05000446/LER-2002-002, Condition Prohibited by Technical Specifications
| ML022400053 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/19/2002 |
| From: | Walker R TXU Energy |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 10200, CPSES-200202603, TXX-02121 LER 02-002-00 | |
| Download: ML022400053 (7) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2) 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor |
| 4462002002R00 - NRC Website | |
text
vdhb TX U N, 4 TXU Energy Comanche Peak Steam Electric Station P.O Box 1002 (E01)
Glen RoseTX 76043 Tel 254 897 8920 Fax 254 897 6652 lance terry@txu corn C. Lance Terry Senior Vice President &
Principal Nuclear Officer Ref. # 10CFR50.73(a)(2)(i)(B)
CPSES-200202603 Log # TXX-02121 File # 10200 August 19, 2002 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
UNIT 2 DOCKET NO. 50-446 CONDITION PROHIBITED BY TECHNICAL SPECIFICATIONS LICENSEE EVENT REPORT 446/02-002-00 Enclosed is Licensee Event Report (LER) 02-002-00 for Comanche Peak Steam Electric Station (CPSES) Unit 2, "Missed Surveillance on Steam Generator High-High Level Channel Operational Test."
A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway
- Comanche Peak Diablo Canyon
- Palo Verde
- South Texas Project Wolf Creek
A TXU TXX-02121 Page 2 of 2 This communication contains no new commitments regarding CPSES Unit 2.
Sincerely, TXU Generation Company LP By:
TXU Generation Management Company LLC, Its General Partner C. L. Terry Senior Vice President and Principal Nu lear Officer By:
Roger D. W er Regulatory Affairs Manager GLM/gm Enclosures c -
E. W. Merschoff, Region IV W. D. Johnson, Region IV D. H. Jaffe, NRR Resident Inspectors, CPSES
NRC FORsI 366 US. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104 (7-2001)
EXPIRES 07I31J2004
, the NRC may not conduct or sponsor, and a person is not requtred to respond to. the information collection Facility Nanin (I)
Docket Number (2)
Page (3)
COMANCHE PEAK STEAM ELECTRIC STATION UNIT 2 05000446 1 OF 5 Tale (4)
CONDITION PROHIBITED BY TECHNICAL SPECIFICATIONS Event Date (5)
LER Number (6) n Date t)l Other Facilities Involved (8)
Month Day Year Year Sequential f
Revision Month Day Year Facilty Name Docket Numbers Nunber Number 05000 06 19 02 00 00 05000 Operating 1
Thi repot i sulbmotd p ursuant to th e
remuevents of I10 CFR * (Check all that apply) (I 1)
Mode (9) 20.2201(b) 20 2203(a)(3)(i) 50 73(a)(2)(1)(C) 50 73(a)(2)(vit)
Power 20 2201(d) 20 2203(a)(3)(tn) 50.73(a)(2)(ti)(A) 50 73(a)(2)(vin)(A) t 995 20 2203(a)(1) 20 2203(a)(4) 50.73(a)(2)(ii)(B) 50 73(a)(2)(vii)(B) 20 2203(a)(2)(i) 50 36(c)(2)(i)(A) 50.73(a)(2)(iii) 50.73(a)(2)(ix)(A) 20 2203(a)(2)(n1) 50 36(c)(1)(li)(A) 50.73(a)(2)(iv)(A) 50 72(a)(2)(x) 20 2203(a)(2)(m) 50 36(c)(2) 50.73(a)(2)(v)(A) 73 71(a)(4) 20 2203(a)(2)(iv) 50 46(a)(3)(in) 50 73(a)(2)(v)(B) 73.71(a)(5) 20 2203(a)(2)(v) 50 73(a)(2)(i)(A)
=
50 73(a)(2)(v)(C)
OTHER 20 2203(a)(2)(vi)
X 50 73(a)(2)(i)(B) 50 73(a)(2)(v)(D)
Specify in Abstract below or
_in (If more space is required use additional copies of NRC Formi 366A) (17)
I.
DESCRIPTION OF THE REPORTABLE EVENT
A.
REPORTABLE EVENT CLASSIFICATION
Any operation or condition prohibited by the plant's Technical Specifications.
B.
PLANT OPERATING CONDITIONS PRIOR TO THE EVENT On June 19, 2002, Comanche Peak Steam Electric Station (CPSES) Unit 2 was in Mode 1, Power Operation, operating at 99.5 percent 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 structures, systems, or components that were inoperable at the start of the event that contributed to the event.
D.
NARRATIVE SUMMARY OF THE EVENT, INCLUDING DATES AND APPROXIMATE TIMES CPSES Technical Specification Surveillance Requirement (SR) 3.3.2.5 for Table 3.3.2-1, Item Sb, requires the performance of a Channel Operational Test (COT) every 92 days on the Steam Generator High-High Water Level instrumentation in order to provide protection against excessive feedwater flow. A COT is performed on each required channel to ensure that the entire channel (EIIS:(CHA)) will perform its intended safety function.
On June 19, 2002, at 1130 hours0.0131 days <br />0.314 hours <br />0.00187 weeks <br />4.29965e-4 months <br />, while investigating a previous circuit card failure, Engineering department personnel (utility, non-licensed) discovered that the COT procedure for a Steam Generator Narrow Range Level failed to verify the Steam Generator High-High level actuation function on the NPL card, a required trip function in the Technical Specifications. The absence of this verification in the procedure constituted a missed surveillance (SR 3.3.2.5.5b).
This condition applies to twelve Unit 2 Steam Generator level COT procedures (three procedures on each of four Steam Generators). The condition does not apply to Unit 1 due to differences in design and testing methodology. The Unit 1 design utilizes lead-lag circuit cards versus NPL timer (EIIS:(TMR)) cards to affect the necessary time delay.
(If mere space k requed. use additional copies of (Ifuiare space I required, use additional copies of (If more space is required, use additional copies of NRC Form 366A) (17)
During the time period that these surveillances were not fully performed, a plant transient or event that would have required these channels to operate did not occur. Also, all of the affected channels were subsequently tested, and this testing demonstrated that the channels would have performed their intended safety function, if required. There were no safety system functional failures associated with this event.
Based on the above, it is concluded that the event of June 19, 2002 did not adversely impact the safe operation of CPSES or the health and safety of public.
IV.
CAUSE OF THE EVENT
TXU Energy believes that the cause of the event was less than adequate attention to detail on the part of both the preparer and technical reviewer of the Unit 2 Steam Generator Level Channel Operational Test procedure revisions that incorporated the 1996 Westinghouse 7300 System Design Modification.
The procedure revisions did not specifically verify the continuity of PROM logic cards in the Westinghouse 7300 Series Process Instrumentation System. This verification of continuity is necessary to satisfy the strict definition for "Channel Operational Test" in the CPSES Technical Specifications, and this resulted in the failure to satisfy Technical Specification Channel Operational Test surveillance requirements.
V.
CORRECTIVE ACTIONS
The twelve affected surveillance testing procedures have been revised to incorporate verification of High-High level actuation function through the NPL card and all of the affected Technical Specification surveillance tests were successfully completed per the revised procedures.
Westinghouse 7300 Series Process Instrument Loop drawings were reviewed to determine whether there are any other instances where logic cards are located downstream of a bistable. The review identified no instances where circuitry installed downstream of a bistable was not adequately tested. A Lessons Learned regarding this event has been issued to procedure writers and test personnel involved with testing of safety-related logic circuits in order to reinforce the importance of verifying card continuity in order to satisfy Technical Specification requirements.
VI.
PREVIOUS SIMILAR EVENTS
There have been other previous events related to missed surveillances. However, the causes for those events were sufficiently different from this event such that the corrective actions would not have prevented this event.