05000277/LER-2005-002, Re Recirculation Motor/Pump Modification Activities Unanalyzed for Postulated Seismic Conditions

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Re Recirculation Motor/Pump Modification Activities Unanalyzed for Postulated Seismic Conditions
ML053250368
Person / Time
Site: Peach Bottom  
(DPR-044, DPR-056)
Issue date: 11/09/2005
From: Grimes J
Exelon Generation Co, Exelon Nuclear
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LER 05-002-00
Download: ML053250368 (5)


LER-2005-002, Re Recirculation Motor/Pump Modification Activities Unanalyzed for Postulated Seismic Conditions
Event date:
Report date:
Reporting criterion: 10 CFR 50.73(a)(2)(i)

10 CFR 50.73(a)(2)(vii), Common Cause Inoperability

10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded

10 CFR 50.73(a)(2)(viii)(A)

10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition

10 CFR 50.73(a)(2)(viii)(B)

10 CFR 50.73(a)(2)(iii)

10 CFR 50.73(a)(2)(ix)(A)

10 CFR 50.73(a)(2)(iv)(A), System Actuation

10 CFR 50.73(a)(2)(x)

10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor

10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat

10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown

10 CFR 50.73(a)(2)(v), Loss of Safety Function

10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
2772005002R00 - NRC Website

text

Exek1ton SM Exelon Nuclear Telephone 717.456.7014 NEuclear Peach Bottom Atomic Power Station www.exeloncorp.com 1848 Lay Road Delta, PA 17314-9032 1 OCFR 50.73 November 9,2005 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 and 50-278

Subject:

Licensee Event Report (LER) 2-05-02 This LER reports an unanalyzed condition that occurred for brief periods of time during previous Refueling Outages in 2002 for Unit 2 and 2003 for Unit 3. The condition involved the seismic capability of the Recirculation System during modification activities.

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, Joseph P. Grimes Plant Manager Peach Bottom Atomic Power Station JPG/djf/CR 377756 Attachment cc:

PSE&G, Financial Controls and Co-owner Affairs R. R. Janati, Commonwealth of Pennsylvania INPO Records Center S. Collins, US NRC, Administrator, Region I R. l. McLean, State of Maryland US NRC, Senior Resident Inspector CCN 05-14100

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 31500104 EXPIRES: 0630/2007

,6-2004)

, the NRC maynot conduct or sponsor, and a person Is not required to respond to, the Information digits/characters for each block) collection.

3. PAGE Peach Bottom Atomic Power Station (PBAPS) Units 2 and 3 05000 277 1 OF 4
4. TITLE Recirculation Motor / Pump Modification Activities Unanalyzed for Postulated Seismic Conditions
5. EVENT DATE
6. LER NUMBER
7. REPORT DATE
8. OTHER FACILITIES INVOLVED SEQENIALRE FACILITY NAME DOCKET NUMBER MONTH DAY YEAR YEAR NUMBER REV MONTH DAY YEAR PBAPS Unit 3 05000278 FACILITY NAME DOCKET NUMBER 09 21 2005 05 02 0

11 6

2005 05000

9. OPERATING MODE 11.THIS REPORT IS SUBMI;TED PURSUANT TO THE REQUIREMENTS OF 10 CFR§: (Check all thatapply) o 20.2201(b) 0 20.2203(a)(3)(i)

El 50.73(a)(2)(i)(C) 0 50.73(a)(2)(vii) 5 Cl 20.2201(d) 0 20.2203(a)(3)(ii)

El 50.73(a)(2)(ii)(A) l 50.73(a)(2)(viii)(A) 0 20.2203(a)(1) 0 20.2203(a)(4)

ED 50.73(a)(2)(ii)(B) a 50.73(a)(2)(viii)(B) o 20.2203(a)(2)(i) 0 50.36(c)(1)(i)(A) 0 50.73(a)(2)(iii) 0 50.73(a)(2)(ix)(A)

10. POWER LEVEL 0 20.2203(a)(2)(ii) 0l 50.36(c)(1)(ii)(A)

D 50.73(a)(2)(iv)(A) al 50.73(a)(2)(x) o 20.2203(a)(2)(iii) 0 50.36(c)(2) al 50.73(a)(2)(v)(A) 0 73.71 (a)(4) o 20.2203(a)(2)(iv)

E 50.46(a)(3)(ii)

E 50.73(a)(2)(v)(B)

D 73.71(a)(5)

El 20.2203(a)(2)(v) 0 50.73(a)(2)(i)(A)

El 50.73(a)(2)(v)(C)

El OTHER o 20.2203(a)(2)(vi) 0 50.73(a)(2)(i)(B) 0 50.73(a)(2)(v)(D)

Specify In Abstract below or In (If more space is required, use additional copies of (If more space is required, use additional copies of NRC Form 366A) (17)The SDC function, as described in the Technical Specification bases for shutdown conditions, is not required to mitigate design basis events as described in the plant safety analysis. However, SDC is required for removing decay heat to ensure that the plant can be maintained in the cold shutdown condition.

Any two of the four Emergency Core Cooling Systems (ECCS) were required to be operable during plant shutdown conditions. If the Reactor cavity is flooded up and there are no Operations with the Potential to Drain the Reactor Vessel (OPDRVs), then ECCS is not required to be operable. Assuming that the LPCI subsystem associated with the Recirc loop being worked on was inoperable, three other ECCS susbsystems could be available for the ECCS function depending on the ECCS system work windows being performed during Recirc motor / pump work.

Additional analysis of this event is being performed in accordance with the Corrective Action Program. Any significant changes in the analyses for this event will be provided in a supplemental LER if necessary.

Cause of the Event

The cause of the event is due to less than adequate review of the interim configuration of the Recirc system associated with Recirc motor/ pump modification activities. Modification work performed on the 2B and 3A Recirc motor / pumps was based on a similar modification performed on the 2A Recirc motor / pump during the time period of 9/24/94 - 10/18/94. Engineering reviews performed in 1994, as well as subsequent Engineering reviews for other Recirc motor / pump replacements, did not consider the interim configuration with regards to seismic capability. Further causal evaluation is being performed in accordance with the Corrective Action program.

Corrective Actions

Engineering analyses will be performed to design an acceptable temporary piping support configuration for future Recirc motor / pump work.

Appropriate procedures for Recirc motor / pump replacement for Units 2 and 3 will be revised to ensure that the interim configuration of the Recirc system during replacement work is in an analyzed condition.

An extent of condition review is being performed in accordance with the Corrective Action Program. This review will assess other interim configurations of equipment that is required to be operable during maintenance conditions.

Previous Similar Occurrences There were no previous LERs identified involving unanalyzed conditions during modification activities.