05000336/LER-1997-016-02, :on 970415,TS 4.0.4 Was Incorrectly Applied to SRs for Tdafwp.Caused by Failure to Incorporate TS SRs Into Plant Surveillance Procedures.Surveillance Procedure for Tdafwp Revised Prior to Entry Into Mode 4

:on 970415,TS 4.0.4 Was Incorrectly Applied to SRs for Tdafwp.Caused by Failure to Incorporate TS SRs Into Plant Surveillance Procedures.Surveillance Procedure for Tdafwp Revised Prior to Entry Into Mode 4

ML20141G126
Person / Time
Site:	Millstone
Issue date:	05/15/1997
From:	Joshi R NORTHEAST NUCLEAR ENERGY CO.
To:
Shared Package
ML20141G109	List: 05000336/LER-1997-016, Forwards LER 97-016-00 Per 10CFR50.73(a)(2)(i)(B).Also Includes Commitments Made in Ltr 05000336/LER-1997-016-02, :on 970415,TS 4.0.4 Was Incorrectly Applied to SRs for Tdafwp.Caused by Failure to Incorporate TS SRs Into Plant Surveillance Procedures.Surveillance Procedure for Tdafwp Revised Prior to Entry Into Mode 4
References
LER-97-016-02, LER-97-16-2, NUDOCS 9705220174
Download: ML20141G126 (4)

LER-1997-016, on 970415,TS 4.0.4 Was Incorrectly Applied to SRs for Tdafwp.Caused by Failure to Incorporate TS SRs Into Plant Surveillance Procedures.Surveillance Procedure for Tdafwp Revised Prior to Entry Into Mode 4

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(iii) 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
3361997016R02 - NRC Website

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• NRC FORM 363 U.S. NUCLE AR REGULATORY COMMISslON APPROVED BY OMS NO. 3150 0104 i

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EXPtRES 04/30/98

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a FOCIUTY NAME (1)

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PAGE (31 Millstone Nuclear Power Station Unit 2 05000336 1OF4 TITLE i41 j

Technical Specification 4.0.4 Incorrectly Applied To Surveillance Requirements For The TDAFW Pump EVENT DATE (5)

LER NUMBER (6)

REPORT DATE (7)

OTHER FACILITIES INVOLVED (8) sE AL RE N

MONTH DAY YEAR YEAR MONTH DAY YEAR Nu E Nu R

" * *^"'

04 15 97 97

-- 016 --

00 05 15 97 OPERATING THIS REPORT is SUBMITTED PURSUANT TO THE REQUIREMENTS OF 1o CFR 5: (Check one or more) (11)

MODE (9)

N 20.2201(b) 20.22o3(a)(2Hv)

X 50.73taH2)(i) 50.73(aH2Hvin)

POWER 20.2203(a)(1) 20.2203(a)(3Hil 50.73(a)(2Hei) 50.73(a)(2)(x)

LEVEL (10) 000 20.2203(aH2Hi) 20.2203(a)(3Hii) 50.73(a)(2)(iii) 73.71 20.2203(a)(2)(n) 20.2203(aH4)

So.73(aH2)(iv)

OTHER 2

20.2203(a)(2Hiii) 50.36(c)(1) 50.73(a)(2)(v)

Specify in Abstract below 20.2203(a)(2)(iv)

So.36(cH2) 50.73(a)(2)(vii) ipr NRC Form 366A LICENSEE CONTACT FOR THIS LER (12)

NQME TELEPHONE NUM8ER (include Area Codel l

R. G. Joshi, MP2 Nuclear Licensing (860)440-2080 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THis REPORT (13)

CAUSE

SYSTEM COMPONENT MANUFACTURER

CAUSE

SYSTEM COMPONENT MANUFACTURER

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SUPPLEMENTAL REPORT EXPECTED (14)

EXPECTED YEs SUBMISSION X NO DATE (15)

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

On April 15,1997, a review of Technical Specification issues discovered that an exception to the provisions of Technical Specification 4.0.4 had been incorrectly applied to Technical Specification Surveillance Requirements (SRs). The current surveillance procedure for testing the Turbine Driven Auxiliary Feedwater (TDAFW) Pump prior to entering Mode 3 did not run the pump for 15 minutes or guarantee that it was started from the Control Room (CR) as required by Technical Specifications SRs 4.7.1.2.a.3 and 4.7.1.2.a.1. It was previously believed that the 15 minute run and start from CR requirements in the Technical Specifications were being met when the pump was run after secondary plant pressure exceeded 800 psig, and that an exception to the provisions of Technical Specification 4.0.4 for performing the run at pressure greater than 800 psig were applicable to the 15 minute run from the CR.

The cause of this event was failure to property incorporate Technical Specification surveillance requirements into plant surveillance procedures.

The surveillance procedure for the Turbine Driven Auxiliary Feedwater (TDAFW) will be revised prior to entry into Mode 4 from the current outage to ensure that the required 15 minute run of the TDAFW Pump is started from the CR and is performed prior to unit entry into Mode 3.

Technical Specification surveillance procedures will continue to be reviewed to ensure compliance with Technical i

Specifications surveillance requirements as part of Mitistone Unit 2 Operational Readiness Plan (Reference NOV 336/96-08-07. NNECO Commitment No. B16076-2).

9705220174 970515 PDR ADOCK 0500033o S

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NRC ORM 366A U.s. NUCLEAR REGULATORY Commission 4

asu LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DOCKET LER NUMBER (6)

PAGE (3)

SEQUENTIAL REVISION YEAR NUMBER NUMBER 2OF4 i

Millstone Nuclear Power Station Unit 2 05000336 97 - 016 00 TEXT (11more space is required. use additional copies of NRC Form 366A) 0 7) 1.

Description of Event

On April 15,1997, a review of Technical Specification issues discovered that an exception to the provisions of Technical Specification 4.0.4 had been incorrectly applied to Technical Specification Surveillance Requirements (SRs). The current surveillance procedure for testing the Turbine Driven Auxiliary Feedwater (TDAFW)[BA)

Pump prior to entering Mode 3 did not run the pump for 15 minutes or guarantee that it was started from the Control Room (CR) as required by Technical Specifications SRs 4.7.1.2.a.3 and 4.7.1.2.a.1. It was previously believed that the 15 minute run and start from CR requirements in the Technical Specifications were being met when the pump was run after secondary plant pressure exceeded 800 psig, and that an exception to the provisions of Technical Specification 4.0.4 for performing the run at pressure greater than 800 psig were applicable to the 15 minute run from the CR At the time of discovery of this event, the unit was defueled.

A different surveillance proc bre which tests the pump prior to mode 3 verifies AFW flow by checking that steam generator (SG)[AB] level increases by 2 percent. A review of Shift Manager logs indicates that the pump is run approximately 10 to 20 minutes during this surveillance. By practice, this surveillance is run from the CR, but the procedure does not specifically require operation from tt CR. Evidence exists that a 15 minute run prior to mode 3 was not accomplished at least one time in the unit's history (June 14,1994), and no direct evidence is available to ensure that the pump was always operated from the CR.

It was previously believed that the 15 minute run and operation from the CR as required by Technical Specifications SRs 4.7.1.2.a.3 and 4.7.1.2.a.1, were being met when performing Technical Specifications SR 4.7.1.2.a.2.b. SR 4.7.1.2.a.2.b requires at least once per 31 days that the TDAFW pump shall be demonstrated OPERABLE by verifying that the pump develops a discharge pressure of equal or greater than 1080 psig on recirculation flow when the secondary steam supply pressure is greater than 800 psig.

SRs 4.7.1.2.a.3 and 4.7.1.2.a.1 do not require a discharge pressure of 1080 psig to be developed by the pump, do not require 800 psig secondary steam supply pressure and do not have an exception to the provisions of Specification 4.0.4. Therefore, SRs 4.7.1.2.a.3 and 4.7.1.2.a.1 are required to be performed prior to entry into Mode 3. The current surveillance procedure does not satisfy the surveillance requirements of the Technical Specifications.

This event is being reported in accordance with 10 CFR 50.73(a)(2)(i)(B), any operation or condition prohibited by the plant's Technical Specifications.

11. Cause of Event

The cause of this event was failure to property incorporate Technical Specification surveillance requirements into plant surveillance procedure (s).

Ill. Analysis of Event The AFW system is designed to provide feedwater for the removal of sensible and decay heat, and to cool the primary system to 300 F in case the main cGadensate and steam generator feed pumps are inoperable due to a loss of normal electric power sources or main steam. The AFW System may also be used for normal cooldown to 300 F. The system supplies feedwater from the condensate storage tank (CST), through either of two motor driven AFW pumps or one TDAFW pump to the steam generators for evaporation and heat absorption.._.

• U.s. NUCLEAR REGULATORY COMMISslON (4 951 LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION l

FACILITY NAME (11 DOCKET' LER NUMBER 16)

PAGE (3)

SEQUENTIAL REVISION YEAR NUMBER NUMBER 3OF4 Millstone Nuclear Power Station Unit 2 05000336 97 - 016 00 3

q l TEXT (11 more space is required. use additional copies of NRC Form 366A) (11) j The surveillance requirements in question revolve around o;r ability of the TDAFW pump prior to Mode 3. The requirements include:

J Operation of the pump from the CR, Operation of the pump for at least 15 minutes, and e

Verifying the flow path from the CST to the SGs before entering Mode 3 after a COLD SHUTDOWN of at 5

least 30 days.

Although starting the pump from CR and operating the pump for at least 15 minutes was not always performed, the flow test has always been performed prior to Mode 3 after a 30 day shutdown. The pump has always been tesud when SG pressure exceeds 800 psig by verifying that it starts from the CR, runs for 15 minutes and develops discharge pressure greater than or equal to 1080 psig with steam supply pressure in excess of 800 psig.

Therefore, this event was not safety significant.

IV. Corrective Action

i As a result of this event, the following actions will be performed.

i 1.

The surveillance procedure for the Turbine Driven Auxiliary Feedwater (TDAFW) Pump will be revised l

prior to entry into Mode 4 from the current outage to ensure that the required 15 minute run of the TDAFW Pump is started from the CR and is performed prior to unit entry into Mode 3.

2.

Technical Specification surveillance procedures will be reviewed to ensure compliance with Technical Specifications surveillance requirements as part of Millstone Unit 2 Operational Readiness Plan (Reference NOV 336/96-08-07, NNECO Commitment No. B16076-2).

V.

Mditional information

Similar Events

Previous LERs that involve deficient surveillance procedures include:

LER 96-023:

Discrepancies Found in Various Technical Specification Required Valve Lineups i

LER 96-024:

Inadequate Surveillances for Reactor Protection System and Engineered Safety Actuation System Response Time Testing LER 96-025:

Enclosure Building Filtration Actuation Signal / Auxiliary Exhaust Actuation SignalInterlock Not Tested Periodically LER 96-026:

Incomplete Technical Specification Required Surveillance - Valve Lineups inside Containment LER 96-035:

Failure to Perform Periodic Surveillance Testing for Interlock Function Associated with the Main Steam Isolation System Functinn of the Engineered Safeguards Actuation System LER 96-037:

Inadequate Surveillance Prc edure for Verifying Average Water Temperature at the Unit 2 intake Structure LER 96-038:

Inadequate Surveillance Procedures Used to Verify Emergency Diesel Generator Operability LER 96-039:

Failure to Perform Periodic Surveillance Testing for Containment Purge System Containment Isolation Valves in Accordance with Technical Specification 4.9.10 LER 96-040:

Inadequate Surveillance Procedure for Verifying Motor Circuit Breaker Position in Accordance with Technical Specification Requirements 4.1.2.3.2,4.1.2.3.3, and 4.4.1.4 LER 97 003:

Surveillance Procedure SP2618C Fails to Meet Technical Requirements Manual Surveillance Requirements__

4 NRC" FORM 366A U.S. NUCLEAR REGULATORY COMMISSION 14-95)

UCENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACillTY NAME (1)

DOCKET LER NUMBER (6)

PAGE (3)

SEQUENTIAL REVISION AR NUMBER NUMBER 4OF4 Millstone Nuclear Power Station Unit 2 05000336 97 016 00 TEXT tif more space es required, use additional copies of NRC Form 366Al (17)

LER 97-007:

Inadequate Surveillance Procedure for Verifying Operabil:ty of Reactor Coolant System Vents Energy Industry identification System (Ells) codes are identified in the text as [XX].

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