ML17326A049

LER 99-016-00:on 990615,TS Requirements for Source Range Neutron Flux Monitors Not Met.Caused by Failure to Understand Design Basis of Plant.Procedures Revised.With 990713 Ltr

ML17326A049
Person / Time
Site:	Cook
Issue date:	07/13/1999
From:	Bakken A, Snodgrass D INDIANA MICHIGAN POWER CO., INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-99-016, LER-99-16, NUDOCS 9907200116
Download: ML17326A049 (6)

Text

CATEGORY REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9907200116, DOC.DATE: 99/07/13 NOTARIZED: NO FACIL:50-315 Donald C. Cook Nuclear Power Plant, Unit 1, Indiana M DOCKET 05000315 I

AUTH,NAME AUTHOR AFFILIATION SNODGRASS,D.D. Indiana Michigan Power .Co. (formerly Indiana & Michigan Ele BAKKEN,A.C. 'ndiana Michigan Power Co. (formerly Indiana & Michigan Ele RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 99-016-00:on "990615,TS requirements for source range neutron flux monitors not met.Caused by failure to understand design basis of plant. Procedures revised. With 990713 ltr.

DISTRIBUTION CODE: IE22T COPIES RECEIVED: LTR 7 ENCL i 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 LTTR ENCL LPD3-1 PD 1 1 STANG, J 1 1 INTERNA  : FILE CE E 1 . 1 NRR/CPM/ IOLB 1 1 REXB 1 1 NRR/DSSA/SPLB 1 1 RES/DET/ERAB 1 1 RES/DRAA/OERAB 1, 1 RGN3 FILE 01 1, 1 EXTERNAL: L ST LOBBY WARD 1 1 LMITCO MARSHALL 1 1 NOAC POORE,W. 1 1 NOAC QUEENER,DS 1 '1 NRC PDR 1 1 NUDOCS FULL TXT 1 1 NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LIS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTR DESK (DCD) ON EXTENSION 415-2083 FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 15 ENCL 15

Indiana riichigan Power Company Cook wtdear Plant

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One COOk rr1anr rridgnatb N 49106 616 465 590)

IRON MA NICHIGAN POMfER July 13, 1999 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Operating License DPR-58 Docket No. 50-315 Document Control Manager:

In accordance with the criteria established by 10 CFR 50.73 entitled Licensee Event Re ort

~estem the following report is being submitted: .

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LER 315/99-016-00, "Technical Specification Requirements for Source Range Neutron Flux Monitors Not Met".

There are no commitments identified in this LER.

Sincerely, A. Christopher Bakken, III Site Vice President

/mbd Attachment J. E. Dyer, Region III R. P. Powers P. A. Barrett G. P. Arent R. Whale D. Hahn Records Center, INPO NRC Resident Inspector

'gr907200ii6 9ir07i3 0500031.5 PDR ADQCK S PDR

Rh136r) U.S. NIICLEAR REGUL Y COMihllSSION APPROV OMB No. 3160.0104 EXPIRES 06/30/2001 LICENSEE EVENT REPORT (LER) Estimated burden per response to comply with this mandatory information collecuon request: 50 hrs, Reported lessons learned are incorporated alto the Bcensing process and fed back to industry. Foward comments regarding burden (Sec reverse for required number of estimate to the Records Management Branch (T.B F33), U.S. No@ear Regulatory Convnission, Washington, DC 20555400t and to the Paperwork Reduction

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digits/characters for each block) Project (3ISOOI04), Ogffxxi Of Management and Budget. Washington. DC 20503.

If an Information collection does not display a currently vatid OMB control number the NRC may not conduct or sponsor, and a person is not required to respond to, the information collect'on.

FACH.ITY NARIE (I) DOCKET NUhtBER (2) PAGE (3)

Cook Nuclear Plant Unit 1 05000-315 1 OF 3 TITLE ta)

Technical Specification Requirements for Source Range Neutron Flux Monitors Not Met EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTIIER FACILITIES INVOLVED(8)

MONTH DAY YEAR YEAR SEQUENTIAL REVISION MONTH DAY YEAR FACILITYNAME DOCKET NUMBER NUMBER NUMBER 1999 FACILITYNAME DOCKET NUMBER Cook Nuclear Plant Unit 2 05000-316 OPERATING THIS REPORT IS SUBh1ITTED PURSUANT TOTIIE REQ UI REM ENTS OF 10 CFR g: (Check onc or niore) (11) hlODE (9) a v a a VIII 20.2203(a)(l) 20.2203(a)(3)(i) 50.73(a)(2)(ii) 50.73(a)(2)(x)

LEVEL(10) a II a II I 20,2203(a)(2)(ii) 20.2203(a)(4) 50.73(a)(2)(iv) OTHER a ui ci y n1 street ow or ill 1PRC Form F 366A a Iv a vn LICENSEE CONTACT FOR TIIIS LER NAhlE TELEPHONE Nuhf BER (Include Area Code)

Mr. Dennis D. Snodgrass, Compliance Engineer (616) 465-5901 X1627 COhlPLETE ONE LINE FOR EACII COMPONENT FAILURE.DESCRIBED IN TIIIS REPORT (13)

CAUSE SYSTEht COMPONENT MANUFACTURER REPORTABLE CAUSE SYSTEht COMPONENT MANUFACTURER REPORTABLE TO EPIX TO EPIX X YES SUPPLEh1ENTAL REPORT EXPECTED (14)

NO EXPECI'ED MONTH 09 15'EAR DAY 1999 (Ifyes, complete EXPECTED SUBMISSION DATE).

ABSTRACT (Limit to 1400 spaces, i.c., approximately l5 single-spaced typewritten lines) (16)

On June 15, 1999 at 1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br /> EST with both units in Mode 5, the Source Range Nuclear Instrumentation channels on both Units were determined to be inoperable. The Expanded System Readiness Review identified that the Technical Specification (T/S) 3.3.1.1 and T/S 3.9.2 surveillance tests did not verify the Source Range "High Flux at Shutdown" alarm operable. This alarm function is required to be operable during modes 3, 4, 5 and 6. On June 15, 1999 at 2013 hours0.0233 days <br />0.559 hours <br />0.00333 weeks <br />7.659465e-4 months <br /> EST an ENS report was made in accordance with 10 CFR 50.72(b)(2)(iii)(D) for an event that could have prevented the fulfillment of the safety function of a system needed to mitigate the consequences of an accident. This LER is therefore submitted in accordance with 10 CFR 50.73(a)(2)(v)(D), and is also reportable per the requirements of 10 CFR 50.73(a)(2)(i)(B), as a condition prohibited by the plant's T/S.

The apparent cause of this event is failure to understand the design basis of the plant. Upon declaring the Source Range Nuclear Instrumentation channels inoperable, Operations entered the action statements for T/S 3.3.1.1. Additional compensatory measures implemented by Operations included hourly checks of Source Range instrumentation response and the "High Flux at Shutdown" alarm clear. The surveillance procedures were revised and the "High Flux at Shutdown" alarm was.verified operable June 17, 1999 on ehch Unit.

The Source Range "High Flux at Shutdown" alarm and the containment evacuation horns share common circuitry. When the containment evacuation horns are verified operable by surveillance test, the "High Flux at Shutdown" alarm is received but not documented. Although not verified in the past by surveillance test, it is our belief the alarm has been functional. Therefore, there were minimal implications to the health and safety of the public as a result of this event.

i<ill 3GGA U.S. NUCLEAR I LATORY CoillMISSIOiN LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITYiNA ME (I) DOCKET (2) LER N(ijlllIER (G) PACE (3)

Null DER (2)

Cook Nuclear Plant Unit 1 05000-315 YEAR SEQUENTIAL NUMBER REVISION 2 OF 3 NUMBER 1999 016 00 TEXT (Ifmore space is required, use additional copies ofPRC Fornr 3GGrI) (17)

Conditions Prior To Event Unit 1 Mode 5 in Cold Shutdown Unit 2 Mode 5 in Cold Shutdown Descri tion Of The Event On June 15, 1999 at 1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br /> EST with both units in Mode 5, the Source Range Nuclear Instrumentation (EIIS: IG) channels for both Units were determined to be inoperable. The Expanded System Readiness Review identified that the Technical Specification (T/S) 3.3.1.1 and T/S 3.9.2 surveillance tests did not verify the Source Range "High Flux at Shutdown" alarm (EIIS: IG/RA) operable. This alarm is credited in the licensing basis for detection and mitigation of a boron dilution event and is required to be operable during modes 3, 4, 5 and 6.

During the event investigation, the Source Range "Loss of Detector Voltage" alarm was also identified as not being verified operable by T/S surveillance test. This alarm is not explicitly credited in T/S or the Updated Final Safety Analysis Report but is relied upon to determine T/S equipment failure.

Cause Of The Event The apparent cause of this event is failure to understand the design basis of the plant. Misapplication of the IEEE 279, 1968 definition of "channel resulted in the channel "High Flux at Shutdown" alarm being determined as not requiring operability verification. The IEEE 279, 1968 definition. of "channel" states that a channel loses its identity when single action signals are combined. The alarm did not meet the IEEE 279, 1968 definition of "channel" for channel functional verification since both Source Range channels share the alarm. It was apparently overlooked that the alarm is credited in the licensing basis for detection and mitigation of a boron dilution. Consequently, operability verification has not been documented for the alarm on either Unit.

Anal sis Of The Event On June 15, 1999 at 2013 hours0.0233 days <br />0.559 hours <br />0.00333 weeks <br />7.659465e-4 months <br /> EST an ENS report was made per 10 CFR 50.72(b)(2)(iii)(D), an event that alone could have prevented the fulfillment of the safety function of a system that is needed to mitigate the consequences of an accident.

The Source Range channels on Units 1 and 2 were determined to be inoperable when it was identified that the Source Range "High Flux at Shutdown" alarm was not verified by T/S 3.3.1.1 and T/S 3.9.2 surveillance tests. This LER is therefore submitted in accordance with 10 CFR 50.73(a)(2)(v)(D), and is also reportable per the requirements of 10 CFR 50.73(a)(2)(i)(B), as a condition prohibited by the plant's T/S.

The primary function of nuclear instrumentation is to,safeguard the reactor by monitoring the neutron flux and generating appropriate trips and alarms for various phases of reactor operating and shutdown conditions. The Source Range nuclear instrumentation provides control room indication, alarms and recording of signals proportional to reactor neutron flux during core loading, shutdown, startup as well as during subsequent refueling.

T/S 3.3.1.1 requires one channel of the source range neutron flux monitors to be operable in Modes 3, 4 8 5.

T/S 3.9.2 requires two source range neutron flux monitors operable in Mode 6.

1 T/S definitions requires the verification of "alarm and/or trip functions" to satisfy surveillance requirements. The source range "High Flux at Shutdown" alarm operability verification has not been documented for either Unit.

The containment evacuation horns operability is verified by surveillance test. The containment evacuation horns and the Source Range "High Flux at Shutdown" alarm share common circuitry. The "High Flux at Shutdown" alarm is received but not documented when the containment evacuation horns response to high flux signals is verified by the surveillance test.

Although not verified in the past by surveillance test, it is our belief the alarm has been functional. Therefore, there were minimal safety implications as a result of this event.

NRC FORM 366A (G-I998)

FOIDI 3GGA U.S. NUCLEAR.R 'GULATORY COAIMISSION

'v-1998)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITYNAME (I) DOCKET (2) LER NUMBER (G) PAGE (3)

NUMBER 2)

Cook Nuclear Plant Unit 1 05000-315 YEAR SEQUENTIAL REVISION 3 OF 3 NUMBER NUMBER 1999 016 00 TEXT (lfmore space is required, use addilional copies of/VRC Form 366') (I7)

CORRECTIVE ACTIONS The Source Range channels were declared inoperable when it was identified that the Source Range "High Flux at Shutdown" alarm was'not verified by T/S surveillance tests.

Upon declaring the Source Range Nuclear Instrumentation channels inoperable, Operations entered the action statements for T/S 3.3.1.1. Additional compensatory measures implemented by Operations included hourly checks of Source Range instrumentation response and the "High Flux at Shutdown" alarm clear until the Source Range channels were declared operable on June 17, 1999.

The surveillance procedures were revised to include a documented operability verification of the Source Range "High Flux at Shutdown" alarm and the "Loss of Detector Voltage" alarm. The surveillance tests were performed to verify operability of the Units 1and 2 "High Flux at Shutdown" and the "Loss of Detector Voltage" alarms. The Unit 1 Source Range channels were both declared operable by 2347 hours0.0272 days <br />0.652 hours <br />0.00388 weeks <br />8.930335e-4 months <br /> EST June 17, 1999. The Unjt 2 Source Range channels were both declared operable by 2225 hours0.0258 days <br />0.618 hours <br />0.00368 weeks <br />8.466125e-4 months <br /> EST June 17, 1999.

AEP:NRC:1260GH, "Enforcement Actions98-150, 98-151,98-152 and 98-186 Reply to Notice Of Violation October 13, 1998", dated March 19, 1999, responded to identified programmatic weaknesses in the Technical Specification Surveillance Program and the plant Design and Licensing Basis. As part of the Restart effort, the adequacy of the T/S, surveillance program will be evaluated, This evaluation includes verification that T/S surveillance requirements for all modes of plant operation are incorporated into T/S surveillance test procedures. Also as part of the Restart effort, System and programmatic assessments in the Expanded System Readiness Reviews and Licensing Basis Reviews are reestablishing and documenting the plant's Design and Licensing Basis.

The root cause investigation for this event is ongoing. The investigation will include a review of the Operations procedures associated with the "High Flux at Shutdown" alarm, and, the UFSAR sections which address the alarm and the boron dilution event, to determine if any revisions are required. Supplemental information, including any additional corrective actions, will be provided in an update to this LER.

SIMILAR EVENTS 315/99-015-00 NRC F Rh1 . 66A (6.1998)