05000445/LER-2010-003

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LER-2010-003, Inadequate Surveillance Test Procedure Resulting in Failure to Meet TS Requirements
Document Numbersequential Revmonth Day Year Year Month Day Year Cpnpp Unit 2 05000 446Number No.
Event date: 06-18-2010
Report date: 11-16-2010
Reporting criterion: 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
4452010003R01 - NRC Website

I. DESCRIPTION OF THE REPORTABLE EVENT

A. REPORTABLE EVENT CLASSIFICATION

10CFR50.73(a)(2)(i)(B) "Any operation or condition which was prohibited by the plant's Technical Specifications"

B. PLANT CONDITION PRIOR TO EVENT

On June 18, 2010, CPNPP Unit 1 and Unit 2 were both in Mode 1 operating at 100% power.

C. STATUS OF STRUCTURES, SYSTEMS, OR COMPONENTS THAT WERE

INOPERABLE AT THE START OF THE EVENT AND THAT CONTRIBUTED TO 'THE

EVENT

There were no inoperable structures, systems, or components that contributed to the event.

D. NARRATIVE SUMMARY OF THE EVENT, INCLUDING DATES AND APPROXIMATE

TIMES

CPNPP TS SR 3.3.4.2 requires verification every 18 months that each required Hot Shutdown Panel power and control circuit and transfer switch is capable of performing the intended function. Contrary to this requirement, the existing surveillance test procedure (STP) was not adequate to verify that capability.

On June 18, 2010, during performance of the Component Design Bases Inspection, the NRC inspectors determined that surveillance test procedure (STP) OPT-216, "Remote Shutdown Operability Test" was not adequate to meet the Technical Specification (TS) Surveillance Requirement (SR). The STP provided a method to test the transfer of functional control from the Control Room (CR) to the Hot Shutdown Panel (HSP), but did not provide assurance that a circuit fault affecting control from the HSP would be identified. Engineering personnel (Utility, Non-Licensed) reported the condition to CR personnel (Utility, Licensed) and both units entered TS SR 3.0.3 for the affected components and risk assessments were completed which supported continued operability.

E. THE METHOD OF DISCOVERY OF EACH COMPONENT OR SYSTEM FAILURE, OR

PROCEDURAL PERSONNEL ERROR

On June 18, 2010, during performance of the Component Design Bases Inspection, the NRC inspectors determined that surveillance test procedure (STP) OPT-216, "Remote Shutdown Operability Test" was not adequate to meet the Technical Specification (TS) Surveillance Requirement (SR).

II. COMPONENT OR SYSTEM FAILURES

A. CAUSE OF EACH COMPONENT OR SYSTEM FAILURE

Not applicable - No component failures were identified during this event.

B. FAILURE MODE, MECHANISM, AND EFFECTS OF EACH FAILED COMPONENT

Not applicable - No component failures were identified during this event.

C. SYSTEMS OR SECONDARY FUNCTIONS THAT WERE AFFECTED BY FAILURE OF

COMPONENTS WITH MULTIPLE FUNCTIONS

Not applicable - No component failures were identified during this event.

D. FAILED COMPONENT INFORMATION

Not applicable - No component failures were identified during this event.

Ill. ANALYSIS OF THE EVENT

A. SAFETY SYSTEM RESPONSES THAT OCCURRED

Not applicable - No safety system responses occurred as a result of this event.

B. DURATION OF SAFETY SYSTEM TRAIN INOPERABILITY

The current method provided in the STP to test the transfer of functional control from the Control Room (CR) to the Hot Shutdown Panel (HSP) has been utilized since the initial licensing of Unit 1 in 1990 and Unit 2 in 1993.

C. SAFETY CONSEQUENCES AND IMPLICATIONS OF THE EVENT

The existing surveillances verified functional transfer capability to assure the control function did transfer to the Hot Shutdown Panel (HSP) and that the control function from the Control Room (CR) was isolated to the extent that control was not functional from the Control Room (CR).

There were no safety system functional failures associated with this event.

Based on the above, it is concluded that this event did not adversely impact the safe operation of CPNPP or the health and safety of the public.

IV. CAUSE OF THE EVENT

The cause of this event was due to a lack of clarity in the description for the basis for SR 3.3.4.2 in the CPNPP Technical Bases.

V. CORRECTIVE ACTIONS

Engineering personnel reported the condition to CR personnel and both units entered TS SR 3.0.3 for the affected components. Risk assessments were completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> which supported continued operability.

As part of the Corrective Action Program, the CPNPP Technical Specifications Bases for SR 3.3.4.2 will be reviewed and revised as appropriate.

Surveillance test procedures will be revised to verify isolation of the Control Room circuitry for those devices required for remote shutdown capability on transfer of controls to the Remote Shutdown Panel from the Control Room.

VI. PREVIOUS SIMILAR EVENTS

There have been no previous similar reportable events at CPNPP in the last three years.