ML20203G079

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Unit 1 Offgas Sys Charcoal Adsorber Combustion Events Final Rept
ML20203G079
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 07/28/1986
From:
CLEVELAND ELECTRIC ILLUMINATING CO.
To:
Shared Package
ML20203G077 List:
References
NUDOCS 8607310314
Download: ML20203G079 (3)
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! PERRY NUCLEAR POWER PLANT - UNIT #1

OFF-GAS SYSTEM i

CHARCOAL ADSORBER COMBUSTION EVENTS 1

1 4 FINAL REPORT l

.I July 28, 1986

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( INTRODUCTION his report provides a compilation and discussion of the data associated with the Off-Gas System combustion events that occurred at Perry on June 20, ,

1986 and July 6, 1986. Condition Reports86-595, 86-596 and 86-656 will capture all the detailed data associated with the events. his report includes the Confirmatory Action Letter, dated June 23, 1986, our written recovery plan which addresses each item in the Confirmatory Action Letter and the details of our investigative analyses and results associated with the recovery plan.

The items addressed in this report under the corresponding tabs are:

O 1. Cenfirmaterv actien tetter. dated Jene 23, 1986

2. Written " Plan for Recovery From Charcoal Adsorber Bed Combustion Event",

dated July 11, 1986

3. General description and background of the Off-Gas Vault Refrigeration and Processing Systems
4. Analysis of the physical and chemical properties of the original and replacement activated carbon
a. In situ carbon samples following the first combustion event O

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O e. s me1es of en sed aer eer-cheeer ce. careon. 1ot 160s. estained fre-the on-site warehouse.

c. Nuclear Consulting Services, Inc. (NUCON) supplied carbon samples from the carbon intended for refill of the adsorbers
5. Analysis and determination of the mode of ignition for both combustion events
6. Analysis and determination of combustion and temperature effects on adsorber bed vessel and piping metallurgy for both events
7. Description of the adsorber thermocouple testing results O

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8. Description of carbon removal, system drying and replacement carbon installation activities
9. Description of the system testing activities to demonstrate the adequacy of the Off-Gas Vault Refrigeration and Off-Gas Processing Systems i

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10. Photographs showing Off-Gas System equipment and recovery activities l

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CONFIRMATORY ACTION LETTER s UNITO STATES

/p ase , A NUCLEAR RE ULATORY COMMisslON

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n ceaos m no noosavatt nono g stem sLLyn, stunois som O- June 23, 1986 Docket No. 50-440 Docket No. 50-441 The Cleveland Electric 111uminating Company ATTN: Mr. Murray R. Edelman Vice President Nuclear Group ,

Post Office Box 5000 Cleveland, OH 44101 Gentlemen:

This letter confirms the telephone conversation between Mr. E. G. Greenman of this office and Mr. Lyster of your staff on June 23, 1986, related to the recovery program for the off gas charcoal fire identified at Perry on June 20, 1986. With regard to this event we understand that you will :

1. Preserve all data and equipment associated with this event until the NRC has an opportunity to review and assess,the information.

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2. Maintain the charcoal adsorber beds in a sealed condition until the NRC O concurs that adequate precautions have been taken to preclude additional combustion. .
3. Provide a written recovery plan that will ba implemented after NRC concurrence that will address as a minimum, the following:
a. A determination of the ignition source and documentation of the activities leading up to the reporting of the fire,
b. The effects of the fire on the adsorber bed tanks and associated l

piping for the off gas treatment system.

c. The effect of the fire on the charcoal. This should address the method of sampling and analysis including the adsorber beds to be sampled.
d. If the charcoal is to be reused, an analysis demonstrating its adequacy shall be provided.
e. A description of any testing to demonstrate the adequacy of the charcoal beds and the associated equipment.

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3 ., a! J3  %W 'd k CONFIRMATORY ACTION LETTER

CONFIRMATORY ACTION LETTER The Cleveland Electric Illuminating 2 June 23, 1986 Company We also understand that startup of the reactor will not occur without concurrence of the Regional Administrator or his designee. Please let us know immediately if your understanding differs from that set out above.

Sincerely, o r :.br W' q &0 --

  1. JamesG.Keppler Regional Administrator cc: J. J. Waldron, Manager, Perry Plant Technical Department M. D. Lyster, Manager, Perry Plant Operations Department .

L. O. Beck, General Supervising Engineer, Nuclear Licensing and Fuel Management Section DCS/RSB(RIDS) ,

Licensing Fee Management Branch' Resident Inspector, RIII O Harold W. Kohn, Ohio EPA Terry J. Lodge, Esq.

James W. Harris, State of Ohio Robert H. Quillin, Ohio Department of Health l

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CONFIRMATORY ACTION LETTER

O PERRY NUCLEAR POWER PUNT UNIT #1 O PIAN FOR RECOVERY FROM CHARCtRL AIiSORBER BED COMBUSTION EVDTI l

July 11, 1986 Revision 5 O - N s-, o,e i r- aa tlt NAj ut swy

TABLE OF CCNTENIS O

J I. INTRODUCTICE II. PURPOSE OF RECOVERY PLAN III. RECOVERY TEAM ORGANIZATION IV.

SUMMARY

SYSTEM DESCRIPTION V.

SUMMARY

DESCRIPTION OF INITIAL CHARCOAL ADSORBER BED COMBUSTION EVENT A. ACTIVITIES IN PROGRESS B. DESCRIPTION OF THE EVENT VI. RECOVERY PLAN A. PIANT STA'IUS DURING RECOVERY PLAN EXECUTION B. DOCUMENIATION GATHERING AND ASSEMBLY C. OPERATION OF OFF-GAS SYSTEM EQUIPMENT D. ME'IHODOLOGY EVR DETERMINATION OF MODE OF IGNITION AND

('] COMBUSTION PROPAGATION U

E. METHODOLOGY EVR DETERMINATION OF COMBUSTION AND TEMPERA'IURE EFFECTS ON ADSORBER BED VESSEL AND PIPING METALLURGY F. PLAN FOR ENTRY AND INSPECTION OF ADSORBER BED VESSELS G. METHODOIOGY EVR PHYSICAL SAMPLING AND ANALYSIS OF ADSORBER BED CHARCOAL MATERIAL (SAMPLING IN THIS DOCUMENT REFERS 'IO PHYSICAL NCTI STATISTICT4L SAMPLING.)

H. METHODOLOGY EVR DETERMINATION OF ADSORBER BED EFFICIENCY DEGRADATION DUE 'IO PARTIAL COMBUSTION I. DESCRIPTION OF TESTING METHODS 'IO VERIFY ADEQUACY OF THE OFF-GAS VAULT REFRIGERATION AND OFF-GAS PROCESSING SYSTEMS VII. APPENDIX A - ADSORBER BED EVENT RECURRENCE A.

SUMMARY

DESCRIPTION OF JULY 6, 1986 CHARCOAL ADSORBER BED EVENT RECURRENCE B. DOCUMENTATION GA'IHERING AND ASSEMBLY EVR JULY 6,1986 CHARCOAL ADSORBER BED EVENT RECURRENCE O . _ . - . _ , - - -.._._ - __ - . .

VII. APPDIDIX A - ADSORBER BED EVENI' RECURRENCE (CCNTINUED)

C. OPERATICE OF OFF-GAS SYSTEM EQUIPMENT FOLIDWING 'IEE JULY 6,1986 QiARCOAL ADSORBER BED EVELT RECURRENCE D. DETERMINATION OF NEED FOR ADDITIONAL MET. ALLURGICAL EVALUATICES E. PIAN FOR CHARCCEL RENOVAL AND INSTALIATION OF NEW CHARCOAL IN

'IEE N64 OFF-GAS PROCESSING SYSTEM ADSORBER BEDS F. RETEST REQUIREMENTS OF THE OFF-GAS VAULT REFRIGERATION AND OFF-GAS PROCESSING SYSTEMS VIII. FULL RECOVERY FROM 'IEE CHARCCKL ADSORBER BED COMLUSTION EVENTS O

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I. RECOVERY PIAN INTRODUCTION O 1

'this Recovery Plan was first issued on June 26, 1986 to address recovery actions from the Unusual Event declared on June 20, 1986 as a result of combustion activity in some of the Off-Gas System charcoal adsorber beds. 'Ihe Unusual Event declared on June 20, 1986 was terminated on June 23, 1986 when the last temperature element reading fell below 250'F with a dramatic rate of decline exhibited.

Nitrogen (N2) Purge activities continued until adsorber bed vessel entry on June 27, 1986. After the charcoal sampling activities were completed, a nitrogen (N 2) blanket was established and remained on both A and B trains of adsorber beds. On July 3, 1986 a plan was formalized and concurrence was obtained from the U.S.N.R.C. for the reperformance of the Off-Gas Vault Refrigeration System (GEN-M-021) temperature pull-down test in parallel with ongoing charcoal and metallurgical analyses. However, entry into the Off-Gas preoperational test (section 6.12) would not occur without NRC Concurrence.

During the normal establishment of prerequisites, on July 6, 1986 a dry instrument air purge at 60 scfm was started through both A and B trains. Approximately one (1) hour after the initiation of the instrument air purge, the center thermocouples on adsorber beds 14A and 14B indicated temperatures greater than 250*F. At 2037 on July 6, 1986 an Unusual Event was declared based upon an indicated recurrence of the adsorber bed combustion event.

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t% Sis Recovery Plan will be updated to reflect revised portions of 5Q the original Plan as appropriate. Appendix A has been added to the Plan to address the recurrence of the adsorber bed combustion event.

II. RECOVERY PIAN PURPOSE h is recovery plan is intended to provide a logical, orderly and controlled approach for full recovery from the two (2) Unusual Events declared due to apparent combustion activity in the 14A and 14B Off-Gas System adsorber beds. This Plan provides a summary description of the activity that was in progress inanediately

! preceding both events and a brief description of the activities and actions taken during the events. Further, this plan will be implemented in full cooperation with the U.S.N.R.C. his Recovery Plan delineates the technical intent of recovery actions. The detailed approved Instructions and work orders will control actual work in the field. Should minor deviations from this Plan be deemed necessary, the on-site NRC representative will be informed. @is Plan delineates the methodologies and sequences for:

1. Documentation gathering and assembly
2. Operation of Off-Gas System Equipment
3. Determination of Mode of Ignition and Combustion Propagation O

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4. Determination of combustion and temperature effects on Msorber O Bed Vessel and Piping Metallurgy
5. Entry and Inspection of Msorber Bed Vessels
6. Physical Sampling and Analysis of Msorber Bed Charcoal Material
7. Determination of Msorber Bed Efficiency Degradation due to Partial Combustion
8. Testing Methods to verify adequacy of the Off-Gas Vault Refrigeration and Off-Gas Processing Systems O III. RECOVERY TEAM ORGANIZATION An organization has been formulated to execute the Recovery Plan in l an orderly, controlled and efficient manner. 'Ihe Recovery Team consists of:

A. Recovery Manager and Operations Representative - M. D. Lyster B. Assistant to the Recovery Manager - R. D. Bowers C. Fire Protection, Health Physics and Chemistry Representative -

S. J. Wojton O

Q D. PP'ID Technical Section Representative - S. F. Kensicki V

E. PPOD Maintenance Representative - D. J. Takacs F. Nuclear 'Itst Section Representative - G. R. Leidich G. Nuclear Engineering Department Representatives - C. M. Shuster and/or K. R. Pech H. Nuclear Quality Assurance Department Representatives - E. Riley and/or V. Higaki I. PPOD I & C Representative - R. P. Jadgchew and/or G. R. Anderson his organization will meet daily in SB320 at 8:00 a.m., Monday

! through Friday, (or as required), until termination of the meeting is deemed appropriate by the Recovery Manager.

IV. OFF-GAS CHARCOAL ADSORBERS [D012A(B), D013A(B), D014A(B), and D015A(B)1 f

1 h e eight (8) charcoal adsorbers are part of the N64 Off-Gas System, which is a non-safety, augmented quality system. As such, the

equipment was designed and procured to applicable criteria and codes which required no Equipment Qualification Program application. We l

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I adsorbers are arranged in two (2) trains of four (4) vessels each.

Each adsorber vessel contains approximately three (3) tons of activated coconut shell charcoal.

W ree (3) temperature elements are installed in each adsorber vessel i

near the top, center, and bottom elevations of the vessel. Refer to attached Figure 1 for specific locations and elevations of the

' temperature elements.

We adsorbers are located in the Off-Gas System charcoal vaults of the Off-Gas Building. We first adsorber of each train is located in a separate vault. he remaining three (3) charcoal adsorbers in each train are located in a separate vault along with two (2) process gas coolers. A basic schematic diagram of the system is included as Figure N64-1 for reference purposes.

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SUMMARY

DESCRIPTION OF CHARCOAL ADSORBER BED COMBUSTION EVETTT W is section of the Plan delineates those activities in progress at 1

the time of the initial event and those activities and actions which took place during the initial event through termination of the initial Unusual Event at 1125 on June 23, 1986.

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A. Activities In Progress Performance of GDI-M-021, generic mechanical testing, was in progress under work Order #86-7034 in response to Field Change 1 Request (FCR) #775 for testing of the tenperature pull-down capability of the Off-Gas Vault Refrigeration System in support of Off-Gas Processing System Preoperational Test (lN64C-P001).

We initial conditions for the IN64C-P001 Preoperational Test required the Adsorber Bed vaults, Adsorber Bed vessels and internal equipment to be at 150'r, prior to beginning the ,

temperature pull-down test.

4 B. Description Of he Event Radiant-type space heaters were being used to raise vault and equipment temperatures to 150'r. vessel charcoal temperatures were being monitored using permanently installed instrumentation consisting of internal thermocouples (3 per adsorber vessel, located at top, middle and bottom regions in the vessel) with readout in the control room using a 24-point

, pen recorder with a range of -50'r to 250*r. Vault air temperature was also being monitored using permanently installed instrumentation with a single-point readout in the Control Room, with a range of -50*r to 200'r.

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Initial heatup commenced at approximately 1100 on Wednesday, June 18, 1986. At 0600 on nursday, June 19, dry instrument air flow at 60 scfm total flow was initiated through the vessels to simulate process flow. At 1200 on Wursday, June 19, dry instrument air flow was increased to 100 scfm. Heating and temperature monitoring continued until 1815 on June 19, at which time point 17 (bottom of vessel D14A) was observed to be indicating a temperature of 230'F. We beaters in the "A" train vault were insnediately de-energized.

Point 17 indicated a temperature of 206'r one hour later.

At 2041, after approximately 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> of heating, point 16 (center of vessel D148) indicated "off-scale high" on the recorder. All remaining heaters were then de-energized. At 2120, two (2) additional points (center of vessel D14A and bottom of vessel D14B) were also indicating "off-scale high".

Instrumentation and control personnel were then dispatched to verify instrumentation readings. Instrument air flow of 100 scfm through the charcoal beds continued.

visual inspections of the vaults were made at 0020 on June 20, 1986. Smoldering paint and tape were observed. At l

I l 0100, June 20th, the off-gas vault refrigeration system was i

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started in the pull-down mode to cool the vault air and external surfaces of the adsorber vessels. h is cooling

' continued as did the 100 scfm instrument air purge internal to the vessels, until 1000 the following morning.

As the vault refrigeration system cooled the vessels externally, internal charcoal temperatures generally lowered 1

also. However, by this time, a total of seven permanently installed thermocouples had reached the upper readable limit of 250'r on the Control Room recorder. It was decided at this time to secure the instrument air purge in consideration of possible combustion of the charcoal. At 1145, the initial Unusual Event was declared by the shift Supervisor.

O A 5 to 10 scfm nitrogen purge was established through the vessels at 1219. Following establishment of the Ny purge, charcoal adsorber bed temperatures continued to be monitored.

hmperatures in the charcoal adsorber beds were trending downward. N2 purge and vault refrigeration were maintained throughout June 20, 21, and 22. By 0900 on June 22, all but one adsorber vessel temperature element reading fell below 250*F. At 1100 on June 23, the last temperature element reading dropped below 250*r and at 1125 the initial Unusual Event was terminated by the Shift Supervisor. We N 2Purge was maintained until adsorber bed vessel entry.

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VI. RECOVERY PIAN

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A. Plant Status During Recovery Plan Execution he plant will not enter Owrational Condition 2 until the questions surrounding the adsorber bed combustion events have been satisfactorily answered. Activities connected with normal plant operations and maintenance will continue. Further, the Non-Nuclear Heatup evolution will proceed as currently planned.

B. Documentation Gathering and Asrembly We initial adsorber bed combustion event will be documented by condition reports (C.R.) #595 and #596. All relevant data such as temperature element reading data sheets, temperature plots, adsorber bed vessel surface contact temperature versus time plots, strip chart recordings, calculation sheets, vault temperature versus time plots, detailed chronological logs of the event, a chronological description of activities from the time of space heater placement through declaration of the initial Unusual Event and a written evaluation of the adequacy of plant staff actions prior to and during the initial event will be captured by C.R.'s #595 and #596. Refer to Appendix A for discussion of documentation assembly related to the July 6, 1986 adsorber bed combustion event.

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C. Operation of Off-Gas System Equipment h e nitrogen (N 2) Purge of both A and B trains of adsorber beds will continue until the adsorber bed vessel flanges are ready to be removed. Upon NRC concurrence, the Off-Gas Vault Refrigeration System will be shut down to allow the vaults and adsorber beds to warm to ambient conditions and adsorber bed

- vessel skin temperatures to rise to a minimum of 60*F to allow metallurgical testing to proceed. Temporary lighting, scaffolding, temperature and humidity control enclosures will be erected in preparation for opening of the adsorber beds.

Every reasonable precaution will be taken to minimize the possibility of adsorber bed contamination.

>O D. Methodology For Determination of Mode of Ignition and Combustion Propagation i

To determine how ignition of the charcoal occurred, an engineering review and analysis will be conducted of all known data concerning the event. Wis data will include:

1. Temperature recordings of adsorber bed thermocouples, adsorber bed contact temperatures, and vault room temperatures.

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2. Operating conditions of the system at the time of the event and during subsequent response actions, including monitored stack effluent flow.
3. Results of inspections of the adsorber beds and associated equipment. .
4. Test data on charcoal combustion characteristics.

%e above data will be compared with all credible scenarios for ignition and propagation of ceabustion to determine which are supported and which can be rejected, and ultimately to reach a conclusion as to which was the most probable. The scenarios currently under evaluation include:

1. S e charcoal reaching its certified minimum ignition temperature.
2. We charcoal igniting at a temperature less than its certified minimum ignition temperature due to the presence of hydrocarbons.
3. We charcoal igniting at a temperature less than its certified minimum ignition temperature due to the presence of moisture.
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4. W e charcoal ignitin'g at a temperature less than its O certified minimum ignition tenperature due to the presence V

of excessive charcoal fines.

5. We effects of flow on ignition temperatures.
6. Consideration of the presence of glycol.

Charcoal receipt documents, charcoal storage requirements, charcoal installation procedures and adsorber bed layup requirements (post-charcoal installation) will be collected, reviewed, evaluated and captured by C.R.'s #595 and #596 in support of the scenario evaluations.

E. Methodology For Determination of Combustion and Temperature Effects on Adsorber Bed Vessel and Piping Metallurgy visual inspections will be made of all equipnent, piping, and components located within the charcoal vault in which the event took place. Equipnent which is found to have undergone any changes due to temperature effects will be evaluated. A.S.M.E.

code stamp considerations will be addressed as a result of this heat excursion and qualifications demonstrated or re-established as appropriate.

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O O A detailed walkdown of the vault on June 21, 1986 founi no J indication of thermal growth in piping and conduit lines, such as scratched paint or galvanizing at support locations. In addition, no abnormalities were found in adsorber vessel supports, adsorber connectors, rubber jacketing or flex l

conduit, vault sheet metal liners, or concrete floor slabs.

%e one abnormality noted was the discoloration / oxidation of the coating on two adsorber vessels, IN64D014A&B. %e discolorations are circumferential near the upper portions of the adsorber beds and are estimated to be three (3) to five (5) feet in height on adsorber bed 14A and five (5) to seven (7) feet in height on adsorber bed 14B. Wese discolorations indicate exposure to higher temperatures than elsewhere on the adsorber beds as no other discolorations have been noted.

Selected sites within the areas of discoloration will be examined metallurgically using a replication process which will allow the comparison of metal grain sizes between the heat affected and unaffected areas of the vessels. %e replication 4

process is described in detail in Attachment 1. We second method will be to use a sceleroscope (hardness tester) to obtain local hardness readings at both the heat affected and unaffected areas for comparison. %e use of the sceleroscope is described in detail in Attachment 2.

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In addition, temperature element readings on adsorber bed 14A bottom are in question. Se readings were low in comparison to other temperature elements within portions of the A train and in comparison to its corresponding location on the B train.

Contingency plans are in process for replacement of the 14A bottom temperature element if further evaluation determines the need for replacement.

i F. Plan For Entry And Inspection Of Adsorber Bed Vessels Based upon the fact that adsorber bed vessels 14A and 14B were the only beds noted to have coating discoloration bands, the current plan is to initially open and inspect beds 14A and 14B.

As previously discussed, the N2 Purge of both A and B trains of adscrber beds will continue until the flanges of adsorber beds 14A and 14B are ready to be removed. Upon NRC concurrence and completion of climate control, safety and fire protection prerequisites, the N2 Purge will be secured and the inlet train

{ piping will be valved closed and the outlet train piping will be valved open for venting requirements. his valve manipulation will retain the N2 inerting blanket in all adsorber beds to minimize the possibility of reignition of the adsorber bed charcoal material.

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[ Establishment of fire protection measures will include:

Staging of CO 2 fire extinguishers in the area with one right next to the adsorber cover area. Also water fire suppression will be available via the charged hose from the 620' level.

Water will be used as a last resort.

To ensure personnel safety, all individualr. involved in opening the adsorber bed vessels will be trained in the use of appropriate respiratory prot.ection apparatus prior to opening any adsorber bed flange. Further, a minimum number of personnel will be allowed to participate in the inspection process. 'Ihe inspection team will consist of the:

1. C.E.I. Metallurgist
2. C.E.I. Chemistry / Health Physics Representative
3. U.S.N.R.C. Representative i
4. G.E. Specialist
5. Support personnel as required.

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( Once the twelve (12) flange bolts on adsorber bed 14B have been detorqued, the flange will be removed and a protective covering placed on the adsorber bed vessel flange surface. A visual i inspection of the adsorber bed vessel interior surface will be conducted and any abnormalities noted and photographed or videotaped.

G. Methodology for Physical Sampling and Analysis of Adsorber Bed Charcoal Material Note: his is a swanary of the physical sampling and analysis plan. We development is underway on a detailed physical sampling plan. Once the detailed plan is completed it will be provided to the U.S.N.R.C. (he detailed plan was submitted and

! concurrence was obtained from the NRC prior to I

commencement of sampling activities.)

Representative charcoal physical samples will be taken to allow performance of coefficient of adsorption testing and other charcoal performance tests. Upon completion of the visual and photographic / videotape inspection of adsorber bed 14B, the exposed bed surface will be physically sampled. If ash is present, the ash will be sampled. Once physically sampled, the ash will be brushed aside until charcoal is reached. We charcoal will then be sampled.

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o Upon completion of the physical sampling process, the 14B adsorber flange will be reinstalled. Se inspection and sample process elapsed time will be kept to a minimum to avoid ogand moisture migration into the adsorber bed charcoal as well as to minimize other contaminants entering the bed. Upon coupletion of resealing of the 14B adsorber bed, the opening, inspection and sampling process will be repeated on the 14A adsorber bed.

H. Methodology For Determination Of Adsorber Bed Efficiency Degradation Due To Partial Combustion i

Each train of adsorber beds contains approximately 13 tons of O ctiv t a ch <ce 1- ^11 a c<d ba < i iti 11r ri11 a using procedure number GEP-IP-0040 - Filling of Charcoal Adsorbers.

h e first adsorber bed vessels (12A and 12B) in each train are required to have sufficient charcoal to cover all three tenperature elements. %e other three adsorber vessels in each train should have enough charcoal to at least cover the bottom two temperature elements.

W e adsorber bed charcoal material samples taken from 14A and i

14B will be tested to determine the in situ coefficient of

! adsorption and other charcoal tests. %ese tests will be conducted by a qualified contractor to determine if deleterious

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effects on the charcoal have taken place due to the event.

0 Q Preliminary calculations indicate that a) based upon purge air flow, b) absorbed 20 in the charcoal and c) 20 in the free air space above the charcoal, the worst case charcoal burnup is 762 pounds. Additional calculations to determine the amount of volumetric degradation will be made.

I. Description Of Testing Methods To verify Adequacy Of he Off-Gas Vault Refrigeration And Off-Gas Processing Systems

% e Off-Gas Vault Refrigeration System performance will be verified by documenting the cooldown rate of the refrigeration system from ambient temperature to O'F. This cooldown rate will be evaluated by the system designer, General Electric (GE), to determine its acceptability for overall system performance in accordance with the appropriate GE design specification. If the rate is unacceptable, modifications and/or retest will be specified by GE. %e acceptability of the vault refrigeration system will be finalized prior to any testing of the Off-Gas Processing System (N64C).

! We performance characteristics of the Off-Gas Processing System will be verified by performing Section 6.12 of the Off-Gas System preoperational test (IN64C-P001). The system designer, GE, will approve the test results via representation i

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on the '14st Program Review Committee. %ese test results will also be approved by the Plant Operations Review Committee prior to entering Operational Condition 2.

VII. APPENDIX A - ADSORBER BED EVENT RECURRENCE A. Susmary Description of July 6, 1986 Charcoal Adsorber Bed Event Recurrence On July 3, 1986 a plan was developed and co m rred with by NRC Region III, outlining the reperformance of the Off-Gas Vault Refrigeration System temperature pull-down test (GEN-M-021).

We testing methodology was revised per FCR #3444 to allow p

v pull-down ftom ambient temperature conditions rather than elevated temperature conditions.

At 1100 on Sunday, July 6, 1986 NTS personnel conducted a walkdown of the off-Gas System and Vaults to ensure the area had been cleared of all temporary facilities. At 1700 on July 6, 1986 NTS personnel again conducted a walkdown to ensure readiness of the off-Gas System and Vaults prior to starting the prerequisite activities for performance of the GEN-M-021 test.

', As part of the normal establishment of prerequisites, a dry instrument air purge at 60 scfm was initiated at approximately 1800 through both A and B trains via the A desiccant bed. At

.--_y . _ - . . - . _ , _ . _ . . - _ , . . . , _ , _ - _ - _ _ - . . _ . . _ _ _ _ - - _ _ _ _ , ._ , -- . - . - , . . . , - - _ _ _ _ - . ~ _ , . . _ , _ , - . - . , - , .

1910 NIS personnel noted that thermocouples for adsorber bed vessels 14A and 14B - center indicated greater than 250'F on recorder IN64-R613. Preparations were made immediately to secure the instrument air purge, enter the vaults and sample the effluent stream for combustion products. At 1942 the instrument air purge was completely secured.

'Iwmperature monitoring and effluent stream monitoring activities continued. By 2032, the adsorber bed 14A center thermocouple read 656*F and the 14B center thermocouple read 578'r using a millivolt meter by Instrumentation and control (I&C) personnel. At 2037 the shift Supervisor declared an Unusual Event due to indicated high charcoal bed temperatures.

'Ihermoccuple readings, adsorber bed vessel contact readings and effluent stream samples continued to be moni~ored.

c At 2307 on Sunday, July 6, 1986, a nitrogen (N2) purge was established through both A and B trains. Following establishment of the Ny purge, charcoal adsorber bed temperatures and effluent stream content continued to be monitored.

At 1645 on July 8, 1986 the Unusual Event was terminated with all temperatures trending downward and effluent stream samples indicating minimal combustion product presence.

O . .__ .- -- . _ _ . - .. .-. --.

B. Documentation Gathering and Assembly for July 6, 1986 Charcoal Adsorber Bed Event Recurrence h e adsorber bed event of July 6, 1986 will be documented by condition report (C.R.) 4656. All relevant data such as temperature element reading data sheets, temperature plots, adsorber bed vessel surface contact temperature versus time plots, strip chart recordings, calculation sheets, vault temperature versus time plots and detailed chronological logs of the event will be captured by C.R. #656. All data collected under C.R. #656 will be included with C.R.'s #595 and 4596.

C. Operation of Off-Gas System Equipment Following the July 6, 1986 Charcoal Adsorber Bed Event Recurrence h e nitrogen (N2) purge through both the A and B trains of I

adsorber beds will continue until the adsorber bed vessel flanges are ready to be removed. Temporary lighting and scaffolding will be erected in preparation for opening of the adsorber beds.

D. Determination of Need for Additional Metallurgical Evaluations visual examinations of the external surfaces of the adsorber bed vessels 14A and 14B will be conducted. Wese visual examinations are intended to identify any additional adsorber bed vessel coating discolorations. Additional photographs of

the external surfaces of the adsorber bed vessels 14A and 14B will be taken to photographically document the condition of the vessel external surfaces after the July 6, 1986 event.

Adsorber bed vessel contact temperatures and thermocouple temperatures taken during the July 6, 1986 event will also be reviewed by CEI and General Electric metallurgists to determine if any additional metallurgical examinations are required based upon this recent event. Preliminary data indicates temperatures much lower than previously experienced.

E. Plan For Charcoal Removal and Installation Of New Charcoal In W e N64 Off-Gas Processing System Adsorber Beds O Detailed reviews of temperature data, effluent sample data, charcoal heat transfer characteristics and charcoal adsorption and desorption characteristics have been performed. nese additional reviews have confirmed that adsorber beds 14A and 14B experienced combustion during the July 6, 1986 event.

'Ihese additional detailed reviews have also revealed the possibility of combustion activity in adsorber beds 15A and ISB. Based upon the fact that the 14A and 14B beds had been inerted with Ny for a period of approximately thirteen (13) days from the previous event and again combusted upon experiencing instrument air flow, the current plan is to O

completely empty all adsorber beds to prevent any further O combustion activity and to assure suitability of the charcoal material for use during plant operations.

A detailed Maintenance Temporary Instruction (MTI)-0006 -

Unloading, Drying and Loading of N64 Charcoal Adsorber Vessels is in development for removal of the charcoal from all adsorber beds. W e NRC will be supplied with a copy of MrI-0006 for review and concurrence. The NRC will be given prior notification and will provide concurrence before charcoal removal activities commence.

W e current plan is to remove the charcoal from adsorber bed vessels 13A, 13B, 14A, 14B, 15A and ISB in a wetted condition O and from adsorber bed vessels 12A and 12B in a dry condition.

A vacuum device will be employed to suction the charcoal from the vessels. Integral to the vacuum device will be a water eductor for mixing demineralized water of sufficient flow with the charcoal in the suction stream of the hose to further ensure quenching of potentially hot charcoal. Refer to Figure 3 for the configuration of the " dry" method of charcoal removal and Figure 4 for the configuration of the " wet" method of charcoal removal.

O

he charcoal in adsorber beds 13A, 13B, 14A, 14B, 15A and ISB Os will be wetted by a spray device, supplied by demineralized water, attached to the suction hose while the charcoal is being removed from the vessels.

We charcoal in adsorber beds 12A and 12B will be removed by suctioning without a spray device. Charcoal wetting in adsorber beds 12A and 12B has been determined to be both unnecessary and undesirable. We charcoal in adsorber beds 12A and 12B experienced no combustion and has experienced the longest and most efficient N2 Purge. We charcoal from each adsorber bed will be transported from the vacuum device to a receiving truck containing water for additional quenching. Se entire removal process is planned to proceed expeditiously to avoid any unnecessary exposure of potentially hot charcoal to the atmosphere so as to minimize any fire hazard. Disposal of the removed charcoal will be at a CEI fossil fueled plant.

We charcoal removal equipnent has been thoroughly tested by conducting a " dry run" of the charcoal removal process. We dry run simulated vessel depth and included water injection into the suction stream. Charcoal material, obtained from the on-site warehouse, has been suctioned from a container to demonstrate the lift capability and the quenching capability of the equipment. We personnel to be involved with the removal lO

' t

process have been thoroughly trained in the operation of the charcoal removal equipnent and hava participated in the " dry run".

As previously discussed, the N2 purge of both A and B trains of adsorber beds will continue until removal activities are ready to commence. Upon NRC concurrence and the completion of safety and fire protection prerequisites, the N2 Purge will be secured and both the inlet and outlet train piping will be valved closed. 'Ihis valve manipulation will retain the N2 inerting blanket in all the adsorber beds.

'Ib ensure personnel safety, all individuals involved in opening the adsorber bed vessels and charcoal removal activities will be trained in the use of appropriate respiratory protection apparatus prior to opening any udsorber bed flange.

Appropriate respiratory protection apparatus will be staged in the imediate area. Atmospheric monitoring of the area will be l

conducted to ensure a habitable atmosphere exists.

l l

Temporary water hoses will be staged at the adsorber bed vessel ,

! loading flange areas of adsorber bed vessels 13A, 13B, 14A, ,

i 14B, 15A and 15B with water supplied from the demineralized water system (P21). All work activities hence forth will proceed from the 15A and ISB adsorber beds to the 14A and 14B

O V adsorber beds to the 13A and 13B adsorber beds and conclude with the 12A and 128 adsorber beds. We current plan is to proceed with charcoal quenching and removal activities in parallel on both trains.

Establishment of fire protection measures will include staging of CO2 fire extinguishers in the area with one (1) right next to each adsorber cover area. Also water fire suppression will be available via the charged hose from the 620' level.

Upon establishment of the N 2 blanket, the thermocouples will be removed from the adsorber beds and replaced with blank flanges.

Se hydrostatic test connection flanges at the bottom of adsorber bed vessels 13A, 13B, 14A, 14B, 15A and ISB will be removed to allow excess water drainage. Upon completion of the test connection flange removal, the adsorber bed vessel loading flanges for all adsorber beds will be removed. Using the temporary water hoses, a water spray via the temporary hoses will be initiated intoI,adsorber beds 13A, 13B, 14A, 14B, 15A 9

. and ISB such that the sntire cross section of the adsorber bed i,

is continually wetted.! We water spray will be continued until

, approximately the firs ( three (3) feat of each adsorber bed I 13A, 13B, 14A, 14B, 15f and ISB, (approximately 100 gallons of

water), have been wettsd. h is wetting will quench any
remaining " hot spots" within the first three (3) feet of the bed in preparation for charcoal removal.

O  :

%e charcoal removal process will then coaunence with the 15A and 15B adsorber beds and proceed through each train to the 12A and 12B adsorber beds. Upon emptying each adsorber bed, a visual boroscope or television camera examination of the ,

adsorber bed vessel internal surface will be performed to ensure all charcoal material has been removed and to examine and document any abnormalities if present.

Nr7FE: he Maintenance Temporary Instruction (MTI)-0006 -

Unloading, Drying and Loading of N64 Charcoal Adsorber Vessel will more fully delineate the mechanics of system drying and charcoal installation.

Once the charcoal removal process is completed for all adsorber beds in the A and B trains, a general area cleanup and '

demobilization of charcoal removal equipment will proceed. We system will be drained of any excess water and additional drain points established if required. Upon completion of system

! draining, the adsorber bed vessel loading flanges and the hydrostatic test connection flanges will be reinstalled.

Upon completion of the demobilization and system boundary restoration, a drying process of the adsorber bed vessels and piping will be initiated. The current plan for drying is to establish a warm dry air purge of the system. Moisture content O

i i

of the drying air will be sampled regularly. %ermocouple ports may be used to obtain local samples of the vessel atmosphere.

Upon completion of the drying process, the air purge will be secured and the area and adsorber bed vessels will be readied for charcoal installation. Rigid environmental controls will be established to ensure no charcoal contamination occurs. he NRC will be given prior notification and will provide concurrence before charcoal installation activities commence.

Se adsorber bed vessels will be refilled using the Maintenance h mporary Instruction (MTI)-0006 - Unloading, Drying and Loading of N64 Charcoal Adsorber Vessel.

O F. Retest Requirements of the Off-Gas Vault Refrigeration and Off-Gas Processing Systems No testing will proceed on either the Off-Gas Vault i Refrigeration or Off-Gas Processing Systems without NRC concurrence. %e current plan for retesting is discussed in Section VI.I.

O

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VIII. FULL RECCNERY FROM WE CHARCCEL ADSORBER BED COMBUSTION E.V ENTS Figure 2 is the sequence of activities to be executed in support of this Recovery Plan. Upon successful completion of the sequence of activities, the charcoal adsorber bed combustion events will have been completely resolved and Off-Gas System adequacy demonstrated to allow entry into Operational Condition 2.

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%e Replication Process is a method by which the grain structure of a metal surface can be reproduced for laboratory examination without physically removing the sample from the field.

W e replication consists of preparing the metal surface using a three step polishing technique. hese steps are: (1) Rough grinding the surface with various grits (80-1000) of silicon carbide paper; (2) Intermediate polishing of the surface with 9 micron diamond paste with lapping oil and (3) finally etching the surface with a standard 3% nital etchant.

Once the surface is prepared, blue replica tape (1/2"x1") is applied.

h is tape will provide a negative of the grain structure being investigated. Se tape is then secured to a glass slide. A preliminary evaluation of the replica quality is made with a field microscope. Final analysis and documentation of the structure is deferred until the replica is returned to the laboratory.

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Attachment 2 O

A sceleroscope is a portable hardness tester which operates on the pginciple of measuring the height to which an indenter rebounds from the surface of a test piece. his indenter is spring loaded and then released onto the surface and the rebound is automatically read and assigned a hardness number.

Spring loading allows the sceleroscope to be used on a test piece in positions other than flat.

W e mark left on the test piece by the indenter is insignificant.

Prior to testing, the surface is ground smooth with medium grit to assure uniform surface preparation in the areas to be tested.

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