05000483/LER-1990-006

LER 90-006-00:on 900603,determined That Tech Spec Action Statement Not Entered for Inoperable Remote Manual Containment Isolation Valves.Caused by Incorrect Tech Spec Interpretation.Interpretation Revised & viewed.W/900628 Ltr

ML20055D071
Person / Time
Site:	Callaway
Issue date:	06/28/1990
From:	Blosser J, Sharkey T UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-90-006, LER-90-6, ULNRC-2238, NUDOCS 9007030178
Download: ML20055D071 (5)

LER-2090-006,

Event date:
Report date:
4832090006R00 - NRC Website

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DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 FACILITY OPERATING LICENSE NPF-30 LICENSEE EVENT REPORT 90-006-00 i TECHNICAL SPECIFICATION ACTION STATEMENT NOT ENTERED j FOR INOPERABLE REMOTE MANUAL CONTAINMENT ISOLATION VALVES DUE TO HUMAN PERFORMANCE c The enclosed Licensee Event Report is submitted purrua

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'10 CFR 50.73(a)(2)(1)(B) concerning operation of the Cal;- , /lant with  !

A a condition prohibited by the plant's Technical Speciff .. ion. The condition resulted from the failure to enter the action statement for  ?

p.~ the Essential Service Water to Containment Cooler remote manual -

isolation valves when they were tagged in their open position and j rendered inoperable. This was due to a human performance error. j l

-3 h J. D..Blosser Manager, Callaway Plant i

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On 6-3-90, the Esstatial Service Water (ESW) to containment cooler isolation valves were tagged with Worker Protection Assurance in their safety injection signal (SIS) posit.fon, open. These valves are remote manual valves as listed in Technical Specification (T/S) 3.6.3 Table 3.6-1. The plant's Technical Specification Interpretation (TSI) written for T/S 3.6.3 states: "Those i valves which are listed as remote manual in Table ?.6-1 do not receive a containment isolation signal. Therefore, simply noving power f rom these valves does not in and of itself make the valven inoperable from a containment isolution standpoint." Utility licensed Scheduling and Operations personnel applied this TSI to mean that the T/S 3.6.3 Action Statement did not need to be entered for the work performed on the valves.

Subsequent evaluation verified that the valves should have been concidered manual containment isolation valves, requiring the valves to be closed per T/S 3.6.1.1. T/S 3.6.3 and T/S 3.6.1.1 were violated as their Action Statements were never entered. The plant was in Mode 1 - Power Operations at 100 percent Reactor Power at the time ef the event.

The root cause of this event was the TSI for T/S 3.6.3 remote manual valves was incorrect.

The TSI will be revised to clarify the effect of removing power to remote manual valves. The revised TS1 and the r at will be reviewed with Scheduling and Operations personne!, the s.i-Site Review Committee (ORC) and the alternate ORC members.

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UCENSIE EVENT REPORT (LER) TEXT CCNTINUATION A** eno oMe wo. 3ino-om EXPihts t'st's 6 ACatity hAMt up (Kacket NUMD4R dal Lit =UM6thISI PAGt (36

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3 10 0 12 0F 0 l3 ttri e n-. a. w eac s.m JNAU HD Description of Event At1316CSTon6-3-90,theEgggntialServiceWater(ESW)(}supplytg3) containment cooler 'B' train outside containment isolation valve, ETHV0032, and the containment cooler 'B' train outside containment return valve, EFHV0050> were tagged with Worker Protection Assurance in their safety injection siguct (SIS) position, open. These valves are remote ranual valves as listed in Technical Specification (T/S) 3.6.3 Table 3.6-1. The plant's Technical Specification Interpretation (TSI) written for T/S 3.6.3 states:

"Those valves which are listed as remote manual in Table 3.6-1 do not receive a containment isolation signal. Therefore, simply removing power from these valves does not in and of itself make the valves inoperable from a containment isolation standpoint." Utility licensed Scheduling personnel applied this TSI to mean that the T/S 3.6.3 Action Statement did not need to be entered for the work performed on the valves. The work included removing power from the valves, rewiring the limit switches, cleaning and inspecting of the Ifmitorque operators, and the installation of breaker trip setpoints.

Due to Scheduling personnels' application of the TS1, the valves were not declared inoperable and were not entered in the Equipment Out of Service log by the Control Room operators when the work package was approved and commenced, on 6-5-90 at 1645, the Shift Technical Advisor discovered the condition  ;

during a review of the completed work package in preparation for the valve '

retests. The remote manual valves were isolated and the T/S 3.6.2.3 Action Statement was entered for the 'B' train containment cooling system.

Basis for Reportability T/S 3.6.3 requires that the containment isolation valves specified in Tabic 3.6-) be OPERABLE with isolation times as shown in Table 3.6-1. Per T/S Table 3.6-1, tbs ESW to Containment Cooler isolation valves have an active safety function to close by remote manual operation. Due to the work that was performed on the valves and the tagging involved, remote operation was not possibic. Subsequent evaluation verified that the valves should have been considered manuni containment isolation valves, requiring the valves to ,

be closed per T/S 3.6.1.1. T/S 3.6.3 and T/S 3.6.1.1 were violated as their '

Action Statements were never entered. The plant was in Mode 1 - Power

. Operations at 100 percent Reactor Power at the time of the event.

This Licensee Event Report is submitted pursuant to 10CFR50.73(a)(2)(1)(B) to y l report a condition prohibited by the plant's T/S.

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0] O 0l 3 OF 0l3 Root Caune The TSI for T/S 3.6.3 remote manual valves was incorrect. The TS1 did not ,

require the remote manual valves to be in their isolation position with power removed. The TSI let! utility licensed Scheduling and Operations personnel to believe that tngging the valves open, in their SIS position, did not make -

them inoperable from a containment isolation standpoint.

Corrective Actionn i The TSI will be revised to clarify the effect of removing power to remote manual valves.

The revised TSI and the event will be reviewed with Scheduling and Operations personnel, the On-Site Review Committee (ORC) members and the alternate ORC members.

Safety Slgnificance The associated inside containment isolation valves were OPERABLE at all times. The maximum containment pressure expected d ring a design basis accident is 48.1 psig for a Nain Steam Line Break. ESW system pressure inside containment rangen from approximately 33 to 110 psig, therefore, no release from containment would occur through this release path if the inside reactor containment isolaticn valve were the active failure unless a major rupture of the Class III ESW system occurred. This possibility is assumed and recognized in the FSAR Figure 6.2.4-1 and in the Safety Evaluation Report 6.2.3 in reference to isolation being provided by the same power source. For most plant conditions, an equipment operator could have been directed to shut the outside containment isolation valves locally by manual operation. The valves are located in an auxiliary building penetration room. This event posed no threat to the health or safety of the public.

Previous occurrences None.

't Footnotes The system and component codes below are from IEEE Standards 805 and 803A, respectively.

1) System - BI

2) System - BK

3) System - JM, Component - VLV C P;aW 3664 .p.s. GPCs 19,8-520-if9c00010