ML19324B517

LER 89-021-00:on 890925,inadequacy Discovered in Procedure Used to Calculate ESF Response Times Re Slave Relays.Caused by Procedure Inadequacy Since Initial Procedure Development. Slave Relay Surveillances revised.W/891025 Ltr

ML19324B517
Person / Time
Site:	Millstone
Issue date:	10/25/1989
From:	Langan J, Scace S NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-89-021, LER-89-21, MP-13658, NUDOCS 8911070030
Download: ML19324B517 (5)

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CE.*.nIEi.N.r e.'rviEc*d ny P.O. BOX 270 HARTFORD. CONNECTICUT 00414-0270 Nortn it woei nergy company (203)666-6000 J October 25, 1989 MP-13658 Re: 10CFR50.73(a)(2)(i)

U.S. Nuclear Regulatory Commission >>

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Reference:

Facility Operating License No. NPF-49

Docket No. 50-423  ;

Licensee Event Report 89-021-00 Gentlemen:

This letter forwards Licensee Event Report 89-021-00 required to be submitted within thirty (30) days pursuant to 10CFR50.73(a)(2)(i), any operation or condition prohibited ~ i by the Plant's Technical Specification, i Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY I

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Ste n Scace Station Superintendent i Millstone Nuclear Power Station ,

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Attachment:

LER 89-021-00 cc: W. T. Russell, Region 1 Administrator

, W. J. Ravmond, Senior Resident Insxctor, Millstone Unit Nos.1, 2 and 3 ,

D. H. Jaffe, NRC Project Manager, Vlillstone Unit No. 3 8911070030 891025 DR ADOCK0500g3 p fji

NHC Form St4 U.S. NUCLE AR REGU.ATORY COVMISSION APPHOVLD OMb NO 01M =O10e (6-891 EXPIRE S 4 30'02 1stemstW buroen oer response to compty witn this

, , information Coii3ction rwu?st &O O hrs. Forw*f tf LICENSEt! EVENT REPORT (LER) *Ue*L't!?la'n"2#e'n%.I','$"$eTEYs*Tf]cioar Repwatory Commission, Washmpton DC 2066f ano to the Paperwork Fieauction Pioiset (3160-010ei. Ottice of Management anc buopet. Washington DC 20603 F ACli.fi Y N AME I t ) DOWL 1 NvMM h 6s ; NM Millstone Nuclear Power Stanon Unit 3 ol 6l of of op l2 l3 1lOFl 0l 4 ut Lt i.i Miscalculation of Enrineered Safety Features Response Time Due to Procedural Inadequacy E VE NT DATE e6s LE A tJJMDF A fc) '

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cAUSE SYSTEM COMPONENT MIUh* 7d I II I I I I I II I I I I I II I I I I I II I I I I SUPPLEMENT AL REoORT EXPECTED (14' MONTH DAY YEAR Exp TED 7 YEr et vos comotete EXPECTED suBM:ssiON DATE) NO WE 61 " g ABSTRACT (Limit to 1400 spaces. i.e , approximately fif teen omgie-speco typewritten imess (16)

On September 25,1989, at 0840 hours0.00972 days <br />0.233 hours <br />0.00139 weeks <br />3.1962e-4 months <br />, with the plant operating in Mode I at 100% power, 566 degrees Fahrenheit and 2250 psia, an inadequacy was discovered in the procedure used to calculate Engineered Safety Feature (ESP) response times This inadequacy involved the failure to account for the response time of slave relays, it was discovered durmg a technical review and revision of the ESF response time test

program.

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The root cause of this event was procedural inadequacy which existed since initial procedure development.

l Data obtained from the slave relay testing performed during August and September,1989 has been

! reviewed to determine the effect of slave relay response time on the "as calculated" channel response time 1 calculated du/ing the past refueling outage. For those slave relays that are " BLOCK" tested (i.e. logic tested without equipment actuation), a special test was performed to measure the response umes. This review concluded that acceptance enteria was met when slave relay response times were included. Slave relay surveillances will be revised prior to April 1,1990, to include determination of slave relay response times at least once per 16 months.

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1. Desmminn of Esent On September 25,1989, at 0840 hours0.00972 days <br />0.233 hours <br />0.00139 weeks <br />3.1962e-4 months <br />, with the plant operatmg in Mode 1 at 1009 power, $b6 degrees Fahrenheit and 2250 psia, an inadequacy was discovered in the procedure esed to calculate Engineered Safety Features (ESF) responte umes. This inadequacy was discovered while the procedures were being revned and rewritten to redistribute responsibility for channel response time calculations, Plant Technical Specifications define ESF response time as that time interval from when the runitored parameter exceeds its ESF Actuation Setpomt at the channel sensor until the ESF equipment performs its safety function. Test procedures currently measure the response time of each hnk from the sensor through actuation of the master relays in the Sohd State Protection System (SSPS) sia overlap testing. The total ESF channel stroke time is then obtained by addmg in the hmiting component actuauon time, taken from the most recent Operauons Department suncillances. These response umes are obtained by timmg pump or vahe stroke ume from the initiation of a change in state signal from the main board control switch, until the component is in its desired state. This method does not include the response time of the slave relays, which generate the final signal to reposition the component in the event of an ESF actuation. Thus, the definition of ESF response time is not met.

II. Cntne of Event The root cause of this event was procedural inadequacy. Operations Department valve stroke surveillances were written to address the Technical Specification and Inservice inspection (151) requirements for stroke time ent), without addressing ESF response time requirements. The Instrument and Control Department (l&C) response time procedures were not written to include slave relay response time testmg. It could not be determmed why the procedures failed to account for slave relay response time when they were originall) written.

Ill. Annksic of Event This event is reportable under 10CFR$0.73(a)(2)(i), as a violation of Technical Specifications.

Every refuehng outape, a comprehensive ESF test is performed to verify operabihty of the Solid State Protection System (SSPS) through to individual components. Every quarter, slave relay testing is performed by the Operations Department to verif) that slave relays actuate and send a signal to their associated equipmen'. Therefore, the ability of the slave relays to actuate is not in question. The data from the most recent round of slave relay "GO" testing (i.e. testing with equipment actuation) was reconstru;ted from the plant process computer. From this data, a response time from initiation of the test signal through to the component reaching ns final stt.te was obtained (i.e., the response time ci the slave relay was meluded). This time was compared to the component response times used to calculate channel response times durmy the precedmg refueling outage. In no case did the channel response time exceed the Technical Specification acceptance criteria. Seven slave elays in each train of SSPS that drive ESF equipment are " BLOCK" tested (i.e. logic tested without equipment actuation). A special test was performed to measure the response time of the slave relays. This time was then added to the stroke time of the associated components. Again, Technical Specification acceptance criteria were met when the revised stroke times were meluded in the channel response time calculation. Therefore, this procedural inadequacy had no adserse impact on plant safety.

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buopet. Washmoton oftece of DC P0503, FAc(rfY NAML ol DQcKET NUMBER m t rm rAv,,rn m FAGE os vEAm eLer.m.i g i Milktone Nuclear Power Station Umi3 ~ ~

0l 6l 0l 0l 0l4 l2 l3 hj9 Oj2l1 0l0 0] 3 OF 0l4 Tex 1 oi mo,. .p.e. i. reaurea u.. .aomon i onc Form ai,i,* i on IV. Corrective Action in order to account for slave relay response time, the slase relay "GO" test surveillance will be revised by April 1,1990, to include stroke timing of the equipment actuated by each slave relay at least once per 18 months. The revised surveillance will measure the time from initiation of the TEST signal into the slase rela), until the equipment is in its fmal state. In addition, the

" BLOCK" test portion of the slave relay test procedure will be revised by April 1,1990, to include measurement of those relays response time at least once per 18 months. These response times will then be added to the stroke times of the associated components. When these times are added to the response times currently calculated by IkC, a channel response time from the time the sensor exceeds its ESF actuation setpomt until the equipment performs us safety function will be .

measured. '

V. Addnionn! Informntion The following LERs document Technical Specification violations due tc procedural inadequacy:

LER Number (;uNect 86-034 Rad Monitor Sampler Flow 86-047 OTdT Setpoint 86-053 Intermediate Range Detector Setpoints86-058 Radiation Monitor Surveillance '87-035 Containment Air Lock 87-04: Missed Intermediate Range / Power Range Surveillance Due :o Procedural inadequacy 87-045 Failure to Sample Diesel Fuel Oil for Kinematic Viscosity 88-000 Improper Bypass Breaker Surveillance 89-006 Missed Fire Detector Surveillance on Six Fire Detectors Techmcal Specification surveillances were reviewed in the 3rd quarter of 1988 as corrective action for LER 87-042-01. LER 88-020 was submitted to document an inadequate surveillance interval .

for the Reactor Trip Bypass Breakers. This inadequacy was identified during the review process.

As corrective action, the surveillance was updated to reflect the required surveillance interval. LER 89-006, which was reported after completion of the review, identified a deficient Fire Detector Surveillance on six Fire Detectors. As corrective action for this LER, a comprehensive review of the Fire Detection and Control System surveillances verifying Technical Specification requirements was performed. Only minor deficiencies were identified and have been corrected.

The lack of slave relay response time testing was identified during the review program performed as corrective action for LER 87-042-01. However. the technical reviewer did not identify this deficiency as a violation of the Technical Specifications, and therefore, it was not reported. The surveillance procedure review yielded 6 minor discrepancies. The discrepancies were to be l corrected during the normal procedure review and revision process. This discrepancy was not I incorporateo mto the new revision due to personnel error. Thk was identified during a review and i rewnte of the response time test proFram. It was also discovered that the lack of this response time testing did, m fact, constitute a violation of the Technical Specifications. All the comments i generated on the ESF response time surveillance procedures as a result of the review have been j review ed. All other "mmor" deficiencies were correctly classified. These changes will be incorpora.ed into the appropriate surseillances as part of the normal review and revision process prior to surveillance performance.

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Y. Additionn! Informatinn (Conunued) ,

None of the other comments generated last fall were determined to be violations of Technical Specifications. It is concluded that the failure to incorporate the requirement to response time test

' slave relays, and the failure to identify this as a volation of Technical Specifications was an isolated occurrence, and no further corrective action is required.

Elle Codes EX11EE1 Engmeered Safety Features Actuation System - JE

• Sohd State Protection System - JO 1

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