ML20012C289

LER 90-003-00:on 900212,determined That Surveillance Procedures for Monthly Functional Testing of Drywell High Pressure Instrumentation Logic Channels Less than Adequate. Caused by Personnel Error.Procedures revised.W/900312 Ltr

ML20012C289
Person / Time
Site:	Hatch
Issue date:	03/12/1990
From:	Hairston W, Tipps S GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HL-1001, LER-90-003, LER-90-3, NUDOCS 9003200450
Download: ML20012C289 (7)

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- 000318 March 12, 1990' U.S. Nuclea Regulatory Commission

' ATTN:: Document Control Desk'

, Washington, 0.C. 20555-PLANT HATCH -~ UNIT 1

-NRC DOCKET 50-321

, OPERATING LICENSE DPR LICENSEE EVENT REPORT PERSONNEL ERROR RESULTS-IN MISSED TECHNICAL SPECIFICATIONS-SURVEILLANCE Gentlemen:

In accordance with the requirements of 10 CFR 50.73(a)(2)(i), G6orgia-Power- Company is ~ submitting the enclosed Licensee Event Report (LER)

-concerning a missed LTechnical Specifications surveillance. This event involves Plant Hatch - Unit 1 and Unit 2.

Sincerely, u ). J . l W

~W. G.'Hairston, III SWR /sjb Enclosure LER 50-321/1990-003 c:::(Sw next page.)

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U .S. Nuclear Regul. tory Commission '

-Marcli 12, 1990 .

Pago Two c: Georaia Power Company Mr. H. C. Nix, General . Manager - Nuclear Plant

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

U.S. Nuclear Requlatory Commission. Washinoton. D.C.

Mr. L. P. Crocker, Licensing Project Manager - Hatch U S. Nuclear Reaulatory Commission. Reaion 11 ,

Mr. S. D. Ebneter, Regional Administrator Mr. J. E. Henning,~ Senior Resident Inspector - Hatch -

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PLANT HATCH, UNIT 1 o i s I o I o I o 1312 Il 1lorl015 TITLt 44) -

• PERSONNEL ERROR RESULTS.IN MISSED TECHNICAL SPECIFICATIONS SURVEILLANCE SWikiT DAf t m l LIR NUMetR ($1 REPORT DAf t (M OTHER f ACILITIES INVOLVED M1 MONTH DAY Yit~~' l YEAR M*,'$* 4 [*f,N MONTH DAY YEAP ' acto h asauts DOCKti NUM94Rt31 P1 ant Hatch Unit 2 015 I o I o 1 o 13 1616

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= desteltilm E736alanitti soJ34en2ns, LICENSEE CONTACT P(an THIS LER (12l NAME TELEPHONE hum 98R ARL A CODE Steven B. Tions. Manaaer Nuclear Safety and Comoliance. Hatch 9 lil? 31617 I -171R 1511 COMPLif t ONE LINE FOR EACH COMPONENT F AILURE DESCRittO IN THt$ REPORT H3)

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CAUSE SY STE M COMPONENT g RfD PR i l ! I I l l l 1 i i l I !

i i I l l I I I I I I i l l I SUPPLEMENTAL REPORT EXPECTtD Hel MONTH DAY YEAR YtS lif vee. eenween f MPRCTtQ sV0Miss/ON DA Til NO l l l A88TLACT ILlanit to HOO apacen. Ie , aooronometeor tofven ennene noese treewntno I*nes) US>

On 2/12/90, at approximately 1030 CST, Unit 1 was in the Run mode at an approximate

power level of 2436 CMWT (approximately 100 percent of rated thermal power) and Unit 2 was in the Run mode at an approximate power level of 2436 CMWT (approximately 100 percent of rated thermal power). At that time, it was determined that surveillance procedures for performing monthly functional testing of the Drywell high pressure instrumentation logic channels were less than adequate resulting in a missed surveillance. The procedures did not require verification of relays 1/2A71-K5A, B, C, and D which provide a protective action signal to the Reactor Building Ventilation System (EIIS Code VA), the Standby Gas Treatment System (SBGT, EIIS Code BH), and the Primary Containment Isolation System (PCIS, EIIS Code JM) Group 2 valves.

When the potential problem with the surveillance procedures was identifTed earlier in the' day on 2/12/90 the relay operation was confirmed to be satisfactory by visual observation as a conservative action. Consequently, at approximately 1030 CST, when the surveillance procedures were confirmed as being deficient, the associated relays had already been proven operable and no limiting conditions for operation were

' entered.

The cause of the event is cognitive personnel error on the part of nonlicensed personnel. Specifically, during a major revision to the surveillance procedures, the procedure writer deleted the requirement for observation of the relay operation from the Unit 1 procedures and failed to include it in the Unit 2 procedures. Corrective actions include revising the surveillance procedures and counseling involved personnel.

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...- OCENSEE EVENT REPORT (LER) TEXT CONTINUATION -arraovto ous No iino im IXPIRE$: t/31/W _

PAClk)TY fsAM6 (1) . DOCKET NUMBth (3) LER NUMBER (6) PA05 (3)

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. PLANT AND SYSTEM IDENTIFICATION General Electric - Boiling Water Reactor -

F Energy-Industry Identification System codes are identified in the text as (EIIS Code XX).

SUMMARY

Cr EVENT On-2/12/90, at approximately 1030 CST, Unit 1 was in the Run mode at an approximate ,

power icvel; of 2436 CMWT (approximately 100 percent of rated thermal power) and Unit 2 was in the Run mode at an approximate power level of 2436 CfM (approximately 100 percent of rated thermal power). At that time, it was determined that surveillance ;

• procedures .for' performing monthly functional testing of the Drywell high pressure--

instrumentation logic channels were less than adequate resulting in a missed .;

surveillance'.- The procedures did not require verification of relays 1/2A71-K5A, B,

'C, and D which provide a protective action signal to the Reactor Building Ventilation-System (EIIS Code VA), the Standby Gas Treatment System (SBGT, EIIS Code BH), and the Primary Containment. Isolation System (PCIS, EIIS Code JM) Group 2

. valves.  :

. When the potential problem with the surveillance procedures =was. identified earlier

'in the day on 2/12/90 the-relay operation was confirmed to be satisfactory by visual observation as a conservative action. Consequently, at approximately 1030 CST, when the surveillance procedures were confirmed as being deficient, the associated relays had already- been proven' operable and no limiting conditions for operation were entered.

The'cause of the event is cognitive personnel error on the part of 'nonlicensed personnel. Specifically, during a major revision to the surveillance procedures,.

the procedure writer deleted the requirement for observation of the relay operation from the Unit 1 procedures and failed _to include it in the Unit-2 procedures.

Corrective ~. actions include revising the surveillance procedures and counseling involved personnel.

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l enc * .'assa u s. wucteangive. Tony conseneesicas i LICENSEE EVENT REPORT (LER) TEXT CSNTWuATION APeRovto ous no. : iso-oio4 ie * ,

IXPIRES: S/31/W FACILfTY 8e4488 (1) . DOCILE 1 NUndBER (M LER Nuh8 DER (6) PAOS 631 U "" -

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0l0 0l3 or 0 l5 DESCRIPTIOW 0F EVENT On 2/12/90, at approximately 1030 CST, nonlicensed plant personnel determined that the Unit 1 and Unit 2 surveillance procedures less than adequately implemented the monthly functional test surveillance requirements of Unit 1 Technical Specifications Table 4.21, item 3 and Unit 2 Technical Specifications Table 4.3.2-1, items 1.b and 2.b . Specific:lly, the relay in each of the four channel logic circuit paths providing.the input to the Reactor Building Ventilation System, PCIS, and SBGT System logic (i.e., relays 1/2A71-KSA, B, C, and D) was not required to be checked for proper actuation in the surveillance procedures although the testing performed did electrically challenge the subject relays. The channel functional testing for l- the Drywell High Pressure instrumentation is addressed in procedures l 57SV-SUV-007-1/2S, "ATTS Panel 1/2H11-P921 Channel Functional Test and Calibration,"

57SV-SUV-008-1/2S, "ATTS Panel 1/2H11-P922 Channel Functional Test and Calibration,"

57SV-SUV-009-1/2S, "ATTS Panel 1/2H11-P923 Channel Functional Test and Calibration,"

and 57SV-SUV-010-1/2S, "ATTS Panel 1/2H11-P924 Channel Functional Test and Calibration." This condition was discovered during an ongoing review of the plant's i

Licensing Comn e. ment Tracking Database. It is noted that the testing of the RPS portion of the channels was adequately addressed in the surveillance procedures.

l Upon confirmation of the procedure problem, Deficiency Cards were initiated and licensed personnel were notified. Earlier in the day, in conjunction with the -

L investigation into the adequacy of the procedures, the relays had been tested as a i

conservative measure to ensure their operability. The testing was accomplished by observing the operation.of the relays while performing the related portions of the l: channel functional test and calibration procedures. The testing was completed by 1010 CST and'all eight relays operated satisfactorily. Consequently, at l approximately 1030 CST, when the surveillance procedures were confirmed as being i . deficient, the relays had already been demonstrated operable and no limiting conditions for operation were entered.

i CAUSE OF EVENT l

The root cause of this event is cognitive personnel error. Specifically, a nonlicensed individual deleted testing of the relays from the Unit 1 procedures and failed to include testing of the relays in the Unit 2 procedures.

F Prior to December of 1985 the Unit 1 surveillance procedure addressed checking the operability of the relays. However, during a major revision of the procedure in December of 1985, a check of +he relays was deleted from the surveillance.

Approximately six months later, in June of 1986, the Unit 2' surveillance procedure went through a similar revision in wnich the same procedure writer failed to include testing of the four A71 relays in the procedures. Due to the date of the revisions, it is not conclusively knc,m why the writer deleted /omitted the check of these .

! rel ays.

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- This event is rez.ured per 10 CFR 50.73 (a)(2)(1)(B) because less than adequate surveillance procedures resulted in a portion of the logic associated with the Drywell High Pressure instrumentation channels (i.e., relays 1/2A71-K5A, B, C, and D) not being tested on a monthly basis as required by Unit 1 Technical Specifications Table 4.2-1, Item 3 and Unit 2 Technical Specifications Table 4.3.b1, Item 1.b and 2.b.

Relays 1/2A71-K5A, B,-C, and D provide actuation signals for a PCIS Group 2 valve ,

isolation, a Reactor Building Ventilation System isolation, and an SBGT system initiation in the event of a high Drywell pressure condition in the respective unit. A high Drywell pressure condition ( e 1.92 psig) is potentially indicative of a loss of Coolant Accident (LOCA). The purpose of the PCIS Group 2 valve isolation is to minimize the releases of radioactive material from Primary Containment (EIIS Code NH) in the unlikely event of an accident. Isolation of the Reactor Building Ventilation

-System and an SBGT System initiation are necessary in order to minimize ground level releases of any radioactive material in the event of an accident. SBGT also provides a filtered, elevated release path for radioactive material thereby minimizing total releases to the environment.

In this event, the subject relays were electrically challenged as part of the monthly.

. functional test, however, there was no procedural requirement to observe and document proper operation of the relays. Documented testing of the relays was performed every 18 months as part of Logic System Functional Test (LSFT) procedures 42SV-SUV-001-1/2S, "Drywell Sump / Isolation Valves & RHR Flush Discharge to Radwaste LSFT." A review of maintenance history records showed no past failures for these relays. Additionally, when the relays were tested on 2/12/90, they were found to function satisfactorily.

Consequently, it is reasonable to conclude that the relays would have fun tioned as designed in the unlikely event of a high Drywell pressure condition.

Based on.the above information, it is concluded that this event had no adverse impact on nuclear plant safety. This analysis applies to all operating conditions.

CORRECTIVE ACTIONS Procedures 57SV-SUV-007-1/2S, 57SV-SUV-008-1/2S, 57SV-SUV-009-1/2S, and 575V-SUV-010-1/25 have been temporarily revised to address testing of the A71 relays.

Permanent revisions will be made effective by April 30, 1990.

Involved personnel have been counseled as to the need for attention to detail.

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~ ADDITIONAL INFORMATI0th ,

No' systems other than the SBGT system, the Reactor Building Ventilation System, and PCIS Group 2 valves 'were affected by this event.

Previous'similar events in which-personnel errors led to deficiencies in procedures:

required by Technical Specifications were reported in the following LFRs*

50-321/1990-002, dated 03/02/90 50-366/1989-006,. dated 10/23/89

50-321/1989-009, dated 09/21/89 50-321/1989-005, dated 04/21/89 50-366/1989-002, dated 03/14/89 50-321/1988-019, dated 01/16/89 ,

Corrective actions resulting.from the previous similar events included counseling of involved-personnel, revisions to appropriate procedures, a review of plant procedures, a review of an. amendment involved in a previous similar event, and a review of selected .

surveillance procedures to ensure compliance with Technical Specifications. These 3 corrective actions would not have prevented this event since the procedures, amendment,  ;

and pr sonnel were unique to those events. 1 i

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