ML17286A581

LER 91-002-00:on 910110,reactor Recirculation Sys Jet Pump Operability Surveillance Testing Did Not Meet Literal Compliance W/Tech Specs.Caused by Inadequate Procedure. Procedure revised.W/910208 Ltr

ML17286A581
Person / Time
Site:	Columbia
Issue date:	02/08/1991
From:	Arbuckle J, John Baker WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-91-023, GO2-91-23, LER-91-002, LER-91-2, NUDOCS 9102140040
Download: ML17286A581 (7)

Text

ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9102140040 DOC.DATE: 91/02/08 NOTARIZED: NO DOCKET FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME . AUTHOR AFFILIATION ARBUCKLE,J.D. Washington Public Power Supply System BAKER,J.W. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 91-002-00:on 910110,reactor recirculation sos jet pump operability surveillance testing'did not meet lxteral D' compliance w/Tech Specs. Caused by inadequate procedure.

Procedure revised.W/910208 ltr.

DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR g ENCL TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc. g SIZE:

NOTES:

RECIPIENT COPIES RECIPIENT COPIES D ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA. 1 1 PD5 PD 1 1 D ENG, P. L. 1 1 S

INTERNAL: ACNW 2 ACRS 2 2 AEOD/DOA 1 1 AEOD/DSP/TPAB 1 1 AEOD/ROAB/DS P 2 2 NRR/DET/ECMB 1 1 NRR/DET/EMEB 7E 1 1 9H'RR/DLPQ/LHFB11 1 1 NRR/DLPQ/LPEB10 NRR/DREP/PRPB11 NRR/DST/SICB 7E NRR/DST/SRXB 8E RES/DSIR/EIB 1

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1 1

1 2

1 1

1 RE

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FILE LB8D1 LE 02 01 1

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1 EXTERNAL: EG&G BRYCE,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 D

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NOTE TO ALL "RIDS" RECIPIENTS PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-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

WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352 Docket No. 50-397 February 8, 1991 G02-91-023 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

NUCLEAR PLANT NO. 2 LICENSEE EVENT REPORT NO.91-002

Dear Sir:

Transmitted herewith is Licensee Event Report No.91-002 for the WNP-2 Plant.

This report is submitted in response to the report requirements of 10CFR50.73 and discusses the items of reportabi lity, corrective action taken, and action taken to preclude recurrence.

Very truly yours, J. W. Baker (H/0 927M)

WNP-2 Plant Manager JWB lr

Enclosure:

Licensee Event Report No.91-002 cc: Hr. John B. Martin, NRC Region V Hr. CD Sorensen, NRC Resident Inspector (H/D 901A)

INPO Records Center Atlanta, GA Hr. D. L. Williams, BPA (M/0 399)

NRC Resident Inspector walk over copy 9i02i40040 9i0208 PDR ADOCK 05000397 p~ r~~>>sent 8 PDR

NAC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION (64)9) APPAOVED OMB NO, 3(504))04 EXPIRES: 4I30(92 FSTIMATED BURDEN PER RESPONSE TO COMPLY WTH THIS INFORMATION COLLECTION REOUEST: 50.0 HRS. FORWARD LICENSEE EVENT REPORT (LER) COMMENTS AEGARDING BURDEN KSTIMATETO THE RECORDS AND RFPOATS MANAGEMENT BRANCH (F630), U.S. NUCLEAR AEGULATOAYCOMMISSION, WASHINGTON, DC 20555, AND TO THE PAPERWORK REDUCTION PROJECT (3)500104), OFF ICE OF MANAGEMENTAND BUDGET, WASHINGTON, DC 20503.

FACILITY NAME Ill DOCKET NUMBER (2) PA E Washington Nuclear Plant - Unit 2 0 5 0 0 0 39 7) oF04 eac or ec)rcu a )on ys em e ump pera ) ) y es )ng no )n ) era omp )ance with Technical Specifications due to Less Than Adequate Procedure Preparation/Review EVENT DATE (5( LER NUMBER IS) REPORT DATE (7I OTHER FACILITIES INVOLVED (6)

MONTH DAY YEAR YEAR e ri SEOVENTIAL NUMBEII .. e NUMBER MONTH

)crc OAY YEAR FACILITYNAMES DOCKET NUMBE'R(SI 0 5 0 0 0 0 110 19 1 0 2 00 02 891 0 5 0 0 0 OPERATING THIS REPORT IS SUBMITTED PURSUANT 7 0 THE REQUIREMENTS OF 10 CFR (): (Check one or more of the followinpl (11 MODE IBI 20A02(BI 20.405(cl 60.73(e l(2) (iv) 73.71 BI)

POWER 20AOS ( ~ I() I (II 50.36(cl Ill 60.73(e) (1)(vl 73.71(c)

LEYEL (10) 0 0 20.405( ~ l(1)(BI 50.36(c) (1) 50.73(e) (2((vil) OTHER ISpecify in Atrttrect trerow enrf In Tent, HRC Form e'Pg 1~)yc'o 20AOS( ~ l(1(()ill 50.73(e I (2) Ill 60.73(el(2) (vill)(Al 366AI 10AOSI ~ ) (1)(ivl 50,73(e) (2)(9) 60.73(e)(2) (vill)(BI

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LICENSEE CONTACT FOR THIS I,ER (12)

NAME TELEPHONE NUMBER AREA CODE J. D. Arbuckle, Compliance Engineer 50 37 7- 115 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

REPORTABLE MANUFAC.

MANU F AC. ~+Pi@~ RS~+iA EPORTABLK CAUSE SYSTEM COMPONKNT TURER CAUSE SYSTEM COMPONENT TURK'R TO NPADS kÃ4%~~

<iFeYCEF SUPPLEMENTAL REPORT EXPECTED 114) MONTH DAY YEAR EXPECTED SUBMISSION DATE (15)

YES IIIyer, COmplete KXPECTKDSUShfISSIOH DATKI NO ABsTRAcT ILimlt to leo0 tpecn, I e.. epproelmetely fifteen tlnpletpece rypewrinen linnl (16)

On Ja'nuary 10, 1991 it was determined that current Reactor Recirculation (RRC)

System Jet Pump operability surveillance testing did not meet literal compliance with the Technical Specifications. The operability of the Jet Pumps was being determined by matching RRC loop flows instead of flow control valve positions as required by Technical Specification 3.4.1.2. This discrepancy was identified by an NRC Inspector during a routine inspection of Plant Operations activities.

The cause of this event was less than adequate procedure preparation/review to ensure that the procedure for determining Jet Pump operability was in literal compliance with the Technical Specifications. The procedure provided direction to adjust drive flows such that both loops are approximately equal in flow. The Technical Specifications require both recirculation loops to be operating at the same flow control valve position. Immediate corrective action consisted of revising the appropriate procedure to be consistent with the Technical Specifications requirement, and re-performing the surveillance. Further corrective actions include

1) submitting a Technical Specification Change Request to remove the requirement of equalizing flow control positions during Jet Pump operability determinations, 2) implementing a procedure verification and validation process, and 3) reverification of the adequacy of Technical Specification procedural compliance as part of the ongoing Technical Specification Improvement Program (TSIP).

This event posed no threat to the health.and safety of either the public or Plant personnel. Matching the RRC loop flows meets the intent of the Technical Specification for determining Jet Pump operability.

NRC Form 366 (64)9)

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (669) APPROVED 0 M 8 NO. 3150010S EXPIRES: S/30/92 EST ED BURDEN PER RESPONSE TO COMPLY WTH THIS LICENSEE EVE EPORT (LER) INFORMATION COLLECTION REOUFST: 500 HRS. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS TEXT CONTINUATION AND REPORTS MANAGEMENT BRANCH (P430), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON. DC 20555, AND TO THE PAPERWORK REDUCTION PROJECT (31504104). OFFICE OF MANAGEMENTAND BUDGET. WASHINGTON, DC 20503.

FACILITYNAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3)

YEAR SEQUENTIAL REVISION

@+~ NUMSER NUM ER Washington Nuclear Plant - Unit 2 o s o o o 9 7 0 0 2 00 2oF 0 4 TEXT /llmore s/Mce /r /s/I/RrrL IISP al/l)/orNJNRC %%drm 366r(3/ (12)

Plant Conditions a) Power Level - 100%

b) Plant Mode - 1 (Power Operation)

E~O On January 10, 1991 it was determined that current Reactor Recirculation (RRC)

System Jet Pump operability surveillance testing did not meet literal compliance with the Technical Specifications. The operability of the Jet Pumps was being determined by matching RRC loop flows instead of flow control valve positions as required by Technical Specification 3.4.1.2. This discrepancy was identified by an NRC Inspector during a routine inspection of Plant operations activities.

The Technical Specifications require that, "The Jet Pumps shall be demonstrated OPERABLE prior to THERMAL POWER exceeding 25% of RATED THERMAL POWER and at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by determining recirculation loop flow, total core flow and diffuser-to-lower plenum differential for each jet pump when . . . both recirculation loops are operating at the same flow control valve position."

However, Plant Procedure (PPM) 7.4.4.1.2, "Jet Pump Operability," provided direction to adjust drive flow such that both loops are approximately equal in flow, instead of adjusting the Recirculation Loop Flow Control Valves (RRC-V-60A and RRC-V-60B) until the FCV positions are equal. This procedure provides instructions for determining the operability of the RRC Jet Pumps and is performed prior to thermal power exceeding 25% of rated thermal power, and daily when in Operational Modes 1 (Power Operation) and 2 (Startup).

Immediate Corrective Action PPM 7.4.4.1.2, HJet Pump Operability," was modified to correctly reflect the Technical Specification requirement that both Reactor Recirculation System loops are lined up with the Flow Control Valves in the same position, and the surveillance was successfully re-performed.

Further Evaluation and Corrective Action A. Further Evaluation

1. This event is reportable in accordance with the requirements of 10CFR50.73(a)(2)(i)(B) as a condition prohibited by the Plant's Technical Specifications.

2. There were no structures, systems or components that were inoperable -at the start of this event that contributed to the event.

NRC Form 366A (689)

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (64)9) APPROVED OMB NO. 3)504)(04 6 XP I R ES: 4/30/92 ES TED BURDEN PER RESPONSE TO COMPLY WTH THIS LICENSEE EVE REPORT ILER) INFORMATION COLLECTION REOUEST: 50.0 HRS. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS TEXT CONTINUATION AND REPORTS MANAGEMENT BRANCH (F430), U.S, NUCLEAR REGULATORY COMMISSION, WASHINGTON, OC 20555, AND TO 1HE PAPERWORK REDUCTION PROJECT (31500104), OFFICE OF MANAGEMENTAND BUDGET, WASHINGTON, DC 20503.

FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3)

YEAR SEQVENTIAL REVISION NUMBER Ice NVM ER

~24 Washin ton Nuclear Plant - Unit 2 o s o o o 9 7 91 00 2 000 3 0F 0 4 TEXT ///mme 4/Jece /4 mqvkrd, IN4 Edd/don4/HRC FomI 36643/ (12)

3. The root cause of this event is Less Than Adequate Procedure Preparation/Review to ensure that the procedural method for determining Jet Pump operability was in literal compliance with the Technical Specifications.

As previously stated, PPM 7.4.4.1.2 is the procedure used to determine the operability of the Jet Pumps. The original version (Revision 0) of was issued in 1983 and contained the Technical Specification-PPM'.4.4.1.2 required direction to line up both recirculation loops such that they have the, same flow control valve position. In 1985, Revision 1 to the procedure was issued and the direction was changed to adjust drive flows such that both loops are approximately equal in flow.

The reason this change was made is because experience had shown that both Reactor Recirculation System pumps and valves have unique operating characteristics that, in combination with matched flow control valve positions, could potentially cause a non-compliance with Technical-Specification 3.4.1.3. With flow control valve positions at 80 85%, the potential could exist for a .flow mismatch to occur. The design of the Reactor Recirculation System at WNP-2 is such that the two pumps (RRC-P-lA and RRC-P-18) run at constant speed, driven by either 15 Hz or 60 Hz power supplies. The only way to vary flow in the recirculation loops is by manipulating the flow control valves.

However, although this change to the procedure was technically prudent and the correct action to take for meeting the intent of the Jet Pump operability requirements, a Technical Specification Change Request should have been submitted and approved prior to implementation of the procedure change to provide literal compliance with the Technical Specifications.

B. Further Corrective Action A Technical Specification Change Request will be submitted to the NRC to remove the requirement of equalizing flow control valve positions during RRC Jet Pump operability determinations.

2 ~ Changes have been made to the procedure preparation and review process since the time-frame when the changes to the Jet Pump operability procedure were made. Specifically, a procedural verification and validation process has recently been implemented. Verification is the process of confirming and documenting the technical accuracy and written correctness of Plant procedures. Validation is the evaluation performed to determine that Plant procedures provide adequate guidance to the procedure user and to ensure proper operation/maintenance of Plant equipment.

3. A reverification of .the adequacy of our procedural compliance to Technical Specification requirements is also planned as part of the Technical Specification Improvement Program (TSIP) which is currently in progress.

NRC Form 366A (689)

NRC FORM 366A (64)9)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION t U.S. NUCLEAR REGULATORY COMMISSION t APPROVED OMS NO. 31504104 EXPIRES'/30/92 ESTIMATED BURDEN PER RESPONSE TO COMPLY WTH THIS INFORMATION COLLECTION REQUEST: 508) HRS. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS AND REPORTS MANAGEMENT BRANCH (P4530), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555, AND TO THE PAPERWORK REDUCTION PRO/ECT (31500104). OFFICE OF MANAGEMENTAND BUDGET, WASHINGTON, DC 20503.

FACILITY NAME (1) DOCKET NUMBER (21 LER NUMBER (6) PAGE (3)

Y 6 AR @g Sf GVS NTIAL,R@ RfVrfrON NVMBfII 'rr%1 NVMSfR Washington Nuclear Plant - Unit 2 0 s 0 0 0 3 9 7 9 1 0 2 0 0 4 OF 0 4 TEXT /// more epeco /4 rer/u/rer/ ueo atd rr/rrre///RC %%drm 35SA'4/ (IT)

Safet Si nificance There is no safety significance with this event. The assumption in the design basis Loss-of-Coolant-Accident (LOCA) analysis for Reactor Recirculation System Jet Pump operability is that the flows are matched. The capability of reflooding the core to two-thirds core height is dependent upon the structural integrity of the Jet Pumps.

If a beam holding a Jet Pump in place fails, the Jet Pump suction and mixer sections could become displaced, resulting in a larger flow area through the Jet Pump and a lower Jet Pump suction elevation. This could adversely affect the water level in the core during the reflood phase of a LOCA, as well as the assumed blowdown flow during a LOCA.

The Technical Specification surveillance requirement is designed to detect significant degradation in Jet Pump performance that could precede Jet Pump failure. The intent of this surveillance is to ensure that the three comparisons in the Specification (loop flow versus flow control valve position, total core flow and individual Jet Pump differential pressure) are measured at approximately a balanced jet pump loop flow condition each time. Matching the Reactor Recirculation loop flows, instead of just matching flow control valve positions, meets the intent of the Specification (in a different way) for verifying that a Jet Pump is not damaged. As a result, the Jet Pumps were operable during the event period.

Accordingly this event posed no threat to the health and safety of, either the public or Plant personnel.

Similar Events There have been LERs written for not being in literal compliance with"'the Technical Specifications; however, none were related to Jet Pump operability or the Reactor Recirculation System.

EIIS Information Text Reference EIIS Reference

~Setem ~tom onent Reactor Recirculation (RRC) System AD RRC Jet Pumps AD P RRC-V-60A AD FCV RRC-V-60B AD FCV RRC-P-1A AD P RRC-P-1B AD P N RC Form 366A (669)