05200025/LER-2022-003, Unborated Water Flowpath Not Secured Per Technical Specification 3.9.2 Due to Inadequate Procedure Change
| ML22353A609 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/19/2022 |
| From: | Martino P Southern Nuclear Operating Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| ND-22-0930 LER 2022-003-00 | |
| Download: ML22353A609 (1) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 0252022003R00 - NRC Website | |
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,~ Southern Nuclear December 19, 2022 Patrick Martino Site Vice President, Vogtle Unit 3 7825 River Road Waynesboro, Georgia 30830 706 848 6602 tel ND-22-0930 10 CFR 50.73(a)(2)(i)(B)
Docket No.:
52-025 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant (VEGP) - Unit 3 Licensee Event Report 2022-003-00 Unborated Water Flowpath not Secured per Technical Specification 3.9.2 Due to Inadequate Procedure Change Ladies and Gentlemen:
In accordance with the requirements of 10 CFR 50.73(a)(2)(i)(B), Southern Nuclear Operating Company is submitting the enclosed Licensee Event Report for VEGP Unit 3.
This letter contains no regulatory commitments. If you have questions regarding the enclosed information, please contact Will Garrett at (706) 848-7154.
Respectfully submitted, Site Vice President, Unit 3 PAM/KMS/sfr
Enclosure:
Unit 3 Licensee Event Report 2022-003-00 CC:
Regional Administrator, Region II VPO Project Manager Senior Resident Inspector - Vogtle 3 & 4 Director, Environmental Protection Division - State of Georgia
Vogtle Electric Generating Plant - Unit 3 Licensee Event Report 2022-003-00 Unborated Water Flowpath not Secured per Technical Specification 3.9.2 Due to Inadequate Procedure Change Enclosure Unit 3 Licensee Event Report 2022-003-00
Abstract
On October 24, 2022, Vogtle Unit 3 identified that Surveillance Requirement (SR) 3.9.2.1 to "Verify one valve in each unborated water source flow path is secured in the closed position," was not met, placing the unit in Technical Specification Limiting Condition for Operation (LCO) 3.9.2 Condition A. The Demineralized Water Supply Containment Isolation valve 3-DWS-V244 was open, having previously been removed from procedure 3-RCS-OTS-20-001, "Unborated Water Source Checklist," without adding adequate requirements for alternate isolation valves in the Chemical and Volume Control system. LCO Required Action A.1, to initiate actions to secure one valve in the flow path in the closed position, was performed immediately and Required Action A.2 was performed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The apparent cause of this event was that the procedure to perform SR 3.9.2.1 (3-RCS-OTS-20-001) was inadequate in ensuring unborated water sources were properly isolated. The immediate corrective action was to close and secure the valve in the flow path. Procedure 3-RCS-OTS-20-001 was revised to add the missing unborated water isolation valves. This event is reportable under 10 CFR 50.73(a)(2)(i)(B) as an operation or condition prohibited by the plant's Technical Specifications. VEGP Units 1, 2, and 4 were unaffected during this event.
EVENT DESCRIPTION
On October 24, 2022, at 0815 EDT with the Vogtle Electric Generating Plant (VEGP) Unit 3 at 0% power, in Mode 6 after completion of the initial fuel load, Surveillance Requirement (SR) 3.9.2.1 verifying that one valve in each unborated water source flow path is secured in the closed position was not met. Specifically, 3-DWS-V244 Demineralized Water Supply Containment Isolation valve [EIIS: KJ / ISV] was in the open position, resulting in an unborated water source flow path without one valve verified secured in the closed position. LCO Required Action A.1, to initiate actions to secure one valve in the flow path in the closed position, was performed immediately, and Required Action A.2, verify boron concentration is within the limit specified in the COLR, was performed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. This event is reportable under 10 CFR 50.73(a)(2)(i)(B) as operation or condition prohibited by the plant's Technical Specifications (TS). The condition prohibited by the TS began when the unit entered Mode 6 on October 13, 2022, at 2354 hours0.0272 days <br />0.654 hours <br />0.00389 weeks <br />8.95697e-4 months <br /> and exited on October 25, 2022, at 1411 hours0.0163 days <br />0.392 hours <br />0.00233 weeks <br />5.368855e-4 months <br />.
EVENT ANALYSIS
The cause of this event is inadequate procedure 3-RCS-OTS-20-001, "Unborated Water Source Checklist," which is the unborated water sources surveillance procedure required to be performed in accordance with SR 3.9.2.1 to verify proper isolation of each unborated water source flow path. Specifically, the dilution flow path was no longer accounted for due to a previous change to procedure 3-RCS-OTS-20-001.
REPORTABILITY AND SAFETY ASSESSMENT
There were no safety consequences due to this event because the boron concentration requirements of TS 3.9.1, "Boron Concentration," were met. No radiological release occurred due to this event. This event is reportable under 10 CFR 50.73(a)(2)(i)(B) as an operation or condition prohibited by the plant's Technical Specifications.
CORRECTIVE ACTIONS COMPLETED Procedure 3-RCS-OTS-20-001, "Unborated Water Source Checklist", was revised to add additional unborated water isolations.
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