ML19324B112

LER 89-022-00:on 890925,discovered That Inservice Test Surveillance Required Stroke Time Testing of HPSI Pump Inlet Isolation Valves in Wrong Direction.Caused by Transcription Error.Surveillance Procedure changed.W/891025 Ltr

ML19324B112
Person / Time
Site:	Millstone
Issue date:	10/25/1989
From:	Cardillo A, Scace S NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-89-022, LER-89-22, MP-13659, NUDOCS 8911010025
Download: ML19324B112 (4)

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PS-13659 i Re: 10CFR50.73(a)(2)(i) l U.S. Nuclear Regulatory Comminion Document Control Desk Washington, D.C. 20555 q h

Reference:

Facility Operating License No. NPF-49 ,.

Docket No. 50-423 Licensee Event Report 89-022-00 i Gentlemen:

This letter forwards Licensee Event Report 89-022-00, required to be submitted within -

thirty (30) days pursuant to 10CFR50.73(a)(2)(i), any operation or condition prohibited by the Plam's Technical Specification.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPAhT I Stephen E. Scace  !

Station Superintendent Millstone Nuclear Power Station l

SES/AAC:tjp  !

Attachment:

LER 80-022-00 i ec: W. T. Russell, Region 1 Administrator l W. J. Raymond, Senior Resident Ins >ector, Millstone Unit Nos.1, 2 and 3 .

D. H. Jaffe, NRC Project Manager, Millstone Unit No. 3  !

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~'l ves sie v.s. oom.i. Exetetto sueu ssioN oAtti kl No N DE l l l AestnAc, rumn to i.co so. .s. . .. . co oum.i.g tift , sinci.-so.c. tro.wntten an.s> Dei On September 25,1969 at 1215, in Mode 1 at 100"c power, 566 degrees and 2250 psia, it was discovered that an Inservice Test (IST) Surveillance, required stroke time testing of the High Pressure Safety Iniection (S!H) Pump Inlet Isolation vah'es in the wrong direction (CLOSE to OPEN vice OPEN to CLOSE). The

, discovery was rnade during a routine review of surveillance data. Immediate action was to pctform the l stroke time test in the proper direction (i.e., OPEN to CLOSE) which was satisfactorily completed.

The root cause of the esent was a transcription error when writing the surveillance procedure. The stroke direction which was properly identihed in the IST Manual, was incorrectly stated in the procedure and was not identified during the procedure review process.

The associated surveillance procedure was changed to reflect the correct stroke direction for the valves. A review of all IST stroke time test direction requirements versus the stroke time test procedures has been completed. No other reportable dehtiencies were identified. One non-reportable discrepancy was identified. The IST program was updated to reflect the proper stroke direction identihed in the surveillance procedure.

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]. Descrmtinn nf Event ,

On September 25,1969 at 1215, while in Mode I at 100% power, $66 degrees Fahrenhen and i 2250 psia, an Inservice Test (IST) techmcian discovered that a Plant Technical Specification r

surveillance was not correct. The High Pressure Safety injection (SlH) Pumps Inlet (motor

• l operated) Isolation valves. 3SIH'M\'8923A & B, were bemp stroke time tested in the wrong direction (i.e., CLOSE to UPEN vice OPEN to CLOSE). The discovery was made during a routine

review of previously performed surveillance data. Immediate action was to perform the stroke time  !

lest in the proper direction (i.e., OPEN to CLOSE). The *as found" stroke time met the acceptance entena.

II. Came of Event The root cause of the event was a transenption error when wnting the procedure. This was not identified during the review of the associated surseillance procedure. During the mitial deselopment of the IST manual, the proper stroke direcuon for the subject valves was identified, in developing the surveillance procedures to implement the stroke test requirements, the stroke direction for the subject valves was incorrectly stated. This was a transenption error in wnting the surveillance i procedure which was not discovered during the procedure review process.

111. Ann)vois of Frent This esent is being reported in accordance with 10 cit 30.73(a)(2)(i), because the Technical Specification surveillance requirements were not properly performed. Technical Specification 1.0.5 requires iraplementation of the IST program m accordance with ASME Section XI, as identified by 10CFR50.55(a)(g).

3SlH'M\'8903A & B are normally open pate valves. Each valve is required to remain open dunng the injection phase of a Lors of Coolant Accident. The valves are closed by an operator to isolate a pump in the event of a passive failure of SlH pump suction piping. Ahhough the OPEN to CLOSE stroke time test was not being performed, the abihty of the valves to isolate the SlH pump suction lines was not degraded. The valves were being stroked OPEN to CLOSE even though the stroke r times were not logged or trended. As a result, reasonable assurance was available that the valves would stroke closed. This was verified by subsequent testing. Therefore, this event had no adverse safety consequences.

l \'. Correcthe Action As immediate corrective action 3SlH'M\'6923A & B were satisfactorily stroke time tested in the

- CLOSE direction.

To prevent recurrence of a similar event, the proper stroke test direction was incorporated into the quarterly SlH valve stroke test suncillance procedure. A review of the IST program stroke time test direction requirements versus the stroke time test suncillance procedures has been completed.

Another discrepancy was idenufied during this review. The IST program identified 3SlH'M\'8635, ,

the SlH Cold Leg isolation valve, to be full stroke tested in both the OPEN and CLOSE directions.

The surveillance procedure tested the valve in the CLOSE direction only. This valve is normally open with power locked out to provide a flow path for cold leg injection and is positioned closed when shifting to hot leg iniection. 3SlH'M\'6635 should therefore be stroke time tested in the CLOSE direction. The IST Manual will be revised to reflect the correct stroking requirements.

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- \' . Addninnal Informntinn Licensee Event Reports previously submitted which concern improperly performed surveillances are: ,

LER Number Subtect t

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j $6-034 Radiation hionitor Sampler Flow  ;66-047 OTdeltaT Setpoint f

, 66-0$3 Intermediate Range Detector Setpoints  !

I '66-058 Radiation hionitor Surveillance 67-035 Containment Air Lock ,

f 67-042 hiissed intermediate Range / power Range Surveillance t

$7-045 Failure To Sample Diesel Fuel Oil for Kinematic Viscosity

$$-020 Improper Bypass Breaker Suneillance

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$9-006 hiissed Fire Detector Surveillance on Six Fire Detectors

• 69-021 hiiscalculation of Engineered Safety Features Response Time Due to  ;

Procedural Inadequacy >

i A review of Technical Specifications surveillance requirements versus surveillance procedures was i performed as corrective action for LER 67-042-01. This review was completed on December 15.

• 1968. LER 66-020 was submitted to document an inadequate surveillance imerval for the Reactor  :

Trip Bypass Breakers. This inadequacy was identified dunng the review process. As corrective '

action, the surveillance was updated to reflect the required surveillance mierval. LER 89-006, t which was reported after completion of this review. identified a deficient fire detector surveillance  :

on six (6) hre detectors. As corrective action for this LER, a comprehensive review of the Fire  !

Detection and Control System surveillances verifying Technical Specification requirements was t performed. Only minor deficiencies were identified and have been addressed. LER 69-021, was  !

submitted to identify a lack of an adequate slave relay response time testing surveillance. The  ?

deficient procedure was identified dunng the surveillance review discussed in LER 67-042-01. }

However, the requirement to response time test slave relays was not incorporated into a subsequer.t  !

revision of the surveillance. The surveillance will be corrected prior to performance and a review i was performed to verify all other comments for the surveillance were incorporated.

The deficiencies identified in this LER were not discovered during the Technical Specification  !

surveillance review because the scope of the review was hmited to the requirements of the ,

Technical Specifications versus surveillance procedure acceptance enteria. The source of tne IST 3 hianual requirement to test the subject valves were the Unit's FSAR rather than the Technical  ;

Specifications. Neither the IST hianual nor the FSAR were used as a cross-senfication during the Technical Specification surveillance review. A subsequent review of the IST hianual and the FSAR versus surveillance procedure stroke time test direction requirements has been completed with the resuhs noted in the corrective action section of this LER.

EllR Codes Systems Comnnnem t I,

i High Pressure Safety injection isolation Yahe - ISV I System - BG t NRC Form 366A 16-89 L