05000423/LER-1996-048, :on 961202,failed to Complete TS Required Testing of Chs Pump While Shutdown.Caused by Lack of Verbatim Compliance W/Ts.Performed Load Shed Surveillances

:on 961202,failed to Complete TS Required Testing of Chs Pump While Shutdown.Caused by Lack of Verbatim Compliance W/Ts.Performed Load Shed Surveillances

ML20138G648
Person / Time
Site:	Millstone
Issue date:	01/03/1997
From:	Peschel J NORTHEAST UTILITIES
To:
Shared Package
ML20138G646	List: 05000423/LER-1996-048, :on 961202,failed to Complete TS Required Testing of Chs Pump While Shutdown.Caused by Lack of Verbatim Compliance W/Ts.Performed Load Shed Surveillances
References
LER-96-048, LER-96-48, NUDOCS 9701020155
Download: ML20138G648 (5)

LER-1996-048, on 961202,failed to Complete TS Required Testing of Chs Pump While Shutdown.Caused by Lack of Verbatim Compliance W/Ts.Performed Load Shed Surveillances

Event date:
Report date:
Reporting criterion:	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) 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
4231996048R00 - NRC Website

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NRC FORM 366 U.s. NUCLEAR REGULATORY COMMisslON APPROVED BY OMB NO.3150-01o4 (4-95)

EXPIRES 04/30/98

' o%^/l#o'Te"J'le"Js! A "',M "9E.Jn"o^"Ju80 N

n'a"'io'Lt#"! "^".4"la 'a=Fafe',a ^" a LICENSEE EVENT REPORT (LER)

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(See reverse for required number of digits / characters for each block)

F ACIUTY NAME (1)

DOCKET NUMBER (2)

PAGE (35 Millstone Nuclear Power Station Unit 3 05000423 1 of 5 i

TITLE 64)

Failure To Complete Technical Specification Required Testing Of CHS Pump While Shutdown EVENT DATE (5)

LER NUM8ER (6)

REPORT DATE (7)

OTHER FACILITIES INVOLVED (8)

MONTH DAY YEAR YEAR SEQUENTIAL REvlslON MONTH DAY YEAR FACluTY NAME DOCKET NUMBER NUMBER I

^"'

12 02 96 96 048 00 01 03 97 OPERATINo THIS REPORT is SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR 5: (Chock one or more) (11)

ODE m 5

)

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

X so.73(aH2)(i)

So.73(a)(2)(viii) power LEVEL (10) 000 20.22o3(a)(1) 20.2203(aH3)(i)

So.73(aH2)(ii)

So.73(aH2)(x) 20.2203(aH2Hi) 20.2203(aH3)(ii) 50.73(ay2)(iii) 73.71 20.2203(a)(2)(ii) 20.2203(a)(4)

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

OTHER 20.2203(aH2Hiii) 50.36(c)(1) 50.73(a)(2)(v)

Sp.cify in Abstract below

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20.2203(a)(2)(iv, 50.36(c)(2) 50.73(a)(2)(vii)

LICENSEE CONTACT FOR THis LER (12) j N t.M E TELEPHONE NUMBER Unclude Area Codel J.M. Peschel, MP3 Nuclear Licensing Manager (860)437-5840 l

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

CAUSE

SYST COMPONENT MANUFACTURER REPOHTABLE

CAUSE

SYSTEM COMPONENT MANUFACTURER REPORTABLE l

TO NPRDS TO NPRDS SUPPLEMENTAL REPORT EXPECTED (14)

EXPECTED MONTH DAY YEAR SUBMISSION J

f YES NO (if yes, complete EXPECTED sUBMisslON DATE).

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

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.

Th3 event is being reported pursuant to 10CFR50.73(a)(2)(i)',B) as a condition pmhibited by Technical Specifications The cause was determined to be a lack of verbatim compliance with the Tect. 91 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 sahty significance of this event is minimal in that the mode in which the surveillances are performed has no physical affect on the ability to complete the surveillances or the abilit; V 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. Additional corrective actions will be completed prior to the unit entering mode 4 from the current outage.

9701020155 961220 PDR ADOCK 05000423 S

PDR NRC FORM 366 (4-95)

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NRC FoftM 366A U.S. NUCLEAR REGULATORY CoMMisSloN (4 95)

LICENSEE EVENT REPORT (LER) i TEXT CONTINUATION I

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 5 l

96 048 00 r

l TEXT Uf more space is required, use additional copies of NRC Form 366A) (11) i J.

l 1.

Description of Event

l j

On December 2,1996, with the plant in Mode 5, it was determined that a portion of the Tech lical Specification i

surveillance which tests the load shed function for both Emergency Diesel Generators GDG3) had not been performed t

in accordance with Technical Specification Surveillance 4.8.1.1.2.g.6. This surveillarNe is required to be completed i

once per 18 months during shutdown. Contrary to this, the surveillances which tested the load shed for both trains of l

Charging (CHS) system pumps and re-energization feature for portions of the CH3 system were performed during l

plint operation. The event is being reported pursuant to 10CFR50.73(a)(2)(i)(B) as a condition prohibited by Technical t

Specifications.

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The Technical Specification requirement to perform a Loss of Power (LOP) test with an Engineered Safety Featwes (ESF) actuation is a condition for EDG operability in modes 1 through 6. Technical Specification 3.3.2, Table 3.3.3, i

itIm 10 labels the Emergency Generator Load Sequencer as an ESF function. Load shedding of the charging pur;T is i

initiated by the sequencer and is, therefore, required to be tested. The surveillance procedure performed to meet the major portion of Technical Specifications 4.8.1.1.2.g.6 is accomplished while shutdown. However, the CHS pumps are 4

only load shed if there is Loss of Power (LOP) while operating in either hot leg or cold leg recirculation mode.

l Therefore, this function has not been tested during the normal ESF/ LOP test. Historically, this function had been

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insted concurrent with the charging pump operability tests when the plant was at power.

in June,1993 (see LER 93-005-00), it was determir.ed from a review of sequencer relay operability, that the ESF/ LOP l

strip function for the charging pumps during the recirculation mode of operation was not being performed. The j

j discovery that these specific tests weia not being performed resulted in surveillances being written as "at power" tests i

to verify operability of this feature. These surveillance's pmcedures were not added to the Production Master j

Surveillance Test Control List (MSTCL) data base at that time.

On May 16,1996 (see LER 96-014-00), it was detennined that several Technical Specification (TS) surveillances for th3 Emergency Diesel Generators (EDGs) had been performed during operation, versus shutdown, contrary to the i

requirements of Surveillance 4.8.1.1.2.g.6. As a result, future surveillances were scheduled for shutdown conditions.

l Additionally, the MSTCL data base was reviewed in order to identify EDG surveillances where similar misinterpretations could have existed. This review failed to identify the surveillances which tested the load shed and j

ra-energization feature for both trains of Charging (CHS) system pumps due to the previous failure to incorporate the i

surveillances into the MSTCL riata base.

Upon discovery the EDGs were declared inoperable and the applicable Technical Specification Actions were I

implemented. The required load shed surveillances were completed on December 3,1996, December 4,1996 and D:cember 7,1996 for the C CHS pump on the A train, and for the B and A CHS pumps respectively. The A EDG was j

1 d:clared operable at 1350 on December 7,1996. Investigation had determined that the re-energization test for the C CHS pump on the A train, and for the A and B CHS pumps had been previously performed while shutdown. The j

existing plant configuration precluded testing on the C CHS pump on the B train.

i 11.

Cause of Event

i The cause was determined to be a lack of verbatim compliance with the written word of the Technical Specifications.

Contributing causes were incomplete updating of the Master Surveillance Test Control List (MSTCL) data base i

following LER 93-005-00 and ineffective corrective actions to identify " shutdown" surveillances following LER 96-014-00 as a result of the previous failure to update the MSTCL data base.

i

I NRC FlftM 366A U.s. NUCLEAR REGULATORY Commission

'M e5)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FAclLITY NAME'D)

DOCKET NUMBER (2)

LER NUMBER (6)

PAGE (3)

YEAR SEQUENTIAL REVISloN Millstone Nuclear Power Station Unit 3 05000423 NUMBER NUMBER 3 of 5 06 048 00 TEXT Ut more space is required. use additional copies of NRC form 366A) (17) lli. Analysis of Event The event had no safety consequence in that the plant has never operated on a post-LOCA recirculation mode with a subsequent initiation of a LOP requiring the load shed and re-energization feature for both trains of Charging (CHS) system pomps to function.

The safety significance of this event is minimal in that the mode in which the surveillances are performed has no physical affect on the ability to complete the surveillances or the ability of the EDGs to perform their safety function.

The actual test had been successfully completed within the required time interval. Additionally, the Final Safety Analysis Report (FSAR) does not address post-LOCA recirculation operation with a subsequent initiation of a LOP within the accident analysis contained in Chapter 15.

IV. Corrective Action

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.

In addition the following corrective actions will be completed prior to the unit entering mode 4 from the current outage unless otherwise specified:

1.

The Unit Director will provide the unit staff with his expectations on compliance with Technical Specifications by March 31,1996.

2.

The surveillance procedures used to test the load shed and re-energization feature for both trains of Charging (CHS) system pumps will be revised to conform with Technical Specification 4.8.1.1.2.g.6(a) and (b).

3.

Testing of C CHS pump while aligned to B train will be performed in accordance with the requirements of Technical Specification 4.8.1.1.2.g.6(a) and (b) Prior to declaring the C CHS operable on Train B.

4.

The MSTCL will be updated to include the surveillance procedures used to test the load shed and re-energization feature for both trains of Charging (CHS) system pumps.

5.

The MSTCL will be reviewed to verify that Technical Specification surveillance procedures and forms have been appropriately incnrporated.

6.

A review of the Technical Specification surveillance forms will be performed to ensure they are included on the surveillance schedule maintained within PMMS. These schedules will be updated to correct any deficiencies identified.

7.

The existing Technical Specification surveillances will be reviewed to verify that load shed and re-energization testing required by Technical Specification 4.8.1.1.2.g.6 (a) and (b) has been completed during " shutdowns".

NRc F ftM 366A U.s. NUCLEAR REGULATORY CoMVilssioN (4 95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DOCKET NUMBER (2)

LER NUMBER (6)

PAGE (3)

YEAR SEQUENTIAL REvlSION Millstone Nuclear Power Station Unit 3 05000423 NUMBER NUMBER 4 of 5 96 048 00 TEXT fit more space is required, use additional copies of NRC l'orm 366A) (11)

V.

Additional Information

Similar Events LER 96-038-00 " Violation of Technical Specifications Pertainina to Hiah Pressure Safety Iniection & Charaina System Pumns."

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 were reported pursuant to 10CFR50.73(a)(2)(i)(C) as a condition prohibited by the plant's Technical Specifications.

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.

A Technical Specification change request will be submitted to resolve the conflict between the applicable Technical Specifications. The procedures affected by the conflict between these Technical Specifications will be changed prior to entry into Mode 4. The Unit Director will provide the unit staff with his expectations on compliance with Technical Specifications by March 31,1996.

LER 96-014-00 " Technical Specification Surveillances for Emeraency Diesel Generators. Misinterpretation and Proarammatic Weakness "

m On May 16,1996, with the plant in Mode 5 at 0-percent power, it was determined that several Technical Specification (TS) surveillances for the Emergency Diesel Generators (EDGs) had been performed during operation, versus shutdown, contrary to the seguirements of Surveillance 4.8.1.1.2.g. Upon discovery of the historical noncompliance, the EDGs were declared inoperable on May 16,1996, and the plant complied with TS Action requirements. As immediate action, a list of surveillances was performed while shutdown, and the B EDG was declared operable May 17,1996.

The A EDG remairied inoperable for other reasons. It was subsequently determined on May 23, 1996, that an additional surveillance was required for both EDGs. After completing all required surveillances the A EDG was declared operable on Mey 25,1996, and the B EDG was declared operable May 26,1996.

The historical noncompliance was caused by a misinterpretation of the " shutdown" stipulation. It was believed that performance of the surveillance while operating satisfied the shutdown)

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NRC FoftM 366A U.S. NUCLEAR REGULATORY COMMisSloN (4 95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DOCKET NUMPER (2)

LER NUMBER (6)

PAGE (3)

YEAR sEoVENTIAL REVISloN Millstone Nuclear Power Station Unit 3 05000423 NUMBER NUMBER 5 of 5 96 048 00 TEXT (11more space is required, use additional copies of NRC form 366A) til) requirement. The cause of overlooking the additional surveillance when taking immectiate action was determined to be a programmstic weakness.

The event had no safety significance. Performing the surveillances during plant operation had no affect on the ability to perform the surveillances or 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 surveillances during shutdown.

As corrective ac' ion the surveillances were performed during shutdown. Future surveillances were scheduled for shutdown conditions. A proposed Technical Specification change was submitted to delete the shutdown stipulation. The EDG surveillances were reviewed for shutdown limitations to ensure no similar misinterpretations existed.

LER 93-005-00: "Inadeauate Overlao Testina?

On May 20,1993 at 1400 with the plant in mode 1 at 100% the Cold Over Pressure Protection System (COPPS) was declared inoperable due to inadequate surveillance testing. The surveillance requirement was a monthly test of the circuit from the sensor up to, but not including, valve operation. However, only the portion of the circuit from the sensor to the input relays to Solid State Protection (SSP) system were tested at this monthly frequency. The discovery was made by a task force established as a corrective action to LER 93-003-00. This task force discovered four (4) other inadequate surveillance's including a portion of the EDGs load shed surveillance which tested the load shed and re-energization feature for both trains of Charging (CHS) system pumps.

The root cause of the event was a management deficiency in that a comprehensive approach to testing was not implemented during procedure development at plant startup. The immediate corrective action was to declare the affected system or component inoperable and enter the appropriate Limiting Condition for Operation (LCO). Allinservice components were tested to j

confirm operability.

i Manufacturer Data

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i Not applicable i