05000458/LER-1993-012

LER 93-012-01:on 930603,deficiency in Plant Surveillance Test Procedures Identified.Caused by Inattention to Detail During Initial Procedure.Surveillance Test Procedures revised.W/930826 Ltr

ML20056G171
Person / Time
Site:	River Bend
Issue date:	08/26/1993
From:	Booker J, Lorfing D GULF STATES UTILITIES CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-93-012, LER-93-12, RBG-38921, NUDOCS 9309020183
Download: ML20056G171 (7)

LER-2093-012,

Event date:
Report date:
4582093012R00 - NRC Website

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GULF STA TES UTILITIES COMPANY o w erwsw a ww wou wnn st uuxwasnusua w s

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August 26, 1993 ,

RBG- 38921 File Nos. G9.5, G9.25.1.3  !

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

Gentlemen: l i

River Bend Station - Unit 1 l Docket No. 50-458 r

Please find enclosed Supplement I to Licensee Event Report No.93-012 for River [

Bend Station -Unit 1. This report is submitted pursuant to 10CFR50.73. I Stacerely, i f Ml J. E. Booker l Manager - Safety Assessment ,

and Quality Verification [

River Bend Nuclear Group  !

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9309020183 930826 E I I PDR ADOCK.05000458 W {

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. r ce: U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400  !

Arlington, TX 760;1 NRC Resident Inspector  ;

P.O. Box 1051 i St. Francisville, LA 70775  ;

i INPO Records Center >

700 Galleria Parkway ,

Atlanta, GA 30339-5957

.- 3 Mr. C.R. Oberg l Public Utility Commission of Texas  !

7800 Shoal Creek Blvd., Suite 400 North l

Austin, TX 78757  ;

j Department of Environmental Quality Radiation Protection Division ,

P.O Box 82135 l Baton Rouge, LA 70884-2135 l ATI'N: Administrator  ;

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I NRC FORC3 566 U.S. EUCLEAR REGULATO7 CIMMISSIO APPROVED BY DEL CD. 3150-0104 (5-92) EXPIRES 5/31/95 ESTIMATED BURDEN FER RESPONSE TO COMPLY WITH

' I3 LICENSEE EVENT REPORT (LER) $ARo"NMEN7S RfGYRDIN$ BURDEN STI$ AT TFE INFORMATION AND RECORDS MANAGEMENT BRANCH (MhBB 7714), U.S. NUCLEAR REGULATORY COMMISSION, (See reverse for retTaired ntriber of digits / characters f or each block) 6ASHINGTON, DC 20555-0001, AND TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE OF MANAGEMENT AND BtOGET, WASHINGTON, CC 20503.

FACILITY WAML (1) DOCKET WUMBER (2) PAGE (3)

RIVER BEND STATION 05000458 1 OF 6 TITLE (4) SURVEILLANCE TESTS FOR THE HIGH DRYWELL PRESSURE T!utR FUNCTION OF THE AU10MATIC DEPRESSURIZATION SYSTEM MAVE NOT l BEEN DEVELOPED PER TECFWICAL SPECIFICA DNS MONTH CAY YEAR YEAR MONTH CAY YEAR NUMBER NumsER 05000 i 06 03 93 93 --012- 01 08 26 93 '

0 0 OPE RATlWG THIS REPORT IS SUBMITTFD PURSUANT TO THE REQUIREMENTS OF 10 CIR i: (Check one or more) (11)

EDE (9) 20.402(b) 20.405(c ) 50.73(a)(2)(iv) 73.71(b)

POWER '

0 LEVEL (10) 20.405(a)(1)(ii) 50.36(c)(2) 50.73(a)(2H vii) OTHER 20.405(a)(1 )( n i ) X 50. 73(a n 2 H i ) 50. 73(a n 2 H vi i i M A) (Specify in 20.405(a)(1 H iv) 50.73(a)(2)(ii) 50.73(a)(2)(vi i i H B) "

]*C 20.405(a)(1 H v) 50. 73(a)(2)( i i i ) 50.73(a)(2)(x ) NRC Form 366A) tlCENSEE CONT ACT FOR THIS LER (12)

KAME TELEPHONE NUMBER (include Area Code)

DAVID N. LORFING, SUPERVISOR - NUCLEAR LICENSING (504) 381-4157 CIMPLETE ONE t INF FOR E ACH C[MPONENT FAltURE DESCRIBED IN THIS REPORT (13)

CAUSE SYSTEM COMPDAEkT MANUFACTURER CAUSE SYSTEM COMPOAE AT MANUFACTURER g

SUPPL E ME NT AL RE POR T FXPE LTfD (14) EXPECTED MONTH DAY YEAR TES SUBMISSION (if yes, ccmplete EXPECTED SUBMISSION DATE). X WO DATE (15)

ABSTRACT (Limit to 1400 spaces, i.e., apprcaimately 15 single-s. paced typewritten lines) (16)

On June 3.1993 with the plant in cold shutdown (Operational Condition 4), a deficiency in plant surveillance test procedures (STPs) was identified. During a logic system functional test review, it was discovered that the channel functional and channel calibration tests were not being performed as required by Technical Specifications. Therefore, this report is submitted pursuant to 10CFR50.73(a)(2)(i)(b) as operation prohibited by the Technical Specifications.

A change analysis was performed which revealed the primary causal factor was inattention to detail during the initial procedure development process. Surveillance test procedures, STP-051-4297 and STP-051-4244, were created to perform the channel calibration of the ADS drywell high pressure bypass timers "E" and "F STP-051-4597 and STP-051-4594 were created to perform the channel functional tests of these same timers. Following this event, these timers were verified to be functioning properly and within the Technical Specification allowable setpoint limits. Therefore, GSU is confident that these timers have been operable since the initial procedure development and the pre-operational system testing. GSU's review of STPs based on MIL STD 105E revealed additional surveillances that were not being performed or did not completely meet the requirements of TS. The performance of revised STPs and preventative maintenance work orders verified that all untested circuitry was satisfactorv.

hRC FORM 366 (5-92)

REQUIRED NUMBER OF DIGITS / CHARACTERS FOR EACH BLOCK BLOCK EDBER OF ESWER DIGITS / CHARACTERS IIIM 1 UP TO 46 FACILITY hAME y 8 TOTAL DOCKET NUMBER 3 IN ADDITION TO 05000 3 VARl[S PAGE NUMBER 4 UP TO 76 TITLE 5

6 TOTAL EVENT DATE 2 PER BLOCK 7 TOTAL 6 2 FOR YMR LER NUMBER 3 FOR SEQUENTIAL NUMBER 2 FOR REVISION NUMBER y 6 TOTAL REPORT DATE 2 PER BLOCK UP TO 18 -- FACILITY NAME 8 OTHER FACILITIES INVOLVED 8 TOTAL -- DOCKET NUMBER 3 IN ADDITION TO 05000

' 1 OPERATlWG MODE 10 3 F0WE R L E VE L 1

11 REQUIREMENTS OF 10 CFR CHECK Box THAT APPt!ES jy UP 10 50 FOR hAME LICENSEE CONTACT 14 FOR TELEPHohE CAUSE VARIES 2 FOR SYSTEM 13 4 F OR COMPONE NT EACH COMPONENT F AILURE 4 FOR MANUFACTURER WFRDS VARIES 14 I

CHECK Bar THAT APPLIES WLEMENTAL REPMT E XPECTED 6 TOTAL 15 EXPECTED SUBMISSION DATE 2 PER BLOCK i

i en.

4

s WRC FORM 366A U.S. NUCLEAR RIGRATC2Y CopenSSIC3 APPROVLD BY 0MB C3. 3150-0104 (5-92) EXP!RES 5/31/95 ESTlMATED BURDEN PER RESPONSE TO COMPLY WITH THIS IkTORMAT ION COLLECT 10N REcufST: 50.0 HRS.

FORWARD COMMENTS REGARDING BURDEN ESilMATE 10 LICENSEE EVENT REPORT (LER) isE INroRMAT!oN AND RECORDS MANAGEMENT BRANCH TEXT CONTINUATION m8B 771t.), u.S. NUCLE AR REGULATORY COMMISSION, WASHlWGTON, DC 20555-0001, AND TO THE PAPERWORK REDUCTION PROJE CT (3150 0104), OFFICE Of MANAGEMENT AND BUDGrT, WASHINGTON. DC P0503.

FACILITY MAME (1) '

DOCKET NtMitf R (2) IIR NtMBER (61 PAGI (3)

YE AR SE QUE NT I AL REVISION RIVER BEND STATION "

05000458 93 0 2 OF 6

-- 012 --

TINT (11 more space is required. use ark 1itional copies of NRC f orm 366A,} (Ir)

.itEPoltTED CONDITION On June 3,1993 with the plant in cold shutdown (Operational Condition 4), a deficiency in plant surveillance test procedures (STPs) was identified. During a logic system functional test review, it was discovered that the channel functional and channel calibration tests that verify the high dlywell pressure bypass timer function of the automatic depressurization system (ADS) were not being ,

performed for channels "E" and "F" .

Technical Specifications (TS) Table 4.3.3.1-1-A.2.g and 4.3.3.1-1.Il.2.f requires that a channel functional '

test be performed every month and that a channei calibration test be performed every quarter. It was discovered that these tests for channels "E" and "F" were not being performed. Therefore, this report is submitted pursuant to 10CFit50.73(a)(2)(i)(b) as operation prohibited by the Techmeal Specifications.  ;

This report documents 3 additional conditions identified during a review of STPs based on MIL STD i 105E. The first one was a failure to conduct a channel functional test on master trip units 1LSV*ESX9A(ll) and slave trip units ILSV*ESY9A(H) as required by TS 4.6.1.10.d.l. The second was a failure to completely test the isolation response time for portions of circuitry which isolate the valve IE22'MOVF023, the high pressure core spray (HPCS) test return to suppression pool, as required per  ;

TS 4.3.2.3 and Table 3.3.2-3. The third was a failure of STP-051-4807, STP-051-4808, STP-051-4809, and STP-051-4810 to perform a complete isolation response time for a portion of circuitry for several ,

Division I and Division Il valves. '

INVESTIGATION l A review of the STP program revealed that high drywell pressure bypass timers, lH21C-Kil4E and F, have not had a channel functional or channel calibration since the implementation of the STP program at itBS. Surveillance test procedures to perform these tests do not exist. Channels "A" and "B" of the high drywell bypass timers were properly tested as required by the Technical Specifications. Therefore, one channel in each trip system has not been tested throughout plant life. This review also found that i STP-051-4224 and STP-051-4225 did test to assure that the timers would operate every 18 months, but I did not include checking the calibration of the timer. The logic system functional test requirements of

, Technical Specification 4.3.3.2 for the ADS high drywell pressure bypass timers IH21C-K114E and F have been performed as required.

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l NRC FORM 366A (5 92)

I

CRC f 0RM 3664 U.S. NUCLEAR REWLATOR7 O[DMISSION APPROVED BY OMR CD. 3150-0104 (5-92) EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS.

FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO LICENSEE EVENT REPORT (LER) THE INFORMATION AND RECORDS MANAGEMENT BRANCH TEXT CONTINUATION (MNsB 7714), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555-0001, AND TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON, DC 20503.

FACILITY NAME (1) DOCKET NLMBER (2) ll R NtMBE R (61 PAGF (3) ygg SEQUENTIAL REVISION NUMBER NUMBER RIVER BEND STATION 05000458 3@ 6 93 -- 012 -- 01 TEXT (If more space is required, use additional copies of NRC form 3%A) (17)

The ADS system is designed to initiate on the combination of a low reactor water level I signal and a high drywell pressure signal. There are two independent trip systems (A and B). Each trip system is comprised of two independent channels. Trip system "A" contains channel "A" and channel "E", while trip system "B" contains channels "B" and "F" Initiation of ADS requires both channels of either trip system to receive a trip signal (ie., channels "A" and "E" or channels "B" and "F").

Within each channel (A, B, E, or F), three signals are required to provide an initiation signal. These are high drywell pressure, low reactor water level 1, and either a low pressure core spray (LPCS) pump  ;

running or a residual heat removal (RHR) pump running. If all three of these siguals are present then that channel will provide an initiation signal to its respective trip system (A or B). Channels "A" and '

"B" also require a confirmatory low level 3 signal.

In the event that there is a low reactor level 1 and level 3 for a duration of 5 minutes without a high  ;

drywell pressure signal, indicating a loss of coolant outside the drywell, the drywell pressure signal will be bypassed and ADS initiated. This is the function of the high drywell pressure bypass timers. These timers have contacts in parallel with the high drywell pressure contacts in the actuation logic which will close (thereby bypassing the normal drywell pressure contacts). This function is installed to depressurize the reactor and enable the lower pressure emergency core cooling systems (ECCS) to assist in making  ;

up a loss of coolant in situations where the loss of coolant will not cause a rise in drywell pressure (e.g.

leak outside the drywell). The 5 minute time delay is designed for automatic backup to operator action.

Channel functional tests of trip units ILSV*ESX9A(B) and ILSV'ESY9A(B) were not performed as required by TS 4.6.1.10.d.l. Master trip units 1LSV*ESX9A(B) and slave trip units ILSV*ESY9A(B) receive signals from transmitters ILSV'PT9A and 9B. The transmitters monitor LSV accumulator tank ILSV*TK6A(B) pressure and provides a signal to the trip units. ILSV*ESX9A(B) actuate on a minimum pressure in the accumulator tank (70 PSIG increasing) to provide a permissive to open PVLCS isolation valves ILSV*MOV11A(B),13A(B),15A(B),16A(B), and 19A(B). The slave trip units, ILSV*ESY9A(B) actuate on low pressure to enable the closing circuits of ILSV*MOVil A(B),

13A(B),15A(B),16A(B), and 19A(B). Loop calibrations of the transmitters and trip units have been performed every 18 months as required per TS; however, the monthly channel functional tests have not been performed. Two equipment qualification (EO) PMs were modified for the LSV*PT9A and 9B instrument loops to include a channel functional test and were performed successfully. I NRC FORM 366A (5-92)

l CRC FORM 3664 U.S. NCCLEAR REEJLMOY COMMISSIO APPRtNED BY UMB CD. 3150-0104 (5-92) FXPlRES 5/31/95

. ESTIMATED BL' N PER RESPONSE TO COMPLY WITH THIS DiFORMA1.ON COLLECTION REQUEST: 50.0 HRS.

FORWARD COMMENTS REGARDING BURDEN E ST IMATE TO LICENSEE EVENT REPORT (LER) THE INFORMATION AND RE CORDS MAhAGEMENT BRANCH TEXT CONTINUATION (nBB m4), u.s. NUCLEAR REGULATORY COMMISSION, ,

WASHINGT ON, DC 20555-0001, AND TO THE PAPERWORK i REDUCTION PROJECT (3150 0104), OFFICE OF MANAGEMENT AND BUDGET, WASHikGTON, DC 20503.

EACILITY NAME (1) DOCKET NUMBf R (?) L E R NUMBrR (6 ? PAGE (3) b YEAR NLNBER NUMBER RIVER BEND STATION 05000458 4 W6 93 -- 012 -- 01

~ TEXT (if more (pace is reovired, use additional copies of ARC Form 366A) (17)

The isolation response time for the circuitry which isolates valve 1E22*MOVF023, high pressure core ,

spray (HPCS) test return to suppression pool, was not tested as required per TS 4.3.2.3 and Table 3.3.2-3. The time response for the instrumentation is checked by STP-051-4811 and STP-051-4812 for reactor vessel level 2 actuation and STP-051-4813 and STP-051-4814 for high drywell pressure actuation, however each of them failed to include 2 relays in their test. Survellance test procedures, STP-051-4811 and STP-051-4813, were revised to include the entire circuit and performances demonstrated compliance with the TS requirements. It was not neccessary to revise and perform STP-051-4S12 and STP-051-4814 immediately since the portion of the circuits that were not tested by thea  ;

STPs were tested under the revised version of STP-051-4811 and STP-051-4813.

A review of the time response test for Division I and Division H ECCS was performed to determine if a similar problem existed as it did for the HPCS valve,1E22*MOVF023. Portions of the circuitry for i the following valves were also found to not be tested: lE12*MOVF021, IE12*MOVF024A&B, IE 12* MOVF011 A&B,1E21 *MOVF012, ISSR*SOV130, ISSR*SOV131,1 CPM

• MOV1 A&B, 2A&B, 3A&B, AND 4A&B. The time response for the instrumentation is checked by STP-051-4807 and STP-051-4808 for reactor vessel level 1 actuation, and STP-051-4809 and STP-051-4810 for high drywell pressure. Surveillance test procedure STP-051-4807 was revised to include in its test the circuitry that was . missing from the original time response test. This STP includes both Divisions and was performed successfully. Only STP-051-4807 was required to be performed since the circuitry that was missed in all 4 STPs is the same.

ROOT CAUSE A change analysis was performed which revealed the primary causal factor was inattention to detail during the initial procedure development process. Adequate verification that the STP program implemented all surveillance requirements would have prevented this condition.

A review of previous LERs for similarity revealed LER 88-010,89-003, 92-014,93-002, and 93-005. l Each of these LERs described conditions in which STPs failed to satisfy the surveillance requirements I as identified in the Technical Specifications. The events reported in LERs92-014 and 93 002 concerned inadequate overlap between STPs implementing LSFT requirements. Licensee event report 93-005, had a secondary causal factor that distinguishes it from LER 93-012. The event reported in LER 93-005 was a failure to include a monthly channel functional test in the STP for the RCIC steam '

flow - high timer function. The primary causal factor for LER 93-005 was failure to include the monthly channel functional in the original procedure NRC FORM 366A (5-92)

NRC FORM 3664 U.S. 8?JCLEAR REGULATCRY CO MIS $1C3 APPROVED BY OMB NO. 3150-0104 (5-92) EXPIRES 5/31/95 ESTIMATED DURDEN PE R RESPONSE TO COMPLY WITH THIS IkFORMATION COLLECTION RE QUE ST : 50.0 HRS.

FORWARD COMMENTS REGARDING BURDEN ESTIMATE 10 LICENSEE EVENT REPORT (LER) THE INFORMATION AND RECORDS MANAGEMENT BRANCH TEXT CONTINUATION (MNBB M 4), U.S. NUCLE AR REGULATORY COMMIS$10N, WASHINGTON, DC 20555-0001, AND TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE of MANAGEME NT AND BUDGET WASHINGTON. DC ?0503.

FACILITY WAME (1) DOCKET WlMBER (2) t rR lRMRFR (6'i PAGE (3)

TEAR SE W M OWW r l NPBER NUMBER RIVER BEND STATION 05000458 5 OF 6 93 -- 012 -- 01 TEXT Uf more space is required, use additional coDies of NRC Form 366A) (17) development. This is similar to the primary causal f actor for this event LER 93-012. Ilowever, LER 93-005 includes a secondary causal factor, the failure of personnel performing previous procedure reviews and revisions to identify this condition. The applicable STPs stated in their purpose sections that they satisfy the requirements for the monthly channel functional test; however, this statement was never verified in subsequent procedure revisions.

CORRECTIVE ACMONS l Surveillance test pr, :edures, STP-051-4297 and STP-051-4294, were created to perform the channel calibration of the ADS drywell high pressure bypass timers "E" and "F" STP-051-4597 and STP-051-4594 were created to perform the channel functional tests of these same timers.

l Surveillance test procedures. STP-051-4807, STP-051-4811, STP-051-4813 have been revised to include j all of the applicable isolation circuitry. STP-051-4808, STP-051-4809 STP-051-4810, STP-051-4812, and )

STP-051-4814 have been revised to include the relay time response.

I l Two STPs will be written to perform the monthly channel functional test on LSV*ESX9A(B) and ,

i LSV"ESY9A(B) by August 31,1993. Two equipment qualification (EO) PMs were modified for the '

LSV*PT9A and 9B instrument loops to include a channel functional test and were performed successfully.

A sampling of STPs based on MIL STD 105E has been performed against the Technical Specification I requirements. The purpose of this review was to provide a detailed technical review and determine the extent of STP inadequacies with respect to TS requirements. A total of 80 Technical specifications

( (approximately 10%) were reviewed and three were not properly implemented. This number of failures requires a review of all Technical Specifications for proper implementation. This review will be completed by January 31,1995.

SAFETY ASSESSMENT The TS surveillance requirements for channel functional and channel calibration were not satisfied for ADS drywell high pressure bypass timers IB21C-K114E and IB21C-K114F. Ilowever, surveillance test )

procedures, STP-051-4224 and STP-051-4225 did test to assure that the timers would operate every 18 months. In addition, these timers have been verified to be functioninj; properly and within the Technical Specification allowable setpoint limits. Therefore, GSU is confident that these timers have been operable since the initial procedure development and the pre-operational system testing.

I NRC FORM 366A (5-92)

NRC 70RM 3664 U.S. QJCLEAR REC 11LA10Y CapMISSIC APPROVED BY UMH CD. 3150 0104 (5-92) EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECT 10N RE QUEST: 50.0 HRS.

f0RWARD COMMENTS RE GARDING BURDEN EFi! MATE TO LICENSEE EVENT REPORT (LER) THE INFORMATION AND RECORDS MANAGE ME NT BRANCH TEXT CONTINUATION (MkBB 7714), U.S. NUCLEAR REGULATORY COMM15510N, WASHINGT ON, DC 2055!-0001, AND TO THE FAPERWDRK REDUCTION PRO.iE CT (3150-0104), OFFICE OF MANAGEMENT AND BUDGFT, WASHINGTOW, DC 20503, I ACII DY NAME (1) DOCXE T NtMHf R (?) (E R NtMil[R (61 PAGF (3)

YE AR SEQUENTIAL REVISION RIVER BEND STATION 05000458 6 OF 6 93 -- 012 -- 0 i

1 EXT (It more space is requirecf use widitional copics of NRC Form 366A) (17)

The additional STP deficiencies identified as a result of GSU's sampling progmm have been addressed by procedure n: visions and subsequent performances to demonstrate compliance with the TS for the components i in question. These were all satisfactory and pmvide confidence that these components were operable prior to the time of discovery.

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l NRC F0kM 366A (5-92)

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