05000315/LER-2015-003, Regarding Main Feed Pump Technical Specification 3.3.2 Violation
| ML15225A466 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 08/12/2015 |
| From: | Gebbie J Indiana Michigan Power Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LER 15-003-00 | |
| Download: ML15225A466 (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 |
| 3152015003R00 - NRC Website | |
text
INDIA NA indiana Michigan Power MICHIGAN Cook Nuclear Plant POWfERn One Cook Place Bridgman, Ml 49106 A unit of American Electric Power Indiana MichiganPower~com August 12, 2015 AEP-.NRC-.201 5-77 10 CFR 50.73 Docket No.: 50-315 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike,*
Rockville, MD 20852 Donald C. Cook Nuclear Plant Unit I LICENSEE EVENT REPORT 31 5/2015-003-00 Main Feed Pump Technical Specification 3.3.2 Violation In accordance with 10 CFR 50.73, Licensee Event Report (LER) System, Indiana Michigan Power Company, the licensee for Donald C. Cook Nuclear Plant Unit 1, is submitting, as an enclosure to this letter, the following report:
LER 315/2015-003-00: "Main Feed Pump Technical Specification 3.3.2 Violation" There are no commitments contained in this submittal.
Should you have any questions, please contact Mr. Michael K. Scarpello, Regulatory Affairs Manager, at (269) 466-2649.
Sincerely, Joel P. Gebbie Site Vice President JEN/ams Enclosure c:
A. W. Dietrich - NRC Washington, DC J. T. King - MPSC MDEQ - RMD/RPS NRC Resident Inspector C. D. Pederson - NRC Region Ill A. J. Williamson - AEP Ft. Wayne
Enclosure to AEP-NRC-2015-77 LER 315/201 5-003-00
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY 0MB: NO. 3150-0104 EXPIRES: 0113112017 (02-201 4)
- o..,,,,oEstimated burden per response to comply with this mandatory collection request: 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />.
Reported lessons learned are incorporated into the licensing process and fed back to industry.
.*Send comments regarding burden estimate to the FOIA, Privacy and Information Collections "LICENSEE' EVENT REPORT (LER Branch (T-5 F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by
'I intemet e-mail to Infocollects.Resource@nrc.gov, and to the Desk Officer, Office of Information and (See Page 2 for required number of Regulatory Affairs, NEOB-10202, (3150-0104), Office of Management and Budget, Washington, DC digits/characters for each block) 20503. Ifsa means used to impose an information collection does not display a csrrentiy valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.
- 13. PAGE Donald C. Cook Nuclear Plant Unit 1 05000315 1 of 4
- 4. TITLE Main Feed Pump Technical Specification 3.3.2 Violation
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED NOT A
YA EUMERN O.A IE~FACIL NAME DOCKET NUMBER MOT A ER YEAR SEUMENILR EVO MONTH DAY YEAR 05000 JFACILITY NAME DOCKET NUMBER 0 18 21 205-o00
- - O,
00 08 12 215050
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply) lii 20.2201(b)
E 20.2203(a)(3)(i)
El 50.73(a)(2)(i)(C)
LI 50.73(a)(2)(vii)
[] 20.2201(d)
El 20.2203(a)(3)(ii)
L] 50.73(a)(2)(ii)(A)
LII 50.73(a)(2)(viii)(A)
LII 20.2203(a)(1)
El 20.2203(a)(4)
El 50.73(a)(2)(ii)(B)
LI 50.73(a)(2)(viii)(B)
[] 20.2203(a)(2)(i)
El 50.36(c)(1)(i)(A)
[II 50.73(a)(2)(iii)
LI 50.73(a)(2)(ix)(A)
- 10. POWER LEVEL El 20.2203(a)(2)(ii)
El 50.36(c)(1)(ii)(A)
El 50.73(a)(2)(iv)(A)
LI 50.73(a)(2)(x)
[II 20.2203(a)(2)(iii)
LII 50.36(c)(2)
El 50.73(a)(2)(v)(A)
[] 73.71 (a)(4)
El 20.2203(a)(2)(iv)
I]
50.46(a)(3)(ii)
El 50.73(a)(2)(v)(B)
El 73.71(a)(5) 00 E 20.2203(a)(2)(v)
L] 50.73(a)(2)(i)(A)
El 50.73(a)(2)(v)(C)
El OTHER El 20.2203(a)(2)(vi)
[] 50.73(a)(2)(i)(B)
[] 50.73(a)(2)(v)(D) specify in Abstract below or in
- 12. LICENSEE CONTACT FOR THIS LER
_ICENSEE CONTACT ITELEPHONE NUMBER (Include Area Code)
Michael K. Scarpello, Regulatory Affairs Manager (269) 466-2649CAUSE SYSTEM COMPONENT FACTURER TO EPIX f~
AS YTM CMOET FACTURER TO EPIX El YES (If yes, complete 15. EXPECTED SUBMISSION DATE)
[]
NO DATE
\\,BSTRACT (Limit to 1400 spaces, iLe., approximately 15 single-spaced typewritten lines)
On June 18, 2015, a review based on U. S. Nuclear Regulatory Commission (NRC) Information Notice (IN) 201 5-05, "Inoperability of Auxiliary and Emergency Feedwater Auto-Start Circuits on Loss of Main Feedwater,"
identified that Unit 1 is susceptible to the subject of the IN. Limiting Condition for Operation (LCO) 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation," does not have a Condition with a provision for two required channels to be inoperable at the same time, which is the case for normal startup and shutdown of the Unit I Main Feedwater (MEW) pumps and some types of maintenance and testing.
An evaluation concluded that the Unit I MFW system has been operated in a manner such that the automatic initiation of Auxiliary Feedwater on loss of all MEW pumps was disabled on multiple occasions over the past three years. This is contrary to UI LCO 3.3.2, requirements.
This condition is a legacy discrepancy between Unit 1 Technical Specifications (TS) and the Unit I MFW pump design existing since the initial operation of Unit 1.
To correct this condition, the NRC has approved an amendment to Unit 1 LCO 3.3.2 which aligns the plant design and TS requirements.
NRC FORM 366 (02-2014)
INTRODUCTION
On June 18, 2015, Donald C. Cook Nuclear Plant Unit 1 was in a forced maintenance outage for repairs to the U1 AB Emergency Diesel Generator [EK]. A review of U. S. Nuclear Regulatory Commission (NRC) Information Notice (IN) 2015-05, "Inoperability of Auxiliary and Emergency Feedwater Auto-Start Circuits on Loss of Main Feedwater," identified that Unit 1 is susceptible to the subject of the IN. Technical Specifications (TS) Limiting Condition for Operation (LCO) 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation,"
[JE] does not have a Condition with a provision for two required channels to be inoperable at the same time, which is the case for normal startup, shutdown, and some types of maintenance and testing of the Unit 1 Main Feedwater (MFW) pumps [JB][P].
An evaluation concluded that the Unit 1 MFW system has been operated in a manner such that the automatic initiation of Auxiliary Feedwater (AFW) [BA] on loss of all MFW pumps was unavailable on multiple occasions over the past three years. This is contrary to U1 LCO 3.3.2, requirements, and is being reported pursuant to 10 CFR 50.73(a)(2)(i)(B), Operation or Condition Prohibited by Technical Specifications. Additionally, the unrecognized inoperability of both MFW pump trip channels should have resulted in entry into [CO 3.0.3.to remove the unit from a mode of applicability. Not performing the actions in the time required by [CO 3.0.3 is reportable in accordance with 10 CFR 50.73(a)(2)(i)(B), Operation or Condition Prohibited by Technical Specifications.
EVENT DESCRIPTION
Following NRC IN 2015-15, "lnoperability of Auxiliary and Emergency Feedwater Auto-Start Circuits on Loss of Main Feedwater," review for applicability resulted in the determination that Unit 1 is susceptible to the subject of the IN. Analysis of Unit 1 operation for the past three years identified instances when the auto-start of AFW was unavailable due to MFW operation.
The following events and times were obtained through a review of unit de-rate logs and digital MFW pump control logs. Events were developed by trending MFW pump stop valve [JK] [VI position and evaluating when the MFW pump turbine stop valves were open with the associated MFW pump not feeding forward.
Events October 29, 2012 November 3, 2012 March 26, 2013 Power reduction to 54 percent to remove East Main Feed Pump from service due to high vibrations. AFW auto-initiation for the East Main Feed Pump was bypassed when pump was removed from service while not feeding forward.
Restoration of East Main Feed Pump following power reduction for high vibrations.
AFW auto-initiation for the East Main Feed Pump was bypassed when pump was placed in service while not feeding forward.
Downpower for the U1C25 Refueling Outage. AFW auto-initiation for the East Main Feed Pump was bypassed when pump was removed from service while not feeding forward.
May 19, 2013 May 22, 2013 December 15, 2013 September 20, 2014 October 24, 2014 November 3, 2014 Restart following the U 1 C25 refueling Outage. AFW auto-initiation for the East Main Feed Pump was bypassed when pump was placed in service while not feeding forward.
East Main Feed Pump was being returned to service following a down power for repairs. AFW auto-initiation for the East Main Feed Pump was bypassed when pump was placed in service while not feeding forward.
Following a unit downpower the East Main Feed Pump was being returned to service when AFW auto-initiation for the East Main Feed Pump was bypassed when the pump was placed in service while not feeding forward.
Downpower for the U1lC26 Refueling Outage. AFW auto-initiation for the East Main Feed Pump was bypassed when pump was removed from service while not feeding forward.
Restart following the U 1026 refueling Outage. AFW auto-initiation for the East Main Feed Pump was bypassed when pump was placed in service while not feeding forward.
Restart following unit trip. AFW auto-initiation for the East Main Feed Pump was bypassed when pump was placed in service while not feeding forward.
EVENT ANALYSIS
The trip of both MFW pumps (feed pump turbine stop valve limit switches signaling the trip) auto starting AFW is required by TS. The automatic initiation of the AFW system does not credit the MFW pump trip function for design basis accidents and transients that result in a loss of MFW and is not a safety function. The MFW pump trip auto starting AFW is an anticipatory function.
ASSESSMENT OF SAFETY CONSEQUENCES
NUCLEAR SAFETY The ESFAS instrumentation function 6.g is an anticipatory start signal for which no credit is taken in any safety analysis. The design basis events for which operation of the AFW system is required are the loss of all AC power to the plant auxiliaries, loss of normal feedwater, loss of electrical load, and small break loss of coolant accident. The analyses presented in Donald C. Cook Nuclear Plant Updated Final Safety Analysis Report, Loss of Normal Feedwater and Loss of All AC Power to the Plant Auxiliaries, state that the Steam Generator (SG) [SG] water level low-low AFW start signal is specifically credited in the analyses. Since the primary success path for accident mitigation is provided by SG low-low level signals, loss of both anticipatory trip channels does not place the plant in an unanalyzed condition.
INDUSTRIAL SAFETY There was no actual or potential industrial safety hazard resulting from the inoperable AFW Auto-Start Circuits.
RADIOLOGICAL SAFETY There was no actual or potential radiological safety hazard resulting from the inoperable AFW Auto-Start Circuits.
CAUSE
This is a legacy discrepancy between Unit 1 TS and the Unit I MFW pump design that has existed since the initial operation of Unit 1.
CORRECTIVE ACTIONS
Immediate Corrective Actions Taken This issue was identified while Unit I was in Mode 5 for a forced outage, not in a mode of applicability, as such, no immediate corrective actions were required.
Corrective Actions to Preclude Repetition To correct this condition, the NRC has approved an amendment to U1 LCO 3.3.2 which makes the plant design and TS requirements consistent. This amendment was made effective prior to Unit 1 ascending to a mode of applicability.
There are no further planned corrective actions.
PREVIOUS SIMILAR EVENTS
A review of the past three years Licensee Event Reports identified no similar events.