ML20043F494

LER 90-011-00:on 900504,Pressure Instrument Root Isolation Valve 1SI-8961 Open When Procedure Indicated Valve Should Be Locked Closed.Caused by Lack of Clear Instructions Re Definition of Physical Work. Valve locked.W/900604 Ltr

ML20043F494
Person / Time
Site:	Comanche Peak
Issue date:	06/04/1990
From:	William Cahill, Hood D TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-90-011, LER-90-11, TXX-90183, NUDOCS 9006150064
Download: ML20043F494 (7)

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Log # TXX-90183

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- C 906.2 C C Ref. # 50.73 (a)(2)(1) 1UELECTRIC June 4, 1990 Entsutove Vice Preudent VOS illuc166F "ulitMy Caseilision utAtta: LBocamat trol-Deski

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SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION DOCKET NO. 50-445 CONTAINMENT ISOLATION ROOT VALVE LEFT IN INCORRECT POSITION LICENSEE EVENT REPORT 90 011-00 Gentlemen:

Enclosed is Licensee Event Report 90-011-00 for Comanche Peak Steam Electric Station Unit 1, " Containment Isolation Root Valve left in Incorrect Position as a Result of Procedural Deficiency."

Sincerely,

[ .1 William J. Cahill, Jr.

JRW/daj Enclosure c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) 9006150064 900604 PDR ADOCK 05000445 s PDC

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M North Ohve Street LB 81 Dallas. Texas 75201 ljl g

Enclosure to TXXo90183 N84C FORM 386 U.S. NUCLE AW REOUL.ATO.Tl COMMIS&lON APPROVED OME NO,31640104 EXPIRES;4'3Wgt ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THS INFORMATON 00L11CTON REQUEST: 60.0 HRS. FORWARD COMMENTS REGARDING BURDEN EMIMATE TO THE RECORDS AND REPORTS MANAGEMENT LICENSEE EVENT REPORT (LER) ORANCH (P 630), U.8, NUCLE AR REGULATORY COMMIS$10N. WASHINGTON.

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FacHy Name (1) Docket Nurreser (2) Page (33 COMANCHE PEAK - UNIT 1 0l510l0l01414l5 1 I or 10i6  !

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On May 4,1990, during the monthly performance of the Containment Isolation Valve Position Verification, it was identified that a pressure instrument root Isolation valve,1S1-8961, was open when the procedure indicated it should be locked closed. Upon investigation, it was determined that a Design Change Notice (DCN) had been approved and issued to address an NRC concern regarding the position of valve 1SI-8961; however, the field work to change the position of the valve (from open to locked closed) had never been performe'd, Upon discovery of this condition, the valve was immediately shut. The valve had been open, in violation of Technical Specification 3.6.?, since March 12,1990 when Unit 1 had initially entered Mode 4.

i The cause of the event ha.; been determined to be a lack of clear instructions concerning Document Change Only E CNs and the definition of " physical work". A Document Change Only DCN should not result in ohysical changes to the plant (i.e., valve position change). Based on the intent of the Documer.t Change Only DCN process, no closure mechanism was established to ensure that physical ct anges to the plant (resulting from Document Change Only DCNs) were implemented. Several reviews were conducted which verified that this problem is very limited in scope, and the problem will be addressed by training and a revision to the Design Modification Process Procedure.

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Enclosure to TXX 90183 Nsc FORM 3004 U.S. NUCLEAR REQuLATOov COMM4SION APPR06 OMS M SNOW ESTIMATED SURDEN PER RE COMPLY W1TH TH$ INFORMATION LICENSEE EVENT REPORT (LER) fygg,",'M','; y*"l","*ffy,'", W,8,",'ff,'%

TEXT CONTINUATION 'f % i g 'f M ," @ ,7,c g ,'gcQ ","'o,7 f OFFCE OF MANAGEMENT AND BUDGET, WASHINGTON DC.20601 7 acery Name (t) Dcr*ar Number (2) LER Nurrter (6) Page(3) v=~ m *c w a ;m COMANCHE PEAK , UNIT 1 015l0l0101414I5 910 Ol1l1 -

Ol0 012 OF 0lB T.st (a more space e esqueso, use moditona NRG Form 366A e) (17)

1. DESCRIPTION OF WHAT OCCURRED ,

A. PLANT OPERATING CONDITIONS BEFORE THE EVENT j At approximately 0100 CST, on March 12,1990, Comanche Peak Steam Electric . l Station (CPSES) Unit 1 initially entered Mode 4, Hot Shutdown. Reactor Coolant System (Ells:(AB)) temperature and pressure were 200 degrees Fahrenheit and 380 pounds per square inch gage (PSIG), respectively.

B. REPORTABLE EVENT DESCRIPTIO.N.flNCLUDING _1ATES AND APPRQXIMATETIMES_OF_MAJOROCC.UBf1ElICES)

Event Classification: Any operation or condition r rohibited by the plant's l Technical Specifications.

Just prior to receipt of the Low Power Facility Operating License on February 8, 1990, the Nuclear Regulatory Commission (NRC) Project Manager for CPSES identified a concern regarding a Final Safety Analysis Report (FSAR) change submitted by CPSES as part of Amendment 66 on January 15,1988. The concern dealt with taking credit for the use of a pressure Indicator on the Safety injection System test line (Ells:(PI)(BP)) as a containment boundary rather than utilizing the pressure indicator's roo. Isolation valve (1 SI-8961) (Ells:(ISV)(BP)) as the containment boundary. In order to resolve the NRC concern, CPSES developed a draft FSAR change allizing valve 1S18961 as the containment boundary. The change was discursed with the NRC Project Manager and it was agreed that the change would bc incorporated in the first FSAR update following issuance of the Low Power Facility Operating License. In addition, CPSES stated that a design change would be implemented to comply with the requirements of 10CFR50, Appendix A, General Design Criteria (GDC) 55, by changing the root isolation valve's position from open to locked closed.

A Document Change Ply Design Change Notice (DCN) (i.e., a DCN which is not included in a Design Modification Package) to change the normal position of 1SI-8961 to locked closed on the station drawings and associated FSAR change request were approved on February 16,1990. The appropriate procedure change notices (PCN) were then initiated for the Operations procedures affected by the DCN.

A revision to the System Operating Procedure was approved and made effective on March 13,1990, and PCNs to the Containment Isolation Valve Position

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' . Enclosure to TXX-90183-NRC FOR;d setA U.S. NUCLEAA REGULATORY COMMn68CN sfPRO NO M04

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0IO OI3 OF 0I6 u.u,tr.r. - . - u NRcr Verification Forms and the Operations Locked Valve List Forms were approved and made effective on April 11,1990. However, on May 4,1990, at approximately 2300 CST, it was identified that although the DCN and procedure changes had been approved and made effective, the actual position of the valve had never been changed.

C. STATUS OF STRUCTURES. SYSTEMS. OR COMPONENTS THAT WERE INOPER ABLE AT THE START OF THE EVENT AND THAT CONTRIBUTED TO THE EVENT Not applicable - no structures, systems, or components were inoperable at the start of the event that have been determined to have contributed to the event.

D. CAUSE OF EACH COMPONENT OR SYSTEM FAILURE. IF KNOWN Not applicable - no component or system failures have been identified.

E. FAILURE MODE. MECH ANISM. AND EFFECT OF EACH FAILED COMPONENT Not applicable - no failed components have been identified.

F. FOR FAILURES OF COMPONENTS WITH MULTIPLE FUNCTIONS. LIST OF SYSTEMS OR SECONDARY FUNCTIONS THAT WERE ALSO AFFECTED Not applicable - no component failures have been identified.

G. FOR FAILURES THAT RENDERED A TRAIN OF A SAFETY SYSTEM lNOPERABLE. AN ESTIMATE OF THE ELAPSED TIME FROM THE DISCOVERY OF INOPERABILITY UNTIL THE TRAIN WAS RETURNED TO SERVICE Not applicable - no failures were involved.

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0IO OI4 OF 0l6 T.. i. -. - . - . una r ; a., ii 73 H. THE METHOD OF DISCOVERY OF EACH COMPONENT OR SYSTEM FAILURE OR PROCEDUR AL ERROR On May 4,1990, during the monthly performance of the Containment Isolation Valve Position Verification, it was identified that valve 1 SI 8961 was open when the procedure indicated that it should be locked closed.

1. CAUSE OF THE EVENT gg,gt Cause There was a lack of clear instructions concerning Document Change Only DCNs and the definition of " physical work". A Document Change Only DCN should not result in physical changes to the plant (i.e., valve position changed). Based on the intent of the Document Change Only DCN process, no closure mechanism was established to ensure that physical changes to the plant (resulting from Document Change Only.

DCNs) were implemented.

J. SAFETY SYSTEM RESPONSES THAT OCCURRED There were no manual cr automatic safety avstem responses as a result of this event.

K. FAILED COMPONENT INFORMATION There were no component failures associated with this event.

II. ASSESSMENT OF THE SAFETY CONSEQUENCES AND_ IMPLICATIONS OF THIS EVENT Each line that is part of the RCS pressure boundary and that penetrates primary reactor containment shall be provided with a containment isolation valve arrangement as specified by 10CFR50, Appendix A, GDC 55 unless it can be demonstrated that the containment isolation provisions for a specific class of lines (e.g., instrument lines) are acceptable on some other defined basis. In accordance with GDC 55, one of the acceptable provisions for containment penetration isolation is to have one automatic isolation valve inside and one locked closed valve outside containment.

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Enclosure to T!.X 90183 NRC FORW 306A U.S. NVCLE Alt REG.AATORY 00Mw2810N ,pp, M DOMSNaStE01W ESTMATED BURDEN PER RES E COMPLY wrTH THe DFORMATON LICENSEE EVENT REPORT (LER) "C'%,",',"$8';

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During the period that valve 1SI 8961 was open, CPSES met the requirement to have one automatic isolation valve (Ells:(ISV)(JM)) inside containment (which could close in response to an actuation signal), but did not have the locked closed valve outside containment. The isolation valve inside containment is normally closed and is designed to fall closed.

Although the root isolation valve,1SI 8961, located off of the Safety injection System Test Line, remained open from March 12,1990 to May 4,1990, the associated containment penetration (Ells:(PEN)(NH)) was effectively isolated during that period. The downstream pressure indicator sensing element is dead ended and hydrostatically tested to 3500 PSIG which exceeds the design pressure of the pipe (2735 PSIG). Additionally, the pressure indicator is seismically mounted and located in an area protected from the effects of high energy line breaks.

Based on the above discussion, the event did not adversely affect the safe operation of CPSES Unit 1 or the health and safety of the public.

Ill. CORRECTIVE ACTIONS A. IMMEDIATE CORRECTIVE ACTION Upon discovery of this condition, the containment isolation valve 1SI-8961 was immediately locked closed. in addition, several reviews were conducted which verified that this problem is very limited in scope. One review ensured that there were no additional actions required by CPSES for FSAR change requests which the NRC agreed could be incorporated in the first FSAR update following the issuance of the Low Power Facility Operating License. Sample reviews were conducted to determine whether any other Document Change Only DCNs had resulted in procedure changes and required implementation of a physical change to the plant to reflect the DCN (e.g., valve position changed). These reviews did not identify any additional examples where a physical change to the plant had not been implemented. Lastly, a review was completed to ensure that there were no Technical Specification Surveillance related PCNs that had been approved and ,

implemented without the actual plant change being made. Similarly, no concerns were identified as part of this review.

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Enti:sure to TXX-90183 N40 FORM 306A U.S. NUCLEAR heGuLATORY COMM""'""

APPROWD OMS W. 31Mes ESTIMATED SUWEN PER RE 00tPLY WITH TH18 INFORMATION LICENSEE EVENT REPORT (LER) ," y%11Ty;, % W , M 'f g 1

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Facasy Name (1) Doomst Nunmer (2) LER Nunter S) Peps (3)

Year .g COMANCHE PEAK - UNIT 1 0!51010l0141415 910 -l 011 11 -

010 018 OF 016 1..nn o -. .. NaC F- w.n a B. ACTIONS TO PREVENT RECURRENCE Root Cause There was a lack of clear Instructions conceming Document Change Only DCNs and the definition of " physical work". A Document Change Only DCN should not result in physical changes to the plant (i.e., valve position changed) Based on the intent of the Document Change Only DCN process, no closure mechanism was established to ensure that physical changes to the plant (resulting from Document Change Only DCNs) were implemented.

Corrective Action Additional guidance will be provided in the Design Modifcation Process Station Manual Procedure regarding the Document Change Only DCN process. Training will j be conducted for the appropriate engineering personnel emphasizing that Document Change Only DCNs cannot result in any physical change to the plant.

IV. PREVIOUS SIMILAR EVENTS There have been no previous similar events reported pursuant to 10CFR50.73. ,

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