05000325/LER-2010-002, For Brunswick Steam Electric Plant Unit 1, Regarding Operation Prohibited by Technical Specifications - Reactor Protection System (RPS) Instrumentation
| ML101800152 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 06/23/2010 |
| From: | Wills E Progress Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BSEP 10-0076 LER 10-002-00 | |
| Download: ML101800152 (7) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 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)(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)(B), Prohibited by Technical Specifications |
| 3252010002R00 - NRC Website | |
text
Progress Energy JUN 23 2010 SERIAL: BSEP 10-0076 10 CFR 50.73 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
Brunswick Steam Electric Plant, Unit No. 1 Renewed Facility Operating License No. DPR-71 Docket No. 50-325 Licensee Event Report 1-2010-002 Ladies and Gentlemen:
In accordance with the Code of Federal Regulations, Title 10, Part 50.73, Carolina Power
& Light Company, now doing business as Progress Energy Carolinas, Inc., submits the enclosed Licensee Event Report (LER). This report fulfills the requirement for a written report within sixty (60) days of a reportable occurrence.
Please refer any questions regarding this submittal to Ms. Annette Pope, Supervisor -
Licensing/Regulatory Programs, at (910) 457-2184.
Sincerely, Edward L. Wills, Jr.
Plant General Manager Brunswick Steam Electric Plant MAT/mat
Enclosure:
Licensee Event Report Progress Energy Carolinas, Inc.
Brunswick Nuclear Plant PO Box 10429 Southport, NC 28461
Document Control Desk BSEP 10-0076 / Page 2 cc (with enclosure):
U. S. Nuclear Regulatory Commission, Region II ATTN: Mr. Luis A. Reyes, Regional Administrator 245 Peachtree Center Avenue, NE, Suite 1200 Atlanta, GA 30303-1257 U. S. Nuclear Regulatory Commission ATTN: Mr. Philip B. O'Bryan, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission (Electronic Copy Only)
ATTN: Mrs. Farideh E. Saba (Mail Stop OWFN 8G9A) 11555 Rockville Pike Rockville, MD 20852-2738 Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 08/31/2010 (9-2007)
, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.
- 3. PAGE Brunswick Steam Electric Plant (BSEP), Unit 1 05000325 1 of 5
- 4. TITLE Operation Prohibited by Technical Specifications - Reactor Protection System (RPS) Instrumentation
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED SFACILITY NAME DOCKET NUMBER MONTH DAY YEAR SEQUENTIAL REV MONTH DAY YEAR 05000 NUMBER NO.
0000 FACILITY NAME DOCKET NUMBER 04 25 2010 2010 - 002 - 00 06 23 2010 05000
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)
[: 20.2201(b)
El 20.2203(a)(3)(i)
[: 50.73(a)(2)(i)(C)
El 50.73(a)(2)(vii) 2
[: 20.2201(d)
El 20.2203(a)(3)(ii)
LI 50.73(a)(2)(ii)(A)
El 50.73(a)(2)(viii)(A)
[] 20.2203(a)(1)
LI 20.2203(a)(4)
LI 50.73(a)(2)(ii)(B)
El 50.73(a)(2)(viii)(B)
El 20.2203(a)(2)(i)
LI 50.36(c)(1)(i)(A)
LI 50.73(a)(2)(iii)
El 50.73(a)(2)(ix)(A)
- 10. POWER LEVEL [L 20.2203(a)(2)(ii)
[1 50.36(c)(1)(ii)(A)
El 50.73(a)(2)(iv)(A)
[L 50.73(a)(2)(x)
EL 20.2203(a)(2)(iii)
[L 50.36(c)(2)
[: 50.73(a)(2)(v)(A)
[L 73.71 (a)(4) 000 El 20.2203(a)(2)(iv)
El 50.46(a)(3)(ii)
[1 50.73(a)(2)(v)(B)
El 73.71 (a)(5)
El 20.2203(a)(2)(v)
L-50:73(a)(2)(i)(A)
[L 50.73(a)(2)(v)(C)
LI OTHER LI 20.2203(a)(2)(vi) 0 50.73(a)(2)(i)(B)
El 50.73(a)(2)(v)(D)
Specify in Abstract below or I_
in Dome Pressure - High," of TS 3.3.4.1, "Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation." However, the Applicability for TS 3.3.4.1 is Mode 1 and the issue was identified and corrected prior to entry into Mode 1.
Event Cause
The select cause of this event was the failure to effectively use concurrent verification during the performance of procedure OMST-EFCV18R, "EFCV Rx Inst Pen Sys Isol Vlv Func Test X53, X82, X49B-A." As a result, valve 1 -B2 1 -IV-1384 was left in the closed versus open position. A review was performed to confirm that performance of OMST-EFCV 1 8R, between March 18 and March 20, 2010, was the only outage activity that could have resulted in the mispositioning of valve 1-B21-IV-1384. OMST-EFCV 18R determines operability of several reactor instrument penetration Excess Flow Check Valves (EFCVs) in conformance with TS Surveillance Requirement 3.6.1.3.7 (i.e., verify a representative sample of reactor instrumentation line EFCVs actuate to the isolation position on an actual or simulated instrument line break signal).
The technicians involved with performing OMST-EFCV I8R were individually interviewed regarding procedure compliance details. The concurrent process consisted of one individual implementing place-keeping and initialing of each step. The second individual, in close proximity and able to concurrently read the step, performed valve manipulations. Gloves were used for potential contamination control while touching the valve handles. This individual would manipulate several valves and after completion of
- multiple procedure steps, remove the gloves and signoff the completed steps. The occurrence of an error during this evolution cannot be confirmed. However, it is believed that errors in place-keeping occurred that resulted in the step for restoration of the isolation valve for B21-PT-N023B (i.e., and B21-PT-N045B) being missed or otherwise incorrectly performed. This is substantiated by the fact that performance of OMST-EFCV 1 8R was the only outage activity that could have resulted in the mispositioning of valve 1-B21-IV-1384.
A contributing cause to this event was a lack of sufficient barriers, in the Return to Service section of OMST-EFCV 18R, to ensure proper system alignment at the completion of the surveillance test. The procedure requires the plant to be in Mode 5 and, as such, contains no means to functionally verify proper component operation upon completion of the test. Additionally, the procedure does not contain independent verification of critical steps to verify components are returned to service.
Safety Assessment
The safety significance of this event is considered minimal. Pressure transmitter 1-B21-PT-N023B is part of the instrumentation required for operability of Function 3, "Reactor Vessel Steam Dome Pressure -
High," of TS 3.3.1.1, "Reactor Protection System (RPS) Instrumentation," which generates a RPS actuation signal. The trip channels for this Function are as follows:
- Al B21-PT-N023A
- A2 B21-PT-N023C 131 B21-PT-N023B
- 132 B21-PT-N023D In this case, the B11 channel was inoperable. Due to the one-out-of-two taken twice logic (i.e., A1 or A2 and B11 or B2 will result in a RPS actuation), trip capability was maintained. Therefore, there was no loss of safety function.
Corrective Actions
The following corrective action-to prevent recurrence has been identified.
" Operations procedure 001-01.02, "Operations Unit Organization and Operating Practices," currently contains proper concurrent verification methodology. Maintenance personnel will use the concurrent verification process described within 001-01.02 during performance of maintenance activities requiring concurrent verification. Implementation of this expectation, within the Maintenance organization, has been completed.
- OPS-NGGC-1303, "Independent Verification," is a fleet level procedure that provides instructions for performance of independent verification including concurrent and functional verification for each of Progress Energy's nuclear plants. This procedure will be revised to incorporate the concurrent verification methodology contained in 001-01.02. This procedure revision is currently scheduled to be completed by August 19, 2010.
Additional corrective actions include the following.
- Valve 1-1321 -IV-1384 was repositioned and, after appropriate testing, pressure transmitter 1-1321-PT-N023B was declared operable at 0309 hours0.00358 days <br />0.0858 hours <br />5.109127e-4 weeks <br />1.175745e-4 months <br /> on April 26, 2010.
- Procedure OMST-EFCV 1 8R will be revised to include requirements for independent verification of critical steps. This procedure revision is currently scheduled to be completed by July 7, 2010.
o Other EFCV surveillance procedures will be revised, as necessary, to include requirements for independent verification of critical steps. The identified procedure revisions are currently scheduled to be completed by July 7, 2010.
Previous Similar Events
A review of LERs and corrective action program condition reports for the past three years identified no previous similar events where failure to effectively use the concurrent verification resulted in Unit 1 or Unit 2 operation prohibited by the plant's Technical Specification.
Commitments
No regulatory commitments are contained in this report.