05000271/LER-2005-002, Re Primary Containment Leak Risks Testing Program Second Barrier Isolation Valve Found Miss-Positioned

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Re Primary Containment Leak Risks Testing Program Second Barrier Isolation Valve Found Miss-Positioned
ML053420361
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 12/01/2005
From: Maguire W
Entergy Nuclear Northeast, Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY-05-104 LER 05-002-00
Download: ML053420361 (4)


LER-2005-002, Re Primary Containment Leak Risks Testing Program Second Barrier Isolation Valve Found Miss-Positioned
Event date:
Report date:
Reporting criterion: 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications

10 CFR 50.73(a)(2)(i)

10 CFR 50.73(a)(2)(vii), Common Cause Inoperability

10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded

10 CFR 50.73(a)(2)(viii)(A)

10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition

10 CFR 50.73(a)(2)(viii)(B)

10 CFR 50.73(a)(2)

10 CFR 50.73(a)(2)(iv)(A), System Actuation

10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor

10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat

10 CFR 50.73(a)(2)(v), Loss of Safety Function
2712005002R00 - NRC Website

text

' En tergy Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

Vermont Yankee P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500 Tel 802 257 5271 December 01, 2005 BVY 05-104 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Vermont Yankee Nuclear Power Station License Number: DPR-28 Docket Number: 05000271 Reportable Occurrence Number: LER 2005-002-00 As defined by 10 CFR 50.73(a)(2)(i)(B), we are submitting the attached Licensee Event Report for a Reportable Occurrence that was discovered on October 04, 2005 as LER 2005-002-00. This correspondence does not contain NRC

Commitments

Sincerely, William F. M guiro General Ma r, Plant Operations cc:

USNRC Region I Administrator USNRC Resident Inspector - VYNPS USNRC Project Manager - VYNPS Vermont Department of Public Service

$1: c_-,,o

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 06/30/2007 (6-2004)

, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

f3. PAGE VERMONT YANKEE NUCLEAR POWER STATION (VY) 05000 271 1 OF 3

4. TITLE Primary Containment Leak Rate Testing Program Second Barrier Isolation Valve Found Miss-Positioned
5. EVENT DATE
6. LER NUMBER
7. REPORT DATE
8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR SEQUENTIALI REV MONTH DAY YEAR N/A N

DoCIMT NUMBER tFACILITY NAME DOCKET NUMBER 10 04 2005 2005 002.

00 12 01 2005 N/A

9. OPERATING MODE
11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR 5: (Check all that apply) o 20.2201(b) a 20.2203(a)(3)(i)

Q 50.73(a)(2)(i)(C)

Q 50.73(a)(2)(vii)

N Q 20.2201(d) a 20.2203(a)(3)(ii) 50.73(a)(2)(ii)(A)

Q 50.73(a)(2)(viii)(A)

O 20.2203(a)(1) 0 20.2203(a)(4) 0 50.73(a)(2)(ii)(B)

D 50.73(a)(2)(viii)(B) 0 20.2203(a)(2)(i) 0 50.36(c)(1)(i)(A) a 50.73(a)(2)(Iii) 60Q 73(a)(2)(Ix)(A)

10. POWER LEVEL 0 20.2203(a)(2)(ii) 0 50.36(c)(1)(ii)(A) 50.73(a)(2)(iv)(A)

[

50.73(a)(2Xx) o 20.2203(a)(2)(iii) 0 50.36(c)(2) 0 50.73(a)(2)(v)(A)

D 73.71(8)(4) 100 Q 20.2203(a)(2)(iv)

Q 50.46(a)(3)(ii) 0 50.73(a)(2)(v)(B)

D 73.71(a)(5) o 20.2203(a)(2)(v)

D 50.73(a)(2)(')(A)

D 50.73(a)(2)(v)(C)

Q OTHER o 20.2203(a)(2)(vi) 6 50.73(a)(2)(I)(B)

Q 50.73(a)(2)(v)(D)

SpoCiFy In Abstract below or In NRC Form 368A

12. LICENSEE CONTACT FOR THIS LER CONTACT NAME TELEPHONE NUMBER /hdude Ame Code)

William F. Maguire, General Manager Plant Operations (802) 257-7711MANU-REPORTABLE CAS YTM CMOET MANU-REPORTABLE

CAUSE

SYSTEM COMPONENT FACTURER TO EPIX FCS SYSTEM COMPONENT FACTURER TO EPIX NIA N/A

14. SUPPLEMENTAL REPORT EXPECTED
15. EXPECTED MONTH DAY YEAR SUBMISSION Q YES (If yes, complete 15. EXPECTED SUBMISSION DATE) a NO DATE ABSTRACT (Lhnt to 1400 spces. i e.. approxinately 15 single-spaced typewritten lines)

On 10/04/05, with the reactor at full power, a sample line isolation valve, Vi 0-1 98A on the Residual Heat Removal (RHR) "An Loop was found open. Vi 0-1 98A is a second barrier that supports Primary Containment integrity and is required to be closed per the Primary Containment Leakage Rate Testing Program (PCLRTP). Upon discovery, Operators closed V10-1 98A and placed it under administrative control. This condition was Identified while reviewing a Safety Classification Worksheet for a different valve in the RHR system sample line. The RHR System procedure valve line-up listed VI 0-1 98A as *open' and the RHR System Piping and Instrumentation Diagram (P&ID) displayed it as closed'. The open valve provided a potential flow path of water from Primary Containment to Secondary Containment. Two air operated valves and a manual sample valve located downstream of V10-198A provided reasonable assurance that effective isolation for this flow path was maintained during plant operation. The cause of this condition was the application of an Insufficient change process in 1996 during implementation of the Qualified Closed Loop Outside Primary Containment modification that lacked sufficient documentation and reviews to effectively implement the change. There was no significant increase in radiological risk to plant workers or the public as a result of this condition.

NRC FORM 366 (6-2004)

PRINTED ON RECYCLED PAPER NRC FORM 366 (S-2004)

PRINTED ON RECYCLED PAPER

(I' more space Is required, use additional copies of (ff more space Is required, use additional copies of NRC Form 366A)

ASSESSMENT OF SAFETY CONSEQUENCES

The subject valve is a second barrier for Primary Containment per the PCLRTP. The first barrier valves remained operable and closed as required. There are two AOVs located downstream of VI 0-1 98A that are designed to automatically close on a PCIS signal or on a loss of instrument air. A third manually operated sampling isolation valve located downstream of the two AOVs is maintained in the closed position. Additionally, incidental leakage from the system past these three valves would be detected by Operations or Chemistry personnel at the Reactor Building Sample Sink. Therefore, reasonable assurance existed that Primary Containment Integrity was maintained. This condition did not result in a significant increase in radiological risk or Industrial risk to plant workers or the general public in the event of a design bases accident.

CORRECTIVE ACTIONS

The Job Order File process that was used when this condition occurred was superseded by an improved design control process. The procedures that implement the current design control process provide clearer and more concise direction that would likely have prevented this condition from occurring if utilized in 1996.

Immediate Actions

1) Upon discovery and confirmation of this condition, Vi 0-1 98A was closed and administratively tagged "SHUT".

Interim Actions

1) VI 0-1 98A was added to the "Current System Valve and Breaker Line Up and Identifications procedure controlled population.
2) A drawing change was submitted for the subject P&ID to indicate Vi 0-1 98A/B normal positions as locked closed.
3) The RHR System procedure's appendix for normal system line up was changed to control Vi 0-1 98A as closed.
4) The RHR and Core Spray system procedures were verified to ensure that the valve line-ups contained within them are in agreement with the procedure for the PCLRTP. No additional discrepancies were noted.
5) On November 10, 2005, the Vice President of Engineering distributed a memo to all Vermont Yankee site employees titled "Configuration Control at Vermont Yankee". This correspondence described the event, expectations for configuration control, current design control processes employed within the Entergy Fleet, provided a list reference materials and described the relevant points from the reference materials that need to be reinforced to prevent this type of event from recurring.
6) Radiation Protection containment sampling procedures were reviewed to ensure compliance with TS 1.0.N.1 and the PCLRTP Procedure administrative controls for manual containment isolation valves. No discrepancies were noted.

Long Term Actions

1) A review of other Job Order File changes from the same time frame will be performed to assess the potential for similar conditions.
2) Evaluate the need to review and as necessary correct the image quality and valve positions for the Control Room P&lDs referenced in the PCLRTP procedure.

ADDITIONAL INFORMATION

No similar events have occurred at Vermont Yankee within the past ten years.