ML17223A288

LER 89-004-00:on 890715,discovered That Reactor Containment Fan Coolers Had Filter Media in Place During Power Operations.Caused by Inadequate Maint Instructions.Filters Removed & Maint Instructions revised.W/890814 Ltr

ML17223A288
Person / Time
Site:	Saint Lucie
Issue date:	08/14/1989
From:	Snyder M, Woody C FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-89-299, LER-89-004-03, LER-89-4-3, NUDOCS 8908220121
Download: ML17223A288 (7)

Text

gcczlERATED DISI+3UTION DEMONSTRA'gN SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8908220121 DOC.DATE: 89/08/14 NOTARIZED: NO DOCKET FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power & Light Co. 05000335 AUTH. NAME AUTHOR AFFILIATION SNYDER,M.J. Florida Power & Light Co.

WOODY,C.O. Florida Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION R

SUBJECT:

LER 89-004-00:on 890715,containment fan cooler filters left in place during unit power operation due to IP.

W/8 ltr.

DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL / SIZE:

TITLE: 50.73/50.9 Licensee Event Report (LER), ncident Rpt, etc.

NOTES:

RECIPIENT COPIES RECIPIENT COPIES h ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 LA 1 1 PD2-2 PD 1 1 NORRIS,J 1 1 INTERNAL: ACRS MICHELSON 1 1 ACRS MOELLER 2 2 ACRS WYLIE 1 1 AEOD/DOA 1 1 AEOD/DS P/TPAB 1 1 AEOD/ROAB/DSP 2 2 DEDRO 1 1 IRM/DCTS/DAB 1 1 NRR/DEST/CEB 8H 1 1 NRR/DEST/ESB 8D 1 1 NRR/DEST/ICSB 7 1 1 NRR/DEST/MEB 9H 1 1 NRR/DEST/MTB 9H 1 1 NRR/DEST/PSB 8D 1 1 NRR/DEST/RSB 8E 1 1 NRR/DEST/SGB 8D 1 1 NRR/DLPQ/HFB 10 1 1 NRR/DLPQ/PEB 10 1 . 1 NRR/DOEA/EAB 11 1 1 PB 10 2 2 NUDOCS-ABSTRACT 1 1 REG FILE 02 1 1 RES/DSIR/EIB 1 1 GN2 ILE 01 1 1 EXTERNAL EG&G WILLIAMS SE 4 4 FORD BLDG HOY,A 1 1 L ST LOBBY WARD 1 1 LPDR 1 1 R NRC PDR 1 1 NSIC MAYS,G 1 1 NSIC MURPHY,G.A 1 1 I D

/

h FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 40 ENCL 40

P.O. Box14000, Juno Beach, FL 33408-0420

@PL AUGUSTj 14 198g L-89'-299 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:

Re: St. Lucie Unit 1 Docket No. 50-335 Reportable Event: 89-04 Date of Event: July 15, 1989 Containment Fan Cooler Filters Left in Place During Unit Pover 0 eration Due to Inade ate Procedures The attached voluntary Licensee Event Report is being submitted to provide notification of the subject event.

Very truly yours, C. 0. Woody Acting Senior Vice President Nuclear COW/JRH/cm

'ttachments cc: Stewart D. Ebneter, Regional Administrator, Region Senior Resident Inspector, USNRC, St. Lucie Plant II, USNRC an 'f'r. Group company

NAC )erin $ 44 U.S. NUCLEAA REGULATORY COMMISSION 19 5$ 1 APPAOVEO OMB NO 2'1100104 EXPIRES 4-$ 1 BS LICENSEE EVENT REPORT ILER)

DOCKET NUMBER Ill PA FACILITY NAME 111 St. Lucie, Unit One 0500033510FO CONTAINMENT FAN COOLER FILTERS LEFT IN PLACE DURING UNIT POVER OPERATION DUE TO INADEQUATE PROCEDURES EVENT DATE ISI LER NUMBER (41 REPORT DATE 171 OTHER F ACILITIE5 INVOLVED ISI 1 4 0 Ij4 4 T I A L iACII.ITYVAMES OOCKF T NVMBERISI MONTH OAY YEAR YEAR 4VM44 I NI Mof re MOIIITH OAY YEAR N/A 0 5 0 0 0 0 7 1 5 8 9 8 4 0 00 8148 N/A 0 5 0 0 0 OPERATINO THIS REPORT IS SUBMITTED PURSUANT T 0 tHE REOUIREMENTS of 10 cf A (): Icnrce onr oi rnrNr oI mr Ioooiiinpl (11 MODE ( ~ ) 7$ .71(4) 5 20.402(oi 20.405(cl 50.7l( ~ I(2 l(ivi POWER 20 405( ~ ) Ill(il 50.$ 4(cl(ll 50.7 2( ~ ) (21( v I 7$ .7)(c)

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Voluntary LICENSEE CONTACT FOR THIS LER (12) 4AME TELEPIrONE 4VMBER AREA CODE Michael J. Snyder, Shift Technical Advisor 407 465" 3550 COMPLE'Tf ONf LINE fOA EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT 1121 MANLPAC. EPOA-ABLE 4IANVFAC. EPORTABLf CAUSE SYSTE M COMPO454T Ti,'AfR TO 4PRDS CAVSE SYSTEM COMPONENT TVRER TO herrDS SUPPLEMENTAL AEPOAT EXPECTED (141 MO47vi DAY vf AR EXPECTED SV 5 M I SS ION DATE (151 YES II'n COMP ~ rr EXPECTED SVSMrSSiOiV OATEI 4O AssTRAcT ILinvr ro repC roicrri r, roorov.i<<rrr I I'Irri<<e <<prr roke ~ trorn<<rrin I.<<nl 1141 On 15 July, 1989, while St. Lucie Unit One was shutdown, it was discovered that the Reactor Containment Fan Coolers (RCFC) had filter media in place during power operations. The RCFC filters reduce fouling of the system's cooling coils when the unit is shutdown. Filters were installed during the February 1987 refueling outage, were replaced during the July 1988 refueling outage and left installed until July, 1989. The cause of this event was due to inadequate maintenance instructions. The filters were removed, and an Engineering evaluation is being prepared to verify filter performance under accident conditions. St. Lucie Unit Two RCFC were verified to have filters removed, maintenance instructions will be revised, and other safety related components were checked for improperly installed filters. This event was determined not to be reportable under 10CFR50.72 or 50.73 and is being submitted for informational purposes.

NAC peri<< $44 19 5$ 1

NRC feIAI 388A U.S. NUCLEAR REGULATORY COMMISSION WQ I ~

LICENSEE EVE: T REPORT (LER) TEXT CONTINUATI APPROVEO OM8 NO. 3150WI04 EXPIRES: 8/31/Nl fACILITYNAME IlI OOCKET NUMSER 121 LER NUMSER 18) PAGE LSI YEAR +SI 55OVENTIAL AEVI5ION r@I NVM 58 NVM 5A St. Lucie, Unit TOIT /8'AMle NMCP 8 /59VIRE One V54 44RRMA4/H/IC hem 3/5348/ (Itl 05000335 0 2 OF DESCRIPTION OF EVENT:

On 15 July, 1989, while St. Lucie Unit One (PSLl) was shutdown for a Steam Generator (EIISIAB) tube plug replacement outage, an inspection of the Reactor Containment Fan Coolers (EIISIBK) (RCFC) showed that the prefilter media for these coolers was excessively discolored. The system Technical Manual for the RCFC implies that the prefilter media should only be used during shutdown modes of operation to reduce fouling of the cooling coils during construction or maintenance.

The prefilters were installed during the February 1987 refueling .outage and remained in place until the next refueling outage of July, 1988.

New filters installed during the July 1988 outage were left in place until July 1989. The length of time these filters were installed prompted utility personnel to initiate an operability assessment on past system performance.

CAUSE OF THE EVENT:

The cause of allowing prefilter media to remain in place during power operation was due to maintenance instructions not stating that the filter should be used only during outage periods.

ANALYSIS OF EVENT:

Technical, Specification 3/4.6.2.3 addresses the surveillance requirements and the bases for the containment cooling system. The operability of the RCFC ensures that 1) the containment air temperature will be maintained within limits during normal operation, and 2) adequate heat removal capacity is available when operated in conjunction with the Containment Spray Systems during postulated loss of coolant accident conditions. The surveillance requirements for the RCFC were met under past system performance. The bases of system operation were satisfied as follows:

1) Normal containment air temperature was maintained within the limits set by PSL1 Technical Specification 3/4.6.1.5. Also, the RCFC manufacturer, Westinghouse, analyzed the results of differential pressure (dp) measurements taken on each of the four cooling fans and determined that the as found filter resistance was not a problem during normal and postulated accident mode operation. The measured dp was less than the maximum dp for the recommended filters.

Therefore, the minimum airflow requirement for the RCFC was never violated under past system performance.

NRC POAM 545A 4 U S GPOI I 988 0 824 538/455 r

NRC form 388A U.S. NUCLEAR REOULATORY COMMISSION (Q4)3)

LICENSEE EVE REPORT {LER) TEXT CONTINUATIO) APPROVEO OMS NO. 3150-0104 EXPIRES: 8/3'I/88 FACILITY NAME II) DOCKET NUMBER ll) LER NUMBER IS) PACE (3)

YEAR SEOUENTIAL REVISION rPPv. NUMSER NUMSER St. Lucie, Unit One TEitT /SRSNo Cfoco/4 oqulor/ Uoo/aP/N/one////)C %%dnR 38SA'4) I IT) 0 5 0 0 0 335 0 3 OF

2) Section 6.2 of the PSL1 FUSAR describes the design bases and minimum requirements for containment heat removal systems. Any one of the following three subsystems will provide at least minimum heat removal capability necessary to limit and reduce the post accident containment pressure and temperature: all four containment fan coolers (100 percent capacity), either of the two containment spray trains (EIISIBE)

(100 percent capacity for each subsystem). Even assuming the worst case, no RCFC available and a single active failure in one of the two containment spray trains, the safety function of containment heat removal would have been met with the remaining operable containment spray subsystem.

Based on the above, it can be concluded that the health and safety of the public were not affected at any time with the continuous installation of prefilters in the RCFC.

This event is not deemed reportable as per the requirements of 10 CFR 50.73, or of any operation or condition prohibited by St. Lucie Plant's Technical Specifications. However, this report is being submitted for informational purposes.

CORRECTIVE ACTIONS:

1. St. Lucie Unit Two's RCFC system Technical Manual explicitly states that the prefilter media should be removed prior to power operation.

An inspection of Unit Two's RCFC on 15 July confirmed that all of the RCFC prefilter media was removed before the unit began power operations.

2. Tests were run to measure the dp across each filter and cooling unit for PSL1. These test runs were made to address possible operability concerns over a potentially high filter dp. A preliminary Engineering evaluation deter'mined that the RCFC were operable with prefilters installed during power operation.

3. The prefilters were removed from the PSLl RCFC and will not be used during power operations. r

4. An Engineering safety evaluation is being performed to ,determine the environmental qualification of the filter media and the performance of these filters under postulated accident conditions. Contact with Westinghouse, Florida Filters (supplier of the filter media last used), and other material manufacturers has been established in order to assess past performance capabilities of the RCFC.

NRC CORM 344A o U.S.GPO: I 988 0.824 538/ ~ 55

)8831

kllC PocM S44A V $ IIVCLEAIIAEGVLATOIIY Ibbb>

T REPORT (LER) TEXT CONTINUA COMMIS'PPIIOVEO LICENSEE OMb IIO SISO&104 EXPIIIE$ . b/SIIEEI PACILITY NAME ill OOCKET IIUMSESI (SS LEll RUMSEA lbl PAGE ul YSAA SSGVCHT<AL ASM+IQH

~ NUM SA MMM 4A St. Lucie, Unit TEXT (/vere 4S444 b 14EMPSKE 444 ~ One iVIIC Asm JXA'4) (17l 0 5 0 0 0 3 3 5 p p g OF 5, PSL 1's Technical Manual on RCFC will be changed to explicitly prohibit leaving filter media on the fans during power operation.

6. Other safety-related components were checked to verify that no other components have unanalyzed filters installed.

ADDITIONAL INFORMATION:

COMPONENT FAILURES None PREVIOUS SIMILAR EVENTS None MAC SOAM 444A 4 U $ GPO lbbb'0 62 ~ 'Sbb ~