05000412/LER-2017-001

LER-2017-001, Surveillance Testing Rendered Service Water System Inoperable Due to the Coupling of Seismic Category 1 Piping to Not Seismic Category 1 Piping

Beaver Valley Power Station Unit Number 2
Event date:	03-03-2017
Report date:	05-02-2017
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat
4122017001R00 - NRC Website

LER 17-001-00 For Beaver Valley Power Station, Unit No. 2 Re: Surveillance Testing Rendered Service Water System Inoperable Due to the Coupling of Seismic Category l Piping to Not Seismic Category 1 Piping

ML17124A382
Person / Time
Site:	Beaver Valley
Issue date:	05/02/2017
From:	Richey M L FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-17-152 LER 17-001-00
Download: ML17124A382 (4)

Eshmaled burden per response Is 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 comments regarding burden estimate to the FOIA, Privacy and Information Collections Branch (1-5 F53), U.S. Nuclear Regulatory Commission. Washington, DC 20555-0001, or by e-mail to .

Inf000llects.Resource@nrc.gov, and to the Desk Officer, Office of Information and RegulakayAffairs, used to impose an information collection does not display a currently vaid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

05000- Beaver Valley Power Station Unit Number 2 412

NUMB ER

Energy Industry Identification System (EIIS) codes are identified in the text as [KG].

CONDITIONS PRIOR TO OCCURENCE

UNIT 2: Mode 1 100% Power There were no systems, structures, or components (SSCs) that were inoperable at the start of the event that contributed to the event.

DESCRIPTION OF EVENT

Per the current licensing basis, the Standby Service Water System, SWE, KG] meets GDC 2 and RG 1.29, Position C.2, with respect to the system's protection against natural phenomena and adequately ensures a sufficient supply of service water is available to accomplish unit shutdown and subsequent cooldown in the event of a flaming barge explosion incapacitating the Service Water System, SWS.

In 2001, a previous "Assessment of Operability", stated that there is a reasonable assurance and expectation that the SWS can perform its intended safety function while coupled to the SWE System (KG), and was used as the basis to revise the SWS/SWE System (KG) procedures to not declare the SWS inoperable when coupled to the SWE System (KG).

In 2016, the NRC issued a Green Finding with a corresponding NCV of 10CFR50, Appendix B, Criterion III, Design Control for inappropriately incorporating a design feature into the SWS/SWE System (KG) procedures. The Assessment of Operability, completed in 2001, was for an automatic actuation of the SWE System, and not intended to be used for intentionally starting the SWE (KG) pump to maintain SWS header pressure during surveillance testing. As a result BVPS, implemented a project to revise the SWS/SWE System (KG) procedures to declare the SWS inoperable when coupled with the SWE System (KG).

In March 2017, the 18 month frequency, refueling surveillance procedure, SWS DBA full flow test was being revised to declare the SWS train inoperable when aligned to the SWE System (KG) during surveillance testing as a result of a condition report captured in our corrective action process in January 2017. It was discovered during the procedure review process, that this change would have resulted in two trains of SWS inoperable, concurrently, during the past three year's performance of the test, due to one SWS train being aligned to the SWE (KG) System at the same time the other train was inoperable due to the test alignment. The procedure was subsequently re-organized in order to perform the test with only one train of SWS inoperable during the setup of the test configuration.

However, the past three year's performance of the test was assessed for reportability for a condition prohibited by Technical Specification 3.0.3, and a loss of Safety Function. The SWS DBA Full Flow test was not in progress, and had not been performed, since the non-conformance was determined. Therefore, this condition was not reportable under 1 OCFR50.72 for a condition that at the time of discovery could have prevented the fulfillment of the SWS safety function; and neither was it an unanalyzed condition that significantly degraded plant safety.

In order to determine if the condition was reportable under 10CFR50.73, BVPS applied the guidance provided in IM-0326, "Operability Determinations & Functionality Assessments for Conditions Adverse to Quality or Safety' in accordance with the guidance in NUREG-1022, comments regarding burden estimate to the FOIA, Privacy and Information Collections Branch (T.-5 F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555.0001, or by email to 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 currently vaid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection 1. FACILITY. NAME 05000- Beaver Valley Power Station Unit Number 2 412 2017 001 Loo_l In April 2017, BVPS determined that although there is reasonable assurance and expectation that the SWS can perform its intended safety function when coupled to the SWE System, (KG) the intentional use of the SWE System (KG) to maintain SWS header pressure during surveillance tests created a non-conformance with the current licensing basis. Therefore, during past performances of the SWS DBA full flow test, the testing configurations resulted in two trains of SWS inoperable for greater than the shutdown completion time of TS 3.0.3.

This is reportable under 10 CFR 50.73(a)(2)(i)(B), for a condition that is prohibited by plant TS 3.0.3. The condition is, also, reportable under 10 CFR 50.73(a)(2)(v)(B) as a condition which potentially affected the fulfillment of a safety function for the Service Water System, along with the systems it supports including the Emergency Core Cooling System (ECCS), the Primary Component Cooling System (CCP), and the Recirculation Spray System (RSS).

CAUSE OF EVENT

In 2001, an "Assessment of Operability" was used as the basis to change the SWS/SWE System (KG) procedures to intentionally couple the SWE System (KG) to the SWS during surveillance testing without declaring the SWS inoperable, which created a non-conformance with the current licensing basis.

BVPS did not recognize that, although it was shown there was a reasonable assurance and expectation that the SWS could perform its intended safety function when coupled with the SWE System (KG), the "Assessment of Operability", performed in 2001, provided the justification for past operability due to an automatic start of the SWE System, and was not intended to be used as the basis to intentionally couple the not Seismic CAT 1SWE System (KG) to the Seismic CAT 1 SWS.

ANALYSIS OF EVENT

The plant risk associated with the past performances of the Unit 2 SWS DBA full flow tests is considered to be very low.

This is based on the delta core damage frequency and delta large early release frequency for a total of 29.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> that the non-conformance condition existed in the past three years.

CORRECTIVE ACTIONS

All applicable surveillance tests have been revised to prevent the alignment as described in this event.

PREVIOUS SIMILAR EVENTS

A review of events of the previous three years has identified one event which was subsequently granted enforcement discretion by the NRG in accordance with the guidance provided in EGM 2015-002, Rev.1. Reference LER 2017-001(Unit 1/2), Inadequate Tornado Missile Protection Identified Due to Non-Conforming Design Conditions.