05000336/LER-1990-001, :on 900110,discovered That Surveillances in Tech Specs for New Smoke Detectors & Suppression Sys Not Performed.Caused by Personnel Error.Fire Protection Sections of Tech Specs Updated

:on 900110,discovered That Surveillances in Tech Specs for New Smoke Detectors & Suppression Sys Not Performed.Caused by Personnel Error.Fire Protection Sections of Tech Specs Updated

ML20006E342
Person / Time
Site:	Millstone
Issue date:	02/09/1990
From:	Bates R, Scace S NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-90-001, LER-90-1, MP-90-149, NUDOCS 9002220708
Download: ML20006E342 (4)

LER-1990-001, on 900110,discovered That Surveillances in Tech Specs for New Smoke Detectors & Suppression Sys Not Performed.Caused by Personnel Error.Fire Protection Sections of Tech Specs Updated

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3361990001R00 - NRC Website

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Re: 10CFR50.73(a)(2)(i)(B).

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U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555

Reference:

Facility Operating License No. DPR-65

' Docket No. 50-336 Licensee Event Report 90-001-00 Gentlemen:

- l This letter forwaras Licensee Event Report 90-001-00 required to be submitted within thirty (30) days pursuant to 10CFR50.73(a)(i)(B).

Very truly yours, NORTHEAST NUCLEAR ENERGY COhiPANY i

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Sth eh. Scace

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Director, Millstone Station 4

SES/RWB:mo Attachment: - LER 90-001-00 cc:

W. T. Russell, Recion I Administrator W. J. Raymond, S'enior Resident inspector, Millstone Unit Nos,1, 2 and 3 G. S. Vissing, NRC Project Manager, Millstone Unit No. 2

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On January 10,1990 at 0745 hours0.00862 days <br />0.207 hours <br />0.00123 weeks <br />2.834725e-4 months <br />, with the plant at 100rc power and normal operation, a review of a Technical Specification change request to the fire protection sections noted that the surveillances specified in the existing Technical Specifications for two listed areas were not being performed. The fire suppression Technical Specification surveillance procedures had been revised to delete the removed smoke detectors and add the testing of the new suppression systems for these areas. The Technical Specifications had not been revised to reflect the plant changes. This was considered to be a condition prohibited by the plant's Technical Specifications, since the surveillance requirement listed in the LCO was not performed. There were no safety consequences because the arent in question were protected at all times by the new systems installed to satisfy Appendix "R" requirements. The old detectors were removed durmp the 1967 and 1966 refuehng outapes, and no change to the Technical Specifications was generated due an administrative oversight. The new systems were installed in accordance with approved designs that were found acceptable by the NRC in subsequent reviews. Smce full protection for the areas in question was provided, no other actions are required, with the exception of the submittal of the required Technical Specification changes.

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Dncetinn of Event j

On January 10,1990 at 074 hours8.564815e-4 days <br />0.0206 hours <br />1.223545e-4 weeks <br />2.8157e-5 months <br />, with the plant at 1009 power and normal operation, a resiew of a Technical Specification change request to the hre protection sections noted that the surveillances specihed in the existing Technical Specihcations for two hsted areas were not being performed. The fire suppression Technical Specification surveillance procedures had been revised to delete the removed smoke detectors and add the testing of the new suppression systems for these areas. The Technical Specifications had not been revised to reflect the plant changes. This was considered to be a condnion prohibned by the plant's Technical Specihcations, smce the surveillance requirement hsted in the LCO was not performed. There were no safety consequences because the areas in question were protected at all times by the new systems installed to sausly Appendix

• R* requirements. The old detectors were removed durmg the 1967 and 1966 refuehng outages, and no change to the Technical Specifications was generated due an administrative oversight. The new systems were installed in accordance wnh approved designs that were found acceptable by the NRC in subsequent reviews. Since full protecuon for the areas in question was provided, no other actions are required, with the exception of the submittal of the required Technical Specification changes. There were no operator actions or automatic safety system responses required by this event.

II, rue of Frent The root cause of the event is personnel error. The omission occurred during the planning and scheduling of events that were part of the modifications to the plant hre protection systems to meet the Appendix *R* requirements. The normal sequence for a known change to a system addressed in the Technical Specifications is to change the Technical Specification requirement such that it becomes effective when the new system will be placed in semce. In this case, the oversight occurred because hre protection is essentially required to be in service at all umes with appropriate compensatory action taken in case of a component or system failure or inoperabihty. Dunnp the transition between the old and new systems, the appropriate compensatory measures (hre watches and backup suppression systems) were in effect to assure the operabihty of the equipment within the areas. Following the completion of work the surveillances on the new systems were staned and the old systems surveillances were never resumed because the items to be checked (smoke detectors) had been remosed. The requirement to perform the old surveillances was overlooked because the new surveillances had taken their place through approved plant procedure revisions.

111.

Analvsk of Event This report is being submitted pursuant to the requirements of 10 CFR 50.73(a)(2)(i)(B), *Any operation or condition prohibited by the plants Technical Specificauons* There were no safety consequences resulung from this event smce the areas m question were protected at all times by operable fire suppression systems as oemonstrated by the surveillances performed under procedures l

SP 2616D and SP 2412, on the new systems. The new systems were found to be acceptable to the NRC in a post installation audit. Due to the scheduling of the implementation of the new fire suppression systems to meet the Appendtx "R" requirement deadhnes, the requirement to update the technical specihcations before the changes actually occurred, was inadvertently overlooked.

During the transition penod between the old and new systems, the apptopriate compensatory c

measures consisting of fire watches and backup suppression systems (fire hoses) were in effect to l

assure the operabihty of the equipment wahm the areas.

IV.

Corrective Action

The missed surveillances were noted dunng the review of the Technical Specification change package being made to consolidate and update the hre protection sections of the Technical Specihcations. Since the areas in question are properly protected by the new systems and the surveillances being performed demonstrate the operability of the new systems, no other action is required, with the exception of the submittal of the required Technical Specihcation changes. The estimated schedule for submission of the required changes to the Technical Specihcanons is March 31.1490.

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Ells: IC (Fire Detection System)

In ' addition, it k expected that plans to follow the NRC recommendation for removal of fire protection items frorn the Technical Specihcations when implemented would prevent a recurrence of the events as reported herein. This is based on the fact that the report identifies requirements 5

t not being performed that were listed in the Technical Specifications for specific smoke detectors for.

i specibe areas. Because these specific areas were being protected from hre concerns by new systems and the new systems were being verihed as operable under new or revised procedures, the omission was only of an administrative nature, and removal of the administrative requirements from the Technical Specifications will prevent a recurrence of this nature.

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