05000316/LER-2006-005

LER-2006-005, Failure to Comply with Technical Specification Surveillance Requirement 3.6.1.1

Docket Number
Event date:	04-10-2006
Report date:	08-02-2006
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3162006005R00 - NRC Website

Conditions Prior to Event Unit 2 was in refueling outage U2C16, in Mode 6.

Description of Event

On April 10, 2006, 2-SI-189, ECCS Safety Valves Discharge Header To Pressurizer Relief Tank Containment Isolation Check Valve [ISV], had a required surveillance inspection performed on it that potentially affected the valve's leak tightness prior to performing the required as-found leak rate test.

This resulted in being unable to meet the Technical Specification Surveillance Requirement (SR) 3.6.1.1 for Containment. SR 3.6.1.1 requires that leakage rate testing be performed in accordance

• with.

the Containment Leakage Rate Testing Program. Donald C. Cook Nuclear Plant's Containment -' Leakage Rate Testing Program specifies as-found testing prior to performing maintenance, repairs, or inspections that could reduce containment leakage integrity.

Valve 2-SI-189, ECCS Safety Valves Discharge Header To Pressurizer Relief Tank Containment Isblation Check Valve, was disassembled per Job Order Activity (JOA) R0267698-04 and an internal visual inspection performed per JOA R0267698-03 prior to performance of the required as-found type B&C leak rate test. The scheduling for these activities was correct and the appropriate logic ties were in the schedule.

This event is reportable in accordance with 10 CFR 50.73(a)(2)(i)(B), due to being unable to meet SR 3.6.1.1. This event occurred, and was identified, on April 10, 2006. The non-compliance with the Appendix J program requirements was identified on April 12, 2006. The initial review for applicability to 10 CFR 50.73 reporting requirements determined that the event was not required to be reported.

Subsequent review and discussion between the plant staff and the Nuclear Regulatory Commission determined, after the 60-day time frame had expired, that the event was required to be reported.

Therefore, this Licensee Event Report (LER) is being submitted greater than 60 days after the event.

Cause of Event

The cause of performing the required surveillance internal inspection prior to a required as-found leak rate test was a weakened barrier in that the work activity instructions did not require verification of completion of the as-found leak rate test prior to beginning the internal inspection.

Analysis of Event

The valve disassembly activities performed on 2-SI-189 on April 10, 2006, were for a required surveillance internal inspection. There were no outstanding corrective maintenance activities for 2-SI­ 189 nor was the valve leakage integrity suspect. Additionally, 2-SI-189 is not on an extended surveillance frequency under the Appendix J program as other more restrictive surveillance requirements outside of the Appendix J program require this valve to be disassembled and inspected on a refueling outage frequency.

Prior to the valve disassembly activities performed on 2-SI-189 on April 10, 2006, the as-left B&C test performed during the previous Unit 2 refueling outage (October 19, 2004) was satisfactory. No maintenance was performed on 2-SI-189 between the satisfactory test on October 19, 2004 and April 10, 2006. Additionally, no flow is expected past this valve during the operating cycle and a review of station Condition Reports between October 2004 and April 2006 did not identify any instances where there was flow past this valve. Thus, it can be concluded that the valve remained in the closed seated position from the satisfactory October 2004 as-left B&C test throughout the last operating cycle.

2-SI-189 is a containment isolation check valve that provides a one-way flow path from Residual Heat Removal [BP] safety valve 2-SV-104W [RV) to the Pressurizer Relief Tank [TK]. Failure of this valve does not contribute to core damage frequency, and additional component failures would be required for the failure to contribute to large early release frequency, which would still be well below 1.0 E-8.

. Therefore, this event was not risk significant.

Corrective Actions

Corrective Actions taken were performance of an acceptable as-left leak rate test following internal inspection of 2-SI-189, and revising the surveillance internal inspection work activity for 2-SI-189 to verify completion of the as-found test prior to performing valve disassembly.

Corrective Actions to be taken include revising all recurring work activities for Appendix J components that potentially affect a valve's leak tightness to require a verification of completion of the as-found B&C type leak rate test prior to performing an activity.

Previous Similar Events

A review was conducted of station Condition Reports and LERs for the previous 3 years. No similar events were identified.