ML20006F716

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LER 90-001-00:on 900118,determined That Containment Purge Isolation Sys Not Demonstrated Operable 100 H Prior to Start of Core Alterations.Caused by Cognitive Personnel Error. Task Force Formed to Review Tech Specs.W/900109 Ltr
ML20006F716
Person / Time
Site: Byron Constellation icon.png
Issue date: 02/16/1990
From: Pleniewicz R, Stauffer G
COMMONWEALTH EDISON CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BYRON-90-0169, BYRON-90-169, LER-90-001-07, LER-90-1-7, NUDOCS 9003010052
Download: ML20006F716 (7)


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) B ron Nuclear Station 7 4[50 North German Church Read '

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January 9, 1990 1 i

Ltra BYRON 90-0169 ,

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.U., S. Nuclear Regulatory Commission ,

Document Control Desk' '

Washington, D.C. 20555 l

4 Dear Sir

.The enclosed Licenseo Event Report from Byron Generating Station is being

, transmitted to you in accordance with the requirements of 10CTR50.73(a)(2)(1).

This report is number 90-001; Docket No. 50-454.

Sincerely,-

/, _-

R. Plenlewict Station Manager Byron Nuclear Power Station i

RP/kr Enc)osure Licensee Event Report No.90-001

.> cci A.' Bert Davis, NRC Region III Administrator

[i W. Kropp, NRC Senior Resident Inspector INPO Record Center CECO Distribution List

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!' - 0521R/0065R P '

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) . *~ f LICEN$EE EVENT REPORT (LER)

Fem Rev 2.0 Facility Name O )- Dock;t Number (2) _hgt._{ 3 )

Rvron. Unit 1 01 El 01 01 01 41 51 4 1 ! ef! 0 ! L ,

  1. ' I#I CONTAINMENT PURGE NOT V'.R!FIED OPERABLE 100 HOUR $ PRIOR TO CORE ALTERATION $

DUE TO MISC 0904UNICAT101 aND INAPPROPRIATE TRACKING MECHANISM __

__htaLDAlt_lft.) LER Number (6) Report Dale (7) OtherJAgiljitgLittrelved (B)

Mor.th Day Year Sesr /// Sequential /// Revision Month Day Year Facilliv Names Docket Number (sl fff fff

/// Number /// Number,,

NONE 01 51 01 01 01 l 1 0l1 Il B 91 0 91 0

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010 0l2 11 6 91.0 01 51 01 01 01 l I ,

pp(, THl$ REPORT !$ $UBMITTED PUR$UANT TO THE REQUIREMENi$ OF 10CFR ,

(Check one er more of the followino) fill

6. ___ 20.402(b) _ 20.40$(c) , 50.73(a)(2)(iv) __ 73.71(b)

POWER 20.40$(s)(1)(1) ,_. 50.36(c)(1) _._ 50.73(a)(2)(v) __ 73.71(c)

LEVEL , ,_, 20.405(a)(1)(ii) __ 50.36(c)(2) _ 50.73(a)(2)(vil) , _ Other (Specify i

(10) I 1 0 20.40$(a)(1)(iii) _1. 50.73(a)(2)(1) _, 50.73(a)(2)(viii)(A) in Abstract  !

//////#/u/////////////// 20.405(a)(1)(iv) _, 50.73(a)(2)(ii) 50.73(a)(2)(viii)(B) below and in

////////////////////////// 20.405(a)(1)(v) ._._ 50.73(a)(2)(iii) _ 50.73(a)(2)(x) Text)

LICEN$EE CONTACT FOR THl$ LER (12)

Name TELEPHONE NUPEER AREA CODE Gar.y.$tauf fer. Anal 11 ant Technical Staf f Supervisor Ext. 2274 Bl115 2 13 14 l .1 f,l 41 41 COMPLETE ONE LINE FOR EACH COMPON NT FAILURE DESCRIBED IN THIS. REPORT (131 l CAUSE SYSTEM COMPONENT MANUFAC- REPORTABLE / CAU$E SYSTEM COMPONENT MANUFAC- REPORTABLE TURER TO NPRDS / TURER TO NPRDS I __ l I l_ l l l '

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LUPPLEMENTAL REPORT EXPECTED (14) Expected Month l Dav l Year Submission

__hes (If ven. comRltlt_DWTED SUBM11$10N DATE) X l NO

"'"$} l l.1 lI r ABSTRACT (Limit to 1400 spwts i.e. approximate 1) fifteen single-space typewritten lines) (16)

On January 10. 1990, at 0225. with Unit 1 in its third refueling outage the fuel Handling Department began unistching the Control Rod Drive Mechanisms which is considered a core alteration. At 0755. Technical Staf f determined the containment purge isolation system had not been demonstrated cperable 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to the start of core alterations as required by Technical $pecification 4.9.9. The $hift Engineer was

, notified, and core alterations were held until 0859 when the surveillance was acceptably completed. -

The root cause of this event is two-fold. On 01/17/90 Technical Staf f personnel decided to postpone l

performance of the surveillance which was a cognitive personnel error. In addition, core alterations were

l. allowed to begin prior to performing the surveillance because of an inadequate tracking mechanism.

l To prevent recurrence. Technical Staff Group Leaders were given guidance on changing non-routine surveillance schedules. A Task Force has been formed to review Technical Specifications to identify non-routine requirements and ensure a consistent tracking mechanism is in place.

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This event is reportable per 10CFR50.73(a)(2)(1)(D). for any operation or condition prohibited by the plant's Technical Specifications.

(0521R/0065R) l'

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LICENSEE IVLNT k[ PORT _fLER) TEXT EQMUNUATION Fern Rev 2.0 i

l. FACit!TY NAME (1) DOCKET NUSER (2) LER NUMER (6) Pane (31 k . Year /// $tquential // Ri'i "

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Number ,

i avron. Unit 1 0 l 5 1 0 1 0 1 0 1 41 51 4 910 - 010l1 - 010 01 2 0F 01 6 TCKT Energy 3ndustry Identification System (E!!$) codes are identified in the text as [XX) l A. PLANT CONDITIONS PRIDR TO EVLgi:

Event Date/ Time 01/18/9L/ 0225 t~ nit 1 MODE 6_,_ . Refuelino Rx Power 0% . RC$ [ AB) Temperature / pressure _05'T /Atn.otcherie Unit 2 MODE 3 - Hot Standbv Rx Power _DL,. RC$ [AB) Temperature / Pressure _557'r /2235 PSIG.  !

B, Q[1CRIPfl0N OF EVENT:

On January 18,1990, at 0225, with Unit 1 in its third refueling outage the Fuel Handling Department began unlatching the Control Rod Drive Mechanisms (CRDMs) per Fuel Handling Procedure IBFP FH-16

" Operation of Control Rod Drive Shaft tatching/ Unlatching Tool", which is considered a core alteration.

At 0710, the Technical Staf f $urveillance Coordinator (non-licensed) notified the Radweste/ Ventilation Group teader (non-licensed) and the Assistant Technical Staf f Supervisor Outage CMJlnator (AT$$-ilcensed) .  !

that core alterations were in progress and he had no record of Technical Staff Surveillance IBVS 9.9-1  ;

" Containment Venttistion System Weekly Surveillance." being completed within 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to core ,

alterations. Per Technical $pecification 4.9.9. the survel11snce is required to be performed within i 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to the start of core alterations and at least once per 7 days during core alterations.  !

The surveillance was last performed on January 12. 1990, which is outside the Technical Specification limit l of 125 hours0.00145 days <br />0.0347 hours <br />2.066799e-4 weeks <br />4.75625e-5 months <br /> (100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> plus 25% grace period). The exceeded surveillance' interval was confirmed by i Technical Staf f, and the $hif t Engineer was notified of the event at 0755. CRDM unistching was already in j hold for removing the upper internals Itfting rig, and was held until completion of the surveillance. At 0014. Primary Containment Mint Purge (VQ)[VA) was isolated to accommodate performance of the surveillance.

  • At 0859, the surveillance was acceptably completed and the fuel Handlers were notified CRDM work 'could continue. ,

The following is a detailed description of the events leading up to the surveillance exceeding ils time interval.

During a refueling outage, daily outage schedules are distributed to various people in all departments and daily meetings are conducted for planning purposes. On Wednesday, January 17. at 1119 the Daily Planning

$chedule, which itsts major outage events, was distributed. This schedule is based on the Update Input 1 Report which is a detailed description of estimated and completed outage activity schedules supplied by

'each department. The Update Input Report had been revised after the January 12 execution of 1BVS 9.9-1 to reschedule the surveillance for January 17. Among the activities listed on the Daily Planning $chedule. -

the unistching of Control Rod Drive Mechanisms was scheduled to begin late Saturday night (January 20). ,

On January 17. at 1315 hours0.0152 days <br />0.365 hours <br />0.00217 weeks <br />5.003575e-4 months <br /> the daily outage planning meeting was conducted at which an Outage Coordinator noted the CRDM work could come "first shif t tomorrow". The AT$$ asked if that meant "first i shift Friday". The response he received was "as soon as 15 to 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> from now". The Outage Coordinator stated that the reactor cavity still had to be filled and that purification of the water (scheduled for 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> duration) would follow. The Outage Coordinator commented that the purification process would probably be done in less time than allotted.

k (0521R/0065R) i

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s I 'e g (LM$LE EVENT ,!LLl9RT ILER) TEXT CQH11NUA110N Fenn Rev 2.0 tra NLDSER f6) Pane (3)

FACIt!TY NAME (1) DOCKET N(#e[R (2)

'i 4 . Year $equential Revision

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.b ron. Unit _1 o I s 1 0 I o I o I 41 51 4 9Ie - 010l1 - 0 Io 01 3 of _ g b TEXT Energy Industry Identification System (Ell $) codes are identifled in the text as (KK)

B. 2L$1][lPJ10N OF EVENT fContinued):

On January 17, at approximately 1515, the Technical Staff Surveillahre Coordinator notified the Radwaste/ Ventilation Group Leader that he had just talked to the Shif t Engineer who informed him that core alterations would probably begin early Thursday morning (January 18h The Group Leader talked with the Assistant Technical $taff Supervisor about the notification. The sTS$ indicated that the CRDMs would be unlatched most likely on first shif t Friday and no sooner ther. 45 to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> based on information given at the 1315 Outage planning Heeting.

In addition, the Technical Staff System Engineer responsible for t.hp Cuiulanant purgo System was also responsible for the Control Room Ventilation (VC)(VI) System. On hwry 17, the 5094 VC Chiller was on day 4 of a 7 day Limiting Condition for Action Requirement (LC0AR) aed ru coasidereo e important job for the day. When the Group teader and the AT$$ discussed perfeming the wrv.t'llanie, they had to consider removing the engineer f rom supervising the VC repair in order to perfm. the serva011ance. Belleving the CRDM unistching work would begin no sooner than the next day, the Gra,e t.ecer erd AT$$ decided to leave _.

the engineer on the chiller activity and perform the survelliance the folloving u.crning (January 18).

No manual or automatic safety system actuations occurred as 3 result of this uneet.

Stable plant conditions were maintained at all times.

This event is reportable per 10CFR50.73(a)(2)(1)(B), for any operatinn er endit$on prohibited by the plant's technical $pecifications.

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C. CAUSE OF EVENT:

The root cause of exceeding the survelliance time interval is two-fold, first, Technical $taf f personnel decided to postpone performance of the turn 111ance based on the Planning Schedule bar charts which were intended as a guideline for major outap activities. The decision to postpone the surveillance, which was very near the end of the 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> crittria, was not based on accurate plant status or current information which resulted in cognitive personnel errors on the part of the Technical Staff personnel. The outage schedule used by Technical Staf f to support their decision included a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> purification period for the refueling cavity which as the activity evolved, did not require that amount of time. Neither the Technical Staf f $urveillance Coordinator, the Shif t Engineer, or Work planning were consulted in postponing the surveillance.

Second, core alterations were allowed to begin prior to performing the surveillance because there was no tracking mechanism on the 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> interval requirement that would alert the Operating or Fuel Handling Departments to verify the execution of the surveillance. 1BGP 100-6, " Refueling Outage", lists 1BVS 9.9-1 in the References, but does not include IBVS 9.9-1 in the Hain Body among the list of 9 survelliances to be verified / performed prior to core alterations.

(0521R/0065R)

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  • LICENiEE EVENT REPORT (LER) TEXT CONTINUATION Form Rev 2.0

' LER NUpBER (6) pane (3)

FACILITY NAME (1) DOCKET NUSER (8) b Year ///

ffj Sequential //j ff

/ Revision

/// Number /// Number

,1yton. Unit 1 0 l 51010 l 0 l 41514 910 - 0l0l1 -

DJ 0 01 4 0F 01 6 TEXT Energy Industry Identification System (EIIS) codes are identified in the text as (XX)

C. CAUit or EVENT (Eentinued):

An additional surveillance may have identified IBVS 9.9-1 as incomplete, but was put estab11shed to meet that need.

Operating $vrveillance 190$ 9.4-1, " Containment Butiding Penetration To Outside Atmosphere Surveillance",

has the same frequency requirements as IBVS 9.9-1 and was performed on 01/14/90, within 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to core alterations. A step in the Main Body of the procedure says PERFORM IBVS 9.9-1. This is ambiguous terminology since Operating does not perform Technical Staff surveillances. Operating verified the surveillance had been performed within the last 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />, which was based on the 01/12/90 execution, and acceptably completed the step.

D. $AFETY ANALYSIS:

There were no safety consequences impacting plant or pubic safety as a result of this event since the containment purge isolation system was capable of performing its function during the core alterations performed between 0225 and approximately 0755 on 01/18/90. 1BVS 9.9-1 had previously been acceptably completed at 0947 on 01/12/90. It was again acceptably completed at 0859 on 01/18/90.

If this event had occurred under a more severe set of initial conditions, the safety consequences of this event would have been the same since the containment purge isolation system was capable of performing its intended safety function throughout this event. Had the containment purge isolation system not auto isolated upon elevated containment radiation levels, aux 111ery building ventilation stack radiation monitors would have alatsed to alert operators of a release of radioactive material, and such release would have been manually terminated.

E. CQRRECTIVE ACH QMS:

The immediate corrective action on 01/18/90 was to ensure core alterations were ceased until IBy$ 9.9.1 was performed. The surveillance was completed, and Fuel Handling was instructed to resume core alterations by 0900 on 01/18/90.

A Human performance Evaluation System investigation was completed as a result of this event. A meeting was held on January 30, 1990, with Station managnent personnel to review this event and deterasine preventive actions.

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(0521R/0065R)

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ttEENSEE EVENT REPORT (LER) TEXT EDWTINu& TION Forn Rev 2.0 FACILITY NAME (1) DOCKET NVPSER (2) LER NUPRER (6) . - . . lene (3) l t ,

Year /// Sequential /// Revision

  • fff fff

/// Number /// Number ,

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_gyton. tinit 1 0 1 5 1 0 1 0 1 0 l al El 4 910 - 0l011 - 0 10 01 5 0F . Olj >

TEXT Energy Industry Identification System (E!!$) codes are identified in the text as (XX) J i

E .' CQRRECTIVE ACTIONS (C9ntinued :

1

1. Technical Staff Group Leaders were informed of this event and it was stated that in the future. l any changes to previously agreed upon schedules for non-routine surveillances would require clearance by the Technical Staf f Surveillance Coordinator and the Station Surveillance Coordinator prior to making the change. Group Leaders were also infonned to contact either the $hif t Engineer, the Shif t Control Room Engineer, or the Outage Expediter with questions related to plant status to j schedule / plan any surveillance activity. j
2. To prevent recurrence of this event, a task force has been formed to review Technical $pecifications to identify all non-routine conditional requirements, verify a surveillance meets the requirement, l j- and ensure a conststent tracking mechanism is in place (i.e. procedurally or within the General l

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Surveillance (GSRV) Tracking Program). Action item Recortl 455-225 90-032 tracks the resolution of l this item.

AIR 454-225-90-042 will track resolution of the ambiguity in 80$ 9.4-1 based on the Task Force  !

investigation, and ensure the surveillance is revised as necessary.

l IBGP 100-6 has been revised to add IBV$ 9.9-1 to the list of survaillances required to be performed prior 1 to core alterations.-- AIR 455-225-90 043 tracks implementation of this revision in 2BGP 100-6. This action may be revised based on the recommendations of the Task Force.

1 As interim correcti' ev actions, an enhancement was made to G$RV in the way it identifies the requirements of IBV$ 9.9-1.

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.G$RV has three activity types:

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1. Routine Active - Frequency > 0 days, Items are routinely scheduled and performed.
2. Non-Routine - Frequency = 0 days. Items are not routinely performed.

3, inactive - Items are routine, but not required due to plant condition or some other reason. I To track 1BV$ 9.9-1, the surveillance was entered as a routine, frequency 7, to track the 7 day Technical l Specification requirement within GSRV. At the end of the last outage, the surveillance was Inactivated so that 1BVS 9.9-1 would not appear on the routine, at power, printout. At the start of the present outage, a the surveillance was again entered as a routine, frequency 7 Each department survelliance coordinator j receives a weekly printout of each type of G$RV activity. They are required to review each report and  ;

ensure that the required activities are performed. The Technical Staff Surveillance. Coordinator's review 1 of the inactive items identified the need to perform 1BVS 9.9-1 100 within hours prior to core )

alterations. However, this requirement might not have been understood by an independent reviewer not j

,. familiar with the Technical $pecification. After the January 18, 1990 event, a separate entry was created l on GSRV to identify the 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> requirement in addition to the 7 day frequency. This action may be j revised based on the recommendations of the Task Force.

(0531R/0065R)

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licit l$EE EVENT REPORT fLER) TEXT CONTINLIA110N . Fern Rev_ Q fACit'!TY NAME (1) DOCKET NUPSER (2) LER NLMSER (6) Phae (3)  ;

4 , Year ffj/

// $equential /j/j/ Revision j

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/// Number /// Number _

.)vron. Unit 1 0I$101010141El4 910 - 01011 - 0 10 01 6 0F 01 6 TEKi Energy Industry identification $ystem ([11$) codes are identified in the text as (KK)

F. EREY1021,9tCURRENCEs There have been previous occurrences of exceeding surveillance intervals.

Licensee Event Report 87-014 (Docket 50-455) dotuments a similar occurrence due to personnel error and ,

inadequate tracking mechanism. The containment air lock was not leak tested af ter an entry because an ]

engineer reviewing the Radiation Key Log Book overlooked a Unit 2 containment entry. No procedure existed  ;

to track air lock door openings. q An in-house Deviation Report resulted from the lack of a procedure to verify reactor vessel water level within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> prior to the start of movement of fuel assemblies or control rods. One of the corrective actions identified in the report was to review non-routine surveillance procedures for adequacy of the r surveillance in meeting Technical Specification requirements and for the effectiveness of the procedure's '

initiating mechanism. The reviewed procedures were determined to be adequate or action was taken to correct deficiencies. A concern was noted that some procedures list surveillances that must be performed prior to certain actions, and that these lists were not always complete. BGP 100-6 was given as an example. However, only non-routine surveillances were noted to be missing. IBV$ 9.9-1 was not discovered because it was classified as routine on GSRV, and was therefore not included as part of the investigation.

No adverse trend was identified as a result of this event. The present task force will be all encompassing in ensuring an appropriate tr6ching eschenism is 4n elace for all non-routine surveil!ances.

G. COMPONENT FAILURE DATA l This event did not involve component failure.

r (0521R/0065R)