ML17325A933

LER 88-009-00:on 880829,while Technician Changing Out Particle Filters & Iodine Cartridges,Open Pathway from Containment Atmosphere to Auxiliary Bldg Established.Caused by Inadequate Procedure.Procedure revised.W/880928 Ltr

ML17325A933
Person / Time
Site:	Cook
Issue date:	09/28/1988
From:	Will Smith, Wojcik J INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
LER-88-009, LER-88-9, NUDOCS 8810070042
Download: ML17325A933 (6)

Text

gC CELZRA BUTlON DZSTRZBUTZOt'EN DEMONS. TION SYFI'EM REGULA ZNEORNA ZON (RZDS)

QACCESSZON NBR:8810070042 DOC.DATE: 88/09/28 NOTARZZED: NO DOCKET FACIL:5G-315 Donald C. Cook Nuclear Power Plant, Unit 1, Indiana & 05000315 50-316 Donald C. Cook Nuclear Power Plant, Unit 2, Indiana & 05000316 AUTH. NAME AUTHOR AFFILIATION WOJCIKzJ.T. Indiana Michigan Power Co. (formerly Indiana & Michigan Ele.

SMZTHgW.G. Indiana Michigan Power Co. (formerly Indiana & Michigan Ele RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 88-009-00:on 880829,non-compliance w/Tech Specs due to open pathway from containment during core alteration.

W/8 ltr.

DISTRIBUTION CODE: ZE22D COPIES RECEIVED:LTR ENCL J SIZE:

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

NOTES:

RECIPIENT COPIES RECIPIENT COPIES ZD CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD3-1 LA 1 1 PD3-1 PD 1 1 STANGzJ 1 1 INTERNAL: ACRS MICHELSON 1 - 1 ACRS MOELLER 2 2 ACRS WYLIE 1 1 AEOD/DOA 1 1 AEOD/DSP/NAS 1 1 AEOD/DSP/ROAB 2 2 AEOD/DSP/TPAB 1 1 ARM/DCTS/DAB 1 1 DEDRO 1 1 NRR/DEST/ADS 7E 1 0 NRR/DEST/CEB 8H 1 1 NRR/DEST/ESB 8D 1 1 .

NRR/DEST/ICSB 7 1 1 NRR/DEST/MEB 1 1 NRR/DEST/MTB 9H 1 1 8D 9H'RR/DEST/PSB 1 1 NRR/DEST/RSB 8E 1 1 NRR/DEST/SGB 8D 1 1 NRR/DLPQ/HFB 10 ll 1 1 NRR/DLPQ/QAB 10 1 1 NRR/DOEA/EAB NRR/DREP/RPB 10 NUDOCS-ABSTRACT RES TELFORD,J 1

2 1

1 1

2 1

1 REG FI

~SIR

'2 NRR/DREP/RAB 10 S SIB 9A DEPY 1

1 1

1 1

1 1

1 RES/DSZR/EIB 1 1 RGN3 FILE 01 1 1 EXTERNAL 'G&G WILLIAMS S E 4 4 FORD BLDG HOY,A 1 1 H ST LOBBY WARD 1 1 LPDR 1 NRC PDR 1 1 NSZC HARRIS,J 1 1 NSIC MAYS,G 1 1 TOTAL NUMBER 'OF COPIES REQUIRED: LTTR 46 ENCL 45

0

~ \

NRC Form 388 U.S. NUCLEAR REOULATORY COMMISSION (94)3 I APPROVED OMB NO. 31504104 LICENSEE EVENT REPORT (LER) EXPIRES: 8/31/88 FACILITY NAME (1) DOCKET NUMBER (2) PAGE 3 D. C. Cook Nuclear Plant, Unit 2 o s o o o 316 ioF03 Non-compliance With Technical Specifications Due to Open Pathway Prom Containment During Core Alteration'and Fuel Movement EVENT DATE (5I LER NUMBER (8) REPORT DATE (7) 01'HER FACILITIES INVOLVED (8)

SEOUENTIAL REVS~

MONTH OAY YEAR YEAR 8:  :

NUMBER MONTH OAY YEAR FACILITYNAMES DOCKET NUMBER(S)

NUMBER D. C. Cook, Unit 1 o so o o315 0 29 88 88 0 0 9 0 0 0 9 2 8 8 8 0 5 0 0 0 THIS REPORT IS SUBMITTED PURSUANT T 0 THE AEOUIAEMENTS OF 10 CFR (): /C/seek one or morr of rhe fo/fovf/np/ (11 OPERATINQ MODE (8) 20.402(bl 20.405(c) 50.73(e I (2) I Iv) 73.71(b)

POWER 20.405(e I (1)(i) SOW(cl(I) 50.73(e) l2)(v) 73.71(cl LEVEL (10) 20.405(e)(1) (ii) 50.38(cl(2) 50.73(e) (2)(vil) DTHER /specify /n 4osrrect orfovrend /n Trrrt, f/RC Form 20.405( ~ l(1) illl) X SODS(el(2)ID 50.73(el(2)(villi(BI 50.73(el(2) (vill)(A) 366A) 20AOS (I I (1)(iv) 50.73( ~ l(2)(Q) 20.405(el(1)(vl 50.73(e) 12) IIIII 50.73 le) (21(e)

LICENSEE CONTACT FOR THIS LER (12)

NAME TELFPHONE NUMBER J. T. Wojcik Technical Physical Sciences AREA CODE Superintendent 6 16 465 -59 01 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

MAHUFAC REPD1 TR8 LR',)~MINIg;, MANUFAC. EPORTABLE CAUSE SYSTEM COMPONENT TURER CAUSE SYSTEM COMPONENT TURER TO NPADS I!&<NI

~M SUPPLEMENTAL RFPORT EXPECTED (14) MONTH OAY YEAR EXPECTED SU 8 MISSION DATE (15)

YE5/lf yrs, complerr EXPECTED Sl/Bet/$ $ /DIV DATE/ NO AssTAAcT /Limit to /coo sprees, fr., rppror/merely fifteen slnple.specs typrvr/Iten lines/ (18)

On August 29, 1988, it'as identified that for short periods of time (typically two to five minutes) while a radiation protection technician was changing out the particulate filters and iodine cartridges for the lower containment monitors, an open pathway from the containment atmosphere to the auxiliary building was established. The change out is performed at least once per day, and the same procedure has been followed since these monitors were installed on Unit 1 and Unit 2 in 1985. The condition is unique to the containment integrity requirements during core alterations due to the fact that there is no automatic containment isolation signal operable

.for the'radiation monitoring system during this mode of operation.

The cause of this event was an inadequate procedure which allowed the particulate filters and iodine cartridges to be changed during core alteration conditions without first establishing positive containment isolation.

When this condition was identified core alteration and fuel movement for the current Unit 2 refueling outage had ceased. As preventive action, procedure r:"12 THP 6010 RADR124 has been revised to include steps to isolate the sample inlet prior to changing particulate filters and iodine cartridges.

Cgl OQsr Qos,7 PDR i'IDQ:;IF. 0,/000."3) r3 j )r7pr3 7

S r/)qt)

NRC Form 388 (94)3)

)SNC Form 38M U.S. NUCLEAR REGULATORY COMMISSION (94)3)

LICENSEE NT REPORT (LER) TEXT CONTINUA N APPROVEO OMB NO. 3(SBM(84 EXPIRES: 8/31/88 ACILITYNAME (11 COCK ET NUMBE R (2) LER NUMBER (6) PAGE (3)

YEAR SEGVENTIAL REVISION NVMSER NUMBER D. C. Cook Nuclear Plant, Unit 2 0 6 0 0 0 3 ] 8 0 0 0 2 OF 0 3 8 0 0 9 TEXT //P/INYs EPscs /4 /sES)sI/, //Ss /dE/4/M////IC Fem/38849/ (17)

Conditions Prior to Occurrence Unit 1 at 90 percent reactor thermal power, Unit 2 refueling..

Descri tion of Event On August 29, 1988, during a drawing review for a refueling integrity procedure revision, it was identified that for short periods of time (typically two to five minutes) while a radiation protection technician was changing out the particulate filters and iodine cartridges for the lower containment radiation monitors (ERS-1300 and ERS-1400 in Unit 1 and ERS-2300 and ERS-2400 in Unit

2) (EIIS/IL-MON) an open pathway from the containment atmosphere to the auxiliary building was established. The particulate filter and iodine cartridge change out was performed per an approved procedure with the radiation protection technician present through the entire change out procedure. The change out is performed at least once per day,, and the same procedure has been followed since these monitors were installed on Unit 1 and on Unit 2 in 1985. The condition is unique to the containment integrity requirements during core alterations due- to the fact that there is no automatic containment isolation signal operable for the radiation monitoring system during this mode of operation. Since this condition was not recognized during previous refueling outages, the open pathway may have existed during previous core alterations or movement it is very likely that of irradiated fuel within the containment building.

No inoperable structures, components, or systems contributed to the significance of this event.

Cause of Event This event was caused by the procedural inadequacy which allowed the particulate filters and iodine cartridges to be changed during core alteration conditions without first establishing positive containment isolation.

Anal sis of the Event This event is considered a failure to comply with Technical Specification 3.9.4 Action Statement requirements in that core alterations or movement of irradiated fuel within the containment building were not suspended while the particulate filters and iodine cartridges were being changed and therefore reportable under 10 CFR 50.73(a)(2)(i).

NRC FORM SSSA '*U.S.GPO:1986 0 624 538/455 (983)

oC Fore 38oA U.S. NUCLEAR REGULATORY COMMISSION (883(

LICENSEE NT REPORT (LER) TEXT CONTINUA N APPROVEO OMB NO. 3150M(04 EXPIRES: 8/31/88 ACILITYNAME (11 OOCKET NUMBER (21 LER NUMBER (BI PAGE (3)

YEAR NS?: SEOVENTIAL 'r 8 REVISION NS NUMBER 'iNS NUMBER D. C. Cook Nuclear Plant, Unit 2 o s o o o 3 1 6 8 8 0 0 9 0 0 0 3 oF 0 3 TEXT ///'/Roro <<oco /4 '////rorL Irro //I/orN//VRC %%dr(II 38843 / (17)

The existence of the direct pathway from the containment atmosphere for the two to five minutes while the particulate filters and iodine cartridges were being changed would not significantly increase the offsite doe from a fuel handling accident within the containment based on the following facts; (1) the short duration that the open pathway existed, (2) there was always a radiation protection technician present that immediately could have isolated the pathway, (3) the small size of the penetration (one inch diameter pipe) and (4) similar evolutions such as opening a manual isolation valve in containment atmosphere sampling line on an intermittent basis under administrative control to obtain grab samples is permitted by the Technical Specifications. Thus the health and safety of the public were not affected by this event.

Corrective Action When this condition was identified core alteration and fuel movement for the current Unit 2,refueling outage had ceased. As preventive action procedure

"'"12 THP 6010 RAD.124 has been revised to include steps to isolate the sample inlet line prior to changing particulate filters and iodine cartridges.

Failed Com onent'dentification No component failures were identified during this event.

Previous Similar Events None.

NRC FORM SSEA *U.S.GPO:1088 0.824 538/455 (84LII

Indiana Michigan Power Company Cook Nuclear Plant P.O. Box 458

~

~

Bridgman, Ml 49106 616 465 5901 Z

2NEMAR$4 MCMCMH PCbVGR September 28, 1988 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Operating License DPR-58 Docket No. 50-316 Document Control Manager:

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

88-009-00 Sincerely, Plant Manager WGS:clw Attachment cc: D. H. Williams, Jr.

A. B. Davis, Region M. P. Alexich III P. A. Barrett J. E. Borggren R. F. Kroeger NRC Resident Inspector J. F. Stang, NRC R. C. Callen G. Charnoff, Esq.

Dottie Sherman, ANI Library D. Hahn INPO PNSRC A. A. Blind S. J. Brewer/B. P. Lauzau.