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MONTHYEARL-MT-13-038, MNGPs Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident2013-04-29029 April 2013 MNGPs Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident Project stage: Response to RAI L-MT-13-088, Request Commitment Change for Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.1 of the Nearterm Task Force Review of Insights from the Fukushima Dai-ichi Accident2013-09-12012 September 2013 Request Commitment Change for Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.1 of the Nearterm Task Force Review of Insights from the Fukushima Dai-ichi Accident Project stage: Response to RAI 05000263/LER-2013-008-01, Regarding Both Secondary Containment Access Doors Briefly Opened Simultaneously2014-03-12012 March 2014 Regarding Both Secondary Containment Access Doors Briefly Opened Simultaneously Project stage: Request L-MT-14-027, Request Commitment Change for Response to NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(D Regarding the Seismic Aspects of Recommendation 2.1 of the Near-Term Task Force Review of Insights from2014-03-31031 March 2014 Request Commitment Change for Response to NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(D Regarding the Seismic Aspects of Recommendation 2.1 of the Near-Term Task Force Review of Insights from Project stage: Request ML14136A2892014-05-12012 May 2014 14C4229-RPT-001, Revision 3, Monticello Nuclear Generating Plant Seismic Hazard and Screening Report Project stage: Request L-MT-14-093, Expedited Seismic Evaluation Process (ESEP) - Augmented Approach to Post-Fukushima Near-Term Task Force (NTTF) 2.12014-12-23023 December 2014 Expedited Seismic Evaluation Process (ESEP) - Augmented Approach to Post-Fukushima Near-Term Task Force (NTTF) 2.1 Project stage: Request L-MT-15-030, Expedited Seismic Evaluation Process (ESEP) - Augmented Approach to Post-Fukushima Near-Term Task Force (NTTF) 2.1 - Response to Requests for Additional Information2015-05-22022 May 2015 Expedited Seismic Evaluation Process (ESEP) - Augmented Approach to Post-Fukushima Near-Term Task Force (NTTF) 2.1 - Response to Requests for Additional Information Project stage: Response to RAI L-MT-15-060, Expedited Seismic Evaluation Process (ESEP) - Augmented Approach to Post-Fukushima Near-Term Task Force (NTTF) 2.1 - Clarification of Response to Request for Additional Information2015-08-13013 August 2015 Expedited Seismic Evaluation Process (ESEP) - Augmented Approach to Post-Fukushima Near-Term Task Force (NTTF) 2.1 - Clarification of Response to Request for Additional Information Project stage: Response to RAI ML15272A4212015-09-0404 September 2015 NRR E-mail Capture - Monticello Nuclear Station, Unit 1 - Technical Review Checklist Related to Interim ESEP Supporting Implementation of NTTF R2.1, Seismic Project stage: Other ML15281A0292015-10-14014 October 2015 Staff Review of Interim Evaluation Associated with Reevaluated Seismic Hazard Implementing Near-Term Task Force Recommendation 2.1 Project stage: Approval 2014-03-31
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LER-2013-008, Regarding Both Secondary Containment Access Doors Briefly Opened Simultaneously |
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Xcel Energy@
March 12, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Monticello Nuclear Generating Plant Docket 50-263 Renewed Facility Operating License No. DPR-22 Monticello Nuclear Generating Plant 2807 W County Road 75 Monticello, MN 55362 L-MT-14-019 10 CFR 50.73 Revision 1 to LER 2013-008, "Both Secondary Containment Access Doors Briefly Opened Simultaneously" After submittal of Licensee Event Report (LER) 2013-008, "Both Secondary Containment Access Doors Briefly Opened Simultaneously," the NRC questioned whether the LER was implying that the primary method for maintaining airlock integrity utilized airlock door windows.
This is in conflict with the Monticello Nuclear Generating Plant Updated Safety Analysis Report.
Therefore, a revision to the LER was developed. Revision 1 of LER 2013-008 is attached.
Summary of Commitments This letter contains no new commitments and no revisions to existing commitments.
Karen D. Fili Site Vice President, Monticello Nuclear Generating Plant Northern States Power Company-Minnesota Enclosure cc:
Regional Administrator, Region Ill, USNRC Project Manager, Monticello Nuclear Generating Plant, USNRC Resident Inspector, Monticello Nuclear Generating Plant, USNRC
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 01/31/2017 (02-2014)
, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.
YEAR 2013
- 6. LER NUMBER I
SEQUENTIAL I NUMBER 008 REV NO.
01 2
- 3. PAGE OF 3
On September 18, 2013, while performing the secondary containment (SCT) [JM] airlock [AL] door [DR]
interlock [IEL] surveillance test, the interlock to the main plenum room did not prevent the opening of both doors to the plenum room airlock (DOOR-85 and DOOR-86). With the outer door to the main plenum room open, the inner door was able to be opened. The plenum airlock doors were then closed. The operator attempted a second time to verify interlock functionality. This time the inner door was opened, and again the interlock did not prevent the opening of the outer door. The plenum airlock doors were immediately closed. The total time both doors were opened is estimated to be less than ten (1 0) seconds.
With both doors open, Technical Specification (TS) surveillance requirement (SR) 3.6.4.1.3 was not met and secondary containment was declared inoperable. Secondary containment was declared operable after independently verifying that at least one SCT access door was closed. There were no radiological releases associated with this event.
The safety related function of the airlock doors is to maintain SCT boundary.
EVENT ANALYSIS
This event is reportable in accordance with 10 CFR 50. 73(a)(2)(v) as an event or condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to:
(C) Control the release of radioactive material; (D) Mitigate the consequences of an accident.
SAFETY SIGNIFICANCE
The safety significance of this event is minor. From a risk perspective the Large Early Release Fraction (LERF) exposure was less than one minute, and is bounded by the safety analysis which assumes a five minute positive pressure period. From a high energy line break (HELB) perspective, the short duration that the HELB door was open is within the normal egress allowance provided in plant procedures for HELB doors.
CAUSE
In this event the surveillance test procedure being performed is used to verify the functionality and operability of Appendix R Fire/HELB Doors. This procedure did not have detailed instructions compared to the procedure that is used to provide a functional check and visual inspection of SCT airlock doors. The procedure for verifying SCT airlock doors has steps to verify the associated indicating light is on or audible indication exists (to verify that the interlock relay is energized) prior to challenging the closed door. The Appendix R/HELB Doors procedure simply states to challenge the doors without validating that the interlock is functioning by observing the status of the indicating light or audible indication.
Therefore, the Equipment Cause Evaluation (ECE) performed for the event determined the following cause for the event:
Both DOOR-85 and DOOR-86 were simultaneously opened during testing because the surveillance procedure lacked specific direction for the user to obtain visual or audible confirmation that the interlock energized prior to challenging the closed door. In addition the failure of the interlock mechanism contributed to the ability to open both doors simultaneously.
CORRECTIVE ACTION
Corrective actions identified in the ECE include the following to correct the identified cause:
Immediately verified both airlock doors were closed.
The door interlock was repaired.
Station airlock interlock testing procedures will be revised to provide specific instructions to not challenge the opposite door if there is no indication that the interlock activation is present when a door is open.
PREVIOUS SIMILAR EVENTS
On June 3, 2010, DOOR-72 and DOOR-82 for Airlock 413 (985' Pump Room) were inadvertently opened simultaneously, breaching the SCT boundary. Personnel immediately identified the situation and closed both doors within four to five seconds (estimated). The cause of the event was the design of the interlock between the doors in the 985' Pump Room. The interlock design allows simultaneous entry under specific timing conditions (i.e., the doors are opened at exactly the same time-otherwise, the interlock prevents one door from opening if the other is open). This event was reported in LER 2010-002-02. A similar event involving these same doors occurred on August 5, 2010 and is reported under LER 2010-003-01.
On November 4, 2010, DOOR-62 and DOOR-63 for Airlock 124 were inadvertently opened simultaneously, breaching the SCT boundary. This occurred when personnel attempted to enter the airlock from SCT before the outboard door fully closed. The local alarm sounded for approximately one to two seconds, and the plant employees noticed DOOR-62 was not fully closed. Plant personnel immediately closed the doors and notified the Control Room that SCT was momentarily breached (for approximately 5 seconds). The apparent cause for Airlock 124 breach was intermittent failure of the magnetic bond sensor due to a lack of periodic maintenance. This event was reported in LER 2010-004.
ADDITIONAL INFORMATION
Energy industry identification system (EllS) codes are identified in the text within brackets [xx].
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| 05000263/LER-2013-000-08, Both Secondary Containment Access Doors Briefly Opened Simultaneously | Both Secondary Containment Access Doors Briefly Opened Simultaneously | 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 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)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(ix)(A), Prevented Safety Function in Multiple System 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(viii)(B) | | 05000263/LER-2013-001, E SRV Low-Low Set Tailpipe Dp Root Valve Found Closed | E SRV Low-Low Set Tailpipe Dp Root Valve Found Closed | 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 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)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(ix)(A), Prevented Safety Function in Multiple System 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(i)(8) 10 CFR 50.73(a)(2)(ii)(8) | | 05000263/LER-2013-002, Regarding Essential Bus Transfer During 2R Transformer Testing | Regarding Essential Bus Transfer During 2R Transformer Testing | 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 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)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(ix)(A), Prevented Safety Function in Multiple System 10 CFR 50.73(a)(2) 10 CFR 50.73(a)(2)(viii)(B) | | 05000263/LER-2013-003-02, Regarding Inadequate External Flooding Procedure | Regarding Inadequate External Flooding Procedure | 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)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(ix)(A), Prevented Safety Function in Multiple System 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(viii)(B) | | 05000263/LER-2013-003-01, Regarding Inadequate External Flooding Procedure | Regarding Inadequate External Flooding Procedure | 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 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)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(ix)(A), Prevented Safety Function in Multiple System 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(viii)(B) | | 05000263/LER-2013-003, Regarding Inadequate External Flooding Procedure | Regarding Inadequate External Flooding Procedure | 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 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)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.72(b)(3)(ii), Degraded or Unanalyzed Condition 10 CFR 50.73(a)(2)(ix)(A), Prevented Safety Function in Multiple System 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(viii)(B) | | 05000263/LER-2013-004, Loss of Normal Off-Site Power as a Result of Switch Gear Fault | Loss of Normal Off-Site Power as a Result of Switch Gear Fault | 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 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)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(ix)(A), Prevented Safety Function in Multiple System 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(viii)(B) | | 05000263/LER-2013-005, Transmittal of LER 13-005-00 for Monticello Regarding Discovered Vulnerability in Safeguards System | Transmittal of LER 13-005-00 for Monticello Regarding Discovered Vulnerability in Safeguards System | | | 05000263/LER-2013-006-01, Regarding Unanalyzed Condition for Emergency Diesel Generator Fuel Oil Pumps Train Separation | Regarding Unanalyzed Condition for Emergency Diesel Generator Fuel Oil Pumps Train Separation | 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 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)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(ix)(A), Prevented Safety Function in Multiple System 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(viii)(B) | | 05000263/LER-2013-006, Regarding Unanalyzed Condition for Emergency Diesel Generator Fuel Oil Pumps Train Separation | Regarding Unanalyzed Condition for Emergency Diesel Generator Fuel Oil Pumps Train Separation | 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 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)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(ix)(A), Prevented Safety Function in Multiple System 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(viii)(B) | | 05000263/LER-2013-007-02, Regarding Unanalyzed Condition Due to Inadequate Flooding Procedures | Regarding Unanalyzed Condition Due to Inadequate Flooding Procedures | 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 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)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(ix)(A), Prevented Safety Function in Multiple System 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(viii)(B) | | 05000263/LER-2013-007-01, Regarding Unanalyzed Condition Due to Inadequate Flooding Procedures | Regarding Unanalyzed Condition Due to Inadequate Flooding Procedures | 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(ix)(A), Prevented Safety Function in Multiple System | | 05000263/LER-2013-007, Regarding Unanalyzed Condition Due to Inadequate Flooding Procedures | Regarding Unanalyzed Condition Due to Inadequate Flooding Procedures | 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 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)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(ix)(A), Prevented Safety Function in Multiple System 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(viii)(B) | | 05000263/LER-2013-008-01, Regarding Both Secondary Containment Access Doors Briefly Opened Simultaneously | Regarding Both Secondary Containment Access Doors Briefly Opened Simultaneously | |
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