05000333/LER-2005-001
| Docket Number | |
| Event date: | |
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| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 3332005001R00 - NRC Website | |
FACILITY NAME (1) DOCKET (2) LER NUMBER (6 PAGE (3) James A. FitzPatrick Nuclear Power Plant 05000333 05 001 00 EIS Codes in [ ]
Event Description:
On November 13, 2003, at approximately 0332 hours0.00384 days <br />0.0922 hours <br />5.489418e-4 weeks <br />1.26326e-4 months <br />, 115 kV transmission line #4, an integral part of the South Oswego 115 kV supply to the James A. FitzPatrick (JAF) switchyard [FK], was deenergized due to arcing on a disconnect switch in the Nine Mile Point (NMP) Unit 1 switchyard. JAF Technical Specifications (TS) Limiting Conditions for Operation (LCO) 3.8.1 requires that two qualified circuits between the offsite transmission network and the plant Class lE AC electrical power distribution system [EB] be Operable in Modes 1, 2 and 3.
TS 3.8.1 requires that when one offsite circuit is inoperable it must be restored to Operable status within seven days, or the plant must be placed in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 4 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Line #4 was not restored until November 22, 2003, at approximately 1113 hours0.0129 days <br />0.309 hours <br />0.00184 weeks <br />4.234965e-4 months <br />, resulting in an out of service time of approximately 9 days and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. This exceeded the allowed out of service time of TS 3.8.1.
JAF did not enter a TS Action statement or take the TS required actions for an inoperable offsite circuit because the qualified offsite circuits, as defined in the TS LCO Bases, did not extend to the 115 kV transmission lines.
When line #4 was removed from service, JAF entered the Actions of Technical Requirements Manual (TRM) Technical Requirements for Operation (TRO) 3.8.C. TRO 3.8.0 required the line to be restored within 14 days or the plant placed in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 4 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. No TS Action statement was entered because line #3 was still Operable in accordance with AOP-72, "115 KV Grid Loss, Instability or Degradation," and both qualified offsite circuits, as defined in the TS 3.8.1 LCO Bases and TRM 3.8.0 Bases, were Operable.
The definition of qualified offsite circuit in the TS LCO Bases did not include the 115 kV transmission lines. The words in the TS LCO Bases and TRM Bases were consistent with the NRC issued NUREG-1433, Standard Technical Specifications General Electric Plants, BWR/4 (STS).
JAF receives offsite electrical power from two substations in the115 kV system, Lighthouse Hill (via line #3) and South Oswego (via line #4 in series with several other transmission elements), that provide power to normal, shutdown and/or engineered safeguard loads (see Figure 1). JAF is designed such that both line #3 and line #4, in almost all circumstances, supply both of the plant's Class lE AC electrical power emergency buses. The initial Improved TS (ITS) amendment request included a discussion of the Lighthouse Hill and South Oswego substations as part of the definition of the qualified offsite circuit contained in the LCO Bases section. This was consistent with the JAF initial license basis in the Final Safety Analysis Report (FSAR), and was largely consistent with the requirement that two 115 kV transmission lines be Operable in the Custom TS (CTS), with applicable Required Actions and Completion Times.
The definition of qualified offsite circuit for JAF (previously known as reserve circuit under CTS) changed during revision G to the ITS amendment request. Revision G removed the discussion of the Lighthouse Hill (via line #3) and South Oswego substations (via line #4 and other transmission system elements) from the definition of the qualified offsite circuit contained in the LCO Bases section. This change to the Bases was performed with the intention of making the definition more consistent with the STS definition.
This ITS change was not properly evaluated in accordance with the established change process. During ITS conversions, the various changes to the CTS as they relate to the new ITS are described in what are called Discussions of Changes (docs). The changes are also categorized into types of changes. The two types of changes that apply in this case are Technical Changes — Less Restrictive (L docs) and Technical Changes — FACILITY NAME (1) DOCKET (2) LER NUMBER (6) PAGE (3) James A. FitzPatrick Nuclear Power Plant 05000333 05� 001� 00 Event Description (continued):
Less Restrictive Removal of Details (LA docs). In general terms, L docs are changes that eliminate existing requirements, require less testing or less frequent testing, or increase operational flexibility. LA docs are changes that relocate details out of the CTS and into the Bases, UFSAR, or other appropriate licensee- controlled documents. They are less restrictive because they result in a less restrictive change control process and a reduced level of regulatory oversight.
Revision G to the ITS amendment request modified the definition of the qualified offsite circuit and invalidated an LA doc (TS Section 3.8.1 LA1 doc) provided with the original ITS amendment request. This LA doc stated that the details pertaining to the 115 kV transmission lines would be relocated from the CTS to the TS LCO Bases. Revision G removed the details of the Lighthouse Hill (via line #3) and South Oswego substations (via line #4 and other transmission system elements) from the definition of the qualified offsite circuit contained in the LCO Bases section and neither revised the LA doc nor provided a new L doe to reflect this removal.
After implementation of ITS, the JAF staff recognized that improved administrative controls needed to be placed on the out of service times for the 115 kV transmission lines, since they had been removed from TS. As a result, the TRM was revised to include TRO 3.8.C, which contained Action statements and a requirement to shutdown the plant if one 115 kV transmission line was inoperable for greater than 14 days. The 14 day allowed out of service time was based on a Probabilistic Risk Assessment (PRA) analysis that indicated JAF can operate for at least 14 days without exceeding the Regulatory Guide 1.177 acceptable risk threshold. JAF is designed such that either Lighthouse Hill (via line #3) or South Oswego (via line #4) can be aligned to energize both of the plant's Class lE AC electrical power emergency buses.
In January, 2005, after review of JAF's position and understanding of the license basis pertaining to the definition of a qualified offsite circuit, the NRC determined that JAF had misinterpreted the TS requirements related to the operability of the qualified offsite circuits. As a result, JAF did not correctly declare the applicable offsite power source inoperable in accordance with TS LCO 3.8.1 and did not take the appropriate TS required actions.
In the November, 2003 instance, line #4 was out of service for approximately 9 days and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. This exceeded the allowed out of service time of TS 3.8.1 without JAF declaring the circuit inoperable per TS 3.8.1 or taking the appropriate TS Actions. Consequently, this report is being submitted in accordance with 10CFR50.73(a)(2)(i)(B), "Any operation or condition which was prohibited by the plant's Technical Specifications.
Cause of Event:
The cause of the event was inadequate work practices of the preparer and reviewer of the revision G change to the ITS amendment request.
Revision G to the ITS amendment request modified the definition of the qualified offsite circuit and invalidated an LA doe (TS Section 3.8.1 LA1 doc) provided with the original ITS amendment request. This LA doc stated that the details pertaining to the 115 kV transmission lines would be relocated from the CTS to the TS LCO I NRC FORM 366A� U.S. NUCLEAR REGULATORY COMMISSION 46-1998) FACILITY NAME (1) DOCKET (2) LER NUMBER (6) PAGE (3) James A. FitzPatrick Nuclear Power Plant 05000333 05�001�00 Cause of Event (continued):
Bases. Revision G removed the details of the Lighthouse Hill (via line #3) and South Oswego substations (via line #4 and other transmission system elements) from the definition of the qualified offsite circuit contained in the LCO Bases section and neither revised the LA doc nor provided a new L doc to reflect this removal. The exclusion of the 115 kV transmission lines from the definition of qualified offsite circuits was not evaluated correctly and resulted in JAF having a different understanding of what constituted a qualified offsite circuit.
[Cause code A]
Event Analysis:
There were minimal safety implications for line #4 being out of service for the period of time described in this event. A PRA analysis determined that, with conservative assumptions regarding concurrent maintenance activities and regarding the capability of the remaining 115 kV transmission line (Lighthouse Hill via line #3), the resultant change in core damage frequency (delta CDF) was 5.5E-7 per year. With these conservative assumptions applied for the full duration of the event (9 days and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />), the resultant conditional core damage probability was 1.4E-8.
Extent of Condition:
Of the ITS sections updated from the original submittal, section 3.8 was the most significantly changed of any section during the revision G change, thus creating a more error likely situation. To reasonably confirm that this type of error was unlikely to have occurred elsewhere during the ITS conversion, reviews of all LA docs in section 3.8 and of a sample of other sections were performed.
A review of 25 other LA docs revealed no other cases where information was not appropriately relocated. A random review of 20 ITS Requests for Additional Information (RAls) revealed no cases where information was changed without an appropriate L doc. Creation of new L docs for other changes during the ITS revision process in accordance with the expected process was verified by sample.
Corrective Actions:
1. Revise the TS LCO Bases to revise the definition of qualified offsite circuit to include the 115 kV transmission lines. (Complete) 2. Delete TRM Section 3.8.0 for 115 kV Transmission Lines, since the lines are now addressed per the TS. (Complete) 3. Provide a briefing on the results of this Cause Evaluation to Regulatory Compliance personnel to provide lessons learned with the intent of reducing document review related human errors in the future.
(Complete) 4. Perform an extent of condition review of ITS Project LA docs to confirm that information was properly relocated. (Complete) NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (6-1998) FACILITY NAME (1) DOCKET (2) LER NUMBER (6) PAGE (3) 14 NUMBER James A. FitzPatrick Nuclear Power Plant 05000333 05 001 00 Safety System Functional Failure Review:
This event does not constitute a safety system functional failure.
Similar Events:
None.
Failed Component Identification:
None.
References:
1. JAF Condition Report CR-JAF-2005-00089 and associated cause analysis.
2. James A. FitzPatrick Nuclear Power Plant — NRC Integrated Inspection Report 05000333/2004005, dated February 2, 2005.
3. Letter from Entergy Nuclear Operations, Inc. to NRC, Revisions D, E, F, G, and H to Proposed Technical Specification Change (License Amendment), Conversion to Improved Standard Technical Specifications, dated May 31, 2001 (JAFP-01-0133).
4. Letter from NRC to Entergy Nuclear Operations, Inc., James A. FitzPatrick Nuclear Power Plant — Amendment Re: Conversion to Improved Technical Specifications (TAC No. MA5049), dated July 3, , 2002.
FACILITY NAME (1) DOCKET (2) LER NUMBER (6) PAGE 3) 05� 00James A. FitzPatrick Nuclear Power Plant 05000333 001� JAF Simplified Electrical Power Arrangement LINE 4 LINE 3Nisignissz 115 KV bus�(From South (Lighthouse Oswego via Hill)(All 115 KV disconnect switchesNine Mile shown are normally closed) IPoint) ) 10012� 10022i le 10)17 k1002510015 ( T3 TA/ 4 KV bus I ) PlantPlant At-I 10400�1 1110300 IA auxiliary auxiliary (non safety) (non safety) bus bus ))� I ) i) Class lE AC Class lE ACi --9- I 10600 II 10500 1 4' emergency emergency busI I bus I)� I )/ /��4 4 44 Figure 1