ML20029E136

LER 94-007-00:on 940412,CRAC & Ebfs Were Inoperable Due to Previous Charcoal Testing Performed to Industry Std Different than Ts.Corrective Actions:Ts Changed to Reflect Newest Charcoal Testing procedure.W/940511 Ltr

ML20029E136
Person / Time
Site:	Millstone
Issue date:	05/11/1994
From:	Lutzi P, Miller D NORTHEAST NUCLEAR ENERGY CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-94-007-01, LER-94-7-1, MP-94-323, NUDOCS 9405170065
Download: ML20029E136 (5)

Text

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//il(\// i Nucienr Etterp* Millstone Nuclear Power Station Northeast Nuclear Energy Company P.O. Box 128 Waterford. CT 06385-0128 (203) 444 - 4300 Fax (203) 444-4277 The Northeast Utilities System Donald B. Miller Jr.,

Senior Vice President - Millstone May 11, 1994 ke[10bb50.73(a)(2)(i)

U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555

Reference:

Facility Operating Ucense No. DPR-65 Docket No. 50-336 '

Licensee Event Report 94-007-00 Gentlemen:

This letter forwards Licerisee Event Report 94-007-00 required to be submitted within thirty (30) days aursuant to 10CFR50.73(a)(2)(i), an event or condition that alone could have preventec the fulfillment of a safety function.

Very truly yours, NORTHEAST NUCLEAR ENERGY MPANY Donald B. Miller, Jr.

f 1 Senior Vice President - Millstone Station i

DBM/PB:cle

Attachment:

LER 94-007-00 l

cc: T. T. Martin, Region l Administrator P. D. Swetland, Senior Resident inspector, Millstone Unit Nos.1,2 and 3 G. S. Vissing, NRC Project Manager, Millstone Unit No. 2 7 w, 9405170065 940511 6 j/

DR ADOCK 0500

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l NRc F orm 366 U.S. NUCLEAR REGULAlORY COMM:SSION APPROVED BY OMB NO. 3150-0104 1

@~&D EXPIRES: 5/31/95 l

ESTIMATED BURDEN PER RESPONSE TO COMPLY WTTH THIS INFORMATION '

COLLECTION REQUEST 30.0 HR$ FORWARD COMMENTS RF.GARDING l BNN ESMA4 TO THE INQRMADON AND RECORDS MANAGEMENT l LICENSEE EVENT REPORT (LER) RRANCH IMNilB 77141. US NUCLEAR REGULATORY COMMIS SION.

WASHINGTON DC 2065S-0001 AND TO TFE PAPERWORK REDUCTION PROJE CT (3160- 0104). Of71CE OF MANAGEMENT AND DVDGET I (See twege for reqped rumrye* of Gytecha wers tue sa@ t40ce) WASHINGTON DC 20503 F ACluTY h AME (1) DOCKET NUMBER (2) PAGE (3)

Millstone Nuclear Power Station Unit 2 05000336 1OF4 nru m Emergency Charcoal Filters Tested to Wrong Standard l

EVENT DATE (S) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8)

MONN DAY M AR YI AR SE P 3 MONTH DAY YEAR F AW Y NAM D M TNU N R 05000 FACluTY NAME DOCKET NUMBER 04 12 94 94 - 007 -- 00 05 11 94 05000 opp RATmG THis REPORT IS BEING SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR 6: (Check One or more) (11) 20 erfb) 20 4C6fc1 SC 73ta;Z(M 73 71(b)

POWER 20 405:aH1@ 50 36(citt) $0 73:a@M 73 71(c) 20 405(aH1i fif) 50.36fc@ 50 734aH2W4 OTHER 20 405ta)(1)fai X S 73

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LICENSEE CONTACT FOR THIS LER (12)

NAME TTLF PHONF NUMhf R tinclAs Arne Codo 1

Philip J. Lutzi, Site Licensing (203) 447-1791 Ext. 6585 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

RE PORTABLE REFORTABLE CAUSE SYSTTM cop 0 % LNT MANUF ACTURE R TO NPRT1S CAUSE SYSTEM COMPONFNT MANUFACTURER TO NPRDS SUPPLEMENTAL REPORT EXPECTED (11) ** "*"

EXPECTED Yes no SUBMISSION m yes enweis rxPECTED sutusslON DATc X DATE (15)

ADSTRACT (tima m 14c() spus t e . antwwmerwy n er,pe- anaced typewmen imesi ps)

On April 12,1994, at 1715 hours0.0198 days <br />0.476 hours <br />0.00284 weeks <br />6.525575e-4 months <br />, with the plant in Mode 1 at 100% power, it was identified that the Facility 2 Control Room Air Conditioning (CRAC) and Enclosure Building Filtration System (EBFS) were inoperable because previous charcoal testing was performed to an industry standard different from the standard referenced in the Millstone Unit 2 Technical Specifications.

Upon determining that the testing criteria specified in the Unit 2 Technical Specifications could not be performed, a Notice of Enforcement Discretion (NED) was requested to perform testing of charcoal adsorbers in accordance with ASTM D3803-89, the more stringent procedure for establishing the capability of new and used activated carbon to remove radio-labeled methyl iodide from air streams. The charcoal for all four trains of equipment, two facilitios of CRAC and two facilit;es of EBFS, were tested utilizing ASTM D3808-89 with results greater than 95%

efficiency as specified in the proposed change to the Millstone Unit 2 Technical Specifications.

l NRC Fwm 366 (5 -(C)

NHC Form 306A U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104 (5-92) EXPIRES: $/31/95

. LICENSEE EVENT REPORT (LER) ENSEE"Er"e7IEs""roElCT"wErs"EE TEXT CONTINUATION EEC"T"[EI T ECE ^70ESE EuYsE H 3150 0 0 0 ICE OF AO NT AND U WASHINGTON DC 20503 FACluTV NAME 0) DOCKET NUMBER Q) LER NUMMR @ PAGE (2 YEAR p rfp Millstone Nuclear Power Station Unit 2 05000336 94 - 007 -

00 02 OF 4 TEXT (n mm .w. mv.n m c@es W NRC F orm 3%A) p D

1. Descrintion_oLEvent On April 12,1994, at 1715 hours0.0198 days <br />0.476 hours <br />0.00284 weeks <br />6.525575e-4 months <br />, with the plant in Mode 1 at 100% power, as part of a ventilation testing procedural review, it was identified to the system engineer that the vendor could not test the Control Room Air Conditioning (CRAC) Emergency Filtration System and Enclosure Building Filtration System (EBFS) charcoal canisters as specified on the Purchase Order and that the vendor had never tested previous test samples as specified on the Purchase Order. Subsequent investigation revealed that previously analyzed charcoal test canisters were not tested to the standards referenced in the Millstone Unit 2 Technical Specifications. The vendor tested the canisters to a different industry standard.

The Unit 2 Technical Specifications state as the surveillance requirements for charcoal adsorbers:

" Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978."

Regulatory Guide 1.52 lists as testing conditions for Laboratory Tests for Activated Carbon as:

"2 inches. Air filtration system designed to operate outside the primary containment and relative humidityis controlled to 70%. Per Test 5.bdat a relative humidity of 70% for a methyliodide penetration ofless than 1%. <

l d

See Table 5- 1 of ANSI N509- 1976 (Ret 1). "

Table 5-1 of ANSI-1976 - Summary Table of New Activated Carbon Physical Properties Batch Tests to be performed on Finished Adsorbents.

"S.b Methyllodide, 80*C and 95% relative humidity. Test Method - RDT M16-1T per 4.5.3, except 80* C and 95% relative humidity air is required for test (pre and post-loading sweep medium is 25

• C). "

The test condition that the vendor could not simulate was the " Pre-and Post-Loading Sweep" condition. )

The pre-sweep at 25*C, immediately followed by the lodido penetration test at 80*C and 95% relative  !

humidity causes water to condense on the charcoal and damages it by " wetting" the charcoal sample.

This action negates the ability to obtain test results from the charcoal sample.

The test which was performed by the vendor was in accordance with ASTM D3803-1970 which became the industry standard for testing charcoal when it was issued. There were identified deficiencies in the RDT M16-1T procedure that were acknowledged by the vendor and therefore, he did not consider it to be a technically correct test.

The past charcoal testing results of both facilities (trains) of CRAC and EBFS were reviewed. It was aetermined that both Facility 1 CRAC and EBFS charcoal beds were operable because no invalid tests had been performed since these charcoal beds were replaced within a time frame where the surveillance testing was not required. However, the Facility 2 CRAC and EBFS were declared inoperable for the following reasons as specified by the surveillance requirements of the amciated Technical Specifications:

1) The Facility 2 CRAC was declared inoperable because the charcoa- td been inservice greater than 18 months and the previous charcoal testing was performed to the wr ong test standard.

2) The Facility 2 EBFS was declared inoperable because it had exceeded the 720 hour0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> run time and the charcoal testing for it was performed to the wrong test standard.

NHC Fwm 3fAA (S-92)

NH orm 366A U.S. NUCLEAR REGULAT ORY COMMisslON APPROVED BY oMD No. 3150-0104 bl EXPIRES: 5/31/9s

, LICENSEE EVENT REPORT (LER) EEEEMEi"Er" L*Ts ' 'roOTI8 cTINis'"lfoEE TEXT CONTINUATION $"E 'EdYN CN TeoirS* EuYsTIOT E N sfos E$cc^"o/ usa $tE"N *TAND wAsaNo1oN. DC 20503 FACEJTY HAME (4 DOCKET NUMBER (2) UR NUMBFR @ PAGE($ l YEAR "F WM Millstone Nuclear Power Station Unit 2 05000336 94 - 007 - 00 03 OF 4 TEXT m mwe spaa m wed we modmons comes of NRC Fwm 366A) (17)

The plant entered Technical Specification Action Statement (TSAS) 3.6.5.1 and 3.7.6.1. A Notice of ,

Enforcement Discretion was requested to perform testing of charcoal absorbers in accordance '

ASTM D3803-89 with the more stringent procedure for establishing the capability of new and used activated carbon to remove methyl iodide from air streams. The charcoal for all four trains of equipment, two facilities of CRAC, and two facilities of EBFS was tested utilizing ASTM D3803-89 with results greater than 95% efficiency as specified by the proposed change to the Millstone Unit 2 Technical Specifications.

The Unit 2 Technical Specifications are in the process of being changed to reference the more stringent test standard and all subsequent charcoal tests will be performed in accordance with ASTM D3803-89.

There were no automatic or manually initiated safety system responses as a result of this event,

11. CauSAptEvent The root cause of this event has been determined to be personnel error in that the purchase requisitions identifying the test condition standard did not receive the appropriate level of review prior to being issued to the test vendor for surveillance testing. Prior to 1983, QA purchase orders were not written to document the testing requirement standards. The testing method was left up to the discretion of the vendor. From 1983 to 1994 the purchase orders that were written were inconsistent, they either did not specify the Technical Specification requirements or identified the wrong testing standard. In conjunctions with this, the  ;

test results did not receive an adequate receipt inspection. The only critical characteristic reviewed on the test data sheets was the acceptance criteria for efficiency, testing parameters were not reviewed or verified. j til. Analysis _of Even.1 Although the charcoal was not tested in accordance with the Millstone Unit 2 Technical Specifications, the charcoal was tested in accordance with standard industry charcoal test conditions. Test results were reviewed and compared against the original acceptance critoria and appropriate actions were taken as a result of these test results. The acceptance criteria for the EBFS and the CRAC systems charcoal efficiency was not different than originally analyzed.

Based on event investigation results that the charcoal in the Facility 2 CRAC and EBFS were not tested in accordance with Technical Specification requirements, this event is being reported under 10CFR50.73(a)(2)(i) as a condition prohibited by the plant's Technical Specifications.

There were no safety consequences associated with this event since the charcoal systems in the Facility 1 CRAC and EBFS were recently changed and within their acceptable surveillance requirement time frame.

Additionally, though previous tests were performed to a different industry standard, the testing was technically acceptable and the units acceptance criteria had been satisfied. Subsequently, the charcoal for all four trains of equipment, two facilities of CRAC, and two facilities of EBFS were tested utilizing ASTM D3803-89 with results greater than 95% efficiency as specified by the proposed change to Millstone Unit 2 Technical Specifications.

i IV. CorrecitvoAction  !

The Technical Specifications surveillance criteria for the Millstone Unit 2 Enclosure Building Filtration System Emergency Filtration (4.6.5.1), the Control Room Emergency Filtration charcoal efficiency testing (4.7.6.1), and the Storage Pool Area Ventilation system (4.9.15) were changed to reflect the newest and more stringent charcoal testing procedure for establishing the capability of new and used activated carbon to remove radio-labeled methyllodido from air streams in accordance with ASTM D3803-W. A charcoal test canister was removed from each of the four charcoal units and tested in accordance witt. D3803-89.

Subsequently, the charcoal for all four trains of equipment, two facilities of CRAC and two facilWes of EBFS, exhibited greater than 95% officiency.

NRC Fcum 3M4 (5-97)

NRQ Form 366A U.s. NUCLEAR REGULATORY COMMisslON APPROVED BY OMB NO. 3130-0104

@-92) EXPIRES: 5/31/95

' LICENSEE EVENT REPORT (LER) EEICINE"5"III>E' 'rOET CE#$s"#G%^E TEXT CONTINUATION 7/ECN cs,nuA$7gqyNU

< neb LEAR RG TORY OM i WASHINGTON DC 206$$-0001. AND TO THE PAPERWORK REDUCTION PROJE CT (3150-0104L Off lCE OF MANAGEMENT AND DVDGET WASHINCTON. DC 20503 FACMJ TV NAME (1) DOCKET NUMBER Q) LER NtWHER (6) PAGE (3r EAN MEF N Bf Millstone Nuclear Power Station Unit 2 05000336 94 -

007 - 00 04 OF 4 TEXT (n mrx acere e reqJfed. use addthore cr. pes of NRC Form 306A) (17)

The Operations Department will provide written departmental guidance to cover the appropriate technical requirements to be specified on the purchase order to the testing vendor for processing laboratory test samples for charcoal test canister for the EBFS and CRAC systems. The surveillance acceptance criteria will also be modified to ensure that all necessary data pertaining to the appropriate vendor data is verified prior to surveillance acceptance. These two items will be accomplished prior to the next scheduled surveillance.

V Addil!Q0all0f0ImatiOD Similar LERs: None Ells. cad 2 Emergency Air Filtration: B11 - FLT- A220 l

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