05000261/LER-2003-003, Unit N0. 2, Regarding Discovery of Two New Appendix R Safe Shutdown Vulnerabilities

Unit N0. 2, Regarding Discovery of Two New Appendix R Safe Shutdown Vulnerabilities

ML040220491
Person / Time
Site:	Robinson
Issue date:	01/20/2004
From:	Burton C Progress Energy Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
FOIA/PA-2004-0277, RNP-RA/04-0010 LER 03-003-00
Download: ML040220491 (10)

LER-2003-003, Unit N0. 2, Regarding Discovery of Two New Appendix R Safe Shutdown Vulnerabilities

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 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)(v), Loss of Safety Function
2612003003R00 - NRC Website

text

10 CFR 50.73 Progress Energy Serial: RNP-RA/04-0010 JAN 2 0 2004 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/LICENSE NO. DPR-23 LICENSEE EVENT REPORT NO. 2003-003-00 DISCOVERY OF TWO NEW APPENDIX R SAFE SHUTDOWN VULNERABILITIES Ladies and Gentlemen:

The attached Licensee Event Report is submitted in accordance with the requirements of 10 CFR 50.73. Should you have any questions regarding this matter, please contact Mr. C. T. Baucom, Supervisor - Licensing/Regulatory Programs, at (843) 857-1253.

Sincerely, (Cobet C. L. Burton Director - Site Operations CLB/jwv Attachment c:

Mr. L. A. Reyes, NRC, Region II Mr. C. P. Patel, NRC, NRR NRC Resident Inspector, HBRSEP Progress Energy Carolinas. Inc.

Robinson Nuclear Plant 3581 West Entrance Road Hartsville, SC 29550 Z'-z' i'j- "

NRC FORM 366 U.S. NUCLEAR REGULATORY APPROVED BY OMB NO. 3150-0104 EXPIRES 7-31-2004 (7-2X01)

COMMISSION

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

FACILITY NAME (1)

DOCKET NUMBER (2) l PAGE (3)

H. B. Robinson Steam Electric Plant, Unit No. 2 05000261 l

1 OF 9

TITLE (4)

Discovery of Two New Appendix R Safe Shutdown Vulnerabilities EVENT DATE (5)

LER NUMBER (6)

REPORT DATE (7)

OTHER FACILITIES INVOLVED (8)

S AFACILITY NAME DOCKET NUMBER MO DAY YEAR YEAR NUMBER NO MO DAY YEAR FACILITY NAME DOCKET NUMBER 11 19 2003 2003 -003

- 00 01 20 20041 OPERATING THIS REPORT IS SUBMflTED PURSUANT TO THE REQUIREMENTS OF 10 CFR (Check all that apply) (11)

MODE (9) 1

_ 20.2201 (b) 20.2203(a)(3)(ii)

__ 50.73(a)(2)(ii)(B) 50.73(a)(2)(ix)(A)

POWER 20.2201 (d) 20.2203(a)(4) 50.73(a)(2)(iii) 50.73(a)(2)(x)

LEVEL (10) 100%

_ 20.2203(a)(1)

_ 50.36(c)(1)(i)(A) 50.73(a)(2)(iv)(A) 73.71 (a)(4) 20.2203(a)(2)(i) 50.36(c)(1)(ii)(A)

X 50.73(a)(2)(v)(A) 73.71 (a) (5) 20.2203(a)(2)(ii)

_ 50.36(c)(2)

X 50.73(a)(2)(v)(B)

OTHER Specify in Abstract below or In 20.2203(a)(2)(iii) 50.46(a)(3)(ii) 50.73(a)(2)(v)(C)

(if more space Is required, use additional copies of (If more space is required, use additional copies of (if more space Is required, use additional copies of (If more space is required, use additional copies of (If more space is required, use additional copies of (if more space is required, use additional copies of (If more space Is required, use additional copies of (If more space is required, use additional copies of NRC Form 366A) (17)

1) To verify the 'A" Charging Pump is not an operating pump in order to mitigate damage to the pump, maintain it water solid, and enable the pump to remain available for RCS inventory makeup as needed.

and

2) To verify Block Valves RC-535 and RC-536 are closed to prevent an initial open RCS vent path upon concurrent spurious opening of both Pressurizer PORVs and Loss of Offsite Power.

Operations Night Order 03-024 was issued November 19. 2003 directing each Operating Shift to review the changes made to FP-001.

In addition. to reduce exposure to the potential effects of a fire from transient combustible materials.

the administrative available limits for the affected fire zones were reduced to 50 percent of the normally allowed loadings.

Long-Term Mitigating Strategy Progress Energy recently completed a position paper on Fire-Induced Circuit Failures for Appendix R purposes to be considered at all Progress Energy nuclear operating facilities.

This paper clearly requires two postulated fire-induced circuit failures to be considered at the system level in the Appendix R Revalidation Project at each site. This position paper defines the number and type of circuit failures to consider. HBRSEP. Unit No. 2. will complete reanalysis of the Appendix R Program utilizing the criteria specified in the Progress Energy position paper and the information contained in the investigation into this nuclear condition report (NCR 111308). Additional design documents will be modified as needed.

The Appendix R Safe Shutdown Analysis Revalidation Project is currently ongoing, with a projected completion date in March 2005.

Project Instructions specifically address the methodology and treatment of spurious operation of equipment. These instructions state that two spurious concurrent mal-operations of equipment must be considered in the circuit analysis for cables and equipment being credited for shutdown of the plant.

Project Instructions also identify hydraulic analyses that must be considered. Plant modifications are anticipated following completion of the full revalidation project.

However, with the expected complexity. implementation of resulting modifications will begin, at the earliest. during Refueling Outage 23 in Fall 2005 and continue thereafter until completion.

V. ADDITIONAL INFORMATION

A review of recent (past three years) events at HBRSEP. Unit No. 2. for conditions that could have prevented the fulfillment of a safety function was conducted.

LER 2003-002 detailed a June 2003 failure of the control switch [JM:HS] that controls the valves for the containment pressure relief penetration.

Upon discovering the failure, the control switch was repaired and the system was restored to operable status.

Investigation of the event determined that an inappropriate design change occurred in about 1980, which when coupled with the switch failure. caused the loss of safety function.

While the cause was a deficient design change. it would have had no impact on these two Appendix R analyses and could not have led to earlier discovery or correction of these two vulnerabilities.