05000440/LER-2018-003, Unanalyzed Condition Resulting from Unfused Alternating Current Control Circuits

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Unanalyzed Condition Resulting from Unfused Alternating Current Control Circuits
ML18334A366
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 11/30/2018
From: Hamilton D
FirstEnergy Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-18-257 LER 2018-003-00
Download: ML18334A366 (4)


LER-2018-003, Unanalyzed Condition Resulting from Unfused Alternating Current Control Circuits
Event date:
Report date:
Reporting criterion: 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition

10 CFR 50.73(a)(2)(iii)

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)(v), Loss of Safety Function

10 CFR 50.73(a)(2)(i)
4402018003R00 - NRC Website

text

FENOC' RrstEnergy Nuclear Operating Company David 8. Hamilton Vice President November 30, 2018 L-18-257 ATTN: Document Control Desk U.S. Nuclear Regulatory"Commission Washington, DC 20555-0001

SUBJECT:

Perry Nuclear Power Plant Docket No. 50-440; License No. NPF-58 Licensee Event Report Submittal Perry Nuclear Power Plant PO. Box 97 10 Center Road Perry, Ohio 44081 440-280-5382 1 0CFR50.73(a)(2)(ii)(B)

Enclosed is Licensee Event Report (LER) 2018-003, "Unanalyzed Condition Resulting from Unfused Alternating Current Control Circuits". There are no regulatory commitments contained in this submittal.

If there are any questions or if additional information is required, please contact Mr. Glendon Burnham, Manager - Regulatory Compliance, at (440) 280-5415.

Sincerely, David B. Hamilton Vice President

Enclosure:

LER 2018-003 cc:

NRC Project Manager NRC Resident Inspector NRC Region Ill Regional Administrator

NRCFORM366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY 0MB: NO. 3160-0104 EXPIRES: 3/31/2020 (04-2018)

Estimated burden per ~ponse to comply with this mandaloly collection request BO h~urs.

LICENSEE EVENT REPORT (LER)

Reported lessons learned are incorporated in1o the licensing process and fed back ID

~<JP"...,,,.,

industry. Send comments regarding burden estimate to the lnfonmation Services Branch 0..

(See Page 2 for required number of digits/characters for each block)

[T-2 F43), U.S. Nuclear Regulaloly Commission, Washingtcn, DC 20555-0001, or by e-mail I

to lnfocolleclS.Resource@nrc.gov, and to the Desk Officer, Office of lnrormation and 0

~ i (See NUREG-1022, R.3 for instruction and guidance for completing this form Regulatcry Affairs, NEOB-10202, (3150-0104), Office of Management and Budget, http://www. n rc.g ov/readinq-rm/doc-collections/n uregs/staff/s r1 022/r3/

Washingtcn, DC 20503. If a means used ID impose an inrormation collection does not display a currently vafid,.OMB conllol number, the NRC may not conduct or sponsor, and a person is not required, to respond to, the information 'collection.

3.Page Perry Nuclear Power Plant 05000-440 1 OF 3

4. Title:

Unanalvzed Condition Resulting from Unfused Alternating Current Control Circuits

5. Event Date
6. LER Number
7. Report Date
8. Other Facilities Involved l

Sequenfial I Rev Facility'Name Docket Number Month Day Year Year Number No.

Month Day Year 05000 Facility Name Docket Number 10 04 2018 2018 -

003 00 11 30 2018 05000

9. Operating Mode
11. This Report is Submitted Pursuant to the Requirements of 10 CFR §: (Check all that apply) 0 20.2201(b) 0 20.2203(a)(3)(i) 0 50. 73(a)(2)(ii)(A) 0 50. 73(a)(2)(viii)(A) 1 0 20.2201(d) 0 20.2203(a}(3)(ii) 181 50:73(a)(2)(ii)(B) 0 50. 73(a)(2)(viii)(B) 0 20.2203(a)(1) 0 20.2203(a}(4)

D 50.73(a)(2)(iii)

D 50. 73(a)(2)(ix)(A) 0 20.2203(a)(2)(i) 0 50.36(c)(1)(i)(A) 0 50. 73(a)(2)(iv)(A) 0 50.73(a)(2)(x)

10. Power Level D 20.2203(a)(2)(ii) 0 50.36(c)(1 )(ii)(A) 0 50.73(a)(2)(v)(A) 0 73.71 (a)(4) 0 20.2203(a)(2)(iii).

0 50.36(c)(2) 0 50.73(a)(2)(v)(B) 0 73. 71 (a)(5) 0 20.2203(a)(2)(iv) 0 50.46(a)(3)(ii) 0 50. 73(a)(2)(v)(C) 0 73.77(a)(1) 100 0 20.2203(a)(2)(v) 0 50. 73(a)(2)(i)(A)

D 50.73(a)(2)(v)(D)

D 73.77(a)(2)(i)

D 20.2203(a)(2)(vi)

D 50. 73(a)(2)(i)(B}

D 50. 73(a)(2)(vii)

D 73.77(a)(2)(ii)

"':.t{1i:ttl

,3:i.0 0

50.73(a)(2)(i)(C)

Other (Specify in Abstract below or in

EVENT ANALYSIS

YEAR 2018

3. LER.NUMBER SEQUENTIAL NUMBER 003 REV NO.

00 Plant design.in regard to IEEE cable separation, divisional independence, fire detection and suppression capabilities, coupled with Appendix R circuitry/method protection and Fire Protection procedural guidance provides reasonable assurance that post-fire safe shutdown will be achieved and maintained for the identified conditions. Additionally, the suspect AC control cables are insulated in cross-linked thermosetting polyethylene. Thermoset insulation as opposed to thermoplastic insulation can withstand higher temperatures during longer periods of time and burns at lower rates. Based on the expectation that any secondary fire potential would be very localized and limited (low voltage and contained to the affected cable/raceway), in addition to the aspects of the plant design and operation, there is a reasonable assurance that post-fire safe shutdown will be achieved and maintained given the postulated failure mode and the events that would have to occur in order to achieve.the postulated condition.

The overall risk of this condition is judged to be very small, based on the consequential impact relative to the aforementioned aspects of plant design and the expected response to a fire event. Correspondingly, as at least one method of safe shutdown would remain available for any potential fire, this condition would be expected to be of very low safety significance.

CORRECTIVE ACTIONS

Compensatory fire watches have been implemented for the affected fire areas. Planned corrective actions include plant modifications to install over-currenfprotection in the respective equipment control circuitry.

PREVIOUS SIMILAR EVENTS

On October 17, 2013, at 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br /> with the plant in mode 1, a review of industry operating experience regarding the impact of 1.,mfused Direct Current ammeter circuits in. the Control Room determined the described.condition to be applicable to the Perry Nuclear Power Plant resulting in a potentially unanalyzed condition with respect to 10 CFR 50 Appendix R analysis requirements. The original plantwiring design and associated safe shutdown analysis for the Class 1 E batteries control room ampere indications did not include overcurrent protection features to limit the fault current. This event was reported under 50. 73(a)(2)(ii)(B) as an unanalyzed condition.

On June 19, 2014, with the plant in mode 1, a review of industry operating experience regarding the impact of unfused. Direct Current (DC) circuits determined the described condition to be applicable to the Perry Nuclear Power Plant related to the Turbine Emergency Bearing Oil Pump, Reactor Feed Pump Turbine 'A' Emergency Lube Oil Pump, Turbine Emergency Seal Oil Pump, and the Reactor Feed Pump Turbine 'B' Emergency Lube Oil Pump circuits. The cause was determined to be latent design deficiency in the identified circuits dating back to original design and installation that was not identified during the design review for 1 O CFR 50 Appendix R Section 111.G. Thi event was reported under 50.73(a)(2)(ii)(B) as an unanalyzed condition:

COMMITMENTS

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