ML20080B524
| ML20080B524 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 12/01/1994 |
| From: | Rehn D DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9412050251 | |
| Download: ML20080B524 (1) | |
Text
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Duke her Company (803)MI3000 Catau t>a Nuclear Station 4800 ConcorJ %d
>brk. SC 29745 DUKEPOWER December 1,1994 1
Document Control Desk l
U. S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Catawba Nuclear Station Docket No. 50413 l
Gentlemen:
Attached is Licensee Event Report 413/94-006 concerning TECHNICAL SPECIFICATION l
3.0.3 ENTERED DUE TO LESS THAN ADEQUATE WORK PRACTICES.
The cover letter attached to the subject Licensee Event Report and originally submitted on November 17, 1994, erroneously stated the Facility Docket No. as 50-414 and the Report Number as LER 4M/94-006. Those errors only existed on the cover letter. The corresponding numbers on the originally submitted Licensee Event Report itself are correct. The information contained in the "
Subject:
" above reDects that of the Report. We regret any inconvenience that those errors may have caused.
This event was considered to be of no significance with respect to the health and safety of the public.
Very truly yours, fhd
/ "' A M A
D. L. Rehn xc:
Mr. S. D. Ebneter Marsh & McLennan Nuclear Regional Administrator, Region 11 1166 Avenue of the Americas U. S. Nuclear Regulatory Commission New York, NY 10036-2774 101 Marietta Street, NW, Suite 2900 i
Atlanta, GA 30323 Mr. R. E. Martin INPO Records Center U. S. Nuclear Regulatory Commission Suite 1500 Office of Nuclear Reactor Regulation 1100 Circle 75 Parkway Washington, D.C. 20555 Atlanta, GA 30339 Mr. R. J. Freudenberger NRC Resident Inspector Catawba Nuclear Station
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LICENSEE EVENT REPORT (LER)
AND RECORDS MANAGEMENT BRANCH (MNBB 7714) U S. NUCLEAci REGULATORY COMMISSION WASHINGTON. OC 20S55-0001, AND TO THE PAPERWORK REDUCTION PRCUECT (31bO-0104). OFFICE OF (See reverse for required number of digits / characters for each block)
MAN AGEMENT AND BUDGET, W ASH'NGTON, DC 20$03.
F ACluTY NAME (1)
DOCKET NUMBER (2)
PAGE (3)
Catawba Nuclear Station, Unit 1 05000 413 10F 6 TITLE (4)
Technical Specification 3.0.3 Entered Due To Inadequate Work Practices EVENT DATE (5)
LER NUMBER (6)
REPORT NUMBER (7)
OTHER FACILITIES INVOLVED (8)
FACIUTY NAME DOCKET NUMBER SEQUENTIAL REVISION uoNTH DAY YE4n vCAR MONTH AY YEAR NouaE n NuMeEn g
F ACiUTY NAME DOCKET NUMBER 10 18 94 94 " 006
~
00 11 17 94 05000 OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR i: (Check one or more) (11)
MODE (9) 1 20.402(b) 20.405(c) 50.73(a)(2)(iv) 73.71(b)
FoWER 20.405(a)(1)(i) 50.36(c)(1) 50.73(a)(2)(v) 73.71 (c)
LEVEL (10) 100 20.405(a)(inio 50 36(c)(2)
X 50 73(a)(2)(viij OTHER 20.405(a)(1)(iii)
X 50.73(a)(2)(i, 50.73(a)(2)(viii)(A)
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LICENSEE CONTACT FOR THIS LER (12)
NAML TELEPHONE NUMBER pnchade Area Code)
D.P. Kimball, Safety Review Group Manager (803)831-3743 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)
CAUSE SYSTEM COMPONENT MANUFACTURER CAUSE SYSTEM COVPONENT MANUFACTURER R
l SUPPLEMENTAL REPORT EXPECTED (14)
EXPECTED MONTH DAY YEAR YEs SUBMISSION (N yes, cornvm EXPECTED SUBM:SSION DATE)
X DATE (15)
ABSTRACT (Limit to 1400 spaces, i e., approximately 15 single-spaced typewritten lines) (16)
ABSTRACT On October 18,1994, at 0438 hours0.00507 days <br />0.122 hours <br />7.242063e-4 weeks <br />1.66659e-4 months <br />, with Unit 1 and Unit 2 both in Mode 1, Power Operation, at 100 pcreent power, Operations tagged out Train B of the Control Room Ventilation and Chilled Water (VC/YC) System. At 0830 hours0.00961 days <br />0.231 hours <br />0.00137 weeks <br />3.15815e-4 months <br />, Technical Specification 3.0.3 was unknowingly entered when maintenance opened access panels on B Train VC/YC to begin routine maintenance. Outward air flow through the open access panels as a result of an unsecured backdraft damper created a bypass leakage flowpath, causing the running VC/YC Train A to be inoperable in that it was not capable of adequately pressurizing the Control Room. The access panels were closed at 0940 hours0.0109 days <br />0.261 hours <br />0.00155 weeks <br />3.5767e-4 months <br /> and Technical Specification 3.0.3 was exited. This event is attributed to work practices, in that a Non-Licensed Operator chose an inappropriate, tagged position for the backdraft damper during the development of a
" preplan" tagout. Corrective actions include Operations' management review of key aspects of this event with all operators to ensure a clear understanding of their responsibilities when tasks cannot be completed as required.
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FACILITY NAME 0)
DOCKET NUMBER (2)
LER NUMBf.R (6)
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M:QUEN hAL REVISION g
NUMBER NUMBER Catawba Nuclear Station, Unit 1 05000413 94
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n.w..au.<,wo....< wC wm o n BACKGROUND Tl e Control Room Area Ventilation [EIIS:Vl] (VC) and Chilled Water [ Ells:KM] (YC) Systems coabine to form one system which is designed to maintain a suitable environment in the following plant areast all times: Control Room [EIIS:NA](C/R), Cable [ Ells:CBL] Room, Battery
[ Ells:BTRY] Rooms, Switchgear [EIIS:SWGR] Rooms, Motor Control Center [EIIS:MCC] (MCC)
Rooms, and the Electrical Penetration [EHS: PEN] Rooms at elevation 594 + 0. The VC/YC System is shared between both Units and consists of two 100% redundant trains of equipment. Each is capable of being powered by Unit 1 or Unit 2 Essential Auxiliary Power [EISS:EB), but under normal conditious both trains are aligned to Unit 1. Two Diesel Generators [EIIS:DG] (D/Gs) are provided per Unit to energize the Essential Auxiliary Power buses [EHS:BU] during emergency conditions. The VC/YC System operates prior to, during and after a Loss of Coolant Accident (LOCA) or Blackout (l3/0).
The portion of the VC/YC System serving the C/R includes two 100% capacity air handling units
[ Ells:AHU](1CR-AHU-l for Train A and 2CR-AHU-1 for Train B), and two 100% capacity outside air pressurizing filter [ Ells:FLT] trains (ICRA-PFT-1 for Train A and 2CRA-PFT-1 for Train B).
Since the AHU housings, PFT housings, and all ductwork [ Ells: DUCT] are an integral part of the Control Room pressure boundary, each train is equipped with dampers (Ells:DMP] for sectional isolation for Preventative Maintenance (PM) or repairs. Following a Nuclear Station Modification, which removed the actuators from the dampers in the VC/YC System and converted the dampers to either manual isolation [EIIS:BDMP] or backdraft dampers [EIIS:UDMP], the means of ensuring that the dampers would remain closed during periods of maintenance was to manually secure them closed with an installed device designed specifically for that purpose.
1 Technical Specification (T/S) 3.7.6 specifies that two independent trains of VC/YC shall be operable during all operational modes. If one train becomes inoperable while either Unit is in Mode 4, Hot Shutdown, or above, the inoperable train must be restored to operability within seven days or be in at least Mode 3, Hot Standby, within the next six hours and in Mode 5, Cold Shutdown, within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Surveillance 4.7.6.c.3 requires that at least once per 18 months the system demonstrates the ability to maintain the C/R at a positive pressure of greater than or equal to 1/8 in we relative to adjacent areas.
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DOCKET NUMBER (2)
LER NUMBER (t)
P AGE (3; 5EQUENTIAL AEVisiON NUMBER NUMBER Catawba Nuclear Station, Unit 1 05000 413 3oF6 94
- 006 00 TtxT w. ua.
,.e,.a,a..m-.,.1 we s.,m (,7, T/S 3.0.3 is required to be entered when the Unit is operating in a condition prohibited by T/Ss. This condition exists when a Limiting Condition for Operation (LCO)is not met except as provided in the associated Action Requirements. It requires that within one hour action shall be initiated to place the Unit in a Mode in which the specification does i.et apply by placing it, as applicable, in:
a) At least Hot Standby in the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, b) At least Hot Shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and c) At least Cold Shutdown within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
EVENT DESCRIPTION On October 18,1994, at 0438 hours0.00507 days <br />0.122 hours <br />7.242063e-4 weeks <br />1.66659e-4 months <br />, with both Unit 1 and Unit 2 in Mode 1, Power Operation, at 100%
power, Operations made out tags for "B" Train of the VC/YC System using a " preplan tagout" for preventative maintenance. "B" Train was declared inoperable and entered into the "Techmeal Specification Action Item Log"(T-SAIL).
At 0512 hours0.00593 days <br />0.142 hours <br />8.465608e-4 weeks <br />1.94816e-4 months <br />,'a Non-Licensed Operator (NLO) proceeded to place the tags. He found manual dampers 2CRA-D-1 and 2CR-D-4 open and each held in place with its respective securing device. He closed each damper, and secured the positioning handle with its securing device. He found backdraft damper 2CR-D-10 closed since no fan was running in that train. He noted that there was a securing device attached to a chain near the position indicating handle. Since the tagout did not specify, he did not secure the position indicating handle in the closed position.
M 0830 hours0.00961 days <br />0.231 hours <br />0.00137 weeks <br />3.15815e-4 months <br />, Technical Specification 3.0.3 was unknowingly entered when maintenance opened the access panels on "B" Train VC/YC for belt and filter inspection per Work Order 94075617-01.
Outward air flow through the open access panels as a result of an unsecured backdraft damper created a bypass leakage flowpath, causing the running "A" Train of VC/YC to be inoperable in that it was not capable of adequately pressurizing the Control Room. From experience, the maintenance team felt that the air flow was more than they expected, so they proceeded to contact the Systems Engineer. Since the air flow did not inhibit work, they continued with scheduled activities.
At 0940 hours0.0109 days <br />0.261 hours <br />0.00155 weeks <br />3.5767e-4 months <br />, a member of the mtenance team, who had exited the work area, met with the Mechnical Systems Engineer and after discussion, the maintenance team member indicated he would NauOaM mi m
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PAGE (3) 5.E QUE N T 4AL HE vGON NUMBER NUMBER 05000 413 4 oF6 Catawba Nuclear Station, Unit 1 TEXT 09 more space e.s topred use naastoonal coo.es of NRC form assA) {ty) ensure that the access panels were closed. When he contacted the team, panel closure was in progress.
This made the "A" Train of VC/YC operable and Technical Specification 3.0.3 was exited for both units.
At 1015 hours0.0117 days <br />0.282 hours <br />0.00168 weeks <br />3.862075e-4 months <br />, when the Mechnical Systems Engineer arrived at the work site on "B" Train VC/YC, he verified the access panels had been closed. Closure of the access panels re-established the normal boundary of the VC/YC System. The Mechnical Systems Engineer found backdraft damper 2CR-D-10 in the closed position, but not secured. The maintenance team was told not to resume work activities that required access to the ductwork until the damper could be secured in the closed position.
At i149 hours, the Mechnical System Engineer and an NLO secured closed 2CR-D-10.
At 1210 hours0.014 days <br />0.336 hours <br />0.002 weeks <br />4.60405e-4 months <br />, immediately upon reopening the access panels, OP/0/A/6450/11, CONTROL ROOM VENTILATION / CHILLED WATER SYSTEM, Enclosure 4.11, Control Room D/P Verification, was successfully performed, ensuring operability of"A" Train VC/YC. The maintenance team then resumed work inside the "B" Train VC/YC ductwork.
On October 19,1994, at 0132 homs, with all work on the "B" Train of VC/YC completed, the train was declared operable and removed from the T-SAIL.
CONCLUSION This event is attributed to less than adequate work practices, in that an NLO in the Operations' Support Group who initially developed the " preplan tagout" selected an inappropriate tagged position for the j
dampers. Preplan tagouts are computer generated, and as such the tagged positions are selected from a
" pick list". Of the selections that were available at the time," closed" and " locked closed" were the two options from the list that most nearly fit the desired tagged position of" secured closed" " Closed" was chosen because the NLO felt that " locked closed" implied that a padlock would be required. The NLO did not take appropriate action to ensure that the proper tagged position was listed on the preplan tagout. Operations'. management will review the key aspects of this event with all operators to ensure a clear understanding of their responsibilities when tasks cannot be completed as required.
A review of reportable events which have occurred during the 24 months prior to this event indicated that entry into Technical Specification 3.0.3 due to both trains of VC/YC being inoperable is a recurring problem. Licensee Event Reports (LERs) 413/92-013 and 413/93-001 involved equipment NFC f OHV 36EA (S 9h
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DOCEE'T NUMBER (2)
LER NUMBER (6)
P AGE (3) blOLENT1A6 REWSION g
NUMBER NOURf A 05000 413 5OF6 Catawba Nuclear Station, Unit 1 94
- 006 00 TEXT (tr irwe spece,s serAmes we acoamas cop,es or NAC form mAj p 7) failure. LER 413/93-009 involved a failure to apply self-checking to ensure the correct component in that a technician cut the wrong wire after first identifying the correct one. The specific causes for these events are not applicable to this event.
A review of reportable events which have occurred during the 24 months prior to this event for which work practices.vas the cause, indicated three LERs attributed to work practices.
LER 414/92-005 involved a failure to apply self-checking in that an operator misread a value from the Operator Aid Computer resulting in a Mode change with Containment temperature below the temperature required for the Mode entered.
LER 414/93-003 involved a failure to adequately perform independent verification in that two technicians working on a sump pump circuit opened a link in the wrong cabinet after identifying the link by the correct number.
LER 413/93-009 involved a failure to apply self-checking to ensure the correct component in that a technician cut the wrong wire after first identifying the correct one.
Even though the causes cited in the above LERs were attributed to work practices, the specific nature of the causes and contributing factors are not applicable to this event. The work practice of selecting an inappropriate tagging position for Removal and Restoration preplan tagouts is not a recurring problem.
IMMEDIATE CORRECTIVE ACTIONS
- 1) The opened access panels were closed and work was stopped that involved access to the ductwork until the damper could be secured.
SUllSEQUENT CORRECTIVE ACTIONS
- 1) The tagging program's " pick list" has been revised to include " secured closed" as a possible selection for tagged position.
- 2) Preplan tagouts for the VC/YC trains have been revised to require that the dampers be " secured closed"
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DOCEET NUMBER (2)
LER NUMBER (6)
PAGE (J)
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NUMBER NUMBER 05000 413-6 OF 6 Catawba Nuclear Station, Unit 1 94
- 006 00 T m cu,,.,. c.c.,,,.e,.am..aaa.,,~.,,, wC u,m <, n PLANNED CORRECTIVE ACTIONS
- 1) Operations' management will review the key aspects of this event with all operators to ensure a clear understanding of their responsibilities when tasks cannot be completed as required.
SAFETY ANALYSIS During the time period from 0830 to 0940,2CR-AHU-l was opened for filter PM's without damper 2CR-D-10 secured closed. In this alignment it is unlikely the Control Room would be pressurized to greater than 1/8 in wc with the Pressurizing Filter Train running, due to the amount of flow escaping through the open AHU panels. Therefore, T/S 3.0.3 was unknowingly entered due to two inoperable trains of VC/YC. However, the time period for this T/S 3.0.3 event is less than the time allowed in the ACTION for T/S 3.0.3 which allows for one hour to fix the problem then six to shutdown.
Due to the construction of the Control Room at Catawba it is not likely that being pressurized to less than 1/8 in we would significantly affect Operator Dose. The Control Room is required to be pressurized to minimize the amount of unfiltered inleakage entering the Control Room. The 1/8 in we is required to compensate for wind and thermal effects along the Control Room pressure boundary which could locally affect inleakage. At Catawba only a small section of the Control Room west wall is exposed to the wind and this is solid concrete with no penetrations. Therefore, wind is an insignificant contributor to Control Room inleakage. Furthermore, of the areas adjacent to the Control Room all the areas normally receive some HVAC and therefore are not thermally stratified to any significant degree because of the mixing action of the HVAC systems. Additionally, because of the relatively small height of the Control Room, thermal column e,Tects are minimal.
An analysis of Control Room pressures during an accident assuming the conditions of this event shows that a slight positive pressure wil.1 exist with respect to all adjacent areas except those across the Auxiliary Building "AA" wall (Operator Aid Computer Room, Service Building and outside). The Control Room will be very slightly negative with respect to these areas. This wall and the two doors in it by nature of their construction are very low leakage. The amount of unfiltered inleakage caused by this slight differential pressure would be much less than the 10 cfm currently assumed in the FSAR dose analysis.
Control Room Operator dose would not exceed those stated in the FSAR dose analysis.
The health and safety of the Operators in the Control Room and of the public were not affected by this incident.
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