05000423/LER-1996-051-01, :on 961221,TS Requirements for Application of 25% Surveillance Interval Extension of SR 4.0.2 to LCO Action Statements Misinterpreted.Caused by Incorrect Application of TS 4.0.2.Practice Discontinued

:on 961221,TS Requirements for Application of 25% Surveillance Interval Extension of SR 4.0.2 to LCO Action Statements Misinterpreted.Caused by Incorrect Application of TS 4.0.2.Practice Discontinued

ML20133N389
Person / Time
Site:	Millstone
Issue date:	01/17/1997
From:	Peschel J NORTHEAST NUCLEAR ENERGY CO.
To:
Shared Package
ML20133N351	List: 05000423/LER-1996-051, Forwards LER 96-051-00 & Util Commitments in Response to Event 05000423/LER-1996-051-01, :on 961221,TS Requirements for Application of 25% Surveillance Interval Extension of SR 4.0.2 to LCO Action Statements Misinterpreted.Caused by Incorrect Application of TS 4.0.2.Practice Discontinued
References
LER-96-051-01, LER-96-51-1, NUDOCS 9701230270
Download: ML20133N389 (4)

LER-1996-051, on 961221,TS Requirements for Application of 25% Surveillance Interval Extension of SR 4.0.2 to LCO Action Statements Misinterpreted.Caused by Incorrect Application of TS 4.0.2.Practice Discontinued

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(ii) 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(i)
4231996051R01 - NRC Website

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i NRC FORM 366 U.s. NUCLEAR REGULATORY COMMISslON APPROVED BY OMB NO. 3160-01o4 4gg EXPtRES 04/30/98

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FAC:UTY NAME (1)

DoCEET NUMBER (2)

PAGE W Millstone Nuclear Power Station Unit 3 05000423 1 of 4 TITLE (4)

Misinterpretation Of Technical Specification Requirements: Application Of The 25 % Maximum Allowable Surveillance Interval Extension Of Surveillance Requirement 4.0.2 To LCO Action Statements EVENT DATE (6)

LER NUMBER (6)

REPORT DATE (7)

OTHER FACILITIES INv0LVED (8)

MONTH DAY YEAR YEAR SEQUENTIAL REVislON MONTH DAY YEAR FAciuTY NAME DOCKET NUMBER NUMBER

[""*"'

12 21 96 90 051 00 01 17 97 OPERATINo THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR 5: (Check one or more) (11)

MODE (9) 6 20.2201(b) 20.22o3(aH2)(v)

X so.73(=>(2)ii)

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

POWER 20.2203(a)(1) 20.22o3(aH3)(i) 50.73(a)(2)(ii) 50.73(a)(2)(x)

LEVEL (10) 000 20.2203(a)(2)(il 20.2203(aH3Hii) 50.73(a)(2Hiii) 73.71 20.22o3(aH2)(ii) 20.2203(aH4)

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

OTHER

~

20.22o3(a)(2)(iv)

So.36(c)(2)

So.73(aH2)(vii)

LICENSEE CcNTACT FoR THIS LER (12)

NAME TELEPHONE NUMBER (include Area Codel l

J.M. Peschel, MP3 Nuclear Licensing Manager (860)437-5840 COMPLETE ONE LINE FOR EACH COMFONENT FAILURE DESCRIBED IN THIS REPORT (13) l

CAUSE

SYSTEM COMPONE NT M ANUF ACTURE R REPORTABLE

CAUSE

SYSTEM COMPONENT MANUFACTURER REPORTABLE TO NPROS To NPRDS 1

SUPPLEMENTAL REPORT EXPECTED (14)

EXPECTED MONTH DAY YEAR SUBMISSION f NO YES

~~

(if yes, complete EXPECTED sVBMisslON DATE).

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

On December 16,1996, it was recognized that the 25 percent surveillance interval extension of Technical Specification (TS) 4.0.2 could have had been historically applied to the periodic activities directed under Technical Specification Limiting Condition for Operation (LCO) action statements. On December 21,1996, with thn plant in Mode 5, it was determined that the programmatic application of the 25 percent surveillance frequency extension was reportable pursuant to 10CFR50.73(a)(2)(i), as an event or condition prohibited by the Technical Specifications.

i This event is significant in that the duration between some performances of the individual activities directed by a particular LCO action statement could have been inappropriately increased. However, because the equipment did meet the requirement at the end of the extended interval, it would have been available and capable of performing its intended safety function. If the equipment had been found to be inoperable at the end of the extended time period, the condition would have been identified and the appropriate compensatory miasures taken or a plant shutdown initiated ts required.

M ;agement will reinforce its technical spocification interpretation expectations associated with action stateinents. A review will be performed of c(ion statements that may have used the TS 4.0.2 surveillance int:rval extension and the procedures / forms will be changed so there is a clear distinction between action statements and surveillances.

9701230270 970117' PDR ADOCK 05000423 s

PDR

NZC FORM 366A U.S. NUCLEAR REGULATORY CoMMISsloN (4 95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DOCKET NUMBER (2)

LER NUMBER (6)

PAGE (3)

YEAR SEQUENTIAL REVislON Millstone Nuclear Power Station Unit 3 05000423 NUMBER NUMBER 2 of 4 96 051 00 TEXT 11! mere space is required, use additional copies of NRC Form 366A) (17) 1.

Description of Event

On December 16,1996, it was recognized that the 25 percent surveillance interval extension of Technical Specification (TS) 4.0.2 could have been historically applied to the periodic activities directed under Technical Specification Limiting Condition for Operation (LCO) action statements.

Th3 investigation initially focused on application of the surveillance interval extension to Action Statement A of Technical Specification 3.8.4.1," Containment Penetration Conductor Overcurrent Protective Devices". This LCO cction statement requires verification of the applicable circuit breaker position (either tripped, or if inoperable, racked-out or removed) at least once per 7 days. Verification was accomplished using a weekly surveillance form. A r view of the Shift Manager's logs indicated that the LCO action statement was performed every 7 days, until the action statement was exited. Research of the historical records did not reveal any instances where the 25 percent m:ximum allowable surveillance time intarval extension had been applied. However, because the controlling document, the surveillance form, implied interval extension was permitted, the control room review process would

{

not detect this problem and this could have resulted in exceeding the LCO action statement time requirement.

On December 21,1996, with the plant in Mode 5, it was determined that the programmatic application of the 25 percent surveillance interval extension was reportable pursuant to 10CFR50.73(a)(2)(i), as an event or condition prohibited by the Technical Specifications.

On January 7,1997, an expanded investigation during the root cause analysis determined that a violation of an LCO action statement requirement had occurred as a result of applying the surveillance interval extension. Specifically, it was determined that the time interval associated with Technical Specification LCO 3.3.3.10, " Radioactive Gaseous Effluent Monitoring Instrumentation," Action Statement 36, which requires "that the f!ow rate.. [be) estimated at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />," had been historically exceeded on several occasions. On September 27,1996, the " Ventilation Vent Stack Normal Range Radiation Monitor" (HVR*RE108), and on October 10,1996, the "ESF Building Gaseous Radiation Monitor"(HVQ*RE49), had exceeded the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> requirement between samples being taken. The associated surveillance forms had incorrectly implied a 25 percent extension of the required time period in which to complete the verification was acceptable.

On January 12,1997, it was identified that Action Statement B of Technical Specification LCO 3.3.3.7.b, " Fire D:t:ction Instrumentation," bd 5een exceedeo on at least two occasions. This LCO requires that a fire watch patrol inspect the fire protection zone (s) containing inoperable instrument (s) "at least once per hour". The program had incorrectly allowed a 25 percent extension of the required time period in which to complete the fire watch inspections.

II.

Cause of Event

Management expectations were incorrect in applying the 25 percent maximum allowable surveillance time interval ext:nsion of Tt chnical Specification 4.0.2 to LCO action statements.

4 Ill. Analv6 of Event Technical Specification 4.0.2 defines a maximum allowable extension of 25 percent to the surveillance time interval.

Tcchnical Specification 4.0.2 does not apply to Section 3.0 Limiting Conditions for Operation and the associated S:ction 3.0 Action Statements. There is no corresponding Section 3.0 time interval extension specification. The understanding was that action statements could be treated like surveillances.

NRC F09M 366A (4-95)

.U.s. NUCLEAR REGULATORY CoMMisSloN (4 93)

UCENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DOCKET NUMBER (2)

LER NUM"ER (6)

PAGE (3)

YEAR SEQUENTIAL REVISloN Millstone Nuclear Power Station Unit 3 05000423 NUMBER NUMBER 3 of 4 96 051 00 TEXT (11more space is required, use additional copies of NRC Form 366A) i17)

This event is significant in that the duration between some performances of the individual activities directed by a particular LCO action statement could have been inappropriately increased. However, because the equipment did mrt the requirement at the end of the extended interval, it would have been available and capable of performing its int:nded safety function. If the equipment had been found to be inoperable at the eed of the extended time period, the condition would have been identified and the appropriate compensatory measures taken or a plant shutdown initiated as required.

IV. Corrective Action

Th3 following corrective action was taken:

1.

Upon recognition by the Shift Managers of the inappropriateness of applying the Technical Specification 4.0.2 surveillance interval extension to LCO action statements the practice was discontinued.

ThD following corrective actions will be taken:

1.

A document will be distributed to Operations Department personnel and a briefing will be provided to each shift to reinforce Operations Management expectations regarding compliance with LCO action statements by January 31,1997, 2.

As described in LERs 96-038-00 and 96-048-00, the Unit Director will provide the unit staff with his expectations on compliance with Technical Specifications by March 31,1997.

3.

A review will be performed of action statements that may have used the TS 4.0.2 surveillance interval extension and the procedures / forms will be changed to provide a clear distinction between action statements and surveillances by March 31,1997.

V.

Additional Information

None

Similar Events

LER 96-U04-00

" Auxiliary Feedwater isolation Valves Noncomoliance with Technical Specifications" On March 19,1996, with the plant in MODE 1 at 100 percent power, it was determined that there were several historical occasions when the plant had failed to enter the appropriate Technical Specification's (TS) limiting condition for operation (LCO) action statement when shutting the Turbine Driven Auxiliary Feedwater pump discharge valves, at less than 10 percent power. The cause of he historical TS noncompliance was a misinterpretation of the Technical Specifications.

The plant erroneously used a TS Surveillance Requirement to take exception to a TS LCO.

As action to prevent recurrence, this event was reviewed with station personnel to caution others on using TS Surveillance Requirements to alter Technical Specification LCOs.

N7.C FORM 366A (4-95)

NRC RM 366A U.S. NUCLEAR REGULATORY Commission (4 95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DOCKET NUMBER (2)

LER NUMBER (6)

PAGE (3)

T AR SEQUENTIAL REVISION Millstone Nuclear Power Station Unit 3 05000423 NUMBER NUM B_E R.

4 Of 4 96 051 00 TEXT (11more space is required, use additional copies of NRC Form 366A) 117) l LER 96-038-00

" Violation of Technical Specifications Pertainina to Hiah Pressure Safety Iniection & Charaina System Pumos" At 1800 on October 10,1996, with the plant in Mode 5, pit.nt personnel determined that the Technical Specification requirement for operability of Hig'a Pressure Safety injection (SlH) and Charging (CHS) system pumps had not historically been met during transitions between Modes 3 and 4. Technical Specifications 3.1.2.4,3.5.2 and 3.5.3 specify different combinations of SlH and CHS pumps that are required to be operable or inopereole at the transition point from Mode 3 to 1

Mode 4 at 350 degrees Fahrenheit. The Technical Specifications do not provide a temperature l

transition band for removing pumps from service or restoring them to operable status as the transition is made from Mode 3 to Mode 4 or Mode 4 to Mode 3. The plant had historically changed modes and placed the plant in the configuration required by the new mode after the 2

mode entry. These conditions occurred as a result of conducting operations to meet the intent of the Technical Specifications rather than ensuring compliance with the Technical Specifications.

The corrective actions associated with this LER have not been fully implemented at this time.

implementation of these actions will aid in preventing recurrences similar to those being reported.

LER 96-048-00

" Failure To Complete Technical Specification Reauired Testina Of CHS Pumo While Shutdown" On December 2,1996, with the plant in Mode 5, it was determined that a portion of the Technical Specification surveillance which tests the load shed function for both Emergency Diesel Generators (EDGs) had not been performed in accordance with Technical Specification Surveillance 4.8.1.1.2.g.6. This surveillance is required to be completed once per 18 months during shutdown. Contrary to this, the surveillances which tested the load shed for both trains of Charging (CHS) system pumps and re-energization feature for portions of the CHS system were performed during plant operation. The cause was determined to be a lack of verbatim compliance with the Technical Specifications. Contributing to this were ineffective corrective actions to identify " shutdown" surveillances, and incomplete updating of the Master Surveillance Test Control List (MSTCL) data base.

The safety significance of this event was minimal in that the mode in which the surveillances were performed had no physical affect on the ability to complete the surveillances or the ability of the EDGs to perform their safety function. As immediate corrective action, the EDGs were declared j

inoperable and the load shed surveillances were performed during shutdown prior to restoring the i

EDGs to operable status.

Manufacturer Data Ells System Code Not Applicable