05000382/LER-2009-001, Regarding 3.0.4 Violation: Mode Change with an Inoperable Emergency Feedwater Pump
| ML091190308 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 04/27/2009 |
| From: | Murillo R Entergy Nuclear South, Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| W3F1-2009-0013 LER 09-001-00 | |
| Download: ML091190308 (6) | |
| 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 |
| 3822009001R00 - NRC Website | |
text
Entergy Nuclear South Entergy Operations, Inc.
17265 River Road Killona, LA 70057-3093 Tel 504739 6715 Fax 504 739 6698
\\e rmurill@entergy.com Robert J. Murillo Licensing Manager Waterford 3 W3F1-2009-0013 April 27, 2009 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
Subject:
Licensee Event Report 09-001 -00 Waterford Steam Electric Station, Unit 3 (Waterford 3)
Docket No. 50-382 License No. NPF-38
Dear Sir or Madam:
Entergy is hereby submitting Licensee Event Report (LER) 09-001-00 for the Waterford Steam Electric Station Unit 3. This report provides the details for a condition prohibited by Technical Specification when a mode change was made on May 30, 2008 with one of three Emergency Feedwater (EFW) Pumps being inoperable due to a lifted lead on the EFW pump governor valve control system.
This report is being submitted pursuant to 10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by Technical Specifications. This report contains no new commitments.
The initial reportability evaluation performed in July 2008 determined that the condition was not reportable. Waterford 3 personnel identified the need for additional review in February 2009, and a subsequent reportability determined that the condition was reportable. This oversight has been entered into the Waterford 3 corrective action program.
This report contains no new commitments. Please contact Robert J. Murillo, Manager, Licensing at (504) 739-6715 if there are any questions regarding this report.
Since ely, RZJM/MEM ssf~
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Attachment:
Licensee Event Report 09-001-00 J_2L
W3F1-2009-0013 Page 2 (w/Attachment) cc:
ýMr. Elmo E. Collins, Jr.
Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400
.Arlington, TX 76011-4125 NRC Senior Resident Inspector Waterford Steam Electric Station Unit 3 P.O. Box 822 Killona, LA 70066-0751 U. S. Nuclear Regulatory Commission Attn: Mr. N. Kalyanam Mail Stop O-07D1 Washington, DC 20555-0001 Wise, Carter, Child & Caraway ATTN: J. Smith P.O. Box 651 Jackson, MS 39205 Winston & Strawn ATTN: N.S. Reynolds 1700 K Street, NW Washington, DC 20006-3817 Morgan, Lewis & Bockius LLP ATTN: T.C. Poindexter 1111 Pennsylvania Avenue, NW Washington, DC 20004 Louisiana Department of Environmental Quality Office of Environmental Compliance Surveillance Division P. O. Box 4312 Baton Rouge, LA 70821-4312 R.K. West, lerevents@inpo.org - INPO Records Center
Attachment W3F1 -2009-0013 Licensee Event Report 09-001-00
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(T-6 E6), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by intemet e-mail to bjsl@nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202 (3150-0104), Office of Management and Budget, Washington, DC 20503. If a means used to impose information collection does not display a currently valid OMB control Severse for reui redn number ofnumber, the NRC may not conduct or sponsor, and a person is not required to respond to, the d(qs raecters feachblock2 information collection.
- 3. PAGE Waterford 3 Steam Electric Station 05000382 1 OF 3
- 4. TITLE 3.0.4 Violation: Mode Change with an Inoperable Emergency Feedwater Pump
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR SEQUENTIAL REV FACILITY NAME DOCKET NUMBER NUMBER NO MONTH DAY YEAR NA 05000 FACILITY NAME DOCKET NUMBER 05 30 2008 2009 - 001 00 04 27 2009 NA 05000
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)
Fi 20.2201(b)
D 20.2203(a)(3)(i)
El 50.73(a)(2)(i)(C)
El 50.73(a)(2)(vii) 3 El 20.2201(d)
Li 20.2203(a)(3)(ii)
El 50.73(a)(2)(ii)(A)
[L 50.73(a)(2)(viii)(A)
[I 20.2203(a)(1)
El 20.2203(a)(4)
El 50.73(a)(2)(ii)(B)
El 50.73(a)(2)(viii)(B)
El 20.2203(a)(2)(i)
El 50.36(c)(1)(i)(A)
El 50.73(a)(2)(iii)
El 50.73(a)(2)(ix)(A)
- 10. POWER LEVEL Li 20.2203(a)(2)(ii)
Li 50.36(c)(1)(ii)(A)
LI 50.73(a)(2)(iv)(A)
Li 50.73(a)(2)(x)
FI 20.2203(a)(2)(iii)
El 50.36(c)(2)
El 50.73(a)(2)(v)(A)
EL 73.71(a)(4)
Li 20.2203(a)(2)(iv)
EL 50.46(a)(3)(ii)
El 50.73(a)(2)(v)(B)
EL 73.71(a)(5) 00 El 20.2203(a)(2)(v)
Li 50.73(a)(2)(i)(A)
Li 50.73(a)(2)(v)(C)
Li OTHER Specify in Abstract below or in EL 20.2203(a)(2)(vi) 0 50.73(a)(2)(i)(B)
Li 50.73(a)(2)(v)(D)
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 ofperforming 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 Inservice 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 LI.