05000328/LER-1985-012-04, :on 851211,during Mode 5,Train a Containment Hydrogen Analyzer Connected to Unqualified Reagent Air Source & Declared Inoperable.Caused by Personnel Error. Reagent Air Being Modified

:on 851211,during Mode 5,Train a Containment Hydrogen Analyzer Connected to Unqualified Reagent Air Source & Declared Inoperable.Caused by Personnel Error. Reagent Air Being Modified

ML20137E714
Person / Time
Site:	Sequoyah
Issue date:	01/08/1986
From:	Frye M, Wallace P TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
LER-85-012-04, LER-85-12-4, NUDOCS 8601170303
Download: ML20137E714 (4)

LER-1985-012, on 851211,during Mode 5,Train a Containment Hydrogen Analyzer Connected to Unqualified Reagent Air Source & Declared Inoperable.Caused by Personnel Error. Reagent Air Being Modified

Event date:
Report date:
3281985012R04 - NRC Website

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On December 11, 1985, at 1200 CST with unit 1 in mode 5 at 0 psig and 124 F and unit 2 in mode 5 at 150 psig and 125 F, it was discovered that reagent air for the unit 2 "A" train containment hydrogen analyzer was connected to a nonessential ~

air source. Because of this condition, the monitor was declared inoperable.'

The monitors reagent air had been changed from an essential air source to the /

nonessential air source as part of a mdification performed during the unit 2, cycle 2 outage. The unit returned to mode 2 from the outage on December 26, 1984, and continued to operate until shutdown on August 21, 1985. This operation is now considered to have been in violation of Limiting Condition for Operation (LCO) 3.0.4 and 3.0.3 which is reportable per =10 CFR M 73, The condition was discovered durinc ? Le system walkdown l erformed by the i

Sequoyah Nuclear Plant's Quality fut 9. P - :e Group. Actions have been implemented%

to reconnect the monitor to the es.entim s.tr supply, and work will be completed prior to unit 2 reentering mode 2.

Due to the existence of a redundant train of containment hydrogen monitoring, post-accident sampling provisions for taking containment hydrogen samples, and the use of the hydrogen ignition system, this ' event is not considered to have affected the public health and safety.

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.m aw wc r assaw im Description of the Event On December 11, 1985, at 1200 CST wigh unit 1 in mode 5 at 0 psig and 124 F and unit 2 in mode 5 at 150 psig and 125 F, it was discovered that the reagent air for unit 2 "A" train containment hydrogen analyzer was connected to the nonessential control air system. This condition was discovered during a plant system walkdown by the Sequoyah Nuclear Plant's (SQN) Quality Surveillance Group. The nonessential air supply is not seismically qualified; therefore, it cannot be considered reliable for providing a safety-related function.

Because the monitor was determined to be connected to an unreliable air supply, it was declared inoperable.

During the unit 2, cycle 2 refueling outage, a modification was performed on the hydrogen analyzer system per Engineering Change Notice (ECN) 6032 to move the test gas bottles and control outside the unit 2 Containment / Shield Building annulus.

Part of the modification caused the "A" train hydrogen analyzer to have its reagent air supply changed from an essential air source to a nonessential air source. Because the monitor is considered inoperable under this condition, reentry q

into mode 2 on December 26, 1984, is now determined to have been in violation of Limiting Condition for Operation (LCO) 3.0.4.

In addition, the unit continued to operate past the 30 days specified in LCO 3.6.4.1 action criteria and, therefore, was also in violation of LCO 3.0.3 until shutdown on August 21, 1985.

.V The hydrogen analyzer does not provide any automatic functions and is normally maintained in the standby mode; therefore, this condition did not have any effect on any additional plant equipment.

Cause of Event

l While scoping out the work to be performed on ECN 6032, the cognizant modifications l

engineer noted that nonessential air was available in the area where units 1 and 2 i

"A" train monitors were to be relocated but essential air would have to be piped in.

He contacted the engineer in charge of the hydrogen analyzer system in the Office of Engineering (OE), the TVA design group, to determine if the nonessential air supply was acceptable for use as reagent air.

The OE engineer verified that it could be used; therefore, the modifications engineer wrote Field Change Request (FCR) 2468 to implement the change. The FCR was processed and approved through the normal channels. The work was completed on unit 2 as specified in ECN 6032 with changes authorized by FCR 2468.

When work was actually started on unit 1, the modifications cognizant engineer discovered that essential air could be supplied to tne "A" train hydrogen analyzer without undue cost impact; therefore, he wrote FCR 3275 to amend FCR 2468 and maintain the reagent air supply for that monitor to the essential air source.

This FCR was processed and approved through normal channels.

The root cause of this event is a cognitive personnel error on the part of the OE engineer performing the technical analysis on the change requested in FCR 2468.

He misinterpreted the hydrogen analyzer technical manual in relationship to the

" function of the reagent air with respect to the analyzer operation.

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.is4..nn interpretation that reagent air was only used for calibrating the analyzer; therefore, an essential air supply was not required for the performance of its normal safety function. Additionally, the reagent air supply to the hydrogen analyzer was not included in the list of required lusds for the design criteria for the essential air system. Further evaluation has revealed that the reagent air is required at all times for the operability of the analyzer.

Analysis of the Event

This event is considered to have caused unit 2 of SQN to operate in a condition prohibited by its technical specifications. This condition is reportable per 10 CFR 50.73, paragraph a.2.1.B.

The "A" train hydrogen analyzer is technically considered inoperable because the nonessential air supply used for its reagent air is not seismically qualified.

In the event where a loss of coolant accident (LOCA) existed and a seismic event also occurred, the monitor would not be available to perform its design function.

The "B" train monitor was connected to essential air and is fully operational.

Also, the hydrogen ignition system is energized during a LOCA to prevent the buildup of hydrogen in containment. In addition, the postaccident sampling system has provisions for :aking containment air samples which can be analyzed for hydrogen content. Because of the additional provisions made for the detection and rdtigation of a potential hydrogen buildup during a LOCA, this event is not considered to have had any effect on the public health and safety.

Corrective Actions

The reagent air for the unit 2 "A" train hydrogen analyzer is being modified to return its supply source to the essential air system. This work will be completed i

before unit 2 is returned to mode 2, where the analyzer is required operable.

The design criteria for the essential air supply is also being revised to add the hydrogen analyzer to the list of equipment required to be supplied f rom that source.

Additional Information

The hydrogen analyzer that was af fected by this event was manufactured by Consip Delphi Incorporated and its model No. is K-IIIM.

During the investigation process, it was discovered that both vendor and TVA control drawings showed the wrong designation for control of the reagent air supply solenoid valve (FSV-43-210 A). The wiring drawings and all operation and testing instructions for the analyzer have been verified and are correct; therefore, this error does not effect proper operation.

The drawings will be revised to show proper control configuration.

There are no previous events of this kind.

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M TENNESSEE VALLEY AUTHORITY Sequoyah Nuclear,Planti Post Office' Box 2000 :

- Soddy' Daisy,:. Tennessee. 37379-January 9,.1986 1

J-U.S. Nuclear Regulatory Commission' Document: Control -Desk i~

Washington, - DC 20555

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k Gentlemen:

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' TENNESSEE VALLEYJAUTHORITY - SEQUOYAH NUCLEAR' PLANT-UNIT:2

- DOCKET NO.

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50-328 FACILITY OPERATING' LICENSE'DPR,79,-~ REPORTABLE,0CCURRENCE REPORT

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SQRO-50-328/85012 Theenclose'dlicensee: event lreportprovidesde$ ails,concerbingthe I

inoperability of the unit'2 "A" train containment ~ hydrogen ulyzer.

j This event'is reported in accordance'with 10'CFRL50.73, paragraph a.2.i..

b Very truly yours, TENNESSEE VALLEY AUTHORITY 4

o. a. LnA- _--

P. R. Wallace Plant Manager.

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k Enclosure cc (Enclosure):

m J. Nelson Crace Regional Administrator

- U.S. Nuclear E sgulatory Commission Suite 2900 101 Marietta Street, NW Atlanta, Georgia 30323 l

t Records Center Institute of! Nuclear Power Operations,-

i si Suite 1500

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1100 Circle 75. Parkway.

Atlanta,. Georgia--30339

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.NRC Inspector,;NUC PR, Sequoyah?

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,1983-TVA 50TH ANNIVERSARY-

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, An Equal Opportunity Employer,c

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