ML18012A250

LER 96-007-00:on 960425,failed to Perform Tech Spec Surveillance Testing Per Specification 4.7.6.d.3.Caused by Inadequate Procedure Development.Satisfied Differential Pressure Testing requirement.W/960528 Ltr

ML18012A250
Person / Time
Site:	Harris
Issue date:	05/28/1996
From:	Chaplin S, Donahue J CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HNP-96-089, HNP-96-89, LER-96-007, LER-96-7, NUDOCS 9606030046
Download: ML18012A250 (10)

Text

~CATEGORY 3 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)ACCESSION NBR:9606030046 DOC.DATE: 96/05/28 NOTARIZED:

NO FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina AUTH.NAME AUTHOR AFFILIATION CHAPLIN,S.

Carolina Power&Light Co.DONAHUE.J.W.

Carolina Power&Light Co.'RECIP.NAME RECIPIENT AFFILIATION DOCKET¹05000400

SUBJECT:

LER 96-007-00:on 960425,failed to perform Tech Spec surveillance testing per specification 4.7.6.d.3.Caused by inadequate procedure development.

Satisfied differential pressure testing requirement.W/960528 ltr.DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE: TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc.NOTES:Application for permit renewal filed.E 05000400 RECIPIENT ID CODE/NAME PD2-1 PD INTERNAL: ACRS AEOD/SPD/RRAB NRR/DE/ECGB NRR/DE/EMEB NRR/DRCH/HICB NRR/DRCH/HQMB NRR/DSSA/SPLB RES/DSIR/EIB EXTERNAL: L ST.LOBBY WARD NOAC MURPHYIG A NRC PDR COPIES LTTR ENCL 1 1 1 1'1 1 1 1 1 1 1 1.1 1 1 1 1 1 1 1 1 1 1 RECIPIENT'D CODE/NAME LE,N AEO ILE CENTER NRR/DRCH/HHFB NRR/DRCH/HOLB NRR/DRPM/PECB NRR/DSSA/SRXB RGN2 FILE 01 LITCO BRYCE,J H NOAC POORE,W.NUDOCS FULL TXT COPIES LTTR ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 2 2 1 1 1 1 Y D 0 N NOTE TO ALL"RIDS" RECIPIENTS:

, PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESKS ROOM OWFiV SD-5(EXT.415-2083)TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 26 ENCL 26 V I,I Carolina Power 8 Light Company Harris Nuclear Plant PO 8ox 165 New Hill NC 27562 U.S.Nuclear Regulatory Commission ATTN: NRC Document Control Desk Washington, DC 20555 MAY 28 l996 Serial: HNP 96 089 10CFR50.73 SHEARON HARRIS NUCLEAR POWER PLANT UNIT 1 DOCKET NO.50-400 LICENSE NO.NPF-63 LICENSEE EVENT REPORT 6-007-00 Gentlemen:

In accordance with Title 10 to the Code of Federal Regulations, the enclosed Licensee Event Report is submitted.

This report relates to inadequate testing of the Control Room Emergency Filtration System pursuant to Technical Specification Surveillance Requirement 4.7.6.d.3.

Sincerely, J.W.Donahue General Manager Harris Plant SDC Enclosure c: Mr.J.B.Brady (NRC-HNP)Mr.S.D.Ebneter (NRC-Rll)Mr.N.B.Le (NRC-PM/NRR)'tt60603004h 960528 PDR ADOCK 05000400 8 PDR State Road 1138 New Hill NC 0 4 I1 a/I II'J lf e NRC FORM 366 (4G5)U.S.NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)(See reverse for required number of digits/characters for each block)APPROVED BY OMB NO.3150-0104 EXPIRES 04/30/96 ESTNATED BURDEN PER RESPONSE TO COMPLY WITH TIRE MANDATORY It(FORMATION COllECTIGtt REDDEST: 50/)HRS.REPOR'TED lESSONS LEARNED ARE It(CORPORATED INTO TH'E LICENSIIIG PROCESS ANO FEO BACK TO U(OUSTRY, FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION ANO RECORDS MANAGEMENT BRANCH IT4)F33L U S.NVCIEAR REGVIATORY COMMISSION.

WASHII(GTON.

OC 20555000(, ANO TO THE PAPERWORK REDUCTION PRG)ECT (3150 OIG(l OFFICE OF MANAGEMENT ANO BUDGET, WASHINGTON.

OC 20503.FACILITY NAME (t)Harris Nuclear Plant-Unit 1 DOCKET NUMBER (2)50-400 PAGE (3)1 OF3 TITlE (4)failure to Perform Technical, Specification Surveillance Testing in accordance with Specification 4.7.6.d.3 EVENT DATE ISI LER NUMBER (6)REPORT DATE (7)OTHER FACILITIES INVOLVED (6)MOIITH OAY 04 25 YEAR YEAR SEQUENTIAL REy$0tt NUMBER NUMBER 96 96-007-00 MOttTH DAY YEAR 05 28 96 FACI'LITY NAME FACIL(TY, NAME DOCKET NVMBER 05000 DOCKET NVMBER 05000 OPERATING MODE (9), PoWER LEVEL (10l 1009 20.2203(a)(2)(v) 20.2203(a)(3)(i)20.2 203(a)(3)(ii)20.2203(a)

(4)X 50.73(a)(2)(il 50.73(a)(2)(ii)50.73(a)(2)(iii)50.73(a)(2)(iv)50.73(a)(2)(viii) 50.73(a)(2)(x) 20.2201(b) 20.2203(a)(1) 73.71 20.2203(a)(2)(i)

OTHER 20.2203(a)(2)(ii)

THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR E: (Check one or more)(11)NAME 20.2203(a)(2)(iii) 20.2203(a)(2)(iv) 50.36(c)(1) 50.36(c)(2)

LICENSEE CONTACT FOR THIS LER 50.73(a)(2)(v)50.73(a)(2)(vii)

(12)TELEPHONE NVMBER(lrrerrrde Area Code)Specrty m Abstract below or in NRC Form 366A Steven Chaplin, Senior Engineer-Licensing/Regulatory Programs (919)362-2113 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13I CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TO NPRDS CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TO NPRDS SUPPLEMENTAL REPORT EXPECTED (14)YEs (If yes, complete EXPECTED SUBMISSION DATE).X No EXPECTED SUBMISSION DATE (15)MONTH OAY YEAR ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)(16)On April 25, 1996 with the plant operating in Mode 1 at 100%power, it was determined that the procedure for performing surveillance testing.equired by t" Techr.ical Specification 3/4.7.6, Control Room Emergency Filtration System (CREFS), did not fully implement the 18 month surveillance testing requirements.

Surveillance 4.7.6.d.3 requires verification of the system's capability to maintain the control room area at no less than 1/8 inch water gauge positive pressure with respect to adjacent areas.The test only measured differential pressure for one of five adjacent areas.Additional testing by a temporary procedure has since been performed for the remaining adjacent areas which verifies the CREFS can achieve at least 1/8 inch water gauge positive pressure relative to each of the five adjacent areas.One adjacent area, the computer room, had the potential to be operated at a pressure approximately the same as the control room area (at 1/8 inch water gauge).Operation of the computer room's ventilation system has been blocked, by temporary means, from operating in a pressurized state.A method for permanent resolution is under review.The Operations Surveillance test procedure will be revised by January 30, 1997.Also under review is the differential pressure surveillance testing of the Reactor Auxiliary Building Emergency Exhaust System to determine if proper differential pressure testing has been performed.

IJ 0 P' NRC FORM 368A (4BG)LICENSEE EVENT BEPOBT (LEB)TEXT CONTINUATION V.S.NUCLEAR REGULATORY COMMISSION FACILITY NAME 0)Harris Nuclear Plant-Unit I DOCKET 50 400 LER NUMBER (8)YEAR SEOV(NTIAL REYISION NUMB(R NV MB(R 96-007-00 PAGE(3)2.OF 3 TEXT iid sroso sisooois sorriod, rsr oddiu'orol osiris ol iii)C fun 388AI (I 7)EVENT DESCRIPTION:

On April 25, 1996 with the plant operating in Mode 1 at 100%power, it was determined that the procedure for performing surveillance testing required'by Technical Specification 3/4.7.6, Control Room Emergency Filtration System (CREFS, EIIS Code: Vl), did not fully implement the 18 month surveillance testing requirements.

Surveillance 4.7.6.d.3 requires verification of the system's capability to maintain the control room area at no less than 1/8 inch water gauge positive pressure with respect to adjacent areas.The surveillance procedure used was OST-1231,"Control Room Emergency Filtration System Operability".

OST-1231 tested the differential pressure between the Control Room and one adjacent area, the Electrical Equipment Protection Room (EEPR)while in normal operating modes.The other adjacent areas which include the Computer Room, the Operations Office Area, the B Switchgear area, and the outside atmosphere (external to the facility)were not tested.This surveillance deficiency was identified through an assessment of an other plants'perating experience.

With the exception of the Computer Room, which is discussed below, testing the control room pressure relative to the EEPR was considered to be a conservative means to test the Technical Specification required differential pressure, since the EEPR pressure was higher than the other adjacent areas.The Computer Room, which is adjacent to both the Control Room and the EEPR, was designed to be pressurized to approximately the same pressure as the Control Room.Both use the EEPR as a reference point to maintain positive 1/8 inch water gauge differential pressure.During normal operation, the Computer Room Return Damper (CK-D11-152) modulates to maintain the Computer Room at positive 1/8 inch water gauge.Upon receipt of a Control Room Isolation Signal, damper CK-D11-152 opens fully at which point the pressure in the Computer Room would return to approximately the pressure of the EEPR.When the Control Room Isolation Signal is reset, damper CK-D11-152 returns to the modulation mode (+1/8" w.g.).Therefore, it would be possible to have the Control Room Emergency Filtration System operating in recirculation/filtration mode with the adjacent Computer Room at essentially the same pressure.CAUSE: Inadequate procedure development due to an incorrect interpretation of the necessary testing.SAFETY SIGNIFICANCE:

The consequences of this event were minimal.The CREFS is designed to ensure the control room will remain habitable during and following credible accident conditions by pressurizing the control room envelope to 1/8 inch water gauge and thereby limiting radiation exposure to personnel in the control room.Until completion of a special test procedure on April 27, 1996, testing had not been performed to show the ventilation systems were maintaining the positive differential pressure as designed for each adjacent area.That additional testing verified the systems were maintaining the necessary pressure differential.

With regard to the computer room, although the design, operation and testing did not ensure the necessary pressure differential, it effectively maintains a comparable level of protection for the Control Room personnel since the computer room contains no source of contamination and would be supplied with filtered air if manually aligned to draw outside air.The Computer Room HVAC System includes a filtration system similar to the CREFS with HEPA and charcoal filters which is started upon receipt of a Control Room Isolation Signal and continues to operate until manually stopped.These events are being reported per 10 CFR 50.73(a)(2)(i)

.bb (

~y NRC FORM 666A (4BB)LICENSEE EVENT REPORT (LER)TEXT CONTINUATION U.S.NUCLEAR REGULATORY COMMISSION FACILITY NAME (I)DOCKET LER NUMBER (6)PAGE (6)Harris Nuclear Plant Unit I 50 400 YEAR SEQUENT)AL BEY)SION NUMBER NUMBER 3 OF 3 96-007 00 TEXT rid sooso spo sois sooodod.oso odd)soool sopos ol IYRC dssso NQI Ill)PREVIOUS SIMILAR EVENTS: A comprehensive technical specification testing program review is in progress to satisfy the requirements of Generic Letter 96-01.The condition reported in this LER is similar to those previously reported in LER 96-002 and its subsequent revisions in that surveillance test procedures did not adequately verify system operability.

CORRECTIVE ACTIONS COMPLETED:

OST-9021T, Temporary Procedure to Measure Delta P between the PIC Room and Surrounding Areas, completed on April 27, 1996, satisfied the differential pressure testing requirements of Technical Specification Surveillance 4.7.6.d.3.

s The Computer Room Ventilation System Return Damper CK-D11-152 was placed in the fully open position and the modulation feature defeated to prevent pressurization of the Computer Room.The Computer Room emergency filtration unit outside air intake dampers were also tagged shut to eliminate the potential ingress of outside air while in the recirculation mode.CORRECTIVE ACTIONS PLANNED: OST-1231 will be revised by January 30, 1997 to incorporate the testing of the Control Room aiea pressure differential relative to the remaining adjacent areas.OST-1231 is an 18 month surveillance test whose next scheduled performance is in mid-1997.An evaluation will be completed by October 7, 1996, to determine the changes needed to implement, on a permanent basis, the intent of the temporary damper repositioning described above.3.Reactor Auxiliary Building Emergency Exhaust System testing will also be reviewed to ensure that appropriate surveiHances regarding maintenance of differential pressure are being performed.

This review will be completed by June 10, 1996.EIIS CODES: Control Room Ventilation System-Vl