05000336/LER-1996-035-02, :on 961009,failed to Perform Periodic Surveillance Testing for Interlock Function of Ms Isolation Sys Function of Esas.Caused by Inadequate Training. Surveillance Procedure Revised & I&C Personnel re-trained

:on 961009,failed to Perform Periodic Surveillance Testing for Interlock Function of Ms Isolation Sys Function of Esas.Caused by Inadequate Training. Surveillance Procedure Revised & I&C Personnel re-trained

ML20132B794
Person / Time
Site:	Millstone
Issue date:	12/09/1996
From:	Laudenat R NORTHEAST NUCLEAR ENERGY CO.
To:
Shared Package
ML20132B752	List: 05000336/LER-1996-035, Forwards LER 96-035-00,documenting Occurrence on 961009. Commitments Listed 05000336/LER-1996-035-02, :on 961009,failed to Perform Periodic Surveillance Testing for Interlock Function of Ms Isolation Sys Function of Esas.Caused by Inadequate Training. Surveillance Procedure Revised & I&C Personnel re-trained
References
LER-96-035-02, LER-96-35-2, NUDOCS 9612170394
Download: ML20132B794 (3)

LER-1996-035, on 961009,failed to Perform Periodic Surveillance Testing for Interlock Function of Ms Isolation Sys Function of Esas.Caused by Inadequate Training. Surveillance Procedure Revised & I&C Personnel re-trained

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(ii) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3361996035R02 - NRC Website

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NRC FORM 366 U.s. NUCLEAR REGULATORY COMMisslON APPROVED BY OMB NO. 3150-0104 M.95)

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digits / characters for each block)

FActuTY NAME (1)

DOCKET NUMBER (2)

PAGE (3)

Millstone Nuclear Power Station Unit 2 05000336 1 of 3 TITLE 14)

Failure to Perform Periodic Surveillance Testing for interlock Function Associated with the Main Steam isolation System Function of the Engineered Safeguards Actuation System EVENT DATE (5)

LER NUMBER (6)

REPORT DATE (7)

OTHER FACILITIES INVOLVED (8)

MONTH DAY YEAR YEAR SEQUENTIAL nEVislON MONTH DAY YEAR FAcluTY NAME DOCKET NUMBER NUMBER 10 09 96 96 035 00 12 09 96 OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR S: (Check one or more) (11)

MODE W 5

20.22o1(b) 20.2203(a)(2)(v)

X So.73(a)(2)(i)

So.73(a)(2)(viii)

POWER LEVEL (10) 000 20.2203(a)(1) 20.2203(a)(3)(i) 50.73(a)(2)(ii)

So.73(a)(2)(x) 20.2203(a)(2)(i) 20.2203(a)(3)(ii) 50.73(a)(2)(iii) 73.71 20.22o3(a)(2)(ii) 20.2203(a)(4)

So.73(a)(2)(iv)

OTHER i

20.22o3(a)(2)(iii)

So.36(c)(1)

So.73(a)(2)(v) spec y n A r t slow 20.2203(a)(2)(iv)

So.36(c)(2) 50.73(a)(2)(vii)

LICENSEE CONTACT FOR THIS LER (12)

NCME TELEPHONE NUMBER (loclude Area Codel R. T. Laudenat, MP2 Nuclear Licensing Manager (860) 444-5248 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13) i

CAUSE

SYSTEM COMPONENT MANUFACTURER REPORTABLE

CAUSE

SYSTEM COMPONENT MANUFACTUREP REPORTABLE j

TO NPRDS TO NPRDS i

c i

p SUPPLEMENTAL REPORT EXPECTED (14)

EXPECTED MONTH DAY YEAR I

SUBMISsloN f

YES No (if yes, complete EXPECTED submission DATE).

ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16)

On October 9,1996 during an Instrument & Controls (l&C) department revi3w of a procedure change to a surveillance procedure, it was identified that the procedure did not note all the bistables that trip during the performance of the functional test. On November 7,1996, an engineering evaluation determined that complete functional testing of the Engineered Safety Feature Actuation System logic for the steam generator (SG) low pressure signal was not being periodically performed as required by Technical Specification 3.3.2.1. The current testing did not verify an interlock trip function between the bistables on both SGs instrument channels.

The cause of this event was a lack of knowledge by the people involved in surveillance procedure development.

These people had not received adequate training on the design basis of this system.

As a result of this event, the surveillance procedure has been revised and testing of the interlock function has been successfully completed. A review is on-going which includes an assessment of Technical Specification surveillance requirements to address the concems identified in Generic Letter 96-01. Training will be provided to l&C and Operations Department surveillance procedure developme;nt personnel on the information produced by the Generic Letter 96-01 review. For the interim period, awareness briefings wi!I be held with l&C and Operations Department surveillance procedure writing personnel. The procedures that direct the process of writing and revising surveillance procedures will be revised to incorporate the process developed in response to Generic Letter 96-01, 9612170394 961209 PDR ADOCK 05000336 S

PDR

'U.s. NUCLEAR REGULATORY Commission

~

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DOCKET NUMBER (2)

LER NUMBER (6)

PAGE (3)

YEAR SEQUENTIAL REVISION Millstone Nuclear Power Station Unit 2 05000336 NUMBER NUMBER 2 of 3 96 035 00 TEXT (11more space is required, use additional copies of NRC Form 366A) (11) 1.

Description of Event

On October 9,1996 during an Instrument & Controls (l&C) department review of a procedure change to Surveillance Procedure (SP) 2402P, "SPEG 200 Safety Parameters Functional Test," it was identified that the procedure did not note all the bistables that trip during the performance of the functional test. An engineering evaluation was initiated to review the design and testing of the affected logic circuit. At the time of discovery of l

this event, the unit was in Mode G at 0 percent power.

On November 7,1996, an engineering evaluation determined that complete functional testing of the Engineered Safety Feature Actuation System (ESFAS) [JE] logic for the steam generator (SG) [SG] low pressure signal was not being periodically performed as required by Technical Specification 3.3.2.1. The current testing did not verify j

an interlock trip function between the bistables [RLY] on both SGs instrument channels. The interlock function i

provides a main steam isolation signal (MSIS) in both facilities of the ESFAS on a SG low pressure sensed on either SG. This interlocking trip is designed to provide signal redundancy in the MSIS/ESFAS logic to protect against a single failure to the actuation circuitry. This design function had not been recognized by the i

surveillance procedure writers in the past and, therefore, the requirement to test this feature had not been included in the appropriate surveillance procedure.

Technical Specification 3.3.2.1 provides the operability and testing requirements for the Engineered Safety

)

Feature Actuation System Instrumentation including the main steam line isolation function initiated by a SG PTssure - Low signal. Testing of this design function for the SG low pressure logic had not been performed in t'

past. - Therefore, this event is rep 3rtable in accordance with 10 CFR 50.73(a)(2)(i)(B), any operation or 1dition prohibited by the plant's Technical Specifications.

Testing of this interlock feature was completed satisfactorily on November 26,1996.

I!. Cause of Event The cause of this event was a lack of knowledge by the people involved in the surveillance procedure 4

development. These people had not received adequate training on the design basis of this system. The lack of knowledge as tc the des lgn basis of the interlock function resulted in an inadequate surveillance procedure that did not perform complete functional testing of the MSIS/ESFAS logic.

Ill. Analysis of Event The pressure in each SG is sensed by four pressure transmitters. A drop in pressure to 500 psia on any two out of the four sensor channels on either SG will actuate a MSIS. In order to protect against a single failure preventing an actuation signal, the ESFAS is wired as two redundant actuation facilities. The interlocking bistable feature provides the redundant logic signal processing for the MSIS.

The interiock function had not been previously tested as part of the periodic functional testing of the ESFAS.

Failure of this interlock to function could result in the failure to actuate all required MSI components on a low pressure sensed in one SG during certain postulated single failures. Testing of this interlock function has been successfully completed. This testing verified that the interlock function would have operated as designed.

Therefore, this event is not safety significant.

NiC FORM 366A U.S. NUCLEAR REIULATORY Commission 14-95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DOCKET NUMBER (2)

LER NUMBEN (6)

PAGE (3)

YEAR SEQUENTIAL REVISloN Millstone Nuclear Power Station Unit 2 05000336 NUMBER NUMBER 3 of 3 96 035 00 TEXT (11more space is required, use additional copies of NRC Form 366A) (17)

IV. Corrective Action

As a result of this event, the following corrective actions have been, or will be, performed.

1.

SP-2402P has been replaced with SP-2402PA, B, C, and D. These new surveillance procedures ensure that the interlock function associated with each SG low ;.ressure logic channel is tested as required by Technical Specifications.

2. The interlock function has been satisfactorily tested with the revised surveillance procedures.

3. A review is on-going which includes an assessment of Technical Specification surveillance requirements to address the concems identified in Generic Letter 96-01. This review will be completed by September 30,1997.

4.

Training will be provided to I&C and Operations Department s"rveillance procedure development personnel on the information produced by the Generic Letter WO1 review. This training will emphasize the process utilized to ensure complete testing of logic circuiu. required by Technical Specifications.

This trair.ing will be completed by September 30,1997. For the interim period, awareness briefings will be held with I&C and Operations Department surveillance procedure writing personnel by January 15, 1997.

5.

The procedures that direct the process of writing and revising surveillance prccedures will be revised to incorporate the process developed in response to Generic Letter 96-01. This will ensure that future surveillance procedure revisions will maintain compliance with logic testing requirements. This revision will be completed by September 30,1997.

V.

Additional Information

in response to Generic Letter 96-01,"Tes'ing of Safety-Related Logic Circuits," surveillance procedures are being reviewed to ensure that complete testing is being performed as required by the Technical Specifications. This review effort is currently in progress and is scheduled to include the MSIS logic identified in this event. However, the MSIS logic had not been reviewed at the time of this event. The discrepancy identified in this ev3nt would have been discovered during the review process for the MSIS logic. The review in response to Generic Letter 96-01 is continuing and will identify any additior.al discrepancies in the surveillance testing program.

Similar Events

LER 96-025: On April 1,1996, an engineering review performed in response to Generic Letter 96-01 issues identified that an interlock between the Enclosure Building Filtration Actuation System and the Auxiliary Exhaust Actuation System was not being periodically tested. The appropiiate surveillance procedure was revised and the interlocks for both trains were tested.

Energy Industry identification System (Ells) codes are identified in the text as [XX].

N..C FORM 366A (4-95)