ML17223B155

LER 90-010-00:on 900720,erroneous Low Temp Overprotection (LTOP) Setpoint Put in Place & Unit Entered Mode 3 on 900805.Caused by Personnel Error & Failure to Utilize Design Control Process.Setpoints changed.W/910405 Ltr

ML17223B155
Person / Time
Site:	Saint Lucie
Issue date:	04/05/1991
From:	Lauver C, Sager D FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-91-102, LER-90-010-02, LER-90-10-2, NUDOCS 9104180017
Download: ML17223B155 (6)

Text

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ACCELERATED DIS>RIBUTION DEMONSTRATION SYSTEM t

t'EGULATORY'NFORMATIONDISTRIBUTION SYSTEM (RIDS)

-,ACCESSION NBR:9104180017 DOC.DATE: 91/04/05 NOTARIZED: NO DOCKET g FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power & Light Co. 05000335 AUTH. NAME AUTHOR AFFILIATION LAUVER,C. Florida Power & Light Co.

SAGER,D.A. Florida Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 90-010-00:on 900720,erroneous low temp overprotection (LTOP) setpoint put in place & unit entered Mode 3 on 900805.Caused by personnel error & failure to utilize design control process.Setpoints changed.W/910405 ltr.

DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR TITLE: 50.73/50.9 Licensee Event Report (LER),

3Incident ENCL L SIZE:

Rpt, etc.

NOTES RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 LA 1 1 PD2-2 PD 1 1 NORRIS,J 1 1 INTERNAL: ACNW 2 2 ACRS 2 2 AEOD/DOA 1 1 AEOD/DSP/TPAB 1 1 AEOD/ROAB/DSP 2 2 NRR/DET/ECMB 9H 1 1 NRR/DET/EMEB 7E 1 1 NRR/DLPQ/LHFB11 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA/OEAB 1 1 NRR/DREP/PRPBll 2 2 NRR/DST/SELB 8D 1 1 NRR/DST/SICB 7E 1 1 NRR D SPLB8Dl 1 1 NRR/DST/SRXB 8E 1 1 02 1 1 RES/DSIR/EIB 1 1 RGA2 FILE 01 1 1 EXTERNAL EG&G BRYCE P J ~ H 3 3 L ST LOBBY WARD 1 1 NRC PDR 1 1 NSIC MAYS,G 1 1 NSIC MURPHY,G.A 1 1 NUDOCS FULL TXT 1 1 NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WAS'ONTACT THE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 33 ENCL 33

p.o. Bex 128, Ft. Pierce, FL 34954-0128 APR 06 199l L-91-102 10 CFR 50.73 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Nashington, D. C. 20555 Gentlemen:

Re: St. Lucie Unit 1 Docket No. 50-335 Reportable Event: 90-10 Date of Event: July 20, 1990 Low Temperature Qverpressure Protection Setpoint Below Technical S ecification Limit Due to Personnel Error The attached Licensee Event Report is being submitted pursuant to the requirements of 10 CFR 50.73 to provide notification of, the subject event.

Very truly yours, D. A.

Vice St L 'l ger r sident DAS GRM:kw Attachment cc: Stewart D. Ebneter, Regional Administrator, USNRC Region II Senior Resident Inspector, USNRC, St. Lucie Plant DAS/PSL N399 9i04gs~00] 7 9f 0405 PDR ADOCK 05000335 PDR 9 Group an FPL company r:-;"," 9P

FPL Facsl&ls ol U.S. NUCLEAR REGULATORY COMMISSION NRC Farm 366 APPROVEOOMB NO.31504104 tO 83) LICENSEE EVENT REPORT (LER) EXPIRES SI31165 FACILITYNAME (1) DOCKET NUMBER (2) PAGE 3 St. Lucie Unit 1 050003351 0 0 4 E(") Low Temperature Overpressure Protection Setpoint Below Technical Specification Limit due to Personnel Error EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED(8)

IAL R FACILITYNAMES DOCKET NUMBER(S)

DAY YEAR YEAR S DAY YEAR N/A 05 000 0 7 2 0 9 0 9 0 0 1 0 0 0 0 4 0 5 9 1 N/A 05000 THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR:

OPERATING Check one or more of tha followin (11)

MODE (9) 20.402(b) 20.405(c) 50.73(a)(2)(iv) 73.71(b)

POWER 50.73(a)(2)(v) 20.405(a) (1 )(i) 50.36(c)(1) 73.71(c)

LEVEL (10) 20.405(a)(1 )(ii) 50.36(c)(2) 50.73(a)(2)(vii) ,OTHER (Specify in Abstract 20.405(a)(1)(iii) 50.73(a) (2)(i) 50.73(a)(2)(viii)(A) below andin Text 20.405(a)(1)(iv) 50.73(a)(2)(viii)(B) NRC Form 356A) 50.73(a)(2)(ii) 20.405(a)(1)(v) 50.73(a)(2)(iii) 50.73(a)(2)(x)

LICENSEE CONTACT FOR THIS LER 12 NAME TELEP ONE NUMBER AREACODE Catherine Lauver, Shift Technical Advisor 4 0 7 465 -3550 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT 13 MANUFAC- REPORTABLE MANUFAC REPORTABLE CAUSE SYSTEM COMPONENT TURER TO NPRDS CAUSE SYSTEM COMPONENT TURER TO NPRDS I I I SUPPLEMENTAL REPORT EXPECTED 14 EXPECTED MONTH DAY YEAR SUBMISSION YES (lfyes, complete EXPECTED SUBMISSION DATE) DATE (15)

ABSTRACT (Limit to 1400 spaces.i.e. approximately fifteen single-space typewritten lines) (16)

On June 11, 1990 St. Lucie Unit 1 received Amendment 104 to the Technical Specifications (TS) which changed the setpoints required for Low Temperature Overpressure Protection (LTOP) to be operable (TS 3.4.13). On July 19, 1990 a meeting of the Facility Review Group (FRG) was held concerning procedural incorporation of the new setpoints. One member suggested additional changes, and these changes were added to the submitted documents and approved.

One change was to lower the setpoint of TA-1115 relay 2 and TA-1125 relay 2, from the 1A1 and 181 Reactor Coolant System cold legs, from the submitted value of 307'F to 298'F. These relays are required to open the Power Operated Relief Valves when pressure is greater than 530 psia and temperature is less than 304'F. As a result, LTOP protection was not available for the band of 298'F to 304'F with pressure greater than 530 psia.

TS 3.4.13 is applicable in Modes 4 and 5 only. Unit 1 was in Mode 5 at the time the setpoints were changed on July 20, 1990, and entered Mode 3 on August 5, 1990. The error was noticed in March of 1991, when a training instructor preparing lessons noticed inconsistencies in plant procedures.

The root cause of the event is cognizant personnel error, in that by recommending and approving additional changes to submitted material, the FRG unintentionally chose the nonconservative course of action.

Corrective actions include: correcting the procedures, changing the setpoints, changing Engineering procedures, and reviewing the event with FRG members and alternate members.

FPL Facsimile of NRC Form 366 (9-83)

FPL Facslmflerr/ U.S. NUCLEAR REGULATORY COMMISSION NRC Form 366 APPROVEO OMS No. 31504104 (9-83) EXPIRES 8/31/85 LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACILITYNAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3)

YEAR EQUENTIAL REVISION St. Lucie Unit 1 NUMBER, NUMBER 0500 0335 9 0 0 1 0 0 0 0 2 0 4 TEXT (limore spaceis required, use additional NRC Form 366A's) (17)

On June 11, 1990 St. Lucie Unit 1 received Amendment 104 to the Technical Specifications (TS),

which changed TS 3.4.13, Power Operated Relief Valves (PORVs)(EIIS:AB). The amendment changed the setpoints required for Low Temperature Overpressure Protection (LTOP)(EIIS:JC) to be operable.

On July 2, 1990, Unit 1 entered Mode 4 to replace a Reactor Coolant Pump (EIIS:AB) seal. Since TS 3.4.13 is applicable in Modes 4 and 5, the Unit would not be permitted to restart until the new setpoints were in place. On July 19, 1990 a meeting of the Facility Review Group (FRG) was held concerning the new setpoints.

While the FRG was considering the submitted procedural changes, one member suggested additional procedure changes resulting from Amendment 104 to TS 3.4.13. One of the changes concerned the setpoint for TA-1115 relay 2 and TA-1125 relay 2. These relays open the PORVs when Reactor Coolant System temperature in cold legs 1A1 and 1B1, respectively, is below 304'F and Reactor Coolant System (RCS)(EIIS:AB) pressure is greater than 530 psia. The submitted setpoint was 307'F, which is 3' conservative. The FRG changed this value to 298'F, incorrectly believing this was conservative.

The erroneous setpoint was put in place on July 20, 1990. The unit entered Mode 3 at 2145, August 5, 1990 and TS 3.4.13 is applicable in Modes 4 and 5 only. The error was discovered in March of 1991, when a training instructor who was preparing to teach LTOP material noticed inconsistencies in plant procedures.

The subject procedure changes were correct when submitted to FRG. The cause of the event is cognitive personnel error by utility supervisory personnel, in that by making additional changes to submitted material, the FRG members unintentionally chose the nonconservative course of action, which is contrary to an approved plant procedure. There were no unusual characteristics of the work location that directly contributed to the error.

A contributing factor is that FPL Engineering did not utilize an existing design control process for plant changes involving Technical Specification setpoints.

FPL Facsimile of NRC Form 366 (9-83)

FPL F6Orlrrilo o1 U.S. NUCLEAR REGULATORY COMMISSION NRC Form 366 APPROVEO 0M B NO. 31530104 I943) EXPIRES 8/31165 LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACILITYNAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3)

YEAR EQUENTIAL REVISION NUMBER NUMBER St. Lucie Unit 1 0 500 0335 9 0- 0 1 0 0 0 0 3 0 0 4 TEXT (l/more spaceis required, use additional NRC Form 366A's) (1/)

Amendment 104 changed the Pressure/Temperature limit curves for Heatup and Core Critical, Cooldown and Insewice Testing, and Maximum Allowable Cooidown Rates, and the LTOP setpoints which are based on these curves. The change was for operation up to 15 Effective Full Power Years (EFPY). The previous values were coveredby analysis for up to 10 EFPY. Unit 1 reached 10 EFPY on September 11, 1990. Since the period of time that the unit was out of compliance with TS 3.4.13 was July 20 through August 5, 1990, and the setpoints in place at that time were acceptable for operation up to 10 EFPY, the LTOP system was at all times able to perform its intended safety function. The health and safety of the public were not at risk at any time during this period.

This event is reportable per 10 CRF 50.73.a.2.i. B, any operation and condition prohibited by Technical Specifications.

1. I&C procedures 1-1200054, "LTOP Functional Test," and 1-1400064T, "Installed Plant Instrumentation Calibration (Temperature)," were changed March 8, 1991 to reflect the correct setpoint values.

2. The setpoints will be changed prior to entry into Mode 4.

3. FPL Engineering will change their procedures to ensure followup with a Plant Change/

Modification which will contain setpoint and drawing changes, when appropriate, when performing a Proposed License Amendment evaluation. This will be completed by October 18, 1991.

4. A detailed summary of this event will be reviewed by all St. Lucie FRG members and alternate members to reinforce the lessons learned by April 30, 1991.

5. Unit 2 LTOP setpoints were verified to be correct.

U

~

FPL Facsimile of NRC Form 366 (9-83)

FPL Faoslaile o1 UW NUCLEAR REGULATORY COMMISSION NRC Form 388 APPROVED OMB NO. 31500104 gl83) EXPIRES 8ISI/85 LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACILITYNAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3)

YEAR EQUENTIAL REVISION

'UMBER NUMBER St. Lucie Unit 1 0 500 0335 9 0- 0 1 0 0 0 0 4 0 4 TEXT (Ifmore space is required, use additional NRC Form 366A's) (17)

Failed Component Identification:

Previous Similar Events:

There have been no previous Licensee Event Reports written at St. Lucie Plant that discuss errors made by the Facility Review Group.

FPL Facsimile of NRC Form 366 (9-83)