05000354/LER-2015-003, Regarding Conditions Prohibited by Technical Specifications Due to Low Pressure ECCS
| ML15187A207 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 07/06/2015 |
| From: | Carr E Public Service Enterprise Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LR-N15-0141 LER 15-003-00 | |
| Download: ML15187A207 (6) | |
| Event date: | |
|---|---|
| Report date: | |
| 3542015003R00 - NRC Website | |
text
LR-N15-0141 JUL 0 6 2015 PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-001 Hope Creek Generating Station Unit 1 PSEG Nuclear LLC 10CFR50.73 Renewed Facility Operating License No. NPF-57 Docket No. 50-354
Subject:
Licensee Event Report 2015-003-00 In accordance with the requirements of 10 CFR 50. 73(a)(2)(i)(B),
PSEG Nuclear LLC is submitting the enclosed Licensee Event Report (LER) Number 2015-003-00, "Conditions Prohibited by Technical Specifications Due to Low Pressure ECCS lnoperabilities."
If you have any questions or require additional information, please contact Mr. Thomas MacEwen at (856) 339-1097.
There are no regulatory commitments contained in this letter.
Sincerely, Eric S. Carr Plant Manager Hope Creek Generating Station ttm Attachment: Licensee Event Report 2015-003-00
LR-N15-0141 Page 2 of 2 Document Control Desk cc:
Mr. Daniel Dorman, Regional Administrator-Region I, NRC Ms. Carleen Parker, Project Manager - US NRC Justin Hawkins, NRC Senior Resident Inspector-Hope Creek (X24)
Mr. Patrick Mulligan, Manager IV Bureau of Nuclear Engineering New Jersey Department of Environmental Protection PO Box 420 Trenton, NJ 08625 10CFR50.73 Mr. Thomas MacEwen, Hope Creek Commitment Tracking Coordinator (H02)
Mr. Lee Marabella - Corporate Commitment Tracking Coordinator (N21)
NRG FORM 366 U.S. N UCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 01/31/2017 (02-2014) ti1\\.Mi:rf
, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.
- 6. LER NUMBER YEAR I SEQUENTIAL I REVISION NUMBER NUMBER 201 5
- - 003
- - 000
- 3. PAGE 2 OF4
- Energy Industry Identification System {EllS} codes and component function identifier codes appear as {SS/CCC}
IDENTIFICATION OF OCCURRENCE Event Date: May 4, 2015 Discovery Date: May 5, 2015 CONDITIONS PRIOR TO OCCURRENCE Hope Creek was shut down for Refueling Outage H1R19 in Operational Condition (OPCON) 4 - Cold Shutdown.
DESCRIPTION OF OCCURRENCE From May 4 through 5, 2015, Hope Creek conducted a planned Reactor Pressure Vessel {AC/RPV} pressure test following RPV reassembly during refuel outage H1R19. The RPV pressure test is considered to be an Operation With the Potential to Drain the Vessel (OPDRV) because some isolation interlocks are bypassed during the test to preclude instrument failures that could lead to over-pressurization of the RPV.
Technical Specification (TS) 3.5.2, ECCS Shutdown, requires that at least two Low Pressure Emergency Core Cooling System (ECCS) subsystems be OPERABLE in Operational Condition 4. The TS requires that with only one ECCS subsystem operable, two subsystems shall be restored to operable status within four hours, or suspend all operations with the potential to drain the reactor vessel. Contrary to this requirement, Hope Creek conducted an OPDRV activity with only one low pressure ECCS subsystem operable.
Hope Creek has a total of six low pressure ECCS subsystems that could be used to meet the requirements of TS 3.5.2. The status of each of the subsystems at the time of the event is provided in Table 1, below. Although only one Core Spray {BM} subsystem was operable at the time, there were two additional low pressure subsystems that were available with operator action in the event that ECCS injection was required. The 'C' RHR {BO} subsystem was aligned for the Low Pressure Coolant Injection (LPCI) mode of operation with the pump breaker in the Pull-To-Lock (PTL) position. When in the PTL position, breaker closure is inhibited for automatic and manual start signals.
Removing the breaker from PTL requires dispatching an operator to the breaker to reposition a single switch on the front of the breaker cubicle. The 'A' RHR subsystem was aligned for shutdown cooling, but isolated from the reactor coolant system to support the RPV pressure test. The 'A' RHR subsystem could be realigned from the control room to the LPCI mode of operation by repositioning pump suction and discharge valves.
With some Low Pressure ECCS subsystems already inoperable, 'B' and 'D' RHR Pumps were removed from service for outage-related maintenance. The collective operability status of the Low Pressure ECCS Pumps was not appropriately assessed for TS compliance. Table 1 summarizes the status of ECCS subsystems used to meet TS 3.5.2 during the period in question.
This condition existed from May 4, at 0400 until May 5 at 1042, a period of 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> and 42 minutes. TS compliance was restored on May 5 at 1042, when the condition was recognized and a second low pressure ECCS system was returned to operable. U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 01/31/2017 (02-2014)
, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.
- 1. FACILITY NAME
- 2. DOCKET
- 6. LER NUMBER
- 3. PAGE YEAR I SEQUENTIAL I REVISION Hope Creek Generating Station NUMBER NUMBER 05000354 3 OF4 2015
- - 003
'A' Core Spray subsystem Inoperable; out of service for maintenance
'B' Core Spray subsystem Operable and in standby
'A' RHR I LPCI subsystem Aligned for SOC; inoperable for ECCS but Could be realigned for available for realignment LPCI from the Control Room
'B' RHR I LPCI subsystem Inoperable; out of service for maintenance
'C' RHR I LPCI subsystem Inoperable but available; pump breaker in PTL Could be restored to operable at the pump breaker
'D' RHR I LPCI subsystem Inoperable; out of service for maintenance
CAUSE OF EVENT
The cause of the event was determined to be failure to properly assess the operability status of all the ECCS subsystems which could be used to meet TS 3.5.2 prior to rendering 'B' and 'D' RHR inoperable for scheduled maintenance.
SAFETY CONSEQUENCES AND IMPLICATIONS
The Emergency Core Cooling System (ECCS) network has built-in redundancy so that adequate inventory makeup can be provided, even with other failures. In Operational Condition 4, the primary purpose of the Core Spray and LPCI subsystems is to provide reactor vessel inventory makeup during postulated drain-down events. LPCI is an operating mode of the RHR system.
The 'A' RHR subsystem was aligned for shutdown cooling, but isolated from the reactor coolant system to support the RPV pressure test. The 'A' RHR subsystem could be realigned from the control room to the LPCI mode of operation by repositioning pump suction and discharge valves. In addition, the 'C' RHR subsystem was available to place in the LPCI mode of operation, if required, by removing the pump breaker from the pull-to-lock position. Improved Standard Technical Specifications (ISTS) recognized that LPCI subsystems aligned for SDC could be considered OPERABLE for ECCS provided the subsystem was otherwise OPERABLE and capable of being manually realigned. This change to the applicability of TS 3.5.2 was endorsed by the NRC approval of TSTF-416, "LPCI Valve Alignment Verification Note Location."
There were no actual consequences due to inoperability of the second required low pressure ECCS system. There is no safety significance associated with this event based on the other low pressure ECCS systems that were available for inventory makeup. (02-2014)
U. S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)
CONTINUATION SHEET
- 1. FACILITYNAME
- 2. DOCKET Hope Creek Generating Station 05000354 SAFETY SYSTEM FUNCTIONAL FAILURE APPROVED BY OMB: NO. 3150-0104 EXPIRES: 01/31/2017
, the NRG may not conduct or sponsor, and a person is not required to respond to, the information collection.
YEAR 2015
- 6. LER NUMBER I
SEQUENTIAL I REVISION NUMBER NUMBER
- - 003
- - 000
- 3. PAGE 4 OF4 There were no safety system equipment problems associated with this event; therefore, there was no safety system functional failure as defined in NEI 99-02, Revision 7, Regulatory Assessment Performance Indicator Guideline.
PREVIOUS EVENTS A review of HCGS LERs from the past three years did not reveal any similar previous events.
CORRECTIVE ACTIONS
The procedure used for operability assessment and equipment control will be revised to clarify the implementation requirements of TS 3.5.2.
Other corrective actions are being tracked in the licensee's Corrective Action Program.
COMMITMENTS
This LER contains no regulatory commitments.