ML17292B445

LER 98-012-01:on 980715,failure to Comply with Requirements of TS SR 3.8.4.7 Was Noted.Caused by Inadequate Work Practices.Training Session Was Held with Personnel.With 981027 Ltr

ML17292B445
Person / Time
Site:	Columbia
Issue date:	10/27/1998
From:	Parrish J, Schill F WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-98-182, LER-98-012, LER-98-12, NUDOCS 9811040081
Download: ML17292B445 (13)

Text

CATEGORY 1 REGULAT

~

Y INFORMATION DISTRIBUTIO S TEM (RIDS)

ACCESSION NBR:9811040081 DOC.DATE: 98/10/27 NOTARIZED: NO DOCKET ¹ FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME 'UTHOR AFFILIATION SCHILL,F.A. Washington Public Power Supply System PARRISH,J.V. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 98-012-01:on 980715,failure to comply with requirements of TS SR 3.8.4.7 was noted. Caused by inadequate work practices. Training session was held with personnel. With 981027 ltr.

DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE:

TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc.

NOTES: G RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD4-2 PD 1 1 POSLUSNY,C 1 1 INTERNAL: ACRS 1 1 AEOD/SPD/RAB 2 2 AEOD/SPD/RRAB 1 1 FILE CENTER 1 1 NRR/DE/ECGB 1 1 NRR/DE/EELB 1 1 NRR/DE/EMEB 1 1 NRR/DRCH/HICB 1 1 NRR/DRCH/HOHB 1 1 NRR/DRCH/HQMB 1 1 NRR/DRPM/PECB 1 1 NRR/DSSA SPLB 1 1 RES/DET/EIB 1 1 FIL 1 1 D

EXTERNAL: L ST LOBBY WARD 1 1 LITCO BRYCE, J H 1 1 NOAC POORE,W. 1 1 NOAC QUEENER,DS 1 1 NRC PDR 1 1 NUDOCS FULL TXT 1 1 THlS DOCUMENT HAS BEEN SCANNEO NOTE TO ALL nRZDSn RECIPIENTS PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DZSTRZBUTZON LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 23 ENCL 23

~y nor t'

WASHINGTON PUBLIC POWER SUPPLY SYSTEM PO. Box 96S ~ Richlaiul, Washingtou 99352-096S October 27, 1998 G02-98-182 Docket No. 50-397 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Gentlemen:

Subject:

WNP-2, OPERATING LICENSE NPF-21 LICENSEE EVENT REPORT 1998-012-01 Transmitted herewith is Licensee Event Report No. 1998-012-01 for WNP-2. This supplemental report is submittted pursuant to 10 CFR 50.73 and discusses additional details of the root cause analysis, corrective actions taken, and actions taken to preclude recurrence.

Should you have any questions or require additional information pertaining to this report, please contact PJ Inserra at (509) 377-4147.

Respectfully, JV Parrish Chief Executive Officer Mail Drop 1023 Attachment cc: EW Merschoff - NRC - RIV NRC Sr. Resident Inspector - 927N GA Pick - NRC - RIV DL Williams - SPA/1399 C Poslusny, Jr. -NRR PD Robinson - Winston &, Strawn 98ii040081 98%027 05000397 PDR ADQCK "8 <<r ~ PDR

LICENSEE EVENT REPORT (LER)

FACILITY NAME (1) DOCKET NUMBER (2) PAGE (3)

Washin on Nuclear Plant - Unit 2 50-397 1 OF 5 TITLE (4)

Failure to corn I with re uirements of Technical S ecification Surveillance Re uirement 3.8.4 .7 EVENT DATE (5) LER NUNBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED IB)

MONTH DAY SEQUENT)AL REV. DAY YEAR FACaflY NAME DOCKET NUMBER NUMBER NUMBER DOCKET NUMBER 07 15 1998 1998 012 01 10 27 1998 OPERATING THIS REPORT IS SUBMITTED PVRSVAtrZ TO THE REQVIREHBNTS OP 10 CPR 5) (check one or moto) (11) 20.402(b) 20.405(c) 50.73(a) (2)(iv) 73.71(b)

POH CR 20.405(s)(1)(t) 50.36(c)(1) 50.73(a)(2)(v) 73.71(c) 100 20.405(s) (1)(ii) 50.36(c) (2) 50.73(s)(2)(vii) OTHER 20.405(s) (1)(iii) x 50 73(a)(2)(t) 50.73(s)(2) (viii)(A) 20.405(s) (1)(iv) 50.73(a) (2) (ii) 50.73(a) (2)(viii)(B) 20.405(a)(1)(v) 50.73(a)(2) (iii) 50.73(a)(2)(x)

LICENSEE CONTACT FOR THIS LER I 1 2 )

NAME TELEPHONE NUMBER (Include Area Code)

F.A. Schill, Licensing Engineer (509) 377-2269 CQHPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

CAUSE ave)04 COMPONENT REPORTABLE CAUSE ave)tM COMPONENT MANUFACTURER REPORTABLE TO NPRDS TO NPRDS SUPPLENENTAL REPORT EXPECTED (14) EXPECTED MONTH DAY YEAR YES NO f corn ieted EXPECTED SUBMISSION DAT ABSTRACT:

On July 15, 1998 at 1600 with the plant operating at 100% power, it was determined that the 24 month Surveillance Requirement (SR) 3.8.4.7 had not been fulfilledwithin the specified Frequency of SR 3.0.2 for the division 2, 125 VDC battery E-Bl-2 IEJI. The Supply System declared SR 3.8.4.7 not met and then used the provision of SR 3.0.3 to delay declaring Technical Specification (TS) Limiting Condition for Operation (LCO) 3.8.4 not met while enforcement discretion was pursued. The Supply System requested and received enforcement discretion for completion ofthe battery service test of SR 3.8.4.7 for the division 2, 125 VDC battery E-B1-2.

SR 3.8.4.7 was not met because surveillance procedure ESP-B12-F101 was not revised to incorporate the "modified" discharge profile described in TS Bases 3.8.4.8 when surveillance procedure changes were made to implement the Improved Technical Specifications. Note 1 of SR 3.8.4.7 permits the use of a "modified" performance discharge test to be performed in lieu of the battery service test once every 60 months. The battery discharge profile in the 60 month performance discharge surveillance procedure ESP-B12-F101 was not modified to envelope the discharge profile of the service test and therefore was not sufficient to meet the requirements of SR 3.847 when it was used for that purpose on April 30, 1997. This procedure deficiency was ~

discovered as a result of questions raised by the NRC during an engineering inspection at WNP-2. A subsequent evaluation revealed that this event had no impact on the battery's capability to perform its intended safety function. The root cause for this event is that work practices used when the procedure was revised were inadequate to ensure that the modified discharge profile was incorporated as part of the changes required for implementation of Improved Technical Specifications.

0

.,"<aa 1 r- ask&I, "Jb

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION

~ FACILITY NAME (I) DOCKET NUMBER (2) LER NUHBER (6) PAGE (3)

SEQUENTIAL REVISION NUMBER NUNBER 2 OF Washington Nuclear Plant - Unit 2 50-397 1998 012 01 TEXT (If more space is required, use additional copIes of NRC Form 366A) (17)

Event Descri tion On July 15, 1998 with the plant operating at 100% power, it was determined that the requirements of the 24 month Surveillance Requirement (SR) 3.8.4.7 had not been fulfilled within the Prequency plus the allowed extension time specified in the, Technical Specifications (TS) for the division 2, 125,VDC battery E-Bl-2 tEJj. The Supply System declared SR 3.8.4.7 not met, then used the provision of SR 3.0.3 to delay taking compensatory measures required by TS Limiting Condition for Operation (LCO) 3.8.4,, while enforcement discretion was pursued. The Supply System requested and received enforcement discretion from the StafF for completion of the battery service test of SR 3.8.4.7 for the division 2, 125 VDC battery E-B1-2.

SR 3.8.4.7 was not fully met because the battery discharge profile in the 60 month performance discharge surveillance procedure ESP-B12-F101 was not sufficient to meet the requirements specified in the TS Bases for SR 3 8 4 7. Note i of SR 3 8 4 7 permits the use of a "modified" performance discharge test to be performed in ~

lieu of the battery service test once every 60 months. This was a change from previous TS (SR 4.8.2.1.e) which allowed the unmodified performance test to be performed in lieu of the battery service test once every 60 months. Surveillance procedure ESP-B12-F101 was not rewritten to incorporate the "modified" discharge profile prior to its use on April 30, 1997 to meet SR 3.8.4.7 in accordance with the note. The fact that the requirements of SR 3.8.4.7 had not been met was determined as a result of questions raised by an NRC inspector who ~

was conducting an engineering inspection at the time. The inspector's questions resulted in the discovery of the inadequate battery surveillance procedure.

Immediate Corrective Action The Supply System reviewed historical test data for the battery to determine ifjustification existed for continued reliance on the battery to perform its required-safety function. Once this justification was established and the manufacturer's concurrence obtained, enforcement discretion was pursued. After enforcement discretion was granted, the Supply System submitted an exigent Technical Specification amendment request to allow the (unmodified) performance discharge test specified in SR 3.8.4.8 to be performed in lieu of the battery service test for the division 2, 125 VDC battery E-B 1-2. It was requested this amendment remain in efFect until entry into Operational Mode 4 (cold shutdown) for the R-14 maintenance and refueling outage or a forced outage of sufficient duration to perform the service test.

Additionally, a review of other surveillance procedures used to meet the conditions of station battery SRs was conducted. This review determined that the same situation existed for the division 1 and 3 125 VDC batteries and the division 1 250 VDC battery. However, the Frequency requirements of SR 3.0.2 have not been exceeded for performance of the service tests (SR 3.8.4.7) for these batteries. An amendment to TS was requested to avoid a TS noncompliance for these batteries as well.

~ ~

fQ4k ci

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION

~ FACILITY NAME II ) DOCKET NUMBER i2) LER NUMBER i6) PAGE I 3)

SEQUENTIAL rtEVI SION NUMBER NUNBER 3 OF Washington Nuclear Plant - Unit 2 50-397 1998 012 01 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

Further Evaluation The battery service test required by the 24 month SR 3.8.4.7 is a special test of the battery's as found capability to satisfy the design requirements (battery duty cycle) of the DC Electrical power system tEIj. The test discharge rate and test length correspond to the design duty cycle requirements specified in the WNP-2 FSAR (Section 8.3.2).

The 60 month SR 3.8.4.8 is satisfied by performance of a battery performance discharge test or a modified battery performance discharge test.

A battery performance discharge test is an as found test of the constant current capacity of the battery intended to determine overall battery degradation due to age and usage. In this test, the battery is subjected to a constant discharge rate.

A modified battery performance discharge test is a combination of the two aforementioned tests and is considered a more severe test of battery capacity. It employs two discharge rates, a short duration discharge rate consistent with the largest current load of the duty cycle, followed by the discharge rate used in the battery performance discharge test.

The test is intended to confirm the battery's ability to meet the critical period of the load duty cycle and determine its percentage of rated capacity. The discharge rate of the modified performance test envelopes the duty cycle of the service test described above.

Technical Specification SR 3.8.4.7 (Note 1) allows the modified performance discharge test of SR3.8.4.8 to be performed in lieu of the 24 month battery service test once every 60 months in order to fulfillthe requirements of SR 3.8.4.7 and SR 3.8.4.8 with the performance of one test in order to avoid excessive battery depletion. The provision of this note was not fully implemented the last time the surveillance was performed for the Division 2 125 VDC battery (April 1997) in that the test that was performed was the performance discharge test and not the modified performance discharge test.

Prior to the implementation of Improved Technical Specifications (ITS), the Technical Specifications allowed the performance test (vice the modified performance test) to satisfy the service test surveillance requirements once every 60 months.

Root Cause The root cause for the noncompliance is that the work practices used to convert these specific battery procedures were ~

inadequate to ensure that the modified performance test discharge profile was incorporated. The preparation, review, and approval activities ofthe individuals assigned to these procedures were not carried out in a manner that ensured all changes were incorporated. None of the individuals involved with the subject procedures ensured that a critical review of all the required changes, regardless of their characterization in the ITS change documents, was performed.

A V

~ (~ J.

k

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION

~ FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3)

SEQUENTIAL REVISION NUMBER EUNEER 4 OF Washington Nuclear Plant - Unit 2 50-397 1998 012 01 TEXT (If more space Is required, use additional copies of NRC Form 366A) (17)

The performance discharge test was not revised adequately because of a failure to recognize that the requirements for crediting SR 3.8.4.7 with the performance discharge test of SR 3.8.4.8 was, in effect, a more restrictive requirement.

This change was categorized as a less restrictive change in the ITS Discussion Of Changes (DOC) document.

Additionally, the DOC incorrectly stated that a note to SR 3.8.4.7 would allow the performance discharge test to be substituted for the service test once every 60 months. Although the DOC incorrectly described the note, the ITS and the ITS Bases correctly describe the note as allowing only the modified performance discharge test to,be performed in lieu ofthe service test once every 60 months.

Corrective Actions Taken A training session was held with personnel responsible for incorporation of ITS requirements into the battery procedures. The'objective of the training was to promote understanding of lessons learned from this event and to coach expectations for future performance when conducting procedure revision activities.

A review of the ITS changes required for battery LCOs 3.8.4, 3.8.5, and 3.8.6 was performed to identify any discrepancies to the implementing procedures. This review identified several less restrictive and administrative changes that were not implemented in the battery procedures. The procedures were subsequently revised to reflect the changes.

WNP-2 entered Mode 4 on August 8, 1998. During the ensuing forced outage, the battery service test was performed on the division 1, 2, and 3, 125 VDC batteries and the division 1, 250 VDC battery with satisfactory results. The performance of these tests established compliance with SR 3.8.4.7 for the current operating cycle negating the need for enforcement discretion or an amendment to the Technical Specifications.

The current revisions of the performance discharge test procedures have been deactivated until they are revised to incorporate the discharge profile required for the modified performance discharge test in order to prevent their use for crediting SR 3.8.4.7.

Further Corrective Action To ensure other procedure reviewers maintained adequate attention to detail during ITS implementation, a self assessment of several LCO sections of TS will be conducted to determine ifall details of the ITS changes were implemented by the appropriate surveillance procedures and TS Bases.

The performance discharge test procedures for all applicable batteries will be revised to incorporate the battery discharge profile required for the modified performance discharge test.

4 C'I 1

>4~~

M

~ ~ V LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME II ) DOCKET NUMBER I2) LER NUMBER I6) PAGE I 3)

SEQUENTIAL REVISION NUMBER NVNEER 5 QF Washington Nuclear Plant - Unit 2 50-397 1998 012 01 5 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

Assessment of Safet Conse uences The service test requires a discharge rate of 400 amps for the first six seconds then drops to less than 250 amps for a duration of two hours. The performance test requires a constant discharge of 350 amps for two hours. Therefore, a difFerence of 50 amps for the first six seconds is not enveloped by the performance test. The service test requirement of 400 amps is less than half of the manufacturer's one-minute discharge rating of the battery (922 amps). The performance test completed in April of, 1997 demonstrated a battefy capacity of 104.7% which is above the battery replacement criteria of 80% capacity. Additionally, the batteiy has been installed for less than five years and test data indicate an expected improving trend in battery capacity. Based on the substantial battery capacity demonstrated by the performance test and the short duration peak load required by the service test (400 amps) as compared to the one-minute rating of the battery (922 amps), the battery is fully capable of meeting the requirements of the modified performance test and the service test. Regularly performed surveillance activities of intercell connector resistance measurement, specific gravity, visual condition and battery terminal voltage indicate continued acceptable battery performance. The battery manufacturer has stated in writing that the difference between the performance discharge test and the modified performance discharge test is not significant relative to the battery capacity and its short duration discharge rate.

Based on this justification, historical test data, and results of the service test performed on August 11, 1998 it is the Supply System's position that even though SR 3.8.4.7 was not met, battery E-Bl-2 has always been able to reliably perform its designed safety function. Therefore, there were no safety consequences resulting &om this event.

Additional Information Block 5 in the heading of Revision 00 of this LER contains an event date of July 16, 1998. This date is erroneous and incongruent with the event date of July 15, 1998 described in the abstract and narrative sections of the Revision 00 report. The heading has been corrected in this revision.

The requested Technical Specification amendments to SR 3.8.4.7 relative to this event have been withdrawn.

Similar Events There have been no recent similar events.