ML20029D622

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LER 94-005-00:on 940401,determined That Both Facilities of Ebfs Had Never Been Tested in Accordance W/Ts.Caused by Program Failure/Personnel Error.Corrective Action: Surveillance Was Completed satisfactorily.W/940429 Ltr
ML20029D622
Person / Time
Site: Millstone Dominion icon.png
Issue date: 04/29/1994
From: Haynes H, Temple W
NORTHEAST NUCLEAR ENERGY CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-94-005-01, LER-94-5-1, MP-94-292, NUDOCS 9405090058
Download: ML20029D622 (4)
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1 Northeast Rope Ferry Rd. (Route 156). Waterford, CT 06385 gsf Nuclear Energy Millstone Nuclear Power Station Northeast Nuclear Energy Company P.O. Box 128 Waterford, CF 06385-0128 (203)444 -4300 Fax (203) 444-4277 The Northeast Utilities System Donald B. Miller Jr.,

Senior Vice President - Millstone Re: 10CFR50.73(a)(2)(i)(B)

April 29, 1994 MP-94-292 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555

Reference:

Facility Operating Ucense No. DPR-65 Docket No. 50-336 Licensee Event Report 94-005-00 Gentlemen:

This letter forwards Licensee Event Report 94 -005-00 required to be submitted within thirty (30) days pursuant to 10CFR50.73(a)(2)(i)(B).

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY FOR: Donald B. Miller, Jr.

Senior Vice President - Millstone Station f ,

BY:

ML hes 'i v &v H. rry F. p Director illstone Unit 1 DBM/cic

Attachment:

LER 94-005-00 cc: T. T. Martin, Region i Administrator P. D. Swetland, Senior Resident inspector, Millstone Unit Nos.1,2 and 3 G. S. Vissing, NRC Project Manager, Millstone Unit No. 2 7 f 9405090o58 940429 PDR #

ADOCK 0500o336 S PDR [I

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NRC Form 366 U.S. NUCLEAR REGULATORY COMMISSION APPROtfED BY OMB NO. 3150-0104 (5-94

  • EXPlRES: 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY WTTH THIS INFORMAftON COLLECTION REQUEST. 50 0 HRS FORWARD COMMENTS REGARDING LICENSEE EVENT REPORT (LER) = ES M , NFORMA nuet m %DG MI ION

. WASHINGTON. DC 20555 - 0001 AND TO THE PAPERWORK REDUCTION

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(S . . ~ -., o-a,am .- 25'Tiema FACIUTY NAME (1) DOCKET NUMBER (2) PAGE (3) 1 Millstone Nuclear Power Station Unit 2 05000336 1OF3 TITLE (4)

EBFS Surveillance Requirements Not Satisfied EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INv0LVED (8)  !

j MONTH DAY YEAR YEAR SE NTIAL R S MONTH DAY YEAR FACluTY NAME DOCAET NUMBER ,

05000

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" 94 04 01 94 94 - 005 - 00 05000 OPERATING THIS REPORT IS BEING SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR i: (Check One Or more) (11) b 20 402(b) 20 405lc) 50 73:a)2(M 73 71(b) 4 i POWER 20 40$ca)(1)0) 50 36(c)(1) 50 73(a)(2)M 73 71tc) 20 405:a)(1101) 50 36(c)2 50 73;a)(2)MQ OTHER 20 405ta)0)ps) X 60 78'a)(2)(i) 50 73(a>mus)<A) (S .cis m Aoa fl

- b.o.o* and m T.iracext, NRC Fonn 366A) 20 405(a)p)M 50 73ta)(2)(a) 50 73(a)(2)MI)(B)

20 405ta)d)M 50 73(a)(2)fhti 50 73<a)2(x)

. LICENSEE CONTACT FOR THIS LER (12)

NAME TFLEPHONE NUMBER (Mclude A es Codel j William J. Temple, Site Licensing (203) 437- 5904 i

j COMPLETE ONE IJ 4E FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

REPORTABLE REPORTABtf CAUSE SYSTEM COMPONENT MANUFACTURER TO NPRDS CAUSE SYSTEM COMPONENT MANUFACTURCR TO NfEDS 4

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SUPPLEMENTAL REPORT EXPECTED (14) "O" "

EXPECTED I YES NO SUBMISSION Of yn compete EXPECTED SUBMISSION DATE) X DATE (15) l i

ABSTRACT fumit to 1400 spacu i . . apommm iy is smy.-apaced iype-men ines) ps) 4 At approximately 1430 hours0.0166 days <br />0.397 hours <br />0.00236 weeks <br />5.44115e-4 months <br />, on April 1,1994, it was determined that both facilities of the Enclosure Building  !

j Filtration System (EBFS) had never been properly tested in accordance with Technical Specification

, Surveillance 4.6.5.1.a. Technical Specification Surveillance 4.6.5.1.a requires that the EBFS system be i demonstrated OPERABLE, in part, "by verifying that the train operates for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with the system I heaters on." The existing surveillance procedure performs this test with the system operating in Auto, however, i

the heaters only energize when the moisture control switch senses a relative humidity greater than 70% )

Consequently, the heaters would not be energized for the required 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> surveillance run if the relative humidity j was less than 70%

1

' This condition resulted in both trains of EBFS being considered inoperable and the plant being outside the a Umiting Condition for Operation (LCO) for the EBFS system. The plant entered Technical Specification Action

] Statement 3.0.3 and Surveillance 4.0.3. A bypass / jumper was processed to jumper out the moisture control switch and to energize the heaters continuously. The 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> surveillance run was then performed satisfactorily for both trains of the EBFS system.

l The root cause of this event was program failure / personnel error resulting in procedure deficiencies. The failure to

, account for the actual system operating configuration during development of the surveillance procedure resulted I in the failure to incorporate into the surveillance procedure, a method to ensure that the system heaters operate continuously for the required 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> surveillance run.

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NRC Form 366 (5-92)

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NRc Forrn 366A U.S, NUCLEAR REGULATORY COMMISSION APPROVED BY OMB No. 3150-0104 (5-92) EXPIRES: 5/31/95 LICENSEE EVENT REPORT (LER) 'EEEN c E"is'" "'IEs 7mE cTENis"REiEi

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WASIBNGTON. DC 20503 FACRJTY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (31 YEAR H N E Millstone Nuclear Power Station Unit 2 05000336 94 - 005 - 00 02 OF 03 TEXT m more space a requeed. use addinonal copies of NRC Form 366Al (17)

1. Descriction of Event At approximately 1430 hours0.0166 days <br />0.397 hours <br />0.00236 weeks <br />5.44115e-4 months <br /> on April 1,1994, while in Mode 1, at 99.8% power, the plant was notified by the NRC Resident inspector, that a problem existed with the surveillance procedure for the Enclosure Building Filtration System (EBFS). The inspector questioned whether compliance with the Technical Specification requirement for running the system for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with the system heaters energized was being satisfied. A subsequent review of the EBFS design drawings indicated that the system heaters would only be energized when the moisture control switch contacts close. The surveillance procedure performs this test with the system operating in Auto, however, in this operating mode the heaters only energize when the moisture control switch senses a relative humidity greater than 70% Consequently, the heaters would not be energized for the required 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> surveillance run if the relative humidity was less than 70% Based on this,it was determined that both facilities of the Enclosure Building Filtration System (EBFS) had never been properly tested in accordance with Technical Specification surveillance 4.6.5.1.a.

Technical Specification surveillance 4.6.5.1.a requires that the EBFS system be demonstrated OPERABLE, in part, "by verifying that the train operates for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with the system heaters on."

This condition resulted in both trains of EBFS being declared inoperable and the plant being outside the Limiting Condition for Operation (LCO) for the EBFS system. The plant entered Technical Specification Action Statement 3.0.3 and Surveillance 4.0.3. Because the current design of the EBFS system does not allow for continuous energization of the system heaters, a bypass / jumper was processed to jumper out the moisture control switch and to energize the heaters continuously. The 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> surveillance run was then performed satisfactorily for both trains of EBFS. There was no automatic or manually initiated safety system actuations as a result of this event.

11. Cause of Event The root cause of this event was program failure / personnel error resulting in procedure deficiencies. The failure to account for the actual system operating configuration during development of the surveillance procedure resulted in the failure to incorporate into the surveillance procedure a method to ensure that the system heaters operate continuously for the required 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> surveillance run. This event was classified as a program error (procedural deficiencies / lack of detail), because the surveillance procedure did not require or provide a method to ensure that the system heaters remained energized during the 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> surveillance run, and also as personnel error (inattention to detail), because the operation of the system heaters in conjunction with the moisture control switch was not recognized or accounted for during the development of the surveillance procedure.

Ill. Analy11LOMv9nt Based on the event investigation, a determination was made that the surveillance procedure for the performance of Technical Specification 4.6.5.1.a was inadequate in that it did not fully test the EBFS system by verifying that each train operates for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with the system heaters energized, and that consequently, both facilities of EBFS had never been properly tested in accordance with the requirements of this surveillance. This is reportable under the criteria of 50.73(a)(2)(i)(B), any operation or condition prohibited by the plant's Technical Specifications. The surveillance procedure operates the system for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, however, due to the system design configuration, the heaters were considered energized as an automatic function, cycling on as the moisture control switch sensed a relative humidity greater than 70% This design condition has existed from original construction.

NRC Form 366A (S-92)

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NRC Form 366A u.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB No. 3150-0104 (5-92) EXPIRES: 5/3'i/95

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LICENSEE EVENT REPORT (LER) EEEJk" Su"isI"Ef&"i' 'ros"# CE$s"E"AR?M l TEXT CONTINUATION E '8,u"E7IMj"'UCE ^ReGEro"Ry' EEsE P 5 0 CE OF W GE NT AND DG WASHINGTON, DC 20503 FACUTY NAME (1) DOCKET NUMBER (2) LER NUMBER 16) PAGE (3)

WAR > MB NU BF Millstone Nuclear Power Station Unit 2 05000336 94 - 005 - 00 03 OF 03 TEXT p mare epace m reqwat use addmonai copies ol NRC Ferm 366A) (1 F)

There were no safety consequences as a result of this event. This conclusion is based on the fact that the system remained available to perform its intended post-accident ESF function and no degradation of the system or its components existed. The subsequent surveillance performed verified that the system heaters l were functional and that the system was OPERABLE. At no time were any safety systems out of service due to this event. Additionally, while the system heaters are designed to maintain and control the relative

, humidity of 70% to ensure the effectiveness of the activated carbon absorber section of the EBFS system, l the effectiveness of the activated carbon absorber section of the EBFS system is tested at a 95% relative l humidity (value required without credit taken for safety grade heaters), in accordance with the testing l criteria specified in Regulatory Guide 1.52, and would have retained its effectiveness even without heater j operation.

IV. Corrective Action l

Following the event discovery on April 1,1994, immediate corrective action was to declare both trains of l EBFS inoperable. A temporary electrical jumper was then installed across the EBFS moisture control l switch to ensure that the heaters would be continuously energized when EBFS was running during the surveillance. The surveillance was then repeated for the required 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> run. The surveillance was j completed satisfactorily for both trains of EBFS.

To prevent recurrence, the surveillance procedure is being revised to include steps to require installation of a temporary electrical jumper across the moisture switch each time this surveillance is performed to ensure that the system heaters remain energized for the entire 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> surveillance run. Additionally, as a long term corrective action, a design change is being evaluated to consider the installation of a permanent moisture control switch key lock bypass switch.

V. AdditionalInformation There were failed components associated with this event.

Similar LERs - None.

Ells Codes Enclosure Building Filtration System - BH NRC Form 366A (S-92)

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