with the missing check valve or with the floor drain plugged.

There were no safety consequences as all safety related systems remained operable during this event.

IV. CORRECTIVE ACTIONS

A. ACTION TAKEN TO RETURN AFFECTED SYSTEMS TO PRE-EVENT NORMAL STATUS:

A temporary plug was installed in the affected floor drain to prevent the back flow of flammable liquids from the Turbine Building to the Intermediate Building. This configuration was evaluated to ensure there was no adverse impact on flood mitigation. A replacement valve could not be readily installed.U.S. NUCLEAR REGULATORY COMMISSION (10-2010)

LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET

1. FACILITY NAME
2. DOCKET
6. LER NUMBER
3. PAGE SEQUENTIAL REV R.E. Ginna Nuclear Power Plant 05000244 YEAR NUMBER NO.

4 OF 4 2013 001 0

B. ACTION TAKEN OR PLANNED TO PREVENT RECURRENCE A plant modification is planned to replace the check valve. This valve will receive an equipment identification number and be entered into the configuration management system.

An extent of condition review has been performed and all accessible check valves have been inspected, with no concerns identified. Inaccessible check valves in containment have been scheduled for inspection at the next available opportunity.

V. ADDITIONAL INFORMATION

A.

FAILED COMPONENT No components failed.

B.

PREVIOUS LERS ON SIMILAR EVENTS A review of Ginna events over the past five years identified no similar events.