05000423/LER-1997-023, :on 970220,MSIV Had Not Been Tested IAW Literal Requirements Contained within TS Due to Inadequate Review During Development & Certification.License Amend Request Will Be Submitted by 970430

:on 970220,MSIV Had Not Been Tested IAW Literal Requirements Contained within TS Due to Inadequate Review During Development & Certification.License Amend Request Will Be Submitted by 970430

ML20147F590
Person / Time
Site:	Millstone
Issue date:	03/22/1997
From:	Peschel J NORTHEAST NUCLEAR ENERGY CO.
To:
Shared Package
ML20147F588	List: 05000423/LER-1997-023, :on 970220,MSIV Had Not Been Tested IAW Literal Requirements Contained within TS Due to Inadequate Review During Development & Certification.License Amend Request Will Be Submitted by 970430
References
LER-97-023, LER-97-23, NUDOCS 9703260254
Download: ML20147F590 (6)

LER-1997-023, on 970220,MSIV Had Not Been Tested IAW Literal Requirements Contained within TS Due to Inadequate Review During Development & Certification.License Amend Request Will Be Submitted by 970430

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i) 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)(i)(B), Prohibited by Technical Specifications
4231997023R00 - NRC Website

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Docket No. 50-423 l

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Millstone Nuclear Power Station, Unit No. 3 l

NNECO's Submittal of (97-023-00) 0 1

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NRC FORM 366 U.s. NUCLEAR REGULATORY COMMISstON APPROVED BY OMB NO.3160-0104 EXPlRES 04/30/98 gg_g5)

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LICENSEE EVENT REPORT (LER) iS='e r"<glfaa,algagegg,aasgaavgaagagc u

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digits /charactersfor each block)

Ff CIUTY NAME (1)

DOCKET NUMBER (2)

PAGE (3)

Millstone Nuclear Power Station Unit 3 05000423 1 of 5 TITLE $1) l Technical Specifications for Main Steam isolation Valves (MSIV)

EVENT DATE (5)

LER NUMBER (6)

REPORT DATE (7) oTHER FACILITIES INVOLVED (8)

MONTH oAY YEAR YEAR SEQUENTIAL Revision MONTH DAY YEAR FACIUTV NAME DOCKET NUMBER NUMBER O2 20 97 97 023 00 03 22 97 OPERATING 5

THis REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR 5: (Check one or more) (11)

MODE (9)

' 20.2201(b) 20.2203(a)(2)(v)

X 50.73(a)(2)(i) 50.73(a)(2)(viii) i 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(a)(3)(ii) 50.73(a)(2)(iii) 73.71 20.2203(a)(2)(ii) 20.2203(a)(4) 50.73(a)(2)(iv)

OTHER

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

Specify in Abstract below

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

LICENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER (include Area Code)

J.M. Peschel, MP3 Nuclear Licensing Manager (860)437-5840 1

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

CAUSE

SYSTEM COMPONENT MANUFACTURER REPORTABLE

CAUSE

SYSTEM COMPONENT MANUFACTURER REPORTABLE TO NPRDS TO NPRDS SUPPLEMENTAL REPORT EXPECTED (14)

EXPECTED MONTH DAY YEAR YES X No Submission (If yes, complete EXPECTED sVBMissioN DATE).

i ABSTRACT (Limit to 1400 spaces,i.e., approximately 15 single. spaced typewrrttenlines) (16)

On February 20,1997, with the plant in Mode 5, it was determined that the Main Steam isolation Valves (MSIV) had not be n tested in accordance with the literal requirements contained within the Technical Specifications (TS) Specifically, TS i

4.7.1.5.1 requires that "each MSIV be demonstrated operable by verifying full closure within 10 seconds in Mode 1,2, and 3 wh n tested pursuant to Specification 4.0.5." Contrary to this requirement, the MSIVs have not been full stroked tested in Mod:s 1 and 2. Failure to perform TS required surveillancesis reportable pursuant to 10CFR50.73(a)(2)(i)(B)as an operation or condition prohibited by the TS.

Th:re was no safety significance nor adverse safety consequence involved in this event. The MSIVs were tested successfully during startups. However,this eventis significant as an example of a lack of verbatim compliance with TS requirements.

i This condition has existed since the initial issuance of the Technical Specifications and is due to an inadequate review during j

th3 development and certification. A License Amendment request will be submitted by April 30,1997 to eliminate the r:quirement for full stroke testing of the MSIVs in Modes 1 and 2.

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j NRC FORM 366 (4-95) l r

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t iU.s. NUCLEAR REGULATORY CoMM3sloN i

(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 2 of 5 97 023 00 i

l TEXT Uf more space is required, use additionalcopies of NRC Form 366A) (11l 1

Description of Event

t l

On February 20,1997, with the plant in Mode 5, it was determined that the Main Steam isolation Valves (MSIV) had not l

been tested in accordance with the literal requirements contained within the Technical Specifications (TS). Specifically, l

TS 4.7.1.5.1 requires that "each MSIV be demonstrated operable by verifying full closure within 10 seconds in Mode 1, I

l 2, and 3 when tested pursuant to Specification 4.0.5." Contrary to this requirement, the MSIVs have not been full stroke t sted in Modes 1 and 2.

l Tcsting pursuant to TS 4.0.5 is perfomied as part of the inservice inspection and testing of American Society of

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Mechanical Engineers (ASME) Code Class 1,2, and 3 components. Relief from the requirement to full stroke test the l

MSIVs during power operation had been granted by the Nuclear Regulatory Commission (NRC). However, this relief r: quest was not appropriately incorporated into the Technical Specification..

P Frilure to perform TS required surveillancesis reportable pursuant to 10CFR50.73(a)(2)(i)(B)as an operation or condition prohibited by the TS.

II.

Cause of Event

This condition has existed since the initial issuance of the Technical Specifications and is due to an inadequate review during the development and certification.

lit. Analvsis of Event Th:re was no safety significance nor adverse safety consequenceinvolved in this event. The MSIVs were tested successfullyduring startups. However,this eventis significant as an example of a lack of verbatim compliance with TS r0guirements identified due to a heightened awareness of the potential for this shortcoming as described in previous Licensee Event Reports, LER 96-038-00, LER 96-048-00, LER 97-001-00, LER 97-004-00 and LER 97-018-00.

IV. Corrective Action

A License Amendment request will be submitted by April 30,1997 to eliminate the requirement for full stroke testing of the MSIVs in Modes 1 and 2.

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i N?.C FORM 366A 14-95) 1

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.U.s. NUCLEAR REGULATORY Commission (4 95) 4 UCENSEE EVENT REPORT (LER)

TEXT CONTINUATION

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FACILITY NAME (1)

DOCKET NUMBER (2)

LER NUMBER (6)

PAGE (3)

L YEAR SEQUENTIAL REVISloN Millstone Nuclear Power Station Unit 3 05000423 NUMBER NUMBER 3 of 5 97 023 00 TEXT Uf more space is required, use additional copies of NRC Form 366A) (17) 1 I

s V,

Additional Information

I None i

5

Similar Events

i LER 96-021-00 Components Not included in The in-ServiceTest Proaram As A Result Of Proarammatic Deficiencies j

On June 28,1996 with the unit irs mode 5 of an extended cold shutdown, a review of the inservice Test Program was completed. This review identified multiple inservice Test (IST)

Program deficiencies which consist of incomplete implementation of several licensing commitments, the omission of several valves from the program, testing inadequacies for

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valves already in the program, inconsistent or missing documentation in the Inservice Test Manual and IST surveillance procedures, and lack of adequate process control procedures which would ensure effective maintenance of the program. Based on the results of this program review it was determined that the IST requirements have not been performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code as required by 10CFR50, section 50.55a(f) and the unit Technical Specifications. Because this condition was discovered when the unit was in an extended cold shutdown, no immediate operator l

action was required.

l The causes of this condition were a lack of management commitment to support these programs, inadequate program monitoring, and a failure to evaluate the program effectiveness. Correction of individual discrepancies and programmatic enhancements to prevent recurrence are being incorporated into the IST manual and applicable surveillance procedures.

LER 97-001-00 Lack of Verbatim Comoliance with Technical Soncification Surveillance Reauirements for

.l 125 Volt Batteries and Batterv Charaers i

On January 4,1997, with the plant in Mode 5, it was identified that 125 volt battery surveillance testing was being performed in a manner that was not in verbatim compliance with the

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Technical Specifications (TS). Similarly, on January 9,1997, with the plant in Mode 5, it was 1

identified that 125 volt battery charger surveillance testing was being performed in a manner that was not in verbatim compliance with the TS. These conditions were determined to be reportable pursuant to 10CFR50.73(a)(2)(i), as an event or condition prohibited by the Technical Specifications.

]

While the surveillance testing performed may have been more accurate or more conservative than the verbatim requirements of the specifications involved, this event is significant in that it identifies further examples of a lack of verbatim compliance with TS requirements. These conditions were identified as the result of a heightened awareness of the potential for additional NRC FoHM 366A (4 95)U.S. NUCLEAR REGULATORY Commission (0-95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACluTY NAME (1)

DOCKET NUMBER (2)

LER NUMBER (6)

PAGE (3)

YEAR SEQUENTIAL REVISION Millstone Nuclear Power Station Unit 3 05000423 NUMBER NUMBER 4 of 5 97 023 00 i

TEXT Vf more space is required, use additional copies of NRC Form 366A) (11) lack of verbatim TS compliance such as those described in previous Licensee Event Reports, LER 96-038-00, and LER 96-048-00.

Corrective actions ircluded a review of the affected TS which would be conducted for potential wording changes to ensure clarity, followed by the development and submittal of any resultant I

amendment request.

LER 97-008-00 FailureTo EnterTechnicalSpecification3.0 3 Action Statement For MSIV Closure On January 24,1997, it was determined that the plant had previously operated in a condition prohibited by TechnicalSpecifications(TS). Specifically,while conducting a scheduled plant shutdown on April 15,1995, Unit 3 operators shut all four Main Steam Isolation Valves (MSIV)s in Mode 4. Due to the known inability of the valves to satisfy surveillancetest requirementsat the low steam pressures in Mode 4, the valves were declared inoperable. TS 3.7.1.5 for Modes 2, 3, and 4 states that "With one MSIV inoperable, operation may proceed provided that the isolation valve is maintained closed. Otherwise, be in Hot Standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Cold Shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />". The plant complied with these required actions.

However, the TS do not bound the condition of four MSIVs inoperable which would require entry into TS 3.0.3.

i lt has also been determined that TS 3.0.4 has been historically violated based upon the plant's entering Mode 4 from Mode 5 with the MSIVs closed, but inoperable because the valves could not meet TS surveillance acceptance criteria at the low steam pressures existing in Mode 4.

This condition was reported pursuantto 10CFR50.73(a)(2)(i)(B)as an operation or condition prohibited by the TS.

It was determined that there was no safety significance nor adverse safety consequence in that the valves were closed in their safety function position and the plant was brought to hot shutdown and cold shutdown conditionsin the specified times of TS 3.0.3.

LER 97-018-00 Technical Specification Parameter Compliance l

On February 8,1997 with the plant in Mode 5 it was determined that the plant had operated in conditions prohibited by 3 different Technical Specifications (TS). Each of these TS specify parameters without specific ranges. Therefore, verbatim compliance with the specified parameters is not possible.

These conditions occurred as a result of interpreting the Technical Specifications for intent rather than conducting operations in strict compliance with the specification. These conditions were determined to be reportable pursuant to 10CFR50.73(a)(2)(i)(B) as any operation prohibited by the Technical Specifications.

The non-compliances have no plant safety consequence. The Surveillances and Safety System Settings will be conducted in the same manner after revision of the Technical Specifications. These non-compliances were identified as the result of heightened awareness to the potential for lack of verbatim Technical Specification compliance. These non-WRC FORM 366A (4-95)

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..U.s. NUCLEAR RE,dLAToRY CoMMisslON (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 5 of 5 97 023 00 l

TEXT (11more space is required, use additionalcopies of NRC Form 366A) t17) compliances are significant as examples of a lack of compliance with TS requirements identified due to a heightened awareness resulting from previous Licensee Event Reports.

Manuf acturer Data Ells System Code Miin Steam System SB Ells Component Function identifier Miin Steam isolation Valve ISV l

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