05000266/LER-1997-019, :on 970404,RHR Not Aligned IAW TS Requirements. Caused by non-conservative Decision Making & Not Recognizing When TS Were Not Controlling Plant Operations.Pbnp Mgt Philosophy Re TS Interpretations Changed to Minimize Use

:on 970404,RHR Not Aligned IAW TS Requirements. Caused by non-conservative Decision Making & Not Recognizing When TS Were Not Controlling Plant Operations.Pbnp Mgt Philosophy Re TS Interpretations Changed to Minimize Use

ML20147J395
Person / Time
Site:	Point Beach
Issue date:	05/02/1997
From:	Weaver D WISCONSIN ELECTRIC POWER CO.
To:
Shared Package
ML20147J393	List: 05000266/LER-1997-019, :on 970404,RHR Not Aligned IAW TS Requirements. Caused by non-conservative Decision Making & Not Recognizing When TS Were Not Controlling Plant Operations.Pbnp Mgt Philosophy Re TS Interpretations Changed to Minimize Use
References
LER-97-019, LER-97-19, NUDOCS 9705070094
Download: ML20147J395 (4)

LER-1997-019, on 970404,RHR Not Aligned IAW TS Requirements. Caused by non-conservative Decision Making & Not Recognizing When TS Were Not Controlling Plant Operations.Pbnp Mgt Philosophy Re TS Interpretations Changed to Minimize Use

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(1)
2661997019R00 - NRC Website

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NRC FORC 360 U.S. NUCLE AR REGULATORY COMMISSION APPROVED BY Ob8 NO. 31504104

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(4-95)

EXPIRES 04/30/98 l

ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS.

LICENSEE EVENT REPORT (LER)

REPORTED LESSONS LEARNED ARE INCORPORATED INTO THE LICENSING PROCESS AND FED BACK TO INDUSTRY.

FORWARD COMMENTS REGARDING BUR lEN ESTIMATE (See reverse for required number of TO THE INFORMATION AND RECORDS MANAGEMENT digits / characters for each block)

BRANCH (T 6 F33).

U.S.

NUCLEAR REGULATORY

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COMMISSION, WASHINGTON, DC 2055,-0001, AND TO THE PAPFRWORK RFOUCTION PROJEN FACILITY NAME (1)

DOCKET NUMBER (2)

PAGE (3)

$ Point Beach Nuclear Plant, Unit 1 05000266 1 OF 4 TITLE 14)

Residual Heat Removal Not Aligned In Accordance With Technical S_pecificitions Requirements EVENT DATE 15)

LER NUMBER (6)

REPORT DATE (7)

OTHER F ACILITIES INVOLVED 18)

SEQUEN TIA L REVISION FACILITY NAME DOCKET NUMBEF.

MONTH DAY YEAR YEAR NUMBER NUMBER MONTH DAY YEAR Unit 2 05000301 FACILITY NAME DOCKET NUMBER 04 04 97 97 019 --

00 05 02 97 05000 OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR 8: (Check one or moral (11)

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NAME TELEPHONE NUMBER (include Area Codel David Weaver (414) 221-3418 COMPLETE ONE LINE FOR E ACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

CAUSE

SYSTEM COMPONENT MANUFACTURER REPORTABLE gg{

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SUPPLEMENTAL REPJRT EXPECTED 1141 EXPECTED MONTH DAY YEAR YES SUBMISSION Uf yes, complete EXPECTED SUBMISSION DATEl.

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ABSTRACT ILet to 1400 spaces to., approximately 15 single-spaced typewntten lines) (16)

On April 4, 1997, Point Beach Nuclear Plant (PBNP) Unit 1 was in cold shutdown and Unit 2 was shut down during its annual refueling outage.

During a review of NRC Inspection Report IR 96018, it was determined that PBNP had been operated during past refueling shutdown conditions with j

neither RHR normal decay heat removal loops in an operable status.

Normal l

RHR decay heat removal takes suction from the "A" RCS loop hot leg and returns to the "B" RCS loop cold leg.

However, during several occurrences, the RHR return was aligned to core deluge, potentially bypassing the reactor core.

In the future, this method of utilizing the ccre deluge RHR line-up will be used only during conditions in which RHR is not required to be operable, or a Technical Specifications Change Request (TSCR) will be submitted to allow this line-up when RHR is requir ed to be operable.

A four-hour report was provided to the NRC in l accordance with 10 CFR 50.72 (b) (2) (i).

The NRC resident inspectors were also notified of this event.

9705070094 970502 PDR ADOCK 05000266 S

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I NRC FOQM 366A U.S. NUCLEAR REGULOTOQY COMMIS$10N I4 95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION F ACILITY N AME (1)

DOCKET NUMBER (2)

LER NUMBER (6)

PAGE (3)

YEAR SEQUENTIAL HEVISION Point Beach Nuclear Plant, Unit 1 05000266 NUMBER NUMBER 2 OF 4 l

97 019 00 TEXT fit more space os required use additional copies of NRC Form 366A) l17)

Event Description

On April 4, 1997, Point Beach Nuclear Plant (PBNP) Unit 1 was in cold shutdown and Unit 2 was shut down during its annual refueling outage.

During a review of NRC Inspection Report IR 96018, it was deterr.ined that PBNP had been operated during past refueling shutdown conditions. with both RHR normal decay heat removal loops inoperable.

Normal RHR decay heat removal takes suction from the "A" RCS loop hot leg and returns to the "B"

RCS loop cold leg.

However, during past evolutions such as Technical Specifications Test TS-30, "High and Low Head SI Check Valve Leakage Test, Unit 1," and TS-31, "High and Low Head SI Check Valve Leakage Test, Unit i

2," the RHR return was aligned to core deluge through valves SI-852A&B, potentially bypassing the reactor core.

A Technical Specifications Interpretation DCS 3.1.22, "Use of Core Deluce as a Modified Residual Heat Removal (MRHR) Loop," provided guidance to allow this line-up.

Safety I

Evaluation Report (SER)01-118 and 91-118-01 incorrectly concluded that the modified RHR line-up utilizing the. core deluge injection path did not involve a change to the plant Technical Specifications.

Technical Specification 15.1.C states, in part, that a system, subsystem, train or component shall be operable "...when it is capable of performing its function (s) as analyzed in the safety analysis report."

This modified lineup is not described in the PBNP Final Safety Analysis Report (FSAR).

Therefore, the definition of operability was not met, rendering both trains of RHR inoperable during the time this line-up was utilized.

Having both trains of RHR inoperable without immediate corrective action to restore a train to service is contrary to Technical Specification 15.3.1.A.3.

In the future, this method of utilizing the core deluge RHR line-up will be used only during conditions in which RHR is not required to be operable, or a Technical Specifications Change Request (TSCR) will be submitted to allow this line-up when RHR is required to be operable.

A four-hour report was provided to the NRC in accordance with 10 CFR l

50.72 (b) (2) (i).

The NRC resident inspectors were also notified of this event.

Cause

The root cause of this event was non-conservative decision making and not recognizing when the Technical Specifications (TS) were not controlling plant operations.

The use of administrative controls (DCS 3.1.22) to administer the intent of the TS led to a failure to submit a Technical Specifications Change Request for prior NRC review and approval.

Corrective Actions

1. DCS 3.1. 2 2, "Use of Core Deluge as a Modified Residual Heat Removal (MRHR) Loop," has been canceled.

2. The PBNP management philosophy regarding TS interpretations has changed to minimize the use of TS interpretations.

BIRC FORM 366A (4 95)

l NRC FOLM 766A U.S. NUCLEAR RECULATORY COMMISSION 14-9 5)

LICENSEE EVENT REPORT (LER)

)

TEXT CONTINUATION i

F ACILITY N AME (1)

DOCKET NUM8ER (2)

LER NUMBER I6I PAGE (3)

YEAR SE QUENTIAL REVISION Point Beach Nuclear Plant, Unit 1 05000266 NUMBER NUMBER 3OF4 I9/

019 00

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TEKT tot more space os required. use additional capnes of NRC Form 366A) l17)

3. This method of utilizing the core deluge RHR line-up will be used only 1

during conditions in which RHR is not required to be operable, or a

]

j Technical Specifications Change Request (TSCR) will be submitted to 4

allow this line-up when RHR is required to be operable.

Associated t

j procedures implementing this line-up vill be revised accordingly.

j

Reportability

This Licensee Event Report is being submitted in accordance with the requirements of 10 CFR 50.73 (a) (2) (1) (B), "Any operation or c.andition i

prohibited by the plant's Technical Specifications."

A four-hour report

]

was provided to the NRC in accordance with 10 CFR 50.72 (b) (2) (i).

The NRC l

j resident inspectors were also notified of this event.

4

Safety Assessment

When using the core deluge lines for residual heat removal (RHR), there is i

no pumped flow through the reactor core.

Cooling water enters the upper j

plenum and exits via the hot leg.

Reactor coolant pumps are not required to be running.

The heat removal method is natural circulation, similar to j

the heat removal means in the spent fuel pool.

j 1

i Although the modifiel RHR line-up discussed above was not described in the PBNP FSAR and had not been previously reviewed by the NRC, the i

configuration has been thoroughly evaluated by Licensee personnel.

One result of forced circulation is the prevention of boron stratification by l

allowing mixing during boron concentration changes.

SERs91-118 and 91-1 118-01 included provisions for preventing inadvertent dilution by securing j

all sources of dilute water to the reactor coolant system when the core deluge line-up is used.

Nuclear Power Department Calculation N-91-112 1

also evaluated the decay heat removal capability of the RHR system using the core deluge line-up.

The calculation included data obtained from testing and concluded that the core deluge lines can be used to remove 1

decay heat.

Therefore, the plant remained in a safe condition and this event created no additional risk to plant personnel and the general public.

Similar occurrences:

i The following LERs describe events involving inadequately implemented i

Technical Specifications requirements:

1 LEE Title i

266/97-016-00 Steam Generator Level Logic Not Tested In Accordance With j

Technical Specifications 266/97-012-00 Diesel-Driven Fire Pump Day Tank Not Sampled In Accordance With Technical Specifications NRC FORM 360A (4-SM y

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NRC FOJ.M d66 i U.S. NUCLEAR RERULATORY COMMIS110N i

14-9 5)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION i

FACILITY NAME 11)

DOCKET NUM8ER (2)

LER NUMBER (6)

PAGE (3)

YEAR SEQUENTIAL REVISION Point Beach Nuclear Plant, Unit 1 05000266 NUMBER NUMBER 4 OF 4 019 00 97 T-,,,-............~.,-...,-,--,,,,,

1 266/97-011-00 Containment Fan Cooler Accident Fans Not Tested In I

Accordance With Technical Specifications i

l 266/97-005-00 1SI-852A Not Tested In Accordance With Technical l

Specifications j

266/97-003-00 Spare Containment Fenetrations Not Leak Tested In l

l Accordance With Technical Specificatiens 1

t 266/96-014-00 Steam Generator Blowdown Sample Not Performed In j

Accordance With Technical Specifications i

l 266/96-012-00 EDG Fuel Oil System Tests Not Performed In Accordance j

With Technical Specifications 1

266/96-008-00 Missed Full Pressure Test of Containment Airlock e

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