05000245/LER-1997-025-01, :on 970424,single Loop Jet Pump Baseline Data Collection Surveillance Missed.Caused by Failure to Properly Review full-term Ol.Sys for Tracking Licensing Commitments Established

:on 970424,single Loop Jet Pump Baseline Data Collection Surveillance Missed.Caused by Failure to Properly Review full-term Ol.Sys for Tracking Licensing Commitments Established

ML20148C802
Person / Time
Site:	Millstone
Issue date:	05/27/1997
From:	Robert Walpole NORTHEAST NUCLEAR ENERGY CO.
To:
Shared Package
ML20148C795	List: 05000245/LER-1997-025, Forwards LER 97-025-00,documenting Event Occurred at Unit 1 on 970424.Commitments Made within Ltr Listed 05000245/LER-1997-025-01, :on 970424,single Loop Jet Pump Baseline Data Collection Surveillance Missed.Caused by Failure to Properly Review full-term Ol.Sys for Tracking Licensing Commitments Established
References
LER-97-025-01, LER-97-25-1, NUDOCS 9705290101
Download: ML20148C802 (4)

LER-1997-025, on 970424,single Loop Jet Pump Baseline Data Collection Surveillance Missed.Caused by Failure to Properly Review full-term Ol.Sys for Tracking Licensing Commitments Established

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(ii) 10 CFR 50.73(a)(2)(iv), System Actuation 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
2451997025R01 - NRC Website

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NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104 (4 95)

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FACluTY NAME (1)

DOCKET NUMBER (2)

PAGE (3)

Millstone Nuclear Power Station Unit 1 05000245 1 of 4 TITLE 64)

Single Loop Jet Pump Baseline Data Collection Missed Surveillance EVFGT DATE (5)

LER NUMBER (6)

REPORT DATE (7)

OTHER FACILITIES INVOLVED (8) i

' MONTH DAY YEAR YEAR SEQUENTIAL REVISION MONTH DAY YEAR FACIUTY NAME DOCKET NUMBER NUMBER

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04 24 97 97 025 00 05 27 97 l

OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR 5: (Check one or more) I',1)

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MODE (9)

N 20.2201(b) 20.2203(aH2Hv)

X so 73(aH2Hi) 50a3(aH2Hviii)

POWER 20.2203(a)(1) 20.2203(a)(3)(i) 50.73(a)(2)(ii)

'o0.73(aH2)(x)

LEVEL (10) 000 20.2203(aH2Hi) 20.2203(aH3Hii) 50.73(aH2)(iii) 73.71 20.2203(a)(2)(ii) 20.2203(a)(4) 50.73(a)(2)(iv)

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f 20.2203(a)(2Hiii) 50.36(c)(1) 50.73(a)(2)(v) specify in Abstract below or m NRC Form 366A 20.2203(aH2)(iv) 50.36(c)(2) 50.73(aH2)(vir, LICENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUVdER (include Area Codel Robert W. Walpole, MP1 Nuclear Licensing Manager (860)440-2191

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COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBFD IN THIS REPORT (13)

CAUSE

SYSTD 4 COMPONENT MANUFACTURER REPORTABLE

CAUSE

YSTEM COMPONENT MANUFACTURER REPORTABLE TO NPRDS To NPRDS I

SUPPLEMENTAL REPORT EXPECTED (14)

EXPECTED MON 1H DAY YEAR NO SUBMISSION g

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ABSTRACT (Limit to 1400 spaces i.e.. approximately 15 single-spaced tyrewritten lines) (16)

On April 24,1997, at 1625 hours0.0188 days <br />0.451 hours <br />0.00269 weeks <br />6.183125e-4 months <br />, with the plant shutr'own and the reactor in the COLD SHUTDOWN condition, it was discovered that the requirements outlined in Technical Specification Surveillance Requiremont 4.6.G 3 were not being met. Technical Specification 4.6.G.3 requires acquiring the baseline data necessary to evaluate the conditions in Specification 4.6.G.1 and 4.6.G 2. When operr. ting with one recirculation pump with the equalizer valves closed, Specification 4.6.G.2 requires checking jet pump differential pressures (dPs) are maintained within 10% of established patterns. The baseline data, required to evaluate the jet pump dPs during operation with one recirculation pump, has not been acquired each operatine; cycle as required by Specification 4.6.G.3. This event is reportable pursuant to 10CFR50.73(a)(2)(i)(B), as a condition prohibited by the plant's Technical Specification.

There were no safety consequences as ta result of this event, in order to provide long term corrective action, specific to this issue, NNECO will submit to the NRC for approval, a revision to Technical Specification 3.6.G and Technical Spscification Surveillance Requireme it 4.6.G prior to startup for operating cycle 16. To ensure compliance with the Technical Specifications, a review of the Technical Specifications requirements will be performed to ensure procedures exist to adequately implement all requirements, prior to startup for operating cycle 16. A system tc track licensing commitments to complation has already been established.

NRC FORM 366 (4-95) 9705290101 970527 PDR ADOCK 05000249 S

PDR u

NRC FORM 066A U.S. MUCLEAR REGULATORY COMMISSION (4 95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DoCAET NUMBER (2)

LER NUMBER (6)

PAGE (3)

YEAR SEQUENTIAL REvislON Millstone Nuclear Power Station Unit 1 05000245 NUMBER NUMBER 2 of 4 97 025 00 TEXT (11more space is required, use additionalcopies of NRC form 36GA) (17) 1.

Descrintion of Ever.'

Ca April 24,1997, at 1625 hours0.0188 days <br />0.451 hours <br />0.00269 weeks <br />6.183125e-4 months <br />, with the plant shutdown and the reactor in the COLD SHUTDOWN condition, it was discovered that the requirements outlined in Technical Specification Surveillance Requirement 4.6.G.3 were not being met. Technical Specification 4.6.G.3 requires acquiring the baseline data necessary to evaluate the cond;tions in Specification 4.6.G.1 and 4.6.G.2, When operating with one recirculation pump with the equaMzer valves closed, Specification 4.6.G.2 requires checking jet pump dPs are maintained within 10% of established patterns. The baseline data, required to evaluate the jet pump dPs during operation with one recirculation pump, has not been acquired as required by Specification 4.6.G.3.

This event is reportable pursuant to 10CFR50.73(a)(2)(i)(B), as a condition prohibited by the plant's Technical Specification.

Operation with one recircuhtion pump is allowed for only 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by Specification 3.6.H.2. Since Specification 4.6.G.2 requires checking jet pump dPs daily, this check is never performed. Consequently, there is no reason to acquire the baseline data reauired to evaluate conditions present during operation with one recirculation pump.

There were no safety consequences as a result of this event.

II.

Cause of Event

The cause of this specific non-compliance is failure to properly review the Full-Term Operating License. This allowed the requirement to acquire single-loop baseline data to end up back in the Technical Specifications, after being taken out.

Ill. Malvsis of Event A review of the history of the jet pump operability surveillance requirements provides insight into'the situation regarding the need for obtaining single loop operating data.

The original Provisional Operating License and Technical Specifications provided by the NRC on October 7, 1970, contained three jet pump operability monitoring requirements, which were to be checked daily. These DI;$Y-included the requirement to ensure individual jet pump dPs varied from the mean of all jet pump dPs by less than

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10%.

At Millstone's request, tna NRC issued Change No.11 on March 2,1973. This change revised the jet pump operability surveillance requirements to the current version.

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Based upon an evaluation of ECCS performance submitted for Millstone Unit 1, the NRC issued Amendment No.

16 to the Provisional Operating License on October 17,1975. Since no evaluation was provided for ECCS performance with one recirc.ulation loop out-of-service, a revision to the Technical Specifications was required.

Specification 3.6.H.2 was added to allow the reactor to operate for only 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with one recirculation loop out-of-service.

Amendment No. 73 to the Provisional Operating License was issued on March 11, 1981. This amendment deleted the requirement to collect the jet pump baseline data required to evaluate the conditions in Specification 4.6.G.2. The NRC Safety Evaluation for this amendment concurred, "since single-loop operation is not licensed nor permitted at Millstone 1."_

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I s' NRC PORM 366A U.S. NUCLEAR REGULATORY COMMISslON (4-95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION I

FACILITY NAME (1)

DOCKET NUMBER (2)

LER NUMBER (6)

PAGE (3)

(

YEAR SEQUENTIAL REVISION Millstone Nuclear Power Station Unit 1 05000245 NUMBER NUMBER 3 of 4 97 025 00 TEXT (11 more space is,equired, use additionalcopies of NRC Form 366Al (17)

During the conversion from the Provisional Operating License to the Full Term Operating License, the NRC provided a package to NNECO which included their version of the Technical Specifications, as then written, through Amendment No.110. The format had been changed to improve ease of use NNECO was given 45 days to review the package and certify that the enclosed Technical Specifications had been accurately l

transcribed. In the proposed "new" Technical Specifications, the requirement to collect single-loop jet pump baseline data re-appeared in Specification 4.6.G,3.

Comments to the NRC on the draft documents, as documented in the July 31,1986 letter from NNECO to NRR, did not note this appamnt discrepancy. The NRC issued the Full-Term Operating License on October 31, 1986, including the requirement it. Technical Specification 4.6.G.3 to obtain single-loop jet pump baseline data each operatir,g cycle.

l There is no procedure identified which implements the requiremer4s of Specification 4.6.G.3, to obtain single-loop jet pump baseline data. The baseline data is used to support the surveillance requirements of Specification 4.6.G.2, which requires monitoring jet pump dPs daily during single-loop operation. Since Specification 3.6.H.2 allows single-loop operation for only 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, there is no need to monitor the jet pump dPs during single-loop operation, and hence no reason to collect baseline data. As such, there were no safety consequences of this event.

IV. Corrective Action

1 To ensure licensing commitments are adequately tracked, a system to track licensing commitments has been established. The system will provide a means of tracking to completion, those items necessary to implement the commitrnent.

1. In order to provide long term corrective action, specific to this issue, NNECO will submit to the NRC for approval, a revision to Technical Specification 3.6.G and Technical Specification Surveillance Requirement 4.6.G prior to startup for operating cycle 16. The new specifications and requirements, relating to jet pump integrity and operability, will be similar to those established by the industry in the Standard Technical Specifications, NUREG-1433.

2. To ensure compliance with the Technical Specifications, a review of the Technical Specifications requirements will be performed to ensure procedures exist to adequately implement all requirements prior to startup for operating cycle 16.

V.

Additional Information

None.

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Similar Events

LER 96-005-00, LER 96-015-00, LER 96-018-00, and LER 96-019 included events for Technical Specification j

l requirements not performed as written.

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' NRC PORM 366A U.S. NUCLEAR REGULATORY COMMISSION (4 95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION i

FACILITY NAME (1)

DOCKET NUMBER (2)

LER NUMBER (6)

PAGE (3) i YEAR SEQUENTIAL REVISION Millstone Nuclear Power Station Unit 1 05000245 NUMBER NUMBER 4 Of 4 l

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97 025 00 TEXT (11more space is required, use additional copies of NRC Form 366A) (17) i Manufacturer Data None.

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