ML18039A875

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LER 99-005-00:on 990901,SR for Standby Liquid Control Sampling Was Not Met.Caused by Deficient Procedure for Chemical Addition to Standby Liquid Control.Revised Procedure.With 990930 Ltr
ML18039A875
Person / Time
Site: Browns Ferry Tennessee Valley Authority icon.png
Issue date: 09/30/1999
From: Herron J, Rogers A
TENNESSEE VALLEY AUTHORITY
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-99-005-02, NUDOCS 9910080129
Download: ML18039A875 (18)


Text

CATEGORY INFORMATION DISTRIBUTION SYSTEM (RIDS) 1Q'EGULATORY.

ACCESSION NBR:9910080129 DOC.DATE: 99/09/30 NOTARIZED: NO DOCKET FACXL:50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH. NAME AUTHOR AFFILIATION ROGERS,A.T. Tennessee Valley Authority HERRON,J.T. Tennessee Valley Authority RECZP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 99-005-00:on 990901,SR for standby liquid control sampling was not met.Caused by deficient procedure for chemical addition to standby liquid control. Revised procedure. With 990930 ltr.

DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE:

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

NOTES:

RECIPIENT COPIES RECIPIENT COPIES 0 XD CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL LPD2-2 1 1 LONG,W 1 1 I

INTERNAL: ACRS 1 1 F CENTRE 1 1 NRR/DIPM/IOLB 1 1 NRR/DRIP/REXB 1 1 NRR/DSSA/SPLB 1 1 RES/DET/ERAB 1 1 RES/DRAA/OERAB 1 1 RGN2 FILE 01 1 1 EXTERNAL: L ST LOBBY WARD 1 1 LMXTCO MARSHALL 1 1 NOAC POORE,W. 1 1 NOAC QUEENER,DS 1 1 NRC PDR 1 1 NUDOCS FULL TXT 1 1 D N

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS'R REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIjZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 16 ENCL 16

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Tennessee Valley Authority, Post Office Box 2000," Decatur, Alabama 35609-2000 John T. Herron

, interim Vice President, Browne Feny Nuclear Rant September 30, 1999 U.S. Nuclear Regulatory Commission 10 CFR 50.73 ATTN: Document Control Desk Washington, D. C. 20555

Dear;Sir:

BROWNS, FERRY NUCLEAR PLANT (BFN) - UNIT' - DOCKET NO. 50-296.

,FACILITY OPERATING LICENSE DPR LICENSEE %WENT REPORT'LER) 50-296/1999005 The enclosed report provides details concerning an event. where a Technical Specifications surveillance requirement was not met.

This condition is reportable in accordance with 10 CFR, 50.73 (a)(2)(i)'(B) as a condition prohibited by the plant's technical specifications.

Sincerely,,

ohn T. Herron See page 2 9.9'f 0080f 29 990930 PDR ADOCK 0500029b 8 PDR

4l U.'S. Nuclear Regulatory Commission Page 2 September 30; 1999 Enclosure cc (Enclosure):

Mr. William O. Long, Senior Project. Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852

Mr. Paul E. Frederickson, Branch Chief U. S. Nucl'ear Regulatory Commission Region II Atlanta Federal Center 61 Forsyth Street, SW, Su'ite 23T85 Atlanta, Georgia 30303-3415 NRC Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611

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IRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB No. 3160.0104 sxPIRss oaraofaool 3.1 9981 Estanated burden per response to comply wsh this mandatory ktrormauon correction request 50 hrs. Reponed lessons learned are incorporated into the lcenaing prOCeSS and fed baCk tO induStry. FOrWard COmmentS regardrng

.ICENSEE EVENT REPORT (LER) burden estimate to the Records Management Branch (TA F33). U.S. Nuclear Rguttatory comrresston, wastangton. Dc 205554001, and to the Paperwork Reduction project (3150%104), oface of Management and Budget.

See reverse for required number of washington. Dc 20503. lf an informauon cosecten does not dislxay a ilgits/charactersfor each block) currently valid.oMS control number. the NAc may not conduct or sponsor.

and a personis rot requa ed to respond lo. the informabon oohccdorL ACIUTY NAME ii) DOCKET NUMSER 121 PACE (al frowns Ferry Nuclear Plant Unit 3 05000296 1of6 ITLS tel Iurveillance Requirement For Standby Liquid Control Sampling Was Not Met EVENT DATE (6) LER NUMBER (6) REPORT DATE (7)

DAY, YEAR YEAR SSOUSNTIAL REVISION DOCKST NVMSLR NUMSSA NUMBER NA DOCKET NUMBER 09 01 99 1999 005 000 9 30 99 NA OPERATING THIS REPORT IS SUBMITTED PURSUANT To THE REQUIREMENTS OF 10 CFR 51 (Check one or more MODE (9) 20.2201(b) 20.2203(a)(2) (v) 50.73(a) (2) (i) (6) ~

50.73(s)(2)(viii)

POWER 20.2203(a) ( I ) 20.2203(a)(3) (I) 50.73(a) (2)(II) 50.73(a) (2)(x)

LEVEL (10) 100 20.2203(a)(2)(i) 20.2203(a)(3)(ii) 50.73(a)(2)(iii) 73.71 20.2203(a)(2)(i() 20.2203(a)(4) 50.73(a)(2)((v) OTHER 20.2203(a) (2](iii) 50.36(c)(l) 50.73(a)(2)(v) Speafy in Abstract below or in NAC Form 366A 20.2203(a) (2) Iiv) 50.36(c) (2) 50.73(s) (2) (vii)

LICENSEE CONTACT FOR THIS LER (12)

TELSPHONS NVMSLR tlnOude Area Code)

Itnthony T. Rogers, Senior Licensing Project Manager (256) 729-2977 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

CAUSE SYSTEM COMPONENT MANUFACTURER RT PORTABLE To CAUSE COMPONENT MANUFACTURER ATPOATABLK NPADS To NPADS SUPPLEMENTAL REPORT EXPECTED (14) EXPECTED MONTH OAY YEAR YES NO SUBMISSION DATE (15)

(If yes, complete EXPECTED SUBMISSION DATE).

BsTtutcr (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten linea) (16 On September 1, 1999, plant personnel discovered that Surveillance Requirement (SR) 3-SR-3.1.7.9 had not been performed within the required 24-hour period following a chemical addition made to the Standby Liquid Control (SLC) tank on August 9, 1999. The SR requires that the sodium pentaborate enrichment is within the established limits after addition of boron to the SLC tank in order to ensure the proper boron atom percentage is being used. The sodium pentaborate enrichment must be calculated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and verified by analysis within 30 days. Upon discovery of the missed surveillance, the required surveillance was initiated and the sample was shipped to the contract lab to verify the analysis. The analysis verified that the established limits were being met. The root cause of the event was a deficient procedure for chemical addition to the SLC tank. The procedure will be revised to require the conditional surveillance. There were no actual or potential safety consequences as a result of this event nor did this event adversely affect the safety of plant personnel or the public.

This condition is reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by the plant's Technical Specifications.

FORM 366B (6.1998)

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NRC FORM 366A U.S. NUCLEAR REGULATOIIY COMMISSION I6 1998)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME I1) DOCKET LER NUMBER )6) PAGE )3)

YEAR 'EQUENTIAL REVisiON NUMBER 2 of 6 Browns Ferry Nuclear Plant - Unit 3 05000296 1999 005 000 TEXT illmore speceis required, IrSe eddirionel copies of iYRC Form 386AJ )17)

I. PLANT CONDITION(S)

At.the time of the discovery of this condition, Unit 2 and Unit 3 were operating at 100 percent power, and Unit 1 was shutdown and defueled.

II. DESCRIPTION OF EVENT A. Event:

On September 1, 1999, plant personnel discovered that Surveillance Requirement (SR) 3-SR-3.1.7.9 had not been performed within the required 24-hour period following a chemical addition made to the Standby Liquid Control (SLC) tank on August 9, 1999. The SR requires that the sodium pentaborate enrichment is within the established limits affer.addition of boron to the SLC tank in order to ensure the proper boron atom percentage is being used. 'The sodium pentaborate enrichment must be calculated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and verified by analysis within 30 days. Upon discovery of the missed surveillance, the required surveillance was initiated and the sample was shipped to the contract lab to verify the analysis.

The analysis verified that the established limits were being met. There were no actual or potential safety consequences as a result of this event nor did this event adversely affect the, safety of plant personnel or the public.

Upon discovery of the failure to meet the requirements of 3-SR-3.1.7.9, a 24-hour TS LCO was entered until a.valid sample was obtained.

This condition is reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by the plant's Technical Specifications (TS).

B. Ino erable'Structures Com onents or S stems that Contributed to the Event'one.

C. Dates and A roximate Times of Ma or Occurrences:

August 9, 1999 -1300 hours CST Chemical addition completed on Unit 3 SLC tank.

August 31, 1999 -1400 hours CST Cognizant chemist realized 3-SR-3.1.7.9, SLC System Boron-10 Enrichment Calculation and Verification, may have not been processed and initiated verification of procedure status.

September 1, 1999 1230 hours0.0142 days <br />0.342 hours <br />0.00203 weeks <br />4.68015e-4 months <br /> CST Cognizant chemist notified Chemistry management that 3-SR-3.1.7.9 had not been performed.

September 1, 1999 1352 hours0.0156 days <br />0.376 hours <br />0.00224 weeks <br />5.14436e-4 months <br /> CST 3-SR-3.1.7.9 commenced in order to meet the 30-day requirement of the SR.

September 1, 1999 -1600 hours CST Chemistry management determined that the 24-hour verification had not been performed.

~ FORM 366 )6-1998)

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NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION IB.I996)

LlCENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACiLITYNAME (1I DOCKET LER NUMBER l6) PAGE'{3I YEAR SEQUENTIAL REVISION NUMBER 4 of 6 Browns Ferry Nuclear Plant - Unit 3 05000296 1999 005 000 TEXT fifmore space is required, use addi'donal copies of NRC form 366AJ 'l17I IV. ANALYSIS OF THE EVENT Trending analysis of Unit 3 SLC surveillances had indicated that the weight percent concentration of Boron-10 had decreased over a period of time and was approaching the lower administrative limit. After discussions between chemistry management and the system cognizant chemist a decision was made to make an addition to the Unit 3 SLC tank to increase the percent weight concentration. 3-Tl-18 would be the controlling document for the addition and was added July 14, 1999, to the five week out work schedule.

Since the routine monthly compliance SLC surveillances were scheduled for August 9, 1999, 3-Tl-18 was tied to the 3-SR-3.1.7.3 performance. On September 1, 1999, the cognizant chemist, after reviewing Unit 3 SLC addition data, discovered that Chemistry had failed to perform 3-SR-3.1.7.9 after the August 9, 1999 addition to the U-3 SLC tank. 3-SR-3.1.7.9 requirements state, "verify sodium pentaborate enrichment is within the limits established by 3-SR-3.1.7.5 by calculating the Boron-10 enrichment within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and verifying by analysis within 30 days", after an addition to the SLC'tank. Upon further review by Chemistry management, it was determined that the 24-hour requirement had not met, and SR 3.0.3 was entered. The required samples were obtained and shipped to the contract lab for verification. The lab analysis verified that the results were acceptable and 3-SR-3.1.7.9 was completed satisfactorily.

The controlling procedure, 3-TI-18, provides adequate instruction for making changes to the SLC contents.

However the procedure failed to clearly require performance of SR 3;1.7.9 and had no requirements to verify its completion within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

IV. ASSESSMENT OF THE SAFETY CONSEQUENCES:

The SLC System is designed to provide the capability of bringing the reactor, at any time in a fuel cycle, from full power and minimum control rod inventory (which is at the peak of the xenon transient) to a subcritical condition with the reactor in the most reactive, xenon free state without taking credit for control rod movement. The SLC System satisfies the requirements of 10 CFR 50.62 on anticipated transient without scram. The SLC.System consists of a boron solution storage tank, two positive displacement pumps in parallel and two explosive.valves'in parallel for redundancy, and associated piping and valves used to transfer borated water from the storage tank to the reactor pressure vessel. The borated solution is discharged near the bottom of the. core shroud, where it then mixes with the cooling water rising through the core. The SLC System is manually initiated from the main control room, as directed by the emergency operating instructions, if the operator believes the reactor cannot be shut down, or kept shut down, with the control rods. The SLC System is used in the event that enough control rods cannot be inserted to accomplish shutdown and coo!down in the normal manner. The SLC,System injects borated water into the reactor core to add negative reactivity to compensate for all of. the various reactivity effects that could occur during plant operations. To meet this objective, it is necessary to inject a quantity of boron, which produces a concentration of 660 ppm of natural boron, in the reactor coolant at 70'F. To allow for imperfect mixing, leakage and the volume in other piping connected to the reactor system, an amount of boron equal to 25% of the amount cited above is added. This volume versus concentration limit and the temperature versus concentration limits are calculated such that the required concentration is achieved accounting for dilution in the RPV with normal water level and including the water volume in the entire residual heat removal shutdown cooling piping and in the recirculation loop piping.

C c FORM 366 I6 199BI

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NRC FORM 366A U.sr NUCLEAR REGULATORY COMMISSION 16 1999)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION

'FACILITYNAME (1) DOCKET LER NUMBER (6I PAGE (3)

YEAR 'EQUENTIAL REViSION NUMBER 5 of 6 Browns Ferry Nuclear Plant - Unit 3 05000296 1999 005 - 000 TEXT ilfmore spaceis required, use additional copies of fIRC Form 366AJ (17)

IV. ASSESSMENT OF THE SAFETY CONSEQUENCES (continued):

'Upon discovery of the missed SR, a sample was obtained and verified to meet the system requirements and it can be concluded that at no time was the system ever outside the required limits, nor was the system required for service. Therefore, there were no actual or potential safety consequences as a result of this event. For the reasons stated above, this event did not adversely affect the safety of plant personnel or the public.

VI. CORRECTIVE ACTIONS A. Immediate Corrective Actions Operations entered a 24-hour TS LCO in accordance with SR 3.0.3 for the affected surveillance requirements.-

B. Corrective Actions to Prevent Recurrence The controlling procedure, 3-TI-18, Enriched Sodium'Pentaborate (SPB) Solution Preparation Procedure for the Standby Liquid Control (SLC) System, will be revised to ensure the conditional surveillance requirements of SR 3.1.7.9 will be met.

'he affected surveillance, procedures will be revised to ensure the cognizant reviews are completed prior to expiration of the surveillance interval.

personnel were briefed on this event and the significance of Technical Specification

'hemistry compliance.

VII. ADDITIONALINFORMATION A. Failed Com onents None.

B. Previous LERs on Similar Events LER 260/97004 documented a TS surveillance which was missed. The root cause was determined to be ineffective control of outage schedules. Therefore, the corrective actions for that event would not have prevented this missed surveillance requirement..

'VA does not consider this corrective action a regulatory commitment; The completion of this item will be tracked in TVA's Corrective Action Program.

FORM 366 (6.1996)

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