05000315/LER-2005-002, Failure to Comply with Technical Specification Requirements Pertaining to Under Voltage Protection Instrumentation
| ML053120369 | |
| Person / Time | |
|---|---|
| Site: | Cook  (DPR-058) |
| Issue date: | 10/28/2005 |
| From: | Weber L Indiana Michigan Power Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| AEP:NRC:2573-27 LER 05-002-00 | |
| Download: ML053120369 (6) | |
| 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 |
| 3152005002R00 - NRC Website | |
text
INDIANA MICHIGAN POWER Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman.MI 49106 aep.com October 28, 2005 AEP:NRC:2573-27 Docket No. 50-315 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop O-P1-17 Washington, DC 20555-0001 Donald C. Cook Nuclear Plant Unit 1 LICENSEE EVENT REPORT 315/2005-002-00 FAILURE TO COMPLY WITH TECHNICAL SPECIFICATION REQUIREMENTS PERTAINING TO UNDERVOLTAGE PROTECTION INSTRUMENTATION In accordance with the criteria established by 10 CFR 50.73 entitled Licensee Event Report System, the following report is being submitted:
LER 315/2005-002-00: "Failure to Comply With Technical Specification Requirements Pertaining to Undervoltage Protection Instrumentation" There are no new commitments identified in this submittal.
Should you have any questions, please contact Mr. Michael K. Scarpello, Regulatory Affairs Supervisor, at (269) 466-2649.
Sincerely, Lawrence J. Weber Plant Manager RAJ/jen Attachment 9-a 3-
U. S. Nuclear Regulatory Commission AEP:NRC:2573-27 Page 2 c:
J. L. Caldwell, NRC Region III K. D. Curry - AEP Ft. Wayne, w/o attachment J. T. King, MPSC - w/o attachment MDEQ - WHMDIRPMWS - w/o attachment NRC Resident Inspector D. W. Spaulding, NRC Washington DC
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NRC Form 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES 6/30/2007 (6-2004)
, the NRC may not conduct or sponsor, and a person is not required to respond to, the intormation collection
- 3. PAGE Donald C. Cook Nuclear Plant Unit 1 05000-315 1 of 4
- 4. TITLE Failure to Comply With Technical Specification Requirements Pertaining to Undervoltage Protection Instrumentation
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED SEQUENTIAL REVISION I
FACILITY NAME DOCKET NUMBER MONTHDAY YEAR YEAR NUMBER NUMBER MONTH l DAY YEAR Donald C. Cook 05000-316 lFACILITY NAME DOCKET NUMBER 08 30 2005 2005 002 000 10 28 2005
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply) 0 20.2201(b) 0 20.2203(a)(3)(i) 0 50.73(a)(2)(i)(C) 0 50.73(a)(2)(vii) 0 a
20.2201(d) 0 20.2203(a)(3)(ii) 0 50.73(a)(2)(ii)(A)
D 50.73(a)(2)(viii)(A) a 20.2203(a)(1) 0 20.2203(a)(4) 0 50.73(a)(2)(ii)(B) 0 50.73(a)(2)(viii)(B) a 20.2203(a)(2)(i) 0 50.36(c)(1)(i)(A) 0 50.73(a)(2)(iii) 0 50.73(a)(2)(ix)(A)
- 10. POWER LEVEL 0 20.2203(a)(2)(ii) 0 50.36(c)(1)(ii)(A) 0 50.73(a)(2)(iv)(A) 0 50.73(a)(2)(x) 0 20.2203(a)(2)(iii) 0 50.36(c)(2) 0 50.73(a)(2)(v)(A) 0 73.71 (a)(4) 100%
0 20.2203(a)(2)(iv) 0 50.46(a)(3)(ii) 0 50.73(a)(2)(v)(B)
DO 73.71 (a)(5) o 20.2203(a)(2)(v) 0 50.73(a)(2)(i)(A) 0 50.73(a)(2)(v)(C)
Li OTHER Specify In Abstract below I___________]___
20.2203(a)(2)(vi)
El 60.73(a)(2)(i)(B)
El 50.73(a)(2)(v)(D) or In (If more space is required, use additional copies of NRC Form (366A)
Conditions Prior to Event
Unit I = MODE I at 100% power Unit 2 = MODE I at 100% power
Description of Event
On August 30, 2005, at approximately 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br />, it was identified that an equipment clearance implemented to support planned maintenance on the Unit I CD Emergency Diesel Generator (I-CD-EDG) [EK] disabled 4 kV bus loss of voltage relays [JE] required by Custom Technical Specification (CTS) 3.3.2.1, "Engineered Safety Features Actuation System Instrumentation."
At the time of this event, CTS were in effect at Donald C. Cook Nuclear Plant (CNP). This is noted because on September 25, 2005, license amendment 287 was implemented to convert from CTS to the Improved Technical Specifications (ITS) and the specific requirements for the Engineered Safety Features Actuation System (ESFAS) item were changed.
On August 30, 2005, the 4 kV loss of voltage relays were required to be operable per CIS 3.3.2.1, Table 3.3-3, Item 6, "MOTOR DRIVEN AUXILIARY FEEDWATER PUMPS," Sub-Item b, "4 kV Bus loss of Voltage" and Item 8, "LOSS OF POWER," Sub-Item a, "4 kV Bus Loss of Voltage."
Action statement 14 of table 3.3-3 of the CI'S stated: "With the number of OPERABLE Channels one less that the Total Number of Channels, operation may proceed until performance of the next required CHANNEL FUNCTIONAL TEST provided the inoperable channel is placed in the tripped condition within I hour."
In the configuration rendered by the equipment clearance placement, all three undervoltage relays (and their associated channels) for 4 kV busses TI IC and TI ID were de-energized and incapable of performing the required function. There was no CTS action stated for the configuration of more than one channel inoperable. CTS 3.0.3 requires when a limiting condition for operation is not met, except as provided in the associated action requirements, within one hour action shall be initiated to place the unit in a mode in which the specification does not apply. This did not occur. This was a failure to recognize the requirements of the CTS were not met, and is reportable under 10 CFR 50.73(a)(2)(i)(B) as an operational condition prohibited by the plant's technical specifications (TS).
This condition was discovered when the equipment clearance (CNP-1052035) de-energized circuit 1-TDCD-2 to perform work on control switches associated with 1-CD-EDG. The equipment clearance was placed and the relays de-energized on August 30, 2005, at approximately 0813 hours0.00941 days <br />0.226 hours <br />0.00134 weeks <br />3.093465e-4 months <br />. As preparations for implementing ITS were underway at CNP, a review of upcoming ITS requirements was performed in conjunction with control room actions taken as required for existing CIS.
De-energizing circuit 1-TDCD-2 brought in several control room annunciators. Licensed operator use of the annunciator response procedures prompted a review of ITS 3.3.5, '"oss of Power Diesel Generator Start Instrumentation," to assess the impact of these annunciator response actions following ITS implementation. ITS 3.3.5 loss of voltage function is applicable in Modes 1, 2, 3, and 4, and when the associated EDG is required to be operable by LCO 3.8.2, AC Sources-Shutdown. In ITS, the associated EDG would be required to be declared inoperable upon a loss of these relays (Condition C). Since the EDG was already removed from service, no further action would be required with ITS implemented. However, ITS 3.3.2, Engineered Safety Features Actuation System (ESFAS) Instrumentation, Item 6e, Action F, only allows one channel per bus to be inoperable. This difference prompted a detailed review of the clearance and its impact on CTS 3.3.2.1.
(If more space is required, use additional copies of NRC Form (366A)
At 0940 hours0.0109 days <br />0.261 hours <br />0.00155 weeks <br />3.5767e-4 months <br /> on August 30, 2005, the Shift Manager directed restoration of the clearance that tagged circuit l-TDCD-2 while the condition was further researched. This circuit was restored at approximately 1011 hours0.0117 days <br />0.281 hours <br />0.00167 weeks <br />3.846855e-4 months <br /> on August 30, 2005, and compliance with the CTS was reestablished.
A historical review of the method in Equipment Clearance Permit CNP-1052035 demonstrated that a similar configuration had been incorrectly used in both Unit I and Unit 2. This review identified 14 Unit I and 12 Unit 2 clearance permits with a similar configuration, resulting in similar CTS non-compliances. This licensee event report (LER) will serve as the report for all similar historical failures to comply with CTS 3.3.2.1 and 3.0.3 due to this configuration.
Cause of Event
The cause of this condition is a failure to assure TS requirements were met prior to removing equipment from service for an equipment clearance. The Operators preparing, reviewing and placing the clearance did not perform a review in sufficient detail to identify all CTS associated with individual components de-energized by the clearance.
Analysis of Event
Using the described clearance to remove the EDG from service for maintenance had the unintended effect of defeating the TI IC and TI ID bus undervoltage automatic start function of the East (A-Train) Motor Driven Auxiliary Feedwater Pump (MDAFP) and flow conservation actuation. Therefore, the function affected by this event was the ability of the East MDAFP to start upon loss of voltage to the Ti IC and TIlD buses. Other automatic start and flow conservation signals for the A train of auxiliary feedwater (e.g., Steam Generator Low Level) were not affected. The Turbine Driven Auxiliary Feedwater Pump starts automatically on loss of the reactor coolant pump busses and was unaffected by this event as was the West MDAFP.
Since the l-CD-EDG was out of service for maintenance during placement of this clearance, loss of the automatic start function had no effect on system operation since no power source would be available to the associated pump during an actual loss of voltage to the Tl IC and Tl ID buses.
This condition is assumed to have existed the entire time the 1-CD-EDG was cleared for maintenance. As is required by the risk analysis for critical maintenance projects on the EDG, no switchyard work was in progress and no other major equipment was scheduled to be out of service during this time.
Both trains of auxiliary feedwater and their automatic actuation functions were available during this event in every scenario in which the pumps had power available. The risk was reflected in the maintenance rule (a)(4) risk assessment performed prior to removing the l-CD-EDG from service. The planned work scope and duration vere below the NUMARC 93-01 guidance thresholds for high and medium risk activities requiring risk management actions. Consequently, this analysis concludes that this event was not risk significant.
Corrective Actions
Actions Completed:
The circuit wvas energized to restore compliance with C'S.
Provided additional information within the clearance software to prompt clearance reviewers of the TS impact from de-energizing the circuit (CRE 05242034).
(If more space is required, use additional copies of NRC Form (366A)
Reviewed actions taken at the time TSCs were cancelled to ensure no additional vulnerabilities exist due to lack of actions taken (CRA 05242034-04).
Provided a Noteworthy Event memo to all Shift Managers, Operations Work Control Manager, and Operations Support Managers to share with their staff regarding this event. This noteworthy event was specifically to communicate the TS impact if these breakers are opened in Modes I through 4 (CRE 05242034).
Actions Pending:
Perform a review of the Reactor Trip Instrumentation Functions in ITS 3.3.1 and the Engineered Safety Features Actuation System Instrumentation Functions in ITS 3.3.2 for both units. The intent of this review is to identify the power supplies that could impact these functions if de-energized. These power supplies will be utilized to add information to the eSOMS Clearance Module that identifies TS impact when removing these power supplies from service (CRA 05242034-01, -02, due January 31, 2006).
Develop a procedure to support removal and restoration of the power supplies that are identified as having an impact on a function contained in ITS 3.3.1 or 3.3.2 (CRA 05242034-03, due March 3, 2006).
Review upcoming EDG work windows being performed on line for work activities that require tagging circuit 2 of TDAB or TDCD for either unit (CRA 05242034-06, due November 4, 2005).
This issue will be considered for inclusion in Operations Initial License Training and Requalification (CR 05242034-05, due November 29, 2005).
Previous Similar Events
During the investigation of this condition, it was identified that the same clearance method has been used routinely for performing scheduled maintenance on the Unit I -AB-EDG and Unit 2-AB-EDG and 2-CD-EDG. However, it had not been identified and reported, with one exception, Unit I LER 1999-030-00, "Improper Use of Clarifications Results in Violation of Two Technical Specifications." This LER reported that a TS clarification regarding the applicability of CTS 3.3.2.1 had mistakenly concluded that it was not applicable during periods the EDG was inoperable. As a corrective action for that condition, the TS clarification was rescinded; however, there was no targeted training provided to operations staff to assure they understood the impact. The clearance software has been changed to prompt users of the TS impact and prevent a repeat of the event.
A second event involving non-compliance xvith the TS resulting from clearance activities was documented in Unit 2 LER 2004-003-00, "Failure to Comply with Containment Ventilation Operability Requirements specified in Technical Specifications 3.0.4, 3.4.9, and 3.9.9." A review of the root cause and corrective actions indicated that the events were similar in the respect that the operations reviewers did not identify the CIS impact prior to the event. The difference between these two events is that the cause of the LER 2004-003-00 condition was associated with work control. The clearance was initiated in a mode where the CIS was not applicable and should have been removed prior to a mode change where the CIS was applicable. The corrective actions for LER 2004-003-00 were made to address mode change controls to prevent recurrence, and would not have prevented this event. -