05000336/LER-1996-023, :on 960425,discrepancies Found in Various TS Required Valve Lineups.Caused by Failure to Incorporate TS SRs Into Plant Surveillance Procedures.Isolation Valves Had Been Inspected & Verified to Be in Closed Position

:on 960425,discrepancies Found in Various TS Required Valve Lineups.Caused by Failure to Incorporate TS SRs Into Plant Surveillance Procedures.Isolation Valves Had Been Inspected & Verified to Be in Closed Position

ML20133M220
Person / Time
Site:	Millstone
Issue date:	01/15/1997
From:	Laudenat R NORTHEAST NUCLEAR ENERGY CO.
To:
Shared Package
ML20133M209	List: 05000336/LER-1996-023, :on 960425,discrepancies Found in Various TS Required Valve Lineups.Caused by Failure to Incorporate TS SRs Into Plant Surveillance Procedures.Isolation Valves Had Been Inspected & Verified to Be in Closed Position 05000336/LER-1996-023-01, Forwards Suppl LER 96-023-01,providing Update on Analysis & Investigation of Event That Occurred at Milestone Station on 960425
References
LER-96-023, LER-96-23, NUDOCS 9701220307
Download: ML20133M220 (4)

LER-1996-023, on 960425,discrepancies Found in Various TS Required Valve Lineups.Caused by Failure to Incorporate TS SRs Into Plant Surveillance Procedures.Isolation Valves Had Been Inspected & Verified to Be in Closed Position

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) 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3361996023R00 - NRC Website

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NRC FORM'J66 U.S. NUCLEAR REGULATORY COMMISSION APPROVED SY oMB NO.3150-0104 EXPIRES 04/30/98 LICENSEE EVENT REPORT (LER)

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P.LCLITY NAME (1)

DOCKET NUMBER (2)

PAGE (3)

Millstone Nuclear Power Station Unit 2 05000336 1OF4 1

TITLE 141 1

Discrepancies Found in Various Technical Specification Required Valve Lineups.

EVENT DATE (5)

LER NUMBER (6)

REPORT DATE (7)

OTHER FACILITIES INVOLVED (8)

SE MONTH DAY YEAR YEAR MONTH DAY YEAR NU NU 01 01 15 97 023 04 25 96 96 OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE R20UIREMENTS OF 10 CFR 5: (Check one or more) (11)

MODE (9) 5 20.2201(b) 20.2203(a)'2)(v)

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

POWER 20.2203(aH1) 20.2203(a)(3H0 50.73(a)(2)(ii) 50.73(a)(2)(x) 000 LEVEL (10) 20.2203(aH2Hi) 20.2203(aH3)(ii) 50.73(a)(2)(iii) 73.71 20.2203(a)(2Hii) 20.2203(a)(4) 50.73(a)(2)(iv)

OTHER 20.2203(a)(2Hui) 50.36(c)(1) 50.73(a)(2)(v) specify in Abstract below or in NRC Form 366A 20.2203(a)(2Hiv) 50.36(cH2) 50.73(a)(2)(vid UCENSEE CONTACT FOR THis LER (12)

NAME TELEPHONE NUMBER tincit,de Area Codel R. T. Laudenat, MP2 Nuclear Licensing Manager (860) 444-5248 9

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

" "^

CAUSE

SYSTEM COMPONENT MANUFACTURIR

CAUSE

SYSTEM COMPONENT MANUFACTURER PRDS PD 1

I 4

MONTH DAY YEAF SUPPLEMENTAL REPORT EXPECTED (14)

EXPECTED YES SUBMISSION X NO DATE (15)

(if yes, complete EXPECTED SUBMISSION DATE).

ABSTRACT (Limit to 1400 spaces. 6 e., approximately 15 single-spaced typewntten lines) (16)

On April 25,1996 at 1520 hours0.0176 days <br />0.422 hours <br />0.00251 weeks <br />5.7836e-4 months <br />, with the plant in mode 5 at 0% power, an internal audit discovered that several valves located within containment isolation boundaries were not being inspected to verify they were in the closed position. This monthly check demonstrates containment integrity and is required to be performed at least once per 31 days, in accordance with the requirements of Technical Specifications (TS) section 4.6.1.1.a. This event is being reported pursuant to the requirements of 10 CFR 50.73(a)(2)(i)(B), "Any operation or condition prohibited i

by the plant's Technical Specifications." As corrective action, other TS surveillances which require periodic valve position verification were reviewed and deficiencies identified for TS sections: 4.1.2.1a & b, 4.1.2.2b, 4.5.2a.7, 4.5.3.1, 4.7.1.2a.5, 4.7.3.1 a.5, and 4.7.4.1 a.5.

l The cause of this event was failure to properly incorporate Technical Specification surveillance requirements into plant surveillance procedures.

4 The isolation valves that had not been inspected in accordance with the TS were subsequently inspected and vzrified to be in the closed position. Other valve line-ups which fulfill TS required valve position verifications were rsviewed. Procedure changes have been completed to add the missing valves to the appropriate forms.

9701220307 970115 PDR ADOCK 05000336 S

PDR NWC f oRM 366 14-95)

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NHC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION l&95)

UCENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DOCKET LER NUMBER (6)

PAGE (3)

SEQUENTIAL REVISION YEAR NUMBER NUMBER 2OF4 Millstone Nuclear Power Station Unit 2 05000336 96

- 023 --

01 TEXT W more space is required, use additional copies of NRC form 366A) (17)

L Descriotion of Event:

On April 25,1996 at 1520 hours0.0176 days <br />0.422 hours <br />0.00251 weeks <br />5.7836e-4 months <br />, with the plant in mode 5 at 0% power, an internal audit discovered that s2veral valves located within containment isolation boundaries were not being inspected to verify they were in th2 closed position. This monthly check demonstrates containment integrity and is required to be performed at Iscst once per 31 days, in accordance with the requirements of TS section 4.6.1.1.a.

As part of the corrective action, other TS surveillances were reviewed to identify those surveillances which r: quire periodic verification of valve positions. The applicable surveillance procedure valve line-ups which fulfill tha other surveillance requirements were reviewed to verify that all required valves were included. Discrepancies w:ro identified in 13 of the 16 valve lineups. The valve line-ups which had discrepancies were associated with TS Surveillances: 4.1.2.1 a & b, 4.1.2.2b, 4.5.2a.7, 4.5.3.1, 4.7.1.2a.5, 4.7.3.1 a.5, and 4.7.4.1 a.5.

II.

Cause of Event

Ths cause of this event was failure to properly incorporate Technical Specification surveillance requirements into plant surveillance procedures.

Ill. Analysis of Evg This event is being reported pursuant to the requirements of 10 CFR 50.73(a)(2)(i)(B), "Any operation or condition prohibited by the plant's Technical Specifications." Valves required to maintain containment integrity and safety system valve alignment were not verified and documented to be in the proper position in accordance with the requirements of TS. The following TS sections were reviewed: 4.6.1.1.a, 4.6.2.1a.6, 4.1.2.la & b, 4.1.2.2b, 4.5.2a.7, 4.5.3.1, 4.7.1.2a 5, 4.7.3.1 a.5 and 4.7.4.1 a.5.

Th3 initial containment isolation valve procedural discrepancies identified in this event were discovered by an inttrnal audit team tasked with reviewing TS compliance. The Final Safety Analysis Report (FSAR) table 5.2-11 lists containment structure isolation valve information. The audit found that some valves listed in the FSAR table, were not listed on the monthly surveillance procedure (OPS Form 2605A-1) and, therefore, operators were not verifying the valves were in the closed position.

Th3 containment isolation valves in the initial investigation, which were determined to be required for the surveillance procedure, are 3/4 inch and smaller vent and drain valves, a 2 inch isolation valve (2-CH-517) located on the pressurizer auxiliary spray line, and two 8 inch main steam line atmospheric dump valves (MS-190 A & B). The 31 day surveillance was not performed on these valves, however, an inspection was p;rformed to verify these valves are closed. Additionally, the investigation determined that all but two 3/8" drein valves were previously inspected as required by other surveillance procedures, however, not within a 31 dry cycle. The actual and potential safety significance of this event is low since subsequent to the event the velves were verified to be closed.

Th3 other system valves discovered in the subsequent reviews included thirty nine 3/4 inch vent, drain and instrument root valves, in addition, there were 28 process flow valves, most were service water (SW) valves us:d to valve the Reactor Building Closed Cooling Water (RBCCW), Turbine Building Closed Cooling Water (TBCCW ), Diesel Generators, or chiller heat exchangers into and out of service and are aligned in system op: rating procedures. Other SW valves aligned lube water to the circulating water pumps. The remaining valves N!.C FORM 366A (4 95)

NRC FORM 3E6A U.S. NUCLEAR REGULATORY COMMISSION (5 95 UCENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DOCKET LER NUMBER (6)

PAGE (3)

SEQUENTIAL REVISION YEAR NUMBER NUMBER 3OF4 Millstone Nuclear Power Station Unit 2 05000336 96

-- 023 -

01 TEXT lit more space os required use additional copies of NRC Form 366A) (17) provide condensate make-up to the RBCCW surge tank. Misalignment of these process flow valves would be d:tected by changes in the operating parameters in the affected systems.

IV. Corrective Action

The isolation valves that had not been inspected in accordance with the TS were subsequently inspected and v:rified to be in the closed position.

Procedure changes to add the missing valves to the deficient surveillance procedure valve line-ups have been completed and approved.

Sito procedures " Administration of Millstone Procedures and Forms" and Developing and Revising Millstone Procedures and Forms" have been revised to provide improved guidance in the areas of Design Basis document end TS compliance.

A shift briefing has been provided to inform operations personnel of this issue and the need to comply with tra above procedural guidance and to maintain verbatim compliance with TS requirements.

Technical Specification surveillance procedures will be reviewed to ensure compliance with Technical Specification surveillance requirements as part of the Millstone Unit No. 2 Operational Readiness Plan. The review will initially focus on Technical Specification surveillance procedures required for Mooc 6 and defueled.

Surveillance procedures required for subsequent mode changes will be reviewed prior in mode entry. (This commitment was previously sent to the NRC in the response to NOV 336/96-08-07, NNECO Commitment No.

B16076-2.)

l V.

Additional Information

Ells Codes:

EK:

Diesel Generators KW:

Service Water KB:

Turbine Building Closed Cooling Water CC:

Reactor Building Closed Cooling Water SB:

Main Steam CB:

Pressurizer Auxiliary Spray

Similar Events

Similar LERs that involve deficient surveillance procedures include:

LER 96-023-00 Failure to Perform Technical Specification Surveillances on Certain Containment Isolation Valves LER 96-024-00 Response Time Testing of RPS and ESAS Failed to include Response Time of SPEC 200 Electronics LER 96-025-00 Enclosure Building Filtration Actuation Signal / Auxiliary Actuation Signal Interlock Not Tested Periodically N.7C FORM 366A (4 951

yU.S. WUCLEAR REGULATORY COMMISSION (4 91) e LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DOCKET LER NUMBER (6)

PAGE (3)

SEQUENTIAL REVISION YEAR NUMBER NUMBER 4OF4 Millstone Nuclear Power Station Unit 2 05000336 96

- 023 -

01 TEKT (11 more space is requoted, use additional copies of NRC form 366A) (17)

~

LER 96-026-00 incomplete Technical Specification Required Surveillance - Valve Lineups inside Containment LER 96-035-00 Failure to Perform Periodic Surveillance Testing for Interlock Function Associated with the Main Steam Isolation System Function of the Engineered Safeguards Actuation System LER 96-037-00 inadequate Surveillance Procedure for Verifying Average Water Temperature at the Unit 2 Intake Structure LER 96-038-00 Inadequate Surveillance Procedure Used to Verify Emergency Diesel Generator Operability LER 96 039-00 Failure to Perform Periodic Surveillance Testing for Containment Purge System Containment Isciation Valves in Accordance with Technical Specification 4.9.10 Manufacturer Data:

None 1

NQC FoQM 366A 44 95)

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