ML18016A911

LER 99-005-00:on 990313,plant Exceeded ESFAS TS 3.3.2,Action 21.Caused by Inadequate Procedure Rev Preparation.Licensee Revised Applicable Maint Surveillance Test Procedure (MST-10072) to Identify TS Required Actions.With 990412 Ltr

ML18016A911
Person / Time
Site:	Harris
Issue date:	04/12/1999
From:	Brooke Clark, Ellington M CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HNP-99-064, HNP-99-64, LER-99-005, LER-99-5, NUDOCS 9904200022
Download: ML18016A911 (8)

Text

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)ACCESSION NBR:9904200022 DOC.DATE: 99/04/12 NOTARIZED:

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

Carolina Power E Light Co.CLARK,B.H.

Carolina Power E Light Co.RECIP.NAME RECIPIENT AFFILIATION DOCKET 05000400

SUBJECT:

LER 99-005-00:on 990313,plant exceeded ESFAS TS 3.3.2,Action 21.Caused by inadequate procedure rev preparation.

Licensee revised applicable maint surveillance test procedure (MST-10072) to identify TS required Actions.With 990412 ltr.DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE: TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc.NOTES:Application for permit renewal filed.0500040d-RECIPIENT ID CODE/NAME LPD2-2 PD INTERNAL: A NRR/DIPM/IQMB NRR/DSSA/SPLB RGN2 FILE 01 COPIES LTTR ENCL 1 1 4 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME LAUFER,R.AEOD/S PD/RRAB NRR/DIPM/IOLB NRR/DRIP/REXB RES/DET/EIB COPIES LTTR ENCL 1 1 1 1 1" 1 1 1 1 1 EXTERNAL: L ST LOBBY WARD NOAC POORE,W.NRC PDR 1 1 1 1 1: 1 LMITCO MARSHALL NOAC QUEENER,DS NUDOCS FULL TXT 1 1 1 1 1~1 NOTE TO ALL"RIDS" RECIPIENTS:

4 PLEASE HELP US TO REDUCE WASTE.TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LIST 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 REQUIRED: LTTR 17 ENCL 17 Carolina Power 8 Light Company Harris Nuclear Plant P.O.Box 165 New Hill NC 27562 P,F'R 12 1999 U.S.Nuclear Regulatory Commission ATTN: NRC Document Control Desk Washington, DC 20555 Serial: HNP-99-064 10CFR50.73 SHEARON HARRIS NUCLEAR POWER PLANT UNIT 1 DOCKET NO.50-400 LICENSE NO.NPF-63 LICENSEE EVENT REPORT 1999-005-00 Sir or Madam: In accordance with 10CFR50.73, the enclosed Licensee Event Report is submitted.

This report describes a condition which resulted in exceeding the requirements of Technical Specifications for Engineered Safety Features Actuation Systems.Sincerely, B.H.Clark General Manager Harris Plant CWF/cwf Enclosure Mr.J.B.Brady (HNP Senior NRC Resident)Mr.R.J.Laufer (NRC-NRR Project Manager)Mr.L.A.Reyes (NRC Regional Administrator, Region II)9904200022 9904i2 PDR ADQCK 05000400 S PDR 5d13 Shearon Harris Road New Hill NC NRC FORM 366 U.S.NUCLEAR REGULATORY COMMISSION

'lI (6-1996)LICENSEE EVENT REPORT (LER)(See reverse for required number of digits/characters for each block)APPROVED BY OMB NO.3150.0104 EXPIRES 06/30/2001 Estimated burden per response to comply with this mandatory information collection request: 50 hrs.Reported lessons learned are incorporated into the licensing process and fed back to industry.Forward comments regarding burden estimate to the Information and Records Management Branch (TA F33), U.S.Nuclear Regulatory Commission, Washington, DC 205554001~and to the Paperwork Reduction Project (31504104), Office of Management and Budget, Washington, DC 20503, lf an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection, FACILITY NAME I1)Harris Nuclear Plant, Unit 1 DOCKET NUMBER I2I 05000400 PAGE I3)1 OF 3 TITLE I4)Engineered Safety Features Actuation Systems Technical Specifications exceeded MONTH DAY YEAR YEAR sEQUENTIAL REVIBIDN NUMBER NUMBER MONTH DAY YEAR FACILITY NAME DOCKET NUMBER 03 13 1999 1999-005'00 04 12 1999 FACILITY NAME DOCKET NUMBER 05000 OPERATING MODE (9)POWER LEVEL (10)000 20.2201 (b)20.2203(a)(1) 20.2203(a)(2)(i) 20.2203(a)(2)(ii)20.2203(a)

(2)(iii)20.2203(a)(2)(iv) 20.2203(a)(2)(v) 20.2203(a)(3)(i) 20.2203(a)(3)(ii) 20.2203(a)

(4)50.36(c)(1) 50.36(c)(2) x 50.73(a)(2)(i) 50.73(a)(2)(ii) 50.73(a)(2)(iii)50.73(a)(2)(iv)50 73(a)(2)(v) 50.73(a)(2)(vii) 50.73(a)(2)(viii)50.73(a)(2)(x) 73.71 OTHER Specify in Abstract below or in NRC Form 366A NAME Mark Ellington, Senior Analyst-Licensing TELEPHONE NUMBER linclude Ares Cods)(919)362-2057 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE To EPIX CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE To EPIX YES (If yes, complete EXPECTED SUBMISSION DATE).X NO EXPECTED MONTH DAY YEAR ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)(16)At 23:31 on March 13, 1999, with the Harris Nuclear Plant (HNP)shutdown in Mode 3, HNP exceeded Engineered Safety Features Actuation Systems (ESFAS)Technical Specifications (TS)3.3.2 Action 21.Train"A" of Solid State Protection System (SSPS)was placed in test, at 17:31 on March 13, 1999, to perform corrective maintenance and post-maintenance testing of the"A" Reactor Trip Breaker.HNP Licensed Operators incorrectly determined that the most limiting Action for"A" Train SSPS inoperability was a requirement to be in cold shutdown (mode 5)in 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> (TS 3.3.2 Actions 14).The Licensed Operators failed to recognize that TS 3.3.2 Action 21 was in effect which required the plant to be in Hot Shutdown (Mode 4)within six (6)hours.Approximately eight (8)hours and 28 minutes elapsed before Licensed Operators recognized TS 3.3.2 Action 21 applicability and subsequently restored"A" Train SSPS to an operable status.During this time, HNP remained in Mode 3 resulting'n a violation of TS 3.3.2 Action 21.Cause of this TS violation:

(1.)Inadequate procedure revision preparation.

(2.)Inadequate Operations review of the TS impact of the work being performed.

Corrective actions include: (1.)Revised the applicable maintenance surveillance test procedure (MST-I0072) to adequately identify TS required Actions.(2.)Counseled Operations supervision concerning timely verification and documentation of Operating License/TS compliance.

(3.)Complete License Operator training of TS requirements for TS 3.3.1"Reactor Protection" and TS 3.3.2"ESFAS".(4.)Counsel shift Operations personnel concerning inappropriate acts and causal factors associated with this event.NRC FORM 366 t6.1998)

NRC FORM 366A (6.96)LICENSEE EVENT REPORT (LER)TEXT CONTINUATION U.S.NUCLEAR REGULATORY COMMISSION FACILITY NAME (1)Harris Nuclear Plant, Unit 1 DOCKET 05000400 LER NUMBER (6)YEAR SEQUENTIAL REVISION NUMBER NUMBER 1999-005-00 PAGE (3)2 OF 3 TEXT III more space Is required, use additional copIes ol NRC Form 366AI (17)I.EVENT DESCRIPTION At 23:31 on March 13, 1999, with the Harris Nuclear Plant (HNP)shutdown in Mode 3, HNP exceeded Engineered Safety Features Actuation Systems (ESFAS)Technical Specifications (TS)3.3.2 Action 21.On March 12, 1999, HNP automatically tripped due to a high steam generator water level.Details of this trip~are documented in HNP LER 1999-04-00.

While the unit was shutdown, HNP management decided to perform corrective maintenance on the Reactor Trip Breaker"A" (RTA).The RTA deficiency did not affect RTA operability, but caused difficulty with closing the breaker during testing.HNP maintenance personnel used a maintenance surveillance test procedure (MST-I0072) to facilitate the corrective maintenance and subsequent post-maintenance testing.MST-I0072 requires the"A" Train Solid State Protection System (SSPS)to be placed in test.Placing SSPS in test prevents various Engineered Safety Features Actuation System (ESFAS)functions on that train from being operable such as Safety Injection, Containment Spray, Containment Isolation, and Auxiliary Feedwater actuation.

MST-I0072 was normally performed in Mode 5 or Mode 6.MST-l0072 was revised to allow performance in Mode 3.A complete discussion of TS requirements and associated Mode 3 applicability was not included in MST-I0072 when it was revised.On March 13, 1999, a pre-job brief for MST-I0072 was performed with HNP Main Control Room (MCR)Licensed Operators.

During the briefing, an HNP system engineer stated, that placing the"A" Train SSPS in test would result in entry into a 30-hour TS Action Statement.

MCR Licensed Operators did not independently assess this statement.

At 17:31 on March 13, 1999,"A" Train SSPS was placed in test in, accordance with MST-I0072.

While"A" Train SSPS was in test, a failure occurr'ed on a cell switch contact used in the"B" Train ESFAS P-4 permissive logic.Testing'of RTA was suspended due to the emergent failure of the"B" train P-4 permissive.

At approximately 00:30 on March 14, 1999, the Work Control Center (WCC)Senior Reactor Operator (SRO)began writing the Equipment Inoperable Record (EIR)associated with performance of MST-l0072 for"A" SSPS inoperability.

During the preparation of the EIR, the WCC SRO questioned the applicability of TS 3.3.2 Action'21.

At 01:15 on March 14, 1999, the MCR Operations staff determined that TS 3.3.2 Action 21 was applicable.

At 01:59 on March 14, 1999, the"A" Train SSPS was returned to operable status by terminating MST-I0072 on RTA and restoring SSPS from a testing condition to a normal standby condition.

==

Conclusion:==

The Licensed Operators failed to recognize that TS 3.3.2 Action 21 was in effect which required the plant to be in Hot Shutdown (Mode 4)within six (6)hours.Approximately eight (8)hours and 28 minutes elapsed before Licensed Operators recognized TS 3.3.2 Action 21 applicability and subsequently restored"A" Train SSPS to an operable status.During this time, HNP remained in Mode 3 resulting in a violation of TS 3.3.2 Action 21.NRC FORM 366 (6.96I

NRC FORM 366A (6.98)LICENSEE EVENT REPORT (LER)TEXT CONTINUATION U.S.NUCLEAR REGULATORY COMMISSION FACILITY NAME (1)Harris Nuclear Plant, Unit 1 DOCKET 05000400 LER NUMBER (6)YEAR SEQUENTIAL REVISION NUMBER NUMBER 1999-005-00 PAGE (3)3 OF 3'I TEXT ilf more space is required, use addirfonal copies of ftfRC Form 366Ai (17)II.CAUSE OF EVENT 1.Inadequate procedure revision preparation.

MST-I0072, Revision 15, did not include a change to the Operator Prerequisite Summary Sheet to include the TS required functions which would be inoperable due to procedure performance.

The Operations procedure impact reviewer for MST-I0072, Revision 15, failed to identify the TS consequences of performing this testing in Mode 3.2.Inadequate Operations review of the TS impact of work being performed.

Operations supervision failed to assure that plant operations were conducted per the requirements of the Operating License and TS.Both the dayshift and nightshift Operations crews failed to perform a timely independent assessment of Limiting Conditions for Operation Actions for SSPS being placed in test.III.SAFETY SIGNIFICANCE There were no actual safety consequences as a result of this event.A Probabilistic Safety Assessment (PSA)Risk Significance evaluation was performed for one train of SSPS out of service for approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in Mode 3.The evaluation determined that Train"A" can be out of service for 261 hours0.00302 days <br />0.0725 hours <br />4.315476e-4 weeks <br />9.93105e-5 months <br /> before the plant configuration is considered risk significant, e.g.reaches the 1E-6 limit discussed in the EPRI PSA Applications Guide.Additionally, during the period that"A" Train SSPS was in test, the redundant"B" Train SSPS was operable to provide safety-related functions.

This report is being submitted pursuant to the criteria of 10CFR50.73(a)(2)(i) for any operation or condition prohibited by the plant's Technical Specifications.

IV., CORRECTIVE ACTIONS I.Revised MST-I0072 to adequately identify TS required Actions.2.Counseled Operations supervision concerning timely verification and documentation of Operating License/TS compliance.

3.Complete Licensed Operator training of TS requirements for TS 3.3.1"Reactor Protection" and TS 3.3.2"ESFAS".4.Counsel shift Operations personnel concerning inappropriate acts and causal factors associated with with the event.V.SIMILAR EVENTS HNP LER 97-021-00 (and subsequent revisions) identified inadequate surveillance test procedures used to comply with TS surveillance requirements.

The inadequate surveillance test procedures identified in LER 97-021 failed to provide complete testing of circuitry to satisfy the TS required surveillances (i.e.inadequate test scope).The condition described in this LER is different than LER 97-021-00 (and subsequent revisions) in that this LER documents an inadequacy in a surveillance test where an applicable TS Limiting Condition for Operation due to the testing configuration was not identified (i.e.test impact not identified).

NRC FORM 366A (6.98)

P!s I'A