ML17349A245

LER 92-003-01:on 920323,identified Improper Pressure Transmitter Calibration.Caused by Inadequate Procedures. Transmitters Locations Will Be Checked & Calibration Procedures Will Be revised.W/920601 Ltr

ML17349A245
Person / Time
Site:	Turkey Point
Issue date:	06/01/1992
From:	Hanek O, Plunkett T FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-92-163, LER-92-003-01, LER-92-3-1, NUDOCS 9206050056
Download: ML17349A245 (7)

Text

ACCELERATED DI. TRIBUTION DEMONS TION SYSTEM REGULATORY XNFORMATION DISTRIBUTION SYSTEM .(RIDS)

ACCESSION NBR:9206050056 DOC.DATE: 92/06/01 NOTARIZED: NO DOCKET FACIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 AUTH. NAME AUTHOR AFFILIATION HANEK,O.I. Florida Power & Light Co.

PLUNKETT,T.F. Florida Power & Light Co.

RECXP.NAME RECIPIENT AFFILIATION R

SUBJECT:

LER 92-003-01:on 920323 identified improper pressure transmitter calibration. Caused by inadequate procedures.

Transmitters locations will be checked & calibration D procedures will be revised.W/920601 ltr.

DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR 3 ENCL / SIZE:

TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, et NOTES:NRR RAGHAVAN,L 05000250 A D

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL D PD2-2 LA 1 ~ 1 PD2-2 PD 1 1 AULUCK,R 1 1 INTERNAL: ACNW 2 2 AEOD/DOA 1 1 AEOD/DSP/TPAB 1 1 AEOD/ROAB/DSP 2 2 NRR/DET/EMEB 7E 1 1 NRR/DLPQ/LHFB10 1 1 NRR/DLPQ/LPEB1 0 1 1 NRR/DOEA/OEAB 1 1 NRR/DREP/PRPB11 2 2 NRR/DST/SELB 8D 1 1 NRR/DST/SICB8H3 NRR/DST/SRXB 8E RES/DSIR/EIB 1

1' 1

1 1

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NRR ST SPLBBD1 RGA2 FILE 01 02 1

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1 1

1 EXTERNAL EG &G BRYCE g J ~ H 3 3 L ST LOBBY WARD 1 1 NRC PDR 1 1 NSIC MURPHY' A 1 1 NSIC POOREgW 1 1 NUDOCS FULL TXT 1 1 NOTES 1 .1 D

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D NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOb'I P 1-37 (EXT. 20079) TO ELlivIINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 31 ENCL 31

P.O. Box 029100, Miami, FL, 33102-9100

. JUN 1 1992 L-92-163 10 CFR 50.73 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:

Re: Turkey Point Unit 3 and 4 Docket Nos. 50-250 and 50-251 Reportable Event: 92-003-01 Date of Event: March 23, 1992 Operation With Improper Pressure Transmitter Calibration The attached'upplement 1 to Licensee Event Report 250/92-003-00 is being provided, pursuant to the requirements of 10 CFR 50.73 to present the results of further review of the event.

Very truly yours, d

T. F. Plunkett Vice President Turkey Point Nuclear

,TFPNOIH Attachment cc: Stewart D. Ebneter, Regional Administrator, Region III USNRC R. C. Butcher, Senior Resident Inspectorr USNRCI Turkey Point Plant 9206050056 92060k PDR ADOCK 05000250 S PDR an FVL Group company

LICENSEE EVENT REPORT (LER)

FACILITY NAME )1) DOCKET NUMBER )2) PAGE )3)

TURKEY POINT UNITS 3 AND 4 05000250 OF 4 TITLE (4) 0 eration With Im ro er Pressure Transmitter Calibration EVENT DATE (5 LER NUMBER{6 RPT DATE <2) OTHER FACILITIES INV. <8 DAY YR YR SEQ 9 MON" DAY YR DOCKET 4 (S)

FACILITY NAMES 03 23 92 92 003 01 06 01 92 Turkey Pc)nt Un1t 4 05000251 OPERATING MODE {9) 1/1 10 CFR 50.73 a 2 i PONER LFVEL <10) 82/100 LICENSEE CONTACT FOR THIS LER (12)

Olga I. Hanek, Licensing Engineer TELEPHONE NUMBER 305-246-6607 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

CAUSE SYSTEM COMPONENT MANUFACTURER NPRDS2 CAUSE SYSTEM MANUFACTURER NPRDS2 COMPONENT ExpecTeD MONTH DAY YEAR SUPPLEMENTAL REPORT EXPECTED {14) NO X YES SUBMISSION DATE (15)

(If yee, conylete EXPECTED SUBMISSION DATE)

ABSTRACT (16)

In response to NRC Information Notice 91-75, "Static Head Corrections Not Included in Pressure Transmitter Calibration Procedures", issued by the NRC on November 25, 1991, a review of the Turkey Point Units 3 and 4 calibration procedures revealed that the static head c'orrection was not considered in some pressure transmitter calibration procedures. IN 91-75 also reported that several plants did not include the static pressure span effects in the differential pressure transmitter calibration procedures. A review of the Turkey Point Units 3 and 4 calibration procedures revealed that the static pressure span effects had been included in the calibration procedures.

However, an error was found in the calibration procedures for steam generator level where the static pressure span effect was not applied properly. On March 23, 1992, FPL concluded that, after including the static head correction, and correcting the static pressure span effect error, Turkey Point Units 3 and 4 are operating in accordance with the current Technical Specifications.

However, without inclusion of static head corrections in some pressure transmitter calibration procedures and after correcting the static pressure span effect error found, operations were not in accordance with the old Technical Specifications in effect prior to August 26, 1991 an engineering analysis and determined that after inclusion of static .head

'PL performed corrections, correcting the static pressure span effect error, and assuming worst case instrument uncertainties, all the setpoints in question were within the design basis of the plant during operation prior to August 26, 1991.

LICENSEE ]ANT REPORT (LER) TEXT COZINUATION FACILITY NAME DOCKET NOHBER LER NUMBER PAGE NO.

TURKEY POINT UNITS 3 & 4 05000250 92-003-01 02 OF 04 KNG NT DESCRIPTION NRC Information Notice 91-75, "Static Head Corrections Not Included in Pressure Transmitter Calibration Procedures", issued by the NRC on November 25, 1991, reported that several plants did not include the static head corrections in their pressure transmitter calibration procedures. A review of the Turkey Point Units 3 and 4 calibration procedures revealed that the static 'head correction was not included in the calibration procedures. IN 91-75 also reported that'everal plants did not include the static pressure span effects in the differential pressure transmitter calibration procedures. A review of the Turkey Point Units 3 and 4 calibration procedures revealed that the static pressure span effects had been included in the calibration procedures. However, an error was found in the calibration procedures for steam generator level where the static pressure span effect was not applied properly. The impact resulting from not incorporating the static head correction in the pressure transmitter calibration procedures and the static pressure span effect error for Safety Related applications was evaluated for the following Technical Specification setpoints:

1. High pressurizer pressure reactor trip

2. Low pressurizer pressure reactor trip

3. Pressurizer high water level reactor trip Steam generator low-low water level reactor trip

5. Pressurizer pressure input to overtemperature delta-T reactor trip

6. Steam/feedwater flow mismatch coincident with steam generator low water level reactor trip

7. Low pressurizer pressure safety injection actuation setpoint

8. High steam line flow coincident with low steam generator pressure safety injection actuation setpoint

9. High differential pressure between steam line header and any steam line safety injection actuation setpoint The calculated static head correction factors are as follows:.

Steam header pressure 3.5 psi (minimum)

Steam generator pressure (Main steam line pressure) 4.4 psi (maximum)

Pressurizer pressure 14.5 psi (maximum)

On March 23, 1992, FPL concluded the evaluation of the above setpoints including the static head and pressure span corrections in the existing transmitter calibration procedures. For the worst'ase pressurizer pressure and steam generator pressure transmitter trip setpoints, the corrected values remain within the current Technical Specification values and therefore are in compliance with the present Technical Specifications and Safety Analysis Limits.

For Technical Specification 3/4.2.5, DNB Parameters, Item b.

pressurizer pressure, the potential existed for the minimum operational pressure value to be violated under system I perturbations. However, the automatic pressure control system would restore system pressure within the allowed action time. Therefore there is no adverse effect on safety.

For the original Technical Specifications prior to Amendments 137 and 132 (i.e., p..ior to August 26, 1991) for Units 3 and 4 respectively for the above setpoints, after inclusion of static head

LICENSEE kNT REPORT (LER) TEXT (QTINVATION

~ FACILITY NAME DOCKET NUMBER LER NUMBER PAGE NO.

TURKEY POINT UNITS 3 & 4 05000250 92-003-01 03 oF 04 corrections, static pressure span correction, and assuming worst case instrument uncertainties, the following Technical Specifications setpoints were violated:

Technical Specification 2 ', Limiting Safety System Settings, Protective Instrumentation Setpoints:

Pressurizer: Low pressurizer pressure reactor trip Steam Generator: Low-low water level Overtemperature delta-T reactor trip

2. Technical Specification 3.5, Instrumentation, Table 3.5-4, Engineered Safety Feature Setpoints:

Item 3. Pressurizer Low Pressure Safety Injection Actuation Setpoint Item 4. High Steam Line Differential Pressure Safety Injection Actuation Setpoint Item 5. High Steam Line Flow Coixcident with Low Steam Line Pressure Safety Injection Actuation Setpoint For Technical Specification 3.1.6, Reactor Coolant System, DNB Parameters, Item b. pressurizer pressure, the potential existed for the minimum operational pressure value to be violated under system perturbations. However, the automatic pressure control system would restore system pressure within the allowed action time. Therefore there is no adverse effect on safety.

FPL performed an engineering analysis and determined that after inclusion of static head corrections, correction of the static pressure span effect error, and assuming worst case instrument uncertainties, all the setpoints in question were within the design basis of the plant during operation prior to August 26, 1991.

II. EVENT CAUSE The cause of the event is attributed to inadequate procedures. The static head corrections had not been incorporated into the calibration procedures for these pressure transmitters. The static pressure span effects were erroneously applied for the steam generator low-low water level setpoint.

III'VENT SAFETY ANALYSIS On March 23, 1992, FPL concluded that, after inclusion of the static head correction, correction of the static pressure span error, and assuming worst case instrument uncertainties, Turkey Point Units 3 and 4 are operating in accordance with the'current Technical Specifications.

FPL reviewed the old Technical Specificati.'ons and the calibration procedures in effect prior to the Technical Specification revision which incorporated the new setpoint methodology. FPL determined that, after applying the static head correction factors to the setpoints, and correcting the static pressure span effect error, there is still adequate margin to the Safety Analysis Limit which existed for the setpoints discussed in Section I. Therefore, there was no operability concern or safety concern with the operation of the Turkey Point Units 3 and 4 without the pressure transmitter static head. correction factors incorporated and the static pressure span effect error in the pre'ssurize." pressure and steam generator pressure and level procedures.

LICENSEE 1+NT REPORT (LER) TEXT CTINUATION FACILITY NAME DOCKET NUMBER LER NOMBER PAGE NO TURKEY POINT UNITS 3 6 4 05000250 92-003-01 04 OF 04 CORRECTIVE ACTIONS Although inclusion of the static head correction factor and correction of the static pressure span effect for the pressure transmitters is not a violation of the current Turkey Point Units 3 and 4 Technical Specifications (Amendments 137 and 132), applicable plant pressure transmitters locations will be checked and the calibration procedures will be revised (as needed) to include the static head correction factor and correct the pressure span effect error. This work will be completed by the end of the next refueling outages currently scheduled for October 26, 1992 for Turkey Point Unit 3, and June 13, 1993 for Turkey Point Unit 4 ~

V. ADDITIONAL INFORMATION No similar events involving pressurizer pressure transmitter static head corrections have been reported for Turkey Point This event was reported in accordance with 10 CFR 50 '3 (a) (2) (i) (B) .