05000315/LER-2006-002, Re Failure to Comply with Technical Specification Requirement 3.6.13
| ML063460188 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 11/30/2006 |
| From: | Peifer M Indiana Michigan Power Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| AEP:NRC:2573-35 LER 06-002-00 | |
| Download: ML063460188 (5) | |
| 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 |
| 3152006002R00 - NRC Website | |
text
INDIANA MICHIGAN POWERW A unit of American Electric Power November 30, 2006 Indiana Michigan Power Cook Nuclear Plant One Cook Place Bridgman, MI 49106 AEP~com AEP:NRC:2573-35 10 CFR 50.73 10 CFR 50.4 Docket No. 50-315 U. S. Nuclear Regulatory Conmission Attn: Document Control Desk Mail Stop O-P1-17 Washington, DC 20555-0001 Donald C. Cook Nuclear Plant Unit 1 LICENSEE EVENT REPORT 3115/2006-002-00 FAILURE TO COMPLY WITH TECHNICAL SPECIFICATION REQUIREMENT 3.6.13 in accordance with the criteria established by 10 CFR 50.73 entitled Licensee Event Report System, the following report is being submitted:
LER 315/2006-002-00: "Failure to Comply with Technical Specification Requirement 3.6.13" There are no comnmtitments contained in this submittal.
Should you have any questions, please contact Ms. Susan D. Simpson, Regulatory Affairs Manager, at (269) 466-2428.
Site Vice President RAM/rdw Attachment Jaz2z-
U. S. Nuclear Regulatory Conlmission AEP:NRC:2573-35 Page 2 c:
J. L. Caldwell, NRC Region 1II K. D. Curry - AEP Ft. Wayne, w/o attachment INPO Records Center J. T. King, MPSC - w/o attachment MDEQ - WHMD/RPMWS - w/o attachment NRC Resident Inspector P. S. Tam, NRC Washington DC
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 information collection.
- 3. PAGE Donald C. Cook Nuclear Plant Unit 1 05000-315 1 of 3
- 4. TITLE Failure to Comply with Technical Specification Requirement 3.6.13
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED SEQUENTIAL REVISION FACILITY NAME DOCKET NUMBER MONTH DAY YEAR YEAR NUMBER NUMBER MONTH DAY YEAR FACILITY NAME DOCKET NUMBER 10 03 2006 2006 002 00 11 30 2006
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)
[E 20.2201(b)
El 20.2203(a)(3)(i)
El 50.73(a)(2)(i)(C)
El 50.73(a)(2)(vii)
Mode 1 El 20.2201(d)
[] 20.2203(a)(3)(ii)
El 50.73(a)(2)(ii)(A)
[I 50.73(a)(2)(viii)(A)
El 20.2203(a)(1)
El 20.2203(a)(4)
[] 50.73(a)(2)(ii)(B)
El 50.73(a)(2)(viii)(B)
El 20.2203(a)(2)(i)
El 50.36(c)(1)(i)(A)
F] 50.73(a)(2)(iii)
El 50.73(a)(2)(ix)(A)
- 10. POWER LEVEL El 20.2203(a)(2)(ii)
El 50.36(c)(1)(ii)(A)
[I 50.73(a)(2)(iv)(A)
El 50.73(a)(2)(x)
El 20.2203(a)(2)(iii)
El 50.36(c)(2)
E3 50.73(a)(2)(v)(A)
El 73.71(a)(4) 100%
El 20.2203(a)(2)(iv)
El 50.46(a)(3)(ii)
[I 50.73(a)(2)(v)(B) 73.71 (a)(5)
El 20.2203(a)(2)(v)
El 50.73(a)(2)(i)(A)
El 50.73(a)(2)(v)(C)
L OTHER Specify in Abstract below El 20.2203(a)(2)(vi)
[
50.73(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
Mode 1 - 100% power
Description of Event
On October 5, 2006, following an inspection of the Donald C. Cook Nuclear Plant (CNP) Unit 1 containment divider barrier seal, Indiana Michigan Power Company (I&M) personnel discovered that contrary to Technical Specification (TS) 3.6.13, Divider Barrier Integrity, one divider barrier seal [SEAL] retaining bolt was missing and a second divider barrier seal retaining bolt was missing its associated nut. The investigation of this condition determined the missing components had previously been identified in November 1998. However, the 1998 evaluation of the condition failed to identify the TS noncompliance and subsequent corrective actions failed to correct the condition.
The failure to replace the missing divider barrier seal retaining components constitutes a failure to comply with TS 3.6.13. This failure to comply with TS 3.6.13 is reportable in accordance with 10 CFR 50.73(a)(2)(i)(B).
Cause of Event
Due to the historical nature of the event, the cause of I&M's failure to identify and correct the condition in 1998 could not be definitively determined. However, I&M believes the cause of the inadequate evaluation and correction of the identified condition was personnel error.
I&M believes its current corrective action program would prevent a failure to correctly evaluate and correct similar plant nonconformances.
Further, the wording within the governing surveillance procedure, in accordance with TS 3.6.13, required a visual inspection of 95 percent of the divider barrier seal each refueling outage. The procedure did not contain wording that would ensure that 100 percent of the divider barrier seal would be inspected at some periodicity. This lack of procedural guidance allowed the same 5 percent of the divider barrier seal to go uninspected for approximately eight years. This procedural wording contributed to I&M's failure to re-identify the missing components in a timely manner.
Analysis of Event
The divider barrier separates the upper and lower compartments of containment and includes a flexible barrier seal located between the ice condenser [BC] compartment and the containment cylinder wall [BC]. This barrier is also located between the containment liner and other structural elements that are part of the divider barrier.
Divider barrier integrity is necessary to minimize bypassing of the ice condenser by the hot steam and air mixture released into the lower compartment during a Design Basis Accident (DBA). This ensures that most of the gases pass through the ice bed, which condenses the steam and limits pressure and temperature during the accident transient.
The elastomeric divider barrier seal is attached on one side to a 5/8" thick support plate and on the other to a 1/4" thick structural plate with 3/8" diameter bolts. Two issues were noted for this attachment - one bolt is missing a nut and another bolt is missing entirely. There is no hole in the elastomeric seal where the missing 3/8" diameter bolt was supposed to be installed. The bolt that is missing a nut is filling its hole and the bolt head is tack welded on the far side of the structural support plate. Based on the above, no bypass of the divider barrier is (If more space is required, use additional copies of NRC Form (366A) judged to result from the missing nut or the missing bolt. However, Structural Design personnel conservatively calculated a deflection at both locations in order to estimate a maximum divider barrier bypass. The calculated bypass area had no significant impact on the existing bypass margin for Unit 1.
The operability evaluation concluded that there was no loss of the divider barrier function. A probabilistic risk assessment was performed and concluded that because there was no loss of divider barrier function, no additional risk was incurred as a result of the bolting issues.
Corrective Actions
The divider barrier bolting conditions described above were corrected on November 3, 2006, prior to Unit 1 entering Mode 4 following refueling.
The Containment Divider Barrier Seal Surveillance Test procedures for Unit 1 (1-EHP-4030-195-249) and Unit 2 (2-EHP-4030-295-249) have been placed on administrative hold until necessary procedural enhancements are completed prior to their next use.
Previous Similar Events
None.