05000334/LER-2009-001, Surveillance Test Inadvertently Violates Technical Specification 3.6.1 for Containment Operability
| ML091630460 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 05/22/2009 |
| From: | Sena P FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-09-147 LER 09-001-00 | |
| Download: ML091630460 (8) | |
| 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) 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)(iii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 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)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(v), Loss of Safety Function |
| 3342009001R00 - NRC Website | |
text
FENOC FirstEnergy Nuclear Operating Company Beaver Valley Power Station' P.O. Box 4 Shippingport, PA 15077 Peter P. Sena III Site Vice President May 22, 2009 L-09-147 724-682-5234 Fax: 724-643-8069 10 CFR 50.73 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 LER 2009-001-00 Attached is Licensee Event Report (LER) 2009-001-00, "Surveillance Test Inadvertently Violates Technical Specification 3.6.1 for Containment Operability." This event is being reported in accordance with 10 CFR 50.73(a)(2)(i)(B).
There are no regulatory commitments contained in this submittal. Any actions discussed in this document that represent intended or planned actions are described for the NRC's information, and are not regulatory commitments.
If there are any questions or if additional information is required, please contact Mr. Colin P. Keller, Manager, Regulatory Compliance at 724-682-4284.
Sincerely, Peter P. Sena III Attachment cc:
Mr. S. J. Collins, NRC Region I Administrator Mr. D. L. Werkheiser, NRC Senior Resident Inspector Ms. N. S. Morgan, NRR Project Manager INPO Records Center (via electronic image)
Mr. L. E. Ryan (BRP/DEP)
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104 EXPIRES 08/31/2010 (9-2007)
, the NRC may sfor each block) not conduct or sponsor, and a person is not required to respond to, the digits/characters finformation collection.
- 3. PAGE Beaver Valley Power Station Unit Number 1 05000334 1 of 7
- 4. TITLE Surveillance Test Inadvertently Violates Technical Specification 3.6.1 for Containment Operability
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED SEQUENTIAL REV I D
FACILITY NAME DOCKET NUMBER MONTH DAY YEAR YEAR NUMBER NO.
MONTH DAY YEAR None NUMDOCKET NUMBER 03 26 2009 2009 001 00 05 22 2009 FACILITY NAME
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply) 1 20.2201(b)
El 20.2203(a)(3)(i) 0 50.73(a)(2)(i)(C)
D 50.73(a)(2)(vii)
E] 20.2201 (d)
El[ 20.2203(a)(3)(ii)
E] 50.73(a)(2)(ii)(a)
[] 50.73(a)(2)(viii)(A)
[] 20.2203(a)(1)
[] 20.2203(a)(4)
[]50.73(a)(2)(ii)(B)
[] 50.73(a)(2)(viii)(B)
_ 20.2203(a)(2)(i)
[] 50.36(c)(1)(i)(A)
[
50.73(a)(2)(iii)
ED 50.73(a)(2)(ix)(A)
- 10. POWER LEVEL E 20.2203(a)(2)(ii) 0 50.36(c)(1)(ii)(A)
E] 50.73(a)(2)(iv)(A)
ED 50.73(a)(2)(x)
E[] 20.2203(a)(2)(iii)
[] 50.36(c)(2)
E] 50.73(a)(2)(v)(A)
[:1 73.71 (a)(4) 100 %
20.2203(a)(2)(iv) 0 50.46(a)(3)(ii)
E] 50.73(a)(2)(v)(B)
E] 73.71 (a)(5)
Li 20.2203(a)(2)(v)
[
50.73(a)(2)(i)(A)
[
50.73(a)(2)(v)(C)
El OTHER Specify in Abstract below 20.2203(a)(2)(vi) 50.73(a)(2)(i)(B) 50.73(a)(2)(v)(D) or in DESCRIPTION OF EVENT (Continued) opened following a CIB signal, and resulted in a path to pressurize the pump's casing. The two CIVs on this RSS piping train were immediately de-energized, removing this portion of the RSS piping from potentially becoming an extension of the containment boundary.
Although the Required Action for TS 3.6.7 for one inoperable RSS subsystem was entered at the start of the surveillance procedure, it was not recognized that TS 3.6.1 for Containment operability was also being entered whenever a normally-closed manual drain/vent valve on the pump's casing was opened by the surveillance procedure while this train's CIVs were energized.
ANALYSIS OF EVENT
The Recirculation Spray System is designed to operate following a design basis LOCA.
The RSS pumps do not immediately start following a LOCA, but start only when sufficient water has been injected into containment to allow an appropriate level of water to accumulate in the containment sump for proper RSS pump operation. The RSS normally-open CIVs receive a signal to automatically open following a containment isolation-Phase B signal. The RSS piping will thus initially experience direct containment pressure following a LOCA, which makes this piping an extension of containment pressure boundary.
TS 3.6.1 requires that Containment shall be operable inModes 1 through 4. The Bases for TS 3.6.1 states that "All penetrations required to be closed during accident conditions are either 1) capable of being closed by an operable automatic containment isolation system or 2) closed by manual valves, blind flanges, or de-activated automatic valves secured in their closed positions." The RSS pump casing drain/vent penetrations are required to be closed during accident conditions, but were not adequately isolated from containment pressure during this surveillance procedure by appropriate automatic or passive isolation function when the RSS pump drain/vent manual valves were open with the RSS CIV's remaining energized while in Mode 1. TS 3.6.1 Required Action A requires that an inoperable containment be restored with one hour and Required Action B requires the Unit be in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> when Completion Time for Required Action A is not met. Thus, non-compliance with TS 3.6.1 occurs when the containment (i.e., penetrations in this case) is inoperable longer than 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. A RSS pump casing drain/vent valve was open for more than 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> during both the filling operation and the draining operation.
Thus, when this RSS pump flow surveillance procedure was being performed, BVPS Unit 1 inadvertently did not comply with TS 3.6.1, which was a condition prohibited by the plant's Technical Specifications and is reportable pursuant to 10CFR50.73(a)(2)(i)(B).
ANALYSIS OF EVENT (Continued)
An engineering evaluation was performed to assess the impact of the containment bypass path that existed during the surveillance procedure on the potential radiological doses following a postulated design basis accident (i.e., LOCA). This assessment determined that neither the licensing bases dose values nor the regulatory dose limits would have been exceeded. Additionally, based on the small unisolated valve openings and the maximum calculated flow rates through the flow path, this event is not expected to impact the Large Early Release Frequency (LERF). Therefore, this event is considered to have very low safety significance.
There was no loss of safety function for the Containment pursuant to 10 CFR 50.73(a)(2)(v) since the evaluation described above concluded that neither the licensing bases radiological dose values nor the regulatory radiological dose limits would have been exceeded if a LOCA were postulated to have occurred during the time that the drain/vent valves were open (providing potential leak paths from the containment) when this surveillance procedure was being performed.
CAUSE OF EVENT
The root cause of this event was determined to be less than adequate change management in revising the performance mode of the test without adequate evaluation of the impact on Technical Specification requirements. Narrow focus by procedure preparers, review organizations and end users on the most obvious TS requirement (Recirculation Spray System) resulted in a failure to identify that a more limiting TS requirement (Containment operability) was impacted by the test.
A contributing cause was that components associated with the Recirculation Spray System pump (vents, drains, pump seal, etc) were not consistently identified in site procedures as potential impacts on containment operability.
CORRECTIVE ACTIONS
- 1. The subject Recirculation Spray System surveillance procedures will be revised to include reference to Containment Technical Specification 3.6.1 and the necessary steps to ensure compliance, such as maintaining the suction and discharge CIVs in the de-energized and closed position.
CORRECTIVE ACTIONS (Continued)
- 2. Various other routine Recirculation Spray System pump procedures will be reviewed and revised as appropriate at both BVPS units to include a reference to Technical Specification 3.6.1 for Containment, and to verify that sequence of steps are appropriate to ensure compliance while in Modes 1 through 4.
- 3. A training needs analysis will be performed for the licensed operator initial and continuing training programs based on this event. This analysis will consider if current training material adequately emphasizes that the Outside Recirculation Spray System components (vents, drains, pump seal, etc) at both units are an extension of the Containment boundary, and the need to take a broad view of affected Technical Specifications when procedure changes are made such as changing the mode of performance.
- 4. A training needs analysis will be performed for Engineering training programs based on this event. This analysis will consider if current training material adequately emphasizes that the Outside Recirculation Spray System components (vents, drains, pump seal, etc) at both units are an extension of the Containment boundary, and the need to take a broad view of affected Technical Specifications when procedure changes are made such as changing the mode of performance.
- 5. The training program for the independent procedure reviewers (IQR) will be updated to include lessons learned from this event with emphasis on the responsibility of the IQR to ensure compliance with applicable Technical Specifications.
Completion of the aboveand other corrective actions are being tracked through the BVPS corrective action program.
PREVIOUS SIMILAR EVENTS
A review found two prior BVPS Unit No. 1 and one prior BVPS Unit No. 2 Licensee Event Report within the last three years for an event involving an actual or potential breach of containment integrity or events involving recent procedure changes for tests being conducted during power operation.
BVPS Unit 1 LER 2006-003, "Inadvertent Technical Specification Noncompliance Due to Inoperable Containment Isolation Valve". This LER involved not closing a containment isolation valve on a clearance boundary as expected, due to a combination of human error and inadequate supervision oversight.
PREVIOUS SIMILAR EVENTS (Continued)
" BVPS Unit 2 LER 2008-002, "Containment Air Lock Equalization Valve Inadvertently Left Open Following Routine Containment Entry". This LER involved not closing a containment isolation valve following a routine containment entry as required by the procedure, due to inappropriate procedure format.
BVPS Unit 1 LER 2007-001, "Valve Testing Program Change Inadvertently Leads to Condition Beyond Design Basis During Test". This LER involved a weakness of the procedure change process.
Both of the first two LERs were not similar to this LER because appropriate procedural steps and practices were not followed. In this 2009 Unit 1 LER, adequate containment isolation procedural guidance was not provided.
The third LER involved not recognizing the procedure change's effect on the design basis safety analysis which would not have been reasonably evident to the procedure performers. This 2009 Unit 1 LER involved not recognizing the procedure change's effect on a second Technical Specification requirement, which could have been understood by the procedure performers.
CR 09-56250 LICENSEE EVENT REPORT (LER)
Simplified Drawing BVPS Unit 1 Recirculation Spray System Outside Pump Subsystem Test Configuration Vent Vent MOV-1RS-156B 1RS-P-2B Pump Casing MOV-IRS-155B Inside Containment Outside Containment