ML17284A538

LER 88-028-00:on 880823,determined That on 870220-21 & 0619,Tech Spec Heatup/Cooldown Limit of 100 F in Any 1 H Period Exceeded.Caused by Program Inadequacy.Heatup & Cooldown Trending Program added.W/880922 Ltr

ML17284A538
Person / Time
Site:	Columbia
Issue date:	09/22/1988
From:	Powers C, Washington S WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
LER-88-028, LER-88-28, NUDOCS 8810040074
Download: ML17284A538 (7)

Text

AC CELERATED DISI'RIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8810040074 DOC.DATE: 88/09/22 NOTARIZED: NO DOCKET FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION WASHINGTON,S.L. Washington Public Power Supply System POWERS,C.M. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 88-028-00:on 880823,excessive plant heatup/cooldown rates caused by piogram inadequacy.

W/8 lgt DISTRIBUTION CODE: IE22D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: 50.73 Licensee Event Report (LER), Incident Rpt, etc. D 4

I NOTES ~i RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA 1 1 PD5 PD 1 1 A SAMWORTH,R 1 1 INTERNAL: ACRS MICHELSON 1 1 ACRS MOELLER 2 2 ACRS WYLIE 1 1 AEOD/DOA 1 1 AEOD/DSP/NAS 1 1 AEOD/DSP/ROAB 2 2 AEOD/DSP/TPAB 1 1 ARM/DCTS/DAB 1 1 DEDRO 1 1 NRR/DEST/ADS 7E 1 0 NRR/DEST/CEB 8H 1 1 NRR/DEST/ESB 8D 1 1 NRR/DEST/ICSB 7 1 1 NRR/DEST/MEB 9H 1 1 NRR/DEST/MTB 9H 1 1 NRR/DEST/PSB 8D 1 1 NRR/DEST/RSB 8E 1 1 NRR/DEST/SGB 8D 1 1 NRR/DLPQ/HFB 10 NRR/DOEA/EAB 11 NRR/DREP/RPB 10 NUDOCS-ABSTRACT RES TELFORD,J 1

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NRR/DLPQ/QAB 10 NRR/DREP/RAB 10 FILE DSIR 02 1

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8 A'

S TOTAL NUMBER OF COPIES REQUIRED: LTTR 46 ENCL 45

4 NRC Form 356 V.S. NUCLEAR REGULATORY COMMISSION (9.8 3 I ~

APPROVED OMB NO. 3)500104 EXPIRES: 8/31/88 LICENSEE EVENT REPORT (LER)

FACILITY NAME (I) DOCKET NUMBER l2) PAGE I3I I

Mashin ton Nuclear Plant - Unit 2 le 0 s 0 0 039 7 1 oF05 TITLE (4)

Excessive Plant Heatup/Cooldown Rates Caused By Program Inadequacy EVENT DATE IS) LER NUMBER (6) REPOR'7 DATE (7) OTHER FACILITIES INVOLVED IS)

MONTH DAY YEAR YEAR SEGUENT/AI R f. VIStON OAY YEAR FACILITY NAMES DOCKET NVMBERISI NUMBER /rlr( NUMBER 0 5 0 0 0 0 23 88 8 8 028 00 09 2 2 8 8 0 5 0 0 0 THIS REPORT IS SUBMITTED PVRSUANT TO THE REOUIREMENTS OF 10 CFR (I: /Cheek Onr or more OI the /oiiovrinP/ (11)

OPERATING MODE (9) 20.402(b) 20.405 (c) 60,73 (2 I (Iv) 73.71(5)

POWE R 20.405 (~ I (I) I r'I d0.36(cl(1) 50,73( ~ )(2)(v) 73.71(cl LEvEL 0 9 3 20.405 (~ I (1 I (it I 50.36(cl l2 I 50.73( ~ l(2)(viil DTHER /sprciiy in Aottrecr OIIovv end in Tert, IJRC FOrm 20.405( ~ I(1)(rii) d0,73( ~ I (2)(il 60.73(e l(2 l(villi(A) 366A) 20.405( ~ )(I)(r ) d0.73( ~ I(2lliil 50,73(el(2)(viiil(BI 20.405(eHI)tvl 50.7 3( ~ ) (2 I (iii) 50,73(e) (2)(e)

LICENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER AREA CODE S.L. Mashin ton, Com liance Engineer 509 377 -2 080 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

SYSTE'M MANUFAC. REPORTAB(.E MANUFAC CAUSE. COMPONENT TVRER TO NPRDS CAUSE SYSTEM COMPONENT TURER rE r 'VZ"':ir SUPPLEMENTAL REPORT EXPECTED (14I MONTH OAY YEAR EXPECTED SUBMISSION DATE (15)

YES /II yrr, comp/etc EXPECTED Sllpht/SSIOIP DATE/ X NO ABSTRACT /Limit ro /400 Iprcrt, Ir, epprov /merely Rftren tinpir Iprce rypevrritren Jinn/ lid)

On August 23, 1988 a Plant Compliance Engineer, while reviewing a Plant Nonconformance Report (NCR), determined that on February 20-21, 1987 and June 19, 1987 the Plant Technical Specification heatup/cooldown limit of 100'F in any one hour period had been

'xceeded. The root cause of this event is programmatic in that procedures and policies did not specify a more conservative administrative limit for the heatup or cooldown rate to prevent exceeding the technical specification limit. The effect of the programmatic failure was that two of three possible'iolations of the heatup/cooldown limit noted 'in a Plant Quality Assurance (QA) Surveillance (2-88-018) were investigated and were determined to be reportable per 10CFR50.73 (a)(2)(i)(B). These events were being investigated as the result of concerns raised by the NRC Resident Inspector.

On February 20-21, 1987, during a Plant cooldown, the Reactor coolant temperature decrease for the period between 2315 hours0.0268 days <br />0.643 hours <br />0.00383 weeks <br />8.808575e-4 months <br /> and 0015 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> was 115.3'F as determined by the conversion of reactor pressure to saturation temperature using steam tables. The Control Room Operator (CRO) performing the technical specification surveillance procedure recorded the cooldown for the same period as 99'F. The reason 'for this difference can not be determined. This event is a violation of the Plant Technical Specification. A review of the technical specification surveillance data for a Plant heatup on June 19, 1987 shows that the actual heatup for the period between 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br /> and 1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br /> was 102.7'F. The value reported in the surveillance for this period is 100'F. It appears that the CRO made an error when converting reactor'ressure to saturation temperature using the steams tables.

8810040074 880922 PDR ADOCK 0500085'7 8 PDC NRC Form 356

U.S. NUCLEAR REGULATORY COMMISSION NRC FoIm 3ddA (943)

LICENSEE EVENT REPORT (LER) TEXT CONTINUATION APPROVEO OM8 NO, 3)SO&104 EXPIRES: 8/31/88 FACILITY NAME (1) OOCKET NUMEER (2) LER NUMBER (8) ~ AGE (3)

SEOVENTIAL II(VISION NVM (11 NVM8% II Washington Nuclear Plant - Unit 2 o, s o o o 2 8 0 0 0 2 or. 0 5 TEXT /I/ maP dPACV II IPdv/'nod, IIIP Add/INvM/HRC Form 38843/ (17)

Abstract (cont'd)

There were no immediate mitigating corrective actions at the time of these events due to their not being recognized at the time of occurrence.

The two major correcti ve actions to prevent reccurrence are: Plant procedures are being modified to administratively restrict the heatup/cooldown rate to 20'F in any 15 minute period and 80'F in any one hour period, and a real-time computerized .

heatup/cooldown trend display has been added to the Control Room Process Computer System.

The gA Surveillance was completed and issued on April 29, 1988; however, the reportability of the events was not determined until August 23, 1988. The following corrective actions address this issue:

o A Plant gA procedure will be revised to include a requirement to review any identified surveillance deficiency to determine if an NCR is required, 2)

Train Licensing and Assurance personnel on plant problem reporting requirements. 3) Implement efficiency improvement within the Plant Compliance Group, and 4) Plant Operations will emphasize effective reviews of gA surveillance deficiencies.

There is no adverse safety significance associated with these events as the heatup and cooldown rates are bounded by a previously-reviewed Plant event.

Plant Conditions a) Power Level 93%

b) Plant Mode - 1 (Power Operation)

Event Descri tion On August 23, 1988 a Plant Compliance 'ngineer, while reviewing a Plant Nonconformance Report (NCR), determined that on February 20-21,. 1987 and June 19, 1987 the Technical Specification heatup/cooldown limit of 100'F in any one hour period was exceeded.

The Plant Compliance Engineer was reviewing the NCR because of concerns expressed by the NRC Resident Inspector. A Plant guality Assurance (I}A) Engineer between March 24, 1988 and April 5, 1988 performed a ()uality Assurance Surveillance (2-88-018) of compliance to Technical Specification 3/4.4.6.1. During performance of the surveillance he noted three instances where using instrumentation different from that used by the Control Room Operator (CRO) the 100'F heatup/cooldown rate .was possibly exceeded. The (jA surveillance was reviewed by a Plant Operations Licensed Senior Reactor Operator. Plant Operations responded to the surveillance'n Jurie 23, 1988, and three corrective actions were specified. Two of the corrective actions were to revise. plant procedures to limit (to approximately 80'F per hour) the heatup/cooldown rate by using the turbine pressure control system which is effective at pressures greater than 125 psig. The third corrective action was to develop a computer program which will trend the heatup/cooldown rate for Plant Operators.

NRC POIIM 3ddA +U.S.GPO,'1()88.0-82d 538/dSS (8831

U.S. NUCLEAA REOULATOAY COMMISSION NRC Poem 3EEA (94)3)

LICENSEE EVENT REPORT ILER) TEXT CONTINUATION APPROVED OMS NO. 3)50WIOO EXPIRES: 8/31/88 FACILITY NAME (I) DOCKET NUMBER (2) LEA NUMBER (El PAOE LT)

EEOUENTIAL REVISION NUMBER NUM ER Washington Nuclear Plant - Unit 2 o s o o o 39.788 028 00 03 OF TEXT ///mo/o E/Moo /s /BEBOP//, oss od/Oo'o//I HAC FBRII 3OLE's/ (IT)

On June 27, 1988 while starting up the 100'F per hour heatup rate was exceeded.

This event is not reportable because all'echnical specification action requirements were met. At the time of the event, only one procedure revision had been completed; however, since Reactor pressure was less than 125 psig during the event, these changes would not have prevented the event. After the June 27, 1988 event, the NRC Resident Inspector raised the issue of the reportability of the events reported in the gA Surveillance and the ineffectiveness of the corrective actions taken in response to the ()A surveillance. These issues are being responded to in the Supply System response to Notices of Violation 88-021-01 and 88-021-02. On July 5, 1988 the Plant gA Engineer initiated an NCR, and on August 23, 1988 a Compliance Engineer determined that two of the events were reportable.

On February 20-21, 1987 a Plant cooldown was in progress. A review of the cooldown surveillance data shows that Plant Operators used the Reactor Recirculation System (RRC) suction loop temperature to determine the hourly cooldown rate. The Plant procedure specifies that the Reactor temperature is to be calculated using Reactor pressure and steam tables when the Reactor coolant temperature is greater than 212'F. The procedure allows the use of the RRC suction temperatures, if subcooling is less than 15'F as it was in the operating region of this event. Between 2315 hours0.0268 days <br />0.643 hours <br />0.00383 weeks <br />8.808575e-4 months <br /> on February 20, 1987 and 0015 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> on February 21, 1987 the surveillance (Reactor Pressure Vessel) RPV System Temperature/Pressure Log shows that Reactor pressure decreased from 255 psig to 45 psig. Using steam -tables to convert the pressure to temperature gives 407.4'F at 2315 hours0.0268 days <br />0.643 hours <br />0.00383 weeks <br />8.808575e-4 months <br /> and 292.4'F at 0015 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> which is a one hour temperature change of 11.5.3'F. The recirculation suction temperature strip chart record shows temperature changes of 110'F and 112'F for this same period. The CRO performing the surveillance using the temperature meter associated with the chart recorder, logged the temperature as 405'F at 2315 hours0.0268 days <br />0.643 hours <br />0.00383 weeks <br />8.808575e-4 months <br /> and 306'F giving a temperature change of 99'F. The reason for .these differences'an not now be reconciled but it does appear that the 100'F in any one hour period cooldown limit was exceeded. This event was a violation of Plant Technical Specifications.

A second cooldown incident identified in the ()A Surveillance Report occurred on June 21, 1987. The ()A Engineer reported in the surveillance that the RRC suction temperature strip chart recorder showed that between 0820 and 0920 a temperature change of 102'F on one channel and 105'F on the other ,channel occurred. . The surveillance data recorded by the CRO shows .hourly temperature decreases of 83'F between 0800 and 0900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> and 96'F between 0830 and 0930 hours0.0108 days <br />0.258 hours <br />0.00154 weeks <br />3.53865e-4 months <br />; however if the rate between 0830 and 0900 is doubled, it gives a rate of 108'F per hour. These temperatures were calculated by converting Reactor Pressure to temperature using the steam tables. The surveillance procedure specifies that pressure be used when the reactor coolant temperature is above 212'F and the hourly cooldown rates indicate temperatures stayed within limits; therefore, this event should not be considered a violation of the Plant technical specification. The purpose incident in the surveillance report was to point out that measuring and calculating

'f including this the temperature decrease at half hour intervals may not be frequent enough to prevent an excessive cooldown/heatup rate in any one hour period as required by the Plant Technical Specification.

NRC FORM 3EOA o U.S.GPO:ISSSW824.538/455 (9 43)

NRC Form 3SSA U.S. NUCLEAR REGULATORY COMMISSION IB83)

LICENSEE EVENT REPORT ILER) TEXT CONTINUATION APPROVED OMB NO, 3)50WIOE EXPIRES: 8/31/88 DOCKET NUMBER 12) LER NUMBER 16) PAGE 13)

REVISION VS*A /Err SEOUENTIAL NUMSEA NUM ER Washington Nuclear Plant - Unit 2 o 5 o o o39 7 8 8 028 0 4 oF0 5 TEXT /// m<<f f/>>oo */AArrled, I/>> fr/dlr/orM/HRC form 3EELE'f/1)T)

The third incident occurred on June 19, 1987 during a Plant heatup. At the time of the event the, monitored instrumentation was transitioned from RRC suction temperature to temperature determined from Reactor pressure. At 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br /> the RRC suction temperature was recorded as 195'F and at 1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br /> the Reactor pressure was recorded as 50 psig which when converted to temperature is 297.6'F which gives a 102.7'F temperature rise. The surveillance data sheet shows the 50 psig conversion to temperature as 295'F giving a heatup rate of 100'F. It would appear that this was a conversion error. This is a technical specification violation.

Immediate Corrective Actions There were no immediate mitigating actions associated with any of the above events since they were not recognized at the time of occurrence.

Further Evaluation and Corrective Action A. Further Evaluation This 'event is reportable per 10CFR50.73 (2)(2)(i)(B). On two separate occasions the Plant exceeded the 100'F in any one hour period Technical Specification heatup/cooldown limit.

There were no structures, systems, or components inoperable prior to this event which contributed to the event.

The root cause of this event is a program inadequacy. Procedures and policies did not specify a more conservative administrative limit for the heatup or cooldown rate to prevent exceeding the technical specification limit.

The Plant Problem Procedure (PPM 1.3.12) requires a Plant Nonconformance Report (NCR) to be initiated for all potentially reportable events. Contributing fac'tors associated with this event include: The Plant QA Engineer who performed the surveillance, while recognizing the potential reportability of the event, did not initiate an NCR until July 5, 1988 because the policy of Plant QA at the time was to not issue NCRs for. problems documented in a QA surveillance report. The surveillance was reviewed and responded to by Plant Operations without =recognizing the potential reportability of the information.

The reportability review of the NCR by Plant Compliance was delayed due to competing workload priorities.

B. Corrective Actions

l. The UPlant Cold Startup Procedure" (PPM 3.1.2); ."Normal Shutdown to Cold Shutdown" PPM (3.2.1); "Normal Shutdown to Hot Shutdown" PPM (3.2.2); and Plant Technical. Specification Surveillance Procedure -"RPV (Reactor Pressure Vessel) Temperature/Pressure LogU (PPM 7.4.4.6.1.1) will be revised to administratively limit the heatup/cooldown to,20'F in any 15 minute period and 80'F in any one hour period.

NAC fOAM 3SSA o U.S.OPO:I BBB.IM24 538/455

)883)

0 U.S. NUCLEAR REGULATORY COMMISSION NRC Form 3SSA (84)31 LICENSEE EVENT REPORT (LER1 TEXT CONTINUATION APPROVEO OMS NO. 3(50M(04 EXPIRES: 8/31/88 FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE I3)

SEQVENTIAL REVISION YEAR NVMSER CS NVMSER Washington Nuclear Plant - Unit 2 0 s 0 0 o 397 88 028 0 0 0 5 OF 0 5 TEXT ///more <<>>ss is s//s)ksr/. o>> //1/Or '>>/ H/)C Form 35E(4's/((T)

2. A heatup and cooldown trending,'program has been added to the Plant status display as part of the Control Room Process Computer System. The program graphically displays the actual heatup/cooldown rate in relation to 80'F/hr reference lines. In addition, the program provides a heatup/cooldown rate based on the temperature change for the previous 15, 30, and 45 minute periods, and an alarm function whenever the actual or a projected rate exceeds the 80'F per hour limit.

3. Plant QA procedure Pt)A-03 "Conduct of ()A Surveillances" will be revised to provide direction to evaluate surveillance deficiency findings against Plant problem reporting requirements.

4. The Plant (}A Manager will review this event with Licensing and Assurance personnel and discuss their responsibilities regarding Plant problem (NCR) report initiation.

5. A review of the Plant Compliance organization has been completed. Several methods of improving the efficiency of the group have been identified and will be implemented.

6. Plant Operations managment will emphasize to its staff the need for increased awareness and the need for effective reviews of ()A Surveillance deficiencies.

Safet Si nificance There is no adverse safety significance associated with this event. The heatup/cooldown .hourly rate was previously reviewed for a Plant event (not reportable because all technical specification action requirements were met) in June 1984 in which the heatup rate for a one hour period was 133'F; The two events described in this LER are bounded by this previous review which determined that the Reactor Pressure Vessel was acceptable for continued service. -This event had no effect on the health and safety of the Public or Plant personnel.

Similar Events None EIIS Information Text Reference EIIS Reference System Component Reactor AC Reactor Recirculation System (RRC) 'AD Reactor Pressure Vessel (RPV) AC RRC Suction Temperature Strip Chart Recorder AD TR NRC FORM SeeA *U.S.OPO.(888 0 824 538/465 (WI3)

WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.o. Box 968 ~ 3000 George Washington Way ~ Richland, Washinglon 99352 Docket Ho. 50-397 September 22', 1988 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C . 20555

Subject:

NUCLEAR PLANT HO. 2 LICENSEE EVENT REPORT HO.88-028

Dear Sir:

Transmitted herewith is Licensee Event Report No.88-028 for the WNP-2 Plant:

This report is submitted in response to the report requirements of 10CFR50.73

.and discusses the items of reportability, corrective action taken, and action taken to preclude recurrence.

Very truly yours, C . . Powers (M/D 927M)

WHP-2 Plant Manager CYP: sm

Enclosure:

Licensee Event Report No.88-028 cc: Mr. John B. Martin, NRC - Region V Mr. C.J . Bosted, NRC Site (M/D 901A)

INPO Records Center - Atlanta, GA Ms. Dottie Sherman, ANI Mr. D.L. Williams, BPA (M/D 399)