ML20045A543

LER 93-020-00:on 930507,determined That H2/O2 Sys Not Leak Tested to Verify Primary Containment Integrity During Testing of Sys.Caused by Failure to Have Administrative Controls in Place.Pressure Testing conducted.W/930605 Ltr

ML20045A543
Person / Time
Site:	Cooper
Issue date:	06/05/1993
From:	Gardner R, Myers J NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CNSS933133, LER-93-020, LER-93-20, NUDOCS 9306110047
Download: ML20045A543 (4)

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COOPER NUCLEAR ST ATION Nebraska Public Power District '" " "A*c" 7"NR@!O.^n*^ ""

CNSS933133-June 5,-1993 U.S. Nuclear Regulatory Commission '

Document Ccntrol Desk Washington, D.C. 20555 t

Dear Sir:

Cooper Nuclear Station Licensee Event Report 93-020, Revision 0, is forwarded as .

an attachment to this letter.

Sincerely, R. L. Cardner .;

Plant Manager

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t cc: J. L. Milhoan 2

G. R. Horn J. M. Meacham ,

R. E. Wilbur V. L. Wolstenholm i D. A. Whitman INPO Records Center  !

NRC Resident Inspector i R. J. Singer CNS Training CNS Quality Assurance 1

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On May 7, 1993, while reviewing the design and testing of the Hydrogen /0xygen Monitoring (H2/02) system, it was determined that the H2/02 system had not been leak tested in accordance with the requirements of the Technical Specifications. Technical Specification 4.7.A.2 requires that an Integrated Leak Rate Test (ILRT) be conducted to verify primary containment integrity. Additionally, the monitors had not been subjected to appropriate pressure during post maintenance testing in those instances where maintenance activities breached the pressure boundary of the monitors.

The 1988 design change for installation of the H2/02 monitors listed the 1LRT procedure as an affected document. A records search did not locate any procedure changes which addressed testing requirements for the monitors. The monitors were routinely secured during outages; it was not recognized that this would result in the inlet and outlet solenoid operated isolation valves being closed during performance of the ILRT.

Additionally, administrative controls were insufficient to ensure that the necessary post maintenance pressure testing of the monitors would be accomplished.

Testing of the monitors was satisfactorily conducted. Appropriate administrative controls will be established to ensure necessary testing of the monitors is performed for future maintenance and IUlT performances. A review is being conducted to verify that no similar situations exist. Other design changes will be reviewed to ensure that appropriate procedure changes have been made. The design change process has been substantially upgraded since monitor installation, including more stringent controls on the identification and processing of procedure revisions associated with new or replacement equipment.

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LICENSEE EVENT REPORT (LER) TEXT CONTINUATION mnovEo ous No. siso-oio4 LXP6RES: 8/31/88 Fl.CIUYY esAME (11 DOCKtT NUMBE R 12) LE R NUMBE R 161 PAGE (3)

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A. Event Description 1 On May 7, 1993, while reviewing the design and testing of the Hydrogen /0xygen Monitoring (H2/02) system, it was determined that the H2/02 system had not been leak tested in accordance with the requirements of the Technical Specifications. Technical Specification 4.7. A.2 requires that an Integrated Leak Rate Test (ILRT) be conducted to verify primary containment integrity. The monitoring system was installed in 1988, and ILRTs were conducted in 1988, following installation, and 1991. The monitoring system was secured during outages as monitoring of primary containment oxygen content is not required. Removing the system from service causes the suction and discharge solenoid operated isolation valves to close. With the solenoid operated valves closed, the monitors were not subjected to the ILRT pressure. Additionally, administrative controls were not established to ensure the monitors were subj ected to post maintenance pressure testing in those instances where maintenance activities breached the pressure boundary of the monitors.

B. Plant Status Shutdown for the 1993 Refueling Outage.

C. P.a s i s for Report Since the test methodology did not meet the requirements of Technical Specification 4.7.A.2, this is a condition reportable in accordance with 10CFR50.73(a)(2)(i).

D. Cause Configuration Control. The design change for the H2/02 monitors listed the ILRT procedure as an affected document. A records search did not locate any procedure changes which addressed testing requirements for the monitors. It was apparently not recognized that the monitors would be secured during the performance of the ILRT, and therefore the solenoid operated isolation valves would be closed. Additionally, appropriate administrative controls were not in place to ensure that the necessary post maintenance pressure testing of the monitors would be accomplished whenever the pressure boundary was breached.

E, Safety Significance Since testing of the monitors was not conducted in accordance with Technical Specification requirements, potential leakage would not have been identified and, if required, corrected. For leakage to have actually exceeded the allowable leakage, a gross failure of the tubing or connectors within the monitors would have been required. It is unlikely that gross failure of the high pressure rated tubing or connections would occur. More likely, minor leakage would occur which would not substantially affect the overall primary containment leakage rate.

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i F. S_afety Implications The safety implications associated with this lack of testing are fully ,

addressed above. .

G. Corrective Action l Pressure testing of the monitors has been satisfactorily conducted.

Appropriate administrative controls will be established to ensure i necessary testing of the monitor is performed for future maintenance and IIRT performances. A review is being conducted to verify that no similar testing situations exist.

Other design changes from 1987 through 1990 will be reviewed to ensure that appropriate procedure changes have been made. The design change process has been substantially upgraded since monitor installation, including more stringent controls on the identification and processing of -l procedure revisions associated with new or replacement equipment.  !

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