ML19325C370

LER 89-017-00:on 890907,determined That Discrepancy in Acceptance Criteria of Surveillance Test Procedure M-452-0 Resulted in Failure to Fully Comply W/Requirements of Tech Spec 3.9.12.Main Cause undetermined.W/891009 Ltr

ML19325C370
Person / Time
Site:	Calvert Cliffs
Issue date:	10/09/1989
From:	Milbradt M, Russell W BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-89-017, LER-89-17, NUDOCS 8910160126
Download: ML19325C370 (5)

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' I CHARLES CENTER e P,0. BOX 1475

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'.cAtvtat CALutRT Cliff 8eowen currs wucaAn NUCLEAR etat POWER PLANT DEPARistui '

, LU$K MARVAND 20657 1 ,

October 9. 1989 )

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0. S. Nuclear Regulatory Commission Docket No. 50 317 i

' Document Control Desk License No. DPR 53 Washington, D. C. 20555 l

Dear Sirs:

The attached LER 89 017 is be'ing sent to you as required under 10 CrR 50.73 Should you have any questions regarding this report, we would be pleased to 1 discuss them with you.  ;

i Very truly yours, ,

b L. B. Russell Manager Calvert Cl1ffs Nuclear ' Power Plant Depart. moat q, u MDM:sb ,

t' cc: William T. Russell .

Director, Office of' Management Information

• and Program Control

. Messrs: G. C.. Creel C.11. Cruse j h

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Assi a AC, <o-, ,e e m <.t e e-.-=, e- r. <* . .. ,, oo nei On September 7, 1999, the Spent Tuel Pool Ventilation system engineer determined that a discrepancy in the acceptance critoria of Surveillance Test Procedure M 452 0 resulted in a failure to fully comply with the requirements of Technical Specification 3.9.12, Action'A. The number 11 Spent Fuel Exhaust fan was declared OPERABLE after meeting the acceptance criteria of M 542-0, yet it did not satisfy the minimum Technical Specificatiot. flow requirement.

The root cause of the procedure error can not be determined. Existing records did not indicate why the acceptance criteria was changed, however it appears to have been a typographical error. The lack of sufficient subsequent procedure reviews is a secondary cause for this event.

Corrective actions for this event include:

1. A Maintenance Request was initiated to determine the cause and corrective actions for the low flow condition on the number 11 fan.

2. A procedure change was made to correce the minimum flow acceptance criteria in STP M 542-0,

3. A detailed review of test procedures used to satisfy Technical Specification requiremants will be performed.

4. An upgraded STP program has been implemented.

5. The Quality Assurance Technical Specification audit process has been improved, a,C,,. .- n.

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1. Description of Event On September 7, 1989, the Calvert Cliffs system engineer for the Spent Fuel l Fool Ventilation system identified a discrepancy betweer. a Surveillance Test Procedure and the associated Technical Specification surveillance requirement, Technical Specification Surveillance 4.9.12 requires we verify a flow rate of  :

32,000 cubic feet per minute (cfm) plus or minus 10 percent for each exhaust fan in the Spent Fuel Ventilation system. The minimum allowed flow rate is 28,800 cfm. Whil reviewing Surveillance Test Procedure (STP) M 542-0, " Spent Fuol Storage 'ilter Test," the engineer discovered the minimum flow acceptar.co celusia in STP h 542 0 was 28,000 cfm. 800 cfm less than that specified ty Jh. 'rechnical Specification. At the time of discovery Unit 1 was ,

in cold sMtdon W Unit 2 was defueled. [

r STP M 542 0, wat performed on August 25, 1989 following replacement of the Spant Puel Pool Ventilation High Efficiency Particulate Air (HEPA) filters.

On September 7, 1989 the system engineer reviewed the results of the test and i noted the flow rate measured for the number 11 Spent Fuel Exhaust fan was 379 i cfm below the Technical Specification minimum limit of 28,800 cfm. The engineer then discovered that the acceptance criteria for minimum flow was ,

incorrectly listed in the procedure as 28,000 cfm. The system engineer immediately notified the shift supervisor and the number 11 fan was declared inoperable. The Shift Supervisor verified the acceptability of the Fuel Pool Exhaust fan 12 flow data, determined it was OPERABLE, and placed it in i service.

A review of plant records indicates number 11 Spent Fuel Exhaust fan was declared OPERABLE on August 30, 1989, following review of STP M 542 0 results  ;

by the Shift Supervisor. The fan was placed in service on August 31, and remained in operation until September 7, 1989. Although declared OPERABLE, Spent Fuel Exhaust fan 11 was technically inoperable for failure to meet the  ;

Technical Specification ninimum flow limit. During this period, irradiated ,

fuel movements were performed in support of fuel inspections. Technical Specification 3.9.12, Action A allows continued fuel movement with an inoperable exhaust fan only if the OPERABLE fan is in operation. Because the OPERABLE fan, number 12, was not in operation during this period, the plant was in a condition prohibited by the Technical Specifications.

II. Cause of Event The root cause of the procedure error can not be determined. A review of previous revisions to the procedure determined the minimum acceptance criteria was changed from the correct number for flow (28,800) to the incorrect flow l

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.(28,000) in December 1984. Existing records did not indicate why the l acceptance criteria was changed. The procedure format was modified during this period, and it is likely that the number change was the result of a typographical error.

Procedure reviews conducted between December 1984 and the event discovery did not identify tho erroneous acceptance criteria. A Quality Assurance (QA) audit of Surveillance 4.9.12 was performed in 1985. The QA audit also failed i to identify the discrepancy. The lack of sufficient reviews is a secondary cause for this event.

III. Annlysis of Event The ventilation system is required to be OPERABLE when irradiated fuel is in the spent fuel storage pool. Technical Specifications cllow fuel movements in the pool with an inoperable fan if an OPERABLE fen is in operation.

Surveillance tests performed since 1984 were reviewed to determine if any prior performances had resulted in flow measurements below the Technical Specification limits. Although previously performed tests used test procedures with the improper acceptance criteria, actual measured results j exceeded the 28,800 cfm limit. Based on this review, the only period i during which the system did not meet Technical Specification limits was

'from August 25, 1989 through September 7, 1989.

The ventilation system is designed to be manually initiated in the event a fuel handling incident occurs. Spent Fuel Pool exhaust would be diverted through HEPA and charcoal filters to minimize offsite releases. The system j charcoal filters remained OPERABLE during this event. The analysis of this l event is provided in Calvert Cliffs Updated Final Safety Analysis Report I

(UFSAR) section 14.18. The analysis credit.: the ventilation system for

! removal of 90 percent of the iodine released in a postulated incident.

l L In this evert, system flow was below the required flow by 379 cfm, only 1.3 l percent of ti.e system minimum acceptable flow. The small deviation in flow i vould not have an affect on system performance during a fuel handling l incident. The s,'te boundary doses would still be well below the allevable 10 CFR 100 limits.  ;

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1 IV. - Corrective Actions i Immediate

1. The system engineer immediately notified the Shift Supervisor of the .

procedure error, whereupon the number 12 fan test results were verified j acceptable and the number 12 fan placed in operation.

2. A maintenance request was initiated to determine the cause and corrective actions for the low flow condition on the number 11 fan.

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1. A procedure change was made to correct the minimum flow acceptance criteria in STP M 542 0,

2. The Surveillance Test Procedure program has been upgraded to include coordinators who are responsible for overseeing and maintaining STPs assigned to them. A major part of their responsibility is assuring that Technical Specification requirements are properly addressed,

3. A detailed r n iew of existing procedures which are used to satisfy Technical specification surveillance requirements is in progress and will ensure that each requirement is correctly addressed in procedures.

l 4. The QA Technical Specification audit precess has been improve.d by becoming more technically oriunted with an expanded audit checklist.

V. Additional Information Related Events

.No similar events have been identified which were the result of improper acceptance criteria listed in a Surveillance Test Procedure. A somewhat l:

similar event related to surveillance testing of the Spent Fuel Pool exhaust ventilation fan was reported in LER 317/89 013, however that event was due to omission of a surveillance requirement.

Comoonent identification Codes L EIIS Function EIIS System  ;

Component Code Code Spent Fu61 Pool ,

Exhaust Fan- FAN VG i l l

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l l l l l I

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I 0" N.S. CP0s 4986+520-589 000 70

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