ML17325B480

LER 99-004-00:on 971030,failure to Perform TS Surveillance Analyses of Rc Chemistry with Fuel Removed Was Noted.Cause of Event Is Under Investigation.Corrected Written Job Order Activities Used to Control SD Chemistry Sampling

ML17325B480
Person / Time
Site:	Cook
Issue date:	03/18/1999
From:	Kosloff D INDIANA MICHIGAN POWER CO.
To:
Shared Package
ML17325B477	List: ML17325B475 ML17325B480
References
LER-99-004, LER-99-4, NUDOCS 9903260069
Download: ML17325B480 (2)

Text

NRC Form 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB No. 31504)104 EXPIRES 06I30/2001 (6-1998) ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH TISS MANDATORY DIFORMATIONCOLLECTK)N REGUEST: 50.0 HRS. REPORTED LESSONS LEARNED ARE DICORPORATED OITO THE LICENSING PROCESS'AND FED BACK TO INDUSTRY.

LICENSEE EVENT REPORT (LER)

(See reverse for required number of P~

FORWARD COMMENTS REGARDOIG BURDEN ESTIMATE TO THE INFORMATION AND RECORDS IMNAGEMENT BRANCH IT4 FSS), LLS. NUCLEAR REGIAATORY COMIBSSIOIL WASISNGTON. OC 2055$ 4001, AND TO THE PRO)ECT IS1504104), OFFICE OF MANAGEMENT AND BUDGET, WASHrNGTON. DC 20$ 05 REDUCTION I

digits/characters for each block)

FACIUTY NAME I ),1 DOCKET NUMBER I2) PAGE IS)

Cook Nuclear Plant Unit 1 05000-315 1 of1 TITLE l4)

Failure to Perform Technical Specification Surveillance Analyses of Reactor Coolant Chemistry with Fuel Removed EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8)

A ILI NAM NUM SEQUENTIAL REVISION D.C. Cook, Unit 2 05000-316 MONTH DAY YEAR YEAR NUMBER NUMBER MONTH DAY YEAR A ILI NAM Oc NUMB 10 30 1997 1999 004 00 03 18 1999 OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR g: (Check one or mo re). (11)

MODE (9) 20.2201 (b) 20.2203(a)(2)(v) 50.73(a)(2)(i) 50.73(a)(2)(viii)

POWER 20.2203(a)(1) 20.2203(a)(3)(i) 50.73(a)(2)(ii) 50.73(a)(2)(x)

LEVEL(10) 00 73.71 20.2203(a)(2)(i) 20.2203(a)(3)(ii) 50.73(a)(2)(iii) 20.2203(a)(2)(ii) 20.2203(a)(4) 50.73(a)(2)(iv) OTHER .

20.2203(a)(2)(iii) 50.36(c)(1) 50.73(a)(2)(v)

Specify ln Abstract below 20.2203(a)(2)(iv) 50.36(c)(2) 50.73(a)(2)(vii) or nNRC Form 366A LICENSEE CONTACT FOR THIS LER (12)

TELEPHONE NUMBER tincbde Area Code)

Mr. Donald C. Kosloff, Compliance Engineer 616/465-5901, X2129 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

REPORTABLE REPORTABLE TO CAUSE SYSTEM COMPONENT MANUFACTURER TO EPIX CAUSE SYSTEM COMPONENT MANUFACTURER EPIX SUPPLEMENTAL REPORT EXPECTED (14) EXPECTED MONTH DAY X YES SUBMISSION 05 28 1999 (If Yes, complete EXPECTED SUBMISSION DATE) NO DATE 15)

Abstract (Limit to 1400 spaces, I.e., approximately 15 single-spaced typewritten lines) (16)

On February 16, 1999, chemistry department personnel determined that Unit 2 reactor coolant system (RCS) chemistry had not been analyzed for fluorides and chlorides, as required by Technical Specification (TS) Surveillance Requirement 4.4.7, while the unit was in an undefined operating mode with all fuel removed from the RCS. The analyses, required "At all times," were not performed from October 30 to November 23, 1997. Unit 2 has remained in Mode 5 or 6 since that time. Additional investigation identified at least seven other periods, for both units, when the chemistry analyses had not been performed.'S ClariTication ¹54 was in force during these seven periods, and provided an inappropriate exemption from sampling while the core was off-loaded and RCS circulation was suspended. Since there was no evidence of an out-of-limit chemistry condition, in each case the limiting condition for operation required action for TS 3.4.7 was not taken, in that an analysis was not performed to determine the effects of a possible out-of-limit condition. As the surveillance requirements were not met, this event is reportable under 10CFR 50.73(a)(2)(i)(B), as operation prohibited by the Specifications.

plants'echnical TS Clarification ¹54 was cancelled on July 23, 1997. However, by the time the TS clarification was cancelled, the chemistry department had established written direction stating that when fuel was removed from the RCS, the spent fuel pool became the RCS for chemistry sampling purposes. Chemistry personnel have been instructed on the requirement to follow the TS as written without reliance on the use of TS clarifications or interpretations. The written job order activities used to control shutdown chemistry sampling were corrected to remove references to the spent fuel pool as an alternate RCS sample point. In each identified case when analyses were not done, the affected unit was at low pressure and temperature. In each identified case, analyses completed prior to and after the missed analyses provided no indication of an out-of-limit condition. The root cause investigation for this event is not complete. When the root cause investigation is complete an update to this LER will be submitted.

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