ML20005E654

LER 89-010-00:on 891204,determined That Plant Was Not Fully Meeting Surveillance Requirements of Tech Spec Table 4.3.6.4-1,item 10.b.Caused by Inadequate Procedure.Recorder Calibr Steps to Be Removed from procedure.W/900102 Ltr

ML20005E654
Person / Time
Site:	Hatch
Issue date:	01/02/1990
From:	Hairston W, Tipps S GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HL-897, LER-89-010-03, NUDOCS 9001100055
Download: ML20005E654 (7)

Text

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, [GeotDM PowerbompIny: I

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Te!ephone 205 86&5581 -

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- !!w Southem cWtric system:

, , . W. G. Heirston, Ill .

, , Senior Vice President .  ;

Nuclear Operations 1 j

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,. January 2, 1990-U.S'.: Nuclear Regulatory Commission ,

ATTN: ' Document Control Desk.

'Hashington, D.C.. 20555 PLANT HATCH - UNIT 2 E 'NRC DOCKET 50-366 L- ,

OPERATING' LICENSE.NPF-5 ,

' LICENSEE EVENT REPORT ..

LESS THAN' ADEQUATE PROCEDURE'RESULTS t IN A MISSED TECHNICAL SPECIFICATIONS SURVEILLANCE Gentlemen:-

In accordance with the requirements of 10 CFR 50.73(a)(2)(i), Georgia' Power Company is submitting - the.. enclosed Licensee Event Report (LER) concerning 'a missed Technical Surveillance due 'to a less than adequate procedure. This event occurred at Plant Hatch'- Unit 2.

't Sincerely,

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Enclosure:

LER 50-366/1989-010

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or laPower U.S. Nuclear Regulatory Commission January'2,~1990; Page Two' c: Georaia' Power Company '

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.Mr. H. C. Nix, General Manager - Nuclear Plant .

- Mr.- J. D. -Heidt, Manager Nuclear Engineering and Licensing - Hatch GO-NORMS ,,

U.S. Nuciear Reaulatory Commission. Washinoton. D.C.

Mr. L. P. Crocker, Licensing Project Manager - Hatch U.S. Nuclear Reaulatory Commission. Reaion II Mr. S. D. Ebneter, Regional Administrator Mr. J. E. Menning, Senior Resident Inspector - Hatch I'

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On 12/04/89, Unit 2 was in the Refueling mode with the fuel loaded in the core.

Non-licensed personnel'were reviewing procedure 57CP-CAL-162-2S, " Leeds and Northrup Speedomax 165 and 250 Multipoint Recorder," for Technical Specifications compliance as part of an on-going validation of the plant's Commitment Tracking System database. At approximately 0900 CST, on 12/04/89, during the review, it was  !

~ determined that the plant was not fully meeting the surveillance requirements of Unit 2 Technical Specifications Table 4.3.6.4-1, item 10.b, concerning calibration .

of instrumentation which provides secondary position indication for the Safety i Relief Valves (SRV, EIIS Code IP). Specifically, the annunciator function of the instrumentation was not being tested as required by the Technical Specifications; all other required testing was being performed fully. Upon discovery of the condition, a deficiency card was written and licensed personnel were notified. The instrumentation was not required by the Technical Specifications to be operable at the time the condition was discovered. The annunciator function was subsequently tested and proven operable on 12/14/89.

The root cause of the event is a less than adequate procedure in that procedure 57CP-CAL-162-2S did not require testing of the annunciator function of the SRV secondary position indication instrumentation.

Corrective actions include testing of the annunciator function to prove operablility and developing a new procedure which fully meets the Technical Specifications surveillance requirement.

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SUMMARY

OF EVENT On'12/04/89, Unit 2 was in the Refueling mode with' the fuel loaded in the core.

Non-licensed personnel were reviewing procedure 57CP-CAL-162-2S, " Leeds and-

.Northrup Speedomax 165 and 250 Multipoint Recorder," for Technical Specifications -

compliance as-part of an on-going . validation of the plant's Commitment Tracking System database. At approximately 0900 CST, on 12/04/89, during the review,'it was determined that _the plant was not fully meeting the surveillance requirements '

of Unit.2 Technical Specifications Table 4.3 6.4-1, item 10.b, concerning.

L' calibration of instrumentation which provides secondary position' indication for

. 'the Safety Relief Valves (SRV, EIIS Code IP). Specifically, the annunciator-function of the instrumentation was not being tested as required by the Technical Specifications; all other required testing was being performed fully. Upon

- discovery of the condition, a deficiency card was written and licensed personnel were notified. The instrumentation was not required by the Technical Specifications:to be operable at the time the condition was discovered. .The annunciator function was subsequently tested and proven operable on 12/14/89.

The root cause of the event is a less than adequate procedure in that procedure 57CP-CAL-162-2S did not require testing of the annunciator function of the SRV p secondary position indication instrumentation.

Corrective actions include testing of the annunciator function to prove p operablility and developing a new procedure which fully meets the Technical l Specification:: surveillance requirement.

L ' DESCRIPTION OF EVENT l

On 12/04/89, Unit 2 was in the Refueling mode with the fuel loaded in the core.

Nonlicensed personnel were in'the process of validating the plant's Commitment Tracking System database. As part of this effort, a review of plant procedures was being performed to verify compliance with the plant's Technical Specifications. At approximately 0900 CST, it was determined that the plant was ,

not fully meeting the surveillance requirements of Unit 2 Technical Specifications Table 4.3.6.4-1, item 10.b, concerning calibration of the instrumentation which provides the secondary position indication for the SRVs. Specifically, procedure L 57CP-CAL-162-2S required calibration of temperature recorder (2821-R614) by l adjusting inputs to the recorder and verifying a corresponding output; however, l

the procedure did not require checking the annunciator function of the i

instrumentation. The instrumentation is designed such that an annunciator alarms in the Main Control Room when an SRV tailpipe temperature exceeds a setpoint programmed in the recorder, i

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On 12/4/89, upon discovery of the condition, a deficiency card was written and i licensed personnel were notified. The SRV position indication was not required to -

be operable at that time. The SRV secondary position indication annunciator function was satisfactorily tested and proven operable in accordance with Unit 2 Technical Specifications -on 12/14/89.

L CAUSE OF THE EVENT The root cause of the event is a less than adequate procedure. Procedure I 57CP-CAL-162-2S did not fully implement the surveillance requirements of Unit 2 Technical Specifications Table 4.3.6.4-1, item 10.b. Specifically, the alarm-verifications portion of~the procedure did not test the annunciator portion of the SRV Secondary Position Indication channel as required by the Technical Speci fications.

R REPORTABILITY ANALYSIS AND SAFETY ASSESSMENT This report is required per 10 CFR 50.73(a)(2)(1) because a condition existed that i was. prohibited by the plant's Technical Specifications. Specifically, the channel calibration of the Safety / Relief Valve (SRV) Secondary Position Indicators 2B21-N004A through H and K through M was not performed as required by Unit 2 l- Technical Specification Table 4.3.6.4-1, item 10.b. The calibration performed using procedure 57CP-CAL-162-2S did not include a check of the alarm function as required for a channel calibration.

SRV position indication is provided by two methods. One method is monitoring ,

downstream, or tailpipe, pressure. This is the primary position indication and is performed by pressure switches 2B21-N301 A through H and K through M. The pressure switches actuate relays which, in turn, actuate annunciators in the Main Control Room. The SRV-Primary Position Indicators are covered by the Unit 2 Technical Specifications (Table 4.3.6.4-1, item 10.a, and Section 4.4.2.1.a) and are tested fully as required.

The secondary method of monitoring SRV position is by tailpipe temperature. This indication is provided by 11 thermocouples, one for each SRV, connected to a common temperature recorder in the Main Control Room. Contacts internal to the i

recorder actuate an annunciator in the Main Control Room if the temperature downstream of an SRV reaches a prescribed trip setpoint (approximately 230*F).

In this event, the alarm function of the recorder fed by the SRV Secondary Position Indicators was not checked as required by the Unit 2 Technical Specifications . Specifically, it was not verified that proper Main Control Room annunciation was received when test inputs to the recorder exceeded the prescribed trip setpoint during performance of the channel calibration. The rest of the channel, including the recorder itself, was calibrated as required, i

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The annunciator actuated'by the temperature recorder, however, is only a backup-to the Primary Position Indicators-(i.e., the pressure switches)._ The pressure

' switches actuate a different annunciator in the Main Control Room.to indicate an SRV. may be open. The Primary Position Indication channel is tested as required by the Unit 2 Technical Specifications, therefore, it.was operable throughout this event.- Additionally, all annunciators are checked during each shift, consequently, problems with the Secondary Position annunciator such as a burned-out bulb or loose wires internal to the annunciator, .would-be found and corrective action initiated promptly . Finally, testing of the annunciator-portion of the SRV Secondary Position Indication channel performed following discovery of. thisLevent revealed it to be operable. It, therefore, is reasonable to assume the annunciator would have alarmed as required in the event high

. temperature was detected downstream of an SRV' .

Based on the above information, it is concluded this event had no adverse impact -

on nuclear safety. This analysis is applicable to all power levels.

CORRECTIVE ACTIONS The annunciator portion of the SRV Secondary Position Indication channel was

. tested as required by the Unit 2 Technical. Specifications. The testing was completed successfully on 12/14/89, thus proving the annunciator operable.

The existing recorder calibration steps will be removed from proccoore 57CP-CAL-162-2S (a generic recorder calibration procedure for Leeds and Northrup recorders) and placed in a new procedure which will include all steps necessary to comply with Technical Specification calibration requirements. Specifically, the

. new procedure will contain steps to check the annunciator alarms when the prescribed trip setpoint is exceeded during calibration of the recorder. The new procedure will be approved for use prior to the next scheduled channel calibration of the SRV Secondary Position Indicators, l

j -ADDITIONAL INFORMATION l' No systems other than the SRV Secondary Position Indicators were affected by this

[ event. These position indicators have no other function.

No component failures resulted in or were caused by this event.

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EXPIRES: e/31/3

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• w w w mu wnn (ThereLhave been previous ~ similar events in.which plant procedures did not.ful.ly

. implement the- surveillance' requirements of the. plant's Technical: Specifications.

• These~ events' were' reported in the following Licensee Event Reports:

321/1989-016, dated'11/30/89 -

50-321/1989-011,- dated 09/26/89:

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321/1989-009, dated 09/22/89 '

150-321/1989-005, dated 04/21/89 4

50-321/1988-019, dated 01/16/89-150-366/1989-006, dated 10/26/89 50-366/1989-002,-dated'03/14/89-50-366/1988-002, dated 03/18/88i

. Corrective actions for these events included counseling personnel, revising procedures, reviewing an- amendment involved in a previous event, and reviewing; a

- sample 'of-surveillance procedures.. These corrective actions would not have prevented this event because it did not result from personnel error, did 'not -

involve the review -of a. Technical Specification amendment, and was not in the l f sample of procedures reviewed.

• U,$. GPos 1988-520-$8 J t!0070

'.-(NRC 9 33) FORM 346A