05000498/LER-1988-015, :on 880206,two MSIVs Declared Inoperable When Duty Shift Supervisor Learned That Packing Adjustments Performed.Addl Requirements for Containment Isolation Valves Not Carried Out Until 880207

:on 880206,two MSIVs Declared Inoperable When Duty Shift Supervisor Learned That Packing Adjustments Performed.Addl Requirements for Containment Isolation Valves Not Carried Out Until 880207

ML20148H008
Person / Time
Site:	South Texas
Issue date:	03/22/1988
From:	Ayala C, Vaughn G HOUSTON LIGHTING & POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
LER-88-015, LER-88-15, ST-HL-AE-2527, NUDOCS 8803290289
Download: ML20148H008 (7)

LER-1988-015, on 880206,two MSIVs Declared Inoperable When Duty Shift Supervisor Learned That Packing Adjustments Performed.Addl Requirements for Containment Isolation Valves Not Carried Out Until 880207

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(1) 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability
4981988015R00 - NRC Website

text

r-

=

e e

LC f orm att U S seuCLef.a LEQutf 10RY ComeWisech LPPAOVI) OW8 BeO 31u410e LICENSEE EVENT REPORT (LER) 8'""'*

PLCILif f haw 6 (1)

DOCA t f I.ve8SE A til F AGE il South Texas, Unit 1 01510 l 0 l 0 l4 p l 8 1 lOFl 015 fif tt let Two MSIV's Inoperable Resulting In A Technical Specification Violation tythf OafI ets Lim hvedsta sti AIPOaf Oaf t 171 OTMER PACitifittthvo.VlOit) uv%fM 04, stam vtam WO%fM Qav stam

' AC'L Y v e auss DOCA t f NvWata,ss

6 n

015 f 0 f 010 1 1 1

_0l2 0l7 88 8l8 0l 1 l5

~

0l0 0l3 2l2 8 l8 0l5l0 1 0 ioi i i

~

YMil # EPO A T 18 tuthatf f t Q PV A$Ua%T TO YMt A t ov4REW8 %fl Of 10 C f A I (CA.i e see e, s ore e,,ne &wo-eas (111 Opt m at:4Q 4 006 to 3

M 40till N 406(si to 73eM2H.vl 73 fitti POveI a M 406'eH1Hd to 3s6eH16 to 7k.H3Het 73114e)

~

~

~

1o O!O O M a0*'a ul u.'

so mieu25 7

to?34n:H>

OtMia<so.g..

4.,,,,,

D*""**#"*

{

u nonsa.

[

~

n aan..>.in.i u,3.nso wai

.. H,,,e,

M 40SeH1Hv6 60734H3Hel N 73442Hal e

LiCtk&lt CO%f act f 04 TMit Lim (131 gavt YtLE*aON8 NWet e anta cggt Charles A. Ayala 5l i 2 9 7 p i-18 (3 l 218 1

i Courteit Oht Leht som taCM COMPONt%f f attunt OtsCat0IO IN TMs5 BIPOAT tit 6 wa)jgC He

,f a d Cadt 5 75'l W

• OV'C%t%T

$C Cault t v st t u cow'O%4%,

70 pe y

a g All

[ l i 1 l [

t i i i 1 1 i l

I I I I I I I

I I I I I i SUPPLEME Ntal 88808f t aPECitD att u0%TM Day staa s.,0%

-],,, i,.. -,. E.,, C r,0,<, 3 5,0 % O a e t,

Te i

t. f. a C f _,,, w...,..... -.

y. _.,..,,..., n. '

At approximately 0900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> on February 5, 1988, with Unit 1 in Mode 3, prior to initial criticality, concurrent valve packing adjustments were performed on two (2) Main Steam Isolation Valves (MSIVs).

The work was approved by a licensed Unit Supervisor who did not believe it would render the valves inoperable.

Technical Specification Limiting Condition for Operation (LCO) 3.7.1.5 only provides action for single MSIV inoperability in Mode 3.

On Febr'2ary 6, 1988, with the unit it. Mode 4 due to an unrelated event, the duty Shift Supervisor upon learning that the packing adjustments had been performed, declared the MSIVs inoperable.

However, because of an error in judgement, the additional requirements of LCO 3.6.3 for Containment Isolation Valves were not carried out until approximately 0830 hours0.00961 days <br />0.231 hours <br />0.00137 weeks <br />3.15815e-4 months <br /> on February 7, 1988.

The MSIVs were restored to operable status at approximately 1730 hours0.02 days <br />0.481 hours <br />0.00286 weeks <br />6.58265e-4 months <br /> on February 7, 1988. The primary cause of this event is insufficient familiarity with the applicable Technical Specifications.

Corsective actions to prevent recurrence include more in-depth training of operators in operability requirements for containment isolation valves and Technical Specification Requirements.

}[

NL.LER88015

/

l 8803290289 880322 PliR ADOCK 05000498 S

DCD

US souCLlam afGutLYoav Consasee660su Itac8een 3e6a L.'CENSEE EVENT REPORT (LER) TEXT CENTINUATION a**a wto o iso me.aio.

EmPint3 8/319e eacitat, esamet iti Occaetsounesa Gl 4ea sesmasea tes Pase a vtae 8 8 g8g,',a k g

a 0 l 5" South ~exas. Unit 1 o l6 jo jo lo l4 9 l8 8 l8 l --

0lIj5 0l0 Oj 2 or 1

f LKT te misse apose e suensiset es, sadiumns AseC Asen Msf Ith DESCRIPTION OF OCCURRENCE:

At approximately 0800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> on February 5, 1988, with Unit 1 in Mode 3 prior to initial criticality and with Main Steam Isolation Valves (MSIVs) closed, an SRO-licensed Unit Supervisor approved concurrent valve packing adjustments on both "A" and "C" MSIVs to stop stearn leaks.

Prior to work start approval, the Unit Supervisvr ensured that a Post Maintenance Test would be performed to verify valve strcke time.

However, the Unit Supervisor did not believe that adjusting valve packing would rendc-MSIVs J, operable.

Therefore he did not log the MSIVs as inoperable in

.rability Tracking Log nor did he specify on the Maintenance Work Req JWR) that work be completed within the applicable Limiting Condition f' eration action statement time constraints.

At approximately 0900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> on February 5, 1988, craftsmen performed the packing adjustments per the approved MVR.

The packing adjustments did not stop the leakage, therefore, according to the work package ir tactions, the craftsmen returned the work package to their foreman and did x-

1. form the Control Room that they had completed their work.

At approximately 0258 hours0.00299 days <br />0.0717 hours <br />4.265873e-4 weeks <br />9.8169e-5 months <br /> on February 6, 1988, Unit I cooled down to Mode 4 due to an unrelated Technical Specification action requirement.

At approximately 1325 hours0.0153 days <br />0.368 hours <br />0.00219 weeks <br />5.041625e-4 months <br /> on February 6, 1988, the Shift Supervisor learned that the packings or. "A" and "C" MSIVs had been adjusted. He immediately declared the MSIVs inoperable and made the appropriate entry in the Operability Tracking Log.

The Unit 1 Operations Manager was informed.

He and the Shift Supervisor reviewed Technical Specificction 3.7.1.5 concerning MSIV operability and concluded that the valves did not require stroke timing until in Mode 3, when steam pressure was equalized across the MSIVs during Main Steam header varming.

Technical Specification 3.7.1.5 allows entry into Mode 3 prior to verifying MSIV operability provided the valves are closed. The Unit i Operations Manager also concluded that because the valves were in their fail-safe position, that the additional action requirements of Technical Specification LCO 3.6.3 for Containment Isolation Valves were not applicable for MSIVs.

At approximately 2100 hours0.0243 days <br />0.583 hours <br />0.00347 weeks <br />7.9905e-4 months <br /> on February 6, 1988, the evening duty Shift Supervisor called the Unit 1 Operations Manager to discuss LCO 3.6.3 applicability.

Again they concluded that only LCO 3.7.1.5 applied.

NL.LER88015 gg.c.. m.

i,nc f e.m 304A U g eeuCLta: Eg;UkifoAY Conah,israose UCENSEE EVENT REPORT (LER) TEXT CONTINUATION maovio omo mo+oa o mis om a

,aciuf r esat-In occati neuessen G8 Lam sevassen ISI PAGE<>

vsaa

" M a" T.".?:

bouth Texas, Unit 1 o l5 l0 l0 j o l4 l 9l8 q8 0l1l5 0 l0 0l 3 0F 0l5 Ym r, w Aac w maa wim DESCRIPTION OF OCCURRENCE (Cont.)

At approximately 0800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> on February 7, 1980, in discussion with the resident NRC inspector, it was determined LCO 3.6.3 was applicable.

Power was removed from "A" and "C" MSIVs at approximately 0830 hours0.00961 days <br />0.231 hours <br />0.00137 weeks <br />3.15815e-4 months <br /> to comply with Technical Specification 3.6.3 action requirements. At this time it was also determined that a 24-hour Technical Specification violation notification was required because power had not been removed from the valve actuators within four (4) hours of declaring the valves inoperable on February 6, 1988, as required by LCO 3.6.3.

At approximately 1730 hours0.02 days <br />0.481 hours <br />0.00286 weeks <br />6.58265e-4 months <br /> on February 7, 1988, with the unit in Mode 4, the "A"

and "C" MSIVs were stroked and timed satisfactory per the approved surveillance procedure. The MSIVs were declared operable at this time and Technical Specifications 3.6.3 and 3.7.1.5 satisfied.

At approximately 1734 hours0.0201 days <br />0.482 hours <br />0.00287 weeks <br />6.59787e-4 months <br /> on February 7, 1988, the NRC was notified via the ENS of Technical Specification non-compliance pursuant to the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> reportability requirements.

The "A" and "C" MSIVs were inoperable for approximately 56 hours6.481481e-4 days <br />0.0156 hours <br />9.259259e-5 weeks <br />2.1308e-5 months <br />. However, they remained closed thrce2ghout this time until stroked for surveillance testing.

At approximately 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br /> on February 8, 1988, the resident NRC inspector dicussed Technical Specification 3.0.3 applicability to this event with the Unit 1 Operations Manager, and it was decided the 2 nit had not complied with Technical Specifications in that two (2) MSIVs were inoperable while the unit in Mode 3, contrary to the action statement requirements of LCO 3.7.1.5.

was A second notification to the NRC was made pursuant to this violation at approximately 1128 hours0.0131 days <br />0.313 hours <br />0.00187 weeks <br />4.29204e-4 months <br /> on February 9, 198U, via the ENS.

_CAUSE OF OCCURRENCE:

The root causes for their event are:

(1) Failure of the Unit Supervisor to recognize that the MSIV's were inoperable due to insufficient familiarity with Technical Specifications 3.6.3 and 3.7.1.5.

(2) Failure of the Unit Supervisor to involve his supervisors in deciding the operability of the valves.

(3) The Te:hnical Specifications do not clearly identify that Section 3.6.3 applies to the MSIV's and it does not clearly specify tho action requirements for this type of containment isolation if the specification is applied.

NL.LER88015 i

e e o a. >w.

U S. NUCLEfJ KE1ULtTZY COMMI58 TON NRC 7erm 364A LICENSEE EVENT REPORT (LER) TEXT CONTINUATION Areaoveo ous No. siso-oio4 EXPIRE S. 8/31/55 P ACILITY NAME II)

DOCK ET NUMBER GI LER NUM8t R 85)

PAGE138 8 ' O ' ' *d ',' '

• I* *h' 2'

YEAR

%yy South Texas, Unit 1 o l5 jo [o l0 l4 l9 p 8 (8 0lIl5 0l0 0l 4 OF d5 rtxt in== -. e...ase,ec r.= amLa u tm

CORRECTIVE ACTIONS

The following corrective actions have been or will be taken to prevent recurrence of this event:

1.

The Unit 1 Operations Manager has issued a memo to the Shift Jupervisors which discusses this event and the applicability of Technical Specification LCO 3.6.3 to all containment isolation valves listed in FSAR table 3.6.2.4-2.

2.

Intermediate corrective action for this event will be to review the operability requirements for containment isolation valves with Licensed Operators between March 28 and April 29, 1988 during requalification training.

3.

Long Term corrective action will be the evaluation and revision as necessary to the Licensed Operator Training Program to ensure that Technical Specifications are taught with emphasis on practical applications.

This will be completed by August 31, 1988.

4.

Nuclear Plant Operations has implemented a procedure which requires a three party review by the Shift Supervisor, Unit Supervisor and Shift Technical Advisor of all LCO actions.

ANALYSIS OF EVENT

This event had no impact on the health and safety of the public because the Main Steam Isolation Valves were closed for the duration of the event and the unit had not achieved criticality by this time.

The MSIVs were to have been stroke tested immediately after opening to prove operability as detailed in the Post-Maintenance Instructions of the MWR.

However, this event is reportable as a Licensee Event Report under 10CFR50.73(a)(2)(1)(B) because the unit was operating in a mode prohibited by Technical Specifications.

Additionally, because this event was the result of a single cause which allowed independent trains to become inoperable, this event is also reportable pursuant to 10CFR50.73(a)(2)(vii).

NL,LER88015 104r33

l U $ DeUChl A3 REGUL AtoaY Coadaste84ces NC f oem 184A LICENSEE EVENT REPORT (LER) TEXT CONTINUATION unovio owe no sino.ew IRPlatl 8/2f ts PLCitif y e.Aast au DxusT seusseta (81 Lea hvaseta ts PAos th

(' [g '['

",'y',*aY vEAA South Texas, Unit 1 0 l5 j o j 0 l0 l419 l 8 fj 8 0 l lI 5 Ol0 Ol 5 0'

0 l5 l

7LXT /r mere spees s soenset ans assenaar AstC Are Jma'st iIM

ADDITIONAL INFORMATION

There has been one other reportable event due to a misinterpretation of the Technical Specifications.

This has been reported to the NRC as LER 86-019.

P L. ' "' ? ? ? ' E esegSQAW Mea it 43#

~ -

The Light company P.O. Ilox 1700 llouston, Texas 77001 (713) 228 9211 llouston Lighting & Power March 22, 1988 ST-HL-AE-2527 File No.:

G26 10CFR50.73 U.

S. Nuclear Regulatory Commission Attention:

Document Control Desk Washington, DC 20555 South Texas Project Electric Generating Station Unit 1 Docket No. STN 50-498 License Event Report 88-015 Regarding Two MSIVs Being Inoperable Resulting in a Technical Specification Violation On February 7, 1988, Houston Lighting & Power Company (HL&P) notified the NRC pursuant to 10CFR50.72 of a reportable event regarding two (2) Main Steam Isolation Valves (MSIVs) being inoperable at the same time resulting in a violation of the Technical Specifications.

The event did not have any adverse impact on the health and safety of the public.

In accordance with 10CFR50.73, HL&P submits the attached Licensee Event Report (LER 88-015).

If you should have any questions on this matter, please contact Mr. C.A. Ayala at (512) 972-8628.

G. E. Vaughn Vice President Nuclear Plant Operations GEV/MEP/eg

Attachment:

Licensee Event Report 88-015 Regarding Two MSIVs Being Inoperable Resulting in a Technical Specification Violation Ob A Subsidiary of Ilouston Industries Incorporated NL.LER88015

/ /

r a

Ilouston Lighting & Power Company

- ST-HL-AE-2550 File No.: G26 Page 2 cc Regional Administrator, Region IV Rufus S. Scott Nuclear Regulatory Commissien Associate General Counsel' 611 Ryan Plaza Drive, Suite 1000 Houston Lighting & Power Company Arlington, TX 76011 P. O. Box 1700 Houston, TX 77001 N. Prasad Kadambi, Project Manager U. S. Nuclear Regulatory Commission INPO 1 White Flint North Records Center 11555 Rockville Pike 1100 Circle 75 Parkway Rockville, MD 20859 Atlanta, Ga. 30339-3064 Dan R. Carpenter Dr. Joseph M. Hendrie Senior Resident Inspector / Operations 50 Bellport Lane e/o U. S.-Nuclear Regulatory Commission Bellport, NY 11713 P. O.. Box 910 Bay City, TX 77414 Don L. Garrison Resident Inspector / Construction c/o U. S. Nuclear Regulatory Commission P. O. Box 910 Bay City, TX 77414 J. R. Newman, Esquire Newman & Holtzinger, P.C.

1615 L Street, N.W.

Washington, DC 20036 R. L. Range /R. P. Verret Central Power & Light Company P. O. Box 2121 Corpus Christi, TX 78403 R. John Miner (2 copies)

Chief Operating Officer City of Austin Electric Utility 721 Barton Springs Road Austin, TX 78704 R. J. Costello/M. T. Hardt City Public Service Board P. O. Box 1771 San Antonio, TX 78296 Revised 03/18/88 NL.LER. DISTR.1

=