05000390/LER-1917-011, Regarding Failure to Enter Technical Specification 3.6.3 for Containment Lsolation Valve
| ML17296A329 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 10/23/2017 |
| From: | Simmons P Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LER 17-011-00 | |
| Download: ML17296A329 (7) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(i) |
| 3901917011R00 - NRC Website | |
text
Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381 October 23,2017 10 cFR 50.73 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001
Subject:
Watts Bar Nuclear Plant, Unit 1 Facility Operating License Nos. NPF-90 NRC Docket Nos. 50-390 Licensee Event Report 39012017-011-00, Failure to Enter Technical Specification 3.6.3 for Containment lsolation Valve This submittal provides Licensee Event Report (LER) 39012017-011-00. This LER provides details concerning a human performance event where Watts Bar personnelfailed to enter a Technical Specification required action. This report is being submitted in accordance with 10 CFR 50.73(aX2XiXB).
There are no regulatory commitments contained in this letter. Please direct any questions concerning this matter to Kim Hulvey, WBN Licensing Manager, at @23) 365-7720.
Respectfully,,
Paul Simmons Site Vice President Watts Bar Nuclear Plant Enclosure cc: see Page 2
U.S. Nuclear Regulatory Commission Page 2 October 23,2017 cc (Enclosure):
NRC Regional Administrator - Region ll NRC Senior Resident lnspector - Watts Bar Nuclear Plant
NRC FORM 366 U.S. NUCI ' REGULATORY COMMISSION (a4-2O17) t"ffi LIcENSEE EVENr REPoRT (LER)
APPROVED BY Oltf- 'lO. 3150-0104 EXPIRES: 031311202A Estimated burden per se to comply with this mandatory collection request: B0 hours.
Reported lessons learned are incorporated into the licensing process and fed back to industry, Send comments regarding burden estimate to the lnformation Services Branch (T-2 F43), U.S.
Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e-mail to lnfocollects.
Resource@nrc.gov, and to the Desk fficer, Office of lnformation and Regulatory Affairs, NE0B-10202, (315G0104), ffice of Management and Budget, Washington, DC 20503, lf a means used to impose an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.
- 1. FACILITY NAME Watts Bar Nuclear Plant, Unit 1
- 2. DOCKET NUMBER 05000390
- 3. PAGE 1
OF 5
- 4. TITLE Failure to Enter Technical Specification 3.6.3 for Containment lsolation Valve
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED MONTHI DAY I YEAR YEAR I tt*tlr=#t REV NO.
MONTH I DAY YEAR FACILITY NAME I
DOCKET NUMBER 08 23 12017 2A17 r 011
- - 00 10 23 2017 FACIL]TY NAME I
DOCKET NUMBER
- 9. OPERATING MODE II.THISREPORTISSUBMITTEDPURSUANTTOTHEREQUIREMENTSOFl0CFR$r (Checkallthatapply) 1 n 20.2201(b) tl 2o.z2o3(aX3)(i) n 50.73(ax2x.ixA) n b0.73(ax2xviiixA) n zo.2zoi(d) n 2o.22os(aX3)(ii) n 50.73(aX2XiiXB) n 50.73(a)(2xviiixB) n 2o.2zo3(aX1) n 2o.2zo3(aX4) n 50.73(ax2)(iii) n 50.73(a)(2XixXA) n zo.22o3(a)(2)(.)
n 50.36(cx1)(ixA) n 50.73(a)(2Xiv)(A) n 50 73(aX2)(x)
- 10. POWER LEVEL 100 n zo.z2o3(a)(2)(ii) tr 50.36(c)(1)(iiXA) n 50.73(aX2Xv)(A) n rc.r1(a)(4) n zo.22o3(a)(2)(iii) tr s0.36(cX2) n 50.73(a)(2)(v)(B) n rc.r1(a)(5) tr 20.22a3(a)(2)(iv) n 50 46(ax3xii) n 50 73(aX2)(vxc) tr rs.7r(a)(1) n 2o.2zos(a)(2Xv) tr s0.73(a)(2)(ixA) n 50 73(ax2xvxD) n B.T7(aX2Xi) n 2o.2zo3(aX2Xvi)
X 50.73(a)(2)(i)(B) n 50.73(aX2Xv.i) tr ft.tr(ax2xii) n 50.73(a)(2)(i)(c) n OTHER Specify in Abstract below or in log entry was made to signify entry into the TS as required by procedure. The in-place clearance satisfactorily met the required actions of TS 3.6.3 condition A.1. to isolate the affected containment penetration flow path by use of at least one closed and de-activated automatic valve. However, without the required TS tracking program activated, personnel failed to comply with TS 3.6.3 condition A.2. to verify the atfected penetration flow path is isolated every 31 days.
Failure to enter the TS tracking program in accordance with procedure was a human performance error. Corrective actions included coaching and department operating experience communication.
NRC FORM 366 (44-2017)
I.
PLANT OPERATING COND]TIONS BEFORE THE EVENT Watts Bar Nuclear Plant (WBN) Unit 1 was at 100 percent rated thermal power (RTP).
II.
DESCRIPTION OF EVENT
A. Event Summary On August 23,2017, Watts Bar Nuclear Plant (WBN) personnel identified Technical Specification (TS) 3.6.3, Containment Isolation Valves, was not entered for on-going work related to 1-FCV-31-330, lncore lnstrument Room Air Handler Unit 1B Chilled Water System {EllS:KM}
lsolation Valve {EllS:lSV}. A clearance was placed on the valve May 17,2017 to support periodic replacement of the valve actuator O-rings and pressure regulator. Scheduled work was completed on May 19,2017, however, post maintenance testing was deferred due to additional scheduled work on the Chilled Water System. During a periodic review of upcoming surveillance requirements on August 23,2017, Operations Work Control discovered the work clearance (1-31-1021-\\ A /) remained in place awaiting post maintenance testing and there was no TS 3.6.3 entry for'1-FCV-31-330 being inoperable. Personnel immediately validated by administrative means the in-place clearance was suitable for compliance with TS 3.6.3 condition A.1 (isolate the affected penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) and the tags to comply with TS 3.6.3 condition A.2 (verify the affected penetration flow path is isolated every 31 days) had never been removed or temporarily lifted since initial installation on May 17,2017.
This event is being reported to the Nuclear Regulatory Commission (NRC) under 10 CFR 50.73(a)(2Xi)(B) as a condition prohibited by TechnicalSpecifications (TS).
B. lnoperable Structures, Components, or Systems that Contributed to the Event No inoperable systems beyond the identified valve contributed to this report.
C. Dates and Approximate Times of Occurrences
Date Time Event (EpT) 05117117 1642 Clearance 1-31-1021-\\ A / issued for work on 1-FCV-31-330 05119117 1020 Maintenance personnelsigned-off clearance 1-31-1021-\\ A /. Post maintenance testing deferred due other Chilled Water system work.
08123117 1011 Operations Work Control personnel discover the failure to track the inoperable valve, 1 -FCV-31 -330 08123117 1029 Entered TS 3.6.3 condition A for penetration X7 due to work on 1-FCV-31-330 08123117 1137 Condition Report 1331287 generated to document deficiency D. Manufacturer and Model Number of Components that Failed During the Event There were no failed components that contributed to this event.
NRC FORM s66A (04-2017)
E. Other Systems or Secondary Functions Affected
No other systems or secondary functions were affected.
F. Method of discovery of each Component or System Failure or Procedural Error
The failure to properly enter the TS was discovered during a periodic review of upcoming surveillance requirements. The Operations Crew recognized the surveillance could not be performed due to a clearance being in place. Upon further investigation, it was discovered the inoperable valve (1-FCV-31-330) had not been entered into the TS tracking program.
G. Failure Mode and Etfect of Each Failed Component Not applicable
H. Operator Actions
Upon discovery of the failure to enter TS 3.6.3 for 1-FCV-31-330, the Operations Work Control Staff immediately entered the TS and ensured compliance with the required actions.
l. Automatically and Manually lnitiated Safety System Responses There were no safety system responses associated with this issue.
III. CAUSE OF THE EVENT
A. The cause of each component or system failure or personnel error, if known.
Failure to enter the inoperable valve into the TS tracking program was a human performance error limited to a single individual.
B. The cause(s) and circumstances for each human performance related root cause.
Failure to enter the inoperable valve into the TS tracking program was a human performance error limited to a single individual
IV. ANALYSIS OF THE EVENT
TS 3.6.3, the containment isolation valve limiting condition for operation (LCO), was derived from the assumptions related to minimizing the loss of reactor coolant inventory and establishing the containment boundary during major accidents. As part of the containment boundary, containment isolation valve operability supports leak tightness of the containment. TS 3.6.3 is applicable in modes 1 through 4. Valve 1-FCV-31-330 is an outside containment isolation valve for the chilled water system. A work clearance was placed to allow periodic replacement of components on the air actuator for 1-FCV-31-330. The clearance boundary also disabled the associated inside containment isolation valve 1-FCV-31-329 thereby meeting the requirements of TS 3.6.3 condition A.1 for penetration X67. With 1-FCV-31-329 closed and
disabled, the penetration was isolated thereby fulfilling its safety function. Failure to enter TS 3.6.3 condition A.2. to verify the atfected flow path isolated every 31 days was determined to be a compliance issue only since the containment penetration was properly isolated per the TS required action at all times.
V. ASSESSMENT OF SAFETY CONSEQUENCES
After investigation, it was determined the safety function of the penetration was constantly maintained by the in-place clearance until time of discovery. At that time, the valve was entered into the TS tracking program to ensure compliance with TS 3.6.3 condition A.2 which verifies the affected penetration flow path is isolated every 31 days. Therefore, while this event is a condition prohibited by TS, the safety implications are minimal.
A. Availability of systems or components that could have performed the same function as the components and systems that failed during the event The in-place work clearance also disabled the inside containment isolation valve 1-FCV-31-329 which served to isolate the containment penetration.
B. For events that occurred when the reactor was shut down, availability of systems or components needed to shutdown the reactor and maintain safe shutdown conditions, remove residual heat, control the release of radioactive material, or mitigate the consequences of an accident Not applicable.
C. For failure that rendered a train of a safety system inoperable, an estimate of the elapsed time from the discovery of the failure until the train was returned to service Not applicable.
VI.
CORRECTIVE ACTIONS
This event was entered into the Tennessee Valley Authority (TVA) Corrective Action Program and is being tracked under Condition Report (CR) 1331287.
A. lmmediate Corrective Actions Restored compliance with TS 3.6.3 and conducted investigation.
B. Corrective Actions to Prevent Recurrence or to Reduce Probability of Similar Events Occurring in the Future Coaching was applied for those personnel directly involved with the event. Lessons learned were communicated to the Operations department.
NRC FORM 3664 tO4-2A17)
VII, PREVIOUS SIMILAR EVENTS AT THE SAME SITE LER 390/2016-009-00 describes a condition prohibited by TS 3.6.3 where the requirements to isolate a containment penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> was not met. The event described in this LER is similar since correct actions to comply with the TS were understood, and a human performance error resulted in the correct actions not being performed.
LER 390/2017-002-00 describes a condition where TS 3.6.3 was correctly entered for an inoperable penetration however, an incorrectly placed TS compliance clearance failed to properly isolate the subject penetration. The event described in this LER is different in that TS actions were entered, however a human performance error resulted in the incorrect containment isolation valve being disabled.
VIII. ADDITIONAL INFORMATION
None.
IX. COMMITMENTS None.
5 Page 5