05000321/LER-2017-001, Regarding Unanalyzed Conditions for a Postulated Fire Discovered During NFPA 805 Transition
| ML17093A892 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 04/03/2017 |
| From: | Vineyard D Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-17-0521 LER 17-001-00 | |
| Download: ML17093A892 (8) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 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), System Actuation 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i) |
| 3212017001R00 - NRC Website | |
text
David R. Vineyard Hatch Nuclear Plant
.A Southern Nuclear VIce President-Plant Halch 11028 Hatch Parkway North Baxley, GA 31513 April3, 2017 Docket Nos.: 50-321 50-366 U.S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant Unit 1 & 2 Licensee Event Reoort 2017-001-0 912 537 5859 lei 912 366 20n lax NL-17-0521 Unanalyzed Conditions for a Postulated Fire Discovered During NFPA 805 Transition Ladies and Gentlemen:
In accordance with the requirements of 10 CFR 50.73(a)(2)(ii)(B), Southern Nuclear Operating Company (SNC) hereby submits the enclosed Licensee Event Report.
This letter contains no NRC commitments. If you have any questions, please contact Greg Johnson at (912) 537-587 4.
Respectfully submitted, David A. Vineyard Vice President-Hatch DRV/jcb Enclosure: LEA 2017-001-0
U. S. Nuclear Regulatory Commission NL-17-0521 Page2 cc:
Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bast, Executive Vice President & Chief Nuclear Officer Mr. D. R. Vineyard, Vice President-Hatch Mr. M. D. Meier, Vice President-Regulatory Affairs Mr. R. D. Gayheart, Fleet Operations General Manager Mr. B. J. Adams, Vice President-Engineering Mr. G. L. Johnson, Regulatory Affairs Manager-Hatch RTYPE: CHA02.004 U.S. Nuclear Regulatory Commission Ms. C. Haney, Regional Administrator Mr. R. Hall, NRR Project Manager-Hatch Mr. D. H. Hardage, Senior Resident Inspector-Hatch
Edwin I. Hatch Nuclear Plant Unit 1 and 2 LER 2017-001-0 Unanalyzed Conditions for a Postulated Fire Discovered During NFPA 805 Transition
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 1013112018 (CJ6.2016)
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 />.
,.-.lf,j X
LICENSEE EVENT REPORT (LER)
Reported lessons teamed are incorporated into the licensing process and fed back to industry.
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Send comments regarding burden estimate to the FOIA, Privacy and Information Collections (See Page 2 for required number of digits/characters for each block)
Branch {T -5 F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e-mail to lnfocollects.Resource@nrc.gov, and to the Desk Officer, Office of lnfonmation and Regulatory (See NUREG-1 022, R.3 for instruction and guidance for completing this form Affairs, NEOB-10202, {3150-0104), Office of Management and Budget, Washington, DC 20503.1f a means used to impose an infonmation collection does not display a currently valid OMB control http://www.nrc.govlreadinq-rmldocxollectionslnureaslstafflsr1 022/r3D number, the NRC may not conduct or sponsor, and a person is not required to respond to, the
.PAGE Edwin I. Hatch Nuclear Plant Unit 1 05000321 1 OF4
- 4. TITLE Unanalyzed Conditions for a Postulated Fire Discovered During NFPA 805 Transition
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR I SEQUENTIAL I REV NUMBER NO.
MONTH FACILITY NAME
~OCKET NUMBER DAY YEAR Edwin I. Hatch Nuclear Plant Unit 2 5000366 FACILITY NAME DOCKET NUMBER 02 03 2017 2017
- - 001
- - 0 04 03 2017
- 9. OPERA liNG MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply) 1 D 20.2201(b)
D 20.2203(a)(3)(i) 0 50.73(a)(2)(ii)(A)
D 50.73(a)(2)(viii)(A)
D 20.2201 (d)
D 20.2203(a)(3)(ii)
~ 50.73(a)(2)(ii)(B)
D 50.73(a)(2)(viii)(B)
D 20.2203(a)(1 )
D 20.2203(a)(4)
D 50.73(a)(2)(iii)
D 50.73(a)(2)(ix)(A)
D 20.2203(a)(2)(i) 0 50.36(c)(1)(i)(A)
D 50.73(a)(2)(iv)(A)
D 50.73(a)(2)(x)
- 10. POWER LEVEL D 20.2203(a)(2)(ii) 0 50.36(c)(1)(ii)(A)
D 50.73(a)(2)(v)(A)
D 73.71(a)(4)
D 20.2203(a)(2)(iii)
D 50.36(c)(2)
D 50.73(a)(2)(v)(B)
D 73.71(a)(5) 100 D 20.2203(a)(2)(iv)
D 50.46(a)(3)(ii)
D 50.73(a)(2)(v)(C)
D 73.77(a)(1)
D 20.2203(a)(2)(v) 0 50.73(a)(2)(i)(A)
D 50.73(a)(2)(v)(D)
D 73.77(a)(2)(i)
D 20.2203(a)(2)(vi) 0 50.73(a)(2)(i)(B)
D 50.73(a)(2)(vii)
D 73.77(a)(2)(ii) 0 50.73(a)(2)(i)(C) 00THER Specify in Abstract below or in NRC Form 366A
- 12. LICENSEE CONTACT FOR THIS LER LICENSEE CONTACT l
ELEPHONE NUMBER (Include Area Code)
Edwin I. Hatch I Jimmy Collins-Licensing Supervisor 912-537-2342
- 13. COMPLETE ONE UNE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT
CAUSE
SYSTEM COMPONENT MANU-REPORTABLE
CAUSE
SYSTEM COMPONENT MANU-REPORTABLE FACTURER TOEPIX FACTURER TOEPIX 8
FA CBL N/A y
- 14. SUPPLEMENTAL REPORT EXPECTED
- 15. EXPECTED MONTH DAY YEAR 0 YES (If yes, complete 15. EXPECTED SUBMISSION DATE)
~NO SUBMISSION DATE
~BSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)
On February 3, 2017, in preparation for transitioning the Plant Hatch Fire Protection Licensing Basis from 10 CFR 50.48(b)
(Appendix R) to 10 CFR 50.48(c) (NFPA 805), a weak-link and operator manual action (OMA) analysis was completed for Information Notice (IN) 92-18 type hot shorts on motor operated valves (MOVs). Examination of the current Plant Hatch Appendix R Safe Shutdown Analysis identified circuit configurations in multiple Fire Areas where an Appendix R postulated fire could impact the ability to achieve safe shutdown conditions. The cable impacts can bypass the limit and torque switches and could result in physical damage to the valves, preventing the valves from being operated from the main control room, remote shutdown panel, or locally. Hourly fire watches had already been established for the affected fire areas and Fire Action Statements were initiated to address the postulated condition for the identified MOVs.
While these impairments represent unanalyzed conditions for Appendix R, the described scenarios are only possible given a fire has occurred in the associated Fire Areas. Plant Hatch issued a letter of intent to the NRC on October 4, 2013 to begin transition to NFPA 805 with a license amendment request (LAR) submittal date of April4, 2018. Any identified noncompliances will be resolved during the transition process.
NRC FORM 366 (CJ6.2016)
U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150*0104 EXPIRES: 10/31/2018
PLANT AND SYSTEM IDENTIFICATION
General Electric-Boiling Water Reactor Energy Industry Identification System codes appear in the text as (EllS Code XX)
DESCRIPTION OF EVENT
On February 3, 2017 at approximately 1458 EST, with Unit 1 at approximately 1 00 percent rated thermal power and Unit 2 at approximately 88.4 percent rated thermal power, in preparation for transitioning the Plant Hatch Fire Protection Licensing Basis from 10 CFR 50.48(b) (Appendix R) to 10 CFR 50.48(c) (NFPA 805), a weak-link and operator manual action (OMA) analysis was completed for Information Notice (IN) 92-18 type hot shorts on motor operated valves (MOVs) to support the Plant Hatch Appendix R Safe Shutdown Analysis. This updated analysis iden@ed circuit configurations in multiple Fire Areas where an Appendix R postulated fire could impact the ability to achieve safe shutdown conditions. The cable impacts can bypass the limit and torque switches and could result in physical damage to the valves, preventing the valves from being operated from the main control room, remote shutdown panel, or locally. This postulated event was identified in Fire Areas 0024 (Main Control Room), 1203F (Unit 1 Reactor Building), 1205F (Unit 1 Reactor Building), 2203F (Unit 2 Reactor Building) for the associated valves below:
1 E11-F003B; RHR Heat Exchanger B Discharge MOV 1 E11-F004B; RHR Pump E11 C002B Torus Suction MOV 1E11-F006B; RHR Pump 18 SDC Suction MOV 1 E11-F007B; RHR Pumps B and D Minimum Flow Bypass MOV 1 E11-F011 B; RHR Heat Exchanger B Drain To Suppression Pool MOV 1 E11-F015B; RHR LPCIInboard Discharge MOV 1 E11-F016B; Containment Spray Outboard Isolation MOV 1 E11-F017B; RHR LPCI Outboard Discharge MOV 1 E11-F028B; Torus Spray/AHA Test Line Outboard Isolation MOV 1 E11-F047B; RHR Heat Exchanger B Inlet MOV 1 E11-F048B; RHR Heat Exchanger B Bypass MOV 1 E11-F049; RHR to Radwaste Discharge Isolation MOV 1 E11-F068B; RHR Heat Exchanger B Service Water Flow Control MOV 1 E11-F073B; RHR Service Water to RHR Cross-tie MOV 1 E11-F1 04B; RHR Heat Exchanger B Vent MOV 1 E51-F007; RCIC Steam Supply Inboard Isolation MOV 1 E51-F008; RCIC Steam Supply Outboard Isolation MOV 1 E51-F012; RCIC Pump Outboard Discharge MOV 1 E51-F013; RCIC Pump Inboard Discharge MOV 1 E51-F019; RCIC Minimum Flow Bypass to Suppression Pool MOV 1 E51-F022; RCIC Pump Test Bypass Valve to Condensate Storage Tank MOV 1 E51-F045; RCIC Turbine Steam Supply MOV 1 E51-F046; RCIC Barometric Condenser and Lube Oil Cooler Cooling Water Supply MOV 1 E51-F524; RCIC Turbine Trip and Throttle MOV 2E11-F003B; RHR Heat Exchanger B Discharge MOV 2E11-F004B; RHR Pump 2B Torus Suction MOV 2E11-F006B; RHR Pump 2B SDC Suction MOV Page 2 of 4 (06-2016)
U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150*0104 EXPIRES: 10/31/2018 1¥~
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LICENSEE EVENT REPORT (LER)
CONTINUATION SHEET (See NUREG-1 022, R.3 for instruction and guidance for completing this form http://www.nrc.gov/reading-rm/doc-collectionslnuregs/staff/sr1022/r31)
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 incorporated into the licensing process and fed back to industry.
Send comments regarding burden estimate to the FOtA, Privacy and lnfonnation Collections Branch (T-5 F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e-mail to lnfocollects.Resource@nrc.gov, and to the Desk Officer, Office ol lnfonnation and Regulatory Affairs, NEOB-10202, (3150*0104), Office of Management and Budget, Washington, DC 20503. If a means used to impose an infonnation collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the infonnation collection.
- 3. LER NUMBER Edwin I. Hatch Nuclear Plant Unit 1 05000-321 YEAR I SEQUENTIAL I
REV NUMBER NO.
2E11-F007B; RHR Pumps 2B and 2D Minimum Flow Bypass MOV 2E11-F011 B; RHR Heat Exchanger B Drain To Suppression Pool MOV 2E11-F015B; RHR LPCIInboard Discharge MOV 2E11-F016B; Containment Spray Outboard Isolation MOV 2E11-F017B; RHR LPCI Outboard Discharge MOV 2E11-F028B; Torus Spray/RHR Test Line Outboard Isolation MOV 2E11-F047B; RHR Heat Exchanger B Inlet MOV 2E11-F048B; RHR Heat Exchanger B Bypass Valve (MOV) 2E11-F049; RHR to Radwaste Isolation MOV 2E11-F068B; RHR Heat Exchanger B Service Water Flow Control MOV 2E11-F073B; RHR Service Water to RHR Cross-tie MOV 2E11-F1 04B; RHR Heat Exchanger B Vent MOV 2E51-F007; RCIC Steam Supply Inboard Isolation MOV 2E51-F008; RCIC Steam Supply Outboard Isolation MOV 2E51-F010; RCIC Pump Suction Valve From Condensate Storage Tank MOV 2E51-F012; RCIC Pump Outboard Discharge MOV 2E51-F013; RCIC Pump Inboard Discharge MOV 2E51-F019; RCIC Minimum Flow Bypass to Suppression Pool MOV 2E51-F022; RCIC Pump Test Bypass Valve to Condensate Storage Tank MOV 2E51-F029; RCIC Pump Suction Valve From Suppression Pool MOV 2E51-F031; RCIC Pump Suction From Suppression Pool Outboard Isolation MOV 2E51-F045; RCIC Turbine Steam Supply MOV 2017 2E51-F046; RCIC Barometric Condenser and Lube Oil Cooler Cooling Water Supply MOV 2E51-F524; RCIC Turbine Trip and Throttle MOV
CAUSE OF EVENT
- - 001 The postulated event was identified as part of a weak-link and OMA analysis for IN 92-18 type hot shorts. This review is being conducted as part of the Hatch transition activities from Appendix R to NFPA 805.
REPORT ABILITY ANALYSIS AND SAFETY ASSESSMENT The event is reportable per 10 CFR 50.73(a)(2)(ii)(B) as the identified circuit configurations represents unanalyzed conditions that significantly degrades plant safety due to the potential to compromise safe shutdown during a postulated fire event.
- - 0 The presence of the compensatory measures, in addition to portable fire protection equipment and installed fire protection and detection equipment, ensures the safe shutdown paths are preserved until the conditions are resolved.
These are postulated events which did not affect the safe operation of the plant, or the health and safety of the public.
Based on this information, this event is considered to have very low safety significance.
CORRECTIVE ACTIONS
Hourly fire watches had already been established for the affected fire areas as part of previously established compensatory measures to preserve safe shutdown paths. Fire Action Statements were initiated to address the postulated condition for the identified MOVs. Plant Hatch issued a letter of intent to the NRC on October 4, 2013 to begin transition to NFPA 805 with a license amendment request(LAR) submittal date of April4, 2018. Any identified Page 3 of 4 (06-2016)
U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150*0104 EXPIRES: 10/31/2018
!¥ '
'-:.... /
LICENSEE EVENT REPORT (LER)
CONTINUATION SHEET (See NUREG-1 022, R.3 for instruction and guidance for completing this fonn http://www.nrc.gov/reading-rm/doc-collectionslnureaslstaff/sr1022/r31)
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 incorporated into the licensing process and fed back to industry.
Send comments regarding burden estimate to the FOIA, Privacy and lnfonnation Collections Branch (T-5 F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e-mail to lnfocollects.Resource@nrc.gov, and to the Desk Officer, OHice of lnfonnation and Regulatory Affairs, NEOB-10202. (3150-0104), Office of Management and Budget, Washington, DC 20503. If a means used to impose an infonnation collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the infonnation collection.
Edwin I. Hatch Nuclear Plant Unit 1 05000-321 noncompliances will be resolved during the trans~ion process.
ADDITIONAL INFORMATION
Other Systems Affected: None
Failed Components Information
Master Parts List Number: N/A (cables in systems E11, E51)
Raceway)
Manufacturer Code: N/A Model Number: N/A Type: Cables YEAR I 2017
- 3. LEA NUMBER SEQUENTIAL NUMBER
- 001 EllS System Code: FA (Cable Reportable to EPIX: Yes Root Cause Code: B EllS Component Code: CBL Comm~ment Information: This report does not create any new licensing comm~ments.
PREVIOUS SIMILAR EVENTS
LEA 2015-001-01 On June 4, 2015, in preparation for trans~ioning the Plant Hatch Fire Protection Licensing Basis from 10 CFR 50.48(b) (Appendix R) to 10 CFR50.48(c) (NFPA 805), an update to the Plant Hatch Appendix R Safe Shutdown Analysis (SSA) was being performed for the Unit 1 and Un~ 2 Reactor Buildings, Turbine Buildings, and Diesel Generator Building. This updated analysis identified circuit configurations in several Fire Areas where an Appendix R postulated fire could impact the abil~ to achieve safe shutdown cond~ions. These are Category 1 barrier impairments. Compensatory measures were established for the affected fire areas to preserve a safe shutdown (SSD) path.
I REV NO.
- - 0 Page 4 of 4
Licensing Action, Concurrence, and Verification NMP-AD-043-FO 1 SNC Version 2.0 UnitS P.age 1 of 5 Letter Number: NL-17-0521 tJ~4L Bot?
Due Date (If applicable): Clicl~ are o enter a date.
Subject:
Unanal~zed Conditions for a Postulated Fire Discovered During NFPA 805 Transition Rl/ Extension:
JaNa~e Baile~ I x3722 CA/TE (if applicable) I Database (C/F/HIV):
CRsl0326399, 10326401,10326402, 10326404,and 10326405 Executive Summary:
In gregaration tor transitioning the Plant Hatch Fire Protection licensing basis from Aggendix R to NFPA 805, a weak-link and ogerator manual action anal:isis was comgleted tor Information Notice 92-18 tyge hot shorts on motor ogerator valves (MOVs}. Examination of the current Plant Hatch Aggendix R Safe Shutdown Anal~sis identified circuit configurations in multigle Fire Areas where an Aggendix A gostulated fire could imgact the abilit:i to achieve safe shutdown conditions. Hourl:i fire watches had alread:i been established for the affected fire areas as gart of greviousl:i established comgensato!:Y measures to greserve safe shutdown gaths and Fire Action Statements were initiated to address the gostulated condition for the identified MOVs.
SECTION 1-CORRESPONDENCE SCREENING (to be completed by Rl)
YES NO 1.1.
Does this letter affect the FSAR or any other License Basis Documents? If YES, complete 1.1.a. If unsure, obtain peer review from 10 CFR 50.59 r
P' qualified individual.
- 1.1.a HasSection IV been completed to update each document?
rl YES rl NO 1.2.
Does this Jetter require posting per 1 o CFR 19? If YES, ensure posting after r
P' submittal.
1.3.
Does this letter contain Safeguards Information? If YES, do NOT scan to SNC Intranet. Enter Special Handling Instructions below and review with the RA r
P' Administrative Assistant (AA).
1.4.
Does this letter contain information to be withheld from public disclosure (for example, Proprietary or Non-Safeguards Security-Related Information)? If r
rv YES, do NOT scan to SNC Intranet. If Proprietary, include appropriate affidavit.
Enter Special Handling Instructions below and review with the AA.
1.5.
Does this letter contain sensitive, limited access or distribution items? If YES, r
P' enter Special Handling Instructions below and review with the AA.
Special Handling Instructions for AA N/A N/A Administrative Assistant Date 1.6.
Oath or Affirmation Required? If YES, ensure proper letter template is used.
r P'
1.7.
Verification Required? If YES, use the guidance of NMP-AD-043.
p r
1.8.
External Affairs and General Counsel Consultation Required? If YES, obtain r
p concurrence signature in Section II.
Printed 03/27/2017 at 08:37:00