05000275/LER-2013-001, Noncompliance with TS 3.4.12, Low Temperature Overpressure Protection System Due to Human Error

Noncompliance with TS 3.4.12, Low Temperature Overpressure Protection System Due to Human Error

ML13064A367
Person / Time
Site:	Diablo Canyon
Issue date:	03/04/2013
From:	Allen B Pacific Gas & Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
DCL-13-018 LER 13-001-00
Download: ML13064A367 (6)

LER-2013-001, Noncompliance with TS 3.4.12, Low Temperature Overpressure Protection System Due to Human Error

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i)(8) 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)(8) 10 CFR 50.73(a)(2)(viii)(8) 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)(8) 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
2752013001R00 - NRC Website

text

Pacific Gas and Electric Company March 4, 2013 PG&E Letter DCL-13-018 Barry S. Allen Site Vice President Diablo Canyon Power Plant Mail Code 104/6 P. O. Box 56 Avila Beach. CA 93424 805.545.4888 Internal: 691.4888 Fax: 805.545.6445 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 10 CFR 50.73 Docket No. 50-275, OL-DPR-80 Diablo Canyon Unit 1 Licensee Event Report 1-2013-001. Noncompliance with Technical Specification 3.4.12. "Low Temperature Overpressure Protection System" due to Human Error Dear Commissioners and Staff; Pacific Gas and Electric Company (PG&E) is submitting the enclosed Licensee Event Report in accordance with 10 CFR 50.73(a)(2)(i)(8) as an operation or condition which was prohibited by the plant's Technical Specification. On January 3, 2013, at 19:32 PST, with Units 1 and 2 in Mode 1 and at 100 percent power, Diablo Canyon Power Plant (DCPP) determined that the Limiting Condition for Operation for TS 3.4.12, "Low Temperature Overpressure Protection System,"

was not met during Unit 1 and Unit 2 refueling outages over the past 3 years.

PG&E makes no new or revised regulatory commitments (as defined by NEI 99-04) in this report. All the corrective actions identified in this letter will be implemented in accordance with the DCPP Corrective Action Program.

This event did not adversely affect the health and safety of the public.

Sincerely, Ba~!l Aa-Site Vice President J8L3/50531685 Enclosure cc/:

Diablo Distribution cc/enc:

Elmo E. Collins, NRC Region IV Thomas R. Hipschman, NRC Senior Resident Inspector James T. Polickoski, NRR Project Manager INPO A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway. Comanche Peak. Diablo Canyon. Palo Verde. San Onofre. South Texas Project. Wolf Creek

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2013 (10-2010)

, the NRC may digits/characters for each block) not conduct or sponsor, and a person is not required to respond to, the information collection.

3. PAGE Diablo Canyon Power Plant, Unit 1 05000-275 1 OF 5

4. TITLE Noncompliance with TS 3.4.12, Low Temperature Overpressure Protection System due to Human Error

5. EVENT DATE

6. LER NUMBER

7. REPORT DATE

8. OTHER FACILITIES INVOLVED YEAR !SEQUENTIAL! REV FACILITY NAME DOCKET NUMBER MONTH DAY YEAR NUMBER NO.

MONTH DAY YEAR Diablo Canyon, Unit 2 05000-323 FACILITY NAME DOCKET NUMBER 01 03 2013 2013

• 001. 00 03 04 2013

9. OPERATING MODE

11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)

D 20.2201 (b)

D 20.2203(a)(3)(i)

D 50.73(a)(2)(i)(C)

D 50.73(a)(2)(vii) 1 D 20.2201(d)

D 20.2203(a)(3)(ii)

D 50.73(a)(2)(ii)(A)

D 50.73(a)(2)(viii)(A)

D 20.2203(a)(1)

D 20.2203(a)(4)

D 50.73(a)(2)(ii)(8)

D 50.73(a)(2)(viii)(8)

D 20.2203(a)(2)(i)

D 50.36(c)(1)(i)(A)

D 50.73(a)(2)(iii)

D 50.73(a)(2)(ix)(A)

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

D 50.36(c)(1)(ii)(A)

D 50.73(a)(2)(iv)(A)

D 50.73(a)(2)(x)

D 20.2203(a)(2)(iii)

B 50.36(c)(2)

D 50.73(a)(2)(v)(A)

D 73.71(a)(4) 100%

D 20.2203(a)(2)(iv) 50.46(a)(3)(ii)

D 50.73(a)(2)(v)(8)

D 73.71(a)(5)

D 20.2203(a)(2)(v)

D 50.73(a)(2)(i)(A)

D 50.73(a)(2)(v)(C)

D OTHER D 20.2203(a)(2)(vi)

[(] 50.73(a)(2)(i)(8)

D 50.73(a)(2)(v)(D)

Specify in Abstract below or in B. LTOP Operating Experience and Impact on DCPP

6. LER NUMBER YEAR I SEQUENTIAL T NUMBER I REV NO.

2013 -

001 00

3. PAGE 3

OF 5

Wolf Creek Nuclear Operating Company (WCNOC) has a charging system and licensing history similar to DCPP's in that it originally had a normal-use reciprocating charging pump and two ECCS CCPs. WCNOC replaced its reciprocating pump with a CCP (similar to DCPP) without revising its LTOP TS. Similar to DCPP, WCNOC's LTOP TS specifies that only one CCP can be capable ofinjecting to the RCS while LTOP is required to be operable.

On January 3, 2013, the U. S. Nuclear Regulatory Commission (NRC) issued a TS interpretation clarifying that the WCNOC TS 3.4.12 does not permit more than a single CCP to be capable of injecting into the RCS while L TOP is required to be operable.

C. Event Description

On January 3,2013, at 19:32 PST, DCPP reviewed the NRC's interpretation ofWCNOC TS 3.4.12 and determined that DCPP had been in non-compliance with TS 3.4.12 (when applicable) since the positive displacement pump (PDP) replacement modifications in Unit 1 in 2005 and in Unit 2 in 2007. DCPP determined this condition was reportable pursuant to 10 CFR 50.73(a)(2)(i)(B) as an operation or condition which was prohibited by the plant's TS.

PG&E maintained CCP configurations in accordance with the L TOP analysis and the PTLR by having procedural requirements as indicated below:

A. with RCS temperature below 280 degrees F and above 156 degrees F, two CCPs are capable of injecting into the RCS, one of which is CCP-3 aligned for LTOP operation.

B. with RCS temperature at or below 156 degrees F, only one CCP is capable of injecting into the RCS.

The following is a list of the approximate dates in the prior 3 years in which DCPP relied on L TOP and was in configuration A listed above and not in compliance with TS 3.4.12:

Unit 1:

Refueling outage 16 (10/03/10 at 06:50 - 10/03/10 at 17:40)

(11102/10 at 07:30 - 11105110 at 0130)

Refueling outage 17 (04/22/12 at 22:20 04/23112 at 17:40)

(06/08/12 at 13:50 - 06/10/12 at 16:00)

Unit 2:

Refueling outage 16 (05/01111 at 08:50 - 05/01111 at 22:00)

(05/31111 at 09:40 - 06/02111 at 12:50)

YEAR

6. LER NUMBER I

SEQUENTIAL I NUMBER 2013 -

001 D. Status of Inoperable Structures, Systems or Components that contributed to the Event None.

E. Other Systems or Secondary Functions Affected

None.

F. Method of Discovery

REV NO.

00 4

3. PAGE OF This condition was discovered during a review of operating experience associated with the NRC's TS Interpretation letter dated January 3, 2012, indicating that TS 3.4.12 does not permit operation of more than a single CCP while L TOP is required to be operable.

G. Operator Actions

None.

H. Safety System Responses None.

III. Cause of the Event

A. The two apparent causes identified with this condition are summarized below:

1. A deficiency in DCPP's 10 CFR 50.59 procedure was identified as the apparent cause. The procedure did not provide guidance regarding proposed design changes that may maintain the original intent but create new literal compliance issues.

2. Human Error - The DCPP staff interpreted the operability requirements outlined in TS 3.4.12 as being equivalent with respect to the PDP to CCP design change.

IV. Assessment of Safety Consequences

5 The plant configuration controls using the new CCP ensured DCPP operated within the limits of the LTOP analysis, ensuring that the (PIT) limits of 10 CFR 50, Appendix G would not be exceeded. Nuclear or radiological safety was not affected. This event had no impact to safety of the public or station personnel. This event did not impact the reliability of plant operation or production capacity.

V. Corrective Actions

A. Immediate Corrective Actions YEAR I

SEQUENTIAL I NUMBER 2013

• 001 REV NO.

00 5

OF 5

1. Revised all affected procedures (shutdown and startup) to require disabling two CCPs consistent with TS 3.4.12 requirements.

B. Other Corrective Actions

1. Revise the Licensing Basis Impact Evaluations Procedure TS3.ID2 to provide clear guidance regarding equivalent replacements that may create new literal compliance issues.

2. Revise Current Licensing Basis Determination Procedure XB.IDI2 to discuss the importance of literal compliance with DCPP TS and license.

3. Provide lessons-learned discussion to staff associated with design changes including staff from other key departments.

VI. Previous Similar Events

There have been no similar reportable events within the last 3 years.

VII. Additional Information

None