Text

LER 93-005-00:on 931011,due to Misinterpretation of TS 4.6.1.e.3.(a) Requirements,Verification of Load Shedding Capability of Safeguards Loads Not Adequately Performed. Testing Completed to Verify capability.W/931110 Ltr
	ML17263A466
Person / Time
Site:	Ginna
Issue date:	11/10/1993
From:	Mecredy R, St Martin J; ROCHESTER GAS & ELECTRIC CORP.
To:	Andrea Johnson; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
References
	LER-93-005, LER-93-5, NUDOCS 9311170036
	Download: ML17263A466 (22)
	v • d • e

ACCEI.ERAT@9 DOCUMENT DIST UTION SYSTEM REGULAT~ INFORMATION DISTRIBUTION STEM (RIDS)

ACCESSION NBR:9311170036 DOC.DATE: 93/11/10 ,NOTARIZED: NO DOCKET FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 AUTH. NAME AUTHOR AFFILIATION ST MARTIN,J.T. Rochester Gas a Electric Corp.

MECREDY,R.C. Rochester Gas & Electric Corp.

RECIP.NAME RECIPIENT AFFILIATION JOHNSON,A.R. Project Directorate I-3

SUBJECT:

LER 93-005-00:on 931011,due to misinterpretation of TS D 4.6.l.e.3.(a) requirements, verification of load shedding

'apability of safeguards loads not adequately performed.

Testing completed to verify capability.W/931110 ltr.

TITLE: 50.73/50.9 Licensee Event Report (LER),QIncidentQRpt, etc.

DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE: I ~

NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72). 05000244 D

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL D PDl-3 LA 1 1 PD1-3 PD 1 1 JOHNSON,A 1 1 1

INTERNAL: AEOD/DOA 1 1 AEOD/DSP/TPAB 1 1 AEOD/ROAB/DSP 2 2 NRR/DE/EELB 1 1 NRR/DE/EMEB 1 1 NRR/DORS/OEAB 1 1 NRR/DRCH/HHFB 1 1 NRR/DRCH/HICB 1 1 NRR/DRCH/HOLB 1 1 NRR/DRZL/RPEB 1 1 NRR/DRSS/PRPB 2 2 BASSA SPLB 1 1 NRR/DSSA/SRXB 1 1 REG ILE 02 1 ~ 1 RES/DSIR/EIB 1 1 RG FILE 01 1 1 EXTERNAL: EGSG BRYCEPJ.H 2 2 L ST LOBBY WARD 1 1 NRC PDR 1 1 NSIC MURPHY,G.A 1 1 NSIC POOREPW. 1 1 NUDOCS FULL TXT 1 1 D

D NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTEl CONTACI'HE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO, ELIMINATEYOUR NAME FROM DISTRIBUTION LISIS FOR DOCUMENTS YOU DON'T NEEDf r rvr r

FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 28 ENCL 28

'l jeylvm IgeZZaxri e ~ ~ ~ II C rrew "jr / 'g coen I]'jlj srArc j'J'ii'OCHESTER GAS AND ELECTRIC CORPORATION ~ 89 EAST AVENUE, ROCHESTER N. Y. 14649-0001 ROBERT C MECREDY TEi.EpHolr E Vice Preridenl AREA CODE 7 l6 546 2700 Cinna Nuclear Production November 10, 1993 U.S. Nuclear Regulatory Commission Attn: Allen R. Johnson Project Directorate I-3 Document Control Desk Nashington, DC 20555

Subject:

LER 93-005, Failure to Perform Surveillance, Due to Misinterpretation of Requirements, Causes a Condition Prohibited by Plant Technical Specifications R.E. Ginna Nuclear Power Plant Docket No. 50-244 In accordance with 10 CFR 50.73, Licensee Event Report System, item (a) (2) (i) (B), which requires a report of, "any operation or condition prohibited by the plant's Technical Specifications", the attached Licensee Event Report LER 93-005 is hereby submitted.

This event has in no way affected the public's health and safety.

Very truly yours, Robert C. Me redy xc: U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna USNRC Senior Resident Inspector 931117003b '7i31110 PDR ADOCK 05000244 S PDR

NRC FORH 366 U.S NUCLEAR REGULATORY COHHISSI ON APPROVED BY QLB NO. 3150-0104 (5-92) EXPIRES 5/31/95 ESTIHATED BURDEN PER RESPONSE TO COHPLY WITH THIS INFORHATION COLLECTION REOUEST: 50.0 HRS.

LICENSEE EVENT REPORT (LER) FORWARD COHMENTS REGARDING BURDEN ESTIHATE TO THE IHFORHATION AND RECORDS MANAGEHENT BRANCH (HNBB 7714), U.S. NUCLEAR REGULATORY COHHISSION, (See reverse for required number of digits/characters for each block) WASHIHGTON, DC 20555-0001 AND TO THE PAPERWORK REDUCTION PROJECT (3150 0104), OFFICE OF HANAGEMENT AND BUDGET WASHINGTON DC 20503.

FAcILITY NAME (1) R. E ~ Ginna Nuclear Power Plant DOCKET NQSER (2) PAGE (3) 05000244 1 OF 9 TITLE (4) Failure to Perform Surveillance, Due to Misinterpretation of Requirements, Causes a Condition Prohibited by Plant Technical Specifications EVENT DATE 5 LER NINBER 6 REPORT DATE 7 OTHER FACILITIES INVOLVED 8 SEQUENTIAL REVISION FACILITY NAME DOCKET NUMBER HONTH DAY YEAR YEAR NUMBER NUMBER HONTH DAY YEAR 05000 10 11 93 93 005 00 10 93 FACILITY NAME DOCKET NUMBER 05000 OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR: Check one or more 11 M<X)E (9) N 20.402<b) 20.405(c) 50 '3(a)(2)(iv) 73.71(b)

POWER 20.405(a )(1)(i) 50.36< c) (1) 50.73(a)(2)(v) 73.71(c) 097 LEVEL (10) 20.405(a)(1)<ii) 50.36(c)(2) 50.73(a)(2)(vii) OTHER 20.405(a)(1)(iii) )( 50.73(a)(2)(i) 50.73(a)(2)(viii)(A) (Specify in 20.405(a)(1)(iv) 50.73(a)(2)(ii) 50 '3(a)(2)(viii)(B)

Abstract below and in Text, 20.405(a)(1)(v) 50.73(a)(2)(iii) 50.73(a)(2)(x) NRC Form 366A LICENSEE CONTACT FOR THIS LER 12 NAHE John T. St. Hartin - Director, Operating Experience TELEPHONE NUHBER (Include Area Code)

(315) 524-4446 C<NPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT 13 REPORTABLE REPORTABLE CAUSE SYSTEH COMPONENT HANUFACTURER SYSTEH COMPONENT HANUFACTURER TO NPRDS TO NPRDS

';;ip:4:+I PQ+IPqx".'AUSE SUPPLEMENTAL REPORT EXPECTED 14 EXPECTED HONTH DAY YEAR YES SUBMISSION (I f yes, complete EXPECTED SUBMISSION DATE). X NO DATE (15)

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

On October 11, 1993, at 1330 EDST, with the reactor at approximately 97'.

full power, evaluation of surveillance testing procedures determined that Technical Specification 4.6.1.e.3.(a) requirements were misinterpreted.

Therefore, it was concluded that verification of load shedding capability of safeguards loads had not been adequately performed.

Immediate corrective action was initiated to complete testing that would verify this load shedding capability. This testing was completed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of discovery, achieving compliance with Technical Specification 4.6.1.e.3.(a) requirements.

The underlying cause of the failure to perform this surveillance was a misinterpretation of Technical Specification surveillance requirements.

(This event is NUREG-1220 (E) cause code.)

Corrective action was to perform the testing. Corrective action to preclude repetition is outlined in Section V (B).

NRC FORM 366 (5-92)

NRC FORM 366A U.S. NUCLEAR REGULATORY COHIISSION APPROVED BY OMB NO 3150-0104 (5-92) EXPIRES 5/31/95 ESTIHATED BURDEN PER RESPONSE TO COHPLY WITH THIS INFORHATION COLLECTION REQUEST: 50.0 HRS.

FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO LICENSEE EVENT REPORT (LER) THE INFORMATION AND RECORDS HANAGEHEHT BRANCH TEXT CONTINUATION (MNBB 7714), U.S. NUCLEAR REGULATORY COHMISSION, WASHINGTON, DC 20555-0001, AND TO THE PAPERWORK REDUCTION PROJECT (3150.0104), OFFICE OF MAHAGEHENT AND BUDGET WASHINGTOH DC 20503.

FACILITY NAME 1 DOCKET NUMBER 2 LER HIMBER 6 PAGE 3 YEAR SEQUENTIAL REVISION R.E. Ginna Nuclear Power Plant 05000244 93 -- 005-- 00 2 OF 9 t

TEXT (If more space is required, use additional copies of HRC Form 366A) (17)

PRE-EVENT PLANT CONDITIONS The plant was at approximately 979. steady state reactor power. An evaluation of surveillance test procedures was in progress, to address potential non-compliance with Technical Specification 4.6.1.e.3.(a) surveillance requirements to verify load shedding from the emergency buses.

II. DESCRIPTION OF EVENT A. DATES AND APPROXIMATE TIMES OF MAJOR OCCURRENCES:

1. October 11, 1993, 1330 EDST: Event date and approximate time.

2. October 11, 1993, 1330 EDST: Discovery date and approximate time.

3. October 11, 1993, 2037 EDST: Initiated testing to verify load shedding capability for loads on emergency bus 14.

4. October 12, 1993, 0441 EDST: Initiated testing to verify load shedding capability for loads on emergency bus 18.

5. October 12, 1993, 0447 EDST: Completed testing of load shedding for safeguards loads from emergency bus 14.

6. October 12, 1993, 0539 EDST: Completed testing of load shedding for safeguards loads from emergency bus 18. Load shedding was satisfactorily verified for the "A" train of safeguards equipment.

7. October 12, 1993, 0540 EDST: Initiated testing to verify load shedding capability for loads on emergency bus 17.

8. October 12, 1993, 0625 EDST: Completed testing to verify load shedding for safeguards loads from emergency bus 17.

9. October 12, 1993, 0626 EDST: Initiated testing to verify load shedding capability for loads on emergency bus 16.

NRC FORH 366A (5-92)

NRC FORM 366A U.S. NUCLEAR REGULATORY CQIIISSION APPROVED BY MB NO. 3150-0104 (5-92) EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY lllTH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS.

FORNARD COMMENTS REGARDING BURDEN ESTIMATE TO LICENSEE EVENT REPORT (LER) THE INFORHATION AND RECORDS MANAGEMENT BRANCH TEXT CONTINUATION (MNBB 7714), U.S. NUCLEAR REGULATORY COMHISSION, NASHINGTOH, DC 20555-0001 AND TO THE PAPERNORK REDUCTION PROJECT (3140-0104), OFFICE OF MANAGEMENT AND BUDGET IJASHINGTON DC 20503.

FACILITY NAME 1 DOCKET NINBER 2 LER NNBER 6 PAGE 3 YEAR SEQUENTIAL REVISION R.E. Ginna Nuclear Power Plant 05000244 M

93 -- 005-- 00 3 OF 9 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

10. October 12, 1993, 0716 EDST: "B" component cooling water (CCW) pump operability was indeterminate. The pump was declared inoperable and removed from service.

11. October 12, 1993, 0950 EDST: Completed testing of load shedding for safeguards loads from emergency bus 16. Load shedding was satisfactorily verified for the "B" train of safeguards equipment, except for the "B" CCW pump.

12. October 12, 1993, 1003 EDST: With the completion of testing for the "A" and "B" trains of safeguards equipment, compliance with Technical Specification 4.6.1.e.3.(a) was achieved.

13. October 12, 1993, 1939 EDST: "B" CCW pump declared operable.

B. EVENT:

On October 11, 1993, at approximately 1330 EDST, station and engineering staff confirmed that surveillance test procedures had not fully complied with the requirements of Technical Specification (TS) 4.6.1.e.3.(a), in that verification of load shedding of safeguards loads powered from the emergency buses (buses 14, 16, 17, and 18), while simulating a loss of offsite power in conjunction with a safety injection (SI) test signal, had not been performed as required. The guidance of NRC Generic Letter (GL) 87-09, entitled "Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements", was followed. Both the "A" and "B""

diesel generators (D/Gs) were available to perform all intended functions. Failure to perform the surveillance within the specified time interval constituted a non-compliance with the Operability Requirements of the Limiting Conditions for Operation (LCO).

NRC FORH 366A (5-92)

NRC FORM 366A U.S. NUCLEAR REGULATORY CQIIISSION APPROVED BY OMB NO. 3150-0104 (5-92) EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COHPLY NITH THIS INFORMATION COLLECTIOH REQUEST: 50.0 HRS.

FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO LICENSEE EVENT REPORT (LER) THE IHFORMATIOH AND RECORDS MANAGEMENT BRANCH TEXT CONTINUATION (MHBB 7714), U.S. NUCLEAR REGULATORY COMMISSION, MASHINGTON, DC 20555-0001 AND TO THE PAPERNORK REDUCTION PROJECT (3110-0104), OFFICE OF MANAGEMENT AND BUDGET NASHINGTON DC 20503.

FACILITY NAME DOCKET NUMBER 2 LER NINIBER 6 PAGE 3 SEQUENTIAL REVISION YEAR R.E. Ginna Nuclear Power Plant 005--

M M 05000244 93 00 4 OF 9 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

Surveillance testing to verify compliance with TS 4.6.1.e.3.(a) was initiated on October 11, 1993, at approximately 2037 EDST, with each emergency bus being tested sequentially. Testing for the "A" train of safeguards equipment (emergency buses 14 and

18) was completed at approximately 0539 EDST (on October 12, 1993), and testing for the "B" train (emergency buses 16 and

17) was completed at approximately 0950 EDST. Technical Specification compliance was achieved at approximately 1003 EDST.

During testing of the "B" train, resistance reading of a relay contact associated with the "B" CCW pump breaker Undervoltage Trip circuitry did not meet the specified acceptance criteria.

Despite having confidence that the higher resistance did not impede the "B" CCW pump load shedding feature, the station staff elected to declare the "B" CCW pump inoperable. The "B" CCW pump was removed from service, and the appropriate TS LCO was entered, until functional testing and/or corrective maintenance could verify acceptable circuit operation.

Subsequently, the "B" CCW pump breaker was racked into the test position, closed from the Main Control Board, and successfully trip tested by actuating the undervoltage circuitry. This test demonstrated acceptable load shedding capability. Following this verification of circuit operability, corrective maintenance was performed to improve circuit performance.

The corrective maintenance consisted of burnishing of an auxiliary relay contact in the pump trip circuitry. The corrective maintenance proved successful, with subsequent resistance readings meeting the acceptance criteria. The "B" CCW pump was restored to service and declared operable.

the functional trip test, 'which was successfully performed Note'hat prior to the corrective maintenance, demonstrated acceptable load shedding capability for the "B" CCW pump.

HRC FORM 366A (5-92)

lf NRC FORM 366A U.S. NUCLEAR REGULATORY CNHIISSIOH APPROVED BY W HO. 3150-0104 (5-92) EXP I RES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS.

FORMARD COMMENTS REGARD IHG BURDEH ESTIMATE TO LICENSEE EVENT REPORT (LER) THE INFORMATION AHD RECORDS MANAGEMENT BRANCH TEXT CONTINUATION (MHBB 7714), U.S. NUCLEAR REGULATORY COMMISSION, IIASHINGTON, DC 20555-0001 AHD TO THE PAPERISRK REDUCI'ION PROJECT (3140-0104), OFFICE OF MAHAGEMENT AHD BUDGET UASHIHGTON DC 20503.

FACILITY NAME 1 DOCKET NINSER 2 LER NIMBER 6 PAGE 3 YEAR SEQUENTIAL REVISION R.E. Ginna Nuclear Power Plant 05000244 93 005-- 00 5 OF 9 TEXT (If more space is required, use additional copies of HRC Form 366A) (17)

C~ INOPERABLE STRUCTURES i COMPONENTS i OR SYSTEMS THAT CONTRI BUTED TO THE EVENT:

None.

D. OTHER SYSTEMS OR SECONDARY FUNCTIONS AFFECTED:

None.

E. METHOD OF DISCOVERY:

This event was apparent after completion of an evaluation of TS RSSP 2 'i 4.6.1.e.3.(a) and RSSP 2 'Ai RSSP 2 'i surveillance test procedures (procedures PT-9.1.16, PT-9.1.17, and PT-9.1.18). This evaluation RSSP 19'SSP 20i PT 9 ' '4i determined that verification of load shedding capability of safeguards loads from the emergency buses had not been adequately performed.

F. OPERATOR ACTION:

The Control Room operators were notified of the failure to fully comply with the requirements of TS, and that the guidance of NRC GL 87-09 provided a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period to complete the required surveillance testing.

G. SAFETY SYSTEM RESPONSE:

None.

HRC FORM 366A (5-92)

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY m5/31/95 NO. 3150-0104 (5-92) EXPIRES ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECT ION REQUEST: 50.0 HRS.

FORWARD COMMENTS REGARD IHG BURDEN ESTIMATE TO LICENSEE EVENT REPORT (LER) THE INFORMATION AND RECORDS MANAGEMENT BRANCH TEXT CONTINUATION (MHBB 7714), U.ST NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555-0001 AHD TO THE PAPERWORK REDUCTION PROJECT (3140-0104), OFFICE OF MANAGEMENT AND BUDGET WASHINGTON DC 20503.

FACILITY NAME 1 DOCKET HLNBER 2 LER NUMBER 6 PAGE 3 YEAR SEQUENTIAL REVI SION R.E. Ginna Nuclear Power Plant 05000244 93 -- 005-- 00 6 OF 9 TEXT (lf more space is required, use additional copies of, NRC Form 366A) (17)

III. CAUSE OF EVENT A. IMMEDIATE CAUSE:

The immediate cause for failure to fully comply with requirements of TS was procedural deficiency, in that surveillance test procedures did not completely reflect the requirements of TS 4.6.1.e.3.(a).

B. ROOT CAUSE:

The underlying cause of the procedural deficiencies was a misinterpretation of TS surveillance requirements. TS 4.6.1.e.3.(a) had been previously interpreted that the load shedding capabilities required to be verified were for the non-essential loads powered from the emergency buses. This capability (for non-essential loads) has been tested by simulating a SI signal during performance of procedures RSSP-2.1 and RSSP-2.1A, which are performed each refueling outage.

The need to verify load shedding capabilities for safeguards loads, with both undervoltage and SI present, had not been considered in this interpretation. (This event is NUREG-1220 (E) cause code, Management/Quality Assurance Deficiency).

IV. ANALYSIS OF EVENT:

I This event is reportable in accordance with 10 CFR 50 Licensee Event Report System, item (a) (2) (i) (B), which

'3i requires a report of, "Any operation or condition prohibited by the plant's Technical Specifications". Failure to perform the surveillance to verify load shedding from the emergency buses for greater than 18 months is a condition prohibited by Ginna Technical Specifications.

NRC FORM 366A (5-92)

NRC FORM 366A U S. NUCLEAR REGULATORY CQNIISSION APPROVED BY W NO. 3150-0104 (5-92) EXP IRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORHATION COLLECTION REQUEST: 50.0 HRS.

FORWARD COMMENTS REGARDING BURDEN ESTIHATE TO LICENSEE EVENT REPORT (LER) THE INFORHATION AND RECORDS MANAGEHENT BRANCH TEXT CONTINUATION (MNBB 7714), U.S. NUCLEAR REGULATORY COMHISSION, WASHINGTON, DC 20555-0001 AND TO THE PAPERWORK REDUCTION PROJECT (3140-0104), OFFICE OF MANAGEMENT AND BUDGET WASHIHGTON DC 20503.

FACILITY NAME 1 DOCKET NUHBER 2 LER NIMBER 6 PAGE 3 SEQUENTIAL REVISION YEAR R.E. Ginna Nuclear Power Plant 05000244 93 005-- 00 7 OF 9 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

As stated in NRC GL 87-09, "Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0.2, shall constitute non-compliance with the OPERABILITY requirements for a Limiting Condition for Operation.

The time limits of the ACTION requirements are applicable at the time it is identified that a Surveillance Requirement has not been performed. The ACTION requirements may be delayed for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to permit the completion of the surveillance when the allowable outage time limits of the ACTION requirements are less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ."

An assessment was performed considering both the safety consequences and implications of this event with the following results and conclusions:

The requirement of TS 4.6.1.e.3.(a) is to simulate a loss of offsite power in conjunction with a safety injection test signal and verify de-energization of the emergency buses and load shedding from the emergency buses.

Performance of this surveillance is accomplished through a number of shutdown procedures: RSSP-2.1, RSSP-2.1A, RSSP-2.2, RSSP-19, RSSP-20, PT-9.1.14, PT-9.1.16, PT-9.1.17, and PT-9.1.18. An evaluation of these procedures indicated that the undervoltage load shedding of the following safeguards equipment was not being performed: safety injection (SI) pumps, residual heat removal (RHR) pumps, service water (SW) pumps, containment recirculation fans, and auxiliary feedwater (AFW) pumps. In addition, the undervoltage (in conjunction with SI signal) load shedding of the CCW pumps was not being performed. The procedures did verify the operability of the undervoltage relays, undervoltage system logic, and partially verified the operability of the undervoltage auxiliary relays. The procedures also verified the load shedding of all other emergency bus loads.

NRC FORM 366A (5-92)

NRC FORM 366A U.S. NUCLEAR REGULATORY CQOIISSION APPROVED BY QQI NO. 3150-0104 (5-92) EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY 'WITH THIS INFORMATION COLLECTIOH REQUEST: 50.0 HRS.

FORWARD COMMENTS REGARDIHG BURDEN ESTIMATE TO LICENSEE EVENT REPORT (LER) THE INFORMATION AND RECORDS MANAGEMENT BRANCH TEXT CONTINUATION (MHBB 7714), U.S. NUCLEAR REGULATORY COMMISSION@

WASHINGTON, DC 20555 0001 AHD TO THE PAPERWORK REDUCTION PROJECT (3140 0104), OFFICE OF MANAGEMENT AND BUDGET WASHINGTON DC 20503.

FACILITY NAME 1 DOCKET HIMBER 2 LER HIHIBER 6 PAGE 3 YEAR SEQUENTIAL REVISION R.E. Ginna Nuclear Power Plant 05000244 93 -- 005 00 8 OF 9 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

The testing performed on October 11 and 12, 1993 demonstrated end-to-end operability of the undervoltage protection system.

This testing verified undervoltage signals to all safeguards equipment, and undervoltage in conjunction with SI signals to the CCW pumps. This testing also verified full operability of the undervoltage auxiliary relays.

The testing, in combination with the surveillance tests conducted during the 1993 outage,.met the requirements of TS 4.6.1.e.3.(a). Based on the above, public's health and safety was assured at all times.

it can be concluded that the V. CORRECTIVE ACTION A. ACTION TAKEN TO RETURN AFFECTED SYSTEMS TO PRE-EVENT NORMAL STATUS:

O Testing was performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of discovery, and compliance with the requirements of TS 4.6.1.e.3.(a) was achieved.

B. ACTION TAKEN OR PLANNED TO PREVENT RECURRENCE:

o Procedures that verify load shedding capability will be upgraded to include safeguards loads, for conditions of undervoltage and SI, prior to the next scheduled refueling outage.

O The requirements of TS 4.6.1 have been reviewed and compared with surveillance procedures. No non-compliances were identified.

O A review of Section 4 of the Ginna Technical Specifications will be performed, to ensure that there are implementing procedures for every surveillance required by TS.

NRC FORM 366A (5-92)

NRC FORM 366A U.S. NUCLEAR REGULATORY C(NHISSIOH APPROVED BY OMB NO. 3150-0104 (5-92) EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY 'NITN THIS IHFORMATIOH COLLECTIOH REOUEST: 50.0 NRS.

FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO LICENSEE EVENT REPORT (LER) THE INFORMATION AND RECORDS MANAGEMENT BRANCH TEXT CONTINUATION (MHBB 7714), U.S. NUCLEAR REGULATORY COMHISSIOH ~

IJASHINGTON, DC 20555-0001 AHD TO THE PAPERMORK REDUCTION PROJECT (3140-0104), OFFICE OF MANAGEMENT AND BUDGET NASHIHGTON DC 20503.

FACI LIT'Y NAME 1 DOCKET NUMBER 2 LER NUMBER 6 PAGE 3 YEAR SEQUENTIAL REVISION R.E. Ginna Nuclear Power Plant 05000244 93 005-- 00 9 OF 9 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

VI. ADDITIONAL INFORMATION A. FAILED COMPONENTS:

None.

B. PREVIOUS LERs ON SIMILAR EVENTS.

A similar LER event historical search was conducted with the following results: No documentation of similar LER events with the same root cause at Ginna Nuclear Power Plant could be identified.

C. SPECIAL COMMENTS:

NRC GL 87-09 allows 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform a missed surveillance test, if the allowable outage time (AOT) of the LCO Action Requirements are less than this 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time limit, or when shutdown Action Requirements apply. This time limit is based balancing the risks between completing the required testing

'n and potentially challenging safety systems while performing shutdown actions. TS 4.6.1.e.3.(a) is normally required to be performed during shutdown conditions, since performing this surveillance removes the normal source of offsite power, which may cause electrical system disturbances. Rochester Gas &

Electric (RG&E) elected to perform the necessary testing at power, after evaluating the potential risks.

A review of existing testing procedures indicated that only specific portions of the load shedding capabilities were not being tested. RG&E determined that performance of the necessary voltage and continuity tests to verify these untested capabilities could be safely conducted at power. This is due to the fact that no safeguards loads on the buses would have to be declared inoperable, and no offsite power source would have to be removed from service to perform the tests. Therefore, performance of the necessary tests (at power) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of discovery was deemed appropriate.

HRC FORM 366A (5.92)

ML17263A466

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