ML17289B097

LER 92-043-00:on 921202,identified That Operator Actions Inadequately Presented in Procedures Used to Implement App R Shutdown Analysis Requirements.Root Cause Under Consideration.Suppl LER Will Be submitted.W/930104 Ltr

ML17289B097
Person / Time
Site:	Columbia
Issue date:	01/04/1993
From:	John Baker, Poche R WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-93-001, GO2-93-1, LER-92-043, LER-92-43, NUDOCS 9301080015
Download: ML17289B097 (6)

Text

ACCELERA']AD REGULA DOCUMENT DISTgfBUTION Y INFORMATION DISTRIBUTI SYSTEM (RIDS)

SYSTEM

'CCESS~ON NBR:9301080015 DOC.DATE: 93/01/04 NOTARIZED: NO DOCKET FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION POCHEtR.J. Washington Public Power Supply System BAKERPJ.W. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 92-043-00:on 921202,operator actions inadequately repesented in procedures used to implement app R shutdown analysis requirements. Cause still corrective actions were necessary.W/930104 under investigation.No ltr.

D DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR Q ENCL TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc. g SIZE:

NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL D PD5 LA 1 1 PD5 PD 1- 1 CLIFFORD P J 1 1 D

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 NRR/DOEA/OEAB NRR/DST/SELB 8D 1,1 1

1 1

1 NRR/DLPQ/LPEB10 NRR/DREP/PRPBll NRR/DST/SICB8H3 1

1 2

1 2

1 JfRR/DSTJSPLB8Dl 1 1 NRR/DST/SRXB 8E 1 1

~REG=FI-LE 02 1 1 RES/DSIR/EIB 1 1 RGNS FILE Ol 1 1 EXTERNAL'G&G BRYCEPJ AH 2 2 L ST IOBBY WARD 1 1 NRC PDR 1 1 NSIC MURPHY,,G.A 1 1 NSIC POORE,W. 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 January 4, 1993 G02-93-001 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 EUENT REPORT NO. 92-043-00 Transmitted herewith is Licensee Event Report No.92-043 for the WNP-2 Plant. This .

report is submitted in response to the report requirements of 10CFR50.73. Final results from an ongoing root cause determination and corr'ective actions will be provided in a supplement to this report.

Sincerely,

. W. Baker WNP-2 Plant Manager (Mail Drop 927M)

JWB/RJP/nw Enclosure CC: Mr. J. B. Martin, NRC'- Region U Mr. R. Barr, NRC Resident Inspector (Mail Drop 901A, 2 Copies)

INPO Records Center - Atlanta, GA Mr. D. L. Williams, BPA (Mail Drop 399)

.930108001 5- 9301 04 PDR ADOCK 05000397 8 PDR

/gal p

LICENSEE EVE% REPORT (LER)

ACILITY HAME (1) DOCKET NUMB R ( ) PAGE (3)

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

OPERATOR ACTIONS INADEQUATELYREPRESENTED IN PROCEDURES USED TO IMPLEMENT APPENDIX R SHUTDOWN ANALYSIS REQUIREMENTS EVENT DATE (5) LER NUMBER 6) REPORT DATE (7) OTHER FACILITIES IHVOLVEO (8)

MOHTH OAY YEAR SEQUENTIAL:;:-.,; EVI 5 IOH MONTH DAY YEAR FACILITY NAMES CKE NUMB R (5)

HUMBER i:- UMBER 5 0 I 2 0 2 9 2 9 2 0 4 3 0 0 0 I 0 4 050 PERATING HIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR 5: (Check one or more of the following) (11)

ODE (9) I POWER LEVEL 20.402(b) 20.405(C) 50.73(a)(2)(iv) 77.71(b)

(i0) 0.405(a)(l)(i) 50.36{c)fi) X 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)(l)(iii) 50.73(a)(2)(i) 50.73(a)(2)(viii)(A) below and in Text, HRC 20.405(a)(1)(iv) 50.73(a)(2)(ii) 50.73(a)(2)(viii)(B) Form 366A) 20.405(a)(1)(v) 50.73(a)(2)(iii) 50.73(a)(2)(x)

LICENSEE CONTACT FOR THIS LER 12)

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

CAUSE SYSTEM COMPONEHT MANUFACTURER EPORTABLE CAUSE SYSTEM COMPOHEH'I MANUFACTURER REPORTABLE 0 NPRDS TO HPRDS SUPPLEMENTAL REPORT EXPECTED (14) EXPECTED SUSMlSSIOH MONTH DAY YEAR ATE (15) 93 YES (lf yes, complete EXPECTED SUBMISSIOH DATE) HO 01 31 mAcs oa>

It was identified that procedures for performing Alternate Shutdown Cooling were not supported by the indication range of fire protected reactor vessel level instruments in the Main Control Room or at the Remote and Alternate Shutdown Panels. Also, fans that were expected to be shut off after a fire were misidentified in procedures. These conditions could have degraded the ability to shutdown the plant or remove residual heat following a fire. Other weaknesses were also identified with regard to Shutdown Analysis directed operator actions.

The root cause of these conditions is still under. consideration. Procedures for performing Alternate Shutdown Cooling were changed and other procedure deficiencies have been corrected. The described conditions did not involve failure of any plant components or systems. A supplemental LER will be submitted with final root causes and corrective actions, WNP-2 has not experienced a fire that required plant shut down. Fire detection and suppression systems, and fire barriers were available to mitigate a fire if it had occurred. Consequently, the conditions described in this report are not safety significant.

LICENSEE EVENT REPORT R)

TEXT CONTINUATION AGILITY NAHE (i) DOCKET NUHBER (2) LER NUHBER (8) AGE (3)

Year ev. No.

Washington Nuclear Plant,- Unit- 2 0 5 0 0 0 3 9 7 2 43 00 2 F 4 ITLE (4)

OPERATOR ACTIONS INADEQUATELY REPRESENTED IN PROCEDURES USED TO IHPL'EMENT APPENDIX R SHUTDOWN ANALYSIS REQUIREMENTS Plant Condi ions Power Level - 100%

Plant Mode - 1 Event Descri tion

'n November 12, 1992, an Operations Department engineer, during a review of procedural implementation for fire related operator actions, identified that fire protected level indication in the Main Control Room and at both the Remote and Alternate Shutdown Panels did not provide sufficient range to support existing procedures for Alternate Shutdown Cooling. The instrument range for fire protected level indicators is

-150 inches to +60 inches; however, Alternate Shutdown Cooling requires flooding of the reactor vessel up to the level of the Main Steam Lines (+108"). As a result of this condition, operators may not have had accurate level indication following a fire.

While investigating this issue, other discrepancies between the Appendix R Shutdown Analysis and plant procedures were noted. On December 2, 1992, it was determined that the level instrument problem and a separate discrepancy involving misidentified fans could have resulted in degraded ability to shutdown the plant or remove residual heat in the event of a fire.

Immediate orrective Actions No immediate corrective actions were necessary. However, procedures have been revised to provide appropriate direction for operator actions in response to a fire.

Further Evaluati n and rrec ive Ac ion Fu her Evaluation The Shutdown Analysis assumes that Operators may be required to use Alternate Shutdown Cooling methods to remove residual-heat following a fire because equipment necessary for normal shutdown evolutions is not totally fire protected. Due to inadequate level instrument range, and the lack of an alternatively specified method for determining vessel water level above +60 inches, it was concluded that procedures guiding decay heat removal operations from the Main Control Room and Alternate and Remote Shutdown Panels were deficient.

L'ICENSEE EVENT REPORT R)

TEXT CONTINUATION FACILITY HAHE (I) OOCKET'KUHSER (2) LER HUHBER (8) AGE (3) umber ev. Ho.

Washington Nuclear Plant - Unit 2 0 5 0 0 0 3 9 7 2 043 00 3 OF 4 ITLE (4),

OPERATOR ACTIONS INADE(UATELY REPRESENTED IN PROCEDURES USED TO IMPLEMENT APPENDIX R SHUTDOWN ANALYSIS RE(UIREHENTS The Shutdown Analysis also requires that fans WMA-AH-52Band WMA-AH-53Bbe secured in the event of a fire in one Radwaste Building area. These fans were incorrectly identified in procedures as WMA-AH-52Aand 53A, respectively. Continued operation of these fans following a fire might have spread smoke and hot gasses to critical switchgear and other areas containing vital equipment. The. fans were misidentified due to an error in an engineering memorandum to Operations.

On December 2, 1992, the above conditions were determined to be reportable under 10CFR50.72(b)(2)(iii), and necessary notifications were made. These conditions are also reportable under 10CFR50.73(a)(2)(v) as conditions that alone could have prevented fulfillment of the safety function of structures or systems that are needed to shut down the reactor and maintain it in a safe shutdown condition, or remove residual heat.

Other weaknesses and deficiencies identified involved actions required for fires both inside and outside the Main Control Room. These items include: fire related compensatory measures for loss of fuel pool cooling, and compensatory measures to address loss of the RHR water leg pumps. It has been determined that these weaknesses would not have significantly affected 'operator response to a fire.

A previous LER, 50/397 92-18 was submitted due to discrepancies between fire directed operator actions described. in plant procedures and requiremeTIts of the Appendix R Safe Shutdown Analysis. 'As a corrective action, a commitment was made to perform a comparative review of operator actions made in plant procedures against requirements in the Safe Shutdown Analysis. When this review was performed, it did not directly compare operator actions described in procedures to the Shutdown Analysis. Instead, it used memoranda and other Engineering correspondence that were based on the Shutdown Analysis to perform the comparison. Failure to review the Shutdown Analysis against fire directed operator actions resulted in delayed identification of some items discussed in this LER.

Determination of root causes for the deficiencies described herein is still in progress.

The condition described in this report did not involve any structures, components, or systems that were inoperable at the start of the event, nor did it involve failure of a plant component or system.

P Firth r rr iv Aci n

1. Plant procedures were revised to reflect an acceptable method, using existing instrumentation, for achieving Alternate Shutdown Cooling operation.

2. A supplemental LER will be submitted by January 31, 1993 providing details of the final root cause and corrective actions.

LICENSEE EVENT REPORT R)

TEXT CONTiNUATlON AGILITY NAME (1) OOCKET 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 - 43 0 4 F 4 1TLE (4)

OPERATOR ACTIONS INADEQUATELY REPRESENTED IN PROCEDURES USED TO IMPLEMENT APPENDIX R SHUTDOWN ANALYSIS REQUIREHENTS WNP-2 has not experienced a fire that could have adversely affected the ability to shut down the plant during the period when required operator actions were not,adequately reflected in procedures.

Furthermore, during this period, fire detection, suppression, and barrier systems were either operable or required compensatory measures had been implemented. The availability of fire detection and suppression equipment ensured the ability to promptly identify, confine, and extinguish fires, and the availability of fire barriers and barrier penetrations minimized the possibility of a fire related challenge to safety systems.

Consequently, the conditions described in this report did not adversely affect safe operation of the plant, or the health and safety of plant personnel or the general public.

imilar Event A previous occurrence involving inadequate procedural implementation of required operator actions necessary to mitigate the consequences of a fire, and Shutdown Analysis deficiencies was described in LER 92-018.

II Information EII Reference Text Reference ~Sstem om onen Fuel Pool Cooling System (FPC) DA Reactor Core Isolation Cooling System (RCIC) BN Control Room Chiller KM, VI CHU Service Water System (SW), valves BI Radwaste Building NE Reactor Building Main Control Room NA Remote Shutdown Panel PL Residual Heat Removal System (RHR), pump BO Cable Spreading and Switchgear Area HVAC, fans VI FAN Nuclear Steam Supply Shutoff System (NSSSS) JM Alternate Shutdown Cooling BO