ML19351A458

LER 89-034-00:on 891108,determined That Reactor Pressure Exceeded 150 Psig on 891107 W/O Performing Surveillance Procedure 8.5.4.4, HPCI Valve Operability Test. Caused by Personnel Error.Procedure initiated.W/891206 Ltr

ML19351A458
Person / Time
Site:	Pilgrim
Issue date:	12/06/1989
From:	Bird R, Lunn B BOSTON EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
89-173, LER-89-034, LER-89-34, NUDOCS 8912180042
Download: ML19351A458 (5)

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U 9-80STON SDfSOV Pilgrim Nuclear Power station Rocky Hill Road Plymouth Massachusetts 02360

L Ralph G. aird

. senior Vice President - Nuclear December 6, 1989-E BECo Ltr. 89- 173

.U.S.-Nuclear Regulatory Commission 'i Attn: Document Control Desk Washington, D.C. 20555

- Docket No. 50-293 License No. DPR-35

Dear Sir:

The enclosed Licensee Event Report (LER) 89-034-00 " Missed High Pressure Coolant Injection System.Hotor Operated Valve Surveillance During Plant Startup" is submitted in accordance with 10 CFR Part 50.73.

Please do not hesitate to contact me if there are tiny questions regarding this report.

. G. Bird 1

BPL/bal

Enclosure:

LER 89-034-00 cc: Mr. William Russell Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Rd.

King of Prussia, PA 19406 i

Sr. NRC Resident Inspector - Pilgrim Station Standard BECo LER Distribution l

l 8912180042 891206 76'2 2.

PDR ADOCK 05000293

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LICENSEE EVENT REPORT (LER) ' " a ' 8 ' '8' '

l F ACILITY NAME til DOCKET NUMBER (2) l PAGEi3+

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j, i** Missed High Pressure Coolant Injection System Motor Operated Valve Surveillance l During Plant Startup EVENT DAT'4153 LER NUMBER t6) REPORT DATE (7) QTHER F ACILITIES INVOLVED (St SE GU 1AL RE V DAY F ACILIY v 9eAMES DOCAE T NUVSENISI MONTH DAY YEAR YEAR gg , MONTH YE AF1 N/A oisl0lolo[ l l

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1l 1 0l 7 8 9 8l9 0l 3l4 0l0 3l2 0l6 8l 9 N/A 0l510 to1 0 i l l

& EPORT 18 SUBMITTED PURSUANT TO THE REQUIREMENTS 0810 CF R 5 (Chere one or more of ,he fonowing/ 01)

OPE R ATING MODE 19) N 20 402imi r0 40swi so.73= H2 Hl. 73.71 <*l ER 70.406 teH1H!t 50.36kHil 60.734 alt 2Hvl 73 711al (101 0l Oi 1 *0 mie Hi Hui 30 3ewH2>

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. to 406(eHiltvl 50.73mK2Hilil 60.73(eH2Hal LICENSEE CONTACT FOR THl3 LER O2)

NAME TE LEPHONE NUM8tR ARE A CODE Brian P. Lunn - Sr. Plant Engineer 510l8 7l4l7i -l812 l411 COMPLETE ONE LINE FCR E ACH COMPONENT F AILURE DESCRIBED IN THit REPORT (131

• • C- ORiA LE CAUSE Sv8 TEM COMPONENT MA AC- REPORTA LE CAUSE $YSTEM COM* 0NE NT y pp s I I I I I I i l I i I i l l I I I I I I I I I I I I l l 1

$UPPLEMENT AL HEPORT EXPECTED tid) MONTH DAY YEAR 4ES lif ves. coenote,e EXPECTED SV0 MISSION DA TEl kO l l l Ann ACT a-, ,. ,~ a . . .,,,. ~, n ,, . n en.., n.)

During a routine review of the Master Surveillance Tracking Program (MSTP) schedule, on November 8, 1989, it was found that reactor pressure had exceeded 150 psig on November 7, 1989, without performing surveillance Procedure 8.5.4.4, "HPCI Valve Operability Test". The High Pressure Coolant Injection (HPCI) System is required to be operable when reactor pressure is greater than l 150 psig. The HPCI System motor operated valve operability surveillance required to be performed montnly per Technical Specification (T.S.) 4.5.C.1.c had become overdue during a plant shutdown that began on October 13, 1989.

Therefore, the HPCI System motor operated valve operability was required to be reestablished prior to exceeding the plant conditions requiring HPCI l operability. The plant had commenced startup from a planned shutdown on November 6, 1989. When the missed surveillance was identified, reactor power was at 31., and reactor vessel pressure was approximately 930 psig.

The missed T.S. surveillance was caused by personnel error.

Procedure 8.5.4.4 "HPCI Valve Operability Test" was successfully completed on l November 8, 1989.

Senior Plant Management discussed the missed surveillance with the Operations l

Section Staff and stressed the importance of performing required surveillances I in accordance with the Master Surveillance Tracking Program schedule.

The missed surveillance had no potential to adversely impact the public health

( and safety.

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LICENSEE EVENT REPORT (LER) TEXT CONTINUATION mRovio ov8 =o. ano-oio4 (KPtRES. 8/31'88 P ACI4if V NAmt til DOCKET NUMain (21 LtR NUM8ER 161 Pact (3)

"*" W.'. ' "*1*,0 Pilgrim Nuclear Power Station o 5 l0 l0 l0 l 2l9 l 3 8l9 -

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0l0 0l2 oF 0 l 4, nxm .-. . , w. ec i asse,mn EVENT DESCRIPTION During a_ routine Systems Engineering review of the Master Surveillance Tracking Program (MSTP) schedule on November 8,1989, it was found that-reactor pressure had exceeded 150 psig on November 7, 1989, without performing i surveillance Procedure 8.5.4.4, "HPCI Valve Operability Test". Technical l Specification (T.S.) 3.5.C.1 requires the High Pressure Coolant Injection l (HPCI) System to be operable whenever irradiated fuel is in the reactor vessel, reactor pressure is greater than 150 psig and reactor coolant temperature is greater than 365* Farenheit. T.S. 4.5.C.l.c requires a HPCI System motor operated valve operability surveillance once per month when HPCI is required to be operable. The HPCI System motor operated valve operability  ;

test was previously performed on September 20, 1989. On October 13, 1989, the plant was shutdown for a scheduled outage. While shutdown, the monthly interval plus 25% (allowed adjustment for T.S. surveillances) was exceeded.

'Because the surveillance interval was exceeded, motor operated valve operability needed to be reestablished prior to exceeding the plant conditions requiring HPCI operability, j REPORTABILITY The missed "HPCI Valve Operability Test" resulted in operations prohibited by the T.S. and is reportable per 10 CFR 50.73(a)(2)(i)(B). Failure and Halfanction Report 89-432 was written on November 8,1989, upon identifying the missed surveillance.

PLANT CONDITION The plant had commenced startup from a planned shutdown on November 6, 1989.

The missed surveillance was identified on November 8,1989, at approximately 0930 hours0.0108 days <br />0.258 hours <br />0.00154 weeks <br />3.53865e-4 months <br />. At the time of discovery, reactor power was at 3%, the reactor mode selector switch was in the STARTUP position, reactor vessel pressure was approximately 930 psig and reactor coolant temperature was approximately 525 degrees Farenheit. The plant conditions requiring HPCI operability were exceeded on November 7, 1989, at approximately 0600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br />. I CAUSE The missed T.S. surveillance was caused by a cognitive personnel error by the on-shift Nuclear Hatch Engineer (Licensed, Senior Reactor Operator).

The Master Surveillance Tracking Program (MSTP) identifies required T.S.

surveillances and when they are due. A MSTP schedule is issued weekly. A master copy of the schedule is maintained in the Control Room Annex and is signed and dated by the surveillance performer when work is complete.

On October 27, 1989, a change was made to the MSTP to require Procedure 8.5.4.4 "HPCI Valve Operability Test" be performed at 150 psig. The change '

was made because with the plant shutdown, HPCI System operability was not required. Therefore, the test scheduled for October 28, 1989, was not required. The test was required to reestablish HPCI System operability prior to exceeding 150 psig.

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LICENSEE EVENT REPORT (LER) TEXT CONTINUATION ApeRovto oue no siso-oio4 l EX PtRES: $ ^31/WI f ACIUTY NAME (4 DOCKti NUMBER (25 - ggR NUMBE R ($1 PA06 (3) n** "MW M*u:

Pilgrim Nuclear Power. Station oF o l5 l 0 l 0 l 012 l 913 819 --

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0l0 0l3 0 l4 The MSTP weekly schedule, as well as the daily outage work schedule, properly scheduled the required HPCI System surveillances. Procedure 8.5.4.1, "HPCI Pump and Valve Monthly / Quarterly Operability" was scheduled at 1000 psig.and Procedure 8.5.4.4 "HPCI Valve Operability Test" was scheduled at 150.psig.

Both of the above procedures meet the requirements for testing motor operated ,

valves as specified in T.S. 4.5.C.I.c. Upon review of the scheduled surveillances, the Nuclear Watch Engineer questioned the need to test the HPCI System valve operability at both 150-psig and 1000 psig, as this was not the normal practice. The Hatch Engineer mistakenly decided that only one of the procedures (8.5.4.1 or 8.5.4.4) needed to be performed. The test scheduled for 1000 psig was selected to be performed because it was considered more of a challenge to the valves opening and closing times. In making this decision, the Hatch Engineer did not recognize that the due date for-the HPCI System valve operability surveillance had been exceeded while the plant was shutdown and the implication regarding T.S. compliance (the need to establish HPCI System motor operated valve operability prior to exceeding 150 psig).

INITIAL CORRECTIVE ACTIONS TAKEN

• Upon identifying the missed surveillance, Procedure No. 8.5.4.4, "HPCI Valve Operability Test" was initiated and a Limiting Condition for Operation (LCO) A 89-141 was issued.

• Procedure No. 8.5.4.4 was completed at 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> on November 8,1989, and LCO A 89-141 was cleared.

CORRECTIVE ACTIONS TAKEN TO REDUCE THE POSSIBILITY OF FUTURE SIMILAR EVENTS

• A Meeting was conducted on November 14, 1989, with the Senior Vice President Nuclear, Vice President Nuclear Operations / Station Director, Plant Manager, Operations Section Manager, Chief Operations Engineer, the Nuclear Hatch Engineers and the Nuclear Operations Supervisors to discuss the missed surveillance and the importance of adhering to the MSTP.

• As an additional measure to assure required surveillances are performed, Procedure 1.3.34 " Conduct of Operations" is being revised to require the Shif t Technical Advisors (STAS) to review the MSTP schedule and identify on the STA turnover sheet the surveillances that are required for the upcoming shift.

ADDITIONAL ACTIONS BEING CONSIDERED e A revision to Procedure 2.1.1 "Startup From Shutdown" is being considered. The revision would provide a checklist to trigger the performance of the surveillances required for specific operating condition plateaus.

SAFETY CONSE0gENCES Procedure No. 8.5.4.4 "HPCI Valve Operability Test" was successfully completed at 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> on November 8,1989. No maintenance action was necessary.

Therefore, the HPCI valves were operable when required. There was no potential to adversely impact the public health and safety, gag ,,o u u j

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" ym astA U.S. NUCLEAR C'E!ULATORY COMMIS$10N LICENSEE EVENT REPORT (LER) TEXT CONTINUATION maovio ove No. mo-oio.

EXPIRf S. 8/316

1. ActLeiv NAmt til p0CKit NUMetR (29 LER NUMSIR (6) PA04 0)

TIA" as a veYn Pilgrim Nuclear Power Station 0F 0 l5 l 0 l 0 l 0 l 219 l 3 El 9 -

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-Q 0 0l4 0 l4 Texi ,,,, . , w. e w we i.-, asse w on PREVIOUS SIMILAR REPORTABLE EVENTS A review of Licensee Event Reports (LERs) since 1984' identified the following events wilere a surveillance test scheduled by the MSTP was not performed within the required interval.

• LER 88-009-00 reported that dccumentation could not be found to j confirm the performance of a once per cycle test of the "B" Emergency l Diesel Generator.  !

• LER 85-016-00 reported that the weekly analysis for gross ,

radioactivity of the reactor building vent particulate filter had not l been performed.

• LER 85-005-00 reported a missed Rod Block Monitor functional and calibration surveillance. The surveillance interval for the Rod Block Monitor had been exceeded when the plant was shutdown and was not performed when required at 30% reactor power, i ENERGY INDUSTRY IDENTIFICATION SYSTEM (EIIS) CODES The EIIS codes for this report are as follows:

COMPONENTS CQDIS Valve V SYSTEMS High Pressure Coolant Injection System BJ l

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NAC FORM 368A

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