ML23102A164

Generation Station, Unit No. 2 – Potential Emergent Relief Request for HPCI IST (EPID L-2023-LLR-0015) - Closure E-mail Dated 4/12/2023

ML23102A164
Person / Time
Site:	Limerick
Issue date:	04/12/2023
From:	Marisa Herrera NRC/NRR/DORL/LPL1
To:	Gurjendra Bedi, Ahsan Sallman NRC/NRR/DEX/EMIB, NRC/NRR/DSS/SNSB
References
EPID L-2023-LLR-0015
Download: ML23102A164 (1)

Text

From: Elena Herrera Torres To: Ahsan Sallman; Gurjendra Bedi Cc: Richard Guzman; Audrey Klett; Hipo Gonzalez; Stewart Bailey; Diana Woodyatt

Subject:

RE: Limerick - potential emergent HPCI IST relief request Date: Wednesday, April 12, 2023 7:14:08 AM Importance: High

Good morning team,

We received a notification from Stephen Flickinger that LGS Unit 2 RCIC was returned to operable status during night shift last night and that Limerick will not be seeking a relief request for LGS HPCI testing at this time.

Therefore, there will be no review and we will be closing out the EPID this morning.

Thanks for all the support.

Elena

From: Elena Herrera Torres Sent: Tuesday, April 11, 2023 3:49 PM To: Ahsan Sallman <Ahsan.Sallman@nrc.gov>; Gurjendra Bedi <Gurjendra.Bedi@nrc.gov>

Cc: Richard Guzman <Richard.Guzman@nrc.gov>; Audrey Klett <Audrey.Klett@nrc.gov>; Hipo Gonzalez <Hipolito.Gonzalez@nrc.gov>; Stewart Bailey <Stewart.Bailey@nrc.gov>; Diana Woodyatt

<Diana.Woodyatt@nrc.gov>

Subject:

RE: Limerick - potential emergent HPCI IST relief request

Good afternoon,

As update to the subject emergent relief request, the licensee indicated earlier this afternoon that they have identified the source of the ground. They are currently working towards restoring the RCIC system. There is a possibility that the Emergent Relief Request will not be needed. The licensee determination will be shared with us by tomorrow morning.

Nonetheless, we will receive a DRAFT version this afternoon.

We will keep you updated.

Respectfully, Elena

Maria Elena Herrera, P.E., C.C.M.

Project Manager NRR/DORL/LPL-1 U.S. Nuclear Regulatory Comission Location: OWFN-7E15 Office: (301) 415-8208 Email:meh9@nrc.gov

From: Audrey Klett < Audrey.Klett@nrc.gov>

Sent: Tuesday, April 11, 2023 9:43 AM To: Richard Guzman < Richard.Guzman@nrc.gov>; Elena Herrera Torres

<Maria.HerreraTorres@nrc.gov >

Subject:

FW: Limerick - potential emergent HPCI IST relief request

Hi Rich, FYi - Hipo wants me to focus on the LIM 50.69 this week, so hes thinking of having you help Elena with this verbal relief request (see info below).

I havent opened an EPID yet but was gonna do that today to get the reviewers lined up, but I can save that for you two if you can work on it.

From: Audrey Klett Sent: Tuesday, April 11, 2023 9:33 AM To: Hipo Gonzalez < Hipolito.Gonzalez@nrc.gov>; Elena Herrera Torres

<Maria.HerreraTorres@nrc.gov >; Stewart Bailey <Stewart.Bailey@nrc.gov>; Diana Woodyatt

<Diana.Woodyatt@nrc.gov >

Cc: Matthew Mitchell <Matthew.Mitchell@nrc.gov>; Angie Buford <Angela.Buford@nrc.gov>; Adam Ziedonis <Adam.Ziedonis@nrc.gov>; Mel Gray <Mel.Gray@nrc.gov>; Kevin Mangan

<Kevin.Mangan@nrc.gov >; Sarah Elkhiamy (She/Her) <Sarah.Elkhiamy@nrc.gov>; Matthew Hardgrove <Matthew.Hardgrove@nrc.gov>; Larry Grimes <Larry.Grimes@nrc.gov>; Wendell Morton

<Wendell.Morton@nrc.gov >

Subject:

RE: Limerick - potential emergent HPCI IST relief request

Licensee said theyll be submitting the application sometime tomorrow (probably ~COB),

requesting an alternative under 50.55a(z)(2), essentially asking to delay the HPCI tests (pump/valve/flow tests & vacuum breaker test) possibly by a couple weeks (for Unit 2).

They would need the alternative authorized by 1 am Friday.

Theyre working on getting me the specific code section to which theyll be requesting an alternative.

Ill open an EPID in RPS today. Ill invite EMIB, SNSB, NPHP, NVIB, but it sounds like DNRL might not need to be on this one.

Ill set up a meeting early Thursday to confirm review assignments.

From: Audrey Klett Sent: Tuesday, April 11, 2023 7:58 AM To: Hipo Gonzalez < Hipolito.Gonzalez@nrc.gov>; Elena Herrera Torres

<Maria.HerreraTorres@nrc.gov >; Matthew Mitchell <Matthew.Mitchell@nrc.gov>; Angie Buford

<Angela.Buford@nrc.gov >; Stewart Bailey <Stewart.Bailey@nrc.gov>; Diana Woodyatt

<Diana.Woodyatt@nrc.gov >; Wendell Morton <Wendell.Morton@nrc.gov>

Subject:

FW: Limerick - potential emergent HPCI IST relief request Importance: High

FYI - will convey more once I talk to the licensee. Info below is from the Limerick SRI.

From: Adam Ziedonis < Adam.Ziedonis@nrc.gov>

Sent: Tuesday, April 11, 2023 7:39 AM To: Audrey Klett < Audrey.Klett@nrc.gov>

Cc: Sarah Elkhiamy (She/Her) <Sarah.Elkhiamy@nrc.gov>; Matthew Hardgrove

<Matthew.Hardgrove@nrc.gov >; Larry Grimes <Larry.Grimes@nrc.gov>; Nikki Warnek (She/They)

<Nicole.Warnek@nrc.gov >

Subject:

Limerick - potential emergent HPCI IST relief request

GM Audrey,

This is just an early, informal heads up..

Limerick is exploring an option to potentially request an emergent ASME IST relief request related to the performance of Unit 1 HPCI system testing.

Background:

Limerick is working through an emergent issue on Unit 2 involving a division 1 safety-related battery system ground that occurred last Thursday night, which brought in several main control room alarms and required closure of some primary containment isolation valves (PCIVs) in the 2A RHR system and the RCIC system, and therefore resulted in all modes of 2A RHR and the RCIC system being inoperable. The risk informed completion time (RICT) program was used to extend the LCO to 30 days, and the station has staffed their Outage Control Center (OCC) to coordinate working 24/7 through complex troubleshooting to methodically check all the div 1 circuits in an effort to identify and repair the source of the ground.

The U2 HPCI system has some IST surveillances coming due by the end of the week, which results in the HPCI system being inoperable during the test. My understanding, from verbal discussions, is that the HPCI IST (pump and valves) will go overdue after this Friday (4/14), which includes the 25%

grace allowed by Tech Specs. If Limerick has not restored U2 RCIC by Friday, U2 would have to enter Tech Spec 3.0.3 with HPCI and RCIC inoperable at the same time. Tech Spec 3.0.3 requires restoration of HPCI or RCIC to OPERABLE within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, and if not completed, requires being in HOT SHUTDOWN within a subsequent 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The station prefers to avoid the nuclear safety risk of rendering HPCI and RCIC inoperable at the same time to perform an IST, and also does not want to place U2 in short duration shutdown statement to complete an IST.

All that said, early this morning they identified a ground in a portion of the div 1 system associated with the D21 EDG control power. They are working through methods to identify the exact source and see if that clears the ground alarm on the div 1 system. I only mention because obviously if they find an correct this issue prior to Friday, I would expect there would be no need for an emergent relief request.

OPEX:

I asked them if they had any operating experience for similar relief requests, and as of yesterday afternoon they said they had some recent Monticello OPEX from Dec 2022, which they sent to me and I have attached.

Ill make sure to keep in touch early and often.

Also, I realized I dont have your cell #. Would you please sent it to me?

Thanks.and Happy Tuesday!

Adam Ziedonis Limerick Senior Resident Inspector Region 1 / DORS / PB4 Cell: 570-793-9673