ML20237J384
| ML20237J384 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 08/04/1987 |
| From: | Croley B, Esperanza E, Humenansky D SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | |
| Shared Package | |
| ML20237J375 | List: |
| References | |
| NUDOCS 8708180155 | |
| Download: ML20237J384 (31) | |
Text
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'u EXPANDED AUGHENTED SYSTEM REVIEH AND' TEST PROGRAM- l f .(EXPANDED ASRTP)
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EVALUATION; ..
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'OF.THE- j CONTROL ROOM / TECHNICAL SUPPORT CENTER ESSENTIAL HVAC l SYSTEM i l
SUBMITTED BY DATE: E-3-87
[/lfREN R. E$PERpA TEAM LEA'OER g
CONCURRENCE: @ i N 3 % c~, c DATE: # .5-5 ?
D HUMENANSKY
/ AVID / ~
/ EXPANDED ASRTP PROGRAM MANAGER CONCURRENCE: \ DATE:
/ B0B(CROLEY /
DIRECTOR, NUCLEAR TryCHNICAL SERVICES I
8708180155 870810 PDR ADOCK 05000312 i G PDR
w TABLE OF CONTENTS e
Pace Number i
1.0 INTRODUCTION
3 2.0 PURPOSE 4 3.0 SCOPE 5 4.0 OVERALL RESULTS AND CONCLUSIONS 6 5.0 DETAILED OBSERVATIONS - REQUEST FOR INFORMATION 9 6.0 ATTACHMENTS 27 6.1 List of Documents Reviewed 28 6.2 Status of RIs 31 4
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p EXPANDED AUGMENTED SYSTEM REVIEH AND TEST PROGRAM EVALUATION OF THE CR/TSC ESSENTIAL HVAC SYSTEM
1.0 INTRODUCTION
The Rancho'Seco Expanded Augmented System Review and Test Program j
[ASRTP] evaluation effort involves an assessment of the effectiveness of-the System Review and Test Program [SRTP] and an analysis of the adequacy of ongoing programs to ensure that systems will continue to function properly after restart. The Expanded ASRTP is a detailed system by system review of the SRTP as -
implemented on 33 selected systems and an in-depth review of the l engineering, modification, maintenance, operations, surveillance, inservice testing, and quality programs. It also conducts a review, on a sampling basis, of many of the' numerous ongoing verification and review programs at Rancho Seco.
Six multi-disciplined teams composed of knowledgeable and i' experienced personnel are tasked with performing the Expanded
-ASRTP. Each multi-disciplined team consists of dedicated personnel with appropriate backgrounds to evaluate the operations, maintenance, engineering, and design functional' areas.
Independence, perspective, and industry standards provided by team members with consultants, architect engineer and vendor backgrounds are joined with the specific plant knowledge of SMUD team members.
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Each team performs an evaluation on a selected system using the same fundamental evaluation techniques employed by the NRC in the ASRTP inspection. System Status Reports are used as the primary source of leads for.the teams. They are augmented with references to available source and design bases documents as needed. Team synergism and communication is emphasized during the process in order to enhance the evaluation. Each team prepares a final report for each completed selected system evaluated. This report is for the Control Room / Technical Support Center Essential (CR/TSC) HVAC j System.
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l 2.0 PURPOSE The objectives of the Expanded ASRTP evaluation are to (1) assess the adequacy of activities and systems in support of restart and (2) evaluate the effectiveness of established programs for ensuring safety during plant operation after restart.
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3.0 SC.0EE To accomplish the first objective, the HVAC team evaluated the CR/TSC ESSENTIAL HVAC system to determine whether:
- 1. The system was capable of performing the safety functions required by its design bases.
l 2. Testing was adequate to demonstrate that the system would perform all of the safety functions required.
- 3. System maintenance (with emphasis on pumps and valves) was adequate to ensure system operability under postulated accident conditions.
- 4. Operator and maintenance technician training was -
l adequate to ensure proper operations and maintenance of the system.
- 5. Human factors relative to the system and the system's supporting procedures were adequate to ensure proper system operations under normal and accident conditions.
To accomplish the second objective, the HVAC team reviewed the progtams as implemented for the CR/TSC ESSENTIAL HVAC system in the following functional areas: -
- 1. Systems Design and Change Control
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- 2. Maintenance
- 3. Operations and Training
- 4. Surveillance and Inservice Testing
- 5. Quality Assurance
- 6. Engineering Programs The HVAC team reviewed a number of documents in preparation for and during the Expanded ASRTP evaluation. This list of documents is found in Attachment 1, Section 6.0.
The primary source of leads for the team were the problems identified in the CR/TSC ESSENTIAL HVAC System Status Report.
Various source documents such as the USAR and Technical Specifications and available design bases documents were reviewed as needed to augment the information needed by.the team.
The evaluation of the CR/TSC ESSENTIAL HVAC system included a review of pertinent portions of support systems that must be functional in order for the CR/TSC ESSENTIAL HVAC system to meet its design objectives.
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4.0' OVERALL RESULTS AND CONCLUSIONS The more significant issues identified pertaining to the adequacy of the SRTP and the effectiveness.of programs to ensure continued safe operations after restart are summarized below. The summary focuses on the weaknesses identified during the evaluation. Section 5.0 provides detailed _ findings by providing the Request for Information (RI) forms that are used by the Expanded ASRTP teams to identify _
potential concerns during the evaluation. The numbers in brackets
. after each individual summary refer to the corresponding RIs in Section 5.0.
4.1 The Control Room /TSC, Essential Filtration System 4.1.1 There is a potential for the CR/TSC Essential Filtration System HEPA filter bank to become overloaded during a- high radiation event. In the high radiation mode 50% of outside air (contaminated) is mixed with 50% clean return air upstream of the moisture separator to capture particulate (such as dust) which could overload HEPA filter bank. !
l In the Rancho Seco CR/TSC Essential Filtration' System, the
! filtration units SF-A-7A and SF-A-78 each have a combination of moisture separator /prefilter in the housing. Performance documentation of the fiberglass pads in these moisture separator sections is inadequate. The installed pads may q not meet the prefilter efficiency requirements of ANSI N509-1980. Prefilters shall have an average dust-spot efficiency of not less than 45%._\The efficiency of.the moisture separator in the CR/TSC essential filtration unit is less than 45%. A review of the system also indicated l that the present instrumentation and surveillance may not '
detect dirty moisture separator /prefilters. : Additionally, there are no signals or alarms that record or inform Control Room operators of pertinent pressure drops and flow rates.
As a result, airborne dust could buildup in the face of the HEPA filter bank causing excessive pressure drop and reduced 1 fan capacity. Reduced fan capacity could cause CR/TSC space t pressure to fall below 0.125 inches water gauge higher than the CR/TSC boundary (design). (RI #006) (RI #045) 4.1.2 A review of the system indicates that during a high radiation event, the TSC may not be maintained at a positive pressure of at least 0.125 inches water gauges relative to the CR/TSC boundary as required by the design bases. During '
a high radiation event and toxic gas event, the CR/TSC Essential HVAC system is actuated and the TSC Normal Air Handler (AH-A-2) continues to operate as required.
Infiltration of unfiltered air through isolation dampers HV-54717 and HV-54718 can occur which makes static pressure on the Auxiliary Building side greater than the TSC side.
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OVERALL'RESULTS AND CONCLUSIONS (Continued)
As a result, continued inleakage may exceed the' amounts assumed for dose and chlorine concentration and could cause the area to become inhabitable. (RI #065) 4.2 The Control Room /TSC Essential HVAC
- 4. 2.1 - The System Status Report Problem 39 identified the CR/TSC Essential HVAC controls and operating status indication in the Control Room as being inadequate.
A review of the CR/TSC HVAC system indicates that: i
- 1. There is no local or Control Room annunciation to.
inform the operator to manually reset the condensing unit relay switch during power interruption. As a result, the condensing. unit will not autostart upon-receipt of Hi Temperature,.Hi Radiation, or Toxic Gas signal.
- 2. There is no annunciation for compressor crankcase.
heater failure (such as blown fuse). The compressor unit will automatically start upon receipt of Hi Temperature. Hi Radiation or Toxic Gas signal.
Operating the compressor without reaching the required crankcase temperature could cause-a low oil pressure and excessive bearing wear due to lubrication with oil which contains refrigerant. i '
Technical Specifications 3.13 and 4.10 requires the CR/TSC Essential HVAC system be operable during normal plant-operations or the plant must be shutdown within the specified time limits.. Consequently, the CR/TSC Essential HVAC system could be inoperable and in violation of Technical Specifications without plant personnel being aware of-the condition. (RI #042) 4.2.2- The CR/TSC Essential HVAC System Status Report, Problem 9, states, "The refrigeration system arrangement does not accommodate convenient or efficient maintenance of the system."
Few provisions have been made for the removal and replacement of heavy HVAC sections on the Auxiliary Building roof.
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7 QVERALL RESUi_TS AND CONCLUSIONS (Continu9d)
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At present there are no permanent cranes, hoists or monorails on the Auxiliary Building roof to facilitate the '
removal' of essential compressors, motors, fans or coil. The absence of rigging equipment will increase the. duration of.
major repair and could cause plant shutdown. Rancho Seco Technical Specifications, Section 3.13.3, requires the plant to go to hot standby if one CR/TSC Essential HVAC Train is ,
inoperable for more than 7 days, or both CR/TSC Essential HVAC Trains are inoperable for more than 3 5 days. '
A draft Maintenance Procedure (H.160) was-written for the
. removal and reinstallation of compressors and motors. This draft procedure is inadequate because of the ability of the Bantam Crane to pick the load in the limited available space. If the plant had to restart, renting and setting a-larger crane in order to complete needed maintenance would increase repair time by days. This could also necessitate a plant shutdown _by Technical Specifications. (RI #040) 1
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L i 5.0 DETAILED OBSERVATIONS - REOUEST FOR INFORMATION
- During an evaluation,, all potential concerns are documented on Request fer Information sheets (RIs) that are sent to the responsible organization to receive their input concerning the potential concern. RIs'are also used to request information that
' the EASRTP team is. having difficulty obtaining.
These RIs are considered drafts throughout the entire evaluation until they become part of the final report. Responsible organizations can accept the potential concern as valid or they may disagree with the potential concern. If they disagree, they can submit information that convinces the EASRTP team members that the potential concern is not valid, or they may redirect the EASRTP members to'better focus the concern. RIs developed during the system evaluation comprise this section of the report.
Attachment 2 of the report provides RI status as of this report date. An RI is considered closed if the Team Leader was convinced a potential concern was not valid or not significant enough'to be en RI. An RI would also be closed if requested information was
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provided. All other RIs are open. Acknowledged RIs are open RIs that have been accepted as valid by the responsible organization.
Approximately one week will be provided after the report is issued to provide time for departments to address each RI for validity. A revision to Attachment 2 will then be issued to reflect the status i of RIs. All RIs not acknowledged at the end of this period will L
have an "Open" status. RIs are then transferred into the Restart Scope List tracking system for resolution and corrective action implementation.
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i REQUEST FOR INFORMATION (RI)
RI NO: 006 SYSTEM CODE: CR/TSC HVS ISSUE DATE: 07-21-87
SUBJECT:
MCR/TSC ESSENTIAL FILTRATION UNIT PERFORMANCE !
DEPARTMENT: NUCLEAR ENGINEERING COORDINATOR: RON LAWRENCE TEAM MEMBER: J. S. GRILL TEAM LEADER: EFREd ESPERANZA POTENTIAL CONCERN /0VESTION:
The documentation of performance of the fiberglass pads in the moisture separator sections of filtration units SF-A-7A and-SF-A-78 is inadequate. The fiberglass pads may not meet the prefilter efficiency requirements of ANSI N509-1980. q SMUD Design Criteria 5108.10, Section 5.4.1, states that the safety-related air filtration systems shall be designed in accordance with the requirements of Reg. Guide 1.52, Rev. 2, ERDA 76.21, ANSI N509 1 and IEEE 323.
Reg. Guide 1.52, Section B, states "prefilters remove the larger particles and prevent excessive loading of the HEPA filters; to some extent demisters may also perform this function." ANSI N509-1980, (
Section 4.1, states "prefilters are required in units where design inlet particulate concentrations and particle size are such that the HEPA filter may be rendered ineffective." Section 5.3 states that prefilters shall have an average atmospheric dust-spot efficiency of not less than 45%.
The efficiency of moisture separators in capturing particulate is usually below 45% by weight. This means that most of the particulate (such as dust) entering the essential ' filtration units would go through the moisture separators and collect on the face of the first HEPA bank.
In the high radiation operation mode, 1,760 cfm of outdoor (contaminated) air is mixed with 1,760 cfm of clean return air upstream of the moisture separator. ,
During a long term. radioactive release and continuous filtration, airborne dust may build up on the face of the first HEPA filter bank-causing excessive pressure drop and reduced fan capacity. Likewise, high
- winds in conjunction with a radioactive release could overload the HEPA filter bank with dust. Reduced fan capacity could cause the MCR/TSC space pressure to fall below 1/8 inch w.g. (design).
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~r RILOO6 (Continued):
-The in-place DOP test for HEPA banks utilizes 0.3 micrometer. size particles (smoke). This test would not determine the effect of heavy dust loading. Likewise, IEEE 323 qualification tests normally do not-consider the effects of particulate.
In' summary..the dust removal efficiency of the moisture separators should-be determined and, if less than 457., additional analysis should be performed.
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- r .. . REQUEST FOR INFORMATION (RI)
- c. RI'N0: 009- SYSTEM CODE: _CR/TSC HVS ISSUE DATE: 22-87
SUBJECT:
LABELS ON 'A' CONTROL ROOM /TSC ESSENTIAL HVAC E0UIPMENT-DEPARTMENT: OPERATIONS COORDINATOR: R. MACIAS TEAM MEMBER: M. RICHARD TEAM LEADER: EFREN ESPERANZA POTENTIAL CONCERN /0UESTION:
. Equipment labels were found not to be in conformance with Administrative Procedure AP.23.15 in several cases during a. partial systam ^walkdown on the 'A Train Essential Control Room /TSC HVAC. !
t . Manual isolation valves HVS-007, HVS-009 HVS-Oll, HVS-017 and HVS-019 (P&ID M504 F-4) .gli lack valve identification tags.
. Breaker 2A323 label indicates the load on that breaker but does not indicate it is breaker "2A323". Breaker 10 is written on the door with " magic marker."' l
. Breaker IA324 label does not list HV-54727 as one of its loads as indicated on E-107 Sh. 27.
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- . REQUEST FOR INFORMATION (RI)
RI NO: 013 SYSTEM CODE: CR/TSC HVS ISSUE DATE: 07-28-87
SUBJECT:
MATERIALS USED TO SEAL THE CR/TSC ESSENTIAL HVAC SYSTEM PRESSURE _ ENVELOPE DEPARTMENT: SYSTEM ENGINEERS COORDINATOR: JOHN ITTNER TEAM MEMBER: BOB THOMAS TEAM LEADER: EFREN ESPERANZA i
POTENTIAL CONCERN / QUESTION:
'The Hardcast tape used to seal the essential air handling units and the Dow Corning 732 sealant used to seal the essential duct joints has not been documented as being qualified for long term exposure to the environment.
ANSI /ASME N509-1980; Nuclear Power Plant Air Cleaning Units and '
i Components, Section 4.12 states:
"All ESF housings shall be welded. Transverse joints of ESF ducts
- - may be welded or made with gasketed flanges."
Regulatory Guide 1.52; Design, Testing, and Maintenance Criteria for Post !
Accident Engineered-Safety-Features Atmospheric Cleanup System Air Filtration and Adsorption Units of Light-Hater-Cooled Nuclear Power Plants, Section Sc states: \
"The use of silicone sealants or any other temporary patching .
1 material on filters, housing, mounting frames, or dacts should not be allowed."
However, Dow Corning 732 sealant was used during the installation of the ducts to seal the flanged and gasketed joints. Also, during the startup testing of the Essential HVAC System, it was revealed that the air handling units could not meet the leakage criteria of ANSI N509-1980 due to inadequate design and fabrication of the unit housing. "Hardcast" i' tape was used to seal all of the joints of the housing based on assurance of qualification from the manufacturer of the tape. Upon evaluation of the qualification information available, it was determined that there was insufficient data available to establish a qualified life of the tape.
The inadequate qualification of Hardcast Tape and Dow Corning 732 Sealant has been documented by Problem 33 of the CR/TSC Essential HVAC System Status Report and NCR S-6576 respectively. Problem 33 states the "Hardcast" tape used to seal the Essential Air Handling Units against air j infiltration has not been documented as~being qualified for long term exposure to expected environmental conditions.
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F e RI-013 (Continued)
Procedure Rt-HVS-Oll, Refueling Internal Inspection of Hardcast Tape on Control' Room / Technical Support Center.(CR/TSC) Heating, Ventilation and Air-Conditioning System, has been issued to provide instructions for periodic inspection of Hardcast tape.. Maintenance Procedure H.168 is being prepared to provide detailed guidance in the repair of Hardcast tape.
The warranty period for Dow Corning 732 sealant is 10 years. However, a ,
SMUD procedure for periodic inspection, repair, and/or replacement of the- I sealana: has not been written.
In summary, these sealing materials do not meet regulatory requirements, are not yet qualifieo, and are not covered by all of the inspection and
- maintenance procedures required for degradable materials.
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, REQUEST FOR INF'ORMATION (RI)
L RI NO: 040 ' SYSTEM CODE: CR/_TSS HVS ISSUE DATE: 07-28-87
SUBJECT:
CP/TSC ESSENTIAL HVAC COMPONENT BJH0 VAL DEPARTHENT: MAINTENANCE COORDINATOR: JIH DARKE TEAM HEMBER: BRIAN A. KNOX TEAM LEADER: 'EFREN ESPERANZA l
POTENTIAL CONCERN /00ESTION:
Few provisions have been made for the removal and replacement of heavy HVAC components on the Auxiliary Building roof.
Section 3.13.3 of the Rancho Seco Technical Specifications requires the plant to go'to hot standby mode after the following:
. One CR/TSC essential HVAC train is inoperable for more than 7 days. l
. Both CR/TSC essential HVAC trains are inoperable for more than 3.5 days.
At present there are no permanent cranes, hoists or monorails on the d Auxiliary Building roof to facilitate the removal of essential HVAC j compressors, motors, fans or coils. This problem was identified in the CR/TSC Essential HVAC System Status Report (Problem 9) which states "The refrigeration. system arrangement does not acco(nmodate convenient or efficient maintenance of the system." -The absence of rigging equipment for the essential HVAC components will increase the duration of major repairs and could cause a reduction of plant generating time.
A draft maintenance procedure (H.160) has been written for removal and l reinstallation of the reciprocating compressors and their motors "!
(U-545A-C and U-545B-C). However, this draft procedure does not address the.following needs:
- a. There are no monorails, jib cranes or platforms to move heavy components from their housings to the edge of the roof.
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- b. The procedure doesn't provide instruction for removing essential fans, fan motors and coils.
- c. The procedure states that the compressors and compressor motors can ,
i be replaced with the on-site Bantam crane. With boom fully extended it will not be able to lift the condenser rolls. i 1
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RI-040 .(Continued)
The maximurn reach of.the Bantam crane boom is 75 ft. at a 16 degree angle. The blockLand hook makes it approximately 73 ft. The. roof is 60 ft. high with a 4 ft. parapet which makes the height of the wall approximately 64 ft. This leaves only 9 ft. for rigging (slings, choker, etc.)'and load. At that height, the load limit is reduced to 5300 lbs off the front of the Bantam crane and 3100 lbs off the back of the Bantam crane.
The only accessible place to make a " pick" is the east side of the stairwell between the Auxiliary Building and the-T&R Building. This
, lwould necessitate making the " pick" from the front of the Bantam crane.
Swinging the . load to the right over the Auxiliary Building and setting it behind the Bantam crane makes the maximum load only 3100~1bs (1-1/2 tons). Renting and setting up a larger crane would increase the repair time by days.
In summary, the absence of' adequate rigging equipment on the Auxiliary
' Building roof and procedures for its use,-could cause a plant shutdown.
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n , REQUEST FOR INFORMATION (RI)
RI NO: 041 SYSTEM CODE: CR/TSC HVS ISSUE DATE: 07-27-87
SUBJECT:
SETPOINT FOR ,' )ISH-54703B/PDISH-54704B DEPARTMENT: SYSTEM ENGINEERS COORDINATOR: JOHN ITTNER TEAM MEMBER: M. RICHARD TEAM LEADER: EFREN ESPERANZA POTENTIAL CONCERN /0 VEST [QN:
Technical. Specification 4.10.1.B.4 requires that "..the pressure drop.
across the combined HEPA filters and charcoal absorber banks is
< 6 incher. water gauge....". The pressure switches for total filter differential pressure for SF-A-7A/B (PDISH-54703B and PDISH-54704B) are set at 8~ inches water gauge, z 21 (Process Standards for HVAC). These switches will not alarm in the Control Room (computer points P2904/P2905) until the differential exceeds the Technical Specification limit by 2 inches water gauge.
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, REQUEST FOR INFORMATION (RI)
RI NO: 042 SYSTEM CODE: CR/TSC HVS_ ISSUE DATE: 07-27-87 '
SUBJECT:
CONTROL ROOM /TSCJSSENTI AL HVAC OPERATING STATUS INDICATION IN THE CONTROL ROOM IS NOT ADE00 ATE DEPARTHENT: NUCLEAR ENGINEERING COORDINATOR: R. LAWRENCE TEAM MEMBER: M. RICHARD TEAM LEADER: EFREN ESPERANZA POTENTIAL CONCERN /0UESTION:
During normal plant operations, the essential CR/TSC HVAC is required to be operable (Technical Specifications 3.13 and 4.10) or the plant must be shutdown within specified time limits. During review of this system, two conditions were identified that could affect operability, but which were not annunciated or indicated in the Control Room. One condition was a power interruption to the control circuit for the condensing unit and the other was a failure of the compressor crankcase heater. System Status Report Problem 39 identified the CR/TSC Essential HVAC controls and operating status indication in the Control Room as being inadequate.
INTERRUPTION OF CONTROL CIRCUIT POWER Any interruption of power to the control circuit for the CR/TSC Essential i HVAC condensing unit for any reason will render the condensing unit "not ready for auto start" until a manual reset button at the compressor is reset by an operator. When an interruption of power occurs, the 3CR relay (Ref: E-206 Sh. 154/155, DCN Sh. 3 of 3 for ECN R-0904D) requires manual reset to energize this relay prior to any auto start of the unit ;
on Hi temperature, Hi rad or toxic gas mode. There is no local or l control room annunciation / indication to inform the operator that the 3CR !
relay is not energized and, therefore, that the unit is "not ready for l autostart" (to indicate to the operator the need to reset this relay).
This lack of annunciation / indication could result in the unit not being ,
ready to perform its intended function.
FAILURE OF CRANKCASE HEATER j Operating Procedure A.14 (limits and precautions) states that "the l crankcase heaters for U-545A/B must be 'ON' for a minimum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> prior to compressor startup if the crankcase heaters were de-energized for one hour or longer." A compressor crankcase heater circuit is energized any time the control power is 'ON' and the compressor is not running (Ref: E-204, Sh. 154/155).
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,: RI-042 (Continued).
! Since the condensing unit is normally in a standby status (ready to start on Hi temperature, Hi Rad or toxic gas-signal), the heater circuit would normally be energized., Since there is no annunciation for heater failure
-(or blown heater fuse), such a failure could go undetected while the condensing unit isHin a standby status. With a failed heater..the unit could still. start'upon receipt of the start signal and operate with low oil pressure and_ excessive bearing wear due to lubrication with oil which contains refrigerant. The heater appears to be a " Required Auxiliary" (Technical Specification 1.3) for the Essential CR/TSC HVAC system, so a means to detect failure should be available.
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4 REQUEST FOR INF09MATION (RI)
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RI NO: 045 SYSTEM CODE: CR/TSC HVS ISSUE DATE: 07-27-87 L
SUBJECT:
MCR/TSC ESSENTIAL FILTRATION UNIT DESIEN__ _
DEPARTHENT: NUCLEAR ENGINEERING COORDINATOR:- RON LAWRENCE TEAM HEMBER: J. S. GRILL- TEAH LEADER: EFREN ESPERANZA POTENTIAL CONCERN /0VESTION:
The moisture separator sections in units SF-A-7A and SF-A-7B are not ,
instrumented in accordance with ANSI N509-1980, or drained in accordance- i with ERDA 76.21.
SMUD Design Criteria 5108.10, Section 5.4.1 states that the safety-related air filtration units shall be designed in accordance with the requirements of Reg. Guide 1.52, Rev. 2,' ERDA 76-.21, and ANSI N509. l Essential filtration units' SF-A-7A and SF-A-78 each have a combination moisture separator /prefilter bank in the housing. A magnehelic {
differential pressure gauge connected across the separator /prefilter bank j is provided. Two 2-inch external drain connections are supplied for the separator /prefilter section, but they are sealed with blind flanges. 7 Reg. Guide 1.52, Section C.2.g states that "the ESF atmosphere cleanup.
system should be instrumented to signal, alarnh and record pertinent pressure drops and flow rates at the control room." Table 4-1 of ANSI N509-1980 requires the following instrumentation: ]
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'* Local l
-- Demister/prefilter pressure differential indication -
- Prefilter high pressure differential alarm q 1
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- Remote Manned Control Panel
- Summation pressure differential alarm which includes the demister/prefilter differential Surveillance Test Procedures SP.84A and SP.848 require that the pressure differential across the moisture eliminators be logged monthly. However, the acceptable pressure drop (0.5 inches w.g.) is not provided in the J procedure. Bechtel Specification M13.16 lists the maximum permissible pressure drop as 0.5 inches w.g.
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, RI-045 (Continued)
Reg. Guide 1.52, Section C.3.h, states that " water drains should be designed in accordance with the recommendations of ERDA 76-21." ANSI H509-1980, Section 5.4, states that the moisture separators shall remove 99% by weight of the moisture in an airstream containing 1.5 to 2 pounds of entrained water per 1,000 cu. ft. of air. Bid Request M13.16, Section 9.6.2, states that the moisture separator shall remove water particles larger than 1 micron and shall collect and pipe the condensate to the housing drain.
The ASHRAE Handbook of Fundamentals indicates the particle diameter of fog ranges from 2 to 70 microns. The weight of the free moisture in fog common to the site was not provided in Specification M13.16. Some of the free moisture in the makeup airstream would be evaporated by the return air before reaching the moisture separator.
Bechtel P&ID H-504, Rev.13, indicates the moisture separator drains as capped with blind flanges. However, vendor print M13.16-1, Rev. O, indicates the drains uncapped. No notes are provided on P&ID H-504, in the System Design Bases (DB-HVS-5433A), or in the Design Basis Report for ECN A-3920A, B, C to explain why these drains should be rapped.
In summary, present instrumentation and surveillance may not detect a dirty moisture separator /prefilter. Also, existing design bas'is documents do not justify capping the moisture separator sump drains.
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i REQUEST FOR INFORMATION (RI)
RI NO: 059 SYSTEM CODE: CR/TSC HVS ISSUE DATE: 07-28-87
SUBJECT:
TRAINING OF BUILDING MAINTENANCE HVAC PERSONNEL IN ELECTRICAL HORK DEPARTMENT: MAINTENANCE COORDINATOR: ._, JIM DARKE TEAli MEMBER: J0EL HESTVOLD/ TEAM LEADER: EFREN ESPERANZA BRIAN KN0X-POTENTIAL CONCERN /0UESTION:
% review of training records indicates that Building' Maintenance (BM)
HVAC personnel have not received any formal training in electrical ]
. circuitry even though they are currently allowed to work on electrical control circuitry below 480 volts. This' apparent lack of training could affect the quality of QA Class I CR/TSC HVAC maintenance that has been performed on electrical circuitry.
-A review of.Hork Request (HR) #127110 and a draft of procedure M.160 seems to indicate that BM HVAC personnel are working on 480 volt power circuitry. This appears to be in violation of an informal agreement between BM and Electrical Maintenance (EM) which requires EM to do all 4,
power circuitry work of or above 480 volts.
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c REQUEST FOR INFORMATION (RI)
RI NO: 060 SYSTEM CODE: CR/TSC HVS ISSUE DATE: __.07-28-87__
SUBJECT:
CLOSURE AND RELEASE OF ECN R-1260 DEPARTMENT: SYSTEM ENGINEERING C0ORDINATOR: JOHN ITTNER TEAM MEMBER: JOEL HESTVOLD/ TEAM LEADER: EFREN ESPERANZA M0E RICHARD POTENTIALCONCERN/UUESTION:
The following apparent discrepancies were identified in the turnover, release and closure of ECNs R-0938 and NCR S-4761.
- 1) The ECN turnover / release packages are not being stored as QA records per the requirements of AP.44 and RSAP-0601. The packages are not 1 being stored in fire proof cabinets prior to turnover to the Records l Information Center (RIC). ;
- 2) The ECNs and NCR appear to have been closed prior to completion of !
required actions. The turnover package and ECN R-0958 identify the i need to address pressure tap installation in SP.618A/B. .The ECN has i been closed but SP.618A/B has ilot yet been issued. The turnover package and ECN punchlist for ECN R-1260 identify the need to address trap modifications in SP.84A/B and RT-HVS-Oll. The ECN has been closed but the procedures have not been revised. NCR S-4761 required mixing uniformity testing per STP.1063A/B. The NCR has been closed but the STP.1063B test results were rejected by the Test Review Group and retesting is necessary.
- 3) A walkdown of the pressure tap installation for ECH R-093.8 identified that the taps are not labeled. This may cause operator confusion during testing.
- 4) The revision to E-638, Sh. 7A to incorporate DCN lA for ECN R-0938 mistakenly addresses the calculation for Section D, E,.and F and l Detail 5 as Z-FPR-I-0482 instead of Z-FPP-E0482. The minimum thickness of Dow Corning 3-6548 Silicone foam for Section F was mistakenly identified as 9" thick instead of 11" thick.
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.c REQUEST FOR INFORMATION (RI)
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RI'NO: 065' . SYSTEM CODE: CR/TSC HVS ISSUE DATE: 07-28-87 1
SUBJECT:
PATH FOR POTENTIAL INFILTRATION INTO TSC DEPARTMENT: NUCLEAR ENGINEERING COORDINATOR: RON LAHRENCE TEAM MEMB'ER: BOB THOMAS TEAM LEADER: EFREN ESPERANZA POTENTIAL' CONCERN /00ESTION: }
The Technical Support Center (TSC) is not maintained at a positive pressure relative to one of the surrounding air spaces during the high radiation operation mode.
The System Design Bases (DB-HVS-5433A) states'that in the " radiological mode" the essential HVAC system shall maintain the control room (CR) and the TSC~at a positive pressure of at least 0.125 inch water gauge (IHG) l relative to the highest pressure adjacent to the CR/TSC boundary.
In the high radiation operation mode, the essential isolation dampers in-the makeup air ducts are opened and the CR/TSC spaces are pressurized by one essential filtration fan.
When the CR/TSC Essential HVAC System is actuated, the TSC Normal HVAC Air Handler (AH-A-2) continues to operate. Static pressure in the duct on the Auxiliary Building side of the TSC isolation dampers HV-54717 and HV-54718 is greater than that on the .TSC side (0.141HG differential when in the radiological mode, 0.45 ING in the toxic gas mode). As a consequence, any leakage past these isolation dampers will result in unfiltered infiltration into the TSC.
The CR/TSC habitability study completed in July 1987 assumed 100 cfm (pressurized) to 110 cfm (isolated) infiltration leakage rates into the control room. However, isolation dampers HV-54717 and HV-54718 are not periodically leak tested to quantify their leak rate during emergency operation.
In summary, the TSC operating pressure in the radiological mode does not meet the system design basis and the rate of inleakage may cause the total inleakage to exceed the amounts assumed for dose and chlorine concentration analyses.
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. REQUEST FOR INFORMATION (RI)
RI'NO: 070 SYSTEM CODE: CR/TSC HVS ISSUE DA1E: 07-28-87
SUBJECT:
CR/TSC ESSENTIAL HVAC ISOLATION DAMPERS DEPARTHENT: MAINTENANCE COORDINATOR: JIH DARKE TEAM HEMBER: B0B THOMAS TEAM LEADER: EFREN ESPERANZA POTENTIAL CONCERH/0UESTION:
The CR/TSC Essential HVAC isolation dampers will not be able to close when~they accumulate dirt. With low efficiency filters, dirt will accumulate, and no program could be identified to insure they are maintained in a clean condition. This problem was identified in the CR/TSC System Status Report (Problem 19) which states " isolation dampers not operating properly."
Tech Manual M13.14-472 for the CR/TSC Essential HVAC System isolation dampers includes recommendations to clean and lubricate the dampers on a periodic basis.
In an August 6,.1986, letter from J. Dodson to J. Naleway, the manufacturer further stated:
"There are no current standards for the performance of PAPCO Bubble Tight Dampers when contaminated by dirt o'r dust. Damper can operate
.in a dirty humid environment. They have performed the isolation function even when badly contaminated, but this has been in violation of the design conditions, and cannot be used as a basis for establishing any sort of performance level."
Proper operation of the CR/TSC Essential HVAC dampers is essential to provide a positive 0.125 inches water gauge relative to the surrounding atmosphere (Technical Specification 4.10.1 B.7).
In summary, the reliability of the isolation dampers for the CR/TSC is questionable because of heavy dust loading and an inadequate maintenance program.
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- e. REQUEST FOR'INFORMATION (RI)
RI NO: 075 SYSTEM CODE: CR/TSC HVS ISSUE DATE: 07-29-87
SUBJECT:
ENVIRONMENTAL QUALIFICATION OF HY-54727 DEPARTMENT: MAINTENANCE COORDINATOR: JIM DARKE e
TEAM MEMBER: JOEL HESTVOLD TEAM LEADER: EFREN ESPERANZA POTENTIAL CONCERN /00ESTION:
The lack of replacement of a solenoid at the time scheduled and the difference in replacement periodicity between MIMS and MARSS appear to be violations of the EQ program.
ERPT E-0177 identifies HY-54727 as necessary to be qualified per 10CFR50.49. To maintain this qualification, the Maintenance and Replacement Schedule Sn.mmary (MARSS) requires gasket replacement every 1.32-years with the first replacement due 8/86. The Nuclear. Engineering Group has stated that rather than simply replace the-gasket, the whole solenoid would be replaced. The MIMS system identifies a PM task to replace the solenoid every 1460 days with the first replacement scheduled for 12-01-86.= MIMS does not identify that this replacement has yet been accomplished. j
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, 6.0 ATTACHMENTS
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6.1 List of Documents Reviewed 6.2 Status of RIs
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i 6.1 LIST OF DOCUMENTS REVIEWED System Design Bases, DB-HVS-5433A, HVAC Systems for the Control Room and Technical Support Center, 07-03-87 SMUD Updated Safety Analysis Report, through Amendment 4, 10-01-86, Sections 1.5.15 and 9.7 Nuclear Engineering Design Criteria Manual, 06-29-87, Sections 5101.1 and 5108.10 Bid Request M13.16, Radiological Filtration Units, Class I, 01-27-82 l Bechtel P&I Diagram M-504, Rev. 13, 05-01-87 SMUD P&I Diagram, M-504, Sheets 1, 2 and 3, Preliminary Control Room / Technical Support Center Essential Air Conditioning System, System Status Report, Rev. 1, 12-05-86 Control Room Habitability Study, Rev. 5, 07-87 ,
Design Basis Report based on ECN R-0904, Rev. O, 04-18-87 Design Basis Report based on ECN R-1402, Rev. O, 06-30-87; CR/TSC f Essential HVAC Noise Reduction Design Basis Report based on ECN R-0769, Rev.\l, 06-22-87 Process Standards Manual, PSM 185, 07-03 R7; Section AP.154, Rev. 12, 10-07-86 Surveillance Procedure Manual, Rev. 26, 07-09-87, Procedures SP.84A/B, SP.485A/B, SP.618A/B (draft), SP.619A/B (draft) l Design Basis Report based on ECN A-3660Z, Rev. 1, 10-86 1 Design Basis Report for ECN A-3920A,B&C, 11-01-82 Elementary Diagram E-206, Sh. 154, Rev. 7c for ECN R-09040, 05-12-87, Control Room and TSC HVAC j
Administrative Procedure AP.23.15, Rev. O, 03-07-87, Equipment Labeling Operating Procedure A.14, Rev. 25, 07-14-86, HVAC System Operating Procedure A.14C Draft. 05-24-87, CR/TSC Building HVAC System Casualty Procedure C.51, Draft, 06-22-87, Loss of CR/TSC Ventilation l
ATTACHMENT 1 1
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, LIST OF DOCUMENTS REVIEHED (Continued)
. System Training Manual, Rev. O, 10-18-84, Chapter 11 Lesson Plan 00 24 D 3300, Rev. O, 12-24-86 Operator Tour Inspection Sheets, HP16368/D-0081B, undated Rancho Seco Technical Specifications, Rev. TSM-76, 05-12-87, Sections 3.13 and 4.10, and Proposed Amendment 161 to Section 4.10 SMUD Maintenance Manual M13.16-IM01 Vendor Print M13.16-1, Rev. O, AAL 574, House Assembly, Filter Vendor Print AAF 1327352, Sheet 1 of 5, Filtration Unit Instrumentation Bechtel Letter BSL-4403, 12-19-84, Hardcast Tape HVAC Maintenance Procedure, H.111, Air Balance of Ventilation Systems Preventive Maintenance Procedure, H.148, Cleaning Nucon BT and BTR Isolation Dampers Special Test Procedures STP.1059 and STP.1061, Operational Verification ,,
of the Refrigeration System for the CR/TSC Essential Air System Trains A/B,'and STP.1063ALB
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Routine Test Procedures RT-HVS-003, RT-HVS-005 and RT-HVS-011 Nonconformance Reports (NCR) S-4761. Rev. 1; S-5611, S-5663 S-6487, S-6576 and S-6634 Occurrence Description Report (0DR)86-279 and 86-280 Engineering Calculation MARSS file Z-EQP-E0068 and Z-EQP-E0074 Engineering Change Notices (ECN) R-0938 (including turnover / release packages 08R, SAR, DVR) and R-1260 (including packages DBR, SAR, DVR)
Hork Requests (hrs) 115770, 118907, 120454, 122339, 122340, 126236, 126237, 126814, 126815, 127110, 127111, 127112, 127114, 127130, 128628, 128452, 131284, 131285, 132621, 135252 Preventive Maintenance Work Request 63888 ATTACHMENT 1 k _ _m._..___ _..__ _m _______m___
.C a LIST OF DOCUMENTS REVIEWED (Continued)
. Drawing' Change Notices'(DCNs)
M-421, Sh. 5, R7, DCN SA; M-421, Sh. 6.,RS, DCN 3A; M-504, R10. DCN 19;
, I-1157, Sh. 5, R0, DCN SA; C-954, Sh. C, R0. DCN 2; E-641, R1, DCN SA; E-638, Sh. 7, R0, DCN 1A; E-638, Sh. 7A, RO, DCN 2A; E-639, Sh.1, RO, DCN 2A; E-639, Sh. 2, R0, DCN 1A; C-955, R0, DCN 3A; C-955, SH. K, R0, DCN 3; and M-504, RIO, DCN-17 QA Audits 87-10, 87-21, 87-23 and 87-24 QA Surveillance Reports 809 and 87-5036 Engineering Report E-0177 Field Problem Reports 1 and 2 to' ECN R-0938
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ATTACHMENT 1 l
1 e .o l: ;. 6.2 STATUS OF RIs a
l l RI NUMBER STATUS RSL NUMBER 006 OPEN 009 ACKN0HLEDGE RSL-RIOO9 013 OPEN 040 OPEN e
041 OPEN 042 OPEN 045 OPEN 059 OPEN 065 OPEN ,
070 0 PEN 075 OPEN h
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ATTACHMENT 2