05000461/LER-2005-001, Regarding Inadequate Procurement Specification for Charcoal Results in Inoperable Control Room Ventilation Subsystem
| ML052070690 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 07/14/2005 |
| From: | Bement R AmerGen Energy Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| U-603739 LER 05-001-00 | |
| Download: ML052070690 (6) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 4612005001R00 - NRC Website | |
text
Amerens.
An Exelon Company Clinton Power Station R.R.3, Box 228 Clinton, IL 61727 10 CFR 50.73 U-603739 July 14, 2005 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461
Subject:
Licensee Event Report 2005-001-00 Enclosed is Licensee Event Report (LER) No. 2005-001-00: Inadequate Procurement Specification for Charcoal Results in Inoperable Control Room Ventilation Subsystem. This report is being submitted in accordance with the requirements of 1 OCFR50.73.
Should you have any questions concerning this report, please contact Mr. William Cliff, Regulatory Assurance Manager, at (217)-937-2800.
ItS. Bement Site Vice President Clinton Power Station RSF/blf
Enclosures:
Licensee Event Report 2005-001-00 Summary of Commitments cc:
Regional Administrator-NRC Region IlIl NRC Senior Resident Inspector - Clinton Power Station Office of Nuclear Facility Safety - IEMA Division of Nuclear Safety
." <1
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 06/3012007
- 6&2004)
, the NRC may digits/Chara.ters for each block) not conduct or sponsor, and a person Is not required to respond to. the digits/ch1aracters for each lok DInl<inffrnntirin nIlrution.
- 3. PAGE Clinton Power Station 05000 461 1 OF 4
- 4. TITLE Inadequate Procurement Specification for Charcoal Results in Inoperable Control Room Ventilation Subsystem
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED SEUNILRVFACILITY NAMAE DOCOKET NUMBER MONTH DAY YEAR YEAR l MSEQUERNTIA R
MONTH DAY YEAR None l
05000 FACILITY NAME DOCKET NUMBER 05 04 2005 2005 - 001 -
00 07 14 2005 None 05000
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR§: (Check all that apply) o 20.2201(b)
E 20.2203(a)(3)Q) 0 50.73(a)(2)(i)(C)
E 50.73(a)(2)(vii) 1 0 20.2201(d) 0 20.2203(a)(3)(ii) 0 50.73(a)(2)(ii)(A) 0 50.73(a)(2)(viii)(A) 0 20.2203(a)(1) 0 20.2203(a)(4) 0 50.73(a)(2)(ii)(B) 0 50.73(a)(2)(viii)(B)
O 20.2203(a)(2)(i)
E 50.36(c)(1)(i)(A) 0 50.73(a)(2)(iii) 0 50.73(a)(2)(ix)(A)
- 10. POWER LEVEL E
20.2203(a)(2)(ii) 0 50.36(c)(1)Ci)(A)
E 50.73(a)(2)(iv)(A)
E 50.73(a)(2)(x) o 20.2203(a)(2)(iii)
E 50.36(c)(2)
E 50.73(a)(2)(v)(A) 0 73.71 (a)(4) oE 20.2203(a)(2)(iv) 0 50.46(a)(3)(ii) 0 50.73(a)(2)(v)(B) 0 73.71 (a)(5) 095
[
20.2203(a)(2)(v) 0 50.73(a)(2)(i)(A) 0l 50.73(a)(2)(v)(C) 0 OTHER ol 20.2203(a)(2)(v;)
X 50.73(a)(2)(i)(B) 0 50.73(a)(2)(v)(D)
Specify In Abstract below or in NRr Form 3flRA
- 12. LICENSEE CONTACT FOR THIS LER FACILITY NAME TELEPHONE NUMBER (Include Area Code)
R. W. Chickering, Design Engineering 1(217) 937-2818CAUSE SYSTEM COMPONENT MANU-REPORTABLE l
CAUSE
SYSTEM COMPONENT MANU-REPORTABLE IFACTURER TO EPIX FACTURER TO EPIX
- 14. SUPPLEMENTAL REPORT EXPECTED
- 15. EXPECTED MONTH DAY YEAR SUBMISSION E YES (if yes, complete 15. EXPECTED SUBMISSION DATE) 0 NO DATE ABSTRACT (Limit to 1400 spaces, I.e, approximately 15 single-spaced typewritten lines)
On 5/16/05 with the plant at power, and 12 days after charcoal adsorber samples were taken from Division 1 Control Room Ventilation (VC) subsystem recirculation bed filter for penetration testing per Technical Specification (TS) 3.7.3.3, the methyl iodide penetration level of the charcoal sample was determined to be unacceptable. As a result of the unsatisfactory test results, TS 3.7.3 was not met.
Additionally, during 5 of the 12 days, the Division 2 VC subsystem was inoperable due to a planned emergency diesel generator (EDG) maintenance outage; however, the EDG was restored to operable status prior to receipt of the charcoal sample results. Thus both subsystems were inoperable during 5 days; however, an analysis concluded that the degraded charcoal would have been capable of performing its safety function.
The cause of this event is the industry standards providing the basis for charcoal purchasing requirements were inadequate for the unique application at Clinton Power Station (CPS) and had no limit on as-manufactured moisture levels. Corrective actions for this event included replacing the charcoal in the Division 1 VC Subsystem with acceptable charcoal, evaluating other charcoal beds in the VC system as acceptable, and establishing a purchasing requirement for charcoal to limit moisture to 8 percent or less by weight.
NRC FORM 366 (6a00)
PRINTED ON RECYCLED PAPER (If more space Is required, use additional copies of (If more space Is required, use additional copies of (If more space Is required, use additional copies of NRC Forn 366A) (17)
Moisture adversely impacts activated charcoal performance and causes caking. The presence of caking indicates that charcoal grain size increased during operation. Both of these mechanisms led to reduced charcoal bed efficiency.
SAFETY ANALYSIS
This event is reportable under the provisions of 10CFR50.73(a)(2)(i)(B) as a condition prohibited by the plant's technical specifications.
This event had no impact on radiological conditions and presented no risk to control room operators from degraded control room ventilation charcoal bed filter iodine adsorption efficiency under normal and transient conditions. Under accident conditions, the radiological consequences from this event would be negligible because the measured penetration level of 8.168 percent, although greater that the CPS operating limit of 6 percent for the penetration test, was less than the 15 percent limit that is consistent with the NRC approved safety factor in GL 99-02, Laboratory Testing of Nuclear-Grade Activated Charcoal. CPS uses the more demanding ASTM D3803-1989, Standard Test Method for Nuclear-Grade Activated Charcoal, test that is the basis for the safety factor of 2 discussed in GL 99-02. (Clinton has included the GL 99-02 provisions in a proposed change to the operating license for the CPS Ventilation Filter Testing Program.) If a design basis accident had occurred while the unsatisfactory charcoal was installed, control room operators would not have received radiation exposure greater than the analyzed level.
No safety system functional failures occurred during this event.
CORRECTIVE ACTION
New acceptable charcoal was installed in the Division 1 VC Subsystem recirculation charcoal bed filter OVC07SA and was validated to be acceptable on May 18, 2005.
Other charcoal beds in the VC Subsystems were tested and found acceptable; however, the Division 2 recirculation and make-up charcoal filter beds were replaced.
A requirement to limit moisture to less than or equal to 8 percent by weight will be incorporated into purchasing specifications for charcoal. (IR 335698-15)
PREVIOUS OCCURRENCES
None
COMPONENT FAILURE DATA
None SUMMARY OF COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)
I COMMITMENT TYPE
COMMITMENT
NTIME ACTION PROGRAMMATIC
{
(Yes/No)
I (Yes/No)
A requirement to limit moisture to less than or Yes equal to 8 percent by weight will be incorporated into purchasing specifications for charcoal. (IR 335698-15) l_
I