The Ghost Monticello's HPCI

This is how risk perspectives looks like while on drugs.

In a big accident, the operating staff at the beginning has very limited resources. They would have no capability to assess if the steam lines were clear. They would assume HPCI was broken and to use it would create new dangers with the condensate damaging other components. So the operators would walk right past the damaged equipment.

This is another huge flaw in risk perspectives. It doesn't matter what the condition is of the component is...it only matter what the operators perception is of safety equipment. These are the lessons of TMI and Davis Besse.

I would consider this equipment broken until proven safe...not available to the accident. Calling it this way would jack up the worth of a broken HPCI...incentive not to let it happen again.  

HIGH PRESSURE COOLANT INJECTION INOPERABLE DUE TO CONDENSATION IN STEAM LINE 

"At 0537 CDT on March 21, 2015, following the High Pressure Coolant Injection (HPCI) system quarterly pump and valve surveillance, after HPCI was removed from service, an alarm for the HPCI Turbine Inlet High Drain Pot Level did not reset. This indicated that LS-23-90 (HPCI Steam Supply Drain High Level Bypass) did not reset, which could be an indication that condensate exists in the steam line. The system responded as designed but the alarm did not clear as expected. Without assurance that the condensate has been removed from the HPCI steam line, HPCI remains inoperable for reasons other than the planned surveillance. As a result, this condition is being reported under 10 CFR 50.72(b)(3)(v)(D) as a condition that could have prevented fulfillment of the safety function at the time of discovery.

"The health and safety of the public was maintained as the plant was in a normal condition with no initiating event in progress.

"The NRC Resident Inspector has been notified."
The State of Minnesota will be notified.

* * * RETRACTION FROM RANDY SAND TO DANIEL MILLS AT 1445 EDT ON 5/11/15 * * *
"On March 21, 2015, Northern States Power Minnesota reported a condition that could have prevented the fulfillment of a safety function under 10 CFR 50.72(b)(3)(v)(D). The High Pressure Coolant Injection (HPCI) System was declared inoperable for a reason other than planned maintenance due to the failure of the HPCI Steam Supply Drain Hi Level Bypass Level Switch to clear the high level alarm subsequent to actuation. 

"An engineering evaluation was performed and concluded that the function of the primary pathway to remove condensate remained unchallenged by the condition present

Do they got this thermography gear available to the operators...so they can immediately see if the condensate is clear??? Is thermography qualified to check the conditions of safety equipment. 

on the level switch This conclusion was also validated via thermography with the HPCI steam supply pressurized and bypass valve open. The verification that the primary pathway was functional provides reasonable assurance that the HPCI steam supply was always clear of condensate supporting the ability of HPCI to perform its required safety function. Therefore, the condition present on the level switch did not render HPCI inoperable. The conclusions of the engineering evaluation provide the basis for retraction of the ENS report made on March 21.
"The NRC Resident Inspector has been notified."
The licensee will also notify the State of Minnesota.

Number 2 event report:

HIGH PRESSURE COOLANT INJECTION INOPERABLE DUE TO CONDENSATION IN STEAM LINE

"At 0537 CDT on March 21, 2015, following the High Pressure Coolant Injection (HPCI) system quarterly pump and valve surveillance, after HPCI was removed from service, an alarm for the HPCI Turbine Inlet High Drain Pot Level did not reset. This indicated that LS-23-90 (HPCI Steam Supply Drain High Level Bypass) did not reset, which could be an indication that condensate exists in the steam line. The system responded as designed but the alarm did not clear as expected. Without assurance that the condensate has been removed from the HPCI steam line, HPCI remains inoperable for reasons other than the planned surveillance. As a result, this condition is being reported under 10 CFR 50.72(b)(3)(v)(D) as a condition that could have prevented fulfillment of the safety function at the time of discovery.

"The health and safety of the public was maintained as the plant was in a normal condition with no initiating event in progress.

"The NRC Resident Inspector has been notified."

The State of Minnesota will be notified.

* * * RETRACTION FROM RANDY SAND TO DANIEL MILLS AT 1445 EDT ON 5/11/15 * * *

"On March 21, 2015, Northern States Power Minnesota reported a condition that could have prevented the fulfillment of a safety function under 10 CFR 50.72(b)(3)(v)(D). The High Pressure Coolant Injection (HPCI) System was declared inoperable for a reason other than planned maintenance due to the failure of the HPCI Steam Supply Drain Hi Level Bypass Level Switch to clear the high level alarm subsequent to actuation.

"An engineering evaluation was performed and concluded that the function of the primary pathway to remove condensate remained unchallenged by the condition present on the level switch This conclusion was also validated via thermography with the HPCI steam supply pressurized and bypass valve open. The verification that the primary pathway was functional provides reasonable assurance that the HPCI steam supply was always clear of condensate supporting the ability of HPCI to perform its required safety function. Therefore, the condition present on the level switch did not render HPCI inoperable. The conclusions of the engineering evaluation provide the basis for retraction of the ENS report made on March 21.

"The NRC Resident Inspector has been notified."

The licensee will also notify the State of Minnesota.

Notified R3DO (Peterson).