ML17312A808

LER 96-002-00:on 960514,Tech Spec Violation Occurred Due to Erroneous Surveillance Requirement.Caused by Incorporation of C-E Generic Ts.Investigation Being conducted.W/960609 Ltr

ML17312A808
Person / Time
Site:	Palo Verde
Issue date:	06/09/1996
From:	Grabo B, James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
192-00970-JML-B, 192-970-JML-B, LER-96-002-02, LER-96-2-2, NUDOCS 9606180070
Download: ML17312A808 (14)

Text

CATEGORY REGULATORY'NFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION'BR:9606180070 DOC.DATE: 96/06/09 NOTARIZED: NO DOCKET g FACIL'STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi Q50Q0528 AUTH. NAME AUTHOR AFFILIATION GRABO,B.A. Arizona Public Service Co. (formerly Arizona Nuclear Power LEVINEgJ.M. Arizona Public Service Co. (formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 96-002-00:on 960514,Tech Spec violation occurred due to erroneous surveillance requirement.Caused by incorporation of C-E generic TS.Investigation being conducted.W/960609 ltr.

DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE:

TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc.

NOTES:STANDARDIZED PLANT '05000528 0

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD4-2 PD 1 1 CLIFFORD,J 1 1 INTERNAL: ACRS 1, 1 AEOD SPD/RAB 2 2 AEOD/SPD/RRAB 1 1 1 1 NRR/DE/ECGB 1 1 1 1 NRR/DE/EMEB 1 1 'NRR/DRCH/HHFB 1 1 NRR/DRCH/HICB 1 1 NRR/DRCH/HOLB 1 1 NRR/DRCH/HQMB 1 1 NRR/DRPM/PECB 1 1 D NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 RES/DSIR/EIB 1 1 RGN4 FILE 01 1 1 EXTERNAL: L ST LOBBY WARD 1 1 LITCO BRYCE,J H 2 2 NOAC MURPHY,G.A 1 1 NOAC POOREgW. 1 1 NRC PDR 1 1 NUDOCS FULL TXT 1 1 NOTE TO ALL "RIDS" RECIPIENTS:

DOCUMENT CONTROL DESK, PLEASE HELP US TO REDUCE WASTEl CONTACT THE YOUR NAME FROM ROOM OWFN 5D-S(EXT. 415-2083) TO ELIMINATE DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 26 ENCL 26

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Arizona Public Service Company PALO VERDE NUCLEAR GENERATING STATION P.O.'OX 52034 ~ PHOENIX. ARIZONA85072-2034 JAMES M. LEVINE 192-00970-JML/BAG/KR VICE PRESIDENT NUCLEAR PRODUCTION June 09, 1996 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-37 Washington, DC 20555-0001

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units1,2, and 3 Docket Nos. STN 50-528, 50-529, 50-530 License Nos. NPFQ1, NPF-51, NPF-74 Licensee Event Report 96402-00 Attached please find Licensee Event Report (LER)96-002 prepared and submitted pursuant to 10CFR50.73., This LER reports a Technical Specification (TS) violation due to an erroneous TS surveillance requirement specification for trisodium phosphate. Control Room personnel declared both trains of the Emergency Core Cooling System inoperable and entered TS Limiting condition for Operation 3.0.3.

The emergency TS amendment was approved by the NRC and TS. LCO 3.0.3 was exited within the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed by TS SR 4.0.3.

In accordance with 10CFR50.73(d), a copy of this LER is being forwarded to the Regional Administrator, NRC Region IV. If you have any. questions, please contact Burton A. Grabo, Section Leader, Nuclear Regulatory Affairs, at (602) 393-6492.

Sincerely,

/y JML/BAG/KR/pv Attachment P'all cc: L. J. Callan with attachment)

K. E. Perkins K. E. Johnston INPO Records Center 9606i80070 960609 PDR ADOCK 05000528 S PDR QI

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LICENSEE EVENT REPORT (LER)

ACILITYSAME (1) DOCKET NUMBER (2) PAGE (3)

Palo Verde Unit 1 0 5 0 0 0 5 2 8 1 OF 0 5

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Technical S ecification Violation Due to Erroneous Surveillance Re uirement LER NUMBER 6 REPORT DATE OTHER FACIUTIES INVOLVED 6 MONTH DAY YEAR YEAR SEQVENftal R Palo Verde Unit 2 0 5 0 0 0 5 2 9 051496 9 6 - 0 0 2 - 0 0 0609 9 6 Palo Verde Unit 3 REPORT IS SUBMIED PURSUANT TO THE REQQREMENTS OF 10 CFR C (Check one ar mare af the fafkirrin6) (11) 0 5 0 0 0 5 3 0 20.602(b) 20.45(c) 50.73(a)(2)(irj 73,71(b) 20.45(a)(1)gi 50.35(a)(t) 50.73(a)(2)(rj 73.71(c)

'LEYEL(to) 1 0 0 20.45(a)(1)(ii) 5IL35(c)(2) 50.73(a)(2)(r4) OTHER (Specify b Abatract 20,45(a)(1)(iii) SO.73(a)(2)(i) 50.73(a)(2)(r6r)(A) bekNr and In TarrL NRC Form 20.45(a)(1)(h) 50.73(a)(2)('u) 50.73(a)(2)(rra)(B) 355A) 3i: AAA4h;~. 20 45(a)(t)(r) 5073( j(2)(a) 50.73(a)(2)(rj UCENSEE CONTACT FOR THIS LER (1 2)

E LEPHONE NUMBER Burton A. Grabo, Section Leader, Nuclear Regulatory Affairs MANUFAC.

lURER REPORTABLE TO NPRDS 'i COMPLETE ONE UNE FOR EACH COMPONENT FAII.URE DESCRIBED fN THIS REPORT (1 3)

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6 0 2 3 MANUFAG.

lURER 9 3 - 6 REPORTABLE TO NPRDS 4 9 2

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SUPPLEMENTAL REPORT EXPECTED (16)

I YES (Eyes. compfeta EXPECIED SUBMISSON DATE) NO X DATE (15)

'TRAc'T (Umit to 14+ apacea, L4, apprcafmatefy 5fteerl alnQIe apace eprntten 4nea) (15)

At approximately 1900 MST on May 14, 1996, Operations personnel were notified by APS Engineering personnel that anhydrous trisodium phosphate (TSP stored in dissolving baskets located in the Containment basement of all three units) was in use as opposed to the Technical Specification (TS) required TSP dodecahydrate and as a result, the TS surveillance requirement (SR) 4.5.2.d.2 had not been satisfied. Although anhydrous TSP is an original design basis specification, Units 1, 2, and 3 Control Room personnel declared both trains of the Emergency Core Cooling System (ECCS) inoperable and entered TS 3.0.3 when the ACTION statements of TS LCO 3.5.2 could not be satisfied. The ACTION requirements foz 3.0.3 were delayed in accordance with TS 4.0.3 for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in order to process an emergency TS SR amendment to replace the word "dodecahydrate" with "anhydrous." Since the anhydrous TSP satisfies the design basis function, plant operations were not affected. At approximately 1553 MST on May 15, 1996, Control Room personnel declared ECCS operable and exited TS 3.0.3 and TS LCO 3.5.2 following the TS amendment approval by the NRC for all three units. A preliminary evaluation determined that the cause of the event was incorporation of the generic TS which specified TSP dodecahydrate without validating the TS against the original design which used anhydrous TSP. There have been no previous similar events reported pursuant to 10CFR50.73.

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LICENSEE EVENT REPORT (LER) TEXT CONTINUATION DOCKET NUMBER LER NUMBER PAGE YEAR RENSO NUMBER Palo Verde Unit 1 0 5 0 0 0 5 2 8 9 6 0 0 2 0 0 0 2 of05

1. 'REPORTING REQUIREMENT:

This LER 529/95-006-00 is being written to report a condition prohibited by the plant's Technical Specifications (TS) as specified in 10 CFR 50.73.(a)(2)(i)(B).

Specifically, at approximately 1700 MST on May 14, 1996, Palo Verde Units 1, 2, and 3 were in Mode 1 (POWER OPERATION), operating at approximately 100 percent power when Operations personnel (utility, licensed) were notified by APS,Engineering personnel (utility,nonlicensed) that anhydrous trisodium phosphate [TSP stored in dissolving baskets located in the Containment (NH) basement of all three units] was in use as opposed to the Technical Specification (TS) required TSP dodecahydrate, and as a result, the TS surveillance requirement (SR) 4.5.2.d.2 had not been satisfied.

Although anhydrous TSP is in the original design basis specification, Units 1, 2, and 3 Control Room (NA) personnel (utility, licensed) declared both trains of the Emergency Core Cooling System (ECCS) (BQ/BP) inoperable and entered TS 3.0.3 when the ACTION statements of TS LCO 3.5.2 could not be satisfied. The ACTION requirements for 3.0.3 were delayed in accordance with TS 4.0.3 for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in order to process an emergency TS SR amendment to replace the wozd "dodecahydrate" with "anhydrous."" Since the installed quality of anhydrous TSP satisfies the design basis function, plant operations were not affected.

2~ EVENT DESCRIPTION:

Prior to the event, the APS team responsible for converting the TS for all three units to the improved standard TS (ZTS) requested APS Design Engineering personnel to verify information related to post-LOCA (loss of coolant accident) sump volume and mass of TSP dodecahydrate used in Containment as part of the ITS first level review process. During the process of validating the quantity of TSP contained in the baskets, APS personnel identified that the form of the TSP in the Containment baskets was anhydrous rather than the dodecahydrate as specified in TS surveillance requirement (SR) 4.5.2.d.2 and the associ'ated TS Bases.

TS SR 4.5.2.d.2 stated that "Each ECCS subsystem shall be demonstrated.

OPERABLE ... At least once per 18 months by: ... Verifying that a minimum total of 464 cubic feet of solid granular trisodium phosphate (TSP) dodecahydrate is contained within the TSP storage baskets."

As a result of this discovery, the 24-hour provision of TS 4.0.3 was entered at 1900 MST on May 14, 1996, since TS SR 4.5.2.d.2 had not been satisfied. Failure to satisfy the TS SR resulted in the declaration of both ECCS trains inoperable. Per the provisions of TS 4.0.3.and Generic

~i 'hi LICENSEE EVENT REPORT (LER) TEXT CONTINUATION ACIUlYNAME DOCKETNUMBER LER NUMBER PAGE YEAR SEOVENllAL RENBIO NUMBER NUMBER Palo Verde Unit 1 0 5 0 0 0 5 2 8 9 6 - 0 0 2 - 0 0 0 3 of05 Letter 87-09, "Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements," in the case:of a missed surveillance, a 24-hour window is provided to perform the surveillance or to obtain the necessary relief from the requirement from the NRC. Failure to satisfy the SR at the end of the 24-hour action would have resulted in the shutdown of all 3 units at PVNGS.

Since the form of the TSP in Containment (i.e., anhydrous form) was in accordance with the design basis of the plant, a TS change under emergency circumstances was submitted to revise TS 4.5.2.d.2 and 'TS Bases to specify that the TSP contained in the baskets in Containment is in the anhydrous form rather than the dodecahydrate form.

At approximately 1553 MST on May 15, 1996, Control Room personnel declared ECCS operable and exited TS 3.0.3 and TS LCO 3.5.2 following the TS amendment approval by the NRC for all three units: .

3. ASSESSMENT OF THE SAFETY CONSEQUENCES AND THE ZMPLZCATZONS OF THZS EVENT:

The Bases for the TS SR 4.5.2.d.2 (TSP stored in dissolving baskets located in the Containment basement) is to minimize the possibility of corrosion cracking of certain metal components during operation of the ECCS following a LOCA. The TSP provides this protection by dissolving in the sump water and causing its final pH to be zaised to greater then or equal to 7.0. The dissolution of the TSP in the baskets also pzecludes the release of volatile iodine into the Containment atmosphere during recirculation following a LOCA.

Either form of TSP in the appropriate quantities would provide adequate neutralization of the borated'lood water following a LOCA since both materials are chelld.cally equivalent. Hence, the use of the anhydrous form does not present any compatibility issues zelative to the dodecahydrate form. However, the two forms differ in their physical characteristics, and in particular, the amount of effective phosphate per sample mass.

Anhydrous TSP yields greater buffering capacity per sample mass relative to the dodecahydrate form. However, anhydrous TSP, when subjected to high humidity, tends to hydrate forming a semi-crystalline solid. The anhydrous material, although retarded by agglomeration when the material hydrates, still possesses high dissolution characteristics as demonstzated by acceptable performances of previous 1B-month TS SR.

Therefore, the ECCS was capable of performing its design basis function during the period the surveillance requirements were not met. This event did not adversely affect the safe operation of the plant or the health and

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LICENSEE EVENT REPORT (LER) TEXT CONTINUATION AQUTYNAME DOCKET NUMBER LER NUMBER'EAR PAGE SEQUENTlAl RENQO Palo Verde Unit 1 0 5 0 0 0 5 2'8 9 6 - 0 0 2 - 0 0 04of05 safety of the public. The event did not result in any challenges to the fission product barriers or result in any releases of radioactive material. Therefore, there were no adverse safety consequences or implications as a result of this event.

4. CAUSE OF THE EVENT:

An independent inve'stigation of this event is being conducted in accordance with the APS Corrective Action Program.. As part of the investigation, a root cause is being performed. A preliminary evaluation, based on available information, has determined that the apparent cause was incorporation of Combustion Engineering (CE) generic TS which specified TSP dodecahydrate without validating the TS against the original design calculations and basis prepared by Bechtel, CE, and APS using anhydrous TSP (SALP Cause Code B: Design, Manufacturing, Installation Error).

Two factors contributed to the delay in identifying the discrepancy,:

1 ~ TSP is loaded on a one-time initial load. Except for the refill of the baskets in Unit 2 following an event on May 28, 1994 (gravity drain from the reactor drain tank to containment), there were no other opportunities for identifying the difference in TSPs. The TSP stored in the warehouse was used for the refill.,

2 ~ The 18-month surveillance procedure does not test for a particular form of TSP.. It is concerned'ith measuring TSP volume and sampling for solubility and buffering capacity.

No unusual characteristics of the work location (e.g., noise, heat, poor lighting) directly contributed to this event. If information is developed which would significantly affect the reader's understanding or perception of this event or if the final evaluation results differ from .this determination, a supplement to this report will be submitted.

STRUCTURE, SYSTEM, OR COMPONENT INFORMATION:

Although the ECCS was declared inoperable for a lapsed surveillance requirement, there were no component or system failures involved in this event. No failures of components with multiple functions were involved.

No failures that rendered a train of a safety system inoperable were involved. There were no safety system responses .and none were necessary.

Ol 'ii LICENSEE EVENT REPORT (LER) TEXT CONTINUATION DOCKET NUMBER LER NUMBER PAGE gEAR SEQUENTlAl REDO NUMBER . NUMBER Palo Verde Unit 1 0 5 0 0 0'5 2 8 9 8 - 0 0 2 - 0 0 0 5 of 0 5

6. CORRECTIVE ACTIONS TO PREVENT RECURRENCE:

An independent investigation of this event is being conducted in accordance with the APS Corrective Action Program. The investigation is expected to be completed by June 19, 1996. Actions to prevent recurrence are being developed based on the results of the investigation and will be tracked to completion under the APS Commitment Action Tracking System (CATS)'. Actions to date include initiating an Updated Final Safety Evaluation Report change request and updating applicable proceduzes.

During the conversion to improved TS, APS wi'll continue its efforts to identify any other TS discrepancies.

7. PREVIOUS SIMILAR EVENTS:

Although there have been previous events reported pursuant to 10CFR50.73 in the last three years for TS surveillance requirements not being satisfied, the causes discussed in the previous events have not been similar to this event. 'Therefore, the corrective actions of the previous events would not have prevented this event.

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