ML15173A094

LER 15-002-00 for Wolf Creek Regarding Two Control Room Air Conditioning Trains Inoperable Due to Failure to Meet Surveillance Requirement

ML15173A094
Person / Time
Site:	Docket Number
Issue date:	06/15/2015
From:	McCoy J H Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ET 15-0017 LER 15-002-00
Download: ML15173A094 (5)

Text

WeLF CREEK'NUCLEAR OPERATING CORPORATIONJamie H. McCoyVice President EngineeringJune 15, 2015ET 15-0017U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555

Subject:

Docket No. 50-482: Licensee Event Report 2015-002-00, "Two Control Room AirConditioning Trains Inoperable Due to Failure to Meet Surveillance Requirement"Gentlemen:The enclosed Licensee Event Report (LER) 2015-002-00 is being submitted pursuant to 10 CFR50.73(a)(2)(i)(B) as an operation or condition prohibited by Technical Specifications and 10 CFR50.73(a)(2)(v)(A) as an event or condition that could have prevented fulfillment of a safety functionneeded to shut down the reactor and maintain it in a safe shutdown condition.This letter contains no regulatory commitments. If you have any questions concerning this matter,please contact me at (620) 364-4156, or Mr. Steven R. Koenig at (620) 364-4041.Sincerely,Jamie H. McCoyJHM/rltEnclosurecc: M. L. Dapas (NRC), w/eC. F. Lyon (NRC), w/eA. A. Rosebrook (NRC), w/eSenior Resident Inspector (NRC), w/eP.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831An Equal Opportunity Employer M/F/HC/VET NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 0113112017(02-2014) Es1in-Ted burden pe respaise to=ply with this nwrlruaty leiion req 80 harm Reportedlessons learned ae inmqoratel into the licenng p ss and fed back to indusy. Sendowmfs regarding rrng ee eifnee to te F-OA Priv and Irlnmmb Cdlctiar. Bra-I CET(T-5 F53), U.S. Nudear Reguiatry Carnissim ihtgtor DC 20555-W01, or by interet e-ril.....P (LER) to ,rbcecl s, and to ft Desk ..sw, Offic, o irnon and guiralry(See Page 2 for required number of Ars, NEOe.102 (3150-0104), Ofie oManageno and Budget Vfthngbý DC2503. If a xme Used to inpse an irform.=eicn cdle ctkn does rn cislay a arrerity vAid CMBdigits/characters for each block) nrtr , the Nr may, nctt xi sponsor, and a perso is rct required to respond to,the infnTonollectior1. FACILITY NAME 2. DOCKET NUMBER 3. PAGEWOLF CREEK GENERATING STATION 05000 482 1 OF 44. TITLE Iwo ControI IRoom Air Conditioning I rains inoperaDle uue to i-allure to ieet Surveillance IRequirement5. EVENT DATE 6. LER NUMBER 7. REPORT DATE 8. OTHER FACILITIES INVOLVEDMONTH DAY YEAR YEAR SEQUENTIAL REV MONTHFACILITY NAME DOCKET NUMBERMOTH DA EA YA NUMBER NO. MOT A ER050004 16 2015 2015 -002 -00 06 15 2015 FACIL1YPVNAME OCCKE NUMBER050009. OPERATING MODE 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all thAt apply)[- 20.2201(b) [1 20.2203(a)(3)(i) [] 50.73(a)(2)(i)(C) [ 50.73(a)(2)(vii)5 [] 20.2201(d) El 20.2203(a)(3)(ii) E] 50.73(a)(2)(ii)(A) E] 50.73(a)(2)(viii)(A)[]20.2203(a)(1) [:] 20.2203(a)(4) [] 50.73(a)(2)(ii)(B) -- 50.73(a)(2)(viii)(B)[120.2203(a)(2)(i) [j 50.36(c)(1)(i)(A) [ 50.73(a)(2)(iii) -150.73(a)(2)(ix)(A)10. POWER LEVEL [120.2203(a)(2)(ii) [] 50.36(c)(1)(ii)(A) [150.73(a)(2)(iv)(A) [] 50.73(a)(2)(x)0 20.2203(a)(2)(iii) Eli 50.36(c)(2) [] 50.73(a)(2)(v)(A) []73.71 (a)(4)0[ 20.2203(a)(2)(iv) Ij 50.46(a)(3)(ii) E1 50.73(a)(2)(v)(S) [73.71(a)(5)Ej 20.2203(a)(2)(v) []50.73(a)(2)(i)(A) []50.73(a)(2)(v)(C) --IOTHERl 20.2203(a)(2)(vi) F'1 50.73(a)(2)(i)(B) 1 50.73(a)(2)(v)(D) Specify in Abstract below or inLJ U LiNRC Form 366A12. LICENSEE CONTACT FOR THIS LERFACILITY NAME TELEPHONE NUMBER (Include Area Code)Steven R. Koenig, Manager Regulatory Affairs 620-364-404113. COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORTMANU- iREPORTABLE MANU- REPORTABLECAUSE SYSTEM COMPONENT MACU RERTABLE CAUSE SYSTEM COMPONENT FACURER ETOBEFACTURER TO EPIX FACTURER TO EPIX14. SUPPLEMENTAL REPORT EXPECTED 15. EXPECTED MONTH DAY YEAR[] YES (If yes, complete 15. EXPECTED SUBMISSION DATE) E] NO SUBMISSION 8 26 2015DATEABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)From January 3, 2013, through August 13, 2013, the Conditions and Required Actions of limiting condition foroperation (LCO) LCO 3.7.11, LCO 3.0.3 and LCO 3.0.4 were not met.On April 16, 2015, an apparent cause evaluation on Condition Report (CR) 92274, "Application of TS SR3.0.1," identified the potential that the acceptance criteria in procedures STS PE-01OA/B, "Control Room A/CSystem Flow Rate Verification [A/B] Train," may not have been met when the acceptance criteria was revisedon January 3, 2013 from > 18,360 cfm and < 22,440 cfm to a new value of > 21,012 cfm. Review ofinformation determined that the prior performances of STS PE-010A/B did not meet the new acceptancecriteria. Additionally, procedure STS PE-010B was not performed until July 8, 2013 and procedure STS PE-010A was not performed until August 13, 2013.The apparent cause of this event is being evaluated and actions to prevent recurrence will be developed toaddress the apparent cause. This information will be provided in a supplement to this Licensee Event Report.NRC FORM 366 (02-2014)

NRC FORM 366A U.S. NLaEARREGULATORY COMMISSION APPROVED BY OMB: NO.3150-0104 EXPIRES: 01/31/2017(02-2014) Estimated burden per response to comply with this mandatory collection request: 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />.Reported lessons learned are inb the licensing process and fed badc to industry.Send comments regarding burden estimate to the FOIA, Pvacy and Information CollectionsBranch (T-5 F53), U.S. Nuclear Regulatory Commission, Washington DC 20555-0001, or by"...., LICENSEE EVENT REPORT (LER) internet e-mail to Infocollects.Resource@nrc.gov, and to the Desk Officer,Office of Inform ation and Regulatory Affairs, NEOB-10202, (3150-0104), Office of ManagemenlCONTINUATION SHEET and Budget, Washington, DC 20503. If a means used to impose an information collection doesnot display a currently valid OMB control number, the NRC may not conduct or sponsor, and aoerson is not reouired to resoond to, the information collection.1 .FACIU-rYNAIVE 2.DOCKET 6. LER NUMBER 3. PAGEYEAR SEQUENTIAL REVWOLF CREEK GENERATING STATION 05000NUMBER NO. 2 OF 42015 -002 00NARRATIVEPLANT CONDITIONS PRIOR TO THE EVENTMode 5The plant was in Refueling Outage 20 when this event was identified. At the time of identification, bothControl Room Air Conditioning System (CRACS) trains had successfully met the unit air flow capacity of> 21,012 cfm.DESCRIPTIONFrom January 3, 2013, through August 13, 2013, the Conditions and Required Actions of limiting conditionfor operation (LCO) LCO 3.7.11, LCO 3.0.3 and LCO 3.0.4 were not met.On April 16, 2015, an apparent cause evaluation on Condition Report (CR) 92274, "Application of TS SR3.0.1," identified the potential that the acceptance criteria in procedures STS PE-01 OAB, "Control RoomA/C System Flow Rate Verification [A/B] Train," may not have been met when the acceptance criteria wasrevised on January 3, 2013 from > 18,360 cfm and < 22,440 cfm to a new value of > 21,012 cfm.In December 1999, Wolf Creek Nuclear Operating Corporation (WCNOC) implemented licenseamendment number 123 that converted the current Technical Specifications to the improved TechnicalSpecifications. The amendment included new specification 3.7.11, "Control Room Air ConditioningSystem (CRACS)," and new surveillance requirement (SR) SR 3.7.11.1. SR 3.7.11.1 verifies that the heatremoval capability of the CRACS air conditioning units (SGK04A and SGK04B) [EIIS: VI, ACU] isadequate to remove the heat load assumed in the control room during design basis accidents. This SRconsists of verifying the heat removal capability of the condenser heat exchanger, ensuring the properoperation of major components in the refrigeration cycle, verification of unit air flow capacity, and waterflow measurement. Procedures STS PE-010A/B, "Control Room A/C System Flow Rate Verification [A/B]Train," were initially issued on December 18, 1999 for verification of unit air flow capacity. An acceptancecriteria of > 20,400 cfm was specified.Procedures STS PE-01 0A/B were revised on March 11, 2002 and changed the acceptance criteria from> 20,400 cfm to > 18,360 cfm and < 22,440 cfm. This revision was based on Performance ImprovementRequest (now referred to as Condition Report) 2001-3149 which determined that a +/- 10% flow ratespecified in ASME/ANSI N510-1980, "Testing of Nuclear Air-Cleaning Systems," could be utilized indetermining the acceptance criteria.On November 20, 2012, Condition Report (CR) 60099 identified that procedures STS PE-010A/B shouldbe revised to remove the +/- 10% flow rate based on concerns identified in CR 58535 on the use of the+/- 10% flow rate in procedures STS PE-016A/B, "[A/B] Train Class 1E Electrical System A/C Flow RateVerification." The Operability Screening Review for CR 60099 indicated that SGK04A and SGK04B wereoperable based on Operability Evaluation OE GK-12-017 which specified a minimum air flow rate of19,449 cfm (that excluded instrument uncertainty). Procedures STS PE-010A/B were revised onJanuary 3, 2013 and specified a new acceptance criteria of > 21,012 cfm.NRC FORM 366A (02-2014)

NRC FORM 366A LICENSEE EVENT REPORT (LER) U.S. NUCLEAR REGULATORY COMMISSION(02-2014)CONTINUATION SHEET1.FACILITY NAME 2. DOCKET 6. LER NUMBER 3.PAGEYEAR SEQUENTIAL REVWOLF CREEK GENERATING STATION 05000 482 NUMBER NO. 3 OF 42015 -002 -00NARRATIVEThe prior performances of STS PE-01OA/B did not meet the new acceptance criteria. Additionally,procedure STS PE-01OB was not performed until July 8, 2013 and procedure STS PE-01OA was notperformed until August 13, 2013. These performances met the new acceptance criteria. An adjustablesheave was installed in the 'B' CRACS train in July 2013 and in the 'A' CRACS train in March 2015.Technical Specification (TS) SR 3.0.1 specifies that SRs shall be met during the Modes of Applicabilityand that failure to meet a Surveillance, whether such failure is experienced during the performance of theSurveillance or between performance shall be a failure to meet the LCO. On January 3, 2013 with therevision of STS PE-01OA/B, LCO 3.7.11 should have been declared not met and the applicableConditions/Required Actions entered. Condition E of LCO 3.7.11 specifies to enter LCO 3.0.3 with twoCRACS trains inoperable in Modes 1, 2, 3, 4, 5, and 6 and during movement of irradiated fuelassemblies.The plant was in Mode 1 on January 3, 2013. Refueling Outage 19 was conducted from February 4,2013 through April 16, 2013. A forced outage occurred from May 6, 2013 through May 13, 2013. Assuch, the Conditions and Required Actions of LCO 3.7.11, LCO 3.0.3 and LCO 3.0.4 were not met.REPORTABI LITYThis event is reportable under 10 CFR 50.73(a)(2)(i)(B) as an operation or condition prohibited by TSswhen it was determined that the Conditions and Required Actions of LCO 3.7.11, LCO 3.0.3 and LCO3.0.4 were not met from January 3, 2013 through August 13, 2013.Additionally, this event is reportable under 10 CFR 50.73(a)(2)(v)(A) an event or condition that could haveprevented the fulfillment of the safety function of structures or systems that are needed to: (A) Shut downthe reactor and maintain it in a safe shutdown condition. Updated Safety Analysis Report (USAR) Section9.4.1.1.1 specifies that the control room air conditioning system is required to function following a designbasis accident and to achieve and maintain the plant in a post accident safe shutdown condition. FromJanuary 3, 2013 through July 8, 2013, two CRACS trains where inoperable when the acceptance criteriain procedures STS PE-01OA/B were not met resulting in a failure to meet SR 3.7.11.1. NUREG-1022,Rev. 3, "Event Report Guidelines 10 CFR 50.72 and 50.73," indicates that for systems, subsystems andcomponents within the scope of this criterion, a report is required when 1) there is a determination that theSSC is inoperable in a required mode or other specified condition in the TS Applicability, 2) theinoperability is due to one or more personnel errors, including procedure violations; equipment failures;inadequate maintenance; or design, analysis, fabrication, equipment qualification, construction, orprocedural deficiencies, and 3) no redundant equipment in the same system was operable.CAUSEThe apparent cause of this event is being evaluated and will be provided in a supplement to this LicenseeEvent Report (LER).CORRECTIVE ACTIONSActions to prevent recurrence are being developed to address the apparent cause and will be provided ina supplement to this LER.NRC FORM 366A (02-2014)

NRC FORM 366A LICENSEE EVENT REPORT (LER) U.S. NUCLEAR REGULATORY COMMISSION(02-2014)CONTINUATION SHEET1.FACILITY NAME 2.DOCKET 6. LER NUMBER 3.PAGESEQUENTIAL REVYEARWOLF CREEK GENERATING STATION 05000 482 NUMBER NO. 4 OF 42015 -002 -00NARRATIVESAFETY SIGNIFICANCEThe design basis of the CRACS is to maintain control room temperature for 30 days of continuousoccupancy. The CRACS components are arranged in redundant, safety related trains. During normal oremergency operations, the CRACS maintains the temperature </= 84 degrees F. Total system failurecould result in equipment operating temperatures exceeding limits in the event of the accident. Duringthe duration of this event, one CRACS train remained in operation with an air flow rate slightly less thanthe design specified flow rate. As such, the safety significance of this event is low.OPERATING EXPERIENCE/PREVIOUS EVENTSCondition Report 92274 identified an event where the 'A' CRACS train failed to meet the acceptancecriteria for procedure STS PE-010A. The 'A' CRACS train was not declared inoperable in accordancewith SR 3.0.1 when information obtained from an operability evaluation was used to justify that the trainwas operable but degraded.NRC FORM 366A (02-2014)