ML18022A599

LER 87-066-00:on 871204,frequency Requirement for Containment Ventilation Isolation Circuitry Actuation Logic Test Not Fulfilled.Caused by Personnel Error.Procedure & Task Sheet for Monthly Tests generated.W/880104 Ltr

ML18022A599
Person / Time
Site:	Harris
Issue date:	01/10/1988
From:	Jerrica Johnson, Watson R CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
HO-870580-(), HO-870580-(0), LER-87-066, LER-87-66, NUDOCS 8801130154
Download: ML18022A599 (6)

Text

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DISXRIBUTlON DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8801130154 DOC.DATE: 88/01/10 NOTARIZED: NO DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION JOHNSON,J.R. Carolina Power & Light Co.

WATSON,R.A. Carolina Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 87-066-00:on 871204,failure to perform satisfactory actuation logic test for containment ventilation isolation.

W/8 ltr.

DISTRIBUTION CODE IE22D COPIES RECEIVED LTR ~ENCL ~SIZE:

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

D NOTES:Application for permit renewal filed. 05000400 S

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 LA 1 1 PD2-1 PD 1 1 BUCKLEY,B 1 1 INTERNAL: ACRS MICHELSON 1 '1 ACRS MOELLER 2 2 D AEOD/DOA 1 1 AEOD/DS P/NAS 1 1 AEOD/DSP/ROAB 2 2 AEOD/DS P/TPAB 1 1 ARM/DCTS/DAB 1 1 DEDRO 1 1 NRR/DE ST/ADS 1 0 NRR/DEST/CEB 1 1 8 NRR/DE ST/ELB 1 1 NRR/DEST/ICSB 1 1 NRR/DEST/MEB 1 1 NRR/DEST/MTB 1 1 NRR/DEST/ J.'SB 1 1 NRR/DEST/RSB 1 1 NRR/DEST/SGB 1 1 NRR/DLPQ/HFB 1 1 NRR/DLPQ/QAB 1 1 NRR/DOEA/EAB 1 1, NRR/DREP/RAB 1 1 NRR/DREP/RPB 2 2 SRZ SIB 1 1 NRR/PMAS/ILRB 1 1 G 02 1 1 RES DEPY GI 1 1 TELFORD, J 1 1 RES/DE/EIB 1 1 RGN2 FILE 01 1 1 EXTERNAL EG&G GROH i M 5 5 FORD BLDG HOY,A 1 1 H ST LOBBY WARD 1 1 LPDR 1 1 NRC PDR 1 1 NSIC HARRIS,J 1 1 NSIC MAYS,G 1 1.

D S

j A

D TOTAL NUMBER OF COPIES REQUIRED: LTTR 46 ENCL 45

NRC Form 366 U.S. NUCLEAR REOULATOAY COMMISSION (943)

APPROVED OMB NO. 3)604104 LICENSEE EVENT REPORT (LER) EXPIRES: 6/31/SS FACILIl'YNAME (1) DOCKET NUMBER (2) PACE 3 SHE FAILURE TO PERFORM SATISFACTORY ACTUATION LOGIC TEST FOR CONTAINMENT 050004001OF04 VENTILATION ISOLATION DUE TO PROCEDURAL INADE UACY EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (6)

YfAA SEOVENTIAL MONTH DAY YEAR NUMBER Ki irV~MSER MO"T" DAY YEAR FACILITYNAMES DOCKET NUMBER(SI 0 5 0 0 0 1 2 04 878 7 0 6 6 00 01 1 088 0 5 0 0 0 THIS REPOAT IS SUBMITTED PURSUANT 7 0 THE REQUIREMENTS OF 10 CFR (): IChrck onr or morr ol the Iollovtinpl (11 OPERATINO MODE (9)

] 20.402(b) 20A05(c) 50.73(e) (2)(lv) 73.71(b)

POWER 20.406( ~ ) (I I(lI 50.36(e) (1) 50.73(s) (2)(vl 73.71(cl l(2)(vill)(A) 1 0 0 20.405( ~ ) (1)(ill 50.36(cl(2) 50.73(el(2) (vill OTHER ISpeclty In Abrtrrct below rnd In Text, NRC Form 20A05( ~ l(1)(BI) 60.73(s)(2)(l) 50 73(e 366AI 20.406(s HI) (lvl 50.73(sl(2)(ll) 50.73(sl(2) (vill)(B) 20.406(e) (1)(vl 60.73(el(2)(ill) 50.73( ~ ) 12) (el LICENSEE CONTACT FOR THIS I.ER (12)

NAME TELEPHONE NUMBER JOSEPH R. JOHNSON AREA CODE SENIOR SPECIALIST REGULATORY COMPLIANCE 919 362 -2 007 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

NR CAUSE SYSTEM COMPONENT MANUFAC MANUFAC.

TURER CAUSE SYSTEM COMPONENT TURER TO NPADS

~%Ik%NP, SUPPLEMENTAL REPORT EXPECTED (14) MONTH DAY YEAR EXPECTED SU 6 M I SS ION DATE (16)

YES Illyet, complete EXPECTED SU84IISSIOII DATEI NO ABSTRACT (Limit to Irpo soccer, I.e., rpproxlmerrly Illrren elnplrrprcr typrwrittrn llnnl (16)

The plant was operating in Mode 1, Power Operation, at 100 percent reactor power on December 4, 1987. At 0830 hours it Ventilation Isolation Circuitry Actuation Logic for containment area radiation monitors was discovered that part of the Containment was not being tested on a staggered monthly basis as required by Technical Specification 4.3.2.1 Table 4.3-2 Item 3.C.2. The procedure that was designated to perform the surveillance te'sted only the portion of the circuitry within the So1id State Plant Protection System (SSPPS). A separate procedure adequately addressed the requirement but was only being done on an 18 month frequency rather than the required frequency in Technical Specifications. This error was discovered while doing a review of scheduling task sheets for the latter procedure.

Upon notification of this event operations personnel immediately declared the four containment area radiation monitor channels, inoperable and entered Technical Specifications Action statement which required the closing of the Containment Purge Makeup and Exhaust Isolation valves.

The surveillance was run satisfactorily and the circuits declared operable.

The cause of the event was personnel error through inadequate preparation and review of the applicable procedure.

Corrective actions include'1) A procedure and task sheet were generated to perform the test monthly, 2) a review of all reactor trip and ESFAS Circuits was performed to ensure no other tests were missed, and 3) a training session was held for the procedure writers discussing this event and its consequences.

This event is being reported in accordance with 10CFR50.73(a)(2)(i)(B) as a violation of Technical Specifications. J 8801130154 880110 PDR ADOCK 05000400 S DCD

0 V.S. NUCLEAR REGULATORY COMMISSION NRC PEIIII SEEA

)043)

LICENSEE EVENT REPORT ILER) TEXT CONTINUATION APPROVED OMS NO. 3150&ICE EXPIRES: 8/31/88 PACILITY NAME 11l DOCKET NUMSER Ill LER NUMBER LS) PAGE 13)

YEAR SEOVENTIAL REVISION NVMEER NVM ER SHEARON HARRIS NUCLEAR POWER PLANT UNIT ONE o s o o o 4 0 0 8 7 0 6 6 00 02 QF 0 4 TEXT /O'IINVP N>>EE /1 IEEVEr4 Vw P/A/ERE/H/IC fcmI 35SASl 117)

DESCRIPTION:

The plant was operating in Mode 1, Power Operation, at 100 percent reactor power on December 4, 1987. At 0830 hours0.00961 days <br />0.231 hours <br />0.00137 weeks <br />3.15815e-4 months <br /> it was discovered that part of the Containment Ventilation Isolation Circuitry Actuation Logic (EIIS:JM) was not being tested on a staggered monthly basis as required by Technical Specification 4.3.2.1, Table 4.3-2, Item 3.C.2.

Maintenance Surveillance Test (MST) - I001, Train A Solid State Protection System Actuation Logic and Master Relay Test, and MST-I0320, Train B Solid State Protection System Actuation Logic and Master Relay Test, which checks Solid State Protection Systems Trains A and B (EIIS:JG) respectively were listed as meeting the requirements of Technical Specification Table 4.3-2, Item 3.C.2. These tests check the Solid State Plant Protection System (SSPS) coincidence logic. However, the 2 out of 4 logic for a Containment Ventilation Isolation signal from containment area monitors is performed by relays in the Auxiliary Relay Panels (EIIS:JM) (ARP) 19-A and 19-B which are upstream of SSPPS. The output of the respective relay logics are on input to respective trains of SSPPS. In effect, MST-I001 and I0320 tested the continuity of the signal through SSPPS, but not the 2 out of 4 logic.

The Maintenance Procedure Group discovered the problem while reviewing a Task Sheet for MST-I0630, Functional and Time Response Test for Containment Area Radiation Monitors, which did incorporate the test of the logic circuitry.

MST-I0630 was listed as satisfying the loop calibration surveillance requirements (Technical Specification Table 4.3-3, Item l.a.) However, this .

surveillance has an 18 month frequency instead of the required staggered monthly basis. [Technical Specification Table 4.3-2 Note (1)]. A subsequent investigation revealed that MST-I0630 had been performed twice; once on October 30, 1986, prior to initial plant startup and again on September 21, 1987. When tested on December 4, 1987, no problems were found with the logic.

Operations was notified upon discovery of the error and immediately closed the Containment Purge Makeup and Exhaust Valves (EIIS:VL) to meet Technical Specification Action Statement 27 (Table 3.3-6).

CAUSE:

The cause of the event was personnel error through inadequate preparation and review of MST"I001 and I0320. Apparently, the personnel that prepared and reviewed these procedures interpreted that the Technical Specification Surveillance only called for a test of SSPPS and not a test of all applicable logic circuitry. This conclusion is based on the fact that:

NRC SORM SEEA R V.S.GPO:108WHl24 838/Edd

)0831

NRC Solm SSSA U.S. NUCLEAR REGULATORY COMMISSION 1043)

LICENSEE EVENT REPORT ILER) TEXT CONTINUATION APPROVED OM8 NO. 3)50&104 EXPIRES: 8/31/88 SACILITY NAME Ill DOCKET NUMSER 121 LER NUMSER Ie) PAGE 13)

YEAR C4@

eeoveNTIAL gp.. IIe V IS IO N NVM TII NUM e II SHEARON HARRIS NUCLEAR POI)tER PLANT UNIT ONE 0 5 0 0 0 4 Q Q 8 70 6 6 0003 OF 0 4 TEXT /1/mNP NMop N /seulme INS AIR/one//VRC Soml 355A3/ I ltl CAUSE: (continued)

(1) All other entries in Table 4.3-2 for "Actuation Logic and Actuation

'elays" are tested in these 2 procedures.

(2) The surveillance frequency is one which is typically applied only to the SSPPS.

(3) The design does not provide for staggered testing of the logic. The coincidence is checked by inputting signals at each containment area radiation monitor to simulate each 2 out of 4 combination. Both sets of the logic were tested simultaneously.

(4) The fact that MST-I0630 recognizes and tests the coincident logic indicates that the procedure writers were aware that this particular logic was outside of SSPPS.

ANALYSIS:

This event is being reported in accordance with 10CFRS0.73(a)(2)(i)(B) as a violation of Technical Specifications.

The function of Containment Ventilation Isolation from the Containment Area Radiation Monitors is to isolate the purge valves during a fuel handling accident. To verify this capability, surveillance of the logic is required within 100 hours of fuel movement.

The Containment Area Radiation monitor provides a backup means of isolating containment in the event of Reactor Coolant System leaks or postulated Loss-Of-Coolant Accident (LOCAs). In the latter two cases, the primary means of isolation are the Containment Leak Detection Monitor (small leaks) and Containment Phase A Isolation (LOCAs). These two latter functions were unaffected by the missed surveillance.

The testing performed on the monitors provided assurance that the individual monitors worked properly and that the individual relays in 2 out of 4 logic responded properly. A review of the design showed that the tie between the logic and the SSPPS was designed as an "energize-to-actuate" circuit.

Failures (open circuit) in the circuit would not be apparent to operations personnel until 2 or more monitors were in alarm and the isolation did not occur. The revised surveillance test is currently the only means to detect these failures.

N 8 C S 0 8 M See A *U.S.GPO.)085.0824 538/455 1083)

NRC Form SSSA U.S. NUCLEAR REOULATORY COMMISSION (843)

LICENSEE EVENT REPORT (LER) TEXT CONTINUATION APPROVEO OMB NO. 319)M(DO EXPIRES I 8/31/58 FACILITY NAME (I I DOCKET NUMBER (2) LER NUMBER (5) PACE (3)

YfAR sf auf rrfIAL rio A fv rfla rr SHEARON HARRIS NUCLEAR POWER PLANT NI/Mff A rrI/M f II UNIT ONE 0 5 0 0 04 OP 0 6 6 OF TEXT /I/rr>>ro f/>>of /I /p//rkfrE r>>f PAE&tp>>/ A/RC /ronrr 3(E(EB/ I(T)

ANALYSIS: (continued)

The justification for use of an "energize-to-actuate" circuit was reviewed by the Plant Nuclear Safety Committee (PNSC) as part of its review of this reportable event. The design change was made prior to fuel load to allow the Containment purge valves to be reopened after an isolation due to high radiation being detected. The original design used a "de-energize to isolate" circuit. The new design was necessary to provide a timed reset option to allow operator action to reopen the valves. An engineering evaluation has determined the new design is satisfactory for the following reasons.')

Relay de-energized to isolate could cause more spurious isolation signals than current design.

2) The logic consists of two redundant Trains.

3) Relay energized to take action is not explicitly prohibited by design commitments.

LER-87-030-00 also reported a missed surveillance caused by a maintenance procedure deficiency.

CORRECT ACTIONS/ACTION TO PREVENT RECURRENCE:

1) MST-I0417P Relay Actuation Logic Test for Containment Area Radiation Monitors, and a new Task Sheet have been issued to perform this test monthly.

2) A review of all Reactor Trip and ESFAS circuits was performed to ensure that, no other surveillances were missed and none were identified.

3) A training session was held with the maintenance procedure writers discussing the consequences of this event.

NRC POIIM 355A o U.S OPO:(8584424 538/455 ID43)

CML

\ i Carolina Power & Light Company HARRIS NUCLEAR PROJECT P.O. Box 165 New Hill, NC, 27562 File Number'. SHF/10-13510C Letter Number'. HO-870580 (0)

U.S. Nuclear Regulatory Commission ATTN: NRC Document Control Desk Washington, DC 20555 H

SHEARON HARRIS NUCLEAR POWER PLANT UNIT 1 DOCKET NO. 50-400 LICENSE NO. NPF-63 LICENSEE EVENT REPORT 87-066-00 Gentlemen:

In accordance with Title 10 to the Code of Federal Regulations, the enclosed Licensee Event Report is submitted. This report fulfills the requirement for a written report within thirty (30) days of a reportable occurrence and is in accordance with the format set forth in NUREG-1022, September, 1983.

Very truly yours, R. A. Watson Vice President Harris Nuclear Project RAW:acm Enclosure cc: Dr. J. Nelson Grace (NRC RII)

Mr. B. Buckley (NRR)

Mr. G. Maxwell (NRC SHNPP)

MEM/LER-87-066/Page 1/OS1 ~g a.a I/r