ML17289B139

LER 92-043-01:on 921202,determined That Discrepancy Existed Between Plant Procedures & Monitoring Range of RPV Instrumentation in MCR & at Remote Shutdown Panel.Caused by Insufficient Communication.Procedures revised.W/930201 Ltr

ML17289B139
Person / Time
Site:	Columbia
Issue date:	02/01/1993
From:	John Baker, Poche R WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-93-023, GO2-93-23, LER-92-043, LER-92-43, NUDOCS 9302100473
Download: ML17289B139 (9)

Text

ACCELEtuRD DOCUMENT DIS'P~UTION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSIllN NBR:9302100473 DOC.DATE: 93/02/01 NOTARIZED: NO DOCKET FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION POCHEIR.J. Washington Public Power Supply System BAKER,J.W. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 92-043-00:on 921202,determined that discrepancy existed between plant procedures !l monitoring range of RPV instrumentation in MCR &'t remote shutdown panel. Caused by insufficient communication. Procedures revised.W/930201 ltr.

DZSTRZBUTZON CODE: ZE22T COPZES RECEZVED:LTR 2 ENCL TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc.

/ SZZE:

NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA 1 1 PD5 PD 1 1 CLIFFORD,J 1 1 INTERNAL: ACNW 2 2 ACRS 2 2 AEOD/DOA 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 SD 1 1 NRR/DST/SICBSH3 1 1 NRR/J3PT SPLB8Dl 1 1 NRR/DST/SRXB 8E 1 1 02 1 1 RES/DSIR/EIB 1 1 RGN5 FILE Ol 1 1 EXTERNAL: EG!EG BRYCE,J.H ~

2 2 L ST LOBBY WARD 1 1 NRC PDR 1 1 NSIC MURPHYgG.A 1 1 NSIC POOREiW. 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

ii WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George 11'ashington Way ~ Richland, 11'ashington 99352 February 1, 1993 G02-93-'023 Docket No. 50-397 jument Control Desk U.S. Nuclear Regulatory Commission.

Washington, D.C. 20555

SUBJECT:

NUCLEAR PLANT WNP-2, OPERATING LICENSE NPF-21 LICENSEE EVENT REPORT NO. 92-043-01 Transmitted herewith is Licensee Event Report No. 91-043-01 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. This supplement is submitted to provide final results from the root cause analysis.

Sincerely, J. W. Baker WNP-2 Plant Manager '(Mail Drop 927M)

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

INPO Records Center - Atlanta, GA Mr. D. L. Williams, BPA (Mail Drop 399) n t' F r i r 9302100473 930201 PDR .,ADOCK 05000397 8 PDR

LICENSEE EV T REPORT (LER)

FACILITY NAME (1) DOCKET NUHB R ( ) PAGE (3)

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

WEAKNESSES IN PROCEDURES FOR SHUT DOWN FOLLOWING A FIRE RESULTING FROM INADEQUATE COMMUNICATIONS EVENT DATE (5) LER NUMBER 6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8)

HOHTH OAY YEAR YEAR SEQUENTIAL E VIS ION HONTH OAY YEAR FACILITY NAMES DOCKET NUHB R (5)

,, NUMBER NUHBER 0 5 0 0 0 1 2 0 2 9 2 9 2 0 4 3 0 1 0 2 0 1 9 3 050 00 PERATING HIS REPORT IS SUBHITTEO PURSUANT TO THE REQUIREMENTS OF 10 CFR 5

(Check one or more of the following) (11)

OOE (9) I ONER 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) 50.73(a)(2)(i) 50.73(a)(2)(viii)(A) below 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) 50.73(a)(2)(iii) 50.73(a)(2)(x)

LICENSEE COHTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER REA CODE R. J. Poche, Licensing Engineer -

5 0 9 7 7 4 1 4 5 COHPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBEO IN THIS REPORT (13)-

CAUSE SYSTEH COMPONENT MANUFACTURER EPORTABLE CAUSE SYSTEH COHPONENT HAHUFACTURER REPORTABLE 0 HPRDS TO HPRDS SUPPLEHEHTAL REPORT EXPECTED (14) EXPECTED SUBHISSIOH MONTH DA'Y 'YEAR ATE (15)

YES (If es c iete EXPECTED SUBHISSION DATE) X NO On December 2, 1992, it was determined that a discrepancy between plant procedures and the monitoring range of reactor pressure vessel (RPV) instrumentation in the Main Control Room and at the Remote Shutdown Panel could have degraded the ability to remove residual heat during a post-fire plant shut down. The procedure governing operation of the Residual Heat Removal (RHR) System in the Alternate Shutdown Cooling mode prescribed operator actions at RPV levels that were outside the range of these instruments. Additionally, comparison of the Appendix R Shutdown Analysis and Abnormal Operating Procedures identified three other items involving procedural implementation and Shutdown Analysis requirements that could have affected operator response following a fire.

The root cause for these conditions was insufficient interdepartmental communication. A contributing cause was inadequately defined policy regarding responsibility for ensuring actions were reflected in procedures, As corrective action, the deficiencies identified in this report have been corrected in procedures, and actions will be undertaken to address programmatic issues involving Appendix R program implementation. The described conditions did not involve failure of any plant components or systems.

WNP-2 has not experienced a fire that required plant shut down. Consequently, the conditions described in this report did not adversely affect plant safety. However, if a fire had occurred, fire detection systems, suppression systems, and barriers, or equivalent compensatory measures, were available to mitigate an event if it had occurred.

LICENSEE EVENT REPOR LER)

TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (8) AGE (3) ear Number ev. No.

Washington Nuclear Plant - Unit 2 0 5 0 0 0 3 9 7 2 043 01 2 OF 7 ITLE (4)

WEAKNESSES IN PROCEDURES FOR SHUT DOWN FOLLOWING A FIRE RESULTING FROM INADEI0UATE COMMUNICATIONS p~lCh l

. Reactor Power Level - 100%

Plant Mode - 1 Event De cri i n On December 2, 1992, it was determined that a discrepancy between plant procedures and the monitoring range of reactor pressure vessel (RPV) level instruments located in the Main Control Room and at the Remote Shutdown Panel could have degraded the ability to remove residual heat during a post-fire plant shutdown. This condition was recognized after a review identified that the procedure governing operation of the Residual Heat Removal (RHR) System in the Alternate Shutdown Cooling mode prescribed operator.

actions at RPV levels that were outside the range of these instruments.

The instruments involved in this discrepancy, MS-LR/PR-R623A, MS-LR/PR-R623B, and MS-LI-10 provide fire-protected indication of RPV level, and facilitate plant operation in the Alternate ShutdowrI Cooling mode following certain postulated fire events. Further comparison of the Appendix R Shutdown Analysis and Abnormal Operating Procedures also identified three other reportable items involving procedural implementation of actions credited in the Shutdown Analysis and required actions that were not adequately identified in the Shutdown Analysis. It is believed that these additional items could have adversely affected operator respdnse in the event of a fire.

Immediate Corrective Actions No immediate corrective actions were necessary. However, procedures have been revised to correct the

, conditions described in this report.

F her Evalu i n nd orrective Action A. ~c

1. The discrepancy between shutdown panel instruments used to monitor RPV level and plant procedures was identified by'n Operations Department engineer during a review of fire-related operator actions, and was documented on a Problem Evaluation Request (PER) on November 11, 1992. The PER described three RPV level instruments, MS-LR/PR-R623A and MS-LR/PR-R623B (main control room), and MS-LI-10 (remote shutdown panel). The concern was that these instruments only provide RPV level monitoring in the -150" to +60" range.

LICENSEE EVENT REPOR (LER)

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

Year Number ev. No.

Washington Nuclear Plant - Unit 2 0 0 3 9 0 5 0 7 2 043 01 3 OF 7 ITLE (4)

WEAKNESSES IN PROCEDURES FOR SHUT DOWN FOLLOWING A FIRE RESULTING FROM INADEQUATE COMMUNICATIONS The procedure governing Residual Heat Removal (RHR) System operation in the Alternate Shutdown Cooling mode, PPM 2.4.2, Residual Heat Removal System, requires flooding of the RPV to the level of the Main Steam Lines (+130"), which is outside the monitoring range for these instruments. The Appendix R Shutdown Analysis assumes that operators may be required to use Alternate Shutdown Cooling to remove residual heat following a fire because not all of the equipment necessary for normal shutdown evolutions is fire-protected.

The monitoring range of these RPV level instruments has been evaluated by Engineering and found to be acceptable to support required plant operations and satisfy design requirements. It was the method prescribed in procedure PPM 2.4.2 for achieving Alternate Shutdown Cooling operation that was inadequate.

In addition to the RPV level monitoring concern, several other items involving required operator actions were identified. These additional items involved required operator actions that were not adequately identified in the Appendix R Shutdown Analysis, and inadequate implementation of required operator actions that were identified in the Appendix R Shutdown Analysis. These items were identified during a review of plant procedures.

This review was initiated to ensure that operator actions required by the Appendix R Shutdown Analysis were adequately reflected in implementing procedures, and was performed as a corrective action for a previous similar event described in LER 50-397/92-018. When plant management assigned the action to perform this review, it was their understanding that the review scope would include a comprehensive evaluation of all operator actions required by the Appendix R Shutdown Analysis.

However, the design and plant organizations that performed this review did not similarly understand the intended review scope. Consequently, the initial review only considered operator actions following a fire outside the Main Control Room. As a result, identification of some items was delayed until the review of required actions following a fire in the Main Control Room'was completed.

It has been determined that three of the additionally identified items could have adversely affected operator response to a fire. These three additional items, and the previously described item involving Alternate Shutdown Cooling operation following a fire, have been inadequately implemented in plant procedures since initial plant startup. The three additionally identified items are summarized below:

1) -Water leg pumps for RHR pumps A and B are not fire-protected. Consequently, it is necessary to start the RHR pumps within one hour following a fire in order to ensure that RHR piping remains full. These actions were not adequately identified or reflected in procedures.

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION AGILITY NAHE (1) DOCKET NUHBER (2) LER NUHBER (8) AGE (3) ear umber ev. No.

Washington Nuclear Plant - Unit 2 0 3 9 7 0 5 0 0 2 4 3 1 4 F 7 ITLE (4)

WEAKNESSES IN PROCEDURES FOR SHUT DOWN FOLLOWING A FIRE RESULTING FROM INADEQUATE COMMUNICATIONS

2) Circuits at local control panels for the emergency diesel generators that are associated with the automatic synchronization feature are not fire-protected. An attempt to automatically synchronize from the local control panels could result in damage to the diesel generator logic that would preclude synchronization and any subsequent attempts to start. Precautionary guidance advising operators to only use the manual synchronization feature following a fire was not adequately reflected in procedures.

3) In order to prevent propagation, of smoke and gasses to cable spreading areas and critical switchgear rooms following a fire in the control room chiller area, it is necessary to secure several HVAC fans. The equipment specific identifiers for these fans were incorrectly stated-

. in procedures.

2. The conditions described in this report were documented on November 11, 1992. Following an extensive investigative effort it was determined that these items were reportable, and necessary notifications were made under 10CFR50.72(b)(2)(iii) on December 2, 1992. These conditions are also reportable under 10CFR50.73(a)(2)(v) as conditions that 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.

3. The root cause for the described procedural implementation inadequacies was a deficiency involving failure to ensure sufficient interdepartmental communication. This is a ..

management/managerial methods category root cause, Implementation of Appendix R Shutdown Analysis requirements in plant procedures was not fully achieved due to a weak interface between design an'd plant organizations. This root cause is considered programmatic due to a number of similar discrepancies involving procedural implementation of operator actions that are needed to support Appendix R requirements that have been recently identified.

A contributing cause was identified involving inadequately defined policy as it pertains to Appendix R program responsibilities. This is a management/managerial methods category root cause. Responsibility for ensuring that operator actions credited in the Appendix R Shutdown Analysis were implemented in procedures was assigned diffusely among several design and plant organizations,

4. 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,

LICENSEE EVENT REPOR LER)

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

Washington Nuclear Plant - Unit 2 3 9 0 5 0 0 0 7 2 043 01 5 OF 7 ITLE (4)

WEAKNESSES IN PROCEDURES FOR SHUT DOWN FOLLOWING A FIRE RESULTING FROM INADE(UATE, COMMUNICATIONS B. Fu her orrective Ac i n In response to the conditions described in this report, the following actions have been taken:

1. PPMs 4.12.1.1 and 4.12.4.1 were revised, as required, to correct the conditions described in this report.

2. PPM 2.4.2 was revised to include a separate section for Alternate Shutdown Cooling operation, and account for post-fire conditions.

3. Engineering procedure, EDP 1.27, Transmitting Action Items from Engineering to External Organizations was recently created. This procedure will provide additional assurance that engineering information is transmitted to the plant organizations responsible for implementation.

Additionally, the following corrective actions are also planned:

4

1. An assessment will be performed to evaluate the interface between design organizations and other plant organizations. The scope of this assessment will include an examination, of this interface for Appendix R related matters, and is scheduled to be performed by April 1993.

2. Plant management will perform an assessment of the process established in EDP 1.27 for closure of engineering information transmitted to plant organizations. This assessment will evaluate the timeliness and effectiveness of the process described in EDP '1.27, and is scheduled for completion by July 31, 1993.

/

3. Inter-organizational communications and responsibilities within the Appendix R implementation process, including responsibility for ensuring actions are adequately reflected in procedures, will be evaluated. These relationships will be clarified and redefined, as necessary, based on the results of this evaluation. This action is scheduled for completion by September 1, 1993.

4. A review of the Appendix R Shutdown Analysis and related design documents will be performed to ensure operator actions identified therein have been adequately reflected in plant procedures; Conversely, plant procedures will be reviewed to ensure Appendix R related operator actions identified therein have bases in design documents. Performance of these reviews, and any necessary procedure or design document changes, will be completed by September 1, 1993.

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION AGILITY NAME (i) DOCKET NUNBER (2) LER NUNBER (8) AGE (3) fear umber ev. No.

Washington Nuclear Plant - Unit 2 0 5 0 0 0 3 9 7 2 043 01 6 OF 7 ITLE (4)

WEAKNESSES IN PROCEDURES FOR SHUT DOWN FOLLOWING A FIRE RESULTING FROM INADE(UATE COMMUNICATIONS WNP-2 has not experienced a fire that adversely affected the ability to shut down the plant during the period when required operator actions were not adequately reflected in procedures. Consequently, the conditions described in this report did not have an adverse affect on safe operation of the plant, or the health and safety of plant personnel or the general public. However, if a fire had occurred during the time when Alternate Shutdown Cooling requirements were inadequately reflected in procedures, 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'o promptly identify, confine, and extinguish fires, and the availability of fire barriers and barrier penetrations minimized the possibility of a fire related to challenge safety systems.

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. The conditions described in this report were identified by a review performed as a corrective action for this previous event.

LICENSEE EVENT REPORT (LER)

'TEXT, CONTINUATION FACILITY NAHE'(1) DOCKET NUHBER (2) LER NUHBER (8) PAGE (3) ear "lumber ev. No.

Washington Nuclear Plant - Unit 2 0 5 0 0 0 3 9 7 2 043 01 7. OF 7 ITLE (4)

WEAKNESSES IN PROCEDURES FOR SHUT DOWN FOLLOWING A FIRE RESULTING FROM INADEQUATE COMMUNICATIONS EII Inf rm tion E~f

~Sstem ~om linen Main Control Room NA Remote Shutdown Panel P.L

'Alternate Shutdown Cooling Mode of RHR BO Residual Heat Removal System (RHR), Pump BO P Reactor Core Isolation Cooling (RCIC) System, Pump BN P High Pressure Core Spray (HPCS) System, Pump BG P Critical Switchgear Area HVAC, Fans VI FAN Control Room Chiller KM, VI CHU E

Emergency Diesel Generator EK DG Reactor Pressure Vessel (RPV) AD BLR Level Indicators MS-LI-10,-MS-LR/PR-R623A /B SB LI