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LER 90-002-01:on 900103,containment Air Return Fan Failed to Start During Test & Breaker FO1A in Motor Control Ctr Opened.Caused by Inappropriate Action.Measures Taken to Ensure Positions of Breakers verified.W/900409 Ltr
	ML20042E314
Person / Time
Site:	Catawba
Issue date:	04/03/1990
From:	Glover R, Owen T; DUKE POWER CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
	LER-90-002, LER-90-2, NUDOCS 9004200602
	Download: ML20042E314 (23)
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^DUKEPOWER April 9,;1990~ ;

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U. S.-Nuclear: Regulatory-Commission

. Washington, D. C.: 20555- ;

Subject:

~ Catawba Nuclear' Station l

. Docket- No.:; 50-413 -

.LER 413/90-02, Rev.:1

~ Gentlemen:

Attached-is-Licensce:EvenE Report 413/90-02, Revision 1,-concerning TECHNICAL. SPECIFICATION 1 VIOLATION FOR CONTAINMENT AIR RETURN.' FAN

. BREAKER OPEN DUE'TO INAPPROPRIATE ACTION,-

This eventwas considered'to be'of no significancefwith' respect 1to' .;

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the health and safety of theLpublic. . l Very truly yours,

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-Tony B. Owen

' Station Manager ,

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'U. S. Nuclear' Regulator Commission The Exchange, Suite 245 .

101-Marietta Street, NW, Suite 2900 270 Farmington Avenue Atlanta, GA 30323 Farmington, CT 06032 M & M Nuclear Consultants Mr. K. Jabbour 1221. Avenues.of the Americas U. S. Nuclear Regulatory Commission- )

New York,.NY 10020 Office of Nuclear Reactor Regulation -

Washington, D. C. 20555 INPO Records Conter l

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LICENSEE EVENT REPORT (LER)

F ACILITY NAest til DOCKET NUMSER (21 PAGE(3) catawba Nuclear Station. Unit 1 ol5lo10lol4l1l3 1lOFl212 Technical Specification Violation For Containment Air Return Fan Breaker Open Due To Inappropriate Action EVtNT DATE lll LER NUMSER (Si REPORT DATE 176 OTHER F ACILITIES INVOLVED (81

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NAME TELEPMONE NUMSER A*4E A CODE R.M. Glover, Compliance Manager 8,0 ,3 8,3 ,.1, , 3,2,3,6 COMPLETE ONE LING FOR I ACH COMPONENT F AILURE OfSCRISt0 IN THIS REPORT H31

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YtS lo! yen cometen EXPLCTED Sugst15310N OA TE) NO l l l AttTE ACT (timer to f e00 spaces. d e , saams,eceresy terreen s,are space rypewr,trea haess 041 On January 3, 1990, at approximately 1030 hours0.0119 days 0.286 hours 0.0017 weeks 3.91915e-4 months , with Unit 1 in Mode 1, Power Operation, quarterly test.

Containment Air Return Fan IB-(CARF-18)' failed to start during a It was subsequently found that breaker F01A in Motor Control Center (MCC) 1EMXN was open (not tripped). After the breaker was closed, the- '

quarterly status by test 2020was hours. successfully performed, and CARF-1B was returned to operable CARF-18 was last run on October 23, 1989. This incident is attributed to an inappropriate action, since it is apparent that this breaker was manually opened, sometime between October 23, 1989 and January 3, 1990.

Several possible causes were investigated. It is speculated that an individual may have stepped on or handled breaker F01A while climbing up to the cable tray above MCC 1EMXN.

Alternatively, the possibility that a wrong Unit / wrong train incident occurred was evaluated, as was the possible involvement of testing activities. Corrective actions included a Corporate Security Services investigation to attempt to determine the individual responsible, measures to ensure that the positions of similar breakers are periodically verified, procedure review, and training on this incident, i

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0l 0 2 OF 2l 2 e o e wecr-.mmm BACKGROUND The Containment Air-Return [EIIS:BK] Subsystem of the Containment Air Return and

.' Hydrogen Skimmer [EIIS:BB] (VX) system is designed to ensure a rapid return of I

! air from' upper to lower Containment [EIIS:NH] after an initial large break LOCA blowdown. This subsystem consists of two independent, 100% capacity fans-j [EIIS:BLO) per Unit, designed to start nine minutes after the Containment j- high,-high pressure (Sp) setpoint (3 psig) is reached. The Containment Air Return Fan Dampers [EIIS:DMP]'(ARF-D-2 for Train A, ARF-D-4 for Train B) are

[ designed to open 10 seconds after anJSp signal, to provide a flow path for the s T air return fans from upper to lower Containment.

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i Technical Specification 3.6.5.6_ requires two operable VX Trains in Mode l', Power Operation, Mode 2, Startup, Mode 3, Hot Standby, and Mode 4, Hot Shutdown. With one train of VX inoperable for greater than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , the Unit must'be in at L

leastfollowing the Hot Standby within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ,'and in Mode 5, Cold Shutdown, within 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

1' With both trains inoperable, Technical Specification

.3.0.3 requires that action be initiated within one hour to place the Unit in a mode in which the Technical specification does not apply. The Unit is to reach Mode 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , Mode 4 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and Mode 5

within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

l Each Containment Air Return Fan (CARF) is interlocked with the Containment Pressure Control System (CPCS) such that if Containment pressure is below 0.250-psig, a contactor coil will deenergize, opening breaker [EIIS:BRK] contacts, preventing the CARF from starting. This interlock is provided'to prevent the l

depressurization of Containment. The isolation contactors for.this interlock are physically separated from the rest of the control circuit and are located in power lockout Motor Control Centers (MCCs) EMXM and EMXN. Each of these '

contactors has an associated breaker-in series. In order to obtain a safety arelated unit. seismic contactor, the breaker:and contactor were purchased and used as l-PT/1/A/4450/05A(B), Containment Air Return Fan 1A(B) and Hydrogen Sk'immer Fan 1A(B) Performance Test, is performed quarterly by Performance.

the CARF is automatically started in response to an Sp signal, with theIn Section 12.1, discharge damper (ARF-D-2 or ARF-D-4) closed.

EVENT DESCRIPTION -

l On October l

23, 1989, CARF-1B operated successfully during the performance of PT/1/A/4450/058.

On January 3, 1990, at approximately 1030 hours0.0119 days 0.286 hours 0.0017 weeks 3.91915e-4 months , with Unit 1 in Mode 1, CARF-1B failed to_ start during the performance of PT/1/A/4450/05B.

' Skimmer Fan (HSF) IB were previously declared inoperable per TechnicalCARF-1B and Hydro '

Specification 0835 hours. A3.6.5.6 for the performance of PT/1/A/4450/05B, at approximately-high priority work request, 7353 PRF, was initiated to

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[ investigate / repair CARF-18. Instrumentation and Electrical =(IAE) personnel found that breaker F01A, in MCC 1EMXN, located in the Unit 1 560 foot elevation Electrical penetration Room, was in the OFF (not tripped) position. The breaker was completely in the OFF position, which would require a manual, not automatic trip, actuation.

The breaker was closed to the ON position, PT/1/A/4450/05B was 4 successfully performed, and CARF-1B and HSF-1B were declared' operable by 2020 hours0.0234 days 0.561 hours 0.00334 weeks 7.6861e-4 months .

F Corrective actions taken on January 3 and-4 included an inspection of this breaker, and a review with Design Engineering of breaker operation and possible causes of its opening. An extensive tagout review was performed by Operations on January 4, including searches for tagouts on any breakers on MCCs IEMXM, 2EMXM, 1EMXN and 2EMXN.

Maintenance Engineering Services-(MES) personnel k investigated the operation'of the breaker, and. concluded that the complete opening could not have been accomplished by a trip mechanism. No evidence was found that would indicate that a tagout error could have resulted in opening breaker F01A in MCC IEMXN. On January 5, all power lockout breakers on MCCs IEMXM, 2EMXK, IEMXN, 2EMXN were locked closed as an interim measure. It was noted that the Nuclear Safety Related stickers were missing for MCCs IEMXM,.

1EMXN and 2EMXM.

Security awareness in the' area of MCC 1EMXN was heightened, due to the possibility of deliberate equipment tampering (sabotage). This possibility was discussed with the Senior Resident NRC Inspector, and it was determined that there was no basis for assuming this to be the cause.

On January 4, 1990, at approximately 1915 hours0.0222 days 0.532 hours 0.00317 weeks 7.286575e-4 months with Unit 2 in. Mode 1, Operations personnel noted that there was no pow,er indication for' Containment Floor and Equipment Sump Pump 2B1 during a control board review. Power indication hours, had been on January 4. present during the previous control board review, at 0700 An Operator investigated the problem, and found that the pump's breaker, F10B in MCC 2MXM, located in the Unit 2 577 foot elevation Electrical Penetration Room, was in the 0FF (not tripped) position. This breaker was apparently opened sometime between 0700 hour0.0081 days 0.194 hours 0.00116 weeks 2.6635e-4 months s-and 1915 hours0.0222 days 0.532 hours 0.00317 weeks 7.286575e-4 months . The Operator subsequently closed the breaker. Subsequently, Security personnel performed area inspections and discovered collections of protective clothing'and other materials in cable trays above both MCC 1EMXN and MCC 2MXM.

CONCLUSION This incident is attributed to an inappropriate action, because.it is apparent in each case that the breaker was manually opened. Several work activities, .

such as tagouts, cable movement and testing, as well as the possibility of ~

sabotage, were considered as potential causes of Breaker F01A being opened. _A definitive conclusion has not been reached. It is speculated that the breaker in bothtray.

cable locations was stepped on or handled while climbing up to an overhead In each case, the breaker is believed to have served as a climbing point to reach a tray containing what were concluded to be bedding materials.

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- While bedding material collections have been found in other cable trays, none of these has been found occupied or in use. If these trays were to be occupied,-it l

j L would not present a seismic concern, according to Design Engineering. Although.

r the presence of these materials-in these cable trays was in violation of Station Directive 2.12.5, Control of Combustible Materials for Safety Related Areas, the materials were removed when discovered. Design Engineering has analyzed the cable tray fire scenario, and determined this not to be a problem due to train '

separation.

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Consideration has also been given to the possibility that action was taken on the wrong Unit or wrong train during a work evolution. No evidence was found that would indicate this as the cause. Further, January'3 testing activities and the procedure controlling the performance test were evaluated; no reason for Breaker F01A being open could be found. The evidence indicated that the correct breaker was opened on that day. A review of work requests has been performed and no evidence has been found indicating an activity which could have opened the breaker.

Immediately following this incident, several corrective actions were implemented' to prevent recurrence. A search of cable trays throughout the Auxiliary Building [EIIS:NF] was performed by K-Mac.(vendor cleaning crews) personnel,.

When similar materials were found in cable-trays, they were removed (as were the 4

materials found above the breakers).

There is no Control Room indication of the status of the power lockout breakers l for the CARFs. Station Problem Report (SPR) No. CNPR-04631 has been initiated by Maintenance Engineering Services (MES), proposing that Control Room indications / alarms be provided in case power lockout breakers are open or tripped. A planned corrective action is for Design Engineering to determine if there are any other safety-related circuits similar to this design, in which a-breaker might be in the 0FF position unknown to the Operators. -Operations verified the positions of all essential 600V. breakers needed for plant operation, in case of an accident, which either have no Control Room indication, or would not indicate being open, on January 6, and is continuing to do this on l a weekly basis as an interim measure. The requirement to verify these breaker I positions has been incorporated in permanent Station procedures. A planned corrective action will be to add labels, beside.the power supply labels on the ~

l main control boards, which identify these components as having pnwer lockout l

breakers, In addition, an SPR has been initiated by Operations to initiate an evaluation of the appropriate long term action for the CARF-1B power. lockout i breaker. An Operator Update has been issued describing the power lockout breakers, and this information has been sent to Training for inclusion in Operations lesson plans as necessary.

An extensive investigation was performed by Duke Power Company (DPC) Corporate .

1 Security Services (CSS) along with the Security Group at Catawba Nuclear Station

(CNS) to determine the person (s) responsible for opening the two breakers. On January 8, CSS was notified to provide investigative assistance.

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N h On January 9, CSS met with CNS Security, and conducted physical inspections of il the areas with Operations. Since the two locations are accessible to almost 1 anyone at CNS with unescorted access, the initial investigation concentrated on

? the collection of existing physical evidence. On January 9, most of the 4 materials collected from the two locations were sent to Forensic Analytical

j. Services and Testing, Inc. (FAST), in Bessemer City, North Carolina. An initial

? forensic inspection of these items did not reveal anything conclusive.. On. .

Y January 11, a forensic chemist from FAST inspected the two areas and obtained C several finger and palm prints from both locations. On January 12, the-Fower b Group, Human Resources Department, Nuclear Access Section, was contacted by CSS s

to determine whether the finger print cards for CNS employees could be released for comparison with the lifted prints. This comparison would initially involve l those employees who possibly left prints while investigating the incidents, on January 3 and 4. CSS contacted Professional Investigators of Raleigh, North Carolina and requested a print examination. A print expert began examination of

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the prints on January 15. This examination revealed that, after excluding:the prints'that matched the employees known to have been in the two areas, three prints were available: two prints from the Unit 1' location, and one print.from the Unit 2 location. CSS obtained a Personnel Access Portal:(PAP) transaction 7

report listing several hundred employees entering and exiting.the PAP between K '0700 hours0.0081 days 0.194 hours 0.00116 weeks 2.6635e-4 months and 1900 hours0.022 days 0.528 hours 0.00314 weeks 7.2295e-4 months on January 4, to attempt to identify the individual responsible for' opening breaker F10B in MCC 2MXM. On January 16, this list was h, forwarded to the Power Group by CSS. It was requested that print cards for each H employee on the list be released for comparison with the three prints collected.

p The Power Group stated that the DPC Legal Department would have to approve the request before the cards could be released. Subsequently, the Legal Department stated that, based on an interpretation of the NRC regulation regarding finger

- print cards, that the print cards could not be released for investigative purposes.

On January 15, the print examiner inspected the-two areas and made the determination that none of the three prints collected could have-been made more than three weeks prior to being removed for examination by the forensic chemist, on January 11. The print examiner stated that he would be willing to offer expert testimony to that effect. This indicates that the three prints lifted ,

were placed no earlier than December 21. However, it-would not be possible, due to surface characteristics,.to lift prints older than three weeks.

On January 17, CSS met with the Legal Department to discuss possible options in-pursuing the investigation. Although the Legal Department would pursue the matter, it was understood by CSS that the eventual release of the employee finger print cards kept on file could not be considered as an available option.

The use of polygraph examinations could also be eliminated as a possible option.

A possible option would be to require employees to finger printed for comparison with the three prints. However, the selection process for deciding which employees would be finger printed would need Lega, Departinent review and-approval.

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.: On January 20 and 21, dose cards for the 0700 hours0.0081 days 0.194 hours 0.00116 weeks 2.6635e-4 months to 1900 hours0.022 days 0.528 hours 0.00314 weeks 7.2295e-4 months period on

$ January 4 were examined by the finger print expert in Raleigh, North Carolina.

/: None of the finger prints on these dose cards matched the three prints. lifted from the MCCs.

4 i

I On January 23, meetings were held with selected Supervisors whose employees were' involved in work activities, in the area of Breaker FICB in MCC 2MXM where a j bedding material collection was found. These Supervisors in turn interviewed their employees to attempt to determine the responsible individual (s). These discussions did not identify the responsible individual (s).

A review of previous incidents reveals that this is-the only case in which h safety-related equipment was rendered inoperable as a result of inappropriate L action during the course of activities which were not work-related. This is not a recurring event or problem.

CORRECTIVE ACTION SUBSEQUENT ll

1) The CARF-1B circuitry was investigated under Work Request (W/R) 7353 p PRF. The power lockout breaker- for CARF-1B (breaker F01A in MCC E 1EMXN) was found, under priority 2X W/R 7353 PRF, to l'e in the full open position. The breaker was not in the intermediate mechanical L

slot (trip) position, but was full open. The trip capability of this p breaker was examined, and it was determined that a-manual, not

automatic, trip would be required to move the. breaker completely to i' the OFF position. The breaker was closed under W/R 7353 PRF. This i

breaker must be closed to start'CARF-1B. CARF-1B was started during

the performance of PT/1/A/4450/05B, Containment Air Return Fan 18 and l

Hydrogen Skimmer Fan 1B Performance Test, which was successfully completed on 1/3/90.

2) Following the completion of the actions on the CARF IB Test, the Security Force implemented " Heightened Awareness" in the area of the CARF Breaker.

3) Tie wraps initially and locks subsequently were placed on these power lockout breakers as an interim measure, until a permanent solution is reached. Subsequent discussion between Operations and Design Engineering revealed that the only breakers on MCCs 1EMXM, 2EMXM, IEMXN and 2EMXN needing to remain locked were the power lockout breakers for the VX Containment Air Return Fans.

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i 4) The power supply breaker for ContainmentLFloor;and. Equipment Sump Pump j 2B1J(Breaker F10B in MCC'2MXM) was found to be open by an Operator l/: following a control board review, which was performed at 1915 hours0.0222 days 0.532 hours 0.00317 weeks 7.286575e-4 months on !

4 January 4, 1990.. Since indication was present at the 0700 hours0.0081 days 0.194 hours 0.00116 weeks 2.6635e-4 months j control board review, and not at' the 1915 hours0.0222 days 0.532 hours 0.00317 weeks 7.286575e-4 months control board review,.

lj it is apparent that this breaker was opened sometime'between 0700 ,

i hours and 1915 hours0.0222 days 0.532 hours 0.00317 weeks 7.286575e-4 months on 1/4/90. The breaker was closed by Operations, ,

1 restoring its Control Room indication.

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5) On January 4,.1990 an inspection of,the two areas involved (MCC IEMXN 1 and MCC 2MXM) was performed by' Security. -Collections of protective:

clothing and other materials,: determined to have been used as bedding,= .

f were found in cable. trays above both MCC 1EMXN'and MCC 2MXM.

materials were removed.

The .i c 6) On January 4, 1990, tagouts (R&Rs) were searched for any breakers on MCCs IEMXM, 2EMXM, 1EMXN and 2EMXN, and'none were found which could have opened breaker F01A on MCC IEMXN by mistake. There-is no work activity in which breaker-F01A-on MCC 1EMXN is' opened.: R&Rs were 3

searched for CARF-1B, as-well.as any R&Rs on.the VX System for the period in question. R&Rs were searched for preplanned tagouts on this

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6 breaker, and none were found. Subsequently, Unit 2 tagouts on VX were

? searched for the period in question. None of these searches revealed P a situation in which this breaker was opened.

Ii 9 7) An Operator Update entitled " Power Lockouts" was initiated on-January 18, 1990. This update-described the power lockout breaker. It stated that if one of these breakers is inadvertently opened, power'is- ,

interrupted to the component, but Control Room indication remains. It also stated that'a periodic verification of-the positions of these breakers would be added to PT/1(2)/A/4350/03, Electrical Power Source Alignment Verification. An Operator Update entitled " Verification Prior to Action" was initiated on February 5, 1990. This update emphasized the importance that the correct unit, train, motor control center, and breaker compartment have been verified before repositioning a breaker. The mispositioned power lockout breaker for CARF-1B was referenced.

8) Operations submitt'ed a Station Problem Report (SPR) to initiate an evaluation of the appropriate long term action for.the CARF IB breaker

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9) Operations evaluated other applications where 2 breakers in series were used and as a result procedures PT/1(2)/A/4350/03, Electrical l Power Source Alignment Verification, were revised to include the L following weekly checks of these breakers being in the closed position:

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F04C in 2EMXH Cont.'Rm. Area PFT-2 Moist. Sep. Htr.

d' F07D in 2EMXH Cont. Rm. Area Chiller Comp. B 0il Pump Mtr

F07C in 2EMXK Elec. Hyd. Rec. Pwr. Sup. Pnl. 2A F01A in 2EMXM Pwr, L/0 For CARF-2A 1 F018 in 2EMXM Pwr. L/0'for 2NI-173A D F010 in 2EMXM Pwr. L/0 for.2NI-121A

? F01E in 2EMXM Pwr. L/0 for 2NI-162A ,

e F01A in 2EMXN Pwr, L/0 for CARF-2B 1 F01B in 2EMXN Pwr. L/0 for 2NI-178B ,

k F01D in 2EMXN Pwr. L/0 for 2NI-152B F01E in 2EMXN Pwr. L/0 for 2NI-183B F07C in 2EMXL Elec.-Hyd. Rec. Pwr. Sys. Pnl. 2B F01C in IEMXZ Pwr. L/0 for 2NI-100B F010 in IEMXZ Pwr. L/0 for12NI-147B F03C in SDSD RC Sup. to Aux'. Feed. Isol. Viv. 2CA-174-F04B in SDSD RC Sup, to Aux. Feed. Isol. Viv. 2CA-175 The above breakers were added as Enclosure 13.7. If power lockout breakers are deleted, these procedure requirements will be deleted.

F 10) Security implemented " Random Controls" to vary their surveillance times in an attempt to identify the individual (s) involved.

(

[ 11) Between January 4 and January 6, 1990, K-Mac personnel performed an h inspection in other aree of the Auxiliary Building, and discovered bedding materials in 14 locations (additional collections have been i found, and removed since this inspection).

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b 12) The K-Mac organization was revised to increase Supervisor. involvement 1

% with their work crews. _This reorganization reduces the number.of

employees per supervisor,-which will result in closer tracking of -,

y employees during shifts. _The supervision within other~ groups onsite.

p, was evaluated as well for-necessary improvements, p

13) Nuclear Safety Related stickers were placed on IEMXM,1EMXN, .and f

2EMXM. These stickers are required'per CNS-1390-01-00-0095, Procedure

" for Tagging Electrical Nuclear Safety-Related Equipment. Maintenance

~

personnel will be responsible for ensuring these-stickers are in place- [

!; in the future.

14) On January 23, meetings were held with' selected Supervisors _ whose:

employees were involved in work activities in:the area of-Breaker F10B in MCC 2MXM where a bedding material collection was found. These

'.' - Supervisors subsequently interviewed their= employees to attempt'to .

identify the responsible individual (s). 1

-15) An extensive investigation involving CSS, CNS Security, Forensic

4 Analytical Services and Testing, Inc. and Professional Investigators j of Raleigh, N.C. was performed to. attempt. to determine the responsible -

p individual (s),

c i 16) Design Engineering-(DE) evaluated the potential for this_ event at Oconee and McGuire. DE notified both stations, J

n

'17) A review was performed by Design Engineering of a possible cause of the breaker (F01A.on MCC IEMXN) opening through the trip (intermediate mechanical slot) position (i.e., tr.ipping to the full open position). ,

i An overcurrent condition would trip the breaker to the intermediate position.

18) An evaluation of test procedures was conducted at the time.of the event to determine if those procedures could have inadvertently left the CARF-1B Breaker open. No discrepancies were found.

PLANNED

1) Labels will be added, next to.the power supply label for affected components, which identify power lockout breakers. Each label is to '

? be approximately 1 1/2 in. by 1/2 in. These labels are being added under 0MP 1-6, Control Panel Information Changes. A total of 20 labels will be added on Control Panels MC-4 and-MC-11, Units 1 and 2

. Components affected are VX CARF 1(2) A, VX CARF 1(2) B, 1(2)NI-173A, 1(2)NI-121A, 1(2)162A, 1(2)NI-178B, 1(2)NI-152B, 1(2)NI-183B, 1(2)NI-100B, and 1(2)NI-147B. A program for labeling maintenance will be established within the maintenance group.

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j. 2) A study is being performed to determine if there are other safety-related circuits, similar to the VX design, where a breaker can t f:'-E be in the OFF position such that Control Room indication.would be '

U compromised. The scope of this study will include QA-1, 600V M breakers. An evaluation will-be. performed to determine if further .

f measures are needed in addition to those already taken. There~is the

possibility that the' power lockout breakers wil1 be eliminated. The '

D purpose of this review is to provide a permanent solution to the 4 problem'of important breakers being in the 0FF position, such that Control Room indication is compromised.

3) K-Mac has begun.a periodic (monthly) inspection of cable trays.

Station Management will review the results of these inspections for

! necessary actions. -In addition, Security is performing ranaom cable tray inspections.

A

4) Operator training will be conducted on- the possible cc.uses of this incident,-to further emphasize the importance of verifying that the correct breaker has been identified.

1 7- 5) The investigation to. determine the-individual (s) involved will n-continue with Legal Department assistance.

h 2 6) Station Management wi_11 review the need to protect certain breakers

from damage or' inadvertent opening and.to provide for necessary protection.

4 7.) Operator training will be conducted on power lockout breakers.-

SAFETY ANALYSIS i:

The Containment _ Air Return Fans (CARF) are designed to automatically start at 10 minutes into a postulated LOCA to provide forced air return into lower Containment. This forced air return limits Containment peak pressure in the L event of a postulated LOCA. The two CARFs discharge air from upper to lower l_ Containment through two discharge dampers, IARD-D-2 for CARF-1A, and 1 ARF-D-4 l for CARF-1B. The discharge dampers are automatically opened when two permissives are received: Containment pressure = 0.25 psig, and differential

. pressure across the divider barrier < 0.5 psid. The discharge dampers open '

y prior to CARF autostart to provide a path for natural convection air return from

? upper to lower Containment.

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6 The latest date that breaker IEMXN-FOIA was known to be closed is October 23,

{ 1989. Therefore, the potential time frame for inoperability of CARF-1B was

]

October 23, 1989, through January 3, 1990.- Since the breaker was open,.

& autostart and operation of the fan would not have occurred in a postulated LOCA V during this incident. It is likely that, during troubleshooting by Operations,.

the breaker would have been found to be open. The closing of the breaker would' y have.made CARF-1B operable. However, since the Main Control Board indicating light for CARF-1B remained illuminated even with the breaker open, the

[ possibility that Operations would have ascertained the breaker positbn and jj manually started CARF-1B will be conservatively ignored.

j CARF-1A was operable throughout this incident and able to perform its design i function, with the following exceptions:

1) Train A Solid State Protection System (SSPS) testing was conducted s from 0930 hours0.0108 days 0.258 hours 0.00154 weeks 3.53865e-4 months to 1130 hours0.0131 days 0.314 hours 0.00187 weeks 4.29965e-4 months on November 16, 1989. This testing

[ defeated the autostart capability of CARF-1A, in addition to the P automatic opening capability of ARF-D-2.

I d 2) Train A Containment Pressure Control System (CPCS) testing was

] conducted from 0800 hours0.00926 days 0.222 hours 0.00132 weeks 3.044e-4 months to 0925 hours0.0107 days 0.257 hours 0.00153 weeks 3.519625e-4 months on November 17, 1989, and from 0915 hours0.0106 days 0.254 hours 0.00151 weeks 3.481575e-4 months to 1057 hours0.0122 days 0.294 hours 0.00175 weeks 4.021885e-4 months on December 15, 1989. This testing defeated

'. the autostart and manual start capability of CARF-1A as well as the

[ automatic and manual opening capability of ARF-D 2 during performance

[ of the test. ,

1 3) Train A Containment Air Return System testing was conducted from 0838 hours0.0097 days 0.233 hours 0.00139 weeks 3.18859e-4 months to 1207 hours0.014 days 0.335 hours 0.002 weeks 4.592635e-4 months on December 11, 1989. This testing involved-opening the feeder breaker to ARF-D-2, thereby defeating its capability to open, either manually or automatically.

4) Train A Diesel Generator (D/G) testing was conducted from 0820 hours0.00949 days 0.228 hours 0.00136 weeks 3.1201e-4 months to 1235 hours0.0143 days 0.343 hours 0.00204 weeks 4.699175e-4 months on January 2, 1990. During this testing, the design Nuclear Service Water (RN) System flow balance is altered slightly by throttling valve IRN236, D/G Cooling Water Heat Exchanger 1A Outlet Throttle Valve. Also during this testing, IFD22, D/G Engine Fuel Oil Day Tank 1A Fill Valve, was in a closed position. Therefore, D/G 1A was declared inoperable during this period of time.

During SSPS testing, conservative estimates yield 45 minutes as the required time to return Train A SSPS to an operable state, at which time the autostart capability of CARF-1A and the automatic opening capability of ARF-D-2 would be.

functional. This time estimate includes operator notification of testing personnel and termination of the test procedure. Additionally, during the period of SSPS testing, the manual start capability of CARF-1A was intact and fully functional. The High Energy Line Break Emergency Procedures require the operators to ensure operation of the CARFs, and this would occur at approximately 15 minutes into a postulated LOCA.

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f. ssXiwm e <-,m mu m nw g 1 l2 or 2l2 3-i- During CPCS testing, conservative estimates yield 20 minutes as the required h time to return Train A CPCS to an operable state, at which time the autostart i capability of CARF-1A and the automatic opening capability of ARF-D-2 woulo be q

functional. This time estimate includes operator notification of test perr.onnel y and termination of the test procedure. Additionally, during the section of the

? procedure in which ARF-D-2 would not manually open, Train B damper, ARF-D-4, a

woul,d have opened to allow natural convection air flow from upper to lower E containment until CARF-1A was started and ARF-D-2 was opened to provide forced air circulation. The CARF-1B power lockout breaker, IEMXN-F01A, does not supply l t

power to either Air Return Fan discharge dampers.

1 3- During Train A Containment Air Return System testing, conservative estimates yield.50 minutes as the required time to return ARF-D-4 to an operable state.by closing the feeder breaker. This time estimate includes operator notification and test termination.

During Train A D/G testing, little or no impact w'ould be realized for the functional operability of the D/G. 1RN236 is in a throttled' position for flow testing, but is not throttled sufficiently to render the D/G incapable of g functior,ing. In fact, during this test the D/G is operating and fully loaded to n provide a heat load. During this test, an Operator is present in the D/G room to respond to any problem that may arise. Upon notification, the Operator would immediately return IRN236 to its initial position to ensure technical operability of the D/G. The D/G engine fuel oil' day tank has the design -

i capability to provide fuel oil for at least i full hour of operation without i makeup. During the 1FD22 valve test, an Operator would be able to open 1FD23, i D/G Eng Fuel Oil Day Tank 1A Fill Bypass Valve.

In the tests cited above, the D/G testing would have-no effect on th6 ability of CARF-1A to operate and fulfil its design funtion. CPCS testing would have affected CARF-1A operability for 20 minutes, SSPS testing would have affected -

CARF-1A operability for 45 minutes, and Containment Air Return System testing would have affected CARF-1A operability for 50 minutes. Therefore, the enveloping time frame for any analysis of the effects of CARF inoperability is ,

considered to be 50 minutes.

On January 30, 1987, it was discovered that the curbs had not been installed around the Containment Air Return Fan pits, in which, during a postulated-LOCA with containment spray actuation, the pits would have been flooded with-collected spray, rendering the fans inoperable (LER # 413/87-005-01). To analyze the effects of this incident, Westinghouse performed a Containment peak pressure analysis using the LOTICI computer model. Using the actual flowrates of the Residual Heat Removal [EIIS:BP] (ND) System, Component Cooling [EIIS:CC]

(KC) System, Containment Spray [EIIS:BE] (NS) System, ard Nuclear Service Water

'[EIIS:BI] (RN) System as inputs to the computer model, along with tha actual ice condenser ice weight and RN System inlet-temperature, it was determined that containment peak pressure would not have exceeded the design pressure in a postulated LOCA. ,

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. To analyze the effects of the present incident, the projected heat transfer L performance through both the ND/KC/RN and NS/RN heat transfer paths was compared to the conditions during the 1987 incident, using actual flowrates,.UA factors ,

for the heat exchangers, and RN System inlet temperature. It has been.

i determined that the performance in a postulated LOCA during this incident would

! have been greater than the corresponding performance during:the missing curb' I incident. The most significant factor in this analysis was:the RN inlet temperature. In the missing curb analysis, the RN inlet temperature was assumed :

to be 85 degrees F. In the evaluation of-this incident, a maximum RN System inlet temperature of 65 degrees F was conservatively assumed. Surveillance data-I l- shows that the actual RN inlet temperature varied between 47 and 65 degrees F l during the period of inoperability of CARF-1B,' and was approximately.47 degrees F during the 50 minute assumed inoperability of CARF-1A during Containment Air.

Return System testing, which is the longest time period of the-cited testing a '

activities. Standby Nuclear Service Water Pond (SNSWP) temperature follows lake temperatures. Surveillance data indicates that 6NSWP temperature was actually i l

l one to two degrees F lower than lake-temperature. SNSWP temperature would not l have varied significantly during post-LOCA response, including the 50-minutes L assumed period of inoperability. As-an additional factor of conservatism, it may.be pointed out that the Ice Condenser ice weight in the 1987 missing curb incident was assumed to be 2.75E+6-(1bm). During this incident, the actual ice condenser ice weight was 2.79E+6 (1bm). Also, the.19sB7 missi'ng curb incident

i. safety analysis assumed no CARFs operating for the duratior, of the transient.

In a postulated LOCA during this incident, at least one train'of the CARFs would begin to operate well before Ice Condenser meltout would occur- (containment peak ~

pressure occurs after Ice Condenser meltout). The containment peak pressure analysis for the missing curb incident-in 1987 is-deemed'to be applicable to this incident. Therefore, it is concluded that containment peak pressure would have been well within its design limit in the event of a postulated LOCA during this incident.

1 With respect to the offsite dose analysis, containment leakage is a function of containment pressure. It has been concluded that the design pressure for containment would not have been exceeded in the event of a postulated LOCA during this incident. Therefore, the assumed Technical Specification leakage rate of 0.2% per day is valid for this incident. Becaus9 the effectiveness of the NS System depends upon a well-mixed containment atmosphere, the iodine removal capabilitiy of the spray is less efficient withoat Containment Air Return System forced air flow. However, no credit for iodine removal was assumed in the design basis LOCA analysis. Standard Review Plan 6.5.4 requires that Containment Air Return System forced flow be available in order to take credit for iodine stripping by the ice condenser. Iodine removal by the. ice condenser was assumed in the design basis LOCA analysis. During the 1987-missing curb incident, the offsite dose consequences were evaluated assuming no iodine removal by the ice beds. The results indicated that offsite doses were within the limits of 10CFR100 limits. This previous analysis is considered l

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bounding for the present' incident, as the,1987 incident involved no CARFs

$y operating during the entire course of the event, while this incident involved no-F CARFs for only a 50 minute duration (most conservative testing activity).

3 Therefore, it is concluded that no offsite dose consequences beyond the design basis would have occurred in the event of a LOCA during this incident.

?

n

? With, respect to hydrogen control, at least one Train of Hydrogen Skimmer Fans N, and associated components was available during this incident. The Hydrogen 7

Skimmer Fans take suction from the dead-ended compartments of lower containment.

No hydrogen accumulation problems would have occurred due to this air movement.

? Also, the Hydrogen Recombiners were available to decrease the containment-hydrogen concentration if a postulated LOCA had occurred during this incident.

/ The absence of the CARFs for a maximum time period of 50 minutes would not cause i stratification or abnormal distribution of the hydrogen in containment due to.

J the natural convection air flow present in a LOCA. EPRI study " Hydrogen Mixing l' S and Distribution in Containment Atmospheres", EPRJ NP-2669, states that the jet

effect due to a LOCA and natural' convection is quite effective at mixing the lower containment volume. The report states that "the concentration differences L between measuring locations was less than one volume percent within 20 minutes f after stopping the hydrogen jet for all cases".

R The impact of delayed air return actuation on Lower Containment temperature and, j

hence, equipment qualification concerns, can be determined by examining the Main G Steamline Break analysis in Chapter 6 of the FSAR. Prior to normal air return Ll fan actuation and operation at 600 seconds, the Lower Containment temperature has peaked at 326 degrees F and.is trending downward. Also, mass and-energy releases for this accident reveal that both the mass flowrate and associated enthalpy are decreasing prior to 600 seconds. In the worst case,. failure of the

, CARF to operate would result in the temperature at 600 seconds (320 degrees F) 4 being protracted through the time-of air return fan start, which-is assumed'to be 50 minutes after the accident. As a result, equipment and instrumentation located in Lower Containment would possibly be exposed to elevated temperatures for a longer period than predicted in the FSAR. The consequences of this.

situation have been examined; sufficient margin exists _in the qualification profiles of the components to accommodate the extended duration of high temperatures. Therefore, a delay in air return fan actuation would'not adversely affect equipment and instrumentation located in Lower Containment.

In conclusion, one train of CARFs was operable during this incident except for the five periods of time in which testing was conducted. During these time

~

periods, four testing activities required greater than the 10 minute autostart time delay to return the system to operable, the most conservative bounding value being 50 minutes. A comparison of this incident (which involved no CARFs

- for a maximum time of 50 minutes) with the 1987 missing curb incident (which involved no CARFs for the duration of the transient) shows that the inoperability of both CARFs for 50 minutes would have no significant impact on containment pressure, offsite dose consequences, equipment qualification concerns, or hydrogen control.

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$ A Design Engineering safety analysis-was performed using both the conservative i FSAR conditions, and Westinghouse analysis using more realistic boundary Q- conditions. The post-LOCA Containment respense, pressure and temperature versus h time, under FSAR conditions is shown on Figures 1 and 2. Important points y concerning these figures are as follows:

1:

.. rapid pressurization following pipe rupture

. sprays actuate immediately at 3 psig

, . VX fans actuate at 10 minutes b . switch safety injection and sprays to sump recirculation mode

? . align RHR containment sprays at.50 minutes 4 . ice meltout at 4191 seconds

. ~ peak pressure, 14.0 psig, at 7308 seconds-

% . peak temperature bounded by steam line break 1

Q The post steam-line break Containment response, temperature versus time, is p shown on Figure 3. Important points concerning this figure are as follows:

, peak temperature occurs prior to 10 minutes VX fan actuation mass and energy release decreasing at 10 minutes-all feedwater 9 isolated peak pressure is bounded by LOCA

{

0 The Westinghouse analysis assumed more realistic boundary conditions, and assumed that the VX fans were unavailable. The results of this analysis (see

[ Figures 4 and 5) show that the peak Containment pressure still occurs after ice C

p: meltout and less than the design temperature:

. ice meltout at approximately 150 minutes

. peak pressure at 213 minutes ,

L There is no negative input on Containment pressure response. The Containment l

temperature response is bounded by the steam line break.

It is conservatively estimated that it would have taken, under accident conditions, 85 minutes to diagnose and close the open power lockout breaker for CARF-18. This Design Engineering safety analysis concluded that there would be no impact on post-LOCA Containment response if the VX fan delay increased from 10 minutes to either 50 or 85 minutes, using the Westinghouse analysis.

With respect to equipment qualification, the Design analysis concluded that there would be no unacceptable impact on any equipment if the VX fan delay

. increased form 10 minutes to 50 to 85 minutes. Since the VX fans cool Lower Containment post-accident, a delay in the rate that Lower Containment cools down would result. The current Lower Containment temperature for equipment

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[l ' term) and LOCA (long term). With a VX f an delay of 50 or 85 minutes, the EQ j temperature profile can be conservatively estimated as (see Figure 6):

Time Temperature ,

}

. 0-10 min. Current Profile (SLB) 10-50 min. 320 degrees F (SLB) !

50-85 min. 230 degrees F (LOCA)

> 85 min. Current Profile (LOCA)

[ The equipment in Lower Containment was evaluated based'on this temperature profile.

l. The health and safety of the public were not affected during this incident.

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