ML18016A321

LER 98-002-00:on 980121,solid State Protection Sys Testing Deficiency Occurred.Caused by Inadequate Review of Initial Tech Specs.Ts Testing Frequency for P-11 Permissive Revised. W/980217 Ltr

ML18016A321
Person / Time
Site:	Harris
Issue date:	02/20/1998
From:	Donahue J, Verrilli M CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HNP-98-014, HNP-98-14, LER-98-002, LER-98-2, NUDOCS 9802240350
Download: ML18016A321 (10)

Text

CATEGORY 1~REGULATORY INFORMATION DISTRIBUTION; SYSTEM (RIDS)f ACCESSION NBR:9802240350 DOC.DATE;98/02/20 NOTARIZED:

NO DOCKET FACIL:50-400 Shearon Harris.Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH.NAME AUTHOR AFFILIATION VERRILLI,M.

Carolina Power&Light Co'.DONAHUE,J.W.

Carolina Power&, Light Co.RECIP.NAME RECIPIENT AFFIL'IATXON

SUBJECT:

LER 98-002-00:on 980101,solid state protection sys testing deficiency occurred.Caused by inadequate review of initial Tech Specs.TS testing frequency for P-11 permissive revised.W/980217 ltr'.DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE!TITLE: 50,.73/50.9 Li.censee Event Report (LER), Incident Rpt,~etc.RECIPIENT 1D CODE/NAME PD2-1 PD COPIES RECIPIENT LTTR ENCL ID CODE/NAME 1 1 FLANDERS,S NOTES:Appli.cation for permit, renewal,fi.led.

COPIES LTTR ENCL 1 1 (05000400(vl (INTERNAL: ACRS AEOD/SPD/RRAB NRR/DE/ECGB NRR/DE/EMEB NRR/DRCH/HXCB NRR/DRCH/HQMB NRR/DSSA/SPLB RES/DET/EIB EXTERNAL: L ST LOBBY WARD NOAC POORE,W.NRC PDR 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 m~~sg ENTE DX/EELB NRR/DRCH/HHFB NRR/DRCH/HOLB NRR/DRPM/PECB NRR/DSSA/SRXB RGN2 FILE 01 LITCO BRYCE,J H NOAC QUEENER,DS NUDOCS FULL TXT 2 2'1 1, 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE~TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION L1ST OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTRO DESK (DCD)ON EXTENSION 415-2083 FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUXRED: LTTR 25 ENCL 25

CP&l 0~4 Carolina Power 8 Light Company Harris Nuclear Plant Po 8ox 165 New Hill NC 27562 FEB 1 7 1998~~U.S.Nuclear Regulatory Commission ATTN: NRC Document Control Desk Washington, DC 20555 Serial: HNP-98-014 10CFR50.73 SHEARON HARRIS NUCLEAR POWER PLANT UNIT 1 DOCKET NO.50-400 LICENSE NO.NPF-63 LICENSEE EVENT REPORT 98-002-00 Sir or Madam: In accordance with 10CFR50.73, the enclosed Licensee Event Report (LER)is submitted.

This LER describes a Solid State Protection System testing deficiency that resulted in a violation of Technical Specification required surveillance testing.Sincerely, J.W.Donahue Director of Site Operations Harris Plant Zq i 1-" Enclosure~-<2 OF 3 EVENT DESCRIPT)OK:

On January 21, 1998, with the plant at approximately 100%power in Mode 1, Harris Plant Engineering personnel determined that Westinghouse Nuclear Safety Advisory Letter (NSAL)9711 was applicable to the HNP Solid State Protection System (SSPS).This NSAL notified the industry that the current SSPS design did not allow for complete overlap testing of the P-11 (Pressurizer Low Pressure)Permissive.

Specifically, the monthly Analog Channel Operational Test (ACOT)required by Technical Specification (TS)4.3.2.1 Table 4.3-2 Item 10a for the P-11 function could not be adequately performed at power.The P-11 Permissive, provides the following functions below 2000 psig;(1)allows low pressurizer safety injection to be blocked, (2)allows steamline low pressure safety injection to be blocked, (3)blocks automatic operation of the pressurizer power operated relief valves, (4)blocks the automatic open signal for the safety injection accumulators, (5)enables Main Steam Isolation on high steam pressure rate decrease, NSAL 97-011 explained that the capability to test the P-11 Permissive from the process protection system at power is limited to the setpoint and does not include the overlap to the SSPS logic input relay since the bistable test switch is opened prior to testing the channel.Opening the bistable test switch is required by the SSPS system design to satisfy the test logic for safety injection.

Since the SSPS input relay is de-energized above 2000 psig pressurizer, opening of the bistable test switch does not allow the input relay to change state during bistable setpoint verification; and therefore, complete overlap testing for the SSPS input relay is not accomplished.

At 1025 hours0.0119 days <br />0.285 hours <br />0.00169 weeks <br />3.900125e-4 months <br /> on January 21, 1998, this condition was determined to be a violation of TS surveillance requirement 4.3.2.1 due to inadequate past testing of the P-11 Permissive.

TS 4.0.3 was entered at this time to allow proper P-11 testing.NSAL 97-011 recommended that a Technical Specification change be initiated to revise the ACOT surveillance frequency to"Refueling" based on relay reliability and consistency with other Reactor Protection System permissive signals.Alternately, a modification was also recommended to allow failing of the P-11 function low for testing.HNP initially elected to revise the surveillance procedure to fail the P-11 low by lifting transmitter leads.However, during a Hams Plant Engineering review of the proposed procedure changes intended to implement the recommended testing, a potential unreviewed safety question was identified per 10CFR50.59.

This potential unreviewed safety question was related to the failure to comply with single failure criterion of IEEE Standard 338(1971), while in the temporary test configuration.

Based on this concern, it became apparent that testing would not be completed within the allotted 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per TS 4.0.3;therefore, P-11 was declared inoperable.

A comprehensive TS surveillance procedure review project is currently in progress to support HNP's conversion to the new Westinghouse Improved Standard Technical Specifications.

This project had not reviewed the surveillance procedures associated with P-11 testing when this condition was identified.

Review of this section of TS and the corresponding surveillance procedures are currently scheduled to begin in mid 1998.6 CAUSE: This condition was caused by an inadequate review of initial Technical Specifications for consistency with other permissive signals and the capability for testing SSPS permissive signals at power.The TS testing frequency for the P-6, P-7, P-8, P-10 and P-13 permissives, which have the same relay reliability, are"once per refueling outage," which would allow testing while shutdown.

E't NRC FORM 666A 1486)LICENSEE EVENT REPORT (LEB)'EXT CONTINUATION 0 US NUCKla REGULATORT COMMISSION lI'FACIUTT NAME (I)Shearon Harris Nuclear Plant~Unit fl OOGNET 50400.LER NUMBER 16)TEAR SEOUENTIAL NET)SION NUMBER NUMBER 98-002-00 PAGE 6))'3*OF" 3 TEXT Irr mn s)ssst Fs sFSaasL sssd id%')ssal copies oMRC hnss 36@I (IT)SAFETY SIGNIFICANCE:

There weie no actual safety.consequences associated with the failure to provide complete overlap testing for the P-11 perimssive function.The inability to completely test;the.P-11'function above 2000 psig pressurizer'pressure would potentially cause an inoperable SSPS input relay to remain undetected until pressurizer pressure drops below 2000 psig.If this inoperability existed, the operators would not be able to manually block safety injection.

This would be~operational concern, but not a safety issue.Additionally, the reliability of the SSPS input relaysshas been excellent.

There have been no failures of the 258 input relays in 10 years of operation.

i'his event is being reported.as a condition prohibited by TS per 10CFR50.73.a.2.i.B.

'")'REVIOUS SIMILAR EVENTS: LER 97-24 was submitted to the NRC on December 18,:1997.This LER also reported a SSPS testing'deficiency, but was specifically related to a logic card failure scenario.Therefore, the corrective actions completed for.LER 97-24 would not have been expected to identify'the P-11 overlap testing issue.CORRECTIVE ACTIONS PLANNED: 1.A revision to Technical Specification 4.3.2.1 Table 4.3-2 Item 10a will be developed and submitted to the NRC.This revision will change the P-11 and not P-11 ACOT to a"Refueling" frequency.

This will be completed by April 30, 1998.

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