ML20029A646

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LER 90-007-01:on 900612,main Steam Line Isolation Sys Declared Inoperable Due to Failure to Test Manual Initiation Handswitch.Caused by Deficiency in Procedure.Procedures reviewed.W/910219 Ltr
ML20029A646
Person / Time
Site: Byron Constellation icon.png
Issue date: 02/20/1991
From: Langan J, Pleniewicz R
COMMONWEALTH EDISON CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
91-0061, 91-61, LER-90-007-01, LER-90-7-1, NUDOCS 9102280124
Download: ML20029A646 (6)


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(3 Crmm:nw:alth Edison

\ Pyron Nucicar Station

{ _ f 4450 Notth Gerrt.an Church Pond Dyron, Ilkno:5 61010 rebtuar/ 19, 1991 Ltre DYRON 91-0061 U. S. Nuclear Regulat.ory Commission Document Control Desk Wanhington, D.C. 205b5 Dear Sir The enclosed cupplemental Licennee Event Report from Dyron Generating Station is being transmitted to you in accordance with tha requirements of 10CrR$0.73(n)(2)(1)D.

This report is number 90-007; Docket No. 50-454.

Sincerely,

[b[ ,/ 4M +

R. Plenlewicz (

Station Manager'~

Dys on Nuclear Power Station RP/DK/mw Enclosures Licensee Event Report No.90-007 cci A. Dort Davis, NRC Region III Administrator W. Kropp, NRC Senior Resident inspector 1NPO Record Center CECO D!stribution List (0705R/0001R) 9102200124 910220 n, ;os nooce 050004s4 [Jt,

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_L1_LL L ABSTRACT (Limit to 1400 spaces, i.e. approximately fif teen single-space typewritten lines) (16)

On 06/12/90, during a review of the Byron Unit 1 Main Steam Isolation Valve (MS!V) full Stroke Test survelliances.

It was found that the! Steam Line Isolation handswitch on Main Control Board Panel 1pH06J had not been tested during the past refueling outages lfor both units. Technical Specification 3.3.2, Table 4.3-2 Item 4.a.2, requires testing of the Steam line Isolation handswitch on a refueling outage interval and requires that two trains be operable in Modes I, 2 and 3. At 1100 on 6-12-90, the M$1V manual isolation system was declared inoperable for both units.

Due to an unrelated problem Unit I was shutdown (Mode 4) on 06/13/90. Therefore. It was decided to perform the test on Unit I first, The handswitches were tested and the system was declared operable at 1545. On 06/13/90, at 2345. with Unit 2 operating in Mode 1, the unit entered Technical Specification 3.0.3 because both trains of manual isolation were inoperable during the test. On 06/14/90 at 000). the test was completed and Technical Specificatics 3.0.3 was enited. The system was declared operable at 0730.

As preventative action. Byron plans to have a review performed on all similar equipment to ensure that proper testing is being done. In addition, the Station will review related procedures and the procedure revier orocess.

There were no systems or components inoperable prior to the event which contributed to the event. No manual or automatic safety system actuations occurred. There have been no previous similar occurrences. This report is being submitted pursuant to 10 CFR 50.73 (a)(2)(l)B.

(0705R/0081R-2)

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A. ELMLCEfQll10!f$,fRIOR TO EvtRI:

fvent Date/ Time .06/12/90 /1100 Unit 1 MODE 1 - Rowir_fttrallpa Ru Power _.33L RCS (AD) Temperature / Pressure Jcmal_0perating_

Unit 2 H0DE 1 - EDEff_DstIA110A__ Rx Power _ E M RC$ ( AB) Temperature / Pressure _RogALDettating.

B. OLSCRIP119tLOLLYLMI:

In preparation for an upcoming review which was to be completed by a consultant, the Byron Technical $taff J was screening procedures that could potentially be defielent in testing parallel contacts. On 06-12-90.

during a review of the Dyron Unit 1 Main $ team Isolation Valve (H5!V) ($B) (!$V) Full $troke Test surveillance, IDV$ 7.1.$-1, it was found that the Steam Line Isolation handswitch (H5) on Hain Control Board Panel IPH06J had not been tested during the past refueling outage. The switch on IPH0$J had been tested as required. Technical Specification 3.3.2. Table 4.3-2 Item 4.a.2. requires testing of both steam Line Isolation handswitches on a refueling outage interval. Subsequent review revealed that the corresponding handswitch (2PH06J) en Unit 2 had also not been tested during its previous refueling outage.

Technical Specification 3.3.2. Table 3.3-3 Item 4.a.2, requires both Manual Initiation $ystems for the

$ team Line Isolation function to be operable in Modes 1 through 3. The Technical specificatter.s require that an inoperable Manual Initiation System be restored to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or the unit must be in Hot $tandby within the following 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> and in Hot $hutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. At 1100 on 0-12-90. Unit I and Ur.it 2 Limiting Condition for Operation Action pequirement (LC0AR) procedures 1D05 3.2-la and 200$ 3.2-la were entered as required by the Technical Spectfications.

A review of applicable system electrical de'ewings indicated that the handswitches could be tested with the units on line. By placing the two local /rsmote switches for the H51V's at the Remote Shutdown Panel to the local position, the Steam Line Isolation switches could be actuated without causing the H$1V's to close.

However, with the system in local control, both trains of the system manual isolation are Inoperable at t'ie main control board. Having both trains of the system manual isolation is not permitted by C LC0AR of

$pecification 3.3.2. Table 3.3-3 Item 4.a.2. In addition, with both Local / Remote switches i he local position, the ability to isolate individual steam lines using the control switch on the Hain t, trol Board was lost. Individual Steam Line isolation is required by Technical Specification 3.3.2. Table 3.3-3 Item 4.a.1. . As a result, testing of the $ team Line Isolation handswitch with the plant in Modes 1, 2. or 3 wo"Id not be permitted within the Technical Specifiestion LC0ARs. It was realtred prior to the test that with both handswitches removed from service, the plant <ould be operating outside the limitations of the Technical Specifications and would have to enter $pec'.ticstion 2.0.3. This situation was discussed with the Senior Resident Inspector prior to perforcing the test.

(0705R/0001R-3)

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Prior to testing the switches on either unit, the procedure was erecutes on the Byron /Braidwood simulator to ersure no problems associated with the test would develop. Due to an unrelated problem, Unit I was shutdown (Mode 4) on 06/13/90. Therefore, it was decided to rerfore the t.st on Unit i first. Using

$pecial Procedure $PP 90-030 the operation of both Manual Initiation handswitches was tested by verifying contact continuity. Unit I was in Mode 4 during the test which precluded the need to enter Technical

$pecification 3.0.3. Performance of the procedure took approximately fifteen minutes. Following a $tation review of the completed procedure, the handswitch was declared operable anti the LC0AR for $pecification 3.3.2 was emited at 1545.

On 06/13/90, at 2345, with Unit 2 operating in Mode 1, toth Manual Initiation handswitches were tesW using $pecial Procedure $PP 90-039. During the test, the unit entered Technical $pecification 3.0.3 as Control of the M51V's was placed in the Locel Position at the Remote $hutdown P m l. un 06/14/90 at 0001 Technical $pecification 3.0.3 was enited as control of the M$1V's was returned to the Remote (Control Room) position. Following a review of the procedure by $tation personnel, the handswitch was dsclared operabie and at 0730 the LC0AR for $pecification 3.3.2 was exited.

There were no systems or components inoperable prior to the event which contributed to the event,. No manual or automatic safety system actuations occurred. All operator actions taken were correct.

This report is being submitted pursuant to 10 CFR $0.73 (a)(2)(1)0 for operation in a condition outside of Technical $pecifications.

C. CAU$LDLERilt Ibe root cause of the event was a deficiency in the procedure used to test the $ team Line Isolation handswitches. This deficiency was introduced during the revision process. The proc & dure required only that the M$1V's be actuated by switch PM0$J. This left the ability of switch PM06J to close the MSIV's unverified. In previous procedure revisions, both handswitches (PM06J and PM0$J) were attuated to initiate a close signal to test the response time of the valves. When the procedures were revised (10-18-88 for Unit 1, 2-13-89 for Unit 2), the steps to verify the operation of PM06J were omitted. Because of the omission, the PH06J train of the M5!t' Manual Init!ation System was inoperable since their last surveillances exoired in April 1990 for both units (the PM06J switch was last tested on 6-10-08 for unit I and 6-2-88 for Unit 2). The April 1990 date was calculated based on an eighteen month survelliance f requency plus the 3.25 interval extension allowed by $pecification 4.0.2.

D. $3rETY ANAL 1$l$:

Manual isolation of the M$1V's is not assumed in the accident analysis. The autoaatic attuation of the

$ team Line Isolation remained operable throughout the event. Therefore, this event had no impact on the )

ability of the plant to respond to an accident and did not endanger the health and safety of the public. ,

In addition, both Main Steam Line Isolation manual handswitches operated as espected when tested and would have, if fhey had been needed to operate. If the improperly tested $ team Line Isolation handswitch lPM06J) 1 had not operated, the remaining properly tested handswitch on the Main Control Board (PH0$J) rould have I been used to close the M5!V's if required. In addition, manual isolation capability is also prov(c;ed at the Remote $hutdown Panel (two switches each actuating two valves), and at the Main Control Board via individual valve control switches, (four switches each actuating one valve). In the worst case, a failure of PM06J would have resulted in a delay in manual isolation of the MSIV's of only a f w? seconds.

1 (0705R/0081R-4) 1

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All contacts used on both swltthes were tested to verify operability using the special procedures $pp

90-038 and $FP 90+039.

The Unit 1 and 2 procedures used to fui' stroke test the M5!V's, IBV$ 7.1.51 and 2BV5 7.1.5-1. have becn revised to include testing of both $ team Line Isolation $ witches. AIR di -225-90-15600 tracked completion of the procedure revisions and is now closed. >

Currently, the Station is having an independent review perf ormed by an outside vetdor to ensure all contatts on control switches and relays as required by technical $yecifications are being tested. This-action was initiated '0110 wing a similar event at another Commonwealth Edison nuclear station and is being trac 6ed by AIR 454-225 90-15400. In addition, the Station Technical Staff hos implemented a program to provide a peer review to enhance procedure technical quality. This action was tracked b) AIR-454-22b-90.Ib500 and is now closed.

The procedure review process continues to be investigated to determine if improvements can be made to ensure that errors made in the revision process are eliminated before procedures are approved. This action is being tracked by AIR 454-225-90-15300.

F. BLCURPlH0.IYLN11JLA!LLtLR10EAL1$11 There have been a number of occurrences where inadeouate procedures led to violations of the Techniul Specifications. However, nkne of tnvie deficiencies were introduced by errors in the revision process.

-tER 454 88-001: Essential $errice Water Makeup pump Inoperable Greater than 72 Hours Due to Erroneous (1ectricai Distribution Data.

~((R 454-00-008: Auxiliary feedwater $ystem Inoperable Oue to inadequate Calibration of the $uction Fressure $ witches.

lER 454-90-003: Late Technical Specification Entry Due to Improper Acceptance Criteria f ormat and

. inadequate Surveillance Review.

LER 455 48-011: Both Trains of Manual Phase A Containment 1s01stion Inoperable Due to inadequate Surveillance.

G. (QtLP9t!LN1._LALWRLDAIA:

Not Applicable.

(0705R/0081R,5)

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