05000482/LER-2014-001, Regarding Failure to Comply with Required Action of Technical Specification 3.4.3 While Performing a Vacuum Fill of the Reactor Coolant System
| ML14071A304 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 03/06/2014 |
| From: | Camp A Wolf Creek |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| WO 14-0022 LER 14-001-00 | |
| Download: ML14071A304 (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)(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 |
| 4822014001R00 - NRC Website | |
text
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'NUCEAROPERATING CORPORATION A. J. Camp, Jr Plant Manager March 6, 2014 WO 14-0022 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
Subject:
Docket No. 50-482: Licensee Event Report (LER) 2014-001-00, "Failure to Comply With Required Action of Technical Specification 3.4.3 While Performing a Vacuum Fill of the Reactor Coolant System" Gentlemen:
The enclosed Licensee Event Report (LER) is being submitted pursuant to 10 CFR 50.73(a)(2)(i)(B) as an operation or condition prohibited by Technical Specifications.
This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4110, or Mr. Michael J. Westman at (620) 364-4009.
Sincerely, AJC/rlt Enclosure cc:
M. L. Dapas (NRC), w/e C. F. Lyon (NRC), wle N. F. O'Keefe (NRC), w/e Senior Resident Inspector (NRC), w/e P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNET
tI NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 01131/2017
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- 3. PAGE WOLF CREEK GENERATING STATION 05000 482 1 OF 3
- 4. TITLE Failure to Comply With Required Action of Technical Specification 3.4.3 While Performing a Vacuum Fill of the Reactor Coolant System
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED DAY YEAR YEAR SEQUENTIAL REV FACILITY NAME DOCKET NUMBER MOT A
YA ER NUMBER NO.
MONTH DAY YEAR 05000 01 06 2014 2014-001 00 03 06 2014 FACILITYNAME DOCKET NUMBER 05000
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check althat apply) 1E20.2201 (b) 020.2203(a)(3)(i)
E]50.73(a)(2)(i)(C)
[D50.73(a)(2)(vii) 1[--]20.2201 (d)
--] 20.2203(a)(3)(ii)
[]50.73(a)(2)(ii)(A) 0*50.73(a)(2)(viii)(A) 0120.2203(a)(1) 1[120.2203(a)(4) 150.73(a)(2)(ii)(B) 1[150.73(a)(2)(viii)(B) i--]20.2203(a)(2)(i)
[:150.36(c)(1 )(i)(A)
[]50.73(a)(2)(iii)
[:150.73(a)(2)(ix)(A)
- 10. POWER LEVEL [120.2203(a)(2)(ii)
[:] 50.36(c)(1 )(ii)(A)
[]
50.73(a)(2)(iv)(A)
[]50.73(a)(2)(x)
[--]20.2203(a)(2)(iii)
[J50.36(c)(2)
[Jso.73(a)(2)(v)(A)
[]73.71(a)(4) 100
[:]20.2203(a)(2)(iv)
E] 50.46(a)(3)(ii)
[_]50.73(a)(2)(v)(B)
[-"]73.71 (a)(5) 11 20.2203(a)(2)(v)
[i]50.73(a)(2)(i)(A)
[:
50.73(a)(2)(v)(C)
DjOTHER
['
20.2203(a)(2)(vi)
[El 50.73(a)(2)(i)(B)
[:
50.73(a)(2)(v)(D)
Specify in Abstract below or in
PLANT CONDITIONS PRIOR TO THE EVENT 100 %
Mode 1 There were no structures, components or systems (SSC) that were inoperable at the start of the event and contributed to the event.
DESCRIPTION
During a review of outside operating experience on January 6, 2014, it was discovered that one utility received a non-cited violation of Technical Specification (TS), "Reactor Coolant System (RCS) Pressure and Temperature (P/T) Limits," for failure to comply with reactor pressure vessel pressure/temperature limits. The licensee had operated the plant with a vacuum in the reactor pressure vessel.
Wolf Creek Generating Station (WCGS) Technical Specification 3.4.3, "RCS Pressure and Temperature (P/T) Limits," Limiting Condition of Operation (LCO) 3.4.3 requires the RCS pressure, temperature and heatup and cooldown rates be maintained within the limits specified in the Pressure/Temperature Limits Report (PTLR). The Applicability for LCO 3.4.3 is "At all times." The RCS heatup and cooldown limitations in the PTLR only specify a pressure to 0 psig. WCGS draws a vacuum on the RCS [EIIS: AB]
at the end of refueling outages to fill the RCS, using procedure SYS BB-112, "Vacuum Fill of the RCS."
During the performance of SYS BB-112, a vacuum is drawn on the RCS to between 20 inches Hg and 24 inches Hg.
A review of operating history for the last three years found that WCGS drew a vacuum on the RCS on May 8, 2011 and March 30, 2013.
REPORTABILITY
NUREG-1 022, Event Reporting Guidelines, Section 3.2.2, "Operation or Condition Prohibited by Technical Specifications," specifies that a Licensee Event Report is required if a condition existed for a time longer than permitted by the TS even if the condition was not discovered until after the allowable time had elapsed and the condition was rectified immediately upon discovery. Events that occurred within 3 years of the date of discovery are reportable.
During the past 3 years, a vacuum was drawn on the RCS on May 8, 2011 and March 30, 2013, using procedure SYS BB-112. TS 3.4.3, "RCS Pressure and Temperature (P/T) Limits," LCO 3.4.3 requires the RCS pressure, temperature and heatup and cooldown rates be maintained within the limits specified in the PTLR. The Applicability for LCO 3.4.3 is "At all times." The RCS heatup and cooldown limitations in the PTLR only specify a pressure to 0 psig.
Since the Applicability of TS 3.4.3 is "At all times," and the PTLR does not provide curves associated with a vacuum in the RCS, the plant was not operating in accordance with the TSs. Required Action C.1 requires initiating action to restore parameter(s) to within limits with a Completion Time of Immediately.
Action was not taken during the performance of SYS BB-112 to restore parameter(s) immediately. TS 1.3, "Completion Times," defines Immediately as pursued without delay and in a controlled manner.
The events that occurred on May 8, 2011 and March 30, 2013 are reportable as an operation or condition prohibited by Technical Specifications pursuant to 10 CFR 50.73(a)(2)(i)(B).
CAUSE
The apparent cause is inadequate engineering evaluation and procedure reviews resulted in allowing operations below PTLR Curve Limits. WCGS implemented a change in the method to which the Reactor Coolant System is filled and vented following a refueling outage without verifying the change complied with Technical Specification 3.4.3. Implementation of vacuum fill and vent of the RCS at WCGS was evaluated in Engineering Evaluation EER 92-BB-02 and implemented by use of SYS BB-112 without reference to the fact that the PTLR curves do not have values less than 0 psig.
CORRECTIVE ACTIONS
Procedure SYS BB-112 was cancelled so a vacuum will not be drawn on the RCS.
SAFETY SIGNIFICANCE
In the development of SYS BB-112, Engineering Evaluation EER 92-BB-02 evaluated the effect of drawing a vacuum on the RCS. Precautions necessary to prevent any system or equipment degradation were incorporated into the procedure. As a result, the reduction in RCS pressure would not affect the integrity of the RCS components.
OPERATING EXPERIENCE/PREVIOUS EVENTS None