05000325/LER-2014-002, Regarding Secondary Containment Isolation Dampers Inoperable During Operations with Potential to Drain the Reactor Vessel
| ML14135A050 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 05/05/2014 |
| From: | Hamrick G Duke Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BSEP 14-0041 LER 14-002-00 | |
| Download: ML14135A050 (6) | |
| 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)(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 |
| 3252014002R00 - NRC Website | |
text
DUKE
- ENERGY, MAY 0 5 2014 George T. Hamrick Vice President Brunswick Nuclear Plant Duke Energy Progress P.O. Box 10429 Southport, NC 28461 o: 910.457.3698 10 CFR 50.73 Serial: BSEP 14-0041 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
Subject:
Brunswick Steam Electric Plant, Unit No. 1 Renewed Facility Operating License No. DPR-71 Docket No. 50-325 Licensee Event Report 1-2014-002 In accordance with the Code of Federal Regulations, Title 10, Part 50.73, Duke Energy Progress, 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 Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 457-2487.
Sincerely, George Hamrick SWR/swr
Enclosure:
Licensee Event Report
U.S. Nuclear Regulatory Commission Page 2 of 2 cc (with enclosure):
U. S. Nuclear Regulatory Commission, Region II ATTN: Mr. Victor M. McCree, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U. S. Nuclear Regulatory Commission ATTN: Ms. Michelle P. Catts, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission ATTN: Mr. Siva P. Lingam (Mail Stop OWFN 8G9A) (Electronic Copy Only) 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: 01131/2017 (02-2014)
(02
,201,4)
Estimated burden per response to comply with this mandatory collection request: 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />.
Reported lessons learned are incorporated into the licensing process and fed back to industry.
Send comments regarding burden estimate to the FOIA, Privacy and Information Collections EV NEEO TBranch (T-5 F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by LICENSEE EVR (LER) internet e-mall to lnfocollects.Resource@nrc.gov, and to the Desk Officer, Office of Information and (See Page 2 for required number of Regulatory Affairs, NEOB-10202, (3150-0104), Office of Management and Budget. Washington, DC 20503. If a means used to impose an information collection does not display a currenty valid OMB digits/characters for each block) control number, 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 4
- 4. TITLE Secondary Containment Isolation Dampers Inoperable During Operations with Potential to Drain the Reactor Vessel
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR SEQUENTIAL REV MONTH DAY YEAR DOCKET NUMBER NO.NAE000 FACILITY NAME DOCKET NUMBER 03 09 2014 2014 -
002
- - 00 05 05 2014 05000
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)
F] 20.2201(b)
El 20.2203(a)(3)(i)
El 50.73(a)(2)(i)(C)
LI 50.73(a)(2)(vii) 5l 20.2201(d)
El 20.2203(a)(3)(ii)
El 50.73(a)(2)(ii)(A)
El 50.73(a)(2)(viii)(A)
El 20.2203(a)(1)
[]
20.2203(a)(4)
El 50.73(a)(2)(ii)(B)
El 50.73(a)(2)(viii)(B) 20.2203(a)(2)(i)
[1 50.36(c)(1)(i)(A)
El 50.73(a)(2)(iii)
El 50.73(a)(2)(ix)(A)
- 10. POWER LEVEL El 20.2203(a)(2)(ii)
[1 50.36(c)(1)(ii)(A)
El 50.73(a)(2)(iv)(A)
El 50.73(a)(2)(x)
El 20.2203(a)(2)(iii)
[: 50.36(c)(2)
El 50.73(a)(2)(v)(A)
El 73.71(a)(4) 00 20.2203(a)(2)(iv)
El 50.46(a)(3)(ii)
El 50.73(a)(2)(v)(B)
El 73.71(a)(5)
El 20.2203(a)(2)(v)
El 50.73(a)(2)(i)(A)
El 50.73(a)(2)(v)(C)
El OTHER
__ 20.2203(a)(2)(vi)
[
50.73(a)(2)(i)(B)
El 50.73(a)(2)(v)(D)
Specify in Abstract below or in I
Energy Industry Identification System (EIIS) codes are identified in the text as [XX].
Introduction
Initial Conditions At the time the event occurred, Unit 1 was in Mode 5 at zero percent rated thermal power. Secondary containment [NG] was removed from service, and the guidance of Enforcement Guidance Memorandum (EGM) 11-003, Revision 2, "Dispositioning Boiling Water Reactor Licensee Noncompliance with Technical Specifications Containment Requirements During Operations with a Potential to Drain the Reactor Vessel," was being followed per plant procedure.
Reportability Criteria This event is reportable per 10 CFR 50.73)(a)(2)(i)(B) as a condition prohibited by the plant's Technical Specifications (TS). Leading up to this event, secondary containment was removed from service while operations with potential to drain the reactor vessel (OPDRVs) were in progress. This is permitted by EGM 11-003 if certain conditions are met. Action 4 of EGM 11-003 says that all other TS requirements involving OPDRVs must be satisfied, and if the TSs are more restrictive than EGM 11-003 guidance, then the TSs must be followed. TS Limiting Condition for Operation (LCO) 3.6.4.2 requires secondary containment isolation dampers (SCIDs) to be operable during OPDRVs. Per the guidance in EGM 11-003, the SCIDs must remain operable during OPDRVs even if the secondary containment has been properly removed from service. At the time of the event, one train of SCIDs was being supplied by temporary electric control power rather than by normal or emergency electric control power. Per the TS definition of operability, either normal or emergency power is required for operability. Without either of these, the affected SCIDs were declared inoperable. The Required Actions of LCO 3.6.4.2 for inoperable SCIDs were not carried out within the Completion Times; therefore, the plant entered a condition prohibited by the TS, and the event is reportable per 10 CFR 50.73(a)(2)(i)(B).
Event Description
On March 9, 2014, Unit 1 was in Mode 5 with the reactor vessel disassembled, water level equalized with the spent fuel pool (SFP), SFP gates removed and a refueling outage underway.
As part of normal outage maintenance activities, leakage was identified from valves connected to the reactor coolant system [AD]. The leakage was classified as an OPDRV. Outage plans called for work to be performed on a main steam [SB] isolation valve, which rendered the secondary containment inoperable when the valve was disassembled. With OPDRVs ongoing and secondary containment planned to be made inoperable, actions were taken to comply with EGM 11-003.
Concurrent with these activities, planned electrical bus work began, which later resulted in removing the normal and emergency control power supplies for one train of SCIDs, rendering them inoperable.
Temporary electrical control power was supplied to the SCIDs because involved personnel mistakenly believed temporary control power was satisfactory since it would provide the SCIDs with the capability to perform their function.
The next shift of Operations personnel questioned whether the temporary power satisfied the requirements for TS operability of the SCIDs and determined that it did not. Subsequently, actions were taken to isolate leakage paths from the reactor, exiting the OPDRV condition by 0453 EDT on March 10, 2014. When OPDRVs were halted, TS compliance was restored.
Event Cause
This event resulted from a procedural deficiency. The temporary power procedure, 0MMM-054, "Temporary Power Feed Documentation," does not require an operability decision by a licensed Senior Reactor Operator (SRO) before determining what process will be used to supply temporary power. A contributing cause was that related procedure OSMP-DMPOO2, "Tie-In of Unit 1 Temporary Power Loads During Division 1 and Division 2 Bus Outages," also fails to state that supplying SCIDs with temporary power could make them inoperable; therefore, in this event, temporary power was applied to SCIDs to maintain their functionality. This condition was erroneously accepted in lieu of a formal review for operability by a licensed individual. This resulted in the temporary power being credited for operability of the SCIDs.
Safety Assessment
The safety significance of this event is minimal. The sole nuclear safety function of the SCIDs is to support secondary containment operability. However, the secondary containment was properly removed from service throughout the event, and the compensatory measures of EGM 11-003 were properly implemented, except for maintaining SCID operability. In addition, temporary control power was sourced from a safety-related electrical bus, though not through a qualified connection. This maintained the capability for the SCIDs to perform their function, but they were not considered operable per the Technical Specifications. Consequently, this event had no adverse impact on nuclear safety.
Corrective Actions
Any changes to the corrective actions and schedules noted below will be made in accordance with the site's corrective action program.
Procedures OMMM-054 and OSMP-DMP002 will be revised by August 6, 2014, to include review by a Senior Reactor Operator and to state that temporary power supplies installed without the use of a formal design process cannot be credited for operability.
Previous Similar Events
Previously submitted LERs and the site's corrective action program database were reviewed for the past three years to identify any previous similar events in which components were erroneously relied on for operability. An event was reported via LER 1-2012-006, dated November 19, 2012, in which a seal on a reactor recirculation system pump was being replaced. The pump's isolation valve had minor leakage, which was not identified as an OPDRV. The corrective action for that event was to revise procedure 001-01.01, "Conduct of Plant Operations Supplement," to clarify the conditions when the plant must be considered to be in an OPDRV. That corrective action addressed when the guidance of EGM 11-003 should be applied and could not reasonably have been expected to prevent this event.
Commitments
No regulatory commitments are contained in this report.