05000423/LER-1997-001-01, :on 970104,discovered Lack of Verbatim Compliance W/Ts SRs for 125 Volt Batteries & Battery Chargers.Caused by Misconception That Performing Surveillances Was Acceptable.Revised Procedures

:on 970104,discovered Lack of Verbatim Compliance W/Ts SRs for 125 Volt Batteries & Battery Chargers.Caused by Misconception That Performing Surveillances Was Acceptable.Revised Procedures

ML20134E153
Person / Time
Site:	Millstone
Issue date:	02/03/1997
From:	Peschel J NORTHEAST NUCLEAR ENERGY CO.
To:
Shared Package
ML20134E141	List: 05000423/LER-1997-001, Submits Commitments Re LER 97-001-00,documenting Condition Determined at Plant on 970104 05000423/LER-1997-001-01, :on 970104,discovered Lack of Verbatim Compliance W/Ts SRs for 125 Volt Batteries & Battery Chargers.Caused by Misconception That Performing Surveillances Was Acceptable.Revised Procedures
References
LER-97-001-01, LER-97-1-1, NUDOCS 9702060045
Download: ML20134E153 (4)

LER-1997-001, on 970104,discovered Lack of Verbatim Compliance W/Ts SRs for 125 Volt Batteries & Battery Chargers.Caused by Misconception That Performing Surveillances Was Acceptable.Revised Procedures

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(i)
4231997001R01 - NRC Website

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F ACluTY NAME 14 DOCKET NUMBER A PAGE (3)

Millstone Nuclear Power Station Unit 3 05000423 1 of 4 i

TrTLE 14)

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Lack of Verbatim Compliance with Technical Specification Surveillance Requirements for 125 Volt Batteries and Battery Chargers EVENT DATE (5)

LER NUMBER (6)

REPORT DATE (7) oTHER FACILITIES INv0LvED (8)

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MONTH DAY YEAR YEAR sEQLf MTIAL REVISION MONTH DAY YEAR FAclWTY NAME DOCKET NUMBER NUMPlR 01 04 97 97 001 00 02 03 97 GPERATING THis REPORT is SUBMITTED PURSUANT TO THE REQUIREMENTS OF to CFR 5: (Check one or more) (11)

ODE m 5

2o.2201(b) 20.2203(aH2)(v)

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So.73(.)(2)(v,,i POWER 20.2203(a)(1) 20.2203(a)(3Hi)

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LEVEL (10) 000 20.2203(aH2Hi) 20.2203(aH3Hii) 50.73(a)(2)(iii) 73.71 aH aH )

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20.22o3(aH2)(iii) 50.36(c)(1)

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Specify m Abstract below

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20.2203(aH2Hiv)

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So.73(a)(2)(vii) j LICENSEE CONTACT FOR THIE LER (12)

J icME TEttewomE NuueER iinciuo. A,.. coa.i J.l?.. Peschel, MP3 Nuclear Licensing Manager (860)437-5840 COMPLETE ONE LINE FOR EACH COMPONENT INEJRE DESCRIBED IN THIS REPORT (13)

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SYSTEM COMPONENT MANUFACTURER REPORTABLE

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CAUSE

SYSTEM COMPONENT MANUFACTURER REPORTABLE TO NPRDS TO NPRDS 4

d' llW SUPPLEMENTAL REPORT EXPECTED (14)

EXPECTED MONTH DAY YEAR SUBMl3SION f NO YES (If yes, complete EXPECTED sVBMisslON DATE).

ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single e r seed typewritten hnes) (16)

On January 4,1997, with the plant in Mode 5, it was identified that 125 voit battery surveillance testing was being performed in a manner that was not in verbatim compliance with the Technical Specificatiens (TS).

Similarly, on January 9,1997, with the plant in Mode 5, it was identified that 125 volt battery charger surveillance j

tGsting was being performed in a manner that was not in verbatim compliance wi'h the TS. These conditions were rMtermined to be reportable pursuant to 10CFR50.73(a)(2)(i), as an event or condition prohibited by the Tecid ;al Specifications.

While the surveillance testing performed may have been more accurate or more conservative than the verbatim requirements of the s[acifications involved, this event is significant in that it identifies further examples i

of a lack of verbatim compliance with TS requirements. These conditions were identified as the result of a i

heightened awareness of the potential for additional lack of verbatim TS compliance such as those desNhed in previous Licensee Event Reports, LER 96-038-00, and LER 96-048-00.

Corrective actions included immediate revision and performance of the battery and batte6y charger surveillance testing procedure requirements to effect verbatim TS compliance with the TS. Additionally, a review of the affected TS will be conducted for poter.*ird wording changes to ensure clarity, followed by the development and submittal of any resultant amendrneni request.

9702060045 970203

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PDR ADOCK 05000423.

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. NRC FORM 366A U.s. NUCLEAR REGULATORY Commission (4-95)

UCENSEE 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 97 001 00 TEXT Uf more space is required, use additionalccpies of NRC Form 366A) til) 1.

Description of Event

On. January 4,1997, with the plant in Mode f vas identified that 125 volt battery surveillance testing was being performed in a manner that was not in verbatn ompliance with the Technical Specifications (TS) 4.8.2.1.b.3.

Accordingly, previously performed surveillances were not acceptable, the 125 volt batteries should have been declared inoperable and the appropriate Limiting Condition for Operation (LCO) should have been entered. Since th:se actions were not performed, it was determined that this condition was reportable pursuant to

)

10C7R50.73(a)(2)(i), as any operation oi condition prohibited by the Technical Specifications (TS).

Technical Specification c.8.2.1.b.3 requires that, to demonstrate operability of the 125 volt batteries every 92 days, the av: rage of six (6) connected battery cells' electrolyte temperatures be verified to be greater than 60 F. Obtaining the clectrolyte terrperatures of all (60) connected cells and averaging them was perceived as a more accurate and conservative validation of battery capabilities and, therefore, was believed to satisfy the TS testing requirement.

Similarly, on January 9,1997, with the plant in Mode 5, it was identified that 125 volt battery charger surveillance t: sting was being performed in a manner that was not in verbatim compliance with TS4.8.2.1.c.4. Accordingly, pr:viously performed surveillances were not acceptable, the 125 volt battery chargers should have been declared inoperable and the appropriate Limiting Cer.dition for Operation (LCO) should have been entered. Since these i

tctions were not perfon ied, it was determined that this condition was reportable pursuant to 10CFR50.73(a)(2)(i),

Es any operation or con 6 tion prohibited by the (TS).

i Technical Specification 4.8.2.1.c.4 requires that, to demonstrate operability of the 125 vde battery chargers every 18

)

months, the battery chargers each supply at least the current specified in TS Table 4.8-2b at 125 vde for at least 24 1

hours. The actual surveillance testing was performed such that the specified current flow was supplied for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, but at a higher voltage than the TS required 125 volts. The surveillance was performed at, or above, the TS minimum float (operating) voltage of 129 vdc. Since testing at a voltage higher than 125vde demonstrated gr:ater charger capability than the TS required, this testing was considered as conservatively within the TS r:quirement. Testing e

'bove, the TS minimum float voltage also eliminated making the battery bu, inoperable during the testing; this we. )nsidered an additional conservatism that enhanced compliance with the TS requirements.

II.

Cause of Event

Th3 operation in a condition prohibited in the Technical Specifications (TS) was the result of a misconception that performing surveillances under conditions "more conservative than", or " meeting the intent of", a specific TS requirement was acceptable for compliance. A causal factor in this lack of understanding was that management expectations and guidance regarding literal compliance withTS were neither clear nor adequately communicated throughout the organization.

Ill. Analysis of Event While the surveillance testing performed may 5ve been more accurate or more conservative than meeting the v rbatim requirements of the specifications ir v

- 17his event is significant in that it identifies examples of a lack of v:rbatim complhnce with TS requirements. Tt n conditions would not have resulted in a loss of safety function and did not involve operation outside the design basis of the plant. They were identified as the result of a heightened cwareness of the potential for additional lack of verbatim TS compliance such as those described in previous Licensec Event Reports, LER 56-038-00, and LER 96-048-00.

.U.s. NUCLEA3 REGULATORY Commission i

(4 95)

LICENSEE EVENT REPORT (LER)

T EXT CONTINUATION FACILITY NAME (1)

DOCKET NUMBER (2)

LER NUMBER (6)

PAGE (3)

YEAR SEQUENTIAL REVISION i

Millstone Nuclear Power Station Unit 3 05000423 NUMBER NUMBER 3 of 4 97 001 00 TEXT Uf more space is required, use additionalcopies of NRC Form 366A) t17) i r

IV. Corrective Action

The following corrective action was taken:

The battery and battery charger surveillance testing procedures were revised to effect verbatim compliance with the TS.

The plant entered the appropriate TS ACTION statements and performed the required verbatim testing to j

e demonstrate equipment operability.

The following corrective actions will be taken:

As described in LERs 96-038-00 and 96-048-00, the Unit Director will provide the unit staff with his expectations e

on compliance with Technical Specifications by March 31,1997, A review of the affected TS will be conducted for potential changes to ensure clarity by March 15,1997, e

Identification of any needed clanfication or enhancement of the subject TS will be followed by the submittal of an e

amendment request by September M,1997.

V.

Additional Information

None

Similar Events

LER 96-038-00

" Violation of Technical SpecificationsPeryinina to Hiah Pressure Safety Iniection & Charaina System Pumps" At 1800 on October 10,1996, with the plant in Mode 5, plant personnel determined that the Technical Specification r( quirement for operability of High 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 inoperable at the transition point from Mode 3 to Mode 4 at 350 degrees Fahrenheit. The Technical Specifications do not provide a temperature 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 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.

NRC FoRtJ 366A (4 95)

- NRC FORM 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)

YEAR SEQUENTIAL REVislON Millstone Nuclear Power Station Unit 3 05000423 NUMBER NUMBER 4 of 4 97 001 00 TEXT (!!more space is required, use additionalcopies of NRC Form 366A) til)

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 Pump While Shutdown" On December 2,1996, with the plant in Mode 5, it was determined that a portion of the Technical Specification surveillancewhich tests the load sherl function for both Emergency Diesel Generators i

(EDGs) had not been performed in accordance with Technical Specification Surveillance 4.8.1.1.2.g.6. This surveillancels required to be completed once per 18 months during shutdown.

Cortm / to this, the surveillanceswhich tested the load shed for both trains of Charging (CHS) systt2A ramps and re-energizationfeature 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 significanceof this event was minimalin that the mode in which the surveillanceswere performed had no physicalaffect oa the abili.o complete the surveillancesor the ability of the EDGs to perform their safety function. As mmediate corrective action, the EDGs were declared inoperable and the load shed surveillanceswere performed during shutdown prior to restoring the EDGs to operable status.

Manufacturer Data Ells System Code Not Applicable

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