05000247/LER-2017-003

LER-2017-003, Technical Specification Violation of Section 3.3.1 RPS Instrumentation

Indian Point Unit 2
Event date:	06-27-2017
Report date:	08-23-2017
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
2472017003R00 - NRC Website

LER 17-003-00 for Indian Point Unit 2, Regarding Technical Specification Violation of Section 3.3.1 RPS Instrumentation

ML17241A047
Person / Time
Site:	Indian Point, Indian Point Unit 2
Issue date:	08/23/2017
From:	Vitale A J Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-17-111 LER 17-003-00
Download: ML17241A047 (5)

comments regarding burden estimate to the Information Services Branch (T-2 F43), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e-mail to used to impose an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

- 003 2017 - 00 On June 27, 2017, during reactor startup, power was raised from Mode 3 to Mode 2 and above the P-6 (Intermediate Ranger Neutron Flux) interlock. With P-6 inoperable this was a violated of the requirement of Technical Specification (TS) Limiting Condition of Operation (LCO) 3.3.1 and resulted in a 60 Day Licensee Event Report (LER).

Unit 2 reactor was in Mode 3 in preparation for start-up following a forced outage to repair the 22 Main Boiler Feed Pump control system. As required by plant technical specifications, forced outage surveillance test 2-PT-V63A, Reactor Protection Logic Train 'A' Partial Functional Test and 2-PT- V63B, Reactor Protection Logic Train 13' Partial Functional Test were scheduled to be performed prior to entering Mode 2. These tests perform an actuation logic test, channel operation test, and trip actuating device operational test (TADOT) on portions of the reactor protection system (RPS) logic circuit that are not able to be tested at full power conditions.

Some of the switch manipulations, including the P-6 permissive switches, involve multiple actions requiring a team of individuals to coordinate rotation of switches to the right, and then pushing and holding switches while verifying test panel trip lamps and trip bus volt lamps are illuminated.

The test is performed in the Unit 2 Control Room, and all RPS test switches are located in adjacent racks designated as Panel `RLTRA' (Train 'A') and `RLTRB' (Train 13').

Three I&C technicians were assigned to perform the two surveillance tests sequentially. The 'A' train test was performed first. The technicians and their first-line supervisor conducted the pre job briefing for the tests in accordance with EN-HU-102 Human Performance Traps &Tools requirements. The test details were discussed, along with roles and responsibilities and stop work criteria. During the work preparations, the technicians identified technical errors in the prerequisites sections of both surveillance tests, requiring DRNs to be issued prior to the start of work. Also identified was that three of the sections in the tests were not required to be performed because they had been performed during the 2R22 refueling outage and were within the required surveillance frequency. The test was not considered a high risk activity and consequences for leaving switches in the wrong position were not identified during the pre job briefing. Had the importance of the switch configuration to reactor safety been understood and discussed during work preparations, additional measures would have been taken to provide for and ensure high quality work.

Indian Point Unit 2 05000-247 comments regarding burden estimate to the Information Services Branch (T-2 F43), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e-mail to used to impose an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

- 003 2017 - 00 05000-247 a LER NUMBER

CAUSE OF EVENT

I&C technicians did not restore test permissive intermediate range switches 1/N35D and 1/N36D to their proper position during surveillance testing as required by procedure.

Poor Work Practices

• Workers did not apply essential maintenance fundamentals to ensure proper switch configuration was preserved during the surveillance test:

n Risk Recognition and Mitigation n Proficiency Supervisory / Management Methods

• The responsible supervisor and maintenance leadership did not provide sufficient oversight or guidance to promote error-free performance.

n Pre-Job Briefing / Work Preparation n Performing Monitoring — Human Performance (HU) elements Written Communications — I&C Procedures

• The test procedure 2-PT-V063A is not aligned with the writer's guide best practices to reduce the potential for human error:

Operations Interface — Configuration Control

• Operations did not apply adequate methods to validate system configuration and overly relied on maintenance processes and procedures

CORRECTIVE ACTIONS

• A site-wide focused stand down was held on July 10, 2017 to review recent IPEC human performance event

• The I&C technicians involved had their qualifications administratively suspended pending the completion of the human performance culpability reviews

• A Performance Analysis was completed as part of the ACA report to identify knowledge and skill gaps for determining training needs

• Revise 1P2 and 1P3 SI Logic and Reactor Protection System surveillance tests to include steps to perform independent verification of as-left switch lineups -

• Revise 2-PT-V053 and 3-PT-V053 mode change checkoff list(s) to validate critical Reactor Protection System switch lineups following testing comments regarding burden estimate to the Information Services Branch (T-2 F43), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e-mail to used to impose an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

- 003 2017 - 00 05000-247

EVENT ANALYSIS

This LER is being submitted pursuant to Title 10 Code of Federal Regulations 50.73(a)(2)(i)(B) "Any operation or condition which was prohibited by the plant's Technical Specifications"

PAST SIMILAR EVENTS

In July 2016, the IP2 reactor tripped due to the inadvertent operation of the 'B' RPS bypass key out of sequence during Reactor Protection logic testing (CR-IP2-2016-04320. In March 2013, an inadvertent Safety Injection (SI) occurred during the 3R17 outage while conducting the reactor protection system functional monthly test (CR-IP3-2013-02115). These events were not discussed prior to the task because the specific conditions were not relevant to the performance of 2-PT-V63A.

SAFETY SIGNIFICANCE

The plant operation impact was that the Source Range flux high level trip was not able to be manually bypassed to continue plant startup. The inoperability of P-6 did not impact the ability to shut down the reactor or maintain it in a safe shutdown condition (both the Source Range and Intermediate Range reactor trip functions were fully operable) or to mitigate the consequences of an accident as described in the FSAR.

This event is reportable and a 60 day LER is required due to violation of the requirements of LCO 3.3.1 During reactor startup, power was raised from Mode 3 to Mode 2 and above the P-6 interlock. P-6 was inoperable at the time, resulting in LCO 3.3.1, Table 3.3.1-1, Item 17 not being met.

This event was classified as a Level 2 Consequential (Major) Component Mispositioned Event because it was an unintentional or unexpected component manipulation that resulted in a major impact to operation of the plant (unplanned shutdown and reportable entry into an LCO).