05000423/LER-1997-022, :on 970218,improper Survillance Testing of CR Emergency Air Filtration Sys Filters Occurred.Caused by Lack of Trigger Mechanisms within Applicable Maintenance Procedures.Cr Air Filtration Sys Will Be Revised by 970315

:on 970218,improper Survillance Testing of CR Emergency Air Filtration Sys Filters Occurred.Caused by Lack of Trigger Mechanisms within Applicable Maintenance Procedures.Cr Air Filtration Sys Will Be Revised by 970315

ML20137E922
Person / Time
Site:	Millstone
Issue date:	03/20/1997
From:	Peschel J NORTHEAST NUCLEAR ENERGY CO.
To:
Shared Package
ML20137E889	List: 05000423/LER-1997-022, :on 970218,improper Survillance Testing of CR Emergency Air Filtration Sys Filters Occurred.Caused by Lack of Trigger Mechanisms within Applicable Maintenance Procedures.Cr Air Filtration Sys Will Be Revised by 970315
References
LER-97-022, LER-97-22, NUDOCS 9703280315
Download: ML20137E922 (4)

LER-1997-022, on 970218,improper Survillance Testing of CR Emergency Air Filtration Sys Filters Occurred.Caused by Lack of Trigger Mechanisms within Applicable Maintenance Procedures.Cr Air Filtration Sys Will Be Revised by 970315

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(viii) 10 CFR 50.73(a)(2)(ii) 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(iv), System Actuation 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
4231997022R00 - NRC Website

text

.. _ _. _ _ _ _.

___m 1

NRC FOR,M 366 U.s. NUCLE AR REGULATOR V Commission APPROVED BY OMB NO. 3160-0104 (4 95)

EXPIRES 04/30/98 I

INYoYa'tSoI"co' tite ioEmIoY[sh so NS E RTED L u^c?'?o^"4MP,"i "^n?Ee 45Mi~"a"M"=Po ^=.M LICENSEE EVENT REPORT (LER) 15ma'e ? =lga,yg g,;<ggsy,'gvangyg u

lAYsEa' ufos 3sE'Eo s"uEr"!. US$IEoI"?$Ns'oS'"*

(See reverse for required number of digits / characters for each block)

Ft.CIUTV NAME (11 DOCKET NUMBER (2)

PAGE (3)

Millstone Nuclear Power Station Unit 3 05000423 1 of 5 TITLE 141 Improper SurveillanceTesting of the Control Room Emergency Air Filtration System Filters EVENT DATE (5)

LER NUMBER (6)

REPORT DATE (7) oTHER FAr"LITIEs INVOLVED (8)

MONTH l DAY MONTH DAY YEAR YEAR sEoVENTIAL REVisloN YEAR FAciUTY NAME DOCKET NUMBER NUMBER 97 [^'* ***'

02 18 97 97 022 00 03 20 OPERATING 5

THis REPORT is SUBMITTED PURSUANT To THE REQUIREMENTsoF 10 CFR 5: (Check one or more) (11)

MODE (9) 20.2201(b) 20.2203(a)(2)(v)

Xl 50.73(a)(2)(i) 50.73(a)(2)(viii)

POWER 000 20.2203(a)(1) 20.2203(a)(3)(i) 50.73(a)(2)(ii) 50.73(a)(2)(x)

LEVEL (10) 20.2203(a)(2)(i) 20.2203(a)(3)(ii) 50.73(a)(2)(iii) 73.71 20.2203(a)(2)(ii) 20.2203(a){4) 50.73(a)(2)(iv) oTHER

~

20.2203(a)(2)(iii) 50.36(c)(1) 50.73(a)(2)(v)

Specify an Abstract below

~

20.2203(a)(2)(iv) 50.36(c)(2) 50.73(a)(2)(vii)

LICENSEE CONTACT FOR THis LER (12)

NAME TELEPHONE NUMBER linciude Area Codel J.M. Peschel, MP3 Nuclear Licensing Manager (860)437-5840 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

CAUSE

SYSTEM COMPONENT M ANUF ACTURE R HEPORTABLE

CAUSE

SYSTEM COMPONENT MANUFACTURER REPORTABLE TO NPRDS TO NPRDS SUPPLEMENTAL REPORT EXPECTED (14)

EXPECTED MONTH DAY YEAR YEs X No submission (If yes, Complete EXPECTED submission DATE).

ABSTRACT (Limit to 1400 spaces,i.e., approximately 15 single-spacedtypewrittenlines) (16)

On February 14,1997, with the unit in Mode 5, following the completion of a routine filter replacement for the "B" Train (3HVC*FLT1B) Control Room Emergency Air Filtration System, a discrepancy in the testing required to be completed prior to declaring the system OPERABLE was identified. It was confirmed on February 18,1997 that Technical Specification (TS) l Surveillance Requirements related to testing filter trains following replacement had historically not been performed prior to d:claring the trains OPERABLE. Specifically, two (2) historical instances were identified, one in each train of the Control l

Room (CR) Emergency Air Filtration System. Contrary to TS requirements, the system was prematurely declared l

OPERABLE prior to one of the required surveillances being performed. Therefore, this eventis reportable pursuantto 10CFR50.73(a)(2)(i)(B),as a condition or operation prohibited by plant technical specifications.

The cause of this event was determined to be to a lack of trigger mechanisms within applicable maintenance procedures or work orders to identify applicable surveillances for the affected system following a full or partial changeout of filter media.

i This event is significant in that the operability of both trains of the CR air filtration equipment was in question between March 1995 and November 1995. However, there was no adverse consequence as a result of this event in that no uncontrolled 1

radioactive releases have occurred that would have impacted the CR emergency air filtration system. Subsequent l

surveillance testing venfied that penetration and bypass leakage for the equipment was within acceptable limits.

NRC FORM 366 (4-95) 9703280315 970320 PDR ADOCK 05000423' s

PDR

-. - = - - - - - - - - -

- ~.

- - - -U.S. NUCLEAR REGULATORY CoMMtssioN (4-95)..

UCENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DOCKET NUMBER (2)

LER NUMBER (6)

PAGE (3)

YEAR SEQUENTIAL REVISION Millstone Nuclear Power Station Unit 3 05000423 NUMBER NUMBER 2 of 5 97 022 00 TEXT Uf more space is required, use additional copies cf NRC Form 366A) (17) 1.

Description of Event

On February 14,1997, with the unit in Mode 5, following the completion of a routine filter replacement for the "B" Train

('HVC*FLT18) Control Room Emergency Air Filtration System, a discrepancy was identified in the testing required to be completed prior to declaring the system OPERABLE. It was determined on February 18,1997 that Technical Specification (TS) Surveillance Requirements, related to testing filter trains following replacement, had historically not besn performed prior to declaring trains OPERABLE. This awareness of a missed surveillance was a result of an Operator training class, given in the latter half of 1996, on Situational Surveillances with emphasis on understanding Operations Surveillance Procedures usage and tracking.

Specifically, two (2) historical instances were identified, one in each train of the Control Room (CR) Emergency Air Filtration System. The dates for filter replacement for each train and for completion of required testing were:

Filter Bank Changeout Date Surveillance Completed CR "A" Train March 1995 November 1995 CR "B" Train April 1995 November 1995 i

Technical Specification (TS) Surveillance Requirement 4.7.7(f) states that *Each Control Room Emergency Air Filtration System shall be demonstrated OPERABLE: (f) After each complete or partial replacement of a HEPA filter bank, by vsrifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of Isss than 0.05% in accordance with ANSI N510-1980 for a DOP test aerosol while operating the system at a flow rate of 1120 CFM +/- 20%."

i Contrary to this requirement, the system was prematurely declared OPERABLE prior to one of the required surveillances being performed. This violates the TS surveillance requirement. Therefore, this eventis reportable pursuantto 10CFR50.73(a)(2)(i)(B),as a condition or operation prohibited by plant technical specifications.

l 1

i iI I

_i m_

.m._

...m_

m..

~ _. _. _. _ _. _ _ _.... _ _. _

IU.s. NUCLEAR REGULATORY COMMisslON (4-95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION l

FACILITY NAME (1)

DOCKET NUMBER (2)

LER NUMBER (6)

PAoE (3)

YEAR SEQUENTIAL REVISION Millstone Nuclear Power Station Unit 3 05000423 NUMBER NUMBER 3 of 5

)

97 022 00 I

TEXT fit more space is required use additionalcopies of NRC Form 366A) (11) i ll.

Cause of Event

The cause of this event was determined to be to a lack of trigger mechanisms within applicable maintenance procedures or work orders to identify applicable mquired surveillances following a full or partial changeout of filter media.

i 111. Analysis of Event L

This event is significant in that the operability status of both trains of the CR Emergency Air Filtration System equipment was in question between March 1995 and November 1995. The loss of the CR Emergency Air Filtration System could have resulted in a contamination of the control room and/or excessive exposure to operators following an uncontrolled rel ase of radioactivity.

There was no adverse consequence as a result of this of this event in that no uncontrolled radioactive releases have occurred in or near the CR that would have impacted the operability of the CR Emergency Air Filtration System. Each train of the filtration system was also successfully leak tested in November 1995. Consequently, the well-being of the operators was not endangered as a result of this condition.

IV. Corrective Acti.D 9

i l

Tha following corrective actions will be taken:

l 1.

Preventative Maintenance work orders for the CR Emergency Air Filtration System will be revised by April 15,1997 to incorporate the requirement to perform the Technical Specifications Conditional Surveillance after partial or complete HEPA filter replacement.

2. The Maintenance procedure for the CR Emergency Air Filtration System will be revised by August 1,1997 to incorporate the requirement for performance of Technical Specification Surveillance Requirement 4.7.7(f) following specified maintenance.

1 1

i

!l

_ -. -U.s. NUCLEAR REGULATORY Commission UCENSEE EVENT REPORT (LER)

TEXT CONTINUATION

[

FACILITY NAME (1)

DOCKET NUMBER (2)

LER NUMBER (6)

PAGE (3)

YEAR SEQUENTIAL REVISION Millstone Nuclear Power Stetion Unit 3 05000423 NUMBER NUMBER 4 of 5 97 022 00 i

TEXT (11more space is required, use additional copies of NRC form 366A) (11)

V.

Additional information

None l

l

Similar Events

LER 96-042-00 incompletely implemented Technical Specification Amendment Resultina in a Missed Surveillance on RMS Monitors On October 28th,1996 at 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br />, with the plant in Mode 5, it was discovered that Technical Specifications (TS) response time surveillance testing of Containment Fuel Drop Radiation Monitoring System (RMS) monitors 3RMS-RE41 and 3RMS-RE42 had not been performed. The l

RMS monitors were declared INOPERABLE and the containment purge & vent valves were shut as required by the applicable TS ACTION statement.

l This condition is reportable pursuant to 10CFR50.73 (a)(2)(i)(B), as any operation or condition prohibited by the plant's Technical Specifications.

l Response time testing of the Containment Fuel Drop Instrument channels will be completed prior to j

returning the Containment Purge & Vent to service. The procedure governing license amendment incorporation and implementation will be revised to clarify roles and responsibilities. Licensing l

personnel will be trained on the requirements and responsibilities associated with developing and l

processing Technical Specification change requests.

l l

LER 96-048-00

• Failure To Complete Technical Specification Reauired Testina Of CHS Pumo While Shutdown" On December 2,1996, with the plant in Mode 5, it was determined that a portion of the Technical Specification surveillancewhich tests the load shed function for both Emergency Diesel Generators

]

(EDGs) had not been performed in accordance with Technical Specification Surveillance 4.8.1.1.2.g.6.

This surveillanceis required to be completed once per 18 months during shutdown. Contrary to this, the surveillanceswhich tested the load shed for both trains of Charging (CHS) system pumps and re-energization feature for portions of the CHS system were performed during plant operation. The cause was determined to be a lack of verbatim compliance with the Technical Specifications. Contributing to this were ineffective corrective actions to identify " shutdown" surveillances, and incomplete updating of the Master Surveillance Test Control List (MSTCL) data base. The safety significanceof this event is minimalin that the mode in which the surveillances are performed has no physical affect on the ability to complete the surveillancesor the ability of the EDGs to perform their safety function. As immediate corrective action, the EDGs were declared INOPERABLE and the load shed surveillances

]

were performed during shutdown prior to restoring the EDGs to OPERABLE status.

l 4l 1

l

.~-.

- _. ~.... _ -. - - -

. ~. _.. ~. _. _ _ ~... -...

i iU.S. NUCLEAR REGULATORY COMMISSION l

14-9 5)..

UCENSEE EVENT REPORT (LER)

TEXT CONTINUAT!ON FACILITY NAME (1)

DOCKET NUMBER (2)

LER NUMBER (6)

PAGE (3)

YEAR SEQUENTIAL REVISION f

Millstone Nuclear Power Station Unit 3 05000423 NUMBER NUMBER 5 of 5 97 022 00 TEXT (If more space is required, use additional copies of NRC form 366A) (11) l i

1 i

Manufacturer Data i

4 Ells SvStem Code Control Building / Control Complex Environmental Control System VI l

Ells Component Code i

Filter FLT l

l l

i l

1 i

i 1

1 I

i

,