05000286/LER-2008-005, Regarding Technical Specification Prohibited Condition Due to Exceeding the Allowed Completion Time for an Out of Position Valve Caused by Personnel Error
| ML083120377 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 10/28/2008 |
| From: | Joseph E Pollock Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-08-146 LER 08-005-00 | |
| Download: ML083120377 (5) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(1), Submit an LER, Invalid Actuation 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 2862008005R00 - NRC Website | |
text
4-Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 flfifl Buchanan, N.Y. 10511-0249 Tel (914) 734-6700 J. E. Pollock Site Vice President October 28, 2008 Indian Point Unit No. 3 Docket No. 50-286 NL-08-146 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-P1-17 Washington, D.C. 20555-0001
Subject:
Licensee Event Report # 2008-005-00, "Technical Specification Prohibited Condition Due to Exceeding the Allowed Completion Time for an Inoperable Isolation Valve Seal Water System Due to an Out of Position Valve Caused by Personnel Error"
Dear Sir or Madam:
Pursuant to 10 CFR 50.73(a)(1), Entergy Nuclear Operations Inc. (ENO) hereby provides Licensee Event Report (LER) 2008-005-00. The attached LER identifies an event where there was a Technical Specification prohibited condition that exceeded the Allowed Completion Time for an inoperable Isolation Valve Seal Water header, which is reportable under 10 CFR 50.73(a)(2)(i)(B). This condition was recorded in the Entergy Corrective Action Program as Condition Report CR-IP3-2008-02095.
There are no new commitments identified in this letter. Should you have any questions regarding this submittal, please contact Mr. Robert Walpole, Manager, Licensing at (914) 734-6710.
Sincerely, J. E. Pollock Site Vice President Indian Point Energy Center cc:
Mr. Samuel J Collins, Regional Administrator, NRC Region I NRC Resident Inspector's Office, Indian Point 3 Mr. Paul Eddy, New York State Public Service Commission INPO Record Center
Abstract
On September 1, 2008, during the performance of Check Off List 3-COL-CB-004, Operations discovered valve IV-1692 of the Isolation Valve Seal Water (IVSW) system out of position with a Temporary Modification (TM) tag applied and the valve closed.
The required position of valve IV-1692 is open but was discovered closed rendering the associated IVSW header inoperable.
Technical Specification 3.6.9, "Isolation Valve Seal Water System (IVSWS),"
Condition A, One IVSWS header inoperable, required action A.1, is to restore IVSW to operable within 7 days.
Investigations determined that a temporary modification installed in March 2007, required the position of the valve to be closed and during system restoration the valve was required to be opened and TM tags removed.
The condition is reportable because the inoperable header exceeded the TS 3.6.9 allowed completion time.
The apparent cause was procedure use and adherence and inadequate error detection practices.
Corrective actions include; restoration of IV-1692 to locked open and tag removal.
Maintenance personnel will also be briefed on the event and lessons learned, counseled on the expectations and standards for procedure adherence and effective use of Human Performance tools such as self checking, good verbal communications and a good questioning attitude, and coached on the TM process.
Human Performance simulator high intensity training will be performed for Maintenance personnel.
The event had no effect on public health and safety.
(if more space is required, use additional copies of (If more space is required, use additional copies of NRC Form 366A) (17)
Event Analysis
The event is reportable under 10CFR50.73(a)(2)(i)(B).
The licensee shall report any operation or condition which was prohibited by the plant TS.
The Action Statement for the IVSW Technical Specification (TS) Limiting Condition for Operation (LCO),
TS 3.6.9 requires the IVSWS to be operable.
The required action A.1 for TS 3.6.9 Condition A, one IVSWS header inoperable or one IVSW automatic actuation valve inoperable, is to restore IVSWS to operable within a completion time of 7 days.
This event meets the reporting criteria because IVSW valve IV-1692 was closed in March 2007, rendering its associated IVSWS header inoperable and restored to locked open per 3-COL-CB-004 on September 1, 2008, at approximately 15:20 hours.
The inoperable condition during past operation exceeded the 7 day allowed completion time for TS 3.6.9 and the required TS actions were not performed.
The condition was not a safety system functional failure as containment isolation capability was maintained with the two DW isolation valves.
The previous periodic testing showed no valve seat leakage.
In accordance with NUREG-1022, it is not necessary to assume an additional random single failure.
Past Similar Events A review was performed of Licensee Event Reports (LERs) for the past three years for any events reporting TS prohibited conditions due to mis-positioned valves.
No LERs were identified that reported events based on this cause.
Safety Significance
This event had no effect on the health and safety of the public. There were no actual safety consequences for the event because there were no accidents or transients requiring the IVSWS.
In accordance with UFSAR Section 6.5, the use of the IVSWS during a loss-of-coolant accident, while not considered for analysis of the consequences of the accident, provides an additional means of conservatism in ensuring that leakage is minimized.
No detrimental effect on any other safeguards systems will occur should the seal water system fail to operate.
The UFSAR discussion is consistent with the basis provided in TS 3.6.9 since the containment is designed with an allowable leakage rate not to exceed 0.1% of the containment air weight per day.
The maximum allowable leakage rate is used to evaluate offsite doses resulting from a Design Basis Accident (DBA).
Confirmation that the leakage rate is within limits is demonstrated by the performance of a Type "A" leakage rate test in accordance with the Containment Leakage Rate Testing Program as required by Technical Specification Surveillance Requirement 3.6.1.1.
During the performance of the Type "A" test, no credit was taken for the IVSW System in meeting the containment leakage rate criteria.
As such, in the event of a DBA without an operable IVSWS, both the whole body and thyroid offsite doses would be within the guidelines specified in 10 CFR Part 50.67.
In addition, Local leak rate testing of valves DW-AOV-I and DW-AOV-2 sealed by IVSW was performed on March 1, 2007 by surveillance test 3-PT-R025B5.
The test recorded a leak rate of zero SCCM using water as the test fluid.
Valves DW-AOV-I and DW-AOV-2 are normally closed CIVs and as such, the space in between these valves is expected to be water filled.
The water would have been part of the sealing fluid during the DBA and not gas.
Since the recorded test leakage was zero SCCM, the expected leakage for these CIVs during a DBA would be approximately zero SCCM even though these valves are not tested with gas in the local leak rate test.
Engineering concluded that the overall containment isolation system with valves DW-AOV-l and DW-AOV-2 not sealed with IVSW would have performed its safety function