05000255/LER-2016-002, Regarding Both Control Room Ventilation Filtration Trains Declared Inoperable

Regarding Both Control Room Ventilation Filtration Trains Declared Inoperable

ML16144A686
Person / Time
Site:	Palisades
Issue date:	05/23/2015
From:	Hardy J Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PNP 2016-027 LER 16-002-00
Download: ML16144A686 (5)

LER-2016-002, Regarding Both Control Room Ventilation Filtration Trains Declared Inoperable

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(v), Loss of Safety Function 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)(i)(B), Prohibited by Technical Specifications
2552016002R00 - NRC Website

text

~Entergy PNP 2016-027 May 23,2016 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Tel 269 764 2000 Jeffery A. Hardy Director, Regulatory Assurance and Performance Improvement 10 CFR 50.73

SUBJECT:

Both Control Room Ventilation Filtration Trains Declared Inoperable Palisades Nuclear Plant Docket 50-255 License No. DPR-20

Dear Sir or Madam:

The enclosed Licensee Event Report (LER) 2016-002-00, "Both Control Room Ventilation Filtration Trains Declared Inoperable," is submitted in accordance with 10 CFR 50.73(a)(2)(v)(D).

This letter contains no new commitments and no revisions to existing commitments.

Sincerely, 9Ak\\~

JAH/tad Attachment: 2016-002-00, Both Control Room Ventilation Filtration Trains Declared Inoperable CC Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC

ATTACHMENT LER 2016-002-00 BOTH CONTROL ROOM VENTILATION FILTRATION TRAINS DECLARED INOPERABLE 3 Pages Follow

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2018 (11-2015)

/"....

, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

r' PAGE PALISADES NUCLEAR PLANT 05000255 10F3

4. TITLE Both Control Room Ventilation Filtration Trains Declared Inoperable

5. EVENT DATE

6. LER NUMBER

7. REPORT DATE

8. OTHER FACILITIES INVOLVED YEAR I SEQUENTIAL REV MONTI-FACILITY NAME DOCKET NUMBER MONTH DAY YEAR NO.

DAY YEAR 05000 NUMBER FACILITY NAME DOCKET NUMBER 03 24 2016 2016

- 002

- 00 05 23 2016 05000

9. OPERAllNG MODE

11. THIS REPORT IS SUBMITTED PURSUANTro THE REQUIREMENTS OF 10 CFR ~(Check al/ that app/YL o 20.2201 (b) o 20.2203(a)(3)(i) o 50.73(a)(2)(i)(C) o 50.73(a)(2)(vii) 1 o 20.2201(d) o 20.2203(a)(3)(ii) o 50.73(a)(2)(ii)(A) o 50.73(a)(2)(viii)(A) o 20.2203(a)(1) o 20.2203(a)(4) o 50.73(a)(2)(ii)(B) o 50.73(a)(2)(viii)(B) o 20.2203(a)(2)(i) o 50.36(c)(1)(i)(A) o 50.73(a)(2)(iii) o 50.73(a)(2)(ix)(A)

10. POWER LEVEL o 20.2203(a)(2)(ii) o 50.36(c)(1)(ii)(A) o 50.73(a)(2)(iv)(A) o 50.73(a)(2)(x) o 20.2203(a)(2)(iii) o 50.36(c)(2) o 50.73(a)(2)(v)(A) o 73.71(a)(4) o 20.2203(a)(2)(iv) o 50.46(a)(3)(ii) o 50.73(a)(2)(v)(B) o 73.71 (a)(5) 100 o 20.2203(a)(2)(v) o 50.73(a)(2)(i)(A) o 50.73(a)(2)(v)(C) o OTHER o 20.2203(a)(2)(vi) o 50.73(a)(2)(i)(B) 181 50.73(a)(2)(v)(D)

Specify in Abstract below or in NRC Form 366A

12. LICENSEE CONTACT FOR THIS LER ICENSEE CONTACT r ELEPHONE NUMER (Include Area Code)

Barb Dotson, Regulatory Assurance Manager 269-764-2265

13. COMPLETE ONE UNE FOR EACH COMPONENT FAlWRE DESCRIBED IN THIS REPORT

CAUSE

SYSTEM COMPONENT MANU*

REPORTABLE

CAUSE

SYSTEM COMPONENT MANU*

REPORTABLE FACTURER TO EPIX FACTURER TO EPIX A

VI AHU A220 Y

14. SUPPLEMENTAL REPORT EXPECTED

15. EXPECTED MONTH DAY YEAR DYES (/fyes, complete 15. EXPECTED SUBMISSION DATE)

~ NO SUBMISSION DATE f-BSTRACT (Umit to 1400 spaces, i.e., approximately 15 single-spaced typewritten Ones)

At 0211 hours0.00244 days <br />0.0586 hours <br />3.488757e-4 weeks <br />8.02855e-5 months <br /> on March 24, 2016, both control room ventilation filtration system trains were declared inoperable in accordance with Technical Specification (TS) 3.7.10, Condition B, due to the inability to fully close control room envelope (CRE) boundary door-15. Mitigating actions were implemented that ensured CRE occupant radiological exposures would not exceed limits and CRE occupants would be protected from chemical and smoke hazards. After maintenance was performed, door-15 was fully closed and both control room ventilation filtration system trains were declared operable for this condition at 1828 hours0.0212 days <br />0.508 hours <br />0.00302 weeks <br />6.95554e-4 months <br /> on March 24, 2016.

Inadvertent operation of the normal opening/closing handwheel of door -15 to the closed position, prior to the door being fully closed, caused the door's locking bolts to extend out from inside the door body to the locked closed position. This created interference between the door and the door frame that prevented the door from being closed. An interlock prevents the door's locking bolts from moving, using the normal opening/closing handwheel, when the locking bolts are extended and the door is open. Due to the lack of detail in the operating instructions posted on the door, and the personnel being unaware of the interlock, they continued to try and manipulate the locking bolts via the handwheel.

Continued operation of the handwheel, with the interlock activated, potentially caused a failure of a bushing inside the door's operating mechanism. The failed bushing prevented normal and emergency operation of the door's locking bolts.

The failed bushing inside the door's operating mechanism was replaced. Additional corrective actions include sharing lessons learned from this event, adding adequate detail to the operating instructions posted on the door, and modification to the door's preventative maintenance program to include bushing inspection and, if needed, replacement.

NRC FORM 366 (11-2015) U.S. NUCLEAR REGULATORY COMMISSION (11-2015)

~\\.

\\.~) LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET

1. FACILITY NAME

2. DOCKET PALISADES NUCLEAR PLANT 05000255 NARRAllVE SYSTEM DESIGN/FUNCTION APPROVED BY OMB: NO. 3150'()104 EXPIRES: 10/31/2018

, the NRC may not conduct or sponsor, and a person is not required to respond to, the infomation collection.

3. lER NUMBER YEAR I

SEQUENTIAL I REVISION NUMBER NUMBER 2016

- 002

- 00 The control room ventilation [AHU] filtration system [VI] safety function is to limit radiation exposure of control room personnel during any of the postulated design basis events within the guidelines of 10 CFR 50, Appendix A and General Design Criterion 19. Specifically, control room ventilation filtration is designed to maintain a habitable environment in the control room for 30 days of occupancy after a design basis accident without exceeding a five rem total effective dose equivalent. Technical Specification (TS) 3.7.10 allows control room envelope (CRE) boundary doors to be opened intermittently, under administrative control for preplan ned activities, provided the doors can be rapidly restored to the design condition.

EVENT DESCRIPTION

At 021 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> on March 24, 2016, both control room ventilation filtration system trains were declared inoperable in accordance with TS 3.7.1 0, Condition B, due to the inability to fully close CRE boundary door-15. Mitigating actions were implemented that ensured CRE occupant radiological exposures would not exceed limits and CRE occupants would be protected from chemical and smoke hazards. After maintenance was performed, door-15 was fully closed and both control room ventilation filtration system trains were declared operable for this condition at 1828 hours0.0212 days <br />0.508 hours <br />0.00302 weeks <br />6.95554e-4 months <br /> on March 24, 2016.

At the time of the event, both trains of the control room ventilation filtration were inoperable for preplan ned maintenance associated with a modification to a CRE wall. No additional structures, components, or systems were inoperable and contributed to the event at the time of discovery.

The event was initially reported to the NRC in accordance with 10 CFR 50.72(b)(3)(v)(D) as documented in event report

1. 51820. This LER is submitted based on NUREG 1022 revision 3, section 3.2.7 guidance which identifies that the requirements of 10 CFR 50.73(a)(2)(v)(D) apply when a system that is used to mitigate the consequences of an accident was declared TS inoperable and no redundant system or equipment could be declared operable. Based on the limited amount of air in-leakage into the CRE with door-15 only slightly open, the subsequent engineering evaluation determined the control room ventilation filtration system would have maintained the ability to limit control room operator doses below required limits and no loss of safety function occurred.

CAUSE OF THE EVENT

While performing security door checks, security officers inadvertently operated the normal opening/closing handwheel of door-15 to the closed position prior to the door being fully closed. This caused the door's locking bolts to extend out from inside the door body to the locked closed position creating interference between the door and the door frame preventing the door from being fully closed. A security interlock prevents the door's locking bolts from moving, using the normal opening/closing handwheel, when the locking bolts are extended and the door is open. Due to the lack of detail in the operating instructions posted on the door, and the security officers being unaware of the interlock, they continued to try and manipulate the locking bolts via the handwheel. Continued operation of the handwheel with the interlock activated potentially caused a failure of a bushing inside the door's operating mechanism. The failed bushing prevented normal and emergency operation of the door's locking bolts. 11-2015)

(~ i

,~)

U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET

1. FACILITY NAME

2. DOCKET PALISADES NUCLEAR PLANT 05000255 NARRA11VE

ASSESSMENT OF SAFETY CONSEQUENCES

APPROVED BY OMB: NO. 3160*0104 EXPIRES: 10/3112018

, the NRC may not conduct or sponsor, [and a person is not required to respond to, the information collection.

3. LERNUMBER YEAR I SEQUENTIAL I REVISION NUMBER NUMBER 2016

- 002

- 00 The temporary loss of ability to fully close door-1S did not challenge nuclear or radiological safety. No actual loss of safety function occurred. The control room ventilation filtration system maintained the ability to limit control room operator doses below required limits.

CORRECTIVE ACTIONS

The failed bushing inside the door's operating mechanism was replaced. Additional corrective actions include sharing lessons leamed from this event, adding adequate detail to the operating instructions posted on the door, and modification to the door's preventative maintenance program to include bushing inspection and, if needed, replacement.

PREVIOUS SIMILAR EVENTS

LER 2013-003-00, Both Control Room Ventilation Filtration Trains Declared Inoperable

~Entergy PNP 2016-027 May 23,2016 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Tel 269 764 2000 Jeffery A. Hardy Director, Regulatory Assurance and Performance Improvement 10 CFR 50.73

SUBJECT:

Both Control Room Ventilation Filtration Trains Declared Inoperable Palisades Nuclear Plant Docket 50-255 License No. DPR-20

Dear Sir or Madam:

The enclosed Licensee Event Report (LER) 2016-002-00, "Both Control Room Ventilation Filtration Trains Declared Inoperable," is submitted in accordance with 10 CFR 50.73(a)(2)(v)(D).

This letter contains no new commitments and no revisions to existing commitments.

Sincerely, 9Ak\\~

JAH/tad Attachment: 2016-002-00, Both Control Room Ventilation Filtration Trains Declared Inoperable CC Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC

ATTACHMENT LER 2016-002-00 BOTH CONTROL ROOM VENTILATION FILTRATION TRAINS DECLARED INOPERABLE 3 Pages Follow

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2018 (11-2015)

/"....

, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

r' PAGE PALISADES NUCLEAR PLANT 05000255 10F3

4. TITLE Both Control Room Ventilation Filtration Trains Declared Inoperable

5. EVENT DATE

6. LER NUMBER

7. REPORT DATE

8. OTHER FACILITIES INVOLVED YEAR I SEQUENTIAL REV MONTI-FACILITY NAME DOCKET NUMBER MONTH DAY YEAR NO.

DAY YEAR 05000 NUMBER FACILITY NAME DOCKET NUMBER 03 24 2016 2016

- 002

- 00 05 23 2016 05000

9. OPERAllNG MODE

11. THIS REPORT IS SUBMITTED PURSUANTro THE REQUIREMENTS OF 10 CFR ~(Check al/ that app/YL o 20.2201 (b) o 20.2203(a)(3)(i) o 50.73(a)(2)(i)(C) o 50.73(a)(2)(vii) 1 o 20.2201(d) o 20.2203(a)(3)(ii) o 50.73(a)(2)(ii)(A) o 50.73(a)(2)(viii)(A) o 20.2203(a)(1) o 20.2203(a)(4) o 50.73(a)(2)(ii)(B) o 50.73(a)(2)(viii)(B) o 20.2203(a)(2)(i) o 50.36(c)(1)(i)(A) o 50.73(a)(2)(iii) o 50.73(a)(2)(ix)(A)

10. POWER LEVEL o 20.2203(a)(2)(ii) o 50.36(c)(1)(ii)(A) o 50.73(a)(2)(iv)(A) o 50.73(a)(2)(x) o 20.2203(a)(2)(iii) o 50.36(c)(2) o 50.73(a)(2)(v)(A) o 73.71(a)(4) o 20.2203(a)(2)(iv) o 50.46(a)(3)(ii) o 50.73(a)(2)(v)(B) o 73.71 (a)(5) 100 o 20.2203(a)(2)(v) o 50.73(a)(2)(i)(A) o 50.73(a)(2)(v)(C) o OTHER o 20.2203(a)(2)(vi) o 50.73(a)(2)(i)(B) 181 50.73(a)(2)(v)(D)

Specify in Abstract below or in NRC Form 366A

12. LICENSEE CONTACT FOR THIS LER ICENSEE CONTACT r ELEPHONE NUMER (Include Area Code)

Barb Dotson, Regulatory Assurance Manager 269-764-2265

13. COMPLETE ONE UNE FOR EACH COMPONENT FAlWRE DESCRIBED IN THIS REPORT

CAUSE

SYSTEM COMPONENT MANU*

REPORTABLE

CAUSE

SYSTEM COMPONENT MANU*

REPORTABLE FACTURER TO EPIX FACTURER TO EPIX A

VI AHU A220 Y

14. SUPPLEMENTAL REPORT EXPECTED

15. EXPECTED MONTH DAY YEAR DYES (/fyes, complete 15. EXPECTED SUBMISSION DATE)

~ NO SUBMISSION DATE f-BSTRACT (Umit to 1400 spaces, i.e., approximately 15 single-spaced typewritten Ones)

At 0211 hours0.00244 days <br />0.0586 hours <br />3.488757e-4 weeks <br />8.02855e-5 months <br /> on March 24, 2016, both control room ventilation filtration system trains were declared inoperable in accordance with Technical Specification (TS) 3.7.10, Condition B, due to the inability to fully close control room envelope (CRE) boundary door-15. Mitigating actions were implemented that ensured CRE occupant radiological exposures would not exceed limits and CRE occupants would be protected from chemical and smoke hazards. After maintenance was performed, door-15 was fully closed and both control room ventilation filtration system trains were declared operable for this condition at 1828 hours0.0212 days <br />0.508 hours <br />0.00302 weeks <br />6.95554e-4 months <br /> on March 24, 2016.

Inadvertent operation of the normal opening/closing handwheel of door -15 to the closed position, prior to the door being fully closed, caused the door's locking bolts to extend out from inside the door body to the locked closed position. This created interference between the door and the door frame that prevented the door from being closed. An interlock prevents the door's locking bolts from moving, using the normal opening/closing handwheel, when the locking bolts are extended and the door is open. Due to the lack of detail in the operating instructions posted on the door, and the personnel being unaware of the interlock, they continued to try and manipulate the locking bolts via the handwheel.

Continued operation of the handwheel, with the interlock activated, potentially caused a failure of a bushing inside the door's operating mechanism. The failed bushing prevented normal and emergency operation of the door's locking bolts.

The failed bushing inside the door's operating mechanism was replaced. Additional corrective actions include sharing lessons learned from this event, adding adequate detail to the operating instructions posted on the door, and modification to the door's preventative maintenance program to include bushing inspection and, if needed, replacement.

NRC FORM 366 (11-2015) U.S. NUCLEAR REGULATORY COMMISSION (11-2015)

~\\.

\\.~) LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET

1. FACILITY NAME

2. DOCKET PALISADES NUCLEAR PLANT 05000255 NARRAllVE SYSTEM DESIGN/FUNCTION APPROVED BY OMB: NO. 3150'()104 EXPIRES: 10/31/2018

, the NRC may not conduct or sponsor, and a person is not required to respond to, the infomation collection.

3. lER NUMBER YEAR I

SEQUENTIAL I REVISION NUMBER NUMBER 2016

- 002

- 00 The control room ventilation [AHU] filtration system [VI] safety function is to limit radiation exposure of control room personnel during any of the postulated design basis events within the guidelines of 10 CFR 50, Appendix A and General Design Criterion 19. Specifically, control room ventilation filtration is designed to maintain a habitable environment in the control room for 30 days of occupancy after a design basis accident without exceeding a five rem total effective dose equivalent. Technical Specification (TS) 3.7.10 allows control room envelope (CRE) boundary doors to be opened intermittently, under administrative control for preplan ned activities, provided the doors can be rapidly restored to the design condition.

EVENT DESCRIPTION

At 021 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> on March 24, 2016, both control room ventilation filtration system trains were declared inoperable in accordance with TS 3.7.1 0, Condition B, due to the inability to fully close CRE boundary door-15. Mitigating actions were implemented that ensured CRE occupant radiological exposures would not exceed limits and CRE occupants would be protected from chemical and smoke hazards. After maintenance was performed, door-15 was fully closed and both control room ventilation filtration system trains were declared operable for this condition at 1828 hours0.0212 days <br />0.508 hours <br />0.00302 weeks <br />6.95554e-4 months <br /> on March 24, 2016.

At the time of the event, both trains of the control room ventilation filtration were inoperable for preplan ned maintenance associated with a modification to a CRE wall. No additional structures, components, or systems were inoperable and contributed to the event at the time of discovery.

The event was initially reported to the NRC in accordance with 10 CFR 50.72(b)(3)(v)(D) as documented in event report

1. 51820. This LER is submitted based on NUREG 1022 revision 3, section 3.2.7 guidance which identifies that the requirements of 10 CFR 50.73(a)(2)(v)(D) apply when a system that is used to mitigate the consequences of an accident was declared TS inoperable and no redundant system or equipment could be declared operable. Based on the limited amount of air in-leakage into the CRE with door-15 only slightly open, the subsequent engineering evaluation determined the control room ventilation filtration system would have maintained the ability to limit control room operator doses below required limits and no loss of safety function occurred.

CAUSE OF THE EVENT

While performing security door checks, security officers inadvertently operated the normal opening/closing handwheel of door-15 to the closed position prior to the door being fully closed. This caused the door's locking bolts to extend out from inside the door body to the locked closed position creating interference between the door and the door frame preventing the door from being fully closed. A security interlock prevents the door's locking bolts from moving, using the normal opening/closing handwheel, when the locking bolts are extended and the door is open. Due to the lack of detail in the operating instructions posted on the door, and the security officers being unaware of the interlock, they continued to try and manipulate the locking bolts via the handwheel. Continued operation of the handwheel with the interlock activated potentially caused a failure of a bushing inside the door's operating mechanism. The failed bushing prevented normal and emergency operation of the door's locking bolts. 11-2015)

(~ i

,~)

U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET

1. FACILITY NAME

2. DOCKET PALISADES NUCLEAR PLANT 05000255 NARRA11VE

ASSESSMENT OF SAFETY CONSEQUENCES

APPROVED BY OMB: NO. 3160*0104 EXPIRES: 10/3112018

, the NRC may not conduct or sponsor, [and a person is not required to respond to, the information collection.

3. LERNUMBER YEAR I SEQUENTIAL I REVISION NUMBER NUMBER 2016

- 002

- 00 The temporary loss of ability to fully close door-1S did not challenge nuclear or radiological safety. No actual loss of safety function occurred. The control room ventilation filtration system maintained the ability to limit control room operator doses below required limits.

CORRECTIVE ACTIONS

The failed bushing inside the door's operating mechanism was replaced. Additional corrective actions include sharing lessons leamed from this event, adding adequate detail to the operating instructions posted on the door, and modification to the door's preventative maintenance program to include bushing inspection and, if needed, replacement.

PREVIOUS SIMILAR EVENTS

LER 2013-003-00, Both Control Room Ventilation Filtration Trains Declared Inoperable