02-05-2016 | system train "B" in support of planned maintenance on the non-safety related train "A". The CREV train "B" did not start. Once the CREV train "B" system failed to start, the non-safety related train "A" was restarted. Proper operation of the CREV system and CREV air conditioning (NC) systems could not be ensured, so both CREV and CREV AC system were declared inoperable. As a result, Technical Specification (TS) 3.7.4, Condition A, and TS 3.7.5, Condition A were entered.
The cause of the CREV train "B" system failure to start was the differential pressure switch, which is installed in a vibration susceptible location on the ductwork. This differential pressure switch makes up the interlock between the CREV train "B" system and the non-safety related Control Room HVAC train "A". The differential pressure switch's normally open contacts had temporarily welded together not allowing the starting signal to be received by the CREV train "B" system.
Corrective actions included replacing the differential pressure switch. A future corrective action will relocate the differential pressure switch off of the ductwork to minimize the vibration effects.
The safety significance of this event was minimal. Given the impact on the CREV system, which is common to both units, this report is submitted (for Units 1 and 2) in accordance with the requirements of 10 CFR 50.73 (a)(2)(v)(D), which requires the reporting of any event or condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident. |
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Category:Letter
MONTHYEARIR 05000254/20230042024-02-0505 February 2024 Integrated Inspection Report 05000254/2023004 and 05000265/2023004 ML24004A0052024-01-17017 January 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0042 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) RS-24-001, Response to Request for Additional Information Regarding Relief Request I5R-26, Inservice Inspection Program Relief Request Regarding Examination Coverage for the Fifth Inservice Inspection Interval2024-01-0303 January 2024 Response to Request for Additional Information Regarding Relief Request I5R-26, Inservice Inspection Program Relief Request Regarding Examination Coverage for the Fifth Inservice Inspection Interval IR 05000254/20234032023-12-22022 December 2023 Public- Quad Cities Nuclear Power Station Security Baseline Inspection Report 05000254/2023403 and 05000265/2023403 IR 05000254/20230102023-12-20020 December 2023 Comprehensive Engineering Team Inspection Report 05000254/2023010 and 05000265/2023010 ML23349A1622023-12-17017 December 2023 Issuance of Amendment Nos. 298 and 294 Increase Completion Time in Technical Specification 3.8.1.B.4 (Emergency Circumstances) RS-23-128, Response to Request for Additional Information for the Emergency License Amendment Request Increase Technical Specifications Completion Time in TS 3.8.1.B.4 from 7 Days to 30 Days2023-12-15015 December 2023 Response to Request for Additional Information for the Emergency License Amendment Request Increase Technical Specifications Completion Time in TS 3.8.1.B.4 from 7 Days to 30 Days ML23305A1402023-12-13013 December 2023 Units 1 & 2; Nine Mile Point, Unit 2; Peach Bottom, Units 2 & 3; and Quad Cities, Units 1 and 2 - Issuance of Amendments to Adopt Traveler TSTF-580 RS-23-123, Emergency License Amendment Request - Increase Technical Specifications Completion Time in TS 3.8.1.B.4 from 7 Days to 30 Days2023-12-13013 December 2023 Emergency License Amendment Request - Increase Technical Specifications Completion Time in TS 3.8.1.B.4 from 7 Days to 30 Days ML23339A1762023-12-0505 December 2023 Notification of NRC Baseline Inspection and Request for Information (05000265/2024001) ML23319A3342023-11-20020 November 2023 Regulatory Audit in Support of License Amendment Requests to Adopt TSTF 505, Revision 2 and 10 CFR 50.69 RS-23-104, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-17017 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23317A1192023-11-10010 November 2023 Constellation Energy Generation, LLC - 2023 Annual Report - Guarantees of Payment of Deferred Premiums IR 05000254/20230032023-11-0909 November 2023 Integrated Inspection Report 05000254/2023003 and 05000265/2023003 RS-23-113, Submittal of Updated Final Safety Analysis Report (Ufsar), Revision 17 and Fire Protection Report (Fpr), Revision 262023-10-20020 October 2023 Submittal of Updated Final Safety Analysis Report (Ufsar), Revision 17 and Fire Protection Report (Fpr), Revision 26 RS-23-097, Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans2023-10-12012 October 2023 Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans ML23206A0382023-09-21021 September 2023 Proposed Alternative to the Requirements of the ASME Code IR 05000254/20230112023-09-20020 September 2023 Safety-Conscious Work Environment Issue of Concern Team Inspection Report 05000254/2023011 and 05000265/2023011 RS-23-089, Sixth Ten-Year Interval Inservice Testing Program2023-09-0505 September 2023 Sixth Ten-Year Interval Inservice Testing Program RS-23-080, Constellation Energy Generation, LLC, Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs2023-08-30030 August 2023 Constellation Energy Generation, LLC, Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs RS-23-086, Relief Request I5R-26, Inservice Inspection Program Relief Request Regarding Examination Coverage for the Fifth Inservice Inspection Interval2023-08-28028 August 2023 Relief Request I5R-26, Inservice Inspection Program Relief Request Regarding Examination Coverage for the Fifth Inservice Inspection Interval SVP-23-038, Owner'S Activity Report Submittal Fifth 10-Year Interval 2023 Refueling Outage Activities2023-08-14014 August 2023 Owner'S Activity Report Submittal Fifth 10-Year Interval 2023 Refueling Outage Activities IR 05000254/20230022023-08-0808 August 2023 Integrated Inspection Report 05000254/2023002 and 05000265/2023002 ML23178A0742023-08-0707 August 2023 Issuance of Amendment Nos. 296 and 292 Adoption of TSTF-416 Low Pressure Coolant Injection (LPCI) Valve Alignment Verification Note Location ML23216A0362023-08-0707 August 2023 Notification of an NRC Biennial Licensed Operator Requalification Program Inspection and RFI ML23216A0562023-08-0404 August 2023 Information Meeting (Open House) with a Question and Answer Session to Discuss NRC 2022 End-Of-Cycle Plant Performance Assessment of Quad Cities Nuclear Power Station, Units 1 and 2 SVP-23-031, Regulatory Commitment Change Summary Report2023-07-14014 July 2023 Regulatory Commitment Change Summary Report ML23181A1062023-06-30030 June 2023 Postponement- Information Meeting (Open House) with a Question-And-Answer Session to Discuss NRC 2022 End-Of-Cycle Plant Performance Assessment of Quad Cities Nuclear Power Station ML23178A2422023-06-28028 June 2023 Reassignment of the U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch III ML23179A1932023-06-28028 June 2023 07122023 Letter-Significant Public Meeting to Discuss NRC End-of-Cycle Performance Assessment of Quad Cities Nuclear Plant for Performance for 2022 Calendar Year IR 05000254/20234012023-06-26026 June 2023 Cyber Security Inspection Report 05000254/2023401 and 05000265/2023401 IR 05000265/20230402023-06-22022 June 2023 Reissue Quad Cities Nuclear Power Station 95001 Supplemental Inspection Supplemental Report 05000265/2023040 and Follow Up Assessment Letter RS-23-077, Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-06-16016 June 2023 Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations ML23167B1722023-06-16016 June 2023 95001 Supplemental Inspection Report 05000265/2023040 and Follow-Up Assessment Letter RS-23-060, Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors2023-06-0808 June 2023 Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors RS-23-059, License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2023-06-0808 June 2023 License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b ML23144A3632023-05-26026 May 2023 Information Meeting (Open House) with a Question and Answer Session to Discuss NRC 2022 End-of-Cycle Plant Performance Assessment of Quad Cities Nuclear Power Station, Units 1 and 2 RS-23-042, Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling2023-05-25025 May 2023 Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling ML23033A4042023-05-15015 May 2023 Exemption from the Requirements of 10 CFR Part 2, Section 2.109(B) Related to Submission of Subsequent License Renewal Application Letter IR 05000254/20234022023-05-15015 May 2023 Security Baseline and ISFSI Inspection Reports 05000254/2023402, 05000265/2023402, 07200053/2023401 ML23132A2022023-05-12012 May 2023 Annual Radiological Environmental Operating Report ML23125A0612023-05-0808 May 2023 Proposed Alternative to the Requirements of the ASME Code IR 05000254/20230012023-05-0808 May 2023 Integrated Report 05000254/2023001 and 05000265/2023001 RS-22-067, 10 CFR 50.46 Annual Report2023-05-0404 May 2023 10 CFR 50.46 Annual Report ML23118A3472023-05-0101 May 2023 County, 1 & 2; Nine Mile Point, 2; and Quad Cities, 1 & 2 - Correction of Amendment No. 193 Adoption of TSTF-306, Revision 2, Add Action to LCO 3.3.6.1 to Give Option to Isolate the Penetration EPID L-2022-LLA-0143 RS-23-068, Response to Request for Additional Information for Quad Cities Relief Request I6R-11, Proposed Alternatives for a Temper Bead Weld Repair of the Mating Surfaces of the Reactor Pressure Vessel Head and Shell2023-04-28028 April 2023 Response to Request for Additional Information for Quad Cities Relief Request I6R-11, Proposed Alternatives for a Temper Bead Weld Repair of the Mating Surfaces of the Reactor Pressure Vessel Head and Shell SVP-23-018, Radioactive Effluent Release Report for 20222023-04-28028 April 2023 Radioactive Effluent Release Report for 2022 ML23114A2522023-04-28028 April 2023 Request to Use a Provision of a Later Edition of the ASME Boiler & Pressure Vessel Code, Section XI ML23110A0622023-04-25025 April 2023 Transmittal of Final Quad Cities Nuclear Power Plant, Unit 1 Accident Sequence Precursor Report (Licensee Event Report 254-2022-001) ML23081A0382023-04-25025 April 2023 County, 1 & 2; Nine Mile Point, 2; and Quad Cities, 1 & 2 - Issuance of Amendments to Adopt TSTF-306, Rev. 2, Add Action to LCO 3.3.6.1 to Give Option to Isolate the Penetration 2024-02-05
[Table view] Category:Licensee Event Report (LER)
MONTHYEARSVP-22-072, Manual Scram Due to Feedwater Regulator Valve Failure Increasing Reactor Water Level2022-12-30030 December 2022 Manual Scram Due to Feedwater Regulator Valve Failure Increasing Reactor Water Level 05000254/LER-2017-0042018-01-0505 January 2018 Unit 1 HPCI Did Not Trip Due to Wear Debris in the Turbine Stop Valve Oil Resetting Solenoid, LER 17-004-00 For Quad Cities Nuclear Power Station, Unit 1 re: Unit 1 HPCI Did Not Trip Due to Wear Debris in the Turbine Stop Valve Oil Resetting Solenoid 05000254/LER-2017-0032017-11-17017 November 2017 Control Room Emergency Ventilation Air Conditioning Piping Refrigerant Leak Due to High Cycle Fatigue, LER 17-003-00 for Quad Cities, Unit 1, Regarding Control Room Emergency Ventilation Air Conditioning Piping Refrigerant Leak Due to High Cycle Fatigue 05000265/LER-2017-0012017-07-13013 July 2017 High Pressure Coolant Injection Minimum Flow Valve Failed to Open, LER 17-001-00 for Quad Cities, Unit 2, Regarding High Pressure Coolant Injection Minimum Flow Valve Failed to Open 05000254/LER-2017-0022017-05-26026 May 2017 Four Main Steam Isolation Valves (MSIVs) Closure Times Exceeded, LER 17-002-00 for Quad Cities, Unit 1, Regarding Four Main Steam Isolation Valves (MSIVs) Closure Times Exceeded 05000254/LER-2017-0012017-03-22022 March 2017 Secondary Containment Interlock Doors Opened Simultaneously, LER 17-001-00 for Quad Cities, Unit 1, Regarding Secondary Containment Interlock Doors Opened Simultaneously 05000265/LER-2016-0022016-06-24024 June 2016 High Pressure Coolant Injection System Declared Inoperable Due to Valve Packing Leak, LER 16-002-00 for Quad Cities Nuclear Power Station Unit 2 - RE: High Pressure Coolant Injection System Declared Inoperable Due to Valve Packing Leak 05000265/LER-2016-0012016-05-19019 May 2016 Main Steam Isolation Valve Local Leak Rate Tests Exceed Technical Specification Limits, LER 2016-001-00 for Quad Cities Nuclear Power Station, Unit 2 Regarding Main Steam Isolation Valve Local Leak Rate Tests Exceed Technical Specification Limits 05000254/LER-2016-0022016-03-14014 March 2016 Secondary Containment Differential Pressure Momentarily Lost Due to Air Line Failure (RWCU Pump Rm), LER 16-002-00 for Quad Cities Units 1 and 2, Regarding Secondary Containment Different Pressure Momentarily Lost due to Air Failure (RWCU pump Rm) 05000254/LER-2016-0012016-03-10010 March 2016 Secondary Containment Differential Pressure Momentarily Lost Due to Air Line Failure (RWCU Hx Rm), LER 16-001-00 for Quad Cities, Unit 1, Regarding Secondary Containment Differential Pressure Momentarily Lost Due to Air Line Failure (RWCU Hx Rm) 05000254/LER-2015-0102016-02-0505 February 2016 Loss of Control Room Emergency Ventilation System Due to Differential Pressure Switch Failure, LER 15-010-00 for Quad Cities, Unit 1, Regarding Loss of Control Room Emergency Ventilation System Due to Differential Pressure Switch Failure SVP-03-036, LER 03-S01-00, Security Event Report for Quad Cities, Unescorted Protected Area Access Granted Based on Falsified Information and Inadequate Screening Caused by a Failure of Administrative Controls.2003-03-0303 March 2003 LER 03-S01-00, Security Event Report for Quad Cities, Unescorted Protected Area Access Granted Based on Falsified Information and Inadequate Screening Caused by a Failure of Administrative Controls. ML17252B4771976-09-15015 September 1976 LER 76-059-00 for Dresden, Units 2 and 3 Re Review of Quad-Cities Unusual Event Letter Led to Discovery That Dresden'S Standby Gas Treatment System Deviated from Single Failure Criteria That Disabled the SBGT System ML18348A2401976-08-0606 August 1976 LER 1976-027-00, Reportable Occurrence of Control Rods for Quad-Cities, Unit 1 ML18348A2391976-08-0404 August 1976 LER 1976-026-00, Reportable Occurrence of Control Rods for Quad-Cities, Unit 1 2022-12-30
[Table view] |
PLANT AND SYSTEM IDENTIFICATION
General Electric - Boiling Water Reactor, 2957 Megawatts Thermal Rated Core Power Energy Industry Identification System (EIIS) codes are identified in the text as [XX].
EVENT IDENTIFICATION
The Control Room Emergency Ventilation (CREV) system failed to start due to a failed differential pressure switch.
A. CONDITION PRIOR TO EVENT
Unit: 1 / 2 Event Date: December 7, 2015 Event Time: 0825 hours0.00955 days <br />0.229 hours <br />0.00136 weeks <br />3.139125e-4 months <br /> Reactor Mode: 1 / 1 Mode Name: Power Operation / Power Operation Power Level: 100% / 100%
B. DESCRIPTION OF EVENT
On December 7, 2015, at 0825 hours0.00955 days <br />0.229 hours <br />0.00136 weeks <br />3.139125e-4 months <br />, Operations attempted to start the safety related Control Room Emergency Ventilation (CREV) [VI] system train "B" in support of planned maintenance on the non-safety related train "A". The CREV train "B" did not start. Once the CREV train "B" system failed to start, the non-safety related train "A" was restarted. Proper operation of the CREV train "B" system and CREV train "B" air conditioning (NC) system could not be ensured, so both CREV and CREV AC system were declared inoperable. As a result, Technical Specification 3.7.4, Condition A, and Technical Specification 3.7.5, Condition A were entered.
On December 7, 2015, at 1402 hours0.0162 days <br />0.389 hours <br />0.00232 weeks <br />5.33461e-4 months <br />, ENS #51589 was made to the NRC under 10 CFR 50.72(b)(3)(v)(D) to report this event as an event or condition that could have prevented the fulfillment of the safety function.
Operations restarted the Train "A" Control Room HVAC system and began troubleshooting. Differential Pressure Switch [PDS] 0-5795-50 and Relay [RLY] 0-9400-105-CR5ISO were replaced and sent to Powerlabs for further analysis. On December 8, 2015, at 2201 hours0.0255 days <br />0.611 hours <br />0.00364 weeks <br />8.374805e-4 months <br />, Operations successfully completed the Post Maintenance Testing on the CREV and CREV AC Systems and exited TS 3.7.4, Condition A and TS 3.7.5 Condition A.
Given the impact on the CREV system, which is common to both Units, this report is submitted (for Units 1 and 2) in accordance with the requirements of 10 CFR 50.73 (a)(2)(v)(D), which requires the reporting of any event or condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident.
C. CAUSE OF EVENT
The apparent cause for the CREV train "B" system failure to start was identified as the differential pressure switch, which is installed on a vibration susceptible location of the ductwork [DUCT]. This differential pressure switch makes up the interlock between the CREV train "B" system and the non-safety related Control Room HVAC train "A". The differential pressure switch was susceptible to vibrations and was installed on the air handling unit ductwork. These vibrations caused the differential pressure switch's normally open contacts to temporarily weld together, which did not allow the CREV train "B" system to automatically start or manually start either locally or remotely.
D. SAFETY ANALYSIS
System Design Habitability systems are provided to ensure that control room operators are able to remain in the Main Control Room (MCR) [NA] and operate the plant safely under normal conditions and to maintain the plant in a safe condition under accident conditions. The worst-case design basis accident (DBA) for habitability considerations is postulated as a loss of coolant accident (LOCA) with main steam [SB] isolation valve [ISV] leakage at TS limits.
Per Updated Final Safety Analysis Report (UFSAR) Section 6.4.2, the Control Room HVAC systems are capable of maintaining the control room atmosphere suitable for occupancy throughout the duration of a DBA. The HVAC systems are capable of both automatic and manual transfer from the normal operating mode to the isolation mode.
Transfer of the Control Room HVAC systems to the emergency (pressurization) mode of operation is not a fully automatic operation, since some Control Room HVAC system components must be manually started to operate the Control Room HVAC systems in the emergency (pressurization) mode. The manual actions required when placing the Control Room HVAC system into the pressurization mode following an accident include: (1) starting the refrigeration compressor unit; and (2) starting one Air Filtration Unit (AFU) booster fan.
Per UFSAR Section 6.4.2.1, the Control Room Emergency Zone (Control Room Envelope) is defined as the following areas: the main control room, the cable spreading room, the auxiliary electrical equipment room, which surrounds the old computer room; and the Train "B" HVAC equipment room. The Control Room Envelope boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the Control Room Envelope. The operability of the Control Room Envelope boundary must be maintained to ensure that the in-leakage of unfiltered air into the Control Room Envelope will not exceed the in-leakage assumed in the DBA analysis for the main control room occupants.
UFSAR Section 6.4.2.4 provides that potential adverse interactions between the Control Room Emergency Zone and adjacent zones that may allow the transfer of toxic or radioactive gases into the control room are minimized by maintaining the control room at a slightly positive pressure with respect to adjacent areas during normal conditions.
Safety Impact The primary purpose of the CREV train "B" system is to provide a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals or smoke. The CREV function was restored when the differential pressure switch was replaced and the CREV system ran when called upon. Since the differential pressure switch had failed and one of its functions is to allow the CREV train "B" system to operate, a safety system functional failure occurred.
Per TS Bases 3.7.4, the CREV train "B" system is considered operable when the train "B" air handling unit is operable along with the AFU and the outside air ventilation intake. Since the train "B" Control Room HVAC system would not start, the system was inoperable and TS 3.7.4 Condition A was entered.
Per TS Bases 3.7.5, the CREV AC system is considered operable when the individual components necessary to maintain the Control Room Emergency Zone temperature are operable. The CREV train "B" air handling unit is necessary to deliver the conditioned air to the Control Room Emergency Zone. Since the train "B" CREV system would not start to all the condition air to be delivered, the CREV AC system was inoperable and TS 3.7.5 Condition A was entered.
Risk Insights The plant Probabilistic Risk Assessment (PRA) model gives no credit to the Control Room Envelope (CRE) and does not include it in the model; hence, the CREV train "B" Fan failing to operate did not contribute to an increase in risk.
In conclusion, the overall safety significance and impact on risk of this event were minimal.
E. CORRECTIVE ACTIONS
Immediate:
The differential pressure switch was replaced.
Follow-up:
The differential pressure switch will be relocated to a non-vibration susceptible area. The failed switch had been in service for 5 years with no issues prior to the failure.
F. PREVIOUS OCCURRENCES
The station events database, LERs, and INPO Consolidated Event System (ICES) were reviewed for similar events at the Quad Cities Nuclear Power Station. This event was attributed to incorrect installation location of the differential pressure switch. Based on the cause of this event and the associated corrective actions, the events listed below, although similar in topic, are not considered significant station experiences that would have directly contributed to preventing this event.
- Station Issue Report (IR) 01067025, "0-9400-105 A-3 Invalid Alarm AFU Post HEPA Filter DP Hi," (05/08/2010) — the local panel for the B Train of Control Room HVAC had tile A-3 lit on panel 0-9400-105 for "AFU Post HEPA Filter DP Hi." The alarm was present when the B Train of Control Room HVAC was not running and differential pressure indication switch DPIS 0-5795-311 was reading 0 inches of water column. The cause of the alarm was a degraded differential pressure indication switch, which was replaced. This previous event, although similar to this LER event was caused by a different failure mode. Both switches were manufactured by the same vendor, but DPIS 0-5795-311 was installed at a location free from excessive vibrations. This is not considered a significant station experience that would have directly contributed to preventing the event of this current LER based on the different failure modes.
- LER 254/2007-003-00, 01/18/08, Safety Function Not Met Due to Control Room Emergency Ventilation System Air Filtration Unit Heater Flow Switch Failure (11/20/07) — Operation's surveillances determined that the CREV Air Filtration Unit (AFU) heaters were not operating as required. Troubleshooting of the AFU heater found that a flow switch had an open contact that was preventing the heater from energizing as required. The previous event was caused by infant mortality of the flow switch, whereas this current LER was caused by improper mounting location of the differential pressure switch.
G. COMPONENT FAILURE DATA
Failed Equipment: Control Room HVAC Differential Pressure Switch (DPS 0-5795-50) Component Manufacturer: Dwyer Instrument Inc.
Component Model Number: 1910-1 Component Part Number: N/A This event has been reported to ICES as Failure Report No. 320582