05000250/LER-1981-006-03, /03L-0:on 810324,rept Not Submitted Per Tech Spec 6.9.2.b.2 When Action Mode of Tech Spec 3.1.5.d Was Entered. Caused by Misinterpretation of Reporting Requirements.Plant in Process of Obtaining Interpretations of Requiremen

/03L-0:on 810324,rept Not Submitted Per Tech Spec 6.9.2.b.2 When Action Mode of Tech Spec 3.1.5.d Was Entered. Caused by Misinterpretation of Reporting Requirements.Plant in Process of Obtaining Interpretations of Requirements

ML17340B165
Person / Time
Site:	Turkey Point
Issue date:	04/23/1981
From:	Pace P FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML17340B164	List: 05000250/LER-1981-006, Forwards LER 81-006/03L-0 05000250/LER-1981-006-03, /03L-0:on 810324,rept Not Submitted Per Tech Spec 6.9.2.b.2 When Action Mode of Tech Spec 3.1.5.d Was Entered. Caused by Misinterpretation of Reporting Requirements.Plant in Process of Obtaining Interpretations of Requiremen
References
LER-81-006-03L, LER-81-6-3L, NUDOCS 8105120369
Download: ML17340B165 (3)

LER-1981-006, /03L-0:on 810324,rept Not Submitted Per Tech Spec 6.9.2.b.2 When Action Mode of Tech Spec 3.1.5.d Was Entered. Caused by Misinterpretation of Reporting Requirements.Plant in Process of Obtaining Interpretations of Requirements

Event date:
Report date:
2501981006R03 - NRC Website

text

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REPORTABLE OCCURRENCE 250-8 6

LICENSEE EVENT REPORT PAGE

'QJO Additional Event Descri tion and Probable Conse uences:

Reference Inspection Report Nos. 50-250/81-05 and 50-251/81-05 During review of Quality Control Surveillance Reports "the (NRC) inspector noted that the technical specification limit for chloride concentration was exceeded in the unit 3 reactor coolant system (RCS) for several days in May 1980 while unit 3 was in cold shutdown.

Technical Specification Limiting Condition for Operation 3.1.5.d.

requires that chloride concentration be maintained at less than 0.15 ppm. 'or several days in May 1980, Unit 3 RCS chloride concentration was 0.20 ppm.

The unit was in cold shutdown which was the. condition required by LCO 3.1.5.d.

The licensee concluded that LCO 3.1.5.d.

had been exceeded but that since the plant was already in the condi-tion required by technical specifications and corrective action was taken that no violation of TS 3.1.5.d.

had occurred and that no report was required.

The inspec-tor noted that the licensee reporting requirements for 30 day reportable occurrences are identical to Regulatory Guide 1.16, 30 day reportable occurrence requirements, less the examples provided in the Regulatory Guide.

The Regulatory Guide paragraphs c.2.a(2) and c.2.b(2)

(reporting requirements for degraded mode) have previously been interpreted to mean that

'...whenever a parameter or system enters an action mode described in the related LCO, no violation of, the specification has occurred, but a 30 day written report is required.

'he licensee is not committed to follow Regulatory Guide 1.16, Reporting of Operating Information Appendix A Technical Specifications.

The licensee's Technical Specification 6.9 "Reporting Requirements" and section 6.9.2.b "Thirty Day

$lritten Reports" is a verbatum copy of Regulatory Guide 1.16 less the examples produced in the regulatory Guide; therefore, the interpretation of that portion of the Regulatory Guide is con-sidered to be an equally valid interpretation of the licensee reporting requirement.

The licensee did not have the benefit of the Inspection and Enforcement Manual Interpretations when he decided that the occurrence was not reportable; however, that not withstanding, the failure to report the out of specification RCS chloride'on-centration is a violation of Technical Specification 6.9.2.b(2).

(250, 251/81-05-02).

The licensee determined that the source of the chloride in the RCS was from. internal leakage in the boron evaporators contaminating the concentrated boric acid solution which was then transferred to the boric acid storage tanks.

Subsequent borations then transferred small amounts of chloride to the RCS of both units.

The dilution of the contaminated boric acid solution by the large volume of pure water in the RCS and the continuous purification of the RCS by the Chemical and Volume Control System (CVCS) demineralizers kept the chloride concentration within specification.

During the Unit 3 cold shutdown,

however, the continuous purification process was lost for several days as a result of maintenance requirements.

The chloride concentration then slowly increased to 0.20 ppm apparently as a result of achieving a new higher equil-ibrium level with the 'resident'hlorides leaching out of RCS materials and corro-sion product inventory within the RCS and interconnected systems.

3~hen the CVCS system was returned to service, chloride concentrations were brought back into specification.

The boric acid storage tanks have been internally cleaned and are now chloride free.

R'eplacement steam tube bundles (for boric acid evaporators) have been placed on order.

Replacement of these tube bundles will complete the long term, corrective action planned by the licensee."