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LER 99-002-00:on 990112,determined That RCS Pressurizer PORVs Had Not Been Tested,Per Ts.Caused by Inadequate Scheduling Controls Allowing Personnel Error.Surveillance Procedure Was Completed & Updated LER Will Be Submitted
	ML17335A517
Person / Time
Site:	Cook
Issue date:	02/11/1999
From:	Kosloff D; INDIANA MICHIGAN POWER CO.
To:	;
Shared Package
ML17335A516	List: ML17335A515; ML17335A517;
References
	LER-99-002, LER-99-2, NUDOCS 9902220034
	Download: ML17335A517 (5)
	v • d • e

NRC Form 366 U.S. NUCLEAR REGUlATORY COMMISSION APPROVED BY OMB NO. 31504104 EXPIRES 06/30/2001 (6-1998) ESTSJATED BVRDEN PER RESPONSE TO COMPLY WITH TISS MANDATORY OJFORMATION CotLECTION REDDEST: 50.0 HRS. REPORTED LESSONS LEARNED ARE INCORPORATED INTO THE LICENSING PROCESS AND FED BACK TO INDUSTRY.

LICENSEE EVENT REPORT (LER) FORWARD COMMENTS REGARDING BIJRDEN ESTIMATE 'ro TIIE INFORMATION AND RECORDS MANAGEMENT BRANCH (ra Fss>. U.S. NVCLEAR RECIAATORY COMMISSION, WASHINGTON, DC 205554001. AND TO THE PAPERWORK REDUCTION PROJECT tsI500100. OFFICF. OF MANAGEMENT AND BIJOGET. WASIeNGTO14, DC (See reverse for required number of 20505 digits/characters for each block) ~

FACILIlYNAME (I) DOCKET NUMBER (2) PAGE (S)

Cook Nuclear Plant Unit 1 05000-315 1of3 TITLE (4)

Failure to Perform Technical Specification Surveillance Test for Pressurizer Power Operated Relief Valves EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED(8)

ACILI NAM K NUM SEQUENTIAL REVISION MONTH DAY YEAR YEAR NUMBER NUMBER MONTH DAY YEAR A ILI NUM R 01 12 1999 1999 002 00 02 1999 OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR (I: (Ghee)( one or mo re) (11)

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

POWER 2P.2203(a)(1) 20.2203(a)(3)(i) 50.73(a)(2)(ii) 50.73(a)(2)(x)

LEVEL(10) 00 20 2203(a)(3)(n) 73.71 2P.2203(a)(2)(i) 50.73(a)(2)(iii) 2P.2203(a)(2)(ii) 20.2203(a)(4) 50.73(a)(2)(iv) OTHER 2O.22O3(a)(2)(iit) 50.36(c)(1) 50.73(a)(2)(v)

SPecrr h Abstract beIINr 20.2203(a)(2)(iv) 50.36(c)(2) 50.73(a)(2)(vii) or n NRC Form SMA LICENSEE CONTACT FOR THIS LER (12)

TELEPHONE NUMBER (Irctode Area Code)

Mr. Donald Kosloff, Licensing Engineer 616/465-5901, X2129 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

REPORTABLE REPORTABLE TO CAUSE SYSTEM COMPONENT MANUFACTURER TO EPIX CAUSE SYSTEM COMPONENT MANUFACTURER EPIX SUPPLEMENTAL REPORT EXPECTED (14) EXPECTED MONTH DAY X YES SUBMISSION 03 25 1999 (If Yes, complete EXPECTED SUBMISSION DATE) NO DATE (15)

Abstract (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (1 6)

On January 13, 1999, with Unit 1 depressurized in Mode 5, surveillance test section personnel determined that the reactor coolant system pressurizer power operated relief valves (PORVs) had not been tested as required by Technical Specification (TS) Surveillance Requirements 4.4.9.3.1a. and 4.4.9.3.1e.2.(a) for low temperature overpressure (LTOP) mitigation. The related surveillance procedure was required to be performed by January 10, 1999, but was not completed until January 13, 1999. Because of the missed surveillance the LTOP PORVs had become inoperable on January 10, 1999. Since the operators were not initially aware of the missed PORV surveillance, all actions required by TS 3.4.9.3 for inoperable PORVs had not been taken within the allowed Action times for the Limiting Condition for Operation. As the surveillance requirements had not been met, this event is reportable as operation prohibited by the plant's TS.

Inadequate scheduling controls allowed two personnel errors to cause the event. After determining the surveillance procedure due date by using the Nuclear Plant Maintenance (NPM) computer system, a surveillance scheduler failed to verify the NPM due date against the Nuclear Test Scheduler (NTS) computer scheduled due date. The NPM due date was wrong because data had not been entered correctly for the previous (December 1998) surveillance. This caused NPM to generate an erroneous surveillance due date of January 15, 1999. As corrective action, additional direct management oversight was instituted to verify that all TS surveillances are current and to improve the accuracy of future surveillance scheduling. This included emphasis on personal accountability standards and proper use of NTS. The root cause investigation for this event has not been completed. It is anticipated that, if significant changes to the LER are identified as a result of completion of the root cause investigation, an update to this LER will be submitted by March 25, 1999. At the time of the event the unit was depressurized, both LTOP PORVs remained capable of performing their safety functions, and one PORV was open (although not blocked open) for pressure control, therefore this event had no safety significance.

9902220034 'I)902iX PDR ADOCK 05000$ i5 S PDR

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

LICENSEE EVENT REPORT (LER)

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

YEAR SEQUENTIAL REVISION Cook Nuclear Plant Unit 1 05000-315 NUMBER NUMBER 2of3 1999 002 00 TEXT (Ifmore space is required, use eddilional copies of NRC Form (366A) (17)

Conditions Prior to Event Unit 1 was in Mode 5, Cold Shutdown, depressurized Descrl tion of Event On January 13, 1999, with Unit 1 in Mode 5, Operations requested the surveillance section to verify how much grace time was available for performance of surveillance test procedure 01-IHP 4030.STP.089, "Pressurizer Power Operated Relief Valve Cold Over-press'urization Bi-stable and Backup Air Pressure System Functional Test." Surveillance test section personnel then determined that the reactor coolant system (RCS) pressurizer power operated relief valves (PORVs) had not been tested at the frequency required by Technical Specification (TS) Surveillance Requirements (SR) 4.4.9.3.1a. and 4.4.9.3.1e.2.(a) for low temperature overpressure (LTOP) mitigation. These TS SR must be performed to verify PORV operability in accordance with TS Limiting Condition for Operation (LCO) 3.4.9.3 in Mode 5 when the temperature of any RCS cold leg is less than or equal to 152 degrees F and the RCS is not vented through a 2-square-inch or larger vent, or through any single blocked-open PORV. SR 4.4.9.3.1a requires the performance of a channel functional test on an LTOP PORV actuation channel at least once per 31 days when the PORV is required to be operable. SR 4.4.9.3.1e.2.(a) is required to determine that the PORV emergency air tank is operable by verifying air tank pressure instrumentation is operable by performing a channel functional test at least once per 31 days.

Surveillance procedure 01-IHP 4030.STP.089 was required to be performed by January 10, 1999. It was not performed until January 13, 1999. Because of the missed surveillance, the PORVs became inoperable on January 10, 1999. Since the operators were not initially aware of the missed PORV surveillance, the actions required by TS 3.4.9.3 for inoperable PORVs were not taken within the allowed LCO action time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for restoration of the inoperable PORVs or, if the inoperable PORVs were not restored to operability, within the allowed LCO action time of 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months for venting of the RCS through at least a 2-square-inch vent, or through any single blocked open PORV.'pon discovery of the missed surveillance, plant management determined that the LTOP PORVs could be promptly restored to operable status by completing the surveillance procedure. The surveillance was completed and the PORVs were declared operable at 21:35 hours on January 13, 1999. This was the most expeditious way to exit the LCO action statement. The completed surveillance indicated that the PORVs had remained capable of performing their safety function during the period from January 10 to January 13 while they were considered inoperable. The RCS remained depressurized during this period.

Cause of Event Preliminary investigation indicated that inadequate scheduling controls had allowed two personnel errors to cause the event. After determining the surveillance procedure completion due date by using the Nuclear Plant Maintenance (NPM) computer system, an instrument and controls suiyeillance scheduler failed to verify the due date from the NPM system computer data base against the Nuclear Test Scheduler (NTS) system computer data base scheduled due date. The NPM-scheduled due date was wrong because of improperly entered data related to completion of the previous (December 1998) surveillance. When the data was entered in NPM for the previous surveillance the "class code" field displayed on the computer screen had a correct entry which indicated that the surveillance procedure was the primary job order activity (JOA). However, there was no entry in the "PRIMARYJOA" field on the primary activity computer display screen. "YES" should have been entered in the "PRIMARYJOA" field of the primary activity screen. The "YES" entry would have activated the NPM computer program to generate a due date for the next surveillance, based on the date that the primary job order activity, the surveillance, was completed. Since there was no entry in the "PRIMARY JOA" field, NPM generated an erroneous due date of January 15, 1999, based on final close-out of other job order activity on December 15, 1998, for completion of the next surveillance. The NTS data base indicated the correct surveillance completion due date for January. The actual December surveillance completion date had been entered correctly in the NTS data base by a clerk using the date of completion from the completed December 1998 surveillance procedure.

NRC FORM 366A (6-1998)

P' NRC FORM 366A U.s. NUCLEAR REGULATORY COMMISSION (6-1998)

LICENSEE EVENT REPORT (LER)

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

YEAR SEQUENTIAL REVISION Cook Nuclear Plant Unit 1 05000-315 NUMBER NUMBER 3of3 1999 002 00 TEXT (ifmore spaceis required, use addilional copies of NRC Form (366A) (17)

Cause of the Event (continued)

The root cause investigation for this event has not been completed. Additional corrective actions may be developed based on the results of the root cause investigation. It is anticipated that, if significant changes are identified as a result of completion of the root cause investigation, an update to this LER will be submitted by March 25, 1999.

Anal sis of Event This LER is submitted in accordance with 10CFR50.73(a)(2)(i)(B) as operation prohibited by the plant's Technical Specifications.

The operability of two PORVs, or of one PORV and the residual heat removal (RHR) safety valve, ensures that the RCS will be protected from low temperature pressure transients when one or more of the RCS cold legs are less than or equal to 152 degrees F. Either LTOP PORV or the RHR safety valve has adequate relieving capability to protect the RCS from overpressurization due to postulated transients. Such transients include the start of an idle reactor coolant pump with the secondary water temperature of the steam generator less than or equal to 50 degrees F above the RCS cold leg temperature and the start of a charging pump and its injection to a water solid RCS. At the time of the event the RCS was depressurized, one PORV was open for pressure control, but not blocked, and the RHR safety valve was operable. Also, on January 13, 1999, surveillance testing of the LTOP PORVs indicated that the PORVs had remained capable of performing their safety functions during the event. Therefore this event had no safety significance.

Although this event only affected Unit 1, the same scheduling programs are used for both units.

Corrective Actions The surveillance procedure was completed and the PORVs were declared operable at 21:35 hours on January 13, 1999.

Additional direct management oversight was instituted for current TS surveillance status and future TS surveillance scheduling. The plant accountability policy was applied to the surveillance scheduler who made the surveillance test scheduling error because he had not followed procedure by failing to validate the schedule dates in the NPM data base against the schedule dates in the NTS data base. The Integrated Scheduling Manager issued "Lessons Learned" to all schedulers to remind them to use the controlled data bases to establish due dates when scheduling TS surveillance tests.

A review of all current plant TS surveillance requirements verified that all required TS surveillances were current for both units. The surveillance test section is now performing parallel tracking of scheduled TS surveillance test activities for both units. Duration of the parallel tracking will be determined based on future evaluation.

The root cause investigation for this event has not been completed. Additional corrective actions may be developed based on the results of the root cause investigation. It is anticipated that, if significant changes are identified as a result of completion of the root cause investigation, an update to this LER will be submitted by March 25, 1999.

Previous Similar Events 315/96-003-00 315/94-010-00 315/92-004-00 315/91-011-00 315/91-002-00 315/90-011-00 315/90-005-00 316/90-005-00 315/89-011-00 NRC FORM 366A (6-1998)

ML17335A517

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