ML17347B373: Difference between revisions
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Since nitrogen pressure on the seal pot could not be monitored , the 3A BATP'as declared out of service.This resulted in loss of a flow path from the A BAT to the Unit 3 Reactor Coolant System.The 3B BATP was aligned to take suction from the A BAT and discharge to the Unit 3 charging pumps.Unit 3 exited Technical Speci-fication 3.0.1 at 1404 on September 10, 1989-Further review revealed that the BATPs are technically"inoperable" when the nitrogen pressure indiaators are removed to refill the seal pot.Operations personnel were not aware that the BATPs are considered inoperable when the seal pot nitrogen pressure indicator is removed;therefore, the BATPs were not dealared out of service prior to refilling the seal pot.An entry has been made in the Operations Night Order Book to aonvey this opera-bility concern to Control Room operators. | Since nitrogen pressure on the seal pot could not be monitored , the 3A BATP'as declared out of service.This resulted in loss of a flow path from the A BAT to the Unit 3 Reactor Coolant System.The 3B BATP was aligned to take suction from the A BAT and discharge to the Unit 3 charging pumps.Unit 3 exited Technical Speci-fication 3.0.1 at 1404 on September 10, 1989-Further review revealed that the BATPs are technically"inoperable" when the nitrogen pressure indiaators are removed to refill the seal pot.Operations personnel were not aware that the BATPs are considered inoperable when the seal pot nitrogen pressure indicator is removed;therefore, the BATPs were not dealared out of service prior to refilling the seal pot.An entry has been made in the Operations Night Order Book to aonvey this opera-bility concern to Control Room operators. | ||
NRC Ferm 345 r9 83i NRC Form 388A (9831 LICENSEE EVENT REPORT ILER)TEXT CONTINUATION U S, NUCLEAR REGULATORY COMMISSION APPROVED OVS NO 3150&104 EXPIRES: 8/31/88 FACILITY NAME (11 Turkey Point Unit 3 TE3ET 0'er/I/eefreee/4 eerreerE uw aaRP/one//Y/IC Ann PRLE 2/(121 DOCKET NUMBER (2)YEAR 2 5 0.8 9 LER NUMBER (8)SEGVSNTIAL NUMseR 0 1 3 rrevrsloN NUMeea 00 02 PAGE (31 oF 0 Deseri tion of the Event On September 10, 1989, at 1345, Unit 3 entered Technical Specification 3.0.1 for 19 minutes when the 3A Boric Acid Transfer Pump (BATP)(EIIS:CA, Component:P) was declared out of service.Unit 3 was operating in Mode 1 at approximately 60 percent power.At the time of this event, the 4A and 4B BATPs were aligned to take suction from the C Boric Acid Tank (BAT)and discharge to the Unit 4 charging pumps, the 3A BATP was aligned to take suction from the A BAT and dis-charge to the Unit 3 charging pumps.The 3B BATP was aligned to recirculate the B BAT.At 1345, the 3A BATP was declared out of service when maintenance personnel accidently damaged the nitrogen pressure indicator while refilling the 3A BATP seal pot.In order to refill the seal pot, the seal pot is depressurized, the nitrogen pressure indicator is removed, water is added via the nitrogen pressure indicator connection, the nitrogen pressure indicator is reinstalled, and the seal pot is repressurized with nitrogen.Since pressure on the 3A BATP seal pot could not be monitored after reinstallation of the nitrogen pressure indicator and the 3A BATP was the only BATP aligned from the A BAT to the Unit 3 charging pumps, no flow path existed from a BAT to the Unit 3 Reactor Coolant System as required by Technical Specifications. | NRC Ferm 345 r9 83i NRC Form 388A (9831 LICENSEE EVENT REPORT ILER)TEXT CONTINUATION U S, NUCLEAR REGULATORY COMMISSION APPROVED OVS NO 3150&104 EXPIRES: 8/31/88 FACILITY NAME (11 Turkey Point Unit 3 TE3ET 0'er/I/eefreee/4 eerreerE uw aaRP/one//Y/IC Ann PRLE 2/(121 DOCKET NUMBER (2)YEAR 2 5 0.8 9 LER NUMBER (8)SEGVSNTIAL NUMseR 0 1 3 rrevrsloN NUMeea 00 02 PAGE (31 oF 0 Deseri tion of the Event On September 10, 1989, at 1345, Unit 3 entered Technical Specification 3.0.1 for 19 minutes when the 3A Boric Acid Transfer Pump (BATP)(EIIS:CA, Component:P) was declared out of service.Unit 3 was operating in Mode 1 at approximately 60 percent power.At the time of this event, the 4A and 4B BATPs were aligned to take suction from the C Boric Acid Tank (BAT)and discharge to the Unit 4 charging pumps, the 3A BATP was aligned to take suction from the A BAT and dis-charge to the Unit 3 charging pumps.The 3B BATP was aligned to recirculate the B BAT.At 1345, the 3A BATP was declared out of service when maintenance personnel accidently damaged the nitrogen pressure indicator while refilling the 3A BATP seal pot.In order to refill the seal pot, the seal pot is depressurized, the nitrogen pressure indicator is removed, water is added via the nitrogen pressure indicator connection, the nitrogen pressure indicator is reinstalled, and the seal pot is repressurized with nitrogen.Since pressure on the 3A BATP seal pot could not be monitored after reinstallation of the nitrogen pressure indicator and the 3A BATP was the only BATP aligned from the A BAT to the Unit 3 charging pumps, no flow path existed from a BAT to the Unit 3 Reactor Coolant System as required by Technical Specifications. | ||
Technical Specification 3.6.d requires that during power operation,"System piping, interlocks and valves shall be operable to the extent of establishing one flow path from the boric acid tanks, and one flow path from the refueling water storage tank, to each Reactor Coolant System." Unit 3 entered Technical Specification | Technical Specification 3.6.d requires that during power operation,"System piping, interlocks and valves shall be operable to the extent of establishing one flow path from the boric acid tanks, and one flow path from the refueling water storage tank, to each Reactor Coolant System." Unit 3 entered Technical Specification 3.0.1 which states, in part,"When a Limiting Condition for Oper-ation is not met, except as provided in the associated ACTION requi,rements, within 1 hour action shall be initiated to place the unit in a MODE in which the specification does not apply...". | ||
states, in part,"When a Limiting Condition for Oper-ation is not met, except as provided in the associated ACTION requi,rements, within 1 hour action shall be initiated to place the unit in a MODE in which the specification does not apply...". | |||
Upon entering Technical Specification 3.0.1, the 3B BATP was realigned to take suction from the A BAT and discharge to the Unit 3 charging pumps.At 1404, Unit 3 exited Technical Specification 3.0.1.Further review of this event raised the question of seal water system pressure impact on the"operability" of the BATPs.A nitrogen pressure between 35 psig and 40 psig is maintained in the seal pot, in part, to ensure seating of the inner seal faces and minimize inner seal leakage.FPL has determined that as long as the BATP seal water system is"closed", loss of the seal pot nitrogen pressure would not render the BATP"inoperable | Upon entering Technical Specification 3.0.1, the 3B BATP was realigned to take suction from the A BAT and discharge to the Unit 3 charging pumps.At 1404, Unit 3 exited Technical Specification 3.0.1.Further review of this event raised the question of seal water system pressure impact on the"operability" of the BATPs.A nitrogen pressure between 35 psig and 40 psig is maintained in the seal pot, in part, to ensure seating of the inner seal faces and minimize inner seal leakage.FPL has determined that as long as the BATP seal water system is"closed", loss of the seal pot nitrogen pressure would not render the BATP"inoperable | ||
." Any leakage through the BATP inner seal faces into the seal water system would tend to pressurize the seal pot and limit the amount of leakage to a value which would not significantly affect the BATP minimum required flow rate.However, whenever the seal pot nitrogen indicator is removed, the seal water system is an"open" system.BATP inner seal leakage during pump operation with the seal water system"open" would not be enough to affect the minimum required flow rate of the BATP, however, the inner seal leak would result in lost inventory from the BAT.For this reason, FPL considers a BATP to be"inoperable" while refilling the seal pot.NRC FORM 388A oU.S GPO'1988 O.S24 538/455 NRC Form 388A (94)3)LICENSEE EYENT REPORT ILER)TEXT CONTINUATION U.S.NUCLEAR REGULATORY COMMISSION APOAOVEO OVIS NO.3150-0)04 EXPIRES: 8/31/88 FACILITY NAME 1'll Turkey Point Unit 3 OOCKET NUMBER (2)YEAR LER NUMBER IS)AM SEGUENTIAL NUMSEA REVISION NUM888 PAGE 13I TIET IPRN88 NM88 N/88888/E 888 eRENono/AIRC | ." Any leakage through the BATP inner seal faces into the seal water system would tend to pressurize the seal pot and limit the amount of leakage to a value which would not significantly affect the BATP minimum required flow rate.However, whenever the seal pot nitrogen indicator is removed, the seal water system is an"open" system.BATP inner seal leakage during pump operation with the seal water system"open" would not be enough to affect the minimum required flow rate of the BATP, however, the inner seal leak would result in lost inventory from the BAT.For this reason, FPL considers a BATP to be"inoperable" while refilling the seal pot.NRC FORM 388A oU.S GPO'1988 O.S24 538/455 NRC Form 388A (94)3)LICENSEE EYENT REPORT ILER)TEXT CONTINUATION U.S.NUCLEAR REGULATORY COMMISSION APOAOVEO OVIS NO.3150-0)04 EXPIRES: 8/31/88 FACILITY NAME 1'll Turkey Point Unit 3 OOCKET NUMBER (2)YEAR LER NUMBER IS)AM SEGUENTIAL NUMSEA REVISION NUM888 PAGE 13I TIET IPRN88 NM88 N/88888/E 888 eRENono/AIRC | ||
/ro/III 3/ESASI)17)o s o o o 4350 89 1 3-0 0 03 QFO This interpretation would not normally affect Unit 4 since the 4A and 4B BATPs are both aligned to take suction from the C BAT and discharge to the Unit 4 charging pumps.Refilling a seal pot on either BATP would leave the other pump available to provide a flow path from a BAT to the Unit 4 Reactor Coolant System.The Unit 3 Boric Acid System configuration utilizes only one BATP, usually the 3A BATP, to take suction from the A BAT and discharge to the Unit 3 charging pumps'efilling the 3A BATP seal pot without first realigning the 3B BATP to take suction from the A BAT and discharge to the Unit 3 charging pumps would place Unit 3 in Technical Specification 3.0.1 when the 3A BATP is placed out of ser-vice.Since Control Room personnel were not provided with this"operability" criteria, the 3A BATP was not declared out of service during previous fillings of the seal pot and Technical Specification 3.0.1 was not entered.Cause of the Event The cause of the failed pressure indicator is a non-cognitive error by utility maintenance personnel.When removing the nitrogen pressure indicator, the wrench slipped off the"rounded flats" inducing vibration in the indicator. | /ro/III 3/ESASI)17)o s o o o 4350 89 1 3-0 0 03 QFO This interpretation would not normally affect Unit 4 since the 4A and 4B BATPs are both aligned to take suction from the C BAT and discharge to the Unit 4 charging pumps.Refilling a seal pot on either BATP would leave the other pump available to provide a flow path from a BAT to the Unit 4 Reactor Coolant System.The Unit 3 Boric Acid System configuration utilizes only one BATP, usually the 3A BATP, to take suction from the A BAT and discharge to the Unit 3 charging pumps'efilling the 3A BATP seal pot without first realigning the 3B BATP to take suction from the A BAT and discharge to the Unit 3 charging pumps would place Unit 3 in Technical Specification 3.0.1 when the 3A BATP is placed out of ser-vice.Since Control Room personnel were not provided with this"operability" criteria, the 3A BATP was not declared out of service during previous fillings of the seal pot and Technical Specification 3.0.1 was not entered.Cause of the Event The cause of the failed pressure indicator is a non-cognitive error by utility maintenance personnel.When removing the nitrogen pressure indicator, the wrench slipped off the"rounded flats" inducing vibration in the indicator. | ||
The vibra-tion resulted in the pointer falling off the indiaator. | The vibra-tion resulted in the pointer falling off the indiaator. | ||
The root cause of the failure to declare previous Technical Specification | The root cause of the failure to declare previous Technical Specification 3.0.1 entries is a cognitive error by utility-licensed operators. | ||
is a cognitive error by utility-licensed operators. | |||
A requirement to maintain a water level within the range of the sightglass and a nitrogen pressure between 35 psig and 40 psig in the BATP seal pots appears as a prerequisite in Operations Surveillance Procedure O-OSP-046.1,"Boric Acid Transfer Pump Inser-vice Test,"'nd as a precaution/limitation in Operating Procedure O-OP-046,"CVCS-Boron Concentration Control." Operations Surveillance Procedure O-OSP-201.2,"SNPO Daily Logs," requires operations personnel to log the water level and nitrogen cover pressure on each BATP seal pot every four hours.Operations personnel were not provided with"operability" criteria to enable them to re-cognize these requirements as having the potential to adversely affect BAT in-ventory, had the BATPs been required to run while refilling the seal pot.Anal eis of the Event No credit is taken for the concentrated boric acid contained in the BATs in any of the Design Basis Accidents described in the Turkey Point Final Safety Analysis Report (FSAR).Sufficient shutdown capability for the most severe anticipated cooldown transient (main steam line break), assuming the most reactive rod con-.trol cluster to be fully withdrawn, is achieved via the use of boron from the NRC FORM 388A o U S GPO 1988 0 824 538/455 NRC form 384A (04(3)LICENSEE EVENT REPORT (LER)TEXT CONTINUATION U,S.NUCLEAR REGULATORY COMMISSION APPROVEO OM8 NO 3150WI04 EXPIRES: 8/31/88 f ACILITY NAME ('l l Turkey Point Unit 3 OOCKET NUMBER (2(YEAR LER NUMBER (61 SEOVENTIAI, NVMSER REV/SION NVMSEA PAGE (31 TN(T O'RKoe<<Moo<<necked, vw 4/8/mdoV/NRC Fonrr 3(P/A'4/((Tl 25 089 013 0 4 oF0 5 refueli.ng water storage tank through the safety injection system.The BATs and the BATPs provide a source of concentrated boric acid to be added to the reactor coolant system to offset reactivity changes caused by normal plant operating transients, changes in power level,-and in order to attain and maintain shutdown conditions. | A requirement to maintain a water level within the range of the sightglass and a nitrogen pressure between 35 psig and 40 psig in the BATP seal pots appears as a prerequisite in Operations Surveillance Procedure O-OSP-046.1,"Boric Acid Transfer Pump Inser-vice Test,"'nd as a precaution/limitation in Operating Procedure O-OP-046,"CVCS-Boron Concentration Control." Operations Surveillance Procedure O-OSP-201.2,"SNPO Daily Logs," requires operations personnel to log the water level and nitrogen cover pressure on each BATP seal pot every four hours.Operations personnel were not provided with"operability" criteria to enable them to re-cognize these requirements as having the potential to adversely affect BAT in-ventory, had the BATPs been required to run while refilling the seal pot.Anal eis of the Event No credit is taken for the concentrated boric acid contained in the BATs in any of the Design Basis Accidents described in the Turkey Point Final Safety Analysis Report (FSAR).Sufficient shutdown capability for the most severe anticipated cooldown transient (main steam line break), assuming the most reactive rod con-.trol cluster to be fully withdrawn, is achieved via the use of boron from the NRC FORM 388A o U S GPO 1988 0 824 538/455 NRC form 384A (04(3)LICENSEE EVENT REPORT (LER)TEXT CONTINUATION U,S.NUCLEAR REGULATORY COMMISSION APPROVEO OM8 NO 3150WI04 EXPIRES: 8/31/88 f ACILITY NAME ('l l Turkey Point Unit 3 OOCKET NUMBER (2(YEAR LER NUMBER (61 SEOVENTIAI, NVMSER REV/SION NVMSEA PAGE (31 TN(T O'RKoe<<Moo<<necked, vw 4/8/mdoV/NRC Fonrr 3(P/A'4/((Tl 25 089 013 0 4 oF0 5 refueli.ng water storage tank through the safety injection system.The BATs and the BATPs provide a source of concentrated boric acid to be added to the reactor coolant system to offset reactivity changes caused by normal plant operating transients, changes in power level,-and in order to attain and maintain shutdown conditions. | ||
An additional means of providing borated water is from the refueling water storage tank through the charging pumps to the reactor coolant system.These flow paths (refueling water storage tank to the charging pumps and to the safety injection pumps)were available throughout the events It should be noted that boration via the BATPs and BATs is'required for various plant conditions, however, these conditions are not Design Basis Accidents for Turkey Point.During previous refillings of the 3A BATP seal pots, the Boric Acid System was not considered to be"inoperable" and no physical changes to the system were made (i.e., the 3A BATP motor breaker was not"racked outuf suction and/or dis-charge valves were not closed).In these instances, the 3A BATP remained"opera-tional" and would have started and supplied boric acid solution to the Reactor Coolant System, had it been required to operate.With operations and maintenance personnel present while refilling the seal pot, FPL believes the nitrogen press-ure indicator could have been reinstalled in sufficient time to preclude signi-'icant loss of boric acid solution inventory in the A BAT resulting from 3A BATP inner seal leakage.Corrective Actions 1)The 3B BATP was realigned to take suction from the A BAT and discharge to the Unit 3 charging pumps.Unit 3 exited Technical Specification 3.0.1 at 1404 on September 10, 1989.2)The nitrogen pressure indicator on the 3A BATP seal pot was replaced.At 2110 on September 10, 1989, the 3A BATP was returned to service.3)An entry was added to the Operations Night Order Book on September 13, 1989 to inform Control Room personnel that BATPs are to be considered out of service during the time the nitrogen pressure indicator is removed to re-fill the seal pots.4)Caution tags were placed at each of the Unit 3 and Unit 4 BATP seal pots.These tags require operations and/or maintenance personnel to notify Control Room personnel prior to opening the seal pots so appropriate actions can be taken to maintain Boric Acid System operability. | An additional means of providing borated water is from the refueling water storage tank through the charging pumps to the reactor coolant system.These flow paths (refueling water storage tank to the charging pumps and to the safety injection pumps)were available throughout the events It should be noted that boration via the BATPs and BATs is'required for various plant conditions, however, these conditions are not Design Basis Accidents for Turkey Point.During previous refillings of the 3A BATP seal pots, the Boric Acid System was not considered to be"inoperable" and no physical changes to the system were made (i.e., the 3A BATP motor breaker was not"racked outuf suction and/or dis-charge valves were not closed).In these instances, the 3A BATP remained"opera-tional" and would have started and supplied boric acid solution to the Reactor Coolant System, had it been required to operate.With operations and maintenance personnel present while refilling the seal pot, FPL believes the nitrogen press-ure indicator could have been reinstalled in sufficient time to preclude signi-'icant loss of boric acid solution inventory in the A BAT resulting from 3A BATP inner seal leakage.Corrective Actions 1)The 3B BATP was realigned to take suction from the A BAT and discharge to the Unit 3 charging pumps.Unit 3 exited Technical Specification 3.0.1 at 1404 on September 10, 1989.2)The nitrogen pressure indicator on the 3A BATP seal pot was replaced.At 2110 on September 10, 1989, the 3A BATP was returned to service.3)An entry was added to the Operations Night Order Book on September 13, 1989 to inform Control Room personnel that BATPs are to be considered out of service during the time the nitrogen pressure indicator is removed to re-fill the seal pots.4)Caution tags were placed at each of the Unit 3 and Unit 4 BATP seal pots.These tags require operations and/or maintenance personnel to notify Control Room personnel prior to opening the seal pots so appropriate actions can be taken to maintain Boric Acid System operability. | ||
Revision as of 02:09, 6 May 2019
| ML17347B373 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/09/1989 |
| From: | GOLDBERG J H, POWELL D R FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| L-89-367, LER-89-013, LER-89-13, NUDOCS 8910170155 | |
| Download: ML17347B373 (7) | |
Text
gc CE~RATED Dl BU'2 ON DEMONS'EON SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)ACCESSION NBR:8910170155 DOC~DATE: 89/10/09 NOTARIZED:
NO FACIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C AUTH.NAME AUTHOR AFFILIATION POWELL,D.R.
Florida Power&Light Co.GOLDBERG,J.H..
Florida Power&Light Co.RECIP.NAME RECIPIENT AFFILIATION DOCKET I 05000250
SUBJECT:
LER 89-013-00:on 890910,boric acid transfer pump not declared out of svc prior to refilling seal pot.W/8 DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE: TITLE 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc.NOTES: RECIPIENT ID CODE/NAME PD2-2 LA EDISON,G INTERNAL: ACRS MICHELSON ACRS WYLIE AEOD/DSP/TPAB DEDRO NRR/DEST/ICSB 7 NRR/DEST/MTB 9H NRR/DEST/RSB 8E NRR/DLPQ/HFB 10 NRR/DOEA/EAB 11 NUDOCS-ABSTRACT RES/DSIR/EIB EXTERNAL EG&G WILLIAMS I S LPDR NSIC MAYS,G NUDOCS FULL TXT COPIES, LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 4 4 1 1 1 1 1 1 RECIPIENT ID CODE/NAME PD2-2 PD ACRS MOELLER AEOD/DOA AEOD/ROAB/DSP NRR/DEST/ESB 8D NRR/DEST/MEB 9H NRR/DEST/PSB 8D NRR/DEST/SGB 8D NRR/DLPQ/PEB 10 NRR/DREPg PB 10 G FILE 02 FILE Ol L ST LOBBY WARD NRC PDR NSIC MURPHY,G.A COPIES LTTR ENCL 1 1 2 2 1 1 2 2 1 1 1 1 1 1'1 1 1 1 2 2 1 1 1 1 1 1 1 1 1 1 NOIE'IO ALL'SIDS" RECIPES PIZASE HELP US K)RECUCB%ASTB CXWIHKT IHE DOCUKKZ CGÃVRL DESKI RXN Pl-37 (EXT.20079)KO ELIMIMGR%SR lQME PKH DIHTRIEXHCN LISTS PGR DOCUMEMIS KÃJ DC@'T NEED!FULL TEXT CONVERSION REQUIRED TOTAI NUMBER OF COPIES REQUIRED: LTTR 38 ENCL 38 P.O.Box l4060, Juno Beach, FL 3340S.0420 FPL.OCT08ER 9 19B9 L-89-367 10 CFR 50.73 U.S.Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.20555 Gentlemen:
Re: Turkey Point Unit 3 Docket No.50-250 Reportable Event: 89-13 Date of Event: September 10, 1989 Boric Acid Transfer Pump Not Declared Out of Service Prior to Refilling the Seal Pot Resulting in no Flow Path From a Boric Acid Tank to the Unit 3 Reactor Coolant S stem The attached Licensee Event Report is being submitted pursuant to the requirements of 10 CFR 50.73 to provide notification of the subject event.Very truly yours, J.H.Goldberg Executive Vice President JHG/JRH/gmp cc: Stewart D.Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant Q5 50j.70<r5 89$0py PbR ADOCK 850002'=0 S PDC 3:Ew~an FPL Group company NRC Form 345 r9 83i LICENSEE EVENT REPORT (LER)U.S.NUCLEAR REGULATORY COMMiSSION APPAOVFD OMS NO, 3(504(Oe EXPIRES: 8/31/88 FACILITY NAME III DOCKET NUMSEA (2)PACE 3)Turkey Point Unit 3 0 5 0 0 0 5 0 1 of p 5""'"'Boric Acid Transfer Pump Not Declared Out of Service Prior to Refilling the Sea Pot o F1ow Path From A Boric Acid Tank To The Unit 3 Reactor Coolant S stem EVENT DATE (5)LER NUMSER (5)AEPOAT DATE (7I OTHER FACILITIES INVOLVED (SI MONTH DAY YEAR YEAR SSOUSNTIAL erUMSER i~RSYA~MONT irUMSSR OAY YEAR FACILITY NAMES DOCKET NVMSERIS)0 5 0 0 0 0 9 0 8 9 8 9 013 00 009 8 9 0 5 0 0 0 OPERATINO MODE (8)POWER LEVEL p 6 p 20.402(b)20.405(~l(1)lil 20AOS(el(1)(iil 20.405(~l(1 I (i(l I 20AOS(e)II I I le)20.405(e)III(rl 20.eOS(c I 50.34 I el(I I 50.35(c I (2)X 50.73(~l(2)(il 50.73(~I (2 I I 4 I S0.73(e l(2)I iiil LICENSEE CONTACT FOR THIS LER (12I 50.73(e)(2)(NI 50.73(e I 1 2(N(50.73(~I(2)(rrl)50.73(el(2)
Ieiiill Al 50.73(~l(2((riiil(8)50.73(~)(2)(cl 0 THE REOVIREMENTS OF 10 CFR (I: fCnrcfi Onr or moir Ol tnr loiiowinpi (11 THIS REPORT IS SUSAIITTED PUASUANT T 73.71(OI 73.71(cl OTHER (Specify in Aorrirct orfow end in Tert frRC Form 344AI NAME David R.Powell, Regulation and Compliance Supervisor TELEPHONE NUMSER AREA CODE 30 24-65 9 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRISEO IN THIS REPORT (13l CAUSE SYSTEM COMPONENT MANUFAC.TVAEA TO NPRDS (I$~~<<c<KgQJ~Ny CAUSE SYSTEM COMPONENT MANUFAC.TUAER TO NPRDS ye'e<</pi.-.gcPjyio t<<<<vii<<sp yC:.A<<,t".rO SUPPLEMEN'TAL REPORT EXI'ECTED IICI MONTH OAY YEAR YES ill yrL comprrrr EXPECTED$(fSerfSSrOH DATEI X NO EXI'ECTED SU8MISSION DATE (15I ASSTAACT (Limit to tc00 rprcrf, i.A, eppforimerrfy fifrrrn tinpfr corer typrwwtrrn lintoi (14)On September 10, 1989, at 1345, Unit 3 entered Technical Specification 3.0.1 for 19 minutes when the 3A Boric Acid Transfer Pump (BATP)was declared out of service.At the time of the event, the 3A BATP was the only BATP aligned to take suction from the A Boric Acid Tank (BAT)and discharge to the Unit 3 charging pumps.At 1345, while refilling the 3A BATP seal pot, maintenanae personnel acaidentally damaged the nitrogen pressure indicator.
Since nitrogen pressure on the seal pot could not be monitored , the 3A BATP'as declared out of service.This resulted in loss of a flow path from the A BAT to the Unit 3 Reactor Coolant System.The 3B BATP was aligned to take suction from the A BAT and discharge to the Unit 3 charging pumps.Unit 3 exited Technical Speci-fication 3.0.1 at 1404 on September 10, 1989-Further review revealed that the BATPs are technically"inoperable" when the nitrogen pressure indiaators are removed to refill the seal pot.Operations personnel were not aware that the BATPs are considered inoperable when the seal pot nitrogen pressure indicator is removed;therefore, the BATPs were not dealared out of service prior to refilling the seal pot.An entry has been made in the Operations Night Order Book to aonvey this opera-bility concern to Control Room operators.
NRC Ferm 345 r9 83i NRC Form 388A (9831 LICENSEE EVENT REPORT ILER)TEXT CONTINUATION U S, NUCLEAR REGULATORY COMMISSION APPROVED OVS NO 3150&104 EXPIRES: 8/31/88 FACILITY NAME (11 Turkey Point Unit 3 TE3ET 0'er/I/eefreee/4 eerreerE uw aaRP/one//Y/IC Ann PRLE 2/(121 DOCKET NUMBER (2)YEAR 2 5 0.8 9 LER NUMBER (8)SEGVSNTIAL NUMseR 0 1 3 rrevrsloN NUMeea 00 02 PAGE (31 oF 0 Deseri tion of the Event On September 10, 1989, at 1345, Unit 3 entered Technical Specification 3.0.1 for 19 minutes when the 3A Boric Acid Transfer Pump (BATP)(EIIS:CA, Component:P) was declared out of service.Unit 3 was operating in Mode 1 at approximately 60 percent power.At the time of this event, the 4A and 4B BATPs were aligned to take suction from the C Boric Acid Tank (BAT)and discharge to the Unit 4 charging pumps, the 3A BATP was aligned to take suction from the A BAT and dis-charge to the Unit 3 charging pumps.The 3B BATP was aligned to recirculate the B BAT.At 1345, the 3A BATP was declared out of service when maintenance personnel accidently damaged the nitrogen pressure indicator while refilling the 3A BATP seal pot.In order to refill the seal pot, the seal pot is depressurized, the nitrogen pressure indicator is removed, water is added via the nitrogen pressure indicator connection, the nitrogen pressure indicator is reinstalled, and the seal pot is repressurized with nitrogen.Since pressure on the 3A BATP seal pot could not be monitored after reinstallation of the nitrogen pressure indicator and the 3A BATP was the only BATP aligned from the A BAT to the Unit 3 charging pumps, no flow path existed from a BAT to the Unit 3 Reactor Coolant System as required by Technical Specifications.
Technical Specification 3.6.d requires that during power operation,"System piping, interlocks and valves shall be operable to the extent of establishing one flow path from the boric acid tanks, and one flow path from the refueling water storage tank, to each Reactor Coolant System." Unit 3 entered Technical Specification 3.0.1 which states, in part,"When a Limiting Condition for Oper-ation is not met, except as provided in the associated ACTION requi,rements, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to place the unit in a MODE in which the specification does not apply...".
Upon entering Technical Specification 3.0.1, the 3B BATP was realigned to take suction from the A BAT and discharge to the Unit 3 charging pumps.At 1404, Unit 3 exited Technical Specification 3.0.1.Further review of this event raised the question of seal water system pressure impact on the"operability" of the BATPs.A nitrogen pressure between 35 psig and 40 psig is maintained in the seal pot, in part, to ensure seating of the inner seal faces and minimize inner seal leakage.FPL has determined that as long as the BATP seal water system is"closed", loss of the seal pot nitrogen pressure would not render the BATP"inoperable
." Any leakage through the BATP inner seal faces into the seal water system would tend to pressurize the seal pot and limit the amount of leakage to a value which would not significantly affect the BATP minimum required flow rate.However, whenever the seal pot nitrogen indicator is removed, the seal water system is an"open" system.BATP inner seal leakage during pump operation with the seal water system"open" would not be enough to affect the minimum required flow rate of the BATP, however, the inner seal leak would result in lost inventory from the BAT.For this reason, FPL considers a BATP to be"inoperable" while refilling the seal pot.NRC FORM 388A oU.S GPO'1988 O.S24 538/455 NRC Form 388A (94)3)LICENSEE EYENT REPORT ILER)TEXT CONTINUATION U.S.NUCLEAR REGULATORY COMMISSION APOAOVEO OVIS NO.3150-0)04 EXPIRES: 8/31/88 FACILITY NAME 1'll Turkey Point Unit 3 OOCKET NUMBER (2)YEAR LER NUMBER IS)AM SEGUENTIAL NUMSEA REVISION NUM888 PAGE 13I TIET IPRN88 NM88 N/88888/E 888 eRENono/AIRC
/ro/III 3/ESASI)17)o s o o o 4350 89 1 3-0 0 03 QFO This interpretation would not normally affect Unit 4 since the 4A and 4B BATPs are both aligned to take suction from the C BAT and discharge to the Unit 4 charging pumps.Refilling a seal pot on either BATP would leave the other pump available to provide a flow path from a BAT to the Unit 4 Reactor Coolant System.The Unit 3 Boric Acid System configuration utilizes only one BATP, usually the 3A BATP, to take suction from the A BAT and discharge to the Unit 3 charging pumps'efilling the 3A BATP seal pot without first realigning the 3B BATP to take suction from the A BAT and discharge to the Unit 3 charging pumps would place Unit 3 in Technical Specification 3.0.1 when the 3A BATP is placed out of ser-vice.Since Control Room personnel were not provided with this"operability" criteria, the 3A BATP was not declared out of service during previous fillings of the seal pot and Technical Specification 3.0.1 was not entered.Cause of the Event The cause of the failed pressure indicator is a non-cognitive error by utility maintenance personnel.When removing the nitrogen pressure indicator, the wrench slipped off the"rounded flats" inducing vibration in the indicator.
The vibra-tion resulted in the pointer falling off the indiaator.
The root cause of the failure to declare previous Technical Specification 3.0.1 entries is a cognitive error by utility-licensed operators.
A requirement to maintain a water level within the range of the sightglass and a nitrogen pressure between 35 psig and 40 psig in the BATP seal pots appears as a prerequisite in Operations Surveillance Procedure O-OSP-046.1,"Boric Acid Transfer Pump Inser-vice Test,"'nd as a precaution/limitation in Operating Procedure O-OP-046,"CVCS-Boron Concentration Control." Operations Surveillance Procedure O-OSP-201.2,"SNPO Daily Logs," requires operations personnel to log the water level and nitrogen cover pressure on each BATP seal pot every four hours.Operations personnel were not provided with"operability" criteria to enable them to re-cognize these requirements as having the potential to adversely affect BAT in-ventory, had the BATPs been required to run while refilling the seal pot.Anal eis of the Event No credit is taken for the concentrated boric acid contained in the BATs in any of the Design Basis Accidents described in the Turkey Point Final Safety Analysis Report (FSAR).Sufficient shutdown capability for the most severe anticipated cooldown transient (main steam line break), assuming the most reactive rod con-.trol cluster to be fully withdrawn, is achieved via the use of boron from the NRC FORM 388A o U S GPO 1988 0 824 538/455 NRC form 384A (04(3)LICENSEE EVENT REPORT (LER)TEXT CONTINUATION U,S.NUCLEAR REGULATORY COMMISSION APPROVEO OM8 NO 3150WI04 EXPIRES: 8/31/88 f ACILITY NAME ('l l Turkey Point Unit 3 OOCKET NUMBER (2(YEAR LER NUMBER (61 SEOVENTIAI, NVMSER REV/SION NVMSEA PAGE (31 TN(T O'RKoe<<Moo<<necked, vw 4/8/mdoV/NRC Fonrr 3(P/A'4/((Tl 25 089 013 0 4 oF0 5 refueli.ng water storage tank through the safety injection system.The BATs and the BATPs provide a source of concentrated boric acid to be added to the reactor coolant system to offset reactivity changes caused by normal plant operating transients, changes in power level,-and in order to attain and maintain shutdown conditions.
An additional means of providing borated water is from the refueling water storage tank through the charging pumps to the reactor coolant system.These flow paths (refueling water storage tank to the charging pumps and to the safety injection pumps)were available throughout the events It should be noted that boration via the BATPs and BATs is'required for various plant conditions, however, these conditions are not Design Basis Accidents for Turkey Point.During previous refillings of the 3A BATP seal pots, the Boric Acid System was not considered to be"inoperable" and no physical changes to the system were made (i.e., the 3A BATP motor breaker was not"racked outuf suction and/or dis-charge valves were not closed).In these instances, the 3A BATP remained"opera-tional" and would have started and supplied boric acid solution to the Reactor Coolant System, had it been required to operate.With operations and maintenance personnel present while refilling the seal pot, FPL believes the nitrogen press-ure indicator could have been reinstalled in sufficient time to preclude signi-'icant loss of boric acid solution inventory in the A BAT resulting from 3A BATP inner seal leakage.Corrective Actions 1)The 3B BATP was realigned to take suction from the A BAT and discharge to the Unit 3 charging pumps.Unit 3 exited Technical Specification 3.0.1 at 1404 on September 10, 1989.2)The nitrogen pressure indicator on the 3A BATP seal pot was replaced.At 2110 on September 10, 1989, the 3A BATP was returned to service.3)An entry was added to the Operations Night Order Book on September 13, 1989 to inform Control Room personnel that BATPs are to be considered out of service during the time the nitrogen pressure indicator is removed to re-fill the seal pots.4)Caution tags were placed at each of the Unit 3 and Unit 4 BATP seal pots.These tags require operations and/or maintenance personnel to notify Control Room personnel prior to opening the seal pots so appropriate actions can be taken to maintain Boric Acid System operability.
5)As stated in LER 251/89-009, FPL is continuing the review of alternate seal~designs for the BATPs.As an interim measure to improve the present BATP seal water system design, a plant change/modification (PC/M)will be issued by May 31, 1990.This PC/M will provide improved level indication for the seal pots and will provide a means of adding make-up water without having to remove the seal pot nitrogen pressure indicator from service.NRC PORM 388A*U.S.GPO;(888 0 824.538/455 NRC FAIR 3SSA (94L3)LICENSEE EVENT REPORT (LER)TEXT CONTINUATION U.S.NUCLEAR REGULATORY COMMISSION APPRQVEO OMB NO.3I 50&104 EXPIRES: 8/31/88 FACILITY NAME (ll OOCKET NUMBER (2l YEAR LER NUMBER (Bl SSQVSNTIAL NUMBER REVISION NVMSSR PAGE (3(Turkey Point Unit 3 TEXT W/RNS<<Mc~JF/Oqvioo/, IIW od//I(ORnol NRC Fc///I 3(%(44J (ill 25 089 013 00 05 QF0 5 Additional Information The BATPs are manufactured by Goulds, Inc., Model No.3196-ST-8.
The seals are manufactured by Durametallic.
Similar occurrences have been reported in LER 251/89-009, LER 250/88-019, LER 250/88-005, and LER 250/87-017.
NRC FORM 3SSA o U 8 GPO (988 0 B24 538/455