05000261/LER-2004-002

LER-2004-002,

Docket Number
Event date:	05-23-2004
Report date:	07-21-2004
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
2612004002R00 - NRC Website

FACILITY NAME (1) DOCKET NUMBER (2) 11 � LER NUMBER (6 PAGE (3) H. B. Robinson Steam Electric Plant, Unit No. 2 05000261

I. DESCRIPTION OF EVENT

At 1555 hours0.018 days <br />0.432 hours <br />0.00257 weeks <br />5.916775e-4 months <br /> on May 23, 2004, during operations being conducted for restart of H. B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2, the reactor operating MODE was changed from MODE 4 to MODE 3 with the Steam Driven Auxiliary Feedwater (AFW) pump [EIIS System:Component BA:P] flowpath not correctly aligned for operation as required by Section 3.7.4 of the HBRSEP, Unit No. 2, Technical Specifications.

Specifically, the suction valve (AFW-4) [BA:V] to the Steam Driven AFW pump was closed with a caution tag that stated the valve was to be maintained in the "closed" position. At 2102 hours0.0243 days <br />0.584 hours <br />0.00348 weeks <br />7.99811e-4 months <br />, an Auxiliary Operator noted that the Steam Driven AFW Pump was rotating due to leakage past one of the steam admission valves (V1-8A) [BA:V], which in turn had resulted in elevated lubricating oil temperature. It was determined that the suction valve should be opened, because with the suction valve closed there is no cooling water being supplied to the Steam Driven AFW pump. The steam admission valve leakage and rotation of the pump is not directly related to the Steam Driven AFW pump flowpath being improperly aligned, but assisted in the identification of the lack of pump cooling that was the result of the suction valve being closed.

At 2139 hours0.0248 days <br />0.594 hours <br />0.00354 weeks <br />8.138895e-4 months <br />, the caution tag was removed and the suction valve was opened.

Opening the suction valve restored compliance with the Technical Specifications (TS) requirement in Section 3.7.4, as delineated in Surveillance Requirement (SR) 3.7.4.1, which requires each AFW valve in each water flowpath to be in the correct position.

At 0148 hours0.00171 days <br />0.0411 hours <br />2.44709e-4 weeks <br />5.6314e-5 months <br /> on May 24, 2004, a clearance order was placed on the Steam Driven AFW pump to allow trouble-shooting of the pump and to take an oil sample to verify that no problems had been introduced by the rotation of the pump when no cooling water was being supplied. At 0549 hours0.00635 days <br />0.153 hours <br />9.077381e-4 weeks <br />2.088945e-4 months <br />, the clearance order was removed from the Steam Driven AFW pump and the pump was considered available at that time. At about 1225 hours0.0142 days <br />0.34 hours <br />0.00203 weeks <br />4.661125e-4 months <br />, the results of the oil sample verified that no bearing damage had occurred.

II. CAUSE OF EVENT

Investigation of this event was conducted using the Corrective Action Program and documented in Significant Nuclear Condition Report (NCR) 127784. It was determined that the root cause of this situation was conflicting requirements (i.e., procedural errors). Specifically, a caution cap should have been placed on the main control board control switches for the Steam Driven AFW pump steam admission valves as FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6 PAGE (3) H. B. Robinson Steam Electric Plant, Unit No. 2 05000261 required by operations procedure OMM-001-9, "Equipment Tagging," and operations procedure GP-007, "Plant Cooldown from Hot Shutdown to Cold Shutdown," which has the caution tag placed on the Steam Driven AFW pump suction valve, did not conform to this guidance.

III. ANALYSIS OF EVENT

The health and safety of the public and plant personnel were not impacted by this event. The required safety functions were maintained and the operating parameters of the plant remained within required safety limits. The condition reported by this Licensee Event Report involves a failure to comply with the requirements of the HBRSEP, Unit No. 2, Technical Specifications, as it pertains to a MODE change.

Technical Specifications Limiting Condition for Operation (LCO) 3.0.4 states that when an LCO is not met, entry into a MODE or other specified condition in the Applicability shall not be made except when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. The improper alignment of the Steam Driven AFW pump flowpath during the MODE change from MODE 4 to MODE 3, which occurred during startup activities associated with the recently completed refueling outage, resulted in the requirements of LCO 3.0.4 not being met.

The primary function of the Auxiliary Feedwater system is to provide feedwater to the steam generators for the removal of heat from the reactor coolant system upon a loss of normal feedwater supply. The HBRSEP, Unit No. 2, AFW system consists of three pumps and four associated flowpaths. The improper alignment of the Steam Driven AFW pump flowpath affected one pump and one flowpath. The remaining two Motor Driven AFW pumps and three associated flowpaths were unaffected and operable as required.

TS LCO 3.7.4, Condition A, provides a 7-day Completion Time to restore an inoperable AFW flowpath in MODE 1, 2, or 3.

The consequences of this event are considered minimal based on several factors.

Specifically, the unit was in the process of being restarted after a refueling outage.

Therefore, the decay heat load of the reactor was substantially less than after the reactor has operated at full power for an extended period of time. Additionally, FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6 PAGE 3 H. B. Robinson Steam Electric Plant, Unit No. 2 05000261 sufficient AFW supply was available via the Motor Driven AFW flowpaths, and no TS LCO Required Action Completion Times were exceeded.

During subsequent surveillance testing conducted on the Steam Driven AFW pump on May 25, 2004, it was discovered that there was rubbing, unrelated to the event described in this Licensee Event Report, that caused the Steam Driven AFW pump to be declared inoperable. LCO 3.7.4, Condition A, was entered at 1420 hours0.0164 days <br />0.394 hours <br />0.00235 weeks <br />5.4031e-4 months <br /> on May 25, 2004. The pump repairs were completed and Condition A was exited at 1754 hours0.0203 days <br />0.487 hours <br />0.0029 weeks <br />6.67397e-4 months <br /> on May 27, 2004. Based on the results of testing and maintenance on the Steam Driven AFW pump, it is likely that the pump was inoperable until the repairs were completed on May 27, 2004. The total time that the unit was in MODE 3 while the Steam Driven AFW pump and flowpath were inoperable was approximately four days. This is less than the Completion Time for the Required Action of seven days to restore the flowpath and pump to operable status associated with LCO 3.7.4, Condition A.

The condition described in this Licensee Event Report has been determined to be reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as any operation or condition which was prohibited by the plant's Technical Specifications.

IV. CORRECTIVE ACTIONS

This event involves a condition prohibited by the plant's Technical Specifications due to the Steam Driven AFW pump flowpath being improperly aligned for operation when the plant entered the MODE of applicability of Limiting Condition for Operation 3.7.4, "Auxiliary Feedwater System." Corrective actions that have already been completed include verification of the correct alignment of the Steam Driven AFW pump flowpath, and the steam admission valve (V1-8A) was repaired to reduce the steam leakage that caused the Steam Driven AFW pump to rotate.

The corrective actions to prevent recurrence for this event include the following:

• Revise operations procedures to use a clearance order on the Steam Driven AFW pump, rather than a caution tag on AFW-4, during shutdown conditions when the Steam Driven AFW pump is not required to be aligned for operation. Also, include clear guidance for when the Steam Driven AFW pump flowpath is to be properly aligned for operation and to ensure cooling to the Steam Driven AFW pump. This action is planned for completion by September 16, 2004.

FACILITY NAME (1) A�� DOCKET NUMBER (2) LER NUMBER (6 PAGE (3) H. B. Robinson Steam Electric Plant, Unit No. 2 05000261

• Revise operations procedures to ensure review of caution tags, temporary modifications, and equipment inoperability records prior to crossing into MODE 5, 4, 3, or 2. This action is planned for completion by September 16, 2004.

V. ADDITIONAL INFORMATION

A.Failed Component Information:

No components were considered to have failed during this event. As previously stated, the leakage associated with the steam admission valve was not directly related to the improper alignment of the Steam Driven AFW pump flowpath. The subsequent discovery of inoperability of the Steam Driven AFW pump was also a separate condition that is not directly related to the improper alignment of the Steam Driven AFW pump flowpath.

B.Previous Similar Events:

A review was performed for similar events at HBRSEP, Unit No. 2, where a MODE change was not performed in accordance with the requirements of LCO 3.0.4 due to equipment misalignment. No recent events of this type were identified.

NRCFOMA366A(1-2001)