ML20215B325
| ML20215B325 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 06/11/1987 |
| From: | Heider L YANKEE ATOMIC ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| FYR-87-61, NUDOCS 8706170290 | |
| Download: ML20215B325 (4) | |
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YANKEE ATOMIC ELECTRIC COMPANY r.i.v8cn. cars >s2<.s2e1 Star Route, Rowe, Massachusetts 01367
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June 11, 1987 r
g f-YANKEE FYR 07-61 United States Nuclear Regulatory Commission Washington, DC 20555 1
Attention:
Document Control Desk
References:
(a)
License'No. DPR-3 (Docket No. 50-29)
(b)
YAEC Letter to USNRC Region I,
dated March 20, 1987, Licensee Event Report 50-29/07-04 (c)
I&E Letter to YAEC dated May 12, 1987;
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I&E Inspection 50-20/97-02
Subject:
Response to Inspection 50-29/87-02
Dear Sir:
Reference is made to I&E Inspection No. 50-29/87-02 conducted by your Mr.
H.
Eichenholz during the period January 27 -April 17, 1987, at the Yankee Nuclear Power Station, Rowe, Massachusetts.
The report made subsequent to that inspection identified one item which apparently was not conducted in full compliance with NRC requirements.
In accordance with Section 2.201 of the NRC's " Rules and Practices," Part 2, Title 10, Code of Federal Regulations, we hereby submit the following information:
Apparent Violation Technical Specification (TS) 6.8.1 requires that written procedures shall be implemented that meet or exceed the requirements and recommendations of Appendix "A" of Regulatory Guide 1.33, Revision 2.
Regulatory Guide 1.33 requires implemented procedures for Temporary Change activities.
AP-OO18, Rev. 12, Temporary Change Control, requires the cognizant department supervisor (CDS) to determine if a Temporary Change Request (TCR) affects an operable system and to perform a preliminary review and identification of appropriate TS and actions required.
Additionally, this procedure requires the shift supervisor to perform a final review which includes identification of appropriate'TS and actions required as well as identifying any additional instructions / actions to ensure safe plant operation.
Contrary to the above, the requirements of AP-OO18 were not, met on February 18, 1987, in that, the assistant I&C-supervisor (the CDS) and the shift supervisor reviews were not adequate prior to implementation of TCR No. 87-41.
Specifically, their' reviews 1) did not identify operability gk requirements associated with the removal of a main coolant f
8706170290 B70611 PDR ADOCK 05000029 G
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I pressure channel from service, 2) did not identify the applicability of TG 3.3.2 Table 3.3-2 requirements and associated action statement, and 3) did not identify the need for placing the safety injection auto start / auto c-stout swi tch J
for Train A in the auto cutout position which would have precluded the inadvertent actuations of a safety injection.and non-essential containment isolation systems that occurred upon implementation of the TCR on February 18, 1987.
1 This is a Severity Level IV Violation (Supplement I).
Response
We concur with the Notice of Violation as described above and in Reference (c).
This event was described in our LER 87-04 dated March 20, 1987.
For purposes of completeness, the information contained in the LER is repeated and supplemented as appropriate.
I EVENT DESCRIPTION On 2/18/87 at 1124 hours0.013 days <br />0.312 hours <br />0.00186 weeks <br />4.27682e-4 months <br /> with the plant in Mode 3, the Emergency Core Cooling System (ECCS) and the Vapor Container Isolation System (CIS) were inadvertently actuated when Main Coolant Pressure Channel 100 (MC-P-100), (TS 3.3.2 Table 3.3-2) was being removed from service to perform maintenance on the channel test switch, MC-TS-100.
The event occurred when the technicians lifted the Main Coolant pressure transmitter j
signal lead.
The resultant zero pressure indication i
actuated ECCS and non-essential CIS.
The technicians performing the work immediately restored MC-P-100 to operable statuu, and the Control Room operators verified that:
- 1) all Engineering Safeguards Systems (ESS) responded as required for loss of Main Coolant pressure indication and 2) actuation of ECCS and non-essential CIS was inadvertent.
Upon verification of
- 1) and 2) at 1128 hours0.0131 days <br />0.313 hours <br />0.00187 weeks <br />4.29204e-4 months <br />, the operators reset ECCS and non-essential CIS.
The NRC was notified via ENS at 1154 hours0.0134 days <br />0.321 hours <br />0.00191 weeks <br />4.39097e-4 months <br /> 2/18/87.
II EVALUATION The root cause of the event has been attributed to personnel error in the failure to perform an adequate review of the system design.
The review should have identified that the Safety Injection Auto Start / Auto Cutout switch for Train A should have been placed in the Auto Cutout position; and to not do so would result in actuation of Train A.
The work was initiated using a Temporary Change Request (TCR).
The TCR provided:
1) information necessary to isolate MC-P-100 electrically, a
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1 and 2) authorization by I&C supervision and an Operations Department Control Room Operator (CRO) and Shift Supervisor (SS) to perform the work.
It did not identify that ECCS and non-essential CIS would be actuated when i
MC-P-100 pressure indication went to zero.
Two additional factors contributing to this event are:
- 1) the TCR did not provide complete information regarding ECCS and CIS Tech. Spec. operability requirements, and
- 2) the TCR was not properly reviewed by the CRO.and the SS in that they did not identify that the performance of i
the TCR would place the plant in the Action Statement of TS 3.3.2 Table 3.3-2.
The plant Tech. Specs. were reviewed only to the extent of determining that MC-P-100 was required to be operational in Modes 1 and 2 per TS 3.3.1 Table 3.3-1.
A later, complete r eview of the Tech.
Specs. identified the requirement that MC-P-100 also be operational in Mode 3 per TS 3.3.2 Table 3.3-2.
III CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED This is the first occurrence of this nature.
A review of Plant procedures has determined that adequate. guidance was in place regarding document review prior to completion of the TCR, and for administrative review prior to beginning work.
The ILC Department Supervisors and Technicians have been instructed to thoroughly review all aspects of work to be performed, during pre-job discussions.
Additional training in the proper completion of the TCR process and form has been given to appropriate personnel.
A Special Order was issued on April 9, 1987, to Operations Department personnel instructing control room personnel to realize the importance of reviewing documents that allow work to be performed and take the necessary time for an adequate review prior to allowing work to continue.
The Shift Supervisors were instructed to review the TCR procedure with their crew and emphasize that whenever a review of a TCR is in question, that higher management (including PORC, if necessary) should be consulted prior to authorization of the work.
IV CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The TCR procedure, AP-OO18, will be revised to clarify the responsibilities of the personnel whose signatures are required prior to the work implementation.
This revision will include a clear statement on the responsibilities of control room personnel to perform an adequate review of a TCR prior to implementation.
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Furthermore, the procedure revision will include
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instructions that in cases when a TCR is in question, the TCR can be brought to. higher supervision.(including PORC) for discussion and/or approval.
V THE DATE WHEN FULL COMPLIANCE WILL DE ACHIEVED I
The revision to AP-OO18 will be completed by July 31, 1987.
If you have any question or desire additional informat2on, I
please contact us.
Sincerely, L.
H.
Heider Vice President and Manager of Operations cc:
[1] Region I
[2] Resident Inspector
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