05000293/LER-1917-013, Regarding Reportable Conditions Involving Standby Gas Treatment System and Secondary Containment Lnoperability Not Reported During the Previous Three Years

From kanterella
(Redirected from 05000293/LER-2017-013)
Jump to navigation Jump to search
Regarding Reportable Conditions Involving Standby Gas Treatment System and Secondary Containment Lnoperability Not Reported During the Previous Three Years
ML18033A326
Person / Time
Site: Pilgrim
Issue date: 01/25/2018
From: Miner P
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
2.18.001 LER 17-013-00
Download: ML18033A326 (7)


LER-1917-013, Regarding Reportable Conditions Involving Standby Gas Treatment System and Secondary Containment Lnoperability Not Reported During the Previous Three Years
Event date:
Report date:
Reporting criterion: 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)(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)(v), Loss of Safety Function

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

10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications

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

10 CFR 50.73(a)(2)(i)
2931917013R00 - NRC Website

text

~Entergx January 25, 2018 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 SUBJECT: Licensee Event Report 2017-013-00, Reportable Conditions Involving Standby Gas Treatment System and Secondary Containment lnoperability Not Reported During the Previous Three Years Pilgrim Nuclear Power Station Docket No. 50-293 Renewed License No. DPR-35 LETTER NUMBER: 2.18.001

Dear Sir or Madam:

The enclosed Licensee Event Report 2017-013-0.0, Reportable Conditions Involving Standby Gas Treatment System and Secondary Containment lnoperability Not Reported During the Previous Three Years, is submitted in accordance with Title 10 Code of Federal Regulations 50. 73.

If you have any questions or require additional information, please contact me at (508) 830-7127.

There are no regulatory commitments contained in this letter.

Peter J.

ner Acting Manager, Regulatory Assurance PJM/sc Attachment: Licensee Event Report 2017-013-00, Reportable Conditions Involving Standby Gas Treatment System and Secondary Containment lnoperability Not Reported During the Previous Three Years (4 pages)

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station cc:

Mr. David C. Lew Acting Regional Administrator, Region I U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd., Suite 100 King of Prussia, PA 19406-2713 Mr. John Lamb, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8C2A Washington, DC 20555 NRG Senior Resident Inspector Pilgrim Nuclear Power Station Letter No. 2.18.001 Page 2 of 2

Attachment Letter Number 2.18.001 Licensee Event Report 2017-013-00, Reportable Conditions Involving Standby Gas Treatment System and Secondary Containment lnoperability Not Reported During the Previous Three Years (4 Pages)

BNRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY 0MB: NO. 3150-0104 EXPIRES: 03/31/2020 (04-2017) htt12://www.nrc.gov/reading-rm/doc-collections/nur§9s/staff/sr1022/r3/)

the NRG may not conduct or sponsor, and a person is not required to respond to, the information collection.

.PAGE Pilgrim Nuclear Power Station 05000 293 1 OF4

4. TITLE Reportable Conditions Involving Standby Gas Treatment System and Secondary Containment lnoperability Not Reported During the Previous Three Years
5. EVENT DATE
6. LER NUMBER
7. REPORT DATE
8. OTHER FACILITIES INVOLVED SEQUENTIAL FACILITY NAME DOCKET NUMBER MONTH DAY YEAR YEAR REV MONTH DAY YEAR N/A NUMBER NO.

05000 N/A 11 26 2017 2017

- 013
- 00 01 25 2018 FACILITY NAME DOCKET NUMBER N/A 05000 N/A
9. OPERA TING MODE
11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)

N D 20.2201(b)

D 20.2203(a)(3)(i)

D 50.73(a)(2)(ii)(A)

D 50.73(a)(2)(viii)(A)

D 20.2201(d)

D 20.2203(a)(3)(ii)

D 50.73(a)(2)(ii)(B)

D 50.73(a)(2)(viii)(B)

D 20.2203(a)(1)

D 20.2203(a)(4)

D so.73(a)(2)(iii)

D 50.73(a)(2)(ix)(A)

D 20.2203(a)(2)(i)*

D 50.36(c)(1 )(i)(A)

D 50.73(a)(2)(iv)(A)

D 50.73(a)(2)(x)

10. POWER LEVEL D 20.2203(a)(2)(ii)

D 50.36(c)(1)(ii)(A)

D 50.73(a)(2)(v)(A)

D 73.71(a)(4)

D 20.2203(a)(2)(iii)

D so.36(c)(2)

D 50.73(a)(2)(v)(B)

D 73.71(a)(5) 100 D 20.2203(a)(2)(iv)

D 50.46(a)(3)(ii)

~ 50.73(a)(2)(v)(C)

D 73.77(a)(1)

D 20.2203(a)(2)(v)

D 50.73(a)(2)(i)(A)

~ 50.73(a)(2)(v)(D)

D 73.77(a)(2)(i)

D 20.2203(a)(2)(vi)

D 50.73(a)(2)(i)(B)

D 50.73(a)(2)(vii)

D 73.77(a)(2)(ii)

D 50.73(a)(2)(i)(C) 0 OTHER Specify in Abstract below or in NRG Form 366A

12. LICENSEE CONTACT FOR THIS LER LICENSEE CONTACT IILEPHONE NUMBER (Include Area Code}

IMr. Peter J. Miner -Acting, Regulatory Assurance Manager

~08-830-7127

, CAUSE SYSTEM COMPONENT MANU-REPORTABLE

CAUSE

SYSTEM COMPONENT MANU-REPORTABLE FACTURER TOEPIX FACTURER TO EPIX X

BH y

14. SUPPLEMENTAL REPORT EXPECTED
15. EXPECTED MONTH DAY YEAR igj YES (If yes, complete 15. EXPECTED SUBMISSION DATE)

D NO SUBMISSION 04 18 18 DATE ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)

On November 26, 2017, with the Reactor in the Run Mode at 100 percent power, while reviewing a procedure to be performed during normal scheduled testing it was determined that the test as written would cause both trains of Standby Gas Treat_ment System (SGTS) to be made inoperable during the test. This also made secondary containment system (SCS) inoperable. This LER is submitted to acknowledge that Pilgrim Nuclear Power Station missed providing Event Notifications and LERs for past occurrences. With both trains of SGTS and SCS inoperable while in Run, this event is reportable in accordance with Title 10 Code of Federal Regulations 50.73(a)(2)(v)(C) and 50.73(a)(2)(v)(D) as conditions that could have prevented the fulfillment of the safety function of a structure or system needed to control the release of radioactive material and mitigate the consequences of an accident. This has been determined to be a reportable condition that has not been reported during the past three years involving SGTS and secondary containment inoperability. The reportable conditions have occurred several times within the past three years during scheduled testing of SGTS.

This event had no impact on the health and/or safety of the public.

BACKGROUND SEQUENTIAL NUMBER

- 013 REV NO.
- 00 The Pilgrim Nuclear Power Station (PNPS) Standby Gas Treatment System (SGTS) is part of the Secondary Containment System (SCS) and addresses the SGTS air filtration trains, including the ducting, the exhaust fans, the dampers, and the various filtration media. SCS is designed, in conjunction with other engineered safeguards and nuclear safety systems, to limit the release of radioactive material during normal plant operations within the limits of Title 10 Code of Federal Regulations ( 10 CFR) Part 20 and to limit the release of radioactive material so that off-site dose from a postulated design basis accident will be below the guideline values in 10 CFR Part 100.

The SGTS discharges processed gases to the Main Stack via underground piping. The Main Stack provides an elevated release point for the processed gases. The mission time for tre SCS is 30 days.

PNPS Technical Specification (TS) 3/4. 7.B.1 governs the operability requirements of the SGTS. The specification requires that with certain exceptions, the SGTS shall be operable during periods that include reactor power operation (RUN, STARTUP, and HOT SHUTDOWN modes), during movement of irradiated fuel assemblies in secondary containment, during movement of new fuel over the spent fuel pool, during CORE ALTERATIONS, and during operations with a potential for draining the reactor vessel (OPDRVs).

PNPS TS 3.7.C.1 requires secondary containment shall be OPERABLE when in the RUN, STARTUP, and HOT SHUTDOWN modes, <:luring movement of recently irradiated fuel assemblies in the secondary containment, and during OPDRVs.

There are two principal accidents for which credit is taken for secondary containment operability. These are a loss of coolant accident and a fuel handling accident involving "recently irradiated fuel." The SCS performs no active function in response to each of these limiting events; however, its leak tightness is required to ensure that the release of radioactive materials from primary containment is restricted to those leakage paths and associated leakage rates assumed in the accident analysis and that fission products entrapped within the SCS will be treated by the SGTS prior to discharge to the environment.

EVENT DESCRIPTION

On November 26, 2017, with the Reactor in the Run Mode at 100 percent power, while reviewing procedures to be performed during a normal scheduled work week it was determined that if the procedure was performed as written would cause both trains of SGTS and SCS to be made inoperable. A follow up review determined that procedures have been performed several times within the past three years that caused both trains of SGTS and SCS to be made inoperable during scheduled testing of SGTS.

Page 2 of 4 (04-2017)

U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY 0MB: NO. 3150-0104 EXPIRES: 3/31/2020

/"'"'""

=

i

\\

I" LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET (See NUREG-1022, R.3 for instruction and guidance for completing this form http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1022/r30

, the NRG may not conduct or sponsor, and a person is not required to respond to, the information collection.

1. FACILITYNAME
2. DOCKET NUMBER
3. LER NUMBER Pilgrim Nuclear Power Station 05000- 293 YEAR 2017 SEQUENTIAL NUMBER
- 013 REV NO.
- 00 This has been determined to be a reportable condition that has not been reported during the past three years involving the SGTS and SCS inoperability.

With both trains of SGTS and SCS inoperable in the Run mode this event is reportable per the requirements of 10 CFR 50. 73(a)(2)(v)(C) and* 1 O CFR 50. 73(a)(2)(v)(D), any event that could have prevented the fulfillment of the safety functions to control the release of radioactive material and mitigate the consequences of an accident.

A Root Cause Evaluation is underway and additional information will be provided at the conclusion of this ongoing investigation.

CAUSE OF THE EVENT

The direct cause of this event is still under investigation and will be provided in a supplement to this LER.

CORRECTIVE ACTIONS

~n interim corrective action to place the identified procedures on administrative hold has been implemented.

SAFETY CONSEQUENCES

rThere were no consequences to the safety of the general public, nuclear safety, industrial safety, or radiological safety due to this event. The actual consequences were a loss of safety function for SCS and SGTS while performing the surveillance.

There was no adverse impact on the public health or safety.

(

REPORT ABILITY With both trains of SGTS and SCS inoperable in the Run mode, this event is reportable per the requirements of 10 CFR 50.73(a)(2)(v)(C) and 10 CFR 50.73(a)(2)(v)(D), any event or condition that could have prevented the

'"ulfillment of the safety functions to control the release of radioactive material and mitigate the consequences of an accident.

Page 3 of 4 (04-2017)

U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY 0MB: NO. 3150-0104 EXPIRES: 3/31/2020

/""

R

..... /

LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET (See NUREG-1022, R.3 for instruction and guidance for completing this form http://www.nrc.gov/readinq-rm/doc-collections/nuregs/staff/sr1022/r3Q

, the NRG may not conduct or sponsor, and a perlion is not required to respond to, the information collection.

3. LERNUMBER Pilgrim Nuclear Power Station 05000- 293 YEAR 2017 PREVIOUS EVENTS SEQUENTIAL NUMBER
- 013 REV NO.
- 00 A review was conducted of PNPS LERs issued in the past five (5) years. The review focused on LERs that involved similar events where the SGTS function was lost. This review identified similar events documented in:
1) LER 2017-004-00 "Secondary Containment Testing Led to Loss of Safety Function"
2) LER 2012-003-00 "Both Trains of Standby Gas Treatment System Inoperable" REFERENCES CR-PNP-2017-02900 CR-PNP-2017-11714 Page 4 of 4