ML20029D253

LER 94-008-00:on 940329,discovered That Data in OPS Form 2604P-2,was Recorded Incorrectly.Caused by Program Failure, Procedure Deficiencies & Technical Error.Corrective Action: Recalculated ESF Equipment Circuit response.W/940428 Ltr

ML20029D253
Person / Time
Site:	Millstone
Issue date:	04/28/1994
From:	Haynes H, Temple W NORTHEAST NUCLEAR ENERGY CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-94-008, LER-94-8, MP-94-288, NUDOCS 9405040325
Download: ML20029D253 (5)

Text

{{#Wiki_filter:. _ _ - - - . . - . . . - . . - - . - .- d Nortlicasi nope Ferry ad. (noute 156), waterford, cT 06385 N,uelear Energy Millstone Nuclear Power Station Northeast Nuclear Energy Company

                   -                                                              P.O. Box 128 Waterford, CT 06385-0128 4

(203) 444 - 4300 l Fax (203) 444-4277 ) The Northeast Utilities System - Donald B. Miller Jr., Senior Vice President - Millstone i ! Re: 10CFR50.73(a)(2)(i)(B)

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i U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555

Reference:

Facility Operating License No. DPR-65 Docket No. 50-336 Licensee Event Report 94-008-00 Gentlemen: This letter forwards Licensee Event Report 94-008-00 required to be submitted within thirty (30) days pursuant to 10CFR50.73(a)(2)(i)(B). Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY FOR: Donald B. Miller, Jr. Senior Vice President - Millstone Station I t p-BY: Harry F. E nes Director - illstone Udt 1 HFH/cle

Attachment:

LER 94-008-00 cc: T. T. Martin, Region i Administrator P. D. Swetland, Senior Resident inspector, Millstone Unit Nos.1,2 and 3 G. S. Vissing, NRC Project Manager, Millstone Unit No. 2 wasn:nn Ot10040

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I l l NRC Form 366 U.s. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104 i . (5-97) EXPIRES: SrJ1/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS PFORMATION [ COLLECTON REQUEST 50 0 HRS FORWARD COMMENTS REGARDING BURDEN ES-E TO mE iN=Am um RECORDS uANAoEuENT LICENSEE EVENT REPORT (LER) BRANCH (MNDB 7714). U S. NUCLEAR REGULATORY COMMISSON. WASHINGTON DC 20555-0001. AND TO THE PAPERWORK REDUCTION (S .w .o ou ., ow. ,a.ci.. . ..c% ""#ETs?d20s * ' ' "^"^ ""'"' ^" "'" "'- FACIUTY NAME (1) DOCKET NUMBER (2) PAGE (3) Millstone Nuclear Power Station Unit 2 05000336 1OF4 TITLE (4) Procedure Data Recording Error for ESF Response Time Test EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8) REVISO FACIUTY NAME DOCKET NUMBER I uONm DAY YEAR YEAR SEQUj MONTH DAY YEAR 05000 FAOluTY NAME DOCKET NUMBER 03 29 94 94 - 008 - 00 04 28 94 05000 i OPERATING THIS REPORT IS BEING SUBMMTED PURSUANT TO THE REQUIREMENTS OF 10 CFR 6: (Check one or more) (11)

           "0D" M                             20 4c2te)                             20 405(c)                          50 73ca)(2)N)                          73 71(b)

POWER 20 4051adi)6) 50 36(c)(1) 50 73f a)m tv) 73 71(c) 20 405(a)(1166 50 36(c)(2) 50 73ta)2)fv10 OTHER 20 405 ajo)m X 50 78t*2m 50 78(**H'^) [$.SMENRC 20 405(a)(1)0v) 50 73(a)(2){li) 50.73(a)(2)(vl4(B) Form 366A) 20 405ta)(1)Ivi 50 73(a)mfu0 50 73(almtr) LICENSEE CONTACT FOR THIS LER (12) NAME TELEPHONE NUMBER finclude Area Code) William J. Temple, Site Ucensing (203) 437- 5904 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13) REPORTABLE REPORTABLE CAUSE SYSTEM COMPONENT MANUFACTURER TO NPRDS CAUSE SYSTEM COMPONENT MANUFACTVRER TO NPRDS SUPPLEMENTAL REPORT EXPECTED (14) "O"* U^* ** EXPECTED YES wo SUBMisslON (if y.s compes EXPECTED SUBMISSON DATE) X DATE (10) ABSTRACT (uma to 1400 spacesa .. app ommatey 15 sog -spaceo typewrmen unes> ps) On March 11,1994, at approximately 1100 hours, with the plant in Mode 1 at 100% power, during a review of response time data records, it was discovered that the data in OPS Form 2604P-2, " Engineered Safety Features Equipment Response Time Testing," was recorded incorrectly. On March 29,1994, the unit's Licensing group determined that this event was reportable as a condition prohibited by the plant's Technical Specifications. On January 11,1993, Operations Department personnel completed SP 2604P, " Engineered Safety Features Equipment Response Time Testing.' One of the data r,heets associated with this surveillance, OPS Form 2604P-2, calculates the circuit response time by totaling the instrument response time, diesel sequence time, and equipment response time. The operators did not consider the equipment sequencing time when they were calculating " diesel sequence time" data on the surveillance form. The form requested " diesel sequencer time" when it should have used the term "DG start and sequencing time." Upon discovery, the response times were recalculated and a new procedure data sheet was completed. The recalculated response times met the acceptance criteria. This test is performed in accordance with Technical Specifications surveillance requirement 4.3.2.1.3. NRC Form 366 (5 - 92)

HRC Form 366A U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-O'iO4 (5-92) EXPlRES: 5/31/95

• S LICENSEE EVENT REPORT (LER) cEEfc588E"Er"

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TEXT CONTINUATION Me" '8JNlB 7IM"'Ec'E ETSRY* "c#*$'s"'oE ou l Ed E N sE d E ' N ["Ew" ENAdr$ 5"E N *ANE* E WASHINGTON, DC 20503 FQCRJTY NAME {1) DOCKET NUMBER Q) LER NUMBER (6) PAGE(3 YEAR [u p yy Millstone Nuclear Power Station Unit 2 05000336 94 - 0 - 00 02 OF 4 TEXT (n more space is esenrad, use addmonal copies of NRC Form 366A) (17)

1. Rescriotion of Event On March 11,1994, at approximately 1100 hours, with the plant in Mode 1 at 100% power, during a review of response time data records, it was discovered that the data in OPS Form 2604P-2, " Engineered Safety Features Equipment Response Time Testing," was recorded incorrectly. On March 29,1994, the unit's Licensing group determined that this event was reportable as a condition prohibited by the plant's Technical Specifications.

On January 11,1993, Operations Department personnel completed SP 2604P, " Engineered Safety Features Equipment Response Time Testing." One of the data sheets associated with this surveillance, OPS Form 2604P-2, calculates the circuit response time by totaling the instrument response time, diesel sequence time, and equipment response time. The data used in OPS Form 2604P-2 is derived from 3 sources:

a. Instrument rcsponse time was calculated using SP 2403, "ESAS Response Time Testing."

b. Diesel sequence time and sequencer loading delays are derived on OPS Form 2613C-1, "ESF Integrated Test." This sun'eillance tests for proper EDG start and energization of emergency buses and permanently connected loads. It also demonstrates the energization of the automatically connected loads by proper operation of the load sequencer. Two data points from l OPS Form 2613C-1 were used in the calculation in OPS Form 2604P-2.

• Diesel start time
• Sequencerloading delays

c. Equipment response time is derived on OPS Form 2604P-1, "ESF Equipment Response Time Testing."

This test is performed in accordance with Technical Specifications surveillance requirement 4.3.2.1.3, which states tha'. the ESF response time of each ESF function shall be demonstrated to be within its limit j every 18 months. The event occurred because the term " diesel sequence time" was not clear to the operators performing the surveillance. They interpreted " diesel sequence time" to be " diesel start time" only. They did not consider the equipment sequencing time when they were calculating " diesel sequence time" data on the surveillance form. The form requested " diesel sequencer time" when it should have used the term *DG start and sequencing time." This 18 month surveillance was also performed on November 10,1990 and April 25,1989. The data on the forms was reviewed for these 2 surveillances and it was determined that the data was correct and the calculations were performed properly. There were no major operator actions required as a result of this event. Additionally, there were no automatic or manual safety system actuations as a result of this event.

11. CauS9mLEvent The root cause for this event was program failure, procedure deficiencies, and technical error. The t

procedure and its associated forms did not provide adequate guidance as to how to calculcte " diesel sequence time." NRC Form 366A (5-92)

NRC Form 366A - U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104 (5-92) EXPIRES: 5/31/95 LICENSEE EVENT REPORT (LER) cec"r&"TEu"/E"E*"Nn"s 70$"EICS"w?I5s'"REIR'E i TEXT CONTINUATION ""2C 'E"'1ISlNE Y E E' EII5IE eR Nee . C o r Y so I 150 0 04) OFFICE OF GE NT AND i WASHINGTON. DC 20503. s FAClUTY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE G YEAR BW N MB Millstone Nuclear Power Station Unit 2 05000336 94 - 0 - 00 03 OF 4 TEXT m more space e regwoo, use addmonal copes of NRC Form 366A) (17) The surveillance procedure did not provide adequate guidance to the operators for the term

• diesel sequence time." The response time calculation section of the procedure did not define the terms used on

the surveillance forms. It basically directed the operators to calculate the response times for thr, appropriate signals using recently completed surveillance data sheets and then verify that the acceptance criteria for the various signals are met. The procedure has been revised as part of the Station Procedure i Upgrade Project. Revision 5 to the procedure, which was approved effective 04/27/94, provie es clearer guidance as to how to perform the surveillance.

t The term " diesel sequence time" was not clear to the operators performing the surveillance,. They interpreted " diesel sequence time" to be " diesel start time" only. They did not consider th s eculpment sequencing time when they were recording " diesel sequence time" data. The data form racwsted " diesel sequencer time" when it should have used the term "DG start and sequencing time" to account for diesel generator starting time and sequencer load delays. 111. Analysis of Event Data for the Engineered Safety Features Response time testing was incorrectly recorded on the procedure data sheets. This resulted in the miscalculation of response times. Upon discovery, the response times were recalculated and a new procedure data sheet was completed. The recalculated response times met the acceotance criteria. Although the recalculations demonstrated that the equipment was operable, the failure to correctly complete the procedure data sheet is considered a missed surveillance because the data is used to determine equipment operability. Therefore, this event was considered reportable pursuant to 10CFR50.73(a)(2)(i)(B), as a condition prohibited by the plant's Technical Specification. In this instance, the procedure violation resulted in a missed surveillance because the data was not used appropriately to determine equipment operability. There were no safety consequences as a result of this event since all response times acceptance criteria requirements were satisfied. IV. Corrective Action When the problem was discovered on March 11,1994, an SRO licensed operator recalculated the ESF equipment circuit response time by adding the sequencer loading delays to the sum of the previously listed data. When this addhional data was added to the original numbers, the total response times was determined to be within the acceptance criteria for the surveillance.

• To prevent recurrence, the f9110 wing action was implemented:

SP 2604P, " Engineered Safety Features Equipment Response Time Testing," was revised and approved effective 04/27/94. In Sectim 4.5, "ESF Response Time Calculation," numerous steps were added to provide clearer guidance as to how to perform the surveillance. All necessary information from OPS Forms 2604P-1 and 2604P-2 were combined. The term " diesel sequence time" on the OPS form was revised to state, *DG st&rt and sequencing time." i 1 NM Form 366A (5-92)

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 . . NRC Form g66A                             U.S. NUCLEAR REGULATORY COMMISSION                         APPROVED BY OMB NO. 3150-0104 (5-92)                                                                                                                EXPIRES: G/31/95 LICENSEE EVENT REPORT (LER)                                              CSICWJ70s?T""'I$s ?OEEETC""" PNrs'"l$%#"$                                            l TEXT CONTINUATION                                         "TCN esnurg;g une              Tg,Nm,ganE YoETYv' EN"iOT                                   l

• i WASHINGTON. DC 20656-0001 AND TO THE PAPERWORK REDUCTION '

PROJECT 0150- 0104). OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON. DC 20603 FCCIUTY NAME (1) DOCKET NUMBER (2) LER NUMBER f@ PAGE($ WAR Mg upp Millstone Nuclear Power Station i Unit 2 05000336 94 - 0 - 00 04 OF 4 TEXT (it more space e rewred. use mooinons copies al NRC Form 366A) (17) V. Additional Information There were no failed components associated with this event. Similar Events: None. Ells Codes; Engineered Safety Features Equipment - JE Emergency Diesel Generator - EK NRC Form 366A (5-92)

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