05000445/LER-2015-001, Regarding Unanalyzed Condition During MSSV Testing
| ML15119A227 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/20/2015 |
| From: | Flores R, Madden F Luminant Generation Co, Luminant Power |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CP-201500355, TXX-15050 LER 15-001-00 | |
| Download: ML15119A227 (5) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 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)(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 |
| 4452015001R00 - NRC Website | |
text
Rafael Flores Senior Vice President
& Chief Nuclear Officer Rafael. Flores@Luminant.com Luminant Power P 0 Box 1002 6322 North FM 56 Glen Rose, TX 76043 Luminant T 254 897 5590 C 817 559 0403 F 254 897 6652 CP-201500355 TXX-15050 Ref. # 10CFR50.73 April 20, 2015 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
SUBJECT:
COMANCHE PEAK NUCLEAR POWER PLANT DOCKET NOS. 50-445 AND 50-446 UNANALYZED CONDITION DURING MSSV TESTING LICENSEE EVENT REPORT 445/15-001-00
Dear Sir or Madam:
Pursuant to 10CFR50.73(a)(2)(ii)(B), Luminant Generation Company LLC (Luminant Power) hereby submits enclosed Licensee Event Report (LER) 445/15-001-00, " Unanalyzed Condition during MSSV Testing," for Comanche Peak Nuclear Power Plant (CPNPP) Units 1 and 2.
This communication contains no new commitments regarding Comanche Peak Units 1 and 2.
Should you have any questions, please contact Mr. Jack Hicks at (254) 897-6725.
Sincerely, Luminant Generation Company LLC Rafael Flores By: /*redW. Madden Director, External Affairs Enclosure c -
Marc L. Dapas, Region IV Balwant K. Singal, NRR Resident Inspectors, Comanche Peak AJ~-f~.
Enclosure to TXX-1 5050 NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104 EXPIRES:10/31/2013 (10-20 10)
, the NRC may digits/characters for each block) not conduct or sponsor, and a person is not required to respond to, the information collection.
- 3. PAGE Comanche Peak Nuclear Power Plant (CPNPP) Unit 1 05000445 1 OF 4
- 4. TITLE UNANALYZED CONDITION DURING MSSV TESTING
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR SEQUENTIAL REV MONTH DAY YEAR FACILITY NAME DOCUMENT NUMBER NUMBER NO.
CPNPP Unit 2 05000446 02 19 2015 15 F 001 00 04 20 2015 FACILITY NAME DOCUMENTNUMBER
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)
[]
20.2201(b)
EJ 20.2203(a)(3)(i)
E]
50.73(a)(2)(i)(C)
EJ 50.73(a)(2)(vii)
E] 20.2201(d)
E]
20.2203(a)(3)(ii)
E]
50.73(a)(2)(ii)(A)
U 50.73(a)(2)(viii)(A)
U 20.2203(a)(1)
E] 20.2203(a)(4)
E]
50.73(a)(2)(ii)(B) 50.73(a)(2)(viii)(B)
U 20.2203(a)(2)(i)
E]
50.36(c)(1)(i)(A) r-50.73(a)(2)(iii) 50.73(a)(2)(ix)(A)
- 10. POWER LEVEL U
20.2203(a)(2)(ii)
EJ 50.36(c)(1)(ii)(A)
E] 50.73(a)(2)(iv)(A)
EJ 50.73(a)(2)(x)
U 20.2203(a)(2)(iii)
E 50.36(c)(2)
Ej 50.73(a)(2)(v)(A)
LI 73.71(a)(4) 100 20.2203(a)(2)(iv)
E] 50.46(a)(3)(ii)
El 50.73(a)(2)(v)(B) 73.71(a)(5)
EJ 20.2203(a)(2)(v)
E]
50.73(a)(2)(i)(A)
[]
50.73(a)(2)(v)(C)
VOU OTHER
[.20.2203(a)(2)(vi)
E]
50.73(a)(2)(i)(B.)
Z] 50.73(a)(2)(v)(g)
VOLUNTARY LER
- 12. LICENSEE CONTACT FOR THIS LER FACILITY NAME TELEPHONE NUMBER (Include Area Code)
Timothy A. Hope, Manager, Regulatory Affairs
- 254-897-6370CAUSE SYSTEM COMPONENT MANU-REPORTABLE
CAUSE
SYSTEM COMPONENT MANU-REPORTABLE FACTURER TO EPIX FACTURER TO EPIX
- 14. SUPPLEMENTAL REPORT EXPECTED
- 15. EXPECTED MONTH DAY YEAR I--
Y cSUBMISSION YES (if yes, complete 15. EXPECTED SUBMISSION DATE) l NO DATEII ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)
In late September 2014, just prior to the start of IRF17, testing of Unit 1 Main Steam Safety Valves (MSSVs) was performed in accordance with maintenance procedure MSM-S0-8702.
During the conduct of that maintenance, Maintenance personnel leave one of the two doors to the Main Steam-Main Feed room open for personnel egress in the event of a steam leak and for heat stress considerations. Testing of the MSSVs was completed satisfactorily and Unit 1 entered its scheduled refueling outage.
On February 19, 2015, it was determined the conduct of the MSSV testing had inadvertently placed Unit 1 in an unanalyzed condition.
Furthermore, placing the Unit in an unanalyzed condition was reportable under 1 OCFR50.73(a)(2)(ii)(B).
The cause of this event was the MSSV testing work process did not consider the operability of safety related equipment when the Main Steam-Main Feed room doors were open. Corrective actions include revising procedures to provide site personnel with guidance sufficient to avoid situations such as the unanalyzed condition resulting from the MSSV testing.
All times in this report are approximate and Central Time unless noted otherwise.
NRC FORM 366 (10-2010)
PRINTED ON RECYCLED PAPER (If more space is required, use additional copies of SUMMARY OF THE EVENT, INCLUDING DATES AND APPROXIMATE TIMES:
In late September 2014, just prior to the start of 1RF17, testing of Unit 1 Main Stearm Safety Valves (MSSVs) was. performed in accordance with maintenance procedure MSM-SO-8702.
During the conduct of that maintenance, Maintenance personnel leave one of the two doors [EIIS:(SB)(DR)] to the Main Steam-Main Feed(MS-MF) room open for personnel egress in the event of a steam leak and for heat stress considerations. The door can remain open while test equipment is being set up and when testing is in progress and when personnel are in attendance within the compartment.
Testing of the MSSVs was completed satisfactorily and Unit 1 entered its scheduled refueling outage.
In late January 2015, the NRC Senior Resident questioned the conduct of the MSSV testing performed prior to the 1RF17 outage. He was concerned that the effect of leaving one of the room's watertight doors open had not been considered prior to conducting the maintenance.
He stated that failure to evaluate the effect of leaving the watertight door open may have placed the Unit in an unanalyzed condition.
On February 19, 2015, following discussions with the NRC and CPNPP Engineering, Operations, and External Affairs, it was determined the conduct of the MSSV testing had inadvertently placed Unit 1 in an unanalyzed condition. Furthermore, placing the Unit in an unanalyzed condition was reportable under 10CFR50.73(a)(2)(ii)(B). In addition, this method of testing MSSVs was used in previous Unit 1 and Unit 2 outages, specifically, in the last three years prior to 1RF16, 2RF13, and 2RF14.
E. THE METHOD OF DISCOVERY OF EACH COMPONENT OR SYSTEM FAILURE, OR PROCEDURAL PERSONNEL ERROR The unanalyzed condition was discovered by Engineering (Utility, Non Licensed) personnel during a review of Main Steam Safety Valve testing.
(If more space is required, use additional copies of (If more space is required, use additional copies of NRC Form 366A) (17)
There were no actual safety consequences for this event. This is a postulated event and as such did not result in challenges to fission product barriers, control of radioactive materials, or the health and safety of the public. This event has been evaluated to meet the definition of a safety system functional failure per 10CFR50.73(a)(2)(v).
IV. CAUSE OF THE EVENT
During the MSSV testing prior to 1RF17, a Barrier Impairment Form (BIF) was generated as required. Even though the testing did not require the passage of hoses and cables through the door, the BIF addressed that as a limiting case. As appropriate, the BIF provided risk reducing measures to be taken due to the impairment of the watertight door. The BIF also alluded to the possibility of adverse effects to components in adjacent spaces should a steam line break occur during the maintenance.
Work Control personnel reviewing the BIF appear to have concerned themselves with the risk reducing measures and may not have given the BIF's evaluation due diligence. Contributing to this, the procedural guidance did not drive them to examine the impact of having the door impaired from a Current License Basis perspective. The work package was eventually routed to the Control Room for approval and the testing accomplished.
At no time during the review of the MSSV testing work package and BIF was the operability of safety related equipment.on the other side of the impaired watertight door considered. The evaluation of potentially affected design functions of those SSCs on the other side of the impaired watertight door was excluded from the scope of the BIF based on the Engineer's misinterpretation of licensing basis requirements. CPNPP's procedures, instructions, or guidelines did not contain adequate regulatory guidance that would have resulted in such a review..Lacking this evaluation and adequate procedural guidancethe SRO did not consider the operability impacts of the impaired door.
Life Cycle Management of the Operability Determination and Hazard Barrier Control. Program has been less than adequate as pertinent regulatory guidance has not been incorporated or referenced in procedures. These documents are flawed in that they lack clarity, specificity and/or internal consistency or are outdated. They failed to provide site personnel with guidance sufficient to avoid situations such as the unanalyzed condition resulting from the MSSV testing.
V. CORRECTIVE ACTIONS
The CPNPP Corrective Action Program will track the necessary revision to CPNPP procedures to require an Operability impact of any affected SSC identified in the Hazard Barrier Control Program. In addition, site procedures are being revised to strengthen the review of applicable guidance received in generic correspondence such as Regulatory Issue Summaries and Information Notices.
VI. PREVIOUS SIMILAR EVENTS
There have been no previous similar reportable events at CPNPP in the last three years.PRINTED ON RECYCLED PAPER