05000397/LER-2013-003, Operation Prohibited by Technical Specifications Due to Valve Leakage

Operation Prohibited by Technical Specifications Due to Valve Leakage

ML13231A111
Person / Time
Site:	Columbia
Issue date:	08/01/2013
From:	Hettel W Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-13-109 LER 13-003-00
Download: ML13231A111 (4)

LER-2013-003, Operation Prohibited by Technical Specifications Due to Valve Leakage

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2) 10 CFR 50.73(a)(2)(1)
3972013003R00 - NRC Website

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Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-37 LICENSEE EVENT REPORT NO. 2013-00$'Q0

Dear Sir or Madam:

Transmitted herewith is Licensee Event Report No. 2013-003-00 for Columbia Generating Station. This report Is submitted pursuant to 10 CFR 50.73(a)(2)(l)(B).

There are no commitments being made to the NRC by this letter. If you have any questions or require additional information, please contact Mr. J. R. Traut,,tter, Regulatory Compliance Supervlo, at (509) 377-4337.

Respectfully, W. G. Hettel Vice President, Operations

Enclosure:

Licensee Event Report 2013-003-00 cc: NRC Region IV Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C A. J. Rapacz - BPAI1 399 W.A. Horin - Winston & Strawn

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APP7OVED BY 0MB NO. 3150-0104 EXPIRES i1(31/2013' (10-2010)

Estimated burden per response to comply with this mandatory collection request:

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Office of Information nd Regulatoi Affairs, NEOB-10202 (3150-0104). Office of (See reverse for required number of Managemant end Budget, Wsngon, DC 20503. If s means used to Impose an digits/characters for each block) hIformatio collection does not disly a currently vaid OMB contr number, the NRC may not conduct or sponsor, and a person Is not required to respond to, the Informationcollectio.

1. FACILITY NAME L DOCKET N E

PAGE Columbia Generating Station "00 l

1 OF3

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&. EVENT DATE

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Specify in Abstract below

.... _or In NRC Form 386A 1.. LICINSE COnACT F

,P TS MR FACIUTY NAME TELEPHONE NUMBER (Include Area Code)

Lisa Williams, Licensing Supervisor

.(5

) 377-8148 CAUSE_

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SYSTEM COMPONENT FACTURER TO EPIX

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SYSTEM COMPONENT FACTURER TO EPIX

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_A7 YE7AR I@ YES (If yes, complete 15. EXPECTED SUBMISSION DATE)

E0 NO OAT 10 16 2013 ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)

On June 3, 2013, with Columbia Generating Station in a planned refueling outage and the reactor cavity flooded up (Mode 5), leakage past a closed isolation valve associated with one hydraulic control unit on the control rod drive system was observed through a drain line. This leakage originated from the reactor vessel and constituted an operation with the potential to drain the reactor vessel (OPDRV).

When the leakage was initially identified, it was not recognized as an OPDRV. The leakage rate was estimated to be less than 10 gallons per hour. This leakage persisted for 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> until the maintenance activities were completed. During this time period, the secondary containment was inoperable. Technical Specifications (TS) require that with secondary containment inoperable during OPDRV activities, action must be initiated immediately to suspend OPDRVs. Contrary to this requirement, action was not taken to suspend the OPDRV. This represents a condition prohibited by TS. The cause of this event was inadequate procedure guidance for actions to take when unexpected OPDRV conditions are encountered. Immediate corrective actions were taken to establish expectations regarding the appropriate actions to take for discovered unplanned OPDRV conditions.

This event is not safety significant since the leakage rate was so small that there was no measurable loss of level in the reactor cavity.

26158 R5

NRC FORM Z U.A NUCLEAREGULATORY COMMSON (10-2010)

LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET

1. FACILIYNAME t2. DOCKET t ýI*NMýWR PAGE R SEQUENTIAL REV Columbia Generating Station 05000397 sEAR L

NUMBER F

NO.

2 OF 3 1

12013 -003--

10

NARRATIVE

Energy Industry Identification System (ElIS) codes are Identified in the text as (XX].

Introduction

Initial Conditions At the time of the event, Columbia Generating Station (Columbia) was in Mode 5, at 0 percent of rated thermal power. The preferred source of offsite power from the 230 kV source through the startup transformer [XMFR]

was inoperable. The Division 2 emergency diesel generator system [EK] was inoperable. The Division 2 emergency core cooling systems (ECCS) consisting of two trains of low pressure coolant injection (LPCI) [BOJ were inoperable. The Division I emergency diesel generator and ECCS, consisting of one LPCI train and the low pressure core spray system [BM], were operable and protected.

Reportability Criteria Secondary containment [NG] operability was not maintained during an operation with a potential to drain the reactor vessel (OPDRV) activity and Required Action C.1 of Technical Specification (TS) 3.6.4.1 to immediately initiate actions to suspend OPDRV activities was not completed. This condition is being reported in accordance with 10 CFR 50.73(a)(2)(1)(8) as an operation prohibited by the plant's TS.

Event Description

On June 3, 2013, with Columbia in a planned refueling outage and the reactor cavity flooded up (Mode 5),

leakage past a closed Isolation valve associated with one hydraulic control unit [HCU] on the control rod drive system [AA] was observed through a drain line. This leakage originated from the reactor vessel and constituted an operation with the potential to drain the reactor vessel (OPDRV). When the leakage was initially identified, it was not recognized as an OPDRV. The leakage rate was estimated to be less than 10 gallons per hour. This leakage persisted for 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> on June 3, 2013, from 0405 hours0.00469 days <br />0.113 hours <br />6.696429e-4 weeks <br />1.541025e-4 months <br /> to 1955 hours0.0226 days <br />0.543 hours <br />0.00323 weeks <br />7.438775e-4 months <br /> until the maintenance activities were completed and the drain line was isolated. The leakage was observed by Engineering personnel conducting a field walk down of the control rod drive system. A subsequent review of the issue by Licensing personnel determined that, although the leakage was minimal, it constituted an OPDRV under the plain language definition provided by Enforcement Guidance Memorandum (EGM) 11-003, "Enforcement Guidance Memorandum on Dispositioning Boiling Water Reactor Licensee Noncompliance with Technical Specification Requirements during Operations with a Potential for Draining the Reactor Vessel,"

dated October 4, 2011.

Event Cause

The cause determination is still in progress. The preliminary cause of this event is attributed to inadequate procedure guidance for actions to take when unexpected OPDRV conditions are encountered. The TS require that actions be initiated immediately to suspend the OPDRV activity. In this case, upon discovery of the leakage, the maintenance activity should have been stopped and a determination undertaken to identify the necessary actions to isolate the leakage while still preserving equipment and personnel safety. A supplement to this licensee event report will be submitted if the final cause determination is substantively different from the initial cause determination.

26158 R5

NRC FORM 3SA U.&. NUCLAR REULTOR commosm (10-2010)

LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET

1. FEM ff DOKE...NMBR&

A YEARI SEY REV Columbia Generating Station 05000397 NUMBER NO.

3 OF 3 2013-003- 00 NARRATIVE Safety Assessme The safety significance of this event is considered to be negligible. At the time of the event, Columbia was in Mode 5 with the reactor cavity flooded up. The leakage rate was small, on the order of 10 gallons per hour.

Approximately 500,000 gallons of water are added to flood up the reactor cavity; thus, this amount of water would be available to drain prior to reaching the top of active fuel. Additionally, the makeup capability of the ECCS far exceeded the observed leakage rate.

Corrective Actions

The following corrective actions were completed: A Night Order was issued to identify that when CRD-V-126/2635 MV] is open, the known leakage past CRD-V-101/2635 requires this configuration be considered an OPDRV. Additionally, the Night Order reinforced the expectation that upon notification that leakage has been discovered that may constitute an OPDRV, action must be commenced Immediately to allow isolation of the drain path in order to satisfy the TS requirements. These actions must be done in a controlled manner to ensure industrial, radiological, and nuclear safety is not jeopardized.

The corrective action plan is still being developed. The preliminary plan will revise procedure PPM 3.4.1 to incorporate the expectations from the Night Order. A supplement to this licensee event report will be submitted iR the final corrective action plan is substantively different than that included here.

Previous Similar Events

During the refueling outage that was in progress during this event, a number of evolutions were properly classified as OPDRVs using the guidance in EGM 11-003. For these planned evolutions, the TS requirements were met. There are no previous similar events involving unplanned OPDRV activities.

26158 R5