View source for 05000361/LER-1997-007, :on 970403,incomplete Surveillance Testing of Radiation Monitors Occurred.Caused by Cognitive Personnel Error.Procedures Corrected

{{Adams
| number = ML20149H610
| issue date = 07/18/1997
| title = :on 970403,incomplete Surveillance Testing of Radiation Monitors Occurred.Caused by Cognitive Personnel Error.Procedures Corrected
| author name = Krieger R
| author affiliation = SOUTHERN CALIFORNIA EDISON CO.
| addressee name = 
| addressee affiliation = 
| docket = 05000361
| license number = 
| contact person = 
| document report number = LER-97-007, LER-97-7, NUDOCS 9707250062
| package number = ML20149H600
| document type = LICENSEE EVENT REPORT (SEE ALSO AO RO), TEXT-SAFETY REPORT
| page count = 5
}}
{{LER
| Title = :on 970403,incomplete Surveillance Testing of Radiation Monitors Occurred.Caused by Cognitive Personnel Error.Procedures Corrected
| Plant = 
| Reporting criterion = 10 CFR 50.73(a)(2)(vii), 10 CFR 50.73(a)(2)(1), 10 CFR 50.73(a)(2)(viii)(A), 10 CFR 50.73(a)(2), 10 CFR 50.73(a)(2)(i)
| Power level = 
| Mode = 
| Docket = 05000361
| LER year = 1997
| LER number = 7
| LER revision = 0
| Event date = 
| Report date = 
| ENS = 
| abstract = 
}}

=text=
{{#Wiki_filter:a LICENSEE EVENT RCPORT (LER)
'F%ility Name (1)
Docket Number (2)
Page (3)
An Onofre Nuclede Generating Station' (SONGS) Unit 2 0l5l0l0l0l3l6l1 1lofl0l5 Titlo (4)
Incoeu>lete surveillance Testing of_ Radiation Monitors l
EVENT DATE (s)
LER NUbSER (6)
REPORT DATE (7) oTHER FACILITIES INVOLVED (8) soeu tar inna inna segmumr.
un m zou wams IAY 1mML FACILITY NAMES DOCKET NUMBER (8) unset SONGS _ Unit 3 0
3 0
0 0 L_f__2_
O!4.0! 3 9l 7 9I7 0l0l7 0 l1 0l 7 il 9 9l 7 l
OPERATING TEIs REPomT Is sUmHITTED PURSUANT To TEE REQUIREWENTS oF 10 CFR S:
HODE
- (9)
(CHECK ONE oR MORE OF THE FoLLottING) (11)
PONBR_IJYELy l 0 l 9 l 6 20.4020>)
: 20. 405 (a)
: 50. 73 (a) (2) (iv) 13.71 (b)
_ 20.405 (a) (1) (1)
_ 50. 35 (c) (1)
_ 50. 73 (a) (2) (v)
_ 13.11 (c)
_ 20,405 (a) (1) (11)
_ 50.35(o) (2)
_ 50.73 (a) (2) (vii)
_ other (specify in
: 20. 405 (a) (1) (iii) 1 50.73 (a) (2) (1)
_ 50.73 (a) (2) (viii) (A)
Abatract below and
_ 20. 405 (a) (1) (iv)
_ 50.73 (a) (2) (11)
_ 50.73 (a) (2) (viis) (a) in text)
: 20. 405 (a) (1) (v) 50.73 (a) (2) (111)
: 50. 73 (a) (2) (a)
.a LICENSEE CONTACT FOR THIS LER (12)
TELEPHONE NUMBER NAME AREA code
_E E._Ktteger d i.c=_. President _.Muelear_Gener_ation 7l1 l4 sl6le 6l2lsls t
CCHPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13) causa sTsTEu coxPoNENT wANUrac-REPORTABLE

==CAUSE==
SYSTEM CoWPoNENT MANUFAC-REPORTABLE TURER To NPRL' TURER To NPRDS SUPPLEMENTAL REPORT EXPECTED (14)
EXPECTED MONTH DAY YEAR SUBNISSIoM l
l l
l T:s (If yes, complete EXPECTED SUBMIG8ICH DATE) f X l No DATE (15)
AssTPACT (Limit to 1400 spaces, i.e., approximately fifteen single space typewritten lines.)
(16)
In 1989, Edison revised the surveillance test procedures for performing channel functional tests on the containment purge exhaust radiation monitors. These changes provided an option to not stroke the outside containment valves, but to rely on an l
overlapping test to stroke the valves.
Personnel performing the test thereafter routinely used this option.
Subsequently, Edison determined that the alternative test was not an overlapping test, and that former Technical Specification (TS) Surveillance Requirements (SRs) to test these and other radiation monitors for downscale failure ware not performed.
Bscause the valves were not always verified to isolate the containment purge exhaust pathway in conjunction with the channel functional test, Edison originally reported this occurrence in accordance with 10CFR50.73 (a) (2) (i).
Edison is submitting this supplemental report to provide these subsequent determinations.
Intdequate management of the surveillance test procedure change pr.,ess allowed the procedures to be revised without appropriate review.
Edison did e. recognize the need to deviate from the standard Radiological Effluent TS regarding th. requirement for downscale failure testing. Miscommunication between Edison personnel resulted in an incorrect understanding of the' nature of the violations, requiring submittal of a revised LER.
Edison tested the valves, corrected the procedures, and conducted a review of the TS SRs which revealed no instances of improper or inadequate overlap testing.
Prior to cubmittal of the original report, the TS SR for downscale failure testing had been either relocated to the licensee-controlled Offsite Dose Calculation Manual (oDCM) or otherwise eliminated-from the TS.
Edison revised the ODCM to (1) delete the rcquirement for downscale failure testing, and (2) change the frequency for verifying icolation of the effluent pathway from once per quarter to once per refueling interval.
9707230062 970718 PDR ADOCK O 1_
S u

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LICENSEE EVENT REPORT (LER) TEXT CONTINUATION s
SAN ONOFRE NUCLEAR GENERATION STATION DOCKET NUMBER LER NUMBER PAGE UNIT 2 05000361 97-007-01 2 of 5 Plcnt:
San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 R3cctor Vendor:
Combustion Engineering Ev:nt Date:
April 3, 1997
:- Mode:
both Units were in Mode 1, power operation Power:
Unit 2: approximately 86%; Unit 3: approximately 100%
.T;mperature:
both Units were at normal operating temperature Bickground Th2 containment main purge (VA) and the containment mini purge flowpaths at SONGS 2 and 3 both exhaust to a Unit-specific containment purge stack, which is monitored for Icdioactive r11 eases, normally by radiation monitor (IL) RT7828.
The Unit-specific plcnt vent stack (VL) is normally monitored by radiation monitor RT7865, which can be rccligned to monitor the containment purge exhaust stack.
In the event of (1) detected high activity, or (2) monitoring circuit failure, the radiation monitor aligned to the l
centainment purge stack sends an automatic close signal to 42" outside containment main purge supply and exhaust valves (V) HV9948 and HV9951, and 8" outside containment mini purge supply and exhaust valves HV9821 and HV9825.
(Srparate inside containment airborne radiation monitors RT7804 and RT7807 (IL)
' initiate a Containment Purge Isolation Signal, an engineered safety feature (JE), to close all 8 containment purge isolation valves per Unit (4 inside containment isolation velves, 4 outside containment isolation valves) in the event of a fuel handling cccident_inside containment.)
To ensure compliance with Technical Specification (TS) 3.6.3,
" Containment Isolation Valves," the main purge valves are sealed closed during power operation.
The mini purge valves may be opened intermittently during power operation to maintain containment ambient pressure, to support required personnel entries, or for curve 111ance testing.
Op3 ration of mini purge supply valve 2HV9821 is illustrated in Figure 1 (next page).
Solenoid valve 2HY9821A'repositions upon a high radiation signal from 2RT7828 (or 2RT7865) to vent instrument air from the 2HV9821 actuator, closing 2HV9821.
Prior to 1/12/90, the SONGS 2 and 3 TS for radioactive gaseous effluent monitoring inctrumentation required one channel of containment purge exhaust monitoring instrumentation to be operable at all times, and to be verified operable by a quarterly chtnnel functional test.
This Surveillance Requirement (SR) included a requirement to l
... demonstrate that automatic isolation of this pathway... occurs...."
Edison used procedure SO23-XXV-4.14 (for RT7865) and procedure SO23-XXV-4.50 (for RT7828) to i
parform this surveillance test.
The SR also included a requirement to demonstrate that cutomatic isolation of this pathway occurs when " Instrument indicates a downscale fcilure."
Edison transferred the above requirements unchanged from the TS into the l
licensee-controlled Offsite Dose Calculation Manual (ODCM), as authorized by the NRC in Unit 2 and 3 TS amendments approved on 1/12/90.
B cides RT7828, the radiation monitors listed in Table 1 (next page) also at one time h d TS SRs for downscale failure testing.

i LICENSEE EVENT REPORT (LER) TEXT CONTINUATION SAN ONOFRE NUCLEAR GENERATION STATION DOCKET NUMBER LER NUMBER PAGE 1
ggI.T 2 05000361 97-007-01 3 of 5 20t-57 b
Clas a m S 9 - V '
% ---6 CPIS CLOSES SI AS CLOSES 9 ---"
r - - - + - - -1 2RY-7828 1
1 I
I Iy] M 2PI' i
82 98 l
d3 tg C
INSTf4UMENT AIR qr 2/3CR-oe V
M.,, M M
v-
$._?
N "Y
v' N-rc i
l FIGURE 1, 2HV9821 OPERATION TABLE 1 Liquid Radwaste Effluents Line 2/3RT7813 l
Steam Generator Blowdown (Neutralization Sump) Effluent Line 2(3)RT7817 l
Turbine Building Sumps Ef fluent Line 2(3)RT7821 l
Steam Generator (E088) Blowdown Bypass Effluent Line 2(3)r ;759 l
Steam Generator (E089) Blowdown Bypass Effluent Line 2 ( 3 ) RT., '53 l
Waste Gas Holdup System 2/3RT7808 2(3)RT7865 Condenser Evacuation System 2(3)RT7818 2(3)RT7870 Plant Vent Stack 2/3RT7808 2(3)RT7865 Weste Gas Holdup System 2/3RT7814*
l Containment Purge System 2(3)RT7804*
l Containment Airborne 2(3)RT7804 2(3)RT7807 "Rtmoved from the TS by Amendments 31 and 20 approved by the NRC 1/11/85.
l

f.
LICENSEE EVENT REPORT.(LER) TEXT CONTINUATION
~
SAN OWOFRE NUCLEAR GENERATION STATION DOCKET NUNBER LER NUMBER PAGE UNIT 2 05000361 97-007-01 4 of 5'
' Description of Event on 1/23/89 and.2/28/89, Edison revised procedures SO23-XXV-4.50 and SO23-XXV-4.14,
.respectively, to provide the user with an option to not stroke the outside containment
. main'and mini purge valves (HV9821, HV9825, HV9948, and HV9951) if the valves were
" inoperable /out of service." Instead, the procedure provided the option to verify that the control logic actuated the relay (RLY) contacts for valve closure.- A separate inservice test verified that the valves stroked closed.
l
:- Parsonnel performing the channel functional test thereafter routinely used.the procedure option to verify relay contact actuation without actually stroking the volves.
Between the date of the first procedure revision (1/23/89) and the date the rsquirement was authorized to be removed from the TS (1/12/90), the valves were not always verified to isolate the containment purge exhaust pathway i'n conjunction with ths quarterly channel functional test.
On 4/3/97. an NRC inspector identified this condition.
Edison submitted LER'2-97-007 in accordance with 10CFR50.73 (a) (2) (i) to report this condition.
Subsequently, Edison initiated an internal review and determined on 6/26/97 that: (1) ths inservice test credited with verifying automatic isolation of the effluent pathway i
did not verify operation of the radiation monitor solenoid valves (2HY9821A in Figure
: 1) and was not an overlapping testi and (2) the RT7828 radiation monitors do not have a downscale failure alarm, so that the SR to verify automatic isolation upon a downscale failure was not being performed.
Additionally, Edison determined the radiation monitors in Table 1 do not have downscale failure alarms. Edison noted that the Table 1 monitors had, in the past, been required by the Ts to be surveilled for downscale failure. Because the Table 1 monitors do not exhibit downscale failure and could not be surveilled as required, on 7/7/97 Edison management concluded a report for a missed TS surveillance was required.
Edison noted j
. that as of the original 4/23/97 submittal date of this report, the TS SR for downscale failure testing of the Table 1 monitors had been either relocated to the ODCM or otherwise eliminated from the TS.
Edison concluded that there has been no contemporary failure to meet TS surveillance requirements.
Edison is submitting this supplemental report to provide these investigation results.

==Cause of the Event==
Inadequate management (cognitive personnel error - utility) of the surveillance test procedure change process in 1989 allowed the procedures to be revised without appropriate review.
When adopting the standard Radiological Effluent TS (NUREG-0472) at the time of plant otartup (circa 1982),. Edison-(cognitive personnel error - utility) apparently did not rGcognize the need to deviate from NUREG-0472 regarding the requirement for downscale
. failure testing.
Miscommunication (cognitive personnel error - utility) between the technical engineers cnd personnel performing the reportability-investigation /LER-preparation resulted in an i
incorrect understanding of the nature of the violations, requiring submittal of a rovised LER.

==Corrective Actions==
Edison tested valves HV9821 and HV9825 as required.
Edison corrected procedures SO23-XXV-4.50 and SO23-XXV-4.14.
Edison believes'that improvements made subsequent to this 1989 event' strengthen the process for revising surveillance test procedures to the extent'that further program enhancements are.not required.

6
~~
1 LICENSEE EVENT REPORT (LER) TEXT CONTINUATION SAN ONOFRE* NUCLEAR GENERATION STATION DOCKET NUMBER LER NUMBER PAGE UNIT 2 05000361 97-007-01 5 of 5 Edison conducted a review of the TS SRs as documented in LER 2-97-001 Revision 3, which ravealed no instances of improper or inadequate overlap testing.
For the reasons cited in the Safety Significance section below, Edison revised the ODCM to delete the requirement for downscale failure testing.
Edison also changed the frequency for verifying isolation of the effluent pathway from once per quarter to once par refueling interval.
Snfety Significance Edison believes that the' Containment Purge Isolation Systems for Units 2 and 3 remained functionally operable during periods of containment purge ventilation in 1989, providing a backup to the containment purge exhaust stack monitor.
Contcinment purge supply and exhaust valves HV9821, HV9825, HV9948 and HV9951 are in Edison's in-service testing program and are periodically stroke tested.
The inservice tact results indicate the valves were, in fact, operable during the period in question end could have been closed manually if required. When tested, the effluent isolation colenoid valves (2HY9821A, e.g.) operated satisfactorily.
Additionally, Edison has determined that plant vent stack radiation monitors 2(3)RT7865, condenser evacuation system monitors 2(3)RT7870, and blowdown bypass effluent line monitors 2(3)RT6753 and 2(3)RT6759 will not fail downscale due to high rediation conditions.
The RT7865 instruments are designed to cover the range of crcdible source terms in NUREG-0737, " Clarification of TMI Action Plan Requirements,"
and Regulatory Guide 1,97; a source term greater than the design maximum is not crsdible.
The RT7870 instruments are bounded by the RT7865 source term analysis.
Edison has calculated that the maximum credible steam generator activity would be within the range of the RT6753 and RT6759 instruments. Therefore, downscale failure of these monitors due to high radiation conditions is not credible.
Edison has proven by test that the remaining Table 1 monitors and containment purge stsck monitors 2(3)RT7828 are not susceptible to downscale failure due to high radiation conditions during normal operation and anticipated operational occurrences.
Therefore, there was no safety significance to this event.
l

==Additional Information==
During the last 3 years, Edison has reported the following instances of missed TS surveillances due to test procedure errors:
LER 2-94-002-01 reported missed fire protection surveillances due to inattention to dstall during procedure revisions in 1988 and 1992.
LER 2-94-003-01 reported missed fire protection surveillances due to individual incttention to detail and lack of management oversight during procedure revision processes in 1984 and 1989.
LER 2-96-009-01 reported missed diesel generator surveillances due to an inadequate tect procedure developed in 1983.
Escause the errors reported in this LER predated the submittal dates of the above raferenced LERs, previous corrective actions could not have prevented the occurrence r ported herein.
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