On October 28, 2005, a procedure change to
AOP-N.08, Appendix R Fire
Safe Shutdown, was implemented. This change incorporated updated guidance provided by a Westinghouse technical bulletin (
TB -04-022) concerning
RCP seal performance during Appendix R fires and a loss of all pump seal cooling. This change reduced the time available to perform manual actions and restore
RCP seal flow from 24 minutes to 13 minutes. In the event of an Appendix R fire resulting in a spurious safety injection signal, plant procedures required that all
RCS injection sources be stopped to prevent filling the pressurizer solid. The vendor guidance stated that actions taken to prevent this condition and restore
RCP seal flow should be completed within 13 minutes to prevent seal damage. The actions outlined by
AOP-N.08 required an auxiliary unit operator (
AUO) to manipulate several valves in the appropriate Charging Pump room and then a
CCP restarted to restore seal flow. Specifically, the
AUO was to open a dedicated flow path to the
RCP seals using manual valve 62-526 (A-train), or 62-534 (Btrain) and close the associated
CCP manual discharge valve,
62-527 (A-train) or 62-533 (B-train) to the
CCP Injection Tank (CCPIT). To support the procedure change, these manipulations were subjected to a manual action validation that consisted of a table top review of the necessary steps. The licensee determined that the
CCP manual discharge valves to the CCPIT could be closed by an individual
AUO in 5 minutes and 20 seconds. Prior to the procedure being approved, PER 91383 was written on October 24, 2005. The PER addressed concerns by at least one plant
AUO that the manual actions required by the change to procedure
AOP-N.08 may not be able to be completed within the time required. PER 91383 requested the need to further evaluate the time necessary to perform the manual actions by actual valve manipulations, or whether additional procedure changes were needed to provide more margin to the required time. The corrective action planned was to perform a timed valve stroke of
CCP discharge valve 2-62-527 to validate procedural change assumptions. Work Order (
WO) 06- 771729-000 was written to implement and track this action during an appropriate
CCP maintenance period. PER 91383 was closed as completed on February 24, 2006 based on the
WO being written. On November 9, 2006, during a self-assessment, the licensee determined that the
WO had not been completed and was not scheduled for performance until January 22, 2007. PER 114455 was written to document the incomplete corrective action. Upon review of PER 114455, the inspectors questioned the licensee on the valves history, the status of corrective actions, and whether a valid safety concern existed if the valve could not be operated within the prescribed time. Prior to resolution by the licensee, on November 27, 2006, during Unit 2 refueling outage activities, operators closed valve 2-62-527 to support maintenance. The operators reported that the valve was very difficult to operate and required approximately 30 minutes for two
AUOs to shut the valve. This observation was documented in in PER 115490 and supported the initial concern expressed in PER 91383. This information prompted the license to evaluate the consequences of the additional time needed to operate valve 2-62-527 with plant Appendix R
