ML19332B958

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LER 89-054-00:on 891025,discovered That Daily Channel Check Surveillance Requirements for Channel D High Level Trip Not Met.Caused by Procedural Deficiency Since Initial Plant Operation.Associated Log Procedures revised.W/891110 Ltr
ML19332B958
Person / Time
Site: Limerick Constellation icon.png
Issue date: 11/10/1989
From: Endriss C, Mccormick M
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-89-054, LER-89-54, NUDOCS 8911220117
Download: ML19332B958 (6)


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10 CFR 50c73

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PHILADELPHIA ELECTRIC COMPANY l LIMERICK GENER ATING ST ATION

' P. O, BOX A S AN ATOG A. PENNSY LV ANI A 19464 (218) 3271200 sat. 2000 6

u. 4.' u.c o e.uic a, a... e.c. November 10, 1989 i....2'.'.'.".'.",*.*.."...... Docket Noa. 50-352 50-353 1 License Nos. NPF-39 ,

NPF-85 i

U.S. Nuclear Regulatory Commission Attn Document Control Desk Washington, DC 20555

SUBJECT:

Licensee Event Report Limerick Generating Station - Unit 1 and Unit 2  ;

This LER reports a condition prohibited by Technical I 1 ' Specifications (TS) in that the daily CHANNEL CHECK surveillance '

requirement for the 'D' channel reactor high level trip (Feedwater/ Main Turbine) was not met and the associated TS actions were not taken. This condition was caused'by a procedural deficiency and has existed since initial plant ,

operations.

Reference:

Docket Nos. 50-352 50-353 Report Number: 1-89-054 -

Revision Number: 00 Discovery Date: October. 25, 1989 Report Date November 10, 1989 Facility: Limerick Generating Station P.O. Box A, Sanatoga, PA 19464 This LER is being submitted pursuant to the requirements of 10'CFR 50.73(a)(2)(1)(B).

Very truly yours, o n (

Q WAR:ch cc: W. T. Russell, Administrator, Region I, USNRC T. J. Kenny, USNRC Senior Resident Inspector, LGS 8911220117 891110 PDR ADOCK 05000352 g\

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Limerick Cenerating Station Unit 1 and Unit 2 o isio!oIoi 3l5g2 tjodnp; l rit'8"> Technical Specification Violation due to missed surveillance of channel 'D' reactor

! high level trin (Feedwater/ Pain Turbine) because of a procedural deficiencv.

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l 1 On October 25, 1989, plant staff engineers discovered that the daily. CHANNEL CHECK surveillance requirements for the 'D' channel reactor high level trip (Feedwater/ Main Turbine) was not being met and the associated Technical Specifications (TS) actions were not initiated. This resulted in a condition prohibited by TS.

This condition was caused by a procedural deficiency and has existed since initial plant operation of both Unit 1 and Unit 2.

The original plant design did not include a level indicator for Feedwater/ Main Turbine Trip System channel 'D'. The consequences of this event were minimal as the remaining channels were sufficient to provide the trip function. The deficient Daily Surveillance Log procedures were revised and the required CHANNEL CHECK.for trip system channel 'D' was successfully completed at approximately 2345 on October 25, 1989 for Unit 1 and Unit 2.

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L 1 Unit Conditions Prior to the Eventt

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Unit 1 Operating Condition: 1 (Power Operation) 4: Unit 2 Operating Condition: 1'(Power Operation)

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Description'of the Event:

4' On OctoberL25, 1989 it was discovered that the daily CHANNEL

' CHECK surveillance requirements.for the Unit 1 and Unit 2 i

. Technical Specifications (TS) 3.3.9, " Feedwater/ Main Turbine Trip )

System Actuation Instrumentation," (EIIS:JK) were not met and the associated action had not been taken resulting in a condition prohibited by TS.-

' The disco'very was made by plant staff engineers during a meeting to review recommendations for reactor vessel overfill protection providedlin NRC Generic Letter 89-19. Specifically, the Daily DL Surveillance Log Procedures (ST-6-107-590-1 and ST-6-107-590-2)

I for Unit 1 and Unit-2 did not include a CHANNEL CHECK of the 'D' L channel for the Feedwater/ Main Turbine Trip System Actuation Instrumentation (Reactor High Water Level 8 Trip). The l; procedures did include the required CHANNEL CHECK for the three l redundant trip system channels (A,B,C). These CHANNEL' CHECKS are L accomplished by comparison of reactor water level readings from Level Indicators LI-42-R606A, LI-42-R606B, and LI-42-R606C.

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At 1630 on October 25, the Main Control Room (MCR) Shift Supet/ision was informed of this procedure deficiency and TS:

non-compliance. Shift Supervision immediately entered TS 3.3.9 Action b, because only 3 of the 4' system instrument channels were in surveillance and considered OPERABLE. The applicable procedures (ST-6-107-590-1 and ST-6-107-590-2) were revised and F the required CHANNEL CHECK for trip system channel 'D' was >

successfully completed at approximately 2345 on October 25,1989 for Unit 1 and Unit 2. At this time, Shift Supervision exited TS 3.3.9 Action b, because all four system instrument channels were now in surveillance and considered OPERABLE. The CHANNEL CHECK was accomplished by comparison of reactor water level readings from Level Indicating Controllers LIC-06-120 (Unit 1) and LIC-06-220 (Unit 2) with readings from the other three channel level indicators. These LICs receive a level signal from the 'D' channel.

Further review of the procedure deficiencies revealed that this problem existed since the original procedure revision 0 and initial plant operations for both Unit 1 and Unit 2. Level Indicators LI-42-R606 A,B,C are located in the MCR. The original plant design did not include a level indicator for Feedwater/ Main Turbine Trip System channel 'D'. Level Indicating Controller LIC-06-120 was added to the plant design via MODIFICATION 5201, ,

completed on May 5, 1989 during the Unit 1 second refueling-outage. LIC-06-220 was incorporated into the Unit 2 design prior to receipt of the initial Operating License NPF-83, issued June 22,-1989. Availability of LIC-06-120 and LIC-06-220 for the trip system channel 'D' reading was coincidental because the purpose of their installation was to enhance Feedwater System flow control.

This LER is being submitted in accordance with 10 CFR 50.73(a)(2)(1)(B), any Operation or Condition Prohibited by TS.

c Consequences of the Event:

There were no adverse consequences resulting from the missed CHANNEL CHECK surveillances of Feedwater/ Main Turbine channel

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The 'D' -channels, when checked on October 25, 1989 were found to l be in operable condition. The other three trip system channels (A,B,C) were operable and. sufficient for.the trip system to perform its intended function if the 'D' channel had become inoperable. The Feedwater/ Main Turbine Trip System instrument channels are highly reliable as evidenced by a lack of problems or inoperability during plant operations or surveillance testing activities (CHANNEL FUNCTIONAL TESTS, CHANNEL CALIBRATIONS, LOGIC SYSTEM FUNCTIONAL TESTS). In addition, individual status lights for each channel (A,B,C,D) in the MCR would have alerted reactor operators to a problem with any channel failure in the conservative upscale TRIP condition.

Cause of the Event:

L The CHANNEL CHECK surveillance requirements for Feedwater/ Main Turbine Trip Instrument channel 'D' were not met because of incomplete Daily Log Surveillance procedures, ST-6-107-590-1 (Unit 1) and ST-6-107-590-2 (Unit 2). These procedures are performed daily by operators on each shift and satisfy most of the frequent TS surveillance requirements. The reason for the CHANNEL CHECK omission'from the original version of ST-6-107-590-1 in November 1984, is not known. However, part of the CHANNEL CHECK TS Definition "where possible," and lack of a channel 'D' level indicator is considered to have contributed to the error. The reason for the CHANNEL CHECK omission from the original version of ST-6-107-590-2 in June 1989, was an oversight error by the procedure writing and review personnel.

l l Corrective Actions: -

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Daily Surveillance Log Procedures ST-6-107-590-1 and ST-6-107-590-2 were revised and the required CHANNEL CHECK for Feedwater/ Main Turbine Trip System Instrument Channel 'D' was successfully completed at approximately 2345 on October 25, 1989 for Unit 1 and Unit 2.

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Actions Taken to Prevent Recurrence: ,

', l A special review of Daily Log Surveillance procedures ST-6-107- ,

590-0, ST-6-107-590-1, ST-6-107-590-2, ST-6-107-591-1 and ST 107-591-2 was completed on November 8, 1989, which verified that all TS instrument CHANNEL CHECK requirements for other systems were satisfied. Additionally, procedures for the other required Feedwater/ Main Turbine Trip System surveillances (CHANNEL FUNCTIONAL TEST, CHANNEL CALIBRATION and LOGIC SYSTEM FUNCTIONAL TESTS) for all four channels, were reviewed and verified to be complete. Therefore the procedures deficiencies are considered to be isolated occurrences and no further corrective actions are necessary.

  • Previous Similar occurrences:

LER 84-001 described a failure to perform two required instrument i system channel checks due to an incomplete Daily Surveillance Log procedure ST-6-107-591-1, used during operational conditions 4 (Cold Shutdown) and 5 (Refueling). The procedural deficiency was l discovered and corrected prior to initial criticality for Unit 1.

Tracking Codes: D2 - Inadequate procedure - did not include all l requirements. ,

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