ML20149J341

Special Rept SR-88-001-00:on 880128,during Plant Startup Operations,Personnel Declared Fuel Handling Exhaust Wide Range Gas Monitor out-of-svc for Calibr.Caused by Extensive Teardown.Procedure Revised

ML20149J341
Person / Time
Site:	Waterford
Issue date:	02/18/1988
From:	Carns N LOUISIANA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
SR-88-001-00, SR-88-1, W3A88-0018, W3A88-18, NUDOCS 8802220370
Download: ML20149J341 (5)

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Ref: 10CFR50.36(c)(2) l l

LOUISIANA /

POWER & LIGHT WATERFORD 3 SES + P. O. BOX B + KILLONA, LA 70066 E N hrSSIU February 18, 1988 W3A88-0018 A4.05 QA U.S. Nuc1 car Regulatory Commission ATTENTION: Document Control Desk Washington, D.C. 20S55

SUBJECT:

Waterford 3 SES Docket No. 50-382 License No. NPF-38 Reporting of Special Report Attached is Special Report Number SR-88-001-00 for Waterford Steam Electric Station Unit 3. This Special Report is submitted per 10CFR50.36(c)(2) and Technical Specifications 3.3.3.1 and 6.9.2.

Very truly yours, T,A W' N.S. Carns Plant Manager - Nuclear NSC/WEM:rk Attachment cc R.D. Martin, NRC Resident Inspectors Office, INPO Records Center (J.'t. Whcolock) E.L. Blake, W.H. Stevenson, D.L. Wigginton i

8802220370 880218 2 / )g ADOCK 050 gDR 1

I l "AN EQUAL OPPORTUNITY EMPLOYER" i

• . *s SPECIAL REPORT SR-88-001-00 Fuel Handling Building Exhaust Wide Range Gas Monitor Out of Service for Calibration Greater then Seven Days INTRODUCTION At 0908 hours0.0105 days <br />0.252 hours <br />0.0015 weeks <br />3.45494e-4 months <br /> on January 28, 1988, Waterford Steam Electric Station Unit 3 was operating at 1% power during plant startup when Operations personnel declared the Fuel Handling Building Exhaust Wide Range Gas Monitor (WRGM) out-of-service for calibration. In accordance with Technical Specification (TS) 3.3.3.1 Action 27, Health Physics personnel established the preplanned alternate method for monitoring Fuel Handling Building exhaust as defined in procedure EP-2-050, "Off-Site Dose Assessment (Manual)."

Since the monitor could not be returned to service within seven days, this report is submitted pursuant to TS 3.3.3.1 and 6.9.2.

NARRATIVE At 0908 hcurs on January 28, 1988, Waterford Steam Electric Station Unit 3 was operating at 1% power during plant startup when Operations personnel declared the Fuel Handling Building (FHB) Exhaust Wide Range Gas Monitor (WRGM),

PRM-IR-3032, out-of-service for calibration per procedure MI-3-371, "Fuel Handling Building Ventilation ?ystem Emergency Exhaust High Range Noble Gas Radiation Monitor Channel Calibration PRM-IR-3 )32." The monitor is declared out-of-service for this calibration due to the extensive teardown, bench testing, and replacement which is required for cartain components. In accordance with Technical Specification (TS) 3.3.3.1 Action 27. Health Physics personnel established the preplanned alternate method for monitoring Fuel Handling Building exhaust as defined in precedure EP-2-050, "Off-Site Dose Assessment (Manual)."

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The calibration performed per MI-3-371, done at 18 month intervals, meets the TS surveillance requirement of TS 4.3.3.1. The WRGM is only required to be operable in modes one through four if irradiated (spent) fuel is stored in the Spent Fuel Pool (SFP). Spent fuel has been stored in the SFP only since the first Refueling Outage which began in December 1986. Thus, the calibration has been performed only once before on this WRGM. This calibration was not due, but Maintenance supervision decided to complete the surveillances on all safety-related Radiation Monitors (RMs) in the FHB prior to the upcoming refueling outage when access to these monitors would be restricted.

The calibration, which normally takes approximately five working days to complete, was initiated under Work Authorization (WA) 01008462 and commenced on January 28, 1988. By the next day, it was realized that the calibration procedure needed to be changed to reflect new Measuring and Test Equipment (M&TE) now used in place of the old M&TE referenced by the procedure. Normally, these procedures receive an informal review prior to performance of the '

surveillance so completion of the surveillance will not be delayed while procedures are revised. In this case, however, the surveillance was scheduled several months in advance of its due date, so this review was missed.

Procedure MI-3-371 was revised to incorporate the new M&TE, causing a delay of approximately one dny.

Once the procedure was commenced, it was discovered that the mid-range alarm setpoint calibration could not be completed due to the magnitude and variability of the actual process flow being measured. The switchover point from the mid to high range detector uses FHB ventilation exhaust (process) flow as an input to determine when to shift from mid to high range radiation monitoring. The alarm setpoint calibration could not be completed due to high process flow which caused the switchover point to shift from mid to high range prior to completing the calibration. Actual process flow is also too variable to permit the alarm setpoint calibration which requires a 1% tolerance. It was therefore necessary to change data points in the WRGM computer to substitute simulated values for process flow in order to calibrate the alarm setpoints.

Additional delay was incurred due to inclement icy weather, unusual for this area, which made removal of the instrument probes difficult. These probes, located on the outside of the FHB and accessible only by ladder, measure the FH6 ventilation exhaust flow and were removed for calibration in the Instrument and Controls Hot (I&C) Shop.

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A requirement to replace the sample pump on the WRGM once every 18 months was recently added. This was done in response to a trending evaluation which discovered that these sample pumps, manufactured by the Thomas Company (Part Number 50011347-00), have a high failure rate after 18 to 24 ronths' use. The sample pump had not been replaced in this WRGM before, so additional delay was incurred in completing the surveillance while Maintenance technicians replaced the pump.

These delays were not considered important since Maintenance personnel involved with this calibration did not comprehend the requirement of TS table 3.3-6 Action 27 to require completion of preventive maintenance actions within seven days. This action states in part, "If the monitor is not restored to OPERAP>LE status within 7 days after the failure, prepare and submit a Special Report..."

In this case, the WRGM had not failed but had simply been placed out of service for calibration. The term "failure" implies an equipment malfunction which was not the case in this event. Thus, Maintenance personnel thought that the out-of-service WRGM was not constrained by the seven day limit. The calibration procedure is long and time consuming, so minor problems encountered during the performance of this procedure can easily result in exceeding the current seven-day time limit as shown in this event. Since it is not clear that events of this nature were intended to be reported pursuant to TS 6.9.2, the need for a clarification or change to Action Statement 27 of TS Table 3.3-6 will be evaluated. If it is deemed appropriate, an amendment to the Technical Specifications will be requested.

The FHB w'RGM was returned to service and deciated operable at 2152 hours0.0249 days <br />0.598 hours <br />0.00356 weeks <br />8.18836e-4 months <br /> on February 6, 1988. Since the ronitor was not returned to service within the seven dey limit as defined in TS 3.3.3.1, this Special Report is submitted pursuant to Specification 6.9.2. Health Physics personnel have an alternate method of monitoring FHB ventilation exhaust, and no cladding or fuel defects exist in the spent fuel assemblies which could resuir in a measurable radioactive release nor were any fuel movements or movements of loads over the SFP conducted during this period; thus, the out-of-service FHB WRGM never posed a safety concern.

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PLANT CONTACT l

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D.W. Vinci, Maintenance Superintendent, 504/464-3138 l

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