05000373/LER-2004-001, Regarding Invalid Containment Isolation Valve Local Leak Rate Test Due to Inadequate Procedure

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Regarding Invalid Containment Isolation Valve Local Leak Rate Test Due to Inadequate Procedure
ML042810125
Person / Time
Site: LaSalle 
Issue date: 09/30/2004
From: Landahl S
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LER 04-001-00
Download: ML042810125 (4)


LER-2004-001, Regarding Invalid Containment Isolation Valve Local Leak Rate Test Due to Inadequate Procedure
Event date:
Report date:
Reporting criterion: 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications

10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition

10 CFR 50.73(a)(2)(iv)(A), System Actuation

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)(vii), Common Cause Inoperability

10 CFR 50.73(a)(2)(i)

10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded

10 CFR 50.73(a)(2)(viii)(B)
3732004001R00 - NRC Website

text

ExeIpnaM Exelon Generation Company, LLC www.exeloncorp.com Nuclear LaSalle County Station 2601 North 21"Road Marseilles, IL 61341-9757 September 30, 2004 10 CFR 50.73 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 LaSalle County Station, Unit 1 Facility Operating License No. NPF-1 I NRC Docket No. 50-373

Subject:

Licensee Event Report In accordance with 10 CFR 50.73 (a)(2)(i)(B), Exelon Generation Company, (EGC), LLC, is submitting Licensee Event Report Number 04-001-00, Docket No. 050-373.

Should you have any questions concerning this letter, please contact Mr. Terrence W. Simpkin, Regulatory Assurance Manager, at (815) 415-2800.

Respectfully, Susan Landahl Plant Manager LaSalle County Station

Attachment:

Licensee Event Report cc:

Regional Administrator - NRC Region IlIl NRC Senior Resident Inspector - LaSalle County Station

r;'C FORM 366 U.S. NUCLEAR REGULATORY APPROVED BY OMB NO. 3150-0104 EXPIRES 7-31-2004 (7-'2OOI)

COMMISSION

, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

1. FACILITY NAME LaSalle County Station, Unit 1
2. DOCKET NUMBER
3. PAGE 05000373 1 of 3 4.TITLE Invalid Containment Isolation Valve Local Leak Rate Test Due to Inadequate Procedure
5. EVENT DATE
6. LER NUMBER
7. REPORT DATE I

S. OTHER FACILITIES INVOLVED MO DAY YEAR YEAR SEQUENTIAL REV MO DAY YEAR FACILITY NAME DOCKET NUMBER NUIfBER NO 08 02 2004 2004 001 00 09 30 2004 FACILITYNAME DOCKETNUMBER 9.OPERATLNG 1

1l. TIIIS REPORT IS SUBMIITTEDPURSUANT TO TIIE REQUIREMENTS OF 10 CFR §: (Check all that apply)

10. POWER 100 LF.VFLl 20-2201(b) 0 20.2203(a)(3)(ii) 0 50.73(a)(2)(ii)(B) 0 73(a)(2)(ix)(A)

+J 20.2201(d) 0]

20.2203(a)(4) 0

]

50.73(aX2)(iii) 0 50-73(a)(2)(x) 20.2203(aXl) 50.36(c)(l)(i)(A)

D 50.73(a)(2)(iv)(A)

[

73-71(a)(4)

.f 20.2203(a)(2)(i) 0 50.36(c)(1)(ii)(A) 0

]

50.73(a)(2)(v)(A)

El 73-71(a)(5)

- 20 2203(a)(2)(ii)

[]

50.36(c)(2)

EJ 50.73(a)(2)(v)(B)

D OTHER 20.2203(a)(2)(iii)

U 50.46(a)(3)(ii) 0 50.73(a)(2)(v)(C)

Specify in Abstract below or in e202203(a)(2)(iv) 0 50.73(a)(2)(i)(A) 0 50-73(a)(2)(v)(D) e 20.2203(a)(2)(v) s 50.73(a)(2)(i)(B)

D 50.73(a)(2)(vii)

U 20.2203(a)(2)(vi)

E 50.73(a)(2)(i)(C)

D 50.73(aX2)(viii)(A)

U,-';

20.2203(a)(3)(i) 5 50.73(a)(2)(ii)(A)

I 50.73(a)(2)(viii)(B)

___*__________-_ads

12. LICENSEE CONTACT FOR TIS LER NAME TELEPHONE NUMBER (Include Area Code)

Vincent Balluff, Programs Engineering l (815) 415-2575CAUSE SYSTEM COMPONENT MANU REPORTABLE

CAUSE

SYSTEM COMPONENT MANU-REPORTABLE FACTURER TO EPIX v.______-'._.FACTURER TO EPIX

14. SUPPLEMENTAL REPORT EXPECTED
15. EXPECTED MONTH DAY YEAR YES NO SUBMISSION (If es. complete EXPECTED SUBMISSION DATE)

DATE li l

ABSTRACT

On 08/02/04, during the development of operator Local Leak Rate Test (LLRT) training, the LLRT Program Owner determined that an inaccurate procedural method for determining static head pressure correction factors was used in the test for the Reactor Core Isolation Cooling (RCIC) Barometric Condenser Vacuum Pump Discharge Containment Isolation check valves 1(2)E51-F028.

These valves were declared inoperable and the RCIC Vacuum Pump Discharge Isolation valves 1(2)E51-F069 were closed.

The procedural deficiency was corrected, and on 09/09/04, the Unit 1 valve (1E51-F028) was retested and failed its LLRT.

On 09/17/04, the valve was disassembled, the valve internals were cleaned, and the disc and spring were replaced. The valve passed its post-maintenance LLRT and was declared operable.

The cause of this event was a procedure error that has existed since 1986.

Corrective actions included revising the affected procedure to correct the correction factor method, and to revise all LLRT procedures requiring head correction to require a signature for the person calculating the correction factor and for the person verifying the calculation.

NRC FORM 366 (7-2001)

N-C (If more space is required, use additional copies of (If more space is required, use additional copies of NRC Form 366A)

LTS-100-38 was changed to use actual suppression pool level to determine the static head correction factor, and on 09/09/04, valve lESI-F028 was re-tested using the revised procedure.

The valve failed the LLRT.

On 09/17/04, the valve was disassembled, the valve internals were cleaned, and the disc and spring were replaced. The valve passed its post-maintenance LLRT and was declared operable.

This event is reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as an operation or condition prohibited by the plant's Technical Specifications.

The Unit 2 valve (2E51-F028) successfully passed its LLRT on 09/10/04.

C.

CAUSE OF EVENT

The root cause of this event was an inadequate procedure, in that LTS-100-38 used an inaccurate method for determining static head pressure correction factors.

This method has been in use since 1986.

D.

SAFETY ANALYSIS

The safety significance of this issue was minimal.

The correction factor for the static head pressure was minor, since the column of water is only about 1.5 feet.

Also, although the error was non-conservative for the 1(2)E51-F028 valves, it was conservative for the 1(2)E51-F069 valves, and the total leakage for the affected penetration was acceptable.

E.

CORRECTIVE ACTIONS

1. LTS-l00-38 was revised to use actual suppression pool level to determine the static head correction factor (Complete).
2. All LLRT procedures that use a static head pressure correction factor will be revised to include a sign off for the person calculating the correction factor with an additional sign off for the person verifying that calculation (AT#

241004-13).

F.

PREVIOUS OCCURRENCES

A review of Licensee Event Reports for the past 10 years identified no previous occurrences of a failed or invalidated LLRTs due to procedural inadequacy.

G.

COMPONENT FAILURE DATA

No components failed during this event.