05000499/LER-1996-001, :on 960119,TS 3.0.3 Entry Occurred Due to Two MFW Isolation Valves Being Inoperable at Same Time.Discussed Enhanced Mgt Expectations W/Emphasis on Clear & Concise Communications

:on 960119,TS 3.0.3 Entry Occurred Due to Two MFW Isolation Valves Being Inoperable at Same Time.Discussed Enhanced Mgt Expectations W/Emphasis on Clear & Concise Communications

ML20100J425
Person / Time
Site:	South Texas
Issue date:	02/19/1996
From:	Groth J, Head S HOUSTON LIGHTING & POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-96-001, LER-96-1, ST-HL-AE-5294, NUDOCS 9602290076
Download: ML20100J425 (6)

LER-1996-001, on 960119,TS 3.0.3 Entry Occurred Due to Two MFW Isolation Valves Being Inoperable at Same Time.Discussed Enhanced Mgt Expectations W/Emphasis on Clear & Concise Communications

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2) 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
4991996001R00 - NRC Website

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.The Light companth Texas Project Electric Generating Station P.O. Box 289 Wadsworth Howton lighteng & Power February 19, 1996 ST-HL-AE-5294 File No.: G26 10CFR50.73 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 i

South Texas Project i

Unit 2 Docket No. STN 50-499 Licensee Event Report 96-001 I

Technical Specification 3.0.3 Entry Due to Two Main Feedwater Isolation Valves Beine Inonerable at the Same Time i

t Pursuant to 10CFR50.73, South Texas Project submits the attached Unit 2 Licensee Event Report 96-001 regarding Technical Specification 3.0.3 entry due to two main feedwater isolation valves being inoperable at the same time. This event did not have an adverse effect on the health and safety of the pubhc.

If you should have any questions on this matter, please contact Mr. S. M. Head at (512) 972-7136 or me at (512) 972-8664.

1 J. F. Groth Vice President, Nuclear Generation l

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Attachment: LER 96-001 (South Texas, Unit 2) 9602290076 960219 PDR ADOCK 05000499 S

PDR g/jfff 290016 Project Manager on Behalf of the Participants in the South Texas Project i

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,- Houston. Lighting & Power Company ST-HL-AE-5294 South Texas Project Electric Generating Static" File No.: G26 Page 2 c

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l Leonard J. Callan Rufus S. Scott i

Regional Administrator, RegionIV Associate General Counsel l

U. S.' Nuclear Regulatory Commission Houston Lighting & Power Company -

t 611 Ryan Plaza Drive, Suite 400 P. O. Box 61067 Arlington, TX 76011-8064 Houston, TX 77208 Thomas W. Alexion Institute of Nuclear Power Project Manager Operations.- Records Center U. S. Nuclear Regulatory Commission 700 Galleria Parkway Washington, DC 20555-0001 13H15 Atlanta, GA 30339-5957 l

l David P. Loveless Dr. Joseph M. Hendrie Sr. Resident Inspector 50 Bellport Lane l

c/o U. S. Nuclear Regulatory Comm.

Bellport, NY l1713 P. O. Box 910 Bay City, TX 77404-0910 Richard A. Ratliff Bureau of Radiation Control J. R. Newman, Esquire Texas Department of Health Morgan, Lewis & Bockius 1100 West 49th Street 1800 M Street, N.W.

Austin, TX 78756-3189 Washington, DC 20036-5869 U. S. Nuclear Regulatory Comm.

K. J. Fiedler/M. T. Hardt Attn: Document Control Desk l

City Public Service Washington, D. C. 20555-0001 P. O. Box 1771 San Antonio, TX 78296 j

J. C. Lanier/M. B.12e J. R. Egan, Esquire City of Austin Egan & Associates, P.C.

Electric Utility Department 2300 N Street, N.W.

721 Barton Springs Road Washington, D.C. 20037 Austin, TX 78704 Central Power and Light Company J. W. Beck ATTN: G. E. Vaughn/C. A. Johnson Little Harbor Consultants, Inc.

P. O. Box 289, Mail Code: N5012 44 Nichols Road Wadsworth, TX 77483 Cohassett, MA 02025-1166

NRC FORM 386 U.S. NUCLEAR kEAULATouY COMMASION APPR5VE3 SY OMS NO. 3150 0104 (4-96) -

EXPIRES 04/30/98 ESTIMATED EUR MANDATORY IN, DEN PER RESPONSE TO COMTLY WITH THIS i

ORMATION COLLECTION REQUEST: 50.0 HRS.

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South Texas, Unit 2 05000 499 1 OF 4 ne p) l Technical Specification 3.0.3 entry due to two main feedwater isolation valves being inoperable at the same time

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EVENT DATE (5)

LER NUMBER (6)

REPORT DATE (7)

OTHER FACIUTIES INVOLVED (5)

FACluTY NAME DOCMET NUMBER SE MONTH DAY YEAR YEAR MONTH DAY YEAR NUMBER NU E 05000 FACIUTY NAME DOCKET NUMBER 01 19

% -- 001 00 02 19 g3999 CPERATING THIS REP RT IS SUBMITTED PURSUANT TO THE REOUIREMENTS OF 10 CFR S: (Check one or more) (11) 3 CODE (9) 20.2201(b) 20.2203(a)(2)(v)

X 50.73(a)(2)(i) 50.73(a)(2)(vni)

POWER 0

LEVEL (10) 20.2203(a)(2)(i) 20.2203(a)(3)(n) 50.73(a)(2)(hi) 73.71 20.2203(a)(2)(ii) 20.2203(a)(4) 50.73(a)(2)(iv) oTHER 20.2203(a)(2)(ni) 50.36(c)(1) 50.73(a)(2)(v) gyge below 20.2203(a)(2)(sv) 50.36(c)(2) 50.73(a)(2)(vH)

UCENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER pneude Area Code)

Scott M. Head - Sr. Consulting Engineer (512) 972-7136 COMPLETE ONE UNE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

REPORTABL T^

CAUSE

SYSTEM COMPONENT MANUFACTURER E

CAUSE

SYSTEM COMPONENT MANUFACTURER r NPRD SUPPLEMENTAL REPORT EXPECTED (14)

MONTH DAY YEAR EXPECTED YES SUBMISSION X

NO (if yes, complete EXPECTED SUBMISSION DATE).

DATE (15)

ABSTRACT (umet to 1400 spaces,6.e, approximately 15 single-spaced typewntion knes) (16)

On January 19,19%, Unit 2 was in Mode 3 at 0% power. At 0825 hours0.00955 days <br />0.229 hours <br />0.00136 weeks <br />3.139125e-4 months <br />, Technical Specification 3.0.3 was entered when it was determined that a Limiting Condition for Operation was not met for an existing condition in which two closed main feedwater isolation valves were declared inoperable for maintenance on January 18,1996 at 1750 hours0.0203 days <br />0.486 hours <br />0.00289 weeks <br />6.65875e-4 months <br />. An Usual Event was declared at 0935 hours0.0108 days <br />0.26 hours <br />0.00155 weeks <br />3.557675e-4 months <br /> on January 19,1996. Post maintenance testing on one of the affected main feedwater isolation valves was performed satisfactorily and the valve was declared operable. With one remaining main feedwater isolation valve inoperable and closed, the required action for Technical Specification 3.7.1.7 Limiting Condition for Operation was met. Technical Specification 3.0.3 was exited at 1028 hours0.0119 days <br />0.286 hours <br />0.0017 weeks <br />3.91154e-4 months <br /> and the Unusual Event was exited at 1031 hours0.0119 days <br />0.286 hours <br />0.0017 weeks <br />3.922955e-4 months <br /> on January 19, 1996. Subsequent investigation determined that the declaration of an Unusual Event was inappropriate. The root cause of this event was human error. Corrective actions included a discussion of enhanced management j

expectations with emphasis on clear, concise communications, use of the chain of command, and control of logging entry into Technical Specification Limiting Condition for Operation. Other corrective actions involve Emergency Plan refresher training with emphasis on continued application of conservative decision making and guidance regarding commumcations and work coordination.

i NRC ForN 366 (4-95)

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l NRCP0xM 306A U.S. NUCLEAR REJULATORY COMMAS 10N

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LICENIEE EVENT REPORT (LER)

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TEXT CONTINUATION FACRJTY NAME (1)

DOCKET LER NUMBER iS)

PAGE (3)

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South Texas, Unit 2 05000 499 2

OF 4 001 -

00 TEKT (if more space ss required, use additional copies of NRC Form 366A) (t7)

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l DI?SCRIPTION OF EVENT:

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L On January 19,1996, Unit 2 was in Mode 3 at 0% power in a planned outage for main electrical generator j

r: pairs. At 0825 hours0.00955 days <br />0.229 hours <br />0.00136 weeks <br />3.139125e-4 months <br />, Technical Specification 3.0.3 was entered and preparations were started for transition

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to Mode 4 operations. Technical Specification 3.0.3 was entered when it was determined that a Limiting l

Condition for Operation was not met for a existing condition in which two closed main feedwater isolation valves were declared inoperable.

L Work to adjust the packing for main feedwater isolation valves FW-7141 and FW-7143 was planned to be conducted on one main feedwater isolation valve at a time. The intent was to test the first valve after packing adjustment was completed in order to verify operability before packing adjustments were conducted on the second valve. This plan was not effectively communicated to personnel involved in controlling the activity.

Work Start' Authority in the outage work control facility reviewed the effect of planned packing adjustment maintenance on Technical Specifications. After a review of Technical Specification 3.7.1.7 and a supporting Technical Specification Interpretation, it was concluded that the main feedwater isolation valves would remain i

operable and performing their intended safety function as long as the valves remained closed and a positive means was maintained to prevent the valve from inadvertently opening. The review failed to note that the Technical Specification Interpretation only applied to Modes I and 2. As a result, work start authorization was given to perform maintenance on both valves.

On January 18,1996, at 1750 hours0.0203 days <br />0.486 hours <br />0.00289 weeks <br />6.65875e-4 months <br />, main feedwater isolation valves FW-7141 and FW-7143 were logged out of service. The condition of these valves was documented in the Operability Assessment System for tracking work and subsequent testing. In addition, an entry was made in the Control Room log that Technical Specification 3.7.1.7 was applicable for main feedwater isolation valves FW-7141 and FW-7143 being placed out of service. Work Start Authority did not fully discuss the documented condition of these two valves with the Control Room except that the valves were out of service.

During the next two shift changes, main feedwater isolation valves FW-7141 and FW-7143 were turned over as inoperable. Neither shift recognized that Technical Specification 3.7.1.7 Limiting Condition for Operation included no provisions for two inoperable main feedwater isolation valves in Mode 3. At approximately 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br /> and 2300 hours0.0266 days <br />0.639 hours <br />0.0038 weeks <br />8.7515e-4 months <br />, the packing on valves FW-7143 and FW-7141 respectively was adjusted, which i

potentially affected each valve's stroke time and brought into question whether each valve's Technical Specification surveillance stroke requirement could be met.

l On January 19, 1996 shortly after turnover to the day shift, discussions were conducted regarding the operability of main feedwater isolation valves FW-7141 and FW-7143 and entry into Technical Specification 3.7.1.7.

At 0825 hours0.00955 days <br />0.229 hours <br />0.00136 weeks <br />3.139125e-4 months <br />, it was determined that there was no provision in Technical Specification 3.7.1.7 Limiting Condition for Operation for two inoperable closed main feedwater isolation valves while in Mode l

3 c.nd Technical Specification 3.0.3 was entered. After further discussion, an Unusual Event was declared l

at 0935 hours0.0108 days <br />0.26 hours <br />0.00155 weeks <br />3.557675e-4 months <br />.

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I NRC FORJ 366A U.S. NUCLEAA REA ULATo..Y CoMMmSION (M5)

LICENZEE EVENT REPORT (LER)

TEXT CONTINUATION FACIUTV NAME (1)

DOCKET LER NUMBER (6)

PAGE (3)

YEAR SEQUENTIAL REVlRION South Texas, Unit 2 05000 499 3

OF 4

96 - 001 00 TEXT (if more space is required use additional copies of NRC Form 366A) (17)

DESCRIPTION OF EVENT (CONTINU.ED1 Operability testing on main feedwater isolatie valve FW-7141 was performed satisfactorily and the valve was declared operable. With one remaining main feedwater isolation valve inoperable and closed, the required action for Technical Specification 3.7.1.7 Limiting Condition for Operation in Mode 3 was met. Technical Specification 3.0.3 was exited at 1028 hours0.0119 days <br />0.286 hours <br />0.0017 weeks <br />3.91154e-4 months <br /> and the Unusual Event was exited at 1031 hours0.0119 days <br />0.286 hours <br />0.0017 weeks <br />3.922955e-4 months <br /> on January 19, 1996. The preparations to transition to Mode 4 were stopped. No plant cooldown was conducted.

i Subsequent investigation determined that the declaration of an Unusual Event was inappropriate. The bases used for declaring the Unusual Event states that an immediate declaration of an Unusual Event is required when the plant cannot be brought to the required operating mode within the allowable action statement time in the Technical Specifications, as the plant is outside its safety envelope. For this event, the plant was required to be in Mode 4 within the 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> following initiation of action to transition to Mode 4 as required by the entry into Technical Specification 3.0.3. There was no indication that the required action of Technical Specification 3.0.3 could not be met at the time of the declaration of the Unusual Event. A conservative decision had been made to declare an Unusual Event.

CAUSE OF EVENT

The root cause of this event was human error.

l The misapplication of the interpretation for Technical Specification 3.7.1.7 resulted in allowing the performance l

of maintenance that affected the operability of more components than allowed Sv Technical Specifications.

The failure to recognize that the plant was in a condition not allowed by Technical Specifications for approximately 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> resulted from a lack of a questioning attitude regarding the condition of main feedwater isolation valves FW-7141 and FW-7143.

Contributing to this event was ineffective communications between the work start authority and the control room.

l 1

ANALYSIS OF EVENT

Any operation or condition prohibited by Technical Specifications is reportable pursuant to 10CFR50.73(a)(2)(i)(B). The main feedwater isolation valves were shut and performing their required safety function. However, the maintenance performed on main feedwater i!.olation valves FW-7141 and FW-7143 brought into question the ability of these valves to meet their Technical Specification stroke time surveillance requirement and resulted in declaring these valves inoperable until post maintenance testing could verify valve operability. In the closed position, the potential inability of the valves to meet their stroke time has no safety 4

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i iU.S. NUCLEAR RE.ULAToRY COMM SloN j

(4 95)

LICENCEE EVENT REPORT (LER)

]

TEXT CONTINUATION FACluTY NAME (1)

DOCKET LER NUMBER (6)

PAGE (3)

YEAR SEQUENTIAL REVISION South Texas, Unit 2 05000 499 4

OF 4 96 - 001 00 TEXT (if more space is required, use additional copies of NRC Form 366A) (t7)

ANALYSIS OF EVENT (CONTINUEDh significance. Post maintenance testing after packing adjustment confirmed that main feedwater isolation valves FW-7141 and FW-7143 met their Technical Specification surveillance requirements.

M in feedwater isolation valves FW-7141 and FW-7143 have large actuator output force of 202,268 lbs-force.

The total valve stem friction component due to packing makes up approximately 3.2 per cent of the actuator output force. Historically, these valves have passed stroke time testing following packing adjustment.

Therefore,it is unlikely that adjusting the packing of the main feedwater isolation valves would have had any significant effect on the valve stroke time and operability.

There were no adverse safety or radiological consequences of this event.

1

CORRECTIVE ACTIONS

l 1.

The lessons from this event resulted in discussions regarding enhanced management expectations including emphasis on clear, concise communications, use of the chain of command, and control of logging entry into Technical Specification Limiting Condition for Operation. These expectations were discussed with the operating crews of both units.

2.

Emergency Plan refresher training discussing the lessons learned from this event will be conducted for Licensed Operators by November 1996. Continued application of conservative decision making in regard to issuing reports will be emphasized.

3.

Guidance has been issued regarding communications and work coordination between the work start authority and the Control Room.

i

ADDITIONAL INFORMATION

A revision to Technical Specification 3.7.1.7 will be submitted as part of the station's Improved Technical Specification submittal. The implementation of Improved Technical Specifications should eliminate the need for Technical Specification Interpretations and clear up potential confusion surrounding the application of Technical Specification 3.7.1.7.

There have been no previous reports by the South Texas Project to the Nuclear Regulatory Commission within the last three years regarding Technical Specification 3.0.3 entry due to two main feedwater isolation valves being inoperable at the same time.

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