UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C.

20555 November 22, 1988 NRC INFORMATION NOTICE NO. 88-92:" POTENTIAL FOR SPENT FUEL POOL DRAINDOWN Addressees: All holders of operating licenses or construction permits for nuclear power reactors. Purpose: This information notice is being provided to alert addressees to potential problems resulting from the failure of the fuel transfer canal door seal. It Is expected that recipients will review the information for applicability to their facilities and consider actions, as appropriate, to avoid similar problems. However, suggestions contained in this information notice do not constitute NRC requirements; therefore, no specific action or written response is required. Description of Circumstances: On October 2, 1988, with Surry Unit 1 in cold shutdown, the licensee was preparing to test the fuel transfer system (see attached figure) before fuel off-load. The transfer canal door was in place and the single door seal was inflated. The fuel transfer canal was dry. The fuel transfer tube was open, the blind flange was removed on the containment side, and the gate valve was open on the spent fuel pool side. The refueling cavity seal was not in place. An accidental pinhole puncture of the single air supply line to the transfer canal door pneumatic seal was promptly detected and the air leak quickly stopped before it could lead to a loss of seal integrity. Discussion: A review of this event by the licensee showed that, given the configuration of the transfer canal, the transfer tube, and the refueling cavity existing at the time of the event, an inadvertent draindown of the spent fuel pool could occur to a height of only 13" above the top of the fuel assemblies (see attached figure). This postulated draindown assumes no operator action and a loss of instrument air or pneumatic seal failure. Increased radiation levels in the spent fuel pool building would have limited stay time in the building and impeded recovery. The licensee estimated that the dose rate, based on the spent fuel inventory at the time of the event, could have reached 50 R/hour on the operating deck. The licensee also calculated that with the refueling cavity seal assembly in place, the spent fuel pool could only draindown to 14 feet above the top of the fuel assemblies.

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In 88-92 November 22, 1988 Page 2 of 3 If newly discharged fuel had been placed in the spent fuel pool, a postulated draindown of the spent fuel pool could have led to even higher radiation levels in the spent fuel pool building than the radiation levels postulated by the licensee. If a seal failed and spent fuel pool water were lost while a fuel assembly was lifted, fuel could be uncovered and fuel cladding could fail. The licensee is considering several actions based on the review of this event. The short-term actions include: (1) revising procedures to require that the refueling cavity seal assembly be installed before opening the transfer tube gate valve for dry testing the fuel transfer system, (2) reviewing and upgrading a procedure for the loss of spent fuel pool inventory, (3) upgrading the material of the plastic air hose in which the pinhole occurrede and (4) providing an emergency escape system for personnel in the transfer canal. The long-term actions include: (1) evaluating the canal door and seal design including the need for a backup air supply, a low air pressure alarm, and a backup seal, (2) evaluating other pneumatic seals used at Surry, (3) developing a procedure for installing, inspecting, and testing the seals in accordance with the manufacturer's recommendations, (4) revising procedures to ensure the transfer tube blind flange is installed whenever the transfer canal is drained for maintenance on the transfer tube gate valve, and (5) reviewing further the procedures for loss of spent fuel pool and refueling cavity water level, after the short-term modifications to these procedures. In 1981, a related event occurred at Arkansas Nuclear One, Unit 2. At the end of a refueling outage with the transfer canal door closed and the door seal inflated, the transfer canal was drained in preparation for performing maintenance on the fuel upender. Concurrent maintenance on the air system resulted in a loss of air pressure to the seal, and water leaked from the spent fuel pool into the fuel upender pit. The transfer gate valve was closed and acted as a barrier to the flow. The leakage stopped when the water levels equalized. The spent fuel pool level had decreased by 7 feet. If the seal had leaked while the maintenance on the upender was in progress with the fuel transfer tube gate valve open and the fuel transfer tube blind flange removed, the spent fuel pool could have drained down to a level just above the top of the fuel assemblies. Pneumatic seals are also used in the refueling cavity seal assembly. In many cases, the failure modes of the refueling cavity seals (IE Bulletin 84-03, "Refueling Cavity Water Sealu and Information Notice 84-93, "Potential for Loss of Water From the Refueling Cavity") apply to the spent fuel pool gate seals. These events show that a door equipped. with a single seal and/or a single air supply is subject to complete loss of function from a single failure. Therefore, the seal must be properly installed, and the seal and air supply system must be carefully maintained. The scenarios discussed also point out the need for carefully coordinating such activities as maintenance and testing to avoid undesirable interactions between systems which could result in fuel uncovery, personnel injury, and personnel contamination.

IN 88-92 November 22, 1988 Page 3 of 3 No specific action or written response is required by this information notice. If you have any questions about this matter, please contact the technical contact listed below or the Regional Administrator of the appropriate regional office.

4harlesE. RoAii Dif/~t

Technical Contact: Daniele Oudinot, NRR (301) 492-1174

Division of Operational Events Assessment Office of Nuclear Reactor Regulation

Attachments: 1. Figure of Fuel Transfer System 2. List of Recently Issued NRC Information Notices

UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C. 20555 November 29, 1991 NRC INFORMATION NOTICE 88-92, SUPPLEMENT I: POTENTIAL FOR SPENT FUEL POOL DRAINDOWN

Addressees All holders of operating licenses or construction permits for nuclear power reactors.

Purpose
The U.S. Nuclear Regulatory Commission (NRC) is issuing this supplement to Information Notice (IN) 88-92 to inform addressees of additional information It is expected that regarding the potential for spent fuel pool draindown. recipients will review the information for applicability to their facilities and consider actions, as appropriate, to avoid similar problems. However, suggestions contained in this information notice supplement are not NRC requirements; therefore, no specific action or written response is required. Background The NRC issued IN 88-92 to alert addressees to problems that could result from the failure of pneumatic-type boot seals used to separate the spent fuel poo! (SFP) from other cavities such as the fuel transfer canal and the refueling cavity. IN 88-92 described events involving the loss or potential loss of this typt of seal that occurred at Surry Power Station, Unit 1, and Arkansas Nuclear One (ANO), Unit 2. A description of a recent event and two potential scenarios with safety significance follows. Description of Circumstances On September 23, 1991, Wolf Creek Generating Station (WCGS) was in cold shutdown in preparation for refueling when it experienced a .SFP draindown. The gate between the SFP and the fuel transfer canal was in place with the dual boot seals inflated (Figure 1). The fuel transfer canal was partially filled (about half full) with borated water and the fuel transfer tube which connects to the refueling cavity was closed. The air supply for the SFP gate seals comes from the nonsafety-related service air system. The event was initiated by the loss of a nonsafety-related electrical bus which caused the service air to isolate from its source. The loss of this bus also caused a loss of the instrumentation that provided SFP level indication. The SFP gate seals subsequently depressurized through leaks in the service air system (Figure 2). The leaks occurred at isolation valve packings, check valves, and at "Chicago" quick-connect fittings that were not in accordance with design drawings. 9111250106

IN 88-92, Supplement 1 November 29, 1991 Page 3 of 3 To mitigate the risk of the second scenario, the licensee committed to either have all three fuel building cavities i.e. the SFP, the cask loading pool, and the fuel transfer canal, full or to notify management and establish other compensatory measures when performing fuel inspections or reconstitutions. This information notice supplement requires no specific action or written response. If you have any questions about the information in this supplement, please contact the technical contact listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

4"harlesE. Rossi, Director Division of Operational Events Assessment Office of Nuclear Reactor Regulation Technical contact: Dr. Dale A. Powers, RIV (817) 860-8195

Attachments: 1. Figure 1. Fuel Transfer System 2 Figure 2. Spent Fuel Pool Gate Seal Air Supply Lines 3. List of Recently Issued NRC Information Notices

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SPENT FUEL POOL GATE SEAL AIR SUPPLY LINES

Attachment 3 IN 88-92, Supplement I November 29, 1991 Page I of I LIST OF RECENTLY ISSUED NRC INFORMATION NOTICES Information
Notice No. Subject

Date of
Issuance Issued to

91-78

Status Indication of
Control Power for Circuit Breakers Used in Safety-Related Applications

11/28/91

All holders of OLs or CPs

for nuclear power reactors.

90-57, Supp. I

Substandard, Refurbished Potter & Brumfield Relays Represented as New Shift Staffing at Nuclear Power Plants 10 CFR Parts 21 and 50.55(e) Final Rules

11/27/91

All holders of OLs or CPs for nuclear power reactors.

91-77 91-76

11/26/91

All holders of OLs or CPs for nuclear power reactors. All holders of OLs or CPs and vendors for nuclear power reactors. All holders of OLs or CPs for nuclear power reactors.

11/26/91

91-75

Static Head Corrections Mistakenly not Included in Pressure Transmitter Calibration Procedures Changes in Pressurizer Safety Valve Setpoints Before Installation Loss of Shutdown Cooling During Disassenmly of High Pressure Safety Injection System Check Valve Issuance of a Revision to the EPA Manual of Protective Action Guides and Protective Actions for Nuclear Incidents Training and Supervision of Individuals Supervised by an Authorized User

11/25/91

91-74

11/25/91

All holders of OLs or CPs for nuclear power reactors.

91-73

11/21/91

All holders of OLs or CPs for nuclear power reactors.

91-72

11/19/91

All holders of OLs or CPs for nuclear power reactors.

91-71

11/12/91

All NRC medical licensees.

OL =Operating License

CP =Construction Permit

UNITED STATES NUCLEAR RIGULATORY COMMISSION WASHINGTON. D.C. 205M5

PEM4LTV FOR PRIVATE USE, $30D

PID POSIAGI 6 PlS as

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PUSE.1SS AOUIqcAL

IN 88-92, Supplement I November 29, 1991 Page 2 of 3

The SFP level decreased as water passed through the seals and into the fuel transfer canal. Finally, cooling to the SFP was lost when the SFP circulating pump tripped on low level. The operators were not alerted to the loss of SFP water in the early part of the event, because the SFP low-level alarm had previously annunciated three days earlier indicating that the SFP level was lower than normal. however. it was still above technical specification (TS) requirements. At that time, the operators did not refill the SFP because of the need for adding makeup water to the reactor coolant system as cooldown progressed. By tho time the operators recognized that the SFP-gate seals had failed and they rai completed actions to repressurize the seals, the SFP level had dropped about 44 inches. This was about 16 inches below the TS required level of 23 feet above the top of the spent fuel. An NRC Augmented Inspection Team (AIT) was dispatched to WCGS to evaluate the event. The results of the inspection and further details of the event may be found in AIT Inspection Report 50-482/91-28. Discussion During the AIT site visit, the NRC identified two additional scenarios of safety significance that applied to WCGS. The first scenario involved possible failure of the SFP gate seals while performing preventive maintenance on the fuel transfer system with the fuel transfer tube open. The licensee did not have established administrative controls over the refueling cavity drains or over the reactor vessel-to-cavity seal for this activity. Under the above conditions, the licensee estimated that, without oper~tor intervention, the failure of the SFP gate seals could have allowed the level in the SFP to drop to about I foot above the top of the spent fuel assemblies. The level in the SFP would have dropped to about 9 feet above the spent fuel assemblies with the reactor vessel-to-cavity seal installed and the refueling cavity drains closed. The second scenario involved possible failure of the SFP gate seals during the periodic inspection or reconstitution of fuel assemblies performed in the SFP or the cask loading pool with the fuel transfer canal drained. At WCGS, the SFF is connected to both the fuel transfer canal and the cask loading pool through removable gates with pneumatic-type seals. The licensee indicated to the AIT that the gate between the SFP pool and the cask loading pool was seldom used. The licensee estimated that without operator intervention, the failure of the SFP gate seals could have allowed the level in the SFP and the cask loading pool to drop enough to uncover a fuel assembly held by the fuel handling bridge crane or in the fuO! inspection stand. To mitigate the ri5k of the first scenario, the licensee committed to perform the followirng whos!ever *,e fuel transfer tube is open and the refueling cavity and the fuel trt fer (.aI are drained: fI) hdve a backup gas supply in place to repressurize t-' bomt, seakb if service air is lost, (2) have a dedicated ooerator in place to install the backup gas supply and close the fuel transfer tube gate valve, and !3' have the reactor vessel-to-cavity seal in place and the refueing cavity drains hlanked or sealed.