05000382/LER-1997-001, :on 970129,RG 1.97 Containment Isolation Valve Does Not Have Direct Position Indication.Caused by Incorrect Judgement Was Made That EFW FCVs Had Adequate Position.Condition Rept 96-1658 Was Generated

:on 970129,RG 1.97 Containment Isolation Valve Does Not Have Direct Position Indication.Caused by Incorrect Judgement Was Made That EFW FCVs Had Adequate Position.Condition Rept 96-1658 Was Generated

ML20135C746
Person / Time
Site:	Waterford
Issue date:	02/27/1997
From:	Gaudet T, Leonard T ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-REGGD-01.097, RTR-REGGD-1.097 LER-97-001, LER-97-1, W3F1-97-0019, W3F1-97-19, NUDOCS 9703040259
Download: ML20135C746 (9)

LER-1997-001, on 970129,RG 1.97 Containment Isolation Valve Does Not Have Direct Position Indication.Caused by Incorrect Judgement Was Made That EFW FCVs Had Adequate Position.Condition Rept 96-1658 Was Generated

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(e)(2) 10 CFR 50.73(a)(2)
3821997001R00 - NRC Website

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2 W3F1-97-0019 A4.05 PR i

February 27,1997 U.S. Nuclear Regulatory Commesson Attn: Document Control Desk Washington, D.C. 20555 4

Subject Waterford 3 SES Docket No. 50-382 4

Licanse No. NPF-38 Reporting of Licensee Event Report

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Gentlemen:

Attached is Licensee Event Report Number LER-97-001-00 fer Waterford Steam Electric Station Unit 3. This Licensee Event Report is submitted in accordance with 10 CFR 50.73(a)(2)(i)(B).

Very truly yours, r

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T.R. Leonard General Manager I

Plant Operations Attachment 05M g2 g

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cc-E.W. Merschoff, NRC. Region IV C.P. Patel, NRC-NRR-A.L Garibaldi.

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.c-LaCEDISEE CONTACT FOR THIS LER (12)

Beansa Tsurnosa nunseen Ramuss a, cesse l

T.J. GAtBET, LICENSING MANAGER (504) 739-6666 i

3 CotrLETE 00E LBIE FOR EACH CORFOMNT FAE.URE DESCftMD NG THIS fle' ORT I13)

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SUPPtSENTAL llEPORT EXPECTED (14)

MONTH DAY YEAll EXPECTED YES SumABBICId NO Of yes, complete EXPECTED SUBMISSION DATE).

X DATE(1R As maiseACT (UrrNt to 1400 epaces,i.e., appronometely 15 eingfe-epooed typewntten linee) (1e Per Technical Specs istion (TS) 3.3.3.6, Category.1 containment isolation valves are required to have a mesmum of 1 channel of position indication available per valve (less than the minimum:

operable channels is allowed for a time period not to exceed 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />). Pursuant to the bases for-TS 3.3.3.6, this posstion indication will be consistent with the recommendations of Regulatory Guide (RG) 1.97. From June 11,1996, to June 14,1996, Emergency Feedwater (EFW) Flow Control Valve (FCV), EFW-224A (see Figure 1, attached), was relied upon for containment isolation for a penod of 62.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. The~ position indication for EFW-224A does not meet the requirements of Regulatory, Guide'(RG) 1.97 in that it does not have " direct" pcenien indication.

l Therefore, EFW-224A'should not have been credsted as a containment isolation valve (CIV).

• Licensing Document Change Request 97-0110, approved on January 9,1997, revised the Technical Requirements Manual and Final Safety Analysis Report to ensure the FCVs are no longer relied upon as CIVs. This event did not compromise the health and safety of the pubhc.

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~NRC' FORM SSSA U.u. NUCt. EAR REGULATORY COWASSION j

im LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACIUTY NAW (1)

DOCKET LER NUWER (6)

PAGE (3)

R t

05000 2 OF 8 l

idATERFORD STEAM FIFCTRIC STATION UNIT 3 382 97 001 00

~

~

l TEXT (11 rnore space is required. use additional copies of NRC Form 366A) (17) i REPORTABLE OCCURRENCE n

l Pursuant to Technical Specification (TS) Table 3.3-10, Accident Monitoring.

1 a

l Instrumentation (Ells Identifier-PI), contamment inalatirvi valves (CIV; Ells Identifier '

j l

ISV) govemed by TS 3.6.3, " Containment isolation Valves," shall have as a nunimum, I

one channel of operable possbon indicabon. TS 3.3.3.6, Action 30,' drects that with the i

number of operable diannels loss than required, either restore the inoperable' channel (s) to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in at least hot shutdown within the l

next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The bases for TS 3.3.3.6 states that this indication is consistent with the l

recommendabons of Regulatory Guide (RG) 1.97i(i.e., " direct" possbon mdecahon).

t, l

Contrary to that requirement, Emergency Feedwater (EFW; Ells Identfier - BA) Flow Control Valve (FCV; Ells identifier - FCV), EFW-224A (see Figure 1, attached), was -

l relied upon for containment (Ells Idenbfier - NH) isolation for greater than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> l

without having qualified position indication. ~ in accordance with 10CFR50.73(a)(2)(i)(B),

l this event is reportable as a condition prohibited by TS.

l' INITIAL CONDITIONS l

At the time this condition was idenbfied, Waterford 3 was operating in Mode 1 at j_

approximately 100 percent power. No major equipment was out of service specific to j

this event and no TS Umiting Conditions for Operabon (LCO) were in effect specific to -

this event.

i j

EVENT DESCRIPTION

The Waterford 3 Final Safety Analysis Report (FSAR) Table 6.2-32 originally indicated that the EFW FCV's were not requred to meet General Design Criteria (GDC) 55 e

j through 57. Licensing Document Change Request (LDCR) 95-0071, which was C

l' approved on May 12,1995,: made a change to FSAR Table 6.2-32 stating that the 4

)

EFW lsolation and FCV's meet the requirements of the Standard Review Plan (SRP) 6.2.4, Contamment Isaisbon System. These valves have always been =*==r* to the j

requiremonta of.TS 3.6.3 allowing either of these senes valves to meet the isolabon M

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i NRC FORM 3SSA U.S. NUCLEAR REGULATORY CnhamemON j

4.

l LICENSEE EVENT REPORT (LER) l TEXT CONTINUATION FACIUTY NAhE (1)

DOCKET t.ER NUhEER (S)

PAGE(3)

)

YEAR SEQUENTIAL REVI9018 05000 3 OF 8

)k 97 - 001 00 idATERFORD STEAM ELECTRIC STATION UNIT 3 382 TEXT (It enore space is required, use additional copies of NRC forrn 366A) (17 i

l requirements. This change credited the Secondary System as a closed system inside 4

containment pursuant to GDC 57 and allowed erther of the EFW series isolation and/or.

control valves to provide the second isolaban bamer. The ' intent of this change was to '

i promote safety such that an EFW flow path would not have to be isolated with only one of the two senes valves inoperable.( -

i i

i in Se,./

a=r 1995, dunng corrective actions associated with Licensee Event Report (LER)95-004, de Operabons procedure coordinator requested Design Engineering /Electncal (DE/E) to address whether or not the valve operator controller j

indicahon for FCVs EFW-223A(B) and EFW-224A(B) could be used for positive indication of containment isolation. It was decided that this type of indication may be i

l acceptable if there was secondary indicanon of valve opersbon avasiable. Coisiiiniauon i

of the valve operation can be obtained from monitoring steam generator level and EFW flow. Based upon the above, it was determined that the EFW FCVs contained adary =ta position indicabon.

i l

On November 1,1995, LDCR 95-0135 was wice which revised the FSAR to j

remove EFW-223A(B) and EFW-224A(B) from FSAR Table 7.5-3 as RG 1.97 CIVs.

Although the valves were believed to have adequate posebon indication, they were l

removed on the basis that the seven day Allowed Outage Time (AOT) per TS 3.3.3.6 is j

bounded by the 72-hour AOT for the EFW TS, 3/4.7.1.2. This basis has since been

{

determined to be flawed; the AOT for TS 3.3.3.6 is 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and not 7 days.

i As documented in NRC Inspection Report No. 50-382/96-202, "Engineenng Inspechon l

at Waterford 3," dated December 13,1996, the inspection team determined that for EFW-223A(B) and EFW-224A(B) to be conssdered as CIVs, they should have either.

quairSed position indications in the control room, or,some allemabve way, of venfying, the valve position indicahon. The report went on to say that these valves do not have such position indications or any approved altamative method of determining valve posebon. Thus, these valves are not +x+y41e CIVs. The team concluded that the 10CFR50.59 evaluation performed for LDCR 95-0071 was inadequate to demonstrate that an unreviewed safetyg==han did not exist.

iac mann.

Yl NRC FORM 384A U.s. NUCLEAR REGutATORY C-maON nes L!CENSEE EVENT REPORT (LER) i TEXT CONTINUATION FACIUTY NAhE (1)

DOCKET LER NUhSER (6)

PAGE (31 05000 4 OF 8 li4TERFORD STEAM ELECTRIC STATION UNIT 3 382 97 -- 001

- 00 TEXT (11 rnore space os requored. Use addotional copies of NRC Forrn 366A) (17)

Waterford 3 believed that, although the requirements of RG 1.97 were not met,

]

EFW-223A(B) and EFW-224A(B) had indirect and secondary indications of position l

which met the intent of the TS for Operability. While this'possbon may,have been acceptable for an Operabslity argument, it was re<walualsd from a verbabm TS comphance standpont after docussens with the NRC and witi Wsterford 3 c l

management and was determmed to be reportable on January 29,' 1997.'

A review of the Equipment Out of Service history forthe EFW isolaton valves revealed one instance where EFW-224A was relied upon for containment isolation for greater than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. From 1249 hours0.0145 days <br />0.347 hours <br />0.00207 weeks <br />4.752445e-4 months <br /> on June 11,1996, to 0310 hours0.00359 days <br />0.0861 hours <br />5.125661e-4 weeks <br />1.17955e-4 months <br /> on June 14,1996, a penod of approximately 62.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. TS 3.3.3.6, Achon 30 states,"with the numberaf i

OPERABLE accident monitnring channels less than the minimum channels OPERABLE requirements of Table 3.3-10; either restore the inoperable channel (s) to OPERABLE j

status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."

j The possbon indicabon for EFW-224A does not meet the requirements of RG 1.97s

}

Therefore, the EFW-224A' containment penetration did not have adequate possbon indication for longer than the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> AOT of TS 3.3.3.6.'

l l

There were no manual or automatic safety system actuabons as a result of this event.

j There were no safety systems nor cornpon=& with multiple funcbons rendered inoperable as a result of this event.

l l

CAUSAL FACTORS 4

The scope of TS 3.6.3 is based on the requirements of GDC 55-57 for containment isolation. It is unclear why the EFW FCVs were included in the original TS 3.6.3 table of CIVs, given that the subject penetrations are GDC 57 penetrabons and requwe only, -

one isolaban valve. Since the FCVs were inciudad in TS 3.6.3, however, the root cause of this issue is believed to.be that Waterford 3's RG 1.97 submittals failed to take i

excephon for the EFW FCVs to allow credst for these valves as CIVs based on the' controller output and secondary. indication of valve possbon. Waterford 3 failed to

y

.U.S. NUCLEAR REGut.ATORY COASSSSION See LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAhE (1)

I DOCKET l.ER NUM (6)

PAGE (3)

)

IRTERFORD STEAM ELECTRIC STATION tlNIT 3 05000 5 OF 8 l

382 97 - 001 00 TEXT (N more space se reqwred. use additional copies of NRC Form 366A) (17) provide an evaluation for the use of secondary position indication for these valves to be i

reviewed and approved by the NRC.

As a result of the EFW-223A(B) and EFW-224A(B) bemg hated in the TS table as CIVs, the following contnbutmg causes to this event occuned:

A missed opportunity occurred in the 10CFR50.59 evalualmn performed for e

LDCR 95-0071 in that it did not consider position indication when stating that all eight EFW FCV and Isolaton valves rnet the requirements for CIVs.

Another messed opportunity occurTed when an incorrect judgment was made that e

the EFW FCVs had adequate possbon indication rather than requesting a RG.

1.97 arc +%=i for these valves.

t The 10CFf350.59 performed in October 1995, for the removal of EFW-223A(B) and EFW-224A(B) from FSAR Table 7.5-3 was incorrectly based, in part; on the ii.L rm./uun that the 72-hour EFW achon is more restrictrve that the 7-day Accident Monitonng Action of TS 3.3.3.6. In reekty, a 48-hour achon was associated with TS 3.3.3.6.

CORRECTIVE ACTIONS

1.

Condition Report 96-1658 was 9 6 i.1.d on October 23,1996, to enter this event into the cor ochve acbon program.

2.

Operations department Standing instruction 96419 was issued with the following recommendations:

i if EFW-228A(B) or EFW-229A(B) become inoperable,' the associated path shall be isolated in accordance with Technical Specification 3.6.3.. Credit for isolation by usmg the associated m-hne flow control valve is not acceptable. (NOTE OP-mimm ama nas w

1U.9. NUCLEAR REGULATORY COMMSSION gas LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACil3TY NAhE (1)

DOCKET LER NUMBER (6)

PAGE (3) 05000 6 OF 8

)

blATERFORD STEAM ELECTRIC STATION UNIT 3 382 97 - 001

-- 00 TEXT lit tru.re space is reqwred. use additional copies of NRC Form 366A) (17) i 100-014 no longer specifically states that alternate credit can be taken for the

)

assocrated valve.) -

3.

LDCR 97-0110, approved on January 9,1997, made the followng changes to the FSAR and TRW e

The follomng (*) note was deleted from Table 3.6-2 of the TRM for EFW-4 223A(B), EFW-224A(8), EFW-228A(B) and EFW-229A(B):

Each of these isolabon valves is capable of meebng the containment isolation requirements of GDC 57. Accordingly, the compensatory achons of Technical Specifkoison 3.6.3 will apply when both valves in senes are inoperable.

i The follomng note was added to Table 6.2-32 of ine FSAR for EFW-223A(B) and EFW-224A(B):

No credit is taken for these isolabon valves in meebng the

)

requirements of GDC 55 through 57.

1 4.

" Direct" position indication in the Control Room was ceAmed for all CIVs

{

categorized in the FSAR as RG 1.97, Category 1.

5.-

This event will be discussed with Engineering and Licensing personnel with j

emphasis placed on ensuring that informatior: used in 10CFR50.59 evaluations is accurate and conscL i

l SAFETY S!GNIFICANCE 4

Although " direct" position indication is not provided for the EFW FCVs', indication that the EFW isolabon funcbon has occuned, by either one or both of the valves in a path is assured via safety related EFW flow and steam generator (Ells Identifier - SG) level EEEM IL

-. -. ~

~.. _ _ -. ~ _.....

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NRC FORM 384A Us. NUCtIAR REGULATORY COmeg nom LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION i

FACit.lTY NA!

.O DOCKET l.ER NUhEER (6)

PAGE (3) i VIAR SEQUENTIAL REVISION

~

05000 7

OF 8 IRTERFORD STEAM ELECTRIC STATION UNIT 3 382 97 - 001 - 00 TEXT tot more space os required, use additscnol copies of NRC Form 366A) (17) indications. The ability of EFW-223A(B) and EFW-224A(B) to perform their safety l

function is not affected by the operabslity= of theer Ke;+2 MM indiustors. EFW-I 223A(B) and EFW-224A(B) are stroke-tuned in the open and closed dirschons each l

refuebng outage. Dunng this test, an operator is staboned locally at each valve to ensure the valve strokes fully open and ~<*= art Amendment 122 to the Waterford 3 TS j

was approved on February 12,1997; which allows CIV poorbon indicabon to be ~

j moperable for 30 days.

1 This event did not compromise the health and safety of the public.

1 a

i

SIMILAR EVENTS

t LER 95-004 was written to document a failure to perform TS surveillance j

requirement 4.3.3.8 for a number of RG 1.97 CIV posebon indicators.

j.

LER 88-04 was wntten to document that ARM-109 (Ells Identifier - JM-FSV) failed i

i to meet the posebon indicahon operabaisty requirement of TS 3.3.3.6.

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U.S. NUCLEAR LEGULATORY ComancsuON 1689 i

LICENSEE EVENT REPORT (LER) l TEXT CONTINUATION FACILITY NAhE (1)

DOCKET LER NUIAER (6)

PAGE (3)

YEAR SEQUENilAL REVISION 3

NUMBEf.

NUMBER WATERFORD STEAM ELECTRIC STATION UNIT 3 0 0 2

W -- 001 - 00 1

TEXT (11 more space is required, use additional copies of NRC Form 366A) (11)

I FIG. 1 EFW SIMPUFED FLOW PATH 1

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