05000302/LER-1994-001, :on 940315,performance of Procedure to Return Makeup Pump 1C to Operability Results in Entry Into LCO 3.0.3.Caused by Lack of self-checking.Personnel Trained & TS 3.5.2 Bases Evaluated for Clarification

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:on 940315,performance of Procedure to Return Makeup Pump 1C to Operability Results in Entry Into LCO 3.0.3.Caused by Lack of self-checking.Personnel Trained & TS 3.5.2 Bases Evaluated for Clarification
ML20065K207
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 04/12/1994
From: Boldt G, Ken Wilson
FLORIDA POWER CORP.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
3F0494-11, 3F494-11, LER-94-001, LER-94-1, NUDOCS 9404190217
Download: ML20065K207 (6)


LER-1994-001, on 940315,performance of Procedure to Return Makeup Pump 1C to Operability Results in Entry Into LCO 3.0.3.Caused by Lack of self-checking.Personnel Trained & TS 3.5.2 Bases Evaluated for Clarification
Event date:
Report date:
Reporting criterion: 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3021994001R00 - NRC Website

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Florida Power CORPORATION April 12, 1994 3F0494-ll U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C.

20555

Subject:

Licensee Event Report (LER) 94-001-00

Dear Sir:

Attached is Licensee Event Report (LER) 94-001-00 which is submitt ed in accordance with 10 CFR 50.73.

Sincerely, G.L. Boldt Vice President Nuclear Production GLB/JAF:rp Attachment xc:

Regional Administrator, Region 11 Project Manager, liRR Senior Resident inspector I

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FACILJTY NAME (1)

DOCKET NUMBE11(2)

PAGE (3)

CRYSTAL RIVER UNIT 3 (CR-3) 0l 5l 0l 0l 0l 3l 0l 2 1 lOFl 0 l 5 Tif LE (4)

Performance of Procedure to Return Makeup Pump 1C to Operability Results in Entry into LCO 3.0.3 EVENT DATE (5)

LiR NUMBER (6)

FEPORT DATE (7)

OTHEJ4 FACILITIES INVOLVED (B)

SEQUENTIAL REVISION FActLITY NAMES DOCKET NUMBER (S) 0l5l0l0l0l l l MONTH DAY YEAR YEAR NUMBER

' NUMBER MONTH DAY YEAR N/A l4 0l0l1 0l0 0l4 1l 2 8l4 0l6l0l0l0l l l 0l3 l5 1

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LJCENSEE CONTACT FOR THis LER (12)

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CAUSE

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On March 15, 1994, Florida Power Corporation's (FPC) Crystal River Unit 3 (CR-3) was in MODE 1 (POWER OPERATION), operating at 100% reactor power and generating 871 megawatts. Makeup pump (MVP)-1C was out of service. Operations personnel were in the process of performing a test procedure which would both complete post maintenance testing to return MVP-lC to operable status and satisfy a scheduled surveillance requirement. The procedure, written for normal surveillance testing, assumes all MUPs are operable and directs the operators to close a discharge crosstie valve (MUV-3) as part of the procedure which tests associated valves.

At 2205, the control room operators closed MUV-3, thereby isolating the flow path to two high pressure injection (HPI) lines from an operable HPI pump.

The shift supervisor identified that the plant was in a condition outside the safety analysis and immediately entered Technical Specification Limiting Condition for Operation (LCO) 3.0.3.

At 2225, following the performance of the procedure section, LC0 3.0.3 was exited.

Between 2205 and 2225, the makeup system would not have provided the HPI flow paths required by the Safety Analysis without operator actions.

The cause of this event was lack of immediate self-checking by the shif t supervisor.

Several corrective actions were established, including additional training to reinforce timely self checking.

NRD form 308 (6-89)

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PAGE (3)

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EVENT DESCRIPTION

On March 15, 1994, Florida Power Corporation's (FPC) Crystal River Unit 3 (CR-3) was in MODE I (POWER OPERATION), operating at 100% reactor power and generating 871 megawatts. Makeup Pump (MVP)-1B [CB, P] was operating in the Engineered Safeguards (ES) mode, supplying water to the Reactor Coolant System (RCS) [AB], via valve MUV-31 [CB, LCV] (Refer to Attachment 1, Simplified Makeup System Diagram). Makeup Pump (MVP)-1A [CB, P] was operable in ES standby and Makeup Pump (MVP)-lC [CB, P]

had been declared inoperable due to planned maintenance being performed on the pump. Discharge crosstie valves (MUV-3) and (MUV-9) were open, and the four High Pressure Injection (HPI) [BQ] Valves (MUV-23) [BQ, FCV), (MUV-24) [BQ,FCV],

(MUV-25) [BQ, FCV], and (MUV-26) [BQ, FCV] were closed. MUPs 1-A and 1-B were ES) selected.

Operations personnel were in the process of performing a test procedure which would both satisfy post maintenance testing to return out of service MVP-1C to operable status and a scheduled quarterly surveillance requirement. The procedure, written for normal surveillance testing, assumes all MVPs are operable and directs the j

operators to close discharge crosstie valve MUV-3 as part of an early section of the procedure which tests associated valves. The shift supervisor recognized that the Emergency Core Cooling System (ECCS) [BQ] would be placed in a degraded condition by closing MUV-3 as required by the procedure and assigned a dedicated operator to stand by MUV-3.

However, he expected this action to place the plant in a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> action.

H At 2205, af ter granting authorization for closure of MVV-3 and performance of the valve stroking, he self-checked these actions and discovered that LC0 3.0.3 applied rather than the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> action, and immediately entered LC0 3.0.3.

When the control room operators closed MUV-3, thereby isolating the flow path to two HPI l

lines from an operable HPI pump, the plant was placed in a condition outside the safety analysis and required immediate entry into Technical Specification Limiting Condition for Operation (LCO) 3.0.3.

At 2225, following the performance of the procedure section, LC0 3.0.3 was exited by reopening MVV-3. Although LC0 3.0.3 requires actions to shut down the reactor to commence within one hour, a reactor shutdown was not required since this condition existed for less than one hour. This report is submitted in accordance with10CFR50.73(a)(2)(i)(B).

EVENT EVALUATION:

Improved Technical Specification (ITS) 3.5.2 requires that two ECCS trains be operable during MODES 1, 2, and 3.

The Final Safety Analysis Report (FSAR) for CR-3 discusses combinations of operable MVPs and HPI valves necessary to ensure adequate HPI flow in the event of a postulated break in one of the HPI lines.

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During normal plant operations, MVP-1B and MVP-10 are ES selected and aligned to automatically start when the Engineered Safeguards Actuation System [JE] actuates.

The pumps provide HPI flow to the RCS via MUV-23, MUV-24, MUV-25, and MUV-26.

Discharge crosstie valves MUV-3 and MUV-9 are normally maintained open to allow any operating MVP to feed all of the HPI lines.

This configuration ensures single failure protection.

When MUV-3 was closed concurrent with the inoperability of MVP-1C, MUV-25 and MUV-26 were isolated from the operable MVP-1A and MVP-1B, and the system could not have performed its intended safety function.

Between 2205 and 2225, the Makeup System would not have provided the HPI flow paths required by the Safety Analysis without operator actions.

However, during this time period a dedicated plant operator was assigned to MUV-3. The dedicated plant operator could have reopened MUV-3 at any time, immediately reestablishing a combination of MVPs and HPI valves that would have returned the required HPI flow paths to an operable state.

CAUSE

The primary cause of this event was lack of immediate self-checking by the shift supervisor. He immediately recognized that the ECCS would be placed in a degraded condition by closing MUV-3, however he expected the plant to be placed in a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> action.

After granting authorization for performance of the valve stroking and closure of MUV-3, he self-checked these actions and discovered that LC0 3.0.3 applied rather than the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> action.

Performance of the valve portion of the procedure after MVP-1C was returned to service would have avoided the LC0 3.0.3 entry.

This option was not considered since operations personnel did not immediately recognize the additional degradation resulting from the standard sequence.

A contributing cause was the conversion to ITS on March 12, 1994. Under previous TS, an interpretation had been written clarifying the ECCS operability requirements which addressed the inoperability of specific ECCS components. This interpretation was generalized in the ITS Bases.

Given the sheer volume of changes as a result of ITS, and the cancellation of the TSI, the operator had questions as to whether ITS requirements for this system differed from STS requirements.

CORRECTIVE ACTION

Corrective actions for this event include the following:

1.

MUV-3 was opened and LC0 3.0.3 was exited.

NRC Form 386A (6-89)

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PAGE (3)

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Training will be conducted reviewing this event and ITS 3.5.2 Bases.

Additionally, the Self-Checking program will be re-emphasized relative to this event.

3.

ITS 3.5.2 Bases will be evaluated for possible clarification.

l 4.

fn Operations Study Book Entry discussing this event will be completed.

5.

1he surveillance procedure is being revised to include a statement to nssure performance of the procedure only if proper pump / valve line-ups exist to avoid entry into LC0 3.0.3.

PREVIOUS SIMILAR EVENTS

There have been twenty-seven previous events involving entry into TS 3.0.3, including a similar event reported in LER 91-005-00.

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ATTACHMENT 1:

SIMPLIFIED MAKEUP SYSTEM DIAGRAM DOWNSTREAM TO COLD LEG DOWNSTREAM TO COLD LEG REACTOR COOLANT REACTOR COOLANT REACTOR COOLANT REACTOR COOLANT PUMP 1D PUMP 1C PUMP 1A PUMP 18 MW-26 MW-25 MUV-31 WV-3 h4N-9 MAKEUP PUMP MAKEUP PUMP MAKEUP PUMP u

1C 18 1A i

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BOAATED WATER DECAY HEAT MAKEUP TANK DECAY HEAT DOAATED WATER STOAAGE TANK pyyp PUMP STOAAGE TANK ALL VALVES SHOWN ARE POWER OPERATED

]

I MUV-3 Normal!y Open MUV-23 Normally Closed MVV-25 Normally Closed MUV-9 Normally OPen MUV-24 Normally Closed MUV-26 Normalty Closed l

NAC Fonn Se6A (6-89)