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{{Adams
#REDIRECT [[05000293/LER-2016-004]]
| number = ML16202A053
| issue date = 07/11/2016
| title = LER 16-004-00 for Pilgrim Nuclear Power Station Regarding Salt Service Water Pump B Past Operability - Operation or Condition Prohibited by Technical Specifications
| author name = Perkins E P
| author affiliation = Entergy Nuclear Operations, Inc
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000293
| license number = DPR-035
| contact person =
| document report number = LER 16-004-00
| document type = Letter, Licensee Event Report (LER)
| page count = 8
}}
 
=Text=
{{#Wiki_filter:* July 11, 2016 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 2016-004-00, Salt Service Water Pump B Past Operability -Operation or Condition Prohibited by Technical Specifications Pilgrim Nuclear Power Station Docket No. 50-293 Renewed License No. DPR-35 LETTER NUMBER: 2.16.038
 
==Dear Sir or Madam:==
The enclosed Licensee Event Report 2016-004-00, Salt Service Water Pump B Past Operability -Operation or Condition Prohibited by Technical Specifications, is submitted in accordance with 10 Code of Federal Regulation 50. 73. If you have any questions or require additional information, contact me at (508) 830-8323. There are no regulatory commitments contained in this letter. Sincerely, Everett P. Perkins, Jr.-. Manager, Regulatory Assurance f EPP/fxm
 
==Attachment:==
Licensee Event Report 2016-004-00, Salt Service Water Pump B Past Operability -Operation or Condition Prohibited by Technical Specifications Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station cc: Mr. Daniel H. Dorman Regional Administrator, Region I U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd., Suite 100 King of Prussia, PA 19406-2713 Ms. Booma Venkataraman, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8C2A Washington, DC 20555 NRC Senior Resident Inspector Pilgrim Nuclear Power Station Letter No. 2.16.038 Page 2 of 2 Attachment Letter Number 2.16.038 Licensee Event Report 2016-004-00 Salt Service Water Pump B Past Operability-Operation or Condition Prohibited by Technical Specifications (5 Pages)
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2018 (11-2015) Estimated burden per response to comply with this mandatory collection request: 80 hours. ... '%.... Reported lessons learned are incorporated into the licensing process and fed back to industry. '$ Send comments regarding burden estimate to the FOIA, Privacy and Information Collections 'l LICENSEE EVENT REPORT (LER) Branch (T-5 F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by ....... internet e-mail to lnfocollects.Resource@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 an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection. 1. FACILITY NAME 2. DOCKET NUMBER 3. PAGE Pilgrim Nuclear Power Station 05000293 1 OF5 \ 4. TITLE Salt Service Water Pump B Past Operability-Operation or Condition Prohibited by Technical Specifications 5. EVENT DATE 6. LER NUMBER 7. REPORT DATE 8. OTHER FACILITIES INVOLVED I SEQUENTIAL I REV FACILITY NAME DOCKET NUMBER MONTH DAY YEAR YEAR NUMBER NO. MONTH DAY YEAR N/A N/A FACILITY NAME DOCKET NUMBER 05 12 2016 2016-004 -00 07 11 2016 N/A N/A 9. OPERATING MODE 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR : (Check all that aoo/vJ 0 20.2201 (b) D 20.2203(a)(3)(i) 0 50.73(a)(2)(ii)(A) 0 50.73(a)(2)(viii)(A) ; D 20.2201 (d) D 20.2203(a)(3)(ii) 0 50.73(a)(2)(ii)(B) 0 50.73(a)(2)(viii)(B) N D 20.2203(a)(1) D 20.2203(a)(4) D 5o.73(a)(2)(iii) D 50. 73(a)(2)(ix)(A) D 20.2203(a)(2)(i) 0 50.36(c)(1)(i)(A) 0 50.73(a)(2)(iv)(A) D 50.73(a)(2)(x) 10. POWER LEVEL D 20.2203(a)(2)(ii) 0 50.36(c)(1)(ii)(A) 0 50.73(a)(2)(v)(A) D 13.11 (a)(4) D 20.2203(a)(2)(iii) D so.36(c)(2) 0 50.73(a)(2)(v)(B) D 13.11(a)(s) D 20.2203(a)(2)(iv) D so.46(a)(3)(ii) 0 50.73(a)(2)(v)(C) D 13.77(a)(1) 100 D 20.2203(a)(2)(v) 0 50.73(a)(2)(i)(A) 0 50.73(a)(2)(v)(D) D 73.77(a)(2)(i) D 20.2203(a)(2)(vi) IBj 50.73(a)(2)(i)(B) 0 50.73(a)(2)(vii) D 13.11(a)(2)(ii) 0 50.73(a)(2)(i)(C) D OTHER Specify in Abstract below or in NRC Form 366A 12. LICENSEE CONTACT FOR THIS LER LICENSEE CONTACT TELEPHONE NUMBER (Include Area Code) Mr. Everett P. Perkins, Jr. -Regulatory Assurance Manager 508-830-8323 13. COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT MANU-REPORTABLE ., MANU-REPORTABLE CAUSE SYSTEM COMPONENT FACTURER TOEPIX CAUSE SYSTEM COMPONENT FACTURER TOEPIX D ED 59 E059 y (,; 14. SUPPLEMENTAL REPORT EXPECTED 15. EXPECTED MONTH DAY YEAR [KJ YES (If yes, complete 15. EXPECTED SUBMISSION DATE) D NO SUBMISSION DATE 09 09 16 ABSTRACT On May 10, 2016 with the reactor at 100% power and the mode switch in RUN; a condition report was written to evaluate past operability of the Salt Service Water (SSW) Pump P-2088 power supply breaker overload relay based on thermography results obtained on October 25, 2013. A similar high temperature condition was identified during the February 29, 2016 thermography surveillance that resulted in declaring the pump inoperable on March 4, 2016 and completing the replacement of the overload relay on March 5, 2016. SSW Pump P-2088 is currently operable. The past operability review covers the period of time between the 2013 thermography surveillance and March 5, 2016 when the pump breaker overload relay was replaced. Based on the lack of detailed information in the 2013 surveillance, past operability of the pump could not be assured. A review of out-of-service time for SSW Pumps P208A and P208C indicates that one instance occurred where less than two SSW pumps were Operable to feed the SSW A L.::oop Header for a period in excess of SSW Technical Specification requirements. This represents a reportable condition. The cause of the overload relay high temperature readings was evaluated and determined to be a high resistance connection on the overload relay heater assembly. Inadequate predictive maintenance monitoring was identified as the apparent cause for not periodically assessing breaker status or replacing the breaker overload relay prior to March 5, 2016. Testing the overload relay that was removed from service is planned. This testing is expected to be completed by*
* August 15, 2016. Results will be reported in a supplement to this report. There was no impact to public health and safety. NRC FORM 366A(11-2015)
Page 2 of 5 NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2018 (11-2015) Estimated burden per response to comply with this mandatory collection request 80 hours. Reported ,, ...... lessons learned are incorporated into the licensing process and fed back to industry. Send commenls regarding burden estimate to the FOIA, Privacy and Information Collections Branch (T-5 i LICENSEE EVENT REPORT (LER) F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by internet e-mail to I .,, *** lnfocollects.Resource@nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, CONTINUATION SHEET NEOB-10202, (3150-0104), Office of Management and Budget, Washington, DC 20503. If a means used to impose an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection. 1. FACILITY NAME 2. DOCKET NUMBER 3. LER NUMBER YEAR SEQUENTIAL REV NUMBER NO. Pilgrim Nuclear Power Station 05000293 2016 004 00 NARRATIVE BACKGROUND The safety objective of the SSW system is to provide a heat sink for the Reactor Building Closed Cooling Water (RBCCW) system under normal, transient, and accident conditions. The SSW system has five SSW pumps and is designed with sufficient redundancy so that no single active system component failure can prevent the system from achieving the safety objective. The system is designed to continuously provide a supply of cooling water to the secondary side of the RBCCW heat exchangers adequate to meet the requirements of the RBCCW system under all conditions. The RBCCW system provides the necessary cooling requirements for the residual heat removal (RHR) system and ultimately the reactor and primary containment. The SSW pumps are separated into two loops. Two pumps are connected to each loop and the fifth pump can feed either loop. Initiation of standby AC power following loss of the preferred AC power source will automatically start at least one pump in each loop during normal conditions. Following a Loss of Coolant Accident (LOCA) and loss-of-offsite power, one pump will start in each loop because of diesel load limitations. Additional pumps are started manually by the operator as additional cooling loads are established and diesel capacity is available. 1 Technical Specification (TS) Limiting Condition For Operation (LCO) 3.5.B.4 requires two SSW loops to be operable whenever fuel is in the vessel and reactor coolant temperature is greater than 212 degrees F. Operability of each loop requires at least two SSW pumps to be operable in the loop along with the associated controls to demonstrate SSW loop operability. / Thermography is part of the SSW pump breaker predictive maintenance program. SSW system TS surveillances do not require use of thermography to determine system or pump operability. The site thermography procedure requires reports to be written if high temperature conditions exist. EVENT DESCRIPTION On May 10, 2016, Condition Report CR-PNP-2016-3308 was written to perform a past operability review on the SSW Pump P-2088 *power supply breaker overload relay based on thermography surveillance results obtained on October 25, 2013. The 2013 thermography surveillance indicated the breaker was in the Level II -Warning Range (a temperature rise of greater than 25 degrees F and less than 50 degrees F for 480 Volt equipment). Procedure instruction for 480 Volt breakers is to take action recorllmended by the Preventative Maintenance Team. Condition Report CR-PNP-2013-7196 was issued and the pump was identified as operable. No follow-up maintenance work was performed to address the potential high temperature condition. Work Order (WO) 366187 to replace the overload relay was created on October 28, 2013 but not worked until after the SSW pump was declared inoperable in March 2016. SSW Pump P2088 TS operability surveillances during the 2013 to 2016 time frame were performed with acceptable results. No actions were taken or believed necessary to replace the overload relay to demonstrate TS operability. NRC FORM 366A(11-2015)
NRC FORM 366 (11-2015) U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER) CONTINUATION SHEET Page 3 of 5 APPROVED BYOMB: NO. 3150-0104 EXPIRES: 10/31/2018 Estimated burden per response to comply with this mandatory collection request: 80 hours. Reported lessons learned are incorporated into the licensing process and fed back to industry. Send comments regarding burden estimate to the FOIA, Privacy and Information Collections Branch (T-5 F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by internet e-mail to lnfocollects.Resource@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 an information collection does not display a currently valid OMB control number, the NRG may not conduct or sponsor, and a person is not required to respond to, the information collection. 1. FACILITY NAME 2. DOCKET NUMBER 3. LER NUMBER YEAR Pilgrim Nuclear Power Station 05000293 2016 NARRATIVE SEQUENTIAL NUMBER 004 REV NO. 00 The February 29, 2016 thermography surveillance indicated high temperature in the breaker overload relay area. The high temperature readings met the procedure criteria for Level II -Warning and Preventative Maintenance Team action recommendation. A subsequent review and follow-up evaluation by engineering resulted in a delayed declaration of SSW Pump P208B inoperability on March 4, 2016 due to the high temperature readings, pump current readings, and conservative consideration for potential low voltage accident conditions. The pump overload relay was replaced via WO 366187 on March 5, 2016 and the SSW pump was restored to Operable status. TS LCO Action Statement (AS) 3.5.B.4.A allows continued reactor operation with one inoperable SSW subsystem (loop) provided the SSW subsystem is restored to OPERABLE status within 72 hours (allowed restoration time). If the SSW subsystem is not restored to OPERABLE status within 72 hours, the TS LCO AS requires the reactor to be in Cold Shutdown within 24 hours (shutdown completion time). Based on the assumption that SSW Pump P-208B was inoperable from the time that the high temperature was noted on October 25, 2013 until the pump was declared operable on March 5, 2016, a review of all the other SSW pumps operability status was performed. One instance of the SSW subsystem (loop) A being inoperable for a time period that exceeded the combined allowed restoration time and shutdown completion time of 96 hours was identified. This occurred from 1947 hours on November 8, 2015 to 1644 hours on November 18, 2015 for a total of 236.95 hours. Continuing to operate for a duration exceeding 96 hours with the SSW loop A inoperable resulted in operation prohibited by the TS. CAUSE OF THE EVENT The cause of the SSW Pump P-208B overload relay high temperature readings was evaluated and determined to be a high resistance connection on the overload relay heater assembly. Inadequate predictive maintenance monitoring was identified as the apparent cause for not periodically assessing the breaker status and replacing the breaker overload relay prior to March 5, 2016. Review of the work orders that performed thermography on the SSW pumps found that the SSW Pump P-208B breaker (52M-1544) had not had a thermography image taken for almost three years, even though the required periodicity for thermography performance on the breaker is every six months. Procedure 3.M.3-60 "Infrared Thermography" allows not performing the thermography on a component if the component is not running. The Work Order (WO) 366187 to replace the overload relay was created on October 28, 2013 but not worked until after the SSW pump was declared inoperable in March 2016. WO 366187 was given a work priority of 30. The guidance for scheduling a WO with work priority of 30 is to -Schedule at next available system I component outage within the Cycle Plan or based on Modification scheduled. Contrary to the scheduling guidance, the WO was not worked until after SSW Pump P-208B was declared inoperable. NRG FORM 366A (11-2015)
Page 4 of 5 NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2018 (11-2015) Estimated burden per response to comply with this mandatory collection request: 80 hours. Reported lessons learned are incorporated into the licensing process and fed back to industry. Send i comments regarding burden estimate to the FOIA, Privacy and Information Collections Branch (T-5 .. F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by internet e-mail to ' LICENSEE EVENT REPORT (LER) lnfocollects.Resource@nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, CONTINUATION SHEET NEOB-10202, (3150-0104), Office of Management and Budget, Washington, DC 20503. If a means used to impose an information collection does not display a currently valid OMB control number, tlhe NRG may not conduct or sponsor, and a person is not required to respond to, the information collection. 1. FACILITY NAME 2. DOCKET NUMBER 3. LER NUMBER YEAR SEQUENTIAL REV NUMBER NO. Pilgrim Nuclear Power Station 05000293 2016 004 00 NARRATIVE CORRECTIVE ACTIONS Corrective action was taken to replace the installed breaker overload relay to restore SSW Pump B Operability. The breaker overload relay installed during the 2013 to 2016 timeframe was an Eaton Corp (formerly Cutler-Hammer; EllS Code= T020), Type A, Cat Number-FH93 relay (EllS Code= 59). Additional corrective actions are captured in the corrective action program in Condition Reports CR-PNP-2016-01546, -2057, and -02061. SAFETY CONSEQUENCES The safety objective of the SSW system is to provide a heat sink for the reactor building closed cooling water (RBCCW) system under normal, transient, and accident conditions. The SSW system has five (5) SSW pumps and is designed with sufficient redundancy so that no single active system component failure can prevent the system from achieving the safety objective. The system is designed to continuously provide a supply of cooling water to the secondary side of the RBCCW heat exchangers adequate to meet the requirements of the RBCCW.system under all conditions. The RBCCW system provides the necessary cooling requirements for the residual heat removal (RHR) system and ultimately the reactor and primary containment. The SSW pumps are separated into two loops. Two pumps are connected to each loop and the fifth pump can feed either loop. Initiation of standby AC power following loss of the preferred AC power source will automatically start at least one pump in each loop during normal conditions. Following a LOCA and loss-of,._ offsite power one pump will start in each loop because of diesel load limitations. Additional pumps are started manually by the operator as additional cooling loads are established and diesel capacity is available. Technical Specifications require two SSW loops to be operable whenever fuel is in vessel and reactor coolant temperature is greater than 212 degrees F. Operability of each loop requires at least two SSW pumps to be operable in the loop along with the associated controls to demonstrate SSW loop operability. Only one SSW loop is required to perform the safety functions. Since SSW Loop B was operable during this time period, no loss of safety function occurred. There was no adverse impact on the public health or safety. REPORT ABILITY This report is submitted in accordance with 10 CFR 50.73(a)(2)(i)(B), Operation or condition .prohibited by Technical Specifications. NRC FORM 366A (11-2015)
Page 5 of 5 NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2018 (11-2015) Estimated burden per response to comply with this mandatory collection request: 80 hours. Reported lessons learned are incorporated into the licensing process and fed back to industry. Send comments regarding burden estimate to the FOIA, Privacy and Information Collections Branch (T-5 LICENSEE EVENT REPORT (LER) . F53), U.S. Nuclear Regulatory Commission, Washington, DC 29555-0001, or by internet e-mail to *11*t.* . lnfocollects.Resource@nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, CONTINUATION SHEET NEOB-10202, (3150-0104), Office of Management and Budget, Washington, DC 20503. If a means used to impose an information collection does not display a currenijy valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection. 1. FACILITY NAME 2. DOCKET NUMBER 3. LER NUMBER YEAR SEQUENTIAL NUMBER Pilgrim Nuclear Power Station 05000293 2016 004 NARRATIVE PREVIOUS EVENTS LERs for the previous ten years were reviewed for SSW Pumps being inoperable. These LERs are summarized as follows: LER 2013-007 -Ultimate Heat Sink and Salt Service Water System Declared Inoperable LER 1998-029 -Intake Structure Indoor Air Temperature Less Than Design REV NO. 00 LER 1997-017-01 -Past Operation With Service Water Temperatures Greater Than Design Due To Licensing Basis Ambiguity LER 1997-015-01 -SSW Pumps Overload Settings Too Low for Single SSW Pump Operation with Degraded Voltage These *prior LERs involved events where SSW Pumps were declared inoperable at the same time. However, the events are different because they did not involve inadequate predictive maintenance monitoring. ENERGY INDUSTRY IDENTIFICATION SYSTEM (EllS) CODES The EllS codes for Components and Systems referenced in this report are as follows: COMPONENTS Relay -Overvoltage SYSTEMS Low Voltage Power System Class 1 E
 
==REFERENCES:==
CODES 59 CODES ED Condition Report CR-PNP-2016-01546 -52M-1544 (SSW Pump B) thermal image hot spots Condition Report CR-PNP-2016-03308 -Comparison of 2016 to 2013 thermography surveillance results for SSW Pump B, Bkr 1544 overload relay for Past Operability Condition Report CR-PNP-2013-07196 -Thermography surveillance results ori SSW Pump motor supply breakers Condition Report CR-PNP-2016-02057 -Work Management Problem Area Condition Report CR-PNP-2016-02061 -Engineering Programs Problem Area NRC FORM 366A (11-2015)}}

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