gCCE~~TED DIIRIEIUTION DEMONiTlTlON SYSTEM

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8902070207 DOC.DATE: 89/01/31 NOTARIZED: NOFACIL:50-410 Nine Mile Point Nuclear Station, Unit 2, Niagara Moha

AUTH.NAME AUTHOR AFFILIATIONMAZZAFERRO,P.A. Niagara Mohawk Power Corp.WILLIS,J.L. Niagara Mohawk Power Corp.

RECIP.NAME . RECIPIENT AFFILIATION

DOCKET I05000410

SUBJECT: LER 88-027-01:on 880707,Tech Spec violation due to failureto submit special rept because of personnel error.

W/8 1tr.DISTRIBUTION CODE: IE22D COPIES RECEIVED:LTR ENCL SIZE:TITLE: 50.73 Licensee Event Report (LER), Incident Rpt, etc..NOTES

RECIPIENTID CODE/NAME

PD1-1 LAHAUGHEY,M

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EXTERNAL: EGGG WILLIAMS,SH ST LOBBY WARDNRC PDRNSIC MAYS,G

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TOTAL NUMBER OF COPIES REQUIRED: LTTR 46 ENCL 45

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NRC Form 355(0.53)

LICENSEE EVENT REPORT ILER)

MP44 045U.S. NUCLEAR AEOULATORY COMMISSION

APPROVED OM(1 NO. 3)504)ILC

EXPIRES: BI31IBB

FACILITYNAME (1) DOCKET NUMBER 12) PA E I

Nine Mile Point Unit 2 o 5 o o o 410 1 oF 05ec naca pec»ca ~on io a ~on ue o a> ure o u m~t a

Special Report Because of a Personnel ErrorEVENT OA'TE (5) LER NUMBER (5) RFPORT DATE (7> OTHER FACILITIES INVOI.VED IBI

MONTH

07

DAY

07

YEAR YEAR

88 88

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027 .

MONTH OAY YEARNUMBER

01 31 89

FACILITY NAMES

N/A

N/A

DOCKET NUMBER(SI

0 5 0 0 0

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OPERATINOMODE (5)

POWERLEvEL

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NAME

20.402 (5)

20.405 (~IllI (I)

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LICENSEE CONTACT FOR THIS LER (12I

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Special Report

TELEPHONE NUMBER

THIS REPORT IS SUBMITTED PUASUANT TO THE REDUIREMEIcTS OF 10 cF R (I: IChrch one or morr of thr foriovfinfl(Ill

Peter A. Mazzaferro, Superintendent Technical AssessmentCOMPLETE ONE LINE FOR EACH COMPONENT FAILUAE DESCAIBED IN THIS REPORT (13)

315 349-7919

CAUSE SYSTEM COMPONENT MANUFACTURER

REPORTABLETO NPROS

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CAUSE SYSTElt COMPONENT MANUFAC.TUAER

EPORTABLETO NPROS

SUPPLEMENTAL REPORT EXPEC'TED Ilri

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ABSTRACT ILimitro Ir(X)totter,.f.r.. eporovrmrrrry frfrrrn rinorr rnrrr typr~nrren Iinrri IISI

EXPECTFDSUBMISSION

DATE (15)

'S3o ca c'o gag%MONTH DAY YEAR

On July 7, 1988 at 1454 hours, it was discovered that Nine tlile Point Unit 2failed to submit a required Special Report and was not in compliance with itsTechnical Specifications (TS), Section 3.3.7.8, concerning the operability ofthe Loose Parts Monitoring (LPM) system. At the time of the discovery theplant was operating at approximately 100K of its rated thermal power with the

. reactor mode switch in the HRUNH position (Operational Condition 1). Thi'sSpecial Report was due in ttovember, 1987.

Corrective actions taken include: (1) The addition of the information requiredin the Special Report by TS Section -3.3. 7, 8 to this report in Section V,Additional Information; (2) Lessons Learned transmittal concerning the need ofan occurrence report for the 'tracking of items requiring a special report andto address the need for accurate Equipment Status Log entries; (3) A documentsearch of the equipment status log for similar events.The following corrective action is still open: Revision to AdministrativeProcedure AP-10.2.2, "Procedure for Reporting Variations from Normal PlantOperations, Defects and tlon-ComplianceH to assure that items that are subjectto an Occurrence Report are better defined.

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The root cause of the event is a personnel error.

The immediate corrective action was to notify the responsible department of theneed for a Special Report by issuing an Occurrence Report.

NRC FonII SSSA(04(31 LICENSEE ENT REPORT (LER) TEXT CONTINUA ON

U.S. NUCLEAR REOULATORY COMMISSION

APPROVED OMB NO. 3(50~ 3>

EXPIRES: 5/311SS

FACILITYNAME (Il DOCKET NUMBER (21

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LER NUMBER (Sl

SEOUSNZIAL'Nag NVMSSR

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Nine Mile Point Unit 2

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I. DESCRIPTION OF EVENT

p p p p p 410 88 027 01 02 oF 05

On July 7, 1988 at 1454 hours, it was discovered that Nine Mile Point Unit 2(NMP2) failed to submit a required Special Report and was not in compliance withits Technical Specifications (TS), Section 3.3.7.8, concerning the operabilityof the Loose Parts Monitoring (LPM) system. At the time of the discovery theplant was operating at approximately lOOX of its rated thermal power with thereactor mode switch in the "RUN" position (Operational Condition 1).

'On October 6, 1987 th'e LPM system was declared inoperable and entered into theNMP2 Equipment Status Log in accordance with Admi ni strative Procedure AP-4.0,"Administration of Operations". Although the log sheet had addressed theapplicable TS and required Limiting Condition for Operation (LCO), the index forthe equipment status log had been marked for this entry as information only andnot as an LCO item. This may have significantly hindered the identification ofthe log entry for TS items by Operations at shift turnovers.

No process, other than the equipment status log.had been initiated to track thelength of time which thi s system had been inoperable. Additionally, thedepartment responsible for writing Special Reports at NMP2 was not notified in atimely manner that the Loose Parts Monitor system was removed from service.Therefore, a Special Report was not submitted. This condition lasted until thediscovery date when a Niagara Mohawk Power Corporation (NNPC) engineer,investigating the inoperable system, determined that NMP2 was in violation ofthe TS.

II. CAUSE OF EVENT

The root cause of this event was a failure of the Operations Department to trackthe LPM system operability status and to notify the NMP2 Technical SupportDepartment in a timely manner.

A contributing factor to this event is a procedural deficiency of the SiteAdministrative Procedure, AP-10.2.2, "Procedure for Reporting Variations fromNormal Plant Operations, Defects, and Non-Compliance". This procedure does notrequire the generation of an Occurrence Report (OR) when equipment is removedfrom service for which TS may require a Special Report be prepared.

NRC PORM SSSArIIA(l

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NRC FoRR 38SA(84)3) LICENSEE 4 NT REPORT (LER) TEXT CONTINUA N

U.S. NUCLEAR REGULATORY COMMISSION

APPROV ED OMS NO, 3I 50&104EXPIRES: 8/31/88

FACILITYNAME (1) OOCKET NUMBER (2)

YEAR

LER NUMSER 16)

ji..:. SEOUENTIAL S>42 REVISIONR U M8 E R '4)'4 IIUM E R

PAGE (3)

Nine Mile Point Unit 2

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0 s 0 0 o 410 027 01 03 oF 05

On two previous occasions during 1987, Occurrence Reports had been initiated as

a result of the inoperability of the LPM system. These Occurrence. Reports=hadbeen used to track the need of a Special Report but in both cases, no report was

required because the equipment was restored to service in less than 30 days.The inconsistency on the use of an Occurrence Report to track items whichrequire Special Reports supports the deficiency of AP-10.2.2 as a contributingfactor.

'II.:ANALYSIS OF EVENT

The 'event is considered reportable via 10CFR50.73 (a)(2)(i)(B) because thefailure to submit a Special Report, within the required time period, is not incompliance with the plant's Technical Specifications.

The total duration of the event was from'ovember 15, 1987 to the .date ofsubmittal of this report, August 5, 1988, approximately 9 1/2 months.

The LPM system is intended to be used for information'urposes only and is not a

safety-related system. The operators do not rely solely on the LPM system orinformation provided by the system for the performance of any safety-relatedaction. Any evaluation or action taken to confi rm the presence of a loose partis handled on a case-by-case basis.

At no time was the public health, safety or ability to shutdown or operate theplant adversely affected.

IV. CORRECTIVE ACTIONS

The immediate corrective action was to notify the responsible department of theneed for a Special Report through the writing of Occurrence Report 88-95.

The Special Report required by TS Section 3.3.7.8 has been incorporated intothis LER. Therefore, submission of this LER/Special Report satisfies therequirements of TS Section 3.3.7.8 bringing NMP2 back into compliance with TS

3.3. 7.8.

A document search has been conducted to determine if a similar situation (itemrequiring a Special Report not being submitted) has occurred. The equipmentstatus log was reviewed from October 31, 1986 (issue date of NMP2 Low Power

License) to August 12, 1988 to satisfy this requirement. This review resultedin the identification of a missed entry in the Semi-Annual Radioactive EffluentRelease Report (SARERR). LER 88-41 was submitted on September 9, 1988 to reportthat event.

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NRC Form 388A(SEr) LICENSEE EVENT REPORT ILER) TEXT CONTINUATION

U.S. NUCLEAR REGULATORY COMMISSION

APPROVED OMB NO, 3)50M(04EXPIRES: 8/31/88

FACI(.ITY NAME (1) DOCKET NUMBER (3) LER NUMBER (EI PAGE (3)

Nine Mile Point Unit 2

TEXT gOANEe «ec ~ )I /SEVE/, ow oAWanV //RC %%drrrr ~3/ ((T)

YEAR:j@

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SEOVENTIALNVMSER

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REVISIONNVMSER

01 04 0F 05

A Lessons Learned Transmittal has been submitted to the Operations Departmentconcerning the need for an Occurrence Report for the tracking of any event whichcould result in the need for a Special Report and to address the need foraccurate entries in the Equipment Status Log.

AP-10.2.2, "Procedure for Reporting Variations from Normal Plant Operations,Defects and Non-Compliance", will be revised to more clearly define what type ofevents are reportable on an Occurrence Report. This change will help assureconsistency in the use of the Occurrence Reports in reporting variations ofnormally expected plant operation.

V. ADDITIONAL INFORMATION

A. Identification of Components Referred to in this LER

Component

Loose Parts Monitoring System

IEEE 803E I IS Funct

N/A

IEEE 805.System ID

B.

C.

Component Failures - None

Previous Similar Events — None.

D.

However, there have been two related events. The first concerned anevent where a Special Report was not submitted due to a programmaticdeficiency (LER 88-03). In that case, Technical Support failed torecognize the need for a Special Report even though an OccurrenceReport was issued.

The other related event, a missed SARERR entry was discovered duringa review for this LER 88-27 Rev. 0, was reported in LER 88-41. Inthat case, the Operations Department had an incomplete entry in theEquipment Status Log index. The Occurrence Report failed to identifythat an SARERR was required, and the department responsible forpreparing the SARERR did not verify that the report was corn'piete.

In compliance with TS Section 3.3.7.8; the following information isbeing provided.

CAUSE - On October 6, 1987 four channels of NMP2 Loose Parts Monitor (LPM)system were in the alarm condition and would not reset. Data beingcollected at that time, as part of the Power Ascension Test phase of NMP2,

led to the determination that the cause of the problem is high backgroundnoi se 1 evel due to mechani cal vibr ati on.

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NRC fons 344AIQB3) LICENSEE E ENT REPORT.tLER) TEXT CONTINUA ON

U.S. NUCLEAR REGULATORY COMMISSION

APPROVED OMB NO. 3150-0104

EXPIRES: 8/31/88

fACILITYNAME ll)

Nine M)ile Point Unit 2

Tl)ET W/RS/4 «MOP Jr /ECvSNE 1/et Odl/OO//IP//IC fo/III3/PEA B) l17)

DOCKET NUMBER 12)

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YEAR

88

LER NUMBER ISI

: '~ SEGVENTIAL'? NVMSEA

027

AEVISIONNVMBE+

01

PAGE 131

05 o)- 05

PLANS FOR RESTORATION - NMPC Engineering activities correct the problemsinvolved interaction between the vendor, Architect/Engineer and other plantswhich have a similar monitoring system. Recommended corrective actions to makethe NMP2 LPM system operational are as follows:

1. Modifications to the amplifier cards based on vendor recommendations.

2. Evaluating cable wiring layout design which could have contributed to theLPM system noise.

3. Procedural changes used in the calibration of the LPM system.

These changes are scheduled to be completed by the end of the first refuelingoutage.

NRC cOAM SECA<8-B3i

~ 5 GPO 1955 0 524 538 <55

44045

NIAGARAMOHAWKPOWER CORPORATION/300 ERIE BOULEVARDWEST, SYRACUSE. N.Y. 13202/TELEPHONE (315) 474 1511

January 31, 1989

United States Nuclear Regulatory CommissionDocument Control DeskWashington, DC 20555

RE: Docket No. 50-410LER 88-27Revision 1

Gentlemen:

In accordance with 10 CFR 50.73, we hereby submit the followingLicensee Event Report:

LER 88-27's being submitted in accordance with 10 CFR 50.73Rev 1 (a) (2) (i ) (8), "Any operation or condition prohibited

by the plant's Technical Specifications".

This revision is bei ng submitted to update information made in theoriginal LER, and the original Special Report.

This report was completed in the format designated in NUREG-1022,Supplement 2, dated September 1985.

Very truly yours,

J. L. WillisGeneral SuperintendentNucl ear Generation

JLW/TJS/cjm

Attachments

cc: Regional Administrator, Region 1

Sr. Resident Inspector, W. A. Cook