05000255/LER-2018-001, Safety Injection Inoperable for Longer than Allowed by Technical Specifications Due to Personnel Error
| ML18180A024 | |
| Person / Time | |
|---|---|
| Site: | Palisades |
| Issue date: | 06/28/2018 |
| From: | Hardy J Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| PNP 2018-032 LER 2018-001-00 | |
| Download: ML18180A024 (5) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(v), Loss of Safety Function |
| 2552018001R00 - NRC Website | |
text
.=:=. Entergy PNP 2018-032 June 28, 2018 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 Regulatory Assurance Manager 10 CFR 50.73
SUBJECT:
LER 2018-001 Safety Injection Inoperable for Longer than Allowed by Technical Specifications Due to Personnel Error Palisades Nuclear Plant Docket 50-255 License No. DPR-20
Dear Sir or Madam:
Entergy Nuclear Operations, Inc., hereby submits the enclosed Licensee Event Report (LER), 2018-001-00, for the Palisades Nuclear Plant. The event is reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as an operation or condition prohibited by Technical Specifications and 10 CFR 50.73(a)(2)(v)(D) as a condition that could have prevented the fulfillment of the safety function of systems that are needed to mitigate the consequences of an accident.
This letter contains no new commitments and no revisions to existing commitments.
Should you have any questions concerning this report, please contact Mr. Jeff Hardy, Regulatory Assurance Manager, at (269) 764-2011.
JAH/bed Attachment: LER 2018-001-00, Safety Injection Inoperable for Longer than Allowed by Technical Specifications Due to Personnel Error CC Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC
ATTACHMENT LER 2018-001-00 SAFETY INJECTION INOPERABLE FOR LONGER THAN ALLOWED BY TECHNICAL SPECIFICATIONS DUE TO PERSONNEL ERROR 3 Pages Follow
NRC FORM 366 U.S. NUCLEAR REGULATORY APPROVED BY OMB: NO. 3150-0104 EXPIRES: 03/31/2020 (04*2018) h!!Q://www.nrc.govlreading-rm/doc-collections/nur~s/staff/sr10221r3D the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.
- 1. FACILITY NAME
~. DOCKET NUMBER
~. PAGE PALISADES NUCLEAR PLANT 05000255 1 OF 3
- 4. TITLE Safety Injection Inoperable for Longer than Allowed by Technical Specifications Due to Personnel Error
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED SEQUENTIAL FACILITY NAME DOCKET NUMBER MONTH DAY YEAR YEAR REV MONTH DAY YEAR NUMBER NO.
05000 05 03 2018 2018 001 00 06 28 2018 FACILITY NAME DOCKET NUMBER 05000
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply) 1 D 20.2201(b)
D 20.2203(a)(3)(i)
D SO.73(a)(2)(ii)(A)
D SO.73(a)(2)(viii)(A)
D 20.2201(d)
D 20.2203(a)(3)(ii)
D SO.73(a)(2)(ii)(B)
D SO.73(a)(2)(viii)(B)
D 20.2203(a)(1)
D 20.2203(a)(4)
D SO.73(a)(2)(iii)
D SO.73(a)(2)(ix)(A)
D 20.2203(a)(2)(i)
D SO.36(c)(1 )(i)(A)
D SO.73(a)(2)(iv)(A)
D SO.73(a)(2)(x)
- 10. POWER LEVEL D 20.2203(a)(2)(ii)
D SO.36(c)(1 )(ii)(A)
D SO.73(a)(2)(v)(A)
D 73.71 (a)(4)
D 20.2203(a)(2)(iii)
D SO.36(c)(2)
D SO.73(a)(2)(v)(B)
D 73.71 (a)(S) 100%
D 20.2203(a)(2)(iv)
D SO.46(a)(3)(ii)
D SO.73(a)(2)(v)(C)
D 73.77(a)(1)
D 20.2203(a)(2)(v)
D SO.73(a)(2)(i)(A)
[gISO.73(a)(2)(v)(O)
D 73.77(a)(2)(i)
D 20.2203(a)(2)(vi)
[gISO.73(a)(2)(i)(B)
D SO.73(a)(2)(vii)
D 73.77(a)(2)(ii)
D SO.73(a)(2)(i)(C)
D OTHER Specify in Abstract below or in NRC Form 366A
- 12. LICENSEE CONTACT FOR THIS LER LICENSEE CONTACT r rLEPHONE NUMBER (Include Area Code)
Weff Hardy, Regulatory Assurance Manager
~69-764-2011
- 13. COMPLETE ONE UNE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT
CAUSE
SYSTEM COMPONENT MANU-REPORTABLE
CAUSE
SYSTEM COMPONENT MANU-REPORTABLE FACTURER TO EPIX FACTURER TO EPIX A
JE RLY N/A Y
- 14. SUPPLEMENTAL REPORT EXPECTED
[g] NO SUBMISSION DATE ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)
On May 3,2018, with the plant at 100% power, Entergy Nuclear Operations, Inc. (ENO) personnel were performing troubleshooting activities on the right train safety injection actuation indicating light. It was identified that wire 13 was not landed on the safety injection initiation relay circuit-2 (SIS-2) relay as required. This rendered the automatic initiation of right train safety injection inoperable and caused an entry into a 48-hour shutdown action statement. It was determined that the wire had been lifted, but not properly landed, during testing in the refueling outage eleven months prior. Consequently, the required actions and associated completion times of Technical Specification 3.3.4 were not met.
The wire was subsequently landed and operability restored. Additionally, during the period the right train was inoperable, the left train was inoperable on four occasions during the performance of quarterly surveillance testing, thus rendering both trains inoperable briefly. The root cause of this event was that post-test restoration of the electrical circuit on a safety significant system relied only on an administrative barrier and did not include a circuit check.
During the time of the right train automatic initiation inoperability, the components could have been manually actuated. Therefore, there were no consequences to the general safety of the public, nuclear safety, industrial safety or radiological safety for this event.
NRC FORM 366 (04-2018)
EVENT DESCRIPTION
SEQUENTIAL NUMBER
- - 001 REV NO.
- - 00 On May 2, 2018, with the plant at 100% power, quarterly test 00-1, "Safety Injection System," was being performed as scheduled. During right train safety injection system (SIS) [JE] testing, it was noticed that the right train safety injection actuation indicating light [IL] did not light as expected. The bulb was replaced with a known good bulb with the same results.
A troubleshooting team was assembled to investigate the issue. During the performance of troubleshooting steps on May 3, 2018, it was identified that one of two wires on relay SIS-2, "Maintained SI Initiation Relay - Ckt #2," terminal 13 was not landed.
The troubleshooting plan was revised to de-energize the right train SIS circuit via the fuses [FU], re-Iand the wire, perform continuity checks, restore fuses, and check circuit voltages. Once completed successfully, right train SIS was restored to operable state on May 3,2018, at 20:15.
The circuit was impacted during the performance of RO-12, "Containment High Pressure (CHP) and Spray System Tests," which was performed in refueling outage 1R25 on May 8,2017. During RO-12, electrical maintenance removes the two wires on terminal 13 of the SIS-2 relay prior to testing. When the test is completed, the two wires are re-Ianded on terminal 13 of SIS-2 relay. This step was not correctly performed.
CAUSE OF THE EVENT
The root cause of this event was that restoration of the electrical circuit for terminal-13 on a safety significant system relied only on an administrative barrier and did not include a circuit check.
ASSESSMENT OF SAFETY CONSEQUENCES
The event is considered to be of very low safety significance. The consequences were that the right train of the safety injection actuation system would not have actuated and therefore, right train equipment would not have automatically actuated during an event requiring SIS (primary coolant system low pressure, containment high pressure). This condition would have also resulted in the right train of the containment spray system (CSS) not actuating on a CHP signal. The manual actuation pushbutton for the right train was also not capable of initiating SIS. The individual right train SIS and CSS components remained capable of being manually actuated by the operators.
A review of operator logs determined that the total time of right train SIS actuation inoperability was 350.08 days.
Operator logs were also reviewed for potential events where left train SIS actuation was inoperable. This search identified that left train SIS actuation was only impacted during quarterly testing (00-1). The quarterly test was performed on the left train four times since startup from the 2017 refueling outage for a total of 103 minutes. 00-1 involves the use of the test portion of the SIS circuits where the test pushbutton is held in to energize relays that block certain loads from energizing when the SIS relays are picked up during testing. The test includes specific steps to monitor for an actual SIS during testing and to immediately release the test pushbutton and verify all equipment required for SIS is aligned and operating.
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LICENSEE EVENT REPORT (LER)
CONTINUATION SHEET (See NUREG-1 022, R.3 for instruction and guidance for completing this form btto:/Iwww.nrc.oov/readino-rm/doc-collections/nureQs/staff/sr1022/r3!)
APPROVED BY OMB: NO. 3150-0104 EXPIRES: 3/31/2020
, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.
- 3. LER NUMBER YEAR PALISADES NUCLEAR PLANT 05000-255 2018 SEQUENTIAL NUMBER
- - 001 REV NO.
- - 00 Because the components could be manually actuated, and the left train was only inoperable during testing for short durations, there were no consequences to the general safety of the public, nuclear safety, industrial safety or radiological safety for this event.
CORRECTIVE ACTIONS
The system was retumed to its intended configuration. Testing was performed, and operability was restored.
Revise RO-12, Containment High Pressure (CHP) and Spray System Tests, to include continuity checks on the SIS circuits for both right and left trains. The intent of this action is to ensure a systematic barrier is in place to verify the circuit has been restored_ This action is being tracked in the corrective action program_
PREVIOUS SIMILAR EVENTS
None.
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