05000400/LER-2022-004, Both Trains of High Head Safety Injection Inoperable
| ML22181A122 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/30/2022 |
| From: | Hoffman D Duke Energy Progress |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RA-22-0184 LER 2022-004-00 | |
| Download: ML22181A122 (5) | |
| Event date: | |
|---|---|
| Report date: | |
| 4002022004R00 - NRC Website | |
text
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~ ENERGY David S. Hoffman Plant Manager Shearon Harris Nuclear Power Plant 5413 Shearon Harris Road New Hill, NC 27562-9300 10 CFR 50.73 June 30, 2022 Serial: RA-22-0184 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400/Renewed License No. NPF-63 Subject: Licensee Event Report 2022-004-00 Ladies and Gentlemen:
Duke Energy Progress, LLC, submits the enclosed Licensee Event Report 2022-004-00 in accordance with 10 CFR 50.73 for Shearon Harris Nuclear Power Plant, Unit 1 (HNP). This report describes an event in which HNP was in Mode 1 and both trains of high head safety injection (HHSI) were inoperable for a brief period of time. This event had no significance with respect to the health and safety of the public.
There are no regulatory commitments contained within this report.
Please refer any questions regarding this submittal to Dennis Earp at (984) 229-2673.
David S. Hoffman Enclosure: Licensee Event Report 2022-004-00 cc:
C. Smith, NRC Resident Inspector, HNP M. Mahoney, NRC Project Manager, HNP NRC Regional Administrator, Region 11
Abstract
On May 2, 2022, at 02:26 Eastern Daylight Time, with Shearon Harris Nuclear Power Plant, Unit 1 (HNP), in Mode 1 at 100 percent power, testing was being performed in accordance with site procedure OST-1093, Chemical Volume Control System/
Safety Injection System Operability Train B. When Charging Safety Injection Pump (CSIP) discharge cross-connect valve 1CS-220 was stroked closed, the Main Control Room (MCR) received alarm ALB-008/2-1, Reactor Coolant Pump (RCP) seal injection low flow, and seal injection flow was lowering to zero. Valve 1CS-220 was immediately restored to the open position and seal injection flows recovered to normal within approximately 23 seconds. Further investigation identified that the B CSIP discharge valve, 1CS-197, was locked shut from prior post-maintenance testing instead of being in its required open position, the result of not validating assumptions related to a B CSIP clearance. With 1CS-197 locked shut when 1CS-220 was stroked closed, both A Train high head safety injection (HHSI) and B Train HHSI were inoperable until 1CS-220 could be restored to open. This was a violation of Technical Specification (TS) requirements to have at least one CSIP operable to meet TS 3.1.2.2, TS 3.1.2.4, and TS 3.5.2 in Modes 1, 2, and 3. If a condition occurred that initiated a safety injection signal while 1CS-220 was closed in accordance with test procedure OST-1093, an operator in the MCR would procedurally restore the valve to its open position, restoring the A CSIP and its discharge path for the Emergency Core Cooling System to operable. This event did not impact plant safety and there was no actual safety consequence on the health and safety of the public as a result of this event. Page of 05000-
- 3. LER NUMBER YEAR SEQUENTIAL NUMBER REV NO.
D. Corrective Actions
Valve 1CS-220 was immediately restored to open and seal injection flows recovered to normal. This was followed by the restoration of the 'B' CSIP valve lineup in accordance with procedure. Human performance accountability actions have been implemented, emphasizing the importance of signing for steps only when complete. Furthermore, a standing instruction was issued to require reviewing all completed procedure sections, prior to signing off Ready to Work or Tags Removed status on a clearance. All pre-start checklists that lack a requirement to check manual suction and discharge valves will be revised to align with the standard contained in fleet procedure AD-OP-ALL-1000.
E. Safety Analysis
If a condition occurred that initiated a safety injection signal while 1CS-220 was closed in accordance with test procedure OST-1093, an operator in the MCR would procedurally restore the valve to its open position, restoring the A CSIP and its discharge path for ECCS to operable. The action to open the valve is contained within a procedure and it is a single uncomplicated action. Emergency operating procedure EOP-E.0, Reactor Trip or Safety Injection, contains further administrative barriers to ensure the ECCS would have performed its safety function in the event the system was required to mitigate the occurrence of a design basis event during the test. In this particular instance on May 2, 2022, the operator restored the valve to its open position within approximately 23 seconds, which is within the ECCS response times (time from safety injection to time ECCS flow reaches cold legs) for both small break and large break LOCAs, and a steam line break at hot zero power (29 seconds, 29 seconds, and 27 seconds, respectively). Therefore, this event did not significantly impact plant safety and there was no actual safety consequence on the health and safety of the public as a result of this event.
NEI 99-02, Revision 7, "Regulatory Assessment Performance Indicator Guidelines," states the following for inclusion of events on the NRC Mitigating Systems Performance Indicator for Safety System Function Failures (SSFF), "The level of judgment for reporting an event or condition under paragraph (a)(2)(v) as an SSFF is a reasonable expectation of preventing the fulfillment of a safety function." Based on this guidance and the above analysis showing the safety function can be reasonably expected to be met within the required period, this event will not be counted as a SSFF.
F. Additional Information
No LERs have been issued by HNP in the past three years for a similar issue.
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Shearon Harris Nuclear Power Plant, Unit 1 400 2022 004 00