05000440/LER-1998-001, :on 980506,instruction Rev Results in Inadequate Testing & Missed TS Sr.Caused by Human Error.On 980506,testing of PRM RM High Alarm Relay Contacts Was Performed

:on 980506,instruction Rev Results in Inadequate Testing & Missed TS Sr.Caused by Human Error.On 980506,testing of PRM RM High Alarm Relay Contacts Was Performed

ML20248K751
Person / Time
Site:	Perry
Issue date:	06/04/1998
From:	Myers L, Sanford S CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-98-001, LER-98-1, PY-CEI-NRR-2287, NUDOCS 9806100245
Download: ML20248K751 (5)

LER-1998-001, on 980506,instruction Rev Results in Inadequate Testing & Missed TS Sr.Caused by Human Error.On 980506,testing of PRM RM High Alarm Relay Contacts Was Performed

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(viii) 10 CFR 50.73(a)(2)(ii) 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(iv), System Actuation 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability
4401998001R00 - NRC Website

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i PerryNuclearPowerPlant -

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10 Center Road PO Box 97

_ E_ E ? V Perry Onoo 44001 m

Low W. Myere 4402805915 Vice Prestdant Fax 4402808029 l

June 4,1998 PY-CEl/NRR-2287L United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Perry Nuclear Power Plant

. Docket No. 50-440

- Ladies and Gentlemen:

Enclosed is Licensee Event Report 1998-001," Instruction Revision Results in Inadequate Testing and Missed Technical Specification Surveillance Requirement."

If you have questions or require additional information, please contact Mr. lienry L. liegrat, Manager-Regulatory Affairs, at (440) 280-5606.

Very trul yours,

/

fo - w. Myer.

Enclosure cc:

NRC Region 111 Administrator NRC Resident inspector NRR Project Manager

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NRC FORM'366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED SY OMa kO. 31 fro-0104 EXPIRES 04/30/98 e

E'"5'E"Is? Fi%*"Wr"o^"E LICENSEE EVENY REPORT (LER)

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FACUTY NAME (1)

DOCKET NUMBER (2)

PAGE (3)

PERRY NUCLEAR POWER PLANT, UNIT 1 05000440 1OF4 TITLE (4) instruction Revision Results in inadequate Testing and Missed Technical Specification Surveillance Requirement EVENT DATE (5)

LER NUMBER (6)

REPORT DATE (7)

OTHER FACILITIES INVOLVED (8)

SE 3

MONTH DAY YEAR YEAR MONTH DAY YEAR U

N

" "^"'

05 06 1998 1998 - 001 --

00 06 04 1998 OPERATING THit REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR 5: (Check one or more) (11)

MODE (9) 1 20.2201(b) 20.2203(a)(2)(v) x 50.73(a)(2)(i) 50.73(a)(2)(viii)

POWER 20,2203(a)(1) 20.2203(a)(3)(i) 50.73(a)(2)(ii) 50.73(a)(2)(x)

LEVEL (10) 100 20.2203(a)(2)(i) 20.2203(a)(3)(ii) 50.73(a)(2)(iii) 73.71 Wge g ibc3 20.2203(a)(2)(ii) 20.2203(a)(4) 50.73(a)(2)(iv) x OTHER

, ykg, Yb[N 20.2203(a)(2)(iii) 50.36(c)(1) 50.73(a)(2)(v)

Specify in Abstract below

,b NID 20.2203(a)(2)(iv) 50.36(c)(2) 50.73(a)(2)(vii)

O'in NRC Form 366A LICENSEE CONTACT FOR THIS LER (12)

NAN.E TILEPHONE NUMBER (include Area Codel Sterling W. Sanford, Compliance Engineer (440)280-5361 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

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CAUSE

SYSTEM COMPONENT MANUFACTURER

CAUSE

SYSTEM COMPONENT MANUFACTURER O NP DS O PRD A'1 SUPPLEMENTAL REPORT EXPECTED (14)

EXPECTED MONTH DAY YFAR SUBMISSION YES X NO DATE (15)

(If yes, complete EXPECTED SUBMISSION DATE).

ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16)

On May 6,1998, at approximately 1025 hours0.0119 days <br />0.285 hours <br />0.00169 weeks <br />3.900125e-4 months <br />, the Perry Nuclear Power Plant (PNPP) staff, based on questions from the licensed operator class, identified that the relay contacts for the Containment Ventilation Exhaust Radiation Monitors' high alarm that provide an isolation signal to the Containment Vessel and Drywell Purge System (CVDP) was not being tested.

Positive verification of the high alarm contact in each of the four radiation monitoring loops for the CVDP system isolation had not been incorporated during instruction changes made while implementing License Amendment 77, the amendment that removed response time testing (RTT) requirements from the Technical Specifications (TS). Because the logic system functional test (LSFT) requirement could not be completed without positive verification that the contact operated, TS Surveillance Requirement 3.3.6.1.5 was not met resulting in a condition prohibited by TS. Upon discovery of the discrepancy, PNPP wrote a condition report and initiated a category 1 investigation.

The logic system testing requirements were incorporated into other surveillance instructions (SVis) to support deletion of the RTT requirements. The mode switch contact arrangement for the radiation monitor was not detailed on plant drawings, but was depicted in the vendor manual. The personnel performing the instruction change and reviews did not reference the vendor manual and, therefore, did not ensure the technbal accuracy and completeness of the SVis as required.

Proper operation of the isolation logic was verified on May 6,1998, to satisfy TS Surveillance Requirement 3.3.6.1.5.

NRC F oRM 366 (4-95)

NRC FORM 36eA U.S. NUCLEAR REGULATORY COMMISSION (G 95) i.lCENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DOCKET LER NUMBER I6)

PAGE (3)

SEQUENTIAL REVISION YEAR NUMBER NUMBER 2OF4 PERRY NUCLEAR POWER PLAWT, UNIT 1 05000440 1998 - 001 -

00 TEXT (11 more space is required, use additional copies of NRC form 366A) (17) 1.

INTRODUCTION

On May 6,1998, at approximately 1025 hours0.0119 days <br />0.285 hours <br />0.00169 weeks <br />3.900125e-4 months <br />, the Perry Nuclear Power Plant (PNPP) staff, basei on questions from the licensed operator class, identified that the relay contacts for the Containment Ventilation Exhaust Radiation Monitors' [RA)

(PRM) high alarm that provide an isolation signal to the Containment Vessel and Drywell Purge System [VA) (CVDP) was not being tested. Positive verification of the high alarm contact in each of the four PRM radiation monitoring loops for the CVDP system isolation was not incorporated during instruction changes made w hile implementing License Amendment 77, the amendment that removed response time testing (RTT) requirements from the Technical Specifications (TS). Upon discovery of the discrepancy, PNPP wrote a condition report and initiated a category 1 investigation.

Investigation determined that the TS Surveillance Requirement (SR) 3.3.6.1.5 to perform the Logic System Functional Test (LSFT) for the PRM radiation monitors was not completely incorporated into plant surveillance instructions (SVIs). The failure to test this logic, as required by SR 3.3.6.1.5, resulted in a condit on that is prohibited by TS. On May 7,1998, at 1003 hours0.0116 days <br />0.279 hours <br />0.00166 weeks <br />3.816415e-4 months <br />, a 24-hour notification (ENS 34187) was made to the NRC as required by the PNPP Operating License. This condition is being reported in accordance with 10CFR50.73(a)(2)(i)(I3).

Proper operation of the isolation logic was verified on May 6,1998, to satisfy TS Surveillance Requirement 3.3.6.1.5.

At the time of discovery, the plant was in Mode 1 at 100 percent of rated thermal power. The reactor pressure vessel was at approximately 1024 pounds per square inch gauge with the reactor coolant at saturated conditions. There were no systems, structures, or components that were inoperable that contributed to this event.

II.

EVENT DESCRIPTION

On May 6,1998, PNPP staffidentified that the relay contact for the PRM radiation monitor high alarm that provides an isolation signal to the CVDP system was not being tested. The failure to test this contact was discovered while performing a technical review of plant drawings in response to questions by members of the current licensed operator class.

As part ofimplementing License Amendment 77, the PRM SVIs that met the RTF requirements were to be cancelled and the LSFT requirements of TS 3.3.6.1-1.2.g and SR 3.3.6.1.5 were to be incorporated into other SVis. The preparer and reviewers of these instruction changes failed to identify that the PRM radiation monitor high alarm relay contacts (one contact in each of four channels) for the CVDP system isolation were no longer being positively verified during the SVis.

l These changes became effective on February 7,1996, with the implementation of Amendment 77. The last satisfactory completion of SR 3.3.6.1.5 was in February 1994.

The relay contacts in question were successfully tested on May 6,1998, at approximately 2240 hours0.0259 days <br />0.622 hours <br />0.0037 weeks <br />8.5232e-4 months <br /> in accordance with the provisions of TS Surveillance Requirement Applicability SR 3.0.3.

111. CAUSE OF EVENT The cause of the event was human error. The preparer of the procedure revisions failed to ensure that the LSFT requirements for the PRM radiation monitor high alarm relay contacts were transferred from the RTF instructions that were being NX FORM 366A I4-95) l

NRC FORM $66A U.S. NUCLEAR REGULATORY COMMISSION (4-95)

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LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DOCKET LER NUMBER (6)

PAGE (3)

SEQUENTIAL REVISION YEAR NUMBER NUMBER 3OF4 PERRY NUCLEAR POWER PLANT, UNIT 1 05000440 1998 - 001 -

00 1 EXT (11more space is required, use additionalcopies of NRC Form 366A) (17) cancelled as part of TS Amendment 77 implementation. Also, the reviewers, who were responsible for performing a technical review of the changes to assure adequacy, failed to identify the discrepancy.

Other contributing causes were also identined. For example, the plant drawings for radiation monitor loops do not provide the details regarding switch contact con 6guration; the vendor man nl must be used for the level of detail to fully describe the contact configuration.

IV. SAFETY ANAI,YSIS Primary containment isolation instrumentation automatically initiates closure of primary containment isolation valves (PCIVs). The function of the PCIVs, in combination with other accident mitigation systems, is to limit fission product release during and following postulated Design Basis Accidents (DB As). Primary containment isolation, within the time limits speciGed for those isolation valves designed to close automatically, ensures that the release of radioactive material to the environment is consistent with the assumptions used in the analysis for a DBA.

The isolation instrumentation includes the sensors. relays, and switches that are necessary to cause initiation of primary containment and reactor coolant pressure boundary isolation. The channels include electronic equipment (e.g., trip units) that compares the measured input signals with pre-established setpoints. When the setpoint is exceeded, the channel output relay actuates, w hich then outputs a primary containment isolation signal to the isolation logic.

The PRM radiation monitor high alarm is an indication of possible gross failure of the fuel cladding. The release may have originated from the primary containment due to a break in the Reactor Coolant Pressure Boundary. When high radiation is detected, valves whose penetrations communicate with the primary containment atmosphere are isolated to limit f he rclease of fission products. This isolation is also assumed to occur in the event of a fuel handling accident. The isolation, in conjunction with other accident mitigation systems, functions to ensure that the steam and water released to the drywell is channeled to the suppression pool to maintain the suppression function of the drywell.

The relay contacts in question were successfully veri 6ed to perform their intended function on May 6,1998, and it is l

assumed that these contacts would have performed successfully, if required. Therefore, this event is '.,t considered to be safety signincant.

V. CORRECTIVE ACTIONS

l l

The following corrective actions have been taken or are in progress, as speci6ed in the PNPP corrective action program:

1. On May 6,1998, testing of the PRM radiation monitor high alarm relay contacts was performed. All four channels were tested satisfactorily and declared operable.

2. A review of plant drawings for similar PRM radiation monitors was completed. A review of all other procedure revisions and cancellations related to Amendment 77 was performed. No additional discrepancies were identified.

l f4RC FORM 366A (4-95) l lU.S. NUCLEAR REGULATORY COMMISSIOM 14 95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DOCKET LER NUMBER 16)

PAGE (3)

SEQUENTIAL REVISION YEAR NUMBER NUMBER 4OF4' PERRY NUCLEAR POWER PLANT, UNIT 1 05000440 1998 - 001 -

00 TEXT fit more space is required. use additionalcopies of NRC Form 366A) l11)

3. The " Containment /Drywell Purge Exhaust Plenum Channel D Calibration for Containment Vent Exhaust Radiation Monitor" SVI (D17-T0066-D) was changed to include steps to test the radiation monitor high alarm relay contact. This SVI was performed satisfactorily on May 20,1998.

4. A revision to SVis D17-T0066-A, B, and C to include testing of the high alarm contact is in progress.

VI. PREVIOUS SIMILAR EVENTS

Licensee Event Report (LER)96-007 addressed missed surveillance requirements due to design modiGeation program weaknesses. The LF.R resulted from inadequate post modi 0 cation testing following installation of a complex modification to the leak detection system (13] instrumentation. Testing following the modiGeation, including surveillance testing, omitted the testing of contacts for numerous division isolations. None of the corrective actions for LER 96-007 could reasonably be expected to have prevented the iss documented by this LER from occurring.

No regulatory commitments were identined in this report.

Ells Codes appear in square [ ] brackets.

NGC FORM 366A (4 95)