ML17342B200

LER 88-001-00:on 880129,operability Requirements of Tech Spec 3.5.1 for Steam Generator lo-lo Level Reactor Could Not Be Met.Caused by Procedural Error.Setpoints of Affected Channels Rechecked,Calibr & Procedure revised.W/880226 Ltr

ML17342B200
Person / Time
Site:	Turkey Point
Issue date:	02/26/1988
From:	Conway W, Hart R FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
L-88-100, LER-88-001-01, LER-88-1-1, NUDOCS 8803030276
Download: ML17342B200 (9)

Text

REGULA Y INFORMATION DISTRIBUTIO YSTEM (RIDS)

ACCESSION NBR: 8803030276 DOC. DATE: 88/02/2b NOTARIZED: NO DOCKET ¹ FACIL: 50-251 Turkey Point Plant> Unit 4> Florida Power and Light C 05000251 AUTH. NAME AUTHOR AFFILIATION HART> R. D. Florida Power 5 Light Co.

CONWAY> W. F. Florida Power Ec Light Co.

RECIP. NAME REC IP IENT AFFILIATION

SUBJECT:

LER 88-001-00: on 880129> operability requirements of Tech Spec 3. 5. 1 For steam generator lo-lo level reactor could not be met. Caused bg procedural error. Setpoints of affected channels rechecked> calibr 0 pr ocedure revised. W/880226 ltr.

DISTRIBUTION CODE: IE22D COPIES RECEIVED: LTR I ENCL TITLE: 50. 73 Licensee Event Report (LER)> Incident Rpt>

+etc.SIZE:

NOTES:

RECIPIENT COPIES RECIPIENT 'OPIES ID CODE/M*ME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 LA 1 PD2-2 PD 1 EDISON> G 1 1 INTERNAL: ACRS MICHELSON 1 ACRS MQELLER 2 2 AEOD/DQA 1 1 AEOD/DSP/NAS 1 1 AEOD/DSP/RO*B AEOD/DSP/TPAB 1 1 ARM/DCTS/DAB 1 1 DEDRO 1 1 NRR/DEST/ADS7E4 .1 0 NRR/DEST/CEBSH7 1 1 NRR/DEST/ESB 8D 1 1 NRR/DEST/ICSB7A 1 1 NRR/DEST/MEB9H3 1 1 NRR/DEST/MTB 9H 1 1 NRR/DEST/PSBSD1 1 NRR/DEST/RSB 8E 1 1 NRR/DEST/SGB 8D 1 NRR/DLPG/HFBiOD 1 1 NRR/DLPG/GAB10A 1 1 NRR/DOEA/E*B11E 1 1 NRR/DREP/RAB10A 1 NRR /DREP /RP 0 10A 2 2 NRR/D3LSIBIBPAi 1 1 NRR/PMAS/ILRB12 R FML 1 1 RES TELFORD> J 1 RES/DE/EIB 1 1 RES/DRPS DIR 1 RGN2 FILE 01 1 EXTERNAL: EG8cG GROH> M 5 5 FORD BLDG HOY> A 1 1 H ST LOBBY WARD 1 1 LPDR 1 1 NRC PDR 1 1 NSIC H*RR IS> J 1 1 NSIC MAYS> G 1 1 TOTAL NUMBER QF COPIES REQUIRED: LTTR 46 ENCL 45

r NRC Form 388 U.S. NUCLEAR REOULATORY COMMISSION (9A)3) APPROVED OMS NO. 31500)0C EXPIRES'/31/88 LICENSEE EVENT REPORT ILER)

'l DOCKET NUMBER (2) PA E FACILI'TY NAME (II burke Point Unit 4 o s o o o 2 51> pF

"""" Technical Specification Limits Exceeded for Safety System Settings Due to ri t P d OTHER FACILITIES INVOLVED (Sl EVENT OA'TE(5) LfR NUMBER (5) REPORT DATE (7)

MONTH DAY YEAR YEAR EEOUENTIAL SCPI REV~ MONTH "nJ NUMBER OAY YEAR fACILITYNAMES DOCKFT NUMSERISI NUMEER Turkey Point Unit 3 o s o o o 250 01 29 88 8 0 1 00 0i2 2 6 88 NA 0 5 0 o o THIS REPORT IS SUBMITTED PURSUANT T 0 THE REOUIREMENTS OF 10 CFR (t (Choco one Or more of tne foiiovy'nf/ III OPERATINO MODE (9) 20.a02(bl 20.405 I c) 50,73(a) (2)(ir) 73.7101) 1 POWER 20A05( ~ )(1)(i) 50.35(c)(ll 50.7 3 (v I l2) H) . 73.71(cl LEVEL 50.73(a) l2) lr8) OTHER ISoeciry in AOttrect (10) 20A05(a) Ill(ii) 50.35(c) (2) treiow anr/In Test, NRC FOnn 20.a05( ~ l(l) (i(il 50.73(a) (2)(il 50.7 3(a H2) I v ii) l(AI 366A/

20A05(a)lllllv) 50.73(a H2) liil 50.73(al(2)lr)QI(SI 20.405 I~ Illl(vl 50.73(al(2)DII) 50.73( ~ )I2)(a)

LICENSEE CONTACT FOR THIS I.ER (12I NAME TELEPHONE NUMBER AREA CODE r

Randall D. Hart, Licensing Engineer 46 -6 559 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE OESCRIBEO IN THIS REPORT (13)

MANUFAC REPORTABLE MANUFAC- EPORTASLE CAUSE SYSTEM COMPONENT TURER TO NPROS SRMNl CAUSE SYSTEM COMPONENT TURER TO NPADS

~tl¹l~]

,MARIE MONTH OAY AYvco:.

YEAR REPDAT ExPEcTED lla) EXPECTED 6B>'UPPLEMENTAL SUBMISSION DATE (15)

YES /II yer, comp/ere EXPECTED SU8M/SS(ON DATE/ NO A8$TRAcT I(imit to /400 tpecet, I,e.. epproeimetery I//teen tinpre apace typewnttrn /met/ (18)

In the course of resolving a management on shift (MOS) concern, a review of instrument surveillance procedures for Technical Specification (TS) compliance was initiated . This review identified instances where the surveillance procedures for instrument channels would allow the channel to be left in a nonconservative setting. Although the setpoints for these channels were set as close as possible to the TS values, the procedures did allow for a tolerance around the specified value which would allow the channel to be left slightly on the nonconservative side of the TS required value. Because of the possibility of nonconservative settings, the actual setpoints of the affected channels were reviewed.

On January 29, 1988, it was determined, based on these reviews, that the operability requirements of TS 3.5.1, Table 3.5-1 and 3.5-2, for steam generator low low level reactor trip could not be met. Because no other action statement is provided for this condition, TS 3.0.1 was entered requiring a unit shutdown. At this time a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> relief from TS 3.0.1 was requested from and granted by the NRC. On January 30, 1988, the affected setpoints were recalibrated and within TS limits taking Unit 4 out of TS 3.0.1. Our investigation has determined that one or more of these procedure inadequacies resulted from an incorrect determination that the TS value was a nominal value which allowed application of a tolerance band .

8803030276 880226 PDR ADOCI/L 05000251 8 PDR NRC form 355 (9 83 I

NRC Form ~ 388A U.S. NUCLEAR REGULATORY COMMISSION I9831 LICENSEE NT REPORT (LER) TEXT CONTINUA I N APPROVEO OMB NO, 3150W104 EXPIRES: 8/31/88 FACILITY'HAMS lll OOCKET NUMBER l21 LER NUMBER 16) PACE 131 SEOUENTIAL REVISION YEAR NUMBER g~ NUMBER Turkey Point Unit 4 0 5 0 0 0 P 5 0 0 1 OF TEXT /8 AKSe <<MOP ir /OSUIRE FFO ~//RC Ann 3/T/AS/ IITI EVENT:

On January 27, 1988, a Management on Shift (MOS) observer noted that certain procedure requirements did not seem to be consistent with the Turkey Point Technical Specifications (TS). The MOS observations were reviewed the next day and an action item was assigned to address the concern. In the course of resolving the concern, a review of instrument surveillance procedures for TS compliance was initiated'his review identified instances where the surveillance procedures for instrument channels would allow the channel to be left in a slightly nonconservative setting. Although the setpoints for these channels were set as close as possible to the TS values, the procedures did allow for a tolerance around the specified value which would allow the channel to be left slightly on the nonconservative side of the TS required value.

Because of the possibility of nonconservative settings, the actual setpoints of the affected channels were reviewed'n January 29, 1988, it was preliminarily determined, based on these reviews, that during the last surveillance, four of nine channels for the low low steam generator (SG) level reactor trip and auxiliary feedwater (AFW) initiation signals were left slightly below the TS setpoint of greater than or equal to 15'ecause two of these channels affected one SG, the minimum channels operable requirements of TS 3.5 ', Table 3 '-1 and 3 '-2, could not be met Because no other action statement is provided for this condition, TS 3.0.1 was

~

entered at 1200 on January 29, 1988, necessitating the unit to be in hot standby (mode 3) within 7 hours't this time, the NRC was contacted regarding the application of discretionary enforcement for the situation ~ After detailed discussions with the NRC, an extension of TS 3 0 1 requirements for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ~ ~

was granted to allow for recalibration of the affected setpoints. At 0210 on January 30, 1988, the affected setpoints were recalibrated and within TS limits taking Unit 4 out of TS 3 ~ 0 1 ~ ~

CAUSE OF EVENT:

Our preliminary investigation has determined that one or more of these procedure errors resulted from an incorrect determination that the TS value was a nominal value which allowed application of a tolerance band . This, tolerance band was set such that the setting could be left outside the TS limits ANALYSIS OF EVENT:

During this event, Unit 4 was at 100%. power and Unit 3 was in cold shutdown (mode 5) ~

Each SG has three (3) level transmitters that feed the reactor protection system and auxiliary feedwater (AFW) initiation logics'he reactor trip and AFW automatic initiation logics for SG low low level is any 2 out of 3 channels indicating low low level on 1 out of 3 SGs ~

NRC FORM SESA *U.S.OPO:1988-0.824 838/ASS (9831

a' RC ForM~A U.S. NUCLEAR REOULATORY COMMISSION 194)3)

LICENSEE E ENT REPORT ILER) TEXT CONTINUATION APPROVEO OMS NO. 3)50M)04 EXPIRES: 8/31/88 FACILITY'NAME (I) OOCKET NUMBER I2I LFR NUMSER 18) PACE LT)

YEAR SEQUENTIAL REVISION NUMSER 'd'or NUM E II Turkey Point Unit 4 0 S 0 0 0 O 5 001 00 03 OF 0 4 TE)EF //F/rrrrro NMoo Jr nqcked, Iroo ~H/IC  %%dr/II 8%49/ 117)

The data from the last surveillance showed that 3 channels were at 14.975% and 1 channel was at 14.95%. The as found settings of 2 channels on the 4B SG at 14 .95% and 1 channel on the 4A SG at 14 .925% fall within the allowable values (greater than or equal to 14%) provided by our NSSS vendor for the proposed upgrade TS. The current TS trip setpoint for SG low low level is greater than or equal to 15%.

The power range flux low setting (less than or equal to 25% power) which provides protection during reactor startup can be manually bypassed when two out of four power range channels reach the P-10 setpoint (10% of rated thermal power). During a unit shutdown, three out of four power range channels reaching the P-10 setpoint automatically reinstates the trip function and enables the P-6 permissive to re-energize the source range channels. During normal power .

operation the power range flux high setting (109% power, actual setpoint of 108% power) provides the reactor trip protective function on overpower condition.

The P-10 permissive does not provide any protective functions during normal power operation.

One channel (N-42) of the power range P-10 setpoint was indicated to be set slightly higher than the TS limit (10% rated thermal power). The as found value of 10.5% falls within the allowable values provided by our NSSS vendor for the proposed upgrade TS.

Our current TS do not provide any action statements for this condition. The TS upgrade project submittal for Turkey Point provides action statements that require the setpoint to be readjusted if it exceeds the trip setpoint but is within the "allowable value", thus not requiring the channel to be declared inoperable . These actions statements are consistent with the standard technical specifications.

The "allowable value" is a nominal allowance for setpoint drift between calibrations and has been used in several plant specific standard technical specifications.

Besides the SG level channels and the P-10 setpoint discussed above, three other instruments had surveillance procedures which could have allowed nonconservative settings. Each of these instruments were reviewed to identify the as found condition of the channels. All of these were found to be in compliance with the current TS settings .

Based on the above, the health and safety of the public was not affected since the procedures acceptance criteria and the as found values fell within the "allowable value" which our NSSS vendor has determined to be bounded by calculations used in the Turkey Point safety analysis.

CORRECTIVE ACTIONS:

1) The setpoints of the affected channels were rechecked, calibrated and the as found values recorded . This action was completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of entering TS 3.0.1.

NRC FORM 344A *U.S.GPO')1988.0 824 538/455 I94)3)

t NRC Fern. 366A US. NUCLEAR REGULATORY COMMISSION

%831 LICENSEE E v T REPORT ILER) TEXT CONTINUAT N APPROVED OMB NO. 3150&(04 EXPIRES: 8/31/88 FACILITY NAME (I 1 DOCKET NUMBER (21 LER NUMBER (6) PACE 131 YEAR SEOUENTIAL REVISION NUMBER NUM E II Turkey Point Unit 4 TEXT //F/rar/e Nrece N /I(/rer/ Iree at/e5orM/HRC fcrrn 388A3/ (171 o s o o o 2 5 l 8 8 00 04<<

2) The affected procedures which allowed the nonconservative setpoints are being revised to ensure that the acceptance criteria falls within the limits provided in the current TS.

The TS table of safety system setpoints is being revised as a part or t<<~

3) standard TS upgrade project. This revised table will provide the setpoints bands . The upgraded along with "allowable values" to be used for tolerance TS will help prevent this event from recurring.

Our NSSS vendor had been requested to reevaluate our current setpoints to 4) rovide the instrument errors and drift assumed in the prov safety analysis . This data will be used to ensure that the procedures are written to ensure compliance with our TS and safety analysis.

ADDITIONAL DETAILS:

The reactor protection system for Turkey Point was designed by Westinghouse .

Similar Occurrences: None NRC FORM 366A *U S GPO 1988 0 82C 538/455 (9831

'e r.

r

P. O. 14000, JUNO BEACH, FL 33408.0420 FEBRUARY 2 6 1988 L-88-100 10 CFR 50.73 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:

Re: Turkey Point Unit,4 Docket No. 50-251 Reportable Event: 88-01 Date of Event: January 29, 1988 Technical Specification Limits Exceeded for Safety System Settings Due to Non-Conservative Acce tance Criteria in Plant Procedures The attached Licensee Event Report (LER) is being submitted pursuant to the requirements of 10 CFR 50.73 to provide notification of the subject event.

Very truly yours,

/

W. F. Co way Senior Vice President-Nuclear WFC/SDF/gp Attachment cc: Dr. J. Nelson Grace, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant SDF/015. LER an FPL Group company