05000390/LER-2012-003, Regarding Entry Into Mode 4 Without Meeting LCO 3.4.12, Cold Overpressure Mitigation System (Coms)
| ML12284A030 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 10/09/2012 |
| From: | Grissette D Tennessee Valley Authority |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| LER 12-003-00 | |
| Download: ML12284A030 (8) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2) 10 CFR 50.73(a)(2)(viii)(B) |
| 3902012003R00 - NRC Website | |
text
Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381 October 9,2012 10 cFR 50.73 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Unit 1 Facility Operating License No. NPF-90 NRC Docket No.50-390 Subject: Licensee Event Report 390/,2012-003, Entry into Mode 4 without Meeting LCO 3.4.12, "Gold Overpressure Mitigation System (COMS)"
The enclosed Licensee Event Report (LER) provides details concerning Watts Bar Nuclear Plant not meeting Limiting Condition for Operation3.4.12, "Cold Overpressure Mitigation System (COMS),' Conditions A and B on two occasions since August 10, 2009. This report is being submitted in accordance with 10 CFR 50.73(a)(2)(iXB), any operation or condition which was prohibited by the plant's Technical Specifications.
There are no regulatory commitments in this letter. Please direct any questions concerning this matterto Donna Guinn, WBN Site Licensing Manager, at(23) 365-1589.
Respectfully, Enclosure cc: see Page 2 D. E. Grissette Site Vice President Watts Bar Nuclear Plant
U.S. Nuclear Regulatory Commission Page 2 October 9,2012 Enclosure cc (Enclosure):
NRC Regional Administrator - Region ll NRC Senior Resident Inspector - Watts Bar Nuclear Plant
U.S. Nuclear Regulatory Commission Page 3 October 9, 2012 DKG: TPM Enclosure bcc (Enclosure):
NRC Project Manager - Watts Bar Nuclear Plant G. Arent T. J. Carter G.M. Cook S.M. Douglas B. M. Duckett K. D. Dutton D. H. Gronek D. K. Guinn D. E. Grissette D. E. Jernigan J. A. Perrel W. J. Pierce W. L. Prevatt J. W. Shea P. D. Swafford E. J. Vigluicci NSRB Support (T. J. Bradshaw)
EDMS, WT CA-K I NPO: LEREvents@inpo. org
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION (10-2010)
LTGENSEE EVENT REPORT (LER)
(See reverse for required number of digits/characters for each block)
APPROVED BY oMB. No. 3150-0104 EXPIRES: 10/31 12013
, the NRC may not conduct or sponsor, and a person is not required to respond to, the information col lection.
- 1. FACILITY NAME Watts Bar Nuclear Plant, Unit 1
- 2. DOCKET NUMBER 05000390 OF
- 3. PAGE 5
1
{. TITLE Entry into Mode 4 Without Meeting LCO 3.4.12, "Cold Overpressure Mitigation System (COMS)'
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR SEQUENTIAL NUMBER REV NO.
MONTH DAY YEAR FACILITY NAME N/A DOCKET NUMBER N/A 09 21 2009 2012 IOO3I 0
10 09 2012 FACILITY NAME N/A DOCKET NUMBER N/A
- 9. OPERATING MODE 4
tr 20.2201(b) tl 20.2201(d) n zo.22o3(aX1) tr 20.2203(aX2Xi) tr 20.2203(aX2Xii)
! 20.2203(a)(2Xiii) n 20.2203(aX2Xiv) tr 20.2203(aX2Xv) tr 20.2203(aX2Xvi) tr 50.73(aX2XiXc) tr 50.73(aX2XiiXA) tl 50.73(aX2XiiXB) n 50.73(ax2xiii) tr 50.73(aX2XivXA) tr s0.73(aX2XvXA) tr 50.73(aX2XvXB) tr 50.73(aX2Xv)(c) tl 50.73(aX2XvXD)
D 50.73(aX2Xvii) tr s0.73(aX2)(viiiXA) tr 50.73(a)(2)(viii)(B) tr 50.73(a)(2Xix)(A) tr 50.73(aX2Xx) tr r3.r1(aX4) tr r3.r1(a)(s) tr orHER Specify in Abstract below or in ll.D.
Other Systems or Secondary Functions Atfected None
Method of Discovery
During a review of an Operations procedure against TS 3.4.12, the WBN Operations Department identified that a possible discrepancy existed between TS 3.4.12 and the Operations procedure.
On August 10,2012, the WBN Operations and Licensing Departments concluded that the Operations procedure was not consistent with TS 3.4.12, resulting in WBN not meeting LCO 3.4.12 and the applicable Required Actions not being taken within their associated Completion Times on September 21,2009 and April 4,2011.
Operator Actions
None Safety System Responses None
CAUSE OF EVENT
The cause of this event was that a licensed SRO did not perform an impact review for the Operations Department for WBN TS Amendment 55, resulting in an impact to an Operations procedure not being identified. This was caused by a Licensing procedure that did not specify the qualification requirements for individuals performing impact reviews. The unidentified impact to the Operations procedure resulted in WBN not meeting LCO 3.4.12 and the applicable Required Actions not being taken within their associated Completion Times on September21,2009 and April 4,2011.
ANALYSIS OF THE EVENT
A WBN Operations procedure provided actions to perform a unit shutdown from Hot Standby at normal operating temperature and pressure to Cold Shutdown, including the transition from Mode 3 to Mode 4.
This procedure allowed up to four hours to secure both Sl pumps and one CCP after entering Mode 4.
This four hour allowance was consistent with TS 3.4.12 prior to the implementation of WBN TS Amendment 55, but Amendment 55 removed the four hour allowance. During the implementation of WBN TS Amendment 55, the impact on the Operations procedure was not identified, and as a result, LCO 3.4.12 was not met and the applicable Required Actions were not taken within their associated Completion Times on September 21, 2009, and April 4,2011, when transitioning from Mode 3 to Mode 4 for scheduled RFOs.
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ASSESSMENT OF SAFEW CONSEQUENCES There were no safety consequences resulting from this event. The September 21, 2009, and April 4, 2011, events did not affect systems or components required to shutdown and maintain safe shutdown conditions, remove residual heat, and mitigate the consequences of an accident. In addition, there were no instances of RCS pressure rise which would have challenged the RCS pressure boundary. Therefore there was no impact on the health and safety of the public.
CORRECTIVE ACTIONS
I mmediate Corrective Actions WBN procedure GO-6, "Unit Shutdown From Hot Standby to Cold Shutdown," was revised on August 16,2012, to be consistentwith TS 3.4.12.
Corrective Actions to Prevent Recurrence The affected Licensing procedure will be revised to require a core group of departments to perform impact reviews for License Amendment Requests (LARs), including a licensed or previously licensed SRO. In the interim, the Operations Department implemented a management directive stating that all LAR impact reviews must be performed by licensed SRO personnel only.
ADDITIONAL I NFORMATION Failed Components None Previous LERs on Similar Events On July 8,2011, TVA submitted Revision 1 to LER 390/2011-001, "Safety Injection Pump Capable of Injecting into Reactor Coolant System in Mode 5." This LER described an incident where LCO 3.4.12 was not met because a Sl pump was capable of injecting into the RCS while in Mode 5. In this event, an Sl pump was being used to fill and vent a Cold Leg Accumulator (CLA).
Shortly after starting the Sl pump, an abnormal rise in RCS pressure occurred, prompting the operators to secure the Sl pump. The abnormal RCS pressure rise occurred due to a crosstie valve being open. Prior to this event, a temporary clearance lift had been issued to open the subject crosstie valve for Sl full flow testing, however, the crosstie valve was not closed after the testing, resulting in the abnormal RCS pressure rise.
The cause of WBN not meeting LCO 3.4.12 and the applicable Required Actions not being taken within their associated Completion Times in LER 390/2012-003 was that in impact to an Operations procedure was not identified as a result of a non-licensed individual performing the impact review. Therefore the event described in LER 39012011-001 did not involve the same underlying cause or failure as the event being reported in this LER.
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Additional Information
None D.
Safety System Functional Failure This event did not result in a safety system functional failure in accordance with 10 CFR 5o.72(a)(2)(v) and NEI 99-02.
E.
Loss of Normal Heat RemovalConsideration None
VIII. COMMITMENTS
None