05000298/LER-2004-001, For Cooper Regarding Process Weakness Results in Technical Specification Prohibited Operation
| ML041040762 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 04/08/2004 |
| From: | Jason Christensen Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NLS2004050 LER 04-001-00 | |
| Download: ML041040762 (5) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 2982004001R00 - NRC Website | |
text
Nebraska Public Power District Always there when you need us NLS2004050 April 8, 2004 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:
Subject:
Licensee Event Report No. 2004-001-00 Cooper Nuclear Station, NRC Docket 50-298, DPR-46 The purpose of this correspondence is to forward a Licensee Event Report.
Sincerely, J hristensen Plant Manager
/rar Enclosure cc: Regional Administrator USNRC - Region IV Senior Project Manager USNRC - NRR Project Directorate IV-I Senior Resident Inspector USNRC NPG Distribution INPO Records Center SORC Administrator Records
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COOPER NUCLEAR STATION P.O. Box 98/ Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com
Abstract
On February 11, 2004, during validation of a valve line-up on the Service Water (SW) Gland Water system, Cooper Nuclear Station discovered that the gland water piping was cross-connected with SW subsystem 'A" safety related pump discharge supplying gland water to both SW subsystems. This resulted in SW subsystem 'B" being declared inoperable and required entry into a 30 day Limiting Condition for Operation (LCO). Diesel Generator (DG) 2, which is cooled by SW subsystem 1B", and the Control Room Emergency Filter System (CREFS), which was aligned to the DG 2 emergency bus, were declared inoperable and required entry into 7-day Shutdown LCOs. The LCOs were entered at 0310 hours0.00359 days <br />0.0861 hours <br />5.125661e-4 weeks <br />1.17955e-4 months <br />. The gland water line-up was returned to the required configuration and the LCOs were exited at 0340 hours0.00394 days <br />0.0944 hours <br />5.621693e-4 weeks <br />1.2937e-4 months <br />. Further investigation determined that the cross-connected configuration had existed since restoration of the system from planned maintenance performed 21 days earlier.
This event is 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 [(TS)]," due to the length of time DG 2 and CREFS were inoperable, which exceeded the TS 7 day shutdown LCO.
The cause of this event was determined to be a process weakness in the Clearance Order program.
Additional instructions for development of clearance orders were issued on February 13, 2004 and a revision to the station procedure for development of clearance orders was completed on April 8, 2004.
NRC FORM 366 (7.2001
(If more space is required, use additional copies of (If more space is required, use additional copies of NRC Form 366A)
The process for development of the clearance order to restore the cross-connected configuration of the SW gland water to the required configuration allowed the use of a note in the clearance order referring the operator to use the system operating procedure (SOP) for system restoration instead of a specific step to direct use of the SOP.
SAFETY SIGNIFICANCE
An evaluation of this event concluded that it was not risk significant. The change in the core damage probability was calculated as less than the threshold for classification as risk significant. The risk assessment included assumptions that the Service Water pumps can run 30 minutes with a loss of gland water flow, and that the average response time to restore the flow in the event of a low gland water flow condition is 20 minutes.
This event is not considered a Safety System Functional Failure as defined in NEI 99-02, Revision 2, Regulatory Assessment Performance Indicator Guideline.
CORRECTIVE ACTIONS
Immediate actions:
The system was restored to the proper configuration at 0340 hours0.00394 days <br />0.0944 hours <br />5.621693e-4 weeks <br />1.2937e-4 months <br /> on February 11, 2004.
Issued instructions for the work control process to require a separate entry for confirmation of clearance order release and an additional entry for confirmation of system configuration restoration. This action was completed February 13, 2004.
The Service Water system operating procedure was revised to include placement and removal of
'Crosstied" tags for the pump control switches, and verification of valve lineups. The procedure revision was effective February 24, 2004.
Long Term actions:
The station procedure for development of clearance orders was revised to eliminate the possibility of improperly using notes instead of numbered steps, and to require the release sequence be coordinated with the applicable system operating procedure sequence. This action was completed on April 8, 2004.
PREVIOUS EVENTS No previous reportable events resulting from mis-positioned components within the last three years were identified.
I ATTACHMENT 3 LIST OF REGULATORY COMMITMENTSl Correspondence Number: NLS2004050 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing & Regulatory Affairs Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITTED DATE
COMMITMENT
OR OUTAGE None N/A I-4.
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