05000315/LER-1999-014, :on 990521,determined That Boron Injection Tank Manway Bolts Were Not Included in ISI Program,Creating Missed Exam for Previous ISI Interval.Caused by Programmatic Weakness.Isi Program & Associated ISI Database Modified

:on 990521,determined That Boron Injection Tank Manway Bolts Were Not Included in ISI Program,Creating Missed Exam for Previous ISI Interval.Caused by Programmatic Weakness.Isi Program & Associated ISI Database Modified

ML17326A015
Person / Time
Site:	Cook
Issue date:	06/18/1999
From:	Snodgrass D INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:
Shared Package
ML17326A013	List: 05000315/LER-1999-014, :on 990521,determined That Boron Injection Tank Manway Bolts Were Not Included in ISI Program,Creating Missed Exam for Previous ISI Interval.Caused by Programmatic Weakness.Isi Program & Associated ISI Database Modified
References
LER-99-014, LER-99-14, NUDOCS 9906220207
Download: ML17326A015 (4)

LER-1999-014, on 990521,determined That Boron Injection Tank Manway Bolts Were Not Included in ISI Program,Creating Missed Exam for Previous ISI Interval.Caused by Programmatic Weakness.Isi Program & Associated ISI Database Modified

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(ii) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(viii) 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(iv), System Actuation 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3151999014R00 - NRC Website

text

NRC FORM 366 U.s. NUCLEAR REGUL RY COMMISSION (6-19961

~

LICENSEE EVENT REPORT (LER)

(See reverse for required number of digits/characters for each block)

APPROVE OMB No. 3150 0104 EXPIRES 06/30/2001 Estimated burden per response to compty with this mendatoly Infoimetion cogecUon requesl: 50 tus.

Reported lessons learned are Incorporated Into the gcenslng process and fed back to Industry. Foweid comments regarding burden estimate to the Records Management Branch (TR F33), U.S, Nudeer Regulatory Commission, Washington, DC 205554001.

end to the Papetwlk ReducUon Project (31500104), Oftice of Management end Budget, Washington, OC 20503, It an hfonnegon cotlecthn does not display a cuirentfy vetkf OMB control number, the NRC mey not conduct or sponsor. end e person Is rot required to respond lo, the hfonneUon coiecUon.

FACILITYNAMEl1)

Cook Nuclear Plant Unit 1 DOCKET NUMBER (21 05000-315 PAGE (3) 1 OF 3

TITLE I4)

Requirements of Technical Specification 4.0.5 Not Met for Boron Injection Tank Bolting EVENT DATE (5)

MONTH OAY YEAR SEQUENTIAL NUMBER REVISION NUMBER LER NUMBER (6)

REPORT DATE (7)

MONTH DAY YEAR FACILITYNAME OTHER FACILITIES INVOLVED(6)

OOCKET NVMBLA OPERATING MODE (9)

POWER LEVEL (10) 1999 20.2201 (b) 20.2203(a)(1) 20.2203(a)(2)(i) 20.2203(a)(2)(v) 20.2203(a) (3) (i) 20.2203(a)(3)(ii)

THIS REPORT IS SUBMITTED PURSUANT TO THE REQU FAclLITYNAME Cook Nuclear Plant Unit 2 IREMENTS OF 10 CFR E: (Check X

50.73(a)(2)(i) 50.73(a)(2)(ii) 50.73(a)(2)(iii)

DOCKET NUMBER 05000-316 one or moro) (11) 50.73(a) (2) (viii) 50.73(a) (2) (x) 73.71 20.2203(a)(2) (ii) 20.2203(a) I2)(iii) 20.2203(a) (2) (iv) 20.2203(a)(4) 50.36(c)(1) 50.36(c) (2)

LICENSEE CONTACT FOR THIS LER (12) 50.73(a)(2)(iv) 50.73(a)(2)(v) 50.73(a)(2)(vii)

OTHER pecify ln Abstract below or in NRC Form 366A NAME Mr. Dennis D. Snodgrass, Compliance Engineer TELEPHONE NUMBBA(Include Ares Code)

(616) 465-5901 X1627 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DES CRIBED IN THIS REPORT (13)

CAUSE

SYSTEM COMPONENT MANUFACTURER REPORTABLE To EPIX

CAUSE

SYSTEM COMPONENT MANUFACTURER REPORTABLE To EPIX SUPPLEMENTAL REPORT EXPECTED 14 YES (I( yes. complete EXPECTED SUBMISSION DATE).

X No EXPECTED MONTH DAY YEAR ABSTRACT (Limitto 1400 spaces, i.e., approximately 15 single.spaced typewritten lines) (16)

On May 21, 1999, the Engineering Programs group determined that the Boron Injection Tank (BIT) manway bolts were not included in the ISI Program, creating a missed examination for the previous ISI interval.

The bolts were being reviewed for surveillance requirements for replacement of two bolts that were identiTied with no markings by the System Engineer while performing an Expanded System Readiness Review walkdown.

Pressure retaining bolting greater than 2 inches in diameter are required to be volumetrically examined once each ISI interval per the 1989 ASME XI Code.

The bolting on the Boron Injection Tank manway is 2-1/2 inches in diameter and as such is required to be in the ISI Program.

This is reportable per 10CFR50.73(a)(2)(i)(B) as a condition prohibited by the plant's Technical Specifications (T/S), for the failure to comply with T/S 4.0.5 on the ISI program.

This condition was found to exist on both Units. The apparent cause for this event is programmatic weakness.

The BIT manway bolts were removed from the ISI Program without proper review, approval and documentation.

This occurred in the early 1980's when ISI Program correspondence and documentation was less formal.

No immediate corrective actions were required as the Units are currently in Mode 5 making the BIT and associated piping in the current Mode exempt from examination in accordance with the 1989 ASME Section XI Code.

The BIT manway bolting has been administratively placed in the ISI Program for the third ISI interval, and will be examined prior to Mode 4.

Review of the ISI database did not identify any other Code category C-D bolts that had not been examined during the previous ISI intervals.

Engineering has developed an action plan to review the ISI Program for compliance with applicable regulatory requirements prior to restart.

Based on the System Engineer walkdown identifying no degraded BIT manway bolts and a work history of no bolt failures, it has been determined that'the failure to perform BIT manway bolting examinations for the previous ISI intervals had minimal impact on the safe operation of either Unit.

9906220207 990658 PDR ADOCK 05000315 S

PDRU.S. NUCLEAR REGULATORY COMMISSION (6 1998I ~

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITYNAME (1)

Cook Nuclear Plant Unit 1 DOCKET (2) 05000-315 YEAR LER NUMBER (6)

PAGE (3)

SEOUENTIAL NUMBER REvlsloN 2

QF 3

NUMBER 1999 014 00 TEXT (Ifmore spaceis required, use additional copies of NRC Form 36GA/ (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 May 21, 1999, the Engineering Programs group determined that the Boron Injection Tank (BIT) manway bolts were not included in the ISI Program, creating a missed examination for the previous ISI interval. The bolts were being reviewed for surveillance requirements for replacement of two bolts that were identified with no markings by the System Engineer while performing an Expanded System Readiness Review walkdown.

The bolting on the Boron Injection Tank manway is 2-1/2 inches in diameter.

Bolting greater than 2 inches in diameter is required to be volumetrically examined once each ISI interval per the 1989 ASME XI Code, Category C-D, Item no. C4.10, "Class 2 Pressure Vessel Bolting Greater than 2 Inches".

The investigation determined the first ISI interval identified the BIT manway bolts as requiring examination.

The Unit 2 bolts were examined during the first ISI interval, however Unit 1 examination can not be verified. When the ISI Programs were updated for the second interval, the BIT manway bolts were not included in the ISI database and examinations were not performed on either Unit.

Cause Of The Event

The apparent cause for this event is programmatic weakness.

The BIT manway bolting was removed from the ISI Program without proper review, approval and documentation.

This occurred in the early 1980's when ISI Program correspondence and documentation was less formal.

Anal sis Of The Event This LER is submitted in accordance with 10CFR50.73(a)(2)(i)(B),

a condition prohibited by the plant's Technical Specifications, for the failure to comply with T/S 4.0.5 on the ISI program.

Technical Specification 4.0.5 requires inservice inspection of ASME Code Class 1, 2, and 3 components per the 1989 ASME Section XI Code. The Boron Injection Tanks are Class 2 components and examination of the manway bolting is intended to identify degraded bolting conditions before they worsen.

Visual observation of BIT manway bolting during the Expanded System Readiness Review walkdown indicated that there were no degraded bolts.

Review of maintenance records did not identify any problems with, or a failure of these bolts.

Based on these factors, it has been concluded that the failure to perform BIT manway bolting examinations for the previous ISI intervals had minimal impact on the safe operation of either Unit.~

U.S. NUCLEAR REGULATORY COMMISSION (6

1 999)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITYNAME I1)

Cook Nuclear Plant Unit 1 DOCKET I2) 05000-315 YEAR LER NUMBER I6)

SEQUENTIAL REVISION NUMBER NUMBER PAGE I3) 3 OF 3-1999 014 00 TEXT (Ifmore speceis required, use edditionel copies ofNRC Form 386A/ I17)

CORRECTIVE ACTIONS

The Boron Injection Tanks (BIT) bolting has been administratively placed in the ISI database for the third ISI interval.

Examination of the bolts has been scheduled and willbe performed prior to Mode 4.

A review of the ISI database did not identify any other Code Category C-D bolts that had not been examined during the previous ISI intervals.

The drawings for Class 2 bolted components were reviewed to determine if there were any other Category C-D bolting not included in the ISI database.

None were found.

Engineering has developed an action plan to review the ISI Program for compliance with applicable regulatory requirements prior to restart.

The ISI Program and the associated ISI database have been modiTied to include the BIT bolting examination requirement.

A lesson learned will be placed in the program notebook to alert personnel of the previously missed examinations and will ensure ISI Program Coordinators are aware of past problems on this component.

To prevent recurrence, PMI-5070, Inservice Inspection, will be revised to add a note that when the ISI Program or portions of the Program are revised, a review shall be made of the changes in accordance with the requirements of 10 CFR 50.59.

Engineering Programs has performed self-assessments of the ASME Section XI Inservice Inspection Program to review for effective implementation, documentation, organization, and degree of Code compliance.

These self-assessments have resulted in an action plan to review the ISI Program for compliance with all regulatory requirements prior to restart.

SIMILAREVENTS 316/98-041-00 316/98-043-00 315/99-002-00 1