ML17263A555
| ML17263A555 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 03/15/1994 |
| From: | Mccreredy 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-94-004, LER-94-4, NUDOCS 9403230032 | |
| Download: ML17263A555 (18) | |
Text
ACCELERATED DISTRIBUTION DEMONSTI'&TION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9403230032 DOC.DATE: 94/03/15 NOTARIZED: NO DOCKET g FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 AUTH. NAME AUTHOR AFFILIATION ST MARTIN,J.T. Rochester Gas & Electric Corp.
MCCREREDY,R.C Rochester Gas & Electric Corp.
'ECIP.NAME RECIPIENT AFFILIATION JOHNSON,A.J. Project Directorate I-2
SUBJECT:
LER 94-004-00:on 940214,Four surveillance test missed due to lack of Clearly defined interpertations of TS. D Intermediate Range bistable circuits reviewed to vertfy trip signal would deenergize reactor trip relay.W/940315 ltr. s DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE:
TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc.
NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72). 05000244 A D
RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL D PD1-3 PD 1 1 JOHNSON,A 1 1 INTERNAL AEOD/DOA 1 1 AEOD/DS P/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/DRIL/RPEB 1 1 NRR/DRSS/PRPB 2 2 SSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 EG FILED 02 1 1 RES/DSIR/EIB 1 1 RGN1 FILE 01 1 1 EXTERNAL EG &G BRYCE i J ~ H 2 2 L ST LOBBY WARD 1 1 NRC PDR 1 1 NSIC MURPHY,G.A 1 1 NSIC POORE,W. 1 1 NUDOCS FULL TXT 1 1 D
D D
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I Toec SSATC ROCHESTER GAS AND ELECTRIC CORPORATION ~ e9 EAST AVENUE, ROCHESTER N.K 14649-'0001 ROBERT C. MECREDY TELEPHONE Vice Psesidens AREA CODE 716 546 2700 Cinne Nucleei Pioducsion March 16, 1994 U.S. Nuclear Regulatory Commission Document Control Desk Attn: Allen R. Johnson Project Directorate I-3 Washington, D.C. 20555
Subject:
LER 94-004, Missed Surveillances, Due to Lack of Clearly Defined Interpretations of Technical Specifications Requirements, Resulted in Violations of 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 94-004 is hereby submitted.
This event has in no way affected the public's health and safety.
Very truly yours, iE~
Robert C. Mecredy xc: U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector enoz2poo3p eiso6s6 PDR ADOCK 05000244 PDR
NRC FORH 366 U.S. NUCLEAR REGULATORY C(NHISSION APPROVED BY NIB NO. 3150-0104 (5-'92) EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY HI TH THIS INFORHATION COLLECTION REQUEST: 5D.D HRS.
LICENSEE EVENT REPORT (LER) FORHARD COHHENTS REGARD ING BURDEN EST IHATE TO THE IHFORHAT ION AND RECORDS MANAGEHENT BRAHCH (HNBB 7714), U.S. NUCLEAR REGULATORY COMHISSIOH, (See reverse for required number of digits/characters for each block) HASHINGTON, DC 20555.0001 AND TO THE PAPERIQRK REDUCTION PROJECT (3150 0104), OFFICE OF MANAGEMEHT AHD BUDGET llASHIMGTON DC 20503.
FAGILITY KQK (1) R. E. Ginna Nuclear Power Plant DOCKET IRNBER (2) PAGE (3) 05000244 1 OF 15 TITLE (4) Hissed Surveillances, Due to Lack of Clearly Defined Interpretations of Technical Specifications Requirements, Resulted in Violations of Technical Specifications EVENT DATE 5 LER IkNBER 6 REPORT DATE 7 OTHER FACILITIES INVOLVED 8 SEQUENT IAL REVISION FACILITY NAME DOCKET NUMBER HOHTH DAY YEAR YEAR HONTH DAY YEAR NNIBER HUMBER 02 14 94 94 --004-- 00 03 16 FACILITY NAME DOCKET NUMBER OPERATING THIS REPORT IS SUBMITTED TO THE REQUIREMENTS OF 10 CFR : Check one or mor e 11 IHSE (9) N PURSUANT'0.402(b) 20.405(c) 50.73(a)(2)(iv) 73.71(b)
PNKR 20.405(a )(1)(i) 50.36(c)(1) 50.73(a)(2)(v) 73.71(c) 098 LEVEL (10) 20.405(a)(1)(ii) 50.36(c)(2) 50.73<a)(2)(vii) O'THER 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) 50.73(a)(2)(viii)(B) Abstract and in Text, below 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 NUMBER (include Area Cade)
(315) 524-4446
~LETE ONE LINE FOR EACH C(NPONENT FAILURE DESCRIBED IN THIS REPORT 13 REPORTABLE REPORTABLE CAUSE SYSTEH COMPONENT HAHUFACTURER CAUSE SYSTEH COMPOHEHT MAHUFACTURER TO NPRDS TO HPRDS QPPLEIKNTAL REPORT EXPECTED 14 EXPECTED HONTH DAY YEAR YES SUBMI SS ION (lf yes, complete EXPECTED SUBHISSIOH DATE) ~ DATE (15)
ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typeMritten lines) (16)
On February 14, 1994, at approximately 1000 EST, with the reactor at approximately 98% steady state power, the Plant Operations Review Committee determined that four surveillance tests had not fully complied with the requirements of Technical Specifications (TS).
Immediate corrective action was to confirm that four missed surveillances had been completed (or other methods used) to ensure that all TS requirements were fully complied with. Except for a test of a pushbutton for manual Containment Isolation actuation, necessary tests and/or verifications had been completed.
The underlying cause of the four missed surveillances was a lack of clearly defined interpretations of the TS wording for the four missed surveillances. (This event is NRC Performance Indicator Program cause code 5.8.1.)
Corrective action to preclude repetition is outlined in Section V (B).
NRC FORH 366 (5.92)
NRC FORH 366A U.S INCLEAR REGULAT(XIY CQNISSION APPROVED BY QHI NO. 3150-0104 (5-92) EXPIRES 5/31/95 EST INATED BURDEN PER RESPONSE TO COHPLY NITH THIS INFORHAT ION COLLECTION REQUEST: 50.0 HRS.
FORllARD CONNENTS REGARDING BURDEN EST IHATE TO LICENSEE EVENT REPORT (LER) TNE INFORNATION AND RECORDS NANAGENENT BRANCH TEXT CONTINUATION (NHBB 7714), U.ST NUCLEAR REGULATORY COHNISSIOHg UASHINGTON, DC 20555-0001 . AHD TO THE PAPERlNRK REDUCTION PROJECT (3110-0104), OFFICE OF NANAGEKENT AND BUDGET llASHINGTON DC 20503.
FACILITY K%K 1 DOCKET IRNBER 2 LER INFUSER 6 PAGE 3 YEAR SEQUENTIAL REVISION R.E. Ginna Nuclear Power Plant 05000244 94 004 00 2 OF 15 TEXT (tf more space is required, use additional copies of HRC Form 366A) (17)
I. PRE-EVENT PLANT CONDITIONS Rochester Gas and Electric (RG&E) formed a Technical Specifications Review Team in October, 1993, as a result of LER 93-005. (Refer to Ginna Docket No. 50-244, LER 93-005. See Section VI.C. of this report for details concerning the Review Team.) This Review Team reported their initial findings to the Ginna Station Plant Operations Review Committee (PORC) on February 14, 1994.. There were four issues discussed at the PORC meeting related to testing of the Nuclear Instrumentation System (NIS) Inter-mediate Range trip bistables, 480V Bus Undervoltage System, Reactor Trip Breaker Logic Channels, and the Containment Isolation system.
The plant was at approximately 984 steady state reactor power at the time of the PORC meeting, and there were no activities in progress related to the review of these four issues.
II. DESCRIPTION OF EVENT A. DATES AND APPROXIMATE TIMES OF MAJOR OCCURRENCES:
- 1. May 11, 1992, 0405 EDST: Initial startup from the 1992 refueling outage. Testing performed during the outage did not fully comply with the requirements of Technical Specifications (TS) for the 480V Bus Undervoltage System. Event date and time.
- 2. April 25, 1993, 0600 EDST: Initial startup from the 1993 refueling outage. Testing performed during the outage did not fully comply with the requirements of TS for the Reactor Trip Breaker Logic Channels and manual Containment Isolation actuation. Event date and time.
- 3. November 22, 1993, 0542 EST: Initiated reactor startup after a brief maintenance outage. Surveillance testing related to NIS Intermediate Range trip bistables did not fully comply with the requirements of TS. Event date and time.
HRC FORH 366A (5-92)
NRC FORH 366A U.S. i)CLEAR REGULATORY CQIIISSION APPROVED BY (INI NO. 3150-0104 (5-92) EXP I RES 5/31/95 ESTIHATED BURDEN PER RESPONSE TO COHPLY llITH THIS INFORHATIOH COLLECTION REQUEST: 50.0 HRS.
FORllARD COHHENTS REGARDING BURDEN ESTIHATE TO LICENSEE EVENT REPORT (LER) THE INFORHATIOH AND RECORDS HAHAGEHEHT BRANCH TEXT CONTINUATION (HNBB 7714), U.S. NUCLEAR REGULATORY CDHHISSION, llASHINGTOH, DC 20555-0001 AND TO THE PAPERIJORK REDUCTIOH PROJECT (3140.0104), OFFICE OF HANAGEHENT AND BUDGET WASHINGTON DC 20503.
FACILITY IWK 1 DOCKET IRNBER 2 LER IRNBER 6 PAGE 3 YEAR SEQUENT IAL REVISION R.E. Ginna Nuclear Power Plant 05000244, OF.15 94 -- 004-- pp 3 TEXT (lf more space is required, use additional copies of NRC Form 366A) (17) 4 ~ February 14, 1994, 1000 EST: The PORC determined that testing of the NIS Intermediate Range trip bistables, 480V Bus Undervoltage System, Reactor Trip Breaker Logic Channels, and the Containment Isolation system had not fully complied with the requirements of TS. Discovery date and time.
1 5~ February 14, 1994, 1000 EST: The PORC determined that testing and/or verification of functionality of the NIS Intermediate Range trip bistables, 480V Bus Undervoltage System, and Reactor Trip Breaker Logic Channels, to fully comply with the requirements of TS, had been successfully completed since the identified event dates.
- 6. February 14, 1994, 1000 EST: One pushbutton for manual Containment Isolation actuation was declared inoperable and the Action Statement for TS Table 3.5-2, No. 4.1.a was entered.
7 ~ February 14, 1994, 1400 EST: RG&E verbally requested NRC Enforcement Discretion related to the failure to test one pushbutton for manual Containment Isolation actuation.
8 ~ February 14, 1994, 1520 EST: RG&E received verbal notification of NRC Enforcement Discretion, provided RG&E also submit a written request.
9 ~ February 15, 1994, 1200 EST: RG&E submitted written request for NRC Enforcement Discretion.
- 10. February 16, 1994, 1256 EST: RG&E received a facsimile notification, which documented that the NRC would exercise Enforcement Discretion, not to enforce compliance with the requirements of TS Table 4.1-2, No. 9, until 2400 EST on March 6, 1994
'RC FORH 366A (5-92)
NRC FORH 366A U.S. IN)CLEAR REGULATORY CQNIISSION APPROVED BY QNI NO. 3150-0104 (5.92) EXPIRES 5/31/95 ESTINATED BURDEN PER RESPONSE TO CONPLY IIITH THIS INFORNATIOH COLLECTION REQUEST: 50.0 HRS.
FORMARD COHHEHTS REGARDIHG BURDEN ESTIHATE TO LICENSEE EVENT REPORT (LER) THE INFORNATIOH AND RECORDS NANAGEHENT BRANCH TEXT CONTINUATION (NHBB 7714), U.S. NUCLEAR REGULATORY CONHISSION ~
llASHINGTOH, DC 20555-0001 AND TO THE PAPERUORK REDUCTION PROJECT (3140 0104), OFFICE OF HANAGEHENT AHD BUDGET 'WASHINGTON DC 20503.
FACILITY IWK 1 DOCKET IRMBER 2 LER IRNSER 6 PAGE 3 YEAR SEQUEHTIAL REVISION R.E. Ginna Nuclear Power Plant 05000244 94 -- 004-- 00 .4 OF 15 TEXT (lf more space is required, use additional copies of NRC Form 366A) (17)
B. EVENT:
RG&E formed a Technical Specifications Review Team in October, 1993.
This team was directed to perform a review of the surveillance requirements contained in TS Section 4 to ensure that there are implementing procedures for every surveillance required by TS. The Review Team completed this review. RG&E expanded the scope of the team to review the identified implementing procedures related to TS Section 4, to ensure that these procedures do, in fact, implement the TS requirements.
On February 14, 1994, at approximately 1000 EST, the Review Team presented their initial findings to the PORC. The PORC reviewed the initial findings of the Review Team, and determined that four violations of the TS had occurred. The PORC confirmed that surveillance test procedures had not fully complied with the requirements of TS Section 4 and notified the NRC Senior Resident Inspector. Since all four TS violations were identified at the same time and by the same method and are the result of the same root cause, the four issues are documented in this Licensee Event Report.
The four violations are described below:
- 1. TS Table 4.1-1, No. 2 (Nuclear Intermediate Range) The TS requires a test of the NIS Intermediate Range trip bistables prior to startup. Procedure PT-6.2, "NIS Intermediate Range Channels", performs this test by independently testing various sections of the channels, but does not verify that the trip signal will deenergize the reactor trip relay when the trip bistable setpoint is reached. Therefore, the PORC determined that the requirements of TS Table 4.1-1, No. 2, were not fully complied with prior to reactor startups.
HRC FORH 366A (5-92)
NRC FORN 366A U.S NUCLEAR REGULATORY CQIIISSION APPROVED BY QIB NO 3150-0104 (5.92) EXPIRES 5/31/95 ESTIHATED BURDEN PER RESPONSE TO COHPLY 'ARITH THIS INFORHATIOH COLLECTIOH REQUEST: 50.0 HRS.
FORHARD CONNENTS REGARDING BURDEN ESTIHATE TO LICENSEE EVENT REPORT (LER) THE IHFORNATION AND RECORDS NAHAGENENT BRANCH TEXT CONTXNUATZON (NHBB 7714), U.S. NUCLEAR REGULATORY CONNISSIOH, WASHINGTON, DC 20555-0001 AHD TO THE PAPERNORK REDUCTION PROJECT (3140 0104), OFFICE OF NAHAGEMENT AND BUDGET l!ASHINGTOH DC 20503.
FACILITY KAID 1 DOCKET IRNIBER 2 LER NNBER 6 PACE 3 SEQUENT I AL REVISIOH YEAR R.E. Ginna Nuclear Power Plant 05000244 94 004-- 00 5 OF 15 TEXT (If more space is reqUired, use additional copies of NRC Form 366A) (17) 2 ~ TS Table 4.1-1, No. 30 (Loss of Voltage/Degraded Voltage on 480 Volt Safeguards Bus) The TS requires.a monthly Channel Functional Test (CFT) of the Undervoltage (UV) system. A CFT is defined in TS Section 1.7.3 as verifying the "operability including alarm and/or trip functions." The UV system contains logic cards located between the UV relays and associated auxiliary relays which are used to shed the loads from each safeguards bus. Due to their location in the circuit, failure of the logic cards could prevent actuation of the auxiliary relays and prevent operation of the UV system. Monthly surveillance test procedures have been performed, but testing of the, logic cards has not been regularly performed as a part of these procedures. Therefore, the PORC determined that the requirements of TS Table 4.1-1, No. 30, were not fully complied with on a monthly basis.
- 3. TS Table 4.1-1, No. 38A and No. 38B (Trip Breaker Logic Channel Testing) Procedures PT-32A-SD, "Reactor Trip Logic Test "A" Train" and PT-32B-SD, "Reactor Trip Logic Test "B" Train", are performed during each refueling shutdown, to'omply with the requirements of TS Table 4.1-1, No. 38B. Procedures PT-32A, "Reactor Trip Breaker Testing - "A" Train", and PT-32B, "Reactor Trip Breaker Testing "B" Train", are performed for each train, on an alternate monthly basis, to comply with the requirements of TS Table 4.1-1, No. 38A. These four procedures fully implement the requirements of TS Table 4.1-1, No. 38A and No. 38B, with one exception.
The Review Team identified that PT-32A and PT-32B verify Main Contxol Board annunciation for the trip logics, and PT-32A-SD and PT-32B-SD do not. PT-32A and PT-32B are performed for each train, on an alternate monthly basis, during power operation. This verification also complies with the refueling outage frequency for testing as specified in TS Table 4.1-1, No. 38B.
HRC FORN 366A (5 92)
NRC FORM 366A U.S NUCLEAR REGULATORY C(SCISSION APPROVED BY QNI NO. 3150-0104 (5-92) EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY lllTH THIS INFORMATION COLLECTION REQUESTs 50.0 HRS.
FORllARD COMMENTS REGARDIHG BURDEN ESTIMATE TO LICENSEE EVENT REPORT (LER) THE INFORMATION AND RECORDS MANAGEMENT BRANCH TEXT CONTINUATION (MNBB 7714), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555-0001 AHD TO THE PAPERHORK REDUCTIOH PROJECT (3140.0104), OFFICE OF MANAGEMENT ANO BUDGET MASHIHGTON DC 20503.
FACILITY NAIF 1 DOCKET NMBER 2 LER NMBER 6 PAGE YEAR SEQUENT 1AL REVISION R.E. Ginna Nuclear Power Plant 05000244 6 OF 15 94 pp TEXT (If more space is required, use additional copies of HRC Form 366A) (17)
Due to plant conditions, procedures PT-32A-SD and PT-32B-SD (and not PT-32A and PT-32B) are performed prior to startup. Note 2 for TS Table 4.1-1, No. 38A, specifies that the reactor trip breaker logic channel testing "shall be performed prior to startup if testing has not been performed with the last 30 days."
Therefore, the PORC determined that performance of PT-32A-SD and PT-32B-SD prior to startup does not fully comply with the requirements of TS Table 4.1-1, No. 38A, when PT-32A and PT-32B have not been performed within the last 30 days.
- 4. TS Table 4.1-2, No. 9 (Containment Isolation Trip) The TS requires a test each refueling shutdown to ensure that the Containment Isolation Trip is "functioning". The automatic Containment Isolation trip function is tested every refueling outage by procedure RSSP 2.1, "Safety Injection Functional Test".
-TS Table 3.5-2, No. 4.1 defines the Containment Isolation function as:
4.1.a Manual 4.1.b Safety Injection (Auto Actuation)
The Review Team could not identify a periodic test procedure that tested the individual pushbuttons for manual Containment Isolation actuation. One pushbutton for manual Containment Isolation actuation was utilized to actuate Containment Isolation during the 1993 Containment Integrated Leak Rate Test (ILRT).
The PORC determined that failure to perform the surveillance on the other pushbutton within the specified time interval constituted a non-compliance with the Operability Requirements of the Limiting Conditions for. Operation (LCO) . The PORC notified the Control Room operators, and the Action Statement for TS Table 3.5-2, No. 4.1.a, was entered at approximately 1000 EST on February 14, 1994. The Action Statement required restoration of the inoperable channel to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in Hot Shutdown within an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and at Cold Shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
NRC FORM 366A (5.92)
NRC FORM 366A U.S. NUCLEAR REGULATORY CaMIISSIOM APPROVED 8'r QQ HO. 315D-01D4 (5-92) EXP I RES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY IIITH THIS INFORMATION COLLECTIOH REOUEST: 50.0 HRS.
FORMARD COMMENTS REGARDIHG BURDEN ESTIMATE TO LICENSEE EVENT REPORT (LER) THE INFORMATION AMD RECORDS MANAGEMENT BRANCH TEXT CONTINUATION (HMBB 77'l4), U.S. NUCLEAR REGULATORY COMMISSIONS MASHINGTOH, DC 20555 0001 AMD TO THE PAPERMORK REDUCTION 'ROJECT (31/0-0104), OFFICE OF MANAGEMENT AND BUDGET llASHINGTON 'DC 20503.
FACILITY KAID 1 DOCKET NtNBER 2 LER IRMBER 6 PAGE 3 YEAR SEQUENTIAL REVISION R.E. Ginna Nuclear Power Plant 05000244 94 -- 004-- 00 7 OF 15 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)
Following a review of electrical drawings, the necessary test has the potential for challenging both trains it was concluded that of engineered safety features. RG&E requested NRC Enforcement Discretion to delay testing of the manual pushbutton until the refueling outage. RG&E received a facsimile of documented notification that the NRC would exercise Enforcement Discretion on February 16, 1994, at approximately 1256 EST.
C. INOPERABLE STRUCTURES i COMPONENTS i OR SYSTEMS THAT CONTRI BUTED TO THE EVENT:
None DE OTHER SYSTEMS OR SECONDARY FUNCTIONS AFFECTED:
None E. METHOD OF DISCOVERY:
RG&E formed a TS Review Team in October, 1993, to review TS Section 4 to ensure that there are implementing procedures for every surveillance required by TS, and to review the identified implementing procedures to ensure that these procedures do, in fact, implement the TS requirements. The Review Team reported their initial findings to the PORC on FebruaryTS 14,had 1994. The PORC determined that four violations of the occurred.
F. OPERATOR ACTION:
The PORC notified the Control Room operators of the failure to pushbutton for manual Containment Isolation actuation. The test'ne Control Room operators declared one pushbutton for manual Containment Isolation actuation inoperable at approximately 1000 EST on February 14, 1994, in accordance with TS Table 3.5-2, No. 4.1.a.
The 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Limiting Condition For Operation was subsequently extended to 2400 EST on March 6, 1994, by the exercise of NRC Enforcement Discretion.
HRC FORM 366A (5-92)
NRC FORH 366A U.S. NUCLEAR REGULATORY CQIIISS ION APPROVED BY (NB NO. 3150-0104 (5-92) EXPIRES 5/31/95 EST INATED BURDEN PER RESPONSE TO CONPLY MITH THIS INFORHATION COLLECT ION REQUEST! 50.0 HRS ~
FORNARD CONHENTS REGARD IHG BURDEN EST INATE TO LICENSEE EVENT REPORT (LER) THE INFORNATION AND 'RECORDS HAHAGENEHT BRANCH (NHBB 7714), U.ST NUCLEAR REGULATORY CONHISSIOH, TEXT CONTINUATION NASHINGTOH, DC 20555-0001 AND TO THE PAPERNORK REDUCTION PROJECT (3140-0104), OFFICE OF NANAGENEHT AND BUDGET MASHINGTON DC 20503.
FACILITY IWK 1 DOCKET IRMSER 2 LER NOR 6 PACE 3 SEQUENT I AL REVI SION YEAR R.E. Ginna Nuclear Power Plant 8 OF 15 05000244 94 -- 004-- pp TEXT (If more space is required, use additional copies of NRC Form 366A) (17)
G. SAFETY SYSTEM RESPONSES:
None III'AUSE OF EVENT A. IMMEDIATE CAUSE:
The immediate cause of the four missed surveillances was failure to perform testing to fully comply with the requirements of TS. The PORC concluded that the four identified tests are required by TS Section 4, and tests previously conducted did not fully comply with the requirements of TS.
B. ROOT CAUSE:
The underlying cause of the failure to fully comply with TS requirements was a lack of clearly defined interpretations of the TS wording for the four issues identified by the Review Team. The wording of the,TS requirements and bases for these four issues are ambiguous, such that there is interpretation required to ensure full compliance with the TS requirements.
This event is NRC Performance Indicator Program cause code 5.8.1, Administrative Control Problem. There is no NUREG-1022 cause code that accurately classifies this root cause. The closest would be NUREG-1022 (X) cause code, "Other", because the proximate cause has been identified, and this cause (lack of clearly defined interpretation of TS wording) cannot be assigned to one of the five classifications listed in NUREG-1022, Appendix B.
HRC FORN 366A (5.92)
366A U.S IRICLEAR REGULATORY COHI SSI OH APPROVED BY QQ NO. 3150-0104 NRC FDRH EXP I RES 5/31/95 (5.92)
ESTIHATED BURDEN PER RESPONSE TO COHPLY IIITN THIS INFORHATION COLLECTION REOUEST: 50.0 NRS.
FORllARD CDHHENTS REGARDING BURDEN ESTIHATE TO LICENSEE EVENT REPORT (LER) THE INFORHATION AND RECORDS HANAGEHENT BRANCH (HNBB 7714), U.S. NUCLEAR REGULATORY COHHISSIONg TEXT CONTINUATION MASHINGTON, DC 20555-0001 AND TO THE PAPERlJORK REDUCTION PROJECT (3140-0104), OFFICE OF HANAGEHENT AND BUDGET l!ASNINGTON DC 20503.
FACILITY KAID 1 DOCKET NEER 2 LER NLNBER 6 PAGE 3 SEOUENTIAL REVISION YEAR R.E. Ginna Nuclear Power Plant 05000244 94 004-- f 00 9 OF 15 TEXT (lf more space is required, use additional copies of NRC Form 366A) (17)
IV. ANALYSIS OF EVENT This event is reportable in accordance with 10 CFR 50.73, Licensee"Any Event Report System, item (a) (2) (i) (B), which requires a report of, operation or condition prohibited'y the plant's Technical Specifications". The four issues identified by the Review Team were determined by the PORC to be failures to fully comply with the surveillance requirements of TS Table 4.1-1, No. 2=, No. 30, and No., 38A,the and TS Table 4.1-2, No. 9. This constitutes a condition prohibited by Ginna TS.
An assessment was performed considering both the safety consequences and implications of not fully complying with the requirementsconclusions: of TS for the four .identified issues, with the following results and A. The failure to fully comply with the surveillance requirements for the NIS Intermediate Range trip bistables did not affect the public's health and safety because:
~ The NIS Intermediate Range trip signal will deenergize the reactor trip relay when the trip bistable setpoint is reached.
Verification that a trip signal would deenergize the reactor trip relay when the trip bistable setpoint is reached can be accomplished by confirming that Main Control Board status lights are appropriately illuminated, when the NIS Intermediate Range is tripped at power.
~ Operators verify these status lights every shift,,per procedure 0-6.13, "Daily Surveillance Log". This verification was performed immediately following the startup from the brief maintenance outage in November, 1993, and continues to be performed every shift. No failure of the status lights (and the continuity from the trip bistable to the reactor trip relay) has been observed.
~ There are no active components located between the trip bistable and the reactor trip relay. There is a high degree of reliablity that continuity exists.
NRC FORH 366A (5-92)
NRC FORK 366A U.S. IN)CLEAR REGULATORY C(HHIISSI ON APPROVED BY (HHI HO 3150-0104 (5-92) EXPIRES 5/31/95 ESTIMATED BURDEN PER, RESPONSE TO COMPLY 'WITH THIS IHFORKATIOH COLLECTIOH REQUEST: 50.0 MRS.
FORIIARD COKHEHTS REGARDIHG BURDEN ESTIMATE TO LICENSEE EVENT REPORT (LER) THE IHFORKATIOH AMD RECORDS KAMAGEKEHT BRANCH TEXT CONTINUATION (KHBB 7714), U.S. NUCLEAR REGULATORY COMMISSION, llASHIMGTOH, DC 20555-0001 AMD TO THE PAPERNORK REDUCTION PROJECT (3110-0104), OFFICE OF KAMAGEKEHT AMD BUDGET llASHIMGTOM DC 20503.
FACILITY IWK DOCKET IRNSER 2 LER IRNBER 6 PAGE 3 YEAR SEQUENTIAL REVISION R.E. Ginna Nuclear Power Plant 05000244 94 -- 004 00 10 OF 15 TEXT (lf more space is required, use additionaL copies of NRC Form 366A) (17)
B. The failure to fully comply with the surveillance requirements for the 480V Bus Undervoltage System did not affect the public's health and safety because:
~ Prior to January 13, 1994, the UV logic cards were tested on an annual basis as part of the diesel generator autostart UV logic tests.
The UV logic cards had been tested by upgraded procedures on January 13, 1994. Consequently, the logic cards were tested within the required one month surveillance interval at the time of discovery.
~ The logic cards are replaced and/or refurbished every four years as part of the Reliability Centered Maintenance (RCM) Program.
Four years is less than the Mean Time Between Failure (MTBF) for these components. Therefore, the logic cards could be expected to perform their function if needed.
C. The failure to fully comply with the surveillance requirements for the Reactor Trip Breaker Logic Channels did not affect the public's health and safety because:
~ Sufficient procedural guidance exists in the Emergency Operating Procedures which provide instructions for operators in the event that expected annuciator windows do not acknowledge a reactor trip.
~ One train of the Reactor Trip Breaker Logic Channels is tested each month during power operation, on an alternate monthly basis, such that each train is tested every two months. Consequently, there was at most one month in which the annunciators for both trains of reactor trip breakers were not tested and two months in which the annunciator for one train was not tested.
~ Verification of the Main Control Board annunciation was accomplished by the performance of procedures PT-32A and PT-32B in the first two months after the 1993 refueling outage.
NRC FORK 366A (5-92)
NRC FOHN 366A U.S. NJCLEAR REGULATORY CQBIISSIQI APPROVED BY (WB NO. 3150-0104 (5-92), EXPIRES 5/31/95 EST IHATED BURDEN PER RESPONSE TO COHPLY MITH THIS INFORHAT ION COLLECT ION REOUEST: 50.0 HRS.
FORNARD CONHENTS REGARD IHG BURDEN EST IHATE TO LICENSEE EVENT REPORT (LER) THE IHFORHAT ION AHD RECORDS NAHAGENENT BRANCH TEXT CONTINUATION (HNBB 7714), U.S. NUCLEAR REGULATORY CDNNISSION ~
NASHINGTOH, DC 20555-0001 AHD TO THE PAPERIJORK REDUCTION PROJECT (3140 '104), OFFICE OF NANAGEHENT AND BUDGET lJASHINGTON DC 20503.
FACILITY NAIL 1 DOCKET NAKER 2 LER IRNBER 6 PAGE 3 YEAR SEQUENTIAL REVISIOH R.E. Ginna Nuclear Power Plant 05000244, 94 -- 004-- 00 11 OF 15 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)
D. The failure to fully comply with the surveillance requirements for manual Containment Isolation actuation did not affect the public's health and safety because:
~ Manual Containment Isolation is a backup that would be needed if two independent automatic Containment Isolation actuation channels (from Safety Injection) failed.
~ One of the two manual Containment Isolation pushbuttons had been verified to be operable during the 1993 .refueling outage. This pushbutton actuates both trains of Containment Isolation.
~ All automatic Containment Isolation valves had been verified to be operable by stroke testing, and therefore there was high confidence that the operators could remotely close all affected Containment Isolation valves from the Control Room, if required.
~ Based on the simple mechanical design of the pushbutton, there is a reasonable degree of confidence that the pushbutton will operate if required.
~ The NRC concurred with RG&E's assessment, and exercised Enforcement Discretion for this issue on February 16, 1994.
Based on the above, safety was assured at all times.
it can be concluded that the public's health and NRC FORH 366A (5-92)
NRC FORH 366A U.S. WCLEAR REGULATORY CONIISS ION APPROVED BY NN NO. 3150-0104 (5.92) EXPIRES 5/31/95 EST IHATED BURDEN PER RESPONSE TO COHPLY MITN THIS INFORHATION COLLECTION REQUEST: 50.0 HRS.
FORMARD COHHENTS REGARDING BURDEN EST IHATE TO LICENSEE EVENT REPORT (LER) THE INFORHATlON AND RECORDS HANAGEHENT BRANCH TEXT CONTINUATION (HXBB 7714)g UoS NUCLEAR REGULATORY COHHISSIDNg MASHINGTON~ DC 20555.0001 AND TO THE PAPERMORK REDUCTION PROJECT (3140 0104), OFFICE OF HANAGEHENT AND BUDGET MASKINGTON DC 20503.
FACILITY IIAIK 1 DOCKET NEER 2 LER NEER 6 PAGE 3 YEAR SEQUENTIAL REVISION R.E. Ginna Nuclear Power Plant 05000244 12 OF 15 94 pp4 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)
V. CORRECTIVE ACTION A. ACTION TAKEN TO RETURN AFFECTED SYSTEMS TO PRE-EVENT NORMAL STATUS:
1~ The NIS Intermediate Range bistable circuits were reviewed to verify that the trip signal would deenergize the reactor trip relay when the trip bistable setpoint is reached. The PORC concluded that, since the plant was currently at power and the NIS Intermediate Range channels were both tripped, proper illumination of the Main Control Board status lights provided sufficient verification that continuity existed between the trip bistable and the reactor trip relay. Therefore, the PORC declared that adequate verification had occurred, and that actions taken assured compliance with TS requirements.
2 ~ The testing of the UV logic cards had been under consideration since 1993, due to ongoing concerns for the reliability of the logic cards and reevaluation of the long-term commitments related to LER 91-008. (Refer to Ginna Docket No. 50-244, LER 91-008.)
Based on this reevaluation, the UV system monthly surveillance test procedures were upgraded on January 12, 1994, and the UV logic cards were tested by these upgraded procedures on January 13, 1994. Consequently, the logic cards were tested within the required one month surveillance interval at the time of discovery. Therefore, the PORC declared that adequate testing had occurred, and that actions taken assured compliance with TS requirements.
3 ~ PORC concluded that the verification of the Main Control Board annunciation for the Reactor Trip Breaker Logic Channels was accomplished by performance of procedures PT-32A and PT-32B in the first two months after the 1993 refueling outage. PT-32A was performed on May 3, 1993, and PT-32B was performed on May 24, 1993. These procedures continued to be performed, on an alternate monthly basis. Therefore, the PORC declared that adequate testing had occurred, and that actions taken assured compliance with TS requirements.
NRC FORH 366A (5-92)
NRC FORM 366A U S. IN)CLEAR REGULATORY CQBIISSIOH APPROVED BY MB NO. 3150-0104 (5-92) EXP I RES 5/31/95 ESTIMATED BURDEN PER RESPOHSE TO COMPLY WITH THIS INFORMATION COLLECTIOH REQUEST: 50.0 HRS.
FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO LICENSEE"EVENT REPORT (LER) THE INFORMATION AHD RECORDS MANAGEMENT BRANCH TEXT CONTINUATION (MHBB T714), U.S, NUCLEAR REGULATORY COMMISSION, WASHIHGTOH, DC 20555-0001 AHD TO THE PAPERWORK REDUCTIOH PROJECT (3150 0104), OFFICE OF MANAGEMENT AND BUDGET WASHINGTON DC 20503.
FACILITY NNK 1 DOCKET IRNBER 2 LER IRNBER 6 PAGE 3 YEAR SEQUEHTIAL REVISIOH R.E. Ginna Nuclear Power Plant 05000244 94 004 00 13 OF 15 TEXT (lf more space is required, use additional copies of NRC Form 366A) (17)
- 4. The NRC exercised Enforcement Discretion, not to enforce compliance with the requirements to test one Containment Isolation pushbutton. Operations management also provided additional guidance to the Control Room operators, by the Operations Plan, that required, and if if manual Containment Isolation were one pushbutton did not actuate Containment Isolation, to use the other pushbutton.
B. ACTION TAKEN OR PLANNED TO PREVENT RECURRENCE:
~ For the wording of the requirements of TS Section 4 that were not clearly defined, documented interpretations have been prepared.
These interpretations will be submitted to the PORC for approval.
~ RG&E has committed to implement Improved Technical Specifi'cations (NUREG-1431). The Technical Specification Improvement Program (TSIP) will consist of upgrading the current Ginna Station TS consistent with industry standards for format and bases content.
~ Procedure RSSP-2.1, "Safety Injection Functional Test", has been upgraded to formally document the testing of both manual Containment Isolation pushbuttons.
~ Procedure PT-6.2, "N.I.S. Intermediate Range Channels", has been upgraded to include documented verification that the channel circuit continuity from the trip bistable to the reactor trip relay is tested.
~ Procedures PT-32A-SD and PT-32B-SD have been upgraded to include documented verification of Main Control Board annunciators during testing of the Reactor Trip Breaker Logic Channels.
HRC FORM 366A (5.92)
NRC FORH 366A U.S. IRICLEAR REGULATORY CNNISSION APPROVED BY ON HO. 3150-0104 (5-92) EXP I RES 5/31/95 EST IHATED BURDEN PER RESPOHSE TO COHPLY illTH THIS INFORHATION COLLECTION REQUEST: 50.0 HRS.
FORllARD COHHENTS REGARD INC BURDEN ESTIHATE TO LICEN8EE EVENT REPORT (LER) THE INFORHATION AHD RECORDS HAHAGEHEHT BRANCH TEXT CONTINUATION (HHBB 77'l4), U.S. NUCLEAR REGULATORY COHHISSIONg WASHINGTON, DC 20555-0001 AHD TO THE PAPERWORK REDUCTION PROJECT (3140.0104), OFFICE OF HAHAGEHENT AHD BUDGET UASHIHGTON DC 20503.
FACILITY ItJVK DOCKET NNBER 2 LER NQEBER 6 PACE 3 YEAR SEQUENTIAL REVISION R.E. Ginna Nuclear Power Plant 05000244 14 OF 15 94 -- 004-- 00 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:
~ LER 83-018, Failure to Perform Surveillance Testing on the Residual Heat Removal Pumps, due to failure to properly incorporate new TS requirements into the existing test program.
~ LER 90-014, Pressurizer Relief Valve Inoperability During Defeat of Pressurizer Channel, due to failure to apply a rigorous interpretation of the TS definition of operability.
~ LER 91-008, One Train of UV Inoperable, due to circuit design.
~ LER 93-005, Failure to Perform Surveillance, due to misinterpretation of TS.
LER 83-018 was a similar event, but with a different root cause.
LER 90-014 was a different event, but with a similar root cause as this report. The corrective action was limited to maintenance and calibration procedures. LER 91-008 was a different event with a different root cause, but involved failure of the UV system logic card, which has not been tested monthly, as identified in *this report. LER 93-005 was a similar event with a similar root cause, and resulted in formation of the Review Team, which directly resulted in the identification of the missed surveillances documented in this report.
NRC FORH 366A (5-92)
HRC FORH 366A U.S. IRICLEAR REGULATORY CNSIISSION APPROVED BY (SHI NO. 3150-0104 (5-92) EXPIRES 5/31/95 EST IHATED BURDEN PER RESPONSE TO CDHPLY MITH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS.
FORNARD CDHHENTS REGARDING BURDEN EST IHATE TO LICENSEE EVENT REPORT (LER) THE IHFORHAT ION AND RECORDS HANAGEHENT BRAMCH TEXT CONTINUATION (HNBB 7714), U.S. NUCLEAR REGULATORY COHHISSIOM, llASHINGTOH, DC 20555-0001 AMD TO THE PAPERMORK REDUCTION PROJECT (3110-0104), OFFICE OF HAMAGEHEMT AMD BUDGET llASHIMGTON DC 20503.
FACILITY NAIL 1 DocKET IRHIBER 2 LER IRMBER 6 PAGE 3
'YEAR SEQUENTIAL REVISION R.E. Ginna Nuclear Power Plant 05000244 94 -- 004 pp 15 OF 15 TEXT <If more spsce is required, use additional copies of NRC Form 366A) (17)
C. SPECIAL COMMENTS:
RG&E formed the TS Review Team, with representation from Ginna Station (Technical Engineering, Results and Test, Maintenance Support Services) and corporate engineering (Nuclear Safety and Licensing). Where necessary, specific discipline knowledge was solicited. The members included two 'individuals who held NRC Senior Reactor Operator (SRO) certification, and a third who held 'a Reactor Operator (RO) license. The Review Team collectively spent over five hundred (500) man-hours in this self-assessment program, identifying and reviewing procedures which implement TS surveillance requirements.
RG&E began considering a Technical Specification Improvement Program (TSIP) in the summer of 1993, following requests from the plant (Operations and Technical Engineering). Discussions were initiated between RG&E and the NRC in October, 1993, to refine the scope and goals of the TSIP. Following further discussions with the NRC in early February, 1994, RG&E committed to the upgrade effort. (Refer to a letter from RG&E (R.C. Mecredy) to NRC (A.R. Johnson), dated February 28, 1994.) The TSIP for Ginna Station began on March 1, 1994, with the objective of implementing TS which are standardized to current industry criteria and which provide a significant human factors improvement over the current Ginna TS. This includes an upgrade of the TS bases to support all specifications and testing requirements. RG&E recognizes the importance of this program, and has committed significant resources from the plant (Operations and Technical Engineering), Training, and Nuclear Safety and Licensing.
Ginna Station is one of the first nuclear plants to commit to the Improved TS and believes that the TSIP will resolve many of the issues identified by the Review Team.
NRC FORH 366A <5-92)