ML20044F628

LER 93-015-00:on 930423,plant Personnel Determined That May 1990 Control Room Makeup & Cleanup Filtration Sys Svc Time Exceeded.Caused by Failure to Develop Run H Tracking Method. Run Times for Cleanup & Makeup Fans monitored.W/930521 Ltr

ML20044F628
Person / Time
Site:	South Texas
Issue date:	05/21/1993
From:	Pinzon J, Rosen S HOUSTON LIGHTING & POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-93-015, LER-93-15, ST-HL-AE-4450, NUDOCS 9305280334
Download: ML20044F628 (6)

Text

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May 21, 1993 ST-HL-AE-4450 File No.: G26 10CFR50.73 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 South Texas Project Unit 1 Docket No. STN 50-498 Licensee Event Report 93-015 Technical Specification Violation due to Non-conservative Determination of Eauipment Service Time Pursuant to 10CFR50.73, Houston Lighting & Power (HL&P) submits the attached Unit 1 Licensee Event Report 93-015 regarding a Technical Specification violation due to non-conservative determination of equipment service time for the Control Room Makeup and Cleanup Filtration System. This event did not have an adverse effect on the health and safety of the public.

If you should have any questions on this matter, please contact Mr. J. M. Pinzon at (512) 972-8027 or me at (512) 972-7138.

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S*. . Rosen Vice President, Nuclear Engineering GLM/sr

Attachment:

LER 93-015 (South Texas, Unit 1) pB004G LFR\L93-015.U1 m l

Projeci Manager ogichair of the Participants in ihe south Texas Proje<<

9305280334 930521 tj ? -

1 PDR ADDCK 05000498 fu J PDR 1.8

Ho'uston Lighting & Power Company ST-HL-AE-4450-South Texas Project Electric Generating Station File No.: G26 Page 2 -

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Regional Administrator, Region IV Rufus S. Scott i

Nuclear Regulatory Commission Associate General Counsel 611 Ryan Plaza Drive, Suite 400 Houston Lighting & Power Company Arlington, TX 76011 P. O. Box 61867 Houston, TX 77208 Project Manager U.S. Nuclear Regulatory Commission Institute of Nuclear Power Washington, DC 20555 Operations - Records Center 1100 Circle 75 Parkway J. I. Tapia Atlanta, GA 30339-3064 Senior Resident Inspector c/o U. S. Nuclear Regulatory Dr. Joseph M. Hendrie Commission 50 Bellport Lane l P. O. Box 910 Bellport, NY 11713 Bay City, TX 77414 D. K. Lacker l'

J. R. Newman, Esquire Bureau of Radiation Control ,

Newman & Holtzinger, P.C., STE 1000 Texas Department of Health  :

1615 L Street, N.W. 1100 West 49th Street Washington, DC 20036 Austin, TX 78756-3189 D. E. Ward /T. M. Puckett U.S. Nuclear Regulatory Comm.

Central Power and Light Company Attn: Document Control Desk P. O. Box 2121 Washington, D.C. 20555 Corpus Christi, TX 78403 J. C. Lanier/M. B. Lee  !

City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704 K. J. Fiedler/M. T. Hardt 1 City Public Service P. O. Box 1771 San Antonio, TX 78296 ,

LER\L93 015.01

NRC FORQ 366*

U.S. GlCLEAR REa#LATOY C00(ISSIO APPROVED BY OMB CD. 3150-0104 (5-92) EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE 10 COMPLY WITH LICENSEE EVENT REPORT (LER) $xg33"'$'gu"S 3 RE RDI R EN ST TE b THE INFORMATION AND RECORDS MAkAGEMENT BRANCH l (MNBB 7714), U.S. NUCLEAR REGULATORY COMMISSION, l (See reverse for required ruter of digits / characters for each block) WASHINGTON, DC 20555-0001, AND TO THE PAPERWORK l REDUCTION PROJECT (3150-0104), OFFICE OF j MANAGEMENT AND BUDGET, WASHINGTON, DC 20503.

FACILITY EAME (1) DOCKET NUMBER (2) PAGE (3) l South Texas Unit 1 05000 498 1 OF 4  :

TITLE (4) Technical Specification Violation due to Non-ennenrvative notermination of Twninment snrvice Tien EVENT DATE (5) (ER MLMPER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8)

MONTH DAY YEAR TEAR MONTH DAY YEAR NUMBER NUMBER 05000 FACIL MY WAME CKET 04 23 93 93 -- 015 --

00 05 21 93 O O l

OPERATING TH m R m T 15 m i m D m SuANT T THE SmuNTS F1 CrR e (Check = or we) (u)  ;

5 20.405(c) 50.73(a)(2)( t v) 73.71(b)

CDDE (9) 20.402(b)  !

POWER 20.405(a)(1)(1) 50.36(c)(1) 50.73(a)(2)(v) 73.71(c)

LEVEL (10) 20.405(a)(1)(ii) 50.36(c)(2) 50.73(e)(2)(vii) OTHER 20.405(a)(1)(iii) X 50.73(a)(2)(1) 50.73(a)(2)(vil l)( A) (Specify in l Abstract ow 20.405(a)(1)(iv) 50.73(a)(2)(li) 50.73(a)(2)(viii)(B) 20.405(a)(1)(v) 50.73(a)(2)(iii) 50.73(a)(2)(x) WRC Form 3664)

(ICENSf E CONTACT FOR THIS Lf R (12)

NAME TELEPH0kE NUMBER (Include Area Code)

Jairo Pinzon - Senior Engineer (512) 972-8027 tIMPLETE ONE iINE FOR E ACH EIMPONENT TAIIURE DESCRIBED IN THIS REPORT (13)

LE E CauSE SYSTEM COMPONENT MANUFACTURER CAUSE SYSTEM COMPONENT MANUFAC1URER g g

SUPPlf MFNT AL REPORT EXPFCTED (14) EXPECTED MNT H DAY YEAR YES SUBMISSION (if yes, conplete EXPEC1ED SUBMISSION DATE). X "U DATE (15)

IASTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16)

On April 23, 1993, Unit 1 was in Mode 5 at 0% power. Plant personnel completed a reportability review which determined that in May, 1990, the Control Room Makeup and Cleanup Filtration System service time exceeded the applicable surveillance requirements. This constituted a violation of Technical Specification 4.7.7. The cause of this event was the failure to develop a run hour tracking method which accounted for operation of the cleanup fans independent of the makeup fans in Modes 5 and 6. The run times for both the cleanup and makeup fans are currently being monitored .

Individually. I I

l l

l l

l NRC FORM 366 (5-92) i r

e hRC fokM 366A u.S. CUCLEAR REIULATOR7 CCDMIS$10N APPR(NED BY OMB NO. 3150-0104

-(5-02) EXPIRES 5/31/95 ESTICATED BURDEN PER RESPCJSE TO COMPL7 UlTH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS.

FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE LICENBEE EVENT REPORT (LER) INFORMATION AND RECORDS MANAGEMENT BRANCH (MNEB TEXT CONTINUATION 7714), U.S. WUCLEAR RECULATORY COMMISSION, WASHINGTON, DC 20555-0001 AND TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE OF MANAGEMENT AND BUDGET, WASH!wCTON, DC 20503.

FACILITY MAM (1) DOCKET WUMBER (2) EER trJ4BER (69 PAGE (3)

SEQUENTIAL REVISION YEAR South Texas, Unit 1 05000 498 2 OF 4 93 -- 016 -- 00 TEXT (If we space is reouf red, use ackfitional copies of WRC Form 366A) (17) pESCRIPTION OF EVENT:

On April 23, 1993, Unit 1 was in Mode 5 at 0% power. Plant personnel completed a reportability review which determined that in May, 1990, the Control Room Makeup and Cleanup Filtration System service time between charcoal adsorber samples exceeded the surveillance requirements of Technical Specification 4.7.7.

On May 19, 1990, at 0530 hours0.00613 days <br />0.147 hours <br />8.763227e-4 weeks <br />2.01665e-4 months <br />, the CRE HVAC was placed in the filtered recirculation Mode in order to satisfy the requirements of Technical Specification 3.7.7.b (Modes 5 and 6) and 3.3.3.7.b. This ventilation lineup was documented in the control room log book. This action applied from May 19, 1990, at 0457 hours0.00529 days <br />0.127 hours <br />7.556217e-4 weeks <br />1.738885e-4 months <br /> until May 23, 1990, at 2030 hours0.0235 days <br />0.564 hours <br />0.00336 weeks <br />7.72415e-4 months <br />. During the filtered recirculation mode, the makeup fans are not operated, and the cleanup fans are in service. The method of determining the run times for compliance with Technical Specification 4.7.7 assumed that both the makeup and cleanup fans are always in service simultaneously. Technical Specification 4.7.7. requires that a charcoal adsorber sample be analyzed for methyl iodine penetration every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of adsorber operation. If the sample results are unsatisfactory, the adsorber is replaced. If the results are satisfactory, the adsorber is considered operable until the next sample is required.

A review of accumulated makeup fan run times was performed and the 900 hour0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> allowable time (720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> allowed by the Technical Specification plus a 25%

grace period) between charcoal adsorber samples was exceeded. As previously stated, the run times on the clean up fans were not individually monitored.

However, investigation revealed that, for the time frame identified, the 11A clean up fan was run independently of the makeup fan for approximately 62 hours7.175926e-4 days <br />0.0172 hours <br />1.025132e-4 weeks <br />2.3591e-5 months <br />. These hours, when added to 866 hours0.01 days <br />0.241 hours <br />0.00143 weeks <br />3.29513e-4 months <br /> which accumulated on the 11A makeup fan before the charcoal adsorber was next sampled in January 1991, exceeds the 900 hour0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> limit of Technical Specification 4.7.7. The charcoal adsorber in question was analyzed in accordance with R.G.1.52. The analysis results were unsatisfactory and the adsorber was replaced. Due to the lack of individual monitoring on the clean up fans, an exact time period for the violation of Technical Specification of 4.7.7 cannot be determined. However, because the cleanup and makeup fans are usually operated simultaneously, it can conservatively be concluded that this violation existed from May,1990 to January, 1991.

CAUSE OF EVENT:

The primary cause of this event was the failure to develop a run hour tracking method that accounted for possible independent operation of the cleanup fans and the makeup fans. Because review of archived ERFDADS data for determining run times is cumbersome it was decided that monitoring of the makeup fans run times alone would be sufficient.

HRC FOC 366A U.S. IIJCLEAR REGULATOY C0941S510 APPROti.D BT Gas No. 3150-0104

-(5-02) EKPIRES 5/31/95 ESTIMATED BURDEN PER RESPOSE TO COMPLV WITH THIS IkFORMAfl0N COLLECT 10W REQUEST: 50.0 HRS.

FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE LICENSEE EVENT REPORT (LER) INFORMATION AND RECORDS MAAAGEMENT ERANCH (MNBB m4), U.S. WUCLEAR REGULATORY COMMIS$10W, TEXT CONTINUATION WASHINGTON, DC 20555-0001 AND TO THE PAPERWJRK REDUCTION PROJECT (31$0-0104), off!CE OF MANAGEMENT AND BUDCET, WASHINGTON, DC ?O503.

F ACILITY ILAW (1) DOCKET WLMBER (?) (ER tRMBER (61 PAGE (3)

SEQUENTIAL REVISION YEAR 3 OF 4 South Texas, Unit 1 05000 498 93 -- 015 -- 00 .

TEXT (If more stece is reavired. use edditional copies of WRC form 366A) (17)

CAUSE OF EVENT: (Cont'd)

A contributing cause of this event was inadequate administrative control.

i A Technical Specification change was issued on May 6, 1990, which established the new filtered recirculation mode of operation in order to resolve a contradiction which had previously existed between specifications 3.3.3.7 and 3.7.7. Technical Specification changes are performed under the provisions of IP-1.19Q, " Changes to Licensing Basis Documents". This procedure was in revision 0 when the Technical Specification change was processed. Revision 0 did not provide concise instructions for performance of interdepartmental review to assess potential impacts.

ANALYSIS OF EVENT:

Technical Specification violations are reportable pursuant to 10CFR50.7 3 (a) (2) (i) (b) . The CRE HVAC system operating in the recirculation mode as described in the Updated Final Safety Analysis Report (UFSAR) does not allow outside air to be admitted into the control room envelope. Failure to sample a charcoal adsorber which exceeded the allowable service time betwecn samples established in Technical Specification 4.7.7 could have resulted in operation with charcoal not fully capable of removal of gaseous iodine (elemental iodine and organic iodides) from the CRE during and following accident conditions. However, these accident conditions did not exist during CRE HVAC operation with the charcoal adsorber which had exceeded the allowable service time between samples. Therefore, this event did not pose a safety concern for the control room personnel and there were no adverse radiological or safety consequences as a result of this event.

CORRECTIVE ACTIONS: i

1. Upon discovery of this event, individual monitoring of the service time for j both the makeup and cleanup fans was initiated. This monitoring method ,

will be formalized in procedure OPGP03-ZE-0008, " Nuclear Air Cleaning  !

Systems Filter Test Program Description". This procedure will be issued l by June 2, 1993. j l

2. A review was performed to identify all of the time periods when STP could l have operated the CRE HVAC system with charcoal adsorber which exceeded the allow ble service time established in Technical Specification 4.7.7. This review, which included research of archived ERFDADS dates, for both units, revealed no additional instances of Technical Specification violations.

1 l

NkC FORM 366A U.S. NUCLEAR REGJLATORY CupW41ESIC: APPROVED ST CMS NO. 3150-C104 (5-92) EXPIRES 5/31/95 ESTIMATED BUT: DEN PER RESPONSE TO COMPLY UlTH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS.

FORWARD COMMENTS REGARDING BURDEN ESilMATE 10 THE LICENBEE EVENT REPORT (LER) INFoRMAttoW AND RECORDS MAkAGEMENT BRANCH (MNBS TEXT CONTINUATION 7714), U.S. NUCLEAR REGULATORY COMMISSION, WAsklNGTON, DC 20555-0001 AND 10 THE PAPERWDRK REDUCTION PROJECT (3150-0104), OFFICE OF MANAGEMENT AND BLOCET, WASklNCTON, DC 20503.

FACILITY KAME (1) DOCrET NtMPJR (?) LER NLMBER (61 PAGE (3)

SEQUENTIAL REVISION YEAR South Texas, Unit 1 05000 498 4 OF 4 93 -- 015 -- 00 TEIT (If more toece is recaired, use e*fitionet cooies of NRC f orm 366A) (17)

CORRECTIVE ACTIONS: (Cont'd)

3. A review of the plant surveillance database was performed to identify other situations where run time or other non-sequential time interval is used to determine the test schedule. No situations were identified where the tracking mechanism for conditional factors was based on an indirect monitoring method subject to missing some time intervals.

4. Procedure IP-1.19Q has been revised to provide concise instructions for the performance of interdepartmental reviews to assess potential impacts. The procedure currently requires all Technical Specification changes to be submitted to all departments on site.

ADDITIONAL INFORMATION:

There have been no previous events involving the non-conservative determination of equipment service times.

,