05000250/LER-2005-001
| Docket Numbersequential Revmonth Day Year Year Month Day Yearnumber No. 05000 | |
| Event date: | 1-1-2005 |
|---|---|
| Report date: | 2-28-2005 |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 2502005001R00 - NRC Website | |
this event.
FACIUTY NAME 111 DOCKET NUMBER 121 LER NUMBER (Al PACE 131 Turkey Point Unit 3 05000250 NUMBER NUMBER
DESCRIPTION OF THE EVENT
On January 1, 2005, Unit 3 entered Mode 2 during reactor [EIIS: AC] startup while in a Technical Specification (TS) shutdown action statement. This is prohibited by Technical Specification 3.0.4.
During reactor startup, 3A Intake Cooling Water (ICW) basket strainer [EIIS: BS, STR] backwash was commenced. This caused 3A ICW header to be declared inoperable and a 72-hour shutdown action was entered in accordance with TS 3.7.3, Action c. The reactor startup continued and the unit entered Mode 2 with the 3A ICW header inoperable.
This condition was determined to be reportable in accordance with 10 CFR 50.73(a)(2)(i)(B).
BACKGROUND
The ICW System provides cooling water to the Component Cooling Water (CCW) heat exchangers [EIIS:
CC, HX]. The ICW System includes three ICW pumps [EHS: P], tie headers, two independent supply headers, piping, valves [EIIS: V], and basket strainers that are required to provide ICW flow from the plant cooling canals, via the intake structure, supply the CCW heat exchangers, and then return ICW to the plant cooling canal system. The ICW System removes the heat load from the CCW System during accident conditions to support both reactor residual heat removal and containment [EIIS: NH] heat removal requirements. The ICW System also provides cooling water to the turbine plant cooling water (TPCW) [EHS: KB] heat exchangers and water to the Service Water/Lube Water System [EHS: KG].
During normal operation, two ICW pumps provide flow to the three CCW heat exchangers and to both TPCW heat exchangers. During an accident, only one ICW pump providing flow to two CCW heat exchangers is required by design.
The ICW System supplies cooling water to the tube side of the CCW and TPCW heat exchangers. A redundant header system is provided with isolation valves that can be shut so that one header out of service does not require immediate shutdown of the unit. The TPCW and Service Water/Lube Water Systems are intended to serve non-safety-related functions only. However, depending on the location of the automatic isolation valve or the flow restricting devices [EIIS: OR] that establish the pressure boundary for the ICW supply to the CCW system, portions of these systems within that pressure boundary are treated as safety related.
The ICW System is required to be operable by TS Limiting Condition for Operation 3/4.7.3. Three ICW pumps and two ICW headers must be operable in Modes 1 through 4 or a Technical Specification Action is entered. The TS basis for operation of the ICW System is that it provides the required cooling capacity for both normal and accident configurations. The design assumes a single active failure concurrent with an accident and loss of offsite power in establishing the design assumptions used in the accident analyses.
MSC FIRM 3655114001/ The cause is attributed to improper communication from the Reactor Control Operator (RCO) to the Unit Supervisor and Shift Manager.
ANALYSIS OF THE EVENT
During reactor startup, the RCO gave permission to perform backwash of the 3A ICW basket strainer. This is a routine evolution that is typically performed near the end of a shift. Communication with the operator in the field was handled by the RCO.
The valve arrangement for the backwash results in declaring the 3A ICW header out of service. TS 3.7.3, Action c allows the header to be returned to service within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or a shutdown is commenced. The radio communication came to the RCO with unit responsibility early in the startup. This was not communicated to the unit supervisor or shift manager with command and control. Without this communication several barriers were effectively removed that could have prevented the event. The ICW header was out of service for 53 minutes and the 72-hour time limit in TS 3.7.3, Action c was not challenged.
Reportability A review of the reporting requirements of 10 CFR 50.72 and 10 CFR 50.73 and NRC guidance provided in "Event Reporting Guidelines," 10 CFR 50.72 and 10 CFR 50.73 (NUREG-1022, Rev. 2) was performed for the subject condition. As a result of this review, the condition is reportable as described below.
1. Part 50.73(a)(2)(i)(B) of Title 10 CFR states that the licensee shall report "Any operation or condition which was prohibited by the plant's Technical Specifications except when:
(1) The Technical Specification is administrative in nature; (2) The event consisted solely of a case of a late surveillance test where the oversight was corrected, the test was performed, and the equipment was found to be capable of performing its specified safety functions: or (3) The Technical Specification was revised prior to discovery of the event such that the operation or condition was no longer prohibited at the time of discovery of the event.
With one ICW header out of service Action c of TS LCO 3.7.3.b applies. The respective TS are shown below:
"3.7.3 The Intake Cooling Water System (ICW) shall be OPERABLE with:
a.Three ICW pumps, and b. Two ICW headers.
NRC FINN 36611140011
- APPLICABILITY: MODES 1, 2, 3, and 4.
ACTION:
c. With only one ICW header OPERABLE, restore two headers to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Action c allows operation to continue with only one ICW header for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. If the ICW header is not restored within this time, a plant shutdown is required.
LCO applicability TS 3.0.4 is as follows:
"3.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be made when the conditions for the Limiting Conditions for Operation are not met and the associated ACTION requires a shutdown if they are not met within a specified time interval. Entry into an OPERATIONAL MODE or specified condition may be made in accordance with ACTION requirements when conformance to them permits continued operation of the facility for an unlimited period of time. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements. Exceptions to these requirements are stated in the individual specifications.
The bases for TS 3.0.4 states that TS 3.0.4 "...precludes placing the facility in a higher MODE of operation when the requirements for a Limiting Condition for Operation are not met and continued noncompliance to these conditions would result in a shutdown to comply with the ACTION requirements if a change in MODES were permitted. The purpose of this specification is to ensure that facility operation is not initiated or that higher MODES of operation are not entered when corrective action is being taken to obtain compliance with a specification by restoring equipment to OPERABLE status or parameters to specified limits.
A change to Mode 2 from a lower mode is not allowed by TS 3.0.4, since Action c of LCO 3.7.3 requires a shutdown if the inoperable ICW header could not be restored within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
The event is reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as a "...condition which was prohibited by the plant's Technical Specifications...." Specifically, entering Mode 2 from a lower mode while Action c of LCO 3.7.3 was in effect (a shutdown action) constitutes non-compliance with TS 3.0.4.
ANALYSIS OF SA1-thlY SIGNIFICANCE Based on the analysis described below, it is concluded that the health and safety of the public were not affected by this event.
NIC1011136611f1-211011 NRC FORM 366A US. NUCLEAR REGULATORY COMMISSION (1-20011
LICENSEE EVENT REPORT HEM
DOCKET NUMBERFACILITY NAME Ell (ER NUMBER WI PACE (3)(21 2005 - 001 - CO The strainer backwash with the 3A ICW header out of service was performed during a reactor startup. The safety significance is similar to removing an ICW header from service to backwash a strainer during power operation. Although a backwash can be performed within a few hours, the TS allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for a header's return to service or a shutdown is required. Therefore, although a mode change is not authorized with an ICW header out of service, the safety significance was no greater than that allowed during power operation based on the required function of the system design. There was no increase in risk as a result.
CORRECTIVE ACTIONS
1. The RCO was coached and counseled on the expectation for communicating required information at all times.
2. The procedure to perform a backwash of the ICW strainer has been updated for both units to obtain Shift Manager written permission prior to removing an ICW header from service and entering the TS Action c.
3. A night order was issued to all Operations personnel to reiterate that removal of any TS related equipment must follow site procedures, which requires the component to be logged in the Equipment Out-of-Service logbook, Reactor Operator Narrative log and appropriate supervision informed.
ADDITIONAL INFORMATION
second component function identifier (if appropriate)].
FAILED COMPONENTS rDENT1HED:�NONE SIMILAR EVENTS: NONE