05000293/LER-2010-002, For Pilgrim Nuclear Power Station, Regarding Standby Gas Treatment Declared Inoperable After Discovery of Open Demister Door

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For Pilgrim Nuclear Power Station, Regarding Standby Gas Treatment Declared Inoperable After Discovery of Open Demister Door
ML101550440
Person / Time
Site: Pilgrim
Issue date: 05/20/2010
From: Bronson K
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
2.10.026 LER 10-002-00
Download: ML101550440 (5)


LER-2010-002, For Pilgrim Nuclear Power Station, Regarding Standby Gas Treatment Declared Inoperable After Discovery of Open Demister Door
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
2932010002R00 - NRC Website

text

"~Enterg Entergy Nuclear Operations, Inc.

Pilgrim Nuctear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Kevin H. Bronson Site Vice Presiden~t May 20, 2010 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

)/

3

SUBJECT:

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Docket No.: 50-293 Ucense No.: DPR-35 Ucensee Event Report 2010-002-00 LETTER NUMBER: 2.10.026

Dear Sir or Madam:

The enclosed Licensee EventReqpo'rt (LER) 2010-002-00, NStandby Gas Treatment Declared Inoperable After Discovery ofLOpen Demist*r Door", is submitted in accordancewith. 10 CFR 50.73.

This letter contains no commitments.

Please do not hesitate to contact Mr. Joseph R. Lynch, (508) 830-8403, if there are any questions regarding this submittal.

Kevin H. Bronson WG./dl Enclosure: LER 2010-002-00, Standby Gas Treatment Declared Inoperable After Discovery of Open Demister Door", (4 pages) cc:

Mr. James S. Kim, Project Manager Plant Licensing Branch 1-1 Division of Operator Reactor Ucensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North O,8C2.

11.555.Rockville Pike

Rockville, MD 20852 Mr. Samuel J. Collins Regional Administrator, Region 1 U.S. Nuclear Regulator Commission 475 Allendale Road King of Prussia, PA 19406 Senior Resident Inspector Pilgrim Nuclear Power Station INPO Records.

700,Galleria Parkway Atlanta, GA 30399-5957-

NRC Form 366 U.S. NUCLEAR REGULATORY COMMISSION Approved by OMB: No. 3150-0104 Expires: 08/31/2010 (9-2007)

Estimated burden per response to comply with this mandatory information EEVENT REPORT (LER) collection request: 80 hrs. Reported lessons learned are incorporated into the LICENSEE Elicensing process and fed back to industry. Send comments regarding burden estimate to the Records and FOIA/Privacy Service Branch (T-5 F52). U.S.

Nuclear Regulatory Commission, Washington, DC 20555-0001, or by internet e-mail to infocollects@nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, (3150-0104), Office of Management and Budget, Washington, DC 20503.

If a means used to impose and information collection does not display a currently valid control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

1. FACILITY NAME I 2. DOCKET NUMBER
3. PAGE PILGRIM NUCLEAR POWER STATION 05000-293 1 of 4
4. TITLE STANDBY GAS TREATMENT DECLARED INOPERABLE AFTER DISCOVERY OF OPEN DEMISTER DOOR
5. EVENT DATE
6. LER NUMBER
7. REPORT DATE
8. OTHER FACILITIES INVOLVED SEQUENTIAL NUMBER REVISION FACILITY NAME DOCKET MONTH DAY YEAR YEAR NUMBER MONTH DAY YEAR N/A NUMBER 05000 II FACILITY NAME DOCKET 03 25 2010 2010 002 00 5

20 2010 N/A NUMBER I

L_

1 05000

9. OPERATING MODE
11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR: (Check one or more) 20.2201 (b) 22.2203(a)(3)(i) 50.73(a)(2)(i)(C) 50.73(a)(2)(vii)

N 22.2202(d) 20.2203(a)(3)(ii) 50.73(a)(2)(ii)(A) 50.73(a)(2)(viii)(A) 20.2203(a)(1) 20.2203(a)(4) 50.73(a)(2)(ii)(B) 50.73(a)(2)(viii)(B) 20.2203(a)(2)(i) 50.36(3)(1 )(i)(A) 50.73(a)(2)(iii) 50.73(a)(2)(ix)(A) 20.2203(a)(2)(ii) 50.36(3)(1)(ii)(A) 50.73(a)(2)(iv)(A) 50.73(a)(2)(x)

10. Power Level 20.2203(a)(2)(iii) 50.36(c)(2) 50.73(a)(2)(v)(A) 73.71(a)(4) 20.2203(a)(2)(iv) 50.46(a)(3)(ii)

I 50.73(a)(2)(v)(B) 73.71 (a)(5) 100 20.2203(a)(2)(v) 50.73(a)(2)(i)(A) x 50.73(a)(2)(v)(C)

OTHER 20.2203(a)(2)(vi) 50.73(a)(2)(i)(B) x 50.73(a)(2)(v)(D)

Specify in Abstract below

__5_73__a_2_or in system is not fully made operable within 7 days, the specification requires the initiation of a reactor shutdown and cold shutdown within the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. If both trains are inoperable, the specification requires the initiation of a reactor shutdown with cold shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Licensed operators monitor drywell-torus differential pressure, and the SGTS is manually operated as necessary to.maintain the differential pressure required by Technical Specifications.

EVENT DESCRIPTION

On March 25, 2010, at 12:12 hours Operations entered into a Limiting Condition of Operation (LCO) for SBGT instrument calibration and functional test for Train 'B' in accordance with Pilgrim Nuclear Power Station (PNPS)

Procedure 8.M.3-18, Attachment 2. The allowed out-of-service time (AOT) in accordance with PNPS TS 3.7.B.1.c is 7 days, with one train in verified operable condition. Accordingly, the procedural steps of PNPS 8.C.34 were performed to verify the required systems were operable for the Train 'B' AOT and Train 'A' was aligned to provide the safety-related function during the surveillance. 8.M.3-18, Attachment 2 Steps 12-15 were completed and demister door on Train 'B' was opened to perform the required surveillance. At 16:07 hours Instrumentation and Control Technicians reported to the Control Room the completion of the surveillance in accordance with PNPS 8.M.3-18, Attachment 2. At 17:10 hours SGTS Train 'A' was placed in service for torus purging in accordance with PNPS Procedure 2.2.70. At 17:45 hours SGTS 'A' was secured and placed in its normal standby status.

At 22:55 hours, a demister door on Train 'B' was discovered open. The door was immediately closed upon discovery. The door was opened during performance of the scheduled surveillance and subsequently not closed at the completion of surveillance. With this door open, the 'B' Train of SGTS was inoperable. Because of the physical configuration of the SBGT system, it could not be immediately verified that the 'A' SBGT Train would be capable of performing its safety-related function. There exists a probability that 'A' SGTS Train could draw suction through the open demister door of the 'B' SGTS Train and a normally open crosstie between the Trains

'A' and 'B' without providing the required full suction flow from the secondary containment -a safety function called for under the TS 3.7.B. 1. Condition Report PNP-2010-1079 was written. The LCO (LCO ACT 1-10-0063) was revised to reflect a new initiation time (12:12 hours) due to the fact that the 'B' Train SGTS demister door was open. The door was closed and the LCO was exited at 22:55 hours, and both 'A' and 'B' Trains of SBGT were declared operable.

CAUSE

The cause of this event was identified as a human performance error, failure to verify the closure of the demister door prior to completion of the surveillance in accordance with the Procedure 8.M.3-18, Attachment 2.

CORRECTIVE ACTION

Immediate corrective actions taken included: closing the demister door, coaching the affected personnel who performed the surveillance, and enhancing procedural steps to provide clarification in the surveillance procedure.

The longer term corrective action taken to preclude recurrence includes: a case study to review expectations for verification practices and implementation of standardized approach for verification practices during the performance of surveillances.

These corrective actions are tracked by the site Corrective Action Program (CAP) under CR-PNP-2010-1079 EXTENT OF PROBLEM The SGTS surveillance that was performed is a frequently performed surveillance and the existing procedure provides steps to conduct the required surveillance. The open demister door is a unique condition due to a 14

human error; it does not extend to equipment or common cause failure. Thus the extent of the problem is related to this single event. An Extent of Condition and Extent of Cause was performed as part of the Root Cause Evaluation issued for this event.

SAFETY CONSEQUENCES

The condition-posed no threat to public health and safety.

The event occurred during normal power operation while at 100% power with the mode switch in the RUN position. The reactor vessel pressure was approximately 1030 psig with reactor water temperature at saturation temperature for that pressure.

During the time the demister door on Train 'B' was open, both trains were aligned to provide a suction path to maintain secondary containment integrity in the event a design basis event were to occur. However with the demister door open on Train 'B', there was a potential that the system could not have drawn the required vacuum to achieve -0.25 inches of water pressure in the secondary containment. The Train 'B' open demister door condition lasted for approximately six hours, which impacted the operability of the system to fulfill its normal safety function to draw the required vacuum on the secondary containment. During this event there were no other adverse safety conditions impacting secondary containment. Thus, the risk presented by this condition was negligible because of the very short duration of the demister door open event and that there were no other adverse conditions present at the time.

REPORTABILITY

This reportwas submitted in accordance with 10 CFR 50.73(a)(2)(v)(C) and (D) for an event or condition that could have prevented fulfillment of a safety function.

SIMILARITY TO PREVIOUS EVENTS A review was conducted of Pilgrim Station LERs issued since 2001. The review focused on LERs that involved a similar event or condition involving the SGTS or similar cause. The review identified no similar event or condition.

ENERGY INDUSTRY IDENTIFICATION SYSTEM (EIIS) CODES The EIIS codes for this report are as follows:

COMPONENTS CODES Demister Door DR SYSTEMS Standby Gas Treatment System (SGTS)

BH