ML17285A485

LER 89-008-00:on 890419,discovered That on 881202,Tech Spec Amend Request Submitted to NRC Describing Diesel Generator Trip Bypass Verification That Had Not Been Performed W/Ler Not Issued within 30 Days After determination.W/890519 Ltr

ML17285A485
Person / Time
Site:	Columbia
Issue date:	05/19/1989
From:	Arbuckle J, Powers C WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-89-008, NUDOCS 8906010240
Download: ML17285A485 (7)

Text

gc CARRIED DISVKBUTION DEMONSTRATION SYFI'EM REGULATOPOINFORMATION DISTRIBUTION LITEM (RIDS) t oitACCESSION NBR:8906010240 DOC.DATE: 89/08/19 NOTARIZED: NO DOCKET

~"FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION ARBUCKLE,J.D. Washington Public Power Supply System POWERS,C.M. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 89-008-00:on 881202,missed HPCS diesel generator Tech Spec surveillance due to program defeciencies.

W/8 ltr.

DISTRIBUTION CODE: IE22D COPIES RECEIVED:LTR ( ENCL i SIZE:

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

NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA 1 1 PD5 PD 1 1 SAMWORTH,R 1 1 INTERNAL: ACRS MICHELSON 1 1 ACRS MOELLER 2 2 ACRS WYLIE 1 1 AEOD/DOA 1 1 AEOD/DSP/TPAB 1 1 AEOD/ROAB/DSP 2 2 DEDRO 1 1 IRM/DCTS/DAB 1 1 NRR/DEST/ADE 8H 1 1 NRR/DEST/ADS 7E 1 0 NRR/DEST/CEB 8H 1 1 NRR/DEST/ESB 8D 1 1 NRR/DEST/ICSB 7 1 1 NRR/DEST/MEB 9H 1 1 NRR/DEST/MTB 9H 1 1 NRR/DEST/PSB 8D 1 1 NRR/DEST/RSB 8E 1 1 NRR/DEST/SGB 8D 1 1 NRR/DLPQ/HFB 10 NRR/DOEA/EAB NUDOCS-ABSTRACT ll 1 1

1 1

1 1

NRR/DLPQ/PEB 10 REP RPB 10 1

2 1

1 2

1 RES/DSIR/EIB 1 1 S~DSR/PRAB 1 1 RGN5 FILE 01 1 1 EXTERNAL: EGGG WILLIAMSFS 4 4 FORD BLDG HOY,A 1 1 L ST LOBBY WARD 1 1 LPDR 1 1 NRC PDR 1 1 NSIC MAYSFG 1 1 NSIC MURPHYFG.A 1 1 NOXK 'IO ALL KIDS" RECIPI1MS PLEASE HELP US 'lo REDOCE RASTE.'CKECT IHE DOCUMERI'ol'.ROL DESK, KKN Pl-37 (EXT. 20079) To EIsIÃHQZB YOUR SAME HEN DIEHGBVTXCN LISTS H3R ~IMENIS VXJ DGNFT NEEDt TOTAL NUMBER OF COPIES REQUIRED: LTTR 43 ENCL 42

WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352 Docket No. 50-397 May 19, 1989 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C . 20555

Subject:

NUCLEAR PLANT NO. 2 LICENSEE EVENT REPORT NO.89-008

Dear Sir:

Transmitted herewith is Licensee Event Report No.88-008 for the WNP-2 Plant. This report is submitted in response to the report requirements of 10CFR50. 73 and discusses the items of reportabili ty, corrective action taken, and action taken to preclude recurrence.

This LER is also submitted in response to NRC Notice of Violation (NOV )

89-04-03. Corrective actions for failure to submit an LER within the required time frame are contained in our response- to the NOV and, as such, this LER describes the event as prevent recurrence.

it occurred and those actions to Very truly yours, N@L C.M. Powers (M/D 927M)

WNP-2 Plant Manager CMP:lg

Enclosure:

Licensee Event Report No.89-008 cc: Mr. John B. Martin, NRC - Region V Mr. C.J . Bosted, NRC Site (M/D 901A)

INPO Records Center - Atlanta, GA Ms. Dottie Sherman, ANI Mr. D.L. Williams, BPA (M/D 399)

F DR <0 890519 S ADOCK 05000a9~

FNV

NRC Form 355 U.S. NUCLEAR REOULATOAY COMMISSION (94)3) APPROVED OMB NO. 31504104 EXPIRES: 5131ISS LICENSEE EVENT REPORT (LER)

PACE 3)

FACILITY NAME (ll DOCKET NUMBER (2I Washin ton Nuclear Plant - Unit 2 0 5 0 0 0 3 9 7 1 OF p 5

"'"""Missed High Pressure Core Spray (HPCS Diesel Generator Technical Specification Surveillance Due to Pro rammatic/Procedural Deficiencies EVENT DATE (5) LER NUMBER (Sl 4EPORT DATE (7) OTHER FACILITIES INVOLVED IS)

YEAR SSOVSNTIAL OAY YEAR FACILITYNAMFS DOCKET NVMSEAISI MONTH OAY YEAR NVMSSR NVMSSR MONTH 0 5 0 0 0 1 02 88 9 0 8 00 05 1 9 8 9 0 5 0 0 0 THIS REPORT IS SUBMITTED PURSUANT T 0 THE REQUI4EMENTS OF 10 CFR (I: IChectr onr or more Of thr IollowlnPI (11 OPER ATINO MODE (D) 73.71(S) 4 20.402(b) 20.405(c) S0,73(el(2) (ivl POWEA 20.405(e l (I I (ll 50.35(cl(1) 50.73(e I (2)(v) 73.71(cl LEVEL p p p 20A05(el(1)(iil 50.35(cl(2) 50.73(e) (2) (vil) OTHER I$prclty ln Ahrtrect g 5 Oelow rnd In Text, PIRC Form S~ >Soy' 'e g 20A05(e I (I I(5I I 50.73(e I (2)( II 50.73( ~ l(2)(vili)(Al 366AI 20.405( ~ l(l l(lv) 50.73( ~ l(2)(lil 50,73(el(2)(viii) (Bl P. 4" ot( 3'm

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LICENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER AREA CODE 0 Arbu kl om 1 iance En ineer 509 3 COMPLETE ONE LINE FOA EACH COMPONENT FAILURE DESCRIBED IN THIS AEPO4'7 (13)

REPORTABLE PIS '

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On April 19, 1989 during a Plant Operating Committee (POC) review of the Supply System response to an NRC Notice of Violation (NOV), it was agreed that a violation of the Plant Technical Specifications had occurred and the appropr iate actions were not taken.

Specifically, on December 2, 1988 a Technical Specification Amendment Request was submitted to the NRC which described a Divison 3 Diesel Generator (DG-3) trip (incomplete starting sequence) bypass verification that had not been performed as required by the Technical Specifications, and an LER was not issued within 30 days after that determination.

The amendment request was submitted to make the Technical Specifications match the FSAR description of the design of DG-3 [i.e., DG-3 trips (is not bypassed) on incomplete starting sequence and is bypassed on an ECCS signal instead of concurrent ECCS and loss of voltage signals]. This discrepancy was due to an oversight in the preparation of the Technical Specifications.

Further review of this issue also revealed that only one of three contact pairs on the DG-3 Bypass Relay were actually ver'ified to .function by the surveillance procedure.

The causes of this event are 1) programmatic deficiency - a process had not been established whereby proposed amendments to the Technical Specifications are formally reviewed for compliance ( i.e., reportability concerns) wih Technical Specification requirements, and 2) procedural inadequacy - the procedure for testing other DG-3 bypass functions did not require testing of all contacts on the bypass relay.

J pig NAC Form 355 (083 I

NRC Form 366A US. NUCLEAR REOULATORY COMMISSION (943)

LICENSEE EV T REPORT (LER) TEXT CONTINUATI APPROVED OMB NO. 3(60-0104 EXPIRES: 8/31/88 FACILITY NAME (I) DOCKET NUMBER (3) LER NUMBER (6) PACE (3)

SEQUENTIAL REVISION NUMBER v&3, NVMBER Washin ton Nuclear Plant - Unit 2 0 5 0 0 0 3 9 7 9 008 000 2 OF 0 TEXT IIImoro EPooo ls morrkorL Irro ortdidorrol HRC %%dmr 3554'8) ()7)

Abstract (continued)

Corrective actions included 1) submitting a request for waiver of compliance from the Technical Specification surveillance requirements applicable to the DG-3 incomplete start sequence bypass verification until the amendment request was approved, 2) successful testing of the remaining contacts on the DG-3 bypass relay, and 3) revising the applicable surveillance procedure to require testing of all contacts on the relay. Further corrective actions are 1) establishing a process whereby proposed Technical Specification amendments are formally reviewed for Technical Specification compliance, and 2) considering a process to review Technical Specification requirements and associated surveillance procedures for accuracy and consistency.

0 This event posed no threat to the health and safety of either the public or Plant personnel.

Plant Conditions a) Power Level - OX b) Plant Mode - 4 (Cold Shutdown)

Event Descri tion April 1989 during a Plant Operating Committee (POC ) review of the Supply

'fOn 19, System response to NRC Notice of Violation 89-04-03, the Plant Technical Specifications had occurred and the appropriate actions were not taken. Specifically, on December 2, 1988 a letter was submitted to the NRC it was agreed that a violation which described a Division 3 Diesel Generator (DG-3) trip bypass verification that had not been performed as required by the Plant Technical Specifications, and an LER was not issued within 30 days after that determination.

The following is a sequence of events associated with this LER:

~ December 2, 1988 A Technical Specification Amendment Request was submitted to the NRC such that surveillance 4.8.1.1.2.e.7 would match the FSAR description of the design of DG-3 [i.e., DG-3 trips (is not bypassed) on incomplete starting sequence and is bypassed on an ECCS signal instead of concurrent ECCS and loss of voltage.'ignals].

It was determined at that time the discrepancy was due to an oversight in the "

preparation of the Technical Specifications. The FSAR descriptions were issued in Amendments 23 and 31 (February 1982 and June 1983), before issuance of the WNP-2 Operating License. As a result, the FSAR description of the DG-3 design should have been reflected in the Technical Specifications.

NRC FORM SEEA ~V~ S. CPOr (988-520-589r00010 (983)

NRC Form 300A U3. NUCLEAR REOULATORY COMMISSION

~

(9413)

LICENSEE EV T REPORT (LER) TEXT CONTINUATIO APPROVEO OMB NO. 3150W104 EXPIRES: 0/31/BB FACILITY NAME I'I) OOCKET NUMBER (2) LER NUMBER (0) PAGE (3) sEQUENTIAL AEvrsloN g$ pw NUM80/l Washin ton Nuclear Plant - Unit 2 0 5 0 0 0 3 9 7 9 008 000 3 oF 0 TEXT /lf/rrrilo opoco /4 o0rr/lrod, 044 oddidono/ ll/IC %%drm 30843/ (17)

. Di scussi ons of the issue at that time al so focused on 1) current Pl ant configuration, 2) function of the incomplete start sequence feature, and 3) modifying the Technical Specifications to match the design of the system.

Supply System personnel did not followup on the issue of noncompliance with the Technical Specifications as written. However, because the incomplete starting sequence trip was not verified to be bypassed when DG-3 was tested per Plant Procedure (PPM) 7.4.8.1.1.2.8, RHPCS Diesel Generator LXA Test," on April 28, 1987 and May 16, 1988, this situation is considered to be a violation of the Plant Technical Specifications. As a result an LER should have been submitted as required by 10CFR50. 73.

~ February 1988 During a review of the Technical Specification Amendment Request, the NRC resident inspector confirmed that the as-built design of DG-3 was as described in the FSAR, and verified that the control circuitry was not bypassed on an, ECCS actuation. The inspector also raised the question of compliance with the Technical Specifications in that PPM 7.4 .8. 1.1.2 .8 did not verify testing the bypassing of the incomplete starting sequence. Accordingly, a request was submitted to the NRC for waiver of compliance from the Technical Specification surveillance requirements applicable to DG-3 incomplete starting sequence bypass verification until the formal changes requested could be granted.

The inspector also was concerned with the manner in which the Supply System was testing other bypass functions associated with DG-3. Verification of those bypass functions was accomplished by pushing a test button on a temperature switch (DCW-TS-4). However, the Supply System interpreted Technical Specification 4.8.1.1.2.e.7 as requiring testing of the bypass function, not that each trip is bypassed. As a result of that interpretation, it was determined that the surveillance program was adequate "bypass function" was verified to .be operable. In addition, because the in that the temperature switch is bypassed on an ECCS signal, it was felt that the requirements of the Technical Specifications were satisfied and, as a result, DG-3 was operable. However, there was a question of operability of the temperature switch in that the test button on the switch had not been tested.

Plant Technical personnel performed an additional review of this issue and discovered that DG-3 Bypass Relay HPCS-RLY-E22B/Kll has three contacts, all of which are used to bypass signals. However, only one of the contacts was actually verified to function by the surveillance procedure (PPM 7.4.8.1.1.2.8). Although only one of three contact pairs was actually verified to be operable by surveillance, it was felt that the relay was it operable due to it design. The relay is an HFA relay and 'would have been highly unlikely that only one set of contacts would operate and the others not.

On March 27, 1989 the NRC issued three NOVS for 1) not testing the bypass function and only testing one of three contact pairs on the bypass relay, 2) not declaring DG-3 inoperable and entering the associated LCO, and 3) failure to submit an LER.

NRC FORM 300A ~ 0,$ , CPOr 1900 S10 SN/00070 (943)

NRC Form 388A UN. NUCLEAR REOULATORY COMMISSION (943)

LICENSEE EVENT REPORT (LER) TEXT CONTINUATION APPROVEO OMB NO. 31 60-0(04 EXPIRES: 8/31/BB FACILITY NAME (1) DOCKET NUMBER (3) LER NUMBER (6) PAOE (3) seaUeNTIAL NUMBER '/

rM REvrsroN NUMBER Washington Nuclear Plant - Unit 2 o s o o o 8 9 008 00 4oF 0 5 TEXT /// moro s/roco /8 ter/rdirrd, rrro oddi5onet HRC Forrrr 36649/ (IT) r Immediate Corrective Action

1. On Febr uary 1, 1989 a request was submi tted to the NRC for wai ver of compliance from the Technical Specification surveillance requirements applicable to the DG-3 incomplete start sequence bypass verification until the changes requested above could be granted. On February 2, 1989 the NRC granted the waiver of compliance.

2. On February 2, 1989 a functional test of the test button associated with Temperature Switch DCW-TS-4 was successfully performed.

3. On February 3, 1989 a temporary procedure was successfully completed which verified operation of the remaining contacts on the DG-3 bypass relay.

4. On March 30, 1989 the Supply System received Amendment No. 66 to the Operating License which deleted the requirement to verify bypassing of the DG-3 incomplete start sequence trip.

5. Plant Procedure (PPM) 7.4.8. 1.1.2,8, "HPCS Diesel Generator LOCA Test," was revised to require testing of all contacts on the DG-3 bypass relay.

Further Evaluation and Corrective Action A. Further Evaluation

1. This event is being reported as a "condition prohibited by the Plant Technical Specifications" per the requirements of 10CFR50.73(a)(2)(i)(B).

2. There were no structures, comppnents or systems that were inoperable prior to the start of this event which contributed to the event.

3. A formal root cause analysis was performed and identified the following causes of this event:

a) Programmatic Deficiency: A process had not been established whereby proposed amendments to the Technical Specifications are formally reviewed for compliance (i.e., reportability concerns) with Technical Specification requirements.

b) Procedural Problem (Less Than Adequate): PPM 7.4.8.1.1.2.8, "HPCS Diesel Generator LOCA Test," did not require testing of all contacts on the DG-3 bypass relay.

4. Submittal of the request for waiver of compliance (and subsequent NRC approval) caused WNP-2 to be in full compliance with Technical Specification requirements.

NRC FORM 38BA AU.S. GPCr 1988 S30 Sssr00010 (943)

NRB Form 388A U.S. NUCLEAR REOULATORY COMMISSION (9831 LICENSEE EVE( T REPORT (LER) TEXT CONTINUATI APPROVED OMB NO. 31SOM(08 EXPIRES: 8/31/88 FACILITY NAME (1l OOCKET NUMBER (2l LER NUMBER (Sl PACE (31 SEOVENTIAL REVISION NUMBER NVM884 0 5 0 0 0 ~ OF TEXT //I mare 8/reed /8 rer/0/red, Iree eddirr'one/NRC Fane 3/I//A'/ (17I B. Further Corrective Action

1. A process will be established whereby proposed amendments to the Technical Specifications are formally reviewed for compliance with the Technical Specifications.

2. A process is currently being considered to review Technical Specification requirements and associated surveillance procedures for accuracy and consistency.

Safety Si nificance There is no safety significance associated with this failure to comply with the Technical Specifications as written. The Technical Specification Amendment Request was submitted to revise the Technical Specifications to be consistent with the FSAR description of the design of DG-3. As stated in the amendment request, a 10CFR50.59 review was performed which concluded that it did not involve an unreviewed safety question. The accident analyses previously performed for this equipment are based on the FSAR description and have not changed. The modification to the Technical Specifications merely corrected an inconsistency between the FSAR and Technical Specification decription.

In addition, as stated in the waiver of compliance letter, the DG-3 incomplete starting sequence is not considered to be a protective device as defined in Regulatory Guide 1.9 and; therefore, is not required to be bypassed.

Furthermore, successful testing of the remaining contacts on the DG-3 bypass relay demonstrated that those other bypass functions would have performed as designed during the event period.

Accordingly, this event posed no threat to the health and safety of either the public or Plant personnel.

Similiar Events LERS 88-036-00 and 88-036-01 EIIS Information Text Reference EIIS Reference System Component High Pressure Core Spray (HPCS), Division 3, Diesel Generator (DG-3) EK DG

.Emergency Core Cooling System (ECCS)

Temperature Switch DCM-TS-4 LB TS DG-3 Bypass Relay HPCS-RLY-E22B/Kll EK RLY NRC FORM 388A iV.S ~ GPOr 1888 820 Sde/00010 (983(