05000316/LER-2004-003

LER-2004-003, Failure To Comp y With Containment Ventilation Operability Requirements Specified In Technical Specifications 3.0.4, 3.9.4, and 3.9.9

Docket Number
Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(V)(C) 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3162004003R00 - NRC Website

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) events noted above.

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.

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.