CP-201400684, Revised Completion Date for Multiple Spurious Operation Circuit Interactions Resolution Implementation Plan

From kanterella
(Redirected from ML14188C054)
Jump to navigation Jump to search
Revised Completion Date for Multiple Spurious Operation Circuit Interactions Resolution Implementation Plan
ML14188C054
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/10/2014
From: Flores R, Thomas McCool
Luminant Generation Co, Luminant Power
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201400684, TXX-14070
Download: ML14188C054 (11)
v • d • e


Text

Rafael Flores Luminant Power Senior Vice President P 0 Box 1002

& Chief Nuclear Officer 6322 North FM 56 Rafael.Flores@Luminant.com Glen Rose, TX 76043 Lum inant 2548975590 C 817 559 0403 IF 254 897 6652 CP-201400684 TXX-14070 June 10, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT (CPNPP)

DOCKET NOS. 50-445 AND 50-446 REVISED COMPLETION DATE FOR THE COMANCHE PEAK MULTIPLE SPURIOUS OPERATION CIRCUIT INTERACTIONS RESOLUTION IMPLEMENTATION PLAN

REFERENCE:

Letter logged TXX-12165, dated November 8, 2012, "Request for Extension of Enforcement Discretion for Multiple Spurious Operation Circuit Interactions Resolution,"

from Luminant Power to the NRC

Dear Sir or Madam:

Luminant Generating Company LLC (Luminant Power) is implementing its plan to resolve multiple spurious operations (MSOs) issues at Comanche Peak, as documented in the referenced letter. This plan integrated resolution of operator manual actions (OMAs) with modifications to Comanche Peak to resolve fire protection potential circuit interactions. The extent of the physical modifications will require work during each refueling outage through Fall 2015 for Unit 2 and Spring 2016 for Unit 1. The revised completion date for the Comanche Peak Multiple Spurious Operation Circuit Interactions Resolution Implementation Plan is September 30, 2016.

Attachment I provides a discussion related to the deferral of Fire Safe Shutdown Analysis (FSSA) modifications from the Unit 2 Spring 2014 refueling outage (2RF14) and the Unit 1 Fall 2014 refueling outage (1RF17). Because of the timing and interaction of OMA and MSO issues, as well as the need to expeditiously address the OMA issues that were the subject of a violation, Luminant Power determined that correction of the OMA issues should precede correction of the MSO issues. The resolution of OMAs has a positive impact on MSO resolution as OMA corrective actions potentially preclude some spurious operations. The corrective actions have been carefully planned to ensure that the modifications are safely implemented with minimal impact on the plant. Resolution of OMAs aided in the resolution of the MSOs. OMA modifications will be essentially complete after 1RF17. Therefore the FSSA analysis will be revised to address the completed OMA modifications and Operations procedures will be updated in the first quarter of 2015.

The physical modifications to address the MSO issues, which began during the Fall 2012 outage, will be completed with the Spring 2016 outage. Attachment 2 provides the Comanche Peak OMA MSO Implementation Plan. The current schedule for Unit I has ten FSSA modifications in 1RF17 (Fall 2014) and two modifications in 1RF18 (Spring 2016). Any Unit 1 FSSA modifications not completed in 1RF17 A member of the STARS Alliance Callaway- ComanchePeak. DiabloCanyon- PaloVerde- Wolf Creek -0 (

ýJV2Z-

U. S. Nuclear Regulatory Commission TXX-14070 Page 2 of 2 06/10/2014 will have a detailed constructability review performed in 1RF17 of all parts of the modification requiring field installation to ensure that there are no issues that would preclude reliable installation in 1RF18.

Unit 2 FSSA modifications will be completed in 2RF15 (Fall 2015). Any post outage work (e.g., fire barrier installation) will be completed by June 30, 2016. Revision of the Fire Safe Shutdown Analysis (FSSA) and update of Operations procedures will be completed in the third quarter of 2016.

This communication contains the following new or revised commitments which will be completed or incorporated into the CPNPP licensing basis as noted:

Number Conmmitment Due Date 4872118 Luminant Power will update the Operations procedures for the 03-31-2015 completed OMA modifications by the end of the First Quarter of 2015.

4872144 Any Unit 1 FSSA modification not completed in 1RF17 will have a End of 1RF17 detailed constructability review performed in 1RF17.

4510008 Luminant Power will complete the Comanche Peak OMA MSO 09-30-2016 Implementation Plan by the end of the Third Quarter of 2016.

The Commitment number is used by Luminant Power for the internal tracking of CPNPP commitments.

Should you have any questions, please contact Mr. Jack Hicks at (254) 897-6725.

Sincerely, Luminant Generation Company LLC Rafael Flores By:

Tom P. McCool Vice President, Nuclear Engineering & Support Attachments 1. Discussion Related to Deferral of FSSA Modifications

2. Comanche Peak OMA MSO Implementation Plan c - Marc L. Dapas, Region IV Balwant K. Singal, NRR Resident Inspectors, Comanche Peak

ATTACHMENT 1 TO TXX-14070 Discussion Related to Deferral of FSSA Modifications to TXX-14070 Page 2 of 7 Deferral of 2RF14 FSSA Modifications

1) MSO-10, 11 & 12 FDA-2010-000172-64 / Single Spurious, Control Room Fire 2-LCV-0112B, 2-LCV-0112C, 2-LCV-0112D and 2-LCV-0112E Control circuit rewiring and cable protection for four (4) motor-operated valves:

Field work performed:

No field work was performed. The FDA was not able to meet the 2RF14 outage milestones, Condition Report CR-2014-001506 was generated. The Outage Scope Change (OSC) process was followed to defer the FDA scope until 2RF15.

CR-2014-001506 This CR is written to document a station decision to defer implementation of FDA-2010-000172-64 from 2RF14 until 2RF15. This is a large scope, detailed modification that addresses MSO scenarios 10, 11, and 12 which, in part:

1. Installs Hot Short Prevention Cable (HSPC) in the Control Room and Cable Spread Room to replace the conductors in existing cables that could potentially cause inadvertent actuation of 2-LCV-0112B, 2-LCV-0112C, 2-LCV-0112D and 2-LCV-0112E between the Main Control Board and the point where the cables/conductors exit the Cable Spread Room;
2. Installs new control switches in the Hot Shutdown Panel (2-LV-01) and Shutdown Transfer Panel (2-LV-15) for 2-LCV-0112B and 2-LCV-0112D to allow control of these valves from the Hot Shutdown Panel. This will isolate the portions of the valve control circuit that are routed in the Control Room and Cable Spread Room;
3. Re-configures the control circuit for 2-LCV-0112B and 2-LCV-0112D so that the valves comply with the guidance of NRC Information Notice IN 92-18; and
4. Modifies the design details to facilitate the removal of 3HR cable currently installed in the power and control circuits for 2-LCV-0112B.

The complexity and breadth of this modification coupled with corrective actions from recent plant events led to late development of work orders and test procedures resulting in a significant impact on producing quality, complete, and impacted work orders for field implementation required to support station outage milestones. Deferral of this modification provides the station time to properly assess and address risk factors to assure final implementation meets all station requirements.

2) MSO-55, Issue 3b, Phase I FDA-2010-000172-30 / Upgrade Bonnet/Bolting at 2-8109 Ensures pressure boundary integrity of 2-8109, Positive Displacement Charging Pump Bypass Valve, by replacing the body to bonnet bolting and the bonnet for 2-8109 with different material.

Field work performed:

Valve 2-8109 was disassembled by Maintenance. Upon re-assembly determined the new bonnet did not meet the procurement specifications and could not be installed, CR-2014-004065 was generated.

The vendor supplied the wrong bonnet assembly. Valve 2-8109 was re-assembled using original parts back to original configuration and tested SATISFACTORILY. The Outage Scope Change (OSC) process was followed to defer the FDA scope until 2RF15.

to TXX-14070 Page 3 of 7 CR-2014-004065:

The new replacement Valve Bonnet for 2-8109 is not a like for like replacement. The Bonnet Backseat Bore is larger than existing and eliminates backseat. FDA-2010-000172-30 will be deferred until 2RF15.

Additional Information:

CR-2014-006298 CR-2014-006298 was written to document that during 1RF16 a new vendor supplied bonnet was installed on 1-8109 that resulted in a factory machined backseat bore too large for the beveled portion of the stem to mate against or create a backseat seal. This issue was identified in 2RF14 when the same mod was to be installed on 2-8109. This modification will be implemented the next available opportunity after parts are available.

3) MSO-55, Issue 3b, Phase IV FDA-2010-000172 Replace Motors and Upgrade Stems of MOVs 2-8100 & 8112 Ensures manual operational capability of 2-8100 and 2-8112, RCP Seal Return Isolation Valves, by replacing existing 10 ft/lb motors with new 5 ft/lb motors and replace the existing valve stem with a SMART STEM to improve the accuracy of field measurements.

Field work performed:

The original 2RF14 work scope was to replace the motor and stems on 2-8100 and 2-8112. The motor for 2-8100 and the stems for both 2-8100 and 2-8112 were on site. Delivery of the new motor for 2-8112 would not support the outage work window, and therefore, CR-2014-003472was generated.

FDA-2010-000172-76 has both valves in scope and would require engineering to revise the FDA to split up the valve design. Planning would need to revise the work orders and Operations would need to re-impact the work order just prior to/or during the outage in order to perform the work scope on only 2-8100. In addition, it would not be prudent to perform work twice on valve 2-8112 (during 2RF14 replace stem then again during 2RF15 to replace the motor). The Outage Scope Change (OSC) process was followed to defer the entire FDA scope until 2RF15. No field work performed on either valve 2-8100 or 2-8112.

CR-2014-003472 Outage Management was notified on March 29, 2014 that one of the new motors to support FSSA Modification FDA-2010-000172-76 on 2-8100-MO and 2-8112-MO would not be delivered to the site before the outage need date. This CR is to document the decision making meeting held in the OCC on March 30, 2014 to remove this FDA from 2RF14 scope and defer to 2RF15

4) MSO-15A FDA-2010-000172-60 / RWST Drain Down 2-8811A & 2-8811B Eliminate the possibility of RSWT inventory loss to the containment sumps via 2-8811A and 2-8811B, Containment Recirculation Sump Isolation Valves, by replacement of unprotected cables with HSPC.

Field work performed:

The required modification for valve 2-8811B was successfully implemented and De-energized/Energized testing performed satisfactorily during 2RF14. During the field implementation activities for 2-8811A, two conductors were de-termed, lugs removed and the cable pulled back to a junction box. During the pull back of cable E0223531, it was identified that the field route did not match the GENESIS (Electronic Cable & Raceway Data System) route. Field work immediately stopped and CR-2014-004604 was generated. Engineering review determined that the field route for cable E0223531 was not per GENESIS. Extensive engineering re-design and walkdowns would be required to determine the current cable route and develop new cable routing.

There was uncertainty in duration for the walkdowns and engineering effort needed to resolve this to TXX-14070 Page 4 of 7 issue. The Outage Scope Change (OSC) process was followed to defer the entire FDA scope until 2RF15. The two conductors were re-pulled back to valve 2-8811A, lugs re-installed and terminated.

De-energized and Energized testing was performed satisfactorily on valve 2-8811A.

CR-2014-004604 Field route of cable EO223531 does not match GENESIS. A reroute of the cable is required.

CR-2014-004723 As a result of the cable routing issues identified in CR-2014-004604, the corrective measures will require significant investigation into the current cable route in order to establish what new design will be required. As a result, the scope of FDA-2010-000172-60 as it pertains to 2-8811A is being deferred to the next refueling outage for Unit 2 (2RF15).

Additional Information:

CR-2014-004721 CR-2014-004604 was written to document that the field route of cable E0223531 does not match the route given in GENESIS. That CR was written because the identified discrepancy caused implementation problems with FDA 2010-000172-60. This CR did not address the potential for other issues as a result of this discrepancy. The resolution of the MSO issue at CPNPP required that the subject cable be protected from the CR hand switch to the termination at the MCC. Review of the existing plant design indicated that this cable was already identified as requiring Thermolag in Fire Areas 2SB and 2AA-S. FDAs 2101-000172-60 and -46 were implementing protection on the remainder of the route. The original Pull Card for the cable was retrieved and the nodal route on that installation document matched the routing currently given in GENESIS. The field implementation activities that led to CR-2014-004604 discovered that the routing in Fire Area 2SD is not in accordance with the plant design given in GENESIS. Printouts of GENESIS FSSA reports are attached that show the requirement for Thermolag on the subject cable and that shows Thermolag on the raceways associated with the subject cable in Fire Areas 2SB and AA-S (fire zones 2-08 and 2-21B). The purpose of this CR is to identify the actual routing of the subject cable and determine any other impacts of the deviation of this cable from the identified GENESIS route.

Licensee Event Report LER 2-14-001-00, "Cable Routing Unanalyzed for Safe Shutdown Barrier," will address this issue.

5) MSO-36A/61 FDA-2010-000172-69 / RCS Pressure Decrease / 2-PCV-0456 & 2-PCV-0455A Prevent the spurious operation of the Unit 2 Pressurizer Power Operated Relief Valves (PORVs), 2-PCV-0455A and 2-PCV-0456, by use of HSPC and RES type material inside containment. HSPC and thermolag will be used outside containment.

Field work performed:

The work scope for 2-PCV-0456 (outside containment) was successfully implemented and tested satisfactorily. However during the implementation activities for 2-PCV-0455A, a junction box cover was removed and the cable fill issue and the existing Kellum grip were identified and CR-2014-004665 was generated. Engineering evaluated the condition and even though GENESIS identified the conduit as 44.7% full, it was determined that the cable could not be pulled through the existing conduit. Also it was determined that the Kellum grip could not be removed without risk of damaging the existing cables.

CR-2014-004665 Due to the extensive time to design an alternate approach to modify the 2-PCV-0455A cable run inside containment, this portion of the FDA is being deferred to 2RF15.

Attachment I to TXX-14070 Page 5 of 7 CR-2014-004723 The remaining work on 2-PCV-0455A is located both inside the Reactor Containment Building (IRC) and outside the Reactor Containment Building (ORC). The remaining work IRC is documented on CR-2014-004665 above. The work outside containment consists of three distinct locations: 2-LV-15, penetration 2-E-0061, and Junction Box JB2S-57980. Details of the work required to be completed are:

  • The new HSPC external wiring has been installed at 2-LV-15. The remaining work is for the HSPC shield to be terminated on the negative of the DC bus.

" The internals of 2-LV-15 for the transfer handswitch internal wiring has not been implemented.

6) MSO-55, Issue 3c, Phase II FDA-2010-000172 Mechanical damage to pressure boundary for 2-8716A, 2-8804A, 2-8809A, 2-8811A, 2-8812A Control circuit rewiring and cable protection for five (5) motor-operated valves Field work performed:

No field work was performed. CR-2014-004249 was generated and the Outage Scope Change (OSC) process was followed to defer the FDA scope until 1RF18.

CR-2014-004249 Based on difficulties encountered in 2RF14 with the installation of FDA-2010-000172-47 (Unit 2 Train B RHR), it was not considered prudent to plan on modifying both trains of RHR in the same outage.

It became evident during the installation of the first train of RHR/SI MOV modification installation that working both trains of the NSSS systems in the same outage contained complications and execution challenges that had not been experienced during the previous outages which only worked a single train MSO -55 mod per outage. The concerns related to other potential unrecognized difficulties could not be positively quantified or dismissed during the outage and at the time the decision was made to defer there was judged to be a possibility that unrecognized coordination issues or other degraded conditions could be created. Therefore it was deemed prudent to implement the SI/RHR valve work for each train in a different time frame until a track record and confidence could be developed. This modification ensures capability of manual actuation for the Train A SI/RHR valves. These valves are not needed for 10 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> post-fire. The decision was made to proceed with the work for the 2EA1 Electrical Bus FSSA modification as this modification protected equipment from immediate failure.

Additional Information:

MSO-49 & 49b, FDA-2010-000172-55, Spurious operation of EDG breakers Control circuit rewiring of switchgear breakers This design error is documented in CR-2014-005198 and it renders the modification ineffective in providing design protection against spurious operation.

CR-2014-005198 It was discovered that there was an error in the design of FDA-2010-000172-55. This error only impacts the shield conductor of the HSPC cables installed by this FDA during 2RF14. The HSPC shield is a passive component that is not connected to any part of the active part of the control circuit. The shield conductor in an AC circuit is required to be connected to the plant's ground in order to protect the circuit against hot shorts. The shield conductor in a DC circuit is required to be connected to the DC negative potential in order to protect the circuit against hot shorts.

I to TXX-14070 Page 6 of 7 The wiring being protected in FDA-2010-000172-55 is part of the 125 VDC control circuit for breakers 2EA1-1, 2EA1-2 and 2EG1. In these circuits the design instructs the ground conductor to be connected to AC ground.

The connection to ground of the HSPC shield conductor has no impact to the functionality of the circuit.

Deferral of 1RF17 FSSA Modifications

1) MSO-10, 11 & 12 FDA-2010-000172-63 / Single Spurious, Control Room Fire 1-LCV-0112B, 1-LCV-0112C, 1-LCV-0112D and 1-LCV-0112E Control circuit rewiring and cable protection for four (4) motor-operated valves Field work performed:

No field work was performed. The FDA was not able to meet the 1RF17 outage milestones, CR-2014-006528 was generated. The Outage Scope Change (OSC) process was followed to defer the FDA scope until the Unit 1 Spring 2016 refueling outage (1RF18).

CR-2014-006528 This CR is written to document a station decision to defer implementation of FDA-2010-000172-63 from 1RF17 until 1RF18. This is a large scope, detailed modification that addresses MSO scenarios 10, 11, and 12 which, in part,

1. Installs Hot Short Prevention Cable (HSPC) in the Control Room and Cable Spread Room to replace the conductors in existing cables that could potentially cause inadvertent actuation of 1-LCV-0112B, 1-LCV-0112C, 1-LCV-0112D and 1-LCV-0112E between the Main Control Board and the point where the cables/conductors exit the Cable Spread Room;
2. Installs new control switches in the Hot Shutdown Panel (1-LV-01) and Shutdown Transfer Panel (1-LV-15) for 1-LCV-0112B and 1-LCV-0112D to allow control of these valves from the Hot Shutdown Panel. This will isolate the portions of the valve control circuit that are routed in the Control Room and Cable Spread Room;
3. Re-configures the control circuit for 1-LCV-0112B and 1-LCV-0112D so that the valves comply with the guidance of NRC Information Notice IN 92-18; and 4. Modifies the design details to facilitate the removal of 3HR cable in the power and control circuits for 1-LCV-0112B."

The complexity and breadth of this modification coupled with corrective actions from recent plant events led to late development of the design package. The work orders and test procedures have not been completed resulting in a significant impact on producing quality, complete, and impacted work orders for field implementation required to support station outage milestones.

Deferral of this modification provides the station time to properly assess and address risk factors to assure final implementation meets all station requirements.

2) MSO-55, Issue 3c, Phase III FDA-2010-000172 Mechanical damage to pressure boundary for 1-8000B, 1-8110, 1-8111, 1-8804B, 1-8812B Control circuit rewiring and cable protection for five (5) motor-operated valves Field work performed:

No field work was performed. The FDA was not able to meet the 1RF17 outage milestones, CR-2014-006530 was generated. The Outage Scope Change (OSC) process was followed to defer the FDA scope until 1RF18.

to TXX-14070 Page 7 of 7 CR-2014-006530 This CR is written to document a station decision to defer implementation of FDA-2010-000172-49 from 1RF17 until 1RF18. Corrective actions from recent plant events led to late development of the design package. The related test procedure development and work order planning commenced late and could not support station outage milestones. Based on difficulties encountered in 2RF14 with the installation of FDA-2010-000172-47 (Unit 2 Train B RHR), it was not considered prudent to plan on modifying both trains of RHR in the same outage. Since FDA-2010-000172-63 was being deferred to 1RF18, the decision was made to defer one train of RHR until 1RF18. Since the pre-outage work is complete on the Unit 1 Train A RHR modification, the decision was made to defer the Unit 1 Train B modification to 1RF18. In addition, a preliminary review of 1RF18 showed that deferring the Unit 1 Train B RHR modification would have the least impact on the critical path in 1RF18.

ATTACHMENT 2 TO TXX-14070 Comanche Peak OMA MSO Implementation Plan

OMA MSO Implementation Plan 2015 1 2016

  • I A

...... T. A ...... ...

0.14 dSOl- &AStC MAO-AS. ASlO-tAA d SADlIa,.* QllII-R *fl i N1-$S S-A.:14* IA AWAA tZN**A S-A 2-StA*S-*1AWA flOAinOW w.o. muu uWSC f INCS MO-NAApA1 At--0 M NSP*Z INCIN-LWAO-AA.* lAOSO*8**,..1 P.1....IN17"N-

. AOAAIAF .CO CAO* SINk..Wlgl t I4 ASe L A INCA NAA A~M~O..

wo-A A ...

AIvN"AAA AMOSAA A-AA (20 LC-AN AA4~l SA WAAO.*d.A (S)-IAAMA4AA.Aa-Cf..A As SAS0.

ISAU (A,A-) OO 1*'**2el 4

A. tw,. M.

(AAAAAAn *pJAS..t IAAC.mt

Retrieved from "https://kanterella.com/w/index.php?title=CP-201400684,_Revised_Completion_Date_for_Multiple_Spurious_Operation_Circuit_Interactions_Resolution_Implementation_Plan&oldid=2047182"