ML17289A963

From kanterella
Jump to navigation Jump to search
LER 92-040-00:on 920930,determined That Start & Load Time for Standby & HPCS DG Not Measured During Monthly Surveillance Testing.Caused by Deficiencies in Mgt Methods. Expedited Effort Initiated to Amend procedure.W/921030 Ltr
ML17289A963
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 10/30/1992
From: John Baker, Poche R
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-92-246, LER-92-040, LER-92-40, NUDOCS 9211040008
Download: ML17289A963 (9)
v • d • e


Text

ACCELERATED L}DISTRIBUTION DEMONSTRATION SYSTEM DI STRI BUT IO~YSTEM RIDS REGULARLY INFORMATION ( )

2

'ACCESSION NBR:9211040008 DOC.DATE: 92/10/30 NOTARIZED: NO DOCKET I FACZL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION POCHE,R.J. Washington Public Power Supply System BAKERiJ.W. Washington Public Power Supply System RECZP.NAME RECIPIENT AFFILIAT10N

SUBJECT:

LER 92-040-00:on 920930,determined that start & load time for standby !'PCS DG not measured during monthly surveillance testing. Caused by deficiencies in mgt'ethods.

Expedited effort initiated to amend procedure.W/921030 ltr.

DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE:

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

NOTES:

R ECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA 1 1 PDS PD 1 1 DEANiW. 1 1 INTERNAL: ACNW 2 2 ACRS 2 2 AEOD/DOA 1 1 AEOD/DSP/TPAB 1 1 AEOD/ROAB/DSP 2 2 NRR/DET/EMEB 7E 1 1 NRR/DLPQ/LHFB10 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA/OEAB ~

1 1 NRR/DREP/PRPB11 2 2 NRR/DST/SELB 8D 1 1 NRR/DST/SICB8H3 :1 1 NR~ PLB8D1 1 1 NRR/DST/SRXB 8E 1 1 REG FILE 02 1 1 RES/DSIR/EIB 1 1 6 1."ZLE Ol 1 1 EXTERNAL: EGSrG BRYCEgJ.H 2 2 L ST LOBBY WARD 1 1 NRC PDR 1 1 NSIC MURPHYIG A 1 1 NSIC POOREgW 1 1 NUDOCS FULL TXT 1 1 NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK.

ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 31 ENCL 31

WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352 October 30, 1992 G02-92-246 Docket No. 50-397 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

NUCLEAR PLANT WNP-2, OPERATING LICENSE NPF-21 LICENSEE EVENT REPORT NO. 92-040-00 Transmitted herewith is Licensee Event Report No.92-040 for the WNP-2 Plant. This report is submitted in response to the report requirements of 10CFR50.73 and discusses the items of reportability, corrective action taken, and action taken to preclude recurrence.

Sincerely, W. Baker

-2 Plant Manager (Mail Drop 927M)

JWB/RP/lr Enclosure CC: Mr. J. B. Martin, NRC - Region V Mr. W, Ang, NRC Resident Inspector (Mail Drop 901A, 2 Copies)

INPO Records Center - Atlanta, GA Mr, D. L. Williams, BPA (Mail Drop 399) 921f04000IP 4'kI63L PDR ADOCK 05000397 S PDR

LICENSEE EVOI REPORT {LER)

FACILITY NAME (I) DOCKET NUMB R ( ) PAGE (3)

Washin ton Nuclear Plant - Unit 2 0 5 0 0 0 3 9 7 I OF 6 TITLE (4)

Start and Load Times for Standby and HPCS Diesel Generators Not Measured During Monthly Surveillance Testing Due to Incorrect Translation of Technical Specifications EVENT DATE 5 LER NUMBER 6 REPORT DATE (7 OTHER FACILITIES INVOLVED (8)

MONTH DAY YEAR YEAR SEQUENTIAL EVI5 ION MONTH DAY YEAR FACILITY NAMES OCKET NUMBERS(S)

NUMBER UMBER 050 0 9 3 0 9 2 9 2 0 4 0 0 0 I 0 3 0 9 2 050 P ERAT ING HIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR 5: (Check one or more of the following) (11)

ODE (9)

POHER LEVEL 20.402(b) 20.405(C) 50.73(a)(2)(iv) 77.71(b)

(iO) 20.405(a)(1)(i) 50.36(c)(1) 50.73(a)(2)(v) 73.73(c) 20.405(a)(1)(ii) 50.36(c)(2) 50.73(a)(2)(vii) THER (Specify in Abstract 20.405(a)(1)(iii) X 0.73(a)(2)(i) 50.73(a)(2)(viii)(A) elow and in Text, NRC 20.405(a)(1)(iv) 50.73(a)(2)(ii) 50.73(a)(2)(viii)(B) Form 366A) 20.405(a)(1)(v) 0.73(a)(2)(iii) 50.73(a)(2)(x)

LICENSEE COHTACT FOR THIS LER (12)

TELEPHOHE HUMBER REA CODE R.J. Poche', Compliance Engineer 5 0 9 7 7 - 4 1 4 5 COMPLETE OHE LINE FOR EACH COMPONENT FAILURE DESCRIBED IH THIS REPORT (13)

CAUSE sYBTEM COMPOHENT MANUFACTURER EPORTABLE CAUSE SYSTEM COMPOHEHT MANUFACTURER REPORTABLE 0 HPRDS TO HPRDS SUPPLEMENTAL REPORT EXPECTED (14) EXPECTED SUBMISSIOH MONTH DAY YEAR ATE (15)

YES (If yes, complete EXPECTED SUBMISSIOH DATE) HO TIIAC1 (1el At 1245 hours0.0144 days <br />0.346 hours <br />0.00206 weeks <br />4.737225e-4 months <br /> on September 30, 1992, it was determined that procedures used to perform monthly surveillance testing of the High Pressure Core Spray and standby diesel generators were not adequate to demonstrate Technical Specification requirements. Technical Specifications require demonstration that these diesel generators start, accelerate, and load within prescribed time intervals. The procedures used to perform these demonstrations did not measure start and load times because it was no longer believed necessary following changes made to satisfy engine warmup requirements. Required safety functions associated with the diesel generators were regularly demonstrated during semi-annual testing; therefore, this condition was not safety significant.

The root cause of this condition was deficiencies in management methods that were in place when monthly surveillance procedures for the diesel generators were changed, and involved a personnel error that resulted in incorrect translation of Surveillance Requirement 4.8.1.1.2. As corrective action, procedures used to perform monthly testing of the diesel generators were amended, and the diesels were tested satisfactorily. Also, a team will be assigned to perform a review of surveillance procedures. The methods used to control changes to procedures have been addressed through programmatic changes, and designated personnel have received training on the performance of safety significance evaluations.

I ICENSEE EVENT REPORTER)

TEXT CONTINUATION "AGILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (8) AGE (3) ear umber ev. No.

Washington Nuclear Plant - Unit 2 0 5 0 0 0 3 9 7 2 40 00 2 F 6 ITLE (4)

Start and Load Times for Standby and HPCS Diesel Generators Not measured During Honthly Surveillance Testin Due to Incorrect Translation of Technical S ecifications Plant ndi i n Plant Mode: 1 (Power Operation)

Power Level: 100%

Event Descri tion At 1245 hours0.0144 days <br />0.346 hours <br />0.00206 weeks <br />4.737225e-4 months <br /> on September 30, 1992, it was determined that procedures used to perform monthly surveillance testing of the standby (Division I and II) and High Pressure Core Spray (HPCS) diesel generators were not adequate to demonstrate Technical Specification requirements. Technical Specification Surveillance Requirement 4.8.1.1.2 states that the standby and HPCS diesel generators shall be demonstrated to start, accelerate to full speed within 10 seconds (13 seconds for HPCS), and synchronize and load within the subsequent 60 seconds on a monthly basis in Operational Conditions 1 through 3.

Surveillance procedures used to perform these monthly demonstrations did not include provisions to measure the time required for the HPCS and standby diesel generators to start or load. This testing methodology deficiency was discovered by two senior plant engineers during a discussion of testing requirements for an Action Statement associated with Technical Specification 3.8.1.1. At the time of this discussion, the plant was involved in accelerated testing of the standby diesel generators on a once per eight hour basis due to failure of the HPCS diesel generator to start and load during testing. This cause of this failure was unrelated to the conditions described in this report.

Immedi rrective Action As immediate corrective action, an expedited effort was initiated to amend the procedures used to perform monthly surveillance testing of the standby and HPCS diesel generators. The corrections included provisions for a timed start and timed loading of the diesel generators from a rest condition. The Division I and Division II standby diesel generators were declared operable based upon test results from the amended procedures at 1910 hours0.0221 days <br />0.531 hours <br />0.00316 weeks <br />7.26755e-4 months <br /> and 2009 hours0.0233 days <br />0.558 hours <br />0.00332 weeks <br />7.644245e-4 months <br /> on September 30, 1992, respectively. The HPCS diesel generator, which was inoperable at the time the test procedure deficiencies were identified, was tested with an amended procedure prior to returning it to service at 0023 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> on October 1, 1992.

LICENSEE EVENT REPORTER)

TEXT CONTINUATION FACILITY NAHE (I) OOCKET NUH8ER (2) LER NUHBER (8) PAGE (3) ear UInber ev. No.

Washington Nuclear Plant - Unit 2 0 5 0 0 0 3 9 7 2 040 00 3 OF 6 ITLE (4)

Start and Load Times for Standby and HPCS Diesel Generators Not Measured During Monthly Surveillance Testin Due to Incorrect Translation of Technical S ecifications Further Ev I i n n rr ive Action Further Eval i n The final Technical Specifications for WNP-2 were issued upon receipt of the Plant Operating License on December 20, 1983, and reflected a change to Technical Specification Surveillance Requirement 4.8.1.1. This change involved a requirement to use pre-test prelube and/or warmup procedures during surveillance testing of the HPCS and standby diesels. Implementing prelube requirements for the HPCS and standby diesel engines did not require any changes to plant design or procedures because the HPCS and standby diesel engines were already equipped with a continuous operation prelube system. However, implementation of the pre-test warmup requirement did require procedure and design changes due to the fact that it must be performed at idle speed.

The original standby diesel generator design did not include the ability to operate at idle speed.

This discrepancy between Technical Specification Surveillance Requirement 4.8.1.1 and the plant design was identified in early 1984, shortly after issuance of the plant Technical Specifications, and was discussed with NRR personnel prior to entering an Operational Condition that would have resulted in plant operations that were not in accordance with Technical Specifications. It was recognized and acknowledged during this discussion that there would be violations of the requirement to warmup the standby diesels during monthly testing until either the necessary design changes or a Technical Specification change could be implemented. A Technical Specification change was granted in August 1984.

A Plant Modification Request to perform the engineering changes needed to allow standby diesel engine operation below synchronous speed was initiated in early 1984. It was not necessary to perform any modifications to the HPCS diesel engine in order to achieve idle speed operation since its original design included a feature that allowed manual control of engine speed. Warmup requirements for the HPCS diesel generator were reflected in the associated monthly surveillance test procedure in January 1984, and design and procedure changes for the standby diesel generators were completed in 1987.

As previously stated, Technical Specification Surveillance Requirement 4.8.1.1.2 states that the ability of the standby and HPCS diesel generators to start from a rest condition, accelerate to full speed within 10 seconds (13 seconds for HPCS), and synchronize and load within the subsequent 60 seconds shall be demonstrated on a monthly basis. A note to this Surveillance Requirement further states that "diesel generator starts from ambient conditions shall be performed at least once every 184 days (6 months) in these surveillance tests and all other engine starts for the purpose of this surveillance testing shall be preceded with by an engine prelube period and/or other pre-test warmup procedures recommended by the manufacturer."

LICENSEE EVENT REPORLER)

TEXT CONTINUATION FACILITY HAHE (1) DOCKET HUHBER (2) LER NUHBER (8) AGE (3) ear umber ev. Ho.

Washington Nuclear Plant - Unit 2 0 5 0 0 0 3 9 7 2 040 00 4 OF 6 ITLE (4)

Start and Load Times for Standby and HPCS Diesel Generators Not Measured During Monthly Surveillance Testin Due to Incorrect Translation of Technical S ecifications Technical Specification 3/4.8.1.1 delineates the operability requirements for AC electrical power sources during Operational Conditions 1 through 3. The intent of Technical Specification Surveillance Requirement 4.8.1.1.2, and the associated note, is that monthly diesel engine testing will be preceded by a warmup cycle at idle speed, and the monthly testing requirements will be performed after the warmup cycle is complete by demonstrating a timed fast start from a rest condition. The requirement to perform a warmup procedure prior to performing monthly surveillance testing was added in order to reduce diesel engine wear associated with excessive cold fast starting of the diesel engines.

When changes reflecting idle speed operation were incorporated into monthly surveillance procedures for the HPCS and standby diesel generators, the intent of this note was not correctly understood by plant personnel. It was broadly believed that the warmup sequence was to be performed in lieu of the required fast start during monthly testing, and that a fast start of the diesel engines from the rest condition was only required during semi-annual testing. As a result, steps satisfying the requirement to measure start and load times were deleted from monthly surveillance procedures when the engine warmup sequence was incorporated into surveillance procedures.

Failure to time the diesel generator start and load sequence was not corrected during subsequent biennial reviews of these surveillance procedures because the misconception that a fast start was only required during semi-annual (once per 184 day) testing was widely held among plant personnel.

The procedures used to satisfy Technical Specification Surveillance Requirement 4.8.1.1.2 on a semi-annual basis include provisions to perform a timed diesel generator start and load sequence from a rest condition. This testing was performed correctly during the period when monthly testing requirements were incompletely implemented.

The root cause of the condition described in this report was deficiencies in management methods that were in place when monthly surveillance procedures for the standby and HPCS diesel generators were revised. The deficiencies resulted from inadequate development and control of the processes necessary to assure the accuracy of procedure changes. The condition described also involved a personnel error that resulted in incorrect translation of a note associated with Technical Specification Surveillance Requirement 4.8.1.1.2. This error resulted in incorporation of an incorrect testing methodology into the surveillance procedures used to perform monthly surveillance testing of the standby and HPCS diesel generators.

The condition described in this report resulted in plant operation that was not in accordance with the plant Technical Specifications, and is reportable pursuant to 10CFR50.73(a)(2)(i)(B). As a result of surveillance testing procedure inadequacies, operability requirements for the HPCS and standby diesel generators were not adequately demonstrated during previous operating cycles when they were required to be operable.

LlCENSEE EVENT REPORTER)

TEXT CONTINUATION FACILITY NAHE (1) DOCKET NUHBER (2) LER NUHBER (8) PAGE (3)

Year umber ev. No.

Washington Nuclear Plant - Unit 2 0 5 0 0 0 3 9 7 2 40 0 5 OF 6 ITLE (4)

Start and Load Times for Standby and HPCS Diesel Generators Not Measured During monthly Surveillance Testin Due to Incorrect Translation of Technical S ecifications The provisions of Technical Specification 4.0.3 were invoked upon discovery of the testing deficiency described in this report. Technical Specification 4.0.3 allows implementation of Action Statement requirements to be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when it is identified that a Surveillance testing requirement has not been performed. The standby diesel generators were tested satisfactorily and returned to service within the time allowed by Technical Specification 4.0.3, The condition described in this event did not directly involve failure of a plant component.

Further orrective Action Incorporation of incorrect changes into plant procedures was a result of weaknesses that previously existed in the methods used to control changes to procedures. These weaknesses have already been addressed through programmatic changes, Revisions to plant procedures now receive either validation and verification, or a review by an independent reviewer who is knowledgeable in the procedure topic prior to approval.

Also, the procedure change process has been strengthened to require an independent review of proposed procedure changes performed in accordance with 10CFR50.59. This independent review is performed by a qualified reviewer prior to change implementation, and personnel who are designated as qualified reviewers receive specialized training on the evaluation of changes for safety significance. The processes used to control Technical Specifications change implementation have also been improved during recent years. These process improvements have provided greater assurance that changes to the Technical Specifications are reviewed and implemented correctly and on a timely basis.

As previously committed in LER 92-035, a project team will be assigned to perform a technical and compliance review of Technical Specification surveillance procedures. This review will ensure that procedures used to satisfy Technical Specification Requirements are technically accurate, and that each Surveillance Requirement is satisfied within plant procedures. Also, in order to assure Surveillance Requirements for the standby and HPCS diesel generators are fully and correctly reflected in existing test procedures, a reconciliation review of diesel generator surveillance procedures and Surveillance Requirements will be performed for requirements that are scheduled on at least a monthly basis. This review of diesel generator Surveillance Requirements will complement the project team review of overall Surveillance Program implementation, and is scheduled for completion by November 30, 1992.

LICENSEE EVENT REPORTER)

TEXT CONTINUATION FACILITY NANE (1) DOCKET NUNBER (2) LER NUMBER (B) PAGE (3) ear umber ev. No.

Washington Nuclear Plant - Unit 2 0 5 0 0 0 3 9 7 2 40 00 6 F 6 ITLE (4)

Start and Load Times for Standby and HPCS Diesel Generators Not Measured During Monthly Surveillance Testin Due to Incorrect Translation of Technical S ecifications sufi if'he condition described in this report did not involve an actual failure of either a standby or HPCS diesel generator to start or load within the required time, nor did it involve circumstances which could have prevented the fulfillment of necessary safety functions. Additionally, the ability of the HPCS and standby diesel generators to perform their design function was demonstrated semi-annually despite deficiencies in the monthly surveillance procedures. Consequently, the condition described in this report did not adversely affect operation of the plant or the safety of the public, and was not safety significant.

Similar Events LERs91-013, 018, 019, 028, 036,92-002, and 92-035 identified instances of failure to satisfy Technical Specification Surveillance Requirements. The surveillance review team described in the corrective action section of this report was created to provide assurance of surveillance procedure adequacy. Previous events involving inadequate surveillance testing of the standby diesel generators due to the lack of an idle speed operation feature were described in LERs84-009, 023, 029, 041, 059, 070, and 085.

~Ef Text Reference f

$ Irntem ~Corn nent Standby Diesel Generator EB DG High Pressure Core Spray System (HPCS) BG HPCS Diesel Generator BG DG Handswitch, HPCS Control Circuit BG HS

Retrieved from "https://kanterella.com/w/index.php?title=ML17289A963&oldid=1992902"