05000354/LER-2003-004

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LER-2003-004, Failure to Fully Implement LCO Action to Put Mode Switch in SHUTDOWN During Mode 5
Hope Creek Generating Station
Event date: 04-22-2003
Report date: 06-19-2003
Reporting criterion: 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3542003004R00 - NRC Website

FACILITY NAME (1)

DOCKET

Hope Creek Generating Station 05000354

PLANT AND SYSTEM IDENTIFICATION

General Electric — Boiling Water Reactor (BWR/4) Reactor Protection System (JC)* * Energy Industry Identification System {EIIS} codes and component function identifier codes appear as {SS/CCC}

IDENTIFICATION OF OCCURRENCE

Event Date: April 22, 2003 Discovery Date: April 26, 2003

CONDITIONS PRIOR TO OCCURRENCE

The plant was in OPERATIONAL CONDITION 5 (REFUELING) at the time of discovery. No other structures, systems or components were inoperable at the start of this event that contributed to the event.

DESCRIPTION OF OCCURRENCE

On April 17, 2003, at 21:32, the weekly Reactor Protection System (RPS) Scram test, HC.OP-ST.SF-0003, RPS Manual Scram Surveillance Test Weekly was performed satisfactorily to satisfy Technical Specification (TS) requirement 4.3.3.1, Table 4.3.1.1-1 item 12. Subsequently on April 22, due to ongoing Control Rod Drive {AA} and Hydraulic Control Unit {HCU} work, the scram pilot solenoids were tagged out of service. This tagging operation prevented the performance of the subsequent weekly scram test, and the 1.25 grace time/period for the test expired on April 26 at 15:32. To address the condition of the Manual Scram function being inoperable due to a late surveillance, the related action for TS 3.3.1-1 Action 9, which states "Suspend all operations involving CORE ALTERATIONS, * and insert all insertable control rods and lock the reactor mode switch in the SHUTDOWN position within one hour", should have been implemented. However, the mode switch was not locked in SHUTDOWN by 16:32 on April 26 to address the expired surveillance test as required. Later, at 19:50, the mode switch was locked in SHUTDOWN to comply with TS 3.3.1-1 Action 9. The Surveillance Test was completed satisfactorily at 02:56 on April 27, which met the allowance of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to complete a missed surveillance provided for in TS 4.0.3.

During review of this event, it was realized that the tagging operation had rendered RPS, including the Manual Scram, inoperable on April 22 at 2036 when the scram pilot solenoids were tagged and removed from service. At that time, Action 9 of TS Table 3.3.1-1 item 12 should have been implemented and was not fully implemented because the Mode Switch was not locked in SHUTDOWN. This condition existed until 1950 on April 26 when the Mode Switch was locked in SHUTDOWN.

FACIUTY NAME (1) Hope Creek Generating Station

DOCKET

LER NUMBER (6) DESCRIPTION OF OCCURRENCE (continued) Since the required action was not completed as required, this event is reportable as a condition prohibited by the plant Technical Specifications in accordance with 10 CFR 50.73(a)(2)(i)(B).

CAUSE OF OCCURRENCE

The apparent cause for this event was failure to perform an adequate review of TS requirements prior to implementing the tagging operation. The on-duty Operating Superintendent (OS) failed to identify and implement the required Technical Specification action at the time that the Reactor Protection System was rendered functionally inoperable. In addition, personnel involved with review and approval of activities that supported the Reactor Protection System outage window failed to identify the Technical Specification impact. This failure then went undetected through several shifts.

PREVIOUS OCCURRENCES

A review of reportable events in the last two years identified one event involving conditions prohibited by Technical Specifications related to failure to implement TS requirements. LER 354/02-002 reported a Secondary Containment breach of 1 inch piping on a Service Water Emergency Makeup line. The breach was caused by the simultaneous open condition of a tagged open Service Water header vent valve in the Auxiliary Building and the opening of Service Water piping in the Reactor Building for planned repair. The apparent cause was a failure to identify the impact of proposed maintenance on the Secondary Containment boundary and failure to identify Technical Specifications associated with planned work. One of the corrective actions, "improvements to guidance on corrective maintenance work order review, tagging, and Technical Specification review for applicability", was too specific to the event and systems involved to reasonably have been expected to prevent this event.

SAFETY CONSEQUENCES AND IMPLICATIONS

There were no safety consequences associated with this event. At the time that the tagging operation was in effect a full scram was implemented, all control rods were inserted, a control rod withdrawal block was in effect, and there were no activities scheduled or in progress that involved core alterations.

This event does not constitute a Safety System Functional Failure (SSFF) as defined in NEI 99-02.

Hope Creek Generating Station 05000354

CORRECTIVE ACTIONS

1. The Mode Switch was locked in SHUTDOWN at 1950 on April 26 when the Manual Scram was declared Inoperable.

2. This event will be provided to the Operations Training Review Group (TRG) for inclusion in the Licensed Operator Requalification Program.

COMMITMENTS

The corrective actions cited in this LER are voluntary enhancements and do not constitute commitments.