ML17286A631

LER 91-003-00:on 910201,inadequate air-aersol Mixing Under Test Conditions.Caused by Procedure Error.Surveillance Test Procedure PPM 7.4.6.5.3.5 Permanently Revised & Surveillance for Plant Procedures Will Be reviewed.W/910301 Ltr

ML17286A631
Person / Time
Site:	Columbia
Issue date:	03/01/1991
From:	John Baker, Fies C WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-91-042, GO2-91-42, LER-91-003, LER-91-3, NUDOCS 9103070266
Download: ML17286A631 (9)

Text

ACCELERATED DJ RIBUTION DEMONIST TION SYSTEM REGULATORY INFORMAT1ON DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9103070266 DOC.DATE: 91/03/01 NOTARIZED: NO DOCKET FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION FIES,C.L. Washington Public Power Supply System BAKER,J.W. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 91-003-00:on 910201,inadequate air-aersol mixing under test conditions. Caused by procedure error. Surveillance Test D Procedure PPM 7.4.6.5.3.5 permanently revised & surveillance for plant procedures will be reviewed.W/910301 ltr.

DISTRIBUTION CODE IE22T COPIES RECEIVED:LTR ENCL TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc. 2 SIZE:

NOTES: A RECIPIENT COPIES RECIPIENT COPIES D ID .CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA 1 1 PD5 PD 1 1 ENG, P. L. 1 1 INTERNAL: ACNW 2 2 ACRS 2 2 AEOD/DOA 1 1 AEOD/DS P/TPAB 1 1 AEOD/ROAB/DS,P 2 2 NRR/DET/ECMB 9H 1 1 NRR/DET/EMEB 7E 1 1 NRR/DLPQ/LHFB11. 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA/OEAB 1 1 NRR/DREP/PRPB11 2 2 NRR/DST/SELB 8D 1 1 NRR/DST/SICB 7E 1 1 PLB8D1 1 1

'NRR/DST/SRXB 8E 1 1 02 1 1 RES/DSIR/EIB 1 1 RGN FILE 01 1 1 EXTERNAL EG&G BRYCE i J H 3 3 L ST LOBBY WARD 1 1 NRC PDR 1 1 NSIC MAYS,G 1 1 NSIC MURPHY,G.A 1 1 NUDOCS FULL TXT 1 1 gggGOZ ~7> D A

D D

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 33 ENCL 33

WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George Washington Way ~ Richland, Washinglon 99352 Docket No. 50-397 Harch 1, 1991 G02-91-042 Document. Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Subject,: NUCLEAR PLANT NO. 2 LICENSEE EVENT REPORT NO.91-003

Dear Sir:

Transmitted herewith is Licensee Event Report No.91-003 for the WNP-2 Plant.

This report is submitted in response to the report requirements of 10CFR50.73 and discusses the items of reportabi lity, corrective action taken, and action taken to preclude recurrence.

Very truly yours J. W., aker (H/D 927H)

WNP-2 Plant Hanager JWB:lr

Enclosure:

Licensee Event Report No.91-003 J

cc: Hr. John B. Hartin, NRC Region V Hr. C. Sorensen, NRC Resident Inspector (H/D 901A)

INPO Records Center Atlanta, GA Hr. D. L. Williams, BPA (H/D 399)

NRC Resident Inspector walk over copy 9103070266 Y108Vl PDR ADOCK 05000397 X K2.2-S PDR /) /

t

'i

NRC FORM 346 U.S, NUCLEAR REGULATORY COMMISSION (64)9) ~ APPROVEO OMB NO, 3)500104 5 XPIR ESI 4/30/92 ESTIMATED BURDEN PER RESPONSE TO COMPLY WTH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS. FORWARD LICENSEE EVENT REPORT {LER) COMMENTS 4EGARDING BURDEN ESTIMATE TO THE 4ECORDS AND REPORTS MANAGEMENT BRANCH (P630), U.S. NUCLEAR REGULATO4Y COMMISSION, WASHINGTON. DC 20555, AND TO THE PAPERWORK REDUCTION PROJECT (31500104I, OFFICE OF MANAGEMENTANO BUDGET, WASHINGTON, OC 20503.

FACILITY NAME HI DOCKET NUMBER (2) PA E 3 0 5 0 0 0 OF

'""'" Inadequate Technical Specification Surveillance Testing 1

Of S tmen 0 EVENT DATE (5) LER NUMBER (6) REPORT DATE (7I OTHER FACILITIES INVOLVED (4) yv~~'. SEQUENTIAL REYISIOrt FACILITYNAMES DOCKET NUMBER(S)

MONTH OAY YEAR YEAR >N", NUMBER NUMBER MONTH OAY YEAR 0 5 0 0 0 0 2 01 91 9 1 003 0 0 0 3 019 1 THIS REPORT IS SUBMITTED PURSUANT T 0 THE REQUIREMENTS OF 10 CFR (): IChech one or more Of the followinPI (11) 0 5 0 0 0 OPE4ATING MODE (9) 20.402(SI 20A05 (c) 60.73(e) l2) livl 73.71(bl POWER 20.405(e) (1)(il 60.34(cl(1) 60,73( ~ )(2)(v) 73.71(c)

LEVEL (10) 20.405( ~ l(1) (91 50.34(cl(2) 50.73( ~ ) (2)(vx) OTHER ISoecity in Ahttrett Oelovr erxt In Text, IIRC Form 20.405( ~ l(ll(iiil 50.73( ~ ) 12) l I) 60.7 3(e) (2) (v>i)) (AI 366AI 20.405( ~ l(1)(ivl 50.73(e)(2) liil 50.73( ~ l(2) (viii)(BI 20.405( ~ l(1)(v) 60.73( ~ l(2) liiil 50.73( ~ ) (2) (xl LICENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER AREA CODE COMPLETE ONE LINE FOR EACH COMPONENT FAILVAE DESCRIBED IN THIS REPORT (13)

CAUSE SYSTEM COMPONENT MANVFAC.

TURER REPORTABLE 'jf>$~$ ccw,:~c+>+>>.

TO NPRDS @kg(~rpPe.'~pPPh CAUSE SYSTEM COMPONENT MANUFACi TVRER 'O NPADS

. '.>>....o4PZY4 O~kM~+~4S'yqgKS(x~vok)(.

@>>.IK+t~s~gj@'P~P:

PPSN yr ~~Sot SUPPLEMENTAL REPORT EXPECTED (14I MONTH OAY YEAR EXPECTED SUBMISSION DATE (15)

YES Itf yet, complete EXPECTED SIIS4IISSIOII DATEI NO ABSTAACT ILimit to te00 tpeceL ie.. epproximetery IitNen Iinple.tpece typevvritten linwi (14)

On February 1, 1991 at 2100 hours0.0243 days <br />0.583 hours <br />0.00347 weeks <br />7.9905e-4 months <br /> a review of surveillance procedure for periodic testing of the downstream Standby Gas Treatment (SGT) High Efficiency Particulate Air (HEPA) filters indicated that methods used were not in compliance with the Technical Specifications due to inadequate air-aerosol mixing. The specific method used was not adequate to meet the requirement in Technical Specification Paragraph 4.6.5.3.b. This paragraph requires that at least once per 18 months each SGT subsystem is to be demonstrated to be operable by test. A review of plant records by Plant Engineers showed that the periodic testing to meet the requirements of this surveillance were completed. However, the testing method used did not assure sufficient air-aerosol mixing for the surveillance test of the downstream HEPA filters.

The root causes of this event were inadequate work practices, inadequate procedures, and less than adequate management programs. A Plant Engineer failed to incorporate the detailed methods required to satisfactorily conduct the surveillance test. The surveillance test procedure did not adequately meet the Technical Specification surveillance requirements. Management programs were in place to detect this omission but were not effectively implemented.

NRC Form 366 (64)9)

NAC FORM 366A (64)9)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION U.S. NUCLEAR REGULATORY COMMISSION t

INFORMATION APPROVED OMB NO. 3'I500104 EXP IR ES: 4/30/92 ESTIMATED BURDEN PER RESPONSE TO COMPLY WTH THIS COLLECTION AEQUESTI 50.0 HRS. FORWARD COMMENTS AEGARDING BUADEN ESTIMATE TO THE RECORDS AND REPOATS MANAGEMENT BRANCH (P4)30), U.S. NUCLEAR REGULATORY COMMISSION. WASHINGTON, DC 20555, AND TO 1ME PAPERWORK REDUCTION PROJECT (31504)104). OFFICE OF MANAGEMENTAND BUDGET, WASHINGTON, DC 20503.

FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3)

SEQUENTIAL ~I'>W REVISION NUMBER NUMBER 0 5 0 0 0 OF TEXT /// morP 4P4ce /4 mSIdnd, II44 Pddirion4/ /VRC Form 366AS / (12)

Abstract (continued)

Immediate corrective action was taken to test the HEPA filter in accordance with Technical Specification requirements. This test, performed on February 2, 1991 showed the SGT HEPA filters were fully capable of performing their design function.

Further, a review of plant records showed the downstream HEPA filters have not been changed out since plant startup which indicates they would have been fully functional if required. Therefore, this event posed no threat to the health and safety of either the public or plant personnel since the filters would have functioned per design in the event of an accident condition.

Plant Conditions Power Level - 10(C Plant Mode - 1 Event Descri tion On February 1, 1991 at 2100 hours0.0243 days <br />0.583 hours <br />0.00347 weeks <br />7.9905e-4 months <br /> a review of techniques for testing the Standby Gas Treatment (SGT) High Efficiency Particulate Air (HEPA) downstream filters indicated that methods used were not in compliance with the Technical Specifications due to inadequate air-aerosol mixing under test conditions. This condition was discovered by Plant Engineers during a detailed review of techniques used for testing the Charcoal Adsorber Filters during plant startup. The review was accelerated due to concerns raised by the NRC Resident Inspector.

At WNP-2 the SGT, in conjunction with other systems, provides a means of controlling and minimizing leakage from the Primary Containment to the outside atmosphere during Primary Containment accidents such as a Loss of Coolant Accident (LOCA). There are two SGT trains consisting of Moisture Separators, Electric Heaters, Pre-filters, HEPA filters, Car'bon Adsorber filters, and downstream HEPA filters followed by redundant fans to draw air through the trains. The purpose of the downstream HEPA filters is to capture any carbon fines that might be carried through by the air flow. The carbon fines, under conditions of an actual demand, could be radioactive.

The downstream HEPA filters also serve as a final barrier in the event of failure of the upstream HEPA filters.

The specific methods used in Surveillance Procedure, PPM 7.4.6.5.3.5, SGT System HEPA Dioctyl Phthalate (DOP) Test and Visual Inspection, were not adequate to meet the requirement in Technical Specification Paragraph 4.6. 5.3.b. This paragraph requires that at least once per 18 months each SGT subsystem is to be demonstrated to be operable by "....verifying that the subsystem satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05% and uses the test procedure guidance in Regulatory Positions C.5.a, C.5.c, and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978.....". A key provision of this requirement is to provide for adequate air-aerosol mixing under test conditions. A review of plant records showed that the periodic testing to meet the requirements of this surveillance were completed. However, the testing method used did not assure sufficient air-aerosol mixing for the test of the downstream HEPA filters.

Specifically, the DOP injection manifold established during startup testing for the downstream HEPA filters was not used for the surveillance testing.

NRC Form 366A (669)

9 NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (64)9) APPROVED OMB NO. 31500104 EXPIRES.I 4/30/92 ESTIMATED BURDEN PER RESPONSE TO COMPLY WTH THIS LICENSEE EVENT REPORT (LER) INFORMATION COLLECTION REQUESTI 503) HRS. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS TEXT CONTINUATION AND REPORTS MANAGEMENT BRANCH (F630). U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555, AND TO 1HE PAPERWORK REDUCTION PROJECT (315001041. OFFICE OF MANAGEMENTAND BUDGET, WASHINGTON, DC 20503, FACILITY NAME (1) DOCKET NUMBER (2) I.ER NUMBER (6) PAGE (3)

YEAR SEQUENTIAL REVISION NUMBER NVMSER Washington Nuclear Plant - Unit 2 o s o o o 9 0 0 0 3 0 0 03oF 0 4 TEXT /// mao SPoco /4 Ioqv/Iod, ooo odd/ceno///RC %%dmI 35549/ ((7)

Immediate Corrective Action The Surveillance Test Procedure, PPN 7.4.6.5.3.5, was modified to allow the downstream HEPA to be tested in accordance with Technical Specification requirements. The modification assured adequate mixing in the air-aerosol stream the upstream HEPA filter during testing of the downstream HEPA filter and by'emoving using the same injection point used for the upstream HEPA. This, testing was completed at 1138 hours0.0132 days <br />0.316 hours <br />0.00188 weeks <br />4.33009e-4 months <br /> on February 2, 1991.

Further Evaluation and Corrective Action A. Further Evaluation

1. This event is being reported per the requirements of 10CFR50173(a)(2)(i)(B) as ".....Any operation or condition prohibited by the plant's Technical Specifications......".

2. Further evaluation of the testing conducted during startup in 1983 disclosed that because of the proximity of the downstream HEPA filter to the injection port, special test rigging was required for a successful test. A special injection manifold was manufactured to allow proper mixing of the air and aerosol spray. Conduct of the In-Place Test without the manifold (or similar device) would result in invalid test results.

3. Initial Start-up Testing and Acceptance Testing conducted in October of 1 983 prior to plant start-up demonstrated satisfactory compliance to the sta'ted criteria utilizing the Dioctyl Phthalate (DOP) distribution

'anifold. The Star tup Engineer who performed the Startup Test was a contract employee who left the site, shortly after the test was completed.

The Technical Staff Engineer who received the system after the completion of acceptance testing left the Supply System within a few months without a turnover to the follow-on engineer.

4. After the start-up testing was completed the test was converted to a simplified procedure for periodic Surveillance Testing. The first Surveillance Test (ST) was performed in September,1984. This test was limited to testing one of the upstream HEPA filters which had been replaced. No testing of a downstream HEPA filter was accomplished which precluded the need for the DOP distribution manifold.

5. The Engineer who participated in the first ST was transferred to a different job that placed him outside the review cycle for any changes to the procedure. In the mean time the decision was made to perform the test without the help of the contractor when it came due the next time.

However, the procedur e was not modified to reflect this decision.

6. The ST was again run in May 1986 with the intent of testing all four HEPA filter banks. Without the guidance of the contractor and without a detailed procedure the test was run without installing the DOP injection manifold. The DOP was injected through a port between the upstream and downstream HEPA filters. This application did not meet the requirements NRC F oIm 366A (669)

NRC FORM 366A (64)9)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION t US. NUCLEAR REGULATORY COMMISSION t APPROVED 0MB NO. 31504)104 EXPIRES: 4/30)92 ESTIMATED BURDEN PER RESPONSE TO COMPLY WTH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS, FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS AND REPORTS MANAGEMENT BRANCH IP4)30), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555. AND TO 1HE PAPERWORK REDUCTION PROJECT (31500104), OFFICE OF MANAGEMENTAND BUDGET, WASHINGTON, DC 20503.

FACILITY NAME (1) DOCKET NUMBER (2) LF R NUMBF R (6) PAGE (3)

YEAR SEQUENTIAL semi( REVISION NUMBE II NUMSER Washington Nuclear Plant - Unit 2 0500O 4 oF 0 4 TEXT (IImare eJ>>oe Js rer)IIJred, Iree eddr)'rar>>l FJRC Farm 3664'4 J (17)

7. In the absence of any other guidance the procedure was permanently modified to reflect the experience of the last ST and was wr itten without reference to using a contractor. Subsequent testing, of the SGT trains was conducted without the DOP injection manifold.

8. The root cause of this event was inadequate work practices, inadequate procedures, and less than adequate supervisory oversight. A Plant Engineer failed to incorporate detailed methods required to satisfactorily conduct the surveillance tests. The surveillance test procedure, PPM 7.4.6.5.3.5 did not contain the requirement for, or the direction to, test the downstream HEPA filters in accordance with Technical Specification requirements. Management programs were in place to detect this omission but were not effectively implemented.

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

B. Further Corrective Action

l. The Su< veillance Test Procedure, PPM 7.4.6. 5.3.5 will be permanently revised to include the proper method of testing the downstream SGT HEPA filters.

2. Other Plant Surveillance procedures associated with HEPA filter testing will be reviewed to assure they meet all applicable requirements as established during startup testing.

Safet Si nificance There is no safety significance associated with this event. Initial Star tup testing showed the downstream HEPA filters were functional. The filters have never been changed and the recent test conducted on February 2, 1 991 showed the filters remained capable of performing to Technical Specification requirements.

Similiar Events There are no similiar events. LER 88-009 reports an event where this surveillance (PPM 7.4.6.5.3.5) was not performed at the required time. That event is not similiar since it did not involve a problem with the method of testing.

EIIS Information Text Reference EI IS Reference

~Sstem ~tom onent Standby Gas Treatment (SGT) BH High Efficiency Particulate Air (HEPA) FLT Filters Primary Containment BT NRC Form 366A (64)9)

f "I