05000382/LER-2009-001

LER-2009-001, Waterford 3 Steam Electric Station 05000382 1 OF 3

Docket Number
Event date:	05-30-2008
Report date:	04-27-2009
LER closed by
IR 05000382/2010005 ()
3822009001R00 - NRC Website

REPORTABLE OCCURRENCE

On May 30, 2008, at 0824, Waterford 3 entered MODE 3 with Emergency Feedwater [BA] Pump AB unknowingly inoperable. With the calibration for the EFW Pump governor valve control system incomplete, a lead remained lifted which would have only allowed the Emergency Feedwater Pump (EFW Pp) AB to come up to "minimum" speed and thus incapable of performing its safety function.

The mode change was not in conformance with LCO 3.0.4 which precludes entry into a MODE or other specified condition in the Applicability statement when an LCO is not met, and the ACTION requires a plant shutdown if the LCO is not met within a specified interval. LCO 3.7.1.2 requires three Emergency Feedwater Pumps to be OPERABLE in Modes 1, 2, and 3. Emergency Feedwater Pump AB is one of the three Emergency Feedwater Pumps required OPERABLE by LCO 3.7.1.2. LCO 3.7.1.2, ACTION (d), has a plant shutdown ACTION with EFW Pp AB inoperable.

INITIAL CONDITIONS

The plant was in Mode 3 when this condition occurred. There were no other structures, systems, or components inoperable at the time of the determination that contributed to the condition.

EVENT DESCRIPTION

On May 30, 2008, at 0824, Waterford 3 entered MODE 3. When the plant entered MODE 3, the EFW Pp AB governor valve lead was in the lifted position which would have limited the EFW Pp AB to "minimum" speed. At 1002, Operations declared EFW Pp AB inoperable for testing and entered Technical Specification (TS 3.7.1.2 a) not realizing the pump was already inoperable due to maintenance. Upon completion of EFW Pp AB governor valve calibration, the lifted lead was re­ landed. Subsequently, on May 31, 2008, at 0406, Waterford 3 declared EFW Pp AB OPERABLE.

The EFW Pp AB was declared OPERABLE within TS Surveillance Requirement (SR) 4.7.1.2.b allowed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and within the TS AOT. TS SR 4.7.1.2.b allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after steam generators reach 750 psig to establish suitable test conditions to perform the lnservice Testing SR.

CAUSAL FACTORS

The apparent cause for the plant entering Mode 3 when the EFW AB Pp was inoperable is that there were ineffective procedural barriers in place to ensure the EFW AB Pp was OPERABLE prior to entry into Mode 3.

CORRECTIVE ACTIONS

Additional procedural barriers have been put in place to ensure EFW Pp AB is OPERABLE prior to entering Mode 3.

SAFETY SIGNIFICANCE

There was minimal safety significance for this condition. EFW Pp AB TS SR 4.7.1.2.b allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after exceeding 750 psig in the steam generators to perform Inservice Testing. The surveillance for EFW Pp AB was completed and the EFW Pp AB declared OPERABLE within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after steam generators reached 750 psig as allowed by TS SR 4.7.1.2.b. The condition prohibited by TS was a verbatim nonconformance with TS LCO 3.0.4 when the plant entered Mode 3 with the EFW AB Pump inoperable. Although TSSR 4.7.1.2.b allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the time when steam generators reach 750 psig to establish suitable test conditions, perform post maintenance activities, and perform Inservice Testing, there is no exception documented in the TS specifying an exception to TS LCO 3.0.4 for entering Mode 3 with EFW Pp AB inoperable.

SIMILAR EVENTS

Waterford 3 has no similar events within the past three years.

ADDITIONAL INFORMATION

Energy industry identification system (EIIS) codes are identified in the text within brackets [ ].