05000364/LER-2019-001, Inoperable Containment Isolation Valve Due to Design Control Error

Inoperable Containment Isolation Valve Due to Design Control Error

ML19161A200
Person / Time
Site:	Farley
Issue date:	06/10/2019
From:	Gayheart C Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-19-0671 LER 2019-001-00
Download: ML19161A200 (5)

LER-2019-001, Inoperable Containment Isolation Valve Due to Design Control Error

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2) 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 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(i)
3642019001R00 - NRC Website

text

~ Southern Nuclear dU~ 1 0 2019 Docket No.:

50-364 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Cheryl A. Gayheart Regulatory Affairs Director Joseph M. Farley Nuclear Plant - Unit 2 Licensee Event Report 2019-001-00 3535 Colonnade Parkway Binningham, Alabama 35243 205.992.5316 tel 205.992.7885 fax cagayhea@ southernco.com NL-19-0671 Inoperable Containment Isolation Valve due to Design Control Error Ladies and Gentlemen:

In accordance with the requirements of 10 CFR 50.73(a)(2)(i)(B), Southern Nuclear Company is submitting the enclosed Licensee Event Report for Unit 2.

This letter contains no NRC commitments. If you have any questions regarding this submittal, please contact Gene Surber at (334) 814-5448.

Respectfully submitted, Cheryl A.

y art Regulatory Affairs Director CAG/rgs/scm Enclosure: Unit 2 Licensee Event Report 2019-001-00 cc:

Regional Administrator, Region II NRR Project Manager-Farley Nuclear Plant Senior Resident Inspector-Farley Nuclear Plant RTYPE: CFA04.054

Joseph M. Farley Nuclear Plant - Unit 2 Licensee Event Report 2019-001-00 Inoperable Containment Isolation Valve due to Design Control Error Enclosure Unit 2 Licensee Event Report 2019-001-00

NRC FORM366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3160.0104 EXPIRES: 03/3112020 (04-2018)

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3.Page Joseph M. Farley Nuclear Plant, Unit 2 05000 364 1

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4. Title Inoperable Containment Isolation Valve due to Design Control Error

5. Event Date

6. LER Number

7. Report Date

8. other Facilities Involved Month Day Yeor Yeor I Sequentlll I Rtv Month Doy Yeor

• • lillY Nome Doclclt Number Number No.

05000 2019 2019 001 00 0~

.;ao1c:t FodltyNeme DoclcltHumbor 04 12

/D 05000

9. Operating Mode

11. This Report Is Submitted Pursuant to the Requirements of 10 CFR §: (Check all that apply) 0 20.2201(b) 0 20.2203(a}(3)(i) 0 S0.73(a}(2)(ii)(A) 0 50.73(a}(2)(Yili}(A}

6 0 20.2201(d)

D 20.2203(*><3><

0 S0.73(a)(2}(d)(B) 0 50.73(a)(2)(Yii)(B)

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0 20.2203(&)(4) 0 50.73(a}(2){iii) 0 50.73(a)(2)(ix}(A) 0 20.2203(&}(2)(1) 0 50.36(c)(1)(1)(A) 0 50.73(a)(2)(1v)(A) 0 50.73(a}(2)(x)

10. Power Level 0 20.2203(a}(2)(ti) 0 50.38(c)(1}(ii)(A) 0 50.73(a)(2)(v)(A) 0 73.71(&}(4) 0 20.2203(a)(2)(1K) 0 50.36(c}(2}

0 50.73(a)(2)(v)(B)

D 73.71(a)(S) 0 20.2203(a)(2)(1v)

D 50.46(a)(3)(1i) 0 50.73(a)(2)(v)(C) 0 73.77(1}(1) 000 D 20.2203(a)(2)(v) 0 50.73(a)(2)(i)(A) 0 50.73(a)(2)(v)(D) 0 73.77(a}(2)(i) 0 20.2203(a)(2)(vt) 0 50.73(a)(2)(i)(B) 0 50.73(a)(2)(vll)

D 73.77(1)(2)(H) 0 50.73(a)(2)(i)(C) 0 Other (Specify In Abstract below or in NRC Form 366A)

12. Licensee Contact for this LER Licensee Contact Telephone Number (Include Area Code)

Gene Surber, Licensing Manager 334-814-5448 Couse Syttem I Component I Monufoc:tuNr Reportllblelo ICES J c.u ** I Byslem I Componetll Mlnufac:luNr I Raportlblelo ICES A

81 ISV L200 Yes

14. Supplemental Report Expected Monlh Doy Year 0 Yea (If yes, complete 15. Expected Submission Date) 0 No

15. Expected Submission Date Abstract (Limit to 1400 spaces, i.e., approximately 14 single-spaced typewritten lines)

On April12, 2019, with Farley Nuclear Plant (FNP) Unit 2 in Mode 6 (refueling) it was determined through surveillance testing that Containment Isolation Valve (CIV) Q2P16MOV3131 (MOV-3131), Service Water (SW) From Reactor Coolant Pump (RCP)

Air Cooler would not close on a simulated Safety Injection (SI) Signal. Following troubleshooting it was identified on April 24, 2019 (Mode 6) that MOV-3131 was incorrectly wired. An omission error completed in a previous design change (October 2017) created a wiring discrepancy that prevented MOV-3131 from closing on an Sl signal. This condition is being reported pursuant to the requirements of 10 CFR50.73(a)(2)(i)(B) as an operation prohibited by the Technical Speciftcations for the inoperable containment isolation valve.

The wiring discrepancy was caused by an engineering human performance error during issuance of a design change. The circuit wiring was corrected, post-maintenance testing was completed satisfactorily, and the valve was returned to service.

NRC FORM 368 (04-2018)

ANALYSIS OF THE EVENT

Technical Specification Surveillance Requirement 3.6.3.6 verifies that each automatic containment isolation valve that is not locked, sealed or otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal. Based on the design control error the containment isolation signal for MOV-3131 has not worked since October of 2017. This resulted in operation of the facility in a manner prohibited by the Technical Specifications. However, the isolation function would have been met by MOV-3134 which was fully OPERABLE.

In addition to closing requirements, containment isolation valves also have pressure integrity requirements. Pressure integrity for the containment penetration is tested in accordance with the integrated and local leak rate testing (1/LLRT) requirements and there have been no containment penetration 32 1/LLRT failures between April2019 (e.g., the time of discovery) and October 2017 (e.g., when the legacy issue occurred).

Based on these test results, FNP concludes that although the closure circuit for MOV-3131 was inoperative, the penetration integrity was tested satisfactory during the 1/LLRT tests, proving the valve was positioning and functioning as a containment isolation feature between October 2017 and Apri12019.

SAFETY SIGNIFICANCE

Although automatic closure of MOV-3131 was not tested in the 2017 U2 Outage, the valve did respond to open I close signals as demonstrated by successful LLRT test results. Based on the above, containment integrity was not challenged by this legacy condition. In addition, if MOV-3131 had remained open during post-accident containment isolation the 'B' channel containment isolation signal would have closed the outboard containment isolation valve (MOV-3134).

Additionally, operators would have been alerted to the problem by MCB indication and closed MOV-3131 per plant emergency procedures. This event was within the analysis of the UFSAR Chapter 15 and the wiring error had no impact on the health and safety of the public. There was no release of radioactivity above Part 100 limits.

REPORT ABILITY:

With MOV-3131 not capable of automatically closing, the valve was not capable of performing its design function of isolating containment as required by TS LCO 3.6.3. This valve was inoperable for the entire operating cycle, which exceeded the Completion Time specified in TS LCO 3.6.3 to restore the valve to Operable status or shutdown the plant.

Therefore, this issue is being reported in accordance with 10 CFR 50. 73(a)(2)(i)(B) as it resulted in operation of the plant in a condition prohibited by the TS. This event had very low safety significance as an additional failure would be required to create a potential containment bypass pathway. Thus, this issue did not result in a loss of safety function.

CORRECTIVE ACTIONS

The circuit wiring was corrected, post-maintenance testing was completed satisfactorily, and MOV-3131 was returned to service. Corrective actions will also include a training performance analysis for the engineering staff on design control, planning, and identification of modification testing requirements.

SIMILAR EVENTS

None NRC FORM 38IIA (04-2018)

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