05000461/LER-1996-001, :on 960110,isolation of Mechanical Vacuum Pumps on Main Steam Line High Radiation Signal Occurred.Caused by Lack of Clarity of Meaning of Note in Table 3.3.2-1. Procedure Revised
| ML20097D290 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 02/06/1996 |
| From: | Connell W, Johnson T ILLINOIS POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LER-96-001, LER-96-1, U-602543, WC-042-96, WC-42-96, NUDOCS 9602120295 | |
| Download: ML20097D290 (4) | |
| 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)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(1) |
| 4611996001R00 - NRC Website | |
text
'
lilinois Power Cornpany Clinton Power Station P.O. Box 678 Clinton. IL 61727 Tel 217 935-5623 Fax 217 935-4632 Wilfred Connell Vice President ILLIN915 u-6025c P&MR u5-95( 02-06 )LP 2C.220 February 6, 1996 WC-042-96 Docket No. 50-461 10CFR50.73 Document Control Desk Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Clinton Power Station - Unit 1 Licensee Event Report No. 96-001-00
Dear Sir:
Enclosed is Licensee Event Report No. 96-001-00: Failure to Perform Technical Specification Required Testing of the Trio and Isolation of the Mechanical Vacuum Pumps on a Main Steam Line High Radiation Signal. This report is being submitted in accordance with the requirements of 10CFR50.73.
Sincerely yours, 444 Wilfred Connell Vice President MRS/csm Enclosure cc:
NRC Clinton Licensing Project Manager NRC Resident Office, V-690 Regional Administrator, Region III, USNRC Illinois Department of Nuclear Safety INPO Records Center IMoh 0 II
-~. -. -
- NRC FORM 366 U.S. NUCLEAR RE2ULATORY COMMLSION AMooyto my oms NA st60mos 1
(4 95)
- ExPiRss 04/soss ESTIMATED BURDEN PER KESPONSE TO COMPLY WITH THIS MANDATORY I
INFORMATION COLLECTION REQUEST: 60.0 HRS.
REPORTED LESSONS LICENSEE EVENT REPORT (LER)
LEARNED ARE INCORPORATED INTO THE UCENSING PROCESS AND FED BACK TO INDUSTRY. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE 4
INFORMATION AND RECORDS MANAGEMENT BRANCH (76 F33),
U.S.
l NUCLE. R REOULATORY COMMISSION, WASHINGTON. DC 20666 0001, AND 4
I (See reverse for required number of TO THE PAPERWORK REDUCTION PROJECT (3160 4 104), OFFICE OF digate/ characters for each blocki MANAGEMENT AND BUDGET. WASHINGTON OC 20603.
^
F ActuiV N AME (1)
DOCKET NUMSWI(2)
PAGE(3)
Clinton Power Station 05000461 1 OF 3 i
TITLE 141 Failure to Perform Technical Specification Required Testing of the Trip and Isolation of the Mechanical Vacuum Pumps on a Main Steam Line High Radiation Signal EVEflT DATF (El LER NUMBER 18 l
RFpoit? DATH (71 OTHER FACIL1 IRES INV SLVED (R)
MONTH DAY YEAR YEAR stoVENTIAL REVISION MONTH DAY YEAR FACIUTY NAME D0CKET NUMBER NUM8ER NUMBER None 05000 01 05 96 96 001 00 02 06 96
' ^ " " " ^ " '
"" " U"
- E" None 05000 OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REoutREMENTS OF 10 CFR 5: (Check One Or rnore) (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) tEVEL (10) i 100 20.2203(a)(2)(il 20.2203(a)(3)(ii) 50.73(a)(2)(iii) 73.71 20.2203(a)(2)(ii) 20.2203(a)(4) 50.73fa)(2)(iv)
OTHER 20.2203(a)(2)(iii) 50.3 6(C)(1) 50.73(a)(2)(v)
Specify in Abstract below i
r in C Fonn 366A 20.2203(a)(2)(iv) 50.3 6(c)(2) 50.73(a)(2)(vii)
LicENEEE CONTACT FOR THis LEF r121 NAME TELEPHONE NUMBER (include Aree Codel T.
P.
Johnson, Project Specialist-Procedures (217) 935-8881, Extension 3649 I
COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRISED IN THIS REPORT (13) i
CAUSE
SYSTEM COMPONENT M ANUF AC T URER REPORTABLE
CAUSE
SYSTEM COMPONENT M ANUF ACT URER REPORTABLE I
l l
sg SUPPLEMENTAL REPORT EXPECTED (14)
EXPECTED MONTH DAY YEAR SUBMISSION DATE (15}
lYES X
NO
..w
.qlete EXPECTED SUBMISSION D ATEl.
ABSTRACT (Limn o 1400 spaces i.e. approximately 15 single spaced typewritten lines) (16)
On January 10, 1996, Illinois Power determined that testing that was required by plant Technical Specification section 4.3.2.2, for the main steam line high radiation trip and isolation of the mechanical vacuum pumps, was not periodically performed as required by the plant Technical Specifications that were in effect from September 29, 1986, until the requirement was removed from the plant Technical Specifications on January 1, 1995.
The cause of the event has been attributed to a lack of clarity of the meaning of a note in Table 3.3.2-2, CRVICS INSTRUMENTATION, of the plant Technical Specifications.
Since the note was in the section that describes what functions are part of the channel operability, it was not clear that this meant that the isolation and trip of the mechanical vacuum pumps on a main steam line high radiation signal was required to be periodically tested.
Corrective actions for this event include revising the proLedure to add the testing requirements, testing the mechanical vacuum pump trip and isolation on a main steam line high radiation signal and reviewing the plant Technical Specifications for similar occurrence of failure to implement testing requirements shown in a note.
NRCFORM 366 14 95)
-~
~
NRC FORM 362A U.S NUCLEAR RESULATORY COMMISSION 14-9 5)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FAcht ITY N AEAC fil DOcKFT l_ER NUMRER 00 PAGE f 31 YEAR SEQUENTIAL REVISION NUMBER NUMRFR Clinton Power Station 0500461 96 001 00 2
OF 3
TEXT lif more space is required, use additional copies of NRC Form 366A) (il)
DESCRIPTION OF EVENT
On January 5, 1996, the plant was in Mode 1 (POWER OPERATION) at about 100 percent reactor j
[RCT) power, a utility maintenance planner was researching the impact on plant operation of parf0rming maintenance work on the main steam line radiation monitors (MON).
During the review of this work, the maintenance planner noticed that Operational Requirements Manual (ORM) Table 3.2.16-1, CRVICS INSTRUMENTATION, which lists operability requirements for the main steam line high radiation monitor containment isolation trip functions has a note that states, "also trips and isolates mechanical vacuum pumps (P)."
The maintenance planner searched for the surveillance test procedure that tests the main steam line high radiation trip and isolation of the mechanical vacuum pumps. The maintenance planner was unable to find any plant procedures that tested this function of the main steam line high radiation monitors. The maintenance planner initiated Condition Report 1-96-01-017 to document that there were no procedures to test this function and to evaluate whether or not this function was required to be tested.
Investigation of this condition determined that the note in Table 3.2.16-1, CRVICS INSTRUMENTATION, of the ORM was meant to define the scope of the required functions for this instrument and thus define the scope of required testing of the mechanical vacuum pumps trip and isolation function. This testing is required as part of the logic system functional testing that is required to be performed every eighteen months by ORM Testing Requirement 4.2.16.4.
Review of testing records showed that the mechanical vacuum pump trip and isolation had been tested on August 9, 1985, as part of the preoperational test program.
No records could be found which documented that this feature had subsequently been tested. The investigation also revealed that this same note was included in plant Technical Specification Table 3.3.2-1, CRVICS INSTRUMENTATION, from initial issuance of the plant operating license until it was removed and relocated to the ORM by Amendment No. 95 to the Clinton Power Station (CPS) Technical Specifications.
This amendment to the CPS Technical Specifications became effective on January 1, 1995.
Therefore, testing of the mechanical vacuum pump trip and isolation on a main steam line high radiation signal was required by CPS Technical Specification section 4.3.2.2 every eighteen months from initial plant licensing on September 29, 1986, until implementation of Amendment No. 95 on January 1, 1995.
Since this testing was required to be performed every eighteen months, l
and testing of the trip and isolation of the mechanical vacuum pumps on a main steam line high radiation signal had not been performed since August 9, 1985, the failure to periodically perform this test constitutes a violation of the CPS Technical Specifications that were in effect prior to January 1, 1995.
On January 10, 1996, at 1445 hours0.0167 days <br />0.401 hours <br />0.00239 weeks <br />5.498225e-4 months <br />, the Shift Supervisor declared the main steam line high radiation trip and isolation of the mechanical vacuum pumps inoperable and determined that the condition was required to be reported in accordance with 10CFR50.73.
At about 2006 hours0.0232 days <br />0.557 hours <br />0.00332 weeks <br />7.63283e-4 months <br />, plant personnel began testing the trip and isolation of the mechanical vacuum pumps as required by the ORM.
At 2133 hours0.0247 days <br />0.593 hours <br />0.00353 weeks <br />8.116065e-4 months <br /> the testing was completed with satisfactory results and the main steam line high radiation trip function was declared operable.
NRC FORM 3{6A (4 95)
1 e
'U.S. NUCLEAR REGULATORY COMMISSION (4 95)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION
]
FActt ITY NauF fil DOcKFT LER NUMRFR M1 PAGE f 31 YEAR SEQUENTIAL REVISION NUMBER NUMRFR Clinton Power Station 0500461 96 001 00 3
OF 3
TEXT lif more space is required. use additional copies of NRC Form 366Al (11)
CAUSE OF EVENT
The cause of the event has been attributed to a lack of clarity of the meaning of a note in Table 3.3.2-1, CRVICS INSTRUMENTATION, of the plant Technical Specifications.
Since the note was in the section that describes what functions are part of the channel operability, it was not clear that this meant that the isolation and trip of the mechanical vacuum pumps on a main steam line high radiation signal was required to be periodically tested.
Consequently, the person that wrote the procedure that implements the required testing either did not see the note, or did not interpret it as a testing requirement, and so a surveillance test procedure was not prepared to test this function.
i
CORRECTIVE ACTION
i CPS procedure 9431.24, " Reactor Protection System Logic System Functional (Fuel Cycle #3),"
was revised to include testing of the trip and isolation of the mechanical vacuum pumps on a main steam line high radiation signal. The trip and isolation of the mechanical vacuum pumps on a main steam line high radiation signal was satisfactorily tested on January 10, 1996.
If the ORM continues to maintain the requirement to test the trip and isolation of the mechanical vacuum pumps on a main steam line high radiation signal the presentation of that requirement will be clarified.
Also, a review of the Technical Specifications will be performed to determine if there are any other notes or portions of the Technical Specification Bases which have not been properly interpreted as requiring testing of any equipment or functions cf equipment.
ANALYSIS OF THE EVENT
This event is reportable under the provisions of 10CFR50.73(a)(2)(1)(B) due to the failure to perform surveillance testing in accordance with the plant's Technical Specifications.
Assessment of the safety consequences and implications of this event indicates that this event was not nuclear safety significant. The surveillance testing performed after the condition was identified shows that the mechanical vacuum pump trip and isolation on a main steam line high radiation signal would have functioned as designed.
ADDITIONAL INFORMATION
No equipment or components failed as a result of this event.
Illinois Power has not reported any other events related to failure to perform the required surveillance testing due to lack of proper interpretation of a note in the plant Technical Specifications.
For further information regarding this event, contact T. P.
Johnson, Project Specialist-Procedures at (217) 935-8881, extension 3649.
NnC FORM 3G6A (4-95)