05000423/LER-1997-006, :on 970117,RHR Suction Isolation Valves Open But Not Under Administrative Control as Required in Mode 4 by TS SR 4.6.1.1.a.Caused by Failure to Identify Conflict Between Requirements.Rhr Required Position Determined

:on 970117,RHR Suction Isolation Valves Open But Not Under Administrative Control as Required in Mode 4 by TS SR 4.6.1.1.a.Caused by Failure to Identify Conflict Between Requirements.Rhr Required Position Determined

ML20138J539
Person / Time
Site:	Millstone
Issue date:	04/30/1997
From:	Peschel J NORTHEAST NUCLEAR ENERGY CO.
To:
Shared Package
ML20138J492	List: 05000423/LER-1997-006, :on 970117,RHR Suction Isolation Valves Open But Not Under Administrative Control as Required in Mode 4 by TS SR 4.6.1.1.a.Caused by Failure to Identify Conflict Between Requirements.Rhr Required Position Determined 05000423/LER-1997-006-01, Forwards LER 97-006-01 Per 10CFR50.73(a)(2)(i).Util Commitments in Response to 970117 Event Contained within Attachment 1
References
LER-97-006, LER-97-6, NUDOCS 9705080243
Download: ML20138J539 (4)

LER-1997-006, on 970117,RHR Suction Isolation Valves Open But Not Under Administrative Control as Required in Mode 4 by TS SR 4.6.1.1.a.Caused by Failure to Identify Conflict Between Requirements.Rhr Required Position Determined

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(viii) 10 CFR 50.73(a)(2)(ii) 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(iv), System Actuation 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i)
4231997006R00 - NRC Website

text

a 53L.-FORM 366' U.s. NUCLE AR F.EGULAToRY COMMISSION APPROYED BY OMB NO. 3160-0104 (4-05)

EXPIRES 04/30/98 l

fN O cOLLE TION R70 ES AT O 60 HRS EPORTED L S nt"'?o^"In?"! a^!!iE?o 'an'u"!.'" ic"ff!n ^30 LICENSEE EVENT REPORT (LER) 15;ta'*J '=f"",^,7a mta'Ega$,n^o",F'avag"6'c a

D=fh'aE'&T"r'M!"?dt!. "'fs"2?T"o?JHM""*

(See reverse for required number of digits /Charactersfor each block)

FACIUTV NAME (1)

DOCKET NUMBER 12)

PAGE131 Millstone Nuclear Power Station Unit 3 05000423 1 of 4 i

mtE i4 1

Residual Heat Removal Suction Isolation Valves Open But Not Under Administrative Control as Required in Mode 4 by Technical Specification Surveillance Requirement 4.6.1.1.a EVENT DATE (5)

LER NUMBER (6)

REPORT DATE (7) oTHER FACIL' TIES INVOLVED (8)

MONTH DAY YEAR YEAR SEQUENTIAL REVislON MONTH DAY YEAR FAciuTY NAME DOCKET NUMBER NUMBER NUMBER F^cm NAME cKn NuuseR 01 17 97 97 006 01 04 30 97 l

OPERATING 5

THis REPORT is SUBMITTED PURSUANT To THE REQUIREMENTS oF 10 CFR 5: (Check one or more) (11) i MotsE (9) 20.2201(b) 20.2203(a)(2)(v)

X so 73(a)(2)(i) 50.73(a)(2)(viii)

POWER 000 20.2203(a)(1) 20.2203(a)(3)(i) 50.73(a)(2)(ii) 50.73(a)(2)(x)

LEVEL (10) 20.2203(a)(2)(i) 20.2203(ai(3)(ii) 50.73(a)(2)(iii) 73.71 20.2203(a)(2)(ii) 2o.2203(a)(4) 50.73(a)(2)(iv) oTHER

~

20.2203(a)(2)(iii) 50.36(c)(1) 50.73(a)(2)(v)

Specify in Abstract below

~

20.2203(a)(2)(iv) 50.36(c)(2) 50.73(a)(2)(vii)

LICENSEE CONTACT FoR THis LER (12)

NAME TELEPHONE NUMBER (include Area Codel J.M. Peschel, MP3 Nuclear Licensing Manager (860)437-5840 l

COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

CAUSE

SYSTEM COMPONENT MANUFACTURER REPORTABLE CAUSF SYSTEM COMPONENT MANUFACTURER RE'ORTABLE TO NPRDS TO NPRDS l

I SUPPLEMENTAL REPORT EXPECTED (14)

EXPECTED MONTH DAY YEAR YEs X No submission

)

DATE (15)

(if yes, complete EXPECTED SUBMisslON DATE).

ABSTRACT (Limit to 1400 spaces,i.e., approximately15 single-spacedtypewrittenhnes) (16)

On January 17,1997, with the unit in Mode 5, it was determined that Residual Heat Removal (RHR) System Suction Containmentisolation Valves (3RHS*MV8701 A/B and 3RHS*MV3702A/B)had not been maintained closed in l

Mode 4 as required by Technical Specification 3.6.1.1. Historica!Iy,the RHR System Suction Containmentisolation i

Valves had been opened in Mode 4 in accordance with the unit operating procedures to provide a flow path for cooldown to cold shutdown as required by plant design. No allowance is provided in Specification 3.6.1.1 for these valves to be openedin Mode 4.

Opening these valves in Mode 4 without a Technical Specification (TS) allowance violates the Specification 3.6.1.1 requirements for maintaining containment integrity and constitutes a condition reportable pursuant to 10CFR50.73(a)(2)(i),as an operation or condition prohibited by the TS.

There were no safety consequences associated with this condition in that the plant has not experienced an event requiring closure of these valves for containment isolation while the valves were open for RHR system operation. Unit design and operating procedures provide assurance that the RHR suction valves will be isolated when required and Containment integrity maintained in the event of an accident.

The corrective actions described in the original LER are complete. A Technical Specification change is being d veloped to include the RHR Suction CIVs in the note to Surveillance Requirement 4.6.1.1.a.

9705000243 970430 PDR ADOCK 05000423 S

PDR

.U.s. NUCLFAR REGULATORY Commission (4-95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DOCKET NUMBER (2)

LER NUMBER (6)

PAGE (3)

YEAR SEQUENTIAL REVislON Millstone Nuclear Povrer Station Unit 3 05000423 NUMBER NUMBER 2 of 4 97 006 01 TEXT (If more space is required, use add onalcopies of NRC Form 366A) (17) 1.

Description of Event

On January 17,1997, with the unit in Mode 5, it was determined that contrary to the requirements of Technical Specification (TS) 3.6.1.1," Primary Containment-ContainmentIntegrity," that Residual Heat Removal (RHR) System Suction ContainmentIsolation Valves (3RHS*MV8701 A/ Band 3RHS*MV8702A/B)had not been maintained closed in Mode 4 as required by the specification. The RHR System Suction ContainmentIsolation Valves (CIVs) are opened in l

l Mode 4 by the unit operating procedures to provide a flow path for cooldown to cold shutdown as required by plant d sign. Historically,these valves had been open to perform this function but no allowanceis provided in Specification 3.6.1.1 for these valves to be open in Mode 4.

Technical Specification 3.6.1.1,

• Primary Containment-Containment lntegrity," Surveillance Requirement 4.6.1.1.a st:tes that" Primary CONTAINMENTINTEGRITY shall be demonstrated: a. At least once per 31 days by verifying that l

til penetrations not capable of being closed by OPERABLE containment automatic isolation valves or operator action i

during periods when containmentisolation valves are opened under administrative control, and required to be closed under accident conditions are closed by valves, blind flanges, or deactivated automatic valves secured in their positions." A note to this Technical Specification provides an exception to the above stated requirementlisting certain

" manual valves [that] may be opened on an intermittent basis under administrativecontrol."

i The Technical Specifications provide three allowances regarding containmentintegrity: 1) that the penetration is capable of being isolated by an automatic containmentisolation valve or; 2) that certain valves that are listed within a note to the Technical Specifications may be opened on an intermittent basis by the operator under administrative control, and; 3) if th:y are not required to be closed under accident conditionsthey may remain open. Because these RHR valves have historically been open during normal operation in Mode 4, these valves have been operated outside of the Technical Specifications because they do not receive an automatic closure signal nor are they operated under administrativecontrol for reclosure in the event an accidentwere to occur. The accident analysis assumes containmentisolation is provided to minimize the release of radioactive materials to the environment. The RHR System Suction CIVs are recuired to be open in Mode 4 to allow the RHR System to be in service for decay heat removal. Previous reviews of Technical Specification j

and operating procedure revisions did not identify tne Technical Specification and procedural conflict.

Opening these valves in Mode 4 without a Technical Specification allowance violates the Specification 3.6.1.1 requirements for maintaining containmentintegrity and constitutes a condition reportable pursuant to 10 CFR50.73(a)(2)(i),as an operation or condition prohibited by the TS.

II.

Cause of Event

The cause of this event is attributed to a failure to identify the conflict between the opr; rational requirement to have RHR in service and the Technical Specification requirement to maintain containment inter /;ty in Mode 4 during previous rcviews.

- U.s. NUCLEAR REGULATORY Commission (4-95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DOCKET NUMBER (2)

LER NUMBER (6)

PAGE (3)

YEAR SEQUENTIAL REVisloN Millstone Nuclear Power Station Unit 3 05000423 NUMBER NUMBER 3 of 4 97 006 01 TEXT (If more space is required, use additionalcopies of NRC Form 366A) (17) 111. Analysis of Event There were no safety consequences associated with this condition in that the plant has not experienced an event requiring closure of these valves for containment isolation while the valves were open for RHR System operation.

The RHR System Suction CIVs are required to be open in Mode 4 to allow the RHR System to be in service for decay heat r:moval. In Mode 4, containmentisolation would be required for accidents resulting in high containment pressure, that is, Loss of Coolant Accidents and steamline breaks. Unit design provides assurance that the RHR suction valves will be isolated when required and Containment integrity maintained in the event of an accident. Therefore, the safety significance of this event is considered to be minimal.

IV. Corrective Action

The following corrective actions have been completed:

l 1.

The required position of the RHR suction containment isolation valves during accident conditions in Mode 4 has been determined.

2.

The design and operating requirements for remotely operated containment isolation valves, that do not get an automatic closure signal, were reviewed for conflicts with the General Design Criteria and Technical Specifications.

3.

A review was performed to verify that manual containment isolation valves, that require intermittent operation in

[

Modes 1 through 4 are included in the note contained within Technical Specification Surveillance Requirement j

4.6.1.1.a.

i An additional corrective action based upon the above reviews is:

1.

A Technical Specification Change Request will be submitted by May 30,1997, to add the RHR Suction CIVs

{

to the list of valves included in the note contained within Surveillance Requirement 4.6.1.1.a.

l V.

Additional Information

j l

None

Similar Events

LER 96-004-C0

" Auxiliary Feedwater Isolation Valves Noncompliance with Technical Specification,s" On March 19,1996, with the plant in MODE 1 at 100 percent power, it was determined that there were several historical occasions when the plant had failed to enter the appropriate Technical Specification's (TS) limiting condition for operation (LCO) action statement when shutting the Turbine Driven Auxiliary Feedwater pump discharge valves, at less than 10 percent power. The

- ______m._._.__

m.

a NRc FORM 316A U.s. NUCLEAR REGULATORY Commission a

(4-95)

UCENSEE EVENT REPORT (LER)

TEXT CONTINUATION 5

FACILITY NAME (1)

DOCKET NUMBER (2)

LER NUMBER (6)

PAuE (3)

I a

YEAR SEQUENTIAL Revision Millstone Nuclear Power Station Unit 3 05000423 NUMBER NUMBER 4of4 97 006 01 TEKT (If more spaceis required. use additionalcopies of NRC Form 366A) (17) t cause of the historicalTS noncompliance was a misinterpretation of the Technical Specifications.

s

{

The plant erroneously used a TS Surveillance Requirement to take exception to a TS LCO.

9 l

As action to prevent recurrence, this event was reviewed with station personnel to caution others on using TS Surveillance Requirements to alter Technical Specification LCOs.

i LER 96-048-00

" Failure To Complete Technical Specification Reauired Testina Of CHS Pumo While Shutdowrf i

1 I

j On December 2,1996, with the plant in Mode 5, it was determined that a portion of the Technical i

Specification surveillancewhich tests the load shed function for both Emergency Diesel Generators j

(EDGs) had not been performed in accordance with Technical Specification Surveillance 4.8.1.1.2.g.6. This surveillanceis required to be completed once per 18 months during shutdown.

Contrary to this, the surveillanceswhich tested the load shed for both trains of Charging (CHS) system pumps and re-energizationfeature for portions of the CHS system were performed during plant operation. The cause was determined to be a lack of verbatim compliance with the Technical Specifications. Contributing to this were ineffective corrective actions to identify " shutdown" surveillances, and incomplete updating of the Master Surveillance Test Control List (MSTCL) data base.

The safety significanceof this event was minimalin that the mode in which the surveillanceswere performed had no physical affect on the ability to complete the surveillances or the ability of the EDGs to perform their safety function. As immediate corrective action, the EDGs were declared inoperable I

and the load shed surveillanceswere performed during shutdown prior to restoring the EDGs to operable status.

Manufacturer Data l

1 Ells System Code R:sidual Heat Removal System..

..BP 1

Ells Component Function identifier Containment isolation Valve..

..lSV_