05000277/LER-1989-006, Corrected LER 89-006-00:on 890209 & 25,determined That Tubing to Containment Isolation Valve Installed W/Inadequate Support & Containment Atmosphere Control & Dilution Sys Not Per Applicable Installation Criteria.Controls Estab

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Corrected LER 89-006-00:on 890209 & 25,determined That Tubing to Containment Isolation Valve Installed W/Inadequate Support & Containment Atmosphere Control & Dilution Sys Not Per Applicable Installation Criteria.Controls Established
ML20247G823
Person / Time
Site: Peach Bottom Constellation icon.png
Issue date: 05/09/1989
From: Cribbe T
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20247G800 List:
References
LER-89-006-02, LER-89-6-2, NUDOCS 8905310080
Download: ML20247G823 (4)


LER-2089-006, Corrected LER 89-006-00:on 890209 & 25,determined That Tubing to Containment Isolation Valve Installed W/Inadequate Support & Containment Atmosphere Control & Dilution Sys Not Per Applicable Installation Criteria.Controls Established
Event date:
Report date:
2772089006R00 - NRC Website

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e" U 5. NUCLEAR REGULATOMY COMMisslON iLC Ferdn 344 s

APPROVED OM8 NO 3150-0104 EXPIRES 8/3F88

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DOCKET NUMSER (2) PAGE136 F ACILITY NAMi til Peach Bottom Atomic Power Station - Unit 2 015l0l010l2j7l7 1 loFl 014 TITLE 446 containment Atmospheric control and Dilution Systems Pneumatic Tubing configuration Not por The Ann 14cnhle Tnntn11ntinn Cr<terla EVENT DATE l'Sl' LER NUMBER 161 REPORT DATE 17) OTHER F ACILITIES INVOLVED 181 SE u iAL is DAv y g as: F AC6 LsT V N AMES DOCKE T NUMBER (S)

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%8v+55 SON 4ES (19 res compiere LXPECTED SU8w$310N OA TEI NO l l l AESTR ACT IL,mrt to 1400 speces o e nooronometes Idreen smg e sonce typewr tre" tunen (191 On February 9,1989, an NRC Inspector, while performing a walkdown of Modification 1316, discovered that the tubing to a Torus Air and Nitrogen Purge 18" Containment Isolation valve was installed with inadequate support. On February 25, 1989, it was determined that the "as-found" configuration of the tubing for seventeen pneumatically operated valves associated with the Unit 2 Containment Atmosphere Control (CAC) and Containment Atmosphere Dilution (CAD) Systems was not per the appliceable installation criteria. The cause of the deficiencies was less than adequate installation and maintenance instructions. No adverse safety consequences occurred as a result of this event. Continued operation of the affected equipment could not be assured during required design basis conditions. This could have resulted in greater than design leakage past the Drywell/ Torus Containment Isolation valves and prevented the use of the CAD system for Post-LOCA combustible gas control.

The configuration was corrected in accordance with applicable standards and installation criteria. Interim controls were established until a detailed set of design, installation, and maintenance requirements are provided. Other programmatic improvements will be based on Nuclear Quality Assurance audit results. There was one previous similar event.

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,a N'C Form 366A - U.S. NUCLEAR MGL'LATo3Y COMMIS5loN

' LICENSEE EVENT REPORT (LER) TEXT CONTINUATION AerRoveo oMe No siso-oio4

, . EXPIRES: 8/31/88 MCILITV NAME (1)

  • DOCKET NUMBER 12) LER NUMBER (6) PAGE {31 JPeach Bottom Atomic Power Station

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Requirements for the Report This report is' required per 10 CFR 50.73(a)(2)(v) because of the potential for.the affected equipment not to fulfill its design safety function during required design basis conditions.

Unit Status at Time of Eve _nt Unit 2 was in Cold Shutdown and Unit 3 in the Refueling mode with the core offloaded.

L Description of Event '

On February 25, 1989, it was confirmed during a walkdown of safety related pneumatic tubing (EIIS:TBG). that the configuration of tubing supplying seventeen pneumatically {

operated valves (EIIS:V) did not comply with the applicable modification criteria and therefore, may not have been sufficient to withstand loads during required design conditions. This investigation was initiated on February 9, 1989, after an NRC Inspector noted an apparently faulty tubing installation while performing a walkdown of Modification 1316 near the end of the Integrated Assessment Team Inspection (IATI). '

Modification 1316 installs a safety-grade instrument gas supply (EIIS:LB) from the bulk nitrogen facility (EIIS:LK) to pneumatically operated isolation valves associated with primary containment purge and vent Tines.

The following is a list of the valves affected by the tubing deficiencies:

A0-25521A/2521B Torus Air & N2 Purge 18" Cont. Isolation (EIIS:ISV)

A0-2511/2512 Torus Vent 18" Cont. Isolation A0-2505/2520 Drywell Air & N2 Purge 18" Cont. Isolation A0-2506/2507 Drywell Vent 18" Cont. Isolation A0-2509/2510 Drywell Vent 2" Cont. Isolation A0-2513/2514 Torus Vent 2" Cont. Isolation A0-2502A/25028 Reactor Bldg to Torus Vacuum Breakers (EIIS:VACB)

A0-2519 N2 Inerting Supply (EIIS:JM) to Containment CV-4954/4957 Torus Exhaust Vent (EIIS:VTV) ti SBGT System It should be noted that during the investigation, deficiencies were identified in the configuration of the pneumatic tubing for twelve battery room dampers. These deficiencies were not significant and would not have affected the design function of the dampers.

The event date, February 9, 1989, differs from the deportability date, April 10, 1989, by more than thirty days. This delay was the result of the amount of time required to walkdown and evaluate the deficiencies prior to making a deportability determination.

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TEXT W med noece is requeed, use edcVtmelMC Fwm 36Wal(1D Cause of the Event The cause of the pneumatic tubing installation deficiencies was determined to be less than adequate installation and maintenance instructions. The origins of these deficiencies fall into two categories, 1) installation of Modification 1316 was less than adequate and, 2) air tubing disturbed by maintenance activities was not returned to its original configuration due to instal % tion drawings being i..adeauate or unavailable. A contributing factor was that the specific design res,.v..sibility for

" tubing" was not assigned to a particular engineering discipline. This situation is uncommon in that other commodities, such as pipe, valves and electrical equipment are the responsibility of specific organizations and have detailed specifications. This lack of assigned responsibility, combined with inadequate installation specifications, was the primary cause of the deficiencies.

Analysis of the Event No actual safety consequences occurred as a result of this event.

The supports for safety related pneumatic tubing ensure that associated operating devices will perform their design safety function. Since the identified deficiencies were numerous and diverse, no attempt was made to uniquely analyze each configuration for acceptability. Instead, the identified deficient installations were restored to l acceptable configurations. Failure of the pneumatic tubing would allow the affected 1 valves to either stroke closed normally or fail to the isolate position. This would satisfy the isolation safety design bases except for the eight 18" purge / vent containment isolation valves. These valve utilize a pressurized boot seal (Ells: SEAL) to help ensure design leak rate is not exceeded. A loss of pneumatic pressure to these seals could compromise the ability of the affected valve (s) to maintain containment integrity. Leakage past the closed 18" Containment Isolation valves in the vent path line would be processed by the Standby Gas Treatment System (Ells:BH). The leakage past the closed 18" Containment Isolation valves in the purge line could progress through the Containment Purge Supply Fan (EIIS: FAN) Discharge Header through the Purge Supply Fans to the Outside Air Plenum. This leakage would be reduced by Purge Supply Fan Discharge Header Isolation valves A0-20459/A0-20460 (non-containment isolation valves) being normally closed when containment purge is not in progress. The probability of these valves being closed is high as Technical Specification requirements only permit purging within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of shutdown and allow no more than a cumulative 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> purging per 365 day period.

Loss of the pneumatic supply to the containment vent valves could prevent use of the CAD system (EIIS:BB) to maintain an inert atmosphere during post-accident conditions.

Post accident containment atmosphere dilution would not be required until approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after an accident per FSAR analysis. This could provide sufficient time to effect repairs assuming radiation levels permit entry into secondary containment.

Additionally, analysis by the BWR owners group and Northeast Utilities Service Company indicate Post-LOCA radiolytic oxygen generation would be much lower than postulated and could reduce if not preclude the need for Post-LOCA combustible gas control.

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  • EXPlRES; Q/31/88 FOCILITY NAME O p DOCKET NUMBER (2) LER NUMBER (6) PAGE13)

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Peach Bottom Atomic Power Station Unit 2 0 l5 lo l0 l0 l2 l7 l 7 8l9 -

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1) The following corrective actions have been completed:

a) A walkdown of Unit 2 safety-related pneumatic tubing associated with the seventeen pneumatically operated valves previously identified.

b) Correction of Unit 2 deficiencies was completed on April 15, 1989.

c) Interim controls were established to ensure the required configuration is maintained until a detailed set of requirements are available.

d) Specific responsibility has been assigned for design of safety-grade tubing installation in the future.

e) A Nuclear Quality' Assurance (NQA) audit of the modification process was completed with specific emphasis on installation and inspection activities.

2) The following corrective actions are planned:

a). A review and upgrade of Unit 3 safety-related tubing similar to Unit 2 will be performed. prior to restart.

b) A detailed set of requirements will be provided for the design, installation and maintenance of safety-grade tubing following the Unit 3 outage.

c) The modification process will be enhanced based on results of the NQA audit.

Previous Similar Events A' previous similar event, LER 2-88-05, involves the non-conformance of the as-built conf _iguration_of the Main Control Panels (EIIS:PL) to original installation requirements. The actions to prevent recurrence of this previous event was to initiate the actions outlined in response to Generic Letter 87-02, Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors. Based on the Generic Implementation Procedure (GIP) schedule these actions would not have been completed in time to prevent this event.

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