05000334/LER-2014-003, Regarding Operation Outside of the Pressure and Temperature Limits Report During Isolated RCS Loop Vacuum Fill
| ML14113A462 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/21/2014 |
| From: | Emily Larson FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-14-142 LER 14-003-00 | |
| Download: ML14113A462 (4) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(v), Loss of Safety Function |
| 3342014003R00 - NRC Website | |
text
FENOC-FirstEnergy Nuclear Operating Company Beaver Valley Power Station P.O. Box 4 Shippingport, PA 15077 Eric A. Larson Site Vice President 724-682-5234 Fax: 724-643-8069 April 21, 2014 L-14-142 10 CFR 50.73 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Beaver Valley Power Station, Unit Nos. 1 and 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 LER 2014-003-00 Enclosed is Licensee Event Report (LER) 2014-003-00, "Operation Outside of the Pressure and Temperature Limits Report During Isolated RCS Loop Vacuum Fill." This event is being reported in accordance with 10 CFR 50.73(a)(2)(i)(B).
There are no regulatory commitments contained in this submittal. Any actions discussed in this document that represent intended or planned actions are described for the NRC's information, and are not regulatory commitments.
If there are any questions or if additional information is required, please contact Mr. Brian F. Sepelak, Supervisor, Regulatory Compliance at 724-682-4282.
Sincerely, Eric A. Larson Enclosure - LER 2014-003-00 cc:
Mr. W. M. Dean, NRC Region I Administrator NRC Resident Inspector Mr. J. A. Whited, NRR Project Manager INPO Records Center (via INPO Consolidated Event System)
Mr. L. E. Ryan (BRP/DEP)
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104 EXPIRES 01/31/2017 (02-20 14)
, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.
- 3. PAGE Beaver Valley Power Station Unit Number 1 05000334 1 OF 3
- 4. IIILh Oneration Outside of the Pressure and Temnerature Limits Renort Dlurina Isolated RCS Loon Vacuuim Fill
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE T
- 8. OTHER FACILITIES INVOLVED IN YEAR I
I FACILITY NAME DOCKET NUMBER MOT DY ER YEAR N
EUMERTA I
E I MON,,TH I DAY1 YEAR,.
NME MONTH DAY YEAR Beaver Valley Unit 2 05000412 I I I
i ~~FACILITY NAMEDOKTNME 02 26 2014 2014 - 003
- - 00 04 21 2014 DOCKET NUMBER
- 9. OPERATING MZOIDAEEOKE UME
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)
El 20.2201(b)
W 20.2203(a)(3)(i) 0 50.73(a)(2)(i)(C)
[D 50.73(a)(2)(vii)
Mode 1 LI 20.2201(d) 0I 20.2203(a)(3)(ii)
LI 50.73(a)(2)(ii)(A)
[1 50.73(a)(2)(viii)(A)
[I 20.2203(a)(1)
[] 20.2203(a)(4)
El 50.73(a)(2)(ii)(B)
El 50.73(a)(2)(viii)(B)
El 20.2203(a)(2)(i)
[I 50.36(c)(1)(i)(A)
E) 50.73(a)(2)(iii) 0I 50.73(a)(2)(ix)(A)
- 10. POWER LEVEL E] 20.2203(a)(2)(ii)
E] 50.36(c)(1)(ii)(A)
LI 50.73(a)(2)(iv)(A)
[I 50.73(a)(2)(x)
LI 20.2203(a)(2)(iii)
[I 50.36(c)(2)
LI 50.73(a)(2)(v)(A)
LI 73.71(a)(4) 100
[_ 20.2203(a)(2)(iv)
DI 50.46(a)(3)(ii)
El 50.73(a)(2)(v)(B)
El 73.71(a)(5) lI 20.2203(a)(2)(v)
LI 50.73(a)(2)(i)(A) 1I7 50.73(a)(2)(v)(C)
Sf OTHER Specify in Abstract below or in NRC I 20.2203(a)(2)(vi) 0 50.73(a)(2)(i)(B)
El 50.73(a)(2)(v)(D)
=
Energy Industry Identification System (EIIS) codes are identified in the text as [XX].
CONDITIONS PRIOR TO OCCURRENCE The events described in this LER are a result of a legacy issue that was discovered on February 26, 2014, during a review of external operating experience. Beaver Valley Power Station (BVPS) Unit 1 and Unit 2 were in Mode 1 at 100 percent power when the issue was identified.
There were no systems, structures, or components that were inoperable at the start of the event that contributed to the event.
DESCRIPTION OF EVENT
On February 26, 2014, during a review of external operating experience, it was discovered that BVPS Unit 1 and Unit 2 had previously operated outside of the limits specified in the Pressure and Temperature Limits Report (PTLR) during past Reactor Coolant System (RCS) [AB] loop vacuum fill evolutions, which were performed while in Mode 5, usually following unit refueling (Mode 6). Technical Specifications (TS)
Limiting Condition for Operation (LCO) 3.4.3 requires RCS pressure and temperature be maintained within the limits specified in the PTLR at all times.
BVPS Unit 1 and Unit 2 operating procedures were revised in the year 2000 to allow the vacuum assist filling of an RCS loop, isolated from the reactor vessel. The procedures permit the RCS loops to be vacuum filled during Mode 5. Placing a vacuum on the RCS loop results in pressures below 0 psig.
Procedure change evaluations were completed which determined that there was sufficient technical justification for the procedure changes at each unit, however failed to identify that conditions below 0 psig were not defined on the applicable pressure/temperature (PIT) limits figures.
In the past three years, isolated RCS loops at each unit were filled using the applicable vacuum fill procedure, while in Mode 5, during the periods of: March 30, 2011 to April 2, 2011 (2R15); April 28, 2012 to May 3, 2012 (1R21); October 23, 2012 to October 26, 2012 (2R16); June 4, 2013 (2FOAC9); and October 25, 2013 to October 27, 2013 (1R22).
CAUSE OF EVENT
The evaluation of the procedure changes to permit vacuum fill of isolated RCS loops focused on the technical evaluation and did not adequately consider the TS compliance aspect of a vacuum condition being below the pressure range specified on the applicable RCS P/T limits figures.
ANALYSIS OF EVENT
In 2000, the BVPS Unit 1 and Unit 2 operating procedures were revised to allow for vacuum assist filling of an isolated RCS loop. Procedure change evaluations were completed which determined that there was adequate technical justification for the changes and concluded that the RCS components are adequately designed to withstand the effects of full vacuum conditions. These conclusions were validated during the investigation of this event. Since the RCS components are adequately designed to withstand vacuum conditions, there are no safety consequences resulting from previous vacuum filling of the isolated RCS loops.
TS LCO 3.4.3 requires RCS pressure and temperature be maintained within the limits specified in the PTLR at all times. Required Action C.1 states, Initiate action to restore parameter(s) to within limits with a Completion Time of Immediately. NUREG-1022, Revision 3, specifies that events that occurred within three years of the date of discovery are reportable. Since pressures below 0 psig are not specified on the applicable PTLR figures, vacuum filling of the RCS loops at each unit within the last three years are conditions prohibited by TS which is reportable under 10 CFR 50.73(a)(2)(i)(B).
CORRECTIVE ACTIONS
The BVPS Unit 1 and Unit 2 PTLRs have been revised to address vacuum conditions.
PREVIOUS SIMILAR EVENTS
A review of internal operating experience was performed for the past 10 years. No previous BVPS Unit 1 or Unit 2 LERs were identified in which a figure referenced by TS was inaccurately applied leading to a violation of a TS.
CR 2014-03819