05000336/LER-1996-039-02, :on 961106,licensee Failed to Perform Periodic Surveillance Testing for Containment Purge Sys Containment Isolation Valves IAW TS 4.9.10.Caused by Inadequate Program design.SP-2605H Has Been Revised to Test Isolation Functio

:on 961106,licensee Failed to Perform Periodic Surveillance Testing for Containment Purge Sys Containment Isolation Valves IAW TS 4.9.10.Caused by Inadequate Program design.SP-2605H Has Been Revised to Test Isolation Function

ML20133E316
Person / Time
Site:	Millstone
Issue date:	01/08/1997
From:	Laudenat R NORTHEAST NUCLEAR ENERGY CO.
To:
Shared Package
ML20133E311	List: 05000336/LER-1996-039, Forwards LER 96-039-00 Which Documents Event That Occurred at Mnps,Unit 2 on 961106.Commitment Made within Ltr,Listed 05000336/LER-1996-039-02, :on 961106,licensee Failed to Perform Periodic Surveillance Testing for Containment Purge Sys Containment Isolation Valves IAW TS 4.9.10.Caused by Inadequate Program design.SP-2605H Has Been Revised to Test Isolation Functio
References
LER-96-039-02, LER-96-39-2, NUDOCS 9701130004
Download: ML20133E316 (3)

LER-1996-039, on 961106,licensee Failed to Perform Periodic Surveillance Testing for Containment Purge Sys Containment Isolation Valves IAW TS 4.9.10.Caused by Inadequate Program design.SP-2605H Has Been Revised to Test Isolation Function

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(viii) 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
3361996039R02 - NRC Website

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NRC FORM 366 U.S. HUCLEAR REGULATORY COMMisslON APPROTED BY oMB NO. 3150-0104 EXPlHEs 04/30/98 LICENSEE EVENT REPORT (LER)

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• FCCluTY NAME (1)

DOCKET NUMBER (2)

PAGE 13)

Millstone Nuclear Power Station Unit 2 05000336 1OF3 i

TITLE I41

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Failure to Perform Periodic Surveillance Testing for Containment Purge System Containment isolation Valves in I

Accordance with Technical Specification 4.9.10 EVENT DATE (5)

LER NUMBER (6)

REPORT DATE (7)

OTHER FACILITIES INVOLVED (8) sEQU AL R $ N MONTH DAY YEAR YEAR MONTH DAY YEAR U

N R

11 06 96 96

-- 039 --

00 01 08 97 OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF to CFR 5: (Check one or more) (11) b MODE (9) 20.2201(b) 20.22o3(a)(2)(v)

X 50.73(a)(2)(i) 50.73(a)(2)(viii)

POWER 20.2203(a)(1) 20.2203(a)(3)(i)

So.73(a)(2)(ii)

So.73(a)(2)(x)

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000 LEVEL (101 20.2203(a)(2)(i) 20.2203(a)(3)(ii) 50.73(a)(2)(iii) 73.71 20.2203(a)(2)(ii) 20.2203(a)(4)

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

OTHER 20.2203(a)(2)(iii)

So.36(c)(1)

So.73(a)(2)(v)

Sp c vgA rgt elow 20.2203(a)(2)(iv)

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

LICENSEE CONTACT FOR THIS LER (12)

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

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CAuSE

SYSTEM COMPONENT MANUFACTURER

CAUSE

SYSTEM COMPONENT MANUFACTURER PRD PR S l

SUPPLEMENTAL REPORT EXPECTED (14)

EXPECTED MONTH DAY YEAR YES SUBMISSION X NO DATE (15)

(if yes, Complete EXPECTED SUBMISslON DATE).

ABSTRACT (Umit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16) i On November 6,1996 during an Operations department review of Surveillance Procedure (SP) 2605H,

" Containment isolation Valve Operability Test - Shutdown," the adequacy of the testing for the containment purge system containment valve isolation function as required by Technical Specification Surveillance Requirement 4.9.10 was questioned. On December 10,1996 as a result of continuing investigation of this condition, it was determined j

that testing of the containment purge valve isolation function did not meet the requirements of Technical l

Specifications.

j i

The cause of this event was inadequate program design in that the test method prescribed failed to meet the Technical Specification requirements.

As a result of this event, SP-2605H has been revised to appropriately test the containment purge valve isolation function in accordance with Technical Specification 4.9.10. This procedure was satisfactorily performed on December 17,1996 prior to entering Mode 6. Additionally, Technical Specification surveillance procedures will be reviewed to ensure compliance with Technical Specification surveillance requirements as part of the Millstone Unit No. 2 Operational Readiness Plan.

9701130004 970108 PDR ADOCK 05000336 S

PDR NRC FORM 366 (4-95)

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.U.S. NUCLEAR REGULATORY COMMISSION [4-95)

O UCENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DOCKET LER NUMDER 16)

PAGE (3)

SEQUENTIAL REvlslON YEAR NUMBER NUMBER 2OF3 Millstone Nuclear Power Station Unit 2 05000336 96 - 039 00 TEXT (if more space is required, use additional copies of NRC Form 366A) (17) 1.

Description of Event

On November 6,1996 during an Operations department review of Surveillance Procedure (SP) 2605H,

" Containment Isolation Valve Operability Test - Shutdown," the adequacy of the testing for the containment purge system (VA) containment valve isolation function as required by Technical Specification Surveillance Requirement 4.9.10 was questioned. On December 10,1996 as a result of continuing investigation of this condition, it was determined that testing of the containment purge valve isolation function did not meet the requirements of Technical Specifications. At the time of discovery of this event, the unit was in Mode 5 at 0 percent power.

SP-2605H section 4.2 tested the closure function of the containment purge system containment isolation valves [ISV] by tripping one of the four bistables (RLY] in the isolation actuation circuitry and observing the closure of the containment purge system containment isolation valves. This testing did not include the circuitry from the containment radiation monitors [ MON] to the bistables nor did it include the other three bistables. This method did not satisfy the requirements of Technical Specification Surveillance Requirement 4.9.10.

Surveillance Requirement 4.9.10 requires the verification of containment purge valve isolation on a high radiation signal from each of the containment radiation monitoring instrumentation channels within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to the start of core alterations. Other surveillance procedures test the circuitry from the containment radiation monitors to all four bistables on a monthly basis; however, these do not ensure that the testing is performed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to the start of core alterations. Therefore, it is likely that this portion of the circuitry had not routinely been tested within the time frame required by the Technical Specifications.

SP-2605H has been revised to appropriately test the containment purge valve isolation function in accordance with Technical Specification 4.9.10. This procedure was satisfactorily performed on December 17,1996 prior to entering Mode 6.

The containment purge valves isolation function is required to be operable in Modes 5 and 6; otherwise, the containment purge system containment isolation valves must be kept closed. Past testing of the containment purge valve isolation function did not satisfy the requirements of Technical Specifications. Therefore, this event is reportable in accordance with 10 CFR 50.73(a)(2)(i)(B), any operation or condition prohibited by the plant's Technical Specifications.

II.

Cause of Event

The cause of this event was inadequate program design in that the test method prescribed failed to meet the Technical Specification requirements.

Ill. Analysis of Event The containment purge system is designed to provide a method of providing fresh air to the containment. During unit operation (Modes 1,2,3, and 4), the containment purge system containment isolation valves are closed and electrically deactivated. In Modes 5 and 6 (cold shutdown and refueling), the containment purge isolation valves will receive an automatic closure signalif the monitored containment radiation level reaches a preset level. Two redundant particulate and gaseous monitoring systems are used to continuously monitor the containment atmosphere. A high radiation signal from any one of the four monitored channels (2 gaseous and 2 particulate) will initiate a containment isolation actuation signal which will automatically close the containment purge system containment isolation valves.-

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i

.U.s. NUCLEAR REGULATORY CoMMisSloN (4 95)

UCENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DOCKET LER NUMBER 16)

PAGE (3)

SEQUENTIAL REVislON YEAR NUMBER NUMBER 3OF3 Millstone Nuclear Power Station Unit 2 05000336 96 - 039 -

00 TEXT (11more space is required, use additional copies of NRC Form 366A) (17)

Although complete testing of the containment purge valve isolation function was not performed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to the start of core alterations, the complete circuitry was tested on a monthly basis by other surveillance procedures. This testing would be adequate to ensure the proper operation of the isolation function. Therefore, 4

this condition is not considered to be safety significant.

IV. Corrective Action

4 j

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

1.

SP-2605H has been revised to appropriately test the containment purge valve isolation function in accordance with Technical Specification 4.9.10. This procedure was satisfactorily performed on December 17,1996 prior to entering Mode 6.

2.

Technical Specification surveillance procedures will be reviewed to ensure compliance with Technical Specification surveillance requirements as part of the Millstone Unit No. 2 Operational Readiness Plan.

The review will initially focus on Technical Specification surveillance procedures required for Mode 6 and defueled. Surveillance procedures required for subsequent mode changes will be reviewed prior to mode entry. (This commitment was previously sent to the NRC in the response to NOV 336/96-08-07, NNECO Commitment No. Bl6076-2.)

V.

Additional information

Previous LERs that involve deficient surveillance procedures include:

LER 96-023-00: Failure to Perform Technical Specifications Surveillances on Certain Containment Isolation Valves LER-96-024-00: Response Time Testing of RPS and ESAS Failed to include Response Time of SPEC 200 Electronics LER 96-025-00: Enclosure Building Filtration Actuation Signal / Auxiliary Exhaust Actuation SignalInterlock Not Tested Periodically LER 96-026-00: Incomplete Technical Specification Required Surveillance - Valve Lineups inside Containment LER 96-035-00: Failure to Perform Periodic Surveillance Testing for Interlock Function Associated with the Main Steam isolation System Function of the Engineered Safeguards Actuation System LER 96-037 00 Inadequate Surveillance Procedure for Verifying Average Water Temperature at the Unit 2 Intake Structure LER 96-038-00: Inadequate Surveillance Procedures Used to Verify Emergency Diesel Generator Operability i

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

1