05000317/LER-2016-004, Regarding High Energy Line Break Barrier Breeched Due to Human Performance Error Causing Both Service Water Trains to Be Inoperable
| ML16204A377 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/20/2016 |
| From: | Flaherty M Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LER 16-004-00 | |
| Download: ML16204A377 (7) | |
| 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) |
| 3172016004R00 - NRC Website | |
text
- fl" IJ> Exelon Generation July 20, 2016 U.S. Nuclear Regulatory Commission ATTN
- Document Control Desk Washington, DC 20555 Calvert Cliffs Nuclear Power Plant, Unit No. 1 Renewed Facility Operating License No. DPR-53 NRG Docket No. 50-317 Mark Flaherty Plant Manager Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657 410 495 5205 Office 443-534-5475 Mobile www.exeloncorp.com mark.flaherty@exeloncorp.com 10 CFR 50.73
Subject:
Licensee Event Report 2016-004, Revision 00 High Energy Line Break Barrier Breeche.d Due to Human Performance Error Causing Both Service Water Trains to be Inoperable The attached report is being sent to you as required by 1 O CFR 50.73.
There are no regulatory commitments contained in this correspondence.
Should you have questions regarding this report, please contact Mr. Larry D. Smith at (410) 495-5219.
Respectfully,
~~~
Mark D. Flaherty Plant Manager MDF/PSF/bjm
Attachment:
As stated cc:
NRG Project Manager, Calvert Cliffs NRG Regional Administrator, Region I NRG Resident Inspector, Calvert Cliffs S. Gray, MD-DNR
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- 3. PAGE Calvert Cliffs Nuclear Power Plant, Unit 1 05000317 1 OF 6
- 4. TITLE High Energy Line Break Bar~ier Breeched Due to Human Performance Error Causing Both Service Water Trains to be Inoperable
- 5. EVENT DATE
- 6. LEA NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED SEQUENTIAL REV FACILITY NAME MONTH DAY YEAR YEAR NUMBER NO.
MONTH DAY YEAR FACILITY NAME 11 13 2015 2016 - 004 000 07 20 2016
- 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) 1 D 20.2201 (d)
D 20.2203(a)(3)(ii)
[81 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)
[81 50.73(a)(2)(v)(A)
D 73.71 (a)(4)
D 20.2203(a)(2)(iii)
D 50.36(c)(2)
[81 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)
[81 50.73(a)(2)(v)(D)
D 73.77(a)(2)(i)
D 20.2203(a)(2)(vi)
D 50.73(a)(2)(i)(B)
[81 50.73(a)(2)(vii)
D 73.77(a)(2)(ii)
D 50.73(a)(2)(i)(C)
D Specify in Abstract below or in qualified for the steam environment that is postulated to exist following a HELB. Declaring both trains of SRW inoperable results in a loss of safety function for a system needed to respond to a HELB to provide safe shutdown of the reactor, remove residual heat and mitigate the consequence of an accident. In addition, this condition also results in an unanalyzed condition that significantly degrades plant safety and a common cause inoperability of independent trains.
A single train of Auxiliary Feedwater (AFW) [BA] was also affected, as were support equipment for other TS components.
C.
INOPERABLE STRUCTURES, COMPONENTS, OR SYSTEMS THAT CONTRIBUTED TO THE EVENT:
There were no structures, systems, or components inoperable at the start of the event that contributed to the event.
D.
DATES AND APPROXIMATE TIMES OF MAJOR OCCURRENCES
October 19, 2015 - SRW HELB barrier is opened for approximately three and a half minutes to move SRW pump motor into the SRW pump room. The SRW HELB barrier closed following the move of the SRW pump into the SRW pump room.
October 21, 2015 - SRW HELB barrier is opened for approximately three and a half minutes to move old SRW pump motor out of the SRW pump room. The SRW HELB barrier closed following the move of the old SRW pump out of the SRW pump room.
November 13, 2015 - Issue Report (IR) 2586773 was written to document that the work order (WO 120070650) did not contain a barrier impairment permit as required by procedure CC-AA-201.
February 9, 2016-Inspection Report 05000317/2015004 and 05000318/2015004 was issued from.the NRG describing the green Non-Cited Violation (NCV) of Technical Specification 5.4.1 for failure to implement procedures as required by Regulatory Guide 1.33, Appendix A.
February 14, 2016 - IR 2625943 was written to require appropriate evaluation of the green NCV. An evaluation was completed and corrective actions developed_
July 1, 2016 - Regulatory Assurance personnel were contacted by the NRG Resident Inspector requesting information related to a Licensee Event Report (LER) for the above described issue.
No LER was located. IR 2688409 was written.
E.
FAILURE MODES:
There are no equipment failure modes.
F.
METHOD OF DISCOVERY
The event should have been determined to be a reportable event following determination that the correct barrier control procedure was not followed on November 13, 2015. However, at that time, the conduct of maintenance for this work order was believed to be acceptable. Receipt of NRC Inspection Report 05000317/2015004 and 05000318/2015004 was an additional opportunity to address the reportable aspect of this event. This event is documented in the site's Corrective Action Program under IRs 2586773 and 2625943.
II. CAUSE OF EVENT
NO.
The cause of the event was human performance related. The work order that provided direction for the movement of the SRW motor into and out of the SRW pump room did not contain the required barrier impairment permit as required by procedure CC-AA-201. The reason the work order did not contain the barrier impairment permit is that the implementation of the procedure was not effectively communicated to Maintenance Planners by the Engineer responsible for the procedure implementation. Therefore, the Maintenance Planners were not aware that a barrier impairment permit was needed for the work order. Use of the barrier impairment permit process would have resulted in different actions being taken to perform this maintenance task.
The apparent cause of the event was that an Engineer failed to provide adequate change management for the implementation of the barrier procedure. Therefore, Maintenance Planners did not include the proper barrier controls in the work order that opened the HELB barrier.
Corrective actions were to brief affected groups about the barrier control procedure. Corrective action for the human performance issue was handled through the performance management system.
A.
SAFETY CONSEQUENCES
The safety consequence of this event was that equipment required to respond to a HELB event in the turbine building was not protected from the HELB event itself. Equipment required to respond to a HELB event is listed in UFSAR Table 1 OA-6, "Mechanical and Electrical Equipment Required to Place the Plant in a Safe Shutdown Condition." The table lists the SRW pump, the motor-driven AFW pump [P] and components that rely on the safety related saltwater air compressors (SWACs) [LE] [CMP] as equipment that is located outside a steam environment during a turbine building HELB. With the SRW pump room door open, this equipment would have been exposed to a steam environment that it was not analyzed for. Therefore, the equipment would be assumed unavailable to respond to a HEL8 event to bring the plant to a safe shutdown condition. A loss of SRW would result in the loss of one of two emergency diesel generators [DG], which would leave one emergency diesel generator to respond to the event and bring the plant to a safe shutdown condition. The loss of the motor driven AFW train would leave two steam driven AFW pumps to respond to the event and bring the plant to a safe shutdown condition. The loss of the SWACs would require operator action during the course of an event to mitigate that loss.
When the HEL8 barrier was opened, the SRW systems behind the barrier should have been declared inoperable per the TSs. For the SRW system, TS LCO 3.0.3 should have been entered. For the. auxiliary feedwater system, TS LCO 3.0.9 should have been entered for one train out of service. There is no TS for the SWACs. These TSs have Actions that are longer than the approximately three and a half minutes that the SRW pump room door was opened.
Therefore, no TSs were violated during this event.
The subject condition satisfies the criteria in NUREG-1022, Revision 3, for an event or condition that could have prevented the fulfilment of a safety function for a system needed to respond to a HEL8 to provide safe shutdown of the reactor, remove residual heat and mitigate the consequence of an accident, due to the loss of both trains of SRW. Therefore, this event is reportable pursuant to 10 CFR 50.73(a)(2)(v)(A) and (8) and (D). In addition, this condition also results in an unanalyzed condition that significantly degrades plant safety based on the loss of safety function and is reportable pursuant to 10 CFR 50.?3(a)(2)(ii)(B). This condition also caused a common cause inoperability of independent trains, since the open barrier (common cause) affected both (independent) trains of SRW. This is reportable pursuant to 1 O CFR
- 50. 73(a)(2)(vii).
- 8.
CORRECTIVE ACTIONS
IR 2625943 was written to require appropriate evaluation of the green NCV received frorn the NRC in Inspection Report 05000317/2015004 and 05000318/2015004. The work group evaluation determined that the apparent cause of the event was that an Engineer failed to provide adequate change management for the implementation of the barrier control procedure by not briefing all affected organizations. Action was taken to provide a briefing to all potentially affected work groups on site. Corrective action for the human performance issue was handled through the performance management system.
Ill. PREVIOUS SIMILAR EVENTS:
A review of Calvert Cliffs' events over the past several years was performed and no similar instances were found.
A.
COMPONENT INFORMATION:
COMPONENT None 05000 317 YEAR 2016 IEEE 803 FUNCTION ID I
SEQUENTIAL NUMBER
-- 004 --
IEEE 805 SYSTEM ID I
REV NO.
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