05000315/LER-1999-021, :on 990728,determined That GL 96-01 Test Requirements Were Not Met in Surveillance Tests.Caused by Failure to Understand Full Extent of GL Requirements. Surveillance Procedures Will Be Revised or Developed

:on 990728,determined That GL 96-01 Test Requirements Were Not Met in Surveillance Tests.Caused by Failure to Understand Full Extent of GL Requirements. Surveillance Procedures Will Be Revised or Developed

ML17326A112
Person / Time
Site:	Cook
Issue date:	08/27/1999
From:	Depuydt M INDIANA MICHIGAN POWER CO.
To:
Shared Package
ML17326A111	List: 05000315/LER-1999-021, :on 990728,determined That GL 96-01 Test Requirements Were Not Met in Surveillance Tests.Caused by Failure to Understand Full Extent of GL Requirements. Surveillance Procedures Will Be Revised or Developed
References
GL-96-01, LER-99-021, NUDOCS 9909020033
Download: ML17326A112 (3)

LER-1999-021, on 990728,determined That GL 96-01 Test Requirements Were Not Met in Surveillance Tests.Caused by Failure to Understand Full Extent of GL Requirements. Surveillance Procedures Will Be Revised or Developed

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3151999021R00 - NRC Website

text

f, NRC FORht 366 (6-I998j US. i/LrCLEARREG ORY COMhIISSION LICENSEE EVENT REPORT (LER)

(See reverse for required number of digits/characters for each block) r APPR BY OMB NO. 31504104 EXPIRES 06/30/2001 Estimated

, the NRC may not conduct or sponsor. and a person is not rertuired to respond to. the information collection.

FACILITYNAME(l)

Cook Nuclear Plant Unit 1 DOCKET NUMBER(2) 05000-315 PAGE (3) 1 OF 3

TITLEta)

Generic Letter 96-01 Test Requirements Not Met In Surveillance Tests EVENTDATE(5)

LER NUMBER(6)

REPORT DATE(7)

OTHER FACILITIESINVOLVED(8)

MONTH 07 DAY YEAR YEAR 28 1999 1999 SEQUENTIAL rr nrnr n 021 REVISION rnnrnr n 00 MONTH DAY YEAR 0

27 1999 FACIUTYNAME Cook Nuclear Plant Unit 2 FACIUTYNAME DOCKET NUMBER 05000-316 OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUI RE MENTS OF 10 CFR gI (Check one or morc) (II)

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2 t

20.2 aX2 v

2.22 I

0 vst 1 POWER 0%

20.2203(aX1)

. 2 (a

t) 20.2203(aX2Xii) a 2 ttt (aX tv 20.2203(aX3Xi) 2.

a tt 20.2203(aX4) c 2

LICENSEE CONTACI'ORTHIS LER 50.73(aX2Xii) 50.7 a

2 tn 5o.73(aX2Xiv) a 2 v 50.73(aX2Xvii)

(12) 50.73(aX2Xx)

OTHER

~yf m Abstract below or m Mary Beth Depuydt, Regulatory Compliance TELEPNONB NUMBER( tnc4de Arcs Code)

(616) 465-5901 X 1589 COMPLETE ONE LINEFOR EACH COMPONENT FAILUREDESCRIBED INTHIS REPORT (13)

CAUSE

COMPONENT MANUFACTURER REPORTABLE To EPIX

CAUSE

MANUFACTURER REPORTABLE To EPIX SUPPLEMENTAL REPORT EXPECIED 14 YES (Ifyes, complete EXPECTED SUBMISSION DATE).

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

On July 28, 1999, Unit 1 was in cold shutdown and Unit 2 was shut down in a defueled condition.

A review performed of Technical Specification (T/S) surveillance tests for the systems requiring conformance to Generic Letter (GL) 96-01 identified that not all requirements were being met.

The surveillance tests for the Solid State Protection

System, Engineered Safeguards System and the Emergency Diesel Generator load shed and sequencing circuits did not meet the GL 96-01 test requirements.

Failure to test these systems per the requirements of GL 96-01 was determined to be a violation of T/S and reportable per 10CFR50.73(a)(2)(i)(B) as a condition prohibited by T/S. The Control Room Ventilation System is required to meet the requirements of GL 96-01 but there is no T/S requirement to test system response to a high radiation signal.

The apparent

cause

of this event was a failure to understand the full extent of the GL 96-01 requirements when the surveillance tests were initially evaluated, as the initial review was restricted to T/S required surveillances only. A third party review, performed as part of the restart effort, identified these discrepancies and led to an in depth independent review of the GL 96-01 implementation. The independent review has not identified to date any additional discrepancies other than those found during the third party review.

Surveillance procedures are being revised or developed to test the nonconforming systems per GL 96-01 test requirements prior to Mode 4 entry for each unit.

Surveillance testing is pe'rformed on the nonconforming systems.

Even though these tests do not meet the complete requirements of GL 96-01, the successful completion of these tests provides confidence that the systems would perform their safety function if called upon to do so.

Therefore, the identified conditions had minimal safety implications to the health and SafetV Of the n>>hllr 9909020033 990827 PDR ADQCK 050003%5 8

PDR

NRC PORM 366A U.S. NUCLEARREGULATORYCoiliilllSSION (6-l598)

LICENSEE EVENT REPORT (LER)

TEXTCONTINUATION FACILITYiVAiME(I)

DOCKET (2)

NuibIBER 2 LER NUMBER (6)

PAGE (3)

Cook Nuclear Plant Unit I 05000-315 SEQUENTIAL NUMBER 1999 021 REVISION NUMBER 00 2

OF 3

TEXT(Ifmore space is required, use additional copies ofPIRC Form 366i() (17)

Conditions Prior To Event

Unit 1 was in Mode 5, Cold Shutdown Unit 2 was Defueled Descri tlon Of The Event Generic Letter 96-01 required that surveillance procedures that test logic circuits that are required to perform a safety function or whose failure could affect a safety function be reviewed to assure that adequate overlap testing is being performed to meet T/S requirements.

The Reactor Protection System (RPS),

Engineered Safety Feature Actuation System (ESF) and Emergency Diesel Generator (EDG) load shed and sequencing circuits are systems specifically addressed in GL 96-01.

Surveillance testing of automatic actuation logic circuits of system functions credited in the accident analysis with surveillance requirements in the T/S is also addressed in GL 96-01.

i Though D. C. Cook documented completion of its implementation of GL 96%1 test requirements to the Nuclear Regulatory Commission (NRC) in October 1997, a third party review of this GL 96-01 implementation was performed as part of the restart effort. The third party review identified several discrepancies and led to an in depth independent review of the GL 96-01 implementation.

The independent review did not identify to date any additional discrepancies other than those found during the third party review.

On July 28, 1999, surveillance tests for the Solid State Protection System (SSPS) [EIIS: JG] permissive input relays [EIIS: JG /

RLY], Engineered Safeguards System (ESS) [EIIS: EA] voltage available relays [EIIS: EA / RLYj and the Emergency Diesel Generator (EDG) [EIIS: EK] breaker trip and blocking relays [EIIS: EK/ RLYjwere identified as failing to meet all GL 96-01 test requirements.

The Control Room Ventilation System (CRVS) [EIIS: Vl] is designed to go into recirculation mode on a high radiation signal [EIIS: Vl / RA] from the control room radiation monitor to maintain radiological conditions during normal and design basis accident conditions.

There is not a T/S requirement to test the CRVS on a control room high radiation signal.

However, the CRVS was identified as being required to meet the requirements of GL 96-01.

The independent GL 96-01 review identified that the CRVS does not have a surveillance procedure to test the system on a control room high radiation signaI.

Cause Of The Event

The apparent

cause

of this event was a failure to understand the full extent of the GL 96-01 requirements when the surveillance tests were initially evaluated.

The initial review only addressed those test requirements specifically identified in the D.C Cook T/S.

Anal sis OfThe Event On July 28, 1999, it was determined that not testing these systems per the requirements of GL 96-01 was a violation of T/S and is reportable per 10CFR50.73(a)(2)(i)(B) as a condition prohibited by the plant's T/S.

Applicable T/S for the GL 96-01 nonconforming systems are T/S Table 3.3-1 for SSPS permissive conditions and setpoints, and T/S 3/4.8 for ESS surveillance requirements and EDG surveillance requirements.

The SSPS permissive P-6 permits a manual block of source range high flux level reactor trip when 1 of 2 intermediate range channels is greater than or equal to the setpoint.

Permissive P-11 permits a manual block of a safety injection signal when 2 of 3 pressurizer channels are less than or equal to the Iow pressure setpoint. The permissive reset prevents a manual block of a safety injection when 2 of 3 pressurizer channels are greater than or equal to the low pressure setpoint.

Permissive P-12 permits a manual block of the safety injection signal on low steam line pressure and causes steam line isolation on high steam flow. The permissive reset prevents a manual block of safety injection signal on low steam pressure and steam line isolation on high steam flow. Existing surveillance tests do not test the SSPS input relays associated with the P-6, P-11 and P-12 permissive signals as required by GL 96-01.

NRC FORilt 366A U.S. NUCLEAR REGULATORYCOMilllSSION (6. I998)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITYiWAME(I)

Cook Nuclear Plant Unit I DOCKET (2)

NUMBFR 2 05000-315 YEAR LER NUMBER (6)

SEQUENTIAL REVISION NUMIIER NUMIIER PAGE (3) 3 OF 3

1999 021 00 TEXT(Ifmore spnceis required. use nddi n'onnl copies ofNRC Form 3668) (I7)

Anal sis Of The Event cont'd Each ESS load that is required to operate under accident conditions contains three parallel voltage available relays in its logic circuit. Only one of the three parallel voltage available relays is required to actuate to complete the logic circuit and start the ESS load. The present surveillance testing does not individuallytest the relays as required by GL 96-01.

Various loads that are fed from busses T11A, T11D, T21A, T21D, 11B, 11C, 21B, and 21C have blocking relays to prevent operator intervention during EDG load shed and sequencing.

Present surveillance procedures do not provide specific steps to test the blocking relays as required by GL 96-01.

The EDG logic circuits contain relays to trip and prevent closure of the EDG output breakers for 2 seconds following a loss of offsite power and/or safety injection signaI.

Present surveillance procedures do not provide specific steps to test the function of these relays as required by GL 96-01.

The CRVS maintains radiological levels within the Control Room which allows for continuous personnel occupancy during normal and Design Basis Accident conditions.

In the event of a radiological release, the outside air intake damper automatically closes and the CRVS air conditioning system continues to operate.

Surveillance testing is performed on the nonconforming systems, including the CRVS.

Even though these tests do not meet the complete requirements of GL 96-01, the successful completion of these tests provides confidence that the systems would perform their safety function if they were called upon to do so.

Therefore, the identified conditions had minimal safety implications to the health and safety of the public.

Corrective Actions

o Surveillance procedures to test the SSPS permissive signals for all applicable plant conditions will be developed.

These procedures willbe implemented and testing complete prior to Mode 4 entry for each unit.

~

The appropriate surveillance procedures will be revised to test each of the three ESS voltage available paths.

These procedures willbe implemented and testing complete prior to Mode 4 entry for each unit.

~

The appropriate surveillance procedures will be revised to test the EDG load shed and sequencing tripping and block relays. These procedures willbe implemented and testing complete prior to Mode 4 entry for each unit.

~

Surveillance procedures to perform testing of the CRVS on a high radiation signal willbe developed.

These procedures willbe implemented and testing complete prior to Mode 4 entry for each unit.

~

Review of the implementation of GL 96-01 at D. C. Cook willbe completed by September 30, 1999.

As part of Restart Action Plan /II 0001 for the Programmatic Breakdown in Surveillance Testing, the adequacy of the T/S surveillance program will be evaluated.

This evaluation includes verification that T/S surveillance requirements for all modes of plant operation are incorporated into T/S surveillance test procedures.

Also as part of the Restart effort, system and programmatic assessments in the Expanded System Readiness Reviews and Licensing Basis Reviews are reestablishing and documeriting the plant's design and licensing basis.

Similar Events

315/99-010-00 315/99-015-00 315/99-016-00