05000277/LER-2003-002, Regarding Condition Prohibited by Technical Specifications Due to Inoperability of Standby Gas Treatment Filter Train
| ML032120559 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 07/17/2003 |
| From: | Stone J Exelon Nuclear |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CCN 03-14064 LER 03-002-00 | |
| Download: ML032120559 (7) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 2772003002R00 - NRC Website | |
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1o nSM Exelon Nuclear Telephone 717.456.7014 NuElear Peach Bottom Atomic Power Station www.exeloncorp.com 1848 Lay Road Delta, PA 17314-9032 1 OCFR 50.73 July 17, 2003 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 & 50-278
Subject:
Licensee Event Report (LER) 2-03-02 This LER reports a condition where the 'A' subsystem of the Standby Gas Treatment System was inoperable for greater than the time allowed by Technical Specifications. In accordance with NEI 99-04, the regulatory
commitment
contained in this correspondence is to restore compliance with the regulations. The specific methods that are planned to restore and maintain compliance are discussed in the LER. If you have any questions or require additional information, please do not hesitate to contact us.
Sincerely,
\\L~~~0A J hn A. Stone P nt Manager each Bottom Atomic Power Station JAS/djf/CR 160784 Attachment cc:
PSE&G, Financial Controls and Co-owner Affairs R. R. Janati, Commonwealth of Pennsylvania INPO Records Center H. J. Miller, US NRC, Administrator, Region I R. l. McLean, State of Maryland A. C. McMurtray, US NRC, Senior Resident Inspector CCN 03-14064
bcc:
J. L. Skolds - Cantera 1 W. Levis - KSA 3-N J. Benjamin - Cantera 1 J. A. Stone - PB, A4-1 S E. J. Eilola - PB, A4-IS G. L. Stathes - PB, SMB 3-2A P. J. Davison - PB, A3-2B J. P. Grimes - KSA 2-N G. L. Johnston - KSA 3-N R. A. Kankus - KSB 3-S A. J. Sherwood - PB-TC E. Anderson - PB, SMB-3 M. P. Gallagher - KSA 3-E D. P. Helker - KSA 3-E K. Langdon - PB, SMB 4-6 Commitment Coordinator - KSA 3-E Site Commitment Coordinator - PB, SMB-3 Correspondence Control Desk - KSA 1-N-1 DAC-KSA 1-N-1
I SUMMARY OF EXELON NUCLEAR COMMITMENTS The following table identifies commitments made in this document by Exelon Nuclear.
(Any other actions discussed in the submittal represent intended or planned actions by Exelon Nuclear. They are described to the NRC for the NRC's information and are not regulatory commitments.)
Commitment
Committed Date or "Outage" In accordance with NEI 99-04, the In accordance with the Corrective Action regulatory commitment contained in this Program correspondence is to restore compliance with the regulations. The specific methods that are planned to restore and maintain compliance are discussed in the LER.
MRC FORM 366 U.S. NUCLEARREGULATORY APPROVEDBY OMBNO.3150-0104 EXPRES 6-30-2001 (1-.2001)
COMMISSION Estimated burden per response to comply with this mandatory Information collectionrquest:
50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br />. Reported lessons teamed are Incorporated Into the licensing process and fed back to Industry. Send comments regarding burden estimate to the Records Management Branch KT(T-E6), U.S. NuclearRegulatoryCommission, Washington, DC20555-0001, orbyintemete-LICENSEEs EVENT REPORT (LER)s lmail to s1 nrc.nov, and to the Desk Officer. Office of Information and Regulator Affairs, (Seereversebrre~uirednumberofNEOB-1 20 (3150-0104) Ofice ofMngmnn Bud getWasin Wasiton, C2O803. If a (See reverse for ruired number of masuetoImps Inomto oleto os o ipa crefyvliaM oto digits/characters Tr each block) number, the NRC may not conductor sponsor, and a person I not required to respond to. the
~~~~~~~~~~~~~informnation collecton.
FACILITY NAME (1)
DOCKET NUMBER (2)
PAGE (3)
Peach Bottom Atomic Power Station (PBAPS), Unit 2 05000 277 1 OF 4
TITLE (4)
Condition Prohibited by Technical Specifications due to Inoperability of Standby Gas Treatment Filter Train EVENT DATE (5)
LER NUMBER (6)
REPORT DATE (7)
[
OTHER FACILIES INVOLVED (6) i r I
FACILITY NAME l DOCKET NUMBER SEQUENTIAL REV 1 MO DAYIY E [R YEAR YERI ERRIN MO DAY YEAR PBAPS 3 05000 278 FACILITY NAME DOCKET NUMBER 1 1 28 02 03 0 0 2 00 07 17 03 l
OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR : IChek all that apply) (11)
MODE (9) 1 0202201(b) l 20.2203(aX3XiI) l 50.73(aX2)(iiXB) l 50.73(aX2Ix )(A)
POWER 20.2201 (d) 20.2203(a)X4) 50.73(aX2Xiii) 50.73(aX2Xx)
LEVEL (10) 100 20.2203(a)(1)
_ 50.36(cX1XiXA)
_ 50.73(aX2)OvXA)
_ 73.71 (aX4)
_ 20.2203(a)(2Xi) 50.36(cX1XfiXA)
_ 50.73(aX2)(v)(A) 73.71(a)(5)
_ 20.2203(a)(2)(
__ 50.36(cX2)
_ 50.73(aX2)(v)(B)
Speciy In Abstract below or In 20.2203(a)(2Xiii) 50A6(aW3Xfl) 50.73(aX2)(v)(C)
(If more space is required, use addifional copies of NRC Form 3684) (17)
Unit Conditions Prior to the Event Units 2 and 3 were both in Mode 1 and operating at approximately 100% rated thermal power when the event occurred. At the time of the event, there were no other structures, systems or components that were out of service that contributed to this event. The Standby Gas Treatment (SBGT) (EIIS: BH) system is common to Units 2 and 3.
Description of the Event On 5/28/03 at approximately 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />, Main Control Room licensed operators were notified by maintenance technicians that approximately 4 inches of water (-170 gallons) was discovered in the bottom of the 'A' SBGT filter plenum (EIIS: DUCT) during the performance of an annual surveillance. An investigation was promptly initiated subsequent to the discovery. This investigation determined that the water was from the fire protection deluge system and was likely caused by previous maintenance / testing activities performed in either November 2002 or January 2003.
On 7/3/03, a causal factor investigation concluded that the water was most likely introduced into the 'A' SBGT filter (EIIS: FLT) plenum during the time period of 11/21-22/02.
Further evaluation determined that a condition prohibited by Technical Specifications existed since this water injection resulted in the 'A' SBGT subsystem being inoperable between the worst-case time period of 11/21/02 until 12/18/02 when the 'A' SBGT filter train was operated for a sufficient amount of time to ensure appropriate drying of the filter elements. The subsystem was considered to be inoperable during this time period due to the wetting of the filters within the filter plenum.
Technical Specification Limiting Condition for Operation (LCO) 3.6.4.3 requires that two SBGT subsystems be operable. If one SBGT subsystem is inoperable, there exists 7 days to restore the subsystem to an operable status. Because the subsystem was inoperable for greater than the Technical Specification Required Action times for Units 2 and 3, this issue is considered as a condition prohibited by Technical Specifications and is reportable pursuant to 10CFR 50.73(a) (2) (i) (B).
The discovery date of this condition is 5/28/03. The event date is 11/28/02 since the Technical Specification Required Action times for an inoperable subsystem were exceeded on 11/28/02.
The water in the 'A' SBGT filter plenum was promptly removed subsequent to discovery and charcoal and appropriate HEPA filters were replaced. The 'A' SBGT subsystem was restored to service by approximately 2200 hours0.0255 days <br />0.611 hours <br />0.00364 weeks <br />8.371e-4 months <br /> on 5/29/03.
Analysis of the Event
There were no actual safety consequences as a result of this condition. The 'B' SBGT subsystem remained operable throughout the worst-case time period that the
'A' SBGT subsystem was inoperable.
(If more space Is required, use additional copies of (If more space is required, use additional copies of NRC Fonm 366A) (17)
Cause of the Event, continued This test was performed by operations personnel (utility, non-licensed). The test requires disconnecting the deluge supply piping from the filter train prior to performing the deluge test. The investigation determined that it is possible that the deluge valves were opened prior to disconnecting the supply piping from the 'A' filter train. Further procedure review determined that these procedure steps inappropriately did not require concurrent verification by a second operator.
Corrective Actions
The water in the 'A' SBGT filter plenum was promptly removed subsequent to discovery and charcoal and appropriate HEPA filters were replaced. The 'A' SBGT subsystem was restored to an operable status by approximately 2200 hours0.0255 days <br />0.611 hours <br />0.00364 weeks <br />8.371e-4 months <br /> on 5/29/03.
The 'B' SBGT subsystem was evaluated and inspected to ensure that there was not a common water intrusion concern. This was completed on 5/30/03.
This event was shared with appropriate individuals involved with maintenance /
testing activities.
Surveillance tests for SBGT fire system deluge functionality will be revised to ensure appropriate verifications are performed when disconnecting the deluge piping and operating valves. The tests will also be reviewed for enhancements such as determining essential testing that is required or if other inspections are required after test performance.
Previous Similar Occurrences There were no previous events identified involving inoperability of the SBGT filter train due to fire system deluge water intrusion.