05000400/LER-2004-004, Regarding Unanalyzed Condition Due to Inadequate Separation of Associated Circuits

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Regarding Unanalyzed Condition Due to Inadequate Separation of Associated Circuits
ML043350387
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 11/23/2004
From: Waldrep B
Progress Energy Carolinas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
HNP-04-145 LER 04-004-00
Download: ML043350387 (8)


LER-2004-004, Regarding Unanalyzed Condition Due to Inadequate Separation of Associated Circuits
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
4002004004R00 - NRC Website

text

d-V Cj Progress Energy NOV ? 3 2004 U.S. Nuclear Regulatory Commission ATTN: NRC Document Control Desk Washington, DC 20555 Serial: HNP-04-145 10 CFR 50.73 SHEARON HARRIS NUCLEAR POWER PLANT UNIT 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 LICENSEE EVENT REPORT 2004-004-00 Ladies and Gentlemen:

The enclosed Licensee Event Report (LER) 2004-004-00 is submitted in accordance with 10 CFR 50.73. This report describes an unanalyzed condition due to inadequate separation of associated circuits. LER 2002-004-05, submitted on November 15, 2004, described similar unanalyzed conditions. However, the cause of LER 2004-004-00 is different than LER 2002-004-05, so this condition is being submitted separately.

Corrective actions underway in response to the previously identified conditions include a comprehensive review and validation of the safe shutdown analysis (SSA). This validation is a detailed analysis of the routing of cables affecting equipment credited in the SSA. The commitments and associated due dates identified in Section VI of this LER correspond with those for LER 2002-004-05. Compensatory actions, including fire watches, ensure safety pending permanent resolution of the identified conditions.

Please refer any questions regarding this submittal to Mr. Dave Corlett, Supervisor -

Licensing/Regulatory Programs, at (919) 362-3137.

Sincerely, tw HA 13. V-Au Pt FP B. C. Waldrep Plant General Manager Harris Nuclear Plant BCW/jpy Enclosure Progress Energy Carolinas, Inc.

Harris Nuclear Plant P.O. Box 165 New Hill, NC 27562

Serial: HNP-04-145 Page 2 C:

Mr. R. A. Musser (HNP Senior NRC Resident)

Mr. C. P. Patel (NRC-NRR Project Manager)

Dr. W. D. Travers (NRC Regional Administrator, Region II)

Enclosure to HNP-04-145 NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 06/30/2007

, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

3. PAGE Harris Nuclear Plant - Unit 1 05000400 1 OF 6
4. TITLE Unanalyzed Condition Due to Inadequate Separation of Associated Circuits
5. EVENT DATE
6. LER NUMBER
7. REPORT DATE S. OTHER FACILITES INVOLVED MONTH DAY YEAR YEAR EUMBENTDAL REA FACILITY NAME DOCKET NUMBER MON A

ER YA EUMENILRE N.MONTH DAY YEAR N/A 05000 FACILITY NAME DOCKET NUMBER 09 27 2004 2004 - 004 -

00 11 26 2004 N/A 05000

9. OPE MATING MODE 1'. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR§: (Checkall that apply) o 20.2201(b) 0 20.2203(a)(3)(i) 0 50.73(a)(2)(i)(C) 0 50.73(a)(2)(vii) 1 0

20.2201(d) 0 20.2203(a)(3)(ii) 0 50.73(a)(2)(ii)(A) 0 50.73(a)(2)(viii)(A) o 20.2203(a)(1) 0 20.2203(a)(4) 0 50.73(a)(2)(ii)(B) 0 50.73(a)(2)(viii)(B) o 20.2203(a)(2)(i) 0 50.36(c)(1)(i)(A) 3 50.73(a)(2)(iii) 0 50.73(a)(2)(ix)(A)

10. POWER LEVEL 0 20.2203(a)(2)(i 0

50.36(c)(1)(Ii)(A) 0 50.73(a)(2)(iv)(A)

[

50.73(a)(2)(x) 0 20.2203(a)(2)(iii) 0 50.36(c)(2) 0 50.73(a)(2)(v)(A) 0 73.71(a)(4) o 20.2203(a)(2)(iv) 0 50.46(a)(3)(ii) 0 50.73(a)(2)(v)(B) 0 73.71(a)(5) 100 E

20.2203(a)(2)(v) 0 50.73(a)(2)(i)(A) 0 50.73(a)(2)(v)(C) 0 OTHER o 20.2203(a)(2)(vI) 0 50.73(a)(2)(i)(B) 0 50.73(a)(2)(v)(D)

Specify In Abstract below

___or in NRIC (if more space is required, use additional copies of (If more space Is required, use additional copies of (If more space is required, use additional copies of (If more space is required, use additional copies of NRC Form 3W6A)

V.

PREVIOUS SIMILAR EVENTS (Continued)

HNP LER 2002-004-00 through -05 (reported February 18, 2003, March 26, 2003, September 19, 2003, April 12, 2004, and November 15, 2004, respectively)

This LER and its associated revisions reported that unanalyzed conditions exist due to inadequate separation of associated circuits. HNP identified postulated fires that could cause spurious actions of multiple valves and components that could also result in some of the following potential conditions:

Spurious opening of multiple valves in the safety injection system or the containment spray system could result in transfer of Reactor Water Storage Tank (RWST) inventory to the containment recirculation sump. However, this water inventory would still be available for use, if needed, from the containment recirculation sump.

Spurious opening of multiple valves in the safety injection system could result in damage to the Charging/Safety Injection Pump (CSIP) in service due to run out conditions.

Spurious closure of valves in the charging system could result in loss of flow and subsequent damage to the running CSIP credited by the Safe Shutdown Analysis (SSA).

Spurious closure of valves in the Component Cooling Water (CCW) System could result in loss of CCW flow credited by the SSA for Reactor Coolant Pump (RCP) seal cooling.

Spurious closure of multiple valves in the charging and CCW systems could result in loss of RCP seal cooling and subsequent degradation of the RCP seals, possibly leading to an RCP seal LOCA without credited CSIPs.

Spurious opening of a valve and spurious start of a containment spray pump could result in discharge of RWST inventory to the containment via the containment spray ring header.

Loss of RCS pressure and level indication credited by the SSA which could potentially impact pressure and level monitoring.

The cause of these conditions was inadequate original Safe Shutdown Analysis. Specifically, certain conductor-to-conductor interactions (i.e., hot shorts) were not adequately evaluated in the initial Safe Shutdown Analysis. The root cause for LER 2002-004-00 through -05 was an old design deficiency (i.e.,

certain conductor-to-conductor interactions such as hot shorts were not adequately evaluated in the initial SSA) and is not significant in relation to the current event. However, the corrective actions for this previous event would be expected to identify or prevent the deficiency identified by the current LER, and, in fact, did identify this deficiency during the ongoing comprehensive review and validation of the HNP SSA. This review and validation are being performed as part of the corrective actions for the previously reported conditions.

(If more space is required, use additional copies of NRC Form 366A)

VI.

COMMITMENTS

The actions committed to by Carolina Power & Light Company doing business as Progress Energy Carolinas, Inc. (PEC) in this document are identified below. Any other actions discussed in this submittal represent intended or planned actions by PEC. They are described for the NRC's information and are not regulatory

commitments

Scheduled Commitment(s)

Completion Date

1. Complete a validation of the HNP safe shutdown analysis.

June 20, 2005

2. Restore the identified conditions of this LER to compliance by design Refueling Outage 13 changes or other methods approved by the NRC.

(Current schedule May 13, 2006)