They could have basically gave them the same level of violation in the 2013 blizzard plant trip LOOP.
The magnitude of chaotic condition isn't cover in the violation amount or level...
May 27, 2015: PILGRIM NRC SPECIAL INSPECTION REPORT 05000293/2015007; AND PRELIMINARY WHITE FINDING
In addition, this report documents one Severity Level IV non-cited violation (NCV) and six findings of very low safety significance (Green). Five of the Green findings were determined to involve violations of NRC requirements.
Green. A self-revealing Green finding was identified for Entergy’s failure to verify that the diesel-driven air compressor (K-117) was available for service prior to the January 27, 2015 winter storm. Specifically, although K-117 was tested prior to the winter storm, the test methodology did not reveal that the capacity of the starting battery was inadequate. The failure to verify that the diesel-driven air compressor (K-117) was available for service prior to the January 27, 2015 winter storm is a performance deficiency that was within Entergy’s ability to foresee and correct. This resulted in a loss of instrument air during the plant trip which complicated the event response. Entergy entered the issue into the corrective action program (CAP) as condition report (CR)-PNP-2015-00559 and initiated actions to supply instrument air with a temporary air compressor. Entergy also revised the operability test for K-117 air compressor to remove the alternating current (AC) power source prior to starting the air compressor.
This self-revealing issue was more than minor because it is associated with the procedure quality and design control attributes of the Initiating Events cornerstone and adversely impacted the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, failure of K-117 resulted in loss of instrument air, which adversely impacted the plant response during the January 27, 2015 winter storm. Additionally, this issue is also associated with the procedure quality and design control attributes of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating event to prevent undesirable consequences...
Green. The team identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion V, “Instructions, Procedures, and Drawings,” when Entergy staff performed an inadequate past operability determination that assessed performance of the ‘C’ safety/relief valve (SRV), which did not open as expected when called upon to function. Specifically, following the January 27, 2015 reactor scram, operators placed an open demand for the ‘C’ SRV twice during post-scram recovery operations, but the valve did not respond as expected and did not perform its pressure reduction function on both occasions. Entergy’s subsequent past operability assessment for the valve’s operation incorrectly concluded that the valve was fully capable of performing its required functions during its installed service. In response to the team’s past operability concerns, Entergy subsequently re-evaluated the past operability of ‘C’ SRV and concluded that it was inoperable and placed the issue into the corrective action program (CAP) as CR-PNP-2015- 02051...
Apparent Violation. A self-revealing preliminary White finding and AV of 10 CFR 50, Appendix B, Criterion XVI, “Corrective Action,” and Technical Specification (TS) 3.5.E, “Automatic Depressurization System,” was identified for the failure to identify, evaluate, and correct a significant condition adverse to quality associated with the ‘A’ SRV. Specifically, Entergy failed to identify, evaluate, and correct the ‘A’ SRV’s failure to open upon manual actuation during a plant cooldown on February 9, 2013. In addition, the failure to take actions to preclude repetition resulted in the ‘C’ SRV failing to open due to a similar cause following the January 27, 2015, LOOP event. Entergy entered this issue in to the CAP as CR-PNP-2015-01983, CR-PNP-2015-00561, and CR-PNP-2015-01520. Immediate corrective actions included replacing the ‘A’ and ‘C’ SRVs and completing a detailed operability analysis of the installed SRVs which concluded that a reasonable assurance of operability existed. Entergy’s failure to identify, evaluate, and correct the condition of the ‘A’ SRV’s failure to open upon manual actuation during a plant cooldown on February 9, 2013, was a performance deficiency. In addition, the failure to take actions to preclude repetition resulted in the ‘C’ SRV failing to open due to a similar cause following the January 27, 2015 LOOP event...
Green. A self-revealing Green NCV of TS 5.4.1, “Procedures,” was identified because Entergy failed to include appropriate operator actions to both recognize the effects of and recover systems and components important to safety within Procedure 5.3.8, “Loss of Instrument Air,” abnormal operating procedure. Entergy entered this issue into the CAP as PNP-CR-2015 0888 and issued a revision to Procedure 5.3.8 to provide additional guidance to operators during a loss of instrument air. The inspectors determined that the level of detail in Procedure 5.3.8, “Loss of Instrument Air,” Revision 39, was inadequate to provide appropriate operator guidance to identify and mitigate key events of January 27, 2015. This self-revealing performance deficiency was reasonably...
Green. A self-revealing Green NCV of TS 5.4.1, “Procedures,” was identified because the operating crew failed to implement a procedure step to open the reactor core isolation cooling (RCIC) system cooling water supply valve during a manual startup of the system. As a result, the RCIC system was operated for over 2 ½ hours with no cooling water being supplied to the lubricating oil cooler or to the barometric condenser. Entergy entered the issue into the CAP as CR-PNP-2015-0566, CR-PNP-2015-0570, and CR-PNP-2015-0952 and conducted a human performance review of the Control Room operators involved with the issue. The inspectors determined that the failure to implement Procedure 5.3.35.1, Attachment 29, “RCIC Injection – Manual Alignment Checklist,” and the Vacuum Tank Pressure Hi Alarm, C904L-F3, alarm response procedure was a performance deficiency and was reasonably within the ability of Entergy personnel to foresee and prevent.... Green. The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, “Corrective Action,” because PNPS staff failed to identify and correct conditions adverse to quality associated with the partial voiding of the ‘A’ core spray (CS) discharge header on January 27, 2015, following the loss of the keepfill system due to a LOOP. PNPS entered the issue into the CAP as CR-PNP-2015-01406 and planned procedural changes that would provide guidance to operate the affected pumps in order to prevent pump discharge piping from voiding if keepfill pressure is lost...
Green. The inspectors identified a Green NCV of 10 CFR 50.54(q)(2) for failing to follow and maintain an emergency plan that meets the requirements of planning standards 10 CFR 50.47(b) and Appendix E. Specifically, on January 27, 2015, following a loss of instrument air, the indications in the Control Room for Sea Water Bay level were lost, and Entergy did not implement compensatory measures, as directed by an Emergency Plan Implementing Procedure, to determine whether a Sea Water Bay level emergency action level (EAL) threshold had been exceeded. Entergy entered this issue into the CAP as CR-PNP-2015- 00948 and initiated corrective actions to identify alternative means for assessing this EAL in the event of a loss of Sea Water Bay level instruments...
Severity Level IV. An NRC-identified SL IV NCV of 10 CFR Part 50.72(b)(3)(xiii) was identified when Entergy failed to make a required event notification within eight hours for a major loss of assessment capability. Specifically, an unplanned loss occurred of all EAL instrumentation associated with Sea Water Bay level that resulted in an inability to evaluate all EALs for an abnormal water level condition. Entergy entered the issue into the CAP as CR-PNP-2015-00949. Compliance was restored on February 5, 2015, when Entergy reported the major loss of assessment capability under Event Notification (EN) 50790...
Wink, wink, wink: they called the 2013 Nemo plant trip and LOOP a full LOOP when it occurred. In the 2015 Juno special inspection the NRC are retroactively calling the 2013 LOOP a partial LOOP based on absolutely no evidence. The difference between between a full LOOP and a partial LOOP is can the 23kv line power up the shutdown transformer. This whole thing about the partial LOOP, they are improperly crafting the Pilgrim 2015 Juno violation level to the public.Date/Time Event1/24 PNPS commenced storm preparations.1/26 High winds and snow impact the site.1/27 01:33 Control Room receives numerous grid disturbance alarms on 345 kilovolt (kV) Line 355, operators reported flashing in the switchyard. Control Room operators commenced power reduction per Procedure 2.1.42, “Operation during Severe Weather,” and placed the safety-related Buses A5 and A6 on the emergency diesel generators (EDGs) ‘A’ and ‘B’, respectively.01:33-02:32 Line 355 power interrupted three times.02:35 Line 355 is lost.04:02 Reactor trip from 52 percent power due to generator load reject upon loss of 345 kV Line 342. Per Emergency Operating Procedure (EOP)-1, “Reactor Pressure Vessel Control,” operators closed the main steam isolation valves and placed the RCIC system in level control and the high pressure coolant injection (HPCI) system in pressure control mode.04:12 Operators commenced a plant cooldown. Diesel-driven air compressor K-117 attempted to start and failed to run on low instrument air header pressure (sustained loss of instrument air).09:48 Operators secured the HPCI system at approximately 120 psig reactor vessel pressure, commencing reactor pressure control using SRVs and the RCIC system. Operators commence periodic operation of the ‘B’ CS pump for level control.09:53 HPCI system declared inoperable following receipt of Gland Seal Condenser Blower Overload Alarm. Condensate discovered backing-up through the blower due to the shutdown condensate flow path being isolated to the Radioactive Waste Building (caused by loss of instrument air).10:56 Following challenges in controlling reactor pressure (pressure increased from approximately 120 psig to 350 psig) and level, operators manually start the RCIC system in the pressure control mode and begin to open SRVs for longer periods of time to reestablish cooldown.16:26 ‘B’ residual heat removal (RHR) system placed in shutdown cooling.16:46 EOP-1 exited.16:57 Reactor temperature <212 font="">1/28 10:47 Instrument air system fully restored using a temporary diesel-driven air compressor.1/30 18:45 Offsite power restored via Lines 355 and 342 following de-icing and inspection of the switchyard with the assistance of the grid operator, NSTAR.1/31 01:30 Safety-related Buses A5 and A6 were restored to their normal offsite power sources.
This is big, do you understand how few people in the USA could do this. So the 2013 Nemo LOOP LER according to the Licensee, this was a "full blown LOOP" because they loss the 23kv electric line supplying the shutdown transformer. I give you clue, they are gaming the violation level. If the station gets into a blackout, they are taking credit that the 23KV line would power up the shutdown transformer and then power up the plant without the diesel generators. In both cases, in the 2015 blizzard Juno and the 2013 Blizzard Nemo, the secondary line was unavailable to power up the plant. It was in improper, basically a fraud and corruption for the NRC to assume the 23 KV line was available to the plant for the risk calculation and thus sets the inaccurate resultant violation level. The violation level is too low. We just don't know how much higher the violation would be.
- (Special Inspection)Pilgrim had a similar event during a severe winter storm in February 2013, which resulted in a partial loss of offsite power. Therefore, this event tripped the deterministic criterion for repetitive failures in the switchyard, which impacted safety-related systems.
That Pilgrim project manager, the boss of the inspectors on site better not give me a call. I fill is ears with problems on this inspection report. This is going to allegations and the OIG...wrong doing by the NRC employees. They are all too smart to do something stupid like this.
Why did the NRC improperly characterize in the 2015 Juno LOOP special inspection that the 2013 Nemo LOOP was a partial LOOP??? It is clearly not accurate. Is the rest of this special inspection that sloppy and intentionally inaccurate? Here is a direct quote from the licencee in their own LER, they define it a LOOP not a partial LOOP:
April 8, 2013: Licensee Event Report 2013-003-00, Loss of Off-Site Power Events Due to Winter Storm Nemo
"On Friday, February 8, 2013, at 2018 hours, the shutdown transformer (SDT) was declared inoperable due to repeated off-site 23KV Trouble/Trip Bypass alarms and reports from NSTAR regarding the power loss and restoration events on the Line via the Manomet Substation.
On February 8th, two line faults occurred on both 345KV transmission lines connected to the PNPS ring bus. At 2102 hours a major fault occurred on off-site Line 342 which remained de-energized for the remainder of the storm. At 2117 hours a fault on Line 355 occurred resulting in a full load reject of the PNPS generator, a subsequent reactor scram, and loss of the SUT. Emergency diesel generators (EDGs) automatically started and provided power to safety buses A5 and A6."
4) The 23kV line remained operable and vital buses were powered by the EDGs, but there were intermittent alarms associated with the 23kV line.(The senior manager in the control room would call the 23kV line inop and dangerous for use in blizzard Juno) Unavailable in blackout.
Key Modeling Assumptions. The following modeling assumptions were determined tobe significant to the modeling of this event analysis:· This analysis models the January 27, 2015 reactor trip at PNPS as a switchyard relatedLOOP initiating event.o The probability of switchyard-related LOOP (IE-LOOPSC) was set to 1.0; allother initiating event probabilities were set to zero.· SDT Availability. The 23kV power source via the SDT was available throughout the event. Given a postulated failure of a diesel generator, the SDT will automatically align to power safety buses A5 and/or A6.o To allow credit for the SDT availability, the house events HE-LOOP (HouseEvent - Loss of Offsite Power IE Has Occurred) and HE-LOOPSC (House Event Switchyard- Related Loss of Offsite Power IE Has Occurred) must be removed from the ACP-23KV (Shutdown Transformer Offsite Power Supply) fault tree.· Offsite Power Recovery. The key offsite power recovery times for PNPS that are modeled within the plant SPAR model are:0 30 Minutes - LOOP and subsequent Station Blackout (SBO) combined withfailures/unavailabilities to RCIC, HPCI, and reactor depressurization.o 1 Hour - LOOP and subsequent SBO with two or more stuck open SRVs (givensuccessful RCIC or HPCI operation).o 3 Hours - LOOP and subsequent SBO with operators failing to recover offsitepower prior to the depletion of the switchyard batteries.
‘B’ SRV was cycled 52 times and ‘D’ SRV was cycled 53 times.
Additionally, offsite power remained available to Buses A5 and A6 via the shutdown transformer (SDT) powered from the station’s 23Kv line.
The team determined that the SRVs were manually cycled 105 times (52 for the ‘B’ SRV and 53 for the ‘D’ SRV) while attempting to stabilize pressure and control RPV level with the CS pump.
No comments:
Post a Comment