IR 05000483/1998002
| ML20217F208 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/26/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20217F179 | List: |
| References | |
| 50-483-98-02, 50-483-98-2, NUDOCS 9803310309 | |
| Download: ML20217F208 (20) | |
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ENCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.:
50-483 License No.:
NPF-30 Report No.:
504 83/98-02 Licensee:
Union Electric Company Facility:
Callaway Plant Location:
Junction Hwy. CC and Hwy. O Fulton, Missouri Dates:
February 2 4,1998 Inspectors:
V. Gaday, Resident inspector Approved By:
W. D. Johnson, Chief, Project Branch B ATTACHMENTS:
Attachment 1:
Supplemental Information Attachment 2:
Sequence of Events
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9803310309 98vd26
{DR ADOCK 05000483 PDR
I EXECUTIVE SUMMARY I
Callaway Plant NRC Inspection Report 50-483/98-02 Maintenance The licensee failed to demonstrate, during the 30-day implementation period of Technical
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Specification Amendment 118, that either train of the auxiliary / fuel building emergency filter system adsorbers would meet the new requirements of Technical Specification 4.7.7.b.2. Failing to comply with these requirements was a violation (Section M8.1).
The licensee believed they did not have to demonstrate compliance with the
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requirements of Technical Specification Amendment 118 during the implementation period because they had satisfactory test results using prior test acceptance criteria.
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This reasoning was incorrect and resulted in the licensee not recognizing that both trains of the emergency exhaust system were inoperable when enforcement discretion was requested. As a result, an incomplete notice of enforcement discretion was requested by the licensee and granted by the NRC (Section M8.2).
The licensee demonstrated that both the control room filtration system adsorbers and the
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control room pressurization system adsorbers could comply with the new requirements of Technical Specification 4.7.6. Compliance was demonstrated prior to the effective date of Technical Specification Amendment 106 (Section M8.3).
The main difference between testing criteria was time, temperature, and methyl iodide
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penetration. The ASTM criteria was believed to be more repeatable and more conservative (Section M8.4).
The licensee's process for implementing Technical Specification amendments was well-
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defined,gnd thorough, although the licensee's failure to maintain all records associated with one license amendment package was identified (Section M8.5).
The licensee's review to ensure prior Technical Specification amendments had been
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effectively implemented was comprehensive and thorough enough to identify any prior implementation problems. No additionalimplementation problems were identified.
Failing to implement the new testing requirement of Technical Specification Amendment 118 was an isolated occurrence in the licensee's Technical Specification
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amendment implementation process (Section M8.6).
Enoineerino Although inoperable, the Train B auxiliary / fuel building emergency filter system adsorber
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was functional to support the 90 percent charcoal filter assumptions in the safety analysis (Section E8.1).
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2-The licensee had appropriately identified and assessed the issues that caused the failure
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to implement Technical Specification Amendment 118 (Section E8.2).
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I Reoort Details l
BACKGROUND On January 9,1998, a carbon sample was removed from Train B of Auxiliary / Fuel Building Emergency Filter System Adsorber FGG02B and sent to a laboratory for analysis to satisfy an 18-month surveillance requirement. On January 21,1998, the Train A emergency generator was removed from service for a scheduled system outage. At 2 p.m. on January 21, the licensee received the results of the analysis performed on the charcoal sample. The analysis indicated that methyl iodide penetration was 2.45 percent, which exceeded the 2.0 percent surveillance acceptance limit. The Train B auxiliary / fuel building emergency filter system adsorber was declared inoperable. With Train A emergency diesel generator inoperable, and the Train B auxiliary / fuel building emergency filter system adsorber inoperable, the requirement of Technical Specification 3.8.1.1, Action d, were not met because the auxiliary / fuel building emergency filter system adsorber depends on the Train B emergency diesel generator as source of emergency power. Technical Specification 3.8.1.1, Action d, states that, if all required systems, subsystems, trains, components, and devices that depend on the remaining diesel generator as a source of emergency power are not operable, and are not restored within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, the plant must be placed in hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Since the requirement of Technical Specification 3.8.1.1, Action d, could not be met on January 21,1998, the licensee asked for, and was granted discretion from, meeting the requirements of Technical Specification 3.8.1.1, Action d, for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to allow the Train A emergency diesel generator to be returned to service.
During discussion with the licensee regarding the notice of enforcement discretion, regional management asked if Train B of the auxiliary / fuel building emergency filter system adsorber had been tested to the acceptance criteria specified in Technical Specification Amendment 118 within 30 days after the amendment issue date of November 13,1996. The licensee stated that Train B had nqt been tested to these requirements. The licensee stated that, although the methyl iodide penetration exceeded the Technical Specification limits, the Train B auxiliary / fuel building emergency filter system adsorber was fully functional to support the 90 percent efficiency assumptions of the safety analysis and there would be no increase in offsite or control room dose consequences for a fuel handling or a loss of coolant accident. These were the only accidents that credited the emergency exhaust system. Train A had been tested to the previous Technical Specification requirements on October 10,1996. The results indicated methyl iodide penetration of 0.02 percent. These surveillance test results provided assurance that Train A was capable of opcrating above the 90 percent efficiency assumptions of the safety analysis.
Subsequent testing of Train A on February 5,1998, yielded results of 1.89 percent and 1.94 percent for the two sample canisters. These results demonstrated that Train A had been operable since the previous testing in October 1996. The Notice of Enforcement Discretion is l
l discussed further in NRC Inspection Report 50-483/98-01.
Subsequent reviews after issuance of the Notice of Enforcement Discretion determined that, during the 30-day implementation period following issuance of Technical Specification Amendment 118 on November 13,1996, Train A Auxiliary / Fuel Building Emergency Filter
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-2-System Adsorber FGG02A should also have been tested to the revised testing requirements.
As a result, the licensee had not demonstrated that either train complied with Technical Sn.xification 4.7.7.b.2. This review prompted a telephone conversation between NRC Region IV and Callaway Plant management. Following this conversation, the licensee declared Train A of the auxiliary / fuel building emergency exhaust system to be inoperable since it had not been tested to the requirements of the current Technical Specifications. On February 2,1998, the NRC initiated a special inspection to review the circumstances surrounding the licensee's failure to implement Technical Specification Amendment 118 as required.
Because of the licensee's belief that Train A of the auxiliary / fuel building filter system was operable, a notice of enforcement discretion from meeting the requirements of Technical Specification 3.8.1.1, Action d, for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to allow returning Emergency Diesel Generator A to service was requested. However, because both trains of the auxiliary / fuel building filter system were inoperable as a resuit of timely surveillance testing not having been performed during Technical Specification Amendment 118 implementation, the appropriate enforcement discretion request should have been for Technical Specification 3.7.7, which required that two independent trains of emergency exhaust be operable, in addition to the requested enforcement discretion.
The NRC did not recognize this at the time and only issued the requested enforcement discretion. The system inoperability resulted from the failure to perform surveillance testing to the new standard and, consequently, is not cited as a separate violation.
The NRC also questioned the implementation of Technical Specification Amendment 106. This amendment changed the testing criteria for the control room pressurization and filtration units.
This report examines the circumstances surrounding the failure to implement Technical Specification Amendment 118 as required and also examines whether the licenses had effectively implemented Technical Specification Amendment 106. A sequence of events is shown in Attachment 2.
M8 Misceippeous Maintenance issues M8.1 Technical Soecification Amendment 118 a.
Insoection Scoce (92902)
The inspector assessed whether the licensee had implemented the requirements of Technical Specification Amendment 118 during the implementation period.
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Observations and Findinas (92902)
On July 18,1996, the licensee submitted a request to the Office of Nuclear Reactor
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Regulation to change Technical Specification 4.7.7. This change would implement an
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updated charcoal test criteria for both trains of the auxiliary / fuel building emergency filter i
system adsorbers. The updated criteria, ASTM D-3803-1989, was consistent with that used for the control room ventilation system approved in Technical Specification I
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-3-Amendment 106. The ASTM D-3803-1989 test methodology changed the test duration and test tempercture requirements of the old Technical Specification requirements (RDT).
On November 13,1996, in Technical Specification Amendment 118, the Office of Nuclear Reactor Regulation approved the Technical Specification change request. The Office of Nuclear Reactor Regulation stated that the amendment was effective on the date of issuance and was to be implemented within 30 days of the date of issue. With the 30-day requirement, Technical Specification Amendment 118 was required to be fully implemented by December 13,1996.
The revised Technical Specification required the licensee on an 18-month frequency to remove a representative charcoal sample from each auxiliary / fuel building filter system adsorber and verify within 31 days after removal that the sample was tested in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, and met the laboratory testing criteria of ASTM D-3803-1989.
The inspector verified that the licensee had revised all' surveillance procedures required to test to the new surveillance requirements prior to the amendment being effective.
Although the amendment was required to be fully implemented by December 13,1996,
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and all surveillance procedures required to test to the new requirements had been updated, the licensee did not obtain charcoal samples from either train of the auxiliary / fuel building emergency filter system adsorbers to demonstrate the adsorbers complied with the new Technical Specification requirements within the 30-day implementation period. In fact, the licensee did not obtain a charcoal sample from either adsorber until January 9,1998. On this date, the licensee obtained a charcoal sample from Train B Auxiliary / Fuel Building Emergency Filter System Adsorber FGG02B and, on January 16 the sample was sent to a laboratory for testing. On January 21, the licensee was nojifjpd by the laboratory that the sample failed the specification for methyl iodide enetration. The test sample allowed 2.45 percent of the methyl iodide to pass through the charcoal sample which exceeded the 2 percent acceptance criteria.
On February 2,1998, the licensee obtained four samples of charcoal from Train A Auxiliary / Fuel Building Emergency Filter System Adsorber FGG02A and sent them to an outside laboratory for testing and analysis. Two of the samples were canister samples and two were deep bed sarnples. On February 6,1998, the licensee obtained results from the laboratory. The methyl iodide penetration for the canister samples was 1.89 percent and 1.94 percent. The methyl iodide penetration for the deep bed samples was 4.61 percent and 5.22 percent. The licensee stated these results were acceptable because Regulatory Guide 1.52 only required canister samples to be obtained and l
tested. The deep bed samples were taken because the entire charcoal beds were replaced for both trains and the licensee wanted to test deep bed samples for
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companson purposes. The reason for the canister and deep bed testing differences is addressed in Section E.
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-4-Failing to demonstrate that the auxiliary / fuel building emergency filter system adsorbers were in compliance with the revised requirements of Technical Specification 4.7.7.b.2 within the implementation period of Technical Specification Amendment 118 is a violation. Charcoal was replaced on January 24,1998, for Train B and February 1,1998, for Train A. The inspector verified that the replacement charcoal met the requirements of Technical Specification 4.7.7.b.2 (483/98002-01).
The licensee's reasoning for not demonstrating compliance with the revised Technical Specification requirements is outlined in Section M8.2 of this report.
The inspector asked if the licensee had historically demonstrated compliance with the old Technical Specification requirements. The licensee stated that prior Technical Specification required testing had been performed. Testing results to both the old and new Technical Specification requirements are outlined in Table 1 below.
Table 1. Auxiliary / Fuel Building Emergency Filter System Adsorbers Test History Unit Test Date Acceptance Criteria Percent Mi Pass / Fall Penetration FGG02A 10/09/96 RDT 0.02 %
P 02/05/98 ASTM 1.89 %
P ASTM 1.94 %
P FGG02B 04/04/95*
RDT 0.03%
P ASTM 0.70%
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08/23/96 RDT 0.05%
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01/21/98 ASTM 2.45%
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'The April 4,1995, tests were performed to compare the two testing methodologies.
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Conclusi20S The licensee failed to demonstrate during the implementation period of Technical Specification Amendment 118 that both trains of the auxiliary / fuel building emergency filter system adsorbers would meet the revised Technical Specification requirements.
Failing to comply with the Technical Specification is a violation.
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-5-M8.2 Reason For Not Imolementino Technical Soecification Amendment 118 a.
Insoection Scoce (92902)
The inspector followed up to determine the licensee's reasoning for not implementing Technical Specification 118 within the implementation period.
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Observations and Findinos When asked to explain their reasoning for not implementing Technical Specification Amendment 118 during the 30-day implementation period, the licensee stated that they had completed the Technical Specification required surveillance tests to the RDT requi:3ments for Auxiliary / Fuel Building Emergency Filter System Adsorber FGG02A on October 9,1996, and for Auxiliary / Fuel Building Emergency Filter System Adsorber FGG02B on August 23,1996. The licensee stated that, when the Technical Specification amendment was received, they were still within the 18-month surveillance performance frequency. Therefore, they concluded that they did not have to test to the ASTM requirements during the implementation period. They also stated that testing to the RDT standard was a valid method of testing.
The licensee also based their decision not to test to the ASTM requirements on similarities between the test methodologies. The licensee believed that, based on comparison tests performed on April 4,1995, the tests would produce similar results.
The inspectors asked if an evaluation had been performed to determine the correlation between testing criteria to assist in equating the test results. The licensee stated that a correlation had not been performed.
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Conclusions The licgqpee believed they did not have to demonstrate compliance with the requirements of Technical Specification Amendment 118 during the implementation period because they had satisfactory test results using the RDT test criteria. This reasoning was incorrect and resulted in the licensee not recognizing that both trains of the emergency exhaust system were inoperable when enforcement discretion was requested.
M8.3 Technical Soecification Amendment 106 a.
Insoection Scoce (92902)
i The inspector assessed whether the licensee had implemented the requirements of Technical Specification Amendment 106 during the implementation period.
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-6-b.
Observations and Findinas On August 4,1994, the licensee submitted to the Office of Nuclear Reactor Regulation a request to change Technical Specification 4.6.2.2. Specifically, this request was to replace Technical Specification 4.6.2.2, " Spray Additive System," with a new specification entitled " Recirculation Fluid pH Control System." The spray additive system was to be retired, pending approval of the amendment request, and replaced with the recirculation fluid pH control system consisting of stainless steel baskets containing trisodium phosphate dodecahydrate. In this request, the licensee also changed the filter efficiency assumption used in the control room dose calculations from 90 to 95 percent for Control Room Pressurization System Filter Adsorbers FGK02A and -B and Control Room Filtration System Adsorbers FGK01 A and -B.
The licensee informed the inspector that the Office of Nuclear Reactor Regulation stated that, if the filter efficiency was changed, then the pressurization and filtration adsorbers should be tested to the ASTM D-3803-1989 criteria. In a letter dated March 14,1995, the licensee committed to perform dual tests using the old Technical Specification 4.7.6 acceptance criteria (RDT) and the criteria specified in ASTM D-3803-1989 on both control room pressurization adsorbers and both control room filtration adsorbers.
On December 20,1995, in Technical Amendment 106, the Office of Nuclear Reactor Regulation approved the Technical Specification request to allow testing the control room pressurization and filtration adsorbers using the ASTM D-3803-1989 test criteria. The Office of Nuclear Reactor Regulation stated that the amendment was effective on the date of issuance and was to be implemented within 30 days of issue. With the 30-day requirement, Technical Specification Amendment 106 was required to be fully implemented by January 19,1996.
Based on the commitment made in the March 14,1995, letter, the licensee began performiry surveillance tests before the implementation date of Technical Specification Amen 8 ment 106. The inspector verified that the licensee demonstrated compliance with the new Technical Specification. A summary of testing results is shown in Tables 2 and 3. Not shown are prior test results to demonstrate compliance with the old (RDT)
Technical Specification acceptance criteria. The inspector verified these tests had been satisfactorily performed.
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Unit Test Date Acceptance Percent M1 Pass / Fall
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Criteria Penetration j
FGK01A 04/08/95 ASTM 0.01 %
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10/08/96 ASTM 0.02 %
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FGK01B 02/10/95*
RDT 0.01 %
P ASTM 0.05%
P 08/23/96 ASTM 0.06 %
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l Table 3. Control Room Pressurization System Adsorbers Test History l
Unit Test Date Acceptance Criteria Percent Mi Pass / Fall Penetration
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FGK02A 04/08/95 ASTM 0.02 %
P 10/08/96 ASTM 0.01 %
P FGK02B 04/04/95 ASTM 0.05%
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09/25/96 ASTM 0.06 %
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Conclusions I
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The licensee demonstrated compliance with new Technical Specification requirements prior to the implementation date of Technical Specification 106.
M8.4 Test Criteria Differences
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a.
Insoection Scoce (92902)
l The inspectors reviewed both the old test (RDT) criteria and the new test (AGTM) criteria j
to assess their similarities and differences. The ASTM criteria was approved for use by Technical Specifications Amendments 106 and 118.
b.
Observations and Findinas The fundamental difference between testing criteria was temperature, time, and methyl iodide penetration. Prior Technical Specifications required the licensee to test for a methyliodide penetration ofless than 1 percent. This represented the amount of methyl l
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iodide that could pass through a charcoal sample. The licensee satisfied this
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requirement by testing to Regulatory Position C.6.a of Regulatory 1.52. The Regulatory Guide, in turn, specified testing was to be performed in accordance with l-ANSI /ASME N509-1976. ANSI /ASME N509-1976 specified testing be performed in
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accordance with Military Specification RDT M-16-1T.
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i Technical Specification Amendments 106 and 118 changed testing requirements to Regulatory Position C.6.b of Regulatory Guide 1.52. This required tests to meet ASTM D-3803-1989 criteria. Testing was to be performed at 30*C and 70 percent relative humidity, for methyl iodide penetration of less than 2 percent. Detailed below are differences in test criteria.
b.1 RDT M-16-1T-1973 This criteria required the licensee to perform testing using a temperature profile.
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Specifically, a 25'C,80'C,25'C temperature profile was used. The charcoal sample l
was heated to 25'C. Once at equilibrium, the temperature was increased to 80*C. At this temperature, the methyl iodide penetration was measured. This sample was then cooled to 25'C. This method of testing was abandoned because condensation buildup in the charcoal sample could invalidate test results. The acceptance criteria was a less
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than 1 percent methyl iodide penetration. Due to the concern about condensation buildup in the sample, this standard was replaced with RDT M-16-1T-1977.
b.2 RDT M-16-1T-1977 This test criteria eliminated the test profile and required the sample to be tested at a constant 80'C. This method was believed to be more repeatable and more conservative because it was performed at a constant temperature and was determined to be more realistic. The acceptance criteria was less than 1 percent methyliodide penetration.
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b.3 ASTM D-3803-1989 This criteria required the sample to be tested at a constant 30*C. The sample was maintained at this temperature for a minimum of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> and tested for methyl iodide penetration for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The acceptance criteria was less than 2 percent methyl iodide penetration. This criteria was believed to be more repeatable and more conservative than the test performed at 80'C because this test allowed more moisture to remain on the charcoal which reduced its capability to absorb methyl iodide.
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The main difference between testing criteria was time, test temperature, and methyl
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iodide penetration. The ASTM criteria was believed to be more repeatable and more f
conservative.
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M8.5 Technical Soecification Amendment imolementation Process i
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Insoection Scooe (92909)
l The inspector reviewed the adequacy of the licensee's Technical Specification l
amendment approval process.
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Observatiopt.ap1Drdings The licensee's process for implementing Technical Specification amendments was l
controlled by Administrative Procedure APA-ZZ-00106, " Primary Licensing Documents:
Change / Revision Process? The licensee had established a well-defined, thorough process for implementing changes in response to Technical Specification amendments.
The process was defined such that all procedures required to demonstrate compliance with revised Technical Specifications should have been implemented concurrent with
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amendment approval.
The inspector performed a review of the documentation that implemented Amendment 118. However, the licensee could not locate data that was needed to independently verify that the amendment implementation process was followed. Since
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the notification forms could not be located, the licensee showed the inspector through attemative methods that the process had been followed. The appropriate procedure l
revisions had been processed in a timely manner in support of the revised surveillance l
requirement. For reasons discussed in Section M8.2, the normal process was not followed and the revised procedures were not implemented within the required implementation period for Technical Specification Amendment 118. As discussed in
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Section M8.6, this appeared to be an isolated occurrence.
Failing to maintain all records associated with an amendment was considered a i
weakngsp. At the conclusion of the inspection, the licensee indicated that l
Procedure APA-ZZ-00108 would be changed to require that all records be retained as part of the licensing amendment package.
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Conclusions The licensee's process for implementing Technical Specification amendments was well-defined and thorough, although the licensee's failure to maintain all records l
associated with one license amendment package was identified.
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M8.6 Review of Prior Technical Soecification Amendments i
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Insoection Scoce (92902)
The inspector reviewed the licensee's evaluation of prior Technical Specification amendment implementation.
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Observations and Findinas To ensure there were no generic problems with the method in which Technical Specification amendments were implemented, the licensee performed a review of the amendments approved during the past 5 years. The licensee evaluated 46 Technical Specification amendments to assure they have been satisfactorily implemented.
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The evaluation consisted of a review of procedures, surveillance test information, modification packages, and other work documents. The licensee also reviewed procedures to ensure they had been appropriately revised to implement the new or revised Technical Specification requirements. During the review of the 46 amendments,
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the only problem the licensee found was the implementation of Technical Specification Amendment 118.
The inspector performed an independent review of three amendment packages. The amendments reviewed were:
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Amendment 84, Change to AFD Penalty Function for the Over Temperature Delta
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Temperature Reactor Tnp, Amendment 112, Emergency Diesel Generator Surveillance and Limiting
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Conditions for Operations, and Amendment 117, Digital Upgrade of Main Steam Feedwater Isolation Signal.
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The inspector verified these amendments had been appropriately implemented.
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Conclusions The licgryee performed a review of prior Technical Specification amendments to ensure they had been effectively implemented. The review was comprehensive and thorough enough to identify any prior implementation problems. The independent review performed by the inspector did not identify any implementation problems. Failing to implement the new requirements of Technical Specification Amendment 118 was an isolated occurrence in the licensee's Technical Specification amendment implementation process.
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i-11-lli. Engineering E8 Miscellaneous Engineering issues E8.1 Safety Sianificance a.
Insoection Scone (92902)
The inspectors performed a review to determine the safety significance of not implementing the Technical Specification changes and to determine if failing to meet the new acceptance criteria would have affected offsite dose calculations.
The Auxiliary / Fuel Building Emergency Filter System Adsorbers FGG02A and -8 collect and process the fuel building atmosphere in the event of a fuel handling accident. During operation, the nonessential fuel building heating, ventilation, and air conditioning air paths would be isolated and the building exhausted to assure that fission products and particulate matter were collected and processed.
The adsorbers served the auxiliary building only following a loss-of-coolant accident to assure that all emergency core cooling system leakage to the auxiliary building atmosphere and the containment air purged via the hydrogen purge system were processed. All ductwork not required for operation of the adsorbers and that penetrates the auxiliary building would be automatically isolated.
b.
Observations and Findinas The licensee informed the inspector that the current analysis for the auxiliary / fuel building emergency filter system adsorbers for the fuel handling accident and loss-of-coolant accident assumed a 90 percent efficiency for the charcoal filter. The licensee stated that less thand percent methyl iodide p?netration assured that the emergency exhaust system would maintain a greater than 95 percent efficiency.
The inspectors inquired about the charcoal sample removed from Train B Auxiliary / Fuel Building Emergency Filter System Adsorber FGG02B on January 16,1998. This sample failed the less than 2 percent methyliodide penetration criterion. The actual test results were 2.45 percent penetration. The licensee indicated this did not have an effect on the offsite dose calculation because, with a safety factor of 4 and applying the method of determining acceptance criteria provided by the NRC at the 21st DOE /NRC Nuclear Air Cleaning Conference in 1990, it resulted in the efficiency being greater than 90 percent.
The licensee concluded that, although inoperable, the Train B adsorber was fully functional to support the assumptions in the safety analysis and therefore there would be
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no increase in offsite or control room dose consequences for a fuel handling accident or l
loss-of-coolant accident.
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Conclusions The licensee concluded that, although inoperable, the Train B auxiliary / fuel building l
emergency filter system adsorber was functional to support the 90 percent charcoal filter
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efficiency assumptions in the safety analysis. The inspector agreed with this assessment.
E8.2 Licensee Incident Assessment a.
Insoection Scooe (92902)
The inspectors reviewed the licensee's assessment of the failure to implement Technical Specification Amendment 118 during the implementation period. The licensee assessed this failure in Suggestion Occurrence Solution 98-0076 and Licensee Event Report 98-001.
b.
Observations and Findinas The licensee broke the failure to implement requirements of Technical Specification Amendment 118 down into the following issues:
(1) Failure to implement the Technical Specification change within 30 days of issuance, (2) Coordination of charcoal test results being received during the appropriate train week, (3) The reason the charcoal failed, and (4) The comparison of the deep bed and the canister test results, issue 1 /
The licensee had completed Technical Specification required surveillance tests to the RDT requirements for Auxiliary / Fuel Building Emergency Filter System
Adsorber FGG02A on October 9,1996, and for Auxiliary / Fuel Building Emergency Filter System Adsorber FGG02B on August 23,1996. Since the adsorbers had been tested to an approved method, there was no indication the surveillance should be done to the new testing criteria within 30 days of the issuance of Technical Specification Amendment 118.
As discussed in Section M8.2, this incorrect reasoning led to failure to implement the revised testing requirements of Technical Specification Amendment 118. As stated in Licensee Event Report 50-483/98-001, the licensee determined the cause of the failure to perform the surveil lance test in accordance with the revised Technical Specification requirement to be a programmatic deficiency to identify the specified 30-day amendment implementation requirement. As corrective action, licensing was revising Procedure APA-ZZ-00108, " Primary Licensing Documents: Change / Revision Process,"
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to establish accountability and a method to identify, track, and positively close all items associated with implementation of each new amendment. This revision was to be completed by May 15,1998.
Issue 2 Poor communication between the system engineer and the testing laboratory resulted in the test results being delivered during the Train A instead of the required Train B week.
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i data was to be provided. Testing procedures were being revised to caution the user and
provide a period in which the laboratory must provide the results. The licensee believed this will ensure the analysis results are obtained during the proper week.
Issue 3 The licensee concluded that the charcoal in auxiliary / fuel building emergency filter system adsorbers failed due to age. The charcoalin both adsorbers had never been changed since the equipment was put into service. As charcoal ages, the process of oxidation or desorbsion of the impregnant occurs. This tends to decrease the efficiency of the charcoal.
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In their evaluation of testing differences, the testing laboratory indicated that the deep bed sample was dirty. The sample had a lot of charcoal fines or dust present. The laboratory believed these particles migrated from the test bed and resulted in higher methyliodide penetration. It was believed that the sampling device crushed some of the charcoal when the deep bed sample was taken. It was suggested that in the future only i
canister samples be used for testing. These results were believed to be more consistent and the,rgrwas less risk of damaging the sample and producing false readings.
c.
Conclusions The inspectors agreed that the licensee had addressed the issues that caused the failure to implement Technical Specification Amendment 11.
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-14-V. Management Meetinas X1 Exit Meeting Summary On February 6,1998, an interim exit was held and the licensee indicated they would provide the inepector with a copy of their assessment of the circumstances surrounding the failure to implement Technical Specification 118 as well as an evaluation explaining the differences in deep bed and canister test results from Train A Auxiliary / fuel Building Emergency Filter System Adsorber FGG02A.
On March 3,1998, a final telephonic exit was held. The licensee acknowledged the findings as presented.
The intpector asked the licensee whether any material examined during the inspection was propriety. No propriety information was identified.
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ATTACHMENT 1 jiUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee R. Affolter, Plant Manager H. Bono, Supervising Engineer, Quality Assurance Regulatory Support G.Czeschin, Training J. Davis, Engineer, Surveillance and Scheduling D. Griffith, Engineer, ISEG G. Hughes, Supervisor, Engineering R. Hux, Operations R. Lamp, Superintendent, Operations
- J. Laux, Manager, Quality Assurance S. Magaa, Operations S. Meyer, Quality Assurance C, Naslund, Manager, Nuclear Engineering A. Passwater, Manager, Licensing & Fuels J. Patterson, Shift Supervisor
- R. Pohlman, System Engineer G. Randolph, Vice President
- M. Reidmeyer, Quality Assurance R. Roselius, Chemistry
- D. Shafer, Supervisor, Regulatory Operations j
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M. Taylor, Asst Manager, Work Control
- J. Welch, System Engineer
- W.Witt, System Engineering tER
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J D. Passeht, Senior Resident inspector
- R. Azua, Project Engineer
- Attended telephonic exit on March 3,1998.
INSPECTION PROCEDURES USED
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92902 Followup-Maintenance ITEMS OPENED. CLOSED. AND DISCUSSED Opened 50-483/9802-01 VIO failure to implement Technical Specification required surveillance
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I ATTACHMENT 2 Seauence of Events Datt Action 08/04/94 Amendment 96 submitted to NRC '
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02/10/95 Tested FGK01B to both ASTM and RDT I
ASTM Methyl lodide (MI) Penetration 0.05%
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RDT Mi Penetration 0.01%
03/14/95 Licensee committed to test control room pressurization and filtration units i
to both RDT and ASTM standard 03/20/95 Amendrnent 96 was approved 04/04/95 Tested FGK02B ASTM Mi Penetration 0.05%
FGG028 comparison test ASTM M1 Penetration 0.70%
RDT Mi Penetration 0.03%
i 04/08/95 Tested FGK01 A ASTM M1 Penetration 0.01%
Tested FGK02A ASTM M1 Penetration 0.02%
12/20/95 Amendment 106 issued
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8/23/96 Tested FGK01B ASTM MI Penetration 0.06%
Tested FGG02B RDT M1 Penetration 0.05%
l 09/25/96 Tested FGK02B ASTM MI Penetration 0.06%
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10/08/96 Tested FGK01A ASTM M1 Penetration 0.02%
Tested FGK02A ASTM M1 Penetration 0.01%
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-2-10/09/96 Tested FGG02A RDT Mi Penetration 0.02%
11/13/96 Amendment 118 issued 01/09/98 Sample removed from FGG028 for testing 01/21/98 Train A Diesel Generator removed from service 01/21/98 Tested FGG02B ASTM M1 Penetration 2.45%
01/21/98 Notice of Enforcement Discretion granted 01/24/98 FGG028 charcoal replaced
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02/01/98 FGG02A charcoal replaced 02/05/98 Tested FGG02B ASTM M1 Penetration 1.89% and 1.94%
RDT-M16-1T tests charcoal at 80*C and 70 percent relative humidity. The acceptance criteria was an Mi penetration of less than 1 percent.
ASTM D-3803-1989 tests charcoal at 30*C and 70 percent relative humidity. The acceptance criteria was an Mi penetration of less than 2 percent.
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