ML18017A918

LER 99-008-00:on 991008,CR Emergency Filtration Sys Tech Specs Occurred.Caused by Site Personnel Failed to Recognize That Blocking Open CR Emergency Filtration Sys.Procedures Revised.With 991008 Ltr

ML18017A918
Person / Time
Site:	Harris
Issue date:	10/08/1999
From:	Brooke Clark, Ellington M CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HNP-99-155, LER-99-008-01, NUDOCS 9910210297
Download: ML18017A918 (9)

Text

I CATEGORY 10 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9910210297 DOC.DATE: 99/10/08 NOTARIZED: NO DOCKET ¹ FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION ELLINGTQN,M.'arolina Power & Light Co.

CLARK,B.H. Carolina Power 6 Light Co.

RECXP.NAME RECIPIENT AFFILIATXON

SUBJECT:

LER 99-008-00:on 991008,CR emergency filtration sys Tech C Specs occurred. Caused by site personnel failed to recognize that blocking open CR emergency filtration sys.Procedures A revised. With 991008 ltr. T DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE:

TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc. E NOTES:Application for permit renewal filed. 05000400 G 0

RECIPXENT COPIES RECIPIENT <cop xmas ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL R LPD2-2 1 1 LAUFER,R. 1 1 Y

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

'E NOTE TO ALL "RZDS" RECIPIENTS:

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

Carolina Power & Light Compariy Harris Nuclear Plant PO Box 165 New Hill NC 27562 OCT 8 1999 U.S. Nuclear Regulatory Commission Serial: HNP-99-155 ATTN: NRC Document Control Desk '0CFR50.73 Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT UNIT 1 DOCKET NO. 50-400 LICENSE NO. NPF-63 LICENSEE EVENT REPORT 1999-00S-00 Sir or Madam In accordance with 10CFR50.73, the enclosed Licensee Event Report is submitted. This report describes a condition which resulted in exceeding the requirements of Technical Specifications for the Control Room Emergency Filtration System.

Sincerely, B. H. Clark General Manager Barris Plant MSE/mse Enclosure c: Mr. J. B. Brady (HNP Senior NRC Resident)

Mr. R. J. Laufer (NRC-NRR Project Manager)

Mr. L. A. Reyes (NRC Regional Administrator, Region Il)

$ C' 99'i02i0297 9'9i 008 PDR ADQCK 05000400 S PDR 5413'Shearon Harris Road New Hill NC

NRC FORM 366 APPROVED BY OMB NO. 3'150-0'104 EXPIRES 06/30/2001 U.S. NUCLEAR REGULATORY COMMISSION Estimated burden per response to comply with this mandatory infermstior IS 1996) collecbon request 50 hrs. Reported lessons learned sre incorporated intr the liCenSing prOCeaa Snd fed baCk IO induauy. FOIWSrd COmmentS regardrnt LlCENSEE EVENT REPORT (LER) burden estimate to the information snd RNxxds Management Branch {T<

F33), U.S. Nuclear Regulatory Commisskxr. Washington, DC 205550001 snd to the paperwork Reduction project (31500I04). office of Msnsgemen

{See reverse for required number ot snd Budget. Washington. DC 20503. II an krformabon collection does no display s currenuy valid OMB control number, the NRC msy not conduct o digits/characters tor each block) sponsor, snd a person is not required to respond to. the informalior FACILITYNAME'1I DOCKET NUMBER lzi PAGE I3I 1 OF 3 Harris Nuclear Plant, Unit 'l 05000400 TITlE lel Control Room Emergency Filtration System Technical Specification Noncompliance MONTH DAY YEAR YEAR srauENTIAL REvrslON MONTH DAY YEAR FACILITYNAME DOCKET NUMBER NVMBEA NVMBER 06 04 1997 1999 - 008 00 . 10 08 1 999 FACILITYNAME DOCKET NUMBER 05000 OPERATING MODE (B) 20.2201(b) 20.2203(s){2)(v) X 50./3(el{2)(i) 50.73{a)(2) {viii]

POWER 000 20.2203(s)(1) 20.2203(s)(3)(i) 50.73(a) (2)(ii) 50.73(s) {2){x)

LEVEL ('101 20.2203(a)(2)(il 20.2203{el(31(ii1 50.73(sH2) (iii) 73.71 20.2203(sl(21(ii) 20.2203{SN4) 50.73(s)(2)(iv) OTHER 20.2203(s) (2) (iii) 50,36{0) l1) 50.73(s) (2) (v) Specify In Abstract below 20.2203(s) {2){iv) 50.36(c)(2) 50.73(a)(2) (vii) or in NRC Form 366A NAME TELEPHONE NUMBER Orrearde Area Coca)

Mark El{ington, Senior Analyst - Licensing {919) 362-2057 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN TH IS REPORT 13 CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TO EPIX To EPIX EXPECTED MONTH DAY YEAR YES NO (lf Yes, complete EXPECTED SUBMISSION DATE).

During four refueling outagcs (RFOS, RFO6, RFO7, and RFO8) with the HSIT{s Nuclear Plant (HNP) shutdown, HNP failed to comply with Tcchnical Specifications (TS) 3.7.6 "Control Room Emergency Filtration System." During these four occasions, the pressure boundary doors for thc HNP Control Room Emergency Filtration System (CREFS) werc blocked open to a))ow electrical cables to pass through the opening. Blocking open pressure boundary doors for the CREFS would require additional operator actions to restore the pressure boundary in the event of an accident. HNP TS 4.7.6.d.3. requires CREFS to bc demonstrated operable by verifying the system maintains the control room at a positive pressure of greater than or equal to 1/8" Water Gauge at less than or equal to a pressurization flow of 315 cfm rclativc to adjacent areas during system operation. With the CREFS doors blocked open, HNP would be unablc to meet the requirements of this surveillance to demonstrate operability. The additional operator action of unblocking thc prcssure boundary doors had not been adequately reviewed with regards to design basis and to licensing basis requirements.

Therefore, with the CREFS doors blocked open in modes 1-4, both trains of CREFS would bc inopcrablc and TS 3.0.3 would be entered.

This condition was identified during RFO8 and documented in HNP condition report (CR) 98-03149. The initial investigation of CR 98%3149 incorrectly determined that the CREFS remained in an operable condition. However, based on further review and evaluation, it was determined on September 8, 1999 that thc configuration estab) ishcd during RFO8 caused the CREFS to be inoperable for approximately 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and TS 3.0.3 should have been <<ntcrcd. The exact length of time that the CREFS was inoperable during RFOS, RFO6, arid RFO7 could not be determined.

Cause of this TS violation: Site personnel failed to recognize that blocking open Control Room Emergency Filtration System boundary doors was a change to thc facility and as a result did not perform an adequate 10 CFR 50.59 review.

Corrective actions inc)udet (1) Revise HNP procedures EST-)04, OP-163.01, and AP-002 to clarify CREFS pressure boundary requirements.

{2) Conduct training for applicable Operations and Engineering personnel concerning events documented in this report.

NRC FORM 388 I8 1SSSI

0 NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION I6 96)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATiON FACILITYNAME I1) DOCKET LER NUMBER IBI PAGE (3)

SEQUENTIAL REVISION OF' Harris Nuclear Plant,'nit 1 05000400 YEAR NUMBER NUMBER 2 1999 008 00 TEXT flfmeme space Is mqofnnf, ose addFtlonal copfes of HRC Form 366A/ I17)

I. DESCRIPTION OF EVENT During four refueling outages (RFO5, RFO6, RFO7, and RFO8) with thc HBITis Nuclear Plant (HNP) shutdown, HNP failed to comply with Technical Specifications (TS) 3.7.6 "Control Room Emergency Filtration System." RF05 occurred in the Spring of 1994. RF06 occurred in the Fall of 1995. RF07 occurred in the Spring of 1997. RF08 occurred in the Fall of 1998.

The following is a description of post accident operation of Control Room Emergency Filtration System (CREFS ). During an accident, the normal outside air intake for CREFS isolates and both emergency recirculation fans automatically start. Following verification of isolation of control room ventilation, an operator places onc of the two emergency filtration units in standby. Next, thc operator selects and opens one emergency outside air intake to pressurize the control room. The NRC reviewed and approved certain operator actions to pressurize the control room but did not specifically include manual closing of pressure boundary doors.

CREFS boundary doors at HNP are designed with two doors in series for each passage out of the control room. Either in series door can provide an adequate CREFS ventilation pressure boundary. The condition described in this report concerns two doors in series being blocked open simultaneously.

On four occasions, pressure boundary doors for the HNP Control Room Emergency Filtration System (CREFS) were blocked open for the performance of surveillance test procedure EST-104, Incorc Thermocouplc and RTD Cross Calibration Data Compilation. The CREFS boundary doors werc blocked open to allow electrical cables to pass through the opening. Blocking open pressure boundary doors for thc CREFS would require additional operator actions to restore thc pressure boundary in the event of an accident. HNP TS 4.7.6.d.3. requires CREFS to be demonstrated operable by verifying the system maintains thc control room at a positive prcssure of greater than or equal to I/8" Water Gauge at less than or equal to a pressurization flow of 315 cim relative to adjacent areas during system operation. With the CREFS doors blocked open, HNP would be unable to meet the requirements of this surveillance to demonstrate operability. The additional operator action of unblochng thc pressure boundary doors had not been adequately reviewed with regards to design basis and to licensing basis requirements. 'Iherefore, with the CREFS doors blocked open in modes IA, both trains of CREFS are considered inoperable and TS 3.0.3 would be entered.

On April4, 1994, HNP surveillance test procedure EST-104, Incore Thermocouple and RTD Cross Calibration Data Compilation, was revised to provide for data collection and evaluation using test equipment which would require temporary electrical leads to bc connected between the control room and an adjacent process, instrumentation, and control cabinet room (PIC room). Thc connection of the temporary electrical leads requires CREFS boundary doors to be blocked open. The revision and associated 10'FR 50.59 evaluation'neglected to analyze the effect of blocking open CREFS boundary doors in a mode which requires CREFS to be operable.

This surveillance test (EST-104) has been performed during each refueling outage since RFO5. Therefore, HNP has violated TS 3.7.6 each refueling outage since April 1994 (a total of four refueling outages) during the performance of EST-104. Additionally, other HNP procedures either permit or do not clearly prohibit blocking open CREFS doors. Operations procedure OP-163.01 "ERFIS Support Systems" provided similar guidance on allowing CREFS boundary doors to be blocked open. In addition, Administrative Procedure, AP-002 "Plant Conduct Of Operations" also provided information that could be misunderstood by the plant staff in determining CREFS boundary door requirements. Therefore, other circumstances of CREFS doors being blocked open may have occurred but werc not formally documented.

condition was identified during RFO8 and documented in HNP condition report (CR) 98-03149. The initial investigation of

'his CR 98-03149 incorrectly determined that thc CREFS remained in an operable condition. However, based on further review and evaluation, it was determined on September 8, 1999 that the configuration established during RFO8 caused the CREFS to be inoperable for approximately 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and TS 3.0.3 should have been entered. The exact length of time that the CREFS was inoperable during RFO5, RFO6, and RFO7 could not be determined.

NRC FORM 366 IB-96)

I a

NRC FORM 366A U.S. NUCLEAR REGUlATORY COMMISSION I6 BB)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION DOCKET LER NUMBER )6) PAGE )3)

FACILITYNAME I 1 )

SEQUENTIAL REVISION Harris Nuclear Plant, Unit 1 osoooaoo YEAR NUMBER 3 OF 3 1999 008 00 TEXT 6/more space ls rerpr)rert, rrse eddiVorral copies oMRC Fomr 366AI )17)

II. CAUSE OF EVENT The cause of this event was that site personnel failed to recognize that blocking open Control Room Emergency Filtration System boundary doors was a change to the facility and as a result did not perform an adequate 10 CFR 50.59 review.

IIL SAFETY SIGNIFICANCE

'i%ere werc no actual safety consequences as a result of this event. The doors are located in the control room ventilation area.

Therefore, operators could easily direct closure of the applicablc doors should an accident occur. Pressurizing thc main control room requires manual operator actions at HNP to place'onc train of CREFS in standby and to open an emergency outside air

. intake. Additional manual actions to shut control room doors would not significantly impact the time to pressurize the control room. This report is being submitted pursuant to the criteria of 10CFR50.73(a)(2)(i) for any operation or condition prohibited by the plant's Technical Specifications.

IV. CORRECTIVE ACTIONS (I) Revise HNP procedures EST-104, OP-I63.01, and AP402 to clarify CREFS pressure boundary requirements (2) Conduct training for applicable Operations and Engineering personnel concerning events documented in this report..

V. SIMILAREVEI~

A review was completed of NRC guidance related to thc McGuirc Nuclear Station entitled "Safety Evaluation by the OAice of Nuclear Reactor Regulation TIA 98008 Use of Manual Compensatory Actions on Control Room Emergency Ventilation Systems Docket Nos. 50-369 and 50-370". Thc reviewed McGuire activity was a breech of the Main Control Room (MCR) penetration seal. Other examples of work performed using this rule include the following: pulling new cables into thc control room and propping open control room doors to allow routing of temporary cable through thc doors. McGuire used a "three minute rule" which allowed breaching any MCR boundary as long as contingency measures were in place to ensure that the system could be scaled within three minutes. The McGuire dose analysis did not take any credit for the MCR HVAC system actuation within the first three minutes of an accident. The NRC concluded that the 50.59 did not properly consider whether a possibility for a malfunction of a different type was created. Also, the possibility of a new failure mechanism was not properly considered. The NRC concluded that in the McGuire case, "it is not appropriate for a licensee to purposefully degrade or create a non-conforming condition and then use a compensatory measure as a means of bypassing Technical Specifications LCO Action Statements." The NRC went on to say that McGuire TS has a surveillance requirement which verifies that either train of the MCR Ventilation System can maintain a positive pressure within the control room boundary. Ifthe MCR HVAC System duct work or control room boundary is breached such that the TS requirements cannot be met then, the appropriate TS actions need to be entered. 'Ibis would mean entry into TS 3.0.3 when in MODES 1, 2, 3 or 4. Thc NRC found that the three minute rule does not provide suQicient time or guaranty that thc surveillance requirement could be performed or that the newly sealed breaches can maintain the boundary positive pressure.

HNP determined thc McGuire NRC guidance was applicable to similar situations documented in this LER. There were no previous LERs at HNP related to blocking open CREFS boundary doors.