05000425/LER-2003-001, Regarding Technical Specification Required Shutdown Not Performed Following Issuance of Notice of Enforcement Discretion
| ML033630569 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/22/2003 |
| From: | Gasser J Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-03-2577 LER 03-001-00 | |
| Download: ML033630569 (5) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 4252003001R00 - NRC Website | |
text
Jeffrey T. Gasser Southern Nuclear Vice President Operating Company, Inc.
40 Inverness Center Parkway Post Office Box 1295 Birmingham, Alabama 35201 Tel 205.992.7721 Fax 205.992.0403 U
SOUTHERN December 22, 2003 COMPANY Energy to Serve Your Worlds Docket No.:
50-425 NL-03-2577 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant Licensee Event Report 2-2003-001 Technical Specification Required Shutdown Not Performed Following Issuance of NOED Ladies and Gentlemen:
In accordance with the requirements of 10 CFR 50.73, Southern Nuclear Operating Company hereby submits a Vogtle Electric Generating Plant Licensee Event Report (LER) for a condition that occurred on November 5, 2003.
This letter contains no NRC commitments. If you have any questions, please advise.
Sincerely, Z&y T.
asser JTG/KWK/daj Enclosures: LER 2-2003-001 cc:
Southern Nuclear Operating Company Mr. J. D. Woodard, Executive Vice President Mr. W. F. Kitchens, General Manager - Plant Vogtle Mr. M. Sheibani, Engineering Supervisor - Plant Vogtle Document Services RTYPE: CVC7000 U. S. Nuclear Reaulatory Commission Mr. L. A. Reyes, Regional Administrator Mr. S. D. Bloom, NRR Project Manager - Vogtle Mr. J. Zeiler, Senior Resident Inspector - Vogtle
Abstract
On October 26, 2003, personnel were performing Technical Specification (TS) surveillances on the Solid State Protection System (SSPS). A switch in the test circuit that is used to test memories logic functions would not operate properly in all positions. This prevented successful completion of the surveillance testing for some functions, which was due by November 5, 2003. After this time, following completion of a 24-hour TS Required Action Completion Time, a unit shutdown would have been required to be initiated per the action requirements of the TS. A telephone conversation with NRC personnel was conducted on November 4, 2003. During this conversation, the NRC granted a notice of enforcement discretion (NOED) allowing the TS surveillance requirements to be late without enforcement for a period of 28 days. The 28 days represented a reasonable period of time for a written request, to change the TS, to be processed by the NRC. The TS change allowed the required surveillance testing to be delayed until after the end of the fuel cycle in Spring 2004, or until the next unit shutdown to Mode 5 (Cold Shutdown), whichever comes first. On December 3, 2003, the requested TS change was approved.
The cause of the test switch failure will be determined after it is replaced and further corrective action(s) will be taken, if needed.U.S. NUCLEAR REGULATORY COMMISSION (1-2001)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACILITY NAME (1)
DOCKET LER NUMBER (6)
PAGE (3) l YEAR l
SEQUENTIAL REVISION YEAR NUMBER Vogtle Electric Generating Plant - Unit 2 05000-425 2
001 00 2 OF 4 TEXT (if more space is required, use additional copies of NRC Form 366A} 1 7 A. REQUIREMENT FOR REPORT This report is required per 10 CFR 50.73 (a)(2)(i)(B). The performance of a Technical Specification (TS) surveillance was missed and, although the NRC has utilized their discretion in agreeing not to exercise enforcement of the TS requirements for this event, it represented operation of the unit in a condition prohibited by the TS.
B. UNIT STATUS AT TIME OF EVENT At the time of this event, Unit 2 was in Mode 1 (Power Operations) at 100% of rated thermal power.
Other than that described herein, there was no inoperable equipment that contributed to the occurrence of this event.
C. DESCRIPTION OF EVENT
On October 26, 2003, personnel were performing TS surveillances on the Solid State Protection System (SSPS). A switch in the test circuit that is used to test memories logic functions would not operate properly in all positions. This prevented successful completion of the surveillance testing for the following functions:
- 1. Memory test for feedwater isolation
- 2. Actuation logic test for feedwater isolation on safety injection or P-14 permissive
- 3. Permissive P-10 block of source range trip The surveillance absolute late date was November 5, 2003. After this time, and following expiration of a 24-hour TS Required Action Completion Time, a unit shutdown would have been required to be initiated per the action requirements of TS 3.3.1, 3.3.2 and 3.0.3. A telephone conversation with NRC personnel was conducted on November 4, 2003. During this conversation, the NRC granted a notice of enforcement discretion (NOED) to allow the TS surveillance requirement to be late without enforcement for a period of 28 days. The 28 days represented a reasonable period of time for a written request, to change the TS, to be processed by the NRC. The TS change allowed the required surveillance testing to be delayed until after the end of the fuel cycle in Spring 2004, or until the next unit shutdown to Mode 5 (Cold Shutdown), whichever comes first. On December 3, 2003, the requested TS change was approved.
NRC Fonr 366A (1-2001)U.S. NUCLEAR REGULATORY COMMISSION (1-2001)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACILITY NAME (1)
DOCKET LER NUMBER (6)
PAGE (3)
YEAR SEQUENTIAL REVISION YEAR NUMBER Vogtle Electric Generating Plant - Unit 2 05000-425 2003 001 00 3 OF 4 rTEXT (if more space is required, use additional copies of NRC Form 366A) (1 7
D. CAUSE OF EVENT
The direct cause of this event was the failure of the test switch to operate properly in all positions.
The root cause of the failure of the test switch will be determined after its removal.
E. ANALYSIS OF EVENT
The switch involved is part of the test circuit only and has no effect on the operation of the SSPS.
There were four options to address this issue. The first was to replace the faulty switch during power operation. This would have involved taking Train B SSPS out of service for at least 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, thus incurring an increase in risk while one train of SSPS is out of service plus the attendant trip risk while working on the SSPS while at power. This alternative was ruled out because of the additional time required beyond the current 24-hour Completion Time to restore a train of SSPS logic and the trip risk. The second option was to shut the unit down to Mode 5 to replace the faulty switch. This would have involved an increase in risk associated with shutting the unit down, plus an additional thermal cycle on the reactor coolant pressure boundary. A third alternative was to complete the required testing using jumpers to mimic the operation of the faulty switch. This would have involved entering the logic cabinet during power operation and installing jumpers which posed a potential trip risk as well as the potential for error. The fourth alternative was to remain at power until the refueling outage scheduled for April 2004. The very small increase in risk associated with this alternative was offset by compensatory actions, and there was no net increase in risk to the health and safety of the public. The compensatory actions included briefing control room operators on the circuits in the Train B SSPS that have not been tested due to the failure of this switch, directing them as to appropriate actions to take in the event of a failure of one of these untested circuits, and increasing operator surveillances of plant parameters indicative of precursors that could challenge the untested functions.
Based on these considerations, there is no adverse effect on plant safety or on the health and safety of the public as a result of this condition.
The event does not represent a safety system functional failure.
F. CORRECTIVE ACTION
- 1) The failed switch will be replaced following the next time the unit enters Mode 5.
NRC Fonn 368A (1-2001)U.S. NUCLEAR REGULATORY COMMISSION (1-2001)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACILITY NAME (1)
DOCKET LER NUMBER (6)
PAGE 3 I ~
~
~~~~~ERI SEU~A REVSIO Vogtle Electric Generating Plant - Unit 2 05000-425 2003 001 l0 4 OF 4 TExM (If more space Is required, use addional copes of NRC Form 368A) (17
- 2) An investigation into the cause of the switch failure will be conducted and further corrective actions will be taken, if appropriate. This may include additional testing or replacing of similar test switches in both Unit 1 and Unit 2.
G. ADDITIONAL INFORMATION
- 1) Failed Component:
Memories test switch manufactured by Grayhill, Inc. / Westinghouse Corp.
Westinghouse Part # 2384A22H10.
- 1) Previous Similar Events:
None
- 3) Energy Industry Identification System Code:
Solid State Protection System - JG Main Feedwater System - SJ Safety Injection System - BQ Nuclear Instrumentation System - JD NRC Form 364A (1-2001)