05000315/LER-2008-003, Failure to Comply with Technical Specification Limiting Condition for Operation 3.0.6
| ML081420016 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 05/12/2008 |
| From: | Peifer M Indiana Michigan Power Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| AEP:NRC:2573-45 LER 08-003-00 | |
| Download: ML081420016 (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 |
| 3152008003R00 - NRC Website | |
text
INDIANA MICHIGAN POWER May 12, 2008 Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106 aep.com AEP:NRC:2573-45 10 CFR 50.73 Docket No. 50-315 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop O-PI-17 Washington, DC 20555-0001 Donald C. Cook Nuclear Plant Unit 1 LICENSEE EVENT REPORT 315/2008-003-00 FAILURE TO COMPLY WITH TECHNICAL SPECIFICATION LIMITING CONDITION FOR OPERATION 3.0.6 In accordance with the criteria established by 10 CFR 50.73, Licensee Event Report System, the following report is being submitted:
LER 315/2008-003-00:
"Failure to Comply with Technical Specification Limiting Condition for Operation 3.0.6."
There are no commitments contained in this submittal.
Should you have any questions, please contact Mr. James M. Petro, Jr., Regulatory Affairs Manager, at (269) 466-2491.
Sincerely, Site Vice President RAM/rdw Attachment I&e2;&
U. S. Nuclear Regulatory Commission AEP:NRC:2573-45 Page 2 c:
J. L. Caldwell - NRC Region III K. D. Curry - AEP Ft. Wayne, w/o attachment INPO Records Center J. T. King - MPSC, w/o attachment MDEQ - WHMD/RPS, 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 08/3112010 (9-2007)
, 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 Limiting Condition For Operation 3.0.6
- 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 D. C. Cook Unit 2 05000-316 FACILITY NAME DOCKET NUMBER 03 13 2008 2008 003 00 05 12 2008
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)
[l 20.2201(b)
El 20.2203(a)(3)(i)
El 50.73(a)(2)(i)(C)
El 50.73(a)(2)(vii)
Mode 1 [1 20.2201(d)
El 20.2203(a)(3)(ii)
El 50.73(a)(2)(ii)(A)
El 50.73(a)(2)(viii)(A)
El 20.2203(a)(1)
El 20.2203(a)(4)
[E 50.73(a)(2)(ii)(B)
El 50.73(a)(2)(viii)(B)
[I 20.2203(a)(2)(i)
El 50.36(c)(1)(i)(A)
El 50.73(a)(2)(iii)
[] 50.73(a)(2)(ix)(A)
- 10. POWER LEVEL El 20.2203(a)(2)(ii)
[E 50.36(c)(1)(ii)(A)
El 50.73(a)(2)(iv)(A)
[E 50.73(a)(2)(x)
El 20.2203(a)(2)(iii)
[j 50.36(c)(2)
El 50.73(a)(2)(v)(A)
El 73.71(a)(4) 100%
El 20.2203(a)(2)(iv)
[1 50.46(a)(3)(ii)
[1 50.73(a)(2)(v)(B)
[
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El 20.2203(a)(2)(v)
El 50.73(a)(2)(i)(A)
[E 50.73(a)(2)(v)(C)
H OTHER Specify in Abstract below El 20.2203(a)(2)(vi) 0 50.73(a)(2)(i)(B)
[j 50.73(a)(2)(v)(D) or in (If more space is required, use additional copies of NRC Form (366A)
Conditions Prior to Event
Both Units were at 100% power.
Description of Event
On March 5, 2008, the Donald C. Cook Nuclear Plant (CNP) Unit 1 was in the process of preparing to remove the East Essential Service Water Pump (ESW) [BI] from service for scheduled maintenance while the Unit 2 East Motor Driven Auxiliary Feedwater (AFW) [BA] Pump room cooler was out of service. The Control Room Senior Reactor Operators (SROs) questioned the need for a Safety Function Determination Program evaluation based on the possible consequences of the Unit 1 East ESW pump scheduled maintenance. Due to the uncertainty of the SROs, the Unit 1 ESW pump maintenance was delayed. On March 13, 2008, a review of the circumstances of the March 5, 2008, activities determined that CNP personnel had failed to comply with Technical Specification (TS) Limiting Condition for Operation (LCO) 3.0.6.
As part of the Corrective Action Program evaluation of this event, an extent of condition evaluation for compliance with TS LCO 3.0.6 was performed. This extent of condition covered the time frame from implementation of CNP's Improved Technical Specifications (ITS) and Safety Function Determination Program on September 25, 2005, to the present. The evaluation found that CNP Operations personnel, based on the established procedures, processes, and training, were performing the equivalent reviews required by TS LCO 3.0.6, but not formally documenting the results of these reviews in accordance with TS LCO 3.0.6 and procedural requirements. The extent of condition evaluation identified that on numerous occasions (approximately 115 events), CNP personnel failed to meet the requirements of TS LCO 3.0.6 by formally documenting the review results when removing an. ESW or AFW train from service, by either entering the conditions and required actions for the supported system(s) or by performing and documenting a safety function determination. The extent of condition review found no instances of-failure to comply with TS 3.0.6 which resulted in a loss of safety function.
This licensee event report (LER) has been initiated in accordance with 10 CFR 50.73(a)(2)(i)(B) to document the numerous failures to comply with TS LCO 3.0.6.
Cause of Event
The apparent cause for this event was the lack of appropriate procedural cross references to ensure the requirements of TS LCO 3.0.6 and the Safety Function Determination Program, and its implementing procedure, were met when ITS was implemented for CNP.
The Safety Function Determination Program implementing procedure was not integrated with other operations procedures that contained steps for cross-train and cross-unit TS verifications based on changing plant conditions from planned or emergent maintenance. This resulted in insufficient rule-based guidance for the operators. In addition, the cause evaluation identified that some licensed operators believed that if the safety function of the supported system is unaffected, then TS LCO 3.0.6 does not apply. This knowledge weakness identified the need for additional training to address the proper use and implementation of TS 3.0.6.
(If more space is required, use additional copies of NRC Form (366A)
Analysis of Event
CNP performed an extent of condition investigation focusing on the applicability of TS LCO 3.0.6 against the TS requirements for ESW and AFW due to the unique cross-unit and cross-train capabilities of those systems.
This evaluation determined that, although CNP failed to perform approximately 115 evaluations required by TS LCO 3.0.6, no instances were found of failure to comply with TS 3.0.6 which resulted in a loss of safety function.
Corrective Actions
Corrective Actions Taken:
Guidance was provided to the Shift Managers to review with all licensed operators and Shift Technical Advisors, the rules of usage for TS LCO 3.0.6 and the requirements of the Safety Function Determination Program procedure.
Operations personnel commenced using the Safety Function Determination Program procedure for TS LCO 3.0.6 applicability.
Planned Corrective Actions
A Training Needs Analysis will be performed to determine the training content to be provided to Operations personnel based on the gaps identified in the cause evaluation of this event.
Procedures will be revised to integrate the Safety Function Determination Program with current Operations procedures.
Previous Similar Events
None.