ML17286B003

LER 91-018-00:on 910712,control Room Emergency Filtration & Standby Gas Treatment Sys Carbon Absorber Surveillances Not Performed Per TS 4.7.2 Requirements.Caused by Inadequate Procedures.Carbon replaced.W/910812 Ltr

ML17286B003
Person / Time
Site:	Columbia
Issue date:	08/12/1991
From:	Arbuckle J, John Baker WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-91-018, LER-91-18, NUDOCS 9108220273
Download: ML17286B003 (7)

Text

ACCELERATED DISTRIBUTION DEMONSTPA.TION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9108220273 DOC.DATE: 91/08/12 NOTARIZED: NO ~ DOCKET FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION ARBUCKLE,J.D. Washington Public Power Supply System BAKER,J.W. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 91-018-00:on 910712,control room emergency filtration &

standby gas treatment sys carbon absorber surveillances not performed per TS 4.7.2 requirements. Caused by inadequate D procedures. Carbon replaced.W/910812 ltr.

DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE:

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

NOTES: A III 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/DSP 2 2 NRR/DET/ECMB 9H 1 1 NRR/DET/EMEB 7E 1 1 NRR/DLPQ/LHFB10 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/SICB8H3 1 1 NRR/~DS'2/QPLB8 D1 1 1 NRR/DST/SRXB 8E 1 1 REGDIHPD 02 1 ' 1, RES/DSIR/EIB 1 1 RGN5 FILE 01 1 EXTERNAL EG&G BRYCE I J ~ H 3 3 L ST LOBBY WARD 1 1 NRC PDR 1 1 NSIC MURPHY,G.A 1 1 NSIC POORE,W. 1 1 NUDOCS FULL TXT 1 1 o D pos5&->~ +

A D

NOTE TO ALL "RIDS" RECIPIEiVSS:

PLEASE HEI.P US TO RFDUCE WASTE! CONTACT THE DOCUivIENT CONTROL DESK, ROOi~l PI-37 (EXT. 20079) TO L!.I,"~IINATEYOUR LISTS FOR DOCUb'IEiNTS YOU DON'T NEED!

M IE FROiW DISTRII3UTION 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, Washlngion 99352 Docket No. 50-397 August 12, 1991 Document Control Desk U.S. Nuclear Regulatory Commission Hashington, D.C. 20555

Subject:

NUCLEAR PLANT NO. 2 LICENSEE EVENl'EPORT NO.91-01B

Dear Sir:

Transmitted herewith is Licensee Event Report No.91-01B for the HNP-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.H. Baker (M/D 927M)

HNP-2 Plant Manager JHB:ac

Enclosure:

Licensee Event Report No.91-01B cc: Mr. John B. Martin, NRC Region V Mr. C. Sorensen, NRC Resident Inspector (M/D 901A)

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

NRC Resident Inspector walk over copy

10822027=-: P108i2 PDF ADCiCf: C>" 000:".";~7 S PDR r>)p~

NRC FORM 366 V.S. NUCLEAR REGULATORY COMMISSION 9)

'6$

APPROVED 0MB NO. 31504)104 EXPIRES: 4/30/92

>>TIMATEO BURDEN PER AESPONSE TO COMPLY WTH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS. FORWARD LICENSEE EVENT REPORT ILER) COMMENTS REGARDING BURDEN FSTIMATE TO THE RECORDS AND REPORTS MANAGEMENT BRANCH (P$ 30), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON. OC 20555, AND TO THE PAPERWORK REDUCTION PROJECT (31504104), OFFICE OF MANAGEMENTAND BUDGET, WASHINGTON, DC 20503.

FACILITY NAME HI DOCKET NUMBER 12( PA E Washin ton Nuclear Plant - Unit 2 0 5 0 0 03 7 1,OFO

"'"'"'on'trol Room Emergency Filtration and Standby Gas Treatment System Carbon Absorber Surveillances Not In Com liance With Tech. S ec. Due to Less Than Ade uate Procedures FVENT DATE (5) LER NUMBER (6) REPORT DATE (7I OTHER FACILITIES INVOLVED IS)

MONTH DAY YEAR YEAR o&n SEQUENTIAL '<<>>ic MONTH DAY YEAR FACILITYNAMES DOCKET NUMBER(6)

Noi NUMBER .x.S NUMBER 0 5 0 0 0 0 7 1 2 9 1 9 1 018 00 08 1 2 9 1 0 5 0 0 0 THIS REPORT IS SUBMITTED PURSUANT TO THE RLOUIREMENTS OF 10 CFR (): IChtck one or mort of the foffowinpl (Ill OPERATING MODE (5) 20.402(trl 20.405 (cl 50.73(e I (2)(lv) 73.71(BI POWER 20.405( ~ ) (I I BI 50.36( ~ 50.73(el(2)(v) 73.71( ~ )

LEYEL 0 OTHER ISpecify in Ahsvtct l(II'0.36(cl(2) 0 0 20.40S(el(1)(6) 50.73(e)(2) (vil) end In FtxL HIIC Form 'elow 20.40S( ~ ) II ) (ilil X 60.73( ~ )(2)(ll 60.73(e)(2)(vill) IA) 3664) 20.405 (e IllI (lv) 50.73(e I (2) l ii) 50.73(el(2)(vlB) (BI 10.405( ~ )(1)(v) 50.7 3 (e I (2) (i ill 50,73(e) (1) (x) 1 LICENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER AREA CODE 5 0 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCAIBEO IN THIS REPORT (13)

MANVFAC MANVFAC EPORTABLE CAUSE SYSTEM COMPONENT. TO NPRDS CAUSE SYSTEM COMPONENT TVRER TUREA TO NPRDS kA, cr.. 'ciSA,"Ag

=o "" an '~VN y>>6 i>>

@op>> ex.

Po&>> .,c c(Sn ':A 9>>>> x .'~PS!C.X SUPPLEMENTAI. REPORT EXPECTED (14) MONTH DAY YEAR EXPECTED SUBMISSION DATE I15)

YES Ilf yts, compiere EXPECTED $ (f64IISSIOH DATE l X No ABSTRACT ILimit to ftr)r) sptcts. i.t., epproximettiy fifrten sinfrt specs typewritten iinesl (16)

On July 12, requirements 1991 pertaining it was determined that the method for implementing the'surveillance to the Control Room Emergency Filtration System carbon absorber was not in compliance with the Technical Specifications. The removed carbon was not being sampled and tested upon replacement as required by Technical Specification 4.7.2. This discrepancy was discovered when a Plant Maintenance Engineer questioned the sampling requirement when the carbon was being replaced a recent 18-month surveillance test for Division A of the system. On August 'uring 8, 1991, as a result of a further corrective action for this event, one additional reportable instance was identified with regard to the Standby Gas Treatment (SGT)

System. From an evaluation of other potential areas of concern, it was determined that on April 18, 1990 the carbon was replaced in the SGT, Division B, absorber filter and a sample was not tested.

The cause of these events was less than adequate procedures due to misinterpretation of the Technical Specification requirements for ensuring that the efficiency of the carbon absorber met the provisions and intent of Regulatory Guide 1.52. The Control Room Emergency Filtration System procedures provided the option of removal of the carbon absorber in lieu of testing, but did not require followup testing. The Standby Gas Treatment System procedures did not specify that followup testing was required if the carbon was to be replaced.

NRC F orm 366 (6$ 9)

NRC FORM 366A (669 I LICENSEE E TEXT CONTINUATION U.S, NUCLEAR REGULATORY COMMISSION T REPORT ILER) I APPROVED OMB NO. 31500104 EXPIRES: 4/30/62 MATED BUADEN PER RESPONSE TO COMPLY WTH THIS ORMATION COLLECTION REOUESTr 60JI HAS. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS AND REPORTS MANAGEMENT BRANCH (F430), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555, AND TO 1HE PAPERWOAK REDUCTION PROJECT (31604)104). OFFICE OF MANAGEMENTAND BUDGET, WASHINGTON, DC 20503.

FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6I IIAGE (3)

YEAR WQP~

BECUENTIAL f2o2 REvrsroN

>O,S NUMBER NUMBER Washington Nuclear Plant - Unit 2 0 5 0 0 0 9 '1 8 0 0 OF 0 5 TEXT /I/ mare elreoe /4 rer)or)ed, e>> eddlrrorre/ HRC Farm 36643/ (I2)

Abstract (continued)

Immediate corrective action consisted of declaring the system inoperable, entering the applicable Limiting Condition for Operation (LCO) and testing the removed carbon absorber. Further corrective action consists of revising applicable Control Room Emergency Filtration System procedures, performing an evaluation to determine if similar discrepancies had occurred in systems other than Control Room Emergency Filtration, and revising applicable Standby Gas Treatment System procedures. This event posed no threat to the health and safety of either the public or Plant personnel.

Plant Conditions Power Level - OX Plant Mode - 4 (Cold Shutdown)

Event Descri tion On July 12, 1991 it was determined that the method for implementing the surveillance requirements pertaining to the Control Room Emergency Filtration System carbon absorber was not in compliance with the Technical Specifications. The removed carbon was not being sampled and tested upon replacement as required by Technical Specification 4.7.2. This discrepancy was discovered when a Plant Maintenance Engineer questioned the sampling requirement when the carbon was being replaced during a recent 18-month surveillance test for Division A of the system.

Plant Technical Specification 4.7.2 requires in part that, "Each control room emergency filtration system train shall be demonstrated OPERABLE . . . At least every 18 months and after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal absorber operation by verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Guide 1.52 meets the laboratory testing criteria of Regulatory Guide 1.52 for a methyl iodide penetration of less than 1.0 percent."

However, Plant procedures for the Control Room Emergency Filtration System, Divisions A and B, carbon absorber surveillance testing provided direction that, the absorber material was considered acceptable if the methyl iodide penetration is less than 1.0 percent, or if the absorber material was re laced. The purpose of these e car on absorber in the filter procedures is to ensure a e e )c)ency o units meets the requirements of Regulatory Guide 1 .52.

On August 8, 1991, as a result of a further corrective action to evaluate other potential areas of concern pertaining to this event, one additional reportable instance was identified with regard to the Standby Gas Treatment (SGT) System. From the evaluation it was determined that on April 18, 1990 the carbon was replaced in the SGT,.Division B, absorber filter and a sample was not tested. This is discussed in additional detail in the "Further Evaluation Section" of this LER.

NAC Form 366A (66SI

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (6491 APPROVED 0MB NO. 31500(OE EXPIRES: EI30/92 MATED BURDEN PER RESPONSE TO COMPLY WTH THIS LICENSEE E REPORT (LER) RMATION COLLECTION REQUEST: 50Al HRS. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS TEXT CONTINUATION AND REPORTS MANAGEMENT BRANCH (P.530), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555, AND TO THE PAPERWORK REDUCTION PROJECT (31600'104). OFFICE OF MANAGEMENTAND BUDGET, WASHINGTON, DC 20503.

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

YEAR .jd% SEQUENTIAL REVISION N NVMSER NVM ER Washin ton Nuclear Plant - Unit 2 0 5 0 0 0 3 9 7 9 1 018 0 0 0 3 " 5 TEXT (d moro EPooo JE need, uro oddro'onol HRC Fonrr 36642) 1(T)

Immediate Corrective Action Control Room Emergency Filtration System Filter Units WMA-FU-54A and WMA-FU-54B were declared inoperable, the applicable Limiting Condition for Operation (LCO) was entered and a sample of the removed carbon was submitted to an off-site laboratory for testing.

Further Evaluation and Corrective Action A. Further Evaluation

1. This event is reportable in accordance with the requirements of 10CFR50.73(a)( 2)(i )(8 ) as a condition prohibited by the Plant' Technical Specifications.

2. There were no structures, systems or components that were inoperable at the start of this event that contributed to the event.

3. The cause of this event is Less Than Adequate Procedures due to misinterpretation of the Technical Specification requirements for ensuring that the efficiency of the carbon absorber met the provisions and intent of Regulatory Guide 1.52. When the procedures were developed (and through subsequent revisions) it was believed that the sampling requirement of Technical Specification 4.7.2 applied only being replaced, and that replacement was a more conservative approach to if the carbon absorber was not meeting the Technical Specification requirement. However, the carbon should have been tested following replacement to validate the maximum run-time and the surveillance frequency.

B. Further Corrective Action

l. On July 25, 1991 satisfactory carbon absorber testing results of the removed sample from Division A of the system were received from the off-site laboratory. The results were 99.99 percent efficiency. Efforts are currently in progress to test a sample from Division 8 of the system.

2. Plant Procedures (PPM ) 7.4.7.2.3A, "Control Room Division A Filtration

'System Carbon Absorber Test," and PPM 7.4.7.2.3B, "Control Room Division B Filtration System Carbon Absorber Test," were revised and approved to remove the option of carbon absorber removal, without followup testing.

The procedure requires that the methyl iodide penetration test shall be verified to be less than 1.0 percent penetration and the results shall be known within 31 days from the date the sample was obtained.

N R C Form 366 A (649)

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION APPROVED 0MB NO. 3160010l (669) E XP I R ES: l/30/92 MATED BURDEN PER RESPONSE TO COMPLY WTH THIS LICENSEE E T REPORT (LER) ORMATION COLLECTION REQUEST: 500 HRS. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS TEXT CONTINUATION AND REPORTS MANAGEMENT BRANCH (F430), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555, AND TO THE PAPERWORK REDUCTION PROJECT (3150010l). OFFICE OF MANAGEMENTAND BUDGET. WASHINGTON, DC 20503.

FACILITY NAME (11 DOCKET NUMBER (2) LER NUMBER (6I PAGE (3)

YEAR 5?l SEQUENTIAL &+ REVISION NUMBER  ???9 NUM ER Washin ton Nuclear Plant - Unit 2 0 5 0 0 0 3 7 9 1 018 0 0 0 4 OF 0 TEXT ll/IIxNP J/Moo /J IR)ii?)od, IIJo oddio'wo/ jVRC Rmn 366AS / (IT)

3. An Engineering evaluation was performed to determine if similar problems had occurred in systems other than Control Room Emergency Filtration. As a result of the evaluation, one other reportable instance was noted where the carbon was replaced in Division B absorber filter of the Standby Gas Treatment (SGT) System, and a sample was not tested. The carbon absorber was replaced on April 18, 1990 and a sample was not obtained because no test canisters were available following replacement efforts (c'arbon sample testing was performed during a,subsequent surveillance on March 29, 1991).

The cause of this event is also Less Than Adequate Procedures due to misinterpretation of the Technical Specification requirements for ensuring that the efficiency of the carbon absorber met the provisions and intent of Regulatory Guide 1.52 as required by Technical Specification 4.6.5.3 (Standby Gas Treatment System Surveillance Requirements). The Standby Gas Treatment System procedures did not specify that'followup testing was required if the carbon was to be replaced. However, as with the Control Room Emergency Filtration System event the carbon should have been tested following replacement to validate the maximum run-time and the surveillance frequency..

Accordingly, applicable SGT System procedures are currently in the process of being revised to ensure that the required carbon material efficiency.

testing is performed.

This event is"also reportable in accordance with the requirements of 10CFR50.73(a)(2)(i)(B ) as a condition prohibited by the Plant's Technical Specifications.

Safet Si nificance There is no safety significance associated with this event. Previous surveillances of the Control Poom Emergency Filtration System carbon absorber have shown minimal degradation of the charcoal. Furthermore, in this particular situation, the test results for carbon absorber efficiency were 99.99 percent efficiency, which exceeds the Technical Specification acceptance criteria of 99 percent. With regard to the Standby Gas Treatment System, previous test history has also shown that the carbon efficiency has not degraded during the surveillance periods. Accordingly, this event posed no threat to the health and safety of either the public or Plant personnel.

NRC Form 366A (6J)9)

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (64) 9) APPROVED OMB NO. 31500104 EXPIRES: 4/30/92 ATED BURDEN PER RESPONSE TO COMPLY WTH THIS LICENSEE EV REPORT (LER) I eORMATION COLLECTION REQUEST: 500 HRS. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS TEXT CONTINUATION AND REPORTS MANAGEMENTBRANCH (P4)30), U.S. NUCLEAR REGULATORY COMMISSION. WASHINGTON, DC 20555, AND TO 1HE PAPERWORK REDUCTION PROJECT (31504))04). OFFICE OF MANAGEMENTAND BUDGET, WASHINGTON, DC 20503.

FACILITY NAME O) DOCKET NUMBER (2I LER NUMBER (6) PAGE (3)

$g

$ 8EQVE NVMEER L 'EAR REVISION NVMEEII Washington Nuclear Plant - Unit 2 o s o o o 3 97 9 1 018 0 0 0 5OF 5 TEXT /I/ rmorm epeoe le rrquked, Iree eddlo'one/ NRC Frrrrrr 36643/ (17)

Similar Events LER 89-003, "Missed Control Room Emergency Filtration System Charcoal Sampling Technical Specification Surveillance due to Misinterpretation of the Surveillance.

Requirement." This LER described an event where, if a sample was to be taken, the Supply System interpreted the Technical Specification as requiring that the sample be analyzed within 31 days of exceeding 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation. However, in this particular case, Division B of the system had operated for 933 hours0.0108 days <br />0.259 hours <br />0.00154 weeks <br />3.550065e-4 months <br />, which was a violation of Technical Specification 4.0.2 which states that the maximum time a surveillance interval can be extended is 25 percent of the surveillance interval.

As a result, procedures were revised to require that a charcoal absorber sample be taken when service time reaches 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br />, and that no more than 900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> (720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> plus 25 percent) be accumulated prior to taking the sample.

EI IS Information Text Reference EI IS Reference

~Sstem ~tom onent Control Room Emergency Fil tration System VH Carbon Absorber VH ABS Filter Units WMA-FU-54A and WMA-FU-54B VH FLT

'Standby Gas Treatment (SGT) System BH NRC Form 366A (669)