05000282/LER-2015-005-01, Regarding Condition Prohibited by Technical Specifications
| ML16285A387 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 10/10/2016 |
| From: | Northard S Northern States Power Company, Minnesota, Xcel Energy |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-PI-16-077 LER 15-005-01 | |
| Download: ML16285A387 (6) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 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)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i) |
| 2822015005R01 - NRC Website | |
text
Xcel Energy@
ocr 1 o 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant, Unit 1 Docket No. 50-282 Renewed Facility Operating License No. DPR-42 Prairie Island Nuclear Generating Plant 1717 Wakonade Drive East Welch. MN 55089 L-PI-16-077 10 CFR 50.73 Licensee Event Report 50-282/2015-005-01, Condition Prohibited by Technical Specifications References: 1) Letter from Northern States Power Company, a Minnesota corporation (NSPM),
d/b/a Xcel Energy to Document Control Desk, "LER 50-282/2015-005-00, Possible Misapplication of C18.1, Engineered SafeguardsEquipment Support Systems".
(ADAMS Accession ML15313A480)
Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), encloses a revised Licensee Event Report (LER) 50-282/2015-005-01, Condition Prohibited by Technical Specsifications. This revision is a complete rewrite to Reference 1, which was submitted on November 9, 2015. The main emphasis of this rewrite is to clarify the cause and the safety significance of this occurrence.
If there is any question or if any additional information is needed, please contact Frank Sienczak, at 651-267-1740.
Summary of Commitments This letter contains no new commitments and no changes to existing commitments Scott Northard Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota
Enclosures:
cc:
Regional Administrator, Region Ill, USNRC Project Manager, Prairie Island Nuclear Generating Plant, USNRC Resident Inspector, Prairie Island Nuclear Generating Plant, USNRC Department of Commerce, State of Minnesota
Document Control Desk Page 2 ENCLOSURE 1 LICENSEE EVENT REPORT 50-282/2015-005-01 4 Pages Follow
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 1013112018 (11-2015) r~
.. ~
, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.
r* PAGE Prairie Island Nuclear Generating Plant Unit 1 05000- 282 1 OF4
- 4. TITL,E Condition Prohibited by Technical Specifications
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED YEAR I SEQUENTIAL I REV FACILITY NAME DOCKET NUMBER MONTH DAY YEAR NUMBER NO.
MONTH DAY YEAR 05000 FACILITY NAME DOCKET NUMBER 9
11 2015 2015
- - 005
- - 01 10 10 2016 05000
- 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)(ii)(A)
D 50.73(a)(2)(viii)(A)
Mode 1 D zo.zzo1(d)
D 20.2203(a)(3)(ii)
D 50.73(a)(2)(ii)(B)
D 50.73(a)(2)(viii)(B)
D 20.2203(a)(1)
D 20.2203(a)(4)
D 50.73(a)(2)(iii)
D 50.73(a)(2)(ix)(A)
D 20.2203(a)(2)(i)
D 50.36(c)(1)(i)(A)
D 50.73(a)(2)(iv)(A)
D 50.73(a)(2)(x)
- 10. POWER LEVEL D 20.2203(a)(2)(ii)
D 50.36(c)(1 )(ii)(A)
D 50.73(a)(2)(v)(A)
D 73.71(a)(4)
D 20.2203(a)(2)(iii)
D 50.36(c)(2)
D 50.73(a)(2)(v)(B)
D 73.71(a)(5) 100%
D 20.2203(a)(2)(iv)
D 50.46(a)(3)(ii)
D 50.73(a)(2)(v)(C)
D 73.77(a)(1)
D 20.2203(a)(2)(v)
D 50.73(a)(2)(i)(A)
D 50.73(a)(2)(v)(D)
D 73.77(a)(2)(i)
D 20.2203(a)(2)(vi)
[8] 50.73(a)(2)(i)(B)
D 50.73(a)(2)(vii)
D 73.77(a)(2)(ii)
D 50.73(a)(2)(i)(C) 0 OTHER Specify in Abstract below or in NRC Form 366A
- 12. LICENSEE CONTACT FOR THIS LER LICENSEE CONTACT
~ELEPHONE NUMER (Include Area Code)
Stephen Sollom, Licensing Engineer 763-295-1611
- 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 TOEPIX
- 14. SUPPLEMENTAL REPORT EXPECTED
- 15. EXPECTED MONTH DAY YEAR 0 YES (If yes, complete 15. EXPECTED SUBMISSION DATE)
IZI NO SUBMISSION DATE
~BSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)
On September 11, 2015, Prairie Island Nuclear Generating Plant (PINGP) staff recognized a possible misapplication of its plant procedure C18.1, Engineered Safeguards Equipment Support Systems. When a train of Safeguards Chilled Water System (SCWS) was removed from service, C18.1 Rev 40 required entry into Technical Specification (TS) 3.8.9. It was determined during the past three (3) years there were five (5) separate occasions between the two (2) trains of sews where C18.1 directed entry into TS 3.8.9. On each of these dates TS 3.8.9 was not entered and the required actions were not taken to restore to an operable status within the completion time. However, an equally correct application of TS would be to enter TS 3.7.11, and then apply TS 3.0.6. TS 3.0.6 allows for supported systems LCO not met solely to support system LCO not met, only support system LCO are required. The Safety Function Determination Program (SFDP) evaluation was performed and determined that there was no loss of safety function. This is a reportable event under 10 CFR 50.73(a)(2)(i)(b), Operation or Condition Prohibited by Tech Spec with the discovery date of inoperability.
The causal evaluation determined C18.1 was not accurate and usable in part, due to inadequate review of changes to the procedure.
The corrective actions revised C18.1 to invoke TS 3.0.6 as applicable for the Bus is Load Sequencer when SCWS is out of service.
NRC FORM 366 (11-2015)
On September 11, 2015, Prairie Island Nuclear Generating Plant (PINGP) staff recognized a possible misapplication of its plant procedure C 18.1, Engineered Safeguards Equipment Support Systems.
When a train of Safeguards Chilled Water System (SCWS) 1 was removed from service, C18.1 Rev 40 required entry into Technical Specification (TS) 3.8.9 for Distribution Systems-Operating. An evaluation determined during the past three (3) years there were five (5) separate occasions between the two (2) trains of SCWS where C18.1 directed entry into TS 3.8.9. On each of these dates TS 3.8.9 was not entered and the required actions were not taken to restore to an operable status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or to enter MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
The chart below shows that at no time both busses were inoperable at the same time. When train A Bus 15 is out of service train A Busses 111 and 112 are also out of service and when train B Bus 16 is out of service train B Busses 121 and 122 are out of service.
Bus 15 Busses 111 and 112 3/3/2014-3/18/2014 (14 days 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> 40 minutes) wo 466701 1/4/2015-1/11/2015 (6 days 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> 49 minutes)
W0488927 Bus 16 Busses 121 and 122 1/28/2013-2/2/2013 (5 days 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> 0 minutes)
Work Order (WO) 498616 6/12/2013-6/28/2013 (16 days 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 34 minutes) wo 448108 3/19/2014-4/5/2014 (17 days 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> 47 minutes)
W0469474 2/16/2015-2/22/2015 (6 days 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> 31 minutes) wo 498616 5/18/2015-5/24/2015 (6 days 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 10 minutes) wo 498616 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2018 (11-2015)
LICENSEE EVENT REPORT (LER)
CONTINUATION SHEET
, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.
- 3. LER NUMBER Prairie Island Nuclear Generating Plant Unit 1 05000- 282 YEAR I
SEQUENTIAL I
REV NUMBER NO.
2015
- - 005
- - 01
EVENT ANALYSIS
The function of the Safeguards Chilled Water System circulates chilled water to provide ambient air cooling to essential areas. These areas include the control room, safeguards switchgear (Unit 1 4160 VAC (4kV)2 and 480 VAC3 bus) rooms, the residual heat removal (RHR) pump pits, the relay room, including the old P-250 computer room, and the event monitoring (EM) equipment room. The system functions during both normal plant operations and accident conditions. Function of the system is to remove heat generated by safety related equipment and any accident condition. The system provides sufficient ventilation and cooling to maintain equipment operability. It does this by controlling temperatures within design ratings of the installed safety related systems. The system performs a safeguard function in that it cools critical equipment. It is Design Class Ill and QA Type I due to its support function of safety-related equipment.
With C 18.1, Rev 40, the action for loss of a train of SCWS was changed to require entry into TS 3.8.9 in addition toTS 3.7.11 for SCWS. However, an equally correct application of TS would be to enter TS 3.7.11.and then apply TS 3.0.6. TS 3.0.6 allows that when the supported systems LCO is not met solely due to a support system LCO not being met, only the support system LCO are required. A requirement of TS 3.0.6 is that an evaluation be performed in accordance with Specification 5.5.13, Safety Function Determination Program (SFDP). The SFDP evaluation determined that there was no loss of safety function when entering only TS 3.7.11 with a train of sews out of service.
This event is reportable to the NRC under 10 CFR 50.73(a)(2)(i)(B) Operation or Condition Prohibited by Technical Specifications.
SAFETY SIGNIFICANCE
There were no Industrial, Environmental or Radiological consequences from this event. While TS 3.8.9 was not entered and the required shutdown actions were not taken, had C18.1 allowed application of TS 3.0.6, actions would have been essentially the same as those that were taken. i.e., entry into TS 3.7.11 Condition A, which has a completion time of 30 days, without entry into supported system conditions. The only difference would be that entry into TS 3.0.6 requires application of SFDP, which was subsequently completed and found not to preclude TS 3.0.6 entry in the case of a train of sews being out of service.
CAUSE
Cause evaluation determined C 18.1 was not accurate and usable in part, due to inadequate review of changes to the procedure.
1 EllS System Code-Bl 2 EllS System Code-EA 3 EllS System Code-EC (11-2015)
U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2018 LICENSEE EVENT REPORT (LER)
CONTINUATION SHEET
, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.
- 3. LER NUMBER Prairie Island Nuclear Generating Plant Unit 1 05000- 282 YEAR I
SEQUENTIAL I
REV NUMBER NO.
2015
- 005
- 01 CORRECTIVE ACTION COMPLETED C18.1 has been revised to invoke TS 3.0.6 as applicable for the Bus is Load Sequencer when SCWS is out of service.
PREVIOUS SIMILAR OCCURRENCES A review of the past three (3) years of LER's found no previous similar events.
NRC FORM 366 (11-2015)