05000269/LER-2006-004, Re Design Oversight Results in Appendix R Deficiencies
| ML063470037 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 12/07/2006 |
| From: | Brandi Hamilton Duke Energy Corp |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| O-05-3849, O-05-4578, O-06-1638, O-06-8064 LER 06-004-00 | |
| Download: ML063470037 (22) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(3)(ii)(B) |
| 2692006004R00 - NRC Website | |
text
Duke BRUCE H HAMILTON Vice President P
E~nergy.
Oconee Nuclear Station Duke Energy Corporation ON01VP / 7800 Rochester Highway Seneca, SC 29672 864 885 3487 864 885 4208 fax December 7, 2006 bhhamilton@duke-energy.com U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555
Subject:
Oconee Nuclear Station Docket Nos.
50-269,-270,
- - 287 Licensee Event Report 269/2006-004, Revision 0 Problem Investigation Process No.: 0-05-3849, 0-05-4578, 0-06-1638, 0-06-8064 Gentlemen:
Pursuant to 10 CFR 50.73 Sections (a)(1) and (d),
attached is Licensee Event Report 269/2006-004, Revision 0, regarding deficiencies identified as part of the Appendix R Reconstitution Program and NFPA 805 Pilot Program.
This report is being submitted in accordance with 10 CFR 50.73 (a)(3)(ii)(B) as unanalyzed conditions.
This event is expected to have no significance with respect to the health and safety of the public.
Very truly yours, Bruce H.
Hamilton, Vice President Oconee Nuclear Site Attachment www. duke-energy, com u
i 2.-
Document Control Desk Date: December 7, 2006 Page 2 cc:
Mr. William D. Travers Administrator, Region II U.S. Nuclear Regulatory Commission 61 Forsyth Street, S.
W.,
Suite 23T85 Atlanta, GA 30303 Mr.
L.
N. Olshan Project Manager U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D.C.
20555 Mr.
D.
W. Rich NRC Senior Resident Inspector Oconee Nuclear Station INPO (via E-mail)
Date: December 7, 2006 Page 3 bxc:
ONS Site:
bxc: ONS Site:
Document Control (Master File)*
PIP FILE*
Site PORC Members RGC MGR/B.G.
Davenport RGC: Commitment Index/J.E. Smith#
LER Book*#
WOE Mgr/S.J. Magee OPS-Procedures/D.B. Coyle#
Work Control:D.V. Deatherage#
Site Engineering:
W.B.
Edge#
T.A. Ledford#
K.R. Alter#
R.J. Freudenberger#
M. Bailey#
EPIX Cord/R.E. Harris GO:
NRIA/R.L. Gill
- ELL/EC050*
NGO/SAA:D.J. Herrick NGO/SA/S.B.
Thomas NGO Serv: R.G. Hull#
LEGAL/L.F. Vaughn*
CNS:
SA MGR/
J.R. Ferguson, MNS:
SA MGR/J.A.
Kammer OPS Mgr/S.L. Bradshaw#
M.S.
Tuckman#
NSRB/E.B. Kulesa/EC05N*
C.M. Misenheimer#
RATES/M.J. Brown#
RGC MGR/R.D.
Hart RGC MGR/C.J.
Thomas Jr.
Non-routine Recipients:
None Hardcopy -
All others by E-Mail Distribution Copied By Request: - All others by Directive (Revised 8-1-2006)
Abstract
Licensee Event Reports 269/2002-02 (5-28-2002) and 269/2003-01 (8 2003) reported vulnerabilities to hot shorts and other Appendix R design deficiencies.
As a result of the corrective actions from the first event, Oconee Nuclear Station initiated an Appendix R reconstitution program and subsequently elected to participate in the pilot NFPA 805 transition program. The original Appendix R evaluations considered spurious operation of many analyzed components to not be credible and assumed components would lose power, thus precluding spurious operation. However, the Current Licensing-Basis requires that plant transients caused by one worst case hot short must be addressed.
Between 6-3-2005 and 11-21-2006, the reconstitution program identified and documented in the Oconee corrective action program vulnerabilities to hot shorts which had not previously been considered. These issues involve potential spurious pump starts and spurious valve operations with associated procedure changes needed to address the possible hot shorts. The continuation of the Appendix R reconstitution program and the pilot NFPA 805 transition program will continue to identify and correct these items.
This event is expected to have no significance with respect to the health and safety of the public.
NRC FORM 366 (7-2001)
(If more space is required, use additional copies of (If more space is required, use additional copies of (If more space is required, use additional copies of (If more space is required, use additional copies of (If more space is required, use additional copies of (If more space is required, use additional copies of (If more space is required, use additional copies of NRC Form 366A) with NRC Region II.
This LER will then be updated with the Phase III results.
The status of the NFPA 805 Transition Project was discussed with the NRC during the October 2006 NFPA 805 Pilot Plant Transition Observation Visit at the Oconee site.
Additional status meetings are expected to be conducted monthly.
The items identified in this LER occurred at the same time as the Appendix R deficiencies identified in LER 269/2002-02 and LER 269/2003-01 as a result of design oversights.
The corrective actions identified in those LERs could not prevent the occurrence of these items.
The corrective actions from those LERs have led to the identification of the items reported in this LER. Therefore, this event is not considered recurring.
There were no releases of radioactive materials, radiation exposures or personnel injuries associated with this event.
This event is not considered reportable under the Equipment Performance and Information Exchange (EPIX) program.
ENCLOSURE 1
SIGNATURE SHEET PIP 0-05-3849 Prepared By:
Revised By:
Reviewed By:
Approved By:
- Manager, RGC Reviewed By:
Station Manager
ENCLOSURES:
Date:
Date:
Date:
Date:
Date:
Date:
Date:
Date:
Date:
Date:
- 1. Regulatory Compliance Signature Sheet
- 2. References
- 3. Corrective Action Schedule
- 4. Personnel Contacted
- 5. Cause Code Summary
ENCLOSURE 2 REFERENCES PIP 0-01-1325 SSF Cables do not meet 10CFR50, Appendix R, Section III.G separation requirements.
PIP 0-02-1357 An issue has been raised to a potential Appendix R fire that may cause a failure of LP-19 or LP-20 (LPI Emergency Sump Suction) on any Oconee unit.
PIP 0-02-5549 Assessment of Oconee Fire Protection/Safe Shutdown Program (10CFR50 Appendix R)
PIP 0-03-3708 Review of Procedure and Cable routing for Appendix R Project PIP 0-4-3779 Control Circuit for Circuit Breaker OTS-1 does not meet Appendix R Section III.L.7 separation requirements PIP 0-04-6342 white finding for the Appendix R procedure response time.
PIP 0-05-3849 Current Post-Fire Safe Shutdown procedural guidance does not adequately address spurious operation of HPI pumps.
PIP 0-05 4578 a number of identified Appendix R issues PIP 0-06-1638 Valves *CC-3, 4,
5, 6 are susceptible to closure due to fire induced hot short with no annunciator to alert the operator.
PIP 0-06-8064 During analysis being performed for PIP 06-7655, a
condition equivalent to a failed or missing fire barrier was identified in regards to MS-24/
33 and MS-126/
129.
LER 269 2002-02 Rev.
1 Potential for Fire to Indirectly Damage Mitigation component LER 269 2003-01 Rev 0 Design Oversight Results in Appendix R Control Cable Separation Issue Compliance Manual Sect 3.7 dated 1/19/01 Licensee Event Reports NUREG 1022, Rev.
2 Event Reporting Guidelines NUREG CR-6850 "Fire PRA Methodology for Nuclear Power Facilities" NSD 202, Rev. 20 dated 11/30/05 Reportability NSD 316, Rev.
6 dated 4/26/05 Fire Protection Impairment and Surveillance NSD 320, Rev.
0 dated 6/8/05 Guidance for Performing Licensing Review of Proposed Changes to Fire Protection Program SD 3.2.4, Rev.
0 Fire Protection Program Compensatory Measure Process Calculation OSC-6832 Rev.
1 dated 3/9/99 NRC Letter dated 12/14/04 "Summary of December 6, 2004 Meeting to Discuss Appendix R Reconstitution and Transition to NFPA 805" Duke Letter dated 2/28/05 "Letter of Intent to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants, 2001 Edition" NRC Letter dated 6/8/05 "NRC Response to Duke's Letter of Intent to Adopt IOCFR50.48(c) (NFPA 805 Rule) 10CFR48 Fire Protection
ENCLOSURE 3 CORRECTIVE ACTION SCHEDULE PIP 0-05-3849 CORRECTIVE ACTION PERSON(S)
CONTACTED PERSON(S)
ASSIGNED TO DUE DATE
ENCLOSURE 4 PERSONNEL CONTACTED PIP 0-05-3849 Harold Barrett/ONS Steve Nader/GO Randy Todd/ONS/RGC
ENCLOSURE 5 CAUSE CODE ASSIGNMENT SHEET PIP 0-05-3849 CAUSE CODES:
Detailed Listing of Deficiencies Post Fire Safe Shutdown procedural guidance does not adequately address potential spurious operation of the HPI Pumps.
Based upon a review of the pump circuits, the HPI pumps could be affected for fires in the following areas/zones (30 items):
Pump Fire Fire Fire Zone Description Area Zone 1A HPI Pump BOP 34 Unit 1 6900/4160 Volt Switchgear 106 Unit 1 Cable Room 110 Unit 1 & 2 Control Room lB HPI Pump BOP 34 Unit 1 6900/4160 Volt Switchgear 41 Unit 2 Heater Bay, Upper Surge Tanks and Offices 106 Unit 1 Cable Room 110 Unit 1 & 2 Control Room 1C HPI Pump BOP 34 Unit 1 6900/4160 Volt Switchgear 106 Unit 1 Cable Room 110 Unit 1 & 2 Control Room 2A HPI Pump BOP 33 Unit 2 6900/4160 Volt Switchgear 105 Unit 2 Cable Room 110 Unit 1 & 2 Control Room 2B HPI Pump BOP 33 Unit 2 6900/4160 Volt Switchgear 41 Unit 2 Heater Bay, Upper Surge Tanks & Offices 105 Unit 2 Cable Room 110 Unit 1 & 2 Control Room 2C HPI Pump BOP 33 Unit 2 6900/4160 Volt Switchgear 105 Unit 2 Cable Room 110 Unit 1 & 2 Control Room 3A HPI Pump BOP 29 Unit 3 6900/4160 Volt Switchgear 101 Unit 3 Cable Room 112 Unit 3 Control Room 3B HPI Pump BOP 29 Unit 3 6900/4160 Volt Switchgear 39 Unit 3 Heater Bay, Upper Surge Tanks & Offices 101 Unit 3 Cable Room 112 Unit 3 Control Room 3C HPI Pump BOP 29 Unit 3 6900/4160 Volt Switchgear 101 Unit 3 Cable Room 112 Unit 3 Control Room Detailed Listing of Deficiencies The following is a summary of potential spurious valve operations identified that could adversely affect safe shutdown, which are not addressed by the existing analyses (90 items):
Eq. Tag Equipment Description Eq. Tag Equipment Description 1CCW-269 A S/G FDW CONTROL 1FDW-347 lB S/G INLET BLOCK ON EMERG HDR lLP-21 lB RX BLDG SUCT (PENE lLP-22 1A LPI BWST SUCTION
- 6)
(PENE
- 7)
(#7) 1HP-0426 RC LETDOWN TO SPENT 1HP-0428 RC LETDOWN RETURN ISO VLV FUEL POOL 1RC-4 PZR POWER RELIEF BLOCK 1RC-5 PZR STEAM SAMPLE ISOL (PENE #1) 1RC-6 PZR WATER SAMPLE ISOL 1RC-7 U-1 PZR SAMPLE ISOL PENE (PENE #1)
(#1) 1RC-155 1A OTSG HOT LEG VENT 1RC-156 1A OTSG HOT LEG VENT VALVE BLOCK VALVE 1RC-157 lB HOT LEG VENT 1RC-158 lB HOT LEG VENT BLOCK 1RC-159 RX VESSEL HEAD VENT VLV 1RC-160 RX VESSEL HEAD VENT VLV 1RC-159 1RC-160 1RC-162 RC SAMPLE VLV (IRC-162) 1RC-163 PALS (PENE #5B)
SAMPLE LINE BLK 2CCW-269 A
S/G FDW CONTROL 2FDW-347 TD EFDWP DISCH TO 2B SG VENT (NOR-EMERG HDR) 2LP-21 2A LPI BWST SUCTION 2LP-22 2B LPI BWST SUCTION 2HP-3 2A L/D COOLER OUTLET 2HP-4 2B L/D COOLER OUTLET (PENE
- 6)
(PENE #6) 2HP-20 RCP SEAL RETURN (PENE 2HP-21 RCP SEAL RETURN PENE (#7)
- 7) 2HP-0426 RC LETDOWN TO SPENT 2HP-0428 RC LETDOWN RETURN FUEL POOL ISOLATION 2RC-4 PZR RELIEF BLOCK 2RC-5 PZR STEAM SAMPLE (PENE
- 58A)
CONT ISOL 2RC-6 PZR WATER SAMPLE 2RC-7 U2 PZR SAMPLE ISOL PENE PENE(#58)
(#1) 2RC-155 2A HOT LEG VENT 2RC-156 2A HOT LEG VENT BLOCK 2RC-157 2B HOTLEG VENT 2RC-158 2B HOTLEG VENT BLOCK 2RC-159 RX VESSEL HEAD VENT VLV 2RC-160 RX VESSEL HEAD VENT VLV 2RC-159 2RC-160 2RC-162 RC SAMPLE ISOL VLV 2RC-163 PALS (PENE #5B)
SAMPLE (2RC-162)
LINE BLK 3CCW-269 3A S/G FDW CONTROL 3FDW-347 3B S/G EMERG HDR PENE
(#17)
INLET BLOCK 3LP-21 3B RX BLDG SUCT (PENE 3LP-22 3A LPI BWST SUCTION
- 6)
(PENE
- 7)
(#7) 3HP-0426 RC LETDOWN TO SPENT 3HP-0428.
RC LETDOWN RETURN FUEL POOL ISOLATION 3RC-4 PZR RELIEF BLOCK 3RC-5 PZR STEAM SAMPLE (PENE
- 58A)
(#1) 3RC-155 3A HOT LEG VENT 3RC-156 3A HOT LEG VENT BLOCK 3RC-157 3B HOT LEG VENT 3RC-158 3B HOT LEG VENT BLOCK 3RC-159 RX VESSEL HEAD VENT 3RC-160 RX VESSEL HEAD VENT 3RC-162 RC SAMPLE VALVE 3RC-162 3RC-163 PALS (PENE #5B)
SAMPLE (SOLENOID VLV)
LINE BLK ICC-3 RCP B1 COOLER OUTLET 1CC-4 RCP B2 COOLER OUTLET VLV VLV 1CC-5 RCP Al COOLER OUTLET 1CC-6 RCP A2 COOLER OUTLET VLV VLV 2CC-3 RCP B1 COOLER OUTLET 2CC-4 RCP B2 COOLER OUTLET VLV VLV 2CC-5 RCP Al COOLER OUTLET 2CC-6 RCP A2 COOLER OUTLET VLV VLV 3CC-3 RCP Bi COOLER OUTLET 3CC-4 RCP B2 COOLER OUTLET VLV VLV 3CC-5 RCP Al COOLER OUTLET 3CC-6 RCP A2 COOLER OUTLET VLV VLV lMS-24 MS LINE "A" SUPPLY TO lMS-33 MS LINE "B" SUPPLY TO STARTUP HDR STARTUP HDR lMS-126 AUX STEAM SUPPLY lMS-129 AUX STEAM SUPPLY CONTROL CONTROL VLV VLV 2MS-24 MS LINE "A" SUPPLY TO 2MS-33 MS LINE "B" SUPPLY TO STARTUP HDR STARTUP HDR 2MS-126 AUX STEAM SUPPLY 2MS-129 AUX STEAM SUPPLY CONTROL CONTROL VLV VLV 3MS-24 MS LINE "A" SUPPLY TO 3MS-33 MS LINE "B" SUPPLY TO STARTUP HDR STARTUP HDR 3MS-126 AUX STEAM SUPPLY 3MS-129 AUX STEAM SUPPLY CONTROL CONTROL VLV VLV Detailed Listing of Deficiencies Procedure Enhancements for required manual operator actions and cold shutdown repairs are taken from the Unit 2 review and are representative of Units 1, 2, and 3 (21 items):
Operator actions required to ensure a turbine trip are not included in post-fire safe shutdown procedures.
A BH12 fire may result in a CT4 lockout signal due to faults in cables
- 4CTI, 1B2T910 or 1EB2T908 (see OEE-78 & KEE-17-1).
These faults could activate the CT4 lockout relay (86CT4) or short the conductors connected the lockout relay contacts (simulating a lockout condition).
(CSD)
Loss of 4KV switchgear lTC and the underground feed to Keowee Auxiliary power transformer CX (cables IETC4X, lETC4Y and IETC4Z) would result in the loss of Keowee auxiliary power.
Actions required to restore power are not addressed by the safe shutdown procedures.
(CSD) 2CC PU0002, 2CC PU0003 -
For Cold Shutdown, Operator Repair is required to start one of two CC pumps which have not been incorporated in safe shutdown procedures (eg: Assure that 2CC VA0007 is open, pull control fuse for pump controls and repair by installing jumper around 2CC VA0007 limit switch contact at MCC 2XN (pts. H17, Hl7a) or MCC 2XL (pts. H36, H36a).
2CC VA0001 - For Cold Shutdown, Operator Action is required to open /
close valve 2CC VA0001 to align component cooling to Letdown Cooler used which have not been incorporated in safe shutdown procedures.
2CC VA0002 - For Cold Shutdown, Operator Action is required to open /
close valve 2CC VA0002 to align component cooling to Letdown Cooler used which have not been incorporated in safe shutdown procedures.
2CF VA0001 - Reactor building entry is necessary for manual operation of 2CF-1 if its power cable burns.
2CF-I, 2 are discussed in the Reactor Building Fire Scenario Descriptions in IP/0/A/0050/002 &
RP/0/B/1000/022, but clear procedural guidance is not provided on mechanically closing this valve for a reactor building fire. Valve must be closed for cold shutdown before RCS pressure is decreased below CFT pressure (600 psig).
2CF VA0002 - Reactor building entry is necessary for manual operation of 2CF-2 if its power cable burns.
2CF-I, 2 are discussed in the Reactor Building Fire Scenario Descriptions in IP/0/A/0050/002 &
RP/O/B/1000/022, but clear procedural guidance is not provided on mechanically closing this valve for a reactor building fire.
Valve must be closed for cold shutdown before RCS pressure is decreased below CFT pressure (600 psig).
2HP VA0003 -
A valid ES signal could close valve 2HP VA0003.
A failure of cable 2EXSF2203 (control) or cable 2EXS22A (power) prevents repositioning this valve.
For Cold Shutdown, Operator Action would be required to open 2HP VA0003 or 2HP VA0004 to establish Normal Letdown Path which has not been incorporated in safe shutdown procedures.
2HP VA0004 - A valid ES signal could close valve 2HP VA0004.
A failure of cable 2EXSF2303 (control) or cable 2EXS23A (power) prevents repositioning this valve.
For Cold Shutdown, Operator Action would be required to open 2HP VA0003 or 2HP VA0004 to establish Normal Letdown Path which have not been incorporated in safe shutdown procedures.
Detailed Listing of Deficiencies 2HP VA0005
- - Failure (short to ground) of cables 2XR3701A,
- 2XR3701B, 2XR3901A or 2XR3901B could cause loss of power to 2HP VA0005.
For Cold Shutdown, Operator Action is required to open valve 2HP VA0005 to establish Normal Letdown Path which have not been incorporated in safe shutdown procedures.
2HP VA0021 - Failure (short to ground) of cables 2XR3701A,
- 2XR3701B, 2XR3901A or 2XR3901B could cause loss of power to 2HP VA0021.
This valve is energize-to-close and SSD position is closed.
Valve will fail open.
For hot shutdown, Operator Action is required to close valve 2HP VA0021 or an analysis is required to justify this loss through the seal leak-off return path.
2LP VA0001 - Reactor building entry is necessary for manual operation of 2LP-1 if its power cable burns.
Valve must be opened for cold shutdown.
2LP-I, 2 are discussed in the Reactor Building Fire Scenario Descriptions in IP/O/A/0050/002 & RP/O/B/1000/022, but clear procedural guidance is not provided on mechanically opening this valve for a reactor building fire.
Also, refer to OP/O/A/1102/024, OP/O/A/1102/025 and OP/2/A/1104/004.
OP/2/A/1104/004 states that special tooling is required to mechanically open this valve.
2LP VA0002 -
Reactor building entry is necessary for manual operation of 2LP-2 if its power cable burns.
Valve must be opened for cold shutdown.
2LP-I, 2 are discussed in the Reactor Building Fire Scenario Descriptions in IP/O/A/0050/002 & RP/O/B/1000/022, but clear procedural guidance is not provided on mechanically opening this valve for a reactor building fire.
Also, refer to OP/O/A/1102/024, OP/O/A/1102/025 and OP/2/A/l104/004.
OP/2/A/1104/004 states that special tooling is required to mechanically open this valve.
2RC VA0066 -
For hot shutdown RC Pressure and Inventory Control, Operator Action is required to open breaker #24 at PNLBD 2DIB to preclude possible spurious operation concern for cable 2DIB24A.
This action will de-energize PORV control circuitry and fail it closed.
A conductor-to-conductor hot short (internal to cable 2DIB24A) to solenoid actuator for this valve can occur.
Completion of this shorting path would require a negative ground fault in the reactor building on circuits fed from either PNLBD 2DIB or 2DIA.
No such circuits were found in an initial search.
A more exhaustive search would be required to ensure that this does not occur.
2RC VA0162 -
This RC Sample Isolation Valve is closed and its associated breaker (2KVIB-9) is opened per procedure CP/2/A/2002/004E.
Armored-sheath cable inside containment precludes a spurious actuation of the valve from an external hot short.
Procedural action is required to open this valve for cold shutdown RC Sampling flow path.
A review of CP/2/A/2002/004E, OP/O/A/1102/024, and RP/O/B/1000/022 provided no guidance for opening this valve after a reactor building fire.
2RC VA0163 -
This RC Sample Isolation Valve is normally closed and fails closed.
Procedural action is required to open this valve for cold shutdown RC Sampling flow path.
A review of CP/2/A/2002/004E, OP/O/A/1102/024, and RP/O/B/1000/022 provided no guidance for opening this valve after a reactor building fire.
2RC VA0164 - This RC Sample Isolation Valve is normally closed and fails closed.
Procedural action is required to open this valve for Detailed Listing of Deficiencies cold shutdown RC Sampling flow path.
A review of CP/2/A/2002/004E, OP/O/A/1102/024, and RP/O/B/1000/022 provided no guidance for opening.
this valve after a reactor building fire.
Procedure OP/O/A/1102/025 uses 2HP-140 and 2HP-120 instead of 2HP-31 and 2HP-122 respectively.
Neither 2HP-140 nor 2HP-120 is in the SSEL or shown on the logic diagrams.
Procedure OP/O/A/1102/025 directs the operators to throttle 2LP-17 vs.
2LP-12 as specified on Logic Diagram U2-LPI-004.