05000324/LER-1995-001, :on 950105,discovered That Hydrogen/Oxygen Analyzer Sys Drain Valve Improperly Assembled During Sys Mod in 1987.Caused by Inadequate Mod Installation Instructions. Valve Reassembled & Bench Tested
| ML20078J143 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 02/02/1995 |
| From: | Cowan J, Tabor S CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| BSEP-95-0060, BSEP-95-60, LER-95-001, LER-95-1, NUDOCS 9502070302 | |
| Download: ML20078J143 (6) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i) |
| 3241995001R00 - NRC Website | |
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CP&L unummmmmmmme Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461-0429 FEB 021995 SERIAL: BSEP-95-0060 10CFR50.73 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 BRUNSWICK NUCLEAR PLANT UNIT 2 DOCKET NO. 50-324/ LICENSE NO. DRP-62 LICENSEE EVENT REPORT 2-95-001 t
Gentlemen:
in accordance with the Code of Federal Regulations, Title 10, Part 50.73, Carolina Power &
[
Light Company submits the enclosed Licensee Event Report.
This report fulfills the requirement for a written report within thirty (30) days of a reportable occurrence and is submitted in accordance with the format set forth in NUREG-1022, September 1983.
Please refer any questions regarding this submittal to Mr. M. A. Turkal at (910) 457-3066.
Very truly yours, Oh.
W ?S J. Cowan, Director-Site Operations Brunswick Nuclear Plant SFT/
Enclosures 1.
Licensee Event Report 2.
Summary of Commitments cc:
Mr. S. D. Ebneter, Regional Administrator, Region 11 Mr. D. C. Trimble, Acting NRR Project Manager - Brunswick Units 1 and 2 Mr. C. A. Patterson, Brunswick NRC Senior Resident inspector The Honorable H. Wells, Chairman - North Carolina Utilities Commission t
9502070302 950202 PDR ADOCK 05000324 I
l S
i NRC FORM 366 U.S. NUCLEAR REGUL.ATORY COWIMISt.. 1 APPROVED OMB NO. 3150-0104
.i (5/92)
EXPIRES: 5/31/95 o
ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REOUEST; 50.0 HRS.
FORWARD LICENSEE EVENT REPORT (LER)
COMMENTS REGARDiNG BURDEN EstruATE TO THE iNFORuATiOu AND RECORDS MANAGEMENT BRANCH IMNBB 7714L U ;. NUCLEAR REGULATORY COMMISSION. WASHINGTON. DC 20555 0001. AND TO THE PAPERWORK REDUCTION PROJECT 13150-01041. OFFICE OF MANAGEMENT AND BUDGET. WASHINGTON. DC 20503.
.F#
FQCILf1 f NAME til DOCKET NUMBER (2)
PAGE131 Brunswick Steam Electric Plant, Unit 2 05000324 1 of 4 TITLE 44)
Invalid Technical Specification Surveillance Due to Improper Assembly of a Hydrogen / Oxygen Analyzer System Drain valve EVENT DATE (5)
LER NUMBER (6)
REPORT DATE (7)
OTHER FACILITIES INVOLVED (8)
MONTH DAY YEAR YEAR MONTH DAY YEAR NUMBER NUMBER 01 05 95 95 00 02 02 95 FACILRY NAME DOCKET NUMBER OPERATINO THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR i: (Check one or more of the followingH11) 01 MODE (9) 20.402(b) 20.405(c) 50.73(aH2Hw) 73.71(b) a cW MMaH2N 73 R c)
POWER 00 LEVEL (10) 20.405(aH1 Hei) 50.304 0 2) 50.73(aH2Hvii)
OTHER 20 405(aH1Hni)
X 50.73(aH2Hi) 50.73(aH 2HviiiHA) jg3(
(Specify in Abstract
,$ M 20.405taH1Hw) 50.73(aH2Hn) 50.73(aH2HvisiHB) and Text)
> pm
/D > p, 20.405(aH I)M 50.73(aH216iil 50.73(aH2Hz)
LICENSEE CONTACT FOR THIS LER (12)
NAME TELEPHONE NUMBER Steve F.
Tabor, Regulatory Affairs Specialist (910) 457-2178 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)
CAUSE
SYSTEM COMPONE NT MANUFACTURER
CAUSE
SYSTEM COMPONENT MANUFACTURER O
R SUPPLEMENTAL REPORT EXPECTED (14)
EXPECTED M NTH DAY YEAR SUBMIS910N YES y
NO DATE (15) m v. nww. EXPECT [D SUBMIS$10N DATE)
ABSTRACT (Limit to 1400 spaces. Le. approximatelY fif teen single space typewntten hnes) (16)
On January 5, 1995, Units 1 and 2 were operating at 100% power.
An ongoing investigation into a failure of the Unit 2 Containment Hydrogen / Oxygen Analyzer Drain Tank drain valve, 2-CAC-SV-4409-5, to pass flow, revealed that the valve had been improperly reassembled during system modification in 1987.
As a result, the Unit 2 Primary Containment Leakage Technical Specification surveillances performed on a portion of the Hydrogen / Oxygen Analyzer system since August of 1993 were invalid.
The improper reassembly of the valve is attributed to inadequate modification instructions and post modification testing.
Corrective actions taken include the proper assembly and testing of the valve and the testinct of the other Unit 1 and Unit 2 Containment Hydrogen / Oxygen Analyzer Drain Tank drain valves to ensure their proper operation.
A review of the Containment Hydroger/ Oxygen Analyzer Drain Tank drain valve corrective maintenance procedure determined that the procedure is adequate for ensuring proper valve operation following valve assembly. The safety significance of this event is minimal in that operating history indicates that analyzer function was not degraded as a result of improper reassembly of the valve.
Furthermore, the recent leakage test of the threaded components downstream of the 2-CAC-SV-4409 performed post repair of the valve did not indicate leakage in excess of acceptable limits. No previous LERs were identified which involved invalid Technical Specification required testing caused by inadequate procedures.
The NUREG-1022 cause classification for this event is D, Defective Procedure.
l
",U. S. NUCLEAR REGULATORY COMMISSION APPROVED OMB NO. 3150-0104 (5/92)
EXPIRES: 5/31/95 j
E STIM ATED BURDEN PER FCSPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REQUEST; 60 0 HRS.
FORWARD UCENSEE EVENT REPOR.e (LER)
COMMENTS REOARolNo.UROEN ESTIMATE TO TsE,NFORM A110N ANo TEXT CO:tTINUATION RECORDS MANAGEMENT ORANCH (MNDS 7714L US NUCLE AR REGULATORY COMMISSION. WMHINGTON. DC 20556 0001. AND TO THE PAPE RWORK REDUCTION NOJECT (3160 0104L OFriCE OF M ANAGEMENT AND BUDGET, WASHINGTON, DC 20603.
F ACILITY NAME (1)
DOCKET NUMBER (2)
LER NUMBER 16)
PAGE (3)
SEOUENTIAL HEVISION Brunswick Steam Electric Plant 05000324 2 of 4 Unit 2 95 00 TEXT (If nmre space is required, use addttenalNRC form 366A's!(17)
IITLE Invalid Technical Specification Surveillance Due to Improper Assembly of a Hydrogen / Oxygen Analyzer System Drain Valve INITIAL CONDITIONS On January 5, 1995, Units 1 and 2 were operating at 100% power. An investigation was in progress to determine the validity of the Technical Specification required primary containment leakage surveillance perf ormed on the Unit 2 Hydrogen /Cxygen Analyzer System as related to the failure of the Unit 2 Containment Hydrogen / Oxygen Analyzer Drain Tank drain valve, 2-CAC-SV-4409-5, identified on December 21, 1994.
EVENT NA~-(RATIVE On December 8, 1994, at 0500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br />, the Unit 2 Division I Containment Hydrogen / Oxygen Analyzer, 2-CAC-AT-4409, was rendered inoperable to support planned corrective and preventive maintenance activities.
Following completion of the work activities and during the post maintenance testing the system low-flow annunciator repeatedly alarmed.
On December 21, 1994, during troubleshooting of t' e low flow condition, a problem o
unrelated to the low flow condition was discovered.
The Unit 2 Containment Hydrogen / Oxygen Analyzer Drain Tank valve, 2-CAC-SV-4409-5, would not pass flow although valve position instrumentation indicated the valve to be in the open position.
On December 23, 1994, a Condition Report was generated in accordance with the requiremento of the Corrective Action Program to address the 2-CAC-SV-4409-5 f ailure.
An investigation into the cause of the f ailure was initiated. Furthermore, since the 2-CAC-SV-4409-5 is required to pass flow when cycled to the open position to support performance of Technical Specification required primary containment leakage surveillance, the scope of the investigation included a review of the validity of previous Technical Specification surveillances.
On December 24, 1994, at 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br />, the 2-CAC-SV-4409-5 was reassembled and tested to ensure proper operation of the valve. On December 25, 1994, at 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />, following performance of the system functional test, the Unit 2 Hydrogen / Oxygen Analyzer was declared operational. Additionally, the Unit 2 Division II and Unit 1 Divisions I and II Hydrogen / Oxygen Analyzer Drain Tank drain valves were tested to e b inate the possibility of a conmon mode f ailure and f ound to be fully operational.
On January 5, 1995, the root cause investigation determined that the failure of the 2 -CAC-SV-4 4 0 9-5 valve t o - rs flow resulted f rom improper reassembly of the valve which occurred during modificaw;;n of the Hydrogen / Oxygen Analyzt.r system in 1987.
By design, upon opening a sample line isolation valve, the 2-CAC-SV-4409-5 valve auto-opens to allow draining of one of the Hydrogen / Oxygen Analyzer system moisture drain tanks. System operating history does not indicate the occurrence of previous analyzer system operability concerns related to moisture collection problems; consequently, the inability of the valve to open was not recognized until this event.
The investigation also revealed that the Hydrogen / Oxygen Ant yzer system primary containment leakage surveillances performed since August of 159:- were invalid due to 2-CAC-SV-44 09-5 valve's inability to pass flow. The testing methodology incorporated by the surveillance since August 23, 1993, required the 2-CAC-SV-4409-5 valve to be in
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?U. S. NUCLEAR REGULATORY COfAMISSION APPROYED 9MB NO. 3150-0104 (5/92)
EXPIRES: 5/31/95 ISTIMAf tD BUHDIN Pf R HESPONSE TO COMPL Y WIT H THi%
LICENSEE EVENT REPORT (LER)
'"$ 7^$"Gl%'BunoruIsS,7E d dr i OaME"L^NE C
TEXT CONTINUATION nrcoRDS MAN AGE MENT BRANCH (MNBB 7714L US NUCL( AR HIGUtATORY COMMIS510N, WASHINGTON, DC 20556 0001. AND TO THE PAPIRWORK Mf DUCTION PHOJE CT (31bO-0104L OFFICE Of MANAGlMiNT AND BUDGET. WASHINGTON. DC 20$03 f ACILITY NAME '9 DOCKET NUMBER (?)
LER NUMBER (Cd PAGE G SFOUINTIAL Hf y1SION Brunswick Steam Electric Plant 05000324 3 of 4 Unit 2 95 00 TlxT (if more space is required, use additenalNHC l' arm 366A's! 01) the open position to allow pressurization and leak testing of the downstream threaded connections.
Prior to August 23, 1993, the Hydrogen / Oxygen Analyzer system primary containment leakage surveillance methodology was such that the position of the 2-CAC-SV-4409-5 valve could not affect the validity of the test (i.e.,
with the valve in either the open or closed position the required test pressure was applied to the system).
Therefore, although the 2-CAC-SV-4409-5 valve was impaired since modification of the system in
- 1987, the Technical Specification required leak testing of the Hydrogen / Oxygen Analyzer system was valid ureil the testing methodology was revised in August of 1993.
This event is being reported in accordance with the requirements of 10 CFR 50.73 (a) (2) (i) in that the invalid Technical Specification surveillance of the Unit 2 Hydrogen / Oxygen Analyzer System leakage performed in May of 1994 constitutes a condition prohibited by the plant's Technical Specification CAUSE OF EVE!q Investigation into the f ailure of the Unit 2 Containment Hydrogen / Oxygen Analyzer Drain Tank drain valve, 2-CAC-SV-4409-5, to pass flow, revealed that the valve had been disassembled during system modification in 1987.
Disassembly was required due to a failure of the local leak rate test performed on the valve during post modification testing. During valve reassembly the valve's plunger to disc rod alignment tolerances were not maintained rendering the valve incapable of passing flow although valve position instrumentation indicated that the valve was open.
The failure to properly reassemble the valve is attributed to inadequate modification installation instructions and post modification testing.
The post modification testing relied solely upon position indication rather than a flow check to verify the valve would pass flow when cycled to the open position.
CORRECTIVE ACTIONS
The 2-CAC-SV-4409-5 valve was reassembled and bench tested to ensure proper operation.
Following installation, leakage testing of the threaded connections downstream of the 2-CAC-SV-4409-5 valve was performed and no leaks were identified.
The Unit 2 Division II and Unit 1 Division I and II Hydrogen / Oxygen Analyzer Drain Tank drain valves were tested to ensure proper operation.
The valves were found to be functioning properly.
A review of installed valves which are similar or identical in design to the 2-CAC-SV-4409-5 was performed. This review provided the assurance that these valves are capable of passing flow when placed in the cpen position.
Since 1987, a corrective maintenance procedure was generated to proceduralize the process f or assembly and bench testing of those valves which are similar or identical in design to the 2-CAC-SV-44 09-5 valve. A review of this procedure determined that the incorporated bench test is adequate for ensuring proper valve operation post maintenance.
Additionally, a review of the existing plant modification procedures determined that this corrective maintenance procedure would be included in the installation and post modification testing development.
i iU. S. NUCLEAR REGULATORY COMMISSION APPROVED OMB NO. 3160-0104 i
15/9 2)
EXPIRES: 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH il5 INFORMATION COLLECTION REQUfST: 60 0
- HRS, FORWARD LICENSEE EVENT REPORT (LER)
COMMENTS REoARo,No suRoEN ESTiuATE To THE iNFORMATiON ANo i
TEXT CONTINUATION RECORDS MANAGEMENT BRANCH (MNDB 7714), U.S. NUCLEAR REQULATORY COMMIS$10N, WASHINGTON. DC 20566 0001. AND TO THE PAPF.RWORK REDUCTION PROJECT 0150 01041. OFFICE OF l
MANAGEMENT AND BUDGET, WASHINGTON, DC 20603, l
FACluTY NAME (U DOCKET NUMBER (2)
LER NUMBER 46)
PAGE (3l SFOUENTIAL REVISION Brunswick Steam Electric Plant 05000324 4 of 4 Unit 2 95 00 t
TEXT fit more space is requked. Use additionalIVRC l'orm 366A 's) (17) l
SAFETY ASSESSMENT
The safety significance of this event is considered minimal for the following reasons:
i Historical evidence does not indicate that the failurr of the 2-CAC-SV-4409-5 valve to open and thus drain the Unit 2 Division I HydN ;en/Ox,1 - Analyzer Drain Tank has prevented the monitor from perf orming it.i intend.a o.lign function during normal plant operation.
i The leakage testing of threaded components downstream
.r h
2-
.C-SV-4409-5 valve performed following the recent repair of tne valve l a ni.d a no leakage.
PREVIOUS SIMILAR EVENTS
t No similar events involving invalid Technical Specification testing as a result of inadequate procedures has been previously reported.
i EIIS COMPONENT IDENTIFICATION
+
System / Component EIIS Code Conte.inment Environmental Monitoring System IK 2-CAC-SV-4409-5 IK\\ASV j
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Enclosure List of Regulatory Commitments The following table identifies those actions committed to by Carolina Power &
Light Company in this document.
Any other actions discussed in the submittal represent intended or planned actions by Carolina Power & Light Company. They are described to the NRC for the NRC's information and are not regulatory
commitments
Please notify the Manager-Regulatory Af f airs at the Brunswick Nuclear Plant of any questions regarding this document or any associated regulatory commitments.
Committed
Commitment
date or outage NONE i
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