View source for 05000270/LER-2021-003, Conditions Prohibited by Technical Specifications Due to Ssf and Psw Inoperability

{{Adams
| number = ML22038A969
| issue date = 02/07/2022
| title = Conditions Prohibited by Technical Specifications Due to Ssf and Psw Inoperability
| author name = Snider S
| author affiliation = Duke Energy Carolinas, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000270
| license number = DPR-049
| contact person = 
| case reference number = RA-22-0062
| document report number = LER 2021-003-00
| document type = Letter, Licensee Event Report (LER)
| page count = 6
}}
{{LER
| Title = Conditions Prohibited by Technical Specifications Due to Ssf and Psw Inoperability
| Plant = 
| Reporting criterion = 10 CFR 50.73(a)(2)(ii)(A), 10 CFR 50.73(a)(2)(viii)(A), 10 CFR 50.73(a)(2)(ii)(B), 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), 10 CFR 50.73(a)(2)(x), 10 CFR 50.73(a)(2)(v)(A), 10 CFR 50.73(a)(2)(v)(B), 10 CFR 50.73(a)(2)(v), 10 CFR 50.73(a)(2)(i)(A), 10 CFR 50.73(a)(2)(i)(B), 10 CFR 50.73(a)(2)(vii), 10 CFR 50.73(a)(2)(i)
| Power level = 
| Mode = 
| Docket = 05000270
| LER year = 2021
| LER number = 3
| LER revision = 0
| Event date = 
| Report date = 
| ENS = 
| abstract = 
}}

=text=
{{#Wiki_filter:Steven M. Snider Vice President Oconee Nuclear Station

Duke Energy ON01SC l 7800 Rochester Hwy Seneca, SC 29672

o.864.873.3478 f: 864.873.5791 Steve.Snider@duke-energy.com

RA-22-0062

February 7, 2022 10 CFR 50.73

Attn: Document Control Desk U. S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2746

Duke Energy Carolinas, LLC Oconee Nuclear Station Unit 2 Docket Number: 50-270 Renewed Operating Licenses: DPR-49

Subject: Licensee Event Report 270/2021-003, Revision 00 - Conditions Prohibited by Technical Specifications Due to SSF and PSW Inoperability

Licensee Event Report 270/2021-003, Revision 00, is being submitted pursuant to the requirements of 10 CFR 50.73 to provide notification of the subject event.

There are no regulatory commitments associated with this LER.

There are no unresolved corrective actions necessary to restore compliance with NRC requirements.

If there are questions, or further information is needed, contact Laura Boyce, Regulatory Affairs, at (864) 873-6774.

Sincerely,

Steven M. Snider Vice President Oconee Nuclear Station

Enclosure: Licensee Event Report 270-2021-003 Rev.00

RA-22-0062 February 7, 2022 Page 2

cc (w/Enclosure):
Ms. Laura Dudes, Administrator, Region II U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257

Mr. Shawn Williams, Project Manager U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop O-08B1A Rockville, MD 20852-2738

Mr. Jared Nadel NRC Senior Resident Inspector Oconee Nuclear Station

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 08/31/2023 (08-2020)

Oconee Nuclear Station Unit 2 0500000270 1 OF 4 4.Title Conditions Prohibited by Technical Specifications Due to SSF and PSW Inoperability 5.Event Date 6. LER Number 7. Report Date 8. Other Facilities Involved Sequential Rev Facility Name Docket Number Month Day Year Year Number No. Month Day Year NA 05000 12 5 2021 2021 003 00 02 07 2022 Facility Name Docket Number NA 05000
: 9. Operating Mode 11. This Report is Submitted Pursuant to the Requirements of 10 CFR &sect;: (Check all that apply) 3 20.2201(b) 20.2203(a)(3)(i) 50.73(a)(2)(ii)(A) 50.73(a)(2)(viii)(A) 20.2201(d) 20.2203(a)(3)(ii) 50.73(a)(2)(ii)(B) 50.73(a)(2)(viii)(B) 20.2203(a)(1) 20.2203(a)(4) 50.73(a)(2)(iii) 50.73(a)(2)(ix)(A) 20.2203(a)(2)(i) 50.36(c)(1)(i)(A) 50.73(a)(2)(iv)(A) 50.73(a)(2)(x)
: 10. Power Level 20.2203(a)(2)(ii) 50.36(c)(1)(ii)(A) 50.73(a)(2)(v)(A) 73.71(a)(4) 20.2203(a)(2)(iii) 50.36(c)(2) 50.73(a)(2)(v)(B) 73.71(a)(5) 000 20.2203(a)(2)(iv) 50.46(a)(3)(ii) 50.73(a)(2)(v)(C) 73.77(a)(1) 20.2203(a)(2)(v) 50.73(a)(2)(i)(A) 50.73(a)(2)(v)(D) 73.77(a)(2)(ii) 20.2203(a)(2)(vi) 50.73(a)(2)(i)(B) 50.73(a)(2)(vii) 73.77(a)(2)(iii) 50.73(a)(2)(i)(C) Other (Specify in Abstract below or in CONTINUED

On December 7th, 2021, Unit 2 entered Mode 3, Mode 2, and Mode 1. After entry into Mode 1, three PSW valves: 2PSW-8, 2PSW-10, and 2PSW -200 were found out of expected position for Mode 1 operation of ONS Unit 2. 2PSW-8 and 2PSW -10 are required to be open for PSW system operability. Operations entered T echnical Specification (TS) 3.7.10 Condition A for PSW system inoperable and took appropriate actions to re -verify system fill and vent and correctly position the valves for proper operational standby. TS 3.7.10 Condition A was exited at 2040 on December 7th, 2021.

On December 13th, 2021, during operator rounds, breakers 2XSF -F4C (U2 SSF RCMUP) and 2XSF -F2B (2RC -219 Valve Operator) were found out of expected position for Mode 1 operatio n of ONS Unit 2. 2XSF -F4C was open and should have been closed. 2XSF -F2B was closed and should have been open and racked out. 2XSF-F4C is required for SSF RCMU System operability. Operations entered TS 3.10.1 Condition C for SSF RCMU System inoperable and took appropriate action to correctly position the breakers for operational standby. TS 3.10.1 Condition C was exited at 1642 on December 13th, 2021.

There were no component failures associated with the PSW valve or SSF breaker positioning event s. The investigations determined that both events were caused by unvalidated assumptions associated with pro cedure sequencing and work dispatch.

SSF Reportability :
From the time Unit 2 entered Mode 3 (mode of applicability) on December 5th until TS 3.10.1 Condition C was exited on December 13th, the SSF RCMUP was INOPERABLE. This period of INOPERABILITY exceeded th e limiting condition for operation (LCO) TS 3.10.1 Condition C, SSF RCMU System INOPERABLE, completion time of 7 days by approximately 37 hours. Subsequently, if the Condition C completion time is not met, Unit 2 is required to be in Mode 3 with in 12 hou rs and Mode 4 in 84 hours (TS 3.7.10 Condition G). Additionally, entry into a Mode or other specified condition in the applicability for LCO 3.10.1 is prohibited by LCO 3.0.4 while the LCO or exceptions in LCO 3.0.4 are not met. Therefore, this event is being reported under 10 CFR 50.73(a)(2)(i)(B) for an Operation or Condition Prohibited by TS.

PSW Reportability :
PSW was INOPERABLE from the time Unit 2 entered Mode 2 (mode of applicability) on December 6th until Mode 3 on December 7th and then again from the time Un it 2 entered Mode 2 on December 7th until TS 3.7.10 Condition A was exited on December 7th. These two periods of IN OPERABILITY do not exceed the LCO TS 3.7.10 Condition A, PSW System INOPERABLE, completion time of 7 days. However, entry into a Mode or other specified condition in the applicability for LCO 3.7.10 is prohibited by LCO 3.0.4 while the LCO or exceptions in LCO 3.0.4 are not met. Therefore, this event is being reported under 10 CFR 50.73(a)(2)(i)(B) for an Ope ration or Condition Prohibited by TS.

CAUSAL FACTORS

For both the SSF and PSW events, cause evaluation s were performed. The evaluations determined that both events were caused by unvalidated assumptions associated with pro cedure sequencing and work dispatch.

==CORRECTIVE ACTIONS==
Immediate:
: 1. Aligned SSF system and PSW system to correct configurations for plant conditions.

Planned:
: 1. Develop and deliver training on validating assumptions.
: 2. Review startup procedures to improve procedure s equencing (Extent of con dition).

CONTINUED

==SAFETY ANALYSIS==
A risk evaluation of these violations determined that they had no significant impact on public health and safety.
The impact on core damage risk of the PSW system being unavailable was very low given the relatively short duration and that PSW is one of se veral backup systems for providing feedwater for steam generator cooling.
Although the SSF RCMU Pump was out of service for a longer period of time, its unavailability also had a very low impact on core damage risk because of Oconees low -leakage RCP sea l design and the ability to repower the HPI pumps from the PSW switchgear for fire, high wind, and other events that could cause a station blackout on the main 4kV buses.

It was noted that the PSW and SSF RCMU systems were out of service concurrently for approximately 24 hours.
However, the combined risk impact remained very low because each system is related to a different safety function and the risk impact is not increa sed further. Also, the breaker for 2RC -219 found closed during power operation has a negligible risk impact given the low probability of a fire event during the short time period, the low probability of this specific hot short circuit, the capability to isolate letdown with 2RC -223, and the other separate means of mitigating these fire events.

Finally, the RCMU Pump was out of service at the time of a Unit 2 Reactor Trip on December 10, 2021. This was an uncomplicated reactor trip where all electrical power sources and normal RCP seal cooling were maintained, and thereby the unavailability of the RCMU Pump was not a risk contributor to the trip event.

Therefore, taking these factors into consideration, it is concluded that these violations had only a very small impact on core damage risk and had no impact on public health and safety.

==ADDITIONAL INFORMATION==
A review of Duke Energys Corrective Action Program did not identify any Oconee LERs or events in the last 3 years that involved the same underlying concerns or reasons as this event.

This event is considered INPO IRIS Reportable.

There were no releases of radioactive materials, radiation exposures or personnel injuries associated with this event.
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