ML19354D893

LER 89-024-00:on 891218,determined That Wires Which Connect Actuation Device Logic Relay Contacts to Remainder of Circuit Not Tested During Channel Calibr Test.Caused by Inadequate Test.Test Program Upgrade underway.W/900117 Ltr

ML19354D893
Person / Time
Site:	Calvert Cliffs
Issue date:	01/17/1990
From:	Gross K, Russell L BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-89-024, NUDOCS 9001230212
Download: ML19354D893 (7)

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• . '. BALTIMORE a' OAS AND ELECTRIC CHARLES CENTER e P.O. BOX 1475

• BALTIMORE MARYLAND 21203-1475 CALVERT CLIFF 8 NUCLLAR POWER PLANT DEPARTNINT 2;Sff'a"2'""" ^^"'

January 17, 1990 s

U. S. Nuclear Regulatory Commission Docket Nos. 50 317 6 50-318 i Document Control Desk License Nos. DPR 53 6 69 1 Washington, D. C. 20555 r

Dear Sirs:

The attached LER 89 24, Revision 0, is being sent to you as required under 10 CFR 50.73 guidelines.

Should you have any questions regarding this report, we would be pleased to discuss them with you.'

Very truly yours,  ;

s L. B. Russell Manager Calvert Cliffs Nuclear Power Plant Department KWG:Ir cc: William T. Russell Director, Office of Management Information I and Program Control Messrs: G. C. Creel C. H. Cruso R. E. Denton J. R. Lemons 4

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. LICENSEE EVENT REPORT (LEMI 8 ACILITY hAME 01 Dockti NunestR us ' ADE i3i Calvert Cliffs Nuclear Power Plant. Unit 1 o l6 l 0 lo l 0 l3l1 p 1 lOrl0 (a Incomplete Channel Calibration Procedure Results in Failure to Test Certain Portions of PORV Actuation Circuitry tytNT DAf t (S) L t R NUM9t R (61 REPORT DAf t (7) OTHE R 9 ACILiitts INv0LvtD 101 MONT H l Da y vtAR vtAR Sigy LA6 ga.ng pg upygg pay y g g,, , Acetiiv haute 00Ct tT NvMetRisi

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On December 18, 1989 it was determined that a limited portion of the automatic actuation circuitry associated with the Pressurizer Power Operated Relief Valves (PORVs), was not properly tested in its associated Technical Specification Surveillance Test. An investigation determined that the wires which connect the actuation device logic relay contacts to the remainder of the circuit, were not tested during conduct of the Channel Calibration tests. The balance of the circuit was properly tested. The cause of this event was an inadequate Surveillance Test and historical surveillance program weakness. The Calvert Cliffs Unit 1 circuitry has been tested and verified operable. The Unit 2 circuitry will be tested prior to restart from its current outage. The condition identified in this report is limited to inadequate testing of the two rel i.ively short lengths of wire associated with each PORVs high pressure function.

The Minimum Pressurization Temperature protection functions of the - PORVs were not affected.

Corrective Actions include a change to correct the procedure, and the ongoing Surveillance Test program upgrade effort. Some of the the corrective measures and improvements implemented to date led directly to identification and resolution of this condition, gC,,,e,. =

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0 l0 0l2 or 0 l6 iext u . ,= we min.inri I. DESCRIPTION OF EVENT On December 18, 1989 it was determined that a limited portion of the automatic actuation circuitry associated witt. both Calvert Cliffs units Pressurizer Power Operated Relief Valves (PORVs) were not properly tested in the associated Surveillance Test. Calvert Cliffs Unit I was in mode-5, cold shutdown,' Unit 2 was de. fueled, and both units were at atmospheric pressure and less.than 120*F at the time this condition was discovered.

During the investigation ref a concern identified in a Surveillance Test Procedure (STP) program review, the Instrumentation and Control (I&C) Functional Surveillance Test Coordinator (FSTC non licensed utility. employee) ' identified two sections of wire associated with each PORV which were not tested during the Channel Calibration test. The FSTC was investigating a concern related to the Channel Functional test of the PORVs as required by the Calvert 011ffs Technical Specifications (T.S.) Section 4.4.3.1.b. This Technical Specification describes the applicable PORV requirements for Power Operation, Startup and Hot Standby.

The FSTC's investigation determined that the wires which connect the actuation device logic relay contacts to the respective terminal blocks and hand twitches, were not tested during the conduct of the channel calibration tests. The balance of the circuitry is adequately tested, including the actuation contacts from the actuation logic relay. The historical method used in the test was to measure the impedance across the contacts of the actuation logic relay. The balance of the circuit was verified operable through the hand switch and Minimum Pressurization

'emperature (MPT) testing. However the test points used in the procedure did not provide verification of the two sections of wire from the relay contact terminals to the terminal block and hand switch on either side of the relay contacts. (See attachment 1.)

11. CAUSE OF EVENT The cause of this event was an inadequate Surveillance Test in that the Channel Calibration performed on the automatic circuitry did not verify the proper portions of the circuitry were capable of performing their design function. The procedure deficiency was the result of historical Surveillance Test Procedure program weaknesses which allowed the generation, review and use of an inadequate procedure. '

III. ANALYSIS OF EVENT The Surveillance Test deficiency described above is- reportable as a condition prohibited by the Technical Specifications in accordance with 10 CFR 50.73(a)(2)(1)(B).

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The condition identified in this report is limited to inadequate testing of the two relatively short lengths of wire associated with each PORVs actuation logic circuitry. The Minimum Pressurization Temperature protection function of the PORVs was not affected. Similarly, the automatic high pressure protection function logic was properly tested through the actuation relay contacts. The PORVs were verified to open in response tc an actuation signal.

At the time this condition was discovered the units were in a mode which did not i

require the high pressure automatic actuation function to be operable. The MPT l function of the PORV's was not affected by this condition. The Unit 1 circuitry has been tested and verified operable. The Unit 2 circuitry will be tested prior to restart from the current . outage. Based on the Unit 1 information, it is believed that the functional capability of the PORVs has not been affected by this procedure deficiency.

The two Pressurizer Power Operated Relief Valves provide relief capacity to prevent the opening of the ASME Code Safety Valves during a high pressure transient in the primary coolant system. The PORVs are actuated by the high reactor coolant system pressure trip signal. The valves are solenoid operated power relief valves. The two half capacity valves are located in parallel pipes which are connected to the two pressurizer safety and relief valve nozzles on the inlet side and to the relief line piping to the quench tank on the outlet side.

Manual operation of PORVs is described in the plant emergency operating procedures written to respond to a total loss of all feedwater. In the unlikely event a total loss of all feedwater occurs, including main and auxiliary feedwater, the PORVs would be manually opened while Safety Injection and Charging are used to inj ect coolant into the primary system. Manual operation of the PORVs is obtained through removal of the High Pressurizer Pressure Trip Units and would have been unavailable if one of the wires omitted from this surveillance test had failed open.

Two ASME Code Safety Valves are located on the pressurizer and provide over l pressure protection for the reactor coolant system, diverse from . the PORVs.

These valves are sized to limit primary system pressure to 110 percent of design following a complete loss of turbine generator load while operating at 2700 megawatts thermal power. This independent over pressure protection was not I affected by this condition.

The only part of the PORV actuation circuitry affected by this event is the wire, a passive component with no readily postulated failure mechanisms. The cabinets in which the wire and relays are located are not in a harsh environment.

Based on the acceptable as-found condition of the Unit 1 circuitry and the l availability of the ASME Code Safety Valves, this condition did not affect the health and safety of the public.

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IV. CORRECTIVE ACTIONS i Immediate The FSTC initiated a Nonconformance Report upon determination that a deficiency existed in the procedure. .

A procedure change has been initiated to correct the Unit 1 Surveillance Test I procedure by assuring that the proper wires are tested and verified capable of performing their safety function. The Unit 2 procedure will be corrected prior to performance, before that unit returns to operation from its current outage.

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The Surveillance Test Procedure (STP) program is undergoing a major upgrade at this time. This deficiency was identified as a result of corrective actions and subsequent investigations initiated to address historical weaknesses. The l program has been upgraded to include coordinators who are responsible for overseeing and maintaining STPs assigned to them. A major part of their responsibility is assuring that Technical Specification requirements are properly ,

addressed in the procedures. The individual who identified this condition is one l of the coordinators who has been assigned to this function. .In addition, a review of the existing procedures which are used to satisfy Technical Specification surveillance requirements is nearing completion. This review ,

initiated the concern which led to the investigation' by the FSTC, and j identification of this condition. Each concern identified by this review is being addressed and resolved to assure Surveillance ~ Test adequacy. The STP program improvement is a continuing effort and includes additional reviews of i procedures and programs as needed. The effort is extensive and current plans include additional detailed reviews of procedures. This effort will continue until all identified concerns have been addressed.

If additional reportable deficiencies are identified as a result of this program, they will be reported as a supplement to this report. If Unit 2 test 'results ,

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9 V. ADDITIONAL INFORMATION ,

Related Events

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No similar reportable events related to incomplete testing of circuitry due to insufficient overlap have been identified. STP program and STP weaknesses and deficiencies have been recorted in LERs 317/89-017 and 317/89 013. .

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