05000250/LER-2021-002, Unrecognized Technical Specification Surveillance Requirement Non-Compliance
| ML21154A110 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 06/03/2021 |
| From: | Pearce M Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-2021-114 LER 2021-002-00 | |
| Download: ML21154A110 (4) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 2502021002R00 - NRC Website | |
text
FPL U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 RE: Turkey Point Units 3 and 4 Docket No. 50-250 and 50-251 Reportable Event: 2021-002-00 Date of Event: April 15, 2021 10 CFR 50.73 L-2021-114 June 3, 2021 Title: Unrecognized Technical Specification Surveillance Requirement Non-Compliance The attached Licensee Event Repmt 05000250/2021-002-00 is submitted pursuant to IO CFR 50.73(a)(2)(i)(B) for a condition prohibited by Technical Specifications. The event affected Units 3 and 4 and is repo1ted on Unit 3 per NUREG-1022 guidance.
[f there are any questions, please call Mr. Robert Hess at 305-246-4112 or e-mail Robert.Hess@fpl.com.
Sincerely, Michael Pearce Site Vice President-Turkey Point Nuclear Plant Florida Power & Light Company Attachments: USNRC Forms 366 and 366A, current revision cc: USNRC Senior Resident Inspector, Turkey Point Plant USNRC Regional Administrator, Region II Floric.la Power & Light Company 9760 SW 344rh St., I lumesteac.l, FL 33035
Abstract
Turkey Point Unit 3 250 3
Unrecognized Technical Specification Surveillance Requirement Non-Compliance 04 15 2021 2021 002 00 06 03 2021 Turkey Point Unit 4 251 1
100
David Stoia, Licensing Engineer 305-246-6538 E
On 4/15/2021 FPL identified that Reactor Protection System (RPS) Technical Specification Functional Unit (FU) 20 had not met Technical Specification Surveillance Requirements (TSSRs) during 5 discrete periods over the past 3 years. Due to RPS design limitations, FU20, Automatic Trip and Interlock Logic, could not be fully tested above the P8 interlock (45% reactor power). The trip functions not tested are automatically bypassed and not testable above the P8 interlock, but below P8 are active and TSSR 4.3.1.1 is applicable. During the identified periods the completion time was not met. Since the condition was unrecognized, action was not taken, resulting in discrete periods of non-compliance with the TSAS.
The subject Actuation Logic Tests have since been completed and test frequencies adjusted in the Surveillance Frequency Control Program to accommodate the RPS system design. All FU20 trip functions are operable and within approved surveillance frequencies.
This event is reportable pursuant to 10 CFR 50.73(a)(2)(i)(B) for a condition prohibited by Technical Specifications.
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I ID Page of 05000-
- 3. LER NUMBER YEAR SEQUENTIAL NUMBER REV NO.
CAUSE
The cause of this event is a latent gap within the test capabilities of the Turkey Point RPS. Although not compliant with the SFCP frequencies, the practice of performing the ALT surveillances during outage conditions is consistent with the design of the Turkey Point RPS.
SAFETY SIGNIFICANCE
The safety significance of this event is low. The subject ALT surveillances had been completed at frequencies that were consistent with the design of the Turkey Point RPS. No test failures had occurred during the assessment period. The actions to bring the SFCP frequencies into alignment with the RPS design did not require any additional surveillance testing.
CORRECTIVE ACTIONS
All FU20 ALT surveillances that cannot be performed above their respective interlock power levels have been completed during reactor shutdown conditions. The SFCP implementing procedure has been revised to assign an 18-month refueling outage frequency to the subject FU20 ALT surveillances. All FU20 ALT surveillances are currently within their approved performance frequencies. FU20 is fully operable.
ADDITIONAL INFORMATION
EIIS Codes are shown in the format [IEEE system identifier, component function identifier, second component function identifier (if appropriate)].
SIMILAR EVENTS
A 5-year historical review of reportable events related to unrecognized inoperability of equipment required by Technical Specifications was performed to identify similar events or patterns. No other cases of TS surveillance frequencies that exceeded Tech Spec shutdown requirements were identified.
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