ML17325B586

LER 99-002-00:on 990415,discovered That TS 4.0.5 Requirements Were Not Met Due to Improperly Performed Test. Caused by Incorrect Interpretation of ASME Code.App J Testing Will Be Completed & Procedures Will Be Revised

ML17325B586
Person / Time
Site:	Cook
Issue date:	05/10/1999
From:	Depuydt M INDIANA MICHIGAN POWER CO.
To:
Shared Package
ML17325B585	List: ML17325B584 ML17325B586
References
LER-99-002-01, LER-99-2-1, NUDOCS 9905170112
Download: ML17325B586 (3)

Text

NRC Form 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 31604104 EXPIRES 06/30/2001 (6-1 998) ESTRIATED BURDEN PER RESPONSE TO COMPLY WITH THIS MANDATORY INFORMATION COLLECTION RECUESTI 500 HRS. REPORTED LESSONS LEARNED ARE INCORPORATED INTO THE UCENSING PROCESS AND FED BACK TO INDUSTRY>

LICENSEE EVENT REPORT (LER) FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION AND RECORDS MANAGEMENT BRANCH IT4) Fss), U.S. NUCLEAR REGULATORY CcsraIISSIOH, WASHINGTON. DC 205554001. AND TO THE PAPERWORK REDUCTION PROIECT O1500104). OFFICE OF MANAGEMENT AND'BUDGET. WASHINGTON. DC (See reverse for required number of 20503 digits/characters for each block)

FACILITYNAME I1) DOCKET NUMBER I2) PAGE I3)

Cook Nuclear Plant Unit 2 05000-316 1 of3 TITLE (4)

Requirements of Technical Specification 4.0.5 Not Met Due to Improperly Performed Test EVENT DATE (6) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED(8)

FACIUTY NAME DOCKET NUMBER SEQUENTIAL REVISION MONTH DAY YEAR YEAR NUMBER NUMBER MONTH DAY YEAR FACIUTY NAME DOCKET NUMBER 04 15 1996 1999 002 00 05 10 1999 OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR li: (Check one or more) (11)

MODE (9) 20.2201 (b) 20.2203(a)(2)(v) 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) 00 73.71 20.2203(a)(2)(l) 20.2203(a)(3)(ii) 50.73(a)(2)(iii) 20.2203(a)(2)(ii) 20.2203(a)(4) 50.73(a)(2)(iv) OTHER 20.2203(a)(2)(iii) 50.36(c)(1) 50.73(a)(2)(v)

SpecEY In Abstract bekw 20.2203(a)(2)(lv) 50.36(c)(2) 50.73(a)(2)(vii) or n NRC Ferns 36BA LICENSEE CONTACT FOR THIS LER (12)

TELEPHONE NUMBER 0nrdodeArea Code)

Ms. M. B. Depuydt, Compliance Engineer 616/465-5901, x1 589 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

REPORTABLE REPORTABLE TO CAUSE SYSTEM COMPONENT MANUFACTURER TO EPIX CAUSE COMPONENT MANUFACTURER EPIX SUPPLEMENTAL REPORT EXPECTED 14 EXPECTED YEAR YES SUBMISSION If Yes, corn lete EXPECTED SUBMISSION DATE NO DATE 15 Abstract (Umit to 1400 spaces, i.e. approximately 15 single-spaced typewritten lines) (16)

~

On April 15, 1996, with Unit 2 in Mode 6, the containment sump pump discharge piping at containment penetration 2-CPN-41 was pressurized for approximately one minute to perform an Insefvice Inspection (ISI) system functional pressu're test.

ASME Code,Section XI required the line to be pressurized for at least ten'inutes for the test. At the time, the one-minute test was considered an acceptable alternative to the ten-minute test. On April 9, 1999, this was identified as an incorrect test method, which did not meet the requirements of the surveillance. Since the requirements of Technical Specification 4.0.5 were not met, this event is reportable under 10 CFR 50.73(a)(2)(i)(B), as an operation prohibited by the plant's Technical Specifications.

The apparent cause of the event was an incorrect interpretation of the ASME Code. No immediate corrective actions were required as the unit is currently in Mode 5 and containment integrity is not required. The Appendix J testing for the penetration piping will be completed prior to restart of the unit. Procedures are being revised to strengthen the ISI program and the interface with the, program coordinator. Based on the satisfactory results of Appendix J testing performed on the same penetration and a work history of no leakage, it has been determined that there is no safety significance associated with the incorrectly performed test.

The root cause investigation for this event has not been completed. If significant changes to the LER are needed as a result of the completion of the investigation, a supplemental report to this LER will be submitted.

9905170ii2 990510 PDR ADQCK 050003lh S

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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 2 05000-316 NUMBER NUMBER 2of3 1999 002 00 TEXT (Ifmore space is required, use additional copies of NRC Form (366A) (17)

Conditions Prior to Event Unit 2 was in Mode 6, Refueling Descri tion of Event On April 15, 1996, during the second Inservice Inspection (ISI) interval, the containment sump pump discharge piping at containment penetration 2-CPN-41 was pressurized, using the sump pump, for approxiryately one minute to perform an ISI system functional pressure test: The 1983 ASME Section XI, Article IWA-5213(b), "Test Condition Holding Time", required the piping to be pressurized for at least ten minutes. The test personnel considered the one-minute test an acceptable equivalent to the ten-minute test. It was desirable to shorten the test time because the sump does not hold enough water to keep the sump pump running for 10 minutes without being refilled.

This condition was Identified as a result of a self-assessment of the ISI pressure test program that was initiated in November 1998. The assessment was conducted to determine the adequacy of the ISI Program. During the assessment the acceptability of the shorter hold time was questioned, and it was subsequently determined that it was not acceptable to decrease the hold time to 1 minute. The self-assessment identified a number of minor issues, however, the pressure test of the 2-CPN-41 piping was the only test or examination identified that did not meet the Code requirements.

Cause of Event The apparent cause of the event was an incorrect interpretation of the ASME Code. Test'personnel believed the test acceptable because of a note in the Job Order which stated "10 minute hold time not required per ANII (Authorized Nuclear Inseivice Inspector) since pump cannot be run for that length of time". This was apparently based on an incorrect interpretation of Article IWA-2240, "Alternative Examinations", of the 1983 Edition of Section XI with Addenda through Summer 1983. Test personnel believed the test was acceptable based on the ANII's sign off of the test and the incorrect interpretation.

Anal sis of Event This event is reportable under 10 CFR 50.73(a)(2)(i)(B), as operation prohibited by the plant's Technical Specifications.

The. requirements of Technical Specification 4.0.5, Surveillance Requirements for Inservice Inspection and Testing of ASME Code Class 1, 2 and 3 components were not met.

This specification ensures that Inseivice Inspection of ASME Code class 1, 2 and 3 components and Inseivice Testing of ASME Code Class 1, 2, and 3 pumps and valves will be performed in accordance with a periodically updated version of Section XI for the ASME Boiler and Pressure Vessel Code and Addenda as required by 10CFR50.55a.

During the second Inservice Inspection interval a system functional test was performed on containment penetration 2-CPN-

41. This test did not meet the Code requirements for pressure hold time, but was declared to be acceptable based on an incorrect interpretation qf Code requirements. A review of the testing performed on this penetration for both the first and second intervals revealed that all other testing, hydrostatic, Appendix J -,B 8 C, and ILRT, had acceptable results. These tests were all performed in accordance with the requirements.

Since Appendix J test results from earlier in the same Inservice Inspection interval verified that the penetration was acceptable, and the penetration does not have a history of work requests that would indicate leakage problems, it has been determined that there is no safety significance associated with the test that was performed incorrectly.

NRC FORM 366A (6-1998)

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (6-1 998)

LICENSEE EVENT REPORT tLER)

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

YEAR SEQUENTIAL REVISION Cook Nuclear Plant Unit 2 05000-316 NUMBER NUMBER 3of3 1999 002 00 TEXT (ifmore space is required, use additional copies of NRC Form (366A) (17)

Corrective Actions No immediate corrective actions were necessary since the unit is currently in Mode 5 and containment integrity is not required.

A relief request to apply Code Case N-522 for system pressure testing of Class 2 components at containment penetrations was submitted to the NRC in November 1996 to request approval for the Appendix J alternative method of testing. This request was approved in July 1997 for use during the third ISI interval and will be applied to 2-CPN-41, which will be tested prior to restart of the unit. The relief granted allows testing in accordance with Appendix J as long as the maximum pressure that will be seen during an accident is used. This is being incorporated into the overall ISI Program, as well as the appropriate procedures.

12 QHP 5070 NDE.002, Visual VT-2 Examinations: lnservice and Repair/Replacements", will be revised to require consultation with the ISI Program Coordinator when problems are encountered with a test, and to delete any references to interface with the ANII. The ISI Program Coordinator will consult with the ANII when appropriate.

The expectations for the interface with the ANII has been added to procedure PMP-5070, "Inservice Inspection Program Implementation", which is being drafted. This procedure will also contain detail on how the ISI Program requirements will be administered, provide information on requesting relief, and specify who can grant relief.

A formal meeting to thoroughly discussSection XI, IWA-2240 has been held with personnel involved with the ISI program.

The ANII also attended the meeting. This meeting provided information as to when relief requests are to be written to deviate from Code requirements and when exemptions from regulatory requirements are required.

Job Orders (JOS) associated with ISI testing, that have already been written, will be reviewed to determine if other JOs contain notes which could lead to the misinterpretation of Code requirements. This review will be performed for both units, and any notes found will be dispositioned appropriately by the ISI program coordinator.

The root cause investigation for this event has not been completed. If significant changes to the LER are identified as a result of the completion of the investigation, a supplemental report to this LER will be submitted.

Previous Similar Events None NRC FORM 366A (6-1 998)