05000254/LER-1996-019-01, :on 960904,main Steam Line Radiation Monitor Functional Test Was Not Performed within Frequency Established for TS When in Refueling Mode Due to Incomplete Documentation of TS Interpretation.Qcap 2300-11 Was Changed

:on 960904,main Steam Line Radiation Monitor Functional Test Was Not Performed within Frequency Established for TS When in Refueling Mode Due to Incomplete Documentation of TS Interpretation.Qcap 2300-11 Was Changed

ML20128N287
Person / Time
Site:	Quad Cities
Issue date:	10/04/1996
From:	Peterson C COMMONWEALTH EDISON CO.
To:
Shared Package
ML20128N205	List: 05000254/LER-1996-019, Forwards LER 96-019 IAW Requirements of 10CFR50.73(a)(2)(ii)(B) & Discusses Listed Commitments 05000254/LER-1996-019-01, :on 960904,main Steam Line Radiation Monitor Functional Test Was Not Performed within Frequency Established for TS When in Refueling Mode Due to Incomplete Documentation of TS Interpretation.Qcap 2300-11 Was Changed
References
LER-96-019-01, LER-96-19-1, NUDOCS 9610160340
Download: ML20128N287 (3)

LER-1996-019, on 960904,main Steam Line Radiation Monitor Functional Test Was Not Performed within Frequency Established for TS When in Refueling Mode Due to Incomplete Documentation of TS Interpretation.Qcap 2300-11 Was Changed

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(iv), System Actuation 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2) 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(x)
2541996019R01 - NRC Website

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LICENSEE EVENT REPC":T (LER)

Form R2v. 2.0 iscihty Ntase ('l)

Docket Number G)

Page (3)

Quad Cities Unit One 0l5l0l0l0l2l5l4 1 l of l 0 l 5 team Line Radiation Monitor functional test not performed within frequency es:ablished for Technical Specification when in Refheling mode due to incomplete docurnentation of a Technical Specification Interpretnion Event Date (5)

LER Number (6)

Report Date (7)

Other Facihties involved (8)

Month Day Year Year Sequential Revision Month Day Year Facihty Docket Numberts)

Nder Number Nann g

0l5l0l0l0l l

l 0l9 0l4 9l6 9l6 ol1l9 0l0 1l0 ol4 9

6 0l5lol0l0l l

l OPERATING THit REPORT IS SUBMJ TrED PUR$UANT TO THE REQU REN ENTS OF 10CFR MODE (9)

(Check one or more of the following) (11) 2 20.402(b) 20.405(c) 50.73(a)(2)(iv) 73.71(b)

POWLR 20.405(s)(1)O) 50.36(c)(1) 50.73(a)G)(v) 73.71(c)

LEVEL 20.405(a)(1)01) 50.36(c)(2) 50.73(a)(2)(vii)

Other (Specify (10) l l

8

- 20.405(a)(1)0ii)

T50.73(a)(2)0) 50.73(a)(2)(viii)(A) tn Abstract 20.405(a)(1)0v) 50.73(a)(2)Oi) 50.73(a)(2)(viii)(B) below and in 20.405(a)(1)(v) 50.73(a)(2)Oii) 50.73(a)(2)(x)

Text)

LICENSEE CON FACF FOR THIS LER (12)

NAME TELEPHONE NUMBER i

AREA CODE Ch:.rles Peterson, Regulatory Affairs Manager, ext. 3602 3

0l9 6l5l4l-l2l2l4l1 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

CAU5E SYSTEM COMPONENT MANUFAGURER REN RTABI.E CAU5E SY5 TEM COMFONENT MANUFACTURER RENRTABM TO NPRDS TO NPRDS I

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I SUP >LEh&NTAL REPORT EXPECTED t14)

Expected Month Day Year Submmeion lYES Of yee. complete EXPECTED SUBMIS$10N DATE) 70 Date (15) l l

l ABSTRACT (Luvut to 4400 speece, ts., appronunately fitteen omgie-space typewntien ames) (16)

ABSTRACT:

During a review by the station of Technical Specification Interpretations (TSI), as a result of a recent Zion Generating Station issue, it was determined that QCIS 1700-01,

" Weekly Main Steam Line Radiation Monitor [RT] Functional Test", had not been performed when required on several occasions dating back to a TSI (dated 10/05/92). The root cause of this event is the incomplete documentation of the 10/05/92 TSI.

The immediate corrective action was for Operations to verify QCIS 1700-01 was current for both Units.

On 09/23/96, Quad Cities Station implemented Amendment 171 to Docket number 50-254 and Amendment 167 to Docket number 50-265.

These Amendments put in place revised Technical Specifications (TS) which eliminated all TSIs, including the earlier referenced TSI. These new TSs provide clearer operability requirements as well as mode specific surveillance requirements. Also on 09/23/96, QCOS 0500-09, "Transitioning from No Mode (All Fuel Removed) to Mode 5", was implemented providing the Operations Department with the means to ensure all Technical Specification requirements including surveillances, are satisfied prior to transferring to the REFUEL Mode. A review was conducted of other similarly denoted surveillances listed on the TSI and no further problems were identified.

A change will be made to QCAP 2300-11, " Technical Specification Clarification Request," to require all future Clarification Requests be approved by the Plant Operations Review V(~TNittee.

(NTS# 254-180-96-01901)

LER254\\96\\019. WPF 9610160340 961004 PDR ADOCK 05000254 S

PDR

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LICENSEE EVENT REPORT (LER) TEXT COPrrINUATION Form Rev. 2.0 FACILTTY NAME (1)

DOLTJrr NUMBER (2)

LER NUMBER (6)

PAGE (3)

Year Sequential Revision v

Number Nusnber ities Unit one 0l5l0 0l0l2 5l4 9l6 0l1l9 0l0 2 lOFl 0 l 5 h

E., Industry " " "non System (EII5) M : are identifies in the text as MX)

PLANT AND SYSTEM IDENTIFICATION

General Electric - Boiling Water Reactor - 2511 MWt rated core thermal power.

1 EVENT IDENTIFICATION:

Unit: One Event Date: 09/04/96 Event Time: 2400 Reactor Mode:

2 Mode Name:

Startup Power Level:

8%

A.

- CONDITIONS PRIOR TO EVENT:

This report was initiated by Licensee Event Report LER254\\96-019.

Startup (2) - Mode switch in Startup/ Hot Standby position with average reactor coolant temperature at any temperature.

B.

DESCRIPTION OF EVENT

l On 09/04/3G, Unit One (U1) was in the STARTUP Mode operating at 8% of rated core i

thermal power.

During a review by the Station of Techr.ical Specification Interpretations (TSI) as a result of a recent Zion Generating Station issue, it was determined that QCIS 1700-01, " Weekly Main Steam Line Radiation Monitor (RT]

Functional Test", had not been performed when required during the Unit I refueling outage QlR14.

Further investigation from the time the TSI (dated 10/05/92) was approved to the presa:it uncovered the following missed TS surveillances.

On 10/05/92, a Technical Specification Interpretation (TSI) request titled

" Surveillance Requirements Not Applicable During Shutdown" was submitted for approval by the Instrument Maintenance (IM) Department. The TSI was to determine if instrumentation that is not required to be operable, because its associated systems or components were inoperable, could have its surveillances suspended during the period when it is not required to be operable.

The interpretation included surveillance QLIS 1700-0l* as not required during cold shutdown and refueling under a system heading " Reactor Protection System (RPS)[JC]/ Primary Containment' Isolation *" (PCI)[JM).

The asterisk denoted that the portions of QCIS 1700-01 which supported Primary Containment Isolation operability were not applicable during shutdown or refueling although a partial surveillance of QCIS 1700-01 would still be required for Reactor Protection System operability as long as there was fuel in the reactor vessel [RCT] and the reactor scram was reset.

The definition of the asterisk, however, was never documented in the TSI or associated supporting documentation. Technical Specification Table 4.1-1 requires a weekly functional test of the Main Steam Line Radiation Monitors (MSLRMs) in the REFUEL, STARTUP/ HOT STANDBY, and RUN Modes.

Since this TSI was appr N d, the following missed TS surveillances have occurred.

9 LER254\\96\\019. WPF I

FACILITY NAME (1)^

LICENSEE EVEPG REPORT (LER) TEXT COfGINUATION Form Rev. 2.o DOCAET NUMBER (2)

LER NUMBER (6)

PAGE (3)

Year Sequenu.!

R. vision Nun br Number

'ities Unit One 0l5l0 0l0l2 5l4 9l6 0l1l9 0l0 3 lOFl 0 l 5 tex 1 En.rsy inau.uy na.,niric.iion sy.i.m (Elis; coa

.r. ia.nuri. in ih. i.xi.. too 1.

From 11/15/92 until 12/16/92 during the QlR12 Refuel Outage, QCIS 1700-01 was not performed as required.

4 2.

From 11/02/93 to 11/24/93, during ths QlM09 Maintenance Outage, QCIS 1700-01 was not performed as required.

3.

From 12/14/93 to 12/30/93, during the QlF34 Forced Outage, QCIS 1700-01 was not performed as required.

j 4.

From 06/24/94 to 07/29/94, during the QlR13 Refuel Outage, QCIS 1700-01 was not performed as required.

5.

From 02/08/96 to 02/26/96, and from 04/19/96 to 04/30/96 during the QlR14 Refuel Outage, QCIS 1700-01 was not performed as required.

C.

APPARENT CAUSE OF EVENT:

The root cause of these events is the incomplete documentation of the 10/05/92 TSI (On Site Review 92-40). The TSI preparer did not document the meaning of the asterisk as it applied to the RPS and PCI functions. The asterisk was intended to denote that the positions of QCIS 1700-01 which supported Primary Containment 3

(V Isolation operability were not applicable during shutdown or refueling although a partial surveillance of QCIS 1700-01 would still be required for Reactor Protection System operability as long as there was fuel in the reactor vessel and the reactor scram was reset. The IM Department used the TSI as justification to suspend performance of QCIS 1700-01 during outages. This basis was documented on QAP 0500-S9 and QAP 2000-11 Attachment A each outage.

In all cases the surveillance was deferred to prior to startup.

These were approved by a Department Superviser, a System Engineer, and an Operating Engineer. None of these reviews uncovered the i

errors. For the Q1R12, QlR13, and QlR14 refuel outages, the surveillance was missed prior to core reload and for a period of time after reload.

For the QlM09 and QlF34 outages, the surveillance was suspended for the entire outage. Also, during the Q1R14 outage, the surveillance was erroneously suspended for 18 days prior to full core offload.

In all cases, however, the surveillance was completed prior to reactor startup.

A contributing factor to this event is the lack of a critical review of QAP 0500-S9 and QAP 2000-11, Attachment A.

During the approval process, each inadequate outage deferral could have been identified by the reviewers.

D.

SAFETY ANALYSIS OF EVENT:

i The function of the MSLRMs is to detect high radiation in the main steam line area and effect mitigating actions to limit possible releases' to the plant and ultimately, the environment. During the missed TS surveillances, the Main Steam Isolation Valves (MSIVs) were closed. Also, the. reactor was subcritical during all

. periods when QCIS 1700-01 was delinquent.

Therefore, the safety significance of Q

this event is minimal.

LER254\\%019. WPF

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LICENSFE EVEPrr REPORT (LER) TEXT CONTINUATION Form Rxv. 2.0 FACILTTY nam 4E (1)

DOLm NUMBER (2)

LER NUMBER (6)

PAGE (3)

Year Sequeenial Revision Number Number ities Unit One 0l5l0 0l0l2l5l4 9l6 0l1l9 0l0 4 lOFl 0 l 5 E.

,y r - a sy (Ens; m = 6ammis i. ei. i.m gxx3 imu l

l Had the MSLRMs been inoperable during a worst case design basis fuel handling accident (DBFHA), no increases to the consequences of the accident would occur.- The DBFHA utilizes the Reactor Building Ventilation and Fuel Pool Radiation Monitoring System to mitigate the consequences of thetaccident. The MSLRMs are not utilized in the Updated Final Safety Analysis (UFSAR) in this particular accident analysis.

In all of the incidents, the Main Steam Isolation Valves (MSIVs) were closed (and main steam line plugs installed during refueling outages only) to prevent filling the main steam lines during reactor flooding. These closed MSIVs prevent exposing reactor coolant to the MSLRM detectors.

l E.

CORRECTIVE ACTIONS

i Corrective Actions Completed-1.

Operations immediately verified QCIS 1700-01 was current for both Units.

l 2.

On 09/23/96, Quad Cities Station implemented Amendment 171 to Docket number 50-254 and Amendment 167 to Docket number 50-265. These Amendments put in place revised TSs and eliminated all TSIs, including the earlier referenced TSI. The new TSs provide clearer operability requirements and mode specific surveillance requirements.

Specifically, surveillances for the MSLRMs are required in Modes 1, 2, and 3 only.

Therefore, the ambiguity brought on by the TSI has been eliminated and surveillances will be performed based on clearly defined plant modes.

t 3.

On 09/23/96, QCOS 0500-09 was implemented providing the Operations Department with the means to ensure all TS requirements including surveillances, are satisfied prior to transferring to the REFUEL Mode.

4.

A review of compliance was conducted of other similarly denoted surveillances listed on the TSI. No violations were identified during the review.

Corrective Actions to be Completed 1.

A change will be made to QCAP 2300-11, " Technical Specification Clarification Request," to require all future Clarification Requests be approved by the Plant Operations Review Committee.

(NTS# 254-180-96-01901).

This item will be completed by December 1, 1996.

lO LER254\\96T019. WPF

i LICEN5EE EVENT REPORT (LER) TEXT CONTINUATION Form Rev. 2.0 iFACulTY NAME(1)

DOCKET NUMBER (2)

LER NUMBER (6)

PAGE (3)

Year Sequential Revision Number Number stics Unit One 0l5l0 0l0l2 5l4 9l6 0l1l9 ol0 5 lOFl 0 l 5 TEXT Energy Industry identi6ceuon System (EIIS) codes ero idenu6= in the text as LG)

F.

PREVIOUS EVENTS:

A search for LERs in the last 2 years involving missed TS surveillances revealed the following events:

1 11/07/94 LER 254/94-14, Fire system surveillance went past their critical due date without the systems being declared inoperable and compensatory actions put in place due to inadequate training and written 1

communication.

11/05/95 LER 254/95-06, The RPS EPA relays had nrt been tested prior to the mode switch being moved to Refuel due to an inadequate written communication.

The primary cause of these previous events was inadequate procedural guidance. In this event the appropriate data was available but not used.

G.

COMPONENT FAILURE DATA

i There were no component failures in this event.

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LER254\\%\\019. WPF