05000295/LER-1997-002-01, :on 970117,containment Isolation Valves Were Not Tested Prior to Leaving Cold Shutdown.Caused by Mgt Deficiencies in TS Implementation Process.Containment Isolation Valves Will Be Verified Tested Prior to Mode 4
| ML20135A546 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 02/18/1997 |
| From: | Brennan N COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML20135A539 | List:
|
| References | |
| LER-97-002-01, LER-97-2-1, NUDOCS 9702270260 | |
| Download: ML20135A546 (15) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2) 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(1) 10 CFR 50.73(a)(2)(x) |
| 2951997002R01 - NRC Website | |
text
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LICENSEE EVENT REPORT (LER)
FACILITY.NAME 30CKET NUMBER PAGE ZION NUCLEAR POWR STATION UNIT 1 0l5l0l0l0l2l9l5 1 l0F l 1 l 8 TITLE CONTAINMENT ISOLATION VALVES NOT TESTED PRIOR TO LEAVING COLD SHUTDOWN. THIS WAS CAUSED BY MANAGEMENT DEFICIENCIES IN THE TECHNICAL SPECIFICATION IMPLEMENTATInN PROCESS. TH]5 EVENT RESULTED IN MINIMAL SAFETY IMPACT.
EVENT DATE LER NUMBER REPORT DATE OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAF.
SEO.
REV.
MONTH DAY YEAR FACILITY NAMES DOCKET NUMBER (S) 710N UNIT 2 0 l 5 l 0 l 0 l 0 l 3 l 0 l4 i
011 117 9
7 917 0l0l?
010 O!?
il8 917 I I I I I I l
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THIS REPORT Is SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR 5: (CHECK ONE OR MORE OF THE FOLLOWING) 1 20.402(b) 20.405(e) 50.73(a)(2)(1v) 73.71(b)
POWER 20.405(a)(1)(1) 50.36(c)(1) 50.73(a)(2)(v) 73.71(c) 1l0l0 LEVEL 20.405(a)(1)(11) 50.36(c)(2) 50.73(a)(2)(vit)
OTHER (Specify in 20.405(a)(1)(iii)
X 50.73(a)(2)(1) 50.73(a)(2)(v111)(A)
Abstract below l
20.405(a)(1)(1v) 50.73(a)(2)(11) 50.73(a)(2)(vi11)(B) 20.405(a)(1)(v) 50.73(a)(2)(111) 50.73(a)(2)(x)
LICENSEE CONTACT FOR THIS LER NAME TELEPHONF NUMBER N. M. Brennan Ext. 2380 1
elal7 7141si-1210lala COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT l
l
CAUSE
SYSTEM COMPONENT MANUFACTURER
CAUSE
SYSTEM COMPONENT MANUFACTURER l
l 1 1 I I I I
I I I I I I I
I I I I I I I
I I I I I I SUPPLEMENTAL REPORT EXPECTED EXPECTED MONTH DAY YEAR SUBMISSION YEs (if yes. complete EXPECTED SUBMISSION DATE)
M No DATE l
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ABSTRACT (L1mit to 1400 spaces. i.e.
approximately fifteen single-space typewritten lines).
In January 1997 it was identified that in previous outages some pts which contain containment isolation valves l
(CIV) were scheduled for performance after entering Mode 4.
Zion Technical Specification (TS) 3.9.3. A/4.0,5 l
requires that CIVs be operable prior to entering Mode 4.
Amendment 129/118 and Amendment 136/125 implemented TS 4.0.5 which changed the required mode of testing for CIVs. The components in question, which are required during accident conditions, are in systems which fulfill multiple functions (e.g. ECCS and Containment Isolation).
The cause of this event was inadequate review and implementation of procedures associated with Amendment 129/118 and Amendinent 136/125 The process that controls License Amendment changes does not provide for independent review. As a result a single error or erroneous conclusion caused the implementation process to fail.
l l
Although the following valves were not tested prior to entry into Mode 4 in previous outages, they were tested l
satisfactorily prior to entry into Mode 1.
Therefore, the satisfactory testing prior to Mode 1 gave assurance l'
entering Mode 4.
Thus, the safety impact was minimal.
these valves were operable during operation, and gives reasonable assurance these valves were operable prior to The corrective actions are: 1) Unit 2 containment isolation valves will be verified tested prior to Unit 2 entering Mode 4 from Z2R14. 2) The Operations Procedures Group will modify associated procedures or create new procedures to ensure that CIVs are tested prior to entering the required mode of applicability. 3) Zion Station IST Group is continuing a review of the IST program to ensure all requirements are met. 4) Zion Station will modify the Technical Specification Amendment implementation process to include a required independent verification. (NUREG 1022 cause: E) 9702270260 970218 l
PDR ADOCK 05000295 S
PDR.
LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACILIlY NAME DOCKET NUMBER LER NUMBER PAGE l
NEAR SEO.
REV.
l ZION NUCLEAR POWER STATION UNIT 1 0l5l0l0l0l2l9l5 9l7 0l0l2 0l0 0l2 1l8 0F TEXT Energy Industry Identification System (Ells) codes are identified in the text as [XX]
A.
PLANT CONDITIONS PRIOR TO EVENT Unit 1 MODE - 1 Rx Power 100%
RCS [AB] Temperature / Pressure 560 F/2235 psig i
Unit 2 MODE - 5 Rx Power 0%
RCS [AB] Temperature / Pressure 185 F/383 psig B.
DESCRIPTION OF EVENT
l 1
ISSVE It was determined that some of the Zion Station Periodic Tests (pts), which contain Containment Isolation Valves [BD](CIVs). were scheduled for performance after entering Mode 4.
Zion Technical Specification (TS) 3.9.3.A/4.0.5 requires that CIVs be operable prior to entering Mode 4.
In previous outages the pts were performed prior to entering mode of applicability based on the operability requirements of the individual system's mode of applicability rather than the more restrictive mode of applicability of the CIVs.
EVENT I
The On-site review and implementation of Amendment 129/118 placed specification 4.0.5 into the TS on August 28. 199I.
The NRC issued, at the request of Zion Station.
Amendment 129/118 incorporating the 4.0.5 specification only into the pressurizer safety valve technical specification. The NRC stated in their correspondence that the remaining parts of section 4.0.5 would be approved and added at a later time.
The On-site review and im)lementation of Amendment 129/118 was based on the narrow scope of 4.0.5 effects on t1e pressurizer safety valve technical specification.
However, as part of Amendment 129/118 the entire wording of the Westinghouse Standard Technical Specification 4.0.5 was added to the Zion Technical Specification. This standard wording included Section 4.0.5.d which states the following: " Performance of the above inservice ins)ection and testing activities shall be in addition to other specified Surveillance Requirements." Previously only CIVs which were required to close during accident conditions (TS surveillance 4.9.3.A.2.d) were required to be surveillance tested prior to entry into mode 4.
10CFR50.55 required ?ST testing of these valves.
but the TS did not ex31icitly tie Inservice Test (IST) co mode 4.
The NRC approved Amendment 136/125 on iay 12.1992, which incorporated all requirements of TS 4.0.5 as requested in 1991.
Amendment 136/125 also added statements in specific sections referencing section 4.0.5.
Documents state that the review of Amendment 136/125 was l
considered as a reference change only that did not affect operational or operability issues because specification 4.0.5 had existed in the TS for a year.
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t ZLER\\97002.ler(2)
l LICENSEE EVENT REPORT (LER) TEXT CONTINUATION l
FACILITY NAME DOCKET NUMBER LER NUMBER PAGE YEAR SEO.
REV.
ZION NUCLEAR POWER STATION UNIT 1 0l5l0l0l0l2l9l5 9l7 0l0l2 0l0 0l3 1l8
~
0F TEXT Energy Industry Ident1fication System (EIIS) codes are identified in the text as [XX) l B.
DESCRIPTION OF EVENT (Continued)
During 1995 a review by offsite personnel was conducted at Zion Station into TS compliance.
The scope of their review stated, in part. that they independently
{
perform the surveillance testing review, which included examination of the source documents.
In addition. the review effort extended beyond surveillance testing into other portions of the TS and several other document types in an effort to find all errors or omissions which could lead to occurrences of noncompliance.
Also, all reference documents invoked by the TS were reviewed, including the Inservice Testing (IST) Program.
However.
the review failed to identify that the CIVs contained within some pts were not being tested prior to entering the appropriate mode of applicability.
The review relative to IST compliance was )erformed by personnel who possessed experience in IST. but not necessarily knowledgea)le in Zion Station design.
Therefore where components fulfilled multiple functions (e.g. ECCS and Containment Isolation), these interrelationships were not understood and were not identified.
In January 1997, pursuant to a Site Quality verification (SOV) audit (CAR 22-96-043).
i a group was tasked to develop a new mode change checklist prior to the conclusion of Zion refueling outage Z2R14.
During the develo) ment of the check list it was determined that some of the Zion Station pts. w1ich contain CIVs. were scheduled for performance after entering Mode 4.
Zion TS 3.9.3. A requires that CIVs be operable prior to entering Mode 4.
In conjunction with TS 3.9.3. specification 4.0.5 "IST tests" is required in addition to other specified surveillance, as a result these tests are required prior to entry into Mode 4.
The components in question are required during accident conditions, and are in systems which fulfill multiple functions (e.g. ECCS and Containment Isolation).
In previous outages the pts were not performed until after entering Mode 4 based on the operability requirements of the individual system's mode of applicability rather than the more restrictive mode of applicability of the CIVs.
C.
CAUSE OF EVENT
The cause of this event was inadequate review and implementation of procedures associated with Amendment 129/118 and Amendment 136/125.
The process that controls i
License Amendment changes does not provide for independent review.
As a result a single error or erroneous conclusion caused the implementation process to fail.
I l
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ZLER\\97002.ler(3)
LICENSEE EVENT REPORT (LER) TEXT CONTINUATION
-., q FACILITY NAME DOCKET NUMBER LER NUMBER Pg j
YEAR SE0.
REV.
ZION NUCLEAR POWER STATION UNIT 1 0l5l0l0l0l2l9l5 9l7 0l0l2 0l0 0l4 1l8
~
0F
)
TEXT Energy Industry Identification System (EIIS) codes are identified in the text as [XX]
l D.
SAFETY ANALYSIS
An evaluation of the safety significance of this event has been performed. Although i
the following valves were not tested prior to entry into Mode 4. they were tested satisfactorily prior to entry into Mode 1 (normal power operations).
Therefore, the satisfactory testing prior to Mode 1 gave assurance these valves were operable during operation, and gives reasonable assurance these valves were operable prior to entering Mode 4.
A review of stroke time testing since 1993 for the valves which are required to close on a containment isolation signal has revealed that at no time were UFSAR limits exceeded. The following discussion demonstrates that this event does not create an unsafe condition nor was the safety of the public jeopardized by this event.
1.
1(2) A0V-SI8880fB01 This valve is the Nitrogen Supply to the Safety Injection (SI) Accumulators and is a containment isolation valve (CIV) located in penetration P-76. This penetration is classified in UFSAR Table 6.2-4 as Class 5.
UFSAR Section 6.2.4.2.1.5 states Class 5 penetrations as: " lines which Jenetrate the Containment and can be opened to c0ntainment atmosphere. Jut which are normally closed during reactor operation, are provided with two isolation valves in series either inside or outside the containment.
In certain cases a blind flange or closed system outside the Containment is utilized as the second barrier in lieu of an isolation valve." This valve is normally aligned in the closed position and is only opened to increase Accumulator Tank pressure during normal power operations.
Operability of this valve includes free movement of the valve stem, response to an automatic actuation signal, manual control switch actuation, full open and close stroke capability, leakage rate testing. control room indication, and stroke time testing. The procedures that test this valve that potentially are of concern with regards to this event include: PT-2B-ST.
PT-2C-B-ST PT-2C-D-ST and PT-2C-F-ST.
In all of these procedures. 1(2) A0V-SI8880 is stroke time tested in the closed direction and position indication tested in PT-40-28. A review of all the stroke time tests for 1(2) A0V-SI8880 since 2/92 reveals that in all cases, except one, the IST stroke times were acceptable.
On 1/16/96 1A0V-SI8880 had a closure stroke time that exceeded the IST Action Range, but was below the containment isolation maximum stroke time.
This stroke test, however, was aerformed during normal operations, not during a j
startup.
Therefore, although t1e stroke time and position indication testing of the valve was not performed prior to Mode 4. there is reasonable assurance that the valves were, in fact, in an OPERABLE condition when entering Mode 4.
In all cases, the valves were satisfactorily tested prior to Mode 1.
r ZLER\\97002.ler(4)
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- - w i
LICENSEE EVENT REPORT (LER) TEXT CONTINUATION l
FACILITY MHE DOCKET NUMBER LER NUMBER PAGE YEAR SEO.
REV.
l ZION NUCLEAR POWER STATION UNIT 1 0lSl0l0l0l2l9l5 9l7 0l0l2 0l0 0l5 1l8
~
DF TEXT Energy Industry Identification System (Ells) codes are identified in the text as [XX)
D.
SAFETY ANALYSIS (Continued) l 2.
1(2) MOV-SI8809A fB01 and 1(2) MOV-SI88098 fB01 These valves are the low head safety injection (Residual Heat Removal-RHR) isolation valves and are containment isolation valves (CIV) located in penetrations P-108 and P-110. These penetrations are classified in UFSAR Table l
6.2-4 as Class 7.
UFSAR Section 6.2.4.2.1.7 states Class 7 penetrations as:
j
" lines which are required for post accident service have power-operated valves which are either normally open and must remain open during an accident or are normally closed and must be opened should an accident occur.
For such lines, a minimum of one valve outside the containment is provided for containment 1
isolation when the system is no longer required. These valves are also designated as Spurious Valve Acuation Group (SVAG) valves.
They are positioned in their Emergency Core Cooling System (ECCS) position (open) and de-energized during normal power operations. Operability of this valve for containment l
isolation purposes involves the capability of the valve to be stroked closed and
]
l give proper control room position indication. These valves do not receive a i
containment isolation closure signal and do not have a containment isolation l
required maximum stroke time. The procedures that test these valves that were j
l identified by this event include: PT-2B-ST, PT-2C-B-ST PT-2C-D-ST, and PT-2C-F-l ST.
Control room Josition indication testing is performed in PT-40-2C.
l Therefore, althoug1 the stroke time and position indication testing of these l
valves was not performed prior to Mode 4 there is reasonable assurance that the valves were capable of performing their containment isolation functions, if l
required.
In all-cases, the valves were satisfactorily tested prior to Mode 1.
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l 4
4 l
ZLER\\97002.ler(5)
LICENSEE EVENT REPORT (LER) TEXT CONTINUATION 1
FACILITY NAME DOCKET NUMBER LER NUMBER PAGE YEAR SEO.
REV.
ZION NUCLEAR POWER STATION UNIT 1 0l5l0l0l0l2l9l5 9l7 0l0l2 0l0 0l6 1l8
~
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0F TEXT Energy Industry Identification System (EIIS) codes are identified in the text 85 [XX]
D.
SAFETY ANALYSIS (Continued) 3.
1(2) MOV-SI9011A fB01 and 1(2) MOV-SI9011B fB01 These valves are the Safety Injection (SI) Hot Leg Injection isolation valves and are containment isolation valves (CIV) located in penetrations P-24 and P-126. These penetrations are classified in UFSAR Table 6.2-4 as Class 7.
UFSAR Section 6.2.4.2.1.7 states Class 7 penetrations as: " lines which are required for post accident service have power-operated valves which are either normally open and must remain open during an accident or are normally closed and must be oaened should an accident occur.
For such lines, a minimum of one valve outside t1e containment is )rovided for containment isolation when the system is no longer recuired." T1ese valves are also designated as SVAG valves.
They are positionec in their Emergency Core Cooling System (ECCS) position (closed) and de-energized during normal power operations.
Operability of this valve for containment isolation purposes involves the capability of the valve to bc stroked closed and give proper control room position indication.
These valves do not receive a containment isolation closure signal and do not have a containment isolation recuired maximum stroke time.
The procedures that test these valves that were icentified by this event include: PT-2B-ST. PT-2C-B-ST.
PT-2C-D-ST. and PT-2C-F-ST.
Control room position indication testing is performed in PT-40-2A.
Although these valves were not tested per these procedures prior to Mode 4. the valves were positioned in their closed position and tested in PT-2A-RT.
Therefore, there is reasonable assurance that the valves were capable of performing their containment isolation functions, if required. In all cases, the valves were satisfactorily tested prior to Mode 1.
1 ZLER\\97002.ler(6)
l LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACILITY fWiE DOCKET NUMBER LER NUMBER PAGE YEAR SEO.
REV.
ZION NUCLEAR POWER STATION UNIT 1 0l5l0l0l0l2l9l5 9l7 0l0l2 0l0 0l7 1l8 0F TEXT Energy Industry Identification System (EIIS) codes are identified in the text as [XX) l D.
SAFETY ANALYSIS (Continued) 4.
1(2) MOV-SI8811A fB01 and 1(2) MOV-SI8811B fB01 These valves are the Recirculation Sump to Residual Heat Removal Pum) Suction Isolation Valves and are located in penetrations P-123 and P-124.
T1ese penetrations are classified in UFSAR Table 6.2-4 as Class 7.
UFSAR Section 6.2.4.2.1.7 states Class 7 penetrations as: " lines which are required for post accident service have power-operated valves which are either normally open and must remain open during an accident or are normally closed and must be opened should an accident occur.
For such lines. a minimum of one valve outside the containment is provided for containment isolation when the system is no longer required." Operability of these valves for containment isolation purposes involves the capabili,y of the valve to be stroked closed and give proper control room position indication.
These valves are normally closed valves that are only opened when aligning for cold leg recirculation. They are verified closed during refueling outages. These valves do not receive a containment isolation closure signal, but do have a containment isolation maximum stroke time. The procedures that test these valves that were identified by this event include: PT-2B-ST PT-2C-B-ST. PT-2C-D-ST. and PT-2C-F-ST.
Control room position indication testing is performed in PT-40-2V. A review of all the stroke time tests for these valves since 2/92 reveals that in all cases the IST closure stroke times were acceptable. Although these valves were not tested per i
these procedures prior to Mode 4. the valves were positioned in their closed position and there is reasonable assurance that the valves were capable of performing their containment isolation functions, if required. In all cases, the valves were satisfactorily tested r>rior to Mode 1.
l ZLER\\97002.ler(7)
LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACILITY MME DOCKET NUMBER LER NUMBER PAGE YEAR
~
SEO.
REV.
l ZION NUCLEAR POWER STATION UNIT 1 0l5l0l0l0l2l9l5 9l7 0l0l2 0l0 0l8 0F 1l8 TEXT Energy Industry Identification System (Ells) codes are identified in the text as [XX) l D.
SAFETY ANALYSIS (Continued) 5.
1(2) MOV-RH8701 fB01 i
This valve is the Safety Injection (SI) Hot Leg Injection isolation valve and is l
a containment isolation valve (CIV) located in penetration P-17. This penetration is classified in UFSAR Table 6.2-4 as Class 5.
UFSAR Section 6.2.4.2.1.5 states Class 5 penetrations as: " lines which Jenetrate the Containment and can be opened to containment atmosphere. ]ut which are normally closed during reactor operation, are provided with two isolation valves in series either inside or outside the containment.
In certain cases a blind flange or closed system outside the Containment is utilized as the second barrier in lieu of an isolation valve." This valve is also designated as a SVAG valve.
It is positioned in its Emergency Core Cooling System (ECCS) position (closed) and de-energized during normal power operations.
Operability of this valve for containment isolation purposes involves the capability of the valve to be stroked closed and give proper control room position indication.
This valve does not receive a containment isolation closure signal and does not have a containment isolation required maximum stroke time.
The procedures that test this valve that were identified by this event include: PT-2B-ST PT-2C-B-ST PT-2C-D-ST, and PT-2C-F-ST. Control room position indication testing is performed in PT-40-2C. Although th1s valve was not tested per these procedures prior to Mode 4. the valve was positioned in its closed position and there is reasonable assurance that the valve was capable of performing its containment isolation -
functions, if required. In all cases, the valves were satisfactorily tested prior to Mode 1.
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ZLER\\97002.ler(B)
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LICENSEE EVENT REPORT (LER) TEXT CONTINUATION l
FACILITY MME DOCKET NUMBER LER NUMBER PAGE YEAR SEO.
REV.
ZION NUCLEAR POWER STATION UNIT 1 0l5l0l0l0l2l9l5 9l7 0l0l2 0l0 0l9 1l8
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0F TEXT Energy Industry Identification System (Ells) codes are identified in the text as [XX]
D.
SAFETY ANALYSIS (Continued) 6.
1(2) MOV-RH9000 fB01 This valve is the Residual Heat Removal (RHR) to RCS Hot Legs isolation valve and is a containment isolation valve (CIV) located in penetration P-22. This penetration is classified in UFSAR Table 6.2-4 as Class 7.
UFSAR Section 6.2.4.2.1.7 states Class 7 penetrations as: " lines which are required for post accident service have power-operated valves which are either normally open and must remain open during an accident or are normally closed and must be opened should an accident occur.
For such lines, a minimum of one valve outside the containment is provided for containment isolation when the system is no longer required." This valve is also designated as a SVAG valve.
It is positioned in its Emergency Core Cooling System (ECCS) position (closed) and de-energized during normal power operations. Operability of this valve for containment isolation purposes involves the capability of the valve to be stroked closed and give proper control room position indication.
This valve does not receive a containment isolation closure signal and does not have a containment isolation required maximum stroke time.
The procedures that test this valve that were identified by this event include: PT-2B-ST, PT-2C-B-ST, PT-2C-D-ST, and PT-2C-F-ST. Control room position indication testing is performed in PT-40-2C.
Although this valve was not tested per these procedures prior to Mode 4, the valve was positioned in its closed position and there is reasonable assurance that the valve was capable of performing its containment isolation functions, if required. In all cases, the valves were satisfactorily tested prior to Mode 1.
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I ZLER\\97002.ler(9)
l LICENSEE EVENT REPORT (LER) TEXT CONTINUATION L
r l
FACILITY EME DOCKET NUMBER LER NUMBER PAGE YEAR SEO.
REV.
ZION NUCLEAR POWER STATION UNIT 1
(
0lSl0l0l0l2l9l5 9l7 0l0l2 0l0 1l0 1l8
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0F l'
TEXT Energy Industry Identificatton System (E!!S) codes are identified in the text as (XX) l D.
SAFETY ANALYSIS (Continued) l t
7.
1(2) MOV-CS0049 and 1(2) MOV-CS0050 fB01 j
These valves are the Residual Heat Removal Supply to Spray Header Stop Valves and are located in penetrations P-31 and P-39. These penetrations are classified in UFSAR Table 6.2-4 as Class 7.
UFSAR Section 6.2.4.2.1.7 states i
Class 7 penetrations as: " lines which are -required for post accident service L
have power-operated valves which are either normally open and must remain open j
l during an accident or are normally closed and must be opened should an accident occur.
For such lines, a minimum of one valve outside the containment-is provided for containment isolation when the system is no longer recuired."
These valves are both normally closed valves that are only opened curing the containment recirculation phase following a Loss of Coolant Accident (LOCA) to i
l allow recirculation spray flow to the containment from the Residual Heat Removal System. Operability of these valves for containment isolation purposes involves l
the capability of the valves to be stroked closed and give proper control room i
l position indication.- They are verified closed during refueling outages.and are 1
left closed. These valves do not receive a containment isolation closure signal, i
l but do have a containment isolation maximum stroke time limit. The procedures that test these valves that were identified by this event include: PT-28-ST. PT-2C-B-ST, PT-2C-D-ST, and PT-2C-F-ST.
Control room >osition indication testing is performed in PT-40-2C. A review of all the stroce time tests for these valves since 2/92 reveals that in all cases the IST closure stroke times were i
j acceptable. Although these valves were not tested per these procedures prior to j
l Mode 4, the valves were positioned'in their closed position and there is-l reasonable assurance that the valves were capable of performing their containment isolation functions, if required. In all cases, the valves were satisfactorily tested prior to Mode 1.
l l
l l
i L
ZLER\\97002.1?. mi f i
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LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACILITY NAME DOCKET NUMBER LER NUMBER PAGE YUR SEO.
REV.
ZION NUCLEAR POWER STATION UNIT 1 0l5l0l0l0l2l9l5 9l7 0l0l2 0l0 1l1 1l8
~
0F TEXT Energy Industry Identification System (EIIS) codes are identified in the text as [XX)
D.
SAFETY ANALYSIS (Continued) 8.
1(2) MOV-t50002fB01. 1(2) MOV-CS0004fB01. and 1(2) MOV-CS0006fB01 These valves are the Containment Spray Pump Discharge Stop Valves and are located in Jenetrations P-31. P-38, and P-39.
These penetrations are classified in UFSAR Ta]le 6.2-4 as Class 7.
UFSAR Section 6.2.4.2.1.7 states Class 7 penetrations as: " lines which are required for post accident service have power-operated valves which are either normally open and must remain open during an accident or are normally closed and must be opened should an accident occur.
For such lines, a minimum of one valve outside the containment is provided for containment isolation when the system is no longer required." Operability of these valves for containment isolation purposes involves the capability of the valves to be stroked closed and give proper control room position indication.
These valves are normally closed valves that are only opened on a Containment Spray Actuation signal to provide flow from the pumps to the spray rings.
These valves do not receive a containment isolation closure signal and do not have a containment isolation recuired maximum stroke time. The procedures that tests these valves that were icentified by this event are: PT-6A-ST, PT-6B-ST, and PT-6C-ST.
Control room position indication testing is performed in PT-40-6.
Although these valves were not tested per these procedures prior to Mode 4, the valves were positioned in their closed position (in PT-10-2) and there is reasonable assurance that the valves were capable of performing their containment isolation functions if required. In all cases, the valves were satisfactorily tested prior to Mode 1.
i l
l ZLER\\97002.ler(11)
LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACILITY NAME DOCKET NUMBER LER NUMBER PAGE YEAR SEO.
REV.
ZION NUCLEAR POWER STATION UNIT 1 olslololol2l9l5 9l7 0l0l2 0l0 1l2 1l8
~
~
0F TEXT Energy Industry Identification System (Ells) codes are identified in the text as [XX]
D.
SAFETY ANALYSIS (Continued) 9.
1(2) MOV-FW0050fJBl. 1(2) MOV-FW0051fJBl. 1(2) MOV-FW0052fJBl. 1(2) MOV-FWOO3fJBl. 1(2) MOV-FW0054fJBl. 1(2) MOV-FW0055fdBl. 1(2) MOV-FW0056fJBl. 1(2)
MOV-FW0057fJB1 These valves are the Steam Generator (S/G) Auxiliary Feedwater (AFW) isolation valves and are located in penetrations P-13. P-68. P-69 and P-74.
These penetrations are classified in UFSAR Table 6.2-4 as Class 7.
UFSAR Section 6.2.4.2.1.7 states Class 7 penetrations as: " lines which are required for post accident service have power-operated valves which are either normally open and must remain open during an accident or are normally closed and must be opened should an accident occur.
For such lines, a minimum of one valve outside the containment is provided for containment isolation when the system is no longer required." Operability of these valves for containment isolation purposes involves the capability of the valves to be stroked closed and give proper control room position indication.
These valves are normally maintained in a throttled position.
These valves do not receive a containment isolation closure signal and do not have a containment isolation required maximum stroke time. The procedures that tests these valves that were identified by this event are: PT-7A-ST PT-781-ST. and PT-782-ST.
Control room position indication testing is performed in PT-40-7.
Although these valves were not tested per these procedures prior to Mode 4. there is reasonable assurance that the valves were capable of performing their containment isolation functions, if required. In all cases, the valves were satisfactorily tested prior to Mode 1.
l 2LER\\97002.ler(12)
LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACILITY NAME DOCKET NUMBER LER NUMBER PAGE YEAR SEO.
REV.
ZION NUCLEAR POWER STATION UNIT 1
.0l5l0l0l0l2l9l5 9l7 0l0l2 0l0 1l3 0F 1l8
~
TEXT Energy Industry Identification System (Ells) codes are !dentified in the text as (XX)
D.
SAFETY ANALYSIS (Continued) 10.
1(2) MOV-VC8105fCBl and 1(2) MOV-VC8106fCBl These valves are the Charging Header Isolation Valves and are located in penetration P-75. This penetration is classified in UFSAR Table 6.2-4 as Class 3B.
UFSAR Section 6.2.4.2.1.3 states Class 3B penetrations as: " incoming lines connected to closed systems outside the containment which are not missile protected or which can otherwise communicate with the containment atmosphere, are provided, at a minimum, with one check valve or normally closed isolation valve located either inside or outside the containment.
The closed piping system outside the containment provides the necessary isolation redundancy.
Most lines in this category are provided with additional isolation valves which satisfy particular systems or ESF requirements.
Seal water injection is provided for certain lines in this category." Operability of these valves includes free movement of the valve stem, response to an automatic actuation signal, manual control switch actuation, full open and close stroke capability.
leakage rate testing. control room position indication, and stroke time testing. These valves do receive a containment isolation closure signal and do have a maximum containment isolation closure stroke time.
The procedure that tests these valves that was identified by this event is PT-20-ST.
In this procedure these valves are stroke time tested in the closed direction.
Control room position indication testing is performed in PT-40A-20. A review of all the stroke time tests for these valves since 3/92 reveals that in all cases the IST closure stroke times were acceptable.
Therefore, although the stroke time and position indication testing of these valves was not performed prior to Mode 4.
there is reasonable assurance that the valves were, in fact, in an OPERABLE condition when entering Mode 4. In all cases, the valves were satisfactorily tested prior to Mode 1.
ZLER\\97002.ler(13)
[
LICENSEE : VENT REPORT (LER) TEXT CONTINUATION FACILITY NAME DOCKET NUMBER LER NUMBER PAGE YEAR SEO.
REV.
ZION NUCLEAR POWER STATION UNIT 1 0l5l0l0l0l2l9l5 9l7 0l0l2 0l0 1l4 1l8
~
~
0F TEXT Energy Industry Identification System (Ells) codes are ident1 fled in the text as [XX)
D.
SAFETY ANALYSIS (Continued) 11.
1(2) A0V-VC8152fCBl and 1(2) A0V-VC8153fCBl These valves are the Letdown Containment Isolation Valves and are located in penetration P-72.
This penetration is classified in UFSAR Table 6.2-4 as Class 1.
UFSAR Section 6.2.4.2.1.1 states Class 1 penetrations as: "normally operating outgoing lines connecting to the Reactor Coolant System (RCS) are provided with at least two automatic trip valves in series located outside the Containment.
Automatic seal water injection is provided for lines in this classification." Operability of these valves includes free movement of the valve stem, response to an automatic actuation signal manual control switch actuation, full open and close stroke capability, leakage rate testing, control room position indication. and stroke time testing. These valves do receive a containment isolation closure signal and do have a maximum containment isolation closure stroFe time.
The procedure that tests these valves that was identified by this event is PT-20-ST.
In this procedure these valves are stroke time tested in the closed direction.
Control room position indication testing is performed in PT-40A-20.
A review of all the stroke time tests for these valves since 3/92 reveals that in all cases the IST closure stroke times were acce) table.
Therefore, although the stroke time and position indication testing of t1ese valves was not performed prior to Mode 4. there is reasonable assurance that the valves were, in fact, in an OPERABLE condition when entering Mode 4. In all cases, the valves were satisfactorily tested prior to Mode 1.
12.
1(2) MOV-SI8803 afb 01 and 1(2) MOV-SI8803BfB01 These valves are the High Header Safety Injection (VC) stop valves and are containment isolation valves (CIV) located in penetrations P-4. This penetration is classified in UFSAR Table 6.2-4 as Class 7.
UFSAR Section 6.2.4.2.1.7 states Class 7 penetrations as: " lines which are required for post accident service have power-operated valves which are either normally open and must remain open
..during an accident or are normally closed and must be opened should an accident occur.
For such lines, a minimum of one valve outside the containment is provided for containment isolation when the system is no longer required."
Operability of these valves for containment isolation purposes involves the capability of the valve to be stroked closed and give proper control ropm position indication.
These valves do not receive a containment isolation i
closure signal and do not have a containment isolation required maximum stroke time. The procedure that tests these valves that was identified by this event is PT-20-ST.
Control room position indication testing is performed in PT-40A-
- 20. Although these valves were not tested per these procedures prior to Mode 4 there is reasonable assurance that the valves were capable of performing their containment isolation functions. if required. In all cases, the valves were satisfactorily tested prior to Mode 1.
l ZLER\\97002.ler(14)
LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACILITY MAME DOCKET NUMBER LER NUMBER PAGE YEAR SEO.
REV.
ZION NUCLEAR POWER STATION UNIT 1 0l5l0l0l0l2l9l5 9l7 0l0l2 0l0 1l5 1l8
~
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0F TEXT Energy Industry Identification System (Ells) codes are identified in the text as {XX]
D.
SAFETY ANALYSIS (Continued) l 13.
1(2) A0V-SI8870 afb 01 This valve is the High Head Safety Injection (VC) Header leak-off valve and is a containment isolation valve (CIV) located in penetrations P-4. This penetration is classified in UFSAR Table 6.2-4 as Class 7.
UFSAR Section 6.2.4.2.1.7 states Class 7 penetrations as: " lines which are required for post accident service have power-operated valves which are either normally open and must remain open during an accider.t or are normally closed and must be opened should an accident occur.
For such lines, a minimum of one valve outside the containment is provided for containment isolation when the system is no longer required."
Operability of this valve' for containment isolation purposes involves the capability of the valve to be stroked closed and give proper control room position indication.
This valve does receive a safety injection closure signal and does have a maximum containment isolation closure stroke time.
The procedure that tests this valve that was identified by this event is PT-20 ST.
In this procedure this valve is stroke time tested in the closed direction.
Control room position indication testing is performed in PT-40A-20. A review of all the stroke time tests for this valve since 2/93 reveals that in all cases the IST closure stroke times were acceptable. Therefore, although the stroke time and Josition indication testing of the valve was not Mode 4. t1ere is reasonable assurance that the valve was, performed prior to in fact in an OPERABLE condition when entering Mode 4. In all cases, the valves were satisfactorily tested prior to Mode 1.
l l
4 ZLER\\97002.ler(15)
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LICENSEE EVENT REPORT (LER) TEXT CONTINUATION 4
FACILITY NAME DOCKET NUMBER LER NUMBER PAGE l
l YEAR SEO.
REV.
[
l ZION NUCLEAR POWER STATION UNIT 1 f
0l5l0l0l0l2l9l5 9l7 0l0l2 0l0 1l6 1l8
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0F TEXT Energy Industry Identification System (EIIS) codes are identified in the text as (XX) 4 D.
SAFETY ANALYSIS (Continued) j 14.
1(2) MOV-MS0017fSBl. 1(2) MOV-MS0018FSBl. 1(2) MOV-MS0019fSBl. and 1(2) MOV-MS0020fSBl These valves are the Steam Generator Atmospheric Relief Valves and are located in penetrations P-5. P-6 P-7 and P-8.
These penetrations are classified in UFSAR Table 6.2-4 as Class 4.
UFSAR Section 6.2.4.2.1.4 states Class 4 penetrations as: " incoming and outgoing lines which penetrate the Containment are connected to closed systems inside the Containment, are protected from missiles throughout their length and are provided with at least one manual isolation valve located outside the Containment. The closed piping system l
inside the Containment provides the necessary isolation redundancy. Seal water injection is not used for this class of penetration." The closed loop is comprised of the steam line from the penetration inside containment up to and including the steam filled portion of the secondary side of the steam generator.
These valves are both normally closed valves that-are only opened when testing or during normal plant cooldown. They are verified closed during refueling outages and are left closed. Operability of these valves for containment isolation purposes involves the capability of the valve to be stroked closed and give proper control room position indication.
These valves do not receive a containment isolation closure signal and do not have a containment isolation i
required maximum stroke time. The procedure that tests these valves that-was identified by this event is PT-20-ST. Control room position iridication testing is performed in PT-40-27G. Although these valves were not tested per this procedure prior to Mode 4, there is reasonable assurance that the valves were capable of performing their containment isolation function to close, if i
required. In all cases, the valves were satisfactorily tested prior to Mode 1.
ZLER\\97002.ler(16)
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)
LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACILITY MME.
DOCKET NUMBER LER NUMBER PAGE j
YEAR SEO.
REV.
ZION NUCLEAR POWER STATION UNIT 1 0l5l0l0l0l2l9l5 9l7 0l0l2 0l0 1l7 1l8 0F TEXT Energy Industry Identification System (Ells) codes are identified in the text as (XX)
D.
SAFETY ANALYSIS (Continued) 15.
1(2) MOV-MS0005fSBl. 1(2) MOV-MS006fSBl. 1(2) MOV-MS0011fSBl j
These valves are the Auxiliary Feedwater Pump Steam Supply Stop valves and are located in penetrations P-104. P-127. and P-128. These penetrations are classified in UFSAR Table 6.2-4 as Class 7.
UFSAR Section 6.2.4.2.1.7 states Class 7 penetrations as:
lines which are required for post accident service have power-operated valves which are either normally open and must remain open during an accident or are normally closed:and must be opened should an accident occur.
For such lines, a minimum of one valve outside the containment is provided for containment isolation when the system is no longer required."
Operability of these valves for containment isolation purposes involves the capability of the valves to be stroked closed and give proper control room i
i position indication.
These valves do not receive a containment isolation closure signal and do not have a containment isolation required maximum stroke i
time. The procedure that tests these valves that were identified by this event is PT-7A-ST.
Control room position indication testing is performed in PT-40-7.
Although these valves were not tested per these procedures prior to Mode 4 I
there is reasonable assurance that the valves were capable of performing their containment isolation functions, if required. In all cases, the valves were satisfactorily tested prior to Mode 1.
1 E.
CORRECTIVE ACTIONS
1.
Unit 2 containment isolation valves will be verified tested prior to Unit 2 entering Mode 4 from Z2R14.
(29518097025701) 2.
The Operations Procedures Group will modify associated procedures or create new procedures to ensure that containment isolation valves are tested prior to entering the required mode of applicability.
(29518097025702) 3.
- - Zion Station IST Group is continuing a review of the IST program to ensure all requirements are met.
This review is expected to be completed by March 31.
1997.
(29518097025703) i I
4.
Zion Station wi'll modify the Technical Specification Amendment implementation process to include required independent verification.
(29518097025704) i
).
i I
i ZLER\\97002.ler(17)
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l LICENSEE EVENT. REPORT (LER) TEXT CONTINUATION 3
I FACILITY MME DOCKET NUMBER LER NUMBER PAGE YEAR
- SEO, REV.
ZION NUCLEAR POWER STATION UNIT 1 0lSl0l0l0l2l9l5 9l7 0l0l2 0l0 1l8 1l8
~
~
0F TEXT
. Energy Industry Identification System (EIIS) codes are identified in the text as (XX]
I PREVIOUS EVENTS SEARCH'AND ANALYSIS i
.F.
In addition to this Licensee Event Report (LER), the Station has experienced non-
. compliance with Technical Specifications due to poorly implemented Technical i
Specifications on 6 previous occasions.
Zion Station Unit 1 LERs95-002. 95-003. 95..
005,95-007. 97-003 and Unit 2 LER 96-011 have causes involving weaknesses in document-
' review and document preparation practices of individuals. The corrective action to i
implement additional appropriate corrective actions after examining the Technical i
Specification Amendment implementation process. with particular emphasis on document review and preparation practices, is expected to address the common cause of these j
events.
i
^
- - G.
COMPONENT FAILURE DATA-l None.
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1 ZLER\\97002.ler(l'f)