05000254/LER-2003-002

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LER-2003-002, xe .°.~n® •
Nuclear Exelon Generation Company, LLC
Quad Cities Nuclear Power Station
22710 206th Avenue North
Cordova, IL 61242-9740
www.exeloncorp.com
February 19, 2004
SVP-04-003
U. S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Washington, D.C. 20555
Quad Cities Nuclear Power Station, Unit 1
Facility Operating License No. DPR-29
NRC Docket No. 50-254
Subject: R Licensee Event Report 254/03-002, Revision 1, "Mode Change with Core
Spray Loop Inoperable due to Failure to Properly Fill and Vent"
Enclosed is Licensee Event Report (LER) 254/03-002, Revision 1, "Mode Change with Core
Spray Loop Inoperable due to Failure to Properly Fill and Vent," for Quad Cities Nuclear
Power Station, Unit 1.
The original report was submitted on August 1, 2003, in accordance with the requirements of
the Code of Federal Regulations, Title 10, Part 50.73(a)(2)(i)(B), which requires reporting of
any operation or condition which was prohibited by the plant's Technical Specifications.
This revision is being submitted to include additional system venting events at Quad Cities
Nuclear Power Station in the "Previous Occurrences" section. These additional events were
not previously included since they did not share the same underlying root cause, but for the
sake of completeness are being added at this time.
Should you have any questions concerning this report, please contact Mr. W. J. Beck at
(309) 227-2800.
Respectfully,
othy J. Tulon
ite Vice President
Quad Cities Nuclear Power Station
cc: R Regional Administrator — NRC Region Ill
NRC Senior Resident Inspector — Quad Cities Nuclear Power Station
NRC FORM 366 6 U.S. NUCLEAR REGULATORY
(7-2001)
)
COMMISSION
LICENSEE EVENT REPORT (LER)
APPROVED BY OMB NO. 3150-0104 6 EXPIRES 7-31-2004
Estimated burden per response to comply with this mandatory information collection request: 50
hours. o Reported lessons learned are incorporated into the licensing process and fed back to
industry. Send comments regarding burden estimate to the Records Management Branch (T.6 E6),
U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by Internet e-mail to
bis1@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
Information collection does not display a currently valid OMB control number, the NRC may not
mruli int nr snonsnr and a nprsnn is not rennin:4 to rpsrinnd to tha ininrmatinn collection
1. FACILITY NAME
Quad Cities Nuclear Power Station Unit 1
2. DOCKET NUMBER
05000254
3. PAGE
1 of 4
4.-rrrLE o Mode Change with Core Spray Loop Inoperable due to Failure to Properly Fill and Vent
Quad Cities Nuclear Power Station Unit 1
Event date:
Report date:
Reporting criterion: 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
2542003002R01 - NRC Website

FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6 PAGE (3) Quad Cities Nuclear Power Station Unit 1 05000254 (If more space is required, use additional copies of NRC Form 366A)(17)

PLANT AND SYSTEM IDENTIFICATION

General Electric - Boiling Water Reactor, 2957 Megawatts Thermal Rated Core Power Energy Industry Identification System (EIIS) codes are identified in the text as [XX].

EVENT IDENTIFICATION

Mode Change with Core Spray Loop Inoperable due to Failure to Properly Fill and Vent

A. CONDITION PRIOR TO EVENT

Unit: 1 Reactor Mode: 4 Event Date: May 29, 2003 Mode Name: Cold Shutdown Event Time: 0353 hours0.00409 days <br />0.0981 hours <br />5.83664e-4 weeks <br />1.343165e-4 months <br /> Power Level: 000% Cold Shutdown (4) temperature - Mode switch in Shutdown position degrees F.

with average reactor coolant

B. DESCRIPTION OF EVENT

On June 4, 2003, at 0114 hours0.00132 days <br />0.0317 hours <br />1.884921e-4 weeks <br />4.3377e-5 months <br />, the monthly verification of fill for the 1B Core Spray [BM] loop was being performed. This verification is required by Technical Specification (TS) Surveillance Requirement (SR) 3.5.1.1. The operator performing the surveillance observed air from the high-point vent [VTV] in excess of the procedural acceptance criteria. Subsequently, the system was filled and vented and operability was re-established.

Investigation determined that a local leak rate test (LLRT) of the 1B Core Spray 'isolation valves [ISV] was performed on May 21, 2003. As part of the return to service process, the system is required to be filled and vented. The procedure steps that accomplish the venting of the system were not performed. The system was inoperable from the time that the LLRT was performed until the air in the piping was discovered.

entered Mode 1. These mode changes are prohibited by Technical Specification SR 3.0.4, which states that entry into a mode shall not be made unless the SRs have been met, and by TS LCO 3.0.4, which states that entry into a mode shall not be made when a limiting condition for operation (LCO) is not met, except when the associated actions permit continued operation in that mode. Therefore, although the system was only inoperable and required to be operable from May 29, 2003, until June 4, 2003, which is less than the TS allowed outage time of 7 days, the event is being reported as operation prohibited by TS due to the mode changes made while Core Spray was inoperable.

DOCKET NUMBER (2) PAGE (3) LER NUMBER (6 FACILITY NAME (1) (If more space is required, use additional copies of NRC Form 366A)(17)

C. CAUSE OF EVENT

The root cause of this event was inadequate procedure adherence and coordination of work activities due to miscommunication and inadequate turnover.

D. SAFETY ANALYSIS

The safety significance of this event was minimal. The lA loop of Core Spray and the Low Pressure Coolant Injection (LPCI) mode of Residual Heat Removal (RHR) were operable throughout the time that the 1B Core Spray loop was required to be operable. Also, the 1B loop of Core Spray was not operated during the time that it was not filled.

E. CORRECTIVE ACTIONS

Corrective Actions Completed:

Operations has instituted a program to continually reinforce fundamentals and develop leadership, providing a comprehensive approach to human performance improvement.

Corrective Actions to be Completed:

The prerequisites in the procedure for normal unit startup will be revised to require verification of operability of Emergency Core Cooling Systems (ECCS) by venting prior to entering conditions where the systems are required to be operable.

F. PREVIOUS OCCURRENCES

No instances of a reportable event involving failure to perform an action due to inadequate turnover and/or miscommunication were identified during the last 2 years.

However, there have been six other events involving venting at Quad Cities Nuclear Power Station over the last four years, two of which were reportable.

On February 11, 2000, it was determined that the High Pressure Coolant Injection (HPCI) system had not been adequately filled and vented following maintenance because the procedure did not specify a long enough venting time. (LER 265/2000- 005, revision 2, dated September 18, 2000, "High Pressure Coolant Injection Inoperability during Low Pressure Testing Due to Incomplete Maintenance Activities and Inadequate Venting.") On April 21, 2000, HPCI failed a venting surveillance due to inadequate fill and vent. Procedure changes in response to a previous event were inadequate. (Condition Report (CR) Q2000-02007) On December 27, 2000, it was determined that the HPCI system had not been adequately filled and vented following maintenance because the procedure required filling and venting only a portion of the piping. (LER 254/2000-007, dated January 26, 2001, "Inadequate Fill and Vent Surveillance Performed on High Pressure Coolant Injection Resulting in Air in Discharge Piping.") .

FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6 PAGE (3) Quad Cities Nuclear Power Station Unit 1 05000254 (If more space is required, use additional copies of NRC Form 366A)(17) On January 4, 2002, the Unit 1 Reactor Core Isolation Cooling (RCIC) system failed its monthly vent verification test. This was determined to be due to a delay in opening of a suction check valve due to additional frictional forces and low available differential pressure. (CR 88923) On November 25, 2002, during venting of the Unit 1 HPCI system, the procedural acceptance criteria were not met, but an evaluation of the discrepancy was not immediately performed. (CR 137008) On January 4, 2003, Unit 2 RHR failed the vent verification procedure because there appeared to be more than 10 minutes of air in the RHR system. This was determined to be due to difficulty reading the sight-glass and not due to air in the system.

(CR 138115) These previous events resulted primarily from inadequate venting procedures and methods: The January 4, 2003, venting event was an equipment issue. The corrective actions for these events addressed the appropriate root causes. Additionally, a Common Cause Analysis was performed for venting events at Quad Cities Nuclear Power Station, and appropriate corrective actions were initiated.

G. � COMPONENT FAILURE DATA There were no component failures associated with this event.