ML20042A276

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Discusses 811126 Auxiliary Feedwater Pump Event & Selection of Severity Level.Inadequate Evaluation Which Resulted W/Pump Failures Constitutes Severity Level IV Violation. Lists Matters Considered in Evaluation
ML20042A276
Person / Time
Site: Zion File:ZionSolutions icon.png
Issue date: 03/15/1982
From: Warnick R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Lieberman J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
NUDOCS 8203230276
Download: ML20042A276 (2)


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MEMORANDUM FOR:

J. Lieberman, Acting Director, Enforcement Staff, IE FROM:

R. F. Warnick, Director, Enforcement and Investigation Staff, RIII

SUBJECT:

ZION 2, AUXILIARY FEED PUMP EVENT - SELECTION OF SEVERITY LEVEL We held an enforcement cor'erence on February 22, 1982 with Commonwealth Edison personnel to discuss circumstances surrounding the failure of the 2B and 2C auxiliary feedwater pumps to start in response to operator action on November 26, 1981. Using the Interim Enforcement Policy as guidance, we conclude that the inadequate evaluation which resulted with pump failures constitutes a Severity Level IV violation.

The following matters were considered in our evaluation:

During a recent outage on Zion, Unit 2, the low suction pressure trip set-points on the 2A, 2B and 2C auxiliary feedwater pumps were changed without the performance of a safety evaluation as required by 10 CFR 50.59.

As a result, the 2B and 2C auxiliary feedwater pumps would trip on low suction pressure immediately following an automatic or manual start, if the dis-charges were throttled to design flow (105 gpm per steam generator per pump or 420 gpm per pump). This was discovered on November 26, 1981, while Unit 2 was undergoing low power physics testing (~3% power). Operators attempted to manually start the 2B and 2C auxiliary feedwater pumps with the discharges throttled to design flow and the pumps immediately tripped on low suction pressure. At the time, the turbine driven pump (2A) was considered to be inoperable in that its surveillance interval had been exceeded. The main feedwater system was operable, but, was not required.

Decay heat was minimal since the plant was just starting up after an extended outage. The 2B and 2C auxiliary feedwater pumps were being operated intermittantly to provide water to the steam generators.

It should also be noted that the 2B and 2C auxiliary feedwater pumps had been demonstrated operable in accordance with technical specifications.

The licensee immediately took appropriate remedial action. The pumps were started with the discharge valves closed and the pumps were left running on recirculation flow. The nuction pressure setpoints were then adjusted to their proper setting. The pumps were then available to operators to main-tain steam generator level by throttling the discharges as necessary. This was accomplished within minutes after discovery of the incorrect pressure setpoints, well within the action time of Technical Specification 3.7.

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We believe that the facility change did not constitute an unreviewed safety question requiring a license amendment, since the loss of auxiliary feedwater system operability and availability was considered and addressed in the Technical Specification Action Statement time limits.

In other words, the facility change did not, in our opinion, result in the violation of e Limiting Condition for Operation.

We believe this to be a Severity Level IV violation in accordance with the Interim Enforcement Policy, Supplement 1, Criterion IV, which states

" Violation of 10 CFR 50.59 which does not result in a Severity Level I, II or III violation."

We are planning to issue a Severity Level IV Notice of violation seven days after the date of this memo. Please let us know within seven days if you have any objections.

R. F. Warnick, Director Enforcement and Investigation Staff 4

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