05000388/LER-1997-007-01, :on 971017,TS 3.0.3 Entry Voluntarily Made. Caused by Inadequate Post Maint Testing Following Earlier Work Associated W/Components.Failed Components Repaired, Replaced & Testing Completed
| ML18026A489 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 11/17/1997 |
| From: | Ellis S PENNSYLVANIA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML17159A053 | List: |
| References | |
| LER-97-007-01, LER-97-7-1, NUDOCS 9711210145 | |
| Download: ML18026A489 (30) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2) 10 CFR 50.73(a)(2)(iv), System Actuation 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 3881997007R01 - NRC Website | |
text
HIJLl LD l>WCI LZ IOC ua rWI. mOb( mV u(.r II C (J ( PtC Vd(d NRO EORM 366 (4+6]
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CLEAR REGULATORY COMMISSION IXCEHSEE EV&2PZ REPORT (TER)
(See reverse for required number of digits/characters for each block)
PROVED BY OMB NO. 31504104 EXPIRES 04/30/98 ESTIMATED BURDEN PER. RESPONSE TO COMPLY WITK TRIS MANDATOAY INFORMATION COLLECTION REOUESTI SO.O KRS, RFPOATED LESSONS LEARNED ARE OICOAPORATEO INTO TKE UCENSING PROCESS AND FEO BACK TO INDUSTAY'.
FORWARD COMMENTS REGARDING BUADEN ESTIMATE TO TKE INFORMATON AND RECORDS MANAGEMENT BRANCH IT 6 F33]. U.S. NUCLEAR REGULATORY COMMISSION, WASKINGTON, OC 2055$ 4OOI, AND TO THE PAPERWORK REDUCTION PROJECT t3160 0104), OFFICE OF MANAGEMENTAND BUDGET, WASKWGTON. DC 20503.
FACIUTYIl(V(IEI'II Susquehanna Steam E(ectric Station - Unit 2 oooo( NvM4EIIIEI 05000388 PAQE Is) 1 OF 5 Entry into Technical Specification 3.0.3 - Rod Block Monitor Operability Testing EVENT PATE (5]
OAT LER NUMBER (6)
TEA(I SEOVENTIAl REVISION NUM$EA NUMaQI REPORT PATE 7]
MONI1(
OAT FACtulYHAME OT1tER FACILI I S I VOLVEO (8]
OOCIID'VM4ER 05000 10 17 97 97 007 00 11 17 97 FACEI1Y KIJKE OOCKET NVI(4OI 05000 ING MODE (9)
POW R LEVEL (10)
THIS REPORT IS SUBMI EO 20.2201 (D]
20.2203(a)(1) 0.2203(a](2]0]
20.2203(a)(2)(>>)
>>II 20, 3(a] (2) liv)
ZO.ZZ03(a] (2]I>>]
20.2203(a)(3) (i) 20.2203la) (3)tii]
20.2203(a) (4) 0.3 te)(1 50.36lc](2]
UIAEMENTSOF 10CFR:
l cc oooo 5.73(a](2]li) 50.73(a)(2) (>>)
- 6) (2]llii]
50.73(a)(2)(iv)
- 50. 3la)l Itv]
50.
Ia)(2)(VBI r more] l11]
50,73(a] (2](yIII]
50.73(a) l2)(x)
OTHER pacify h Abstrael below o(>>I NRC Fo(m 366A LICENSEE CONTACT FOR I
L R (12)
NAME Stephen J. E)lis - Nuclear Licensing Engineer TELEX(ONE NI>>(ISEA II>>CLAIAtaa COdt) 717/542-3537 OMPLE E ONE N
C IVI NEN ALLUREPES CRISEP IN HIS REPORT (13]
CAllS4 sYST6M CQMPONEtc(
%44lhF*CTVRER sysTEM Co>>VONENT NANVfACTVAER REPORTAILE To NPabs SUPPLEMENTAL R ORT X
YES (II Yes, comp]etc EXPECTED SUBMISSION DATE).
(14)
EXPECTEO SUBMISSION DATE (15),
MONTH OAY YEAR ABSTRACT (Liltto 1400 spaces, I,e., aPproximately 15 sin(]te spaced typewrmen ilneS (16]
On October 17, 1997, at 0920 hours0.0106 days <br />0.256 hours <br />0.00152 weeks <br />3.5006e-4 months <br />, with Unit 2 in.Condition 1 (Power Operation) at 100% Power, a Technical Specification 3.0.3 entry was voluntarily made.
In accordance with the guidance of NUREG 1022, a Technical Specification 3.0.3 entry requires an LER to be submitted within 30 days of the event.
The entry was made to allow completion of surveillance testing of one channel of the Rod Block Monitor
'RBM)t after considering the other available options.
There is no provision provided in current Technical Specifications to allow operability testing without entry into Technical Specification 3.0.3.
It is PPRI 's position that this course of action was the most conservative from a nuclear safety perspective.
The Technical Specification 3.1.4.3 ACTlON statement had been entered to perform surveillance testing of one channel of the RBM. Unexpected results had been obtained during the testing.
Investigation of these results determined that 11 LpRMs were not providing an output to the RBM. The testing resumed prior to the expiration of Technical Specification 3.1.4.3 ACTION allowable time limit, but was not completed before the limit expired, thus requiring Technical Specification 3.0.3 entry. The cause of the LPRM failures has been traced to inadequate post maintenance testing following earlier work associated with these components.
The failed components were repaired/replaced, testing was completed and the RBM retu<<ed to operable status.
The safety significance of this event was minor, and the health and welfare of the public was not compromised.
The technical aspect of this event will be reviewed with the work group and a review of associated work plans and procedures willbe performed, and appropriate changes implemented.
NRC FORM 366 (4 35]
4(I(I(495)
LICENSEE EVENTREPORT g ER)
TEXT CONTINUATION U.S. NUCLEAR REGULATORY COMMSSION'ACILITY NAME t1)
DOCKET 05000 LER NUMBER I6)
YCAll
- IAl, V
H
~50l HUMID PAGE (3)
Susquehanna Steam Electric Station - Unit 2 TEXT (ifmore speceis required, use edditionef copies ofHRC Form 36'O'Al I)7) 388 97 007 00 2
OF 5
EVENT DESCRIPTION
On October 17, 1997, at 0920 hours0.0106 days <br />0.256 hours <br />0.00152 weeks <br />3.5006e-4 months <br />, with Unit 2 in Condition 1( Power Operation) at 100%
power, a Technical Specification 3.0.3 entry was voluntarily made.
On October 16, 1997, at 0820 hours0.00949 days <br />0.228 hours <br />0.00136 weeks <br />3.1201e-4 months <br /> Technical Specifications Limiting Condition for Operation (LCO) 3.1.4.3 ACTION and 3.3.6 ACTION 60 were entered to perform required surveillances for the Rod Block Monitor (RBM) (EIIS Code: I). The RBM must be removed from service to perform
~ these surveillances.
The ACTION of the most limiting Technical Specification states:
"With one RBM channel inoperative, restore the inoperative channel to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and verify that the reactor is not operating on a LIMITINGCONTROL ROD PATTERN; otherwise, place the, inoperable rod block monitor channel in the tripped condition within the next hour."
A few hours into the testing, unexpected results were observed and testing was halted to investigate these results.
Since the RBM remained inoperable, the LCO ACTION remained in
~.> effect. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time period expired prior to restarting the surveillance testing.
One hour remained before the Technical Specifications ACTION requires that the RBM channel be placed into the tripped condition.
Prior to the expiration of the one hour period, testing was restarted.
., Since testing had begun, the decision was made to voluntarily enter Technical Specification 3.0.3, considering that the completion of the surveillance testing would allow this channel of the
, RBM to be restored to service.
Technical Specification 3.0.3 was entered at 0920 hours0.0106 days <br />0.256 hours <br />0.00152 weeks <br />3.5006e-4 months <br /> on October 17, 1997 and exited at 1410 hours0.0163 days <br />0.392 hours <br />0.00233 weeks <br />5.36505e-4 months <br /> on October 17, 1997.
It was determined that the RBM was actually operating as designed.
A number of the Local Power Range Monitors(LPRM) (BIS Code: I) had a zero volt output to the RBM. The RBM correctly identified a zero input condition from an LPRM(s) and, automatically eliminated it from the averaging circuit. As long as the RBM had more than the required minimum number of
'good'PRlVI inputs, it continued to function normally.
CAUSE OF EVENT
The cause of.the unexpected results of the RBM 'surveillance has been traced to the failure of components in the LPRM output to the RBM. When these components failed, their output to the RBM went to zero volts.
11 LPRMs were identified to have this condition.
LPRM output to the Average Power Range Monitor (APRM) (EIIS Code: I), the Oscillation Power Range Monitor (OPRM) (EIIS Code:I), and to the plant computer were normal.
It has been determined that the cause of the failed components stems from a power supply failure in June of 1997.
The power supply had been replaced and outputs to the APRM and computer were checked, but not the outputs to the RBM. The post maintenance testing followingthe power supply replacement was not adequate, and is considered a root cause of the event.
~
= ~ NAC.FOAM 366A ls-N)
LICENSEE EVENTREPORT (MR)
TEXT CONTINUATION U,S, NUCLEAAAEGULATOAYCOMMlSSION FAClLITYNAMEl1)
DOCKET 05000 l.ER NUMBER [6)
YKAA V
I N HVM44R NVa444a PAGE l3)
SUsquehanna Steam Electric Station - Unit 2 388 97 007
00 3
OF 5
TEXT (Ifmore spece is required, crse ed/donsi copies ofHRC Form 366AJ l17)
Entry into Technical Specification 3.0.3 is required when an inoperable channel of RBM is not in the tripped condition following the expiration of allowable time limit of Technical Specification 3.1.4.3 ACTlON (a); ln order to perform the operability testing, the RBM can not be in the tripped condition. The entry into 3.0.3 is required.
The root cause of the Technical Specification 3.0.3 entry is an administrative omission in the current Technical Specifications.
Improved Technical Specifications contain provisions to perform operability testing on inoperable
.equipment without entry into a shutdown action statement.
Entry into Technical Specification 3.0.3 was determined to be an appropriate and conservative course of action given this event.
REPORTABILITYANALYSlS This Licensee Event Report is being made per 10 CFR 50.73(a)(2)(i)(B), in that NUREG 1022 requires the reporting of any entry into Technical Specification LCO 3.0.3.
Technical Specification 3.0.3 was conservatively entered to allow completion of surveillance testing of one channel of the RBM. As previously noted, one channel of the RBM was removed from service to perform surveillance testing.
During that testing, unexpected results were obtained.
The time to evaluate these results and then complete the testing was going to exceed the time allowed by Technical Specifications.
Since completion of the surveillance testing would allow the RBM to be restored to operable status, the decision was made to resume testing and a Technical Specification 3.0.3 entry was made when Technical Specification 3.1A.3 ACTION (a) expired.
This decision was made after considering the following alternatives:
1.
Place the RBM to the tripped condition.
~
Placing the RBM to the tripped condition at this time would only delay restoring it to an operable condition, The problem with the LPRM had been repaired and the surveillance testing was ready to resume.
Restoration of the equipment in the most timely manner is consistent with assuring the highest standards of nuclear safety.
~
Placing the RBM to the tripped condition at that time would still require entry into Technical Specification 3;0.3 in order to resume testing.
The need to enter Technical Specification 3.0.3 for performance of operability testing was a known administrative shortcoming of current Technical Specifications.
- 2. Reduce power to <30%, thereby placing the unit in a condition where Technical Specification 3.1.4.3 is not applicable.
NRC FOAM 366A l4 SS)
HUJ LD L'd>tf Lg'k4 uv mv wm tccv uI r)I c; I J I 1PRC IIIIVI4.95)
XXCENSEE EVENTREPORT (LER)
TEXT CONTINUATION v.s. NUCLEAR REGULATORY COMM)ss)ON FAG)I.ITYNAME(1)
Susquehanna Steam Electric Station - Unit 2 DOCKET 05000 388
).ER NUMBER (6)
N IAI.
aVMBBA
)IVMBEa 97 -
007
00 PAGE )3) 4 OF 5
TEXT (Ifmore spece is required, ceo eddiuonol copies ofNRC Arm 386AI (17)
~
Anytime a power reduction is undertaken, especially to a relatively low power level, there is an increased challenge to plant operations personnel.
Unnecessary challenges to the plant and the operators is not a conservative course of action.
There would be no sa'fety benefit derived from a power reduction in this situation.
Based on the above considerations, the decision was made not to trip the RBM and to resume testing.
This course of action is conservative in that it restored the plant eqvipment to an operable status in the most expeditiovs manner without compromising nuclear safety.
At no time during this event was the ability of the plant to safely shutdown or the health and welfare'of the public compromised.
The significance of this event from a safety standpoint was minor. The other channel of the RBM was available throvghout this period to provide rod block protection, as well as the APRMs to provide core protection in the event of a power transient.
In accordance with the gvidance provided in NUREG 1022, Supplement 1, the required submission date of this report was determined to be November 17I 1997.
CORRECTIVE ACTIONS
With regard to the Technical Specification 3.0.3 entry, PPSL considers this action appropriate.
Improved Technical Specifications addresses this type situation by providing allowance for operability testing withovt entering a shvtdown action statement LCO. PPSL's improved Technical Specification submittal is in review by the commission.
A Technical Specification change request to the current Technical Specifications has been submitted to the NRC to extend the LCO ACTION statement allowable time for one RBM channel inoperable from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to seven days.
Improved Technical Specifications also reflects the lengthened ACTlON time limits.
The failed components identified in the LPRMs were repaired/replaced.
The following actions are scheduled to be completed:
A review of the technical aspects of the event with the involved maintenance work group stressing the importance of comprehensive post maintenance testing.
~
A review of work plans and procedures'associated with the LPRMs, APRMs, and RBMs to determine and implement satisfactory methods of ensuring that all outputs from the LPRMs are sufficiently tested following work activities.
Evaluate results/conclusions of above review for generic applicability to other systems.
HLAl 10 4 'p'V0 LZ OD uv wet.'mm ma ur r sac I Jl ~C, IVIV I
~ ka NRC 'FORM 366A g SSI LICENSEE EVENT,REPORT (LER)
TEXT CONTINUATION U,S. NUCLEAR REGULATORY COMMISSION FACILITYNAME[1)
Susquehanna Steam Electric Station - Unit 2 DOCKET 05000 388 LER NUMBER I6)
YCAR N IAI, auvarA marsrR PAGE )3) 97 007
00 5
OF 5
TEXT (lfmore speceis required, use eddie'opal copies offVRCForm 366AI (17)
ADDITIONALINFORMATIO Past similar events:
None Entries into Technical Specification 3.0.3 have been reported on numerous occasions, although none of the previous reports were a result of a similar condition.
Failed Component:
None LER written for Technical Specification 3.0.3 entry, the failed components were not the reason for submitting this report.
uo iud wm ma urr sis REFERENCE 5
IXI M%C COND)TIONREPORT-EVENTREPORTING FORM QRI81NAl Identifying Organization:
Operations Event/Cond.
Date:, 10/$ 7/97 Time:
0920
'nit 0
12, X
Op Cond I % Power 100'jo 100%
System Number 78 CONDITION REPORT NO.
97Q434 Tech Spec LCO 3.0.3 entered to permit testing of'A'od Block Monitor ON 10/16/97 at 0820 hours0.00949 days <br />0.228 hours <br />0.00136 weeks <br />3.1201e-4 months <br />, the 'A'od Block Monitor (RBM) was taken out of service to perform surveillance SI-278-325A, Semi-Annual Calibration of RBM2A. During the calibration problems were identified with LPRM outputs to the RBM2A and documented under CR 97-3414.
The LCO Actions under Tech Spec 3.1.4.3 and 3.3.6 required the inoperable channel to be restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or place the channel in the tripped condition within the next hour. Due to the extensive investigation required to resolve the problems, completion oftesting to return the 'A'BMto operable status was going to exceed the LCO Action,Limits. At 0920 hours0.0106 days <br />0.256 hours <br />0.00152 weeks <br />3.5006e-4 months <br /> on 10/17/97 Unit 2 voluntarily entered Tech Spec LCO 3.0.3 due to the failure to place the 'A'BMin the tripped condition. The 'A; RBM was not placed in the tripped condition to facilitate testing. At 1410 hours0.0163 days <br />0.392 hours <br />0.00233 weeks <br />5.36505e-4 months <br />, Mowing completion of SI-278-325A, the 'A'BMwas declared operable and LCOs 3.0.3, 3.1.4.3a, and 3.3.6 Action 60 cleared.
D Cont'd.
Rod Block Monitor A C
N Obtained permission from Operations Supervisor-Nuclear to enter LCO 3.0.3 Entered LCO.
INC completed surveillance Declared A EBM operable and cleared LCOs F4 bo D Cont'd.
D YES H
NQ Q
N/A'he A RBM was inoperable at the time Originator.
Da neR. Bro h (Print)
Time:
1450 D: J Supe<vis'or.
Date: 'o l~ 9 t Signature Q I recommend this item for closure.
FORM NDAP-QA-0702-1, Rev 2, Page 1 of 1
OPERABIVTVASSESSMEN7 Corrective Action Document 97-3431
'answers to fhe folfowingquestions provide the basis forde'cisions of operability for degraded or'non~nformin9>>fety related equipment.
&ere should be reesoneble essurence ofequipment reliabilityforperforming its intended safety function to decide operability has not been impacted end allow continued operation.
Follow-up technical analysis mey be required to support the reasonable assurance ofoperability documented here.
NOTE:
Originator or problem identifier to answer'r support Operations in answering the following questions:
ls the affected component still capable of performing all its safety functions with reasonable assurance or reliabi%'tynow and foranticipated changes in plant conditions, e.g., plant startup7 include a brief explanation of the component's safety function and how that function is affected. (This evaluation should consider possible failures that may result because ofthe degraded condition and ifother similar equipment might be degraded.):
During the time that LCO 3.0.3 was in affect the A RBM was considered inoperable.
The LCO was not cleared until successful completion of the surveillance.
2.
Explain the basis for your conclusion (e.g., analysis, test, operating experience, judgment):
N/A 3.
List the mechanism(s) used to administratively control equipment status and correct the degraded or nonconforming condition of safety related equipment before reliance is placed on the equipment (LCD Log, document in System Status File, Fire Protection System Status Change Form):
LCOs 3.0.3, 3.1.4.3, and 3.3.6 Iffollow-uptechnical evaluation is needed to substantiate the initial evaluation of operability, notify the applicable functional unit supervisor and document this notification and expectation in the immediate corrective actions taken section ofthe condition report.
Equipment is operable:
HYes
.@No Complete y
Date Approved by (Shift Svpeivisor) l
/O l7 FORM NDAP-QA-0703-1, Rev. 1, Page 1 of 1 (File R48-9)
REPORTABXLHYDETEKVQNATION CONDITION REPORT NO:
97-3431 PAGE OF Et~0
.CII~I 4)S IMMBDIA'HiOR PROMPT NRC REPORTING REQUIRED:
NRC NOTIFICATIONMADE:
NO YES TYPE:
BASIS FOR DESTINATION:
1HR 4HR 24HR Upon review of NDAP-QA-0720 Attachments E, F, G, K,Land R it has been determined there ks no immediate NRG notification required.
ln accordance with Attachment H, a thirty day LER is required.
COMP ED X
Y 0 t
I n97 SHIFT SUPERVISOR DA fORMNDAPQA4720-), REv.o. PAGE I d'2 (FILE R48 2)
TOTAL P. 16
HLV LD LWK)
LC LL UO I'Al MW ITCHY IJt I I'4C PCAF 96-6219
REPORTABILITY
DETERMINATION CONDITION REPORT NO:
97-3431 PAGE 1 OF 1
DETAILS OF NUCLEAR COMPLIANCEREPQRTABILITYDETERMINATION REPORTABLE:
TECH SPEC SPECIAL REPORT:
REPORTABLE PER 10CFR50.9/10CFR21:
N P
PER 10CFR 0
Y P
PER SECTION Y Q p
REFERRED TO NUCLEAR LICENSING' DATE REPORT DUE DATE'
/0 BASIS FOR DETERMINATION'.
Technical Specification Deviations or Shutdowns.
None 2.
Degraded Power Plant Condition.
None 3.
Danger of a Natural Phenomenon.
None 4.
Engineered SafetyFeaturesActua'lion.
None 5.
Important plant System or Slructure Unable to perform Their Function, None 6.
Loss of one train in multiple Channel Systems.
None 7.
Exposure to Individuals or Releases.
None 8.
Failure of Effectiveness of Packaging.
None 9.
Violation of NPDES Permit.
None
- 10. Change of Status or Disability of Licensed Reactor Operator.
None
- 11. Defect in Spent Fuel Storage Cask Structure.
None
- 12. Reduction in Fffectiveness of a Spent Fuel Confinement System.
None John M Kocher 10/20/97 COMPLETED BY DATE l~w i~/~v SVPV. OPERATINS EXP. SVCS.
DATE FORM NDAP-QAZ720-1, REV. 0, PAGE 2 OF 2 (FILE R43-2)
CONDITIONREPORT - SIGMFICA1VCEREVIEW'CAP 1.974166
'ago 3 of4 CR NO:
97-3431 UNIT:
2 OPERA G EXPERIENCE SERVICES ANDM GE OES EVALUATOR:
IXVEL:
RESO TYPE RCA OPERABKIIY AFFECTED?:
NO FUNCTIONALFAXLURE?
NO LEALGRP:
/ OPS RESO DUE: Il/6/9/
NON-CONFORMANCE?:
50.59 REQUXRED?:
NO REPORTABLE?:
YES CYCLE: 209 EQUIP FAILURE? yes
'ATEGORY: TEcHSPaceocgZR1 HUMANPERFORMANCE?:
PLANT/SYSTEMOPERATION MANAGEMENTSUMMARY:
. UNIT2 VOLUNTAMLYENTEIKDEXCH SPEC LCO ACIION3.0.3 WHENTHE A ROD BLOCKMONITOR
'" (RBM)WASNOT PLACED INTHE TRIPPED CONDITIONTO FACILITATE'IZSTING.
THE ACTIONSTA'IDENT FOR THE RBMWAS TO RESTORE 'GK CKQINELTO OPHVBLE STATUS IN 24 HOURS OR PLACE THE RBMINTHE 'IMPPED CONDmON. DUE TO THEI.ONG INVESTIGATION WHICHWAS REQU1RED 'IHERBMWAS NOTPLACED IN'IHETMPPED CONDITIONBUTLCO 3.0.3 WAS ENTERED.
'TESTING WAS COMPLETED, THE ARBMDECLARED OPERABLE, AND.ALLASSOCIATED LCOs WERE CLEARED.
SIGNIHCANCE: ENTRYINTO LCO 3.0.3 REQUIRES A WRITIENREPORT TO THENRC, (LZR) l OES CONTACTS: D ROTHE, LWEST, G MEIMLL,R WEHRY THIS CR IS RELATEDTO CR 97-3414 CAUSE(S)/CAUSALFACTORS:
PAST OCCURRENCES:
4 OTHER CRs IN 1997 ON ENTERING LCO 3.0.3 CORRECTIVE ACTION(S):
EORMNDAPQA4702-3, Rev. 1, Page 1 of 1
~
~
CONDITIONREPORT - EVALUATION4 ACTIONPLAN CR NO.
97-3431 EVALUATIONL ACTION PLAN INVESTIGATION Refer to corrections annotated on Form NDAP~W70M Technical Specification 3.0.3 was entered to allow operability testing of the Unit 2 "A"Rod Block Monitor. Since an entry into 3.0.3 was made, this Condition Report was generated.
This Condition Report willa'ddress the administrative issues associate'd with the need to enter Tech Spec 3.0.3. The technical issues associated with the 2A RBM are discussed in CR 97-3414.
A timeline of the activities associated with this event are attached.
A general discussion of the overall event willbe discussed herein.
On 10/16/97 at 0820 LCO Action Statements 3.1A.3 Action (a) and 3.3.6 Action 60 were entered to perform required surveillance's Sl-278-225A and SI-278-325A. The action statement requires:
IVithone RBM channelinoperable, restore the inoperable channel to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and veri that the reactoris not operating on a LIMITINGCONTROL ROD.
PATTERN; otherwr'se, place the inoperable rod block monitor channel in the tripped condition within the next hour".
Approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> later, unexpected results were encountered during performance of the surveillance.
The problem was believed to be with the "A"and "C" LPRM outputs to the "A"RBM.
WA's V73181 and V731 82 were written to investigate the problem. Since the 2A RBM remained inoperable, the LCO Action Statements remained in effect.
Discussions were ongoing regarding the course of action to take in order to restore the 2A RBM to an operable status.
The decision was made that the 2A RBM would be placed in the tripped condition as required by TS 3.1.4.3 Action Statement (a) ifit could not be restored to an operable status jn time.
SAFETYASSESSMENT tsI Cont'd.
The decision to enter Tech Spec 3.0.3 was based on the following objectives:
1.
Minimize the period of time the 2A RBM was out of service, 2.
Minimize the risk to nuclear safety, 3.
Maintain compliance with Tech Specs.
Based on these considerations, a conservative decision was made and the appropriate course of action followed. There was no nuclear safety significance to this event.
FORM NDAP-QA-0702-4, Rev, 1, Page 1 of 4 Q Cont'd.
UD IVV'I MM %CO LN C ll C CR NO.
97-3431 CONDITIONREPORT-EVALUATION4 ACTIONPLAN
'EVALUATION& ACTION PLAN ROOT CAUSES I CAUSALFACTORS NDAP-QAZ?02-? Form Attached FF PRES HNO PERFORMANCE CRITERIA Q YES Q NO MPFF
+YES HNO REPEAT MPFF P VeS 5g NO TRAIN desi nate or N/A N/A NOTE: Form NDAP-QA-0702-7 is not included with this Condition Report since the event was not a human performance event.
Entiy into 3,0.3 is required when an inoperable channel of the RBM is not in the tripped condition following expiration of Tech Spec Action Statement 3.4.1.3 Action (a). In order to perform operability testing, the RBM cannot be in a tripped condition. Therefore entry into Tech Spec 3.0.3 is required, The root cause for the entry into Tech Spec 3.0.3 is an administrative omission in current Technical Specifications.
Improved Tech Specs contains provisions to perform operability testing on inoperable equipment without entry into Tech Spec 3.0.3.
Entry into Tech Spec 3.0.3 was determined to be an appropriate course of action given this event.
PAST EXPERIENCE 0 Contd.
There have been 4 other Condition Reports documenting entry into Tech Spec 3.0.3 in 1997.
Only one of the four was required to perform operability testing (CR 97-3136).
FORM NDAP-QA-0702-4, Rev. 1, Page 2 of 4 Q Cont'd.
~
~
~
~
4-HUQ JD JOKED JCiJC
~ CR NO.97-343 uD imv ouDv ~D urr s~
CONDITIONREPORT-EVALUATION8 ACTIONPLAN
.EVALUATION8 ACTION PLAN Does co'ndition require repair or usews~sV lf es corn letea rovalblockon a e4.
ACTIONS TO CORRECT CONDITION YES Q FUNC UNIT NO H DUE DATE status.
None Required - The 2A RBM was restored to an operable ACTIONS TO PREVENT RECURRENCE None Required - Entry into Tech Spec 3.0.3 was an appropriate course of action.
Improved Tech Specs has provisions to allow operability testing of inoperable equipment without entering a shutdown action statement.
FUNC UNIT Cont'd.
DUE DATE FORM NDAP-QA-07024, Rev. 1, Page 3 of 4 Q Cont'd.
HVO ld J VVD JC'd CR NO.
97Q431 CONDITIONREPORT-EVALUA7ION8 ACTIONPLAN EVALUATION& ACTlON PLAN Descri tion/8asis of "Use-As-ls" or "Re air."
None Required Desi n and License Documents Re uiring U date.
None Required PREPARED BY DATE LEAD FUNCT UNITMANAGER DATE AFFECTED FUNCT UNIT MANAGER DATE AFFECTED FUNCT UNIT MANAGER DATE AFFECTED FUNCT UNIT MANAGER DATE MANAGER-NSE 8 NUCLEAR MODIFICATIONS se-As-ls or Re air A rova DATE OES SUPERVISOR Level 1 8 Reportable Level 2 DATE PORC, MEETING NUMBER Level 1 8 Reportable Level 2 FORM NDAP-QA-0702-4, Rev. 1, Page 4 of4 DATE.
LD JVVD JC~ JD CR NQ.
97-3431 uv imv ouaat mv vrr sac IXI MlC IMIM 0
0 CONDITIONREPORT-CONTINUATIONFORM CONTINUATIONFORM I
EVENT REPORTING FORM (0702-1)
Q EVALUATION&ACTION PLAN 0702<
INVESTIGATION H
PAST EXPERIENCE Q
SAFETY ASSESS.
D ACTIONS TO CQRR. COND. 0
CAUSES
Q EVAL.&ACTION PLAN D
ACTIONS TQ PREV. RECURR.
CYCLE EXTENSION JUSTIFICATION On 10/17/97 at 0820 the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period to restore the 2A RBM to operable status had expired. At this time, l&Chad completed the repairs to the LPRM's and wa's prepared to resume surveillance testing.
ln light of the completed repairs to the LPRM's, the earlier decision to place the 2A RBM to the tripped condition was reviewed by Shift Supervision and the Operations Supervisor-Nuclear. Since completion of the sutveillance testing would allow the 2A RBM to be restored to an operable status, the decision was made to resume surveillance testing. Entry into TS 3.0.3 would be taken when the TS 3.1.4.3 Action Statement expired. This decision was made after considering the following alternatives:
1.
Place the 2A RBM to the tripped condition.
2.
a)
Placing the 2A RBM to the tripped condition at this time would only delay restoring it to an operable status.
The problem with the LPRM's had been repaired and the surveillance testing was ready to resume.
Restoration of this equipment in the most timely manner possible is consistent with assuring the highest standards of nuclear safety.
- - b)
Placing the 2A RBM to the tripped condition at this time would still require en'nto TS 3.0.3 in order to resume testing. The need to enter TS 3.0.3 for performance of operability, testing was a known administrative oversight of current Tech Specs, The practice of entering TS 3.0.3 to perform operability testing has been accepted by the NRC in the past. Also, Improved Tech Specs corrects this oversight and contains provisions to perform operability testing without entering TS 3.0.3.
Reduce power to < 30%, thereby placing the unit in a CONDITIONwhereby TS 3.1.4.3 is not applicable.
a)
Any time a power reduction is undertaken, especially to a low power level, there is an increased challenge to plant operations.
Unnecessary challenges the plant and operations personnel is not a conservative course of action and does not increase nuciearsafety.
H Cont'd.
FORM NDAP-QA-07024, Rev. 1, Page 1 of 1
HLU-LD LO>c5 Lg: LQ uv mv mm rcco urr inc I 4 I dNC NP Id CR NO.
97-3431 CONDITIONREPORT-CONTINUATIONFORM CONTINUATIONFORM EVENT REPORTING FORM'(0702-1)
Q EVALUATION&ACTION PLAN 0702-4 INVESTIGATION g
PAST EXPERIENCE P
ACTIONS TO PREV. RECURR.
SAFETYASSESS.
Q ACTIONS TO CORR. COND. P CYCLE EXTENSION JUSTIFICATION
CAUSES
P EVAL. &ACTION PLAN P
EXT.
Based on the above considerations, the decision was made not to trip the 2A RBM and resume surveillance testing. This course of action is conservative in that it restored plant equipment to an operable status in the most expeditious manner without compromising nuclear safety.
OP-AD-001 requires approvaf of the Manager - Nuclear Operations for a voluntary entry into Tech Spec 3.0.3. Since he was unavailable at the time, the Operations Duty Manager (Operations Supervisor - Nuclear) granted permission to continue operability testing and to enter TS 3.0.3 when the TS 3.1.4.3 Action Statement (a) expired. The Manager-Nuclear Operations was later notified of and concurred with this decision.
At0838 Powerplex was restored to obtain a core edit prior to resumption of the surveillance test.
Powerplex was blocked'at 0849 and the testing resumed.
At 0920 the TS 3.1.4.3 Action Statement (a) expired arid TS 3,0.3 was entered.
The remainder of the surveillance was performed without incident. Testing was completed at 1252. TS Action Statements 3.0.3, 3.1.4.3, and 3.3.6 were cleared at 1410 following closure of the 2 WA's that repaired the LPRM's.
Technical As ects of the Event CR 97~14 willbe assessing the technical aspects of this event.
However, the following is known at this time. The investigation identified that the A & C level LPRM output to the 2A RBM had failed downscale.
The 2F APRM was not affected nor was the 2A RBM itself failed. The defective components were replaced and re-tested satisfactorily. The exact cause for the failure is currently under investigation, but is believed to be the result of an earlier electrical transient due to a failed power supply.
P Cont'd.
FORM NDAP-QA-0702-6, Rev. 1, Page 1 of 1
tQV ld lVPO JC'N VO I%'lr OVQQI AC4 Wl
~ 'le CR 97-3431 Timeline Date 10/16/97 10/17/97 Time 0820 0821 1020 0820 0838 0849 0920 1250 1252 1410 Activi /Action LCO entered for'A'od Block Monitor inoperable for Sl-278-325A and SI-278-225A Powerplex blocked to support testing of 2A RBM Problems encountered during performance of Sl-278-325A due to failed LPRM outputs.'(See CR 97-3414, WA's V73181, V73182 RBM 2A remains inoperable.
LCO 3.1.4.3,(a) 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period expired.
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> remains to place the 2A RBM in the
'tn ed condition.
Power plex restored to obtain core edit before RBM testin resumes.
Powerpfex blocked and testing of 2A RBM resumes.
Tech Spec 3;0.3 entered since LCO 3.1.4.3.a expired and the action to place 2A RBM in the tripped condition cannot be completed due to operability testing in ro ress.
Powe lex monitors restored Sl-278-325A corn Ieted satisfactoril AllLCO's cleared when V73181N73182 dosed.
Tech S eclm act 3.1.4.3 Action a. and 3.3.6 Action 60-24 hrs to restore, otherwise 1 hr to place in trip condition.
Im act: 10/17/97 0820 3.1.4.3.a Impact:
0920 3.0.3-1 hour to commence shutdown/ be in Cond 2 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Im act: 1020/1620
HUG-ld-LJWa LZ LD ub IWI. mm mD urrlVC III PIC told CR NO.
97-3431 CONTINUATIONFORM CONDITlONREPORT-CONTINUATIONFORM EVENT REPORTING FORM (0702-1)
Q EVALUATION&ACTION PION 0702<
INVESTIGATION H
PAST EXPERIENCE 0
ACTIONS TO PREV. RECURR.
SAFETY ASSESS.
Q ACTIONS TO CORR. COND.
Q CYCLE EXTENSION JUSTIFICATION
CAUSES
Q EVAL.&ACTION PLAN Q
EXT.
NOTE TO OES:
ft was necessary to revise the disposition plan for this CR. Attached is a revision to the "Investigation" and
- Actions to Prevent Recurrence'hat need to be added to the original CR package.
As a result of this
~
revision, 4 new action items are required (See Action to Prevent Recurrence).
~t%
9 Cont'd.
FORM NDAP-QA-0702-6, Rev. 1, Page 1 of 1
tiVQ ld JVPQ JCi ld ua >mi moo mo vrr sac'
~
~
I CR NO.
97-3431 CONDITIONREPORT - CONTINUATIONFORM CONTINUATIONFORM EVENT REPORTING FORM (0702-1)
Q EVALUATION8 ACT ON PLAN 0702-4 INVESTIGATION 8
PAST EXPERIENCE Q
ACTIONS TO PREY. RECURR.
SAFETYASSESS.
Q ACTIONS TO CORR. COND.
Q CYCLE EXTENSION JUSTIFICATION'AUSES Q
EVAL. 8 ACTION PLAN '
EXT.
Following completion of the initial disposition to CR 97-3431, NRC resident inspectors raised questions concerning compliance with Tech Spec LCO 3.1A,3.(a) and 3.0.3. Their concern is documented in NRC Inspection Report 97-10.
It states:
Youractionsin response to a failure ofthe Unit 2 rod block monitor were observed and, in general, were considered conservative and safety oriented.
However, SSES managemenf chose to enter TS 3.0.3 and did notinifiafe any acfion to shutdown the unit, asisintended by the technical specification.
The NRC questioned the appropriatenes or fhe decision to enter TS 3.0,3 and considered managemenf's decision to intentionally not n.duce power a weakness inimplementation ofthe TS. Ke request the SSES Plant Operation Review Commiffee formallyevaluate the issue fo enter 3.0.3 within 20 days.
This information wi7Ibe used to evaluate the unresolveditemidenfifiedin fhe enclosedinspecfion report and to determine whether further IVRC action is required. "
The following is a re-evaluation of the actions taken on October 17, 1997 concerning the Unit 2 'A'BM.
Issue 1 is the question raised by NRC concerning the appropriateness of entering TS 3.0.3.
Issue 2 reviews our actions taken in response to the entiy into TS 3.0.3.
A time line for events associated with this Condition Report is attached, Applicable sections from Unit 2 Technical Specifications are also attached.
Discussion of Issue 1
At the time of the event the Shift Supervisor believed he had three options to choose from.'uspend testing of the RBM. Place the 'A'hannel in the tripped condition to satisfy LCO Action 3.1.4.3.(a).
Enter TS LCO 3,0.3, activate the 'A'BMchannel to allow testing to resume.
2.
Reduce power to less than 30% of Rated Thermal Power. With-power less th'an 30% the RBM is not required to be OPERABLE. LCO Action 3.1.4.3.(a) would no longer apply.
gj Cont'd.
FORM NDAP-QA-0702-6, Rev. 1, Page 1 of 1
CONDITIONREPORT CONTINUATIONFORM CR NO.
97-3431 CONTINUATIONFORM EVENT REPORTING FORM (0702-1) P EVALUATION&ACTION PLAN 0702<
INVESTIGATION H
PAST EXPERIENCE P
SAFETY ASSESS.
P
'ACTIONS TO CORR. COND. P
CAUSES
P. EVAL 8, ACTION PLAN P
ACTIONS TO PREY. RECURR, CYCLE EXTENSION JUSTIFICATION
'iscussion of issue 0 cont'd 3.
Allowtesting of the 'A'BMto continue. This would mean that compliance with LCO Action 3.1.4.3. (a) would not be maintained.
As a result, enter TS LCO 3.0.3. A further consideration for this option was whether an NRC Notice of Enforcement Discretion was needed in order to allow such an action.
Options 1 and 2 were viewed by the Shift Supervisor and Operations Supervisor as presenting an increased risk to nuclear safety, Option 1 required that l&Cstop their surveillance testing, delayed the restoration of the 'A'BMand ultimately resulted in the unit being in TS LCO 3.0,3. The l&Csurveillance testing is performed in'the Lower Relay room in panel 2C608. This panel contains the RBM modules along with the APRM Channels and Recirc Flow Units, These later components provide signals to RPS so caution must be exercised when working on RBM. The two surveillances being performed required the removal of various logic cards, installation of test equipment and manipulation of various test pots inside the cabinet.
Halting this testing, placing the 'A'BMin the trip condition and subsequently restoring the
'A'BMto resume testing was viewed as an un-necessary nsk. Option 2 challenged the operators to manipulate reactor power and placed the unit in a low power operating state.
This was viewed as an un-necessary challenge.
The RBM system ls designed to provide controls for the movement of Control Rods.
Reducing power to 30% would require a significant number of Control Rod movements.
With the one channel of RBM out of service the risks associated with commencing a power reduction were considered greater then completing the restoration of the RBM system.
Option 3 was considered to be the feast challenging to Operations and to be within our authority as licensees to exercise on our own. As a result, Option 3 was chosen.,
The question of NRC involvement was reviewed. The conclusion was that we had the legal authority to enter TS LCO 3.0.3 on our own. We have periodically entered TS LCO 3.0.3 in order to perform required testing. This condition was viewed as the same situation. This weakness in our Tech Spec's has been identified and willbe corn.cted'by ITS through the addition of a new section of Tech Spec's to address allowances for testing of in-operable equipment without entry into shutdown action statements.
Cont'd.
FORM NDAP-QA-0702-6, Rev. 1, Page 1 of 1
t1UQ la) JPVO JC'D V4 I'A4 iXIQO 0 J
~
~
CONDITIONREPORT - CONTINUATIONFORAf CR NQ.
97-3431 CONTINUATIONFORM EVENT REPORTING FORM (0702-1) 0 EVALUATION& ACTION PLAN 0702<
INVESTIGATION I PAST EXPERIENCE Q
ACTIONS TO PREV. RECURR.
SAFETY ASSESS.
Q 'ACTIONS TO CQRR. COND. P CYCLE EXTENSION JUSTIFICATION
CAUSES
D EVAL. &ACTION PLAN Q
EXT.
The questions then boils down to; 1) Do we have the authority to not comply with an Action Statement required by Tech Spec's when we believe the performance of the Action posses undue risk7 2) Ifwe decide to not comply with an Action Statement, is entry into TS LCO 3.0.3 appropriate7
- 3) How should such decisions be made and controlled7 A~nal sis The intent of TS LCO 3.0.3, as introduced in Generic Letter 80-30 was to preserve the single failure criterion for systems that are relied upon in the safety analysis report. The examples cited in the GL were cases when more than one train or channel of redundant safety related systems were inoperable.
In such cases the new specification 3.0.3 provided direction for shutting down the unit in a reasonable time frame.
The GL did not address situations where other provisions of an LCO Action might not be complied with.
The Bases Section of our Tech Spec's also reflects this intent The Bases states in part; "The purpose of this specification is to delineate the time limits for placing the unit in a safe shutdown CONDITIONwhen plant operation cannot be maintained within the limits for safe operation defined by the Limiting Conditions for Operation and its ACTION requirements.
It is not intended to be used as an operational convenience which permits (routine) voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.
A key phrase included in our Tech Spec Bases must be considered;
"...notintended to be used as an operational convenience...".
Clearly, any time we are viewed as using entry into TS LCO 3.0.3 as an "operational convenience" we are subject to regulatory review on our use of this Tech Spec provision.
The test for "operational. convenience" needs to be developed.
Ifwe strictly followall written Tech Spec LCO's, Actions and Surveillance Requirements and find we have no other choice, we can defend that we have not exercised TS LCO 3.0.3 as an "operational convenience".
In the case of the 'A'BMwe did not exercise this approach.
At 0820 the 18 C corrective maintenance was completed and the surveillance testing had not yet started.
We could have placed the 'A'BMin the trip condition to meet the Action Statement, Once I&Cwas ready to begin the surveillance test at 0849, TS LCO 3.0.3 could have been entered and the 'A'BMcould have been taken out of the trip condition to allow surveillance testing, This fourth option would have allowed compliance with Tech Spec Action g Cont'd.
FORM NDAP-QA-0702-6, Rev. 1, Page 1 of 1
CONDlTiONREPORT ~ CONTINUATIONFORM CR NO.
97-3431 CONTINUATIONFORM EVENT REPORTING FORM (0702-1) D EVALUATION&ACTION PLAN 0702<
INVESTIGATION H
PAST EXPERIENCE D ACTIONS TO PREY. RECURR.
SAFETY ASSESS.
D ACTIONS TO CORR. COND. P CYCLE EXTENSION JUSTIFICATION
CAUSES
D EVAL.&ACTION PLAN P
EXT.
Anal sis cont'd Statements and minimized un-necessary chaftenges and risks to the unit. It a situation similar to the events associated with the 'A'BMwere to exist in the future, exercising the new fourth option outlined above would be the correct action properly balancing compliance and risk issues.
We also could have halted testing prior to exceeding the LCO Action Statement time limit,placed the Channel in the tripped condition, thereby satisfying the Action Statement.
At that point we would be in a similar position to other recent cases where we exercised TS LCO 3.0.3 to allow performance of post maintenance testing.
Not halting the testing and not placing the channel in the tripped condition can be viewed as entering TS LCO 3.0.3 as an "operational convenience
. Consideration of the risks associated with halting a test in progress'to allow completion of a required Action may provide appropriate justification for not considering this to be an "operational convenience".
Another option exists within 10CFR50 for taking actions that depart from the Technical Specifications.
10CFR50.54(x) states; A licensee may take seasonable action that departs from a license condition or a technical specification.... in an emergency when this actionisimmediately needed to protect the public health and safety and no action consistent with ficense condition's and technical specification that can..
provide adequate or equivalent protectionisimmediately apparent." This provision is cieariy intended to address emergency situations.
The testing of the 'A'BMdid not fall into that category.
Based on our review of regulations, the answer to the three questions posed above are; 1)
Do we have the authority to not comply with an Action Statement required by Tech Spec's when we believe the performance of the Action posses undue risk? The answer to this question is Yes.
Cleariy 10CFR50.54(x) allows licensee's to take actions that depart from our license when needed to protect the health and safety of the public. We must be very dear about the risk we are discussing when making such decisions,
'Risks to public health and safety are the focus of the regulations.
. 0 Cont'd.
FORM NDAP-QA-0702-6, Rev. 1, Page 1 of 1
Hm-z>-x>>a xe'a
~
~
CR NO.
97-3431 CONTINUATIONFORM CONDITIONREPORT - CONTINUATION FORM EVENT REPORTING FORM (0702-1)
D EVALUATION8 ACTION PLAN 0702<
INVESTIGATION H
PAST EXPERIENCE Q
ACTIONS TO PREV. RECURR.
SAFETY ASSESS.
0 'ACTIONS TO CORR. COND.
Q CYCLE EXTENSION JUSTIFICATION
'AUSES Q
EVAL. 8 ACTION PLAN CI EXT.
Anal SiS Cpnt'd 2)
Ifwe decide to not comply with an Action Statement, is entry into TS LCO 3.0.3 appropriate'? 'The decision to depart from the license can be made under 10CFR50.54(x).
Due to weaknesses in current Technical Specifications situations arise when a completed Action Statement must be departed from in order to perform required testing to return an inoperable piece of equipment to service'.
Improved Technical Specifications(ITS} includes a new LCO 3.0.5 to address these situations.
Until ITS is approved, entry into LCO 3.0.3 is appropriate for these situations.
3)
How should such decisions be made and controlled' Clearly any time a decision is made to not comply with Technical Specifications, appropriate controls and decision making is needed.
Under emergency conditions the Shift Supervisor has such authority. Ifwork activities require entry into TS LCO 3.0.3, the Operations Supervisor and Manager - Nuclear Operations must also be involved in the decision. This level of control exists today and is adequate, Additional written guidance to procedures is warranted to aid in this decision making.
Discussion of Issue 2 Once entered, TS LCO 3.0.3 requires actions be taken to place the affected unit in Startup and Hot Shutdown. This section reads in part;
'...within'one hour action shall be taken to place the unitin an OPERATIONAL CONDITIONinwhich the Specification does not apply by placing it, as applicablein:
1.
At least STARTUP within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, 2.
At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,....'
Cont'd.
FORM NDAP-QA-0702-6, Rev. 1, Page 1 of 1 TOTAL P. 16
PllA IJ lVPQ JC ~ CC CR NO, 97-3431 CONDITIONREPORT-CONTINUATIONFORIH CONTINUATIONFORM EVENT REPORTING FORM (0702-1) 0 EVALUATION&'ACTIONPION 0702-4 INVESTIGATION g
PAST EXPERIENCE Q
ACTIONS TO PREV, RECURR.
SAFETY ASSESS.
Q 'ACTIONS TO CORR. COND.
Q CYCLE EXTENSION JUSTIFICATION
'AUSES Q
EVAL. 8 ACTION PLAN Q
EXT.
Discussion of Issue 2 cont'd The Basis section ofTech Spec's reads in part; "...The time fimits specified to reach lower CONDIT(ONS of operation permit the shutdown to proceedin a controlled and orderly manner thatis well within the specitied maximum cooldown rate and within the cooldown capabi%ties ofthe facilityassuming only the minimum required equipment is OPERABLE."
Tech Spec LCO 3.0.3 was entered at 0920 hours0.0106 days <br />0.256 hours <br />0.00152 weeks <br />3.5006e-4 months <br />. The LCO was cleared at 1410 hours0.0163 days <br />0.392 hours <br />0.00233 weeks <br />5.36505e-4 months <br />. This is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and 50 minutes into the LCO.'o reductions in reactor power were made during this time period. This left 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 10 minutes for the unit to be in STARTUP had any further problems been encountered with the RBM system< Through out this period the Shift Supervisor maintained oversight on the activities associated with clearing the RBM problems.
Testing to declare the 'A'BMoperable started at 0849 and was completed at 1252. As a result, the Shift Supervisor had reasonable expectations, throughout the LCO Action period, that the LCO would be cleared before he was required to be in STARTUP.
Procedural guidance on Entry into TS LCO 3.0.3 is included in OP-AD-001. There is no guidance on specific actions that shall be taken by particular times frames to ensure compliance with the Action time limits. In this particular case the Shift Supervisor was planning for success based on the feedback he was receiving from the work group. With no specific guidance, the Shift Supervisor used judgment to determine ifmore aggressive actions were needed to reduce power and begin the shutdown sequence.
He concluded none were needed.
This was reasonable considering the situation but did not leave margin iffurther problems were encountered with the RBM and unit shutdown was required.
g} Cont'd.
FORM NDAP-QA-0702-6, Rev. 1, Page 1 of 1
@MA ld J770 IC'C9 I v'l tV' M CR NO.
97-3431 CONDITIONREPORT - CONTINUATIONFORM CONTINUATIONFORM EVFNT REPORTING FORM (0702-1) 'Q EVALUATIONBi'ACTIONPLAN 0702-4 INVESTIGATION g
PAST EXPERIENCE Q
ACTIONS TO PREY. REGURR.
SAFETY ASSESS.
P ACTIONS TO CORR. COND.
Q CYCLE EXTENSION JUSTIFICATION
'AUSES P
EVAL. 8 ACTION PLAN P
EXT.
Anal sis cont'd As noted in the Analysis of Issue 1 above, any time we voluntarily enter TS LCO 3.0.3 we should expect an increased level of review and scrutiny from many outside parties, As a result, it is important that we have very dear expectations associated with actions we intend to take under these situations.
It is not appropriate to totally rely on the judgment of individuals on-shift to determine when power reductions should begin.
In the case of an entry into TS LCO 3.0.3, our expectation should be that we begin actions to reduce power and place the unit in STARTUP in a controlled and orderly manner within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> of entry. It is not expected that we remain at fullpower and then discover the need to rapidly reduce power or initiate a Scram from high power levels in order to comply with the Action statement time periods. To cleahy communicate these expectations a set of guidelines should be constructed to define expected actions by the Unit Supervisors when entry is made to TS LCO 3.0.3. The followingwould be an example of the guidelines:
First Hour Second and Third Hour Fourth Hour Fifth Hour Sixth Hour Seventh Hour Unit Supervisor should review GO for shutdown. Work group actions should be underway to dear work items and allow unit to exit TS LGO 3.0.3.
Unit Supervisor should brief shift personnel on shutdown and notify PCC of possible shutdown.
By the end of the fourth hour, the unit should be at 90% power.
sf During this hour actions shall be taken'o continue power reduction using Reactor Recirc. and control rods.
By the end of the fifth hour the unit should be at 50% power.
Actions continue to drive control rods and reduce power to approximatefy 25%.
Manual scram inserted to put unit in STARTUP by the end of the seventh hour.
g Cont'd.
FORM NDAP-QA-07024, Rev. 1, Page 1 of 1
tWQ JB JVOO JC ~ CD CR NO.
97-3431 CONDITIONREPORT-CONTINUAT/ONFORM CONTINUATIONFORM
'VENTREPORTING FORM (0702<<1)
Q EVALUATION8 ACTION PLAN 0702M INVESTIGATION Q
PAST EXPERIENCE Q
ACTIONS TO,PREV. RECURR.
SAFETY ASSESS.
Q ACTIONS TO CORR. COND.
Q CYCLE EXTENSION JUSTIFICATION.
CAUSES
0 EVAL8 ACTION PLAN Q
EXT.
Conclusion The specific actions taken by shift personnel during the recovery of'A'BMon Unit 2 were appropriate when viewed from the perspective of minimizing challenges to operations personnel and recognizing the actions being taken by I8 C to return the channel to service. When viewed from the perspective of Tech Spec compliance, improvements in our implementation of TS LCO 3.0.3 is warranted.
Iffaced with a situation similar to the events of October 16th and 17th, completion of all required Tech Spec Actions shall occurr. Only after fullycompleting all actions willentry into TS LCO 3.0.3 be considered to allow completion of required post maintenance testing and restoration of equipment to OPERABLE. Operations Management (Operations Supervisor/Operations Manager) approval willbe obtained prior to TS LCO 3.0.3 entry in response to event circumstances not specifically addressed by Technical SpeciTication Action statements.
Once TS LCO 3.0.3 is entered, specfic actions shall be taken to initiate and complete, ifnecessary, the requirements of the unit shutdown.
Four specTiic actions shall be taken:
2.
3.
Clear guidance willbe added to OP-AD-001 dealing with voluntary entry to TS LCO 3.0.3. This guidance willdeal with removal of redundant equipment from service and with failure to meet LCO Action requirements in other manners.
Clear guidance willbe added to OP-AD-001 dealing with actions to be taken by Unit Supervis'ofS-'nce their unit has entered TS LCO 3.0.3.
Communication of these changes to operational policy willbe made and training of appropriate personnel willbe'held.
CR 97-3431 and LER 50-388/97-007 willbe revised to reflect these changes in policy and additional actions.
Q Cont'd.
= FORM NDAPNA-0702-6, Rev. 1, Page 1 of 1
HUL)-14-15Jd 18: 8 C jI ( PIC Adjs CR NO.
CONDITIONREPORT - EVALUATION4 ACTIONPLAN 97-3431 EVALUATION8 ACTION PLAN Does condition require impair or usews~s?
If es,corn Ietea rovalblockon a e4.
VaS P NOH ACTIONS TO CORRECT CONDITION FUNC UNIT DUE DATE ACTIONS TO PREVENT RECURRENCE FUNC UNIT Q Cont'd.
DUE DATE Clear guidance should be added to OP-AD-001 dealing with voluntary entry to TS LCO 3.0.3. This guidance should deal with removal of redundant equipment from service and with failure to meeting LCO Action requirements.
2.
Clear guidance should be added to OP-AD-001 dealing with actions to be taken by Unit Supervisors once their unit has entered TS LCO 3.0.3.
3.
Communication of these changes to operational policy should be made and training of appropriate personnel should be held.
- 4. 'R 97-3431 and LER 50-388/97-007 should be revised to reflect these changes in policy and additional actions.
ops OpS Ops Qpa/Li~s~j 4/1/98 4/1/98 4/15/98 Q Cont'd.
FORM NDAP-QA-0702-4, Rev. 1, Page 3 of 4
CR NO.
9 -3431 CONDITIONREPORT - EVALUATION8 ACTIONPLAN EVALUATION8 ACTION PLAN Descri'on/Basis of "Use-As-Is" or "Re air."
Desi n and License Documents Re uirin U date.
PREPARED BY I
~
Cl.c~ ~
s a ~r rr ATE LEADFUNCT UNITMANAGER AT AFFECTED FUNCT UNIT MANAGER DATE AFFECTED FUNCT UNIT DATE MANAGER
/
AFFECTED FUNCT UNIT MANAGER OES SUPERVISOR Level 1 & Reportable Level 2 f8'-02 -S ~
PORC MEETING NUMBER Level 1 & Reportable Level 2 DATE MANAGER-NSE
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DATE a/w/ca DATE FORM NDAP~Q702%, Rev. 1, Page 4 of 4
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ICC,Q Ul I Jl 0 I Jl WC %VIV CR 97-3431 Timeline Date 10/16/97 10/17/97 Time 0820 0821 1020 0820 0838 0849 0920 1250 1252 1410 Activi /Action LCO entered for'A'od Block'Monitor inoperable for SI-278-325A and SI-278-225A Powerplex blocked to support testing of 2ARBM Problems encountered during performance ofSI-278-325A due to failed LPRM outputs. (See CR 97-3414, WA's V73181, V73 182 RBM2A remains inoperable.
LCO 3.1.4.3.(a) 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period expired, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> remains to place the 2ARBMin the tri ed condition.
Powerplex restored to obtain core edit before RBMtestin resumes.
Powerplex blocked and testing of2A RBMresumes, Tech Spec 3.0.3 entered since LCO 3.1.4.3.a expired and the action to place 2A RSM in the tripped condition cannot
'be completed due to operability testing in ro ess.
Powe lex monitors restored SI-278-325A corn leted satisfactoril AllLGO's cleared when V73181/V73182 closed.
Tech S ecIm act 3.1.4.3 Action a. and 3.3.6 Action 60-24 hrs to restore, otherwise 1 hr to place in trip condition.
Im act '0/17/97 0820 3.1.4.3.a Impact:
0920 3.0.3-1 hour to commence shutdown/ be in Cond 2 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Im act: 1020/1620
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