Text

LER 92-003-01:on 920214,operators Determined That Certain ESF Sys Logic Actuation Relays Were Not Properly Tested Per TS 4.1-1,item 6.Caused by Procedural Deficiencies.Test Procedures Changed Re PORV Alarm actuation.W/920622 Ltr
	ML18153D039
Person / Time
Site:	Surry
Issue date:	06/22/1992
From:	Kansler M; VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
	92-422, LER-92-003, LER-92-3, NUDOCS 9206250383
	Download: ML18153D039 (6)
	v • d • e

10CFR50.73 Virginia Electric and Power Company Smry Power Station P.O.Box315 Surry, Vll'ginia 23883 June 22, 1992 U.S. Nuclear Regulatory Commission Serial No.: 92-422 Document Control Desk SPS:VS Washington, D. C. 20555 Docket Nos.: 50-2.80 50-281 License Nos: DPR-32 DRP-37

Dear Sirs:

Pursuant to Surry Power Station Technical Specifications, Virginia Electric and Power Company hereby submits the following updated Licensee Event Report applicable to Surry Power Station Units 1 and 2.

BEPQRI'NUMBER .

50-280/92-003-01 This report has been reviewed by the Station Nuclear Safety and Operating Conimittee and will be forwarded to the Management Safety Review Committee for its review.

Very tnily yours, Enclosure cc: Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 M. W. Branch NRC Senior Resident Inspector Surry Power Station

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9206250383 920622 PDR ADOCK 05000280 S PDR

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NRCFORM366 U.S. NUCLEAR REGULATORY COMMISSION (6-89) , APPROVED 0MB ND. 3150-0104 EXPIRES: 4i30/92 ESTIMATED BURDEN PER RESPONSE TO COMPLY WTH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS. FORWARD LICENSEE EVENT REPORT (LER) COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS AND REPORTS MANAGEMENT BRANCH (P-530), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555, AND TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON, DC 20503.

FACILITY NAME (1) *

DOCKET NUMBER (2) I PA<<.E 131 TITLE 14)

Surry Power Station, Unit 1 Io 15 Io Io Io 12 I 810 1 loF O 1S Iricomplete Engineered Safety Features Testing Due to-Procedure.Deficiency EVENT DATE (5) LER NUMBER (6) . REPORT DATE (7) OTHER FACILITIES INVOLVED_.(11)

MONTH DAY YEAR FACI LITV NAMES DOCKET NUMBER(SI Surry Unit 2 o Is Io I o I o I 2 18 I 1 o I 2 1 14 9 2 oIo I 3 - oI1 o16 212

§:

THIS REPORT IS SUBMITTED PURSUANT TO THE R~QUIREMENTS OF 10 CFR /Ch<<k *on* or moro of th* following/ .(11)

OPERATING N

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MODE Ill 20.4021b)

- 20.40!5(c) II0.73(all2lliv) 73.71(bl POWER 20,4051*ll1lUI II0.3S(c)(1) 50.73(*ll2ll*'-

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II0.73(all21(1) 366A)

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--- II0,73(all2)(11) 50.73(1)12)11111 LICENSEE CONTACT FOR THIS LER (12)

II0.73(all2)1vlll)IBI 50.73(all2llxl NAME TELEPHONE NUMBER AREA CODE M. R. Kansler, Station Mariager 8 10 r 4 3 1 5 r 7 r- 1 31 l 18 I 4 COMPLETE ON_E LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

MANUFAC- MANUFAC*

CAUSE SYSTEM COMPONENT CAUSE SYSTEM COMPONENT TURER TURER I I I I I I I I I I I I I I I .I I I I I I I I I I I I I SUPPLEMENTAL REPORT EXPECTED (141 MONTH DAY YEAR EXPECTED n YES (If y*s, comp/or. EXPECTED SUBMISSION DATE)

ABSTRACT /Limit to 1400 ,,,.cos, i.*.* *pproximatoly fifto*n 1inglo-,,,.co typowrirttJn linOI} (16) rxi NO SUBMISSION DATE 1151 I I I On February 14, 1992 at 1343 hours0.0155 days 0.373 hours 0.00222 weeks 5.110115e-4 months , with Unit i and Unit 2 at 90% and 100%

reactor power, respectively, it was determined that certain Engineered Safety Feature (ESF) system

logic actuation* relays associated with* automatic initiation of safety injection and main. steam line isolation were not being fully tested in accordance* with Technical Specifications (TS). On May 21, 1992 with Unit 1 and Unit* 2 at 100% reactor power it was determined that the Pressurizer Power Operated Relief Valve (PORV) position indication channel calibration procedures did not include actuation verification of the associated alarm. For these events, the affected instrumentation was declared inoperable and the appropriate* Limiting Conditions for Operation (LCOs) were entered in accordance with TS. Actions were promptly initiated to* test the affected instrumentat_ion. Following successful testing, the LCOs were exited. Since the instrumentation was verified operable, no safety implications were posed by the events. The events occurred because of procedural deficiencies in properly or completely specifying test methodology. The procedural deficiencies *were* identified during. upgrades of certain ~urveillance test procedures and assessments of surveillance testing by Engineering and Quality Assurance. A programmatic review of TS required* surveillances, including engineering reviews, procedure upgrades and Quality Assurance activities is being undertaken to identify other surveillance deficiencies. These events are being reported pursuant to 10CFRSO. 73 (a) (2) (i) (Bl.

NRC Form 366 (6-89)

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NRC FORM 366A *

(6-89) e LICENSEE EVENT REPORT (LER)

U.S. NUCLEAR REGULATORY COMMISSION APPROVED DMB NO. 3150-0104 EXPIRES: 4/30/92

'ESTIMATED BURDEN PER RESPONSE TO COMPLY WTH THIS INFORMATION COLLECTION REQUEST: 50,0 HRS, FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO'THE RECORDS TEXT CONTINUATION AND REPORTS MANAGEMENT BRANCH (P-530), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555,,AND TO l'HE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON, DC 20503.

FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER 16) PAGE (3)

- ,: SEQUENTIAL -:,:*:*:*:* REVISION VEAR

-:-:*:*:* . NUMBER ..... NUMBER Surry Power Station, Unit 1 o Is I o I o*1o 12 1s I o .g 12 - o I 01 3 - o 11 o12 oF o *I s TEXT (ff inora ,,,,,.,,. i1J raqulrad, u* additional NRC Form 366A 'al 117) 1 . 0 DESCRIPTION OF THE EVENT On February 14, 1992 at 1343 hours0.0155 days 0.373 hours 0.00222 weeks 5.110115e-4 months , with Unit 1 and Unit 2 at 90%

and 100% reactor power, respectively, it was determined that certain Engineered Safety Feature (ESF) system logic actuation relays [EIIS-JE,RLY] associated with automatic initiation of safety injection and main steam line isolation were not being fully tested in accordance with Technical Specific~ti6n (TS) Table 4.1-1, Item 26. Specifically, actuation of* the relays which

. energize on low reactor coolant* system average tempera,ture were not being verified. These procedural errors were identified during the revisions to certain surveillance test procedures which were being performed as part of the Surry Procedure Upgrade Program.

Automatic*initiation of safety injection and main steam isolation will occur when a high steam flow condition in two of three steam lines exists coincident with either a low steam line pressure greater.than or equal .to 525 psig in two of three steam lines or a low average reactor coolant system (RCS) temperature greater than or equal to 543°F in two of three RCS loops. TS Table 3.7-2, Item le, and Table 3.7-3, Item 2a, require_ that a minimum of two low RCS average temperature channels must be operable. TS Table 4.1-1, Item 26 requires tha:t Logic Channel- Testing, consisting of a channel functional test, be performed monthly.

In this particular instance, the monthly surveillance test procedures verified continuity of the low average RCS temperature relay coils, but did not verify actuation of the relays. This is contrary to the Technical Specification definition of a channel functional test which requires verification of trip initiating action.

On May 21, 1992, with Unit 1 and Unit 2 at 100% power, it was determined that the Reactor Coolant System (RCS) { EISS-AB}

Pressurizer {EISS-PZR} Power Operated Relief Valve (PORV) {EISS-PCV} position indication channel calibration procedures did not include actuation verification of the associated alarm. The PORVs are .equipped with two limit switches, but the alarm is only actuated from one of the limit. switches. The procedure deficiencies were identified during a Quality Assurance audit at North Anna Power Station. Subsequently, it was determined that Surry Power Station's procedures also contained the same deficiencies. As a result, the channels were not being fully tested. In this particular instance, the alarm actuation was not being verified as part of the channel calibration. This condition is believed to have existed since PORV limit switch replacement in 1987. The alarm actuation can only be verified by stroking the PORV which is, at a minimum, performed during ref~eling outages.

NRC Form 366A (6-89)

e e NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION 16-89) APPROVED 0MB NO. 3150-0104 EXPIRES: 4/30/92 ESTIMATED BURDEN PER RESPONSE TO COMPLY WTH THIS LICENSEE EVENT REPORT .(LER) INFORMATION COLLECTION REQUEST: 50.0 HRS. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS TEXT CONTINUATION AND REPORTS MANAGEMENT BRANCH IP-530), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555, AND TO THE PAPERWORK REDUCTION PROJECT 13150-0104), OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON, DC 20503.

FACILITY NAME 11) DOCKET NUMBER (2) LER NUMBER 16) PAGE (3)

Surry Power _Station, Unit r The surveillance test procedures which govern PORV stroking did .

not include instructions for documenting the appropriate alarm I

actuation.

Technical Specifications (TS) surveillance 4.1.B.1.b requires that each PORV accident monitoring instrumentation channel shall be dei:nonstrated operable by performance of channel calibrations at a minimµm of each refueling as shown in Table 4.1-2. The definition in TS 1.G.~ states channel calibration.shall encompass the entire channel including equipment action, alarm, or trip and* shall be deemed to include the channel functional test. The surveillance test procedures which govern PORV stroking did not include adequate instructions to document alarm actuation.

These events are being reported pursuant to 10CFR50. 73 (a) (2) (i) (B).

2. 0 SIGNIFICANT SAFETY CONSEQUENCES AND IMPLICATIONS Following discovery that the trip initiating actuation of the relays had not been verified, the low average RCS temperature

relays were tested and determined to be operable. Additionally,.

the high steam flow low steam line pressure protection function, for which the high steam flow/low average temperature protection serves as a* backup, was being tested and verified operable in accordance with Technical Specification requirements.

Although the surveillance test procedures for the PORVs did not include verification of the alarm, additional- indications were available to alert Control Room personnel to the actuation o-f a PORV. These include low pressurizer pressure indication/alarm,.

backup heater operation, increasing level, temperature' and pressure in the pressurizer relief tank, high temperatures downstream of the PORVs and two open indications from the PORV position indicator lights. This event posed no significant saf~ty impiications because the alarm is not required for the Pressurizer PORVs to perform their design functions and subsequent testing demonstrated that the associated alarms actuated as required .

.Therefore, the health and safety of the general public was not affected at any time due*to these events.

I 3.0 CAJJSE or TRE EVENT These events were caused by procedural deficiencies. An improper test methodology had been specified during the original preparation of the test procedures. The weakness in the methodology was identified during the Surry Procedure Upgrade Program.

NRC Form 366A 16-89)

L

e NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION APPROVEDOMBN0.3150-0104 , .

(6-89)

EXPIRES: 4/30/92 E ATED BURDEN PER RESPONSE TO COMPLY WTH THIS LICENSEE EVENT REPORT (LER) INFORMATION COLLECTION REQUEST: 50.0 *HRS. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS TEXT CONTINUATION AND REPORTS MANAGEMENT BRANCH IP-530), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555, .AND TO 1'HE PAPERWORK REDUCTION PROJECT 13150-0104). OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON, DC 20503. .

FACILITY NAl'IIE 111 DOCKET NUMBER 121 LER NUMBER (61 . PAGE 131

SEQUENTIAL *:,:-:-:*:* REVISION YEAR ;:;::::::: NUMBER ..... NUMBER Surry Power Station, Unit 1 o Is Io Io Io I .21 s I o -912 - o I 01 3 - o11 o14

oF o I s TEXT (ff more s,Mt:e is ,-qui,.,,_ u* *dditianal NRC Fann 3156A 'a) (171 The failure to verify the PORV alarm actuation was caused by a procedural deficiency that resulted in a failure to satisfy the channel calibration surveillance requirements. When the PORV indications were originally installed, the alarm was not considered part of the channel.

4.0 rMMEDrATE CORRECTtVE ACTrON(S)

The affected channels were declared inoperable, and a LCO requiring hot shutdown within six hours and cold shutdown within 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months was entered for each Unit in accordance with TS Tables 3.7-2 and 3.7-3 at 1343. on February 14, 1992. Additionally, a Station Deviation Report was submitted.

On May. 21, 1992,. at 2310 hours0.0267 days 0.642 hours 0.00382 weeks 8.78955e-4 months ; Units 1 and 2 PORV indication channels were declared inoperable and a forty-eight hour action statement was*entered in accordance with TS 3.7.F.'2.

5.0 ApprTIONAL CORRECTIVE ACTIONlS)

The test procedures were changed and actuation testing of the low RCS average temperature relays was performed satisfactorily. This allowed Unit 1 and Unit 2 to exit the LCOs at 1413 and 1434, respectively, on February 14, 1992.

Surveillance test procedures governing the channel functional test of the PORV position indications were changed to include testing of PORV alarm actuations. Units 1 and 2 Pressurizer PORV alarm actuation verifications were performed satisfactorily. The PORV indication channels were returned to service, and the a6tion statements were exited on May 22, 1992 at 1420 hours0.0164 days 0.394 hours 0.00235 weeks 5.4031e-4 months for Unit 1 and 1516 hours0.0175 days 0.421 hours 0.00251 weeks 5.76838e-4 months for Unit 2.

6. 0 ACTIONS TO PREVENT RECURRENCE Surveillance test procedures governing* the channel calibration test of the PORV position indications will be changed to include testing of PORV alarm actuations.

One event was identified though the Surry Procedure Upgrade Program. To improve surveillance programs, a structured Review of TS required surveillances is being conducted for both stations.

This structured program includes Engineering Reviews, Procedure Upgrades and Quality Assurance Audit activities. This program

. will continue until the TS required surveillances and associated procedures have been reviewed. Any additional discrepancies will be appropriately dispositioned, categorized and reported in accordance with the Station's deviation reporting and corrective action programs.

NRC Form 366A 16-891

e NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (6-89)

APPROVED DMB NO. 3150-0104

EXPIRES: 4/30/92 ESTIMATED BURDEN PER RESPONSE TO COMPLY WTH THIS LICENSEE EVENT REPORT (LER) INFORMATION COLLECTION REQUEST: 50.0 HRS. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS TEXT CONTINUATION AND REPORTS MANAGEMENT BRANCH (P-530). U.S. NUCLEAR

--~ REGULATORY COMMISSION, WASHINGTON, DC 20555, AND TO 1'HE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE OF MANAGEMENT-AND BUDGET, WASl;IINGTON, DC 20503.

FACILITY NAME 11) DOCKET NUMBER (21 LER NUMBER (61 PAGE (3)

Surry Power Station, Unit 1 0 15 10 IO IO I 21s 1o _9 12 _ o 1o I 3 _ 011 o, s OF O I5 TEXT (ff mom sp,,c,, i& ,-quin,d, U/11!1 *dditional NRC Form 36&il's) 117) 7.0 SIMILAR EVENTS LER S2-91-007-00: Failure To Full Flow Test 2-RH-4 7 Due To Procedure Deficiency.

8. 0 ADDITIONAL INFORMATION None.

NRC Form _366A (6-89)

ML18153D039

Text

Dear Sirs:

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