ML20044D282

LER 93-007-00:on 930413,determined That Surveillance Test Procedure Re RHR Sys Inservice Pump B Test Not Accomplished by 930410.Caused by Lack of Oversight of Surveillance program.Past-due Notice proceduralized.W/930511 Ltr

ML20044D282
Person / Time
Site:	Wolf Creek
Issue date:	05/11/1993
From:	Maynard O, Moles K WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-93-007, LER-93-7, WO-93-0100, WO-93-100, NUDOCS 9305180425
Download: ML20044D282 (7)

Text

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W4pLF CREEK NUCLEAR OPERATING CORPORATION Otto L. Maynard Vice President Piant Operations May 11, 1993 WO 93-0100 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station F1-137 Washington, D. C. 20555

Subject:

Docket No. 50-482: Licensee Event Report 93-007-00 Gentlemen:

The attached Lice:'see Event Report (LER) is being submitted pursuant to 10 CFR 50.73 (a) (2) (1) (B) concerning a Technical Specification violation.

Very truly yours, O

[

Otto-L. Maynard Vice President Plant Operations OLM/jan cc: W. D. Johnson (NRC) , w/a J. L. Milhoan (HRC), w/a ,

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W. D. Beckley (NRC), w/a I t

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ABSTR ACT 4 ref te 7430 speces e e . ecero.< mere + 84reca s<ap e spece r.pewnreen uness 0 61 Or, April 13, 1993, at approximately 1715 CDT, it was determined that f surveillance test procedure STS EJ-100B, " Residual Heat Removal System )

Inservice Pump B Test," had not been accomplished by April 10, 1993. ]

This surveillance test is required to be performed on a quarterly basis per Technical Specification 4.0.5 to demonstrate operability of Residual Heat Removal Pump (RHR) "B". On April 14, 1993, at 0010 CDT, RHR Pump ,

"B" was declared operable following the successful performance of  !

surveillance test procedure STS EJ-100B.

The root cause of this event was a lack of oversight of the Surveillance j Program. After it was identified that STS EJ-100B had the potential for becoming late, an attempt to resolve the deficiencies was not performed in accordance with step 6.6.2.5.1.2 of Administrative Procedure ADM 02-300. Corrective actions include the proceduralization of the use of a Past Due Notification Sheet, which will be routed to the Control Room when a surveillance test procedure has not been completed at least two days prior to its late date. This will eliminate the use of verbal communications to relay information regarding surveillances becoming late and will place the Control Room in the information loop.

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0l0 0l2 Or 0l6 nn -. -- - ~>c w., m, PLANT CONDITIONS AT TIME OF DISCOVERY Mode 6, Refueling Reactor Coolant System Pressure - O pounds per square inch gauge Reactor Coolant System Temperature - less than 100 degrees Fahrenheit Reactor Coolant System Level - Approximately 15 inches below the Reactor Vessel Flange with the Reactor Head set and three studs tensioned l, i

BASIS FOR REPORTABILITY l l

On April 13, 1993, at approximately 1715 CDT, it was determined that i surveillance test procedure STS EJ-100B, " Residual Heat Removal System f Inservice Pump B Test," had not been accomplished by April 10, 1993. }

This surveillance test is required to be performed on a quarterly basis [

per Technical Specification 4.0.5 to demonstrate operability of Residual {

Heat Removal Pump (RHR) "B" [BP-P). The failure to perform surveillance  !

test procedure STS EJ-100B within the required time-frame is being i reported pursuant to 10 CFR 50.73 (a) (2) (i) (B) as a condition prohibited f by the plant's Technical Specifications. j i

DESCRIPTION OF EVENT t

Technical Specification 4.0.5 requires, in part, that inservice testing of ASME Code Class 1, 2, and 3 pumps and valves be performed in  !

accordance with Section XI of the ASME Boiler and Pressure vessel Code l and applicable Addenda. The Technical Specification further states that l each surveillance requirement must be performed within the specified ,

surveillance interval with a maximum allowable extension not to exceed '

25 percent of the stated surveillance interval. l In accordance with the requirements of Technical Specification 4.0.5, i surveillance test procedure STS EJ-100B, "Pesidual Heat Removal System j Inservice Pump B Test," had an assigned due date of March 18, 1993, at l 1510 CST, with a late date of April 10, 1993, at 1510 CDT. On March 13, 1993, RHR Pump "B" was declared inoperable in order to perform required non-pump related maintenance during the Sixth Refueling Outage. Since the pump was out-of-service, the performance of the surveillance test ,

procedure was not scheduled on the Control Room R1 Status Chart. The R1 l Status Chart is used by Control Room personnel to track required i surveillances that are performed on a monthly or longer frequency. ,

Surveillances which are scheduled for equipment that is out-of-service  !

were removed from the Control Room R1 Status Chart for this refueling outage to prevent confusion with surveillances that are required to be performed on operable equipment. l l

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010 013 016 Tl'KT 191 mn, noect M renumnf., us,00$toonet kMC Form 36fA sI(111 on April 6, 1993, during a routine review of the R1 schedule, which is maintained by the Surveillance Group, the Surveillance Coordinator noted that surveillance test procedure STS EJ-100B had the potential for not being accomplished by the required date. Step 6.6.2.5.1.2 of Administrative Procedure ADM 02-300, " Surveillance Testing," requires the Surveillance Group to routinely review the R1 schedule to identify any scheduled R1 surveillances which have the potential for being missed. It also requires an investigation to be performed to determine the status of any R1 surveillances meeting this criteria, and if the defi ciencies cannot be readily resolved it shall be brought to the ,

attention of Plant Management for resolution. Following discovery of the condition on April 6, 1993, the Surveillance Coordinator verbally discussed the potential for STS EJ-100B becoming late with Operations t Supervision. Also, on April 8, 1993, operations Supervision was verbally informed of the condition. The requirement for the performance ,

of the surveillance was placed on a maintenance work schedule following the discussion, but this schedule is not used by the Control Room for surveillance activities. However, Operations Management did not follow- '

up the concern with the Control Room because it was believed that the situation was being addressed by the Surveillance Group and the requirement to perform the surveillance test would be put on the Control ,

Room R1 Status Chart for completion. On April 8, 1993, RHR Pump "B" was returned to operable status following repairs to RHR Pump Room Cooler SGL10B [BP-CLR]. ,

on April 13, 1993, questions were raised by an Outage Management Representative concerning when surveillance test procedure STS EJ-100B would be accomplished. Following an investigation, the manual surveillanca testing tracking log, which is maintained by the Survei31ance Group, was consulted and it was determined that STS EJ-100B had not been acccmplished by April 10, 1993, as required by Technical  !

Specification 4.0.5. At 1715 CDT, the Shift Supervisor was notified of  ;

the necessity to perform surveillance test procedure STS EJ-100B. Upon being notified that the surveillance had been missed, the Shift Supervisor declared RHR Pump "B" inoperable and entered Technical Specification 3.9.8.2. Technical Specification 3.9.8.2 requires, in part, that with less than two independent residual heat removal loops operable while in Mode 6 with the water level above the top of the reactor vessel flange less than 23 feet, immediate corrective actions must be initiated to return the required RHR loop to operable status, or i establish greater than or equal to 23 feet of water above the reactor vessel flange, as soon as possible. At 1740 CDT, performance of surveillance test procedure STS EJ-100B was commenced to verify l operability of RHR Pump "B". On April 14, 1993, at 0010 CDT, RHR Pump "B" was declared operable following the successful performance of surveillance test procedure STS EJ-100B and Technical Specification 3.9.8.2 was exited.

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ROOT CAUSE The root cause of this event was a lack of oversight of the Surveillance Program. After it was identified that STS EJ-100B had the potential for beccming late, an attempt to resolve the deficiency was not performed in accordance with step 6.6.2.5.1.2 of Administrative Procedure ADM 02-300.

Operations Management was informed of the potential for STS EJ-100B to be late; however, believing that the Surveillance Group had control of the situation, Operations Management did not follow-up on this concern with the Control Room. The Surveillance Group did not follow-up with the Control Room to ensure that STS EJ-100B would be accomplished within the time requirements of Technical Specification 4.0.5.

CONTRIBUTING FACTORS ,

1. Failure to have surveillance test procedure STS EJ-100B on Control Room R1 Status Chart.

2. Use of multiple schedules for the accomplishment of tracking of surveillance test procedures.

3. Lack of adequate procedural guidance on the performance of investigation and follow-up required to correct deficiencies identified for potential late surveillances.

CORRECTIVE ACTIONS In response to this event and previous events involving late performances of surveillance test procedures, Administrative Procedure ADM 02-300 is being superseded by procedure ADM 01-300. The rewrite of  ;

the procedure is based on continued input from other plants and knowledge gained from late performances of surveillance test procedures in the past. This rewrite will proceduralize the use of a Past Due Notification Sheet, which will be routed to the Control Room when a surveillance test procedure has not been completed at least two days prior to its late date. This will eliminate the use of verbal communications to relay information regarding surveillances becoming late and will place the Control Room in the information loop. Procedure ADM 01-300 will be issued by June 30, 1993.

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T w w , , - . .,,- .nr.ac w w . , <,T, The use of multiple schedules to track surveillance test procedures is currently being evaluated to determine if the use of one schedule would be appropriate to eliminate confusion. If it is determined that the use i of one schedule is warranted based on the results of the evaluation, the use of one schedule will be implemented by December 6, 1993. l SAFETY ANALYSIS During the time that RHR Pump "B" was considered to be inoperable due to the failure to perform STS EJ-100B IApril 10, 1993, at 1510 to April 14, 1993, at 0010 CDT) the pump was fully functional. Also, the  ;

satisfactory completion of the surveillance test procedure on April 14, 1993 indicates that the pump would have performed its required safety function had it been needed. Therefore, the health and safety of the .

public and plant safety was assured during this condition.

f PREVIOUS SIMILAR OCCURRENCES Licensee Event Report (LER) 482/87-014-00 discusses an event in which '

the completion date was incorrectly entered into the Surveillance procedure scheduling program by nonlicensed operations personnel which resulted in the calculation of an incorrect due date for the next performance of the surveillance test procedure. Corrective actions for that event included the checking of the past due Surveillance Procedures Inquiry every week and building checks into the computer program to question the date entered if it is not within a specific range of the current date.

LER 482/90-004-00 discusses an event in which a scheduled surveillance '

test was not performed because of a scheduling error. The performance  ;

date of a surveillance was not entered in the computerized surveillance tracking system and consequently no new "due date" for the surveillance j was calculated. Corrective actions for that event included proceduralizing a requirement to check the Past Due Surveillance Inquiry Report on a weekly basis. The event discussed in this report was initially identified by a review of the Past Due Surveillance Inquiry Report. However, when the condition was identified, personnel relied on the control Room R1 Status Chart to indicate that the surveillance had been performed.

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010 Ol6 M 016 nrTur-.-. ,,- -C, .-.e LER 482/91-009-00 discusses an event in which a scheduled surveillance  ;

test was not performed prior to restoring a piece of equipment to operable status. That event was attributed to a lack of interface between the Equipment Out-of-Service Log and the Surveillance Testing

• Program. Corrective actions discussed in that event are not applicable ,

to this event.

f LER 482/91-011-01 discusses an event in which the control Room R1 Status Chart was improperly marked to indicate ccmpletion of a surveillance test after only a partial performance of the surveillance test had been ,

acecmplished. Corrective actions for that event included adding step '!

6.6.2.5.1.2 to procedure ADM 02-300, which as discussed previously, j requires an investigation to be performed to determine the status of any R1 surveillance which has the potential for being missed, and if the de fi ciencies cannot be readily resolved it shall be brought to the attention of Plant Management for resolution. The corrective actions

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discussed in this report, including the use of the Past Due Notification Sheet, will ensure that discrepancies identified by the Surveillance Group receive adequate resolution.

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