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.e lNDIANA & MICHIGAN ELECTRIC COMPANY P. O. BO X 18 BOWLING GREEN ST ATION NEW YORK, N. V.10004 January 21, 1983 AEP:NRC:0764 Donald C. Cook Nuclear Plant Unit Nos. 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 50-315/8'-19 (DPRP);
lNDIANA & MICHIGAN ELECTRIC COMPANY P. O. BO X 18 BOWLING GREEN ST ATION NEW YORK, N. V.10004 January 21, 1983 AEP:NRC:0764 Donald C. Cook Nuclear Plant Unit Nos. 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 Reports No. 50-315/8'-19 A    (DPRP);
Reports No.
50-316/82-19 (DPRD)
A 50-316/82-19 (DPRD)
Mr. James G. Keppler U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Mr. James G. Keppler U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137


==Dear Mr. Keppler:==
==Dear Mr. Keppler:==
This letter and its attachments are in response to Mr. R. L.
This letter and its attachments are in response to Mr. R. L.
Spessard's {{letter dated|date=December 15, 1982|text=letter dated December 15, 1982}} which attached the subject reports of an inspecti :.. conducted by members of your staff on September 16 through Octobet 31, 1982 wherein two items of violation were identified in the Appendix. We requested and received a one week extension on this submittal by Mr. J. Streeter.
Spessard's {{letter dated|date=December 15, 1982|text=letter dated December 15, 1982}} which attached the subject reports of an inspecti :.. conducted by members of your staff on September 16 through Octobet 31, 1982 wherein two items of violation were identified in the Appendix. We requested and received a one week extension on this submittal by Mr. J. Streeter.
ITEM 1
ITEM 1
                  " Appendix A Technical Specification 3.3.1.1 states: "As a minimum, the reactor trip system instrumentation channels and interlocks of Table 3.3-1 shall be operable with the response tbnes as shown in Table 3.3-2." Table 3.3-1 specifies for Modes 1 and 2: four operable channels of Over Power and Overtemperature Delta-T with one allowed inoperable if, as a minimum; the following Action is met: "... place the inoperable channel in the tripped condition within one hour..."
" Appendix A Technical Specification 3.3.1.1 states: "As a minimum, the reactor trip system instrumentation channels and interlocks of Table 3.3-1 shall be operable with the response tbnes as shown in Table 3.3-2."
Table 3.3-1 specifies for Modes 1 and 2: four operable channels of Over Power and Overtemperature Delta-T with one allowed inoperable if, as a minimum; the following Action is met: "... place the inoperable channel in the tripped condition within one hour..."
Contrary to the above, on September 14,1982, Unit 1 entered Mode 2 at about 2235 with three operable Over Power and Quertemperature Delta-T channels and the fourth channel was not placed in the tripped condition until about 0630 on September 15, 1982."
Contrary to the above, on September 14,1982, Unit 1 entered Mode 2 at about 2235 with three operable Over Power and Quertemperature Delta-T channels and the fourth channel was not placed in the tripped condition until about 0630 on September 15, 1982."
This is a Severity Level IV Violation (Supplement 1).
This is a Severity Level IV Violation (Supplement 1).
8303240190 830318                                                     JAU N PDR ADOCK 05000315 0               PDR
8303240190 830318 JAU N PDR ADOCK 05000315 0
PDR


  *  .      Mr.. James G. Keppler                     2                 AEP NRC 0764 RESPONSE TO VIOLATION NUMBER 1 During the low power physics testing program following the end of cycle 6-refueling, Unit 1 entered mode 2 with the overpower Delta-T and overtemperature Delta-T Bistables associated with the Nuclear Instrumentation system power range channel N43 in a non-conservative configuration. In addition, approximately two and one-half hours
Mr.. James G. Keppler 2
    .        . elapsed between the time that the condition was discovered and the bistables were tripped. This event is described in detail in LER 50-315/82-079/01T-0. The failure to trip the required bistables within the one hour time limit of the Action Item 2 of specification 3.3.1 is apparently similar to the event described in LER SC-316/81-036.
AEP NRC 0764 RESPONSE TO VIOLATION NUMBER 1 During the low power physics testing program following the end of cycle 6-refueling, Unit 1 entered mode 2 with the overpower Delta-T and overtemperature Delta-T Bistables associated with the Nuclear Instrumentation system power range channel N43 in a non-conservative configuration. In addition, approximately two and one-half hours
While there are similarities in the end result, we believe the events are dissimilar in the nature of the underlying problem. In the case of LER 50-316/81-036, the problem was primarily a communication problem between Operations Department and Technical Department pbrsonnel. The urgency of the problem was.not conveyed to the Instrument Maintenance Supervisor. This resulted in a delay in investigating the problem. In the case of LER 50-315/82-079/01T-0, the delay in tripping the bistables occurred af ter Technical Department personnel had identified the existence of a problem. The Instrument Maintenance Supervisor who identified the problem was requested to assist with a transient on the Unit 2 feedwater heaters which occurred shortly af ter the problem was identified on Unit 1. The technician instructed to research the bistables that needed to be tripped was unable to complete the task without assistance within the required time. LER 50-315/82-079/01T-0 is attached. It describes the event in detail.
. elapsed between the time that the condition was discovered and the bistables were tripped. This event is described in detail in LER 50-315/82-079/01T-0. The failure to trip the required bistables within the one hour time limit of the Action Item 2 of specification 3.3.1 is apparently similar to the event described in LER SC-316/81-036.
While there are similarities in the end result, we believe the events are dissimilar in the nature of the underlying problem.
In the case of LER 50-316/81-036, the problem was primarily a communication problem between Operations Department and Technical Department pbrsonnel. The urgency of the problem was.not conveyed to the Instrument Maintenance Supervisor. This resulted in a delay in investigating the problem.
In the case of LER 50-315/82-079/01T-0, the delay in tripping the bistables occurred af ter Technical Department personnel had identified the existence of a problem. The Instrument Maintenance Supervisor who identified the problem was requested to assist with a transient on the Unit 2 feedwater heaters which occurred shortly af ter the problem was identified on Unit 1.
The technician instructed to research the bistables that needed to be tripped was unable to complete the task without assistance within the required time. LER 50-315/82-079/01T-0 is attached. It describes the event in detail.
Corrective Actions indicated in LER 50-315/82-079/01T-0 are, "To prevent recurrence the applicable procedure for initial criticality has been modified to include a signoff sheet to' ensure the overpower Delta-T and overtemperature Delta-T bistables for the nuclear instrumentation system channel that is connected to the reactivity computer are in the tripped position before control rods are withdrawn."
Corrective Actions indicated in LER 50-315/82-079/01T-0 are, "To prevent recurrence the applicable procedure for initial criticality has been modified to include a signoff sheet to' ensure the overpower Delta-T and overtemperature Delta-T bistables for the nuclear instrumentation system channel that is connected to the reactivity computer are in the tripped position before control rods are withdrawn."
o "In addition, controls have been established prohibiting changing operating modes with redundant technical specification equipment physically inoperable, unless a specific evaluation verifies its propriety."
o "In addition, controls have been established prohibiting changing operating modes with redundant technical specification equipment physically inoperable, unless a specific evaluation verifies its propriety."
                      " Prior to the next need to perform this testing, a technical specification change request will be processed for Unit No. 1 to incorporate the note "the provisions of specification 3.0.4 are not applicable" to action statement No. 2 for technical specification 3.3.1.1 (Table 3.3-1). This statement presently exists in the Unit No.
" Prior to the next need to perform this testing, a technical specification change request will be processed for Unit No. 1 to incorporate the note "the provisions of specification 3.0.4 are not applicable" to action statement No. 2 for technical specification 3.3.1.1 (Table 3.3-1).
This statement presently exists in the Unit No.
2 Technical Specification. This change is editorial in nature. We have always understood the technical specifications to permit zero power physics testing. To date, full compliance, has been achieved."
2 Technical Specification. This change is editorial in nature. We have always understood the technical specifications to permit zero power physics testing. To date, full compliance, has been achieved."


Mr.' James G. Keppler                                   3                                     AEP:NRC:0764 Other actions have been taken in an attempt to address the underlying problems. A two phase technical specification training                                                                                       ,
Mr.' James G. Keppler 3
program has been initiated in the. technical department. Phase I consists of identifying those technical specifications, for each Section, with which Section personnel should be familiar and to conduct 2
AEP:NRC:0764 Other actions have been taken in an attempt to address the underlying problems. A two phase technical specification training program has been initiated in the. technical department. Phase I consists of identifying those technical specifications, for each Section, with which Section personnel should be familiar and to conduct 2
training on the' identified material. Phase II consists of incorporating these subjects in_the Bi-annual training' program to
training on the' identified material. Phase II consists of incorporating these subjects in_the Bi-annual training' program to include lesson plans and validation. Phase I is complete in all j
;                          include lesson plans and validation. Phase I is complete in all j                           Sections but one. The remaining Section will' complete Phase I by March 31, 1983.: Phase II will be complete in all Sections by March 31, 1984.
Sections but one. The remaining Section will' complete Phase I by March 31, 1983.: Phase II will be complete in all Sections by March 31, 1984.
;                                  In addition, a controlled document which contains in one location                                                                               r a list of all bistables to be tripped.for each instrument failure will l                         .be written. It will contain instructions for tripping the bistables and other pertinent material that may be judged appropriate. The document will be complete by December 31, 1983.
In addition, a controlled document which contains in one location r
a list of all bistables to be tripped.for each instrument failure will l
.be written. It will contain instructions for tripping the bistables and other pertinent material that may be judged appropriate. The document will be complete by December 31, 1983.
In order to clarify the-start of the one hour time limit for bistable tripping action statements, PMSO.070 was issued on May 5, 1982. It states in part -
In order to clarify the-start of the one hour time limit for bistable tripping action statements, PMSO.070 was issued on May 5, 1982. It states in part -
:                                ?"It is the control room operator's responsibility to properly
?"It is the control room operator's responsibility to properly interpret control room indications, parameter changes, or possible instrument. failure. When an instrument channel indication deviates from other channels measuring the same parameter by an amount greater than acceptable limits, the C&I Section must be immediately notified to
;                          interpret control room indications, parameter changes, or possible instrument. failure. When an instrument channel indication deviates from other channels measuring the same parameter by an amount greater
]
;                          than acceptable limits, the C&I Section must be immediately notified to
have the channel checked.
]                         have the channel checked.
l It is the C&I Section's responsibility to determine if the channel is inoperable. If the channel is declared inoperable the C&I Section representative must place the failed channel's applicable bistables in i
l It is the C&I Section's responsibility to determine if the channel is inoperable. If the channel is declared inoperable the C&I Section representative must place the failed channel's applicable bistables in i                           the tripped condition within one hour from the time the channel-was declared inoperable.
the tripped condition within one hour from the time the channel-was declared inoperable.
{                                   In cases when an instrument channel fails in such manner that is L                         obvious from the panel indication that the channel has failed, the
{
!                          operator will declare the channal inoperable and start the one-hour time limit. Every effort must be made to get a C&I representative to i                         place the affected bistables in the tripped condition within the action statement one-hour time limit. If this requirement cannot be met, j                         within one hour action shall be initiated to place the unit in at least hot standby within the next six hours as required by technical specification 3.0.3.
In cases when an instrument channel fails in such manner that is L
obvious from the panel indication that the channel has failed, the operator will declare the channal inoperable and start the one-hour time limit. Every effort must be made to get a C&I representative to i
place the affected bistables in the tripped condition within the action statement one-hour time limit. If this requirement cannot be met, j
within one hour action shall be initiated to place the unit in at least hot standby within the next six hours as required by technical specification 3.0.3.
T ITEM 2
T ITEM 2
                                  " Technical Specification 6.8.1.a states: " Written procedures shall i
" Technical Specification 6.8.1.a states: " Written procedures shall be established, implemented, and maintained covering the activities i
be established, implemented, and maintained covering the activities
referenced below: The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, November 1972." Appendix A of Regulatory Guide 1.33, November 1972, includes administrative procedures such as i
!                          referenced below: The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, November 1972." Appendix A of Regulatory Guide 1.33, November 1972, includes administrative procedures such as i                         " Equipment Control (e.g. , locking and tagging) ."
" Equipment Control (e.g., locking and tagging)."
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Mr. James G. Keppler                     4                   AEP:NRC:0764 PMP 2110 CPS.001, " Clearance Permit System", states: "When a Clearance Permit bas been released, the Shif t Operating / Operating Engineer or their designee shall remove all tags associated with that Clearance Permit and restore all valves, switches, fuses, etc., to their normal operating condition."
Mr. James G. Keppler 4
AEP:NRC:0764 PMP 2110 CPS.001, " Clearance Permit System", states: "When a Clearance Permit bas been released, the Shif t Operating / Operating Engineer or their designee shall remove all tags associated with that Clearance Permit and restore all valves, switches, fuses, etc., to their normal operating condition."
Contrary to the above, when clearance Permit 29946 was released at 0550 hours on October 8, 1982, Unit I valve WM0-715, Essential Service Water inlet to the "W" Containment Spray System Heat Exchanger, was not restored to its normal operating condition (open) until after 1150 hours on October 8, 1982."
Contrary to the above, when clearance Permit 29946 was released at 0550 hours on October 8, 1982, Unit I valve WM0-715, Essential Service Water inlet to the "W" Containment Spray System Heat Exchanger, was not restored to its normal operating condition (open) until after 1150 hours on October 8, 1982."
This is a Severity Level V Violation (Supplement 1).
This is a Severity Level V Violation (Supplement 1).
RESPONSE TO ITEM 2 The circumstances surrounding this event, including actions taken to prevent recurrence, are described completely in LER 82-095/03L-0.
RESPONSE TO ITEM 2 The circumstances surrounding this event, including actions taken to prevent recurrence, are described completely in LER 82-095/03L-0.
This incident was attributed to personnel error. The corrective actions included:
This incident was attributed to personnel error. The corrective actions included:
: 1. On the return to service sheet, the statement of position will be limited to descriptive words (e.g. off, on, open, throttled). The use of "as is" is not acceptable.
1.
: 2. The raturn to service sheet will receive an independent review by someone other than the individual who initiates it.
On the return to service sheet, the statement of position will be limited to descriptive words (e.g. off, on, open, throttled). The use of "as is" is not acceptable.
: 3. The report was reviewed by all Operations Department shif t personnel.
2.
The raturn to service sheet will receive an independent review by someone other than the individual who initiates it.
3.
The report was reviewed by all Operations Department shif t personnel.
The text of the NRC letter which forwarded this IE Report directs that we address the concern that certain of our activities which should be incorporated into reviewed and approved procedures are being implemented by Plant Manager and Operations Standing Orders. Reference is made to Report S action 4 for additional details regarding this Concern.
The text of the NRC letter which forwarded this IE Report directs that we address the concern that certain of our activities which should be incorporated into reviewed and approved procedures are being implemented by Plant Manager and Operations Standing Orders. Reference is made to Report S action 4 for additional details regarding this Concern.
The contents of the three OS0's noted in Report Section 4 were collected into a single document and issued for trial use, review, and comment on October 22, 1982. This project was started by direction of the Operations Superintendent on April 22, 1982. Following incorporation of comments and review by the Department Heads and QA, this document was approved by the PNSRC as a procedure (OHI-4012) and issued on December 28, 1982. OSO's .003, .005. and .037 were cancelled on that date.
The contents of the three OS0's noted in Report Section 4 were collected into a single document and issued for trial use, review, and comment on October 22, 1982. This project was started by direction of the Operations Superintendent on April 22, 1982. Following incorporation of comments and review by the Department Heads and QA, this document was approved by the PNSRC as a procedure (OHI-4012) and issued on December 28, 1982. OSO's.003,.005. and.037 were cancelled on that date.
In future reviews of existing Standing Orders or draf ting of new ones, we will ensure that activities specified by the conditions of our license are included in appropriate procedures.
In future reviews of existing Standing Orders or draf ting of new ones, we will ensure that activities specified by the conditions of our license are included in appropriate procedures.


                    'Mr. Jcmes G. Kapplar                       5                     AEP:NRC:0764 Further clarification of the discussion in IE Inspection Report 82-19 Section 3, is also included in this response:
'Mr. Jcmes G. Kapplar 5
AEP:NRC:0764 Further clarification of the discussion in IE Inspection Report 82-19 Section 3, is also included in this response:
FOLLOW-UP REPORT OF LER 316/82-022/03L-0 The IE Inspection report, Section 3, discussion of closed item -
FOLLOW-UP REPORT OF LER 316/82-022/03L-0 The IE Inspection report, Section 3, discussion of closed item -
regarding "LER 50-316/82-68 makes reference to previous violations which occurred in March, 1982 (LER 316/82-22) when the effective i
regarding "LER 50-316/82-68 makes reference to previous violations which occurred in March, 1982 (LER 316/82-22) when the effective i
Technical Specification change for overpressure protection systems was not promptly implemented." Ef forts of the plant manager to prevent a recurrence of this event are referred to in this section of the report.
Technical Specification change for overpressure protection systems was not promptly implemented." Ef forts of the plant manager to prevent a recurrence of this event are referred to in this section of the report.
Those efforts have resulted in a more correct understanding of the term
Those efforts have resulted in a more correct understanding of the term
                      " effective date" on Technical Specification changes and will preclude l                  classifying as " violations" future situations which result from NRC               ,
" effective date" on Technical Specification changes and will preclude classifying as " violations" future situations which result from NRC l
  !                  approval of the Technical Specification change, followed by some period of time for distribution to the plant. The plant will amend LER 1                    316/82-22 accordingly.
approval of the Technical Specification change, followed by some period of time for distribution to the plant. The plant will amend LER 316/82-22 accordingly.
,                    FOLLOW-UP REPORT OF LER 050-316/82-68 During the night shif t on 8-1-82 Coerations Procedure 2-OHP 4021.001.004, (Plant shutdown f rom hot standby to cold shutdown),
1 FOLLOW-UP REPORT OF LER 050-316/82-68 During the night shif t on 8-1-82 Coerations Procedure 2-OHP 4021.001.004, (Plant shutdown f rom hot standby to cold shutdown),
i                     required a C&I signoff for STP.089 that was necessary prior to reducing the RCS temperature below 152 F.       The STP referenced was numbered wrong since the STP's numbered from 1 through 99 are for Unit 1 and the 4
i required a C&I signoff for STP.089 that was necessary prior to reducing the RCS temperature below 152 F.
STP's numbered from 100 through 199 are for Unit 2. The operator
The STP referenced was numbered wrong since the STP's numbered from 1 through 99 are for Unit 1 and the STP's numbered from 100 through 199 are for Unit 2.
!'                    explained that the signoff was for operability of the PORV's.       Since C&I had recently instituted STP's (STP.087 and STP. 187) concerning the l                     PORV's the C&I supervisor presumed that STP.089 was the Unit 1
The operator 4
!-                    Procedure and STP.189 should be the Unit 2 procedure.
explained that the signoff was for operability of the PORV's.
With these assumptions, the C&I Supervisor signed-of f the STP, l                     instructing the operator to change the referenced STP to STP.189, and informed 'the operator that he (the C&I Supervisor) would check the C&I
Since C&I had recently instituted STP's (STP.087 and STP. 187) concerning the l
: j.                    files to ensure the STP number was correct. The C&I Supervisor became l                   -involved in other activities and forgot about investigating the STP 1                     number. Following this incident, the C&I Supervisor realized that he j                     should not have signed-off the operations procedure until he had j                     investigated the reason for the signoff.
PORV's the C&I supervisor presumed that STP.089 was the Unit 1 Procedure and STP.189 should be the Unit 2 procedure.
Further investigation revealed that when the C&I Supervisor signed-off the operations procedure, there was no approved procedure to j                     perform the required testing, since STP.189 has not been approved by PNSRC. It was true that STP.187 had been issued and completed. It is also the case that these procedures relate to the PORV's. However,
With these assumptions, the C&I Supervisor signed-of f the STP, l
!'                    they do not include the required testing.
instructing the operator to change the referenced STP to STP.189, and informed 'the operator that he (the C&I Supervisor) would check the C&I files to ensure the STP number was correct. The C&I Supervisor became j.
l
-involved in other activities and forgot about investigating the STP 1
number. Following this incident, the C&I Supervisor realized that he j
should not have signed-off the operations procedure until he had j
investigated the reason for the signoff.
Further investigation revealed that when the C&I Supervisor signed-off the operations procedure, there was no approved procedure to j
perform the required testing, since STP.189 has not been approved by PNSRC. It was true that STP.187 had been issued and completed.
It is also the case that these procedures relate to the PORV's. However, they do not include the required testing.
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                      'Mr. James G. Keppler                     6                       AEP:NRC:0764 i
'Mr. James G. Keppler 6
i This document has been prepared following Corporate procedures which incorporate a reasonable set of controls to ensure its accuracy I                     and completeness prior to signature by the undersigned.
AEP:NRC:0764 i
i This document has been prepared following Corporate procedures which incorporate a reasonable set of controls to ensure its accuracy I
and completeness prior to signature by the undersigned.
Very truly yours, s
Very truly yours, s
e R. F. Hering Vice President
e R. F. Hering Vice President
                                / sag Attachment cc: John E. Dolan - Columbus M. P. Alexich R. W. Jurgensen W. G. Smith, Jr. - Bridgman j                                 R. C. Callen G. Charnoff NRC Resident Inspector at Cook Plant - Bridgman 2
/ sag Attachment cc: John E. Dolan - Columbus M. P. Alexich R. W. Jurgensen W. G. Smith, Jr. - Bridgman j
R. C. Callen G. Charnoff NRC Resident Inspector at Cook Plant - Bridgman 2
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          ~ ,-                                                                                                         4 ATTACHMENT TO AEP:NRC:0764
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                $  e G,,,. ,  If IN5'A     & A1/CHIGAN ELECTRIC COATPANY
4 ATTACHMENT TO AEP:NRC:0764 e
                                                      ~
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DONALD C. COOTNUCEAR PLAYT P.O. Box 458. Bridgman. Michigan 49106 (616) 465 5001 Septe:nber 29, 1982
N5'A & A1/CHIGAN ELECTRIC COATPANY If I DONALD C. COOTNUCEAR PLAYT
                                                                                                      ,=
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P.O. Box 458. Bridgman. Michigan 49106 (616) 465 5001 Septe:nber 29, 1982 g
                                                                                                              /
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Mr. J.G. Feppler, Regicnal Aiministrator                                                   YO  -
/YO Mr. J.G. Feppler, Regicnal Aiministrator United States Nuclear Regulatory Ca mission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 Cperating License CPR-58 Docket No. 50-315
United States Nuclear Regulatory Ca mission                                 .        .
Region III 799 Roosevelt Road                       ,          . . .
Glen Ellyn, IL 60137 Cperating License CPR-58 Docket No. 50-315


==Dear Mr. Fappler:==
==Dear Mr. Fappler:==
Pursuant to the requirements of the Appendix A Technical Specifications, the following report /s are subnitted:
Pursuant to the requirements of the Appendix A Technical Specifications, the following report /s are subnitted:
a RO 82-079/01T 0.               l- Oc/ $t-6/o7 Sincerely,                                                     .
RO 82-079/01T 0.
I
l-Oc/ $t-6/o7 a
                            .<-~
Sincerely, I
t()/ dn W.G.%,ith,         J.wt.$ b Plant lunager
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                      /bab cc:   J.E. Dolan                                                                             '
W.G.%,ith, J.wt.$ b t()/
R.S. Panter                                                                           '
dn Plant lunager
M.P. Alexic 1 R.{. Kr eger
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J.E. Dolan R.S. Panter M.P. Alexic 1 R.{. Kr eger g j 2 jg82 m.
g j 2 jg82 E.   .a' en 4 DiBry RO:III R.C. Callen PSSC G. Charnoff, Esq.
E.
J.M. Fennigan R.O. Bruggee EPRI L70                                                                               ~
.a' en 4 DiBry RO:III R.C. Callen PSSC G. Charnoff, Esq.
PNSRC                                      --
J.M. Fennigan R.O. Bruggee EPRI L70 PNSRC
~
J.F. Stietrel E.L. Tcwnley, Dir., IE (40 copies)
J.F. Stietrel E.L. Tcwnley, Dir., IE (40 copies)
                                                ~
~
_.                      Dir., MIPC (4 ccpies)                                                   p
Dir., MIPC (4 ccpies) p


LIGENSEE EVENT REPORT
LIGENSEE EVENT REPORT CONTROL sLOCxi l l
  ,                  CONTROL sLOCxi l                   l   l     l   l   1 (PLEASE PRINT OR TYPE ALL R*QUIRIO INFORMATION) i lil4 l9 M l I l D ! C I C l l l@l 0 l0UCEN5E UCENSEE CCCE              to      15                        l- 101010 hut.:eER              l010 l- l010 25              26 l@l4 11 S3(1CAT UC&t*5E Tyrg J3 l l1.11 !@[
l l
                                                                                                                                                                                                          $5(@
l 1
s T                                                                             '
(PLEASE PRINT OR TYPE ALL R*QUIRIO INFORMATION) i lil l M l I l D ! C I C l l l@l 0 l0 l-101010 l010 l-l010 l@l4 11 (1 l1.11 !@[
alil 8            U',,,"e!60 ! L l@l       51 0151010         I O [ 3 I 1 I 64S I@l DOCKET NuceER                        63 019 11 15 18 12 l@l0 19 12 19 18 12 l@
l
E VEN , OATE                     74     75                   R E*C AT DA,E           E3 EVENT DESCRIPTION AND PROSA8LE CCNsEQUENCES O'o
(@
        , i 21 l DURING THE LOW POWER PHYSICS TESTING PROGRAM FOLLOWING THE END OF CYCLE 6 REFUELIN
4 9 UCENSEE CCCE to 15 UCEN5E hut.:eER 25 26 UC&t*5E Tyrg J3 S3 CAT $5 T
s U',,,"e! ! L l@l 0151010 I O [ 3 I 1 I S I@l 019 11 15 18 12 l@l0 19 12 19 18 12 l@
alil 8
60 51 DOCKET NuceER 64 63 E VEN, OATE 74 75 R E*C AT DA,E E3 EVENT DESCRIPTION AND PROSA8LE CCNsEQUENCES O'o
, i 21 l DURING THE LOW POWER PHYSICS TESTING PROGRAM FOLLOWING THE END OF CYCLE 6 REFUELIN
[
[
        ,!3i [ THE UNIT ENTERED MODE 2 WITH THE 0VERPOWER DELTA-T AND OVERTEMPERATURE DELTA-T -
,!3i [ THE UNIT ENTERED MODE 2 WITH THE 0VERPOWER DELTA-T AND OVERTEMPERATURE DELTA-T -
g 3,4i l BISTABLES ASSOCIATED WITH NUCLEAR INSTRUMENTATION SYSTEM *(NIS) POWER RANGE CHANNEL                                                                                                                           g 3,3# r N43 IN A NON-CONSERVATIVE CONFIGURATION.
g 3,4i l BISTABLES ASSOCIATED WITH NUCLEAR INSTRUMENTATION SYSTEM *(NIS) POWER RANGE CHANNEL g
* THIS EVENT IS NON-CONSERVATIVE WITH                                                                         ;
3,3# r N43 IN A NON-CONSERVATIVE CONFIGURATION.
3 is t l RESPECT TO TECHNICAL SPECIFICATIONS 3.0.4 AND 3.3.1.1                                                                         TABLE 3.3-1 ITEMS 7 AND 8.                                                   ,
THIS EVENT IS NON-CONSERVATIVE WITH 3 is t l RESPECT TO TECHNICAL SPECIFICATIONS 3.0.4 AND 3.3.1.1 TABLE 3.3-1 ITEMS 7 AND 8.
1 i 71 I IN ADDITION, THE ACTION REQUIREMENT WAS NOT FULFILLED WITHIN THE ONE HOU
IN ADDITION, THE ACTION REQUIREMENT WAS NOT FULFILLED WITHIN THE ONE HOU 1 i 71 I
      ,ni! (SEE ATTACHED SUPPLEMENT).                                                                                                                                                   '
,ni! (SEE ATTACHED SUPPLEMENT).
85                                                                                                                                                                                                           i no C E             CC E       SUEC E TT                                                                                              COMPONENT CODE                                 sus dg                 sI ((:ht
85 i
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no C E CC E SUEC E COMPONENT CODE sus dg s ((:ht I
9         to         18           12             13                                   18                 19                         23 SEQUENTIAL LE RIRO     EVENTvfAR                             R EPORT NO.
TT l II Al@ l D l@ l Z l@ l Zi Zl Zl II Zi Zi@~ [Z_j@ 12 l @
CCCUR R ENCE                    RfrCRT                                  REvtstcN COCE
9 to 18 12 13 18 19 23 SEQUENTIAL CCCUR R ENCE RfrCRT REvtstcN LE RIRO EVENTvfAR R EPORT NO.
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02 JS 26 34 40 41 42 43 44 47 CAust cEsCArPTicN AND CCRRECT'VE ACTIONS h
:oil THE BISTABLES FOR OVERPOWER DELTA-T AND OVERTEMPERATURE DELTA-TI WE ii! TRIP POSITION.
:oil THE BISTABLES FOR OVERPOWER DELTA-T AND OVERTEMPERATURE DELTA-T WE I
TO PREVENT RECURRENCE OF THIS SITUATION THE APPLICABLE PROCEDURE                                                                                               I T,i HAS EZEN MODIFIED.                                                                                            .
ii! TRIP POSITION.
                                                                                                                                                                                  ~
TO PREVENT RECURRENCE OF THIS SITUATION THE APPLICABLE PROCEDURE I
f esiI u.J t as                                                                                                                                                                                                ,        i STA '                   % PCWER                       CTHER STATUS                         RY 15 I11 @ 'IOIOI2!@l"
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,,c.,5 ;,


LER# 82-079/01T-0
LER# 82-079/01T-0
            . SUPPLEMENT TO EVENT DESCRIPTION DURING THE LOW POWER PHYSICS TESTING PROGRAM FOLLOWING THE END OF CYCLE 6 REFUELING, THE' UNIT ENTERED MCDE 2 AT APPROXIMATELY 2235 HOURS ON SEPTEMBER 14, 1982. AT THAT TIME, NUCLEAR INSTRUMENTATION SYSTEM CHANNEL N43 WAS INOPERABLE BECAUSE IT'S IONIZATION CHAMBERS WERE USED FOR THE IN-PUT TO THE REACTIVITY COMPUTER THAT IS USED FOR LOW POWER PHYSICS TESTS.
. SUPPLEMENT TO EVENT DESCRIPTION DURING THE LOW POWER PHYSICS TESTING PROGRAM FOLLOWING THE END OF CYCLE 6 REFUELING, THE' UNIT ENTERED MCDE 2 AT APPROXIMATELY 2235 HOURS ON SEPTEMBER 14, 1982. AT THAT TIME, NUCLEAR INSTRUMENTATION SYSTEM CHANNEL N43 WAS INOPERABLE BECAUSE IT'S IONIZATION CHAMBERS WERE USED FOR THE IN-PUT TO THE REACTIVITY COMPUTER THAT IS USED FOR LOW POWER PHYSICS TESTS.
THE OVERPOWER DELTA-T AND OVERTEMPERATURE DELTA-T BISTABLES ASSOCIATED WITH NUCLEAR INSTRUMENTATION SYSTEM (NIS) POWER RANGE CHANNEL N43 SHOULD HAVE DEEN 6UT WERE NOT IN THE " TRIPPED" POSITION, WHICH IS NON-CCNSERVATIVE WITH RESPECT TO TECHNICAL SPECIFICATIONS 3.0.4 AND 3.3.1.1 TABLE 3.3-1 ITEMS 7 AND 8. IN ADDITION, THE ACTION REQUIREMENT WAS NOT FULF'ILLED WITH-IN THE ONE HOUR ALLOWED BY ACTION ITEM 2a 0F SPECIFICATION 3.3.1.1.
THE OVERPOWER DELTA-T AND OVERTEMPERATURE DELTA-T BISTABLES ASSOCIATED WITH NUCLEAR INSTRUMENTATION SYSTEM (NIS) POWER RANGE CHANNEL N43 SHOULD HAVE DEEN 6UT WERE NOT IN THE " TRIPPED" POSITION, WHICH IS NON-CCNSERVATIVE WITH RESPECT TO TECHNICAL SPECIFICATIONS 3.0.4 AND 3.3.1.1 TABLE 3.3-1 ITEMS 7 AND 8.
IN ADDITION, THE ACTION REQUIREMENT WAS NOT FULF'ILLED WITH-IN THE ONE HOUR ALLOWED BY ACTION ITEM 2a 0F SPECIFICATION 3.3.1.1.
THE FOLLOWING SEQUENCE OF EVENTS DESCRIBES AND EXPLAINS HOW THE TECHNICAL SPECIFICATIONS WERE VIOLATED AND HOW THE EVENT WAS DISCOVERED.
THE FOLLOWING SEQUENCE OF EVENTS DESCRIBES AND EXPLAINS HOW THE TECHNICAL SPECIFICATIONS WERE VIOLATED AND HOW THE EVENT WAS DISCOVERED.
AS OPERidIONAL TIME Od UNIT 1 HAS BEEN ACCUMULATED, AN INCREASE HAS ALSO BEEN OBSERVED IN THE BEGINNING OF CYCLE, SUBCRITICAL, NUCLEAR INSTRUMENTA-         ,
AS OPERidIONAL TIME Od UNIT 1 HAS BEEN ACCUMULATED, AN INCREASE HAS ALSO BEEN OBSERVED IN THE BEGINNING OF CYCLE, SUBCRITICAL, NUCLEAR INSTRUMENTA-TION SYSTEM POWER RANGE DETECTOR SIGNAL.
TION SYSTEM POWER RANGE DETECTOR SIGNAL.       THIS SUBCRITICAL POWER RANGE
THIS SUBCRITICAL POWER RANGE
(
(
SIGNAL CONSTITUTES A BACKGROUND TO THE. SIGNAL RESULTING FROM NEUTRONS, DURING ZERO POWER PHYSICS TESTS.       IF THIS BACKGROUND SIGNAL IS SUFFICIENTLY LARGE, IT CAN INVALIDATE R0D WORTH MEASUREMENTS.       IN ORDER TO COMPLETE TECHNICAL SPECIFICATION SURVEILLANCE 4.1.1.1.1.d, MEASURED R0D WORTH DATA ARE REOUIRED TO CALCULATE THE SHUTDOWN MARGIN. AS PART OF THE EFFOP,T TO
SIGNAL CONSTITUTES A BACKGROUND TO THE. SIGNAL RESULTING FROM NEUTRONS, DURING ZERO POWER PHYSICS TESTS.
                                                                                              ~
IF THIS BACKGROUND SIGNAL IS SUFFICIENTLY LARGE, IT CAN INVALIDATE R0D WORTH MEASUREMENTS.
STUDY THE BACXGROUND PROBLEM AND COMPENSATE FOR IT, BACKGROUND, LEVELS WERE MEASURED GN ALL FCUR NUCLEAR INSTRUMENTATION SYSTEM POWER RANGE CHANNELS BYSEOUENTIALLYCONNEChNGTHEREACTIVITYCOMPUTERTOEACHCHANNELDURING
IN ORDER TO COMPLETE TECHNICAL SPECIFICATION SURVEILLANCE 4.1.1.1.1.d, MEASURED R0D WORTH DATA ARE REOUIRED TO CALCULATE THE SHUTDOWN MARGIN. AS PART OF THE EFFOP,T TO STUDY THE BACXGROUND PROBLEM AND COMPENSATE FOR IT, BACKGROUND, LEVELS WERE
~
MEASURED GN ALL FCUR NUCLEAR INSTRUMENTATION SYSTEM POWER RANGE CHANNELS BYSEOUENTIALLYCONNEChNGTHEREACTIVITYCOMPUTERTOEACHCHANNELDURING


s LERg 82-079/OlT-0 Page 2 of S J
s LERg 82-079/OlT-0 Page 2 of S J
THE WEEKS OF AUGUST 23, 1982 AND AUGUST 30, 1982. AS A RESULT OF THESE MEASUREMENTS, ON SEPTEMBER 1, 1982, POWER RANGE CHANNEL N42 WAS REPLACED AND SUBSEQUENT BACKGROUND LEVEL MEASUREMENTS WERE TAKEN TO DETERMINE WHETHER THE NEW DETECTOR WAS MORE SUITABLE FOR LOW POWER PHYSICS TESTING. A DETER-MINATION WAS MADE THAT THE NOISE LEVELS HAD INCREASED ON THE NEW N42 AND IT WAS DECIDED TO USE N43 FOR THE LOW POWER PHYSICS TESTING. DURING THE ABOVE MENTIONED MEASURE?iENTS OF THE DETECTORS AND THE. REPLACEMENT OF N42, THE REACTOR WAS IN MODES 3, 4 AND 5 AND THE OVERPOWER DELTA-T AND OVERTEMPERATURE DELTA-T BISTABLES ASSOCIATED WITH THE NUCLEAR INSTRUMENTATION SYSTEM CHANNEL BEING STUDIED WERE NOT TRIPPED.
THE WEEKS OF AUGUST 23, 1982 AND AUGUST 30, 1982. AS A RESULT OF THESE MEASUREMENTS, ON SEPTEMBER 1, 1982, POWER RANGE CHANNEL N42 WAS REPLACED AND SUBSEQUENT BACKGROUND LEVEL MEASUREMENTS WERE TAKEN TO DETERMINE WHETHER THE NEW DETECTOR WAS MORE SUITABLE FOR LOW POWER PHYSICS TESTING. A DETER-MINATION WAS MADE THAT THE NOISE LEVELS HAD INCREASED ON THE NEW N42 AND IT WAS DECIDED TO USE N43 FOR THE LOW POWER PHYSICS TESTING. DURING THE ABOVE MENTIONED MEASURE?iENTS OF THE DETECTORS AND THE. REPLACEMENT OF N42, THE REACTOR WAS IN MODES 3, 4 AND 5 AND THE OVERPOWER DELTA-T AND OVERTEMPERATURE DELTA-T BISTABLES ASSOCIATED WITH THE NUCLEAR INSTRUMENTATION SYSTEM CHANNEL BEING STUDIED WERE NOT TRIPPED.
AT APPROXIMATELY 0400 HOURS ON SEPTEMBER 15, 1982, APPROXIMATELY FIVE HOURS AFTER ENTERING MODE 2, A INSTRUMENT MAINTENANCE SUPERVISOR NOTICED THAT THE STATUS LIGHTS FOR THE OVERPOWER DELTA-T AND OVERTEMPERATURE DELTA-T CHANUEL ASSOCIATED WITH THE NUCLEAR INSTRUMENTATION. SYSTEM CHANNEL (N43) CONNECTE TO THE REACTIVITY COMPUTER WERE NOT ILLUMINATED (NOT INDICATING" TRIPPED").
AT APPROXIMATELY 0400 HOURS ON SEPTEMBER 15, 1982, APPROXIMATELY FIVE HOURS AFTER ENTERING MODE 2, A INSTRUMENT MAINTENANCE SUPERVISOR NOTICED THAT THE STATUS LIGHTS FOR THE OVERPOWER DELTA-T AND OVERTEMPERATURE DELTA-T CHANUEL ASSOCIATED WITH THE NUCLEAR INSTRUMENTATION. SYSTEM CHANNEL (N43) CONNECTE TO THE REACTIVITY COMPUTER WERE NOT ILLUMINATED (NOT INDICATING" TRIPPED").
BELIEVIN3 THIS WAS INCORRECT,' THE INSTRUMENT MAINTENANCE SUPERVISOR IN-                                 ~
BELIEVIN3 THIS WAS INCORRECT,' THE INSTRUMENT MAINTENANCE SUPERVISOR IN-
                                                                                                                ~
~
STRUCTED A JUNIOR TECHNICIAN TO RESEARCH THE BISTABLES THAT NEEDED TO BE IN l
STRUCTED A JUNIOR TECHNICIAN TO RESEARCH THE BISTABLES THAT NEEDED TO BE IN
THE TRIPPED POSITION. THE SUPERVISOR CONTINUED TO REVIEW OTHER INSTRUMENTA-                     ,'
~
                                                                                                              ~
l THE TRIPPED POSITION. THE SUPERVISOR CONTINUED TO REVIEW OTHER INSTRUMENTA-TION IN THE UNIT 1 CONTROL ROOM TO ENS'RE THAT IT WAS FUNCTIONING PROPERLY.
TION IN THE UNIT 1 CONTROL ROOM TO UENS'RE THAT IT WAS FUNCTIONING PROPERLY.
U
!            AT THIS TIME, THE SUPERVISOR RECEIVED A REQUEST FOR ASSISTANCE FROM THE UNIT 2 CONTROL ROOM. HE PROCEEDED TO THE UNIT 2 CONTROL ROOM WHERE HE 08-SERVED A TRANSIENT IN PROGRESS ON THE FEEDWATER HEATERS. HIS INTENTION WAS TO TAKE CORRECTIVE ACTION IF THE TRANSIENLWAS INSTRUMENT-RELATED BEFORE SITUATION WORSENED AND HE WISHED TO BE PP.ESENT IF THE REACTOR TRIPPED IN s
~
ORDERTOASSISTWITH45YRESULTlGPROBLEMSWITHINHISCCGNIZANCE.THE l                                               . . . _ . . . . _ . . . . . . . .      . - . . . . .. . - .      . . - . .
AT THIS TIME, THE SUPERVISOR RECEIVED A REQUEST FOR ASSISTANCE FROM THE UNIT 2 CONTROL ROOM. HE PROCEEDED TO THE UNIT 2 CONTROL ROOM WHERE HE 08-SERVED A TRANSIENT IN PROGRESS ON THE FEEDWATER HEATERS. HIS INTENTION WAS TO TAKE CORRECTIVE ACTION IF THE TRANSIENLWAS INSTRUMENT-RELATED BEFORE SITUATION WORSENED AND HE WISHED TO BE PP.ESENT IF THE REACTOR TRIPPED IN ORDERTOASSISTWITH45YRESULTlGPROBLEMSWITHINHISCCGNIZANCE.THE s
l


LER! 82-079/01T-0                                                 PAGE 4 0F 5 J
LER! 82-079/01T-0 PAGE 4 0F 5 J
AVAILABLE TO TRIP THE REACTOR. IF A REACTIVITY EXCURSION HAD OCCURRED THE FOLLOWING TRIPS WOULD HAVE BEEN AVAILABLE:
AVAILABLE TO TRIP THE REACTOR.
: 1. NUCLEAR INSTRUMENTATION SYSTEM SOURCE RANGE CHANNEL AT 105 cps, ONE OF 10 CHANNELS, BELOW P-6.
IF A REACTIVITY EXCURSION HAD OCCURRED THE FOLLOWING TRIPS WOULD HAVE BEEN AVAILABLE:
: 2. NUCLEAR INSTRUMENTATION SYSTEM INTERMEDIATE RANGE CHANNEL AT 25% RTP, ONE OF TWO CHANNELS.
1.
: 3. NUCLEAR INSTRUMENTATION SYSTEM POWER RANGs NEUTRON FLUX, LOW SETPOINT AT 25". RTP, TWO 0F FOUR CHANNELS (N43 WAS ALREADY IN TRIP).
NUCLEAR INSTRUMENTATION SYSTEM SOURCE RANGE CHANNEL AT 105 cps, ONE OF 10 CHANNELS, BELOW P-6.
: 4. NUCLEAR INSTRUMENTATION SYSTEM POWER RANGE NEUTRON FLUX, HIGH SETPOING AT g 25% RTP, TWO OF FOUR CHANNELS (N43 WAS ALREADY IN TRIP).
2.
: 5. FOR A RAPID POWER EXCURSION POWER RANGE NEUTRON FLUX, HIGH POSITIVE RATE, TWO 0F FOUR CHANNELS (N43 WAS ALREADY IN TRIP).                 '
NUCLEAR INSTRUMENTATION SYSTEM INTERMEDIATE RANGE CHANNEL AT 25% RTP, ONE OF TWO CHANNELS.
: 5. IF A DEPRESSURIZATION ACCIDENT HAD OCCURRED, THE REACTOR WOULD MAYE TRIPPED AT 1815 PSIG AS A RESULT OF A SAFETY INJECTION ACTUATION. AT THIS PRESSURE THE RCS WOULD HAVE BEEN APPROXI-MATELY 76* F SUSC00 LED.                                                       ' -
3.
l
NUCLEAR INSTRUMENTATION SYSTEM POWER RANGs NEUTRON FLUX, LOW SETPOINT AT 25". RTP, TWO 0F FOUR CHANNELS (N43 WAS ALREADY IN TRIP).
: 7. THE OVERPOWER DELTA-T AND OVERTEMPERATURE DELTA-T TRIPS WERE ALSO AVAILABLE BUT WERE REDUCED FROM A TWO OF FOUR LOGIC TO A TWO OF THREE LOGIC.
4.
TO PREVENT RECURRENCE THE APPLICABLE PROCEDURE FCR INITIAL CRITICALITY HAS SEEN MODIFIED TO INCLUDE A SIGNOFF SHEET TO ENS 9RE THE OVERPOWER DELTA-T AND     __
NUCLEAR INSTRUMENTATION SYSTEM POWER RANGE NEUTRON FLUX, HIGH SETPOING AT g 25% RTP, TWO OF FOUR CHANNELS (N43 WAS ALREADY IN TRIP).
OVERTEMPERATURE DELTA-T.3-I-STABLES FOR THE~ NUCLEAR INSTRUMENTATION SYSTEM CHANNEL THAT IS CONNEC'TED TO THE REACTI'(ITY COMPUTER ARE IN.THE TRIPPED POSITION BEFORE CONTROL RODS ARE WITHDRAWN.
5.
FOR A RAPID POWER EXCURSION POWER RANGE NEUTRON FLUX, HIGH POSITIVE RATE, TWO 0F FOUR CHANNELS (N43 WAS ALREADY IN TRIP).
5.
IF A DEPRESSURIZATION ACCIDENT HAD OCCURRED, THE REACTOR WOULD MAYE TRIPPED AT 1815 PSIG AS A RESULT OF A SAFETY INJECTION ACTUATION. AT THIS PRESSURE THE RCS WOULD HAVE BEEN APPROXI-MATELY 76* F SUSC00 LED.
l 7.
THE OVERPOWER DELTA-T AND OVERTEMPERATURE DELTA-T TRIPS WERE ALSO AVAILABLE BUT WERE REDUCED FROM A TWO OF FOUR LOGIC TO A TWO OF THREE LOGIC.
TO PREVENT RECURRENCE THE APPLICABLE PROCEDURE FCR INITIAL CRITICALITY HAS SEEN MODIFIED TO INCLUDE A SIGNOFF SHEET TO ENS 9RE THE OVERPOWER DELTA-T AND OVERTEMPERATURE DELTA-T.3-I-STABLES FOR THE~ NUCLEAR INSTRUMENTATION SYSTEM CHANNEL THAT IS CONNEC'TED TO THE REACTI'(ITY COMPUTER ARE IN.THE TRIPPED POSITION BEFORE CONTROL RODS ARE WITHDRAWN.
i
i


LER#   82-079/01T-0                                                   PAGE 3 0F 5
LER#
      ./
82-079/01T-0 PAGE 3 0F 5
./
SUPERVISOR WAS INVOLVED IN UNIT 2 ACTIVITIES UflTIL APPROXIMATELY 0600 HOURS ON SEPTEMBER 15, 1982, AT THIS TIME, THE TECHNICIAN ASSIGt!ED TO THE OVERPOWER DELTA-T AtlD OVER' TEMPERATURE DELTA-T BISTABLES CONFERRED WITH THE MAINTENANCE SUPERVISOR ABOUT HIS FINDINGS AND THE BISTABLES WERE PLACED THE TRIPPED POSITION AT 0630 HOURS ON SEPTEMBER 15, 1982. THE PUBLIC HEALTH AND SAFETY WERE NOT AFFECTED.
SUPERVISOR WAS INVOLVED IN UNIT 2 ACTIVITIES UflTIL APPROXIMATELY 0600 HOURS ON SEPTEMBER 15, 1982, AT THIS TIME, THE TECHNICIAN ASSIGt!ED TO THE OVERPOWER DELTA-T AtlD OVER' TEMPERATURE DELTA-T BISTABLES CONFERRED WITH THE MAINTENANCE SUPERVISOR ABOUT HIS FINDINGS AND THE BISTABLES WERE PLACED THE TRIPPED POSITION AT 0630 HOURS ON SEPTEMBER 15, 1982. THE PUBLIC HEALTH AND SAFETY WERE NOT AFFECTED.
SUPPLEMEf!T TO CAUSE DESCRIPTION       .
SUPPLEMEf!T TO CAUSE DESCRIPTION TESTIllG WAS CONDUCTED TO DETERMINE BACXGROUND SIGNAL LEVEL ON THE NUCLEAR IllSTRUMEilTATION SYSTEM POWER RANGE CHANNELS IN MODES 3, 4, AND 5.
TESTIllG WAS CONDUCTED TO DETERMINE BACXGROUND SIGNAL LEVEL ON THE NUCLEAR IllSTRUMEilTATION SYSTEM POWER RANGE CHANNELS IN MODES 3, 4, AND 5.           Itt THESE MODES, THE OVERPOWER DELTA-T AND OVERTEMPERATURE DELTA-T TRIP BISTABLES WERE !!OT REQUIRED TO BE TRIPPED AND WERE NOT TRIPPED ~. THE INITIAL CRITI-CALITY PROCEDURE DID NOT INCLUDE A HOLD POINT, PRIOR TO ENTERING MODE 2, T0 s
Itt THESE MODES, THE OVERPOWER DELTA-T AND OVERTEMPERATURE DELTA-T TRIP BISTABLES WERE !!OT REQUIRED TO BE TRIPPED AND WERE NOT TRIPPED ~. THE INITIAL CRITI-CALITY PROCEDURE DID NOT INCLUDE A HOLD POINT, PRIOR TO ENTERING MODE 2, T0 s
ENSURE THAT ALL REQUIRED BISTABLES WERE TRIPPED AFTER SELECTING THE CHAN TO BE USED FOR PHYSICS TESTING.                                                                           t OPEP.ATING PERSONNEL DID NOT OBSERVE THE FACT THAT THE OVERPOWER DELTA-T AND OVERTEMPERATURE DELTA-T BISTABLES WERE NOT TRIPPED. BEGINilING OF CYCLE PHYSICS TESTING IS A NORMAL ROUTINE ACTIVITY.           REMOVIllG THE POWER                         ,
ENSURE THAT ALL REQUIRED BISTABLES WERE TRIPPED AFTER SELECTING THE CHAN TO BE USED FOR PHYSICS TESTING.
RANGE CHAN?!EL FROM SERVICE WAS NOT ASSOCIATED WITH AN ABNORMAL PLANT
t OPEP.ATING PERSONNEL DID NOT OBSERVE THE FACT THAT THE OVERPOWER DELTA-T AND OVERTEMPERATURE DELTA-T BISTABLES WERE NOT TRIPPED. BEGINilING OF CYCLE PHYSICS TESTING IS A NORMAL ROUTINE ACTIVITY.
                .LINE-UP Ill THI.S EVOLUTION. THE ABSENCE OF OVERPOWER AND OVERTEMPERATURE DELTA-T STATUS LIGHTS IS fl0T AN INDICATI0ft THAT IS READILY IDENTIFIED l               UNLESS IT IS SEING SPECIFICALLY VERIFIED.           THE STATUS LIGHTS ARE IN A l
REMOVIllG THE POWER RANGE CHAN?!EL FROM SERVICE WAS NOT ASSOCIATED WITH AN ABNORMAL PLANT
t              FART OF THE CONTROL ROOM SOME DISTANCE FROM THE flUCLEAR INSTRUf!EllTATION SYSTEM.                                                                                                   _
.LINE-UP Ill THI.S EVOLUTION. THE ABSENCE OF OVERPOWER AND OVERTEMPERATURE DELTA-T STATUS LIGHTS IS fl0T AN INDICATI0ft THAT IS READILY IDENTIFIED l
      }.       FAILURE TO TRIP THE OVERPOWER DELTA-T AND 0VERTEMPERATURE DELTA-T BISTABLES WAS SERIOUS FRCM SOTH A TECHNICAL SPECIFICATION Atl0 PROCEDURAL CONT 0L POINT OF VIEW. HOWEVER, SEVERAL ALTERNATE REACTOR PROTECTION FEATURES WERE l
UNLESS IT IS SEING SPECIFICALLY VERIFIED.
                                                                                ~
THE STATUS LIGHTS ARE IN A l
                                                                ,    _    _                                                  59
FART OF THE CONTROL ROOM SOME DISTANCE FROM THE flUCLEAR INSTRUf!EllTATION t
SYSTEM.
}.
FAILURE TO TRIP THE OVERPOWER DELTA-T AND 0VERTEMPERATURE DELTA-T BISTABLES WAS SERIOUS FRCM SOTH A TECHNICAL SPECIFICATION Atl0 PROCEDURAL CONT 0L POINT OF VIEW. HOWEVER, SEVERAL ALTERNATE REACTOR PROTECTION FEATURES WERE l
~
59


        .s LERf 82-079/OlT-0                                               PAGE 5 0F 5
.s LERf 82-079/OlT-0 PAGE 5 0F 5
    ./
./
IN ADDITION, CONTROLS HAVE BEEN ESTABLISHED PROHIBITING CHANGING OPERATIN3 MODES WITH REDUNDANT TECHNICAL SPECIFICATION EQUIPMENT PHYSICALLY IN0PER-ABLE, UNLESS A SPECIFIC EVALUATION VERIFIES ITS PROPRIETY.
IN ADDITION, CONTROLS HAVE BEEN ESTABLISHED PROHIBITING CHANGING OPERATIN3 MODES WITH REDUNDANT TECHNICAL SPECIFICATION EQUIPMENT PHYSICALLY IN0PER-ABLE, UNLESS A SPECIFIC EVALUATION VERIFIES ITS PROPRIETY.
PRIOR TO THE NEXT NEED TO PERFORM THIS TESTING, A TECHNICAL SPECIFICATION CHANGE REQUEST WILL BE PROCESSED FOR UNIT NO. 1 TO INCORPORATE THE NOTE "THE PROVISIONS OF SPECIFICATION 3.0.4 ARE NOT APPLICABLE" TO ACTION STATEMENTN0.2FORTECHNICALSPECIFICATION3.3II.1(TABLE 3.3-1).         THIS STATEMENT PRESENTLY EXISTS IN THE UNIT NO. 2 TECHNICAL SPECIFICATION.
PRIOR TO THE NEXT NEED TO PERFORM THIS TESTING, A TECHNICAL SPECIFICATION CHANGE REQUEST WILL BE PROCESSED FOR UNIT NO. 1 TO INCORPORATE THE NOTE "THE PROVISIONS OF SPECIFICATION 3.0.4 ARE NOT APPLICABLE" TO ACTION STATEMENTN0.2FORTECHNICALSPECIFICATION3.3II.1(TABLE 3.3-1).
THIS CHANGE IS EDITORIAL IN NATURE. WE HAVE ALWAYS UNDERSTOOD ThE TEC-NICAL SPECIFICATIONS TO PERMIT ZERO POWER PHYSICS TESTING. TO DATE, FULL COMPLIANCE, HAS BEEN ACHIEVED.
THIS STATEMENT PRESENTLY EXISTS IN THE UNIT NO. 2 TECHNICAL SPECIFICATION.
THIS CHANGE IS EDITORIAL IN NATURE. WE HAVE ALWAYS UNDERSTOOD ThE TEC-NICAL SPECIFICATIONS TO PERMIT ZERO POWER PHYSICS TESTING.
TO DATE, FULL COMPLIANCE, HAS BEEN ACHIEVED.
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Latest revision as of 05:25, 15 December 2024

Responds to NRC Re Violations Noted in IE Insp Repts 50-315/82-19 & 50-316/82-19.Corrective Actions: Controlled Document Containing List of All Bistables to Be Tripped Will Be Written
ML20072F411
Person / Time
Site: Cook  
Issue date: 01/21/1983
From: Hering R
INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20072F399 List:
References
AEP:NRC:0764, AEP:NRC:764, NUDOCS 8303240190
Download: ML20072F411 (6)
v • d • e


Text

,

.e lNDIANA & MICHIGAN ELECTRIC COMPANY P. O. BO X 18 BOWLING GREEN ST ATION NEW YORK, N. V.10004 January 21, 1983 AEP:NRC:0764 Donald C. Cook Nuclear Plant Unit Nos. 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 50-315/8'-19 (DPRP);

Reports No.

A 50-316/82-19 (DPRD)

Mr. James G. Keppler U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Keppler:

This letter and its attachments are in response to Mr. R. L.

Spessard's letter dated December 15, 1982 which attached the subject reports of an inspecti :.. conducted by members of your staff on September 16 through Octobet 31, 1982 wherein two items of violation were identified in the Appendix. We requested and received a one week extension on this submittal by Mr. J. Streeter.

ITEM 1

" Appendix A Technical Specification 3.3.1.1 states: "As a minimum, the reactor trip system instrumentation channels and interlocks of Table 3.3-1 shall be operable with the response tbnes as shown in Table 3.3-2."

Table 3.3-1 specifies for Modes 1 and 2: four operable channels of Over Power and Overtemperature Delta-T with one allowed inoperable if, as a minimum; the following Action is met: "... place the inoperable channel in the tripped condition within one hour..."

Contrary to the above, on September 14,1982, Unit 1 entered Mode 2 at about 2235 with three operable Over Power and Quertemperature Delta-T channels and the fourth channel was not placed in the tripped condition until about 0630 on September 15, 1982."

This is a Severity Level IV Violation (Supplement 1).

8303240190 830318 JAU N PDR ADOCK 05000315 0

PDR

Mr.. James G. Keppler 2

AEP NRC 0764 RESPONSE TO VIOLATION NUMBER 1 During the low power physics testing program following the end of cycle 6-refueling, Unit 1 entered mode 2 with the overpower Delta-T and overtemperature Delta-T Bistables associated with the Nuclear Instrumentation system power range channel N43 in a non-conservative configuration. In addition, approximately two and one-half hours

. elapsed between the time that the condition was discovered and the bistables were tripped. This event is described in detail in LER 50-315/82-079/01T-0. The failure to trip the required bistables within the one hour time limit of the Action Item 2 of specification 3.3.1 is apparently similar to the event described in LER SC-316/81-036.

While there are similarities in the end result, we believe the events are dissimilar in the nature of the underlying problem.

In the case of LER 50-316/81-036, the problem was primarily a communication problem between Operations Department and Technical Department pbrsonnel. The urgency of the problem was.not conveyed to the Instrument Maintenance Supervisor. This resulted in a delay in investigating the problem.

In the case of LER 50-315/82-079/01T-0, the delay in tripping the bistables occurred af ter Technical Department personnel had identified the existence of a problem. The Instrument Maintenance Supervisor who identified the problem was requested to assist with a transient on the Unit 2 feedwater heaters which occurred shortly af ter the problem was identified on Unit 1.

The technician instructed to research the bistables that needed to be tripped was unable to complete the task without assistance within the required time. LER 50-315/82-079/01T-0 is attached. It describes the event in detail.

Corrective Actions indicated in LER 50-315/82-079/01T-0 are, "To prevent recurrence the applicable procedure for initial criticality has been modified to include a signoff sheet to' ensure the overpower Delta-T and overtemperature Delta-T bistables for the nuclear instrumentation system channel that is connected to the reactivity computer are in the tripped position before control rods are withdrawn."

o "In addition, controls have been established prohibiting changing operating modes with redundant technical specification equipment physically inoperable, unless a specific evaluation verifies its propriety."

" Prior to the next need to perform this testing, a technical specification change request will be processed for Unit No. 1 to incorporate the note "the provisions of specification 3.0.4 are not applicable" to action statement No. 2 for technical specification 3.3.1.1 (Table 3.3-1).

This statement presently exists in the Unit No.

2 Technical Specification. This change is editorial in nature. We have always understood the technical specifications to permit zero power physics testing. To date, full compliance, has been achieved."

Mr.' James G. Keppler 3

AEP:NRC:0764 Other actions have been taken in an attempt to address the underlying problems. A two phase technical specification training program has been initiated in the. technical department. Phase I consists of identifying those technical specifications, for each Section, with which Section personnel should be familiar and to conduct 2

training on the' identified material. Phase II consists of incorporating these subjects in_the Bi-annual training' program to include lesson plans and validation. Phase I is complete in all j

Sections but one. The remaining Section will' complete Phase I by March 31, 1983.: Phase II will be complete in all Sections by March 31, 1984.

In addition, a controlled document which contains in one location r

a list of all bistables to be tripped.for each instrument failure will l

.be written. It will contain instructions for tripping the bistables and other pertinent material that may be judged appropriate. The document will be complete by December 31, 1983.

In order to clarify the-start of the one hour time limit for bistable tripping action statements, PMSO.070 was issued on May 5, 1982. It states in part -

?"It is the control room operator's responsibility to properly interpret control room indications, parameter changes, or possible instrument. failure. When an instrument channel indication deviates from other channels measuring the same parameter by an amount greater than acceptable limits, the C&I Section must be immediately notified to

]

have the channel checked.

l It is the C&I Section's responsibility to determine if the channel is inoperable. If the channel is declared inoperable the C&I Section representative must place the failed channel's applicable bistables in i

the tripped condition within one hour from the time the channel-was declared inoperable.

{

In cases when an instrument channel fails in such manner that is L

obvious from the panel indication that the channel has failed, the operator will declare the channal inoperable and start the one-hour time limit. Every effort must be made to get a C&I representative to i

place the affected bistables in the tripped condition within the action statement one-hour time limit. If this requirement cannot be met, j

within one hour action shall be initiated to place the unit in at least hot standby within the next six hours as required by technical specification 3.0.3.

T ITEM 2

" Technical Specification 6.8.1.a states: " Written procedures shall be established, implemented, and maintained covering the activities i

referenced below: The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, November 1972." Appendix A of Regulatory Guide 1.33, November 1972, includes administrative procedures such as i

" Equipment Control (e.g., locking and tagging)."

i l

i

Mr. James G. Keppler 4

AEP:NRC:0764 PMP 2110 CPS.001, " Clearance Permit System", states: "When a Clearance Permit bas been released, the Shif t Operating / Operating Engineer or their designee shall remove all tags associated with that Clearance Permit and restore all valves, switches, fuses, etc., to their normal operating condition."

Contrary to the above, when clearance Permit 29946 was released at 0550 hours0.00637 days <br />0.153 hours <br />9.093915e-4 weeks <br />2.09275e-4 months <br /> on October 8, 1982, Unit I valve WM0-715, Essential Service Water inlet to the "W" Containment Spray System Heat Exchanger, was not restored to its normal operating condition (open) until after 1150 hours0.0133 days <br />0.319 hours <br />0.0019 weeks <br />4.37575e-4 months <br /> on October 8, 1982."

This is a Severity Level V Violation (Supplement 1).

RESPONSE TO ITEM 2 The circumstances surrounding this event, including actions taken to prevent recurrence, are described completely in LER 82-095/03L-0.

This incident was attributed to personnel error. The corrective actions included:

1.

On the return to service sheet, the statement of position will be limited to descriptive words (e.g. off, on, open, throttled). The use of "as is" is not acceptable.

2.

The raturn to service sheet will receive an independent review by someone other than the individual who initiates it.

3.

The report was reviewed by all Operations Department shif t personnel.

The text of the NRC letter which forwarded this IE Report directs that we address the concern that certain of our activities which should be incorporated into reviewed and approved procedures are being implemented by Plant Manager and Operations Standing Orders. Reference is made to Report S action 4 for additional details regarding this Concern.

The contents of the three OS0's noted in Report Section 4 were collected into a single document and issued for trial use, review, and comment on October 22, 1982. This project was started by direction of the Operations Superintendent on April 22, 1982. Following incorporation of comments and review by the Department Heads and QA, this document was approved by the PNSRC as a procedure (OHI-4012) and issued on December 28, 1982. OSO's.003,.005. and.037 were cancelled on that date.

In future reviews of existing Standing Orders or draf ting of new ones, we will ensure that activities specified by the conditions of our license are included in appropriate procedures.

'Mr. Jcmes G. Kapplar 5

AEP:NRC:0764 Further clarification of the discussion in IE Inspection Report 82-19 Section 3, is also included in this response:

FOLLOW-UP REPORT OF LER 316/82-022/03L-0 The IE Inspection report, Section 3, discussion of closed item -

regarding "LER 50-316/82-68 makes reference to previous violations which occurred in March, 1982 (LER 316/82-22) when the effective i

Technical Specification change for overpressure protection systems was not promptly implemented." Ef forts of the plant manager to prevent a recurrence of this event are referred to in this section of the report.

Those efforts have resulted in a more correct understanding of the term

" effective date" on Technical Specification changes and will preclude classifying as " violations" future situations which result from NRC l

approval of the Technical Specification change, followed by some period of time for distribution to the plant. The plant will amend LER 316/82-22 accordingly.

1 FOLLOW-UP REPORT OF LER 050-316/82-68 During the night shif t on 8-1-82 Coerations Procedure 2-OHP 4021.001.004, (Plant shutdown f rom hot standby to cold shutdown),

i required a C&I signoff for STP.089 that was necessary prior to reducing the RCS temperature below 152 F.

The STP referenced was numbered wrong since the STP's numbered from 1 through 99 are for Unit 1 and the STP's numbered from 100 through 199 are for Unit 2.

The operator 4

explained that the signoff was for operability of the PORV's.

Since C&I had recently instituted STP's (STP.087 and STP. 187) concerning the l

PORV's the C&I supervisor presumed that STP.089 was the Unit 1 Procedure and STP.189 should be the Unit 2 procedure.

With these assumptions, the C&I Supervisor signed-of f the STP, l

instructing the operator to change the referenced STP to STP.189, and informed 'the operator that he (the C&I Supervisor) would check the C&I files to ensure the STP number was correct. The C&I Supervisor became j.

l

-involved in other activities and forgot about investigating the STP 1

number. Following this incident, the C&I Supervisor realized that he j

should not have signed-off the operations procedure until he had j

investigated the reason for the signoff.

Further investigation revealed that when the C&I Supervisor signed-off the operations procedure, there was no approved procedure to j

perform the required testing, since STP.189 has not been approved by PNSRC. It was true that STP.187 had been issued and completed.

It is also the case that these procedures relate to the PORV's. However, they do not include the required testing.

t i

i 4

'Mr. James G. Keppler 6

AEP:NRC:0764 i

i This document has been prepared following Corporate procedures which incorporate a reasonable set of controls to ensure its accuracy I

and completeness prior to signature by the undersigned.

Very truly yours, s

e R. F. Hering Vice President

/ sag Attachment cc: John E. Dolan - Columbus M. P. Alexich R. W. Jurgensen W. G. Smith, Jr. - Bridgman j

R. C. Callen G. Charnoff NRC Resident Inspector at Cook Plant - Bridgman 2

I 4

i

~,-

4 ATTACHMENT TO AEP:NRC:0764 e

G,,,.

N5'A & A1/CHIGAN ELECTRIC COATPANY If I DONALD C. COOTNUCEAR PLAYT

~

P.O. Box 458. Bridgman. Michigan 49106 (616) 465 5001 Septe:nber 29, 1982 g

,=

/YO Mr. J.G. Feppler, Regicnal Aiministrator United States Nuclear Regulatory Ca mission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 Cperating License CPR-58 Docket No. 50-315

Dear Mr. Fappler:

Pursuant to the requirements of the Appendix A Technical Specifications, the following report /s are subnitted:

RO 82-079/01T 0.

l-Oc/ $t-6/o7 a

Sincerely, I

. < - ~

W.G.%,ith, J.wt.$ b t()/

dn Plant lunager

/bab cc:

J.E. Dolan R.S. Panter M.P. Alexic 1 R.{. Kr eger g j 2 jg82 m.

E.

.a' en 4 DiBry RO:III R.C. Callen PSSC G. Charnoff, Esq.

J.M. Fennigan R.O. Bruggee EPRI L70 PNSRC

~

J.F. Stietrel E.L. Tcwnley, Dir., IE (40 copies)

~

Dir., MIPC (4 ccpies) p

LIGENSEE EVENT REPORT CONTROL sLOCxi l l

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3,3# r N43 IN A NON-CONSERVATIVE CONFIGURATION.

THIS EVENT IS NON-CONSERVATIVE WITH 3 is t l RESPECT TO TECHNICAL SPECIFICATIONS 3.0.4 AND 3.3.1.1 TABLE 3.3-1 ITEMS 7 AND 8.

IN ADDITION, THE ACTION REQUIREMENT WAS NOT FULFILLED WITHIN THE ONE HOU 1 i 71 I

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LER# 82-079/01T-0

. SUPPLEMENT TO EVENT DESCRIPTION DURING THE LOW POWER PHYSICS TESTING PROGRAM FOLLOWING THE END OF CYCLE 6 REFUELING, THE' UNIT ENTERED MCDE 2 AT APPROXIMATELY 2235 HOURS ON SEPTEMBER 14, 1982. AT THAT TIME, NUCLEAR INSTRUMENTATION SYSTEM CHANNEL N43 WAS INOPERABLE BECAUSE IT'S IONIZATION CHAMBERS WERE USED FOR THE IN-PUT TO THE REACTIVITY COMPUTER THAT IS USED FOR LOW POWER PHYSICS TESTS.

THE OVERPOWER DELTA-T AND OVERTEMPERATURE DELTA-T BISTABLES ASSOCIATED WITH NUCLEAR INSTRUMENTATION SYSTEM (NIS) POWER RANGE CHANNEL N43 SHOULD HAVE DEEN 6UT WERE NOT IN THE " TRIPPED" POSITION, WHICH IS NON-CCNSERVATIVE WITH RESPECT TO TECHNICAL SPECIFICATIONS 3.0.4 AND 3.3.1.1 TABLE 3.3-1 ITEMS 7 AND 8.

IN ADDITION, THE ACTION REQUIREMENT WAS NOT FULF'ILLED WITH-IN THE ONE HOUR ALLOWED BY ACTION ITEM 2a 0F SPECIFICATION 3.3.1.1.

THE FOLLOWING SEQUENCE OF EVENTS DESCRIBES AND EXPLAINS HOW THE TECHNICAL SPECIFICATIONS WERE VIOLATED AND HOW THE EVENT WAS DISCOVERED.

AS OPERidIONAL TIME Od UNIT 1 HAS BEEN ACCUMULATED, AN INCREASE HAS ALSO BEEN OBSERVED IN THE BEGINNING OF CYCLE, SUBCRITICAL, NUCLEAR INSTRUMENTA-TION SYSTEM POWER RANGE DETECTOR SIGNAL.

THIS SUBCRITICAL POWER RANGE

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SIGNAL CONSTITUTES A BACKGROUND TO THE. SIGNAL RESULTING FROM NEUTRONS, DURING ZERO POWER PHYSICS TESTS.

IF THIS BACKGROUND SIGNAL IS SUFFICIENTLY LARGE, IT CAN INVALIDATE R0D WORTH MEASUREMENTS.

IN ORDER TO COMPLETE TECHNICAL SPECIFICATION SURVEILLANCE 4.1.1.1.1.d, MEASURED R0D WORTH DATA ARE REOUIRED TO CALCULATE THE SHUTDOWN MARGIN. AS PART OF THE EFFOP,T TO STUDY THE BACXGROUND PROBLEM AND COMPENSATE FOR IT, BACKGROUND, LEVELS WERE

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MEASURED GN ALL FCUR NUCLEAR INSTRUMENTATION SYSTEM POWER RANGE CHANNELS BYSEOUENTIALLYCONNEChNGTHEREACTIVITYCOMPUTERTOEACHCHANNELDURING

s LERg 82-079/OlT-0 Page 2 of S J

THE WEEKS OF AUGUST 23, 1982 AND AUGUST 30, 1982. AS A RESULT OF THESE MEASUREMENTS, ON SEPTEMBER 1, 1982, POWER RANGE CHANNEL N42 WAS REPLACED AND SUBSEQUENT BACKGROUND LEVEL MEASUREMENTS WERE TAKEN TO DETERMINE WHETHER THE NEW DETECTOR WAS MORE SUITABLE FOR LOW POWER PHYSICS TESTING. A DETER-MINATION WAS MADE THAT THE NOISE LEVELS HAD INCREASED ON THE NEW N42 AND IT WAS DECIDED TO USE N43 FOR THE LOW POWER PHYSICS TESTING. DURING THE ABOVE MENTIONED MEASURE?iENTS OF THE DETECTORS AND THE. REPLACEMENT OF N42, THE REACTOR WAS IN MODES 3, 4 AND 5 AND THE OVERPOWER DELTA-T AND OVERTEMPERATURE DELTA-T BISTABLES ASSOCIATED WITH THE NUCLEAR INSTRUMENTATION SYSTEM CHANNEL BEING STUDIED WERE NOT TRIPPED.

AT APPROXIMATELY 0400 HOURS ON SEPTEMBER 15, 1982, APPROXIMATELY FIVE HOURS AFTER ENTERING MODE 2, A INSTRUMENT MAINTENANCE SUPERVISOR NOTICED THAT THE STATUS LIGHTS FOR THE OVERPOWER DELTA-T AND OVERTEMPERATURE DELTA-T CHANUEL ASSOCIATED WITH THE NUCLEAR INSTRUMENTATION. SYSTEM CHANNEL (N43) CONNECTE TO THE REACTIVITY COMPUTER WERE NOT ILLUMINATED (NOT INDICATING" TRIPPED").

BELIEVIN3 THIS WAS INCORRECT,' THE INSTRUMENT MAINTENANCE SUPERVISOR IN-

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STRUCTED A JUNIOR TECHNICIAN TO RESEARCH THE BISTABLES THAT NEEDED TO BE IN

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l THE TRIPPED POSITION. THE SUPERVISOR CONTINUED TO REVIEW OTHER INSTRUMENTA-TION IN THE UNIT 1 CONTROL ROOM TO ENS'RE THAT IT WAS FUNCTIONING PROPERLY.

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AT THIS TIME, THE SUPERVISOR RECEIVED A REQUEST FOR ASSISTANCE FROM THE UNIT 2 CONTROL ROOM. HE PROCEEDED TO THE UNIT 2 CONTROL ROOM WHERE HE 08-SERVED A TRANSIENT IN PROGRESS ON THE FEEDWATER HEATERS. HIS INTENTION WAS TO TAKE CORRECTIVE ACTION IF THE TRANSIENLWAS INSTRUMENT-RELATED BEFORE SITUATION WORSENED AND HE WISHED TO BE PP.ESENT IF THE REACTOR TRIPPED IN ORDERTOASSISTWITH45YRESULTlGPROBLEMSWITHINHISCCGNIZANCE.THE s

l

LER! 82-079/01T-0 PAGE 4 0F 5 J

AVAILABLE TO TRIP THE REACTOR.

IF A REACTIVITY EXCURSION HAD OCCURRED THE FOLLOWING TRIPS WOULD HAVE BEEN AVAILABLE:

1.

NUCLEAR INSTRUMENTATION SYSTEM SOURCE RANGE CHANNEL AT 105 cps, ONE OF 10 CHANNELS, BELOW P-6.

2.

NUCLEAR INSTRUMENTATION SYSTEM INTERMEDIATE RANGE CHANNEL AT 25% RTP, ONE OF TWO CHANNELS.

3.

NUCLEAR INSTRUMENTATION SYSTEM POWER RANGs NEUTRON FLUX, LOW SETPOINT AT 25". RTP, TWO 0F FOUR CHANNELS (N43 WAS ALREADY IN TRIP).

4.

NUCLEAR INSTRUMENTATION SYSTEM POWER RANGE NEUTRON FLUX, HIGH SETPOING AT g 25% RTP, TWO OF FOUR CHANNELS (N43 WAS ALREADY IN TRIP).

5.

FOR A RAPID POWER EXCURSION POWER RANGE NEUTRON FLUX, HIGH POSITIVE RATE, TWO 0F FOUR CHANNELS (N43 WAS ALREADY IN TRIP).

5.

IF A DEPRESSURIZATION ACCIDENT HAD OCCURRED, THE REACTOR WOULD MAYE TRIPPED AT 1815 PSIG AS A RESULT OF A SAFETY INJECTION ACTUATION. AT THIS PRESSURE THE RCS WOULD HAVE BEEN APPROXI-MATELY 76* F SUSC00 LED.

l 7.

THE OVERPOWER DELTA-T AND OVERTEMPERATURE DELTA-T TRIPS WERE ALSO AVAILABLE BUT WERE REDUCED FROM A TWO OF FOUR LOGIC TO A TWO OF THREE LOGIC.

TO PREVENT RECURRENCE THE APPLICABLE PROCEDURE FCR INITIAL CRITICALITY HAS SEEN MODIFIED TO INCLUDE A SIGNOFF SHEET TO ENS 9RE THE OVERPOWER DELTA-T AND OVERTEMPERATURE DELTA-T.3-I-STABLES FOR THE~ NUCLEAR INSTRUMENTATION SYSTEM CHANNEL THAT IS CONNEC'TED TO THE REACTI'(ITY COMPUTER ARE IN.THE TRIPPED POSITION BEFORE CONTROL RODS ARE WITHDRAWN.

i

LER#

82-079/01T-0 PAGE 3 0F 5

./

SUPERVISOR WAS INVOLVED IN UNIT 2 ACTIVITIES UflTIL APPROXIMATELY 0600 HOURS ON SEPTEMBER 15, 1982, AT THIS TIME, THE TECHNICIAN ASSIGt!ED TO THE OVERPOWER DELTA-T AtlD OVER' TEMPERATURE DELTA-T BISTABLES CONFERRED WITH THE MAINTENANCE SUPERVISOR ABOUT HIS FINDINGS AND THE BISTABLES WERE PLACED THE TRIPPED POSITION AT 0630 HOURS ON SEPTEMBER 15, 1982. THE PUBLIC HEALTH AND SAFETY WERE NOT AFFECTED.

SUPPLEMEf!T TO CAUSE DESCRIPTION TESTIllG WAS CONDUCTED TO DETERMINE BACXGROUND SIGNAL LEVEL ON THE NUCLEAR IllSTRUMEilTATION SYSTEM POWER RANGE CHANNELS IN MODES 3, 4, AND 5.

Itt THESE MODES, THE OVERPOWER DELTA-T AND OVERTEMPERATURE DELTA-T TRIP BISTABLES WERE !!OT REQUIRED TO BE TRIPPED AND WERE NOT TRIPPED ~. THE INITIAL CRITI-CALITY PROCEDURE DID NOT INCLUDE A HOLD POINT, PRIOR TO ENTERING MODE 2, T0 s

ENSURE THAT ALL REQUIRED BISTABLES WERE TRIPPED AFTER SELECTING THE CHAN TO BE USED FOR PHYSICS TESTING.

t OPEP.ATING PERSONNEL DID NOT OBSERVE THE FACT THAT THE OVERPOWER DELTA-T AND OVERTEMPERATURE DELTA-T BISTABLES WERE NOT TRIPPED. BEGINilING OF CYCLE PHYSICS TESTING IS A NORMAL ROUTINE ACTIVITY.

REMOVIllG THE POWER RANGE CHAN?!EL FROM SERVICE WAS NOT ASSOCIATED WITH AN ABNORMAL PLANT

.LINE-UP Ill THI.S EVOLUTION. THE ABSENCE OF OVERPOWER AND OVERTEMPERATURE DELTA-T STATUS LIGHTS IS fl0T AN INDICATI0ft THAT IS READILY IDENTIFIED l

UNLESS IT IS SEING SPECIFICALLY VERIFIED.

THE STATUS LIGHTS ARE IN A l

FART OF THE CONTROL ROOM SOME DISTANCE FROM THE flUCLEAR INSTRUf!EllTATION t

SYSTEM.

}.

FAILURE TO TRIP THE OVERPOWER DELTA-T AND 0VERTEMPERATURE DELTA-T BISTABLES WAS SERIOUS FRCM SOTH A TECHNICAL SPECIFICATION Atl0 PROCEDURAL CONT 0L POINT OF VIEW. HOWEVER, SEVERAL ALTERNATE REACTOR PROTECTION FEATURES WERE l

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59

.s LERf 82-079/OlT-0 PAGE 5 0F 5

./

IN ADDITION, CONTROLS HAVE BEEN ESTABLISHED PROHIBITING CHANGING OPERATIN3 MODES WITH REDUNDANT TECHNICAL SPECIFICATION EQUIPMENT PHYSICALLY IN0PER-ABLE, UNLESS A SPECIFIC EVALUATION VERIFIES ITS PROPRIETY.

PRIOR TO THE NEXT NEED TO PERFORM THIS TESTING, A TECHNICAL SPECIFICATION CHANGE REQUEST WILL BE PROCESSED FOR UNIT NO. 1 TO INCORPORATE THE NOTE "THE PROVISIONS OF SPECIFICATION 3.0.4 ARE NOT APPLICABLE" TO ACTION STATEMENTN0.2FORTECHNICALSPECIFICATION3.3II.1(TABLE 3.3-1).

THIS STATEMENT PRESENTLY EXISTS IN THE UNIT NO. 2 TECHNICAL SPECIFICATION.

THIS CHANGE IS EDITORIAL IN NATURE. WE HAVE ALWAYS UNDERSTOOD ThE TEC-NICAL SPECIFICATIONS TO PERMIT ZERO POWER PHYSICS TESTING.

TO DATE, FULL COMPLIANCE, HAS BEEN ACHIEVED.

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