ML19325D129

LER 89-052-00:on 890910,discovered That Twice During Routine Evolution,Reactor Power Changed in Excess of 15% Rated Thermal Power in 1 H W/O Tech Specs Requirements for Sampling Being performed.W/891010 Ltr

ML19325D129
Person / Time
Site:	Limerick
Issue date:	10/10/1989
From:	Endriss C, Mccormick M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-89-052, LER-89-52, NUDOCS 8910190032
Download: ML19325D129 (7)

Text

i 10 CFR 50.73 l PHILADELPHIA ELECTRIC COMPANY a LIMERICK GENER ATING ST ATION P. O. BOX A t'

S AN ATOG A. PENNSYLV ANI A 19464 j i

(215) 3271200 any. 2000 M. J. M c CO R M t C M. Ja.. P.C.

t u. . . ..* l'."',lli,'.*.."... ... October 10, 1989 Docket No. 50-352~  !

,' License No. NPF-39 )

U.S. Nuclear' Regulatory Commission r Attn: Document Control Desk i Washington, DC 20555

SUBJECT:

Licensee Event Report Limerick Generating Station - Unit 1 ,

t This LER reports a condition prohibited by Technical ,

Specifications for primary' coolant and gaseous effluent sampling end radiological analyses due to a procedural deficiency.

Reference:

Docket No. 50-352  :

Report Number: 1-89-052 s Revision Number: 00 Event Date:- September 10, 1989 <

Report Date: October 10, 1989 Facility: Limerick Generating Station P.O. Box A, Sanatoga, PA 19464-n  :

This LER is being submitted pursuant to the requirements of 10

• CPR 50.73(a)(2)(1)(B).

Very truly yours, , ,

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On September 10, 1989, Unit 1 reactor power was reduced to perform routine control rod pattern adjustments and was then increased to 100%

Rated Thermal Power (RTP) using normal plant operating procedures.

Later, on September 11, plant staff discovered that twice during this routine evolution, reactor power had changed in excess of 15% RTP in one hour without the Technical Specifications (TS) requirements for sampling and radiological analysis being performed. Specifically, primary coolant was not sampled and analyzed for specific activity as required by ACTION c.1 of TS 3.4.5. Also gaseous effluent sampling and analysis was not initiated as required by Surveillance Requirements of TS Table 4.11.2.1.2-1 until 1900 on September 11, immediately following discovery of the missed samples. The consequences were minimal because analysis results for unmples taken during this reactor power change period showed little variation and were well within TS allowable limits indicating no apparent problems of fuel cladding leakage. The event was caused by the lack of detailed instructions for the method of monitoring and notifying Shift Chemistry Technicians when reactor power changes exceed 15% of RTP in

! one hour. To prevent recurrence of this event, additional instructions have been provided to Operations personnel and applicable procedures will be revised.

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' Unit Conditions Prior to the Event ,

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Unit'l'. Operating condition: 1(Power Operation)

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Description'of the Event:

During. reactor power changes to perform routine control rod pattern 1 adjustments, on September 10, 1989, primary coolant and gaseous )

effluent samples were not obtained and analyzed as required by Technical Specifications-(TS) ACTION and Surveillance Requirements, .

resulting in a' condition prohibited by TS.

'A primary coolant isotopic analysis for Iodine is required by ACTION ,

c.1 of TS Limiting Condition for Operation (LCO) 3.4.5 whenever -

reactor thermal power is~ changed by more than 15% of RATED THERMAL l, POWER (RTP) in one hour. The sample is requir9d to be taken between-two'and six hours following the power change. In addition, sampling and analysis of gaseous effluents is. required oy TS Surveillance  ;

Requirement'(SR) Table 4.11.2.1.2-1, whenever reactor thermal power is changed by.more than 15% of RTP in one hour if primary coolant,. -

condenser.offgas, or South Stack effluent radioactivity increases.by more than a factor of three. The basis for these requirements is to alert: plant 1 staff to the occurrence of any fuel cladding failures  ;

- resulting,from;the power transient.

~On< September 10, between'0015 and 0405, reactor power was reduced from 100% to 52% RTP to perform routine control rod pattern adjustments. .

Reactor power was then increased slovly and reached 300% RTP at 0830 on September 11.

At-0100 on September 10, the Main Control Room (MCR) Shift Supervisor, a licensed operator, notified the Shift Chemistry Technician of a ,

reactor power reduction that was greater than 15% RTP in one' hour.

Based.on the information given, the Shift Chemistry Technician, at 0330, obtained a primary coolant sample, initiated the analysis ,

processJand monitored the change in radioactivity for effluent gases using appropriate procedures. Sampling of gaseous effluent was not

' initiated because the. condenser offgas, South Stack and the primary coolant sample activity levels did not increase by a factor of three.

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ni o 0 13 N 0 16 reanu,, ~ . < : sc ,me e ns At'0650 on September 10, the MCR Shift Supervisc.r notified the Shift Chemistry Technician that reactor power was being increased at a rate greater than 15% RTP per hour. The Shift Chemistry Technician then waited for another notification from the MCR that reactor power had  !

increased by 15% RTP in one hour. The reactor power increase was completed at 0830 on September 11, with the reactor at 100% RTP.

During this return to full power, the procedures for primary coolant sample analysis and monitoring the change in effluent gas radioactivity were not performed.

On September 11, the Chemistry Surveillance Test Coordinator reviewed the recent data for power level changes versus time (every 10

, minutes). This review revealed that during the return to 100% reactor power, the 15% RTP change in one hour criteria occurred between 0625 l and 0745 on September 10, without the applicable sampling and analysis.

i requirements of TS LCO 3.4.5 ACTION c.1 and TS SR Table 4.11.2.1.2-1 I being performed. In addition, this review revealed that during the L power reduction period 0015 to 0405, the 15% RTP change in one hour criteria occurred between 0015 and 0215 on September 10, and not at i

! 0100 as previously indicated. Therefore the primary coolant sample l taken at 0330 on September 10,-did not satisfy the TS LCO 3.4.5 ACTION l c.1 requirements. Specifically, the 0330 sample was not taken within l the time period of two to six hours following 0215, the end of the i applicable RTP change period. Upon discovery of these missed samples, at approximately 1900 on September 11, the applicable procedures for i obtaining and analyzing gaseous effluent samples were immediately -

l initiated to satisfy requirements of TS SR Table.4.ll.2.1.2-1. A l primary coolant sample was not taken upon discovery of the noncompliance, because one had been taken earlier at 0015 on September 11, as a routine daily surveillance. The results from these sample

. analyses and continuous gaseous effluent radiation monitor readings were well within TS allowable limits, indicating no apparent problems of fuel cladding leakage.

The two identified occurrences when primary coolant samples were not taken as required by TS LCO 3.4.5 ACTION col and failure to meet the effluent gas sampling SR of TS Table 4.11.2.1.2-1 resulted in an operation or condition prohibited by TS. This is reportable in accordance with 10 CFR 50.73 (a)(2)(1)(B).

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Consequences of the EJent:

The consequences of not complying with the TS sampling and analysis-requirements were minimal because the analysis results for samples taken during this reactor power change period showed little variation and were well within TS allowable limits, indicating no apparent problem of fuel cladding leakage. A significant primary coolant Iodine concentration during this reactor power change period would have been detected by the continuous sampling offgas radiation monitors, which were in service during this event. Procedural '

guidance for high offgas radiation levels exists to ensure that reactor power would have been reduced as necessary to limit the radioactive release below TS allowable limits. r Cause of the Event:

This event was caused by a procedural deficiency which resulted in inadequate communication by Shift personnel. General Plant Procedure GP-5, " Power Operations, identifies the applicable sampling procedures to be performed when reactor power is changed by more than 15% of RTP in one hour. Both Operations and Chemistry personnel are aware of these requirements. However, details for the method of monitoring the power change and notifying Chemistry personnel are not specified.' Investigation of normal practices revealed that the type of notification (before, during, and/or after reactor power changes)

L gnd the extent of communications varied between occurrences depending l- upon the situation and individuals involved.

Durin.g the power reduction portion of this event, the Shift Chemistry Technician took the primary coolant sample at an optimum time of 0330

, (approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> following the reported applicable reactor power l change). However, the technician was not specifically informed of, and did not realize, that reactor power was continuing to decrease at a rate exceeding 15% RTP per hour until 0215 on September 10.

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During the power ascension portion of this event, a different Shift j Chemistry Technician was notified by the MCR Shift Supervisor at 0650, that reactor power was being increased and would exceed 15% RTP in one hour. The MCR Shift Supervisor meant the power change was occurring at that time and the Shift Chemistry Technician understood the message to mean the power change is going to occur soon. The Technician did not initiate the required sampling procedures because he was awaiting notification that the power change exceeding 15% RTP.in one hour had occurred and he did not receive further notification from the next MCR Shift Supervisor. The next MCR Shift Supervisor did not notify the Shift Chemistry Technician because he was informed at Shift Turnover, that a notification had already been made.

Corrective Actions:

On September 11, at approximately 1900, following discovery of the missed samples, the applicable procedures for obtaining and analyzing gaseous effluent samples were immediately initiated by the Chemistry Surveillance Test Coordinator to satisfy the SR of TS Table 4.11.2.1.2-1. A primary coolant sample was not taken at this time because one had been taken earlier at 0015 for routine daily  ;

surveillance proposes. Results from these sample analyses were evaluated and found to be well within TS allowable limits indicating no apparent problem of fuel cladding leakage.

Actions Taken to Prevent Recurrence:

Operations shift supervision will continue the normal practice of discussing the status of current and planned power change evolutions at the shift turnover meetings. This helps the Shift Chemistry Technician to remain aware of, and anticipate the need for these

• special sampling and analysis activities.

As an interim corrective action, instructions for the method of monitoring and notifying Shift Chemistry Technicians of reactor power changes exceeding 15% RTP in one hour have been provided to Operations personnel via Shift Night Ord'ers.

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0l0 0 l6 or 0 l6 net w n ana a m-n .- ~~ w ww ,.- mu v m, There are five General Plant Procedures directing activities during  ;

reactor power change evolutions.

--GP-2, NORMAL PLANT STARTUP

--GP-3, NORMAL PLANT SHUTDOWN

--GP-4, RAPID PLANT SHUTDOWN TO HOT SHUTDOWN

--GP-5, POWER OPERATIONS

--GP-18, SCRAM /ATWS EVENT REVIEW PROCEDURE These procedures will be revised by December 1, 1989, to standardize the method of monitoring reactor power changes and of notifying the

- Shift Chemistry Technician of reactor power changes exceeding 15% RTP in one hour.

In addition the applicable Chemistry procedures for sampling and analysis will be reviewed for possible addition of notification guidance and revised if deemed beneficial by December 1, 1989.

As a result of the ccmmunication deficiencies described in this LER and other recent events, a special committee has been established by I

the Plant Manager to review this and other events for root cause.

Further actions to prevent recurrence will be established as deemed necessary, based upon the results of thic rev3ew. In addition, all Section Superintendents have been directed to hold special meetings to address the recent communication problems and to set the appropriate >

standards to prevent recurrence.

Previous Similar Occurrences:

No similar events have occurred regarding these TS sampling requirements. However, LERs87-036 and 87-039 reported TS sample requirements missed due to Chemistry Technician miscommunications. In addition, LERs85-003, 86-025,89-018, and 1-89-051 resulted from improper communication between Operations personnel and between Operations personnel, and technicians / test personnel. These LERs will be included in the special committee review of communication deficiencies for root cause and generic implications.

Cause Code: D2 - Inadequate Procedure; did not cover situation A7 - Failure to properly communicate FFu 384.