ML17326A033

LER 99-004-01:on 971030,failure to Perform TS Surveillance Analyses of Reactor Coolant Chemistry with Fuel Removed Was Noted.Caused by Ineffective Mgt of Tss.Chemistry Personnel Have Been Instructed on Requirement to Follow TS as Written

ML17326A033
Person / Time
Site:	Cook
Issue date:	07/01/1999
From:	Berry L INDIANA MICHIGAN POWER CO.
To:
Shared Package
ML17326A032	List: ML17326A031 ML17326A033
References
LER-99-004, LER-99-4, NUDOCS 9907090123
Download: ML17326A033 (3)

Text

NRC FORM 366 U.S. NUCLEAR REGULA COMMISSION APPROV OMB NO. 3150-0104 EXPIRES 06/30/2001 (6-1999)

Estimated burden per response to comply viith this mandatory information

, LlCENSEE EVENT'REPORT (LER) collection request: 50 hrs. Reported lessons learned are Incorporated into the licensing process and fed back to Industry. ForNtard comments regarding burden estimate to the Records Management Branch (TW F33), U,S. Nuclear Regulatory (See reverse for required number Commission, Washington. DC 205554001. and to the Pap+work Reduction for each block) of'igits/characters Project (31500104), Oirice of Management and Budget, Washington, DC 20503.

If an information collection does not display a currently valrd OMB control number, the NRC may not conduct or sponsor. and a person is not required to respond to. the information co)lection.

FACILITYNAME I1) DOCKET NUMBER I2) PAGE I3)

Cook Nuclear Plant Unit 1 05000-315 1 OF 3 TITLE I4)

Failure to Perform Technical Specification Surveillance Analyses of Reactor Coolant Chemistry with Fuel Removed EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (6)

MONTH DAY YEAR YEAR SEauENTIAL REVISION MON1H DAY YEAR FACILITYNAME DOCKET NUM8ER NUMBER NUMBER Cook Nuclear Plant Unit 2 05000-316 1999 FAcrLITYNAME DOCKET NUMBER OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQU IREMENTS OF 10 CFR II: (Check one or more) (11)

MODE (9) 20.2201(b) 20.2203(a)(2)(v) X 50.73(a)(2)(i) 50.73(a)(2)(viii)

POWER 20.2203(a)(1) 20.2203(a)(3)(i) 50.73(a)(2)(ii) 50.73(a)(2)(x)

LEVEL (10) 20.2203(a)(2)(i) 20 2203(a)(3)(ii) 50.73(a) (2)(iii) 73.71 20.2203(a)(2)(ii) 20.2203(a) (4) 50.73(a) (2) (iv) OTHER 20.2203(a) (2)(iii) 50.36(c)(l) 50.73(a) (2) (v) Spec)fy in Abstract below or in NRC Form 366A 20.2203(a)(2)(iv) 50.36(c)(2) 50.73(a)(2)(vii)

UCENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUM8ER (lrraarde Area Coda)

Mr. Lyle R. Berry, Compliance Engineer (616) 465-5901 X1 623 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DES CRIBED IN THIS REPORT (13)

CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE To EPIX To EPIX SUPPLEMENTAL REPORT EXPECTED 14 EXPECTED MONTH DAY YEAR YES (If yes, complete EXPECTED SUBMISSION DATE).

X NO ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single. spaced typewritten lines) (16)

On February 16, 1999, Chemistry personnel determined that Unit 2 reactor coolant system (RCS) chemistry had not been analyzed for fluorides and chlorides, as required by Technical Specification (TS) Surveillance Reqoirement 4.4.7, while the unit was defueled. The analyses, required "at all times," were not performed from October 30 to November 23, 1997. Unit 2 has remained in Mode 5 or 6 since that time. Additional investigation identified a total of ten periods (6 for Unit 1 and 4 for Unit 2) since 1989, when the chemistry analyses had not been performed. TS Clarification (TSC) ¹54, which had been in effect since 1992, provided an inappropriate exemption from sampling while the core was off-loaded and RCS circulation was suspended. Since the surveillance requirements were not met, this event is reportable pursuant to the requirements of 10CFR 50.73(a)(2)(i)(B), as an operation prohibited by the plants'echnical Specifications.

The root causes for this event include: 1) ineffective management of Technical Specifications, and 2) ineffective ownership of Chemistry department performance.

Chemistry personnel have been instructed on the requirement to follow the TS as written without reliance on the use of TS clarifications or interpretations. The written job order activities used to control shutdown chemistry sampling were corrected to remove references to the Spent Fuel Pool as an alternate RCS sample point.

In each identified case when analyses were not done, the affected unit was at low pressure and temperature, and analyses completed prior to and after the missed analyses provided no indication of an out-of-limit condition. Based upon this information, this event had minimal impact on the health and safety of the public.

9907090123 99070%

f Df" APOCK OSnnO~i ~

NRC FORM 366A U.S. NUCLEAR ~ LATORY COMMISSION i6-1999)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACIUTY NAME I1) DocKET I2) LER NUMBER I6) PAGE {3)

Cook Nuclear Plant Unit 1 05000-315 SEQUENTIAL REvisloN 2 OF 3 NUMBER NUMBER 1999 004 01 TEXT /lfmore spaceis required, use additional copies of NRC Rearm 366A/ I17)

Conditions Prior To Event Unit 1 Mode 5, Cold Shutdown, at 0% power Unit 2 Mode 5, Cold Shutdown, at 0% power Descri tion Of The Event On February 16, 1999, Chemistry personnel determined that Unit 2 reactor coolant system (RCS) chemistry had not been analyzed for fluorides and chlorides, as required by Technical Specification (TS) Surveillance Requirement 4.4.7, while the unit was defueled. The analyses, required "at all times," were not performed from October 30 to November 23, 1997.

Unit 2 has remained in Mode 5 or 6 since that time. Additional. investigation identified a total of ten periods, for both units, since 1989, when the chemistry analyses had not been performed.

TS Clarification (TSC) ¹54, which had been in effect since 1992, provided an inappropriate exemption from sampling while the core wasoff-loaded and RCScircuiationwassuspended. TSC¹54wascancelled on July23,1997. However, although the TSC was cancelled, written direction based upon the TSC, which had been previously established by the chemistry department, remained in place. This direction stated that when fuel was removed from the RCS, the Spent Fuel Pool (SFP) became the RCS for chemistry sampling purposes. Thus the TS surveillance continued to be performed improperly, with the SFP sampled and analyzed instead of the RCS.

Cause Of The Event The root causes for this event include:

1) Ineffective management of TS by Licensing and Plant management, demonstrated by the fact that Nuclear Licensing/Plant Management approved TS clarification letters containing inappropriate TS exceptions;

2) Ineffective ownership of department performance by Chemistry management, demonstated by the ineffective establishment, communication and enforcement of appropriate standards and a lack of awareness of and involvement in department activities.

Contributing factors to this event include: 1) the relative difficulty in obtaining representative RCS samples when defueled, drained to half loop conditions with no recirculation flow and 2) a history of confusing sampling requirements and related'interpretations for the RCS in the defueled condition. In January 1992, this. culminated in TSC ¹54 which addressed those Technical Specifications applicable to conditions when no fuel was in the reactor pressure vessel or refueling canal. TSC ¹54 referenced two earlier TS clarification letters written in 1989 and 1990, which weie "to be used to determine technical specification applicability with no fuel in the reactor vessel or refueling canal." Use of the unclear guidance in TSC ¹54 by Chemistry Department personnel to implement RCS sampling and testing requirements contributed to the described TS noncompliances.

Anal sis of the Event Technical Specification (TS) Limiting Condition for Operation (LCO) 3.4.7 requires the Reactor Coolant System (RCS) chemistry to be maintained within the limits specified In Table 3.4-1. Table 3.4-1 specifies steady state and transient limits for RCS dissolved oxygen, chloride and fluoride concentrations.

NRC FORM 366A i6-1999)

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (6-1998)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1) DQGKET (2) LER NUMBER (6) PAGE (3)

Cook Nuclear Plant Unit 1 05000-315 YEAR SEQUENTIAL REVISION 3 OF 3 NUMBER 1999 004 01 TEXT iifmore space is required, use addidonal copies of IVRC Form 366A) (17)

~ Unit 2 TS Surveillance Requirement (TSSR) 4.4.7 requires RCS samples for fluoride, chloride and oxygen to be sampled at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Oxygen is exempted when Tavg is < 250 'F. Applicability of TS 3.4.7 is defined to be "at all times".

~ Unit 1 TSSR 4.4.7 requires RCS samples for fluoride, chloride and oxygen to be sampled 3 times per 7 days, not to exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Oxygen is exempted when Tavg is < 250 'F. Applicability of TS 3.4.7 is defined to be "at all times."

Contrary to TS, the investigation for this event identified a total of ten periods (6 for Unit 1 and 4 for Unit 2) since 1989, when the RCS chemistry analyses had not been performed. This is an operation prohibited by TS and is reportabie pursuant to the requirements of 10CFR50.73(a)(2)(i).

In each identified case when analyses were not done, the affected unit was at low pressure and temperature. In each identified case, analyses completed prior to and after the missed analyses provided no indication of an out-of-limit condition.

The basis for the TS chloride and fluoride limits is to ensure that corrosion of the RCS is minimized and reduce the potential for RCS leakage or failure due to stress corrosion. Stress cracking corrosion requires several conditions. As the fluoride and chloride limits in the RCS before and after defueled periods were less than 0.02 ppm, weil below the 0.15 ppm limits, temperatures were well below 200 'F, and the system was depressurized, it was unlikely the RCS integrity was compromised, due to corrosion. It is believed that this event resulted in no equipment damage. Based'upon this information, there were minimal implications to the health and safety of the public as a consequence of this event.

CORRECTIVE ACTIONS Chemistry personnel have been instructed on the requirement to follow the TS as written without reliance on the use of TS clarifications or interpretations. The written job order activities used to control shutdown chemistry sampling were corrected to remove references to the Spent Fuel Pool as an alternate RCS sample point. TSC ¹54 was cancelled on July 23, 1997. Existing TS clarifications have been recently evaluated pursuant to Administrative Letter 98-10 and have been determined to be conservative and assure plant safety.

1) A TS Amendment for TS 3.4.7 will be prepared and submitted to addre'ss the RCS sample requirements for times when there is a lack of sufficient coolant inventory.

2) As a part of the restart effort, DC Cook is performing diverse programmatic and functional area assessments which will be used to address the improvement of performance. For example, the Chemistry self assessment progra'm will be enhanced to place particular emphasis on sampling requirements and TS-related activities.

3) Existing Technical Specification Clarifications are being eliminated by incorporation into procedures, TS amendments or deletion, as appropriate.

4) A review of the Technical Specification Clarifications, both active and cancelled, will be performed to verify that no TSC provided an interpretation to the TS such that the TSC was used to procedurally define an exemption or alternative to a technical specification.

The above corrective actions will be tracked to completion under the D.C. Cook Commitment Managt.ment Program.

Improvements to Management Oversight and the Technical Specification Surveillance Program are being addressed as described in the CNP Reply to Notice of Violation of October 13, 1998, dated March 19, 1999.

SIMILAR EVENTS 315/98-053-00 NRC FORM 366A (6-1998)