ML17290A306

LER 93-010-00:on 930304,noncompliance W/Ts Identified as Part of TS Surveillance Improvement Project Re end-of-cycle Recirculation Pump Trip & Closure of Turbine Throttle Valve. Caused by Less than Adequate Procedures.Procedures Revised

ML17290A306
Person / Time
Site:	Columbia
Issue date:	05/14/1993
From:	Lewis K WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:
Shared Package
ML17290A305	List: ML17290A304 ML17290A306
References
LER-93-010, LER-93-10, NUDOCS 9305180310
Download: ML17290A306 (18)

Text

LICENSEE EVI4 REPORT (LER)

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

Washin ton Nuclear Plant - Unit 2 0 5 0 0 0 3,9 7 I DF 15 ITLE (4)

TECHNICAL SPECIFICATION SURVEILLANCE IMPROVEMENT PROJECT IDENTIFICATION OF NON-CONFORMING CONDITIONS EVENT DATE (5) LER NUMBER 6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8)

HONTH DAY YEAR YEAR SEQUENTIAL s EVI SION MONTH DAY YEAR FACILITY NAMES 0 CKE NUHB R (5)

NUMBER is. UHBER s%'

00 0 4 1 4 9 3 9 3 1 0 0 1 0 5 1 4 9 3 0 5 00 PERATIHG HIS REPORT IS SUBHITTED PURSUANT TD THE REQUIREMENTS OF 10 CFR 5: (Check one or more of the following) (11 ODE (9) 1 OWER LEVEL 20.402(b) 20.405(C) 50.73(a)(2)(iv) 77.71(b)

(10) 0.405(a)(1)(i) 50.36(c)(1) 50.73(a)(2)(v) 73.73(c) 0.405(a)(1)(ii) 50.36(c)(2) 50.73(a)(2)(vii) THER (Specify in Abstract 0.405(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)(8) orm 366A) 20.405(a)(1)(v) 50.73(a)(2)(iii) 50.73(a)(2)(x)

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TELEPHONE NUHBER Kurt B. Lewis REA CODE 5 0 9 7 7 - 4 1 4 5 COHPLETE OHE LINE FOR EACH COHPOHENT FAILURE DESCRIBED IH THIS REPORT (13)

CAUSE SYSTEH COHPDNEN'I MANUFACTURER EPORTABLE CAUSE SYSTEM COHPDNEHT HANUFACTURER REPORTABLE s,'.s(s.';<.",.

0 HPRDS 1'0 HPRDS SUPPLEHEHTAL REPORT EXPECTED (14) EXPECTED SUBHISSIOH MONTH DAY YEAR ATE (15)

YES (If yes, complete EXPECTED SUBHISSIOH DATE) NO TRACT UN On March 4, 1993, a condition of non-compliance with WNP-2 Technical Specifications was identified as part of a Technical Specification Surveillance Improvement Project (TSSIP). This two year project was recommended by a Supply System Quality Action Team formed as a corrective action of LER 91-013-02.

The TSSIP revises and broadens the scope of the Surveillance Procedure Verification Program completed in May 1991.

A total of five reportable problems identified by this process are described in this LER. All five items relate to failure of procedures to fully implement WNP-2 Technical Specification surveillance requirements. This LER reports the initial findings of the TSSIP surveillance procedure review process.

Based upon previous experience with the Surveillance Procedure Verification Program, it is likely that additional reportable items will be identified. A supplement to this LER will be submitted as necessary to describe future reportable items.

Immediate and further corrective actions include, but are not limited to, entering Technical Specification Action Statements, additional testing, Plant Procedure changes, Technical Specification changes, and design changes.

The root causes for these events include less than adequate barriers and controls for program changes, and less than adequate test procedures, directives/requirements, and design. The general root cause has been r)etermined to be less than adequate management control of the Surveillance Test Program.

930S1803i0 930504 PDR ADOCK 05000397 8 ano

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Washington Nuclear Plant - Unit 2 0 5 0 0 0 3 9 7 3 010 01 2 F 15 ITLE (4)

TECHNICAL SPECIFICATION SURVEILLANCE IMPROVEMENT PROJECT IDENTIFICATION OF NON-CONFORMING CONDITIONS The safety significance of each item and the whole surveillance program was evaluated, and it has been concluded that this event had potential safety significance.

Plant Conditions Power Level - 100%

Plant Mode - 1 ven De cri i n On March 4, 1993, a condition of non-compliance with WNP-2 Technical Specifications was identified as part of a Technical Specification Surveillance Improvement Project (TSSIP). This is a two year project recommended by a Supply System Quality Action Team formed as a corrective action of LER 91-013-02.

The TSSIP is staffed by Contract Engineers and Supply System employees, and revises and broadens the scope of the Surveillance Procedure Verification Program completed in May 1991.

The previous Surveillance Procedure Verification Program was a five week Technical Specification surveillance implementation review. This was a limited scope review that compared Technical Specification surveillance requirements with information obtainable from the Scheduled Maintenance System (SMS) data base. The surveillance procedures were reviewed for purpose, but not content or methodology. Approximately 145 discrepancies were identified during the review.

In contrast to the previous review, the TSSIP review is an in-depth technical review of the surveillance procedures to ensure they meet Technical Specification surveillance requirements. The review criteria includes proper test methodology, procedure consistency, technical accuracy, and reference bases for all acceptance criteria. The goals of the project are to assure:

1. That all related procedures required to be performed to satisfy Technical Specification surveillance requirements are referenced (listed) and explained in the Purpose section of the procedure.

2. That any prerequisites and special conditions required to assure Technical Specification compliance are stated in the procedure.

3. That all procedure acceptance criteria satisfy the Technical Specification surveillance requirements, and all acceptance criteria have reference bases.

4. That procedure*steps associated with assuring Technical Specification acceptance criteria are met and identified.

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TECHNICAL SPECIFICATION SURVEILLANCE IMPROVEMENT PROJECT IDENTIFICATION OF NON-CONFORMING CONDITIONS

5. That all numerical values, setpoints, tolerances, calculations, graphs, figures, and tables included or referenced in the procedure are consistent with values specified in Technical Specifications.

6. That the procedure tests the entire channel, including sensor, indicators, alarms, and trip functions as applicable.

7. That the procedure performance frequency meets Technical Specification requirements.

8. That the procedure satisfies the applicable Technical Specification surveillance requirements, and meets the intent of the Technical Specification Bases.

Any potential deficiencies will be evaluated for validity and necessary follow-up actions.

A total of five reportable problems identified by this process are described in this LER. All five items relate to failure of procedures to fully implement WNP-2 Technical Specification surveillance requirements.

This LER reports the initial findings of the TSSIP surveillance procedure review process. The project was initiated November 1, 1992, and is scheduled to continue through April 1994. Based upon previous experience with the Surveillance Procedure Verification Program, it is likely that additional reportable items will be identified. A supplement to this LER will be submitted as necessary to describe future reportable items.

This LER is written with each item discussed as a separately numbered paragraph under the major headings of Specific Event Description, Immediate Corrective Action, Further Evaluation, Specific Further Corrective Action, and Specific Safety Significance, A general discussion of all items is found under the major headings of General Event Description, above, and General Further Corrective Actions, General Safety Significance, and Similar Events, below.

S ific Even De cri tion

1. End- f-C cle Recirculation Pum Tri Surveillance Requirement 4.3.4.2.3 requires the End-Of-Cycle (EOC) Recirculation Pump Trip (RPT) circuit breakers to be tested at least once per 60 months to demonstrate that arc suppression time is less than or equal to 83 milli-seconds. Technical Specification Surveillance (TSS) 7.4.3.4.2.3.3A, "EOC-RPT Breaker Arc Suppression Time RPT-3B/RPT-4A," and TSS 7.4.3.4.2.3.3B, "EOC-RPT Breaker Arc Suppression Time RPT-3A/RPT-4B," were used to perform this test. However, a review of these procedures discovered that they actuate Trip Coil 1 (TC-1) for EOC-RPT circuit breaker arc suppression response time testing, and not Trip Coil 2 (TC-2). TC-2 performs the actual EOC-RPT breaker trip safety function, whereas, TC-1 performs the normal and Anticipated Transient Without Scram (ATWS) RPT breaker trip functions. Since the electrical and mechanical characteristics of TC-2

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washington Nuclear Plant - Unit 2 0 5 0 0 0 3 9 7 3 010 01 4 F 15 ITLE (4)

TECHNICAL SPECIFICATION SURVEILLANCE IMPROVEMENT PROJECT IDENTIFICATION OF NON-CONFORMING CONDITIONS could vary from that of TC-1, the test methodology is inadequate to assure the RPT breaker trip and arc suppression response time meets the surveillance requirement. Consequently, inadequate surveillance procedures caused the Plant to violate Technical Specification 4.0.3 by not satisfactorily completing the surveillance requirements within the allowed interval.

Technical Specifications 3.0.1 and 3.0.4 were violated when reactor power was increased to 30%

without meeting the operational condition surveillance requirements, and by not entering Technical Specification Action Statement (TSAS) 3.3.4.2.e.

2. rbin overn r V Ive- Fa I re Surveillance Requirement 4.3.4.2.1 requires the EOC-RPT Turbine Governor Valve - Fast Closure system instrumentation to be demonstrated operable by the performance of a monthly Channel Functional Test (CFT) and a Channel Calibration (CC) every 18 months in accordance with Table 4.3.4.2.1-1.2. TSS 7.4.3.1.1.20, "RPS and EOC Recirc Pump Trip - TGV Fast Closure Channel A - CFT/CC," and TSS 7.4.3.1.1.78, "RPS and EOC Recirc Pump Trip -TGV Fast Closure Channel B - CFT/CC," were used to perform the CFT and CC. However, a review of these procedures discovered that they direct that certain safety-related function verification steps in the CFT not be performed, and marked "N/A" (Not Applicable), when reactor power is less than 30%. When these portions of the CFT were not completed, the CFT did not meet the surveillance requirements. This also results in the CC not meeting the surveillance requirements because it takes credit for satisfactory completion of the CFT. WNP-2 Technical Specification definitions require a CC to include a CFT.

Consequently, inadequate surveillance procedures caused the Plant to violate Technical Specification 3.0.3 by not satisfactorily completing the surveillance requirements within the allowed interval. Technical Specification's 3.0.1 and 3.0.4 were violated when reactor power was increased to 30% without meeting the operational condition surveillance requirements, and by not entering TSAS 3.3.4.2.e.

3. r ine Thr tie V Iv - I ure Surveillance Requirement 4.3.4.2.1 requires the EOC-RPT Turbine Throttle Valve - Closure system instrumentation to be demonstrated operable by the performance of a monthly CFT in accordance with Table 4.3.4.2.1-1.1. TSS 7.4.3.8.2.1, "Monthly Turbine Valve Tests," was used to perform this test.

However, a review of the procedure discovered that it allows that certain safety-related function verification steps not be performed, and marked "N/A," if either Reactor Recirculation (RRC) pump is not in 60 Hertz operation. The RRC pumps are normally in 15 Hertz operation at a reactor power level less than 30%. When these portions of the CFT were not completed, the CFT did not meet the surveillance requirement. Consequently, an inadequate surveillance procedure caused the Plant to violate Technical Specification 4.0.3 by not satisfactorily completing the surveillance requirements within the allowed interval. Technical Specifications 3.0.1 and 3.0.4 were violated when reactor power

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Washington Nuclear Plant - Unit 2 0 5 0 0 0 3 9 7 3 010 01 5 OF 15 ITLE (4)

TECHNICAL SPECIFICATION SURVEILLANCE IMPROVEMENT PROJECT IDENTIFICATION OF NON-CONFORMING CONDITIONS was increased to 30% without meeting the operational condition surveillance requirements, and by not entering TSAS 3.3.4.2.e.

4. E -RPT em In men i n Surveillance Requirement 4.3.4.2.1 requires the EOC-RPT Turbine Governor Valve - Fast Closure system instrumentation to be demonstrated operable by the performance of a CC every 18 months in accordance with Table 4.3.4.2.1-1.2. The system logic is dependent on the proper operation of pressure switches MS-PS-3A, 3B, 3C and 3D, which sense main turbine first stage pressure and enable the EOC-RPT logic at reactor power levels greater than or equal to 30%. Although these pressure switches are part of the EOC-RPT system instrumentation, no procedures were developed to meet the CC surveillance requirements. The Preventive Maintenance (PM) Program includes these pressure switches, and instrument calibrations were performed at approximately 18 month intervals. However, WNP-2 Technical Specification definitions require that a CC include a CFT.

There is no assurance that acceptable CFTs were performed following each calibration. Consequently, the lack of adequate surveillance procedures caused the Plant to violate Technical Specification 4.0.3 by not satisfactorily completing the surveillance requirements within the allowed interval. Technical Specification 3.0.1 and 3.0.4 were violated when reactor power was increased to 30% without meeting the operational condition surveillance requirements, and by not entering TSAS 3.3.4.2.e.

5. IRMNe iv V I eP wer l N Tested On April 14, 1993, Technical Specification Surveillance Review personnel determined that all Intermediate Range Monitors (IRMs) were inoperable, Personnel attributed the inoperability to a lack of a Logic System Functional Test (LSFT) of the negative-voltage-low IRM inoperative trip function. This trip function is provided with each IRM channel. The Reactor Manual Control System (RMCS) uses IRM inoperative trip signals to generate rod blocks, and the Reactor Protection System (RPS) uses these same inoperative trip signals to generate scrams. Technical Specification 4.3.1.2 requires "LSFTs and simulated automatic operation of all channels shall be performed at least once per 18 months" An ~

LSFT is defined as "a test of all logic components, i.e., all relays and contacts, all trip units, solid state logic elements, etc, of a logic circuit, from sensor through and including the actuated device, to verify OPERABILITY. The LSFT may be performed by any series of sequential, overlapping or total system steps such that the entire logic system is tested".

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Year Number ev. No.

Washington NucleaY Plant - Unit 2 0 5 0 0 0 3 9 7 3 I 0 I 6 F 15 ITLE (4)

TECHNICAL SPECIFICATION SURVEILLANCE IHPROVEHENT PROJECT IDENTIFICATION OF NON-CONFORHING CONDITIONS Imm i rr iv Aci n Immediate corrective actions were initiated for each item discovered during the TSSIP procedure reviews.

They are enumerated below in paragraphs corresponding to the event description above:

1. En - f- le R irculation Pum Tri EOC-RPT System Channels A and B were declared inoperable and Technical Specification Action Statement (TSAS) 3.3.4.2.e was entered at 1932 hours0.0224 days <br />0.537 hours <br />0.00319 weeks <br />7.35126e-4 months <br /> on March 4, 1993. Reactor power was reduced to 92% and the Minimum Critical Power Ratio (MCPR) was demonstrated to be less than the MCPR Limit at 2008 hours0.0232 days <br />0.558 hours <br />0.00332 weeks <br />7.64044e-4 months <br />. Continued power operation was thereby authorized by the TSAS.

2. r in yern rVlv -F l re No immediate corrective action was required as Turbine Governor Valve EOC-RPT System Channels A and B were in compliance with Surveillance Requirement 4.3.4.2.1 at the time of event discovery on March 9, 1993. TSS 7.4.3.1.1.20 and TSS 7.4.3.1.1.78 were satisfactorily completed at a reactor power level greater than 30% on February 19, 1993, and February 20, 1993, respectively.

3. Tr in Thr t le V Iv - l re No immediate corrective action was required as Turbine Throttle Valve EOC-RPT System Channels A and B were in compliance with Surveillance Requirement 4.3.4.2.1 at the time of event discovery on March 9, 1993. TSS 7.4.3.8.2.1 was satisfactorily completed at a reactor power level greater than 30%, with both RRC pumps in 60 Hertz operation, on March 6, 1993.

4. EO -RPT stem Instrumen tion No immediate corrective action was required as Turbine Governor Valve EOC-RPT System Channels A and B were in compliance with Surveillance Requirement 4.3.4.2.1 at the time of event discovery on March 9, 1993. Pressure switches MS-PS-3A, 3B, 3C and 3D were all found to have been calibrated within the last 18 months. TSS 7.4.3.1.1.20 and TSS 7.4.3.1.1.78 meet the CFT requirements when performed at a reactor power level greater than or equal to 30%. As previously stated, they were satisfactorily completed on February 19, 1993, and February 20, 1993, respectively.

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TECHNICAL SPECIFICATION SURVEILLANCE IMPROVEMENT PROJECT IDENTIFICATION OF NON-CONFORMING CONDITIONS

5. IRM Ne ative Volta e Power Su 1 Not Tested No immediate corrective action was required, because the IRMs were already deemed inoperable at the time Technical Specification Surveillance Review personnel discovered the IRM inoperability problem.

The IRMs are normally declared inoperable in Mode 1, as associated Channel Functional Test (CFT) surveillances cannot be performed during this mode of operation.

F h rEv 1 i n nd rreciv Aci n P~hE These events are reportable under 10CFR50.73(a)(2)(i)(B) as "Any operation or condition prohibited by the plant's Technical Specifications...," and under 10CFR50.73(a)(2)(vii)(D) as "Any event where a single cause or condition caused... two independent trains or channels to become inoperable in a single system designed to... Mitigate the consequences of an accident."

There were no structures, components, or systems that were inoperable before the start of these events that contributed to the events.

Further evaluations were performed on each of the items discovered during the TSSIP procedure reviews. They are enumerated below in paragraphs corresponding to the event description above:

1. nd- f- 1 Recir 1 i n Pum Tri In accordance with 10CFR50.72(b)(1)(ii)(B), this item was reported to the NRC Operations Center via the Emergency Notification System (ENS) at 2026 hours0.0234 days <br />0.563 hours <br />0.00335 weeks <br />7.70893e-4 months <br /> on March 4, 1993, as "Any event or condition during operation that... results in the nuclear power plant being... In a condition that is outside the design basis of the plant...."

TSS 7.4.3.4.2.3.3A and TSS 7.4.3.4.2.3.3B were developed and approved on February 19, 1992, as a corrective action of LER 91-013-02. The previous surveillance procedure did not include the RPT-4A and RPT-4B circuit breakers in EOC-RPT breaker arc suppression response time surveillance testing. The Surveillance Procedure Verification Program reviews did not identify the need to perform the response time testing using TC-2. Consequently, the LER did not include it as a corrective action.

2. r ine ernor V 1ve- F t I ure An investigation of TSS 7.4.3.1.1.20 and TSS 7.4.3.1.1.78 found that they were originally only the 1S month CC procedures. The monthly CFTs were conducted using TSS 7.4.3.1.1.19 and

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TECHNICAL SPECIFICATION SURVEILLANCE IMPROVEMENT PROJECT IDENTIFICATION OF NON-CONFORMING CONDITIONS TSS 7.4.3.1.1.71. The CFT procedures met Surveillance Requirement 4.3.4.2.1 until they were revised on December 7, 1984. This revision added directions to mark certain status light and annunciator verification steps "N/A" when reactor power was less than 30%. The conditional steps were added in response to comments from the field, because the steps could not be performed as written. They were being marked "N/A" by the field performers, with an explanation in the Comments section of the procedures. It was apparently not realized that the steps being marked "N/A" in the field, and now being made conditional, were required to verify RPS relay contact functional status. They were, therefore, critical to the satisfactory completion of the CFT surveillance requirements. When the CFT and CC were incorporated into Revision 5 of TSS 7.4.3.1.1.20 and TSS 7.4.3.1.1.78 on January 27, 1988, these conditional steps were carried over.

3.Trin r I Vlv - l r An investigation of TSS 7.4.3.8.2.1 found that the Note, allowing certain throttle valve position status light verification steps to be marked "N/A," was first added to Revision 5 of the procedure on April 15, 1987. Before this time, the procedure met Surveillance Requirement 4.3.4.2.1. The reason for the revision was given that 15 Hertz RRC pump operation causes an abnormal light configuration. The Revision 10 Note further clarifies this by stating that "Ifeither RRC pump is not in 60 Hertz operation, the... fturbine throttle valve position]... indicating lights will be extremely dim and monitoring of their status is difficult." However, based upon a review of previous procedure performances, there was no indication that the field performers had difficulty determining the light status. Apparently, the indicating lights are difficult, but possible, to use for throttle valve position status during 15 Hertz RRC pump operation. It was apparently not realized that the steps being made conditional were required to verify RPS relay contact functional status, and therefore, critical to the satisfactory completion of the CFT surveillance requirement.

4. EOC-RPT stem Instrumentation A review of the Scheduled Maintenance System (SMS) data base for pressure switches MS-PS-3A, 3B, 3C and 3D found they were being calibrated at approximately 18 month intervals under the PM Program. The pressure switch PM cards were recently revised to perform the calibrations in accordance with Plant Procedures PPM 10.27.53, "Main Turbine First Stage Pressure Switch Calibration Div 1," and PPM 10.27.54, "Main Turbine First Stage Pressure Switch Calibration Div 2." These procedures were developed and approved on March 18, 1993, to perform the pressure switch CCs every 24 months. They do not, however, reference Surveillance Requirement 4.3.4.2.1, nor do they meet the 18 Month CC surveillance interval requirement of Table 4.3.4.2.1-1.2. It is assumed that the failure to develop CC surveillance procedures for these pressure switches was due to an oversight during the initial procedure preparation process.

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TECHNICAL SPECIFICATION SURVEILLANCE IMPROVEHENT PROJECT IDENTIFICATION OF NON-CONFORMING CONDITIONS 5.IRMNe aiveV1 eP wer I N Te General Electric Service Information Letter (GE SIL) 445, dated September 10, 1986, identified a blown fuse event at Monticello in which all positive and negative IRM fuses connected to the associated negative-voltage bus were blown by a power surge. After replacing all the positive fuses, the IRMs appeared to be operating normally. But, because the negative-side fuses were not replaced, continued loss of the negative power supply prevented the IRMs from processing flux signals, and thus generating related IRM scram functions. By design, the loss of the IRM's negative voltage supply was not annunciated, so the loss of the power supply, as well as the inability for the IRMs to generate scram functions remained undetected. The blown, negative-side fuses were detected later during IRM surveillance testing.

In response to this design error, the Supply System modified the IRM and Source Range Monitoring (SRM) systems in June of 1987 to include a voltage sensing relay to detect the loss of the negative voltage supply, and upon loss of the negative voltage supply, generate IRM inoperative rod block and scram signals.

On April 14, 1993, TSSIP personnel discovered that related IRM LSFT requirements were considered, but deemed not necessary, during the design modification process. Further investigation revealed that the negative-voltage-low inoperative trips added to the SRM drawers had not been LSFT'd since their installation, either. However, these SRM inoperative trips are not required to be LSFT'd by Technical Specifications.

ILmRIIR Five general root causes were identified by the Surveillance Procedure Verification Program in 1991, and remain valid for this review. They are described below:

1. Procedures Less Than Ad uate LTA - Surveillance procedures developed during the startup period that do not fully implement the requirements.

2. h n e M n emen LTA - Procedure revisions, procedure deviations or plant changes that introduced errors into the Technical Specification Surveillance Program.

3. ir ive /R iremen LTA - Technical Specifications were accepted at the time of startup that could not be complied with because of hardware restraints. These issues were recognized at the time, but were not adequately documented or resolved.

AD~i "LAA-Pl d lg d <<T dldgg lll 4 Rl

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TECHNICAL SPECIFICATION SURVEILLANCE IMPROVEMENT PROJECT IDENTIFICATION OF NON-CONFORMING CONDITIONS

5. Pr mm i n I LTA - Plant Procedures do not provide adequate control of the Surveillance Testing Program.

ific R ause Root causes were determined for each item discovered during the TSSIP procedure reviews. They are enumerated below in paragraphs corresponding to the event description above:

l. En -Of-C cle Recirculation Pum Tri The root cause for the failure to properly test the EOC-RPT circuit breaker trip response time was Procedures LTA.

2. r ine yern rVlv -F I re The root cause for the failure of the CFT and CC to meet the surveillance requirements was Change Management LTA.

3. Tur ine Thr ttl V lve- losure The root cause for the failure of the CFT to meet the surveillance requirement was Change Management LTA.

4. E -RPT em In men ion The root cause for the lack of CFT and CC surveillance procedures for the EOC-RPT related main turbine pressure switches was Procedures LTA.

5.IRM e ativeV I P werS I N Tesed The root cause for the IRM and SRM negative-voltage-low inoperative trip functions not being LSFT'd was Change Management LTA; during the design change process, cognizant personnel considered surveillance testing of the IRM's negative-voltage-low inoperative trips, but deemed. the testing unnecessary. Additionally, applicable revisions to the FSAR were not identified during the design change process.

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TECHNICAL SPECIFICATION SURVEILLANCE IMPROVEMENT PROJECT IDENTIFICATION OF NON-CONFORMING CONDITIONS ene 1F h r orrecive Acti n Following the completion of the Surveillance Procedure Verification Program in 1991, the Supply System recognized that the high number of specific items of Technical Specification non-compliance was indicative of a broader programmatic issue. The five general root causes were reviewed to determine Technical Specification Surveillance Testing Program corrective actions. The results of the review are as follows:

For the Procedures LTA and Change Management LTA root causes, the following two actions were taken:

1. PPM 1.2.6, "PPM Evaluation Program," was revised on September 9, 1992, to strengthen the Technical Specification surveillance procedure verification process.

2. PPM 10.1.5, "Scheduled Maintenance System (SMS)," was revised on January 11, 1993, to include specific signoffs for SMS changes to Technical Specification surveillance requirements.

3. Appropriate plant procedures will be revised by August 1, 1993, to assign central "ownership" of the Surveillance Testing Program within the Technical Staff Department. Future surveillance procedures, and non-editorial changes and revisions to the existing surveillance procedures will receive a Technical Specifications compliance review by the TSSIP staff.

The TSSIP is already underway to methodically review surveillance procedures by applicable Technical Specification. Procedures received prior to their scheduled review date will be screened for significant problems, but will not receive a detailed review until scheduled by the TSSIP staff.

For the Programmatic Controls LTA root cause, the WNP-2 Technical Specification Surveillance Testing Program was reviewed by a Quality Action Team (QAT), the Supply System formal problem solving process. The QAT completed their review and presented their findings and recommendations to Plant Management on April 17, 1992. The TSSIP, which discovered the items reported in this LER, is one of the QAT recommended actions being implemented.

There were no programmatic corrective actions applicable to the Directives/Requirements LTA and Design LTA root causes since the problems occurred before Plant startup, while under administrative controls that are no longer in affect. These root causes will be addressed on an individual basis by specific corrective actions.

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TECHNICAL SPECIFICATION SURVEILLANCE IHPROVEHENT PROJECT IDENTIFICATION OF NON-CONFORHING CONDITIONS ifi F h r rrective A i n

1. End- f- le Recirculati n Pum Tri TSS 7.4.3.4.2.3.3A and TSS 7.4.3.4.2.3.3B will be revised by June 15, 1993, to test the RPT-3A, 3B, 4A and 4B breaker trip time response using TC-2.

2. Turbine yern r V Iv - F Closure TSS 7.4.3.1.1.20 and TSS 7.4.3.1.1.78 will be revised by June 15, 1993, to meet the CFT and CC surveillance requirements of Table 4.3.4.2.1-1.2 when reactor power is less than 30%, as well as, greater than or equal to 30%.

3. r ine Thr le Valve - I re TSS 7.4.3.8.2.1 will be revised by June 15, 1993, to meet the CFT surveillance requirement of Table 4.3.4.2.1-1.1 when reactor power is less than 30%, as well as, greater than or equal to 30%.

4. E -RPT m Inst men i n Existing procedures will be revised, or new procedures developed, by June 15, 1993, to meet the CFT and CC surveillance requirements of Table 4.3.4.2.1-1.2 for pressure switches MS-PS-3A, 3B, 3C and 3D.

5. IRM Ne ative Volta e Power S I Not Tested

a. On May 2, 1993, RPS Surveillance procedure 7.4.3.1.2.1 was changed to LSFT the voltage sensing relay that initiates the negative-voltage-low IRM inoperative trip. The relay functioned as designed.

b. The applicable surveillance will be revised or developed to LSFT the negative-voltage-low SRM inoperative trip. This will be completed before the RPS Shorting Links are removed.

c. An FSAR change notice will be prepared by July 31, 1993, to reflect the negative-voltage-low inoperative trip as being part of the IRM and SRM trip circuitry.

LICENSEE EVENT REPORTQhR)

TEXT CONTINUATION AGILITY KAHE (1) OOCKET KUHBER (2) LER KUMBER (8) AGE (3)

Year ev. Ko.

Washington Nuclear Plant - Unit 2 0 5 0 0 0 3 9 7 3 10 01 13 OF 15 ITLE (4)

TECHNICAL SPECIFICATION SURVEILLANCE IHPROVEHENT PROJECT IDENTIFICATION OF NON-CONFORHING CONDITIONS ene l fe i nifi nce The Supply System regards the programmatic aspects of these items as an important issue that had potential safety significance. The General Corrective Actions listed above are defined to prevent recurrence of Technical Specification non-compliance problems in the future.

ifi f i nifi ne The Safety Significance was determined for each of the items discovered during the TSSIP procedure reviews. They are enumerated below in paragraphs corresponding to the event description above:

1. En - f- cleR ir lati n Pum Tri A review of circuit breaker test procedures found that EOC-RPT breaker testing is inadequate to assure the RPT breaker trip and arc suppression response time meets the surveillance requirement.

All breaker testing is performed by actuating TC-1. No procedures were found in the SMS data base that verify the characteristics of TC-2, which performs the EOC-RPT breaker trip safety function.

The characteristics of TC-2 are assumed to be similar to TC-1 based upon previous operation of the EOC-RPT breaker trips during actual events. However, the breaker arc suppression response times using TC-2 have not been accurately measured to ensure they are within the Plant design basis.

Consequently, this item was determined to have had potential safety significance. Both EOC-RPT system channels were declared inoperable and the Plant remains in an LCO awaiting completion of corrective actions for this item.

2. r ine overnor Valve - Fa lo ure The EOC-RPT Turbine Governor Valve - Fast Closure system instrumentation CFTs are performed monthly and satisfy Surveillance Requirement 4.3.4.2.1 when at a reactor power level greater than or equal to 30%. The EOC-RPT safety function is automatically bypassed at a reactor power level of less than 30%. Worst case, the longest period of operation in a non-compliance condition was 30 days. This fact, combined with the testing that was performed and the redundancy of the associated instrumentation, provides a high degree of confidence that the system could perform its safety function. Accordingly, this item was determined to have had no safety significance.

3. Turbine Throttle Valve - Clo ure The EOC-RPT Turbine Throttle Valve - Closure system instrumentation CFT is performed monthly and satisfies Surveillance Requirement 4.3.4.2.1 when both RRC pumps are in 60 Hertz operation.

The RRC pumps are normally in 60 Hertz operation at a reactor power level greater than or equal to

LICENSEE EVENT REPORTER)

TEXT CONTINUATION ACILITY 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 3 1 0 0 1 14 F 15 ITLE (4)

TECHNICAL SPECIFICATION SURVEILLANCE IMPROVEMENT PROJECT IDENTIFICATION OF NON-CONFORMING CONDITIONS 30%. The EOC-RPT safety function is automatically bypassed at a reactor power level of less than 30%. Worst case, the longest period of operation in a non-compliance condition was 30 days. This fact, combined with the testing that was performed and the redundancy of the associated instrumentation, provides a high degree of confidence that the system could perform its safety function. Accordingly, this item was determined to have had no safety significance.

4. E -RPT tern In men ion Pressure switches MS-PS-3A, 3B, 3C and 3D were being calibrated approximately every 18 months by the PM Program to assure proper setpoint. The EOC-RPT Turbine Governor Valve - Fast Closure system instrumentation CFTs are performed monthly and satisfy Surveillance Requirement 4.3.4.2.1 when performed at a reactor power level greater than or equal to 30%. The pressure switches do not have an EOC-RPT safety function at a reactor power level of less than 30%,

but serve only as an automatic logic bypass. Worst case, the longest period of operation in a Technical Specification non-compliance condition was 30 days. This fact, combined with the testing that was performed and the redundancy of the associated instrumentation, provides a high degree of confidence that the system could perform its safety function. Accordingly, this item was determined to have had no safety significance.

S.IRMNe iv V I eP wer I N tTe ed Plant Modification Request (PMR) 02-86-0204 added negative-voltage-low inoperative trips to each IRM and SRM chassis. Operability testing conducted during the design change process demonstrated that all installed trips functioned as designed. The Supply System has no knowledge that these IRM trips have been inoperable, other than from a lack of LSFT testing, since the time of the modifica-tion. During this period of time, these IRM inoperative trips have never been challenged to perform their function, therefore, there is no safety significance associated with this event.

LlCENSEE EVENT REPORTkR)

TEXT CONTINUATION AGILITY 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 3 010 01 15 OF 15 ITLE (4)

TECHNICAL SPECIFICATION SURVEILLANCE IMPROVEMENT PROJECT IDENTIFICATION OF NON-CONFORMING CONDITIONS imil r Even LER 91-013 reported a total of 12 items of non-compliance with WNP-2 Technical Specifications.

Following final submittal of the LER in August 1991, four additional LERs were submitted reporting similar events of non-compliance with Technical Specifications. LER 91-031 reported that IRM Control Rod Block Upscale and Downscale Trip surveillance procedures did not meet the CC surveillance requirements as defined by Technical Specifications. LER 92-004 reported that scram discharge volume scram and control rod block level instrumentation procedures did not meet the CFT surveillance requirements as defined by Technical Specifications. LER 92-035 reported that the scram discharge volume vent and drain valves surveillance procedure did not accurately measure stroke time as required by Technical Specifications. LER 92-040 reported that the monthly High Pressure Core Spray (HPCS) diesel generator surveillance procedure did not measure start and load times as required by Technical Specifications.

The TSSIP was initiated to ensure compliance with WNP-2 Technical Specifications through improvement of the Technical Specification Surveillance Testing Program. This LER reports items relating to previous program deficiencies, and is a direct result of the TSSIP implementation.

EII Inf r i n Text Reference EIIS Reference

/@stem ~om i~nen Reactor Protection System (RPS) JC Reactor Recirculation (RRC) Pump AD p RRC Circuit Breaker RPT-3A, 3B, 4A, 4B AD BKR Turbine Governor Valve TA V Turbine Throttle Valve TA V Main Turbine TA TRB Main Steam (MS) Pressure Switch 3A, 3B, SB PS 3C, 3D Intermediate Range Monitoring System (IRM) IG Source Range Monitoring System (SRM) IG