05000316/LER-1999-002-01, :on 990415,discovered That TS 4.0.5 Requirements Were Not Met Due to Improperly Performed Test. Caused by Incorrect Interpretation of ASME Code.App J Testing Will Be Completed & Procedures Will Be Revised

:on 990415,discovered That TS 4.0.5 Requirements Were Not Met Due to Improperly Performed Test. Caused by Incorrect Interpretation of ASME Code.App J Testing Will Be Completed & Procedures Will Be Revised

ML17325B586
Person / Time
Site:	Cook
Issue date:	05/10/1999
From:	Depuydt M INDIANA MICHIGAN POWER CO.
To:
Shared Package
ML17325B585	List: 05000316/LER-1999-002, Forwards LER 99-002-00 Re TS 4.0.5 Requirements Not Being Met Due to Improperly Performed Test.Commitments Identified in Ler,Listed 05000316/LER-1999-002-01, :on 990415,discovered That TS 4.0.5 Requirements Were Not Met Due to Improperly Performed Test. Caused by Incorrect Interpretation of ASME Code.App J Testing Will Be Completed & Procedures Will Be Revised
References
LER-99-002-01, LER-99-2-1, NUDOCS 9905170112
Download: ML17325B586 (3)

LER-1999-002, on 990415,discovered That TS 4.0.5 Requirements Were Not Met Due to Improperly Performed Test. Caused by Incorrect Interpretation of ASME Code.App J Testing Will Be Completed & Procedures Will Be Revised

Event date:
Report date:
Reporting criterion:	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
3161999002R01 - NRC Website

text

NRC Form 366 (6-1 998)

U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)

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

APPROVED BYOMB NO. 31604104 EXPIRES 06/30/2001 ESTRIATED BURDEN PER

RESPONSE

TO COMPLY WITH THIS MANDATORY INFORMATIONCOLLECTION RECUESTI 500 HRS. REPORTED LESSONS LEARNEDARE INCORPORATED INTO THE UCENSING PROCESS AND FED BACK TO INDUSTRY>

FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION AND RECORDS MANAGEMENT BRANCH IT4)

Fss),

U.S.

NUCLEAR REGULATORY CcsraIISSIOH, WASHINGTON. DC 205554001. AND TO THE PAPERWORK REDUCTION PROIECT O1500104).

OFFICE OF MANAGEMENT AND'BUDGET. WASHINGTON. DC 20503 FACILITYNAMEI1)

TITLE(4)

Cook Nuclear Plant Unit 2 DOCKET NUMBERI2) 05000-316 PAGE I3) 1 of3 Requirements of Technical Specification 4.0.5 Not Met Due to Improperly Performed Test EVENT DATE (6)

LER NUMBER (6)

REPORT DATE (7)

OTHER FACILITIESINVOLVED(8)

MONTH 04 DAY YEAR 15 1996 YEAR 1999 SEQUENTIAL NUMBER 002 REVISION NUMBER 00 MONTH 05 DAY 10 YEAR 1999 FACIUTYNAME FACIUTYNAME DOCKET NUMBER DOCKET NUMBER OPERATING MODE (9)

POWER LEVEL(10) 00 20.2201 (b) 20.2203(a)(1) 20.2203(a)(2)(l) 20.2203(a)(2)(v) 20.2203(a)(3)(i) 20.2203(a)(3)(ii) 50 73(a)(2)(i) 50.73(a)(2)(ii) 50.73(a)(2)(iii) 50.73(a)(2)(viii) 50.73(a)(2)(x) 73.71 THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR li: (Check one or more) (11) 20.2203(a)(2)(ii) 20.2203(a)(2)(iii) 20.2203(a)(2)(lv) 20.2203(a)(4) 50.36(c)(1) 50.36(c)(2)

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

OTHER SpecEY In Abstract bekw or n NRC Ferns 36BA Ms. M. B. Depuydt, Compliance Engineer TELEPHONE NUMBER 0nrdodeArea Code) 616/465-5901, x1 589 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

CAUSE

SYSTEM COMPONENT MANUFACTURER REPORTABLE TO EPIX

CAUSE

COMPONENT MANUFACTURER REPORTABLE TO EPIX SUPPLEMENTAL REPORT EXPECTED 14 YES IfYes, corn lete EXPECTED SUBMISSION DATE NO EXPECTED SUBMISSION DATE 15 YEAR Abstract (Umitto 1400 spaces, i.e. ~ approximately 15 single-spaced typewritten lines) (16)

On April 15, 1996, with Unit 2 in Mode 6, the containment sump pump discharge piping at containment penetration 2-CPN-41 was pressurized for approximately one minute to perform an Insefvice Inspection (ISI) system functional pressu're test.

ASME Code,Section XI required the line to be pressurized for at least ten'inutes forthe test. Atthe time, the one-minute test was considered an acceptable alternative to the ten-minute test.

On April9, 1999, this was identified as an incorrect test method, which did not meet the requirements ofthe surveillance.

Since the requirements ofTechnical Specification 4.0.5 were not met, this event is reportable under 10 CFR 50.73(a)(2)(i)(B), as an operation prohibited by the plant's Technical Specifications.

The apparent cause ofthe event was an incorrect interpretation ofthe ASME Code.

No immediate corrective actions were required as the unit is currently in Mode 5 and containment integrity is not required. The Appendix J testing for the penetration piping willbe completed prior to restart ofthe unit. Procedures are being revised to strengthen the ISI program and the interface with the, program coordinator.

Based on the satisfactory results ofAppendix J testing performed on the same penetration and a work history of no leakage, it has been determined that there is no safety significance associated with the incorrectly performed test.

The root cause investigation forthis event has not been completed.

Ifsignificant changes to the LER are needed as a result ofthe completion ofthe investigation, a supplemental report to this LER willbe submitted.

9905170ii2 990510 PDR ADQCK 050003lh S

PDR I'VWrI'L/AM~ LV IOev/U.S. NUCLEARREGULATORYCOMMISSION (6-1998)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITYNAME (1)

Cook Nuclear Plant Unit 2 DOCKET NUMBER(2) 05000-316 YEAR 1999 LER NUMBER (6)

SEQUENTIAL NUMBER 002 REVISION NUMBER 00 PAGE (3) 2of3 TEXT (Ifmore space is required, use additional copies ofNRC Form (366A) (17)

Conditions Prior to Event

Unit 2 was in Mode 6, Refueling Descri tion of Event On April 15, 1996, during the second Inservice Inspection (ISI) interval, the containment sump pump discharge piping at containment penetration 2-CPN-41 was pressurized, using the sump pump, for approxiryately one minute to perform an ISI system functional pressure test: The 1983 ASME Section XI,Article IWA-5213(b), "Test Condition Holding Time", required the piping to be pressurized for at least ten minutes.

The test personnel considered the one-minute test an acceptable equivalent to the ten-minute test. It was desirable to shorten the test time because the sump does not hold enough water to keep the sump pump running for 10 minutes without being refilled.

This condition was Identified as a result of a self-assessment ofthe ISI pressure test program that was initiated in November 1998. The assessment was conducted to determine the adequacy ofthe ISI Program.

During the assessment the acceptability ofthe shorter hold time was questioned, and it was subsequently determined that it was not acceptable to decrease the hold time to 1 minute. The self-assessment identified a number of minor issues, however, the pressure test ofthe 2-CPN-41 piping was the only test or examination identified that did not meet the Code requirements.

Cause of Event

The apparent cause ofthe event was an incorrect interpretation ofthe ASME Code. Test'personnel believed the test acceptable because of a note in the Job Order which stated "10 minute hold time not required per ANII (Authorized Nuclear Inseivice Inspector) since pump cannot be run forthat length of time". This was apparently based on an incorrect interpretation ofArticle IWA-2240, "Alternative Examinations", ofthe 1983 Edition of Section XI with Addenda through Summer 1983. Test personnel believed the test was acceptable based on the ANII'ssign offofthe test and the incorrect interpretation.

Anal sis of Event This event is reportable under 10 CFR 50.73(a)(2)(i)(B), as operation prohibited by the plant's Technical Specifications.

The. requirements ofTechnical Specification 4.0.5, Surveillance Requirements for Inservice Inspection and Testing of ASME Code Class 1, 2 and 3 components were not met.

This specification ensures that Inseivice Inspection ofASME Code class 1, 2 and 3 components and Inseivice Testing of ASME Code Class 1, 2, and 3 pumps and valves willbe performed in accordance with a periodically updated version of Section XIforthe ASME Boiler and Pressure Vessel Code and Addenda as required by 10CFR50.55a.

During the second Inservice Inspection interval a system functional test was performed on containment penetration 2-CPN-

41. This test did not meet the Code requirements for pressure hold time, but was declared to be acceptable based on an incorrect interpretation qf Code requirements.

A review of the testing performed on this penetration for both the first and second intervals revealed that all other testing, hydrostatic, Appendix J -,B 8 C, and ILRT, had acceptable results. These tests were all performed in accordance with the requirements.

Since Appendix J test results from earlier in the same Inservice Inspection interval verified that the penetration was acceptable, and the penetration does not have a history ofwork requests that would indicate leakage problems, it has been determined that there is no safety significance associated with the test that was performed incorrectly.U.S. NUCLEARREGULATORYCOMMISSION (6-1 998)

LICENSEE EVENT REPORT tLER)

TEXT CONTINUATION FACILITYNAME (1)

Cook Nuclear Plant Unit 2 DOCKET NUMBER(2) 05000-316 YEAR LER NUMBER (6)

SEQUENTIAL NUMBER REVISION NUMBER PAGE (3) 3of3 1999

002 00 TEXT(ifmore space is required, use additional copies ofNRC Form (366A) (17)

Corrective Actions

No immediate corrective actions were necessary since the unit is currently in Mode 5 and containment integrity is not required.

A relief request to apply Code Case N-522 for system pressure testing of Class 2 components at containment penetrations was submitted to the NRC in November 1996 to request approval forthe Appendix J alternative method oftesting. This request was approved in July 1997 for use during the third ISI interval and will be applied to 2-CPN-41, which will be tested prior to restart ofthe unit. The relief granted allows testing in accordance with Appendix J as long as the maximum pressure that willbe seen during an accident is used.

This is being incorporated into the overall ISI Program, as well as the appropriate procedures.

12 QHP 5070 NDE.002, Visual VT-2 Examinations: lnservice and Repair/Replacements",

willbe revised to require consultation with the ISI Program Coordinator when problems are encountered with a test, and to delete any references to interface with the ANII. The ISI Program Coordinator willconsult with the ANIIwhen appropriate.

The expectations for the interface with the ANII has been added to procedure PMP-5070, "Inservice Inspection Program Implementation", which is being drafted. This procedure willalso contain detail on how the ISI Program requirements will be administered, provide information on requesting relief, and specify who can grant relief.

A formal meeting to thoroughly discussSection XI, IWA-2240 has been held with personnel involved with the ISI program.

The ANIIalso attended the meeting.

This meeting provided information as to when relief requests are to be written to deviate from Code requirements and when exemptions from regulatory requirements are required.

Job Orders (JOS) associated with ISI testing, that have already been written, willbe reviewed to determine ifother JOs contain notes which could lead to the misinterpretation of Code requirements.

This review willbe performed for both units, and any notes found willbe dispositioned appropriately by the ISI program coordinator.

The root cause investigation forthis event has not been completed.

Ifsignificant changes to the LER are identified as a result ofthe completion ofthe investigation, a supplemental report to this LER willbe submitted.

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