05000316/LER-2004-003, Re Failure to Comply with Containment Ventilation Operability Requirements Specified in Technical Specifications 3.0.4, 3.9.4, and 3.9.9
| ML043450306 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 12/08/2004 |
| From: | Jensen J Indiana Michigan Power Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| AEP-NRC-2573-22 LER 04-003-00 | |
| Download: ML043450306 (7) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2) 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)(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)(1) 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 3162004003R00 - NRC Website | |
text
Indiana Michigan Power Company 500 Circle Drive Buchanan, MI 49107 1395 INDIANA MICHIGAN POWER December 8,2004 AEP:NRC:2573-22 10 CFR 50.73 Docket No.
50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-P1-17 Washington, DC 20555-0001 Donald C. Cook Nuclear Plant Unit 2 LICENSEE EVENT REPORT 316/2004-003-00, FAILURE TO COMPLY WITH CONTAINMENT VENTILATION OPERABILITY REQUIREMENTS SPECIFIED IN TECHNICAL SPECIFICATIONS 3.0.4,3.9.4, AND 3.9.9 In accordance with 10 CFR 50.73, "Licensee Event Report System," the following report is submitted:
Licensee Event Report (LER) 316/2004-003-00: "Failure to Comply With Containment Ventilation Operability Requirements Specified in Technical Specifications 3.0.4, 3.9.4, And 3.9.9." identifies the commitments contained in this submittal.
Should you have any questions regarding this correspondence, please contact Mr. Toby K. Woods, Compliance Supervisor, at (269) 466-2798.
Sincerely, ph N. Jensen Site Vice President RAM/jen Attachments
U. S. Nuclear Regulatory Commission AEP:NRC:2573-22 Page 2 C:
J. L. Caldwell - NRC Region III K. D. Curry - AEP Ft. Wayne J. T. King - MPSC C. F. Lyon - NRC Washington DC MDEQ - WHMD/HWRPS NRC Resident Inspector Records Center - INPO
ATTACHMENT I TO AEP:NRC:2573-22 REGULATORY COMMITMENTS The following table identifies those actions committed to by Indiana Michigan Power Company (I&M) in this document. Any other actions discussed in this submittal represent intended or planned actions by I&M. They are described to the Nuclear Regulatory Commission (NRC) for the NRC's information and are not regulatory commitments.
Commitment
Date Modify the Electronic Shift Operations January 31.2005 Management System (eSOMS) to activate and utilize an existing program feature that will identify and provide information regarding the TS impacted for clearance points contained on clearances. [CRA 04285009-03]
Establish formalized procedural controls for January 31, 2005 coordination between scheduling, clearance, and work groups to ensure plant impacts from clearances are identified and entered into the schedule with the appropriate logic ties.
[CRA 04285009-04]
NRC Form 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES 613012007 (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 # 2 05000-316 1 of 4
- 4. TITLE Failure To Comply With Containment Ventilation Operability Requirements Specified In Technical Specifications 3.0.4, 3.9.4, and 3.9.9
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED SEQUENTIAL I REVISION FACILITY NAME DOCKET NUMBER MONTH DAY YEAR YEAR l
NUMBER NUMBER MONTH DAY YEAR Unit 1 05000-315 FACILITY NAME DOCKET NUMBER 10 09 2004 2004 003 00
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)
Mode 6 0 20.2201 (b) 0 20.2203(a)(3)(i)
El 50.73(a)(2)Ci)(C)
El 50.73(a)(2)(vii) o 20.2201(d) 0 20.2203(a)(3)(ii) 0 50.73(a)(2)(ii)(A)
El 50.73(a)(2)(viii)(A) o 20.2203(a)(1)
El 20.2203(a)(4) 0 50.73(a)(2)(ii)(B)
El 50.73(a)(2)(viii)(B) 0 20.2203(aX2)(i) 0 50.36(c)(1)(i)(A) 0 50.73(a)(2)(ii()
0 50.73(a)(2)(ix)(A)
- 10. POWER LEVEL El 20.2203(aX2)(ii) 0 50.36(c)(1)(ii)(A)
El 50.73(a)(2)(iv)(A)
El 50.73(a)(2)(x) 0%
0 20.2203(a)(2)(iii) 0 50.36(c)(2)
El 50.73(a)(2)(v)(A)
E 73.71(a)(4) 0% 20.2203(a)(2)(iv) 0 50.46(a)(3)(ii)
El 50.73(a)(2)(v)(B) 73.71 (a)(5) 0 20.2203(a)(2)(v)
El 50.73(a)(2)(1)(A) 0 50.73(a)(2)(v)(C)
H OTHER Specify In Abstract below El 20.2203(a)(2)(vi)
ID 50.73(a)(2)(i(B)
D 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 2 -
MODE 6
Description of Event
At 1330 hours0.0154 days <br />0.369 hours <br />0.0022 weeks <br />5.06065e-4 months <br />, on October 9, 2004, Indiana Michigan Power Company (I&M) established a clearance in Unit 2 to facilitate calibration of time delay relays. As part of the clearance, breakers supplying power to both trains of the solid state protection system (SSPS) outputs were opened.
This disabled the automatic actuation of both trains of the containment ventilation isolation (CVI) and manual phase "A" containment isolation.
At 1441 hours0.0167 days <br />0.4 hours <br />0.00238 weeks <br />5.483005e-4 months <br />, on October 9, 2004, movement of fuel from the reactor vessel to the spent fuel pool commenced.
At this point, the requirements of Technical Specifications (TS) 3.9.9, 3.9.4, and 3.0.4 were not met.
TS 3.9.9 requires that the containment purge isolation system be operable during core alterations or fuel movement. TS 3.9.4 requires containment penetration closure capability during fuel movement.
TS 3.0.4 prohibits entry into a mode or applicability condition when the requirements of the applicable TSs are not met.
Late in the day on October 10, 2004, the clearance was lifted and CVI returned to operable status and compliance with TS 3.9.9, 3.9.4, and 3.0.4 was restored.
At 0020 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />, on October 11, 2004, during an investigation into an unexpected component operational response, I&M discovered the above discussed TS violations.
Upon identification of the concern, I&M conducted an extent of condition review.
This review identified two similar historical events for Unit 1. The similar historical Unit 1 events occurred on May 11, 2002, through May 13, 2002, and October 26, 2003, through October 30, 2003.
These events did not result in both trains of containment ventilation system inoperable, therefore the safety function remained.
This licensee event report is being submitted in accordance with the requirements of 10 CFR 50.73(a)(2)(V)(C) as an event or condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to control the release of radioactive material and in accordance with the requirements of 10 CFR 50.73(a)(2)(i)(B) as a condition which was prohibited by the plant's TS for the Unit 2 October 10, 2004, event.
Additionally, this licensee event report is being submitted in accordance with the requirements of 10 CFR 50.73(a)(2)(i)(B) as a condition which was prohibited by the plant's TS for the historical Unit 1 events noted above.
(if more space is required, use additional copies of NRC Form (366A)
Cause of Event
The root causes of this event were:
Root Cause 1:
The failure to properly identify and logic sequence the clearance order into the outage schedule, including establishment of necessary logic ties, to preclude conflict with other incompatible outage activities and to support TS requirements.
Root Cause 2: The failure of the clearance issuer to identify the adverse impact of the clearance on the plant.
Analysis of Event
Based upon a qualitative assessment, it has been determined that there is no change in risk with respect to core damage and large early release frequency from the unavailability of the automatic actuation of containment purge and exhaust isolation system.
The actual safety significance of this event was small.
Operators could have manually closed the CVI valves individually from the control room at any time during the event.
Procedures were in place to direct this response; therefore, the manual isolation function remained available.
The containment radiation monitors and high radiation alarm function remained operable.
Corrective Actions
Immediate Corrective Actions:
- The refueling procedure guidelines were revised to incorporate a requirement to hang caution tags on the breakers supplying power to the SSPS output bays.
Caution tags will also be hung to ensure that the SSPS output bay mode select switches remain in "operate" (needed for CVI operability).
- A review was performed of all clearances involving power supplies, including clearances used in the outage to date, currently hanging clearances, and clearances scheduled to be used during the outage.
This review included an evaluation for appropriate logic ties and verification that no TS conflicts existed. No issues with similarity to this event were identified.
- The outage schedule was reviewed to identify any medium or high risk activities that were not previously identified as such.
This action ensured that additional barriers were in place for activities such as the removal of power from the SSPS output bays.
(If more space is required, use additional copies of NRC Form (366A)
Corrective Actions To Prevent Recurrence:
Root Cause 1:
- Modify the Electronic Shift Operations Management System (eSOMS) to activate and utilize an existing program feature that will identify and provide information regarding the TS impacted for clearance points contained on clearances.
[CRA 04285009-03]
- Establish formalized procedural controls for coordination between scheduling, clearance, and work groups to ensure plant impacts from clearances are identified and entered into the schedule with the appropriate logic ties.
[CRA 04285009-04]
Root Cause 2:
- Modify the eSOMS system to activate and utilize an existing program feature that will identify and provide information regarding the TS impacted for clearance points contained on clearances. [CRA 04285009-03]
Previous Similar Events
Unit 2 LER 05000-316/2002-002-00, "Technical Specification 3.9.4.c was Violated During Core Alteration."
A review of the causes and corrective actions associated with this LER demonstrated that the root cause and corrective actions for LER 05000-316/2002-002-00 were substantively different and could not have prevented the event reported in LER 05000-316/2004-003-00.