ML17329A726

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LER 92-009-00:on 921122,MSIV Technically Determined to Be Inoperable Due to Interpretation of TS 3.7.1.5.TS Will Be Revised to Clarify LCO & SRs to Address Mode Changes W/ Closed MSIVs.W/921221 Ltr
ML17329A726
Person / Time
Site: Cook American Electric Power icon.png
Issue date: 12/21/1992
From: Blind A, Joel Wiebe
INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-92-009-01, LER-92-9-1, NUDOCS 9212290198
Download: ML17329A726 (7)
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Text

ACCEI ERATQiL) DOCUMENT DISTH~~~VTION SYSTEM REGULAT~ INFORMATION DISTRIBUTIO~YSTEM (RIDS)

ACCESSION NBR:9212290198 DOC.DATE: 92/12/21 NOTARIZED: NO DOCKET FACZL:50-316 Donald C. Cook Nuclear Power Plant, Unit 2, Zndiana M 05000316 AUTH. NAME AUTHOR AFFILIATION WIEBEF J.S. Indiana Michigan Power Co. (formerly Indiana & Michigan Ele BLINDFA.A. Indiana Michigan Power Co. (formerly Indiana & Michigan Ele RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 92-009-00:on 921122,MSIV technically determined to be inoperable due to interpretation of TS 3.7.1.5.TS will be revised to clarify LCO & SRs to address mode changes w/ D closed MSIVs.W/921221 ltr.

DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE:

TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc.

NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME'D3-1 LTTR ENCL D PD3-1 LA 1 1 PD 1 1 DEANFW 1 1 D INTERNAL: ACNW 2 2 AEOD/DOA 1 1 AEOD/DSP/TPAB -1 1 AEOD/ROAB/DSP 2 2 NRR/DET/EMEB 7E 1 1 NRR/DLPQ/LHFB10 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA/OEAB 1 1 NRR/DREP/PRPB11 2 2 NRR/DST/SELB 8D 1 1 NRR/DST/SICB8H3 1 1 NRR/DST/SPLB8D1 1 1

-NRR/DST/SRXB 8E 1 1 02 1 1 RES/DSIR/EIB 1 1 RGN3 FILE 01 1 1 EXTERNAL EG&G BRYCE F J ~ H 2 2 L ST LOBBY WARD 1 1 NRC PDR 1 1 NSIC MURPHYFG.A 1 1 NSIC POOREIW 1 1 NUDOCS FULL TXT 1 l.

D D

D NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTETH CONTACI'HE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 29 ENCL 29

indiana Michigan Power Company

~

Cook Nuclear Plant One Cook Place Bridgman, Ml 49106 616 465 5901 INDlANA NfCHIGAN Pi'ecember 21, 1992 United States Nuclear Regulatory Commission Document Control Desk Rockville, Maryland 20852 Operating Licenses DPR-74 Docket No. 50-316 Document Control Managex".

In accordance with the criteria established by 10 CFR 50.73 entitled Licensee Event. Re ort S stem the following report is being submitted:

92-009-00 Sincerely, A. A. Blind Plant Manager

/sb c'.

Attachment H. Wi*lliams, Jr.

A. B. Davis, Region E. E. Fitzpatrick III P. A. Barrett R. F. Kxoeger B. Walters Ft. Wayne NRC Resident Inspector W. M. Dean - NRC J. G. Keppler M. R. Padgett G. Charnoff, Esq.

D. Hahn INPO S. J. Brewer B. A. Svensson 9212290198 921221 PDR ADOCK 05000316 8 PDR

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED OMB NO. 3150410C (669) ~

EXPIRES: C/30/92 ESTIMATED BUADEN PEA RESPONSE TO COMPLY WTH THIS LICENSEE EVENT REPORT ILER) COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS AND REPORTS MANAGEMENT BRANCH (P630). U.S. NUCLEAR REGULATORY COMMISSION. WASHINGTON, OC 20555, AND TO THE PAPERWORK REDUCTION PAO)ECT (3150010C), OFFICE OF MANAGEMENTANO BUDGET, WASHINGTON. OC 20503.

DOCKET NUMBER I?) PA FACILITY NAME lll D. C. Cook Nuclear Plant Unit 2 05000311OF05 TITLE ICI Mode Change with Technically Inoperable Main Steam Isolation Valves EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (SI SSOUENTIAL .jrr~n OAY YEAR FACILITYNAMES DOCKET NUMBER(S)-

MONTH DAY YEAR YEAR NUMSER NUMSSR MONTH 0 5 0 0 0 29 292 0 0 9 001 221 9 2 onr or morr of tnr forrowinp/ (ill 0 5 0 0 0 THIS REPORT IS SUBMITTED PURSUANT TO THE RLDUIREMENTS OF 10 CFR I)t /Cnectr OPERATING MODE (9) 20A02(bl ?OAOS(c) 50.73(cl(2)(tvl 73.7)(b) 20AOS(cl(ll(0 50.36lc) Ill 50.73( ~ )(2)(v) 73.71(c)

POWER LEVEL OTHER /Specify in Abrrrrcr p p p ?0AOS(e) (I ) (6 I 50.36(cl(2) 50.73(c)12)(rBI below rnd in Tref, HAC perm

?OAOS( ~ )(I)(IB) 50.73(c)(?)(1) 50 73( ~ I (2)(rill)(A) 36$ A/

20AOS(cl(1)(Iv) 50.73(cl(2)(9) 50.73( ~ l(2)(vlSI(BI 20AOS(cl(1 l(v) 50.73(c) (2) (i<<I 50,73 Iv) (2)( c I LICENSEE CONTACT FOR, THIS LER (12I TELEPHONE NUMBER NAME AREA CODE J. S. Wiebe, Safety and Assessment Superintendent 6 16 465 -59 1 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE OESCRISEO IN THIS REPORT (13)

"CAUSE SYSTFM COMPONENT MANUFAC. EPORTABLE SYSTEM COMPONENT MANUFAC TURER EPORTABL I~g+,~<<k TUAER TO NPADS MONTH DAY YEAR

'UPPLEMENTAL AEPORT EXPECTED (ICI EXPECTED SU 6 MISS ION DATE (15)

YEs //f yer. comp/err d/rpEcTED SvdMI$$ /DH DA)'d/ NO ABsTRAGT /Limit to /rrrr/ tpecrr, fr., rpprorfmrtrfy dftrrn rrnprr rover typewritrrn /inN/ IISI On November 22,'992 at 0021 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> an UNUSUAL EVENT was declared as a result of entering a Technical Specificat'ion 3.0,3 condition on UnitSteam Two. The 3.0.3 entry was made based on a determination that, although the Main Isolation Valves (MSIVs) were tagged closed for turbine generator maintenance, they were of current stroke time technically INOPERABLE as a result not having upon surveillances. A Unit Two shutdown from MODE 2 to MODE 3 was commenced determination of the valves INOPERABLE status. The Plant entered MODE 3 at 0032 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> on November 22, 1992 The S/G stop valves were considered INOPERABLE as a result of the surveillance requirements" contained in plant surveillance procedures (to verify that the stop valves close in less than 8 seconds) not being performed withinof this year. No the last 92 days.

This test had last been completed on June 13 and June 14tested.

maintenance had been performed on these valves since last Although the mode change to MODE 2 was a condition prohibited by ahad no safety conservative literal Technical Specifications interpretation, the condition significance. Additionally, since the MSIVs were in the position required for them to perform their intended safety function, the plant was never in a Technical Specification 3.0.3 condition.

NRC Form 366 (669)

NRC FORM 388A U.S, NUCLEAR REGULATORY COMMISSION APPROVEO OMB NO. 31504((04 (889) EXPIRES: 4/30(92 ESTIMATED BURDEN PER RESPONSE TO COMPLY WTH THIS LICENSEE EVENT REPORT (LER) INFORMATION COLLECTION REQUEST: 500 HRS. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS TEXT CONTINUATION AND REPORTS MANAGEMENT BRANCH IP430), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, OC 20555, AND TO THE PAPERWORK REDUCTION PROJECT (3(500(041. OFFICE OF MANAGEMENTAND BUDGET, WASHINGTON, DC 20503.

FACILITYNAME u) DOCKET NUMBER (21 LER NUMBER (8) PAGE LSI YEAR NUM Ell ~+2 FEVOKIN X& SEQUENTIAL ':i NVMPEII D. C. Cook Nuclear Plant Unit 2 0 5 0 0 0 3 ] 92 009 0 02 oF 0 5 TEXT lll~ JP444 l( nq~ u44 4dd/rionel HRC hwn 35843l ((tl Conditions Prior to'ccurrence:

Unit One in Mode 1 (Power Operation) at 55X rated thermal power.

Unit Two in Mode 2 (Startup) at approximately 10E-7 amps.

Descri tion of Event:

On November 22, 1992 at 0021 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> an UNUSUAL EVENT was declared as a result of entering a Technical Specification 3.0.3 condition on Unit Two. The 3.0.3 entry was made based on a determination that although the Main Steam Isolation Valves (EIIS: SB/ISV) (MSIVs) were tagged closed for turbine generator (EIIS: TA/GEN) maintenance, they were technically INOPERABLE as a result of not having current stroke time surveillances. A Unit Two shutdown from MODE 2 to MODE 3 was commenced upon determination of the valves INOPERABLE status.

The Main Steam Isolation valves (EIIS: SB/ISV) were considered INOPERABLE as a result of the surveillance requirements contained in "plant surveillance procedures (to verify that the MSIVs (EIIS: SB/ISV) close in less than 8 seconds) not being- performed within the last 92 days. This test had last been completed on June 13 and June 14 of this year. No maintenance had been performed on these valves since last tested.

On November 21, 1992 a review was conducted to determine if Unit Two could enter MODE Two in preparation for turbine roll. Part of this review included a determination of Technical Specifications which would be impacted by the Mode Change. One of the Technical Specifications affected is 3.7.1.5, which deals with the Main Steam Isolation Valves(EIIS: SB/ISV). It was identified that the Technical Specification allowed for entry into MODE 2 for physics testing with the surveillance not current provided the MSIVs (EIIS: SB/ISV) were maintained in the closed position. While all low power physics testing had been completed, it was determined to be allowable (satisfying the intent of the Technical Specification) to enter MODE 2 with the surveillance not current as long as the MSIVs (EIIS: SB/ISV) were maintained in the closed position.

Plant administrative guidance requires the tracking of MODE changes made when component/system surveillances are not current. With respect to the MSIVs (EIIS:

SB/ISV) this fact was recognized and the required documentation, PMI-4030 (Technical Specification Review and Surveillance) Attachment j/6 (Authorization to Change Modes With Technical Specification Equipment Out Of Service), was completed and approved by the acting Operations Department Superintendent and an Assistant Plant Manager. PMI 4030 Att. g6, to allow entry into mode 2, was approved based on the knowledge that the intent of the MSIV (EIIS: SB/ISV) time closed surveillance is to ensure the MSIVs (EIIS: SB/ISV) close to minimize the effects of a steam break accident. At the time of the mode change the MSIVs (EIIS: SB/ISV) were closed and tagged closed under a clearance permit to provide protection for work in progress on the main generator (EIIS: TA/GEN).

NRC Fo 388A (84191

NRC FOAM 355A US. NUCLEAR REGULATORY COMMISSION APPROVED OMB NO. 31500)04 15e9) EXPIRES: 4/30/92 ESTIMATED BURDEN PEA RESPONSE TO COMPLY WTH THIS LICENSEE EVENT REPORT ILER) INFORMATION COLLECTION REQUEST: 50.0 HRS. FORWARD COMMENTS REGARDING BURDEN FSTIMATE TO THE RECORDS TEXT CONTINUATION AND AE'PORTS MANAGEMENT BRANCH IP430). U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON. OC 20555, AND TO THE PAPERWORK REDUCTION PROJECT 13)504))04), OFFICE OF MANAGEMENTAND BUDGET, WASHINGTON,OC 20503.

FACILITYNAME 11I DOCKET NUMBER 12) LER NUMBER FS) PAGE ISI YEAR <<~R SBGVSNZIAL NVMeso AEYISION NUMesll D. C. Cook Nuclear Plant Unit 2 0 5 0 0 0 3 9 2 0 9 0 003 OF 0 5 TEXT /// more sosse is ser/rrired, ose sddRr'orrs/HRC Form 35EA's/ ) )2)

Descri tion of Event cont.

Based on the guidance provided on Attachment 6, entry into MODE 2 was made on November 21, 1992 at 2112 hours0.0244 days <br />0.587 hours <br />0.00349 weeks <br />8.03616e-4 months <br />.

Following the mode change, the Shift Supervisor commenced a review of the activities performed for entry into MODE 2. As part of his review, he re-evaluated the transition into MODE 2 with the,MSIVs (EIIS: SB/ISV) INOPERABLE.

At this time, he determined that changing modes with all four MSIVs (EIIS:

SB/ISV) inoperable was not in literal compliance with the ACTION STATEMENT for Technical Specification 3.7.1.5 ~ Upon determination of this finding, the Shift Supervisor contacted Operations Department Management and relayed his concerns and interpretation of the Technical Specification. Following discussions with Operations Department Management, it was concluded that a conservative approach would be to consider the unit in a Technical Specification 3.0.3 condition and perform a shutdown into MODE 3 (Hot Standby).

At 0021 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> on November 22, 1992 the Shift Supervisor declared an UNUSUAL EVENT (as a result of the unit considered being in a Technical Specification 3.0.3 condition) and made a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> report to the NRC Operations Center in accordance with 10CFR 50.72(b)(l)(i)(A). MODE 3 was entered at 0032 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> on November 22, 1992.

Cause o Event:

This event was the result of an interpretation of Technical Specification 3.7.1.5 by the acting Operations Superintendent, a Shift Supervisor and an Assistant Plant Manager to allow entry into MODE 2 by meeting the intent of the specification. This interpretation resulted in the failure to meet the literal requirements of the specification.

NRC Form 355A IM9)

NRC FOAM 368A US. NUCLEAR AEGULATOAYCOMMISSION APPR OV ED 0 M 6 NO, 3) 500)04

)669) EXPIRES: 4/30/92 ESTIMATFO BURDEN PER RESPONSE TO COMPLY WTH THIS LICENSEE EVENT REPORT (LER) INFORMATION COLLECTION REQUEST: 500 HRS, FORWARD COMMENTS REGARDING BURDE'N ESTIMA'TE TO THE RECORDS TEXT CONTINUATION AND REPORTS MANAGEMENT BRANCH IP430). U.S. NUCLEAR AEGULATORY COMMISSION. WASHINGTON. OC 20555. AND TO THE PAPERWORK REDUCTION PROJECT )31500104). OFFICE OF MANAGEMENTAND BUDGET, WASHINGTON, DC 20503.

FACILITYNAME II) DOCKET NUMBER I2I LER NUMBER )6) PAGE 13)

SEQIJENTIAL REVISION V8 A R,)3 I NuMEER NUMSER D. C. Cook Nuclear Plant Unit 2 0 6 0 0 0 3 1 6 9 0 0 9 0 004 QF 0

TEXT /// md>> EP444 /4>>9v/)Ed. P>> Edde'os/F/RC FdmI 3664'4/ I )2)

Anal sis of Event:

This event is considered reportable pursuant to 10CFR 50.73(a)(2)(i)(B), Any operation or condition prohibited by the plant's Technical Specifications. The failure to surveil the main steam isolation valves prior to entry into MODE 2 resulted in a violation of the Plant Technical Specifications.

A review of the safety significance determined that there was no safety significance associated with the plant being in MODE 2 with the MSIVs closed and the surveillance not performed. Technical Specification 4.7.1.5.3 clearly allows this condition during PHYSICS TESTING with the provision that the valves are maintained closed. It is apparent that although the mode change to MODE 2 was a condition prohibited by a conservative literal Technical Specifications interpretation, the condition had no safety significance. Additionally, since the MSIVs were in the position required for them to perform their intended safety function, a Technical Specification 3.0.3 did not exist.

A contributing factor to this event was a weakness'f the process to independently review Technical Specifications and surveillances outstanding, prior to the MODE change. A review of the process revealed that although a mode change prohibited by Technical Specifications was allowed to occur, safety significance was of prime consideration by the operating shift and management review of the decision to proceed to MODE 2 as required by the process. The process is not considered deficient from a safety significance standpoint.

The main steam isolation valves were maintained closed for the entire period of this event. In the closed position they were performing their intended safety function. As a result, this event had no impact on the health and safety of the public.

CORRECTIVE ACTION After the Shift Supervisor determined that the mode change to MODE 2 was made in error, the unit was placed in MODE 3.

To prevent recurrence of this event, the following actions will be taken:

Technical Specification 3.7.1.5 will 'be 'revised to clarify the Limiting Conditions for Operation and the survei.llance requirements to address mode changes with closed MSIVs. Both the Unit One and Two specifications will be addressed to ensure consistency.

The PMI-4030 process will be enhanced to delineate specific independent reviews which must be accomplished prior to authorization for mode changes with Technical Specification equipment inoperable or with surveillance in grace or expired.

NRC FoIm 368A (64)9)

NRC FORM 356A U.S, NUCLEAR REGULATORY COMMISSION (669) APPROVED OMB NO,31504)104 EXPIRES: 4/30/92 ESTIMATED BURDEN PER RESPONSE TO COMPLY WTH THIS LICENSEE EVENT REPORT ILER) INFORMATION COLLECTION REOUESTI 50S) HRS. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE RECORDS TEXT CONTINUATION AND REPORTS MANAGEMENTBRANCH (P4)301. U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555, AND TO THE PAPERWORK REDUCTION PROJECT 131504104I, OFF ICE OF MANAGEMENTAND BUDGET. WASHINGTON, DC 20503.

FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE 13)

YEAR :oos SEOVENTIAL ~<y> REVISION

'-46 NUMBER  :<<'%fUrsssR D. C. Cook Nuclear Plant Unit 2 0 s o o o 31 692 0 0 9 0 0 05 '"0 TEXT ///mors spsos /4 nqvwd, vso sdd/a'eel /t///C Form 3654's/ ()7)

Failed Com onent Identification:

There were no failed components associated with this condition.

Previous Similar Events:

None NRC Form 366A (6$ 9)

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