05000255/LER-1999-001, :on 990310,noted Failure to Perform TS Surveillance Channel Check of Auxiliary Feedwater Flow Indication.Caused by Misinterpretation of Definition of Channel Check.Implementing Procedure Has Been Revised
| ML20205P287 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/09/1999 |
| From: | Domonique Malone CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML18066A458 | List: |
| References | |
| LER-99-001, LER-99-1, NUDOCS 9904200107 | |
| Download: ML20205P287 (2) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 2551999001R00 - NRC Website | |
text
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CONSUMERS ENERGY COMPANY - PALISADES NUCLEAR PLANT 05000255 1 OF 2 ftTLE M)
FAILURE TO PERFORM TECHNICAL SPECIFICATION SURVEILLANCE CHANNEL CHECK OF AUXILIARY FEEDWATER FLOW INDICATION EVEldT DA TE (5)
LER NUnansst 16 REPORT DJ TE (71 OTHER FACILITIES lldVOLVED (8)
U MCTUH DAY YEAR YEAR MONTH DAY YEAR NUMBER NUMBER 05000 03 10 99 99 001
-- 0 04 09 99 50 0 OPERATING THIS REPORT IS aunu TTso PURaUANT TO THE Rent;ipsiasMTS OF to CFR O (Check one or moral (111 N
MODE (9) 2o.2201(b) 20.2203(aH2Hv)
X 50.73(aH2)(i) 50.73(a)(2Hviii)
POWER 20.2203(a)(1) 20.2203(a)(3)(i) 50.73(a)(2Hii) 50.73(aH2Hx) 100 LEVEL (10) 20.2203(aH2 Hit 20.2203(aH3Hii) 50.73(aH2)(iii) 73.71 20.2203(a)(2)(ii) 20.2203(a)(4) 50.73(a)(2Hiv)
OTHER 20.2203(a)(2)(iii) 50.36(c)(1) 50.73(a)(2Hv)
Specify in Abstract below 20.2203(a)(2Hiv) 50.36(cH2) 50.73(a)(2Hvii) or in NRC Form 366A LicNNR8F CONTACT FOR THIS LEf' (12)
NAME TELEPHONE NUMBER (include Area Codel Danirl G. Malone, Regulatory ActMties Administrator (616) 764-2463 COMPLETI' ONE LINE FOR E LCH COMPONEffT F AILURE DERCPlasri IN "HIS REPORT 113)
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ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewntten lines) (16)
On March 10,1999, an audit revealed that the channel check of Auxiliary Feedwater (AFW) (BA) flow indication specified in Technical Specification Table 4.17.6, item 6 was not being performed as required by Technical Specification 3.17.6. This channel check is specified to be performed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when ths PCS temperature is greater than 300" F. However, due to a misinterpretation of the definition of a channel check, the channel check was inappropriately specified in the implementing procedure to be performed only when the AFW system was In operation. Since the AFW is not normally in operation, the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> channel check was regularly not performed.
There are no safety implications associated with this occurrence since AFW flow indication is utilized during several periodic surveillance tests of the AFW system which routinely demonstrate its operability.
The implementing procedure has been revised.
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.U.S. NUCLEAR REGULATORY COMMISSION 6/98 LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACILITY NAME (1)
DOCKET (2)
LER NUMBER (l)
PAGE CONSUMERS ENERGY COMPANY YEAR SEQUENTIAL REVISION NWBER N W BER PALISADES NUCLEAR PLANT 05000255 2oF2 99 001 Oo TEXT Of more space a regnet use aMennel copse of NRC Form 066A) (1D
EVENT DESCRIPTION
On March 10,1999, with the plant at full power, an audit revealed that the channel check of Auxiliary Feedwater (AFW) (BA] formed as required. The channel check is specifie flow indication specified in Technical Specification Table 4.17.6, item 6 was not being per 3erformed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. However, the implementing procedure inappropnately specified uhe channel check to be performed only when the AFW system was in operation. Since AFW is not normally in operation, the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> channel check was regularly not performed.
This occurrence is reportable to the NRC in accordance with 10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by Technical Specifications.
ANALYSIS OF THE EVENT
The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> channel check requirement was added as part of Technical Specification Amendment 162 which revised the instrument and Control sections of the Technical Specifications. The amendment was issued in October 1994 and was subsequently implemented in January 1995.
The definition of a channel check in Technical Specifications begins with the statement: "A channel check shall be the qualitative assessment of channel behavior during operation by observation." The procedure sponsor, in revising the implementing procedure to accommodate the channel check of AFW flow indication, interpreted "during operation" to mean the AFW system being in operation. This errant interpretation was not detected by subsequent reviewers or performers of the procedures.
A review of Technical S aecification channel check requirements reveals that the AFW flow indication channel chec < is unique in that it is required to be performed when the system is off, with AFW indicated flow on each channel indication being zero.
SAFETY SIGNIFICANCE
There are no safety implications associated with this occurrence. The channel check would not yield meaningful data when the AFW system is not in service.
CAUSE OF THE EVENT
The event was caused by failure to correctly interpret the definition of a channel check, which allowed the inappropriate criterion of AFW system operation to be added to the r
implementing procedure.
CORRECTIVE ACTIONS COMPLETED The implementing procedure has been revised to perform the channel check as required.
Other channel checks were reviewed for similar problems and none were noted.
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