05000333/LER-1993-017
| ML20056H402 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 08/30/1993 |
| From: | Mcguire P, Harry Salmon POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| JAFP-93-0473, JAFP-93-473, LER-93-017-01, LER-93-17-1, NUDOCS 9309090272 | |
| Download: ML20056H402 (5) | |
| Event date: | |
|---|---|
| Report date: | |
| 3332093017R00 - NRC Website | |
text
, James A.FitzPatrick
, , Nucles7 Power PICnt
, P.O. Box 41 Lycoming, New York 13093 315 342-3840
- > NewYo.rkPower Harry P. Salmon, Jr.
(sf Authonty i
neseen m anage, l
)
August 30, 1993 l JAFP-93-0473 United States Nuclear Regulatory Commission Document Control Desk Mail Station P1-137 Washington, D.C. 20555 :
SUBJECT:
DOCKET NO. 50-333 LICENSEE EVENT REPORT: LER-93-017: APRM Downscale Companion IRM Upscale / ,
~
Scram ;
Surveillance Test
Dear Sir:
This report is submitted in accordance with 10 CFR 50.73 (a) (2) (i) .
Questions concerning this report may be addressed to i Mr. Paul McGuire at (315) 349-6362.
Very truly yours, i
HARRY P.' SALMON, J .
HPS:PJM: tid I
Enclosure cc: USNRC, Region I USNRC Resident Inspector !
INPO Records Center I
-nnnno eff i i
4 l .J 9309090272 930830 % -
PDR S
ADDCK 05000333 's p-PDR Q
CRG FORM 366 U.S. CUCLEAR REOJLAT(DY CD941SS10N APPRCNED BY De CD. 3150-0104 (5-92) EXPIRES 5/31/95 ESTIMATED BURDEN PER .iESPONSE TO COMPLY WITH I "
LICENSEE EVENT REPORT (LER) $4an""CN'N 5 NRDINY ERDEN SilaiATE b THE INFORMATION AND RECORDS MANAGLMENT BRANCH (MNBB 7714), U.S. NUCLEAR REGULATORY COMMISSION, (See reverse for required rmber of digits / characters for each block) A ON, C 20555 000 AND V THE P RWOR MANAGEMENT AND BUDCET. WASHf gI_ , DC 20503.
FOCILITY KAK (1) DOCKET IR.MBER (2) PAE. (3)
James A. FitzPatrick Nuclear Power Plant 05000333 01 OF 04 TITLE (4)
APRM Downscale Companion IRM Upscale / Inoperable Scram Surveillance Test EVENT DATF (5) LER anmarR (6) IPORT DATE (7) OTHER F ACillTIFS INVOLVED (B)
DAY YEAR YEAR MONTH DAY YEAR g 0 0 FACILITY NAME DOCKET NUMBER 07 29 93 93 017 00 08 30 93 05000 cstRATiuc y inis Rimi 15 sunMiTTrD PuRSuxWT TO THE RrouiRrMiNTS Or 10 CrR i: (Check one or more) (11)
CDDE (9) 20.402(b) 20.405(c) 50.73(a)(2)(iv) 73.71(b) pgg, 20.405(a)(1)(i) 50.36(c)(1) 50.73(a)(2)(v) 73.71(c) 100 LEVEL (10) 20.405(a)(1)(ii) 50.36(c)(2) 50.73(a)(2)(vil) OTHER 20.405(a)(1)(iii) X 50.73(a)(2)( t ) 50.73(a)(2)(vi ii )( A) (Specify in 20.405(a)(1)(iv) 50.73(a)(2)(li) 50.73(a)(2)(viii)(B) *[
20.405(a)(1)(v) 50.73(a)(2)(iii) 50.73(a)(2)(x) NRC Form 366A) t ICENsFF CONT ACT FOR THIS LFR (12)
CIAME TELEPHONE NUMBER (Include Area Code) '
Mr. Paul McGuire, Senior Licensing Engineer (315) 349-6362 COMPT FTE ONE TINE FOR F ACH COMPONf MT F AILuRE DESCRIBED IN THIS REPORT (13)
CAUSE SYSTEM COMP 0hENT MANUFACTURER CAUSE SYSTEM COMPOWENT MANUFACTURER 0 S 0W StPPt E MF WT AL RE PORT EXPE CTE D (14) MONTH DAY YEAR EXPECTED YES SUBMISSION (if yes, conplete EXPECTED SUSMISSION DATE). NO y DATE (15)
ABSTRACT (Limit to 1400 spects, i.e., apr;roximately 15 single-spaced typewritten lines) (16)
EIIS Codes are in []
l On July 29, 1993, at 1033 hours0.012 days <br />0.287 hours <br />0.00171 weeks <br />3.930565e-4 months <br /> with the plant operating at 100 percent )
power and the mode switch in the Run position, an Unusual Event was !
declared when it was determined that the APRM Downscale, Companion IRM !
Upscale / Inoperative Scram was not being tested and was therefore inoperable. A plant shutdown was initiated. The APRM Downscale Scram was tested and performed as designed. The Unusual Event was terminated at 1350 hours0.0156 days <br />0.375 hours <br />0.00223 weeks <br />5.13675e-4 months <br /> on the same day. Although the trips had always been calibrated and tested individually, the APRM Downscale, Companion IRM Upscale / Inoperable !
Scram conincident trip function had not been tested due to a l misinterpretation of the surveillance requirement. This scram function exists, and is required, only in the Run mode. The IRMs are not required to be operable in Run. This misinterpretation of the trip function ;
requirements as related to the mode switch position caused the procedural I deficiency. The corrective actions included testing of the function and adding this test to the weekly surveillance, as required by Technical Specifications.
I hRC FORM 366 (5-92) l
NRC FORM '366A U.S. NUCLIAR GEQJLATOY 03etIESIC APPRLMD BY OMB NO. 3150-0106 l (5-92) EXPikES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS.
. LICENSEE EVENT REPORT (LER) $"E"^[wFONE AN"^[EC[ DS fIct sfAW$
(MNBB 7714), U.S. NUCLEAR REGULATORY COMMISSION, TEXT CONTINUATION WASHINGTON, DC 20555-0001 AND TO THE PAPERWORK REDUCTION PROJECT (31dO-0104), OFFICE OF MAN AGPENT AND BUDGET. WASHINGTON. DC 20503.
FACitITY NAE (1) 00crFT NtMHFR (?) LER ulamfR (6? PAGF (3)
James A. FitzPatrick Nuclear YEAR SEQU TIAL R Power Plant 05000333 93 og 02 OF 04 017 TEXT (If more space is reouired. use sifitional copies of hRC Form 366A) (IT)
EIIS Codes are in []
Description On July 29, 1993, with the plant operating at 100 percent power, it was determined that the plant had not been testing the Average Power Range Monitor (APRM) [IG] Downscale, Companion Intermediate Range Monitor (IRM)
[IG) Upscale / Inoperative Scram function in the Run mode as required by Technical Specification 3.1A (Table 3.1-1) and 4.1A (Table 4.1-1).
In 1984, a self-initiated Surveillance Test Review was performed by the Operations, Instrumentation and Control, and the Maintenance Departments with an independent review by the Quality Assurance Department. Although the Quality Assurance review did note that the APRM Downscale, Companion IRM Upscale / Inoperative Scram in the Run mode was not functionally tested, the final Quality Assurance report did not identify this as a discrepancy.
In March, 1993, APRM Surveillance Test Procedure reviews were directed to resolve discrepancies between Operations and Instrument and Control Department APRM Surveillance Procedures. Failure to test the APRM Downscale Companion IRM Upscale / Inoperable Scram was identified, but was not identified as a problem with respect to compliance with Technical Specifications. Both times the testing requirement was incorrectly interpreted because the APRM Downscale Companion IRM Upscale / Inoperable Trip is only functional, and required, when in the Run mode and the IRMs are not required to be operable in the Run mode.
In 1988, INPO Significant Event Notification (SEN) 026 was issued, which identified a similar problem at the Hatch Plant. The initial screening of this event required an evaluation for applicability to FitzUntrick. The evaluation was not completed at that time. An evaluation was performed as part of the FitzPatrick Operating Experience backlog prcject. This evaluation, performed in June of 1993, incorrectly described this event as not being a problem at FitzPatrick. The evaluation of the circuit logi:
and testing requirement was misinterpreted. The trip is enabled in the Run mode, and the IRMs were known to normally be withdrawn and not required in that mode.
Independently, this " conflict" was noted by site Licensing. On February 19, 1991, a proposed Technical Specification change was submitted from the plant to Licensing to eliminate the APRM Downscale, Companion IRM Upscale / Inoperative Scram function from Technical Specifications. Other plants (Dresden 2 and 3, and Monticello) had been granted Technical Specification amendments to eliminate this scram function.
=
CRC FORM 366A (5-92)
I l
NRC FORM 3664 U.S. C3sCLEAR REGAATORT COMMISSION APPRCMD ST CBS 10. 3150-0104 I (5-02) EXPIRES 5/31/95 j ESTIMATED BURDEN PER RESPONSE TO '%>tptY VITH THIS INFORMATION COLLECTION REQULST: 50.1 HRS.
" "^ '
LICENBEE EVENT REPORT (LER) $ i FO ERE A N N DS Y NAGE BRAN TEXT CONTINUATION gg,y.SiosI5 00Y1 AND TO HE k REDUCTION PROJECT (31$0-0104), OFFICE OF MN AGEMENT AND BUDMT. WWINGTON. DC 20503.
FACILITY k8K (1) DOCKTT NLMPER (?) LEY WJWER (6:' PAE (3)
James A. FitzPatrick Nuclear yExa SEQUENTIAL REVISION Power Plant 05000333 03 OF 04 93 017 00
' TEXT fif more space is reo; ired. use additional copies of NRC Form 366A) (17) l In July, 1993, a licensed staff instructor questioned the potential for violating the minimum number of operable instrument channels required for certain combinations of bypassed channels and whether the APRM Downscale Trip .kad ever been functionally tested. This led to a re-review of the APRM logic diagrams and a decision that the required testing had not been performed, l
On July 29, 1993, at 1033 hours0.012 days <br />0.287 hours <br />0.00171 weeks <br />3.930565e-4 months <br />, the APRMs were declared inoperable in accordance with Technical Specifications and an Unusual Event was declared.
The NRC was notified and an order)y shutdown commenced. The APRMs Downscale Trip with Companion IRM Upscale / Inoperable Scrams were tested and verified operable and the Unusual Event was terminated at 1350 hours0.0156 days <br />0.375 hours <br />0.00223 weeks <br />5.13675e-4 months <br />. The plant's power level had been reduced from 100 percent to 87 percent. The plant power level was returned to 100 percent following completion of the surveillance.
Cause The event was caused by a procedure deficiency stemming from failure to include all scram functions in the APRM Surveillance tests because the testing requirement was not correctly understood (Cause Code D). Technical Specification Table 3.1-1 requires the APRM Downscale, Companion IRM Upscale / Inoperable Trip to be operable only in the Run mode, and the IRM upscale and inoperative trips be operable in the Refuel and Startup/ Hot !
Standby modes. Technical Specification 4.0.A states the following,
" Surveillance Requirements shall be applicable during the Operation Condition (modes) specified for individual Limiting Condition for Operation unless otherwise stated in the individual Surveillance Requirements".
Also, Technical Specification 4.0.C states the following, " Performance of a Surveillance Requirement within the specified time interval shall constitute compliance with OPERABILITY requirements for a Limiting Condition for Operation and associated ACTION statements unless otherwise required by the specification. Surveillance requirements do not have to be performed on inoperable equipment". The difference in the trip function requirements with respect to mode switch position caused the misinterpretation of the surveillance test requirements. Since the IRM Upscale / Inoperative Scram function is not required to be operable in the Run mode and since surveillance is only required on equipment required in LCO Specified mode, personnel concluded that surveillance of the APRM Downscale, Companion IRM Upscale /Incperative Trip function was not required. The trips had always been calibrated and tested individually.
h3C FokM 366A (5-92)
L l
NRG FORM 366A U.S. NUCLEAR RE(ERAT O Y CoppilSSION APPRDWED ST (35 N0. 3150-0106 i (5-92) EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITN i I
LICENSEE EVENT REPORT (LER) Ego$" 3"nS$RDr'W EN$ ks Idu"'$6 TEXT CONTINUATION THE INFORMATION AND RECORDS MANAGEMENT SRANCH (MNBB 7714), U.S. NUCLEAR REGULATORY COMMISSION,
[
i WASHiWGTON, DC 20555-0001 AND TO THE PAPERWORK ;
REDUCTION PROJECT (31$0-0104), OFFICE OF s MANAGEMENT AND BUDGET. WASHINGTON. DC 20503.
FACILITY NAME (1) DOCKET NLMBER (?) LER WL53ER (6? PAE (3) I James A. FitzPatrick Nuclear YEAR SE HAL RE Power Plant 05000333 93 og 04 OF 04 ;
017 i
TEXT (if more space is reouired, use autfitional copies of WRC Form 366A) (IT)
Analysis The surveillance tests which were performed on July 29, 1993, demonstrated, ,
that although the surveillance tests were never performed, the scram ,
function did perform as designed. Based on the information above, this !
event io not safety significant. This event was determined to be (
1 reportable under 10CFR50.73 (a) (2) (i) since the surveillance required was j not performed.
f Corrective Actions i
- 1. The immediate corrective action was to initiate a plant shutdown and j declare an Unusual Event until a surveillance test demonstrated the operability of the APRM Downscale, Companion IRM Upscale / Inoperable Trip.
l
- 2. Surveillance Test Procedures have been prepared to test these l functions weekly.
i f
- 3. A formal review of Logic System Function Test (LSFT) adequacy is in !
progress at FitzPatrick. This review is being performed in accordance !
with TSSO-18, Surveillance Test (LSFT) Adequacy Review Procedure. The !
APRM surveillance review (and two other surveillance adequacy reviews i on HPCI and the EDG logic) was performed independent of and prior to ;
j the start of this proceduralized process. An adequacy review of the HPCI, APRM and EDG system surveillance requirements will be
, re-performed using an approach similar to JAF LSFT adequacy reviews by December 31, 1993. l
- 4. A sample of previous Industry Operating Experience Evaluation is under :
review for potential surveillance test adequacy concerns and will be l completed by September 10, 1993.
Additional Infornation Failed Components: None Previous Similar Events: 93-007,93-014, 92-020,92-032, 92-050 s
, - - ,, , - -- ,- -