ML18012A150

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LER 96-002-01:on 960201,failed to Properly Perform TS Surveillance Testing.Caused by Personnel Error.Counseled Personnel & Revised procedure.W/960301 Ltr
ML18012A150
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 03/01/1996
From: Donahue J, Verrilli M
CAROLINA POWER & LIGHT CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HNP-96-032, HNP-96-32, LER-96-002, LER-96-2, NUDOCS 9603050326
Download: ML18012A150 (8)
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Text

CATEGORY 1 REGULATOr INFORMATION DISTRIBUTION STEM (RIDS)-

4ACCEBEION NBR:9603050326 DOC DATE: 96/03/01

~ NOTARIZED: NO DOCKET 6 FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME- AUTHOR-AFFILIATION VERRILLI,M. --Carolina Power 6 Light Co.

DONAHUE,J.W. Carolina Power 6 Light Co.

RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 96-002-01:on 960201,failed to properly perform TS surveillance testing. Caused by personnel error. Counseled personnel & revised procedure.W/960301 ltr.

DISTRIBUTION CODE: ZE22T COPIES RECEIVED:LTR ENCL SIZE:

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

E [

NOTES:Application for permit renewal filed. 05000400 8

RECIPIENT COPIES REC1PIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 PD 1 1 LE,N 1 1 INTERNAL: ACRS 1 1 AEOD/SPD RAB 2 2 Y AEOD/SPD/RRAB 1 1 NT 1 1 NRR/DE/ECGB 1 1 NR D EELB 1 1 NRR/DE/EMEB 1 1 NRR/DRCH/HHFB 1 1 NRR/DRCH/HICB 1 1 NRR/DRCH/HOLB 1 1 NRR/DRCH/HQMB 1 1 NRR/DRPM/PECB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 .1 RES/DSZR/EIB 1 1 RGN2 FILE 01 1 1 D EXTERNAL: L ST LOBBY WARD 1 1 LITCO BRYCEZJ H 2 2 0 NOAC MURPHYiG.A 1' NOAC POORE,W. 1 1 r. i NRC PDR 1 1 NUDOCS FULL TXT 1 .1 C U

E N

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK ROOM OWFN 5D-5(EXT. 415-2083) TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED/

FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 26 ENCL 26

Carolina Power 8 Light Company Harris Nuclear Plant PO Box 165 New Hill NC 27562 U.S. Nuclear Regulatory Commission MAR 0 Serial: HNP-96-032 1 f996 ATTN: NRC Document Control Desk 10CFR50.73 Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT UNIT 1 DOCKET NO. 50-400 LICENSE NO. NPF-63 LICENSEE EVENT REPORT 96-002-01 Gentlemen:

In accordance with Title 10 to the Code of Federal Regulations, the enclosed supplement to Licensee Event Report 96-002 is submitted. This supplement reports additional Technical Specification Testing deficiencies identified during the on-going Technical Specification testing program review.

Sincerely, J. W. Donahue General Manager Harris Plant MV Enclosure c: Mr. S. D. Ebneter (NRC - RII)

Mr. N. B. Le (NRC - PM/NRR)

Mr. D. J. Roberts (NRC - HNP)

'7603050326 96030i PDR ADOCK 05000400 S PDR 05OOVe State Road 1138 New Hill NC Pi@~

U. S. Nuclear Regulatory Commission Document Control Desk / HNP-96-032 Page 2 of 2 CC: Ms. P. B. Brannan Mr. R. K. Buckles (LIS)

Mr. W. R. Campbell (BNP)

Mr. J. M. Collins Mr. J. P. Cowan Mr. G. W. Davis Ms. S. D. Floyd Ms. S. F. Flynn Mr. H. W. Habermeyer, Jr.

Mr. G. D. Hicks (BNP)

Mr. M. D. Hill Mr. W. J. Hindman Mr. R. M. Krich (RNP)

Mr. P. M. Odom (RNP)

Mr. C. W. Martin (BNP)

Mr. R. D. Martin Mr. J. P. McKone Mr. J. W. Moyer (RNP)

Mr. W. R. Robinson Mr. G. A. Rolfson Mr. C. T. Sawyer Mr. R. S. Stancil G. M. Stokes

'r.

Mr. J. P. Thompson (BNP)

Mr. T. D. Walt HNP Real Time Training INPO NLS File: HI/A-2D (L. M. Randall)

Nuclear Records

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104 FLB5) EXPIRES 04/30/BB ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS MANDATORY INFORMATION COLLECTION REOUEST: 5GD HRS. REPORTED lESSONS lEARNED ARE LICENSEE EVENT REPORT...(LER) DICORPORATEO INTO THE UCENSUIG PROCESS AND FEO BACK TO INDUSTRY.

FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE UIFORMATION ANO RECORDS MANAGEMENT BRANCH IT 6 F33L Us. NUCLEAR REGULATORY COMMISSIOIL (See reverse for required number of WASHDIGTON. OC 205550001, AND TO THE PAPERWORK REDUCTION PRIMECT 0150.

digits/characters for each block) 010)L OFFICE OF MANAGEMENT AND BUDGET, WASIUNGTON, OC 20503.

FAGILrrY NAME Il) DOCKET NUMBER I2) PAGE )3)

Harris Nuclear Plant Unit-1 50-400 1 OF 5 TITLE (4)

Failure to properly perform Technical Specification surveillance testing.

EVENT DATE {5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (6)

FACILITYNAME DOCKET NUMBER SEOUENTIAL REVISION MONTH OAY MONTH BAY YEAR NUMBER NUMBER 05000 FACILITYNAME DOCKET NUMBER 2 01 96 96 002 01 1 96 05000 OPERATING THIS REPORT IS SUBMITTED,PURSUANT TO THE REQUIREMENTS OF 10 CFR 5: {Check one o r more} (11)

MODE (9) 20.2201(b) 20.2203(a) (2) (v) X 50.73{a)(2)(i) 50.73(a)(2)(viii)

POWER 20.2203(a) {1) 20.2203(a) (3) (i) 50.73(a)(2)(ii) 50.73(a) (2)(x) 1 oook LEVEL {10) 20.2203(a) (2) (i) 20.2203(a) (3)(ii) 50.73(a) (2) (iii) 73.71 20.2203(a)(2)(ii) 20.2203(a)(4) 50.73(a)(2)(iv) OTHER 20.2203(a)(2)(iii) 50.36(c) (1) 50.73(a)(2)(v) Specify In Abstract below or in NRC Form 366A 20,2203(a) (2) (iv) 50.36(c) (2) 50.73(a) (2) (vii)

LICENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER linoiude Area Code)

Michael Verrilli Sr. Analyst - Licensing (919) 362-2303 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DES CRIBED IN THIS REPORT (13)

REPORTABLE REPORTABLE CAUSE SYSTEM COMPONENT MANUFACTURER CAUSE SYSTEM COMPONENT MANUFACTURER TO NPROS TO NPROS SUPPLEMENTAL REPORT EXPECTED (14) MONTH OAY EXPECTED YES SUBMISSION X (If yes, complete EXPECTED SUBMISSION DATE).

NO DATE {15)

ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single. spaced typewritten lines) (16)

On January 17, 1996, during a Technical,Specific"tion testing program review, a failure to perform required surveillance testing during a planned maintenance outage in October, 1994 was identified. Specifically, on October 30, 1994, the plant was shut down and taken to Mode-5 (Cold Shutdown). This outage exceeded 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and per Technical Specification requirements Engineered Safety Feature slave relay testing was required. To satisfy this requirement OST-1083 and OST-1084 were satisfactorily completed, however the slave relay circuits for the CSIP Alternate Mini-Flow Isolation Valves, 1CS-746 and 1CS-752 were not tested due to an error that occurred during a procedure revision in June 1993.

In September 1992, a plant modification was completed on the Charging/Safety Injection Pump (CSIP) Alternate Mini-Flow System that necessitated revisions to Operations Surveillance Test procedures OST-1083 and OST-1084. These revisions were completed in June 1993 and removed the slave relay testing for CSIP Alternate Mini-Flow Isolation Valves (1CS-746 and 1CS-752) from OST-1083 and OST-1084 and transferred the testing requirement to procedure OST-1809. The cause of the Technical Specification violation was personnel error during the June 1993 procedure revision process for OST-1083 and OST-1084. OST-1809 was successfully performed during Refueling Outage 6 on September 8, 1995. This test veriTied the operability of these circuits, thus no immediate corrective action was required upon identification of the deficiency. Additional corrective actions included personnel counseling, appropriate procedure revisions and the continuation of an in-progress Technical Specification testing program review.

Five additional Technical Specification testing deficiencies were identified during the on-going comprehensive Technical Specification testing program review and are being reported by this supplemental report.

NRC FOAM 36BA US. NUCLEAR REGULATOAY COMMISSION LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (II DOCKET LEA NUMBEA (BI PAGE I3I SEOUENnAL REVISION YEAR NUMBER NUMBER

...Shearon Harris Nuclear Plant ~ Unit //1 50400 2 OF 5 96 - 002 - 01 TEXT Pr mort sport is rtrprarof. ost tditrdrool topitS ol iVRC Fam SBQI (IT)

EVENT DESCRIPTION:

On January 17, 1996, a failure to perform Technical Specification surveillance testing during an October 1994 planned maintenance outage was identified. The identification of this condition was a result of an on-going comprehensive Technical Specification testing program review that began in September 1995 folio'wing submittal of LER 95-07.

Specifically, on October 30, 1994, the plant was shut down and taken to Mode-5 (Cold Shutdown) for a planned maintenance outage. This outage exceeded 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and therefore, per Technical Specification 4.3.2.1 requirements, Engineered Safety Feature (ESF) slave relay testing was required for the 13 ESF relays delineated in Table 4.3-2 that had not been tested in the last 92 days due to being at full power operations. To satisfy this requirement OST-1083 and OST-1084 were completed on November 3, 1994. However, the slave relay circuits for the CSIP Alternate Mini-Flow Isolation Valves (ICS-746 and 1CS-752, EIIS Code BQ-ISV) were not tested due to an error that occurred during procedure revisions performed in June 1993 on Engineered Safety Feature (ESF) 18-Month Slave Relay Operations Surveillance Test procedures OST-1083 and OST-1084. This error involved inappropriately removing the slave relay testing for the 1CS-746 and 1CS-752 circuits from OST-1083 and OST-1084 and transferring the testing requirement to procedure OST-1809 (Refueling Water Storage Tank switchover to the Containment sumps), which is also an 18-month ESF response time test.

OST-1809 was not performed following the October maintenance outage, thus resulting in the testing omission and Technical Specification violation.

During the investigation of this event, personnel performing the Technical Specification testing program review verified tha OST-1809 had been successfully performed during Refueling Outage 6 on September 8, 1995, which verified the operability of the affected circuits.

The June 1993 revisions to OST-1083 and OST-1084 were performed to incorporate a plant modification (PCR-6547) on the Charging/Safety Injection Pump (CSIP) Alternate Mini-Flow lines. This modification removed the previously installed relief valves and provided an "open" signal to 1CS-746 and 1CS-752 upon receipt of a Safety Injection signal.

This condition was determined to be a violation of the Technical Specification surveillance test periodicity requirement and is being reported per 10CFR50.73(a)(2)(i)(b).

The following additional Technical Specification testing deficiencies have been identified by the on-going comprehensive Technical Specification testing program review:

Slave relays (K635 & K640) for the Auxiliary Feedwater (AFW) Flow Control Valves (EIIS BA-FCV) were not tested within their required quarterly surveillance interval following Refueling Outage (RFO) 5 in 1994 through RFO 6 in October 1995. This was a result of inadequate technical reviews associated with the plant modification (PCR-6502) that installed the auto-open signal to these valves. PCR-6502 specified the slave relay surveillance testing interval as once per 18 months per Technical Specification 4.7.1.2, but failed to identify the quarterly requirement contained in Technical Specification 4.3.2.1. Both of these relays were subsequently tested following RFO 6, which verified their operability. This condition was identified on February 1, 1996.

Testing for manual Safety Injection (SI, EIIS-BQ) and Containment Spray (CS, EIIS-BE) actuation has not fully tested all switch contacts within the required 18 month surveillance test interval per Technical Specification 4.3.2.1 The Operations Surveillance Test Procedures (OST-1825 & OST-1826) that verify the operability of the actuation circuits, only test one of the two manual actuation switches for each signal once per 18 months, thus resulting in the Technical Specification violation. The alternate test switch has been satisfactorily tested approximately once pe 36 months due to test performance staggering. Based on this previous testing, the SI and CS switches are currently operable. However, one set of CS switches will become inoperable on March 3, 1996 and one SI switch will become inoperable on March 19, 1996. This condition has existed since initial development of OST-1825 & OST-1826 and was identified on February 12, 1996.

RM 3 A (4- 5)

NRC FORM 366A US. NUCLEAR REGUlATORY COMMISBION

)6-65)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME n) DOCKET LER NUMBER I6) PAGE 0)

SEOUENNAL REYIBION NUMBER NUMBER Shearon Harris Nuclear Plant - Unit //1 50400 3 OF 5 96 - 002 - 01 TEXT fffmoro spssoir foqvi od, vso sddI)d)vsf Sopd)S of hf)C Fosm 36atU Iir)

Quarterly surveillance testing was not performed for the "B" Charging/Safety Injection Pump Mini-Flow Isolation Valve (1CS-196) Slave Relay (K601) during Refueling Outage 6 in 1995. This slave relay should have been tested during the performance of OST-1086 in August of 1995, but the "B" CSIP was inoperable and 1CS-196 was under clearance at the time of the test. This was noted in the procedure, but the test was considered satisfactory by the operations control room staff due to a deficiency in the acceptance criteria section of OST-1086. The'acceptance criteria, which was changed during a recent procedure revision, did not specify the need to test the 1CS-196 slave

, relay, so no Equipment Inoperable Record was generated for tracking purposes, which would have required subsequent testing. The operability of the slave relay was successfully verified by performing OST-1086 in December 1995. This condition was identified on February 17, 1996.

Eleven Maintenance Surveillance Test (MST) Procedures were identified that did not verify automatic isolation of th effluent pathway on a loss of power for the associated radiation monitor as required by Technical Specification 4.3.3.10. This affected six radiation monitors and their related pathways. This testing omission was created when the MSTs were inappropriately revised in 1993 in an effort to eliminate procedure steps that were thought to be redundant and unnecessary. Inattention to detail and an incomplete understanding of the Technical Specification testing requirements for the radiation monitor circuitry caused the deficiency. The testing requirements for these radiation monitors were removed from Technical Specifications in May 1995, but due to the time frame of the deficiency, the condition constitutes a violation and is therefore included in this LER supplement. This condition was identified on February 14, 1996.

5. Proper overlap testing has not been performed for an actuation of the Fuel Handling Building Emergency Ventilation System (EIIS-VG) originating from a high radiation alarm signal, as per Technical Specification 4.9.12.

OST-1048 tests this feature, but does not include a particular section of cable (¹12913M-SA) between the North Spent Fuel Pool Radiation Monitor (RM-1FR-3567A-SA) and the South Spent Fuel Pool Radiation Monitor (RM-1FR-3564A-SA). This condition has existed since initial development of OST-1048 and was identified on February 19, 1996.

CAUSE:

The cause of the Technical Specification violation was personnel error during the June 1993 procedure revision process for OST-1083 and OST-1084. The testing requirements for the slave relay circuits for the CSIP Alteniate Mini-Flow Isolation Valves (1CS-746 and 1CS-752) were inappropriately transferred to OST-1809, which was not identified or scheduled as a Mode-5 "event related" surveillance test.

Cause For Additional Items Identified:

Item 1:

The failure to adequately test the K635 and K640 slave relays for the AFW Flow Control Valves was caused by inadequate technical reviews associated with plant modification PCR-6502. This resulted in deficient surveillance test procedures developed to verify the operability of the automatic open signal for the flow control valves on a quarterly basis.

Items2 3 4 5:

Each of these items were caused by inadequate surveillance test procedures that resulted from incorrectly interpreting how to implement Technical Specification testing requirements. The test procedures for the Safety Injection and Containment Spray manual actuation switches, as well as the FHB Emergency Ventilation system, were based upon this incorrect interpretation and have been deficient since initial development. The radiation monitor MST revisions completed in 1993, were intentionally performed to eliminate what was considered to be redundant and unnecessary testing steps. This decision was also based on the incorrect testing requirement interpretation, as was the revision to OST-1086 that resulted in the acceptance criteria section not listing 1CS-196, and subsequently resulting in the failure to test the valve.

U.S. NUCLEAR REGUIATOAT COMMISSION NRC FOAM 366A

)6-B6)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME II] DOCKET LEA NUMBEA (6) PAGE )3)

SEQUENTIAL REVIBION YEAR NUMBER NUMBER Shearon Harris Nuclear Plant Unit 41 60400 4 OF 5

~

96 - 002 - Ol TEXT pl errors specs N seceded, ose oddrrroosl copies ol NRC For<o 36gl IIT)

SAFETY SIGNIFICANCE:

There were no adverse safety consequences as a result of this event. The CSIP Alternate Mini-Flow Isolation Valve circuits were tested satisfactorily on September 8, 1995 to verify operability. This testing provides confidence that had an accident occurred requiring CSIP mini-flow protection due to the re-pressurization of the Reactor Coolant System during a safety injection, the isolation valves would have opened to prevent pump damage.

There were no adverse safety consequences as a result of the five additional items reported in this supplement. In each cas where applicable, subsequent testing was performed that verified the operability of the effected component or circuit.

PREVIOUS SIMILAR EVENTS:

Previous events have been submitted as LERs related to surveillance testing deficiencies caused by procedural inadequacies.

LER 95-07, which was submitted on September 28, 1995, contained a corrective action to perform a comprehensive Technical Specification testing program review and it was during this review process that the CSIP Alternate Mini-Flow Isolation Valve condition was identified. This review is being performed by a multi-discipline team and is still in progress.

The five additional items reported in this LER revision were identified as a result of the on-going Technical Specification testing program review.

CORRECTIVE ACTIONS COMPLETED:

1. Slave relay testing was satisfactorily completed on September 8, 1995 that verified the operability of the CSIP Alternate Mini-Flow Isolation Valve circuits.
2. Personnel involved in the June 1993 procedure revision process for OST-1083 and OST-1084 were counseled.
3. Surveillance procedures OST-1083 and OST-1084 were revised on February 16, 1996 to include the requirements for CSIP Alternate Mini-Flow Isolation Valve slave relay testing.

CORRECTIVE ACTIONS PLANNED:

1. The Technical Specification testing program review (committed to in LER 95-07) that identified this condition is currently in progress and is scheduled for completion in 1996.

CORRECTIVE ACTIONS FOR ADDITIONALITEMS IDENTIFIED:

~Item I OST-1044 was revised in December 1995 and OST-1045 was revised in February 1996. These revisions incorporated K635 and K640 slave relay testing on a quarterly basis.

Item 2:

To address the SI switch that becomes inoperable on March 16, 1996, a Request for Exigent License Amendment was submitted to the NRC on February 16, 1996. This requests a one-time extension of the testing interval for testing the SI switch. Operations Surveillance Test procedure (OST-9016T) will be revised and performed to test the CS switches prior to their surveillance interval expiration date of March 3, 1996. Additionally, a new OST will be developed to properly test each Safety Injection and Containment Spray manual actuation switch once every 18 months. This revision will be completed as addressed in the Harris Plant response to NRC Generic Letter 96-01.

RM 3 A (4-95

NRC fORM 366A US. NUCLEAR REGULATORY COMMISSION l696)

LlCENSEE EVENT REPORT (LER)

TEXT CONTINUATION fACILITYNAME (n OOCKET LER NUMBER (6) PAGE I3)

SEOUENTIAL REVISION NUMBER NUMBER Shearon Harris Nuclear Plant - Unit //1 50400 5 OF 5 96 << 002 - 01 TEXT Pl mors spsooi rorpri od. vso sddi)dmor oopis of A'RC form 3566/ Ill)

Item 3:

OST-1086 will be revised to enhance the acceptance criteria to ensure that testing of the "B" CSIP Normal Mini-Flow Isolation Valve (1CS-196) slave relay is included. This revision will be completed as addressed in the Harris Plant response to NRC Generic Letter 96-01.

Item 4:

The radiation monitor operability and testing requirements were inoved from Technical Specification 4.3.3.10 to the Off-Site Dose Calculation Manual (ODCM) in May 1995. Upon identification of this condition, the affected radiation monitors were declared inoperable. Appropriate MST procedure revisions were completed and the tests performed, to fully verify the automatic pathway isolation function of the radiation monitors. Additional procedure changes and/or ODCM revisions will be completed to clarify the testing requirements and enhance the performance of future testing. These actions will be completed as addressed in the Harris Plant response to NRC Generic Letter 96-01.

Item 5:

OST-1048 will be revised to test the FHB Train A Emergency Ventilation actuation from Radiation Monitor RM-1FR-3567A-SA, which will properly include the previously omitted cable. This revision will be completed as addressed in the Harris Plant response to NRC Generic Letter 96-01.

EIIS CODES:

High Head Safety Injection: BQ Auxiliary Feedwater Flow Control Valves: BA-FCV Containment Spray: BE Fuel Handling Building Ventilation: VG RM 3 A (4- 5)

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