05000272/LER-2014-001, Regarding High Energy Line Break Door Blocked Open During Maintenance Activity

Regarding High Energy Line Break Door Blocked Open During Maintenance Activity

ML14069A245
Person / Time
Site:	Salem
Issue date:	03/10/2014
From:	Jamila Perry Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LR- N14-0052 LER 14-001-00
Download: ML14069A245 (6)

LER-2014-001, Regarding High Energy Line Break Door Blocked Open During Maintenance Activity

Event date:
Report date:
Reporting criterion:	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) 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 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)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
2722014001R00 - NRC Website

text

MAR 1 0 2014 LR-N14-0052 PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 PSEG Nudmr /1,C 10 CFR 50.73 U.S. Nuclear Regulatory Commission ATT N: Document Control Desk Washington, DC 20555-0001 S UBJE CT:

LER 272/2014-001-00 Salem Nuclear Generating Station Unit 1 and Unit 2 Renewed Facility Operating License Nos. DPR-70 and DPR-75 NRC Docket Nos. 50-272 and 50-311 High Energy Line Break Door Blocked Open During Maintenance Activity The Licensee Event Report, "High Energy Line Break Door Blocked Open During Maintenance Activity," is being submitted pursuant to 10 CFR 50.73(a)(2)(ii)(B) as "The nuclear power plant being in an unanalyzed condition that significantly degraded plant safety; 10 CFR 50. 73(a)(2)(v) as "Any event or condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to: (B) Remove residual heat, and (D) Mitigate the consequences of an accident"; and 10 CFR 50.73(a)(2)(vii) as "Any event where a single cause or condition caused at least one independent train or channel to become inoperable in multiple systems or two independent trains or channels to become inoperable in a single system designed to:

(B) Remove residual heat, and (D) Mitigate the consequences of an accident."

The attached LER contains no commitments. Should you have any questions or comments regarding the submittal, please contact David Lafleur of Salem Regulatory Assurance at 856-339-1754.

Sincerely, i

Site Vice President J./alem Attachments (1)

Document Control Desk Page 2 10 CFR 50.73 LR-N14-0052 cc Mr. W. Dean, Administrator-Region 1, NRC Mr. John Hughey, Licensing Project Manager-Salem, NRC Mr. P. Finney, USNRC Senior Resident Inspector, Salem (X24)

Mr. P. Mulligan, Manager IV, NJBNE Mr. T. Joyce, President and Chief Nuclear Officer-Nuclear Mr. T. Cachaza, Salem Commitment Tracking Coordinator Mr. L. Marabella, Corporate Commitment Tracking Coordinator Mr. D. Lafleur, Salem Regulatory Assurance

NRC FORM 366 U. S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB:

NO. 3150-0104 EXPIRES: 0113112017 (01-2014)

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 incorporated into the licensing process and fed back to industry.

.-.. 

LICENSEE EVENT REPORT (LER)

Send comments regarding burden estimate to the FOIA, Privacy and Information Collections Branch (T-5 F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by (See Page 2 for required number of internet e-mail to lnfocollects.Resource@nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, (3150-01 04), Office of Management and Budget, Washington, DC digits/characters for each block) 20503. If a means used to impose an information 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 information collection.

M. PAGE Salem Generating Station - Unit 1 05000272 1 OF4

4. TITLE High Energy Line Break Door Blocked Open During Maintenance Activity

5. EVENT DATE

6. LER NUMBER

7. REPORT DATE

8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR I SEQUENTIAL I REV MONTH FACILITY NAME DOCKET NUMBER DAY YEAR NUMBER NO.

Salem Generating Station - Unit 2 050003 11 FACILITY NAME DOCKET NUMBER 0 1 07 2014 20 14

- 00 1

- 00 03 10 2014

9. OEPRATING MODE

11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR§: (Check all that apply) 1 D 20.22o1(b)

D 20.2203(a)(3)(i)

D 50.73(a)(2)(i)(C)

I 50.73(a)(2)(vii)

D 20.22o1(d)

D 20.2203(a)(3)(ii)

D 50.73(a)(2)(ii)(A)

D 50.73(a)(2)(viii)(A)

10. POWER LEVEL D 20.2203(a)(1)

D 20.2203(a)(4)

I 50.73(a)(2)(ii)(B)

D 50. 73(a)(2)(viii)(B)

D 20.2203(a)(2)(i)

D 50.36(c)(1)(i)(A)

D 50.73(a)(2)(iii)

D 50.73(a)(2)(ix)(A) 100%

D 20.2203(a)(2)(ii)

D 50.36(c)(1)(ii)(A)

D 50.73(a)(2)(iv)(A)

D 50.73(a)(2)(x)

D 20.2203(a)(2)(iii)

D 50.36(c)(2)

D 50.73(a)(2)(v)(A)

D 73.71(a)(4)

D 20.2203(a)(2)(iv)

D 50.46(a)(3)(ii)

I 50.73(a)(2)(v)(B)

D 73.71(a)(5)

D 20.2203(a)(2)(v)

D 50.73(a)(2)(i)(A)

D 50.73(a)(2)(v)(C) 0 OTHER D 20.2203(a)(2)(vi)

D 50.73(a)(2)(i)(B)

I 50.73(a)(2)(v)(D)

Specify in Abstract below or in A review of procedure revisions documents a change in 2005 implementing this guidance with little or insufficient reasoning or regulatory basis. Regulatory and engineering reviews could not provide sufficient bases to indicate that a designated door attendant would be a sufficient compensatory measure to ensure operability of the adjacent motor driven auxiliary feedwater (MDAFW) pumps while the TDAFW pump enclosure door was open with steam valved in to the room.

On January 7, 2014, PSEG determined that the control of the HELB door to the 23 TDAFW pump enclosure did not ensure the operability of the MDAFW pumps. An 8-hour report was made to the NRC pursuant to 10 CFR 50. 72(b )(3)(ii)(B) as "the nuclear power plant being in an unanalyzed condition that significantly degrades plant safety."

CAUSE OF OCCURRENCE The cause of this event is attributed to an organizational failure to ensure that guidance provided in plant HELB program procedures contained sufficient justification for compensatory actions used for barrier impairments. The stations HELB program was determined to be inconsistent with regulatory guidance.

PREVIOUS SIMILAR OCCURRENCES A review of LERs at Salem Station dating back to 2011 identified no other HELB barrier related inoperability conditions. A review of work performed since 2011 in the Unit 1 and Unit 2 TDAFW pump rooms identified other occurrences in which work may have been performed with the HELB barrier door held or blocked open while steam was valved in to the enclosure.

SAFETY CONSEQUENCES AND IMPLICATIONS

The Salem Unit 1 and 2 Auxiliary Feedwater (AFW) {BA} systems serve each unit as backup systems for supplying feedwater to the secondary sides of the steam generators at times when the units Main Feedwater System is not available. The AFW system is relied upon to prevent core damage and system overpressurization in the event of accidents such as a loss of normal feedwater or a secondary system pipe rupture, and to provide a means for plant cooldown. Each unit has two MDAFW pumps and one TDAFW pump. Each units TDAFW pump is located in an enclosure provided with a steel door to contain the energy released by a postulated HELB in the room. The MDAFW pumps are located adjacent to the enclosure such that if a secondary steam HELB event were to occur in the TDAFW pump room while its door was open or disabled, the steam plume from the room could render both MDAFW pumps inoperable.

A postulated steam break in the TDAFW enclosure while the door is open or otherwise disabled could thus render both the TDAFW pump and the two MDAFW pumps inoperable preventing mitigation of the consequences of a secondary steam break.

There was no impact on the health and safety of the public as a result of this event. The probability of a HELB event occurring during the short time period while the door was impaired was very low. Thus the safety significance of the event was low.

2014

- 001

- 00 The main steam piping inside the TDAFW pump enclosure is inspected in accordance with the In-Service Inspection (lS I) Program to ensure piping integrity and substantially reduce the likelihood of a guillotine pipe break. Pipe shrouding and restraints are provided on main steam lines for the TDAFW pump to limit pipe whipping and reduce the effects of steam line break impact on adjacent components. This combination of inspections and pipe shrouding and restraints reduces the likelihood of a guillotine break and its effect in the room. It is thus likely that should a leak occur, a designated door watch attendant would be able to perform the actions required to close the barrier door at the first sign of pipe leakage ensuring the functioning of the MDAFW pumps.

In the case in which a break of sufficient size would cause the designated door attendant to be unable to close the door, plant operators may be required to respond to a loss of AFW. Emergency operating procedures (EOPs) would direct operators to either establish cooling with the Residual Heat Removal system if available, or perform once-through Reactor Coolant System (RCS) heat removal by depressurizing the RCS through the pressurizer Power Operated Relief Valves and injecting coolant via the High Pressure Safety Injection pumps. These EOP strategies would preclude core damage in this unlikely event.

A review of this event determined that a Safety System Functional Failure (SSFF) as defined in Nuclear Energy Institute (NE I) 99-02 did occur.

CORRECTIVE ACTIONS

1.

A plant-wide communication was made describing the HELB event, its impact on operability of plant equipment and corrective actions in progress.

2.

A revision to the Operability Assessment and Equipment Control Program procedure has been made to ensure it conforms to the guidance of NRC R IS 2001-09, Control of Hazard Barriers.

3.

Permanent signs will be installed on all HELB barrier doors prohibiting them from being blocked open without authorization from Salem Operations.

COMMITMENTS

No commitments are made in this LER.