ML18101B042: Difference between revisions
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Technical Specification Violations: Differential Pressure of the Fuel Handling Building Ventilation System EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8) | Technical Specification Violations: Differential Pressure of the Fuel Handling Building Ventilation System EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8) | ||
MONTH DAY YEAR YEAR I SEQUENTIAL NUMBER | MONTH DAY YEAR YEAR I SEQUENTIAL NUMBER | ||
'REVISION NUMBER MONTH DAY YEAR FACILITY NAME Salem Unit 2 DOCKET NUMBER 05000311 DOCKET NUMBER 09 11 95 95 - 024 - 00 10 11 95 FACILITY NAME | 'REVISION NUMBER MONTH DAY YEAR FACILITY NAME Salem Unit 2 DOCKET NUMBER 05000311 DOCKET NUMBER 09 11 95 95 - 024 - 00 10 11 95 FACILITY NAME OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check one or more) (11) | ||
OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check one or more) (11) | |||
MODE(9) A 20.2201(b) 20.2203(a)(2)(v) x 50. 73(a)(2)(i)(B) 50. 73(a)(2)(viii) | MODE(9) A 20.2201(b) 20.2203(a)(2)(v) x 50. 73(a)(2)(i)(B) 50. 73(a)(2)(viii) | ||
POWER 20.2203(a)(1) 20.2203(a)(3)(i) 50. 73(a)(2)(ii) 50. 73(a)(2)(x) 20.2203(a)(2)(i) 20.2203(a)(3)(ii) 50. 73(a)(2)(iii) 73.71 iii NAME Zarechnak, A. | POWER 20.2203(a)(1) 20.2203(a)(3)(i) 50. 73(a)(2)(ii) 50. 73(a)(2)(x) 20.2203(a)(2)(i) 20.2203(a)(3)(ii) 50. 73(a)(2)(iii) 73.71 iii NAME Zarechnak, A. | ||
20.2203(a)(2)(ii) 20.2203(a)(2)(iii) 20.2203(a)(2)(iv) 20.2203(a)(4) 50.36(c)(1) 50.36(c)(2) | 20.2203(a)(2)(ii) 20.2203(a)(2)(iii) 20.2203(a)(2)(iv) 20.2203(a)(4) 50.36(c)(1) 50.36(c)(2) | ||
LICENSEE CONTACT FOR THIS LER (12) | LICENSEE CONTACT FOR THIS LER (12) | ||
Line 41: | Line 38: | ||
TELEPHONE NUMBER (Include Ame Code) | TELEPHONE NUMBER (Include Ame Code) | ||
(609) 339-1755 or In OTHER S~~ln Abstract below C Form 366A COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13) | (609) 339-1755 or In OTHER S~~ln Abstract below C Form 366A COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13) | ||
II CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TONPRDS TONPRDS | II CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TONPRDS TONPRDS VG N IYES SUPPLEMENTAL REPORT EXPECTED (14) | ||
VG N IYES SUPPLEMENTAL REPORT EXPECTED (14) | |||
I EXPECTED SUBMISSION MONTH DAY YEAR (If yea, complete EXPECTED SUBMISSION DATE). x1NO ..lATE (15) | I EXPECTED SUBMISSION MONTH DAY YEAR (If yea, complete EXPECTED SUBMISSION DATE). x1NO ..lATE (15) | ||
ABSTRACT (Limit to 1400 apacH, i.e., approximately 15 1ingle-11peced typewritten lines) (16) | ABSTRACT (Limit to 1400 apacH, i.e., approximately 15 1ingle-11peced typewritten lines) (16) |
Latest revision as of 05:39, 3 February 2020
ML18101B042 | |
Person / Time | |
---|---|
Site: | Salem ![]() |
Issue date: | 09/11/1995 |
From: | Zarechnak A Public Service Enterprise Group |
To: | |
Shared Package | |
ML18101B041 | List: |
References | |
LER-95-024, LER-95-24, NUDOCS 9510160164 | |
Download: ML18101B042 (10) | |
Text
NRCFORM 368 (4-95)
U.S. NUCLEAR REGULATORY COMMISSION
~ICENSEE EVENT REPORT (LER)
- APPROVED BY OMB NO. 3150-0104 EXPIRES IM/30198 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS MANDATORY INFORMATION COLLECTION REQUEST: 50.0 HRS.
REPORTED LESSONS LEARNED ARE INCORPORATED INTO THE LICENSING PROCESS ANO FED BACK TO INDUSTRY. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION ANO (See reverse for required number of RECORDS MANAGEMENT BRANCH g-e F33), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGT N, DC 20656-0001, ANO TO digits/characters for each block) THE PAPERWORK REDUCTION PROJECT (316CM>104), OFACE OF MANAGEMENT AND BUDGET, WASHINGTON, DC 20503.
FACILITY NAME (1) DOCKET NUMBER (2) PAGE (3)
SALEM - Unit 1 05000272 1 OF 10 TITLE (4)
Technical Specification Violations: Differential Pressure of the Fuel Handling Building Ventilation System EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8)
MONTH DAY YEAR YEAR I SEQUENTIAL NUMBER
'REVISION NUMBER MONTH DAY YEAR FACILITY NAME Salem Unit 2 DOCKET NUMBER 05000311 DOCKET NUMBER 09 11 95 95 - 024 - 00 10 11 95 FACILITY NAME OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check one or more) (11)
MODE(9) A 20.2201(b) 20.2203(a)(2)(v) x 50. 73(a)(2)(i)(B) 50. 73(a)(2)(viii)
POWER 20.2203(a)(1) 20.2203(a)(3)(i) 50. 73(a)(2)(ii) 50. 73(a)(2)(x) 20.2203(a)(2)(i) 20.2203(a)(3)(ii) 50. 73(a)(2)(iii) 73.71 iii NAME Zarechnak, A.
20.2203(a)(2)(ii) 20.2203(a)(2)(iii) 20.2203(a)(2)(iv) 20.2203(a)(4) 50.36(c)(1) 50.36(c)(2)
LICENSEE CONTACT FOR THIS LER (12)
(Mgr., Mechanical Engineering)
- 50. 73(a)(2)(iv)
- 50. 73(a)(2)(v)
- 50. 73(a)(2)(vii)
TELEPHONE NUMBER (Include Ame Code)
(609) 339-1755 or In OTHER S~~ln Abstract below C Form 366A COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)
II CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TONPRDS TONPRDS VG N IYES SUPPLEMENTAL REPORT EXPECTED (14)
I EXPECTED SUBMISSION MONTH DAY YEAR (If yea, complete EXPECTED SUBMISSION DATE). x1NO ..lATE (15)
ABSTRACT (Limit to 1400 apacH, i.e., approximately 15 1ingle-11peced typewritten lines) (16)
On 8/23/95, it was identified that the low differential pressure (dp) alarm for the Unit 2 Fuel Handling Building(IBB) was wired incorrectly since 1991. This error has been subsequently corrected. On 9/8/95, it was identified that Technical Specification(TS) Action Statements were recently entered due to intermittent alann conditions. On 9/11/95, it was determined that the E1IB dp Surveillance Testing (ST) did not ensure compliance with TS requirements in that it did not ensure the required dp was maintained during normal system operation.
In addition, investigation revealed that a design issue remained unresolved since 1990 concerning a disparity between the Fuel Handling Ventilation (FHV) controller setting and the TS dp requirement. Also, routine changes to the FHV system configuration during normal operation were found to have degraded the continuous compliance with the TS limit over the life of the facility. This condition also applies to Salem Unit 1. This event is reportable per 10CFR50.73(a) (2) (i) (B) "Technical Specification Violation". Corrective actions include assuring that design basis open items affecting operability of the FHV system are properly prioritized and resolved, revising affected ST proced1_1res, and correcting dp alarm and controller setpoints prior to restart.
9510160164 950911 NRC FORM 388 (4-95) PDR ADOCK 05000272 S PDR
NRC FORll 366A (4-95)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION
- U.S. NUCLEAR REGULATORY COMMISSION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER 6) PAGE (3)
YEAR I SEQUENTIAL NUMBER REVISION NUMBER Salem Unit 1 05000272 95 - 024 - 00 2 OF 10 TEXT (If more space i* required, use additional copies of NRC Form 366A) (17)
PLANT .AND SYSTEM IDENTIFICATION Westinghouse - Pressurized Water Reactor Fuel Handling Building Ventilation System - EIIS Identifier {VG}
IDENTIFICATION OF OCCURRENCE Discovery Date: September 11, 1995 Report Date October 11, 1995 CONDITIONS PRIOR TO OCCURRENCE Operational Mode: Defueled (Salem 1), 5 (Salem 2)
Reactor Power: 000% Both units DESCRIPTION OF OCCURRENCE On 8/23/95, while Unit 2 was shutdown and in Mode 5, a problem with the low differential pressure (dp) alarm for the Fuel Handling Building(FHB) Ventilation system was identified. This condition was identified when the Fuel Handling Building-Ventilation (FHV) fans were removed from se.rvice for scheduled maintenance and the appropriate Technical Specification(TS) Action Statement(AS) was entered. Upon noticing that an alarm condition was not present, Operations directed I&C to troubleshoot the condition. Investigation revealed that the alarm switch had been miswired. The wiring was corrected and due to continuous alarm conditions, the alarm was temporarily set to actuate on increasing pressure of 0.00 inch water gauge ("wg). The Unit 2 dp alarm setpoint was historically maintained at -.1" wg except for a briefperiod beginning 8/26/95 when the setpoint was changed to 0.0" wg.
In the following weeks, several dp alarm conditions were received in the control room and Operator actions were required. These actions included, entering TSASs and investigating the cause of the alarm conditions. On one occasion, Operations personnel found contractor personnel manipulating a non-safety related damper. Investigation further found that unauthorized changes to the differential pressure controller setpoint also occurred. The incorrect damper positions, and controller setpoints were corrected following each occurrence.
These uncontrolled changes to the FHV system configuration degraded the ability to comply with the TS dp limits over the spent fuel pool area.
On September 11, 1995 surveillance testing was conducted on Salem Unit 2 to satisfy the TS 4.9.12.d.3 requirements for maintaining the fuel handling building (FHB) differential pressure (dp) at -0.125" wg relative to the outside atmosphere. This test was performed while the FHV controller setpoint was increased to -0.13" wg from the normal -0.1" wg setting. As a result, the test NRC FORM 366A (4-95)
NRC FORll 366A (4-95)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION
- U.S. NUCLEAR REGULATORY COllMISSION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3)
YEAR I SEQUENTIAL NUMBER I REVISION
~
SALEM - Unit 1 05000272 95 - 024 - 00 3 OF 10 TEXT (If more apace ia required, uae additional copies of NRC Form 366A) (17)
Description of Occurrence (Cont'd) conditions were not representative of the normal system operating conditions and failed to meet the TS surveillance requirements for the FHV system. It was later determined that the controller setpoint had also been increased during previous surveillance tests for both Salem Units 1 and 2. These control setpoint changes, as well as system maintenance changes, were made prior to the testing to ensure that the dp measured over the spent fuel pool satisfied the TS requirements. Following the test, the controller setpoint would be returned to
-.1" wg.
As a result of the conditions and observations below, the required -1/8" wg dp above the spent fuel pool area cannot be assured to have been maintained over the life of the operating units. Therefore numerous TS action statement entries were potentially missed. These conditions and observations include:
- inadequate surveillance testing,
- miswired alarm condition for a four year period,
- inadequate post maintenance testing,
- lack of documented basis for the controller and alarm settings,
- alarm conditions subsequent to the wiring correction when setpoint was at 0.0" wg, and a System Engineering Assessment Transmittal (SEAT) provided dir"ection to set the alarm to 0. 0" wg in 1991, and
- uncontrolled manipulation of non-safety inlet dampers and controller setpoints.
Salem has historically used a differential pressure controller setpoint of -0.1" wg and an alarm setpoint of -0.1" wg for both units. Since 10/16/91, the Unit 1 dp alarm setpoint was changed to 0.0" wg. The Unit 2 dp alarm setpoint was changed to 0.0" wg since 8/26/95. Currently, the controller setpoint for both units is maintained at 0.2" wg.
The controller setting was consistent with UFSAR section 9.4.3.2.2. This controller setting appears to conflict with the TS requirement of -0.125" wg; however, the location of the controller alarms and sensors influence their setpoints and, under the current configuration, are supposed to be different than the TS dp requirement applicable directly over the spent fuel pool area.
The spent fuel pool area, referred to in the TS, is defined in the UFSAR as a ten foot height above the pool. However, no engineering documentation which establishes the basis for the FHV differential pressure controller and alarm setpoints could be located. In addition, design modifications to the FHB ventilation system (e.g., installation of backdraft dan~ers, installation of vane stops, etc) could have rendered previously determined controller settings and alarm setpoints to be inadequate.
NRC FORM 366A (4-95)
NRC FORM 366A (4-95)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION
- U.S. NUCLEAR REGULATORY COMMISSION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER 6) PAGE (3)
YEAR I SEQUENTIAL NUMBER REVISION NJMBER SALEM - Unit 1 05000272 95 - 024 - 00 4 OF 10 TEXT (If more apace ia required, uae additional copiea of NRC Form 366A) (17)
Description of Occurrence (Cont'd)
The status of the FHV system is inoperable on both Salem units. All fuel movements and FHB crane operations have been suspended pending completion of the spent fuel pool dp surveillance test .
.Analysis of Occurrence The FHV system is designed to operate continuously during normal and emergency plant operations to maintain the atmosphere of the fuel handling building separate from the environment and the other Salem Station buildings. In an accident condition, the exhaust from the E1IV is HEPA/charcoal filtered to control the spread of any fuel handling related contaminants. A negative pressure is maintained in the building to prevent unfiltered out-leakage from the building. These safety related ventilation functions are monitored to ensure there is no release of contaminants to the atmosphere.
The monitoring of the FHB dp is provided on a continuous basis from the control room through the BUILDING AIR D/P LO alarm and periodic TS surveillance testing.
The differential pressure historically used for the low dp alarm setpoint (-0.1" wg) and that required by the testing (-0 .125" wg) are different. Further, the differential pressure controller setpoint (-0.1" wg) was less negative than that required by the Technical Specification.
On September 16, 1995, a special test was performed to demonstrate the relationship between the TS requirement for dp above the spent fuel pool and the differential pressure measured at the controller and alarm location. The special test indicates that a dp of 0.025" wg (when extrapolated) may exist between the pool and the controller with a controller setpoint of -0.1" wg.
This indicates that the controller setpoint of -0.1 in. wg could have had an adequate basis (although undocumented) under the original FHB design configuration. This further provided evidence that actual dp above the spent fuel area is more negative than the alarm setting thus indicating less potential for unmonitored and unfiltered airborne contaminant releases. These test results are currently being evaluated by engineering as part of the resolution of the open Discrepancy Evaluation Form (DEF) .
Investigation further revealed that compliance with the TS was previously provided by temporarily increasing the differential pressure controller setpoint during TS surveillance testing. This step is not includea in the testing procedure but was a normal testing practice. At that time, based on the verbal direction provided from Engineering, it was believed that the purpose of the surveillance test was to demonstrate the capability of ~he FHV system to achieve
-.125" wg pressure differential over the spent fuel pool. The design basis of the system regarding this issue was not documented. However, the compliance of the FHV system with the Technical Specification requirement for differential NRC FORM 366A (4-95)
NRC FORM 366A (4-116)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION
- U.S. NUCLEAR REGULATORY COMMISSION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3)
YEAR I SEQUENTIAL NUMBER I REVISION
~
SALEM - Unit 1 05000272 95 - 024 - 00 5 OF 10 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)
Analysis of Occurrence (Cont'd) pressure is required on a continuous basis and was therefore unproven by the surveillance test. Further, the Technical Specification testing was performed using an undocumented process (i.e., following steps prescribed by previous practice but not identified in the procedure) . Also, it was noted that the ST procedure did not require recording of the "as-found" and "as-left" condition.
It was also found that these differences were not reported to operations as required by the "TS Surveillance Program" which states, in part; "Notify the Job Supervisor and the SNSS/NSS as soon as possible whenever As-Found conditions do not meet Technical Specification allowable values". These concerns with the operation of the FHV system apply to both Salem units.
The specific relationship of the Technical Specifications to the FHV system design basis and operability has been a concern at Salem since 1990. The problem was previously identified for engineering resolution as part of the Configuration Basis Document (CBD) (Design Reconstitution) effort begun in 1988 and documented in a DEF in 1990. However, the basis for the resolution priority assigned to these issues did not consider HVAC systems a priority in terms of safety significance. Sensitivity by engineering to the importance of HVAC systems remained inadequate as eveidenced by the fact that this issue remains unresolved to date. Furthermore, it was by engineering-verbal direction that the interpretation was adopted wherein the purpose of the surveillance test was thought to be that the system is capable of achieving the required TS value. In addition, a SEAT was generated in 1991 which provided the basis for the 0.0" wg setpoint for the alarm. The Unit 1 dp alarm setpoint was changed on 10/16/91 to 0.0" wg. The Unit 2 alarm was changed on 8/26/95.
Failure to understand the system design basis also resulted in the unauthorized manipulation of the FHV systems controls. The design basis for the differential pressure alarm and controller setpoints was not documented. Therefore, the system was manipulated on the supply side, non-safety related portion of the system, to improve the comfort of the personnel working in the FHB without understanding the impact on the safety related function of the ventilation system. Changes from the specified system line-up were found to be the cause of the fuel handling building differential pressure alarms on several occasions.
The local differential pressure controls were not designed or labeled to protect from this type of manipulation. In addition, the significance of changing the non-safety alarm setpoint to 0.0" wg following the rewiring correction was not understood.
The operator response to the alarm conditions was also investigated; however the review was incomplete and inconclusive. The investigation revealed that operators properly identified the absence of an alarm condition in mid-August
'95 which led to discovery of the wiring error. In addition, operators NRC FORM 366A (4-95)
NRC FORll 366A (4-115)
LICENSEE EVENT REPORT (LER)
- U.S. NUCLEAR REGULATORY COlllllSSION TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE(3)
YEAR I SEQUENTIAL NUMBER I REVISION NUMBER SALEM - Unit 1 05000272 95 - 024 - 00 6 OF 10 TEXT (If more apace ia required, uae additional copies of NRC Form 366A) (17)
Analysis of Occurrence (Cont'd) responded to alarm conditions as evidenced by identifying contractor personnel manipulating non-safety related dampers. This review also revealed that the TS AS was not consistently entered immediately upon alann indication. Interviews with three operators indicated that the Action Statement was not entered if the alann cleared within a minute. The alarm response procedure was also reviewed.
The procedure does not specifically require the operator to enter into an Action Statement; rather, the alann response procedure states:
"3.1 STOP any Fuel Handling in progress.
3.2 Notify SNSS/NSS to refer to Technical Specifications".
Operator response to the FHB dp alarm, operator involvement in approval of the work order which allowed manipulation of the non-safety damper, and adequacy of the alann response procedure will be further investigated.
Prior Similar Occurrences Recent other reportable issues involving the Salem Station ventilation (HVAC) include 272/95-06, 272/95-08, 272/95-17, 272/95-19, and 272/95-22. These issues suggest that a heightened awareness and understanding of licensing and design basis requirements associated<with HVAC systems is required. In addition, the System Readiness Reviews have identified deficiencies in the plant ventilation systems. Action has been initiated to evaluate the aggregate impact of these deficiencies on the plant. A cumulative impact evaluation will be perfonned to identify any additional corrective actions required other than the corrective actions listed in the individual LERs.
Safety Significance Actual The negative differential pressure requirement for the operation of the FHV system has a direct impact on the potential for unmonitored off-site release.
The deficiency in the Technical Specification implementation and system maintenance could have resulted in periods of operation when unmonitored out-leakage from the fuel handling building was possible. The safety significance of this degraded condition is low since no fuel handling or crane operation accidents occurred to cause a significant release.
The special test conducted provided further evidence that actual dp above the spent fuel area is more negative than at the location of the alarm and controller thus indicating less potential for unmonitored and unfiltered airborne contaminant releases.
NRC FORM 366A (4-95)
NRC FORM 388A (4-116)
- _)
- U.S. ~UCLEAR REGULATORY COlllllSSION LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE(3)
YEAR I SEQUENTIAL NUMBER I REVISION l\ll-"EER SALEM - Unit 1 05000272 95 - 024 - 00 7 OF 10 TEXT (If more apace ia required, use additional copies of NRC Form 366A) (17)
Safety Significance (Cont'd)
Potential A review was performed by Nuclear Fuels to determine the potential significance of an unmitigated release (i.e., inoperable F1IV system) following a fuel handling accident. This accident assumes a release of the gaseous fission products contained in the fuel rod gap of all 264 fuel rods in a single assembly. Fission product inventories were estimated using the ORIGEN-2 code.
It further assumed a dropped fuel assembly burned to 65,000 MWD/MTU and, prior to the outage, the reactor had been operating at 3600MWth (105.5% of rated power) . The iodine and xenon inventories were assumed to be conservatively proportional to the radial power peaking factor, which was in turn, conservatively set to l.70(current TS limit per 3.2.3 is 1.55). Technical Specification 3/9.3 requires that the reactor remain subcritical for 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> prior to the movement of irradiated fuel. These inputs along with an assumed filter decontamination factor of 1.0 (i.e., no filtration of airborne source terms) yielded offsite doses within the limits of 10 CFR Part 100. It should be noted that an unfiltered fuel handling accident release was assumed as part of the calculation for GDC-19 compliance.
For both the actual and potential cases above, the actuation of the alarm caused by the existence of a high radiation signal from the local radiation monitor would have alerted the operators and resulted in operator cognizance and requisite mitigative actions.
cause of Occurrence A significant cause of this issue was determined to be inadequate design basis information; several contributing causes are also discussed below. The ventilation system TS requirement for maintaining a negative dp in the F1IB was not well understood as evidenced by the TS interpretation that the surveillance only has to demonstrate that the system is capable of achieving the required value. In addition, the lack of sensitivity to the safety significance of the ventilation system was evidenced by its low priority for resolution. Specific inconsistencies exist between the design basis information reflected in the E1IV system configuration basis document (CBD), UFSAR, and the TS. The incomplete and conflicting design basis information resulted in:
- inappropriate selection of the E1IV alarm and control set points,
- inadequate understanding of the intent of the Technical Specification requirements,
- inadequate surveillance procedure instructions and conduct of testing,
- incorrect manipulation of portions of the F1IV system,
- inadequate requirements for post maintenance testing and periodic maintenance of non-safety HVAC components which affect compliance with HVAC TS requirements, and NRC FORM 366A (4-95)
NRC FORll 366A (4-85)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION
- U.S. NUCLEAR REGULATORY COlllllSSION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3)
YEAR I SEQUENTIAL NUMBER I REVISION llAJMBER SALEM - Unit 1 05000272 95 - 024 - 00 8 OF 10 TEXT (If more space i* required, use additional copies of NRC Form 366A) (17)
Cause of Occurrence (Cont'd)
These concerns with the design basis information also extend, at least in part, to other Salem HVAC systems. Previously identified design basis inconsistencies and documentation inadequacies require resolution on these systems especially as they relate to the resolution of open DEFs.
Inadequate control over the local operation and adjustment of the FHV system components also affected the Technical Specification compliance. A standing work order for the FHV System allowed for unspecified changes to the system without specific review. The lack of cognizance (system operating and testing requirements) by testing, maintenance, work control, operations and engineering personnel, as well as the incomplete surveillance testing procedures, was indicative that the level of understanding was not commensurate with the safety significance of the FHV system. The system design, the station operations procedures and work control practices did not ensure the FHV system configuration was protected from changes impacting the TS. The use of Radiation Protection personnel for the conduct of the HVAC surveillance testing and their respective training was ineffective in ensuring compliance with TS requirements.
It should be noted that the review results to date regarding Operations response to the FHB dp alarm were not considered to be a significant contributor to the FHV problems. Further review will be performed.
Corrective Actions The corrective actions listed below apply to both Salem units, except as noted otherwise.
Immediate Actions Taken Immediate Actions taken to ensure FHV system operability associated with the FHB dp for both Salem units include:
- changed the FHV dp controller setpoints to be more* negative than the -0.125" wg TS requirement.
- Added local monitoring of the FHV dp controller to the Operator rounds.
- Ensured operability of the FHB dp alarm.
- Verified the TS requirements for air flow and determined that it had no impact on current FHB system operation
- Following the initial immediate actions, a new electronic controller and alarm sensor was installed in Unit 2; similar to that which was previously installed in Unit 1.
NRC FORM 366A (4-95)
, NRC FORM 366A (4-95)
LICENSEE EVENT REPORT (LER)
- U.S. NUCLEAR REGULATORY COMMISSION TEXT CONTINUATION FACILITY NAME (1) DOCKET NUMBER121 LER NUMBER (6) PAGE(3)
YEAR I SEQUENTIAL NUMBER I REVISION NUMBER SALEM - Unit 1 05000272 95 - 024 - 00 9 OF 10 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)
Corrective Actions (Cont'd)
Near Term Actions
- A surveillance test will be perform.ed using the revised methodology prior to declaring the system operable and prior to the formal revision of the procedure referred to in "Long Term. Corrective Actions". This testing is expected to be completed by October 23, 1995.
- Direction will be provided to appropriate personnel regarding the impact of manipulating non-safety FHV components on the operability of the FHV system.
This direction is expected to be provided prior to declaring the FHV system operable.
- The FHV dp alarm setpoints will be reset to -0.13" wg until such time that the design basis setpoint is determ.ined by Engineering in item 1 below.
Long Term Corrective Actions The causes of the concerns will be addressed as follows:
- 1. Establish the design basis and setpoints for the FHV system pressure controller, differential pressure switch (alarm.), and radiation monitors.
This activity is expected to be completed by December 11, 1995.
- 2. Disposition all open issues identified in DEFs which affect the operability of the FHV system prior to restart, which is exp0cted during the first and second quarter of 1996 for Units 1 and 2, respectively.
- 3. Identify inconsistencies between the established design, technical specifications and surveillance test procedures prior to restart, which is expected during the first and second quarter of 1996 for Units 1 and 2, respectively.
- 4. The impact of the Technical Specification changes and clarifications developed on the design, testing, and maintenance of the FHV system will be formally communicated to appropriate personnel . This training will be provided to appropriate personnel prior to restart, which is expected during the first and second quarter of 1996 for Units 1 and 2, respectively *.
- 5. A condition resolution has been initiated to address the failure to detect the rniswired alarm.
- 6. Evaluate and identify, where required, the need for controls to prevent unauthorized manipulation of HVAC components (e.g., dampers, vents, controllers, alarms, etc) which can affect TS compliance/operability of a safety related system.
NRC FORM 366A (4-95)
NRC FORM 366A (4-95)
NRC FORll 366A (4-96)
- LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION
- U.S. NUCLEAR REGULATORY COlllllSSION FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3)
YEAR I SEQUENTIAL NUMBER I REVISION
~
SALEM - Unit 1 05000272 95 - 024 - 00 10 OF 10 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)
Long Tenn Corrective Actions (Cont'd)
- 7. Operator response to the E1IB dp alann condition, involvement in approval of the work order which allowed manipulation of the non-safety damper, and adequacy of the alann response procedure will be further investigated.
- 8. Action has been initiated to evaluate the aggregate impact of the HVAC deficiencies, as discussed in "Prior Similar Occurences". A cumulative impact evaluation will be perfonned to identify any additional corrective actions required other than those considered in the corrective actions listed in the individual LERs.
A supplement to this LER will be provided if the corrective actions taken as a result of this LER determine that additional TS violations were found to have existed. All corrective actions will be taken in accordance with the revised corrective action program.
NRC FORM 386A (4-95)