ML20006F005

LER 90-006-00:on 900118,chemistry Dept Determined 6-month Interval Tech Spec for Average Disintegration Energy Determination Not Met.Caused by Inappropriate Appliance of Surveillance Interval.Addl Controls placed.W/900216 Ltr

ML20006F005
Person / Time
Site:	Millstone
Issue date:	02/16/1990
From:	Langan J, Scace S NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-90-006, LER-90-6, MP-90-173, NUDOCS 9002270069
Download: ML20006F005 (4)

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• d%'a:IS5tUs5ev N c7ompany HARTFORD. CONNECT 10UT 06414-0270 Nortrieast Nucioar Enerov company (203)665-5000 February 16, 1990 MP-90-173 Re: 10CFR50.73(a)(2)(i)

.U.S. Nuclear Regulatory Commission Document Control Desk

-Washington, D.C. 20555

Reference:

Facility Operating License No. NPF-49 Docket No. 50-423 Licensee Event Report 90-006-00 Gentlemen:

This letter forwards Licensee Event Report 90-006-00 required to be submitted within thirty (30) days pursuant to 10CFR50.73(a)(2)(i), any operation or condition prohibited by the Plant's Technical Specifications.

Very truly yours, NORTHEAST NUCLEAR ENERGY COhiPANY FOR: Stephen E. Scace Director, Millstone Station P.

BY: ~

. H vnes Millstone n'it Services irector SES/JAL:ljs

Attachment:

LER 90-006-00 cc: W. T. Russell, Recion 1 Administrator W. J. Raymond, S'enior Resident ins 3ector, Millstone Unit Nos.1, 2 and 3 D. H. Jaffe, NRC Project Manager, Millstone Unit No. 3 [j[

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At 2t00 hours on January 18, 1990, in Mode 3, Hot Standby, 555 degrees and 2250 psia, the Chemistry depa tment determined the six-month interval Technical Specification for average disintegration energy (E-Bar) determination had not been met. Ten months had elapsed between the E-Bar value obtained on October 19, 1988, and the next update on August 14, 1989, The sample which led to the August 14, 1989, value of E-Bar was drawn on May 5,1989. No samples had been drawn since then. Root cause of the event was personnel error. The required surveillance mterval was inappropnately applied.

The plant is required to be in Mode 1, Power Operation, in order to draw the sample for E-Bar determination. Since Technical Specification 4.0.4, which allows mode changes without the surveillance being met, is not invoked for this specification, the plant could not startup from its Mode 3 condition. A request for enforcement discretion was sought and granted on January 18, 1990. The plant entered Mode 1 on January 20, 1990. On January 22, 1990, an E-Bar sample was drawn and a new E-Bar value obtained on January 26,1990. To prevent recurrence, additional administrative controls have been placed on the sampling program to ensure an updated value of E-Bar is provided every six months.

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1. Deerintion of Event At 2100 hours0.0243 days <br />0.583 hours <br />0.00347 weeks <br />7.9905e-4 months <br /> on January 18, 1990, with the plant in Mode 3. Hot Standby. 555 degrees Fahrenheit and 2250 psia, the Chemistry department determined the Technical Specification Surveillance for determination of aserage dismtegration energy (E-Bar) had not been met.

Technical Specification Surveillance 4.4.8 requires a radiochemical analysis for E-Bar every six months in Mode 1, Power Operation. E-Bar determmations had been performed satisfactorily through 1966. On October 19, 1966, a new value of E-Bar was accepted by the Operations depanment. The next E-Bar sample was drawn on May 5,1969. Normal processing time through the offsite laboratory used to determine E-Bar is two to three months. Therefore, a new value of E-Bar was not accepted by the Operations department until August 14, 1989. This is in violation of the Technical Specification Surveillance which requires E-Bar to be updated every six months.

No samples had been drawn smce May 5,1989.

This defidency was identified darmg a surveillance review performed while the plant was in Mode 3. preparms to perform a reactor startup. Technical Specification 4.0.4, allowing mode changes without the surveillance requirement bemp met, is not invoked for this specihcation. A request for enforcement discretion was sought and granted on January 18, 1990. This allowed the plant to stanup on January 19, 1990, and enter Mode 1 on January 20, 1990. A sample to determine and update E-Bar was drawn on January 22,1990, No immediate operator action was required in response to this event.

II. Cue nf Frent The root cause of the event was personnel error. The six-month requirement for updating E-Bar was properly noted on the surveillance form. However, the six-month requirement was applied inappropriately. On October 19, 1988, the six-month intenal was restarted upon Operations

' department acceptance of a new value of E-Bar. On May 5,1989, approximately six months later, an E-Bar sample was drawn. Because of the long lead time in getung the resuhs b'ick from the laboratory, ten months elapsed between acceptance of a new value on October 19,1968, and August 14, 1989. Therefore, the surveillance requirement of updating E-Bar every six months was not met.

I!!. Analysis of Event This event is reportable pursuant to 10CFR50.73(a)(2)(i), as a violation of Technical Specifications. Technical Specifications define E-Bar as the average, weighted m proportion to the concentration of each radionuclide in the sample, of the sum of the average beta and gamma energies per disintegration for those radionuclides in the Reactor Coolant System (RCS) with a half I

life greater than ten minutes (excludmg radiciodines). After E-Bar is determined, a value of 100/E-Bar is calculated. Every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. RCS gross activity is measured and verihed to be less than 100/E-Bar. Adherence to this limit will ensure the two hour dose at the site boundary will )

not exceed an appropriately small fraction of 10CFR Part 100 dose guideline values following a steam generator tube rupture in conjunction with an assumed steady-state reactor-to-secondary steam generator leakage rate of 1 gallon per mmute.

The failure to update E-Bar within the required six months had no significant impact on plant safety. Although the value of E-Bar placed in effect on August 14. 1989, was higher than the previous value fresulting in a lower value of 100/E-Bar, and therefore, a lower hmit on RCS pross ,

activity), pross RCS activity was runnmg several orders of magnitude below even the new, more .

conservative value of 100/E-Bar. Had a steam generator tube rupture occurred during the four j months that E-Bar was outside its surveillance wmdow, doses at the site boundary would still have

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been a small fraction of 10CFR Part 100 hmits.

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0l6l0l0l0l4l2l3 9l0 0l 0l 6 0l0 0l 3 OF 0l3 Ttx7 of mor space . reasireo, use ecoition i Nac 6erm 36o4, si (in Operation during cycle 3 without having obtained an E-Bar sample is conservative with respect to current core conditions. The last sample for E-Bar was taken at end of core life, with a high burnup on the fuel, and with several leaking fuel rods in the core. Due to the removal of some of these leakmg fuel rods, and insertion of approximately one third of a core of fresh fuel, RCS activity, since the start of cycle 3 in July 1989, has been running significantly lower than during the later stages of cycle 2. Gross RCS actiuty was determined on January 3,1990, to be 5.73E-0.1 microcunes/ gram. This compares to a gross actnity of 6.50E-0.1 microcuries/ gram on Ma) 5,1989 (the day the last E-Bar sample was drawn). The bippest difference in RCS pross acuvity and the activity used to determine E-Bar is the inclusion of St-89, St-90, and Fe-55 activines in determining E-Bar. These isotopes account for only a small fraction of the specific activity to be found in the RCS. The 100/E-Bar calculated from the May 5.1469, sample was 68.7 microcuries/ gram. Because of the lower current RCS gross activity, and the close relationship between RCS gross acth1ty and 100/E-Bar, it is safe to assume that the current 100/E-Bar hmit is higher than 66.7 microcuries/ gram. Operating to the current hmit is, therefore, conservative.

IV, Cntrective Action To expedite the analysis process for the E-Bar sample drawn on January 22,1990, the sample was sent to a Northeast Utilities laboratory at the Connecticut Yankee Nuclear Power Station for processing. A new E-Bar value was obtamed on January 26,1990. To prevent this from recurrmg, additional administrative controls hate been placed on the sampling program to ensure an updated value of E-Bar is provided within the six month surveillance requirement. j V. Additionnl Informntion The administrative deficiency that led to this event stemmed from a misapplication of the surveillance interval. No other events have occurred due to this root cause.

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