ML030410114

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IR 05000458-02-007, on 09/24/2002 - 11/14/2002, Entergy Operations, Inc., River Bend Event Followup
ML030410114
Person / Time
Site: River Bend Entergy icon.png
Issue date: 02/07/2003
From: Graves D
NRC/RGN-IV/DRP/RPB-B
To: Hinnenkamp P
Entergy Operations
References
IR-02-007
Download: ML030410114 (35)


See also: IR 05000458/2002007

Text

February 7, 2003

Paul D. Hinnenkamp, Vice President - Operations

River Bend Station

Entergy Operations, Inc.

P.O. Box 220

St. Francisville, Louisiana 70775

SUBJECT: NRC SPECIAL INSPECTION REPORT 50-458/02-07

Dear Mr. Hinnenkamp:

On November 14, 2002, the NRC completed a Special Inspection at the River Bend Station.

The enclosed report documents the inspection findings which were discussed with you and

members of your staff on November 14, 2002.

The inspectors examined activities associated with a reactor scram and subsequent system

interactions that occurred on September 18, 2002. The inspection was conducted in

accordance with Inspection Procedure 93812, Special Inspection, and the inspection team

charter. The inspectors reviewed selected procedures, records, and evaluation activities. The

inspectors also interviewed plant personnel. As a result of this inspection, the NRC developed

a sequence of events, initiated a risk significance determination of the event, and assessed

your response to and evaluation of the event.

Based on the results of this inspection, the NRC has identified an issue that requires further

analysis to determine the significance. This issue was an apparent violation of Technical Specification 5.4.1.a, which requires the licensee to establish and implement procedures to

operate the condensate system. Condensate Prefilter Vessel Bypass Flow Control

Valve CNM-FCV200 was not locked open as required and constitutes an apparent violation of

this Technical Specification.

The final significance of this apparent violation is to be determined. The issue was initially

characterized as having a safety significance of more than minor. Further determination of

significance will be made through a Phase 3 significance determination analysis by the NRC.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its

enclosure, and your response will be made available electronically for public inspection in the

NRC Public Document Room or from the Publicly Available Records (PARS) component of

NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Entergy Operations, Inc. -2-

Should you have any questions concerning this inspection, we will be pleased to discuss them

with you.

Sincerely,

/RA/

David N. Graves, Chief

Project Branch B

Division of Reactor Projects

Docket: 50-458

License: NPF-47

Enclosure:

NRC Inspection Report

50-458/02-07

cc w/enclosure:

Executive Vice President and

Chief Operating Officer

Entergy Operations, Inc.

P.O. Box 31995

Jackson, Mississippi 39286-1995

Vice President

Operations Support

Entergy Operations, Inc.

P.O. Box 31995

Jackson, Mississippi 39286-1995

General Manager

Plant Operations

River Bend Station

Entergy Operations, Inc.

P.O. Box 220

St. Francisville, Louisiana 70775

Director - Nuclear Safety

River Bend Station

Entergy Operations, Inc.

P.O. Box 220

St. Francisville, Louisiana 70775

Entergy Operations, Inc. -3-

Wise, Carter, Child & Caraway

P.O. Box 651

Jackson, Mississippi 39205

Mark J. Wetterhahn, Esq.

Winston & Strawn

1401 L Street, N.W.

Washington, DC 20005-3502

Manager - Licensing

River Bend Station

Entergy Operations, Inc.

P.O. Box 220

St. Francisville, Louisiana 70775

The Honorable Richard P. Ieyoub

Attorney General

Department of Justice

State of Louisiana

P.O. Box 94005

Baton Rouge, Louisiana 70804-9005

H. Anne Plettinger

3456 Villa Rose Drive

Baton Rouge, Louisiana 70806

President

West Feliciana Parish Police Jury

P.O. Box 1921

St. Francisville, Louisiana 70775

Michael E. Henry, State Liaison Officer

Department of Environmental Quality

P.O. Box 82135

Baton Rouge, Louisiana 70884-2135

Brian Almon

Public Utility Commission

William B. Travis Building

P.O. Box 13326

1701 North Congress Avenue

Austin, Texas 78701-3326

Entergy Operations, Inc. -4-

Technological Services

Branch Chief

FEMA Region VI

800 North Loop 288

Federal Regional Center

Denton, Texas 76201-3698

Entergy Operations, Inc. -5-

Electronic distribution by RIV:

Regional Administrator (EWM)

DRP Director (ATH)

DRS Director (DDC)

Senior Resident Inspector (PJA)

Branch Chief, DRP/B (DNG)

Senior Project Engineer, DRP/B (RAK1)

Staff Chief, DRP/TSS (PHH)

RITS Coordinator (NBH)

Scott Morris (SAM1)

RBS Site Secretary (LGD)

W. Maier (WAM)

D. Thatcher (DFT)

R:\_RB\2002\RB2002-07RP-MOM.wpd

RIV:RI:DRP/B DRS/OB DRS/PSB C:DRP/B

MOMiller JFDrake JSDodson DNGraves

/RA/ /RA/ E - DNGraves /RA/

1/16/03 1/6/03 1/7/03 2/7/03

OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

ENCLOSURE

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 50-458

License: NPF-47

Report: 50-458/02-07

Licensee: Entergy Operations, Inc.

Facility: River Bend Station

Location: 5485 U.S. Highway 61

St. Francisville, Louisiana

Dates: September 24 through November 14, 2002

Inspectors: M. O. Miller, Resident Inspector River Bend Station, Team Leader

J. S. Dodson, Project Engineer

J. F. Drake, Operations Engineer

Approved By: D. N. Graves, Chief, Project Branch B

ATTACHMENT: Special Inspection Charter

TABLE OF CONTENTS

SUMMARY OF FINDINGS

REPORT DETAILS

1 Special Inspection Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

2 Event Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

2.1 Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

2.2 Details . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Reactor Power Response

Reactor Pressure Response

Reactor Water Level Response

Feedwater and Condensate Systems Response

CNM-FCV200, Condensate Pre-Filter Vessel Bypass Flow Control Valve

CRD System Response

3 Special Inspection Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

3.1 Sequence of Events . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

3.2 Operator Response . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

3.3 Unmonitored Release Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

3.4 Posttrip Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

3.5 Root Cause Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

3.6 Risk Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

3.7 10 CFR 50.72 Report Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

4 Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

ATTACHMENT:

Special Inspection Charter

SUMMARY OF FINDINGS

River Bend Station

NRC Inspection Report 50-458/02-07

IR 50-458/02-07; Entergy Operations, Inc.; on 09/24/2002-11/14/2002; River Bend Station.

Special Inspection Report. Event Followup.

The report covers a special inspection conducted by Region IV inspectors concerning a reactor

scram with a loss of the condensate and feedwater systems and the condensate storage tank

discharge of steam. The significance of most findings is indicated by their color (Green, White,

Yellow, or Red) using Inspection Manual Chapter 0609, Significance Determination Process.

Findings for which the Significance Determination Process does not apply are indicated by the

severity level of the applicable violation. The NRCs program for overseeing the safe operation

of commercial nuclear power reactors is described at its Reactor Oversight Process website at

http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/index.html.

A. Inspector Identified Findings

Cornerstone: Mitigating Systems

  • (to be determined) The inspectors identified an apparent violation of Technical

Specification 5.4.1.a, which requires that written procedures be established,

implemented, and maintained covering the applicable procedures recommended in

Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33,

Revision 2, Appendix A, Item 4.n requires instructions for operation of the condensate

system.

System Operating Procedure SOP-0007, Condensate System, Revision 21, required

Condensate Prefilter Vessel Bypass Flow Control Valve CNM-FCV200 to be locked

open. On September 18, 2002, Valve CNM-FCV200 was found to be not properly

locked open. The failure to properly lock Valve CNM-FCV200 in the open position

resulted in unexpected closure of the valve and a loss of feedwater flow to the reactor

vessel following a reactor scram.

The final significance of this issue will be determined using the Significance

Determination Process (Section 3.5).

REPORT DETAILS

1 Special Inspection Activities

The NRC conducted this special inspection to better understand the circumstances

surrounding a malfunction in the turbine control system, the subsequent reactor scram,

loss of feedwater, and a discharge of steam from the Condensate Storage Tank (CST)

that occurred on September 18, 2002. The decision to conduct a special inspection was

based on these collective factors:

  • The licensees risk evaluation documented a Conditional Core Damage

Probability for the scram as 9.3E-7. This was statistically equivalent to the

threshold (1E-6) established in Manual Chapter 8.3 for conducting special

inspections.

  • The event included an unexpected loss of feedwater.
  • Steam was unexpectedly released from the CST.

The inspectors used Inspection Procedure 93812, Special Inspection, to conduct the

inspection. The team reviewed procedures, logs, instrumentation printouts, corrective

action documents, and design and maintenance records for the equipment of concern.

The team interviewed key station personnel regarding the event and subsequent

posttrip review investigation.

2 Event Description

2.1 Summary

On September 18, 2002, at 8:24 p.m. with the plant at full power, a turbine control

system malfunction caused the turbine control and intercept valves to slowly close. The

turbine bypass valves (BPVs) opened in response to the increase in steam line

pressure. An upscale neutron flux automatic reactor scram occurred 3.5 seconds after

the onset of the transient. When reactor water level began to decrease following the

scram, feedwater flow increased. This caused Condensate Prefilter Vessel Bypass

Flow Control Valve CNM-FCV200 to close unexpectedly, isolating the condensate

system from the feedwater system. The reactor feedwater pumps (RFP) tripped on low

suction pressure shortly after Valve CNM-FCV200 closed. A reactor low water level

alarm (Level 3) was received as reactor water level continued to decrease.

The operators manually started reactor core isolation cooling (RCIC), stabilized the plant

in Mode 3, Hot Shutdown, controlled reactor water level between +10 and +51 inches on

narrow range (NR) reactor water level instruments, and maintained reactor pressure

between 500 and 1090 psig using the turbine BPVs.

Operators in the turbine building reported water coming from under the doors to each

Steam Jet Air Ejector (SJAE) room. The reactor operators shut down the condensate

pumps and nuclear equipment operators (NEO) isolated the SJAE intercondensers to

terminate the water coming from the SJAE rooms.

At approximately 10 p.m., an inspector arriving onsite observed a plume of steam

coming from the CST vent. In addition, loud banging noises were noted coming from

the CST. The inspector notified control room personnel of these observations. It was

later determined that water was flowing from the reactor water cleanup system (RWCU)

filter demineralizers to the CST via the feedwater and condensate system.

2.2 Details

At 8:24 p.m., a transient in the +22 volt supply to the turbine control system caused the

turbine control valves and intercept valves to slowly close. The BPVs opened

automatically to control reactor pressure as designed. When the BPVs reached their full

open position and the turbine control valves continued to close, reactor pressure

increased to 1087.6 psig. This pressure increase resulted in a reactor power increase

and reactor water level decrease.

Reactor Power Response

Approximately 3.5 seconds into the transient, the average power range monitor (APRM)

system generated a scram signal on upscale neutron flux from five of the eight APRMs.

The licensee analysis showed that a relatively slow transient of this type could be

expected to trip sufficient APRM channels to terminate the transient without causing all

channels to trip. The highest rated thermal power value recorded was 121.99 percent

rated thermal power on APRM E. Licensee analysis of the core thermal performance

showed that no core thermal limit was exceeded.

Reactor Pressure Response

The maximum reactor pressure of 1087.6 psig was reached approximately 4.4 seconds

into the transient. This was less than one second after the scram was initiated. The

scram terminated the pressure transient. There were no reactor safety relief valve

actuations because the maximum pressure reached was below the minimum lift setpoint

of 1133 psig.

Reactor Water Level Response

Prior to the event, reactor water level was in the normal range at 36 inches as indicated

by the NR level indicators. At the same time, the average reactor water level was

21.8 inches as indicated on the wide range (WR) reactor water level instruments. The

WR level instruments normally indicate lower than the NR instruments due to the

recirculation pump suction effect on the pressure at the WR level instrument variable leg

sensing taps. The higher the power level (therefore the higher the reactor recirculation

system flow) the lower the indicated reactor water level on the WR level instruments.

At 3.4 seconds from the start of the turbine control system malfunction (just prior to the

scram), the average WR level instruments indicated 17.73 inches. When the scram was

initiated, the reduction in reactor power caused a further reduction in reactor water level

as the steam voids in the core collapsed. At 9.42 seconds from the start of the turbine

control system malfunction, reactor water level stopped decreasing at -24 inches, as

indicated on the WR level instruments.

As a result of the decrease in reactor water level, feedwater flow increased and reactor

water level reached about +20 inches when the feedwater flow was lost (at

approximately 35 seconds into the event). This caused reactor water level to drop again

quickly to about zero inches. Over the next 9 minutes, reactor water level continued to

decrease because the turbine control valves were not yet completely shut. At 8:33 p.m.,

the turbine control valves closed when the turbine tripped. Reactor water level reached

-21 inches WR before the operators manually started RCIC and restored reactor water

level.

Feedwater and Condensate Systems Response

Following the scram, the feedwater flow control valves opened in response to lowering

reactor water level. This increased feedwater flow caused Condensate Prefilter Vessel

Bypass Flow Control Valve CNM-FCV200 to close unexpectedly (Figure 1).

The closure of Valve CNM-FCV200 isolated flow to the RFPs and they tripped on low

suction pressure. When Valve CNM-FCV200 closed, condensate system pressure

increased to greater than 800 psig for a short duration (less than one second). The

gaskets on the SJAE intercondensers failed as a result of the pressure surge. The

failed gaskets allowed the condensate pumps to transfer water from the hotwell to the

turbine building 95 foot elevation. At 8:33 p.m., the operators shut down the condensate

pumps to stop this transfer of water.

Flow in the feedwater system and much of the condensate system stopped when

Valve CNM-FCV200

closed, which, in turn,

caused the condensate

system and RFP

minimum flow valves to

open. This created a

flowpath to vacuum-drag

water from the feedwater

and condensate systems

to the hotwell, which was

still under condenser

vacuum. Interlocks

closed the minimum flow

valves when the RFPs Figure 1

tripped and the

condensate pumps were

shut down.

The resulting high hotwell level caused condenser hotwell reject level control

Valve CNS-LCV105 to the CST to open.

When CNS-LCV105 opened, it created

an abnormal and reverse flowpath from

the condensate and feedwater systems

to the CST (Figure 2).

The RWCU system, which takes suction

from the reactor recirculation system and

discharges to the feedwater lines, was in

service at the time of the event. At

8:25 p.m., immediately after the RFPs Figure 2

tripped, RWCU flow increased rapidly.

As the feedwater system depressurized

(due to RFP and condensate minimum flow

valves being open to the main condenser)

the flow path for RWCU was from the

reactor recirculation system, through

RWCU filter demineralizers, backwards

through feedwater Line B into the

feedwater and condensate systems

(Figure 3). A check valve on feedwater

Line A prevented a similar flowpath through Figure 3

feedwater Line A. The check valve on

feedwater Line A had been installed to

prevent reverse flow in the feedwater system during RCIC injection.

There were two separate flowpaths from the condensate system into the CST

discharging 200 psig fluid that was between 356 and 378EF. One flowpath was through

Valve CNS-LV105. This line terminates in the CST below the surface of the water. The

water in the CST was cooler

and quenched the flashing

steam, which accounted for

the loud noises. The second

flow path was through the

control rod drive (CRD)

pumps minimum flow line and

into the space above the water

level in the CST. That fluid

was flashing into steam and

issuing from the vent on the

roof of the CST. The

operators closed Valve CNS-

LCV105 at 11:30 p.m., which

Figure 4

isolated one of the two flowpaths of water from RWCU to the CST. At 11:36 p.m. the

operators closed the low pressure feedwater heater inlet valves to start a condensate

pump. This isolated the remaining path of water from RWCU to the CRD to the CST,

and temperatures in the condensate and feedwater system began to return to their

normal values (Figure 4).

Condensate Prefilter Vessel Bypass Flow

Control Valve CNM-FCV200

The licensee had previously developed a

plant modification to install full flow filtration

equipment (prefilters) in the condensate

system. The licensee planned to install the

modification in two phases. The first phase

of the modification was installed in May

2002. The installed portion of the Figure 5

modification included Condensate Prefilter

Vessel Bypass Flow Control Valve CNM-

FCV200 (Figure 5).

CNM-FCV200 was a triple eccentric metal seated valve,

similar to a butterfly valve. The valve actuator was air-

operated with a handwheel for manual operation.

The photos on the right were taken with the handwheel

engaged and the handwheel disengaged. When the lever

was in the engaged position (moved to the left as shown in

the top photo), the handwheel was physically connected to

the valve through gears. Chaining the handwheel would then

keep the valve from moving. When the lever was in the Handwheel engaged

disengaged position (moved to the right as shown in

the lower photo), the valve was not connected to the

handwheel.

Because the handwheel was disengaged, the only

thing holding the valve open was friction from the

packing and internal components and the weight of the

disc. When flow through the valve increased

suddenly, as occurred when the feedwater system

tried to restore reactor water level following the scram,

the force on the disc was enough to cause the valve to

go closed. Handwheel Disengaged

CRD System Response

Design

The CRD system contains two pumps, with one pump normally running. The pump

takes a suction from the condensate system and supplies high pressure water to the

control rod hydraulic control units for normal control rod movement and control rod

scram functions. A portion of the CRD pump discharge flow is diverted through the

minimum flow bypass line to the CST. This flow is controlled by an orifice and is

sufficient to prevent pump damage if the pump discharge was inadvertently closed.

Condensate water to the CRD system is processed by two sets of filters. The CRD

pump suction filters are disposable element type with a 25-micron absolute rating. A

250-micron strainer in the CRD suction filter bypass line protects the CRD pumps when

the filters are being serviced. Downstream of the CRD pumps are two parallel drive

water filters which have a filtration rating ranging from 50-micron to 15-micron absolute.

A differential pressure indicator and main control room alarm monitor the in-service

suction filter element as it collects foreign materials. A similar arrangement is provided

for the drive water filters.

CRD Pump Suction Filters and Drive Water Filter

Normally, the suction supply to the CRD pumps was from the condensate system.

When pressure in the condensate system decreased to less than that from the head of

water in the CST, the CST became the suction source. When this occurred, the suction

filter differential-pressure alarm annunciated. The operators responded to the high

differential-pressure annunciator by implementing the alarm response procedure. The

operators bypassed the suction filter and placed the standby drive water filter in service.

The CRD suction filter was found to be fouled with red iron oxide debris. The licensee

stated that this was not an unusual occurrence when the CRD pump suction shifted

from the condensate system to the CST.

Temperature Response

The normal temperature in the part of the condensate system upstream of the feedwater

heaters was approximately 180EF. During the transient on September 18, 2002,

condensate temperature increased to approximately 350EF due to RWCU flow through

the system from about 9:40 p.m. until 11:15 p.m. The inservice CRD pump was

cavitating during this time as a result of the high temperature in the CRD pump suction.

The following was a list of CRD Loads:

  • Reactor water level reference leg backfill

While the CRD pump was cavitating, there was no flow through the charging or drive

headers. Therefore, these headers were not subjected to the higher condensate

system temperatures. These headers acted as a thermal barrier between the CRD

pumps and control rod hydraulic control units. The scram occurred at 8:25 p.m. with

CRD suction temperature at 128EF. At 8:58 p.m., the scram was reset and CRD pump

suction temperature had increased to 143EF as a result of residual heat in the low

pressure feedwater heaters. The temperature remained about 143EF for approximately

35 minutes following the scram reset. At the time of the scram reset, the CRD flow

control valves were closed, diverting flow to the charging header. The scram

accumulators were fully charged approximately 10 minutes later, before the temperature

of the water supply to the CRD pumps began to increase from RWCU flow. When the

scram accumulators were fully charged, the CRD flow control valve began to open,

redirecting flow to the cooling water header. Therefore, the scram accumulators were

not exposed to the elevated condensate water temperatures.

CRD fluid temperature peaked at approximately 350EF at 10 p.m. As CRD fluid

temperature began to increase, flow was supplied to the cooling water header and then

to the CRD mechanisms. The CRD mechanisms were normally exposed to high

temperatures and can withstand temperatures in excess of 500EF. Therefore, based on

the observed temperatures and design capabilities of the mechanisms, no functions

associated with the CRD mechanisms were affected.

High temperature water (350EF) from the CRD system was also being injected into the

reactor recirculation pump seals at a flow rate of 2 gpm per recirculation pump. This

CRD water was cooled by the reactor plant component cooling water system before

injection into the reactor recirculation pump seal cavity area. The highest reactor

recirculation pump seal temperature was 165EF, which was within the normal range. No

seal high temperature alarms were received.

The reactor water level reference leg backfill system was designed to reduce the

probability of step changes in indicated reactor water level caused by steam bubble

formation in the reference leg. The formation of steam bubbles in the reference leg can

force water mass out of the reference leg, which would cause indicated reactor water

level to increase. The steam bubbles then either collapse or vent out of the reference

leg and the indicated reactor water level returns to normal. There were no signs of step

changes in indicated reactor water level seen by the operators or noted during a review

of reactor water level graphs. At the nominal settings of 0.004 to 0.012 gpm through

long, uninsulated, small bore lines that supply the CRD water to the reference legs,

ambient losses to atmosphere would be such that the temperature of the water arriving

at the reference legs would be well below the temperature necessary for step changes

in indicated reactor water level to occur.

3 Special Inspection Areas

3.1 Sequence of Events

a. Inspection Scope

The inspectors developed a sequence of events related to the September 18, 2002,

reactor scram and compared it to the licensees sequence of events to determine if the

event had been accurately reviewed.

b. Background

The inspectors developed a sequence of events related to the identification and

timeliness of actions taken in response to the event of September 18, 2002. The time

line was generated from the sequence of events printout, annunciator log report,

archived operator logs, and interviews with the licensees staff.

This sequence of events was then compared to the licensees sequence of events. The

only differences identified in the licensees sequence of events were minor event

omissions. These were resolved as being related to the level of detail chosen by the

licensee for their sequence of events and had no impact on the licensees ability to

assess the event.

c. Findings

No findings of significance were identified.

3.2 Operator Response

a. Inspection Scope

The inspectors evaluated the adequacy of the operator response to this transient. The

sequence of events log, the annunciator report, and the operator logs were reviewed.

The inspectors also interviewed 10 control room operators and NEOs that were on duty

at the time of the event.

b. Background

The operators implemented the following procedures in response to the reactor scram

and loss of the condensate and feedwater systems:

  • AOP-003, Automatic Isolations, Revision 17B
  • AOP-006, Condensate/Feedwater Failures, Revision 13

The licensed operators recognized the loss of condensate and feedwater systems and

started the RCIC system to maintain reactor water level. The operators placed residual

heat removal Loop A in service to remove the heat of RCIC from the suppression pool.

The licensee was unaware of the steam issuing from the CST vent and the loud noises

in the CST until informed by one of the inspectors. The licensee initially believed that

the source of the steam and noise was RCIC recirculation flow diverted back to the

CST, although this had not been observed in the past. The RWCU flow into the CST

was unintentionally terminated when the low pressure feedwater heater inlet valves were

closed as part of the preparations for starting a condensate pump, almost 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> after

the scram. The source of the vent steam was not determined until after the event was

terminated and the plant response was evaluated by the licensee.

Two NEOs were contaminated upon entering the SJAE rooms to investigate the water

leaking from under the door. The contaminated personnel were properly

decontaminated. No internal exposures occurred.

Fire alarms sounded on the turbine building 67 foot elevation as a result of the paint

melting off the condensate system piping. Operators responded appropriately to the fire

alarms. No injuries were reported.

c. Findings

No findings of significance were identified.

3.3 Unmonitored Release Evaluation

a. Inspection Scope

The inspectors interviewed cognizant personnel and reviewed the CST venting to

atmosphere (unmonitored release) during the event. The following items were reviewed

and compared with regulatory requirements:

C Radiation Section Procedure RSP-0008, Offsite Dose Calculation Manual,

Revision 11

C Condition Reports CR-RBS-2002-01371 and -01372 and current offsite dose

calculations contained in Condition Report CR-RBS-2002-01384

C Evaluation of Potential for Unmonitored Release of Radioactive Material from

Turbine Building during Post SCRAM Period on September 18, 2002, by Davey

Wells, Superintendent Radiation Protection

C Radiological Evaluation of the CST Release, by Senior Environmental

Specialist (1136)

C Technical Requirements Manual Section 3.11, Radioactive Effluents

The inspectors performed independent calculations of the potential radiation release

using RWCU effluent sample data to determine if the licensees calculations were

accurate and no release in excess of 10 CFR Part 50, Appendix I, requirements

occurred.

b. Background

There were two flowpaths of reactor coolant from the reactor to the CST from 9:25 p.m.

until 11:30 p.m. The reactor coolant traveled from the reactor to the RWCU pumps

through two parallel filter demineralizers and into feedwater Line B. Reactor coolant

then flowed backwards through the feedwater system into the condensate system.

Once in the condensate system the reactor coolant had two flowpaths to the CST. One

flowpath was through Condenser Hotwell Reject Level Control Valve CNS-LCV105.

Valve CNS-LCV105 was opened early in the event due to high water level in the hotwell.

At 11:30 p.m., the operators closed Valve CNS-LCV105, isolating this flowpath. The

other flowpath was through the CRD pumps. The CRD pumps normally take suction on

the condensate system. The CRD pump minimum flow line discharges to the CST.

During the event, reactor coolant from the RWCU system, via the condensate system,

and CRD pumps minimum flow line, was being discharged to the CST. At 11:36 p.m.,

the operators closed the low pressure heater string inlet valves to start a condensate

pump. This stopped RWCU flow to the CST.

c. Findings

No findings of significance were identified.

3.4 Posttrip Review

a. Inspection Scope

The inspectors evaluated the adequacy of the licensees posttrip review. Included in this

review was the thoroughness of the licensees assessment of the event, whether

potential complications on the plant systems (i.e., extent of condition) were properly

considered and whether the immediate corrective actions were comprehensive and

appropriate.

b. Background

1. Scram Report and Post-Trip Review Checklist

General Operating Procedure GOP-003, Scram Recovery, Enclosure 1, Post Trip

Review Checklist, dated September 18, 2002, and Enclosure 2, Scram Report, dated

September 18, 2002, were completed and presented to the Operational Safety Review

Committee (OSRC) for review.

The OSRC meeting was held in two parts on September 19, 2002. The first session

reviewed the following items related to a plant restart:

  • GOP-003, Scram Recovery, dated September 18, 2002
  • Cause of the change in feedwater Line B temperature following the scram
  • Cause of the increase in temperature in the CST

The OSRC concluded that no further review of GOP-003 was required and that nuclear

plant response was satisfactory. Four issues required further review:

  • Provide a troubleshooting plan for EHC and plant conditions necessary for that

troubleshooting.

  • Revise report of the reactor feedwater Line B temperature rise to reflect OSRC

discussions relative to RWCU as the source of the elevated temperatures.

  • Correlate CRD flow to the temperature rise in the CST.
  • Provide the results of an assessment of components served by CRD, with regard

to the effect of the high temperature water being pumped by the CRD pumps for

the 3-hour period.

The second OSRC meeting was convened at 12 midnight on September 19, 2002, to

address the four questions remaining from the first OSRC meeting.

The OSRC approved plant restart and unrestricted operation under the following

conditions:

  • The troubleshooting plan as outlined for the EHC system be pursued with

appropriate instrumentation installed for monitoring during power operation, and

  • A mode restraint condition report be written to address the impact of the higher

CRD water temperatures on equipment in the CRD system and answered prior

to entering Mode 2.

The licensee made appropriate entries into their corrective action program. These

corrective actions were assigned and given a due date. The mode restraint corrective

actions were completed prior to entering Mode 2.

2. Licensee Evaluation of Piping and Component Pressure Transient

Operations personnel reported condensate piping coating damage, piping noises during

the reactor scram transient, and water flooding on the turbine building 67 foot and

95 foot elevations. Consequently the licensee conducted two separate walkdowns

(described below) of the condensate and feedwater system. Other than the SJAE

intercondenser gasket failure, no physical damage was observed.

At 1 a.m. on September 19, 2002, the licensee walked down the condensate full flow

filtration area, condensate and feedwater piping, both heater bays on the turbine

building 67 foot elevation, the SJAE rooms on the turbine building 95 foot elevation, the

condenser recycle valve room, and piping/hangers in RFP and condensate pump areas.

This walkdown focused primarily on identifying transient-induced physical damage to

these systems.

The following items were identified:

  • Condensate Prefilter Vessel Bypass Flow Control Valve CNM-FCV200 indicated

80 percent closed. This valve handwheel was normally locked open. This was

immediately reported to the outage control center and the operations shift

manager.

  • Pipe coupling for condensate system flow Element CNM-FE114 leaking
  • Component cooling water to condensate Pump C seal leak

actuator cover

  • Extensive amounts of unidentified debris were noted around several floor drains.

The licensee entered each of these items in the corrective action program and

appropriate corrective actions were taken.

At 8 p.m. on the evening of September 19, 2002, the licensee repeated this walkdown

(with the exception of the full flow filtration) after condensate Pump CNM-P1B had been

placed in service to pressurize the system. This walkdown focused on leak detection

and capturing conditions potentially missed during the first walkdown. Seventeen leaks

were identified as well as a loose pipe clamp and a detached leak seal injector nozzle.

An evaluation of the pressure transient in the piping as a result of the closure of

Valve CNM-FCV200 was also conducted. The value of the pressure used in the

evaluations of piping and components was 925 psig. This value was derived from

failure of the gaskets in the end-bells of the SJAE intercondensers, plant process

computer recordings of the event, and mechanical engineering stress analyses.

An analytical assessment of the condensate piping indicated that static stresses were

allowable up to a maximum pressure of approximately 1850 psig. During a water

hammer event, the stress applied was short in duration and thus the pressure the piping

could withstand was much higher than the allowable static pressure of 1850 psig. The

condensate pressure values were sampled by the plant process computer at

one second intervals. The highest recorded value was approximately 800 psig. Any

pressure higher than this lasted less than one second.

3. Licensee Evaluation of Piping and Component Temperature Transient

A series of events resulted in an increased fluid temperature in the condensate and

other interconnected systems. The temperature transient was an unexpected event and

not evaluated in the design basis of the affected systems. Licensee engineers

evaluated the impact of the temperature on the affected piping, equipment nozzle, pipe

supports, and in-line plant components. It was concluded that the evaluated piping and

plant components were not adversely affected by the temperature transient and can be

relied upon to perform their design functions.

The following was a summation of evaluations for each component:

  • The normal operating temperature of the affected condensate piping ranges

from 142EF to 304EF. The condensate piping and feedwater heaters were not

safety related. The affected piping was qualified to the requirements of

ANSI B31.1. Evaluations concluded that the affected piping, pipe supports, and

equipment nozzles did not exceed the design code allowable values. The effects

of the thermal transient on the instrumentation tubing were bounded by the

existing design.

  • The condensate demineralizers were qualified to a maximum temperature of

175EF for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or less. The maximum temperature transient above 180EF

lasted for less than 5 minutes. The maximum temperature recorded was 238EF

for approximately one minute. Due to the relatively short duration of the thermal

transient and the inherent flexibility of the piping, the effects of the transient on

the piping, pipe supports, and equipment nozzles were considered negligible.

  • The CST was qualified to a temperature of 200EF, higher than the maximum

transient temperature noted during this event (180EF). The line from Condenser

Hotwell Reject Level Control Valve CNS-LCV105 is supported by spring hangers.

Thus this pipe section was very flexible and capable to accommodate expansion

in the riser.

  • The suction and discharge piping of the CRD pumps within the fuel building was

Class II piping and was qualified to an operating temperature of 120EF in pipe

stress calculations. A preliminary review of the calculated maximum stresses

shows that there was sufficient margin to accommodate the effects of the

temperature transient to 350EF, and no code allowables were exceeded.

  • CRD system piping inside the containment and drywell, including recirculating

pump seal purge piping, was qualified by a licensee vendor. A sample review of

the qualifying calculations showed that there was sufficient margin in the piping

thermal stress to accommodate the effects of the temperature increase in the

system for a short duration as permitted by ASME Section III, NC-3612.3.

design temperatures were higher than the transient maximum temperature of

350EF. The feedwater and condensate heater manufacturer was contacted and

concluded that a 350EF temperature in the tube side would not cause adverse

effects on the structural integrity of the heaters.

  • The licensee determined that no damage to the CRD pumps occurred as a result

of the cavitation. The pump was subsequently restarted and proper operation

was observed.

c. Findings

No findings of significance were identified.

3.5 Root Cause Evaluation

a. Inspection Scope

The inspectors reviewed the licensees root cause determinations for completeness and

accuracy. Key assumptions and facts were independently verified.

b. Background

The licensee prepared two Root Cause Analyses.

C Automatic Reactor Scram on High Neutron Flux, dated October 28, 2002

C Closure of Condensate Valve CNM-FCV200, dated November 21, 2002

Generic implications were considered. Each root cause analysis presented evaluations

of previous similar occurrences at other plants and a corrective action plan.

Automatic Reactor Scram on High Neutron Flux

The licensee conducted a Kepner-Trego problem analysis and concluded that the most

likely cause for the event was a momentary bus ground or failure of a power supply.

Short-term corrective actions were completed and included the following:

supplies were replaced.

  • Field cables, wiring, circuitry, connections, and critical card edge connectors

were inspected.

  • Tests with the turbine simulated to be running at 1800 rpm to determine system

response were conducted.

  • A high speed data acquisition system was installed on additional points in the

turbine control system cabinet to obtain additional data if the event should recur.

There were 18 long-term corrective actions identified. Several were completed during

this inspection. The following were representative of the actions:

  • Test removed power supplies, in house and at the vendors facilities. No

malfunctions were identified.

  • Evaluate alternate power supply vendors and alternate configurations.
  • Develop plans and inspect 22vdc bus work.
  • Determine a plan for additional inspections/testing to be performed in the next

refueling outage if cause for the trip was not determined first.

  • Perform additional evaluations of minimum reactor water level reached after the

scram (approximately -24 inches). This was completed satisfactorily.

  • Investigate whether any offsite power line transients occurred around the time of

the event which may have contributed to the event or the plant response after

the event.

Closure of Condensate Prefilter Vessel Bypass Flow Control Valve CNM-FCV200

The licensee employed several methods during this root cause analysis. They included:

  • document reviews
  • personnel interviews
  • field walkdowns
  • barrier analysis
  • TAP root
  • Event and causal factor analysis
  • Entergy standard root cause investigation guide

Two root causes were identified for the closure of Valve CNM-FCV200:

C Failure to meet management expectations

C Failure to follow up on identified problems

For the root cause failure to meet management expectations, seven inappropriate

actions were identified by the licensee:

1. The Valve CNM-FCV200 request was issued with only subtle indication that the

valve was other than what was normally installed in the plant.

2. The training department failed to identify the need for operator training.

3. A component engineer failed to identify different operational aspects of the valve.

4. After providing assurance to management that the valve would not go closed

during manual operation, the responsible engineering analysis was limited to

feedback provided by the vendor, rather than a comprehensive analysis.

5. Following identification of a potential nonfamiliarity with the new valve actuator,

an operator and an engineer failed to resolve the issue.

6. Following difficulty getting the valve open, the organization failed to flag that

personnel did not know how to operate the valve.

7. An operator directed a contractor, who was not a qualified representative, to lock

the valve when he opens it. At the time the valve was locked open, it was within

a tagging boundary and under control of the contractors. No procedural violation

occurred.

For the root cause failure to follow up on identified problems, there were five

inappropriate actions identified:

1. Following identification of a potential nonfamiliarity with the new valve actuator,

an operator and an engineer failed to resolve the issue.

2. An operator identified the need to learn valve operation without capturing in the

process.

3. A procedure writer identified a need to learn valve operation without capturing it

in the process.

4. An untrained operator was assigned to verify valve locked open.

5. A valve lineup change in condensate system operating Procedure SOP-0007 did

not include handwheel engage[d].

The licensee determined that, during the plant modification to install the condensate full

flow filtration system, the construction team installed Valve CNM-FCV200 in the closed

position so that it could be inserted between two flanges. After the valve was installed,

the construction team engaged the manual handwheel and opened the valve. The

intent had been to keep the handwheel engaged with the valve and locked in position.

At some point following opening, however, the handwheel was disengaged from the

valve. The licensee wrapped the handwheel and engaging lever with a chain and put a

padlock on the chain. The licensee believed that the construction workers that opened

the valve also disengaged the handwheel to prevent inadvertent manual operation.

With the handwheel and manual operator disengaged from the valve, the only thing

holding the valve in position was the weight of the valve disc and the friction of the valve

packing on the valve stem. When the scram took place on September 18, 2002,

feedwater flow increased in response to a reactor water level decrease. This increased

feedwater flow, with the handwheel disengaged from the valve, caused Valve CNM-

FCV200 to close unexpectedly.

There was only one other valve in the plant from this particular vendor with a manual

operator, and the manual operator was significantly different and smaller than the valve

used for this application. The Engineering Request for this modification did not call out

this difference and, as a result, the operations and training staff did not recognize a

difference in the operator/valve interface. As a result, training personnel did not obtain

the documents necessary to determine that valve operation would be different. Training

personnel took credit for previous training experience and assumed the new valve was

similar to other valves already installed in the plant.

The inspectors reviewed the licensees assessment of the failure to properly lock open

Valve CNM-FCV200 and the corrective action taken. The licensee appropriately used

their processes to subsequently provide training to all of the operators, and made the

necessary revision to Condensate System Operating Procedure SOP-007.

c. Findings

An apparent violation of Technical Specification 5.4.1.a was identified when the licensee

failed to lock open Condensate Prefilter Vessel Bypass Flow Control

Valve CNM-FCV200, as required by System Operating Procedure SOP-0007,

Condensate System, Revision 21. The risk significance determination was still in

progress when this report was completed. The final risk significance determination has

yet to be determined.

On September 19, 2002, at 1 a.m. following a reactor scram and loss of feedwater on

September 18, 2002, the licensee determined that Valve CNM-FCV200 had not been

properly locked open, as required by procedure. This performance deficiency occurred

on May 15, 2002, when an individual signed a valve lineup affirming Condensate

Prefilter Vessel Bypass Flow Control Valve CNM-FCV200 was locked open. It was not

properly locked open and, as a result, the feedwater flow transient resulting from a

reactor scram on September 18, 2002, caused Valve CNM-FCV200 to close

unexpectedly and cause a complete loss of feedwater. Corrective actions taken or

planned by the licensee have been entered into the licensees corrective action program

as Condition Report CR-RBS-2002-1372.

The inspectors conducted a Phase I significance determination of the performance

deficiency in accordance with Manual Chapter 0609, which led to a Phase II significance

determination. The Phase II analysis indicated that the significance was potentially

greater than very low. The Phase II determination was validated by an NRC Senior

Reactor Analyst (SRA), and a Phase III analysis was initiated. The final risk

determination was in progress at the end of this inspection.

Technical Specification 5.4.1.a requires written procedures be established,

implemented, and maintained covering the applicable procedures recommended in

Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33,

Revision 2, Appendix A, Item 4.n, requires instructions for operation of the condensate

system. System Operating Procedure SOP-0007, Condensate System, Revision 21,

required Condensate Prefilter Vessel Bypass Flow Control Valve CNM-FCV200 to be

locked open. On September 18, 2002, Valve CNM-FCV200 was not properly locked

opened. This is an apparent violation of Technical Specification 5.4.1.a

(50-458/2002-07-01). The licensee has revised Procedure SOP-0007 and trained the

operators on the proper operation Valve CNM-FCV200.

3.6 Risk Analysis

a. Inspection Scope

The inspectors reviewed the licensees risk analysis of the event, as documented by

Entergy Inter-Office Correspondence SA-02-030, Risk Impact of Feedwater System

Out of Service, dated September 27, 2002. An independent risk analysis being

conducted by NRC was in progress at the end of this inspection.

b. Background

The licensee conducted an analysis of the risk impact of the feedwater system being out

of service. The licensee calculated the incremental change in core damage frequency

at 9.3E-7 and concluded that the calculated incremental risk value with the feedwater

out of service for 4 months was nonrisk-significant. Four months was the approximate

time that Condensate Prefilter Vessel Bypass Flow Control Valve CNM-FCV200 was not

properly locked open.

The inspectors examined the significance of this issue by completing Phases 1 and 2

Significance Determination Process (SDP) worksheets in accordance with NRC Manual

Chapter 0609. The evaluations assumed that Valve CNM-FCV200 would have failed

shut during any full power reduction event, that this condition existed for approximately

4 months, that the packing resistance did not change appreciably over that duration, and

that the valve failing closed would result in a complete loss of condensate and feedwater

flow to the reactor. The existing condition was the result of a performance deficiency

(failure to properly lock open Valve CNM-FCV200) affecting the Mitigating Systems

cornerstone and represented a loss of safety function of non-Technical Specification

equipment, specifically the condensate and feedwater systems. The dominant accident

sequences identified from the Phase 2 SDP River Bend Station site-specific

risk-informed notebooks included Table 3.1, Transients (Reactor Trip), Sequence 4;

Table 3.11, Loss of 120 VDC Emergency Division I, Sequences 1, 2, and 3; and

Table 3.12, Loss of 120 VDC Emergency Division II, Sequences 1 and 2. The issue

was mitigated by the fact that all emergency core cooling systems were available. The

Phase 2 SDP evaluation determined that the issue was potentially of greater than minor

safety significance. The Phase 2 analysis was validated by a regional Senior Reactor

Analyst, and a Phase 3 analysis was initiated. The Phase 3 analysis was in progress at

the issuance of this report. Therefore, the final significance of this issue is to be

determined.

c. Findings

No findings of significance were identified.

3.7 10 CFR 50.72 Report Evaluation

a. Inspection Scope

The inspectors reviewed the 10 CFR 50.72 report submitted by the licensee to

determine whether it satisfied the subject reporting requirements.

b. Background

The reactor scram occurred at 8:25 p.m. on September 18, 2002. The NRC Operations

Center was notified at 11:41 p.m. in accordance with 10 CFR 50.72 requirements (Event

Notification 39200).

The licensee completed NRC Form 361, Reactor Plant Event Notification Worksheet,

and transmitted a copy to the NRC Operations Center, in addition to telephone

notification. Several observations were noted by the inspectors in their review of the

completed Form 361. In the description section of the form, the licensee stated The

plant systems performed as required post scram. The cause of the scram was stated

as being still under investigation. In addition, the section of the Event Notification

Worksheet asking Anything Unusual or Not Understood was checked No. The

question Did All Systems Function As Required was checked Yes.

The licensee indicated that their interpretation of the required reporting information was

to focus on the reactor/core, emergency core cooling systems, and other safety-related

systems. The condensate and feedwater systems, the CRD system, the CST, and

RWCU were not safety-related systems, and the licensee did not believe those systems

needed to be addressed as long as the reactor was shut down safely and being

maintained in a safe and shut down condition. With this view in mind, the Event

Notification stated that plant systems performed as required post scram, that nothing

unusual or not understood occurred, and that all systems functioned as required.

The inspectors reviewed the reporting requirements identified in 10 CFR 50.72 and the

guidance provided in NUREG 1022, Event Reporting Guidelines 10 CFR 50.72 and

50.73." Although no regulatory noncompliance was identified, the report to the

Headquarters Operations Center was lacking detail and information regarding the

complexity of the event and the impact the event had on nonsafety-related, although

important, systems.

b. Findings

No findings of significance were identified.

4 Exit Meeting Summary

The inspectors presented the inspection results to Paul D. Hinnenkamp, Vice President

- Operations, and other members of licensee management during an exit meeting on

November 14, 2002. The licensee acknowledged the findings presented.

The inspectors asked the licensee whether or not any materials discussed during the

exit should be considered proprietary. No proprietary information was identified.

ATTACHMENT

SUPPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

Licensee

B. Biggs, Coordinator, Licensing

W. Brian, Director, Engineering

D. Burnett, Superintendent, Chemistry

T. Gates, Manager, System Engineering

W. Holland, Radiation Protection Outage Coordinator

J. Leavines, Manager, Licensing

T. Lynch, Manager, Operations

J. Malara, Manager, Design Engineering

J. McGhee, Manager, Maintenance

D. Mims, General Plant Manager

P. Page, Supervisor, Health Physics

W. Spell, Senior Environmental Specialist

T. Trepanier, Assistant General Manager

W. Trudell, Manager, Corrective Action and Assessment

D. Wells, Superintendent, Radiation Protection

Operators Interviewed

David Bowman, Turbine Building Operator

Kevin Burnett, Auxiliary Control Room Operator

Forrest Drummond, Radwaste Operator/Auxiliary Control Room Operator

Ken Jelks, Control Building Operator

Brian Kelley, Operations Shift Manager

Lemar Palmer, Outside Operator

Eric Pickrell, Reactor Building Operator

Scott Shultz, Unit Operator

Erich Weinfurter, Shift Technical Advisor

Terry Wymore, Control Room Supervisor

ITEMS OPENED AND CLOSED

Opened

50-458/2002-07-01 AV Failure to properly lock open Valve CNM-FCV200

Closed

None

LIST OF ACRONYMS AND INITIALISMS USED

APRM average power range monitor

BPV turbine bypass valves

CFR Code of Federal Regulations

CR-RBS River Bend Station Condition Report

CRD control rod drive

CST condensate storage tank

HCU hydraulic control units

NEO nuclear equipment operator

NR narrow-range

NRC U.S. Nuclear Regulatory Commission

OSRC operational safety review committee

RCIC reactor core isolation cooling system

RFP reactor feedwater pump

RWCU reactor water cleanup system

SDP significance determination process

SJAE steam jet air ejector

SRA senior reactor analyst

WR wide-range

ATTACHMENT TO NRC INSPECTION REPORT 50-458/02-07

September 23, 2002

MEMORANDUM TO: Michael O. Miller, Resident Inspector, River Bend Station

FROM: Ken E. Brockman, Director, Division of Reactor Projects

SUBJECT: SPECIAL INSPECTION CHARTER TO EVALUATE THE RIVER BEND

STATION REACTOR TRIP WITH COMPLICATIONS

In response to the reactor trip that occurred at the River Bend Station on September 18, 2002,

and the subsequent complications due to the isolation of the condensate system and the loss of

physical integrity of the Steam Jet Air Ejector condensers, a Special Inspection Team is being

chartered. You are hereby designated as the Special Inspection Team leader. The Special

Inspection Team will consist of yourself; Mr. James Drake, Reactor Engineer; and James Dodson,

Reactor Inspector. Additional regional resources are available for consultation as needed.

A. Basis

At approximately 8:24 p.m. on September 18, 2002, the River Bend Station scrammed

from 100 percent reactor power due to a high average power range monitor flux trip. All

control rods fully inserted in the core. The cause of the reactor trip and the details

surrounding the subsequent complications in the plant response are currently under

investigation by the licensee. Preliminary evidence indicates that a failure of a control

card within the electrohydraulic control system, resulting in rapid cycling of the turbine

generator bypass valves, may have been the cause for the high power scram.

Following the scram, both steam jet air ejector condensers experienced gasket failures

on the end bells of the condensers, and all reactor feed pumps tripped on low suction

pressure. Operators responded to the condensate system gasket failure by securing all

condensate pumps and manually isolating the steam jet air ejector condensers. With

the loss of condensate to the reactor vessel, operators manually initiated the reactor

core isolation cooling system to maintain the appropriate reactor level and remove

decay heat.

Upon securing the condensate pumps, the control rod drive pumps automatically aligned

suction to the condensate storage tank. Following this transfer, alarms in the control

room indicated high differential pressure conditions on the control rod drive pumps

suction and discharge filters. Operators bypassed the filters and were able to regain

flow. The high differential pressure condition was a result of particulate in the

condensate storage tank being collected in the control rod drive system filters. The

transient causing the steam jet air ejector condenser gasket failure and loss of feed

Michael O. Miller -2-

pump suction pressure were both apparently caused by an inadvertent closure of the

condensate full flow filter bypass valve following the scram.

B. Scope

The team is expected to perform fact-finding in order to address the following:

C Develop a complete sequence of events related to the September 18, 2002,

reactor trip.

C Review the licensees root cause determination for completeness and accuracy.

Independently verify key assumptions and facts.

C Evaluate the adequacy of the operator response to the transient (i.e., timeliness

in initiating manual reactor trip, emergency operating procedure usage, etc.).

C Evaluate the accuracy and completeness of the licensees 10 CFR 50.72 report.

C Review the adequacy of the posttrip review. Include in this review the

thoroughness of their assessment of the event and whether potential

complications on the plant systems (i.e., extent of conditions) were properly

considered, the quality and adequacy of the operability evaluations, and the

comprehensiveness and appropriateness of the immediate and long-term

corrective actions.

C Review the licensees risk analysis of the event.

C Review the event to determine whether there are any generic impact issues

related to the condensate storage tank design of venting to the atmosphere,

controls of all operated valves, foreign material exclusion, and the

appropriateness and concerns of an unmonitored release point.

C. Guidance

Inspection Procedure 93812, "Special Inspection," provides additional guidance to be

used by the Special Inspection Team. Your duties will be as described in Inspection

Procedure 93812. During performance of the Special Inspection, designated team

members are separated from their normal duties and report directly to you. The team is

to emphasize fact-finding in its review of the circumstances surrounding the event, and it

is not the responsibility of the team to examine the regulatory process. Safety concerns

identified that are not directly related to the event should be reported to the Region IV

office for appropriate action.

The Team will report to the site, conduct an entrance, and begin inspection no later than

Tuesday, September 24, 2002. Tentatively, the inspection should be completed by the

close of business on September 27, 2002, with a report documenting the results of the

inspection issued within 30 days of the completion of the inspection. While the team is

Michael O. Miller -3-

on site, you will provide daily status briefings to Region IV management, who will

coordinate with NRR to ensure that all other parties are kept informed.

This Charter may be modified should the team develop significant new information that

warrants review. Should you have any questions concerning this Charter, contact Ken

Brockman, Director, Division of Reactor Projects at (817) 860-8248.

cc:

E. Merschoff

T. Gwynn

S. Morris

W. Ruland

A. Howell

M. Webb

A. Gody

D. Graves

P. Alter