05000334/LER-2006-003, Regarding Inadvertent Technical Specification Noncompliance Due to Inoperable Containment Isolation Valve
| ML062620250 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 09/14/2006 |
| From: | Lash J FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-06-139 LER 06-003-00 | |
| Download: ML062620250 (6) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 3342006003R00 - NRC Website | |
text
FENOC FirstEnergy Nuclear Operating Company James H. Lash 724-682-5234 Site Vice President Fax: 724-643-8069 September 14, 2006 L-06-139 Beaver Valley Power Station, Unit No. 1 Docket No. 50-334 License No. DPR-66 LER 2006-003-00 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 The following Licensee Event Report is submitted:
LER 2006-003-00, 10 CFR 50.73(a)(2)(i)(B), "Inadvertent Technical Specification Noncompliance Due to Inoperable Containment Isolation Valve."
OL James H. Lash Attachment c:
Mr. T. G. Colburn, NRR Senior Project Manager Mr. P. C. Cataldo, NRC Senior Resident Inspector Mr. S. J. Collins, NRC Region I Administrator INPO Records Center (via electronic image)
Mr. L. E. Ryan (BRP/DEP)
S~2-2.
Abstract
On July 22, 2006, Beaver Valley Power Station (BVPS) Unit 1 initiated a work activity to replace a manual isolation valve in the Pressurizer liquid sample line outside of containment. The clearance intended to close and de-energize the outside containment isolation valve (TV-1SS-100A2) which is a normally open, fail-close, air-operated valve. The clearance activity isolated the air supply to this valve's solenoid actuator at approximately 1315 hours0.0152 days <br />0.365 hours <br />0.00217 weeks <br />5.003575e-4 months <br />; however, the clearance did not provide adequate instructions to bleed off the trapped air in the valve's actuator, keeping this valve open. At approximately 2310 hours0.0267 days <br />0.642 hours <br />0.00382 weeks <br />8.78955e-4 months <br />, an oncoming Reactor Operator noted during his Control Board walk-down that the valve position indicating light for containment isolation valve TV-1 SS-100A2 was indicating open with a clearance tag posted on it.
The valve was placed in the closed position at 2351 hours0.0272 days <br />0.653 hours <br />0.00389 weeks <br />8.945555e-4 months <br />. BVPS Unit I did not comply with Technical Specification 3.6.3.1 Action a for an inoperable containment isolation valve, which is reportable pursuant to 10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by the plant Technical Specifications.
The root causes for this event were 1) human performance errors (inattention to detail) occurring during the development, review/approval and implementation process that resulted in inadequate/incomplete clearance instructions and 2) supervision/management failed to provide the necessary oversight and reinforce expectations to ensure that error prevention tools were used during work execution. The safety significance of this event was very low.
NRC FORM 366 (6-2004)
- 1 (If more space is required, use additional copies of (If more space is required, use additional copies of NRC Fonn 366A)
Simplified Sketch of Valves Containment wall Pzr Sample Sink TV-1SS-108 TV-1SS-10OAl TV-1SS-100A2 ISS-27 I
Drain Valve
REPORTABILITY
At approximately 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br />, a maintenance clearance was initiated to isolate sample system manual valve 1 SS-27 just downstream of the outside containment isolation valve, TV-1SS-100A2. The air supply to TV-1SS-100A2 was isolated shortly thereafter. Since the valve's actuator was not vented, the valve remained open, and was inoperable due to it not being capable of automatic closure. The upstream inside containment isolation valve (TV-1 SS-1 00A1) remained in its normally open position during this time (which was not intended to be closed). Although the next further upstream valve inside containment, TV-1SS-108, remained in its normally closed position, it did not have its power removed.
BVPS Unit I Technical Specification 3.6.3.1, Action a states "With one or more penetration flow paths with one containment isolation valve inoperable, isolate the affected penetration flow path within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured,...
Otherwise, be in at least Hot Standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Cold Shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />."
Since there was no closed and de-energized automatic valve, no closed manual valve, no blind flange or a check valve with flow secured, then BVPS Unit I did not comply with Action a within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of TV-1SS-100A2 becoming inoperable and was not in Hot Standby within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> since TV-1 SS-1 00A2 was not closed and de-energized until approximately 10.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after its air supply was initially isolated.
Thus, this was an inadvertent non-compliance with Technical Specification 3.6.3.1, and is reportable pursuant to 10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by the plant Technical Specifications.
(If more space is required, use additional copies of (If more space is required, use additional copies of NRC Form 366A)
CORRECTIVE ACTIONS
- 1. Upon discovery, actions were immediately taken to close and de-energize the affected containment isolation valve.
- 2. The causes of this event and the related ineffective human performance behaviors will be reviewed with BVPS Unit I and Unit 2 Operations personnel involved with the clearance process.
- 3. A repetitive administrative task will be developed for Operations supervision/
management to perform field observations that focus on the use of human performance tools during clearance activities to ensure Technical Specification references are provided. Operations Management will reinforce expectations for clearance development.
Completion of the above and other corrective actions are being tracked through the BVPS corrective action program.
PREVIOUS SIMILAR EVENTS
A review found no prior BVPS Unit I and one prior BVPS Unit 2 Licensee Event Report within the last three years for an event involving a containment isolation valve or a work clearance:
- BVPS Unit 2 LER 2005-001, "Containment Isolation Valve Relay Failure Unknowingly Leads to Technical Specification Noncompliance." BVPS Unit 2 LER 2005-001 involved a cascading component failure, which is not similar to BVPS Unit I LER 2006-003 event.
COMMITMENTS
There are no new commitments made by FirstEnergy Nuclear Operating Company for BVPS Unit I in this document.
NRC FORM 365A (1-2001)