ML19325C449

LER 89-032-00:on 890906,discovered That Monthly Functional Test for Reactor Bldg Area Radiation Monitors Not Performed as Required by Tech Spec.Caused by Inadequate Procedural Guidance.Procedure Rev Request Form revised.W/891006 Ltr

ML19325C449
Person / Time
Site:	Arkansas Nuclear
Issue date:	10/06/1989
From:	Ewing E, Millar D ARKANSAS POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
1CAN108904, LER-89-032-00, LER-89-32, NUDOCS 8910160264
Download: ML19325C449 (4)

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.- Lee HxA AR 722D3 Tel 501377 4000 October 6, 1989 1CAN198954 U. S. Nuclear Regulatory Commission Document Control Desk Mail Station P1-137 Washington, D. C. 20555

SUBJECT:

Arkansas Nuclear One - Unit 1 Docket No. 50-313 License No. OPR-51 Licensee Event Report No. 50-313/89-032-00

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Gentlemen: I In accordance with 10CFR50.73(a)(2)(1)(B), attached is the subject report concerning inadequate procedural guidance which resulted in the failure to perform the reactor building area radiation monitors monthly surveillance required by Technical Specifications.

! Very truly yours, i E. C. Ewing General Manager, Technical Support and Assessment 1

ECE/0M/sgw attachment cc: Regional Administrator Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 INP0 Records Center 1500 Circle 75 Parkway Atlanta, GA 30339-3064 p >>

0910160264 POR 891016 1 I

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Firm 1062.01 A NRC Fem N6 U.S. Nuclear Regulatory Commission (9-83) Approved OMB No. 3150 0104 Expires: 8/31/85 LICENSEE EV(NT REPORT (L E R)

~ FACILITY NAME (1) Arkansas Nuclear One, Unit One IDOCKET NUMBER (2) IPAGE (3) 10151010101 31 11 !!110Fl013 TITLE (4) Inadequate Procedural Guidance Results in the Failure to Perfom the Reactor Building Ares Radiation Monitors Monthly Surveillance Required by Technical Specifications EVENT DaTE (5) ,ER NuteER (6) i REPORT DATE (7) i l l IJequentiell IRevisioni OTHER FACILITIES INVOLVED (8) ~

I 1 i Month! Day lYear lYear 1 l Number l l Number IMonth Day lYear i Facility Names Docket Number (s)

I 1 I I I i l l l 1 0 3 0 0 0 1 01 91 01 6 81 91 81 91--I 01 31 Pl"I 01 of II 01 01 61 81 91 0 4 0 0 0 t

OPERATING lTHIS REPORT 15 5UgMIIILD PUR5UANT TO THE REQUIREMENT.5 0F 10 CFR 5:

MODE (9) Ni (Check one or more of the follt.winn) (11)

POWERl ,

,,,,,1 20. 402(b) l,,,,,l 20. 405(c) l l 50.73(a)(2)(iv) l LEVEll (10) 10171411,,,,,,l1 20. 405(a)(1)(1) i,,,,1 Sn.36(c)(1) l I 50.73(a)(2)(v) i.,,,1 20.405(a)(1)(ii) 20.405(a)(1)(iii) 50.36(r )

l3l150.73(a)W(2)(1)1.,,,,1 1

l[l50.73(a)(2)(vit)

_ 1_'t 73.71(c)l**l 50.73(a)(2)(v111)( A)l,,,,,1 Other (Specify in Abstract below and 73.71 l1,,,,l120.405(a)(1)(v)

20. 405(a)(1)(i v) l,,,,,1 50. 73(a)(2)(11 ) l_l 50.73(a)(2)(viii)(B)I in Text, NRC Form 1 l 50.73(a)(2)(iii) i i 60.7a(a)(2)(x) i 366A)

LICENSEE CONTACT FOR THIS LER C,2 )

, Name i Telephone humber Dana Millar, Nuclear Safety and Licensing $pecialist l Area l ICode l 510111916141-13111010 COMPL8iTE ONE LINE FOR [ACH COMPONENT FAILURE DISCRIBED IN THIS REPORT ( .3) l l -l lReportablel l l l l lReportablel Causel$ystem ConDonent IManufacturerl to NPRDS I Causel$ystem Component IManufacturerl to NPRD$ 1 i l l l l i i

1 i I i i i i I I l i I I I I I I i 1 l l l l 1 o l I l i I I I I I I i i i i l I i SUPPLEMDr REPORT EXPECTED (14) Day Year EXPECTED l Month H SUBMI$510N l l*l Yes (If ves. complete Expected Submission Date) til No I DATE (15) i I I I I I ABSTRACT -(Limit to 1400 spaces, i.e. , approximately fif teen single-space typewritten lines) (16)

Or September 6, 1989, it was discovered tha* the monthly functional test for the reactor building area radiation oonitors was not performed as required by Technical Specification. A new procedure for the testing of these monitors had been written and the monitors had been deleted from the original test procedure. A Master Test Centrol List (MTCL), maintained to track the testing requirreents associated with Technical Specifications, should be revised whenever a procedure that may affect the MTCL is changed. Currently, there is no procedural guidance given to ensure this is accomplished. A revision

< to the MTCL was submitted with the revisions to the area radiat%n monitor procedures, however, due to an error on the MTCL revision request it wss not approved at the game time the area radiation monitor test procedures were approved and implemented on June 26, 1989. The time lapse associated with the final approval of the MTCL revision resulted in the reactor building area radiation monitors not being tested as required. The subsequent satisfactory completion of the surveillance indicated the monitors were operable. To ensure that a required Technical Specification surveillance is properly identified on the MTCL, a revision to the Procedure Revision Request Form, which accompanies each procedure change, and specific procederal guidance concerning the MTCL has been initiated.

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A. Plant Status i

At the time of occurrence of this event Arkansas Nuclear One, Unit One (ANO-1) was operating at i 74 percent of rated thermal power. Reactor Coolant System (RCS) (AB) pressure wat approximately )

2150 psia and RCS teoperature was about 579 degrecs Fahrenheit.  ;

8. Event Description ,

On September 6,1989, it was discovered that the required monthly functional test of four area radiation monitors (ll) located inside the AND*1 reactor building had not been performed within i the allowable surveil)ance interval specified in the ANQ 1 Technical Specifications. In June 1989, i a procedure which centained the testing requirements for each area radiatier monitor located

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throughout the plant aaas revised into two procedures, a new procedure addressing testing of only the area radiation monitors located in the reactor builoing ano the origine) procedure for the testing requirements of the remaining area radiation monitors (deleting the reactor building l area radiation monitors). On June 26, 1989, these two procedures were approved and authorized for i use by the Plant Safety Committee (PSC).

A Master Test Control List P CL) procedure, which lists the surveillknces that are required by Technical Specification, is used by Plannir.g and $cheduling personnel to ensure surveillances are scheduled and performed within the required time intervals as established by Technical Specifications. Any time procedures are changed which are reflected on the MTCL, an appropriate change to the MTCL procedure may be necessary. Personnel responsible for writing or changing procedures are responsible for ensuring that the MTCL procedure is revised, if necessary. When the new procedure was written for the testing of the rest

tor building area radiation monitors and the ceiginal procedure was revised to delete these monitors, a MTCL revision form was prepared and submitted to the PSC, at the same time the new procedures for testing were submitted for approval.

Upon review of the procedures and NTCL revisions by the PSC, the MTCL revision was found to be unacceptable and the procedure writer was notified of the need to correct the MTCL revision prior to apprcval by the PSC. However, the testing procedures were approved and issbed. On September 6, 1989, the MTCL revision request was approved by the PSC. As a result, between June 26 and September 6 the reacter building area radiation monitors were not functionally tested, since the MTCL did not reference the new testing procedure. This error was not detected because the original procedure which had contained the testing requirements for the area radiation monitors located inside the reactor building was listed on the MTCL and had been properly scheduled and performed.

Therefore, it appeared List the reactor building area radiation monitors were being tested as required by Technical Specifications. On September 6,1989, when it was discovered that the reactor building area radiation monitots had not been functionally tested, the monitors were declared inoperable until the testing requirements were completed. The monitors were tested satisfactorily and returned to service on September 6, 1989.

C. Safety $1gnificance Upon completion of the functional testing of the reactor building area radiation monitors, the monitors were declared operable and returned to service. Although the surveillance requirements were not perfomed within the required time interval, the satisfactory completion of the testing indicated the monitors were operable, therefore, no significant safety concerns exist.

Si Root Cause Currently, the station administrativw procedure which provides guidance to personnel concerning the procedure review, approval, and revision process does not address the need to update the MTCL if necessary when a prccedure which may affect the MTCL is changed. Without procedural v ;ance, if a change to the MTCL vvre necessary, the personnel responsible for writing, review %, or changing a procedere could only rely upon thtir memory to ensure the MTCL procedure was appropriately changed. Therefore, the lack of procedural guidance resulted in an unreliable means of ensuring the MTCL was properly updated.

E. Basis for Repottability The failure to perform a surveillance within the allowable interval specified in Technical Specifications is considered to be a condition prohibited by Technical Specifications and is therefore reportable under 10CFR50.73(a)(2)(1)(B).

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F. ' Corrective Actions-When it was identified that the surveillance asscciated with the testing requirements for the reactor building area radiation monitors had not oeen perfonned within the required time interval the tonitors were declared 1.1 operable. Lipon satisfactory completion of the surveillance on September 6, 1989, the monitors were declared operable and returned to service. Additionally, a change to the Procedure Revision Request Form, which is required to accompany each procedure that is subtitted to the PSC for approvais h6s beest initiated. Procedural guidance will be given and a specific entry on the Procedure Revision Request Form required for each procedure as to whether a change to

the MTCL is necessary or not, in the future, if a change to the MTCL in required for a given procedure the required effective date for the procedure to be implemented will be assigned when theMTCLIsupdated. This improved process provides relative assurance that the cause of missing a surveillance as a result of the NTCL not being update should not occu;' again.

G. Additional Information

. There are no ptvviously identified similar events which resulted in a Technical Specification surveillance not being performed within the required testin0 interval.because the MICL was not properly updated.

Energy Indutry Identification System (E!!$) codes are identified in the text as (dX).

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