05000261/LER-2012-001

LER-2012-001, Technical Specification Required Plant Shutdown Due to Missed Surveillance and Operation Prohibited by Technical Specifications

Docket Number
Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(iv)(A), System Actuation
2612012001R01 - NRC Website

I. DESCRIPTION OF EVENT

Improved Technical Specification (ITS) Limiting Condition for Operation (LCO) 3.8.4 states that Train A and Train B DC electrical power subsystems shall be OPERABLE in Modes 1, 2, 3, and 4. ITS Surveillance Requirement (SR) 3.8.4.6 requires that the operability of Station Batteries [EI:BTRY] be verified every 60 months by conducting a performance capacity test. On January 17, 2012, with H. B.

Robinson Steam Electric Plant (HBRSEP), Unit No. 2, in Mode 1 at 85.5% power, it was determined that SR 3.8.4.6 for the Station-B Battery had become overdue. The last performance of SR 3.8.4.6 on Station-B Battery was completed on October 12, 2005. The frequency for testing is 60 months and with the addition of the 25% grace period, the performance test should have been conducted no later than January 12, 2012.

At 0921 hours0.0107 days <br />0.256 hours <br />0.00152 weeks <br />3.504405e-4 months <br /> (EST) on January 17, 2012 an investigation regarding an Unplanned LCO ENTRY was initiated due to determination that MST-920 for Station Battery-B may not have been completed within its required periodicity plus grace period. This investigation was to perform an Operability Condition Report and had an expiration of 0921 hours0.0107 days <br />0.256 hours <br />0.00152 weeks <br />3.504405e-4 months <br /> (EST) on January 18, 2012.

At 1814 hours0.021 days <br />0.504 hours <br />0.003 weeks <br />6.90227e-4 months <br /> (EST) on January 17, 2012, following discovery of the missed surveillance, plant Operations personnel declared Station-B Battery inoperable and entered the required action for ITS 3.8.4, Condition A, which requires that the DC electrical power subsystem be restored to operable status in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. At 2014 hours0.0233 days <br />0.559 hours <br />0.00333 weeks <br />7.66327e-4 months <br /> (EST), Operations personnel entered the required action for ITS 3.8.4, Condition B due to required actions and associated completion time for Condition A not met.

Condition B requires the unit to be in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> AND be in Mode 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A controlled plant shutdown commenced, in accordance with procedure, at 2223 hours0.0257 days <br />0.618 hours <br />0.00368 weeks <br />8.458515e-4 months <br /> (EST). The reactor was manually tripped at 0038 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br /> (EST) on January 18, 2012.

SR 3.8.4.6 was successfully completed on January 28, 2012, with a recorded capacity of 116.4%.

II. CAUSE OF EVENT

This event was investigated using the HBRSEP, Unit No. 2, Corrective Action Program (CAP) and is documented in CR 509668.

The CR 509668 investigation concluded that HBRSEP, Unit No. 2, does not have an accurate means of monitoring ITS SR due dates and over due dates to support scheduling and completion of SRs required to ensure ITS compliance. The cause was attributed to inadequate procedural controls and inaccurate data.

III. ANALYSIS OF EVENT

There was an initial delay to comply with the LCO. This was the result of an incorrect determination by site personnel that the condition was an operability concern where as it was a compliance issue.

SR 3.8.4.6 requires that the capacity of Station Batteries be verified every 60 months by conducting a performance capacity test. On January 17, 2012, with HBRSEP, Unit No. 2, in Mode 1 at 85.5% power, it was determined that SR 3.8.4.6 for the Station-B Battery had become overdue. As a result of the missed surveillance, the plant completed a Technical Specification required shutdown for failure to meet the Limited Condition of Operation for Direct Current Sources Operating.

The investigation revealed that daily reports, which were used to track surveillance tests, did not include those tasks to be performed offline unless the plant was in an outage. It was further determined that the Preventative Maintenance and Surveillance Testing Administration procedure did not provide sufficient guidance to ensure ITS frequencies, due dates and overdue dates were met.

The condition described in this Licensee Event Report is reportable in accordance with 10 CFR 50.73(a)(2)(i)(A), the completion of any nuclear plant shutdown required by the plant's Technical Specifications, 10 CFR 50.73(a)(2)(i)(B), any operation or condition which was prohibited by the plant's Technical Specifications, and 10 CFR 50.73(a)(2)(iv)(A), any event or condition that resulted in manual or automatic actuation of the Reactor Protection System including a reactor trip.

IV. SAFETY SIGNIFICANCE

Following the discovery of the missed SR, the Performance Capacity Test of Station-B Battery was satisfactorily performed on January 28, 2012, with a recorded capacity of 116.4%, indicating the subject equipment was capable of performing its required safety function during the delinquent surveillance interval. Therefore, based on the above, the event had no adverse impact on the health and safety of the public.

V. CORRECTIVE ACTIONS

Completed Corrective Actions:

• The Performance Capacity Test of Station-B Battery was successfully completed on January 28th, 2012, following a Technical Specification required shutdown.

• An interim method of reporting and reviewing ITS SRs was implemented until a more robust method could be developed.

Planned Corrective Actions:

• Revise frequency codes and calculation methods to provide due dates and late dates that are aligned with or conservative to ITS frequencies, due dates and overdue dates.

• Develop and implement a set of site specific procedures to provide implementing guidance for the coordination of SRs at HBRSEP, Unit No. 2.

VI. PREVIOUS SIMILAR EVENTS:

Licensee Event Reports (LERs) for HBRSEP, Unit No. 2, were reviewed from the past 5 years. No similar events were identified.