ML17227A750

LER 93-002-00:on 921201,missed Surveillance on RCS Pressure Isolation Check Valves Due to Procedural Deficiency. Deficiencies in SR Corrected to Include Precautions in procedure.W/930226 Ltr

ML17227A750
Person / Time
Site:	Saint Lucie
Issue date:	02/26/1993
From:	Hurchalla J, Sager D FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-93-053, L-93-53, LER-93-002-02, LER-93-2-2, NUDOCS 9303050185
Download: ML17227A750 (5)

Text

ACCELERANT DOCUMENT DIST VTION SYSTEM REGULAT Y INFORMATION DISTRIBUTIO SYSTEM (RIDS)

'ACCESSION NBR:9303050185 DOC.DATE: 93/02/26 NOTARIZED: NO DOCKET FACIL:50-389 St. Lucie Plant, Unit 2, Florida Power & Light Co. 05000389 AUTH. NAME AUTHOR. AFFILIATION HURCHALLA,J.A. Florida Power & Light Co.

SAGER,D.A. Florida Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 93-002-00:on 921201,missed surveillance on RCS pressure isolation check valves due to procedural deficiency. D Deficiencies in SR corrected'to include precautions in "procedure.W/930226 ltr.

DISTRIBUTION CODE: ZE22T COPIES RECEIVED:LTR L ENCL ~ SIZE:

TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc.

NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL D PD2-2 LA 1 1 PD2-2 PD 1 1 NORRIS,J 1 1 D INTERNAL: ACNW 2 2 ACRS 2 2 AEOD/DOA 1 1 AEOD/DSP/TPAB 1 1 AEOD/ROAB/DSP 2 2 NRR/DE/EELB 1 1 NRR/DE/EMEB 1 1 NRR/DORS/OEAB 1 1 NRR/DRCH/HHFBHE 1 1 NRR/DRCH/HICB 1 1 NRR/DRCH/HOLB 1 1 NRR/DRIL/RPEB 1 1 NRR/DRSS/PRPB 2 2 R SPLB 1 1 NRR/DSSA/SRXB 1 1 EG FILE 02 1 1 RES/DSIR/EIB 1 1 RGN2 FILE 01 1 1 EXTERNAL: EG&G BRYCEgJ.H 2 2 L ST LOBBY WARD 1 1 NRC PDR 1 1 NSIC MURPHYgG.A 1 1 NSIC POORE,W. 1 1 NUDOCS FULL TXT 1 1 D

D NOTE TO ALL"RIDS" RECIPIENTS PLEASE HELP US TO REDUCE WASTEI CONTACT THE DOCUMENT CONTROL DESK, ROOM PI-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

• 1 FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 32 ENCL 32

P.O. Box 128, Ft. Pierce, FL 34954-0128 February 26, 1993 L-93-053 10 CFR 50.73 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Re: St. Lucie Unit 2 Docket No. 50-389 Reportable Event: 93-002 Date of Event: February 3; 1993 Missed Surveillance on Reactor Coolant Isolation Check Valves System'ressure due to Procedural Deficienc 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, D. A.. er Vice r sident St. Lucz.e Plant DAS/JWH/kw

'Attachment cc: Stewart D. Ebneter, Regional Administrator, USNRC Region II Senior Resident Inspector, USNRC, St. Lucie Plant DAS/PSL 8867-93 050029 9303050185 'rr3022b I ADQCK 05000389 PDR S PDR an FPL Group company gpss~

U.S. NUCLEAR REGULATORY COMMrSSION pppNorro olw w1 $ 1 $ 041 Ol FPL FOCErrrr'Io or ETPTPEINAOOTT NRC ForrTT S6S TETPIATT 0 TAPE N PEN TEWTCNCE TO OOWET WITH T I4$ 0PCINIATIOMCOUlCTION

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LICENSEE EVENT REPORT (LER) TECAESTI SOD f000 TOAWAITCCOANNNT0 TEOAIEPNO TAATXNEETNAATE TO TIO f0 COfOO NET TE PCITTS IININXANNT TTTANCNTP4$ 00 OO MACEENl INTTNATCITT 00044$ 0NPA WAWNIOTCN . OO TO f00 NO TO TIN 0ETEWIW$00 TEOOC TKN PNOE CT f

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FACILITYNAME (1) DOCKET NUMBER (2) PAGE 3 St. Lucie Unit 2 050003891 0 3

'~ (4) Missed Surveillance on Reactor Coolant System Pressure Isolation Check Valves Due to Procedural Deficiency EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED(8)

IAL FACILITYNAMES DOCKET NUMBER(S)

DAY YEAR YEAR S MONTH DAY YEAR N/A" 1 2 0 1 9 2 9 3 0 0 2 0 0 0 2 2 6 9 3 N/A 05 0 0 0 THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR:

OPERATING Check one or more of the followin (11)

MODE (9) 73.71(b) 20.402(b) 20.405(c) 50.73(a)(2)(iv)

POWER 50.73(a)(2)(v) 73.71(c) 20.405(a)(1)(i) 50.36(c)(1)

LEVEL (10) 0 0 0 20.405(a)(1)(ii) 50.36(c)(2) 50.73(a)(2)(vii) OTHER (Specify in Abstract 20.405(a)(1)(iii) X 50.73(a)(2)(i) 50.73(a)(2)(viii)(A) below and in Text 20.405(a)(1 )(iv) 50.73(a)(2)(viii)(B) NRC Eorm 366A) 50.73(a)(2)(ii) 20.405(a)(1)(v) 50.73(a)(2)(iii) 50.73(a)(2)(x)

LICENSEE CONTACT FOR THIS LER 12 NAME TELEP ONE NUMBER AREA CODE James A. Hurchalla, Shift Technical Advisor 4 0 7 465 -3550 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT 13 MANUFAC- REPORTABLE MANUFAC- REPORTABLE CAUSE SYSTEM COMPONENT TURER TO NPRDS CAUSE SYSTEM COMPONENT 'fURER TO NPRDS I I I SUPPLEMENTAL REPORT EXPECTED 14 EXPECTED MONTH DAY YEAR SUBMISSION YES (Ifyes, complete EXPECTED SUBMISSION DATE) X NO DATE (15)

ABSTRACT (Limit to 1400 spaces.i.e. approximately fifteen single-space typewritten lines) (16)

On January 30, 1993 St. Lucie Unit 2 was in Mode 3 implementing the Plant Heatup Procedure OP 2-0030121.

As part of this procedure, the Safety Injection (Sl) headers were recirculated causing six Reactor Coolant System (RCS) pressure isolation check valves to be exercised. These valves are then required to be tested per Technical Specifications. The Technical Staff was advised of this and the valves were subsequently tested satisfactorily within the required time interval. A Technical Staff supervisor realized that there was not an adequate procedurally addressed method to ensure performance of surveillance requirements of this evolution during heatups. A review was initiated to address past startups to ensure this requirement had not been previously missed. On February 3, 1993 a Technical Staff pump and valve specialist performing the review discovered only two instances on 12/1/92 and 12/7/92 in which the required surveillances of the RCS pressure isolation check valves had not been performed within the appropriate time interval during past plant heatups.

The root cause of the missed surveillances was procedural deficiency. There was no note or caution in the Plant Heatup Procedure as exists in the Prestart Check-Off List on the necessity of testing the valves as required by Technical Specification 4.4.6.2.2.d.

The corrective actions were to ensure current surveillance requirements on the Sl header check valves were met satisfactorily and to change the Plant Heatup Procedure OP 2-0030121 to identify the surveillance requirements following recirculation of the Sl headers during plant heatup. This event is not applicable to Unit 1 due to differences in design.

FPL Facsimile of NRC Form 366 (6-89)

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YEAR EQUENTIAL 'EVISIO NUMBER NUMBER St. Lucie Unit 2 05000389 366A's) 9 3 0 0 2 0 0 0 2 0 3 TEXT (/f more spaceis required, use additional NRC Form (17)

On January 30, 1993 St. Lucie Unit 2 was in Mode 3 implementing the Plant Heatup Procedure OP 2-00301 21. As part of this procedure, the Safety Injection (Sl) (EIIS: BP) headers were recirculated to equalize their boron concentration with the Reactor Coolant System (RCS) (EIIS: AB). This

, evolution caused six RCS pressure isolation check valves (EIIS: BP) to be exercised. This required the valves to be verified closed per Technical Specifications (TS) within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and leak rate tested within 31 days. The Technical Staff was advised of this and the valves were subsequently tested satisfactorily within the required time interval. A Technical Staff supervisor realized there was not an adequate procedurally addressed method to ensure the required pressure isolation check valve testing during plant heatups. A review was initiated to address past startups to investigate as to whether this requirement had been previously missed. On February 3, 1993 a Technical Staff pump and valve specialist performing the review discovered instances in which the required surveillances had not been performed within the appropriate time interval during past heatups.

subsequent to recirculating the Sl Headers. During plant heatups on 12/1/92 and on 12/7/92 the surveillance data sheet for these valves was not performed. This resulted in missing the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> requirement on four Sl header valves and both the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and 31 day requirements on two Hot Leg Injection valves. The review discovered no other such instances during startups from 1985 until the present.

The root cause of the event was inadequate procedural guidance. The check valves which are exercised in the Sl recirculation portion of OP 2-0030121 are required to be verified in their shut position against flow from the Reactor Coolant System per TS 4.4.6.2.2.d within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and leak tested within 31 days. However, no guidance is provided referencing this requirement. The surveillance requirements of these valves is addressed in the Prestart Check-Off List procedure OP 2-0030120 but it does not adequately address the suweillance requirement of an evolution which may take place at any time over the course of several days. There were no unusual characteristics of the work location which contributed to this event.

This event is reportable under 10 CFR 50.73.a.2.i.b, as a missed surveillance required by Technical Specifications.

Technical Specification 4.4.6.2.2.b states that the Reactor Coolant System pressure isolation check valves shall be demonstrated operable by verifying leakage to be within its limit upon actuation or initiation of flow through the valve by verifying valve closure within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and leak rate testing within 31 days. The bases for this Technical Specification requirement is to provide additional assurance of valve integrity thereby reducing the possibility of an intersystem Loss of Coolant Accident (LOCA).

FPL Facsimile of NRC Form 366 (6-69)

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F PL I Scsim(s o( U.S. NUCLEAR REGULATORY COMMISSION APPROIEO ODO NCI $ 174 4 1 fl NRC Form S66 EAPIIE4 IC00 I

(('P89)

'STDIATIORAIS(N PER IESPCNIE TOO(SNIT WITH TIDS SEOISIATCN C(SAECTION LICENSEE EVENT REPORT (LER) IE(SECT: 000 IRS, IORWAISIC(SSRNT0 IECARCNC IAASNN ESTIIIAIETO(IN IECOIIS AIR IEPCRT 0 SANA(EDE NT 4 RANCH (PDI(4 IA4 IAICAEARIE(ADA(CRY TEXT CONTINUATION WARNAITCN,CC RSI4 AIO TO TIE PPEINI(Ã0( IEOVCRON PRON CT (I'IDADI IIIOf fICE CP IIANA(XIEIITAfo IRANRT.WARCACTOID OC tfff(A FACILITYNAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3)

YEAR EQUENTIAL REVISIO NUMBER NUMBER St. Lucie Unit 2 0 500 0369 9 3 002-0003 0 3 TEXT (ff more spaceis required, use additional NRC Form 366A's) (17)

The six check valves cycled in the recirculation of the Sl header all have redundant check valves between them and the RCS which act as the first pressure boundary. These redundant valves are not cycled as part of the Sl Loop recirculation and were within their surveillance requirements at all times. Should any of these redundant valves not have closed or had leaked excessively it would have become apparent by a low SIT level alarm, high Sl loop header pressure alarm, or by RCS inventory balance.

Other suweillance requirements of Technical Specification (TS) 4.4.6.2.2 within the Prestart Check-Off List have insured that the surveillances were performed in past plant heatups within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

and the 31 day required time intervals. During the latest series of plant heatups on Unit 2 the other requirements were no longer applicable as the short period of time between heatups meant that these surveillances need not be performed per the other criteria of TS 4.4.6.2.2. Records of testing resulting from other evolutions previous and subsequent to these missed suweillances showed that the cycled valves had been performing as required. Therefore, the health and safety of the public was not affected by this event.

1) A review was conducted by the Technical Staff pump and valve specialist to determine if during past heatups the required surveillances of the RCS Pressure Isolation Check Valves had been performed. Two heatups involved missed surveillances while all the rest were satisfactory.

2) Deficiencies in surveillance requirement guidance in the Unit 2 Plant Heatup Procedure OP 2-0030121 were corrected to include precautions in the procedure stating tlie required surveillance when the Sl recirculation is performed. Unit 1 is not affected since the safety injection design is slightly different between the units and these check valves do not exist.

There were no component failures.

The following LERs were on missed surveillances due to procedural deficiencies:

LER 335-90-006 Missed surveillance on Control Element Assemblies Due to Procedural Deficiency LER 33543-016 Inadequate Procedure for Boric Acid Flow Path Surveillance LER 369-91-002 Missed Technical Specification Surveillance Due to Procedural Error FPL Facsimile of NRC Form 366 (6-89)