ML20080R617

Responds to NRC Re Violations Noted in IE Insp Rept 50-261/83-27.Corrective Actions:New Sample Points Established by Documented Uniform Mixing Test for Various Ventilation Filter Sys

ML20080R617
Person / Time
Site:	Robinson
Issue date:	01/20/1984
From:	Morgan R CAROLINA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20080R379	List: ML20080R617
References
RSEP-84-33, NUDOCS 8402280357
Download: ML20080R617 (3)

Text

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CD&L Carolina Power & Light Company

'H. B. ROBINSON STEAM ELECTRIC PLANT

- Post Office Box 790 Hartsville, South Carolina 29550 JAN2 01984 .

Robinson File No: 13510C Serial: RSEP/84-33 Mr. James P. O'Reilly Regional Administrator Region II U. S. Nuclear Regulatory Commission 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 H. B. ROBINSON STEAM ELECTRIC PLANT UNIT NO. 2 DOCKET NO. 50-261 LICENSE NO. DPR-23 RESPONSE TO NRC INSPECTION REPORT IER-83-27

Dear Mr. O'Reilly:

Carolina Power and Light Company (CP&L) has received and reviewed the subject report and provides the following response:

SEVERITY LEVEL 4 VIOLATION (IER-83-27-01-SL4).

Technical Specification Table 4.1-3, Item No. 14 states that once per operating cycle the charcoal and absolute filters for the Residual Heat

' Removal Compartments, HVE-5, shall be tested in-place to show 99 percent removal of polydispersed DOP particles by the HEPA filters and freon by the charcoal filters.

-Technical Specifications 4.12 and 4.15 require the Control Room Spent Fuel Building filter systems to be tested in-place at the stated frequencies. The in-place-tests shall verify:

1) -That the HEPA filters remove 99 percent of DOP when tested in-place in accordance with ANSI N101.1 (1972).

2) That the charcoal filters remove 99 percent of a halogenated hydrocarbon when tested in-place.

ANSI N101.1 (1972), Section 3.3 requires that when a single sample point is used in determining filter efficiency, the sample point shall be representative of the DOP concentration across the sample plane. The single er 5

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semple point for the unfiltered mixture may be considered representative of the sampling plane if the. unfiltered mixture across the sampling plane is sufficiently uniform such that the maximum and minimum DOP concentrations do not differ by more than 10 percent of the maximum DOP concentration. The sampling plane for the filtered mixture shall be considered sufficiently uniform if the difference between the maximum and minimum DOP concentration is

-not more than 0.01 percent of the DOP concentration in the unfiltered air.

Contrary to the above, the tests demonstrating system operability performed prior to October 8, 1983, of the Spent Fuel Handling Building, Control Room,

.and Residual Heat Removal Compartment filter systems were inadequate in that:

a. The single sample points used during the period of this inspection to determine filter efficiencies for the above systems were not

. representative in that DOP concentrations across the sample planes differed from the maximum DOP concentrations by 25 percent.

b. The-requirement that filters in the Residual Heat Removal Compartment and Control Room filter systems be tested in-place to verify 2,99 percent removal of DOP and halogenated hydrocarbon gas was not met in that in-place filter tests performed during the period of this inspection failed to include filter bypass in the efficiency test.

RESPONSE

1. Admission or Denial of the Alleged Violation Carolina Power and Light Company acknowledges the alleged violation.

2. Reason For The Violation

a. The single sample points used in the initial filter efficiency test in 1983 were believed to be valid. These sample points were previously established in 1979 and documented on data sheets that were thought to be attached to the 1979 filter efficiency tests.

The 1979 efficiency tests are on file at the Plant; however, the sample point data sheets could not be located. Therefore, sample point validation tests were re-run in 1983. The results of these tests could not validate previous tests using the established sample points. Therefore, new sample points were identified, and the filter efficiency tests were re-run,

b. Technical Specification Table 4.1-3 Item 14 requires a test to demonstrate that the Residual Heat Removal (RHR)-ventilation exhaust and control room filter systems will remove 399 percent of DOP particles by the HEPA' filters and freon by the charcoal filters.

The control room system is HVE-19. The RHR filter system addressed in the Technical Specification is the auxiliary building emergency exhaust HVE-5A and B filter system which takes suction from the RHR room as well as from four other rooms in the auxiliary building.

CP&L personnel applied the technical specification specifically to the respective filter banks only and not the entire filter system which includes the filter bypass dampers.

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Because of this interpretation, the sample points used were on the inlet and outlet of the filter and did not include -the bypass dampers. >

3. Corrective Steps Which Have Been Taken and Results Achieved

a. 'New sample points have been established by a documented uniform mixing test for the various ventilation filter systems.

b. Using the new sample points, the efficiency of the HVE-19 filter system, including the bypass damper, was satisfactorily tested.

, Using the new sample points, a filter efficiency test was run on the HVE-5A and'B filter system. Although the HVE-5A and B filter alone met the 99% removal efficiency requirement, leakage was measured across the bypass damper which dropped the overall system efficiency to 92%. _The leakage was due to the design of the bypass damper and to the negative pressure downstream caused by this system discharging into the suction of the larger capacity auxiliary

~ building normal exhaust system.

4. Corrective Steps Which Will Be Taken To Prevent Further Violation The leakage past the HVE-5A and B filter system was discussed with the NRC inspector. Since the amount of leakage is small and this equipment is not covered by a Limiting Condition for Operation, sufficient time is available to perform a detailed study prior to initiating corrective action. CP&L will determine corrective action to reduce the bypass damper leakage or justify that the existing b /pass leakage is acceptable and submit an appropriate revision to the Technical Specification. The ventilation system tests will be permanently revised prior to their next use to include the valid sample points and to include the bypass dampers in the filter efficiency tests.

5. Date When Full Compliance Will Be Achieved The procedures will be revised prior to their next use. The leakage past the HVE-5A and B bypass damper should be resolved by June 30, 1984.

Very truly yours, A

R. E. rgan General Manager H. B. Robinson S. E. Plant CLW:FMG:JMC/ tid cc: R. C. DeYoung

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