05000446/LER-2014-002, Regarding Both Trains of RHR Inoperable During Testing in Mode 3
| ML14188C078 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/24/2014 |
| From: | Peters K Luminant Generation Co, Luminant Power |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CP- 201400774, TXX -14078 LER 14-002-00 | |
| Download: ML14188C078 (5) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i) 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)(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 |
| 4462014002R00 - NRC Website | |
text
Rafael Flores Senior Vice President
& Chief Nuclear Officer rafael.flores@Luminant.com Luminant Luminant Power P 0 Box 1002 6322 North FM 56 Glen Rose, TX 76043 T 254 897 5550 C 817 559 0403 F 254 897 6652 CP-201400774 TXX -14078 Ref. # 10CFR50.73(a)(2)(v)(B) 10CFR50.73(a) (2) (vii)
June 24, 2014 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
COMANCHE PEAK NUCLEAR POWER PLANT (CPNPP)
DOCKET NO. 50-446 BOTH TRAINS OF RHR INOPERABLE DURING TESTING IN MODE 3 LICENSEE EVENT REPORT 446 / 14-002-00
Dear Sir or Madam:
Enclosed is Licensee Event Report (LER) 446/14-002-00, "Both Trains of RHR Inoperable During Testing in Mode 3," for Comanche Peak Nuclear Power Plant (CPNPP) Unit 2.
This communication contains the following new or revised commitments which will be completed or incorporated into the CPNPP licensing basis as noted:
Commitment Number 4872850
Commitment
Implement a procedure change to the MODE change checklists (e.g., IPO-001A/B attachment 2 step 1) which ensures that a review of the Technical Specification surveillances that must be completed prior to the upcoming mode, as well as Surveillance Testing performance requirements that direct completion prior to entering the upcoming mode, is performed prior to changing modes.
Should you have any questions, please contact R. A. Slough at (254) 897-5727.
Sincerely, Luminant Generation Company LLC Rafael Flore By:
Ken 4 J. Peters Sit
- e President Enclosure c -
Marc L. Dapas, Region TV B. K. Singal, NRR Resident Inspectors, Comanche Peak A member of the STARS Alliance Callaway
- Comanche Peak
- Diablo Canyon
- Palo Verde
- Wolf Creek E )0,L
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104 EXPIRES:01/31/2017 (02-2014)
, the NRC may 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 2 05000 446 1 OF4
- 4. TITLE Both Trains of RHR Inoperable During Testing in MODE 3
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR SEQUENTIAL REV MONTH DAY YEAR FACILITY NAME DOCKET NUMBER NUMBER NO.
1 04 25 2014 2014 002 00 06 24 2014 FACILITY NAME DOCKET NUMBER
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)
El 20.2201(b)
LI 20.2203(a)(3)(i)
[]
50.73(a)(2)(i)(C) 50.73(a)(2)(vii) 3 I 20.2201(d)
El 20.2203(a)(3)(ii)
E]
50.73(a)(2)(ii)(A)
LI 50.73(a)(2)(viii)(A)
[]
20.2203(a)(1)
E]
20.2203(a)(4)
El 50.73(a)(2)(ii)(B)
El 50.73(a)(2)(viii)(B)
[]
20.2203(a)(2)(i)
E]
50.36(c)(1)(i)(A)
El 50.73(a)(2)(iii)
[]
50.73(a)(2)(ix)(A)
- 10. POWER LEVEL
[]
20.2203(a)(2)(ii)
E]
50.36(c)(1)(ii)(A)
El 50.73(a)(2)(iv)(A)
El 50.73(a)(2)(x)
El 20.2203(a)(2)(iii)
El 50.36(c)(2)
El 50.73(a)(2)(v)(A)
[]
73.71(a)(4) 0 El 20.2203(a)(2)(iv)
[] 50.46(a)(3)(ii)
[]
50.73(a)(2)(v)(B)
El 73.71 (a)(5)
El 20.2203(a)(2)(v)
[
50.73(a)(2)(i)(A)
[]
50.73(a)(2)(v)(C)
[]
OTHER El 20.2203(a)(2)(vi)
[
50.73(a)(2)(i)(B)
[J 50.73(a)(2)(v)(D)
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 I~II
- 14. SUPPLEMENTAL REPORT EXPECTED
- 15. EXPECTED MONTH DAY YEAR SUBMISSION l
YES (If yes, complete 15. EXPECTED SUBMISSION DATE)
I NO DATE ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)
On April 25, 2014, valve 2-8809B, RHR to CL 2-03/2-04 INJ ISOL VLV was closed during performance of boundary valve testing per procedure OPT-61 5B, "RCS PRESSURE BOUNDARY LEAKAGE TEST FOR LOOP 3 CL INJECTION VALVES" while Unit 2 was in MODE 3. Closure of valve 2-8809B rendered both Residual Heat Removal (RHR) trains inoperable resulting in entry into Technical Specification (TS) Limiting Condition for Operation (LCO) 3.0.3.
The cause of the event has been determined to be due to a failure to transmit pertinent information to support a decision to change plant operating modes. Corrective actions include procedure revisions.
All times in this report are approximate and Central Daylight Time unless noted otherwise.
(If more space is required, use additional copies of SUMMARY OF THE EVENT, INCLUDING DATES AND APPROXIMATE TIMES:
On April 25, 2014, Unit 2 was in MODE 4 during recovery from Unit 2 refueling outage 2RF14. Surveillance testing of RHR boundary valves [EIIS: (BP)(V)] was in progress in accordance with procedure OPT-6151B, "RCS PRESSURE BOUNDARY LEAKAGE TEST FOR LOOP 3 CL INJECTION VALVES". Unit 2 entered MODE 3 at 0445 on April 25, 2014. At 1649 on April 25, 2014, valve 2-8809B, RHR TO CL 3&4 INJ ISOL VLV ORC, was closed as part of the system alignment to perform leak testing of valve 2-8948C, SI ACCUM 2-03 DNSTRM INJ CHK VLV. Closing valve 2-8809B rendered both Unit 2 Residual Heat Removal (RHR) trains incapable of providing Emergency Core Cooling System (ECCS) injection flow to Reactor Coolant System (RCS) cold legs 3 and 4. TS 3.5.2, "ECCS - Operating" is applicable in MODE 3 and requires two Emergency Core Cooling System (ECCS) trains to be OPERABLE. An OPERABLE Emergency Core Cooling System (ECCS) train is required to be capable of injecting to all four Reactor Coolant System (RCS) loops. Since neither Residual Heat Removal (RHR) train was capable of injecting to all four Reactor Coolant System (RCS) loops with valve 2-8809B closed, both trains of Residual Heat Removal (RHR) were inoperable. Since TS 3.5.2 does not provide a CONDITION and REQUIRED ACTION for two inoperable Emergency Core Cooling System (ECCS) trains, Technical Specification (TS) Limiting Condition for Operation (LCO) 3.0.3 was applicable.
In addition, the system lineup for the test of valve 2-8948C created a flowpath which resulted in lowering water level in Safety Injection (SI) Accumulator 2-03 [EIIS: (BQ)(ACC)] due to draining of the accumulator through the (If more space is required, use additional copies of (If more space is required, use additional copies of NRC Form 366A) (17) required flow-rates from the low head Residual Heat Removal (RHR) pumps could not be assured.
However, a probabilistic risk assessment of the closing of valve 2-8809B found a negligible effect on core damage frequency and large early release frequency. Additionally, there were no events which required an Emergency Core Cooling System (ECCS) actuation during the time the valve was closed. Based on these considerations, there was no adverse effect on plant safety or on the health and safety of the public.
IV. CAUSE OF THE EVENT
The MODE change checklist inaccurately reflected surveillance tests were completed to support the mode change to MODE 3. OPT-61 5B/61 6B section 8.4 was not completed prior to the MODE change and clearly identified in the MODE 3 Surveillance Mode Change Report.
V.
CORRECTIVE ACTIONS
Implement a procedure change to the MODE change checklists (e.g., IPO-001A/B attachment 2 step 1) which ensures that a review of the Technical Specification surveillances that must be completed prior to the upcoming mode, as well as Surveillance Testing performance requirements that direct completion prior to entering the upcoming mode, is performed prior to changing modes. This procedure change will require identification of the specific report to be utilized to conduct this review and will contain a requirement that the report be vaulted as part of the procedure.
VI. PREVIOUS SIMILAR EVENTS
There have been no previous similar reportable events at Comanche Peak Nuclear Power Plant (CPNPP) in the last three years.PRINTED ON RECYCLED PAPERPRINTED ON RECYCLED PAPER