ML18066A178

LER 98-008-00:on 980511,noted That Procedure Did Not Fully Satisfy Requirement to Test High Startup Rate Trip Function. Caused by Misunderstanding of Testing Requirements.Revised TS Surveillance Test Procedure & Reviewed Other Procedures

ML18066A178
Person / Time
Site:	Palisades
Issue date:	06/09/1998
From:	Engle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML18066A177	List: ML18066A176 ML18066A178
References
LER-98-008, LER-98-8, NUDOCS 9806150306
Download: ML18066A178 (4)

Text

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104

\J (4/95) EXPIRES 4130/98 ESTIMATEO BURDEN PER RESPoNse TO C0MPLY wm1 THIS MANDATORY INFORMATION COUECTION REQUEST: 50.0 ~. REPORTED LESSONS l.EARHEOARE LICENSEE EVENT REPORT (LER1 IN CORPORATEO INTO THE LICENSING PROCESS AND FED BACK TO INDUSTRY.

FORWARD COMMENTS REGARDING BURDEN ESTIW.TE TO THE INFORMATION AND RECORDS MANAGEMENT BRANCH (T.e F33). U.S. NUCLEAR REGUlATORY COMMISSION. WASHINGTON, DC 20S55--0001, AND TO THE PAPER'M:>RK REDUCTION (See reverse fc:ir required number of digits/characters for each block) PRO.eCT (3150-0104, OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON, DC 20503 DOCKET NUMBER (2) (3)

FACIUTYNAME(1) CONSUMERS ENERGY COMPANY PAGE 05000255 1of4 PALISADES NUCLEAR PLANT I TITLE (4) LICENSEE EVENT REPORT 98-008, "REACTOR PROTECTION SYSTEM, HIGH STARTUP RATE TRIP NOT VERIFIED DURING TECHNICAL SPECIFICATION SURVEILLANCE TESr EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8)

FACILITY NAME DOCKET NUMBER I

SEQUENTIAL REVISIO MONTH DAY YEAR YEAR N MONTH DAY YEAR 05000 NUMBER NUMBER FACILITY NAME DOCKET NUMBER 05 11 98 98 008 0 06 09 98 05000 OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR§: (Check one or more) (11)

MODE(9) N 20.2201 (b) 20.2203(a)(2)(v) X 50.73(a)(2)(i) 50.73(a)(2)(iii)

I POWER LEVEL (10)

• I

. 0 l,__""""""2~0,~22~0~3(_a)_(1~)--------t~2~0.~22~0~3(_a)_(3~)(=i)____.,__..,5=0~.7~3(~a)~(2_)(=ii)____-+---t-5=0~.7-3(_a)_(2_)(_x)____~,

. 20.2203(a)(2)(i) 20.2203(a)(3)(ii) 50.73(a)(2)(iii) 73.71 LICENSEE CONTACT FOR THIS LER (12)

NAME Dale Engle, Licensing Engineer TELEPHONE NUMBER (Include Area Code)

(616) 764-2848 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT 13)

CAUSE SYS COMPONENT MANUFACTURER REPORTABLE CAUSE SYS COMPONENT MANUFACTURER REPORTABLE TONPRDS TONPRDS D IG 39 G077 N SUPPLEMENTAL REPORT EXPECTED (14) MONTH DAY YEAR I YES If yes, COMPLETE EXPECTED COMPLETION DATE x I NO EXPECTED SUBMISSION DATE (15)

ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 sirigle-spaced typewritten lines) (16)

On May 11, 1998, during a review of a Technical Specification Surveillance Test Procedure, it was discovered that the pro~dure did not fully satisfy the requirement to test the High Startup Rate Trip function (94) within seven days prior to each plant startup. This discrepancy was discovered while the plant was in a refueling shutdown. The Technical Specification Surveillance Test Procedure checked the wide range neutron monitor (mon) startup rate function, but the procedure steps did not specifically verify a reactor trip signal had been received. This procedure deficiency had existed since 1991 and was present on at least twelve occasions when the procedure was performed to satisfy Technical Specification requirements. A review of other Technical Specification Surveillance Test Procedures confirmed that a Channel Functional Test of the High Startup Rate Trip had been completed periodically, and operability was verified by the performance of other surveillance procedures; however, these other procedures had not been performed within the required seven days prior to plant startup. This event was caused by a misunderstanding of the testing requirements as described in the Technical Specifications. Corrective actions included revising the Technical Specification Surveillance Test Procedure to include appropriate completion of the Channel Functional Test for the RPS High Startup Rate Trip function within seven days prior to plant startup; -and completion of a review of other Technical Specification Surveillance Test Procedures needed for the current plant startup which require a Channel Functional Test, to assure associated Technical Specifications have been properly addressed. No other occurrences were found.

9806150306 980609 PDR ADOCK 05000255 S PDR

NRC FORM 366a 4/95

• U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION

~

I FACILITY NAME l1\ DOCKETl2\ LER NUMBER 6\

YEAR REVISION CONSUMERS ENERGY COMPANY SEQUENTIAL

• NUMBER NUMBER PALISADES NUCLEAR PLANT 05000255 4 98 008 00

..

TEXT (If more space 1s required, use additional copies of NRC Form 366A) (17)

EVENT DESCRIPTION On May 11, 1998, during a review of a Technical Specification Surveillance Test Procedure P0-1, "Operations Pre-Startup Tests," it was discovered that the procedure did not fully satisfy the requirement to test the High Startup Rate Trip function (94) within seven days prior to each plant startup. This discrepancy was discovered while the plant was in a refueling shutdown. The procedure performed a test of the High Startup Rate function, but the procedure steps did not fully meet the definition of a 'Channel Functional Test' as defined by the Palisades Technical Specifications. The definition of a Channel Functional Test is the injection of a simulated signal into the channel to verify that it is operable, including any alarm and trip initiating function. The procedure, completed within seven days prior to plant startup, checked the wide range neutron monitor (mon) startup rate function and included insertion of an internally generated signal to verify full scale indication, but did not specifically contain a step to verify that the High Startup Rate Trip was received. This procedure deficiency had existed since 1991 and was present on at least twelve occasions when the procedure was performed to satisfy Technical Specification requirements.

ANALYSIS OE THE EVENT The Technical Specification surveillance requirement to perform a Channel Functional Test had been completed at the appropriate frequency until 1991. The High Startup Rate Trip was verified through observation of the internal trip indication on the front of the nuclear instrumentation (NI)

• processor. These same NI processors were replaced in 1991 with processors that did not have this internal trip indication. After this modification was complete, the Technical Specification Test Procedure was revised and no longer included verification of the High Startup Rate trip function.

Revisions to Technical Specifications (approved in 1975) removed details of the testing method from the Surveillance Requirements Section, based on the reasoning that details were provided in the Definitions Section of the Technical Specifications. Later, in 1991 when the NI processors were replaced, personnel did not understand that the specific testing requirements were defined in the Definitions Section of the Technical Specifications. Therefore the procedure (revised in 1991) completed testing by a literal interpretation of the information provided in the Surveillance Requirements Section, which stated that the surveillance requirement was a test using an internally generated test signal. Consequently, the procedure did not contain steps to verify the High Startup Rate Trip function.

A review of other Technical Specification Surveillance Test Procedures verified that valid Channel Functional Tests had been completed periodically for the High Startup Rate Trip function, but none were performed within the required seven days prior to plant startup.

NRC FORM 366a 4/95

• U.S. NUCLEAR REGULA TORY COMMISSION LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME 111 CONSUMERS ENERGY COMPANY PALISADES NUCLEAR PLANT

..

DOCKETl2l 05000255 TEXT (If more space 1s required, use add1t1onal copies of NRC Form 366A) (17)

YEAR 98 LER NUMBER 16\

I SEQUENTIAL NUMBER 008 REVISION NUMBER 00 g 4 SAFETY SIGNIFICANCE The High Startup Rate Trip function is an anticipatory trip that is not credited in any of the design basis accident analyses. In addition, other Technical Specification Surveillance Test Procedures periodically performed a complete Channel Functional Test which ensured that the High Startup Rate Trip was operable when required.

Therefore, although a Channel Functional Test of the High Startup Rate Trip may not have been performed within 7 days prior to each reactor startup, the procedures discussed above ensured continued operability of the High Startup Rate Trip.

CAUSE OF THE EVENT The cause of this event was a failure to understand the intent of test requirements in past Technical Specification revisions for the High Startup Rate Trip function.

• When the NI processors were replaced and there was no longer a High Startup Rate Trip indicating light on the front of the processors, the surveillance procedure should *have been revised

. to verify the trip function using another method. It appears that the procedure author did not understand the definition of "Test" for the Wide Range Neutron Monitors.

CORRECTIVE ACTIONS Corrective Actions Completed

1. Technical Specification Surveillance Procedure (P0-1) was revised to include directions for accomplishing a proper Channel Functional Test of the High Startup Rate Trip within 7 days of startup.

2. A sample of Technical Specification Surveillances requiring a channel function test, was reviewed to assure the Surveillance Test Procedures fully implement Technical Specifications requirements. No additional discrepancies were found.

3. Discussion with the sponsor of Technical Specification Surveillance Procedure P0-1 has assured understanding of the intent of the stated Technical Specifications test requirements.

NRC FORM 366a 4/95

• U.S. NUCLEAR REGULA TORY COMMISSION LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME 11 \

CONSUMERS ENERGY COMPANY PALISADES NUCLEAR PLANT

..

DOCKET12\

05000255 TEXT (If more space 1s required, use additional copies of NRC Form 366A) (17)

YEAR 98 LER NUMBER 6\

I SEQUENTIAL NUMBER 008 REVISION NUMBER 00 g 4 Corrective Actions to be Completed Complete a review of all surveillance procedures that are intended to perform a Channel Functional Test to, assure the requirements of the Technical Specifications are satisfied.