ML20029A847
| ML20029A847 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 02/28/1991 |
| From: | Azzarello R, Mcgaha J ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LER-90-019, LER-90-19, W3B5-91-0059, W3B5-91-59, NUDOCS 9103040377 | |
| Download: ML20029A847 (12) | |
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! February 28, _1991
) U.S. Nuclear Regulatory Commission ATTENTION: Document Control Dock 4 Washington, D.C. 20555 Subject Watorford 3 SES Docket No. 50-302 Licenso No. NPF-
Submittal of-Lt.4 a nven Report Contletnen:
Attached is Licensoo Event Ronort Number LER-90-019-01 for .
Waterford Steam Electric Station Unit 3. This Licensoo Event !
Report supplement is submitted to provido additional information resulting from investigation of the ovonts described including the reporting of an entry into Technical Specification 3.0.3 on December 14, 1990. This Licensoo Evont Report is submitted pursuant to-10CFR50.73 (a) (2) (1) .
Very truly yours,=
7 sg J.R. McGaha Gonoral Manager - Plant Operations JRM/KTW/rk Attachmont cc t - Mossrs. R.D. Martin G.-Florreich J.T. Wheolock - INPO Records Contor E.L .Blako D.L.-Wigginton .
NRC-Rosident Inspectors Offico
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On December 12 1990. with Waterford Steam Electric Station Unit 3 at 100%
power. Technien1 Specification (TS) Limiting Condition for Operation (LCO) 3.0.3 was entered when both trains of the Control Room Heating Ventilation and Air Conditioning (HVAC) System were declared inoperable due to a breach in the Control Room envelope. The breach in the Control Room envelope existed since December 5, 1990. wh(n a Control Room penetration fire seal was removed in accordance with . spproved Design Change. The root cause of this event is lack of suf ficient documentation and details of the Cont rol Room envelope boundary r,eals.
On December 14, 1990, the plant was operated in a TS LCO 3.0.3 condition for approximately one and one half hours while investigating a problern with the Control Room HVAC System. The root cause of this event is the combination of two failures. The Control Room recirculation damper failed in the Ntermediate position and the Control Room envelope had excessive leakage. As a result, the operability requirements of the Control Room HVAC System could not be met.
Operation in a TS LCO 3.0.3 condition is reportable as operation prohibited by plant TS. Calculations have shown that during each of these events the habitability of the Control Room would have been preserved during a high radiation or toxic chemical scenario; therefore, this event did not threaten the health and safety of the general public or plant personnel.
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0' l.L' _1 On Decettiber 12, 1990, engineers discovered fite seal (Ells Identifter-SEAL)
VIA0070 had been removed f rom around Fire Damper (FD)-45 (EIIS Identif der-DMp) in accordance with Design Change (DC)-3197 and as a renult, a breach in the Control Room (EIIS Identifier-NA) envelope existed. At 1045 hours0.0121 days <br />0.29 hours <br />0.00173 weeks <br />3.976225e-4 months <br /> on December 12, 1990, Technical Specification (TS) 3.0.3 was entered baoed on engineering judgement that the Control Room envelope would not maintain a 0.125" water gage (w.g.) differential pressure with the outside air in accordance with Surveillance Test procedure PE-$-004, " Control Room Air Conditioning System Surveillance." In addition, the consequences of a high radiation or toxic chemical seenario were unknown in the condition of fire seal VIA0070 being removed. This event is reportable no operation prohibited by plant TS.
DC-3197 was approved for construction on Septemb, 24, 1990. The scope of tais DC addressed a problem in which fire dampers vere found to be inoperabic due to the absence of an expansion space between the ffre damper and the surrounding wall. This expansion space is required to allow for thermal expansion of the damper assembly under fire conditions. The fire seal around FD-45 (penetration seal number VIA0070) was removed on December 5, 1990. DC-3197 f ailed to identify certain fire seals en being an air pressure barrier for the Control Room-envelope and the Reactor Auxiliary Building (RAB) (EIIS Identifier-NF).
The control Room envelope is designed to maintain a positive pressure of 0.125" w.g. or greatet with respect to the outside air, with a make up rate of 200 cubic feet per minute (cfm) or less, during the high radiation mode of operation.
The prensure and airflow limits are also used to test the leak tightness of the Control Room envelope for the toxic gan mode of operation, during which the system is in full recirculation with no outside air make up. The requirements are specified in the Final Safety Analysis Report (FSAR) and Regulatory Guides (RG) 1.78 and 1.95, wac e- asu ius.
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0 l1 01 3 1(1 1.ER 88-025 reported ftre barrier discrepancies due to procedural inadequacy, and committed to the corrective action of inspecting all fire barriers in accordance with Procedure ME-003-009, " Fire Walls, Floors, and Ceilings" and Procedure ME-003-006 " Fire 11arrier penet ration Seals." The inspection of the fire dampers was initiated in November 1988 and revealed that some fire dampers had not been installed per the manufacturer's requirements and fire test configurations. The concern is that the dampet s were not provided with adequate annular space between the fire dattper and surrounding wall to allow for thermal expansion of the dattper and seal material. This problem has existed since initial construction and could have resulted in the dampers not functioning properly in a fire condition due to binding.
A Station Modification Request (SMR) Fp-Oli vos initiated to correct penetration (Ells Identifier-PEN) seal, fire barrier, and f tre damper design dcficiencles identified during the 100% penetration seal inspection. The SMR was approved on February 12, 1990, and was later approved an DC-3197 on September 18, 1990.
DC 3197 provides for the field installation or mdification of approximately 228 seals, 25 dampera, and one fire barrier.
Fire seal VIA0070 was identified for modification in DC-3197. The penetration around FD-45 had been sealed with silicone foam during initial const ruccion.
Fire seal VIA0070 was evaluated in condition Identification (C1) 260111 on November 8, 1989, an having no requirement for fire protection and subsequently, the damper was declared inoperabic until the seal material around the damper could-be removed and replaced with an air seal, eaee is i m
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0 l1 0' 1 l1 sas a m u w,,e.1 m omwe sav .am .1o,, 0[4 on December 5, 1990, the following work van performed on seal VIA0070 in accordance with the DC:
- the retaining clorure angles f rom one side of the seal were removed to facilitate removal of the seal. !
the seal materini was removed from around the damper.
At this point, the plant was operating with a breach in the Control Koom envelope. There was approximately a 1/4" gap on the top and siden, and a 1/2" gap on the bottom, between the ventilation duct (Ells Identifier-DUCT) and the surrounding barrier wall.
l At approximately 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br /> en December 5,1990, a routine walkdown by an engineer noted that work in progress on two other senlo (penetration seal numbers V1A0255 and VIA0256), also part of DC-3197. could possibly breach the Control Room envelope. A discussion was held with several other engineers and after further evaluation, the engineers determined that the Control Room envelope had not been breached. The basis of this conclusion is that sheet metal had been installed during initial construction to f acilitete installation of the seals t.ad had provided a Control Room envelope pressure boundary.
On December 6, 1990 Nuclear Operations Construction (NOC) personnel were informed of the potential problem discovered with seals VTA0255 and V1A0256 '
A decision was made that each fire seal being removed should be carefully evaluated to determine if removal would cause a breach in the Control Room envelope. NOC personnel conducted a review of the fire scala that were !
currently being worked. No work was being done on fire seal VIA0070 during the review; therefore, seni VIA0070 was not ident! led as a potential proolem..
Engineering personel were directed to evaluate the method and consequences of i removing fire seals under DC-3197, with emphasis on the pressure boundary configuration for the Control Room envelope.
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.. <...x wer- a..,on On December 10, 1990. Design Engineering (DE) personnel vere informed of the potential problems with DC-3197. On December 11, 1990. DE personnel developed a list of 9 seals that were to be worked under DC-3197 which could possibly breach the Control Room envelope. On this lint, 5 reals weie identified as being curiently worked. These seals were VIA0039. VIA0046, VIA0255, VIA0250, and VIA0070. A cursory inspection was made of the five neals and the Control Room envelope appeared v. to be breached. The retaining angle had already been replaced on seal VIA0070 which masked sae fact that the penetration was breached, from a presnure boundary standpoint.
On December 12, 1990, another innpection was performed on the five seals and a determination was made that seal VIA0070 was breached because air flow pant the retaining angle was observed. TS 3.0.3 was entered at 1045 hours0.0121 days <br />0.29 hours <br />0.00173 weeks <br />3.976225e-4 months <br /> on December 12, 1990 as a result of engineering judgement, baned on the size of the breach and the affect on both Control Room Heating Ventilation and Air Conditioning UIVAC) System trains (E1IS Identifier VI) with respect to the operability require-ments of TS 3.7.6 A temporary seal was installed per Nonconformance Condition Identification (NCI) 27 Ull. The seal was determined to be operable based on engineering judgement. The HVAC system was observed to be capable of maintaining 0.125" w.g. positive pressure, ter Control Room indications, under normal operation without regard to the amount of make up air being used. No visible signs of leakage were noted around the seal. Administrative controls were implemented to maintain the pressure boundary integrity at the seal. TS 3.0.3 was exited at !!41 hours4.74537e-4 days <br />0.0114 hours <br />6.779101e-5 weeks <br />1.56005e-5 months <br /> on December 12, 1990.
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)l 3 ttas un mws enn a <wa en eu wc on .m v o n The root cause of this event is lack of sufficient documentation and details of the Control Room envelope boundary seals. There is no singic document that identifies any penetration seals as being a part of the pressure boundary for the Control Room envelope or as being associated with a TS requirernent. '
The other problems that contributed to this event weret
- DC 3197 inadequacies. Existing documentation was not thoroughly researched in the development of DC-3197.
- The HVAC system engineer was not included as part of the review process for DC 3197 in accordance with Nuclear Operation and Engineerinp, Construction procedures.
- Timely corrective netton van not taken by plant personnel upon initini discovery of the potenttal problems with the Control Room envel ope.
No specific methods exist to track or control work being performed l
on the Control Room envelope to ensure that the integrity of the Control Room envelope is maintained in modes for which it is required.
I Immediate corrective action was taken on December 12, 1990, to restore the I integrity of th, .ontrol Room envelope. All seal work affecting the Control Room nyelope was stopped until air seal details could be developed and remc- ...atallation trethods bet ter defined.
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(" 111 tuta m =.a==w w. wei ..c % a .nin As a follow-up to the corrective action taken under NCI 272811, Surveillance Procedure PE-5-004, " Control Room Air C:nditioning Systems Surveillance," van scheduled as a conservative measure to check the overall integrity of the Control Room envelope.
The acceptance criteria for Surveillance Procedure PE-5-004 requires that the Control Room Air Conditioning System maintain the Control Room at a positive pressure of greater than or equal to 0.125" w.g. relative to the outside atmosphere when operating the Control Room Ventilation System in a high radiation mode with an emergency outside air intake open.
Surveillance Procedure PE-5-004 was commenced at approximately 1930 hours0.0223 days <br />0.536 hours <br />0.00319 weeks <br />7.34365e-4 months <br /> on 1
December 14, 1990. The Emergency Filtration Unit 'A' (EIIS Identifier-VI-AHU) was engaged, in accordance with procedure, to provide the emergency outside air flov. The Emergency Filtration Units are started for the purpose of the Surveillance by inserting a test high radiation signal to the respective filtration unit. At approximately 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br />, attempts to adjust the recirculation damper (HVC-213A) for the Emergency Filtration Unit 'A' train failed to achieve greater than or equal to 0.125" w.g. Control Room differential pressure. HVC-213A indicated in the intermediate position on the Plant Monitoring Computer. At approximately 2130 hours0.0247 days <br />0.592 hours <br />0.00352 weeks <br />8.10465e-4 months <br />, Surveillance Procedure PE-5-004 was exited and an investigation of the HVAC system was commenced. The Emergency Filtration Unit 'B' was engaged to verify that no gross leakage existed in the Control Room envelope.
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Oli 0l8 M 1 l1 E, , - . . n.c ,. - - ,m n Once the Emergency filtration Unit ' It ' van engaged, the Emergency filtration Unit 'A' could not i a secured because sufficient differential pressure across the Emergency Filtration Unit 'B' van not developed and the test high radiation signal still existid on the Emergency Filtration t> nit ' A'. The Control Room envelope differential pressure van noted to be less than 0.125" w.g. with the maximum achievabic makeup air flow of 200 efm, while both Emergency Tiltration Units were running. The outside air flow of 200 cfm is the designed and balanced condition of the system with a f ailed open recirculation damper in one train.
After several minutes of running, the Emergency Filtration Unit 'B' tripped due to low differential temperature across the filtratiot nit.
TS LCO 3.0.3 was not entered at the time because the Control Room staff felt that there was no reason to doubt the operability of the Emergency Filtration Unit 'B' to pressurize the Control Room t o 0.12$" w.g. differential pressure.
Ilovever, as a result of the failed damper and unidentified leakage paths in the Control Room envelope. 0.125" w.g. differential pressure could not have been achieved and the plant was in fact, operating in a TS LCO 3.0.3 condition.
At approximately 2200 hours0.0255 days <br />0.611 hours <br />0.00364 weeks <br />8.371e-4 months <br /> on December 14, 1990. IIVC-213A van confirmed to be stuck in the intermediate position by local verification and as a result, the Emergency Filtration Unit 'A' train van declared inoperabic. Recirculation damper IIVC-213A was manually locked in the closed position. At approximately 2300 hours0.0266 days <br />0.639 hours <br />0.0038 weeks <br />8.7515e-4 months <br />. Surveillance Procedure PE-5-004 was performed utildr.ing the Emergency Filtration Unit 'B' and resulted in 0.125" w.g. positive differential prennure being achieved which is the acceptance criteria of Surveillance Test Procedure pE-5-004. The dif ferential pressure of 0.125" w.g. vns maintained with an outside airflow of greater than 200 cfm.
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q1 Q9 of 1l1 on December IS, 1990. Seal VIA0070 vno re-scaled with silicone foam in an air seal configuration. Temporary measures of scaling the equiptnent room doors in the Control Room envelope allowed Surve111 ante Tent pE-5-004 to be completed with 0.125" w.g. differential prennure md less than 200 efm make up airflow.
Several Control Room envelope Icahnge paths were identified on December 20, I 1990 and repaired. The major leakage paths identified weret an unsealed penet ration through the RAll Computer Room floor. The seal was opened to re-pull a ceble through a penetration under C1 269870. The real van only addrensed an being an impaired fire cent under fire impairment 90-494 a failure of the grouted joint between the walls and ceiling of the 3
Control Room envelope, and air leakage past cold joints between walls that were not grouted or scaled.
- a poorly scaled joint between the f airing on doore 85 and 86 and the concrete wall. These doora provide an airlock with the Control Room envelope and RAll.
Several condulet covers (EIIS Identifier-CDT) were discovered to be misning or installed incorrectly, i
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0 11 0' 1 11 tm e m m a n ,,. . 1 _ _ w ,- au ,, n t, 110 Af ter repairs to the listed Icakage paths were made Surveillance Test pE-5-004 was completed satisfactory with 0.125" w.g. differential pressure and less than 200 efm make up airflow on December 21, 1990.
The following actione to prevent recurrence of breaching the Control Room envelope have been initiated. The Nuclear penetration hist (Nph) will be revised by July 7, 1991, such that all scair., which provide an air pressure seal with the Control Room envelope or Controlled Ventilation Area Section (CVAS) (EIIS Identifier VF), are properly identified. The NPL will also be revised by March 1, 1992 to ensure that all seals, which are cddressed by TS or are designed as an air pressure boundary, are properly identified. Design, construction and maintenance work controls will be evaluated by March 15, 1991, to ensure that any work on penetration seals, pressure boundaries, and HVAC equipment, addresses TS requirements.
Permanent repairs have been made to the Icakage paths that were identified in the Control Room envelope. ' 9ermanent repair to the cold joints and the grouted joints between the walls and ceiling in the Control Room envelope is being evaluated to determine the best methods for making the permanent repairs.
This event will be discussed with all Waterford 3 personnel by March 1, 1991.
Training on a recurring basis by means of a case study will be implemented by June 15, 1991. The case study will address all aspects of the Control Room ventilation problems discussed in this report. DC-3197 will be revised to address the fire seals that affect the integrity of the Control Room envelope or CVAS boundary by April 1, 1991. Existing DCs have been reviewed to determine if revision is necessary, to ensure that pressure boundaries are adequately add re ss ed .
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I To summarize, the removal of fire seal VIA0070 created a breach in the Control Room envelope f rom December 5,1990, until repair of the seal on December 12, 1990. The breach in the Control Room envelope could have prevented achieving the TS required 0.125" w.g. differential pressure; therefore, the plant operated in a condition prohibited by TS for a period of 8 days. Futher review of the sequence of events that occurred on December 14, 1990, revealed that the plant was operated in a TS 1,00 3.0.3 condition for approxiamtely one and one half hours thile investigating the failed recirculation damper.
Calculations show that the removal of sen1 VIA0070 concurrent with the identified leakage paths in the Control Room envelope would have resulted in a Control Room envelope leakage rate of approximately 888 cim. The calculations also show that the habitability of the Control Room, during and after a toxic chemical or high radiation accident, would have been maintained; therefore, this event did not threaten the health and safety of the general public or plant personnel.
SIMILAR EVENTS None pl. ANT CONTACT R.C. Azzarello. Director, Engineering and Construction. (504) 739-6680.
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