05000336/LER-1996-040-02, :on 961212,inadequate Surveillance Procedure for Verifying Motor Circuit Breaker Position Identified. Caused by Failure to Properly Incorporate TS Requirements. Surveillance Procedures Revised

:on 961212,inadequate Surveillance Procedure for Verifying Motor Circuit Breaker Position Identified. Caused by Failure to Properly Incorporate TS Requirements. Surveillance Procedures Revised

ML20133L849
Person / Time
Site:	Millstone
Issue date:	01/13/1997
From:	Laudenat R NORTHEAST NUCLEAR ENERGY CO.
To:
Shared Package
ML20133L744	List: 05000336/LER-1996-040, Forwards LER 96-040-00,documenting Event That Occurred at Mnps,Unit 2 on 961212.Commitment Made within Ltr,Listed 05000336/LER-1996-040-02, :on 961212,inadequate Surveillance Procedure for Verifying Motor Circuit Breaker Position Identified. Caused by Failure to Properly Incorporate TS Requirements. Surveillance Procedures Revised
References
LER-96-040-02, LER-96-40-2, NUDOCS 9701220153
Download: ML20133L849 (3)

LER-1996-040, on 961212,inadequate Surveillance Procedure for Verifying Motor Circuit Breaker Position Identified. Caused by Failure to Properly Incorporate TS Requirements. Surveillance Procedures Revised

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)(x) 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3361996040R02 - NRC Website

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4 NRC FOR6 lo6 U.s. NUCLEAR REGULATORY Commission APPROVED BY OMS NO. 315o-01o4 (4-95)

EXPIRES 04/30/98 i

EoE'*E 'c"oIao"ISI 'oU$*1'E"o'ESE LICENSEE EVENT REPORT (LER)

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Millstone Nuclear Power Station Unit 2 05000336 1OF3 TITLE 14) inadequate Surveillance Procedure for Verifying Motor Circuit Breaker Position in Accordance with Technical Specification Requirements 4.1.2.3.2,4.1.2.3.3, and 4.4.1.4 i

EVENT DATE (5)

I LER NUMBER (6) l REPORT DATE (7)

OTHER FACILITIES INVOLVED (8) 4 sEQU AL RE N

MONTH DAY YEAR YEAR MONTH DAY YEAR U

U R

12 12 96 96

-- 040 --

00 01 13 97 OPERATINo THIS REFORT IS SUBMITTED PURSUANT To THE REQUIREMENTS OF 1o CFR B: (Check one or more) (11) l MODE (9) 5 20.2201(b) 20.2203(a)(2)(v)

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

I POWER 20.2203(a)(1) 20.2203(a)(3)b)

So.73(a)(2)(ii) 50.73(a)(2)(x) 000 1

LEVEL (10) 20.22o3(a)(2)(i) 20.2203(a)(3)(ii)

So.73(a)(2)(iii) 73.71 l

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20.2203(a)(2)(ii) 20.2203(a)(4)

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

OTHER i

l 20.22o3(a)(2)(iii)

So.36(c)(1)

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

Specify in Abstract below 4

20.22o3(a)(2)(iv)

So.36(c)(2)

So.73(a)(2)(vii) i LICENSEE CONTACT FOR THIS LER (12) 4 NAME TELEPHONE NUMBER linclude Area Codel j

R. T. Laudenat, MP2 Nuclear Licensing Manager (860) 444-5248 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13) 0 [O

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CAUSE

SYSTEM COMPONENT MANUFACTURER

CAUSE

SYSTEM COMPONENT MANUFACTURER PRD j

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SUPPLEMENTAL REPORT EXPECTED (14)

EXPECTED MONm DAY YEAR YES SUBMISSloN (If yes, complete EXPECTED Submission DATE).

X No DATE (15)

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

On December 12,1996, it was identified that surveillarice procedure (SP) 2619A,

• Control Room Shift Checks,"

did not adequately satisfy the requirements of Technical Specification (TS) Surveillance Requirements 4.1.2.3.2,4.1.2.3.3, and 4.4.1.4 for verifying motor circuit breaker position. This discrepancy was identified during an investigation of a concern from a NRC inspection. SP 2619A was used to remotely verify within the Control Room the motor circuit breaker position. It was determined that remote verification was insufficient and that local verification was necessary in oroer to meet the surveillance requirements of the TS.

The cause of the event was failure to properly incorporate Technical Specification surveillance requirements into plant surveillance procedures.

Upon identification of this event plant surveillance procedures were revised to perform local verification of the motor circuit breakers positions. 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 P..sn.

9701220153 970113 PDR ADOCA 05000336 S

PDR NRC FORM 366 (4-95)

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NRC FORM 366 U.s. NUCLEAR REGULATORY COMMisslON (4 95)

UCENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DOCKET LER NUMBER 16)

PAGE (3)

SEQUENTIAL REvlSION YEAR NUMBER NUMBER 2 OF 3 Millstone Nuclear Power Station Unit 2 05000336 96 - - 040 - -

00 TEXT U1 more space is required. use additional copies of NRC Form 366A) (17) 1.

Description of Event

On December 12,1996, it was identified that surveillance procedure (SP) 2619A, " Control Room Shift Checks,"

did not adequately satisfy the requirements of Technical Specification (TS) Surveillance Requirements 4.1.2.3.2, 4.1.2.3.3 and 4.4.1.4 for verifying motor circuit breaker [52] position. This discrepancy was identified during an investigation of a concem from a NRC inspection. At the time of discovery of this event, the unit was in Mode 5 at 0 percent power.

The surveillance requirements state the following:

TS 4.1.2.3.2 requires that for Modes 5 and 6, all charging pumps [CB) not intended to be capable of injecting shall be demonstrated inoperable at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the motor circuit breakers are in the open position.

TS 4.1.2.3.3 requires that for Modes 5 and 6, all High Pressure Safety injection (HPSI) [BQ] pumps not intended to be capable of injecting shall be demonstrated inoperable at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by either verifyhg that the motor circuit breakers have been disconnected from their power supply circuits, or by shutting and tagging the discharge valve with the key lock on the control panel.

TS 4.4.1.4 requires that for Mode 5, two Reactor Coolant Pumps (RCPs) [AB] shall be demonstrated inoperable at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the motor circuit breakers have been disconnected from their electrical power supply circuits.

Surveillance Procedure SP 2619A, was used to remotely verify within the Control Room the associated motor circuit breaker position of the pumps by utilizing a combination of control board extinguished indicating lights and an administrative control. The administrative control encompassed the installation of a Shift Manager red tag (controlled by procedure WC-2, " Tagging") on the control board switches to verify the breaker is racked down (disconnected from its power supply circuits) for the RCPs and HPSI pumps, or in the open position for the charging pumps. It was determined that rem % verification was insufficient and that local verification was necessary in order to meet the surveillance requirements in the TS.

Plant surveillance procedures were revised to require local verification of motor circuit breaker position to satisfy the TS requirements. These changes were implemented on December 12,1996.

Past performance of SP 2619A did not satisfy the surveillance requirements of Technical Specifications.

Therefore, this event is reportable under 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 the event was failure to properly incorporate Technical Specification surveillance requirements into plant surveillance procedures.

!!!. Analysis of Event Technical Specification Surveillance Requirements TS 4.1.2.3.2,4.1.2.3.3 and 4.4.1.4 are intended to ensure that a Reactor Coolant System (RCS) low temperature overpressurization (LTOP) event does not occur. The required periodic surveillar'ce of the motor circuit breaker position during Modes 5 and 6 ensures that there is no power supplied to the associated pumps, thereby preventing inadvertent pump starts.

NRC F 366 U.S. NUCLEAR REGULATORY COMMISslON (4 %

UCENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACluTY NAME (1)

DOCKET LER NUMBER ' 6)

PAGE (3)

SEQUENTIAL REVislON YEAR NUMBER NUMBER 3OF3 Millstone Nuclear Power Station Unit 2 05000336 96 - 040 -

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

Considering that the Technical Specifications surveillance requirements do not provide a specific method to determine acceptable verification of circuit breaker position, the use of local verification to satisfy the procedural acceptance criteria, as opposed to remote verification, is the correct method and provides additional confirmation that the surveillance requirements are satisfied.

Although compliance with the Technical Specification Surveillance requirements were not met prior to the identification of this event, the bases for the Technical Specification requirement were met by ensuring that administrative controls were in piace (tags on the control switches) and the control board light indication was verified. Therefore, this event is not safety significant.

IV. Corrective Action

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

1. Upon identification of this event, plant surveillance procedures were revised to perform local verification of the motor circuit breakers positions.

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. B16076-2.)

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 PM Electronics LER 96-025-00: Enclosure Building Filtration Actuation Signal / Auxiliary Exhaust Actuation Signal Interlock 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 LER 96-039-00: Failure to Perform Periodic Surveillance Testing for Containment Purge System Containment Isolation Valves in Accordance with Technical Specification 4.9.10 Energy Industry identification System (Ells) codes are identified in the text as [XX).