ML17345A317

LER 88-014-00:on 880714,RCS Leakage Surveillance Not Performed within Required Interval Due to Personnel Error. Note Placed in Night Book Stressing Need to Meet 18-30 H Tech Specs requirements.W/880815 Ltr

ML17345A317
Person / Time
Site:	Turkey Point
Issue date:	08/15/1988
From:	Conway W, Gross K FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
L-88-348, LER-88-014, LER-88-14, NUDOCS 8808190083
Download: ML17345A317 (6)

Text

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• AC CELZRATED i

DISTRIBUTION DEMONSTRATION 0

SYFZ@M REGULATORY XNFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8808190083 DOC.DATE: 88/08/15 NOTARIZED: NO DOCKET g ~

FACIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 AUTH. NAME . AUTHOR AFFILIATION GROSS,K.W. Florida Power & Light Co.

CONWAY,W.F. Florida Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 88-014-00:on 880714,RCS leakage surveillance not performed within required interval due to personnel error.

W/8 ltr.

DISTRIBUTION CODE: IE22D COPIES RECEIVED:LTR ( ENCL )

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

SIZE: W 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 EDISON,G 1 1 INTERNAL: ACRS MICHELSON 1 1 ACRS MOELLER 2 2 AEOD/DOA 1 1 AEOD/DSP/NAS 1 1 AEOD/DSP/ROAB 2 2 AEOD/DSP/TPAB 1 1 ARM/DCTS/DAB 1 1 DEDRO 1 1 NRR/DEST/ADS 7E 1 0 NRR/DEST/CEB 8H 1 1 NRR/DEST/ESB 8D 1 1 NRR/DEST/ICSB 7 1 1 NRR/DEST/MEB 9H 1 1 NRR/DEST/MTB 9H 1 1 NRR/DEST/PSB 8D 1 1 NRR/DEST/RSB 8E 1 1 NRR/DEST/SGB 8D 1 1 NRR/DLPQ/HFB 10 1 1 NRR/DLPQ/QAB 10 1 1 NRR/DOEA/EAB 11 1 1 NRR/DREP/RAB 10 1 1 NRR/DREP/RPB 10 2 2 R- SIB 9A 1 1 NUDOCS-ABSTRACT 1 1 REG FI 02 1 1 RES TELFORD,J 1 1 SXR DEPY 1 1 RES/DSIR/EIB 1 1 RES/DSR DEPY 1 1 RGN2 FXLE 01 1 1 EXTERNAL: EG&G WILLIAMS,S 4 4 FORD BLDG HOY,A 1 1 H ST LOBBY WARD 1 1 LPDR 1 1 NRC PDR NSIC MAYS,G 1

1 1

1 NSIC HARRIS,J 1 1 I' B.

A TOTAL NUMBER OF COPIES REQUIRED: LTTR 46 ENCL 45

NRC Form 348 U J. NUCLEAR REGULATORY COMMISSION (44)3) ~

APPROVED OMB NO. 31504104 LICENSEE EVENT REPORT (LER) EXPIRES: 8/31/88 FACILITY NAME (I) DOCKET NUMBER (2) PA E 3)

Turkey Point Unit 3

""eactor ot er ps op p25010F04 Coolant System Leakrate Surveys ance orme I

Within Re uired Interval Due to Personnel Error EVENT DATE ISI LER NUMBER Lel REPORT DATE (7) OTHER FACILITIES INVOLVED (4)

YEAR SEOUENTrAL jgC REYtsrON MONTH DAY YEAR FACILITYNAMES OCKET NUMBER(>>

MONTH DAY YEAR NVMSER,,) NuMSER Turke Point Unit 4 p 5 o o o 2 5 1 7 1 4 8 8 8 8 014 0 0 0 8 1 5 8 8 0 5 0 0 0 THIS REPORT IS SUBMITTED PURSUANT T 0 THE REOUIREMENTS OF 10 CF R (): (Check One or more of the follorfrhP/ (11 OPERATINO MODE (8) 20.405(cl 50.73(el(2)()r) 73.71(4)

POWER 20.405( ~ )Ill(ll SOM(e)(I) 50.73(el(2)bl (2)(ale 73.71(c)

LEYEL (I 0 I 1 0 0 20 405 (e l(11(E) 50.34(cl(2) 50.73(e) (2)(re) oTHER (Spectfy ln Aettrect Selow end in Tent, Hl)C Form

.4%k,>>':Atria'0.402(e) 20.405 (4 ) () I (el) 50.73( ~ l(2)(II 50.73(el(2)(rIII)(A) 3r)EA) 20AOS(el(1) llrl 50.73( ~ )(2)(e) 50.73(e l (8) 20.405(e) IIsr) 50.73(e) (2)(III) 50.73(el(2)(e)

LICENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER AREA CODE Karl W. Gross, Complaince Engineer 30 5 246 - 7 49 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

COMPONENT MANUFAG EPORTABLE CAUSE SYSTEM COMPONENT MANUFAG EPORTABL CAUSE SYSTEM TURER TO NPRDS TVRER TO NPRDS 54M SUPPLEMENTAL REPORT EXPECTED (14) MONTH OAY YEAR EXPECTED SUBMISSION DATE (15)

YES (lf yet, complete EXPECTED SVESIISSIDIV DATE( X ABSTRACT (Limit to f400 tpecel, I e., epproxlmetely fifteen tlnple.tp>>ce typewrlnen lineal (I ~ I On July 14, 1988 a Quality Assurance Audit conducted to verify the implementation of Technical Specification 3.1, "Reactor Coolant System" identified two occasions in December of 1987 when RCS leakage was not determined within the required interval. The surveillances should have been performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> plus or minus 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The intervals between actual performances were 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br />, 42 minutes and 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />, 25 minutes. Existing plant procedures require either stabilized RCS conditions or a visual inspection for leakage . During both of the occurrences identified the unit was in the process of changing power levels which the operators believed precluded obtaining accurate results. The root cause of this event was personnel error by operators in delaying performance of the surveillance beyond the required interval.

Corrective actions taken include a note placed in the night order book stressing the need to meet the 18 to 30 hour3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />., requirement identified by the Technical Specifications for conduct of the RCS Leakrate determination, evaluation of a third method for performance of'CS leak rate calculations and review of Technical Specifications for possible changes .

SSOS1900S3 SSOSl5 PDR ADOCK 05000250 S PDC

'ER NRC Form 354A

!9831 U.S, NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER) TEXT CONTINUATION APPROVEO OMB NO. 3150M104 EXPIRES: 813IIBB FACILITY NAME Ill DOCKET NUMBER 12)

NUMBER 151 PAGE 13)

YEAR . !o!o SEGVENTrAL .+ I REVrSION NUM SR "rr+: NUMBER Turkey Point Unit 250 TSKT O'IROre <<Moe << ~, rrOO aklhbnel 3

iVRC Farm 3554'ol I Ill o s o o o 8 8 1 4 0 0 0 2 oF 0 4 Event Descri tion On July 14, 1988 a Quality Assurance Audit conducted to verify the implementation of Technical Specification 3.1, "Reactor Coolant System" (RCS, EIIS Code AB), identified two occasions in December of 1987 when RCS leakage determination was delayed beyond the required interval.

Technical Specification (TS) Table 4.1-2, "Minimum Frequencies for Equipment and Sampling Tests", item 11, "RCS Leakage," lists a frequency of "Daily" for the interval for performance of RCS Leakage calculations. TS 4.0.1 allows specified intervals to be "adjusted plus -or minus 25X to accommodate normal test schedules." Procedure O-OSP-200.1, "Schedule of Plant Checks and Surveillances," requires procedures 3- and 4-0SP-041.1, "RCS Leak Rate Calculations" to be performed in all modes of operation on a "daily" basis.

Procedure O-OSP-200.1 defines daily as "at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ." Therefore with the application of the 25% rule, the appropriate interval between performances was between 18 and 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, that is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> plus or minus 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

On December 5, 1987, at 0325, Unit 4 was at approximately 50X power and was being ramped up to full power at a rate of 3X rated power per hour. A leak rate of 0.23 gpm was obtained after a calculational duration of 37 minutes.

To comply with the TS surveillance interval, the next leak rate calculation should have been completed on December 6 plus or minus six hours, i.e. no earlier than 2125 on December 5 and no later than 0925 on December 6. The first of two calculations completed on December 6 was not completed until 1503, resulting in an interval of 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br />, 42 minutes . This exceeded the 30 hour3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> maximum interval.

On December 21, 1987, Unit 3 was in mode 3 (Hot Standby) when its leak rate calculation procedure, 3-0SP-041.1, was completed at 0505 hours0.00584 days <br />0.14 hours <br />8.349868e-4 weeks <br />1.921525e-4 months <br /> . The reactor was made critical at. 0130 on December 22, 1987 and a power escalation begun. A leak rate should have been completed by 0505 hours on December 22, 1987 plus or minus six hours, i .e . no earlier than 2305 on December 21, and no later than 1105 on December 22. Instead, the calculation was not completed until 1230 on December 22, 1987, resulting in an interval of 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> and 25 minutes .

Cause of Event The RCS leak rate procedures, 3- and 4-0SP&41.1, provide two methods for determination of RCS leakage . The first method is "RCS Leak Rate Calculation for Normal Parameter review" which requires the average reactor coolant system to be stabilized at 340 degrees F or greater, the reactor in modes 1 (Power Operation) through 4 (Hot Shutdown) and stabilized levels in the Volume Control Tank (EIIS system code CB and component code TK), the RCS Pressurizer (EIIS component code TK), the Pressurizer Relief Tank (EIIS comonent code TK),

the Reactor Coolant Drain Tank (EIIS Component Code TK), and the containment sump (EIIS system code NH.) In addition, the operators are to "anticipate no load adjustments during the period of the test ." The other option is for a "Containment Visual Inspection of the RCS" which requires authorization for containment access and compliance with health physics requirements for entry.

NRC FORM $ 44A I 4ISI

• U.S.GPO:1988.0-824 538/455

NRC Form 3BSA UA, NUCLEAR REGULATORY COMMISSION (983)

LICENSEE EVENT, REPORT {LER) TEXT CONTINUATION APPROVED OMB NO. 3(50W104 EXPIRES: 8/31/88 RACILITYNAME ll) DOCKET NUMBER (2) LER NUMBER (5) PAGE (3)

YEAR @@ SEQUENTIAL NUMBER

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'4d IIEVISION NUMBER Turkey Point Unit 3 o s o o o 8 8 014 00 OF 0 4 TEXT /l'AIO/O <<MCe lr /OEM)or/, INO ~ /I/IO/oo/HRC hvrr 3////A'4/ (Il)

Neither of these methods are ideal for periods during power level and load changes. The first is difficult to comply with due to the required stabilized levels, average temperature and restriction on load changes . The second is impractical due to health physics and ALARA concerns. During both of the occasions described above, power level and load changes were occurring .

The root cause of this event was cognizant personnel error by licensed utility operators, contrary to approved plant procedures . The appropriate action would have been to stabilize the plant and complete the required surveillance. The operators believed that more accurate results would be achieved by delaying performance of the procedure until a stabilized condition was reached.

Also, the operators were not fully aware that this delay would prevent compliance with the TS interval requirement.

Anal sis of Event The leak rate calculations were performed within a short period after stabilization of the RCS parameters. The leak rates determined were not indicative of a condition outside the TS limits or design basis for the plant.

The belief that a more accurate calculation would be achieved by delaying test performance is indicative of the concern the operators held for acheiving accurate information. Based on the above, the health and safety of the public was not effected.

This condition is reportable as a condition prohibited by the Technical Specifications.

Corrective Actions 1)' note was placed in the night order book stressing the need to meet the 18 to 30 hour3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> requirement identified by the Technical Specifications'for conduct of the RCS Leakrate determination. This was completed on August 3, 1988.

2) A third method for performance of RCS leak rate calculations during.

transient conditions is being developed. This would allow accurate determination during conditions similar to those described above . This method is forecast to be included into the surveillance procedure by September 30, 1988

3) The Technical Specification applicable to Reactor Coolant System Leakage is under review for possible changes. This is being accomplished with the overall conversion of the Turkey Point Technical Specifications to a format similar to the Standard Technical Specifications. Recent draft versions under discussion with the Commission provide the needed operational flexibility to assure accurate results are achieved .

NRC FORM SSSA o U.S GPO'1988.0.824 538/455

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PWC Form 34EA US. NUCLEAR REGULATORY COMMISSION (94)3)

LICENSEE EVENT REPORT {LER) TEXT CONTINUATION APPROVED OMB NO. 3150-0104 EXPIRES: B/31/BB IrACILITYNAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3)

YEAR SEQVENTIAL g~rr. REVISION NVMSER NVMSER Turkey Point Unit 3 0 5 0 0 0 2 5 0 8 8 014 pp p4 OF 0 4 TI(T EF ARES Nrsoo + /FEvSmE Imo 4+SUoes/ HBC %%drm 33(4'g J (IT) hdditional Information Similar events involving delayed or missed surveillances were described in LERs 250 86 0101 250 86 013) 250 86 020> 250 '86 027'50 86 0291 250 87 250-88-006, 251-88-05, and 250-88-009. 025'50-87-28, The Turkey Point Reactor Coolant System was supplied by Westinghouse.

NRC FORM ESSA o U.S.GPO;(985.0-824.535/455

P. O. 14000, JUNO BEACH, FL 33408.0420 AUGUST, 1 5 1988 L-88-348 10 CFR 50.73 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:

Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Reportable Event: 250-88-14 Date of Event: July 14, 1988 Reactor Coolant System Leakrate Surveillance Not Performed Within ired Interval Due to'ersonnel Error

'e 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. way Senio ice President Nuclear WFC/SDF/gp Attachment cc: Dr. Z. Nelson Grace, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant SDF3. LER an FPL Group company