05000483/LER-2018-001, Violation of Technical Specification 3.6.3 Containment Isolation Manual Found in Open Position

Violation of Technical Specification 3.6.3 Containment Isolation Manual Found in Open Position

ML18071A208
Person / Time
Site:	Callaway
Issue date:	03/12/2018
From:	Cox B Ameren Missouri, Union Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ULNRC-0642 I LER-2018-001-00
Download: ML18071A208 (8)

LER-2018-001, Violation of Technical Specification 3.6.3 Containment Isolation Manual Found in Open Position

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)(A), Seriously Degraded 10 CFR 50.73(a)(2) 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 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)
4832018001R00 - NRC Website

text

Ameren MISSOURI CalIaa Phint March 12. 2018 ULNRC-0642 I U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington. DC 20555-0001 10 CFR 50.73(a)(2)(i)(B)

Ladies and Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT I UNION ELECTRIC CO.

RENEWED FACILITY OPERATING LICENSE NPF-30 LICENSEE EVENT REPORT 2018-001-00 VIOLATION OF TECHNICAL SPECIFICATION 3.6.3 CONTAINMENT ISOLATION MANUAL VALVE FOUND IN OPEN POSITION The enclosed Licensee Event Report (LER) is submitted in accordance with 0 CFR 50.73(a)(2)(i)(B) to report a vioLation of Technical Specification 3.6.3. Containment Isolation Valves. due to the inoperability of the outside containment isolation vaLve for containment penetration P-63.

This letter does not contain new commitments.

If you have any questions concerning this LER, please contact Torn Elwood. Supervising Engineer. Regulatory Affairs and Licensing at (314) 225-1905.

Sincp5Y.

Barry L. Cox Senior Director, NucLear Operations

Enclosure:

LER 2018-001-00 P.O. Box 620 Fulton, MO 65251 AmerenMissoitri.com

ULNRC-0642 I March 12. 2018 Page 2 of 3 cc:

Mr. Kriss M. Keirnedy Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington. TX 7601 1-4511 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. L. John Kios Project Manager. Callawav Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission NIail Stop 081-14 Washington. DC 20555-0001

ULNRC-0642 I March 12, 2018 Page 3 of 3 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 6100 Western Place, Suite 1050 fort Worth. IX 76107 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)

Electronic distribution for the following can be made via LER ULNRC Distribution:

F. M. Diya B. L. Cox T. E. Herrmann S. P. Banker R. C. Wink I. B. Elwood F. J. Bianco M. K. Covey B. D. Price Corporate Oversight Corporate Communications NSRB Secretary Performance Improvement Coordinator Resident Inspectors (NRC)

STARS Regulatory Affairs Mr. Jay Silberg (Pillsbury Winthrop Shaw Pittman LLP)

Missouri Public Service Commission

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY 0MB: NO. 3150-0104 EXPIRES: 03/31/2020 (04-2017)*,

Estimated burden per response to comply with this mandatory collection request 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> Reported lessons learned are incorporated into the licensing process and fed back to inaustry, LICENSEE EVENT REPORT (LER)

Send comments regarding burden estimate to the Information Services Branch (T.2 F43). US

(See Page 2 for required number of digits/characters for each block)

Nuclear Regulatory Commission, Washington, DC 20555-0001 or by e-mail to Intocollects Resource©nrc nov.

and to the Desk

Officer, Office of Information and Regulatory

Affairs, NEOB.t0202. (3150-0104), Office of Management and Budget. Washington. DC 20503 If a means (See NUREG-1 022, R.3 for instruction and guidance for completing this form used to impose an information collection does not display a currently valid 0MB control number, httpilwww.nrc.gov/reading-rmfdoc-coifections/nuregslstaff/sr10221r3/)

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

3. PAGE Callaway Plant Unit 1 05000483 1 of 5

4. TITLE Violation of TechnjcLSpjfication 36 Contafflment IsolatIon ManatVaie Found cnQpn Position

5. EVENT DATE

6. LER NUMBER

7. REPORT DATE

8. OTHER FACILITIES INVOLVED

=

1 SEQUENTLAL FACIUTY NAME 1JOCKETNUMBER MONTH DAY YEAR YEAR REV MONTH DAY YEAR

I NUMBER NO I

05000 01 11 2018 2018 001 000 03 12 t2FACILITYNAME OCKETNUMBER

9. OPERAtiNG MODE

11. THIS REPORT IS SUBMITtED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)

Mode 1 0 20.2201(b)

El 20.2203(a)(3)(i)

El 50.73(a)(2)(ii)(A)

El 50.73(a)(2)(viit)(A)

El 20.2201(d)

El 20.2203(a)(3)(u)

El 50.73(a)(2)(ii)(B)

El 50.73(a)(2)(viii)(B)

El 20.2203(a)(1)

El 20.2203(a)(4)

El 50.73(a)(2)(iii)

El 50.73(a)(2)(ix)(A)

El 20.2203(a)(2)(i)

El 50.36(c)f1)(i)(A)

El 50.73(a)(2)(iv)(A)

El 50.73(a)(2)(x)

10. POWER LEVEL El 20.2203(a)(2)(ii)

El 50 36(c)(1)fii)(A)

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

El 7371(a)(4)

El 20 2203(a)(2)(iii)

El 50.36(c)(2)

El 50.73(a)(2)(v)(B)

El 73 71 (a)(5) 100%

El 20.2203(a)(2)(iv)

El 50.46(a)(3)(ii)

El 50.73(a)(2)(v)(C)

El 73.77(a)(1)

El 20.2203(a)(2)(v)

El 50 73(a)(2)(i)(A)

El 50.73fa)(2)(v)(D)

El 73.77(a)(2)(i)

El 20.2203(a)(2)(vi) 50.73(a)(2)(i)(B)

El 50.73fa)f2)fvii)

El 73.77(a)(2)(ii)

El 50.73(a)(2)(i)(C)

El OTHER Specify in Abstract below or in NRC Form 366A

12. LICENSEE CONTACT FOR TI-US LER LICENSEE CONTACT

)LEPH0NE NUMBER (Inctude Area Code) h-s. EIWOOdn Supervising Eflgineer, Regulapy_Attairs and Licensing 314-225-1905

13. COMPLETE ONE UNE FOR EACH COMPONENT FJLURE DESCRIBED IN ThIS REPORT

CAUSE

SYSTEM COMPONENT FACTURER REPORTABLE

CAUSE

SYSTEM

- COMPONENTJFA R

D ED ISV Velan N

j I

14. SUPPLEMENTAL REPORT EXPECTED MONTH DAY YEAR YES (Ifyes, complete 15. EXPECTED SUBMISSION DATE)

BSTRACT (Limit to 1400 spaces. I e. approximatety 15 singte-spaced fypewntten tines)

Between 11/25/2017 and 01/11/2018, containment isolation valve KAVO118 was inoperable due to being open. This normally closed manual valve serves as the outside containment isolation valve tot a service air line that passes into Dontainment through penetration P-63. The containment isolation/integrity function for P-63 was maintained by KAVOO39, he inner containment isolation valve, during the time KAVO1 18 was inoperable.

\\n Operations Technician found the valve in the fully open position on 01/11/2018. The valve had been left in the open Dosition after the penetration had been used to provide service air in containment during Refuel 22. Technical Specification TS) 3.6.3 requires each containment isolation valve to be OPERABLE in Modes 1 through 4.

In this case, it was not recognized that the valve was in full open position when the plant entered Mode 4 on 11/25/2017. Therefore, a condition Drohibited by TS 3.6.3 occurred due to failure to comply with the Required Actions specified in the IS. The IS 3.6.3

\\ctions were exited at 0959 on 1/11/2018 after valve KAVO118 was closed and locked in the closed position.

the root cause of the valve inoperability was inadequate procedural control to ensure KAVO1 18 was locked closed prior to entering Mode 4. For corrective action, procedures will be revised to ensure that the valve is closed prior to Mode 4.

REPORTABLE TO EPIX NO

15. EXPECTED SUBMISSION DATE NRC FORM 366 (04-2017)

1.

DESCRIPTION OF STRUCTURE(S), SYSTEM(S) AND COMPONENT(S):

The issue addressed in this LER concerns a normally closed manual valve that serves as a containment isolation valve (CIV) [EIIS System: ED, Component: ISV] for the penetration flow path(s) associated with containment penetration P-63.

The line penetrating containment at penetration P-63 is a service air line [EIIS System: LF] to the service air connections inside containment. The containment isolation provisions for this line consist of CIVs inside and outside containment, consistent with the requirements of General Design Criterion (GDC) 56.

In general, the containment isolation valves form part of the containment pressure boundary and provide a means for fluid penetration flow paths not serving accident consequence limiting systems to be provided with two isolation barriers that are closed on a containment isolation signal. These isolation devices are either passive or active (automatic). Manual valves, de-activated automatic valves secured in their closed position (including check valves with flow through the valve secured), blind flanges, and closed systems are considered passive devices. Check valves or other automatic valves that are designed to close without operator action following an accident are considered active devices.

Two barriers in series are provided for each penetration flow path so that no single credible failure or malfunction of an active component can result in a loss of isolation or leakage that exceeds limits assumed in the safety analyses. The containment isolation valves are subject to the requirements at Technical Specification (15) 3.6.3, Containment Isolation Valves. The Limiting Condition for Operation (LCO) of TS 3.6.3 was derived from the assumptions related to minimizing the loss of reactor coolant inventory and establishing the containment boundary during a design basis accident (DBA).

TS operability requirements for the CIVs support assumptions in the safety analysis of any event requiring isolation of containment. The DBAs that result in a release of radioactive material within containment are a loss of coolant accident (LOCA) and a rod ejection accident.

In the analyses for each of these accidents, it is assumed that containment isolation valves are either closed or function to close within the required isolation time following event initiation. This ensures that potential paths to the environment through containment isolation valves (including containment shutdown purge and mini-purge valves) are minimized.

For the DBAs involving release of fission product radioactivity, release to the environment is controlled by the containment leak rate, TS 3.6.1, Containment, requires containment leakage to be limited to less or equal to the specified leak rate limit. For CIVs, TS 3.6.1 requires leakage rate testing in accordance with the Containment Leakage Rate Testing Program. When both valves in a containment penetration tlowpath are operable, overall containment leakage is calculated based upon the maximum leakage of the two valves for entry into Mode 4 from Mode 5.

In Modes 1-3, leakage is allowed to be calculated based upon minimum leakage of the two valves.

KAVOIIS AND ASSOCIATED PIPING GENERAL OVERVIEW The Reactor Building Service Air supply is provided by a single 4-inch line that passes through containment penetration P-63. The service air system inside the Reactor Building consists of service air connections, each with isolation valves, drain and vent valves, test connections, strainers and two drain traps.

The configuration of Penetration P-63 consists of a manual isolation valve outside containment, KAVO1 18, and a check valve inside containment, KAVOO39, which complies with 10 CFR 50 Appendix A GDC-56, Primary Containment(04-2017)

Page 2 of 5US. NUCLEAR REGULATORY COMMISSION APPROVED BY 0MB: NO. 3150-0104 EXPIRES: 313112020 04-2017)

, the http:I/weriv.nrcgov/reading-rm/doc-collectionslnuregs/stafflsrlO22/r31)

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

1. FACILITY NAME

2. DOCKET NUMBER

- 3. LERNUMBER YEAR SEQUENTIAL I

REV Callaway Plant Unit 1 05000-483 NUr,1EER NO 2018 001 000 4.

ASSESSMENT OF SAFETY CONSEQUENCES

With KAVO118 in a fully open position during the noted time period, the containment penetration isolation function was adversely impacted but still fulfilled. The event is not considered to be a degraded or unanalyzed condition that significantly affected plant safety per 10 CFR 50.73(a)(2)f ii) since the containment isolation/integrity function was maintained by KAVOO39, the inner containment isolation valve for penetration P-63. Further, an as-found local leak rate test (LLRI) was performed on KAVOO39 shortly after the condition was found. The result was a measured leakage of 1277 standard cubic centimeters per minute, which was below the target value of 3,200 standard cubic centimeters per minute. Therefore, the total containment as-found minimum pathway leak rate remained within the limits of TS 3.6.1 during the timeframe when KAVO118 was inoperable, and for this reason, the event/condition was of low safety significance.

In addition, per TS 3.6.3 Condition A. the plant could have continued operation with KAVOJ 18 inoperable as long as flow through check valve KAVOO39 was secured, as defined in the TS bases.

In order to determine if flow was secured, a leak tightness test of the service air header in containment was performed. This job demonstrated that flow was secured through inner containment isolation check valve KAVOO39.

However, the components that secured that flow included drain traps and manual valves that would not meet the criteria of the examples given in TS Bases 3.6.3 on how flow should be secured, so no credit was taken for the test. The test did demonstrate that the flow was secured for the check valve, thus adding to the determination that the event/condition was of low safety significance.

5.

REPORTING REQUIREMENTS

This LER is submitted pursuant to 10 CFR 50.73(a)(2)(i)(B) to report a condition prohibited by Technical Specifications.

Specifically, with KAVO1 18 inoperable during applicable plant Modes, Condition A of IS 3.6.3 would have been required to be entered. This Condition applies to penetration flow paths having two containment isolation valves (which is the case for P-63 and its associated penetration flow paths, particularly the KAVO118-KAVOO39 penetration flow path).

Per Condition A, for one or more penetration flow paths with one containment isolation valve inoperable, Required Actions A,1 and A.2 must be entered.

Required Action A. 1 requires isolating the affected penetration flow path by use of at least one de-activated automatic valve, closed manual valve, blind flange, or check valve with flow secured through the valve, within a specified Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Required Action A.2 requires verifying that the affected penetration flow path is isolated, prior to entering MODE 4 from MODE 5 if not performed with the previous 90 days for isolation devices inside containment. With either (or both) of these Completion Times and Required Actions not met, Condition E applies and its Required Actions E.1 and E.3 become applicable. These Required Actions require the plant to be shut down such that per Required Action El, the plant must be in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and per Required Action E.2, the plant must be in Mode 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Since KAVOJJ8 was not known to be inoperable when the plant entered the Applicability of LCO 3.6.3 upon restart from Refuel 22, the above-noted Conditions and Required Actions were not entered and thus not met. Compliance with Required Action Al, in particular, would have been the isolation of the affected penetration flow path by use of check valve KAVOO39, with flow through the valve secured, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. With Required Action A. 1 not met within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the plant should have been in or brought back to Mode 3 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> per Required Action El, and to Mode 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

It may also be noted that a violation of LCD 3.0.4.a occurred in connection with the plant entering the Applicability of LCD 3.6.3, with the valve inoperable. With an LCD not met, LCD 3.0.4.a only permits entry into the Applicability of that LCD when the associated Actions to be entered permit continued operation in the applicable Mode for an unlimited period of time. This provision would only have been met if Required Actions A.1 and A.2 of LCD 3.6.3 had been met.Page 4 of 5

6.

CAUSE OF THE EVENT

This event was evaluated using a root cause analysis process. The causal factor (OF) identified with the root cause was inadequate procedures associated with closing KAVO118. The root cause for this event was that the procedure guidance did not direct closing and locking KAVO1 18. The contributing causes (CC) associated with this CF include the need for better guidance on administrative controls as defined in the TS 3.6.3 Bases.

7.

CORRECTIVE ACTIONS

The corrective action to prevent recurrence for this event is to revise procedures to ensure KAVO1 18 is closed prior to entering Mode 4 and to provide additional guidance on actions required if KAVO1 18 is to remain open (under the administrative controls allowed per TS 3.6.3 with the applicable Condition/Required Action(s) in effect for the inoperable CIV) at the time of the mode change. This will ensure IS 3.6.3 is met for any future mode changes when entering Mode 4 from Mode 5.

8.

PREVIOUS SIMILAR EVENTS

LER 2017-003-00 documents a violation of TS 3.6.3 where the failure of normally closed containment isolation check valve KCV0478 to fully close was identified. While that LER is associated with the same TS, the cause of that reported condition is unrelated to the condition reported in this LER, and the corrective actions taken would not have prevented the KAVO1 18 event.

LER 2010-007-00 documents a violation of IS 3.6.3 where the failure to adequately implement administrative controls for opening a normally closed containment isolation valve was identified. While that LER is associated with the same TS, the cause of that reported condition is unrelated to the condition reported in this LER, and the corrective actions taken would not have prevented the KAVO118 event.U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY 0MB: NO. 3150.0104 EXPIRES: 3131/2020 (o42oi7)

EstimateS the http]/www.nrc.gov/reading-rm/doc-collectionsfnuregs/stafffsrlO22/r3/)

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

1. FACILITY NAME Callaway Plant Unit 1

2. DOCKEtNUMBER 05000-483 YEAR

3. LER NUMBER SEQUENTIAL NUMBER REV ND 2018 001 000 NRC FORM 306A 106-2016)