ML20028G955

LER 90-026-00:on 900828,surveillance Missed Due to Inadequate Procedural Requirements.Caused by Inadequate Manual Surveillance Scheduling Methods.Station Procedures revised.W/900927 Ltr

ML20028G955
Person / Time
Site:	Comanche Peak
Issue date:	09/27/1990
From:	William Cahill, Mcgee G TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-90-026, LER-90-26, TXX-90337, NUDOCS 9010040261
Download: ML20028G955 (8)

Text

_ . . . . . . . . . . . .

-a 3

=

=== '

I ~2 LNe#TXX-90337 F # 10200 905.4 Ref. # 100FR50.73 10CFA50.73(a)(2)(i)

MlELECTRIC wim. J.c.hiii.Jr. September 27, 1990 tmwn nar,na-U. S. Nuclear Regulatory Comicsion Attn: Document Control Desk Washington, D. C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION 2

DOCKET NO.50-44f OP..ATION PROHIBITED BY TECHNICAL SPECIFICATION '

LICENSEE EVENT REPORT 90 076-00 Gentlemen:

Enclosed is Licensee Event Report 90 026-00 for Comanche Peak Steam Electric Station Unit 1, " Missed Surveillance Due to Inadequate Procedural Requirements."

Sincerely, A

3 w- w-William :. Cahill, Jr.

JAA/daj Enclosure c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) 9010040261 900927 l' goa Anoen Oso g s pF onca _,, _, s , m . , e..... m., _

i

l Enclosure to TXX 90337 l

hWG 7 0HW l,te . U.S. NJraE A4 64GJLA10RY GOWWibbON 4pFRM'ED OWB NO. StE0104 l

i EXPIRES. A'3092 ESTRAA1ED BURDEN PER RE S.ONSE TO COMPLY WITH THit INFORMATON X3LLEr'10N REQJEST: MS HR$. FOAW AC COWWENTS REGARDING

' " * ' " ' " ' " ' ' ' ' '"' "E "'**"'""""'*'""

LICENSEE EVENT REPORT (LE9) BRANCH (P $3:1), U.S. NUCLE AR REOULATORY C0bWISSON. WASHINGTON 3C 20bM. AND TO THE PA.ERwoRK REDUCTON PROJECT (3150 0104)

PfICE CF MANAGEWENT AND BJDOET.wASHI43 TON.DC.3023.

Jack.q %%s, (2) P ps (31 I scany ,s.m. (1)

COMANCHE I)E AK - UNIT 1 0151010101414 l 5 1 I or 10i7 i,,. m MISSED SURVFIll ANCE DUE TO INADEOUATE PROCEDURAL REQUIREMENTS m..-~.,

a ... n., ,, m,...., ,,~, 3.. m e.,,.. e., v., v, T; .r.* t",n? u ,* o., v.- 'grg"a p5 $~01010 l I I Ol8 218 901 910 01216,* Ol0 Ol9 217 910 N/A 0151010101 I I tw.,,,, i s. . . .- - , ,,, ,<. w n mv.c. . .m a r .~, n n ,

"~,m 1 _ nmm nmm - wnum _ nnm Fo*. Pn 40$(syp)(1) 60 %c)O) _

60.73;.M2)(v) _ 73 71(c)

T 01910 -

• 0H4 "** - 8* - "*4S** * **"" * *"*

• T'S "ro '4m.>p u.e -A ne 73xim _

".'7x.'mkB no )mivocA> NHC lem 3n6A)

PO 4%.ip)(.v) 60.73i.)mM .73<.XF)(v4fHB) r a w ,,,,,,,.,

s, w.,,-

6,,0,i n..,.i tin,nese Conted F e, TN. L E R (t 2n 1 ephon. wrra.,

93,,,,

A u.

G.P.McGEE SUPEnVISOR COMPLIANCE 8 l 117 81917 l- l 51417 I 7 c .o u . E . C - ,. r.*, - 1,.. Re ns, c s, C.,...,. u.e,., g g; .

w C.- s,c Cow .,-e u.e,., a' T a

'gn, @F#

o' 4 * #

I I I l l 1 I I II I IIl ,

i l l l l l l wh+ i l l l l l l an Sur. msnial Repost E uvec,ed t14) E .p.cied W.a* D*Y Butes.ston O v.un , t. m.4 s . o,.i [D No l l l Ai . uu, ,o. im .P a... .. , .,,, ,, e. , w.> o.)

On June 15,1990, the Residual Heat Removal Pump 01 (RHRP 01) quarterly inservice test (IST) was satisfactorily performed. On July 2,1990, post test data review determined that RHRP-01 was in ALERT status due to low differential pressure, as defined by American Society of Mechanical Engineers Boiler and Pressure V( , 91 Code,Section XI. As a result, the test frequency for RHRP 01 was increased to once p, 46 days.

On July 25,1990, a Surveillance Work Order (SWO) was manually printed in accordance with the increased test frequency requirement. However, the test frequency for this activity had not been revised in the Managed Maintenance Computer Program Surveillance Activity Data Base. As a result, the actual due date and violation date was not reflected on the SWO On August 12,1990, the required surveillance exceeded the violation date. On August 14,1990, the required surveillance was performed satisfactorily. On August 28,1990, while compiling test data for several IST components, the missed surveillance was discovered.

The root cause was deteimined to be inadequate manual surveillance scheduling method.

Corrective actions include revisions to station procedures.

1 i

Enclosure to TXX 90337 Ns,c p Onw.3M,A . W.S. NAE AR HLGAA1084v LOWW4 SON gpPRDVED0ut NO.312010s CSTNATED SVRDEN PER RES T COMPEY wrTH 1 Hit NF0feuATON

'C 5*

LK:ENSEE EVENT REPORT (LER) 33g,1,"',y*,'; 1, "Jego",*,'*, C,',",'fo*,"

TEXT CONTINUATION '"'"*"**'"*""'**^'"'*""***""'*""'"-

30. Ions, AND TO THE PAPE RWORK REDJCTON PROJECT ($140104) 0FFCE OF WANA0EMENT AND BUDGET WASHINGTON.DC.30603.

1. nose, same 0; Down Neate (*3 LE(< Norme em Fap (33 R

Y ear Qjag,* Aq COMANCHE PEAK - UNIT 1 015101010l4I415 910 -

0l2l8 -

010 012 OF 017 w -. .. . . - NRa . m ., o r, is DESCRIPTION OF THE REPORTABLE EVENT A. REPORTABLE EVENT Cl ASSIFICATION Any operation or condition prohibited by the plant's Technical Specifications, e B. PLANT OPERATING CONDITIONS BEFORE THE EVENT l

j On August 12,1990, Comanche Peak Steam Electdc Station (CPSES) Unit 1 was in Mode 1, Power Operation, at approximuly 90 percent power.

C. STATUS OF STRUCTURES. SYSTEMS. OR COMPONENTS I THAT WERE INOPER ABLE AT THE START OF THE EVENT AtiD THAT CONTRIBUTED TO THE EVENT i l- Not aor;licable no structures, systems or components were inoperable at the start of the event that contributed to the event, i

l D. NARRATIVE

SUMMARY

OF THE EVENT. INCLUDING DATES AND )

APPROXIMATE TIMES ,

At 0556, on June 15,1990, a quarterly inservice test (IST) was performed on Residual Heat Removal Pump 01 (RHRP 01) (Ells:(P)(BP)). The operability criteria for RHRP 01 was satisfied as required by Technical Specification Surveillance .

Requirements 4.5.2, 4.5.3, and 4.0.5. l l

On July 2,1990, the IST Coordinator (contractor, non licensed) notified the Operations Survelilance Test (OST) Coordinator (contractor, non licensed) that based on review of test data from the June 15,1990 test, RHRP-01 was in ALERT status. ALERT status is a condition identified by the American Society of Mechanical Engineers Boiler and Pressure Vessel (ASME BPV) Code,Section XI, in which a measured pump parameter has exceeded a predetermined threshold value and is approaching an operability limit, in such a case, the Code requires that the  !

frequency of testing be doubled until the cause of the deviation is determined and l l

l

dnclosure to TXX 90337 NIGONW.366A . . NUCLE AR RLGJLA106W 00Mg3(4pN ADPPOWO OMO NO. 8W1M ESTIMATED SURDEN PER RE& T COW 8%Y WITH TNiB PFORWATON LICENSEE EVENT REPORT (LER) g3l'%,"j,y*,'; ,6 l"fegg'* g,'f&*,%

j TEXT CONTINUATION 'fgigf,3,",",'o ','id" (*gl@icQ"g i

&FCE Cr WANAGEWEt(T AND BJOQET. WASHINGTON.DC.80003.

fmsg Namee, armen wmtar m LE R Never sei Pape 63 r

% ear Qg,ai cp

, COMANCHE 015101010'41415 910 -

012l6 -

010 013 OF 017

- -. . -,,. _ PEAK - UNIT

., o 1

,.nu - mi r, the condition corrected. The cause fo/ ALERT status on RHRP-01 was low differential pressure. The IST Coordinator requested that the test frequency be increased from once per 92 days to once per 46 days until further co' ice. The due date for this test would be July 31,1990.  ;

On July 25,1530, the OST Coordinator manually printed a Surveillance Work Order (SWO) to perform the required RHRP 01 surveillance in accordance with the  !

increased test frequency requirement. A scheduled date of August 8,1990 was selected to colqcide with scheduled routine pump runs. However, the test frequency -

for this activity had not been revised in the Managed Maintenance Computer  :

Program (MMCP) Surveillance Activity Data Base, and as a result the act: ~ ' due  :

date (July 31,1990) and violation date (August 12,1990) were not reflecteu oil the SWO. The SWO assigned September 14,1990, as the due date, and October 6, 1990 as the violation date, which correspond to the normal quarterly due and i violation dates. Delaying the required surveillance from July 31,1990, to August 8, 1990 was acceptable based on Technical Specification 4.0.2 which allows a 25 percent grace period or 11.5 days.

On August 8,1990, the scheduled surveillance was not performed due to CPSES Unit 1 recovery and subsequent startup following a reactor trip. The control room -

staff was u.iaware of the actual violation date for the required surveillance. At 1756 on Augurc 12,1990, the required surveillance exceeded the violation date. At 1550, August i4,1990, the required surveillance was performed satisfactorily.

E. T.tiffiETHOD OF DISCOVERY OF EACH COMPONENT OR SYeTEM EML.'JRE OR PROCEDUR AL OR PERSONNEL ERROR On August 28 1990, while compiling test data for several IST components in ,

~

response to requests from Nuclear Regulatory Commission inspectors, the missed surveillan :e was discovered by the OST Coordinator. The missed surveillance was promptly documented via appropriate plant procedures.

_--w

- *-_ - _ -_ +_ _ - _ _ _ _ - _ _ _ - -r=

Enclosure to TXX-90337  :

M4C f 0RW.366A

• U.S. NJCLE AR REl S ATORY COWW$$ON A*PROWD DW8 080. 319401M E MPIRE3:4'tbW E STIMA 'l D $11RXN PER RESPONDE TO COMPLY WITH THl3 II#0RMATON LCENSEE EVENT REPORT (LER) ' jc*,'%, M *lf17"n**e/,g ,'" $ 7,'Jfgj",

, o 5

TEXT CONTINUATION ****"""'""""'"***'****"'*"'

3C. 20%%, AND TO THE PAPERWORK REDUCTON PROJECT (31640104) ,

3FFICE OF WANAGEWENT AND BJDGET,WASHauTON,DC.to!WIS. ,

f sever Name p) ;aussi hweer (gj LEFiNum e (to F ese gas

% ear QQ :i' i (**

COMANCHE PEAK UNIT 1 0151010101414l5 910 -

0l2l6 -

0Io OI4 OF 0l 7  ;

T..u. -. . . . .. . w - ., o n

11. COMPONENT OR SYSTEM FAILUREF e

A. FAILURE MODE, MECHANISM AND EFFECT OF EACH FAILED COMPONENT Not applicable - there were no component failures associated with this event.

B. CAUSE OF EACH COMPONENT OR SYSTEM FAILURE Not applicable there were no component failures associated with this event.

C. SYSTEMS OR SECONDARY FUN

• FAILURE OF COMPONENTS Wn d MULTIPLE FUNCTIONS Not applicable there were no component failures associated with this event.

D. FAILED COMPONENT INFORMATION Not applicable - there were no component failures associated with this event.

Ill. ANALYSIS OF THE EVENI i A. SAFETY SYSTEM RESPONSES THAT OCCURRED Not applicable - no safety system responses occurred as a result of this event.

l B. DUR ATION OF SAFETY SYSTEM TRAIN INOPERABILITY Not applicable - there were no safety systems which were rendered inoperable.

I

, , _ . , . -. . e,.,,y-- ,, ,.

j Enclosure to TXX 90337- '

hRC FORW an64 u 6. NJGLL A4 RL4JLA10RY COWWi&$CN APPROVED OWS NO. $1940104 EXMRF.9:4'3090 ESTNATED BUCEN PER RESPONSE TO COMPLV W'TH THS INFORWATON ,

LICENSEE EVENT REPORT (LER) g 'l,'j"," g' ','; ,**l ***g g g ,"*, W ,' f 1 *",j, l

• • ^*" N ' " " '""' ** " " " * * * * * * " ' * ' " -

TEXT CONTINUATION 3C, tom &. AC TO THE PAPERWORK REDUCTON PROJECT (31640104 3rFICE OF WANAGEMENT AW BJDGET. WASHINGTON. DC. 20601 7 aceny Name p) Ducer hemier (2) LE R Ne'w (63 rape i3 w e  ;

COMANCHE PEAK - UNIT 1 015101010141415 910 -

0l2l8 -

010 015 OF 017 1..u. .- . . .. - u % u .w, C. SAFETY CONSEQUENCES AND IMPLICATIONS OF THE EVENT I

The Residual Heat Removal (RHR)(Ells:(BP)) system is safety related bo 'n its I' normal function to remove decay heat during shutdown and in its post accident function to provide emergency core cooling. The RHR pumps, therefore, are surveillance tested to demonstrate that the minimum pump performance assumed in  !

various analyses is available. Technical Specification 4.5.2 and 4.5.3 require that this testing be performed quarterly. ASME BPV Code,Section XI (Technical Specification 4.0.5), further requires that for a pump determined to be approaching .

its minimum performance limit (i.e., entered ALERT status), the frequency of testing

, be increased to once per 46 days. The more frequent testing of pumps in ALERT status reducas the likelihood that the plant would operate in a condition in which a -

given pump was not meeting its minimum performance requirements. ,

In the case of RHRP-01, the SWO, while performed late, demonstrated that the pump exceeded its minimum performance requirements and therefore the plant remained l within analyzed limits.

Based on the above discussion, the event did not adversely affect the safe operation ,

of CPSES Unit 1 or the health and safety of the public.

IV. CAUSE OF THE EVENT t

ROOT CAUSE The manual surveillance scheduling method selected was less than adequate. The

• control room staff was not properly informed of the actual violation date or the due date for the subject late surveillance. Although manualinitiation of a SWO and forwarding of the -

SWO to the control room in a timely manner are certainly aspects of a successful manual scheduling method, the failure to manually enter the true surveill::,1ce due date and violation date on the SWO allowed the method to fall.

l

___._..-_______m_ ~ , _,

4 Enclosure t)TXX 90337 NRO FORW MA e U.S. NJCLE AR NEGAATORY COWW450N APPROWD NS M DN0104 CSTNATED BORDEN PER RES ET COWPLY WITH TH$ NFORMATON

"'C'*""""' ' * " * ' "**'*C""E""'"

LICENSEE EVENT REPORT (LER) BURDEN ESTlWATE TO THE RECORDS AND REPORTS WAtJAGEWENT TEXT CONTINUATION ""*"**"^""'*^^'"'****"*'*""*'*

% 3025, AND TO THE PAPERWORK REDUCTON PROJECT (1@0104)

JF CE OF WANAGEMENT AND BVOGET.W4tHINGTON. CC. 30603.

F weev Name (1) h Wnvase (2) LE h No"t* 16: Pap 43a i.- i te.- m em COMANCHE PEAK - UNIT 1 0l5101010l41415 910 -

Ol2l6 -

0IO OI6 OF 087 .

i..n. . . ~ . ~ . m - w .nia t V. CORRECILV1 ACTIONS A. CORRECTIVE ACTIONS TO PREVENT RECURRENCE ROOT CAUSE f

Inadequate manual surveillance scheduling method.

CORRECTIVE ACTION The Surveillanco Test Program procedure will be reviewed, and revised as required, [

to ensure that requirements for updating the frequency of surveillance activities, as  ;

conditions change, are incorporated, B. CORRECTIVE ACTION TAKEN ON GENERIC CONCERNS IDENTIFIED l AS A DIRECT RESULT OF THE EVENT L

GENERIC CONSIDER ATION The possibility exists that a similar problem could occur in the manual methods used by the other Surveillance Test Coordinators.

CORRECTIVE ACTION A memo addressing this concern will be distributed to the Surveillance Test Coordinators.

I 1

$nc$sure to TXX 90337 N8tC FOfW.30$A .. u,$. NJOLE AR MEGJLA10RT 00MW4 SON Appqogoogg Df3 91B0104 EKPIRE 8:4'3090

($TlWATED BUCE N PER RESPONSE TO COMPLY WITH TH4 INFORMATON

""'C"""'*"' '"""'"*'*"""'""'"'**  !

LICENSEE EVENT REPORT (LER) OURDEN ESTlWATE TO THE RECORDS AND REPORTS WANAGEWENT TEXT CONTINUATlON ****"""*""'"""""******'"- '

3C. 20hh6. AND TO THE PAPERWORK REDUCTION PROJEC1 iC4101) 3FFCE OF MANAGEWENT AND BUDGET, w ASHINGTON. DC.20603.

W %%e g) Lt R wne (ei Fogo (3; )

I soser Name (1)

• eY$? & $$ j

, o.n, COMANCHE 0151010l014l415 910 -

0l2l6 -

0IO Ol7 OF 017 I

-. . n.e. PEAKo -.- UNIT w.- m1 ow n a

VI. PREVIOUS SIMILAR EVENTS Although'here have been several previous everi s (LER 90 005, LER 90 010, LER 90-024) resulting from failure to perform Technical Fpecification surveillance activities, the root causes of those events were ur.related to the root chuse of this event. The corrective actions taken to resolve the root causes of".e previous events would not have prevented this event. Therefore, no previous sim'iar eveists have been reported pursuant to n 10CFR50.73.

Vo ADDITION AL INFORMATION t

The times listed in the report are approximate and Central Daylight Savings Time (CDT).

t 5

h l

i i

1

_ .