05000423/LER-1997-018, :on 970208,determined Plant Operated in Conditions Prohibited by 3 Different Ts.Caused by Interpreting TS for Intent Rather than Compliance W/Spec.Ts &/Or Bases Will Be Revised

:on 970208,determined Plant Operated in Conditions Prohibited by 3 Different Ts.Caused by Interpreting TS for Intent Rather than Compliance W/Spec.Ts &/Or Bases Will Be Revised

ML20136F468
Person / Time
Site:	Millstone
Issue date:	03/07/1997
From:	Peschel J NORTHEAST NUCLEAR ENERGY CO.
To:
Shared Package
ML20136F445	List: 05000423/LER-1997-018, :on 970208,determined Plant Operated in Conditions Prohibited by 3 Different Ts.Caused by Interpreting TS for Intent Rather than Compliance W/Spec.Ts &/Or Bases Will Be Revised
References
LER-97-018, LER-97-18, NUDOCS 9703140117
Download: ML20136F468 (6)

LER-1997-018, on 970208,determined Plant Operated in Conditions Prohibited by 3 Different Ts.Caused by Interpreting TS for Intent Rather than Compliance W/Spec.Ts &/Or Bases Will Be Revised

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(viii) 10 CFR 50.73(a)(2)(ii) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(iv), System Actuation 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
4231997018R00 - NRC Website

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a NRC FORM 366 U.S. NUCLEAR REGULATORY CoMMisSloN APPROYED BY OMB NO. 3150-0104 (4-95)

EXP1RES 04/30/98 fN OWAT 7

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FAcaLITV NAME (1)

DOCKET NUMBER (2)

PAGE 13)

Millstone Nuclear Power Station Unit 3 05000423 1 of 6 TITLE (4)

Technical Specification Parameter Compliance EVENT DATE (5)

LER NUMBER (6)

REPORT DATE (7) oTHER FACILITIES INVOLVED (B)

MONTH DAY YEAR YEAR SEQUENTIAL REVISloN MONTH DAY YEAR FACIUTY NAME DOCKET NUMBER

'^' " **"'

02 08 97 97 018 00 03 07 97 OPERATING 5

THis REPORT is SUBMITTED PURSUANT To THE REQUIREMENTS oF 10 CFR 5: (Check one or more) (11)

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

X 50.73(a)(2iti) 50.73(a)(2)(viii)

POWER 000 20.2203(a)(1) 20.2203(a)(3)(i) 50.73(a)(2)(ii)

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

LEVEL (10) 20.2203(a)(2)(i) 20.2203(a)(3)(ii) 50.73(a)(2)(iii) 73.71 20.2203(a)(2)(ii) 20.22o3(a)(4) 50.73(a)(2)(iv) oTHER 20.22o3(a)(2)(iii) 50.36(c)(1) 50.73(a)(2)(v)

Specify in Abstract below 20.2203(a)(2)(iv) 50.36(cH2) 50.73(a)(2)(vii)

LICENSEE CONTACT FoR THis LER (12)

NAME TELEPHONE NUMBER (include Area Code)

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

CAUSE

SYSTEM COMPONENT MANUFACTURER REPORTABLE

CAUSE

SYSTEM COMPONENT MANUFACTURER REPORTABLE TO NPROS TO NPRDS SUPPLEMENTAL REPORT EXPECTED (14)

EXPECTED MONTH DAY YEAR YEs X No submission (If yes, complete EXPECTED Submission DATE).

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

On February 8,1997 with the plant in Mode 5 it was determined that the plant had operated in conditions prohibited by 3 different Technical Specifications (TS). Each of these TS specify parameters without specific ranges. Therefore, verbatim compliance with the specified parameters is not possible.

These conditions occurred as a result of interpreting the Technical Specifications for intent rather than conducting operations in strict compliance with the specification. These conditions were determined to be reportable pursuant to 10CFR50.73(a)(2)(i)(B) as any operation prohibited by the Technical Specifications.

Th3 non-compliances have no plant safety consequence. The Surveillances and Safety System Settings will be conducted in the same manner after revision of the Technical Specifications. These non-compliances were identified as the result of heightened awareness to the potential for lack of verbatim Technical Specification compliance. These non-compliances are significant as examples of a lack of compliance with TS requirements identified due to a heightened awareness resulting from previous Licensee Event Reports.

I Ths Technical Specifications and/or Bases will be revised.

I i

9703140117 970307

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J 1U.s. NUCLEAR REGULATORY Commission (4-95)

UCENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DOCKET NUMBER (2)

LER NUMBER (6)

PAGE (3) 4 YEAR SEQUENTIAL REVISloN Millstone Nuclear Power Station Unit 3 05000423 NUMBER NUMBER 2 of 6 l

97 018 00 TEXT Uf more space is required, use additionalcopies of NRC form 366A) (11) l.

Description of Event

I On February 8,1997, with the plant in Mode 5, it was determined that the plant had operated in conditions prohibited by i

3 different Technical Specifications (TS). Each of these TS specify parameters without specific ranges. Therefore, j

verbatim compliance with the specified parameters is not possible. The specific TS are:

I i

e 2.2-1 Table 2.2-1. The constants that are input to the OPAT and OTAT formulae are exact numbers. The TS I

indicates exact values which cannot be set on the circuit cards.

i Surveillance Reauirement 4.6.4.1 requires channel calibration of the Hydrogen Monitors with exact percentages of e

hydrogen. It is not possible to obtain exact gas mixtures.

Surveillance Reauirement 4.8.41.a 2 requires injection current testing of breakers to verify the circuit breaker e

i operates within the time delay bandwidth. The values specified are 300% and 150% of the pickup current of the long-time and short-time delay trip elements. It is not possible to inject exact currents.

q I

f As the above requirements can not be complied with, it was determined that this condition was reportable pursuant to j

10CFR50.73(a)(2)(i)(B) as any operation prohibited by the Technical Specifications.

II.

Cause of Event

u These conditions occurred as a result of interpreting the Technical Specifications for intent rather than conducting operations in strict compliance with the specification. Historically, the plant has conducted operations to meet the intent of the Technical Specifications rather than submitting a TS change to the NRC for review, approval and transmittal which would then allow strict compliance with the specification. The Technical Specification inconsistencies noted above have not previously been identified as specifications that could not be complied with l

l Ill. Analysis of Event The above non-compliances have no plant safety consequence. The Surveillances and Safety System Settings i

will be conducted in the same manner after revision of the Technical Specifications. These non-compliances were identified as the result of heightened awareness to the potential for lack of verbatim Technicci l

Specification compliance. These non-compliances are significant as examples of a lack of compliance with TS 1

requirements identified due to e heightened awareness resulting from previous Licensee Event Reports.

IV. Corrective Action

The following corrective action wi.! be taken:

1 As described previously in LER 96-038-00, LER 96-048-00, LER 97-001-00,and LER 97-004-00 the Unit Director e

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

Technical Specification change (s) will be submitted to revise SR 4.6.4.1, and SR 4.8.4.1.a.2 by April 30,1997.

e I

A Technical Specification change will be submitted to revise Table 2.2-1 and/or the 2.2-1 Bases will be revised by e

April 30,1997.1

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• 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 Revision Millstcme Nuclear Power Station Unit 3 05000423 NUMBER NUMBER 3 of 6 i

97 018 00 TEXT (11more space is required, use additionalcopies of NRC Form 366A) t17}

1 V.

Additional Information

None.

Similar Events

LER 96-008-00

" Reactor Protection System Lead /Laa Time Constants Set Non-Conservatively" On April 12,1996, at 14:30, with the plant in Mode 5 at 0-percent power, it was discovered that time constants used on lead / lag cards for Overpressure Delta Temperature and Overtemperature Delta Temperature Reactor Trip setpoints as well as Steam Line Negative Rate -High Main Steam Line lsolation setpoints may be set non-conservatively. A subsequent review determined that the time constants specified in plant Technical Specifications for Overpressure Delta Temperature and Overtemperature Delta Temperature Reactor Trip setpoints were used as an input to calculate Safety Analysis Limits, thus affecting Limiting Safety System settings. These values were treated in the l

plant as Nominal values, which allowed field calibration within a specified calibration range on either side of the Technical Specification limit. The same review found that the plant Technical Specification that identifies the rate-lag time constant used for the Steam Line Negative Rate - High Main Steam Line isolation setpoint incorrectly identifies the direction of conservatism. In addition, the plant considered this value as a Nominal value instead of a limiting setting. The conservative calibration requirements for reactor protection circuits, specifically lead / lag time constants, in the plant Technical Specifications were not identified by the vendor (Westinghouse). The current lead / lag settings were based on reasonable interpretation of vendor documents and were adopted with the endorsement of the vendor.

LER 96-014-00

" Technical Soecification Surveillances for Emeraencv Diesel Generators Misinterpretationand ProarammaticWeakness" On May 16,1996, with the plant in Mode 5 at 0-percent power, it was determined that several Technical Specification (T S) surveillances for the Emergency Diesel Generators (EDGs) had been performed during operation,versus shutdown, contrary to the requirementsof Surveillance 4.8.1.1.2.g. Upon discovery of the historicalnoncompliance,the EDGs were declared inoperable May 16,1996, and the plant complied with TS Action requirements. As immediate action, a list of surveillanceswas performed while shutdown, and the B EDG was declared operable May 17,1996. The A EDG remained inoperable for other reasons. It was subsequently determined on May 23,1996, that an additional surveillancewas required for both EDGs. Aftercompleting all required sun /eillancesthe A EDG was declared operable on May 25,1996, and the B EDG was declared operable May 26,1996. The historicalnoncompliancewas caused by a misinterpretationof the " shutdown" stipulation. It was believed that performanceof the surveillancewhile operating satisfied the shutdown requirement. The cause of overlooking the additional surveillancewhen taking immediate action was determined to be a programmaticweakness. The event had no safety significance. Performing the surveillancesduring plant operation had no affect on the ability to perform the surveillancesor the ability of the EDGs to perform their safety function. The surveillances had been successfully completed within required intervals. The only affect was compliance with a stipulation to do the surveillancesduring shutdown.

NRC FORM 362A 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 REVISION Millstone Nuclear Power Station Unit 3 05000423 NUMBER NUMBER 4 Of 6 97 018 00 TEXT filmore space is required, use additional copies of NRC Form 366A) (17) l 1

1 4

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~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 Revision Millstone Nuclear Power Station Unit 3 05000423 NUMBER NUMBER 5 of 6 97 018 00 TEXT lif more space is required, use additional copies of NRC form 366A) (17)

LER 96-038-00

" Violation of Technical SDecifications Pertainina to Hioh Pressure Safety iniection & Charaina System Pumos" At 1800 on October 10,1996, with the plant in Mode 5, plant personnel determined that the Technical Specification requirement 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.

LER 96-048-00

" Failure To Comolete 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 surveillancewhich 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 surveillanceis required to be completed once per 18 months during shutdown. Contrary to this, the surveillanceswhich 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 significanceof this event is minimalin that the mode in which the surveillances are performed has no physical affect on the ability to complete the surveillancesor the ability of the EDGs to perform their safety function. As immediate corrective action, the EDGs were declared inoperable and the load shed surveillanceswere performed during shutdown prior to restoring the EDGs to operable status.

LER 97-001-00 " Lack of Verbatim Comoliance with Technical Specification Surveillance Reauirements for 125 Volt Batteries and Battery Charaers" On January 4,1997, with the plant in Mode 5, it was identified that 125 volt battery surveillance testing was being performed in a manner that was not in verbatim compliance with the Technical Specifications (TS). Similarly, on January 9,1997, with the plant in Mode 5, it was identified that 125 volt battery charger surveillance testing was being performed in a manner that was not in verbatim compliance with the TS. 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 additionallack of verbatim TS compliance such as those described in previous Licensee Event Reports. Corrective actions included immediate revision and performance of the battery and battery charger surveillance testing procedure requirements to effect verbatim TS compliance with the TS.,

m_

. *U.s. NUCLEAR REoulAToRY 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 6 Of 6 97 018 00 TEXT (11 more space is required, use additionalcopies of NRC Form 366A) (17)

LER 97-004-00 " Lack of Verbatim Compliance with Technical Specification Surveillance Reauirements for Molded Case Circuit Breakers" 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 the Technical Specifications (TS). 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 turn, 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. These conditions were identified as i

the result of a heightened awareness of the potential for additional lack of verbatim TS compliance such as U:ose described in previous Licensee Event Reports. Corrective actions included a change to the affected surveillance testing procedure to ensure verbatim compliance with the TS and performance of the required testing.

Manufacturer Data Not Applicable