ML14188C054

Comanche Peak, Units 1 and 2, Revised Completion Date for Multiple Spurious Operation Circuit Interactions Resolution Implementation Plan

ML14188C054
Person / Time
Site:	Comanche Peak
Issue date:	06/10/2014
From:	Flores R, McCool T P Luminant Generation Co, Luminant Power
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201400684, TXX-14070
Download: ML14188C054 (11)

Text

Rafael Flores Luminant PowerSenior Vice President P 0 Box 1002& Chief Nuclear Officer 6322 North FM 56Rafael.Flores@Luminant.com Glen Rose, TX 76043Lum inant 2548975590C 817 559 0403IF 254 897 6652CP-201400684TXX-14070June 10, 2014U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT (CPNPP)DOCKET NOS. 50-445 AND 50-446REVISED COMPLETION DATE FOR THE COMANCHE PEAK MULTIPLE SPURIOUSOPERATION CIRCUIT INTERACTIONS RESOLUTION IMPLEMENTATION PLAN

REFERENCE:

Letter logged TXX-12165, dated November 8, 2012, "Request for Extension ofEnforcement 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 multiplespurious operations (MSOs) issues at Comanche Peak, as documented in the referenced letter. This planintegrated resolution of operator manual actions (OMAs) with modifications to Comanche Peak toresolve fire protection potential circuit interactions. The extent of the physical modifications will requirework during each refueling outage through Fall 2015 for Unit 2 and Spring 2016 for Unit 1. The revisedcompletion date for the Comanche Peak Multiple Spurious Operation Circuit Interactions ResolutionImplementation 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 refuelingoutage (1RF17). Because of the timing and interaction of OMA and MSO issues, as well as the need toexpeditiously address the OMA issues that were the subject of a violation, Luminant Power determinedthat correction of the OMA issues should precede correction of the MSO issues. The resolution of OMAshas a positive impact on MSO resolution as OMA corrective actions potentially preclude some spuriousoperations. The corrective actions have been carefully planned to ensure that the modifications are safelyimplemented with minimal impact on the plant. Resolution of OMAs aided in the resolution of theMSOs. OMA modifications will be essentially complete after 1RF17. Therefore the FSSA analysis will berevised to address the completed OMA modifications and Operations procedures will be updated in thefirst quarter of 2015.The physical modifications to address the MSO issues, which began during the Fall 2012 outage, will becompleted with the Spring 2016 outage. Attachment 2 provides the Comanche Peak OMA MSOImplementation 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 1RF17A member of the STARS AllianceCallaway- ComanchePeak. DiabloCanyon- PaloVerde- Wolf Creek -0 (ý JV2Z-U. S. Nuclear Regulatory CommissionTXX-14070Page 2 of 206/10/2014will have a detailed constructability review performed in 1RF17 of all parts of the modification requiringfield 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 barrierinstallation) will be completed by June 30, 2016. Revision of the Fire Safe Shutdown Analysis (FSSA) andupdate 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 orincorporated into the CPNPP licensing basis as noted:NumberConmmitmentDue Date4872118 Luminant Power will update the Operations procedures for thecompleted OMA modifications by the end of the First Quarter of 2015.4872144 Any Unit 1 FSSA modification not completed in 1RF17 will have adetailed constructability review performed in 1RF17.4510008 Luminant Power will complete the Comanche Peak OMA MSOImplementation Plan by the end of the Third Quarter of 2016.03-31-2015End of 1RF1709-30-2016The 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 LLCRafael FloresBy:Tom P. McCoolVice President, Nuclear Engineering & SupportAttachments1. Discussion Related to Deferral of FSSA Modifications2. Comanche Peak OMA MSO Implementation Planc -Marc L. Dapas, Region IVBalwant K. Singal, NRRResident Inspectors, Comanche Peak ATTACHMENT 1 TO TXX-14070Discussion Related to Deferral of FSSA Modifications to TXX-14070Page 2 of 7Deferral of 2RF14 FSSA Modifications1) MSO-10, 11 & 12FDA-2010-000172-64 / Single Spurious, Control Room Fire2-LCV-0112B, 2-LCV-0112C, 2-LCV-0112D and 2-LCV-0112EControl 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 wasfollowed to defer the FDA scope until 2RF15.CR-2014-001506This CR is written to document a station decision to defer implementation of FDA-2010-000172-64from 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 toreplace 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 andthe 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 HotShutdown Panel. This will isolate the portions of the valve control circuit that are routed in theControl Room and Cable Spread Room;3. Re-configures the control circuit for 2-LCV-0112B and 2-LCV-0112D so that the valves complywith the guidance of NRC Information Notice IN 92-18; and4. Modifies the design details to facilitate the removal of 3HR cable currently installed in the powerand control circuits for 2-LCV-0112B.The complexity and breadth of this modification coupled with corrective actions from recentplant events led to late development of work orders and test procedures resulting in a significantimpact on producing quality, complete, and impacted work orders for field implementationrequired to support station outage milestones. Deferral of this modification provides the stationtime to properly assess and address risk factors to assure final implementation meets all stationrequirements.2) MSO-55, Issue 3b, Phase IFDA-2010-000172-30 / Upgrade Bonnet/Bolting at 2-8109Ensures 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 didnot 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 originalparts back to original configuration and tested SATISFACTORILY. The Outage Scope Change (OSC)process was followed to defer the FDA scope until 2RF15. to TXX-14070Page 3 of 7CR-2014-004065:The new replacement Valve Bonnet for 2-8109 is not a like for like replacement. The Bonnet BackseatBore is larger than existing and eliminates backseat. FDA-2010-000172-30 will be deferred until2RF15.Additional Information:CR-2014-006298CR-2014-006298 was written to document that during 1RF16 a new vendor supplied bonnet wasinstalled on 1-8109 that resulted in a factory machined backseat bore too large for the beveled portionof the stem to mate against or create a backseat seal. This issue was identified in 2RF14 when thesame mod was to be installed on 2-8109. This modification will be implemented the next availableopportunity after parts are available.3) MSO-55, Issue 3b, Phase IVFDA-2010-000172-76 -Replace Motors and Upgrade Stems of MOVs 2-8100 & 8112Ensures manual operational capability of 2-8100 and 2-8112, RCP Seal Return Isolation Valves, byreplacing existing 10 ft/lb motors with new 5 ft/lb motors and replace the existing valve stem with aSMART 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 motorfor 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 tosplit up the valve design. Planning would need to revise the work orders and Operations wouldneed to re-impact the work order just prior to/or during the outage in order to perform the workscope 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 ScopeChange (OSC) process was followed to defer the entire FDA scope until 2RF15. No field workperformed on either valve 2-8100 or 2-8112.CR-2014-003472Outage Management was notified on March 29, 2014 that one of the new motors to support FSSAModification FDA-2010-000172-76 on 2-8100-MO and 2-8112-MO would not be delivered to the sitebefore the outage need date. This CR is to document the decision making meeting held in the OCCon March 30, 2014 to remove this FDA from 2RF14 scope and defer to 2RF154) MSO-15AFDA-2010-000172-60 / RWST Drain Down 2-8811A & 2-8811BEliminate 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 fieldimplementation activities for 2-8811A, two conductors were de-termed, lugs removed and the cablepulled back to a junction box. During the pull back of cable E0223531, it was identified that the fieldroute did not match the GENESIS (Electronic Cable & Raceway Data System) route. Field workimmediately stopped and CR-2014-004604 was generated. Engineering review determined that thefield route for cable E0223531 was not per GENESIS. Extensive engineering re-design andwalkdowns 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-14070Page 4 of 7issue. The Outage Scope Change (OSC) process was followed to defer the entire FDA scope until2RF15. 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-2014-004604Field route of cable EO223531 does not match GENESIS. A reroute of the cable is required.CR-2014-004723As a result of the cable routing issues identified in CR-2014-004604, the corrective measures willrequire significant investigation into the current cable route in order to establish what new designwill be required. As a result, the scope of FDA-2010-000172-60 as it pertains to 2-8811A is beingdeferred to the next refueling outage for Unit 2 (2RF15).Additional Information:CR-2014-004721CR-2014-004604 was written to document that the field route of cable E0223531 does not match theroute given in GENESIS. That CR was written because the identified discrepancy causedimplementation problems with FDA 2010-000172-60. This CR did not address the potential for otherissues as a result of this discrepancy. The resolution of the MSO issue at CPNPP required that thesubject cable be protected from the CR hand switch to the termination at the MCC. Review of theexisting plant design indicated that this cable was already identified as requiring Thermolag in FireAreas 2SB and 2AA-S. FDAs 2101-000172-60 and -46 were implementing protection on the remainderof the route. The original Pull Card for the cable was retrieved and the nodal route on that installationdocument matched the routing currently given in GENESIS. The field implementation activities thatled to CR-2014-004604 discovered that the routing in Fire Area 2SD is not in accordance with theplant design given in GENESIS. Printouts of GENESIS FSSA reports are attached that show therequirement for Thermolag on the subject cable and that shows Thermolag on the racewaysassociated with the subject cable in Fire Areas 2SB and AA-S (fire zones 2-08 and 2-21B). The purposeof this CR is to identify the actual routing of the subject cable and determine any other impacts of thedeviation of this cable from the identified GENESIS route.Licensee Event Report LER 2-14-001-00, "Cable Routing Unanalyzed for Safe Shutdown Barrier," willaddress this issue.5) MSO-36A/61FDA-2010-000172-69 / RCS Pressure Decrease / 2-PCV-0456 & 2-PCV-0455APrevent 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 andthermolag will be used outside containment.Field work performed:The work scope for 2-PCV-0456 (outside containment) was successfully implemented and testedsatisfactorily. However during the implementation activities for 2-PCV-0455A, a junction box coverwas 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 theconduit as 44.7% full, it was determined that the cable could not be pulled through the existingconduit. Also it was determined that the Kellum grip could not be removed without risk ofdamaging the existing cables.CR-2014-004665Due to the extensive time to design an alternate approach to modify the 2-PCV-0455A cable runinside containment, this portion of the FDA is being deferred to 2RF15.

Attachment I to TXX-14070Page 5 of 7CR-2014-004723The 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 onCR-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 theHSPC 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 beenimplemented.6) MSO-55, Issue 3c, Phase IIFDA-2010-000172-46 -Mechanical damage to pressure boundary for 2-8716A, 2-8804A, 2-8809A,2-8811A, 2-8812AControl circuit rewiring and cable protection for five (5) motor-operated valvesField 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-2014-004249Based on difficulties encountered in 2RF14 with the installation of FDA-2010-000172-47 (Unit 2 TrainB 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 installationthat working both trains of the NSSS systems in the same outage contained complications andexecution challenges that had not been experienced during the previous outages which only workeda single train MSO -55 mod per outage. The concerns related to other potential unrecognizeddifficulties could not be positively quantified or dismissed during the outage and at the time thedecision was made to defer there was judged to be a possibility that unrecognized coordinationissues or other degraded conditions could be created. Therefore it was deemed prudent to implementthe SI/RHR valve work for each train in a different time frame until a track record and confidencecould be developed. This modification ensures capability of manual actuation for the Train ASI/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 toproceed with the work for the 2EA1 Electrical Bus FSSA modification as this modification protectedequipment from immediate failure.Additional Information:MSO-49 & 49b,FDA-2010-000172-55, Spurious operation of EDG breakersControl circuit rewiring of switchgear breakersThis design error is documented in CR-2014-005198 and it renders the modification ineffective inproviding design protection against spurious operation.CR-2014-005198It was discovered that there was an error in the design of FDA-2010-000172-55. This error only impactsthe shield conductor of the HSPC cables installed by this FDA during 2RF14. The HSPC shield is apassive component that is not connected to any part of the active part of the control circuit. The shieldconductor in an AC circuit is required to be connected to the plant's ground in order to protect the circuitagainst hot shorts. The shield conductor in a DC circuit is required to be connected to the DC negativepotential in order to protect the circuit against hot shorts.

IAttachment 1 to TXX-14070Page 6 of 7The wiring being protected in FDA-2010-000172-55 is part of the 125 VDC control circuit for breakers2EA1-1, 2EA1-2 and 2EG1. In these circuits the design instructs the ground conductor to be connected toAC ground.The connection to ground of the HSPC shield conductor has no impact to the functionality of the circuit.Deferral of 1RF17 FSSA Modifications1) MSO-10, 11 & 12FDA-2010-000172-63 / Single Spurious, Control Room Fire1-LCV-0112B, 1-LCV-0112C, 1-LCV-0112D and 1-LCV-0112EControl circuit rewiring and cable protection for four (4) motor-operated valvesField 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 FDAscope until the Unit 1 Spring 2016 refueling outage (1RF18).CR-2014-006528This CR is written to document a station decision to defer implementation of FDA-2010-000172-63from 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 toreplace 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 andthe 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 HotShutdown Panel. This will isolate the portions of the valve control circuit that are routed in theControl Room and Cable Spread Room;3. Re-configures the control circuit for 1-LCV-0112B and 1-LCV-0112D so that the valves complywith the guidance of NRC Information Notice IN 92-18; and 4. Modifies the design details tofacilitate 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 recentplant events led to late development of the design package. The work orders and test procedureshave not been completed resulting in a significant impact on producing quality, complete, andimpacted 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 factorsto assure final implementation meets all station requirements.2) MSO-55, Issue 3c, Phase IIIFDA-2010-000172-49 -Mechanical damage to pressure boundary for 1-8000B, 1-8110, 1-8111,1-8804B, 1-8812BControl circuit rewiring and cable protection for five (5) motor-operated valvesField 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 FDAscope until 1RF18. to TXX-14070Page 7 of 7CR-2014-006530This CR is written to document a station decision to defer implementation of FDA-2010-000172-49from 1RF17 until 1RF18. Corrective actions from recent plant events led to late development of thedesign package. The related test procedure development and work order planning commenced lateand could not support station outage milestones. Based on difficulties encountered in 2RF14 with theinstallation of FDA-2010-000172-47 (Unit 2 Train B RHR), it was not considered prudent to plan onmodifying both trains of RHR in the same outage. Since FDA-2010-000172-63 was being deferred to1RF18, the decision was made to defer one train of RHR until 1RF18. Since the pre-outage work iscomplete on the Unit 1 Train A RHR modification, the decision was made to defer the Unit 1 Train Bmodification to 1RF18. In addition, a preliminary review of 1RF18 showed that deferring the Unit 1Train B RHR modification would have the least impact on the critical path in 1RF18.

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