ML18039A607

LER 98-005-00:on 981014,mode Changes Not Allowed by TS 3.0.4 Were Made During Reactor Startup.Caused by TS LCO 3.0.4 Not Being Properly Applied.Training Info Memo Re Proper Application for TS LCO 3.0.4 Was Prepared.With 981112 Ltr

ML18039A607
Person / Time
Site:	Browns Ferry
Issue date:	11/12/1998
From:	Morris B, Singer K TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-98-005, LER-98-5, NUDOCS 9811170324
Download: ML18039A607 (16)

Text

t'a.j.et'vms REGULAT INFORMATION DISTRIBUTIO STEM-(RIDS)'CCESSION NBR:9811170324 DOC.DATE: 98/11/12 NOTARIZED:

NO DOCKET FACXL:50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH.NAME, AUTHOR AFFILIATION MORR(S,B.C.

Tennessee Valley Authority SINGER,K.W.

Tennessee Valley Authority RECXP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 98-005-00:on 981014,mode changes not allowed by TS 3.0.4 were made during reactor startup.Caused by TS LCO 3.0.4 not being properly applied..Training info memo re proper application for TS LCO 3.0.4 was prepared.With 981112 ltr.DISTRIBUTION CODE: IE22T.COPIES RECEIVED:LTR ENCL SIZE: TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc.NOTES: E[RECIPIENT ZD CODE/NAME PD2-3-PD'NTERNAL: ACRS AEOD/SPD/RRAB NRR/DE/ECGB NRR/DE/EMEB NRR/DRCH/HOHB NRR/DRPM/PECB RES/DET/EIB EXTERNAL: L ST LOBBY WARD NOAC POORE,W.NRC PDR COPIES LTTR ENCL 1 1 1 1 1-1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ZD CODE/NAME DEAGAZIO,A AEOD B NRR/DE/EELB NRR/DRCH/HZCB NRR/DRCH/HQMB NRR/DSSA/SPLB RGN2 FILE 01 LZTCO BRYCE,J H NOAC QUEENER,DS NUDOCS FULL TXT COPIES LTTR ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1-.1 1 1 1 1 C NOTE TO ALL"RZDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE.TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION'-LZSTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)ON EXTENSION 415-2083 FULL.TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 23 ENCL 23 II Tennessee Valley Authority, Post Office Box 2000, Decatur, Alabama 35609-2000 Karl W.Singer Vice President, Browns Ferry Nuclear Plant November 12, 1998 U.S.Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.20555

Dear Sir:

10 CFR 50.73 BROWNS FERRY NUCLEAR PLANT (BFN)-UNIT 3-DOCKET NO.50-296 FACILITY OPERATING LICENSE DPR-68-LICENSEE EVENT REPORT (LER)50-,296/1998005 The enclosed report provides details concerning two instances of not meeting the mode change requirements of Technical Specifications (TS)Limiting Condition for Operation 3.0.4 during a recent Unit 3 startup.This report is submitted in accordance with 10 CFR 50.73 (a)(2)(i)(B)as an operation prohibited by plant TS.Karl W.x ger cc: See page 2 98iii70324

'tfsiii2 PDR ADOCK 05000296 8'DR%~

0 U.S.Nuclear Regulatory Commission Page 2 November 12, 1998 Enclosure cc (Enclosure):

Mr.A.W.De Agazio, Project Manager U.S.Nuclear Regulatory'ommission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 Mr.H.O.Christensen, Branch Chief U.S.Nuclear Regulatory Commission.

Region II Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303-3415 NRC Resident Inspector-Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611 Mr.L.Raghavan, Project Manager U.S.Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 li C%~, I NRC FORM 366 I6-1998)U.S.EAR REGULATORY COMMISSION LlCENSEE EVENT REPORT (LER)(See reverse for required number of digits/characte'rs for each block)APPRO Y OMB NO.3160-0104 EKPIRES oe/30/2001 Estimated burden per response to comply with this mandatory information collection request: 50 hrs.Reported lessons learned are ncoorporated into the licensing process and fed back to Industry.Forward comments regarding burden estimate to the Records Management 8ranch (T4 F33), U.S.Nuclear Reguhtory Commission.

Washington, OC 205554001, and to the Paperwork Reducdon Project (31504104), Otrice of Management and Budget.Washington, DC 20503.If an information collection does not display a currently valid OMB control number.the NRC may not conduct or sponsor, and a person is not required to respond to.the Informatkrn cotlection.

FACIUT Y NAME ul Browns Ferry Nuclear Plant Unit 3 DOCKET NUMBER (2l 05000296 PAGE l3l 1 of 5 TITLE t4)Mode Changes Not Allowed by Technical Specifications 3.0.4 Made During Reactor Startup EVENT DATE (5)DAY YEAR LER NUMBER (6)YEAR SEQUENTIAL REVISION NUMBER NVMBER REPORT DATE (7)MONTH DAY OTHER FACILITIES INVOLVED (8)DOCKET NUMBER FACIUTY NAME NA DOCKETNVMBER 10 14 98 1998-005-0 12 98 OPERATING MODE (9)POWER LEVEL (10)001 20.2201(b) 20.2203(a)

(1)20.2203(a)(2)(i)20.2203(a)(2)(v)20.2203(a)

(3)(I)20.2203(a)

(3)(ii)X 50.73(a)(2)(i)(B) 50.73(a)(2)(ii) 50.73(a)(2)(iii) 50.73 (a)(2)(viii)50.73(a)(2)(x)73.71 THIS REPORT IS SUBMITTED PURSUANT To THE REQUIREMENTS OF 10 CFR 51 (Check one or more)(11)20.2203(a)

(2)(ii)20.2203(a)

(2)(iii)20.2203(a)

(2)(iv)20.2203(a)

(4)50.36(c)(1)50.36(c)(2)'LICENSEE CONTACT FOR THIS LER (12)50.73(a)(2)(iv)50.73(a)(2)(v)50.73(a)(2)(vii)OTHER Specify In Abstract below or In NRC Form 366A Bertram C.Morris, Senior Licensing Project Manager TELEPHONE NUMBER (Ir>>dude Area Code)(256)729-7909 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TO NPRDS CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TO NPRDS SUPPLEMENTAL REPORT EXPECTED (14)YES (If yas, complete EXPECTED SUBMISSION DATE).x No EXPECTED SUBMISSION DATE (15)MONTH 0AY YEAR During the reactor startup from the Unit 3 Cycle 8 refueling outage on October 14, 1998, the requirements of Technical Specifications (TS)Limiting Condition for Operation (LCO)3.0.4 were not met on two occasions.

Specifically, the High Pressure Coolant Injection (HPCI)system had been removed from service to support scheduled valve testing activities.

With the reactor in Mode 2, startup operations proceeded and the LCO for an inoperable HPCI system was entered in accordance with TS 3.5.1 prior to reactor pressure increasing to 150 psig.However, TS 3.0.4 was violated when reactor pressure increased above 150 psig as startup continued.

HPCI was subsequently returned to service and then again declared inoperable to conduct the TS required HPCI flow rate surveillance at normal reactor pressure.Startup activities continued in order to achieve the rated pressure condition and the mode switch was transferred from Mode 2 to Mode 1 (Run Mode).This mode switch change was prohibited by TS LCO 3.0.4 since HPCI was still inoperable for surveillance testing at the time of the switch transfer The event analysis determined the primary cause for the events was deficient operator knowledge on the proper application and interpretation of TS LCO 3.0.4.Hence, previous operator training on this section of the Improved TS was deemed not fully effective.

As a prompt corrective action, a training memorandum on TS LCO 3.0.4 requirements was prepared and provided to Operations shift personnel during stand down meetings.To further improve operator understanding, retraining on TS LCO 3.0.4 and the TS Section 3.0 LCO Applicability provisions will be presented during operator requalification training.Also, the reactor startup and shutdown operating procedures will be revised to include improved procedural instructions for verifying requirements are met for making mode changes and for entering othe'r specified conditions in TS Applicability statements.

• This report is submitted in accordance with 10 CFR 50.73 (a)(2)(i)(B) as an operation prohibited by plant TS.NRC FORM 366B (6-1998)

~i NRC FORM 366A Ia-I 998)LICENSEE EVENT REPORT (LER)TEXT CONTINUATION.S.NUCLEAR REGULATORY COMMISSION FACILITY NAME 1 Browns Ferry Nuclear Plant-Unit 3 DOCKET 05000296 LER NUMBER 6 YEAR SEQUENTIAL REVISION NUMBER 1 998-005-00 PAGE 3 2of 5 TEXT llf more spaceis required, use additional copies of NRC Form 366Ai{17)I.PLANT CONDITION(S)

Prior to this event, Unit 3 was starting up from a refueling outage.Unit 2 was in Mode 1 at 100 percent power.Unit 1 was shutdown and defueled.II.DESCRIPTION OF EVENT A.Event: During initial reactor startup on October 14, 1998, following the recent Unit 3 cycle 8 refueling outage, the requirements of Technical Specifications (TS)Limiting Condition for Operation (LCO)'.0.4 for mode changes were not met on two occasions.

In the first case, with the Unit 3 reactor in startup operations (Mode 2), reactor pressure was being increased.

TS 3.5.1 requires High Pressure Coolant Injection:(MPCI)

[BG]system operability above 150 psig and HPCI had been declared inoperable since, earlier in the day, electrical power from the HPCI system turbine steam supply valve, 3-FCV-73-16, had been removed to support motor operated valve (MOV)diagnostic differential testing (Generic Letter 96-05 MOV testing)~Accordingly, the TS 3.5.1 LCO for inoperable HPCI equipment was entered.prior to achieving 150 psig reactor pressure.Plant operators, however, did not fully recognize that entering the HPCI LCO did not supersede TS LCO 3.0.4 requirements which required that HPCI be operable at the time.of entering'the specified condition-in-the TS 3.5.1'Applicability statement (Mode 2 with reactor pressure>150 psig as startup continued).

HPCI was returned to service at 2213 hours0.0256 days <br />0.615 hours <br />0.00366 weeks <br />8.420465e-4 months <br />.At 2303 hours0.0267 days <br />0.64 hours <br />0.00381 weeks <br />8.762915e-4 months <br />, HPCI was again declared inoperable in preparation for performing the TS required HPCI flow rate surveillance at rated.reactor pressure.The.HPCI TS 3.5.1 LCO was entered.Startup.continued to achieve the rated reactor pressure test conditions.

At 0220 on October 15, 1998, the mode switch was transferred from.Mode 2 to Mode 1 (Run mode)while the HPCI surveillance was in progress.This mode switch change was not allowable under TS LCO 3.0.4 since HPCI operability is a prerequisite for tlie actual mode switch change.HPCI was returned to service at 0300 following completion of HPCI surveillance testing.B.Ino erable Structures Com onents orS stems that Contributedtothe Event: None., C.Dates and A roximate Times of Ma or Occurrences:

October 14, 1998 1514 hours0.0175 days <br />0.421 hours <br />0.0025 weeks <br />5.76077e-4 months <br /> Unit 3 mode switch placed in startup (Mode 2).October 14, 1998 1809 hours0.0209 days <br />0.503 hours <br />0.00299 weeks <br />6.883245e-4 months <br /> Unit 3 critical at 205 degrees Fahrenheit moderator temperature.

October 14, 1998 2117 hours0.0245 days <br />0.588 hours <br />0.0035 weeks <br />8.055185e-4 months <br /> Reactor pressure at 150 psig.HPCI previously declared inoperable and TS 3.5.1 LCO entered.NRc FoRM 366 I6-1998)

%c.

NRC FORM 366A (6-1998I LICENSEE EVENT REPORT (LER)TEXT CONTINUATION.S.NUCLEAR REGULATORY COMMISSION FACILITY NAME 1 Browns Ferry Nuclear Plant-Unit 3 DOCKET 05000296 LER NUMBER 6 YEAR SEQUENTIAL REVISION NUMBER 1998-005-00 PAGE 3 3of 5 TEXT (II more spaceis required, use additional copies of fVRC Form 366A)I17)C.Dates and A roximate Times of.Ma or Occurrences continued:

October 14, 1998 2213 hours0.0256 days <br />0.615 hours <br />0.00366 weeks <br />8.420465e-4 months <br /> October 14, 1998 2303 hours0.0267 days <br />0.64 hours <br />0.00381 weeks <br />8.762915e-4 months <br /> October 15, 1998 0050 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> October 15, 1998 0220 hours0.00255 days <br />0.0611 hours <br />3.637566e-4 weeks <br />8.371e-5 months <br /> HPCI declared operable.HPCI declared inoperable in preparation.to conduct HPCI flow rate surveillance at normal reactor pressure.HPCI TS 3.5.1 LCO entered.Reactor at rated temperature and pressure.Mode switch placed in Mode 1 (Run mode).October 15, 1998 0300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> HPCI returned to operable status following completion of HPCI flow rate surveillance.

D.Other S stems or Seconda Functions Affected None.E.Method of Discove.The first example was discovered by an NRC resident inspector.

The second example was reported by TVA while investigating the circumstances of the first example.~~F.0 erator Actions-None.G.Safe S stem Res onses None.III.CAUSE OF THE EVENT A.Immediate Cause TS LCO 3.0.4 requirements for mode changes and for entry into other specified conditions were not properly applied./~B.Root Cause The event analysis indicated that operator training on the application of TS LCO 3.0.4 was not fully effective.

This resulted in operator knowledge deficiencies in the proper application and interpretation of the subject TS.NRC FORM 366 I6-1998)

Cl I)

NRC FORM 366A I6-1998)LICENSEE EVENT REPORT (LER)TEXT CONTINUATION.S.NUCLEAR REGULATORY COMMISSION FACILITY NAME 1 Browns Ferry Nuclear Plant-Unit 3 DOCKET 05000296 LER NUMBER 6 YEAR SEQUENTIAL REViSION NUMBER 1998-.005-00 PAGE 3 4of 5 TEXT/If more spaceis required, use addidonal copies of NRC Form 366AI I17)III.CAUSE OF THE EVENT (continued)

C.Contributin Factors The Improved TS were implemented in July 1998 and this was the first startup from a refueling outage using the Improved TS.Custom TS did not have an analogous provision to TS LCO 3.0.4.Additionally, the cause analysis noted that for the second example, the Unit Operator, while appropriately declaring'=HPCI inoperable for the surveillance test, did not fully communicate this status to other Operations shift personnel.

IV.ANALYSIS OF THE EVENT The events demonstrated deficiencies in operator knowledge in the application of the subject TS LCO.The Improved TS were adopted in July 1998 after ari extensive training effort and, in general, implementation has been smooth.In some cases such as for this event, additional training needs on the Improved TS have been identified.

V.ASSESSMENT OF SAFETY CONSEQUENCES The primary objective of TS LCO 3.0.4 is to prohibit changing modes or entering other specified conditions with inoperable equipment with the basic intent to ensure malfunctioning TS equipment is repaired prior to starting up or raising reactor power.For the first example in this report, TS LCO 3.0.2 would have allowed the reactor-to be.brought above 150 psig and then HPCI taken out of service for testing.For the second example, the TS would have allowed Mode 1 to be entered, and then HPCI taken out of service to conduct the TS surveillance.

Hence, the actual safety significance of the two events is low since the net time that HPCI was inoperable was unaffected by the sequence of events.However, the deficiencies in operator...understanding concerning the proper application of TS LCO 3.0.4 is an important concern to TVA since under the Improved TS, the Section 3.0 TS provide essential rules in properly applying the system related=-TS;--t VI.CORRECTIVE ACTIONS A.Immediate Corrective Actions C A training information memorandum concerning the proper application and requirements of TS LCO 3.0.4 was promptly prepared and provided to Operations shift personnel during stand, down meetings.B.Corrective Actions to Prevent Recurrence The Operations Training department will develop a training presentation for TS Section 3.0 and the associated TS Bases.This training will be provided in operator requalification training and will be completed by April 30;1999.1 Also, the plant starlup and shutdown operating instructions will be reviewed and revised to improve written instructions for ensuring TS requirements are met prior to making mode changes or entering other specified conditions.

This action and several lesser remedial actions related to counseling of personnel and outage scheduling coordination with TS will be tracked under the TVA corrective action document for this event.NRC FORM 366 I6-1999) 0 II 5.

NRC FORM 366A 16-1998)LICENSEE EVENT REPORT (LER)TEXT CONTINUATION.S.NUCLEAR REGULATORY COMMISSION C FACILITY NAME 1 Browns Ferry-Nuclear Plant-Unit 3 DOCKET 05000296 LER NUMBER 6 YEAR SEQUENTIAL REVISIQN NUMBER 1998-005-00 PAGE 3 5o(5 TEXT llf more spece is required, use eddidonel copies of hfRC Form 366Ai l17)VII.ADDITIONAL INFORMATION A.Failed Com onents None.B.Previous LERs on Similar Events There are no previous LERs involving inappropriate TS LCO 3.0.4 mode changes.C.Additional Information None.Vill.COMMITMENTS The Operations Training department will develop a training presentation for TS Section 3.0 and the associated TS Bases.This training will be provided in the licensed operator requalification rotation which will be completed by April 30, 1999.NRC FORM 366 (6-'1999) 0~ij