05000423/LER-1997-004, :on 970114,lack of Verbatim Compliance with TS Surveillance Requirements for Molded Case Circuit Breakers Occurred.Caused by Addl Lack of Verbatim Compliance. Corrected 18 Month Surveillances Will Be Performed

:on 970114,lack of Verbatim Compliance with TS Surveillance Requirements for Molded Case Circuit Breakers Occurred.Caused by Addl Lack of Verbatim Compliance. Corrected 18 Month Surveillances Will Be Performed

ML20134P778
Person / Time
Site:	Millstone
Issue date:	02/11/1997
From:	Peschel J NORTHEAST NUCLEAR ENERGY CO.
To:
Shared Package
ML20134P741	List: 05000423/LER-1997-004, :on 970114,lack of Verbatim Compliance with TS Surveillance Requirements for Molded Case Circuit Breakers Occurred.Caused by Addl Lack of Verbatim Compliance. Corrected 18 Month Surveillances Will Be Performed
References
LER-97-004, LER-97-4, NUDOCS 9702260115
Download: ML20134P778 (4)

LER-1997-004, on 970114,lack of Verbatim Compliance with TS Surveillance Requirements for Molded Case Circuit Breakers Occurred.Caused by Addl Lack of Verbatim Compliance. Corrected 18 Month Surveillances Will Be Performed

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)
4231997004R00 - NRC Website

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l NRC FORM 366 U.S. NUCLEAR REGULATORY COMMisslON APPROVED BY oms NO. 3160-0104 M-95)

EXPIRES 04/30/98 NOETION E C'T" UE'ST? SO CO EPO TED L'^c""'?o^",',0l'LW "^Pc Ke l'oaSW."*.f!!a'a ^l$4 i

LICENSEE EVENT REPORT (LER) l'"^.a Tuc5?*"^la.'TW'8JJ,s"s's' '#'st,,"!^ot."e

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(See reverse for required number of digits / characters for each block) 4 FACluTY NAME (1)

DOCKET NUMsER (2)

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

Lack of Verbatim Compliance with Technical Specification Surveillance Requirements for Molded Case Circuit Breakers EVENT DATE (5)

LER NUMBER (6)

REPORT DATE (7)

OTHER FACILITIES INv0LVED (8)

MONTH DAY YEAR YEAR SEQUENTIAL REvlslON MONTH DAY YEAR FAclWTY NAME DOCKET NUM8ER

]

NUMBER l

i 01 14 97 97 004 00 02 11 97 OPERATING THIS REPORT IS SUBM!TTED PURSUANT TO THE REQUIREMENTS OF 10 CFR B: (Check one or more) (11)

MODE (9) 6 20.2201(b) 20.2203(a)(2)(v)

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

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

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

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

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

LEVEL (10) 000 20.2203(a)(2)(i) 20.2203(a)(3)(ii) 50.73(a)(2)(iii) 73.71 1

20.2203(a)(2)(ii) 20.22o3(a)(4)

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

OTHER j

z 20.2203(a)(2)(iii) 50.36(c)(1) 50.73(a)(2)(v)

Specify in Abstract below 20.22o3(a)(2)(iv)

So.36(c)(2)

So.73(a)(2)(vii)

LICENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER (include Area Codel J.M. Peschel, MP3 Nuclear Licensing Manager (860)437-5840 i

COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13) l

CAUSE

SYSTEM COMPONENT MANUFACTURER REPORTABLE

CAUSE

SYSTEM COMPONENT MANUFACTURER ltEPOLDI F TO NPRDS TO NPRDS m

l 1

?

1 SUPPLEMENTAL REPORT EXPECTED (14)

EXPECTED MONTH DAY YEAR j

SUBMISSION j

f YES NO 4

(If yes, complete EXPECTED sUBMISslON DATE).

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

On January 14,1997, with the plant in Mode 5, it was identified that the performance of 480 volt molded case circuit breaker (MCCB) surveillance testing was being performed in a manner not in verbatim compliance with a

the Technical Specifications (TS). These conditions were determined to be reportable pursuant to i

10CFR50.73(a)(2)(i), as an event or condition prohibited by the Technical Specifications.

This event is significant in that, by not performing expanded population testing for MCCB failures, it createa the condition wherein the reliability of the remaining untested population of the type of MCCB which failed was not ensured. This, in turn, could have resulted in a loss of safety function. This event is also significant as an cxample of a lack of verbatim compliance with TS requirements. These conditions were identified as the result of a heightened awareness of the potential for additionallack of verbatim TS compliance such as those d; scribed in previous Licensee Event Reports, LER 96-038-00, LER 96-048-00, and LER 97-001-00.

Corrective actions include a change to the affected surveillance testing procedure to ensure verbatim compliance with the TS and performance of the required testing.

9702260115 970211" PDR ADOCK 05000423 S

PDR

1 NRC 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 REVISION Millstone Nuclear Power Station Unit 3 05000423 NUMBER NUMBER 2 of 4 97 004 00 TEXT (if more space is required, use additional copies of NRC Form 366A) (17) 1.

Description of Event

On. January 14,1997, with the plant in Mode 5, it was identified that 480 voit Molded Case Circuit Breaker (MCCB) 18 month surveillance testing was being performed in a manner that was not in verbatim compliance with Technical Specifications (TS)4.8.4.1.a.2). This TS specifies that a representative sample of at least 10% of each type of lower voltage breakers be functionally tested. The TS requires single pole instantaneous testing, followed by 2-pole combination testing for any 480 volt MCCB/ unitized starter that fails the single pole testing.

Furthermore, TS requires the sample size to be increased by an additional 10% for each MCCB of a specific type found inoperable, until there are no further failures or the entire popuiation of that type breaker has been tested.

i Contrary to this, the initial sample size chosen for testing in each type of breaker was set at 50% of the population and any MCCB that failed its single pole instantaneous test was immediately discarded and replaced with a new, fully tested MCCB without performing the required 2-pole combination testing. In addition, the sample size was not increased because the large (50%) initial sample was believed to be sufficiently conservative to satisfy that requirement. The most recent surveillance records were reviewed and a single failure was found in the initial 50%

simple and, although the MCCB was replaced, no additional 10% expansion of the sample size was made.

Accordingly, previously performed surveillances were not acceptable, the MCCBs that failed the single pole instantaneous testing should have been tested with the two-pole combination test, declared inoperable, and, for cich failure in that type of MCCB, an ariditional 10% sample added to the test population. Because an operable MCCB was always installed, there was no operability issue for any failed MCCB. However, by not expanding the sample population following a failure (or failures), the reliability of the remaining untested population was not ensured. Since the s",ecmed TS activities were not performed, it was determined that this condition was r: portable pursuant b 10CFR50.73(a)(2)(i), as any operation or condition prohibited by the Technical Specifications.

11.

Cause of Event

The subject operation in a condit% punioited in the Technical Specifications (TS) was the result of a misconception that performing survenbnces ender conditions "more conservative than", or " meeting the intent of", a specific TS requirement was acceptabic 'or verbatim compliance. A causal factor in this lack of understanding was that management expectations and guidance regarding literal compliance with TS were neither clear nor adequately communicated throughout the organization.

Ill. Analysis of Event Since the MCCBs that failed a 1-pole, instantaneous test were immediately replaced with fully tested, operable MCCBs, there is no safety significance nor any operability issue involved with the failure to perform the 2-pole combination test. This event is significant in that, by not performing expanded population testing for MCCB failures, it created the condition wherein the reliability of the remaining untested population of the type of MCCB which failed was not ensured. This, in tum, could have resulted in a loss of safety function. This event is also significant as an example of a lack of verbatim compliance with TS requirements identified due to a heightened awareness of the potential for this shortcoming as described in previous Licensee Event Reports, LER 96-038-00, LER 96-048-00, and LER 97-001-00.

~U.s. NUCLEAR RE2ULAToRY Commission LICENSEE EVENT REPORT (LER) l TEXT CONTINUATION l

FACILITY NAME (1)

DOCKET NUMBER (2)

LER NUMBER (6)

PAGE (3) l YEAR SEQUENTIAL REvlSION l

Millstone Nuclear Power Station Unit 3 05000423 NUMBER NUMBER 3 of 4 97 004 00 TEXT (11more space is required, use additional copies of NRC Form 366A) (11)

IV. Corrective Action

Th3 following corrective action will be taken:

As described previously in LER 96-038-00, LER 96-048-00, and LER 97-001-00, the Unit Director will provide o

the unit staff with his expectations on compliance with Technical Specifications by March 31,1997.

A revision will be made to the MCCB/ unitized starter surveillance testing procedure requirements to effect o

verbatim compliance with the TS by April 15,1997.

The corrected 18 month surveillances will be performed on required MCCBs prior to entry into Mode 4. This e

surveillance requirement does not apply in Mode 5.

V.

Additional Information

None

Similar Events

LER 96-038-00

" Violation of Technical Specifications Pertainina to Hiah Pressure Safety Iniection & Charaina System Pumos" l

At 1800 on October 10,1996, with the plant in Mode 5, plant personnel determined that the i

Technical Specification requirement for operability of High Pressure Safety injection (SlH) and i

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.

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" NRC FORhll 36YA U.S. NUCLEAR REGULATORY COMMISSION j

(445)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DOCKET NUMBER (2)

LER NUMBER (6)

PAGE 63)

YEAR SEQUENTIAL REVislON Millstone Nuclear Power Station Unit 3 05000423 NUMBER NUMBER 4 of 4 97 004 00 l

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

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 botn 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. dontributing 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 inoperable and the load shed surveillances were performed during shutdown prior to restoring the EDGs to operable status.

P LER 97-001-00

• Lack of Verbatim Comoliance with Technical Specifications Surveillance Reauirements for 125 Volt Batteries and Batterv Charaers" On January 4,1997, with the plant in Mode 5, it was determined that the performance of 125 volt battery surveillance testing was being performed in a manner that was not in verbatirn compliance with the Technical Specifications (TS). Similarly, on January 9,1997, with the plant in Mode 5, the performance of 125 volt battery charger surveillance testing was being performed in a manner that was not in verbatim compliance with the TS. These conditions were determined to be reportable pursuant to 10CFR50.73(a)(2)(i), as an event or condition prohibited by the Technical Specifications.

1 While the surveillance testing performed may have been more accurate or more conservative than the verbatim requirements of the specifications involved, this event is significant in that it identifies further examples of a lack of verbatim compliance with TS requirements. These conditions were identified as the result of a heightened awareness of the potential for additional lack of verbatim TS compliance's such as those described in previous Licensee Event Reports, LER 96-038-00, and LER 96-048-00.

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

1 Manufacturer Data Ells System Code (ED)

Comoonent ID (S)