ML17335A262

LER 98-041-00:on 980818,CCW Pump Surveillance Testing Had Potential to Cause Unplanned Entry Into TS 3.0.3.Caused by Failure to Perform Adequate 10CFR50.59 Se.Reviewed & Revised Plant Operating Procedures as Necessary.With 981002 Ltr

ML17335A262
Person / Time
Site:	Cook
Issue date:	10/02/1998
From:	Sampson J, Weber L INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-98-041, LER-98-41, NUDOCS 9810130242
Download: ML17335A262 (7)

Text

CATEGORY 1 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9810130242 DOC.DATE: 98/10/02 NOTARIZED: NO DOCKET FACIL:50-315 Donald C. Cook Nuclear Power Plant, Unit 1, Indiana M 05000315 AUTH.NAME AUTHOR AFFILIATION WEBER,L. Indiana Michigan Power Co. (formerly Indiana 6 Michigan Ele SAMPSON,J.R. Indiana Michigan Power. Co. (formerly Indiana & Michigan Ele RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 98-041-00:on 980818,CCW pump surveillance testing had potential to cause unplanned entry into TS 3.0.3.Caused by failure to perform adecpxate 10CFR50.59 SE.Reviewed 8 revised plant operating procedures as necessary. With 981002 ltr.

DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE:

TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc. E NOTES:

RECIPIENT COPIES RECIP IENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD3-3 PD 1 1 STANG,J 1 1

'NTERNAL: AEOD B 2 2 AEOD/SPD/RRAB 1 1 ILE C E 1 1 NRR/DE/ECGB 1 1 NR DE ELB 1 1 NRR/DE/EMEB 1 1 NRR/DRCH/HICB 1 1 NRR/DRCH/HOHB 1 1 NRR/DRCH/HQMB 1 1 NRR/DRPM/PECB 1 1 NRR/DSSA/SPLB 1 1 RES/DET/EIB 1 1 RGN3 FILE 01 1 1 D

EXTERNAL: L ST LOBBY WARD 1 1 LITCO BRYCE, J H 1 1 NOAC POORE,W. 1 1 NOAC QUEENER, DS 1 1 NRC PDR 1 1 NUDOCS FULL TXT 1 1 NOTE TO ALL "R1DS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATIONS CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 FULL TEXT CONVERSION REQUIRED

~ TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 22

Indiana Michigan Power Company Cook Nuckw Rare One Cook pkea

~MI46I06 616 466 5601 Z

INDIANA MICHIOiAN POWER October 2, 1998 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Operating License DPR-58 Docket No. 50-315 Document Control Manager.

In accordance with the criteria established by 10 CFR 50.73 entitled Licensee Event 98-041-00 Sincerely, J. R. Sampson Site Vice President

/mbd Attachment c: J. L. Caldwell (Acting), Region III R. P. Powers P. A. Barrett J. B. Kingseed R. Whale D. Hahn Records Center, INPO NRC Resident Inspector qn qq',fq

'rI8iOf0024K erI8i002 050003i5.'

PDR ADGCK PDR AEPAmerr'ca's Errergi iirrrirrer

APPROVED SY OMS NO 5150010l NRC Form 366 U.S. NUCLEAR REGUlATORY COMMISSION EXPIRES OJIJ0I55 (4-95)

ESTSJATED SVRDEN PER RESPONSE TO COMPLY WITH THIS MANDATORY OIFORMATeN COLLECTION REOVEST: 50 0 HRS. REPORTED LESSONS LEARNED LICENSEE EVENT REPORT (LER) ARE CORPOPORATEO WTO THE UCENSWG PROCESS AND FEO SACK TO INDVSTRY. FORWARD COMMENTS REGARDING 8VRDEN ESTSJATE TO THE INFORMATION AND RECORDS MANAGEMENT BRANCH IT4 F551. V.S. NVCLEAR REGIAATORY COMMISSION. WASISNGTON. DC 205550001. AND TO THE (See reverse for required number of PAPERWORK REDUCTION PROJECT OI50010ll OFF JOE OF MANAGEMENT ANO 8VOGET. WASISNGTOIL DC 20505 digits/characters for each block)

DOCKET NUMBER I2) PAGE IS)

FACIUTY NAME (I)

Cook Nuclear Plant Unit 1 50-315 1of3 TITLE Ie) 3.0.3 Component Cooling Water Pump Surveillance Testing Has Potential to Cause Unplanned Entry Into TS LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED(8)

EVENT DATE (5)

A ILI NVM MONTH DAY YEAR YEAR SEQUENTIAL REVISION MONTH DAY NUMBER Cook Unit 2 50-316 NUMBER A ILI NAM DOC NVM 08 18 98 98 041 00 10 02 98 OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR g: (Check one or more) (11)

MODE (9) 20.2203(a)(2)(v) 50.73(a)(2)(i) 50.73(a)(2)(viii) 20.2201 (b) 20.2203(a)(3)(i) 50.73(a)(2)(ii) 50.73(a)(2)(x)

POWER 20.2203(a)(1)

LEVEL(10) 00 20.2203(a)(3)(ii) 50.73(a)(2)(iii) 73.71 20.2203(a)(2)(i) 20.2203(a)(4) 50.73(a)(2)(iv) OTHER 20.2203(a)(2)(ii)

Pe .NI ADSIIscl Delow of 20.2203(a)(2)(iii) 50.36(c)(1) 50.73(a)(2)(v) M NRC FonII 866A 20.2203(a)(2)(iv) 50.36(c)(2) 50.73(a)(2)(vii)

LICENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER (SKJvde Ares Code)

Mr. Larry Weber, Operations Manager 616/465-5901, x2443 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

MANUFACTURER REPORTABLETO CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE CAUSE SYSTEM COMPONENT NPRDS TO NPRDS M N AY SUPPLEMENTAL REPORT EXPECTED (14) EXPECTED NO SUBMISSION YES X DATE (15)

(If Yes, complete EXPECTED SUBMISSION DATE).

Abstract (Limit to 1400 spaces, l,e., approximately 15 single-spaced typewritten lines) (16)

On August 18, 1998, while reviewing the Component Cooling Water (CCW) system configuration during the performance of a surveillance test, Operations personnel discovered that both trains of CCW may become inoperable under specific circumstances when the system is aligned to the test configuration. The surveillance directs the closure of the pump discharge header cross-tie valve and heat exchanger outlet valve for the CCW train that is not being tested, making the train inoperable by isolating its discharge flow path to the safeguard headers. Operations personnel concluded that if the surveillance was being performed post-maintenance to restore a pump to operable status, both trains of CCW would then be inoperable while in the test configuration. This would constitute an unplanned entry into Technical Specification (TS) 3.0.3 while the units were in Modes 1 through 4. This LER is submitted in accordance with 10CFR50.73(a)(2)(i)(B), for a condition or operation that is prohibited by the plant's Technical Specifications.

The root cause of this condition is failure to perform an adequate 10CFR50.59 safety evaluation when the surveillance procedures were revised several years ago. The plant operating procedures, including the surveillance test procedures, will be reviewed and revised as necessary to ensure the valve alignment fulfills the operability requirements of the system'or the TS required modes of operation. Changes have been made since then to the 10CFR50.59 program to improve the quality of safety evaluations.

The safety significance of this event was evaluated and found to be minimal, as condition would only occur when aligning the system to test an inoperable pump. The normal operating configuration of the CCW system provides the necessary discharge path required to meet the design basis. The health and safety of the public were never jeopardized.

NRC FORM 366 (4-95)

0 0 U.S. NUCLEAR REGULATORY COMMISSION NRC FORM 366A (4-95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITYNAME (1) DOCKET NUMBER(2) LER NUMBER (6) PAGE (3)

YEAR SEQUENTIAL REVISION Cook Nuclear Plant Unit 1 50-315 NUMBER NUMBER 2 of 3 98 041 00 TEXT (ifmote space is mquffed, use additional copies of NRC Form (366A) (17)

Conditions Prior to Event Unit 1 was in Mode 5, Cold Shutdown Unit 2 was in Mode 5, Cold Shutdown Descri tion of Event On August 18, 1998, while reviewing the Component Cooling Water (CCW) system configuration during the performance of surveillance 1/2 OHP 4030 STP.020, "Component Cooling Water Loop Surveillance Tests," Operations personnel discovered that under certain conditions both CCW trains could be inoperable at the same time while performing the surveillance. This would occur only when the surveillance is performed to restore an inoperable train, while the system is aligned in the test configuration.

1/2 OHP 4030 STP.020 directs the closure of the pump discharge header cross-tie valve and the heat exchanger outlet valve for the CCW train that is not being tested, making the train inoperable by isolating the discharge flow path to the safeguard headers. Because the surveillance is being run post-maintenance to restore an inoperable CCW pump to operable status, the valve alignment would result in both trains of CCW being inoperable at the same time.

Cause of Event The root cause of this condition is the failure to perform an adequate 10CFR50.59 safety evaluation. In early 1992 the surveillance procedures were changed to maintain the crosstie valve closed after pump shutoff, due to leak-by of the heat exchanger outlet valves, as the leak-by had the potential to invalidate the test results. A 10 CFR 50.59 review was performed, but the potential for entry into TS 3.0.3 was not identified. Additionally, it was not recognized that isolating the pump from all of its discharge paths even momentarily, as had been the case before the 1992 revision to maintain the crosstie valve closed, would make the pump inoperable.

At the time the procedures were revised, the 10CFR50.59 safety evaluation program did not provide adequate guidance or tools for personnel reviewing potential changes. This resulted in a 10CFR50.59 review that was not well documented, particularly in those aspects, which interfaced with the design basis.

Anal sls of Event This LER is submitted in accordance with 10CFR50.73(a)(2)(i)(B), a condition or operation that is prohibited by the plant's Technical Specifications. After review of the condition and the guidance provided by NUREG-1022, Revision 1, a determination was made that there were instances where unplanned entries were made into TS 3.0.3.

The design basis of the CCW system includes providing cooling to the safeguard loads. During a Safety Injection, the CCW pump receives a start signal and the heat exchanger outlet valve opens to provide cooling to the safeguards header.

Some of the miscellaneous header cooling loads are automatically isolated to maximize the support for the safety-related components.

During a Loss of Off-site Power, the CCW pumps receive a load shed signal to trip the pump and are then sequenced to load onto the safeguard buses, to supply the miscellaneous header for Reactor Coolant Pump seal cooling. The CCW system does not receive any other automatic signals, such as automatic valve motion.

. The valve lineup required by the surveillance to prove post-maintenance operability of the pump which had been taken out of service would have placed the CCW system in a configuration that required operator action to re-align the non-test pump to discharge to the header. It was not recognized that this configuration made both pumps inoperable and constituted an entry into TS 3.0.3.

NRC FORM 366A (4-95)

I NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (4-95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITYNAME (1) DOCKET NUMBER(2) LER NUMBER (6) PAGE (3)

YEAR i SEQUENTIAL REVISION Cook Nuclear Plant Unit 1 50-315 NUMBER NUMBER '3 of 3 98 041 00 TEXT (Ifmore space is required, use addiiional copies of NRC Form (386AJ (17)

ANALYSIS OF EVENT (cont'd)

Adequate flow conditions are established on the pump in test prior to isolating the heat exchanger discharge isolation valve for the opposite pump, therefore the time that two trains of CCW would, be inoperable would have been minimal. If an automatic pump start would have occurred, the operators would have terminated the surveiilance procedure and restored the CCW system to the operable alignment as soon as possible. The Emergency Operating Procedures do require verification that the CCW system is operable.

As the time that the system is in this configuration is short, manual re-alignment could be expected of the operator performing the surveillance, and the normal operating configuration of the CCW system provides the necessary discharge path required to meet the design basis, the safety significance of this event is considered minimal.

Corrective Actions The plant operating procedures, including the surveillance test procedures, will be reviewed and revised as necessary to ensure the valve alignment fulfillsthe operability requirements of the system for the TS required modes of operation.

There have been improvements in the 10CFR50.59 review process which include the defining of the design basis, additional training of 10CFR 50.59 reviewers, enhanced standards, and process improvement. The UFSAR, design basis documents, utility correspondence, commitment database and other tools are now available as computer based resources.

Additionally, increased emphasis has been placed on performance of high quality safety evaluations and maintenance of the design basis.

Failed Com onent Identificatio Not applicable Previous Similar Events 315/95-004-00 NRC FORM 366A (4-95)