05000245/LER-1997-029-01, :on 970513,GL 96-01 Review Discovered Inadequate Surveillance Testing.Caused by Programmatic Deficiency.Procedure Tested IAW TS Requirements

:on 970513,GL 96-01 Review Discovered Inadequate Surveillance Testing.Caused by Programmatic Deficiency.Procedure Tested IAW TS Requirements

ML20141C842
Person / Time
Site:	Millstone
Issue date:	06/12/1997
From:	Robert Walpole NORTHEAST NUCLEAR ENERGY CO.
To:
Shared Package
ML20141C817	List: 05000245/LER-1997-029, Forwards LER 97-029-00,documenting an Event That Occurred at Millstone Nuclear Power Station,Unit 1 on 970513.Commitments Made within Ltr,Listed 05000245/LER-1997-029-01, :on 970513,GL 96-01 Review Discovered Inadequate Surveillance Testing.Caused by Programmatic Deficiency.Procedure Tested IAW TS Requirements
References
GL-96-01, GL-96-1, LER-97-029-01, LER-97-29-1, NUDOCS 9706260036
Download: ML20141C842 (3)

LER-1997-029, on 970513,GL 96-01 Review Discovered Inadequate Surveillance Testing.Caused by Programmatic Deficiency.Procedure Tested IAW TS Requirements

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)(x) 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
2451997029R01 - NRC Website

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MRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OM8 NO. 3150-0104 l

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FOCILITY NAME (1)

DOCKET NUMBER 42)

PAGE(3)

Millstone Nuclear Power Station Unit 1 05000245 1 of 3 TITLE F3)

GL 96 01 Review Discovers inadequate Surveillance Testing in Accordance with Technical Specifications l

l EVENT DATE (5)

LER NUMBER (6)

REPORT DATE (7)

OTHER FACILITIES INVOLVED (8) j l

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

05 13 97 97 029 00 06 12 97 l

OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR 5: (Check one or more) (11) f 20.2201(b) 20.2203(a)(2)(v)

X so 73(a>(2)(i) 50.73(a)(2)(viii) i POWER 20.2203(a)(1) 20.2203(a)(3)(i) 50.73(a)(2)(ii) 50.73(a)(2)(x)

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20.2203(a)(2)(i) 20.2203(a)(3)(ii) 50.73(a)(2)(iii) 73.71 20.2203(a)(2)(ii) 20.2203(a)(4) 50.73(a)(2)(iv)

OTHER

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t 20.2203(a)(2)(iii) 50.36(c)(1) 50.73(a)(2)(v) specif y in Abstract below

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20.2203(a)(2)(iv) 50.36(c)(2) 50.73(a)(2)(vii) i LICENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER (include Area Codel Robert W. Walpole, MP1 Nuclear Licensing Manager (860)440-2191 l

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

CAUSE

sY'4 TEM COMPONENT MANUFACTURER REPORTABLE

CAUSE

SYSTEM COMPONENT MANUFACTURER REPORTABLE To NPRDS To NPRDS i

SUPPLEMENTAL REPORT EXPECTED (14)

EXPECTED MONTH DAY YEAR YES X NO l

(If yes, complete EXPECTED SUBMl3SION DATE).

ABSTRACT (Limit to 1400 spaces. Le., approximately15 single-spacedtypewrittenlines) (16)

On May 13,1997, at 1030 hours0.0119 days <br />0.286 hours <br />0.0017 weeks <br />3.91915e-4 months <br />, with the plant in Cold Shutdown, while performing a procedure review for Generic Letter (GL) 96-01 it was discovered that the Instrument Functional Test for the Reactor Building Ventilation and Refuel Floor High Radiation Monitor channels did not encompass the entire instrument channel. The Standby Gas Treatment system (SGTS) initiation relays, which drop out on a downscale trip of the radiation monitors, were not tested monthly per the Millstone Unit 1 Technical Specifications (TS). The downscale trip functions are part of the radiation monitor channels, which include these initiation relays. These relays are tested every refueling and not monthly. This condition is being reported pursuant to 10CFR50.73(a)(2)(i)(B) as a condition prohibited by TS.

The surveillance procedure was revised to ensure that the instrumentation channel was tested in accordance with the TS requirements. Subsequent performance of the surveillance procedure demonstrated satisfactory channel response, j

therefore no safety consequences or safety implications resulted from the event. Corrective action is to complete l

instrument control surveillance procedure reviews to identify any additional TS surveillances not properly performed.

9706260036 970612 l

PDR ADOCK 05000245l l

S PM NRC FORM 366 (4-95)

U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FAclLITY NAME (1)

DOCKET NUMBER (2)

LER NUMBER (6)

FXGE (3)

YLAH btGUENilAL HLVIEUN Millstone Nuclear Power Station Unit 1 05000245 NUMBER NUMBER 2 of 3 97 029 00 TEXT (11more space is required, use additionalcopies of NRC Form 366A) (17)

I, Descrintion of Event On May 13,1997, at 1030 hours0.0119 days <br />0.286 hours <br />0.0017 weeks <br />3.91915e-4 months <br />, with the plant in Cold Shutdown, while performing a procedure review for GL 96-01 it was discovered that the Instrument Functional Test for the Reactor Building Ventilation and Refuel Floor High Radiation Monitor channels did not encompass the entire instrument channel. The SGTS initiation relays, which drop out on a downscale trip of the radiation monitors, were not tested monthly per the TS. The downscale functions of the Reactor Building Ventilation and Refuel Floor High Radiation Monitors are part of the instrument channels as described by TS, and include the SGTS initiation relays. Therefore the Reactor Building Ventilation and Refuel Floor High Radiation Monitor channels were not fully tested in accordance with TS.

The monthly surveillance test requirements were applicable at all times these monitors were required to be operable. Since the required surveillance testing was not fully performed, this event is considered to be a missed surveillance, and this occurrence is being reported pursuant to 10CFR50.73(a)(2)(i)(B), as a condition prohibited by TS.

The Reactor Building Ventilation and Refuel Floor High Radiation Monitor channels were declared inoperable. The surveillance procedure was revised to meet the TS requirements for an instrument functional test and subsequent performance demonstrated satisfactory channel responso. The Reactor Building Ventilation and Refuel Floor High Radiation Monitor channels were then declared operable.

There were no automatic or manualinitiated safety system responses.

11.

Cause of Event

l Programmatic deficiency in that sufficient guidance did not exist to specifically define what constitutes an adoquate instrument functional test.

Contributing causes to this event are the fellore to identify this discrepancy in previous TS compliance reviews, and the failure to implement compliance with TS.

Ill. Analysis of Event The downscale trip functions of the Reactor Building Ventilation and Refuel Floor High Radiation Monitors are part of the instrument channels as described by TS. The basis for TS 3/4.2 discusses both the high radiation and the downscale trip actuations of the SGTS Initiation and Reactor Building Ventilation Isolation logics.

Therefore, the downscale trip actuations of the Reactor Building Ventilation and Refuel Floor High Radiation Monitors must be functionally tested on a monthly basis to meet the surveillance requirements of TS Table 4.2.1.

TS 1.0.0.1, Protective Instrumentation Definitions, defines an " Instrument Channel" to be an arrangement of a sensor and auxiliary equipment required to generate and transmit to a trip system a single trip signal related to the plant parameter monitored by the instrument channel. The downscale trip actuation portions of the Reactor Building Ventilation and Refuel Floor High Radiation Monitor channels were not fully tested in accordance with TS Table 4.2.1, since the monthly functional tests of the instrument channels have not included the SGTS l

initiation relay coils. The SGTS initiation relay coils are part of the instrument channels since they are auxiliary l

equipment required to transmit to a trip system a single trip signal. The SGTS initiation relays associated with l

tha downscale trip actuation portions of the Reactor Building Ventilation and Refuel Floor High Radiation Monitor j

channels have been tested each refueling outage, but have not been tested monthly to meet the requirements of TS Table 4.2.1.

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• • NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION j

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION l

FAGluTV NAME (1) i DOCKET NUMBER (2)

LER NUMBER (5)

PAGE (3)

YLAH btGUEN ilAL HEViblVN l

Millstone Nuclear Power Station Unit 1 05000245 NUMBER NUMBER 3 of 3 97 029 00 TEXT Uf more space is required, use additionalcopies of NRC form 366A) (17)

Subsequent performance of the surveillance procedure demonstrated satisf actory channel response, therefore no safety consequences or safety implications resulted from the event. The safety related functional requirement of the Reactor Building Ventilation and Refuel Floor Radiation Monitors is to monitor the reactor building ventilation exhaust plenum and the refueling floor area to provide prompt indication of a gross release of radioactive material. If setpoints are exceeded, signals will isolate the normal reactor building and steam tunnel ventilation j

systems and initiate operation of the SGTS. The only TS required trip values for these radiation monitors are the high radiation settings specified in TS 3.2.E.3.

A failure of the downscale trip actuation function of these radiation rnonitors would not, in itself, degrade the principle safety barrier (secondary containment) of the plant provided the radiation monitors remain capable of responding to a valid high radiation condition. Since the monitors responded to a known radiation field and the high radiation trip function performed satisfactorily as demonstrated during surveillance testing, any one monitor would have isolated reactor building and steam tunnel ventilation and started SGTS in the event of a gross release of radioactivity. Also, since the downscale annunciators were tested on a monthly basis, it is concluded that appropriate operator action would have been taken in the unlikely event that the SGTS initiation relays failed to initiate SGTS on a downscale trip as required.

It is noted that testing has demonstrated that the relays trip as required, i

IV. Corrective Action

Northeast Nuclear Energy Company (NNECO) has developed the necessary procedures to fully test the downscale trip actuation function of the Reactor Building Ventilation and Refuel Floor Radiation Monitors on a monthly basis, and has performed the appropriate surveillances satisfactorily to meet the TS as they pertain to Table 4.2.1.

NNECO will develop and provide reviewers with criteria for evaluating the adequacy of the surveillance procedures for the performance of TS required instrument functional testing prior to startup for operating Cycle 16.

NNECO will be performing a review of all instrumentation and control related surveillance procedures to verify compliance with Millstone Unit 1 TS surveillance requirements prior to startup for operating Cycle 16.

V.

Additional Information

Similar Events LER 97-020-00 Liquid Radwaste Effluent Monitor Functional Test Surveillance Not in Accordance with Technical Specifications LER 96-015-00 Recirculation Pump Flow Mismatch Surveillance Not Performed In Accordance With Technical Specifications LER 96-019-00 Sensor Calibration of SRM/lRM Nuclear Instrumentation not Performed as Required LER 96-043-00 Inadequate Instrument Calibrations Due to Failure to Verify Response Time LER 96-044-01 High Range Stack Noble Gas Monitor Inoperable Due to inadequate Calibration Manufacturer Data Energy industry Identification System (Ells) codes are identified as follows: BH, RLY, and IL.

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