ML18012A775

LER 97-008-00:on 970404,safety-related AHU Not Declared Inoperable During Maintenance on Associated Temperature Switches Resulting in Violation of Ts.Caused by Incorrect Interpretation.Operations Night Order issued.W/970505 Ltr

ML18012A775
Person / Time
Site:	Harris
Issue date:	05/05/1997
From:	Donahue J, Verrilli M CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-97-008, LER-97-8, NUDOCS 9705130398
Download: ML18012A775 (8)

Text

CATEGORY REGUI ATCI INFORMATION DISTRIBUTION . STEM (RIDE)

ACCESSION NBR:9705130398 DOC.DATE: 97/05/05 NOTARIZED: NO DOCKET ¹ FACIL:50 400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina

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05000400 AUTH. NAME AUTHOR AFFILIATION VERRILLI,M. Carolina Power & Light Co.

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

RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 97-008-00:on 970404,safety-related AHU not declared inoperable during maintenance on associated temperature switches resulting in violation of TS.Caused by incorrect interpretation. Operations night order issued.W/970505 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. 05000400

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RECIPIENT COPIES RECIPIENT'D COPIES ID CODE/NAME LTTR ENCL CODE/NAME LTTR ENCL PD2-1 PD 1 1 LE,N 1 1 INTERNAL: ACRS 1 1 AEOD/IS P D/ERAB 2 2 AEOD/SPD/RRAB 1 1 ILE CENTER 1 1 NRR/DE/ECGB NRR/DE/EMEB 1 l hfRR'; ' LB 1 1 1 1 NRR/DRCH/HHFB 1 1 NRR/DRCH/HICB 1 1 NRR/DRCH/HOLB 1 1 NRR/DRCH/HQMB 1 1 NRR/DRPM/PECB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 RES/DET/EIB 1 1 RGN2 FILE 01 1 1 Z EXTERNAL: L ST LOBBY WARD 1 1 LITCO BRYCEFJ H 1 1 C NOAC POOREFW. 1 1 NOAC QUEENER,DS 1 1 NRC PDR 1 1 NUDO S FULL TXT 1 1

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NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 25

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Carolina Power 8 Light Company Harris NucIear Plant PO Box 165 MAY 5 ]99j New Hill NC 27562 U.S. Nuclear Regulatory Commission Serial: HNP-97-098 ATTN: NRC Document Control Desk 10CFR50.73 Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT UNIT 1 DOCKET NO. 50-400 LICENSE NO. NPF-63 LICENSEE EVENT REPORT 97-008-00 Sir or Madam:

In accordance with Title 10 to the Code of Federal Regulations, the enclosed Licensee Event Report is submitted. This report describes past instances where safety-related air handling units were not declared inoperable during maintenance on associated temperature switches, thus resulting in a violation of Technical Specifications.

Sincerely, J. W. Donahue Director of Site Operations Harris Plant MV Enclosure c: Mr. J. B. Brady (HNP Senior NRC Resident)

Mr. L. A. Reyes (NRC Regional Administrator, Region II)

Mr. N. B. Le (NRC - NRR Project Manager) 9705i30398 970505 05000400 PDR ADQCK PDR !Illllllllllllllllllllllllllllllllllllll State Road H34 New Hill NC

NRC FORP/I 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB No. 31504104

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EXPIRES 04/30/BB ESTIMATED BURD"N PER RESPONSE To COMPLY WITH THIS MANDATORY INFORMATION COLLECTION REQUEST: 50.0 HRS.

LICENSEE EVENT REPORT (LER) REPORTED LESSONS LEARNED ARE INCORPORATED INTO THE LICENSING PROCESS AND FED BACK TO INDUSTRY. FORWARD COMMENTS REGARDING BURDEN ESTIMATE To THE (See reverse for required number of INFORMATION AND RECORDS MANAGEMENT BRANCH (T-6 F33).

digits/characters for each block) U.S. NUCLEAR REGULATORY COMMISSION. WASHINGTON, DC 20555.0001. AND To THE PAPERWORK REDUCTION PROJECT FACILITYNAME (1) DOCKET NUMBER (2) PAGE (3)

Shearon Harris Nuclear Plant, Unit-1 50-400 1 OF4 TITLE I4)

Safety-related Air Handling Units not declared inoperable during maintenance on associated tempe'rature switches resulting in a violation of Technica( Specifications.

EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED {6)

FACILITYNAME DOCKET NUMBER SEOUENTIAL REVISION MONTH OAY YEAR MONTH OAY YEAR NUMBER NUMBER FACIUTY NAME DOCKET NUMBER 04 04 97 97 008 00 05 05 97 05000 OPERATING ~ THIS REPORT IS SUBMITTED PURSUANT To THE REQUIREMENTS OF 10 CFR O: (Check one or more) (11)

MODE (9) 20. 2201 (b) 20.2203(a) (2) {v) X 50.73(a)(2){i) 50.73(a) (2) (viii) 20.2203(a) (1) 20.2203(a)(3) {i) 50.73(a) {2) (ii) 50.73(a)(2)(x)

POWER 100%

LEVEL (10) 20.2203(a)(2) {i) 20.2203(a) (3) (ii) 50.73(a){2)(nr) 73.71 20.2203(a) (2) (ii) 20.2203(a) (4) 50.73(a)(2)(iv) OTHER 20.2203(a)(2)(iii) 50.36(c) {1) 50.73(a)(2)(v) S p ecif y in Abstract below or in NRC Form 20.2203(a) (2) (iv) 50.36(c) (2) 50.73(a)(2)(vii) 366A LICENSEE CONTACT FOR THIS LER l12)

NAME TELEPHONE NUMBER Urcrvde Arse Cooel Michael Verrilli Sr. Analyst - Licensing (919) 362-2303 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

REPORTABLE REPORTABLE CAUSE SYSTEM COMPONENT MANUFACTURER CAUSE S'STEM COMPONENT MANUFACTURER TO NPROS TO NPROS SUPPLEMENTAL REPORT EXPECTED {14) EXPECTED MONTH DAY YEAR YES SUBMISSION

{Ifyes, compIete EXPECTED SUBMISSION DATE). X NO DATE (15)

ABSTRACT (Limit to 1400 spaces, i.e., approximateiy 15 singie spaced typewritten lines) (16)

On April 4, 1997, with the plant in mode-1 operating at 100% power, investigation determined that certain safety-related air handling units had not been declared inoperable during maintenance on their associated temperature elements, temperature transmitters and/or temperature switches. During certain postulated scenarios, these temperature circuitry components would be required for the air handling units to perform their safety function. In the instances described in the event description, the temperature circuitry components were out of service for a period of time that exceeded the Technical Specification (TS) action statement for the specific component cooled by the air handling unit and/or were out of service during plant mode changes, which would result in a violation of TS 3.0.4.

This condition was caused by an incorrect interpretation of operability requirements related to safety-related air handling units. TS Interpretation ¹87-002 Revision-2, which was approved in August 1988, provided guidance on this issue by stating that the automatic start of a fan on high temperature was not an operability requirement. Based on this, maintenance performed on associated air handling unit temperature elements, temperature transmitters, and/or temperature switches was considered to have no effect on operability. This incorrect interpretation resulted in deficient plant procedures and processes that provide guidance for control of component operability.

An Operations Night Order was issued to address the operability requirements associated with the safety-related air handling units and their associated temperature circuitry components. Additional corrective actions will include: (1) training for appropriate Operations and Maintenance personnel, (2) revisions to the site computerized equipment database system (EDBS) and component operability database system (SPECAPRAISAL), and (3) revisions to affected maintenance tern erature loo test and calibration rocedures.

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NRC FORM 3$ BA ILS. NUClEAR REGUlATORT COMMISSION

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LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACIUTY NAME (I) DOCKET lER NUMBER IB) PAGE I3)

SEOUENnAE REnSION TEAR NUMBER NUMBER Shearon Harris Nuclear Plant ~

Unit //t 50.400 2 OF 4 97 - 008 - 00 TEXT pf moro tpotoit rorpritd, oto oridrrdtool oopiot oi rYRC Form 3aW )IT)

EVENT DESCRIPTION:

On April 4, 1997, with the plant in mode-1 operating at 100% power, investigation determined that certain safety-related air handling units had not been declared inoperable during maintenance on their associated temperature elements, temperature transmitters and/or temperature switches. During certain postulated scenarios, these temperature circuitry components would be required for the air handling units to perform their safety function. In the instances described below, the temperature circuitry components were out of service for a time period that exceeded the Technical Specification (TS) action statement for the specific component cE)oled by the air handling unit and/or were out of service during plant mode changes, which is a violation of the operational mode change limitations of TS 3.0.4. P In November 1986, Work Request/Job Order (WR/JO) 86-RQNZI was initiated to resolve a concern with the power supply card for Temperature Element Loop TE-6507BSB. This temperature loop is associated with the safety-related AH-6 (1A-SA) Air Handling Unit (EIIS Code: VF-AHU) that provides cooling in the of the Reactor Auxiliary Building (RAB) where the A-train Component Cooling Water (CCW), 236'levation Auxiliary Feedwater (AFW) and Emergency Service Water (ESW) Booster pumps are located. Work was completed to repair the temperature element power supply card in May 1987. During the time period that the temperature element deficiency existed, the plant operated in mode-1 and made changes between mode-1 and mode-4. With the temperature loop power supply card in this deficient condition, the AH-6 Air Handling Unit may not have been capable of automatically starting on high temperature to perform its safety function and should have been declared inoperable. This condition is a violation of the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Limiting Condition for Operation (LCO) requirements of TS 3.7.1.2 (AFW), 3.7.3 (CCW), the 7-day LCO requirement for TS 3.6.2.3 (ESW - Containment Cooling) and the mode change limitations of TS 3.0.4.

In November 1986, WR/JO 86-BPBB1 was initiated due to a blown'fuse in the power supply card for Temperature Element Loop TE 6532BSB. This temperature loop is associated with the safety-related AH-11 (1B-SB) Air Handling Unit (EIIS Code: VF-AHU) that provides cooling in the 236'levation of the Reactor Auxiliary Building where A-train and B-train Containment Isolation Valves and Instrumentation are located.

Work was completed to repair the temperature element power supply card in January 1987. During the time period that the temperature element deficiency existed, the plant operated in mode-1 and made changes between mode-1 and mode-4. With the temperature loop power supply card in this deficient condition, the AH-11 Air Handling Unit may not have been capable of automatically starting on high temperature to perform its safety function and should have been declared inoperable. This condition is a violation of the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO requirements of TS Interpretation'87-002 and the mode change limitations of TS 3.0.4.

In March 1987, WR/JO 87-AGNNl was initiated to repair and calibrate Temperature Transmitter TT-01AV-6582X. This temperature transmitter is associated with the AH-29 (1X-SB) Air Handling Unit (EIIS Code: VF-AHU), which provides cooling for the AH-1 Fan Cooler power supply motor control center.

located on the 236'levation of the Waste Processing Building. Repair and calibration of this transmitter was completed approximately forty days later per WR/JO 87-AGNN2. During the time period required to complete repairs and calibration, the plant operated in mode-1 and made changes between mode-1 and mode-

4. With the transmitter in this condition, the AH-29 Air Handling Unit may not have been capable of automatically starting on high temperature to perform its safety function and should have been declared inoperable. This condition is a violation of the 7-day LCO requirements of TS 3.6.2.3 and the mode change limitations of TS 3.0.4.

NRC FORM 3~~BR ~ US. NUCEEAR REGU(ATORT COMMISSION P}O6)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACIUTT NAME (I) DOCKET IER NUMBER (6) PAGE(3)

SEQUENT(At REvLS ON NUMBER NUMBER Shearon Harris Nuclear Plant Unit ¹1 50 400 3 OF 4 97 - 008 - 00 TEXT pl fvofo spsso fs rs(Rd)oK vso oddifd)vol sopis of fff)C pfvfo 3agl lir)

EVENT DESCRIPTION: (continued)

4. In February 1990, WR/JO 90-ACYK1 was initiated to resolve spurious alarms caused by Temperature Switch TS-01AV-6567A2SA. This temperature switch is associated with the safety-related AH-26 (lA-SA) Air Handling Unit (EIIS Code: VF-'AHU) that provides cooling for the E-6 RAB Emergency Exhaust Fans. Troubleshooting confirmed that the temperature switch was causing the spurious alarms. In March 1990, approximately 14 days after initiating the above WR/JO, the temperature switch and related instrument loop were calibrated to resolve the problem. During the time period that the temperature switch was not properly functioning, the plant operated in mode-1. With the temperature switch in this deficient condition, the AH-26 Air Handling Unit may not have been capable of automatically starting on high temperature to perform its safety functioi. and should have been declared inoperable. This condition is a violation of the 7-day LCO requirements of TS 3.7.7 (RAB Emergency Exhaust).

In February 1991, WR/JO 91-ACTL1 was initiated to resolve alarms caused by Temperature Switch TS-01EV-6588A3. This temperature switch is associated with the safety-related AH-86 (1A-SA) Air Handling Unit located in the ESW Intake structure, which provides cooling air to the associated ESW pump electrical cabinets and sprves as a backup heat supply for the ESW pumps. Troubleshooting identified a loose electrical connection at the temperature element. Repairs and loop calibration were completed in April 1991. During the time period that the temperature switch/element were not properly functioning, the plant operated in mode-1. VFith the temperature switch in this deficient condition, the AH-86 Air Handling Unit may not have been capable of automatically starting on high temperature to perform its safety function and should have been declared inop(:rable. This condition is a violation of the 72-hour LCO requirements of TS 3.7.4 (ESW).

In October 1991, WR/JO 91-ANXN1 was initiated when the ESW Intake Structure Exhaust Fan (E-88 1B-SB) failed to automatically start at its high temperature setpoint. Trouble shooting performed in January 1992 identified a broken conductor in the power supply card for Temperature Element Loop TE-01EV-6592BSB. Additional troubleshooting also identified a bad process instrument control bistable relay (NAS) card in this temperature loop in March 1992. Since replacement of the NAS card would impact several other instrument loops, a voluntary LCO was initiated for the E-88 ESW Exhaust Fan. However, during the time period prior to initiating the LCO, the temperature control loop was not properly functioning and the plant was in mode-1. With the temperature control loop in this deficient condition, the E-88 Exhaust Fan may not have been capable of automatically starting on high temperature to perform its safety function and should have been declared inoperable. This condition is a violation of the 72-hour LCO requirements of TS 3.7.4 (ESW).

CAUSE:

This condition was caused by an incorrect interpretation of operability requirements related to safety-related air handling units. TS Interpretation ¹87-002 Revision-2, which was approved in Augu'st 1988, provided guidance on this issue by stating that the automatic start of a fan on high temperature was not an operability requirement. Based on this, maintenance performed on associated air handling unit temperature elements, temperature transmitters, and/or temperature switches was considered to have no effect on operability. This incorrect interpretation resulted in deficient plant procedures and processes that provide guidance for control of component operability.

SAFETY SIGNIFICANCE:

There were no actual safety consequences associated with this event. However, based on the following postulated scenario, the safety-related air handling units/exhaust fans identified above should have been declared inoperable with their respective temperature control circuits not operating properly.

In the event of an accident which results in safety injection, Engineered Safety Feature (ESF) components would receive an automatic start signal from the Emergency Safeguards Sequencer to perform their safety function. This would also include the safety-related air handling unit fans for ESF component support. When the safety injection signal is reset per plant procedures, the air handling unit fans will automatically shutdown if they had not been manually started prior to the event, if room temperature is below the high temperature auto-start setpoint, or if the associated temperature control loop is failed low. With the temperature control loops not functioning properly N R (4 )

I'k NRC FORM 366A ~ U.S. NUCLEAR REGULATORY COMMIBQON Io/6)

LlCENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (Il COCKET LER NUMBER IB) PAGE I3)

BEOUENTULL ~

NUMBER NUMBER Shearon Harris Nuclear Plant ~

Unit II1 50400 4 OF 4 97 - 008 - 00 TEXT rrr moro spar N ropvved, vso oddrr ml copies or irRC Form 36QI 11))

SAFETY SIGNIFICANCE: (continued) as described in the event description, the fans may not have automatically re-started at their required high temperature setpoints and component damage may have occurred.

This event is being reported per 10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by the plant's Technical Specifications.

PREVIOUS SIMILAR EVENTS:

There have been no previous reports submitted related to temperature control circuits and their potential impact on safety-related air handling unit operability.

CORRECTIVE ACTIONS COMPLETED:

1. An Operations Night Order was issued on March 14, 1997 describing this condition and the operability requirements associated with safety-related'air handling units and their associated temperature control loops.

2. TS Interpretation )I)87-002 was revised on November 22, 1996 to state that the automatic high temperature fan start signal may be required for fan operability based on safety function.

3. Maintenance Temperature Loop Calibration Procedures LP-T-6592A and LP-T-6592B were placed on administrative hold on May 5, 1997. ~

CORRECTIVE ACTIONS PLANNED:

1. The plant processes used for component operability control will be updated to reflect the applicable temperature control circuit, requirements. This will include the EDBS database 440 screen and the SPECAPRAISAL database. These updates will be completed by August 15, 1997 and November 15, 1997 respectively.

2. Maintenance Temperature Loop Calibration Procedures LP-T-6592A and LP-T-6592B will be revised prior to their next use or no later than July 15, 1997.

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