ML20134E959
Text
,
UNITED STATES
/pa asog%'4 NUCLEAR REGULATORY COMMISSION REGION 11 3*
101 MARIETTA STREET. N.W., SUITE 2900 o
j ATLANTA, GEORGIA 3tH234190
]
- MAY I 71994 Docket Nos. 50-424, 50-425 License Nos. NPF-68, NPF-81 Georgia Power Company ATTN: Mr. C. K. McCoy Vice President Vogtle Electric Generating Plant P. O. Box 1295 Birmingham, AL 35201 Gentlemen:
SUBJECT:
CONFIRMATION OF MEETING ARRANGEMENTS - V0GTLE UNIT I This confirms the arrangements made between Mr. C. K. McCoy of Georgia Power Company and P. H. Skinner of my staff concerning an Open Enforcement l
Conference to be conducted at the Nuclear Regulatory Commission's Region II l
l office in Atlanta on June 2,1994, at 9:00 a.m.
This Enforcetaent Conference l
will be open for public observation in accordance with the Commission's trial program as discussed in the Federal Register Notice provided as an enclosure.
l The purpose of the conference is to discuss the circumstances associated with the extended degradation of the Unit 1 piping penetration ventilation system.
A copy of our Inspection Report will be provided before the meeting.
Should you have any questions regarding these arrangements, we will be pleased to discuss them.
Sincer ly, n,
W on oIi on, Acti g DiFector
~~
Divisi n f Reactor Projects
Enclosure:
Federal Register Notice cc w/ encl:
J. D. Woodard Senior Vice President-Nuclear Georgia Power Company P. O. Box 1295 Birmingham, AL 35201 cc w/ encl: Continued page 2 9611040198 960827 PDR FOIA KOHN95-211 PDR
- =
MAY l 71994 Georgia Power Company 2
cc w/ encl: Continued J. B. Beasley General Manager. Plant Vogtle Georgia Power Company P. O. Box 1600 Waynesboro, GA 30830 J. A. Bailey Manager-Licensing Georgia Power Company P. O. Box 1295 Birmingham, AL 35201 Nancy G. Cowles, Counsel 4
Office of the Consumer's Utility Council 84 Pez':htree Street, NW, Suite 201 Atlanta, GA 30303-2318 Office of Planning and Budget j
Room 615B 270 Washington Street, SW 4
Atlanta, GA 30334 j
}
Office of the County Commissioner i
Burke County Corr.'ission Wayriesboro, GA U 30 Harold Reheis, Director Department of Natural Resources 205 Butler Street, SE, Suite 1252 Atlanta, GA 30334 Thomas Hill, Manager Radioactive Materials Program Deprtment of Natural Resources i
4244 International Parkway Suite 114 Atlanta, GA 30354 i
Attorney General Law Department 13E Judicial Building Atlanta, GA 30334 Dan H. Smith Vice President Power Supply Operations
. Oglethorpe Power Corporation 2100 E. Exchange Place Tucker, GA 30085-1349 cc w/ encl: Continued page 2
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MAY 'I 7 1994 Georgia Power Company' 3-l cc w/ enc 1: Continued Charles' A.'Patrizia, Esq.
Paul, Hastings, Janofsky & Walker
- 12th-Floor 1050 Connecticut Avenue, NW 4
. Washington, D. C.
20036 i
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[
ENCLOSURE
- 10. 1932 / Nstices rWref Regisser / vel. 57,.No.133 / Friday. July 307s2 aaa====== Send commaats to:ne sindes currently boog developed or Secretary of the Comaussion. U.S.
in poor revtews for the Yankee Nuclear l
improvements m all vd"-" guides Noclear Regulatory Comaussion, Power Stauen.De plant wee hcensed ase es-d at any tune. Written Washmston.DC 20555. ATTN:
before the regatonnent forissuance of a commenta may be submitted to the Docketma and Sernce Branch.
Fmal Enytronmental Statement.
Regulatory Publicanons Branch.
Hand dehver comments to: One White AFencies and persone Consuhed Dinston of Freedom of Information and Flint North.11555 Rockville Pike.
The NRC staf! renewed Ahelicensee a Publicanons Servicea. Omce of Rocknile. MD between 7:45 a.m. to 415 Adannastronon. U.S. Nuclear Regulator 7 Comnussion. Washangton. DC 20555.
p.m Federalworkdays.
request and did not cons other Copies of comments may be exammec asencies or persons.
Regulatory gudes are availaWe for at the NRC Public Document Room, n:C ca==u== s Pubhc Finding of No impact inspecnon at the The Commiasson has eternuned not Document Room. 2120 L Street NW-L Street. NW. (14wer Level)'
to prepare an enviro talimpact Washangton.DC. Copies of lessed Washington.DC statement for the pro exempuen.
gmes may be Ased from ee Poe uma emomaanos contact Based upon the lo enysronmental Government Printing Omco at the James !Jeberman. Director.Omce of assessment, we conel that the current GPO pnes. Informanos ca Enforcement. U.S. Nuclear Regulatory proposed actice will ihavea entrent GPO pnemi may be obumed by Comaussion. Washington. DC 20555 sigmacant effect on quality af the
.amung & Sepermundmig g 001-504-2741).
Documents. U3 Government Printing m any m m humanennronnen For further detai with respect to this Omco h OmcoBa27082, acnon. see the app canon for exempeen Washington DC20013-7082, telephone Backymmad dated May 22.1 which is available 902M1mM202)312 2171. Issued De NRC's current pokcy on bhc eat Roons.
Nanonal Teoluncal Informanon Sernceenforcement conferences is addressed me Washington. DC on a stamiang oester bms. Details on Seenco V of the latest revision to h 20585. and at the hal pobLc document this sermsmay be obGued by wriung " General Statement of Policy and n20 L Street.
room at Green $ id Commuruty College
- NTIS.520sIPort Royal Road Synagneld. Procedere for Enforces 1 Couese Green $ eld.
VA 221SL/
(Edorcement Pobey)10 CFR part 2.
appendix C that was j'M on Massachaestts 301.
Autheory: 5 U.S.C.Saata).
February 18.1sER (87 FR 5791).The 1
Mar ad day Deted di Redville. Maryland. this 30th day Enforcement Policy states that.
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Federed Regiment / Vol 57. No. 233 / Friday, July to.1sez / Nodcas 3rias 1.
- 1. Criteria For Seleselse Opus three cowsones ofIsoseness wdl be subject to pornommel screemas. that T.afessement Camdesumans comunercsaloperanas rescansa, sigma. beamere, pesessa, ear not larger h-W and other hcommese, widdi than 13" he permassed, and that l
Pdorcement cod-wdl not k coneastof the romaamas types of da pemone ma me,eved.
open to the puhhc if the endercement J
conduct the enfomamentconference l
(1) W be taked agnaest as II. A==-==d=g Open Enforceaeest pWP as accordance wis regional indivuiuak or ni the acnon, though not Canterences pm.com.De enferanensat conference taken agamat an indmdual turns os As soon u itis deuremad that an wdl conunn a be a namens ktween whothat an admdualhas camnuuad enforcement conference wGI be open to the NRC and the hoensee. While the mengdoing:
public observanos, the NRC wdl arally enforcement conference u open for (2)lavolves saged5 cant personnel notify the licensee that the enforcement public observenoa.it is not open for failures where the NRC has requested contemace wm W open to public pubhc ppm j
l that the individoal(s) involved be ohuon a prt of the agency's trial Persone ettendens open enforcement present at the conference.
progran and send es konsee a copy of confwence am remaded eat (tl es (3)la bened on the Andiase of an NRC this Federal Regleter notice that petianes apparent vielseems checeased at open Omce ofInveenganons (OI) report:or the program.1.ie====== wm be asked to enforcement comissemens are embtect to j
H11avolves e _,informanen-unmem se number af parecipests it further reeww and may be embpm to Pmacy Act infonmation, or other wdl brtng to the enforosseet conference change pnar to say resulmag l
informanon widch could be considend so that the NRC can schedule en enforcement acnos and (2) es j
- pmputary, appropriately essed confereses room.
statemente of views or expresanans of j
Enforcement conferences involving The NRC wdl also acefy appropriate optaion made by NRC employees at j
medical misedministrobons or State listoon omcore that en open enforcement conferences or the j
ovaresposume wdl be open aseuem.s enforcement omederemos has bem leck thereof. are not utended to the conferenos can be ~~'-*=d scheduled and that it is open to pubhc represent final deterannatone or bebefs.
without diacionaag the exposed observenon, la addition to pnmdnas comments on l
individual e name.In addition.
De NRC intends to =aaaa== oP" the agency's trial progren in accodiance l
l enforcement conferences will feet be enforcommet coedmences to the pobhc with the guidance in this notica, persons j
open to the public if the conference wG normaUy at least 10 wortung days la attending open enforcement conferences i
be conducted by telephone or the advance of the enforcement conference wul b provided an opportunity to conference wdl be conducsed at a through the ionsonas ash subent written comments amanymenaly l
relativdy smalllicensee's facdity.
(1) Noeless poseed in the Puddis to the regional ol5ce.These comments Finally, with the approval of the Document Room will subsequendy be forwenied to the j
j Executive Director for Operanons.
(2) ToiMee sniophone====ag== emi Director of the OlBas of Enforcement for enforcement conferences wG not be (3) Toll. free electrompe baileen heard review and consideremon.
i open to the publicin special cases a
I where good cause has been shoura alter establisiumentof thetoudree Doisd at Asakulls@bea Fe day e@y 1881' balancing the homeSt of penbhc mesenge systems, the public may ceH Far the Nealear Rayslatary Camammasa.
observaalos assinat the potentialimpaat (301) 4ss. 4yst te obtana e soeurding of on the agency's aalorsmaamt accon as a upcosaseg span selettement SeessellDik 1
pardcular case.
conferwoose.De NRC wiH hees another secreenry e/4 W -
i ne NRC wdl strive to conduct open FederalRegiseur mense eheres toh (FR Dec. es team Flied T+el: Gass e.m.)
enforcement conferences dorms the message eyeesmes are estabilshed.
esame coes ress,ews two. year anal program as accordness To easiet the NRC la meidag with the folleense three sosis:
appropnate er:nagemente to support (1) Approximasely as pescent of au public observesten danimesment OpFICE Op ptRS000EL.
ehsible esloveement comissansas conderummes. indivsdeals interseesd in gagggggggggy t
raaduceed by the NRC wtB he open for attending a particular emiercoment public obeavemen; conferssos should neefy the indw6 dual mespsestsercommummeofa (2) Atlaaet ama spaa miereemset lematt8sdla the uselbig mesen ingenommon Comaneumto pene RI cualerence wdl be ad-*=d la ensk of ammemades the opse emionament 33.y tu cess cassammes anos-the regional olhces: and esadmemesas noter een ave hemose*
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1 (3) Open enternement asedsequese days preerto the andesamment am mesu CIBee af I
wtu be condessedwtth avertsey of to conserames, 55.Cadme af Open Eminsemt
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e of = = =de four eh,ideon nemu m,een s, es involvtag one of esse estagenes of to mammaarus held at the NRC
- 44. U.S. Code, 35),thismenos liseneseswemesumAFhespanto the oSess.u.-am =s of the public he emmenases a dereineresseof a I
puhtteduringtheeteipoepean, allowed sensesto theISCaegional, meland toadd j
Hemver.la esses whose there le as oSese se amend opemendesamment fann Rt 3D F to Appumedemier j
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UNITED STATES
/pM8:
NUCLEAR REG'JLATORY COMMISSION 3
REGION 11 5
S 101 MARIETTA STREET. N.W., SUITE 2900 l
ATLANTA, GEORGIA 3032H199
...../
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MAY 181994 Docket Nos. 50-424, 50-425 License Nos. NPF-68, NPF-81 EA 94-87 Georgia Power Company ATTN: Mr. C. K. McCoy Vice President Vogtle Electric Generating Plant P. O. Box 1295 Birmingham, AL 35201 Gentlemen:
SUBJECT:
NRC INSPECTION REPORT NOS. 50-424/94-15 AND 50-425/94-15 This refers to the inspection conducted by R. Starkey of this office on April 24 - May 12, 1994. The inspection included a review of activities authorized for your Vogtle facility. At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the enclosed report (Enclosure 1).
Areas examined during the inspection are identified in the report.
Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observation of i
activities in progress. The purpose of the inspection was to determine whether activities authorized by the licensee were conducted safely and in j
accordance with NRC requirements.
Based on the results of this inspection, one apparent violation was identified and is being considered for escalated enforcement action in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), 10 CFR Part 2, Appendix C.
The apparent violation 2
concerned the extended operation of Unit 1 with a degraded piping penetration j
ventilation system. Accordingly, no Notice of Violation is presently being issued for these inspection findings.
In addition, please be advised that the i
characterization of the apparent violation described in the enclosed inspec-tion report may change as a result of further NRC review.
An enforcement conference to discuss this apparent violation has been scheduled for June 2,1994. This enforcement conference will be open to pub-lic observation in accordance with the Commission's trial program as discussed in the enclosed federal Register notice (Enclosure 2). The decision to hold an enforcement conference does not mean that the NRC has determined that a violation has occurred or that enforcement action will be taken.
The purposes of this conference are to discuss the apparent violation, its cause and safety significance; to provide you the opportunity to point out any errors in our inspection report; and to provide an opportunity for you to present your pro-posed corrective action (s).
In addition, this is an opportunity for you to
?P
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Georgia Power Comp::ny 2
MAY I 81994 provida any information concerning your perspectives on 1) the severity of the violation (s), 2) the application of the factors that the NRC considers when it determines the amount of a civil penalty that may be assessed in accordance with Section VI.B.2 of the Enforcement Policy, and 3) any other application of the Enforcement Policy to this case, including the exercise of You will be advised by separate discretion in accordance with Section VII.
No correspondence of the results of our deliberations on this matter.
response regarding this apparent violation is required at this time.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enciosure will be placed in the NRC Public Document Room.
Sincerely, wl,'fhe b,JonR.(Johnson,ActingDirector Division of Reactor Projects
Enclosure:
- 1. NRC Inspection Report
- 2. Federal Pagister Notice cc w/ encl:
J. D. Woodard Senior Vice President-Nuclear Georgia Power Company P. O. Box 1295 Birmingham, AL' 35201 J. B. Beasley General Manager, Plant Vogtle Georgia Power Company P. O. Box 1600 Waynesboro, GA 30830 J. A. Bailey Manager-Licensing Georgia Power Company P. 3. Box 1295 Birmingham, AL 35201 Nancy G. Cowles, Counsel Office of the Consumer's Utility Council 84 Peachtree Street, NW, Suite 201 Atlanta, GA 30303-2318 cc w/ encl cont'd:
(See page 2)
c...
MAY I 8 !?94
-Georgia Power Company 3
(ce w/enci cont'd:
Office of Planning and Budget Room 615B 270 Washington Street, SW Atlanta, GA 30334-Office of the County Commissioner Burke County Commission Waynesboro, GA 30830 Harold Reheis, Director Department of Natural Resources 205 Butler Street, SE, Suite 1252 Atlanta, GA 30334 Thomas Hill, Manager Radioactive Materials Program Department of Natural Resources 4244 International Parkway Suite 114 Atlanta, GA 30354 Attorney General 132 Judicial Building
-Atlanta, GA 30334 Dan H. Smith Vice President Oglethorpe Power Corporation 2100 E. Exchange Place Tucker, GA 30085-1349 Charles A. Patrizia, Esq.
Paul, Hastings, Janofsky & Walker 1050 Connecticut Avenue, NW Washington, D. C.
20036
UNITEo STATES
,pa af og%,
NUCLEAR REGULATORY COMMISSION f
y
'g REGloN 11 i
'e 101 MARIETTA STREET, N.W., sufTE 2900 l
ATLANTA, GEORGIA 3GIZ34190
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Report Nos.:
50-424/94-15 and 50-425/94-15 Licensee: Georgia Power Company P. O. Box 1295 Birmingham, AL 35201 Docket Nos.:
50-424 License Nos.: NPF-68 and NPF-81 Facility Name: Vogtle Units.I and 2 April 24 - May 12, 1994 Inspection Conducted:
- r A->
Inspector:
- u. U.
~'4 4, -
& R. D. Starkey, Resident Inspector Date Signed
- 0. E /
5 /T %'
Date Signed
,e -P. A. Balm p Resident Inspector O
INNb Approved by:
m P. Skinner, Chief Date Signed Reactor Projects Section 3B Division of Reactor Projects
SUMMARY
Scope:
This special inspection, conducted by the resident inspectors, concerns an event where the Unit 1 Piping Penetration Area Filtration and Exhaust System (PPAFES) was in a degraded condition for 54 days.
Results:
An apparent violation was identified involving the Unit 1 PPAFES.
The licensee unknowingly deenergized, for 54 days, the PPAFES exhaust flow dampers which are designed to maintain a negative pressure in the auxiliary building following a containment ventilation isolation.
W 9%@N
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REPORT DETAILS i
1.
Persons Contacted Licensee Employees J. Beasley, General Manager Nuclear Plant S. Bradley, Reactor Engineering Supervisor
- W. Burmeister, Manager Engineering Support S. Chesnut, Manager Engineering Technical Support
)
- C. Christiansen, SAER Supervisor C. Coursey, Maintenance Superintendent i
- R. Dorman, Manager Training and Emergency Preparedness
- G. Frederick, Manager Maintenance W. Gabbard,' Nuclear Specialist, Technical Support
- J. Gasser, Operations Unit Superintendent M. Griffis, Manager Plant Modifications M. Hobbs, I&C Superintendent
- K. Holmes, Manager Operations D. Huyck, Nuclear Security Manager J
- W. Kitchens, Assistant General Manager Plant Support i
R. LeGrand, Manager Health Physics and Chemistry i
- G. McCarley, ISEG Supervisor R. Moye, Plant Engineering Supervisor
- M. Sheibani, Nuclear Safety and Compliance Supervisor C. Stinespring, Manager Administration
- J. Swartzwelder, Manager Outage and Planning J
C. Tynan, Nuclear Procedures Supervisor J. Williams, Supervisor Work Planning and Controls j
Other licensee employees contacted included technicians, supervisors, engineers, operators, maintenance personnel, and office personnel.
Oglethorpe Power Company Representative T. Mozingo NRC Inspectors
- D. Starkey, Resident Inspector
- P. Balmain, Resident Inspector
- 0. Wheeler, NRR Project Manager
- Attended Exit Interview An alphabetical list of abbreviations is located in the last paragraph of-the inspection report.
C-2 2.
Event Description On April 24, 1994, during a review of MWO 19401858, the Unit 1 USS recognized that the PPAFES Train A and Train B exhaust flow con-trol dampers, 1PV-2550B and 1PV-2551B, were deenergized closed and had been in that condition since March 1, a period of 54 days.
-When the licensee recognized the degraded condition on April 24 the dampers were promptly reenergized to return the PPAFES to its normal standby cordition. After evaluating the potential reportability of tne event, the licensee made a four-hour non-The licensee emergency notification to the NRC on April 26.
subsequently initiated an event critique team to investigate the l
event. During that review the licensee identified three addition-al instances, one in 1992, and two in 1988, when the PPAFES exhaust flow control dampers were closed for a period of time that exceeded the TS allowed outage time.
===3.
System Description===
The PPAFES is a safety-related system and is designed to maintain a negative pressure on the piping penetration area rooms and fil-ter the exhaust from those areas. The PPAFES is part of the Aux-iliary Building Emergency Ventilation System which functions after an accident to keep ESF equipment rooms cooled, maintain a nega-tive pressure on the area, and filter the exhaust from the negative pressure boundary to prevent release of radioactivity to the atmosphere. The PPAFES ensures that airborne radioactive materials leaking from the mechanical penetration rooms and ECCS equipment rooms are filtered prior to reaching the environment.
The Vogtle FSAR, Section 6.5.1.1.B. ESF Filter Systems-Design Bases, states, in part, that the PPAFES filter exhaust system is designed to maintain the filtration unit rooms at -1/4 inch WG with respect to the atmosphere which ensures that the piping j
penetration areas are maintained at a negative pressure with respect to adjacent areas. The system is in standby readiness during normal plant operations and is activated by a CVI signal.
The CVI signal isolates the Auxiliary Building Normal HVAC system l
from the piping penetration areas and starts both trains-(A and B) j of the filtration and exhaust units, opens their inlet and outlet i
dampers, and the exhaust flow control dampers.. This results in the filtration and exhaust unit serving the various rooms, valve galleries and corridors within the Auxiliary Building.
i The PPAFES exhaust flow control dampers, IPV-25508 and IPV-25518, which were deenergized during this event, are butterfly type i
electro-hydraulically operated valves. Upon a CVI, they are de-si; mad to open to a pre-set position and exhaust approximately 107, of the total PPAFES exhaust fan's air flow to the atmosphere via l
the plant stack. FSAR Table 9.4.3-5 describes the safety function
)
of these dampers as "open to maintain negative pressure insiCa the auxiliary building." When the PPAFES is in standby, these dampers are normally closed and will fail closed upon loss of power to the l
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l dampers. During the time when these two dampers were deenergized and failed close, negative pressure could not have been ensured in j_
the piping penetration areas.
4.
Cause of the Event l
The primary cause of this event was the inadequate preparation and l
i review of hold clearances by licensee personnel which resulted in an alteration of the PPAFES which prevented 'it from performing its j
function of maintaining a negative pressure in the piping penetra-a tion areas. The licensee had initiated clearances 19400133 and 19400134 on February 28 and March 1,1994, for the purpose of j'
allowing work to be performed related to MOD 93-V1M138. The M00 i
was written to delete the Electrical Penetration Filtration System and abandon in place as much of that system as possible. The s
system was partially installed on Unit 1 and had never been in-stalled on Unit 2.
Two breakers, 1AYEl-33 (Train A) and IBYCl-28 (Train B), were tagged out under these clearances with the intent of removing power from dampers related to the Electrical Penetra-tion Filtration System.
Personnel writing the clearances were i
unaware that these two breakers also supplied vital 120 VAC poer j
to the two PPAFES dampers, 1PV-25508 and 1PV-25518.
Thus, when the breakers were opened, the two dampers were deenergized and s
i failed to their closed position.
l The licensee discovered, during a review of reference material, that both the electrical load list and the one-line electrical r
drawing related to breaker 1AYEl-33 (Train A) did not indicate that the breaker supplied power to PPAFES damper 1PV-25508. How-ever, similar reference material related to breaker 18YC1-28 (Train B) correctly indicated that PPAFES damper 1PV-2551B was one of its loads.
Breaker 1AYEl-33 had been previously tagged out on two other occasions, once in 1992 and once in 1988, with the in-tent of deenergizing components related to the Electrical Penetra-tion Filtration System.
In both of these examples, the exhaust flow control damper in the PPAFES was unknowingly deenergized.
Also, in 1988, during a tag out of the "B" Train of the Fuel Han-dling Building Filtration System another breaker, 1BYCl-30, was opened, which deenergized the PPAFES Train "B" suction damper, 1HV-12614, for a period of 18 days. The impact on the PPAFES was apparently not identified wi.en the above clearances were written and subsequently implemented. The licensee has taken action to correct the deficient electrical load list and drawing.
The licensee had several opportunities between March 1 and April 24, to identify that the dampers were deenergized and failed closed.
For example, once each 31 days, as required by TS surveillance 4.7.7, on a staggered basis, one of the two trains of PPAFES is run for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per operations Procedure 14515-1, Pip-ing Penetration Area Filtration and Exhaust System Operability Test. Data Sheet 1 of that procedure requires the operator to m-m e
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4 verify that the exhaust flow damper (IPV-25508/IPV-25518) is open.
During surveillances performed on March 28, (Train B) and April 11, (Train A), Data Sheet 1 indicated that the dampers were open, although hold clearances were in effect and the dampers were deenergized.
Inspector discussions with members of the event cri-tique team indicated that during these surveillances the operators observed that the PPAFES had normal flow and negative pressure indications and assumed that the damper's were open, even though the control room indications for the dampers were deenergized (not illuminated).
It should be noted that the negative pressure is read on control room indicator: PDI-2550 and PDI-2551 and that these indicators reflect only the pressure within the Pipin9 Penetration Filtration Exhaust Unit Room. Neither of the two surveillances contained any remarks in the " comments" section of the procedure to indicate that there was any problem with damper However, on March 28, the lack of position position indication.
indication was observed by operators and discussed by the control room staff following the surveillance. That observation was not documented with a WRT or turned over to subsequent shifts for investigation. Also, during the performance of the surveillance on April 11, two system engineers were dispatched to damper IPV-2550B to verify its operation..Due to the normally limited movement of the damper, they concluded that it was open, when in fact it was deenergized and failed closed. After the performance of the-surveillance on April 11, a WRT was written identifying that the control room damper position indicators were not illuminated. That WRT resulted in the issuance of MWO 19401858 and the eventual discovery of the deenergized dampers by electri-cians on April 20.
The electricians informed the USS on April 20 of their discovery; however, this USS did not recognize the impact to the PPAFES.
It was not until April 24, during a review of the MWO package, that another USS identified the affect on the PPAFES.
Also, during the period from March 1 - April 11, numerous back panel control board walk-downs were conducted by licensed control room personnel, and the damper position indicators not being illuminated was not identified and corrected.
i 4
5.
Requirements l
Technical Specification 3.7.7, Piping Penetration Filtration and j
Exhaust System, requires that two independent P' 4FES shall be operable in Modes 1,2,3, and 4.
The ACTION st ament for TS 3.7.7 allows only one of the two systems (trains) to be inoperable for a e
period of seven days after which the Unit r G begin a shutdown.
i
]
No provision is made in TS 3.7.7 for both r.) cens being inoperable simultaneously and therefore the provisions of TS 3.0.3, Limiting Conditions for Operation and Surveillance Requirements, would l
apply.
In addition to the degraded condition of the PPAFES described above, the inspector was concerned about the adequacy of TS Sur-i veillance Requirement 4.7.7.d.3, which requires that at least once
i 5
per 18 months that the Piping Penetration Exhaust Unit Room be i
verified to maintain a negative pressure of greater than or equal to 0.25 inches WG relative to the outside atmosphere.
According to TS 4.7.7.d.3, this is the only location in which negative pres-sure is required to be measured within the piping penetration The piping penetration area includes numerous rooms at area.
The exhaust unit various elevations in the auxiliary building.
-room pressure is considered to be representative of a typical room in the PPAFES. The inspector learned during discussions with the system engineer and a review of system drawings, that the exhaust room pressure is maintained by manually adjusting ventilation duct supply and exhaust registers located within the exhaust room (one register on.the suction side of the filter unit and one register on the exhaust side of the filter unit) to achieve the desired A negative pressure can therefore be maintained in room pressure.
the exhaust room, by adjusting these registers, independent of the
+
position of the exhaust flow dampers, IPV-25508 and IPV-25518. It would appear that there is no relationship between the negative pressure measured in the exhaust unit room and the pressure in the other rooms within the PPAFES..This could explain how operators observed a negative room pressure on March 28 and April 11 when the exhaust flow dampers were closed.
In order to address the effect that the closed dampers would have had on off-site and control room dose limitations of 10 CFR 100 and GDC 19, if an emergency had occurred during the period that the dampers were closed, the licensee initiated a Request for Engineering Analysis, REA 94-VAA025, with its corporate headquar-ters engineering staff. The licensee's evaluation, based on the current ECCS leakage value, as determined by the visual inspection required by TS 6.7.4, Primary Coolant Sources Outside Containment, concluded that off-site and control room dose limitations would not have been exceeded. Vogtle personnel provided a copy of the REA to NRC for evaluation.
l This event is significant because an ESF system was in a degraded condition for 54 days during which time a negative pressure in the auxiliary building may not have been ensured during an event.
Additionally, numerous opportunities existed for the licensee to have prevented this event or to have identified the degraded
~
condition earlier.
Pending further NRC management review, this event is identified as Apparent Violation 50-424/94-15-01, Unit 1 l
Piping Penetration System Degraded for Extended Period of Time.
6.
Exit Meeting The inspection scope and findings were sussiarized on May 12, 1994, with those persons indicated in paragraph 1.
The inspector de-i scribed the areas inspected and discussed in detail the inspection findings. No dissenting coiunents were received from the licensee.
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6 The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during the inspection.
Description and Reference Item No.
APPARENT VIOLATION 424/94-15-01 Unit 1 Piping Penetration Ventilation System Degraded for Extended Period of Time 7.
Abbreviations-CFR
- Code of Federal Regulations CVI
- Containment Ventilation Isolation ECCS
- Emergency Core Cooling System ESF
- Engineered Safety Feature FSAR
- Final Safety Analysis Report HVAC
- Heating-Ventilation Air Conditioning IR
- Inspection Report MOD
- Minor Departure from Design MWO
- Maintenance Work Order NPF
- Nuclear Power Facility NRC
- Nuclear Regulatory Commission NRR
- NRC Office of Nuclear Reactor Regulation PPAFES
- Piping Penetration Area Filtration and Exhaust TS
- Technical Specifications USS
- Unit Shift Supervisor VIO
- Violation WG
- Water Gage i
WRT
- Work Request Tag
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'N'" **'c e" yy g39g4 LCV-0370 Docket No. 50-424 2
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U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 1
Ladies and Gentlemen.
l VOGTLE ELECTRIC GENERATING PLANT LICENSEE EVENT REPORT 7
CLOSED DAMPERS RENDER TWO TRAINS OF HVAC INOPERABLE In accordance with the requirements of 10 CFR 50.73. Georgia Power Company submits the enclosed report related to an event which was initially reported to the NRC per 10 CFR 50.72 (b)(2)(iii) on April 26.1994 Sincerely i
C. K. McCoy CKM/AFS
Enclosure:
LER l-91-003 xc:
Georgia Power Comoany Mr. J. B. Beasley, Jr.
Mr. M. Sheibani NORMS U. S. Nuclear Reculatorv Commission Mr. S. D. Ebneter, Regional Administrator Mr. D. S. Hood. Licensing Project Manager Mr. B. R. Bonser. Senior Resident inspector, Vogtle 2'
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On April 24,1994, exhaust dampers in both trains of the piping penetration area filtration and exhaust system (PPAFES) were found to be closed due to circuit breakers being deenergtzed while a j
design change was bemg performed on another air filtration system that utilized the same circuit breakers. The exhaust dampers were reenergized and restored to service. Concurrently, an initial l
determination was made, based on test results, that this condition had not rendered the system l
inoperable. On April 26,1994, a further engineering evaluation determined that having the exhaust dampers closed would limit the ability of the PPAFES to control radioactive releases in a post-l LOCA scenario.
i The cause of this event was cognitive personnel error and lack of attention to detail. This resulted in an inadequate review of the circuit breaker clearances associated with the design change. Also, subsequent personnel errors occurred which delayed the identification and resolution of the problem.
1 Personnel were counseled and additional training will be conducted to emphasize the importance of clearance reviews for proper configuration control.
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4 I Vogtle Electric Generating Plant - Unit 1 01510 lo lo 141214 9I4 01013 0 l 0 l 2 _ oF l
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.,-,.,,, mum A. REQUIREhENT FOR REPORT This report is required per 10 CFR 50.73 (a)(2)(v) because a condition existed that alone could have prevented the fulfillment of a safety function of a system needed to control the release of radioactive material It is also required per 10 CFR 50.73 (a)(2)(i) because the unit operated in a condition prohibited by the Technical Specification (TS) when a system was inoperable for a period of time longer than that allowed by the action statement.
B. UNIT STATUS AT TIhE OF EVENT l
At the time of this event. Unit I was operating in Mode 1 (power operations) at 100 percent of rated thennal power. Other than that descnbed herein, there was no inoperable equipment that contributed to the occurrence of this event.
C. DESCRIPTION OF EVENT The Unit 2 electrical penetration filtration system had never been installed and as part of a design change to abandon the Unit I system, on February 28,1994, and March 1,1994, personnel installed clearances by opening the applicable circuit breakers. These clearances removed power to several dampers in this filtration system. However, power was also unknowingly removed to piping penetration area filtration and exhaust system (PPAFES) train A and B exhaust dampers, IPV.
2550B and IPV-2551B. because they share circuit breakers with the system being abandoned. This left the PPAFES exhaust dampers in their closed positions and inoperable. These exhaust dampers open to preset positions to mamtain negative pressure during PPAFES operation. Thus, the PPAFES was limited in its ability to control the release of radioactive materials from the piping penetration rooms. had it become necessary to do so m a post-LOCA scenario TS surveillances were performed for the Train A PPAFES on March 15,1994, and April 11,1994, and for the Train B PPAFES on March 28,1994. Personnel noted that the position indication lights, used for verifying modulation of dampers IPV-2550B and IPV-2551B, were not illuminated during two of these three surveillances. During the March 28,1994, surveillance, an investigation of the apparent position indication problem was initiated, but was not pursued due to shift turnover.
Since the acceptance enteria for the surveillance was met, the surveillance was signed off as satisfactory. A more thorough and complete investigation was conducted during the April 11,1994, surveillance.
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AfUes9ER Vogtle Electric Generating Plant - Unit 1 0 l 5101010 l41214 _ 914 01013 010 13 or lt rwe -.
.,,.G, s wn Visual indication of 1PV-2550B valve linkage led the personnel involved to believe that the valve had actually moved to its preset demanded position, and a work order was initiated to effect repairs of the position indication. On April 20,1994, an investigation by an electrician, per the work order, revealed that both the indicator lights and the dampers were removed from service because the power had been removed The unit shift supervisor (USS) was notified that the position indication was lost due to the breakers being open However, he did not realize that opening the breakers had also removed power to the dampers On April 24.1994, during work order closecut, another USS recognized the impact on the PPAFES While reviewing the clearance for modification to reenergize the exhaust dampers, PPAFES testing was performed to determine operability. System flows, differemial pressures, and alarm indications all indicated normal, with :he only abnormality being the indication for the exhaust dampers. ARer discussion of the test results with the systen engineering supervisor and plant management, an initial determination was made that this condition had not rendered the system inoperable. However, plant management requested a design review of this condition to determine the complete impact to the PPAFES. Power was restored and the system returned to service.
l On April 25,1994, the design engineering staff began to evaluate the effect of the deenergized dampers on the operability of the system and on April 26,1994, it was determined that PPAFES had been rendered inoperable and that the safety function of the system had been degraded by the dampers being deenergized while in their closed positions. A four-hour non-emergency notification was made to the NRC Operations Center per 10 CFR 50.72 (b)(2)(iii) because a condition existed that alone could have prevented the fulfillment of a safety function of a system needed to control the release of radioactive material.
l l
A broadness review found that similar events had occurred when damper circuit breakers were I
deenergized for one train of PPAFES on three other occasions. Train A breakers were deenergized from October 28,1988, to November 9.1988, and from July 30,1992, to August 19,1992. One i
train B breaker was deenergized from August 8,1988, to August 26,1988. No Unit 2 events were found.
D. CAUSE OF EVENT i
The cause of this event was cognitive personnel error and lack of attention to detail by the operation work planner and the support shift supervisor (SSS). This resulted in an inadequate review of the circuit breaker clearance associated with the design change. The operation work planner's and SSS's j
reviews did not find the PPAFES train A exhaust damper on the appropriate breaker drawing or its respective load list because it was not listed on these documents. The PPAFES traia B exhaust i
i I
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-- a ~ec ew,, umm damper was shown on its respective drawing and load list, but these were not adequately reviewed since the train A and train B clearances were being developed at the same time.
Subsequent personnel errors committed during performance of surveillance testing and investigation of damper position indication prevented the early detection and correction of the clearance error.
The occurrence of these cognitive personnel errors by the Georgia Power Company personnel involved was not the result of any unusual characteristics of the work location.
A contnbuting cause of this event is that the single line diagram and electrical load list failed to specifically identify by equipment number that the train A exhaust damper was a device being powered from the affected circuit breakers. The single line diagram and electrical load list identified other dampers and an HVAC panel as devices being fed from the circuit breakers which were deenergized on February 28.1994. However. the tram A exhaust damper was also being fed from these circuit breakers via the HVAC panel.
E. ANALYSIS OF EVENT The functions of the PPAFES are to maintain a negative pressure boundary on the piping penetration area rooms and to filter the exhaust from those areas. Safety Evaluation Report dated July 9,1992, assumes iodine leakage from the piping penetration rooms and emergency core cooling system (ECCS) equipment to both offsite and control room locations during post-LOCA conditions.
Therefore, the controi room and offsite dose analyses are potentially affected by the degradation of this system caused by the inoperable exnaust dampers.
I Based upon the latest dose analpis, had the ECCS leakage risen to the design basis analyzed value of 2 gpm with the PPAFES exhaust dampers closed, the offsite dose would have remained within the 10 CFR 100 limits, and the control room dose would also have remained within the General Design Criteria 19 acceptance criteria.
Several other factors also existed that would have mitigated the consequences of this scenario:
1)
The latest surveillance value for ECCS leakage, based on the requirements ofTS 6.7.4 and taken during the last Unit I refueling outage, indicated the leakage was less than 0.1 gpm.
This would result in the expected source term being significantly less than the 2 gpm assumed in the design basis dose analysis.
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Vogtle Electnc Generating Plant - Unit 1 015101010141214 914 b 01013 010 l5 W lt 1w a-. ~ ~.
. ~.w m Although the PPAFES exhaust dampers were inoperable and would have resulted in an increase of radioactivity release, the filter and recirculation function of the PPAFES was operable and would have tiltered out a majority of the airborne radiation resulting from ECCS leakage.
Combining these two conditions of a low ECCS leakage value and the operability of the recirculation / filtration function of PPAFES being unaffected by the inoperability of the exhaust dampers results in maintaining the expected source term within the design basis dose analysis value.
2)
ECCS leakage which occurred would enter the auxiliary building in interior rooms below i
grade, and have to diffuse through several rooms or be transported via the filter system to rooms bordering on the exterior of the building pnor to release. After filtration, the expected discharge flow of 2700 cfm would have been retumed with the recirculation flow of 11760 cfm to the vanous ECCS rooms These rooms are typically provided with sealed penetrations and solid doors (not wire mesh) maintained closed for flood protection, radiation protection, fire protection etc, and would provide a substantial barner to radioactivity release. Therefore, the majority of the leakage would be processed through the PPAFES filters, perhaps being recirculated several times, prior to release. The leakage which bypasses the filters would have a long winding pathway to follow prior to exiting the auxiliary building and would be subject to natural removal processes along the way, such as settling and I
plateoul.
i 3)
The PPAFES charcoal filter iodine removal efficiency is supplemented by heaters that aid in decreasing humidity. Since the expected relative humidity at the charcoal filter inlet (following the guidance of Regulatory Guide 1.52) is much closer to the controlled environment value of 70 percent than to the uncontrolled environment value of 95 percent, the PPAFES efficiency ofiodine removal would be greater than that taken credit for in the design basis dose analysis. In addition, the filter actually has a bed depth of four inches as opposed to the two inches taken credit for in the accident analysis. Therefore, the recirculation / filtration which would occur would be more effective than discussed above.
Finally, there was no leakage event during the period of time involved. Based on these considerations, there was no adverse effect on plant safety or on the health and safety of the public as a result of this event.
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rw n.~.s _, _ _ ~ ~ uen F. CORRECTIVE ACTIONS
- 1) The work planner and SSS involved have been counseled on the significance of consguration control when preparing, reviewing, and approving clearances.
- 2) The operation work planners and system engineers will be trained regarding this event with emphasis on configuration control, by June 15,1994.
- 3) Licensed operators will review this event in continuing training by July 15,1994, with particular instruction on configuration control Emphasis will also be given to utilizin8 a questioning attitude when test indications are not clearly understood.
- 4) The appropriate Unit I and Unit 2 single line diagrams and electrical load lists, which failed to 1
identify by equipment number that the Train A PPAFES exhaust damper was being powered from the circuit breakers, have been corrected. An initial sample review of other breakers that power j
I similar loads revealed no further drawing problems. An additional review will be completed by August 1,1994
- 5) An evaluation of the test methodology for the current PPAFES TS surveillances will be completed with recommendations for system and procedure improvements by July 1,1994 t
G. ADDITIONAL INFORMATION I
1)
Failed Components:
None 2)
Previous Similar Events:
None 3)
Energy industry Identification System Code:
l Emergency Core Cooling System - BJ, BP i
Piping Penetration Air Filtration and Exhaust System - VA TOTAL P 03