05000366/LER-2013-003, Regarding HPCI Declared Inoperable Due to Error in Connecting Tubing to a Hydraulic Actuator
| ML13137A426 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 05/17/2013 |
| From: | Pierce C Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-13-0984 LER 13-003-00 | |
| Download: ML13137A426 (6) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(v), Loss of Safety Function 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)(8) 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 3662013003R00 - NRC Website | |
text
Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company. Inc.
40 Inverness Center Parkway Post Office Box 1295 Alabama 35201 Tel 205.992.7872 Fax 205.992.7601 SOUTHERN'\\
COMPANY May 17, 2013 Docket Nos.: 50-366 NL-13-0984 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant - Unit 2 Licensee Event Report 2013-03 HPCI Declared Inoperable Due to Error in Connecting Tubing to an Hydraulic Actuator Ladies and Gentlemen:
In accordance with the requirements of 10 CFR 50.73(a)(2)(v)(D), Southern Nuclear Operating Company hereby submits the enclosed Licensee Event Report concerning an incorrectly performed 10-year preventive maintenance procedure that led to the inoperability of the High Pressure Coolant Injection (HPCI) system.
This letter contains no NRC commitments. If you have any questions, please contact Doug McKinney at (205) 992-5982.
Respectfully submitted, C.R. Pierce Regulatory Affairs Director CRP/SB/md Enclosures: LER 2-2013-03
U. S. Nuclear Regulatory Commission NL-13-0984 Page 2 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. B. L. Ivey, Vice President - Regulatory Affairs Mr. B. J. Adams, Vice President - Fleet Operations Mr. M. A. Dowd - OE Coordinator RTYPE: CHA02.004 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager - Hatch Mr. E. D. Morris, Senior Resident Inspector - Hatch
Edwin I. Hatch Nuclear Plant Licensee Event Report 2013-03 HPCI Declared Inoperable Due to Error in Connecting Tubing to a Hydraulic Actuator
~RCFORM366 U.S. NUCLEAR REGULATORY COMMISSION 10-2010)
LICENSEE EVENT REPORT (LER)
APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/3112013 Estimated burden per response to comply with this mandatory collection request: SO hours. Reported lessons learned are incorporated into the licensing process and fed back to industry. Send comments re~arding burden estimate to the Records and FOIAJPrivacy Service Branch ( -5 F53). U.S.
Nuclear Re~ulatory Commission, Washington, DC 20555-0001. or by internet e-mail to in ocollects.resources@nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, (3150..(J104), Office of Mana~ement and Budget, Washington. DC 20503. If a means used to impose an in ormation collection does not display a currently valid OMB control number. the NRC may not conduct or sponsor, and a person is not required to resoond to. the information collection.
- 1. FACILITY NAME Edwin I. Hatch Nuclear Plant Unit 2
- 2. DOCKET NUMBER
- 13. PAGE 05000366 1 OF 3
- 4. TITLE HPCI Declared Inoperable Due to Error in Connecting Tubing to a Hydraulic Actuator
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR SEQUENTIAL NUMBER REV NO.
MONTH DAY YEAR FACILITY NAME DOCKET NUMBER 03 18 2013 2013 - 003 -
00 05 17 2013 FACILITY NAME DOCKET NUMBER
~. OPERATING MODE Mode 2
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR§: (Check al/ that apply) o 20.2201 (b) o 20.2203(a)(3)(i) o SO.73(a)(2)(i)(C) o 50.73(a)(2)(vii) o 20.2201 (d) o 20.2203(a)(3)(ii) o 50.73(a)(2)(ii)(A) o 50.73(a)(2)(viii)(A) o 20.2203(a)(1) o 20.2203(a)(4) o 50.73(a)(2)(ii)(B) o 50.73(a)(2)(viii)(B) o 20.2203(a)(2)(i) o 50.36(c)(1)(i)(A) o 50.73(a)(2)(iii) o 50.73(a)(2)(ix)(A) o 20.2203(a)(2)(ii) o 50.36(c)(1)(ii)(A) o 50.73(a)(2)(iv)(A) o 50.73(a)(2)(x) o 20.2203(a)(2)(iii) o 50.36(c)(2) o 50.73(a)(2)(v)(A) o 73.71(a)(4) o 20.2203(a)(2)(iv) o 50.46(a)(3)(ii) o 50.73(a)(2)(v)(8) o 73.71(a)(5) o 20.2203(a)(2)(v) o 50.73(a)(2)(i)(A) o 50.73(a)(2)(v)(C) o OTHER o 20.2203(a)(2)(vi) o 50.73(a)(2)(i)(B) 181 50.73(a)(2)(v)(O)
Specify in Abstract below or in NRC Form 366A
- 10. POWER LEVEL 000
- 12. LICENSEE CONTACT FOR THIS LER FACILITY NAME ITELEPHONE NUMBER (Include Area Code)
Edwin I. Hatch I Steven Tipps - Principal Engineer - Licensing 912-537-5880 CAUSE SYSTEM COMPONENT MANU FACTURER REPORTABLE TO EPIX
CAUSE
SYSTEM COMPONENT MANU FACTURER REPORTABLE TO EPIX D
BJ XCO W290 Yes
ONO
- 15. EXPECTED SUBMISSION DATE 08 29 2013 ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)
On March 18,2013 at 0910 EDT, the Unit 2 High Pressure Coolant Injection (HPCI) system was declared inoperable after the Turbine Control Valve (TCV) did not open as expected during the HPCI Pump Operability 165 psig Test. Unit 2 was in Mode 2 (Startup) and was not in power production at the time of the event. The TCV failed to open because the hydraulic lines between the E-GR actuator and the remote servo had been interchanged during performance of the 10-year preventive maintenance procedure in the 2013 refueling outage for Unit 2.
Technical Specification 3.5.1.C requires HPCI to be operable in Mode 1 and in Modes 2 and 3 when reactor pressure is greater than 150 psig. If no other Emergency Core Cooling Systems (ECCS) are inoperable and the Reactor Core Isolation Cooling System (RCIC) is determined to be operable, Unit 2 can repair HPCI within fourteen days before an escalation in required actions is necessary. However, HPCI is a Single-train system and the declaration of inoperability requires Unit 2 to report the loss of HPCI in accordance with 10 CFR 50.72(b)(3)(v)(D) and 10 CFR 50.73(a)(2)(v)(D): Event or Condition that Could Have Prevented Fulfillment of a Safety Function. The required eight-hour report was made at 1650 EDT on March 18, 2013. This Licensee Event Report is written to satisfy the requirement to report under 10 CFR 50.73(a)(2)(v)(D).
NRC FORM 366 (9-2007)
PRINTED ON RECYCLED PAPER
3
PLANT AND SYSTEM IDENTIFICATION
General Electric - Boiling Water Reactor Energy Industry Identification System codes appear in the text as (EllS Code XX).
DESCRIPTION OF EVENT
Unit 2 was returning to power production on March 18, 2013 after the 2R22 refueling outage and the crew was running a bank of operability tests in preparation for startup operations. Unit 2 High Pressure Coolant Injection (HPCI) (BJ) system had been in a system outage but was returned to operable status based on successful surveillances performed prior to reactor vessel pressurization.
Technical Specification (TS) 3.0.5 allows equipment removed from service to comply with actions to be returned to service under administrative controls. The restriction in TS 3.0.5 states that the equipment can be operated only to demonstrate its operability, or the operability of other equipment.
The final functional test surveillances for HPCI operability must occur at known reactor pressures.
The first of these surveillances occurs when reactor pressure is between 150 psig and 165 psig. The second surveillance is performed when reactor pressure is between 920 psig and 1058 psig. HPCI is required to be operable when reactor pressures are greater than 150 psig in Mode 2 by Technical Specification 3.5.1. The crew is allowed to assume HPCI operability based on preliminary surveillances so that the plant can move from Mode 5 (Refuel) to Mode 2 (Startup). In this manner, the final functional tests can be performed prior to entering Mode 1 (Run).
In the morning of March 18, 2013 the crew logged an entry for the HPCI Pump Operability 165 PSIG Test at 0803 EDT. At 0910 EDT, the crew entered a Required Action Statement for Technical Specification 3.5.1.C because the system operators indicated that the HPCI Turbine Control Valve did not open as expected when performing the HPCI Pump Operability 165 psig Test. A surveillance for Reactor Core Isolation Cooling (RCIC) System Operability had been performed at 0600 EDT that morning, and RCIC had proven to be operable. The crew began reducing pressure in the reactor vessel to less than 150 psig, and formed an Incident Response Team (JRT) to identify the cause(s) of the HPCI failure and affect repairs. Shift Management made the required 8-hour report per 10 CFR 50.72(b)(3)(v)(O) for the HPCI system at 1650 EDT and notified the site resident inspectors.
CAUSE OF EVENT
A final apparent cause report is not available at the time this Licensee Event Report is submitted to the NRC. A determination was made that the hydraulic tubing between two ports on the EG-R hydraulic actuator and the remote servo had been interchanged. The resulting inability to remove the pressure at the affected port was determined to be the direct cause for the Turbine Control Valve (TCV) failure to open. The EG-R and remote servo had been replaced during the 2R22 refueling outage by vendors in February, 2013. There were two apparent causes for the event. First, the 10 year preventive maintenance procedure for the evolution did not have a complete diagram between the EG-R hydraulic actuator and remote servo. A more complete diagram was available in another system procedure, but was not referenced for this evolution. The procedure the vendor used has instructions to label the ends of the tubing for correct placement, but gives no instructions on how to label them or confirm their routing. The second cause was related to human performance in that self checking was inadequate or not used. The vendor employees were required to label the hydraulic connections prior to removal. If self-checking had been performed when labeling and routing the LICENSEE EVENT REPORT (LER) u.s. NUCLEAR REGULATORY COMMISSION (10-2010)
CONTINUATION SHEET
- 1. FACILITY NAME
- 2. DOCKET
- 6. LER NUMBER
- 3. PAGE YEAR I SEQUENTIAL
/REVISION l
NUMBER NUMBER 3
OF 3
2013 003 0
Edwin I. Hatch Nuclear Plant Unit 2 05000-366 tubes, it is unlikely that the lines would have been interchanged. A subsequent revision will be provided after the final cause determination is completed.
REPORT ABILITY ANALYSIS And SAFETY ASSESSMENT While Technical Specifications allows HPCI to be inoperable for a limited number of hours, or days under certain circumstances, HPCI is a single-train Emergency Core Cooling System and any failure of the HPCI system could prevent the fulfillment of its safety function to mitigate the consequences of an accident. This failure of HPCI was discovered when the plant was returning to power from a refueling outage. The failure was discovered during one of the surveillances required for HPCI operability after reactor pressurization begins, but before power operations have begun. The response to the failure was to reduce reactor pressure to less than 150 psig until HPCI could be repaired. The other high pressure core coolant injection system, RCIC was also confirmed to be operable at the time of the HPCI actuator failure. RHR and Core Spray systems that are relied upon to mitigate the consequences of a DBA were fully operable during this evolution which provided full capacity to mitigate the consequences of a DBA during the time that HPCI was considered inoperable. Given these conditions, this failure of the HPCI actuator was considered to have low
safety significance
CORRECTIVE ACTIONS
Procedure 52PM-E41-002-0 (HPCI Turbine and Auxiliaries Major Inspection) was revised to include detailed instructions on the labeling of the EG-R and remote servo piping prior to removal.
Additionally, a verification step/signoff prior to removal and during reinstallation was included. More corrective actions will be provided once the final cause determination is completed.
ADDITIONAL INFORMATION
Other Systems Affected: None
Failed Components Information
Master Parts List Number:
2E41C002-5*
EllS System Code: BJ Manufacturer: Woodward Reportable to Epix: Yes Model Number: DR9903-099 Root Cause Code: D Type: E-GR Hydraulic Actuator EllS Component Code: XCO Manufacturer Code: W290
- The Turbine Control Valve failed to open due to inappropriate replacement of the hydraulic tubing to the new E-GR hydraulic actuator and remote servo, which do not have individual MPL numbers but are nested under the MPL number for the HPCI Turbine (2E41C002). The number given is the nested MPL for the E-GR hydraulic actuator. The Turbine Control Valve itself needed no repair.
Commitment Information: This report does not create any new permanent licensing commitments.
Previous Similar Events
A review of LERs and Corrective Action Program documents did not reveal any events similar to those discussed in this report within the last three ~ears.