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{{#Wiki_filter:NRCForm366U.S.NUCLEARREGULATORY COMMISSION (6-1996)LICENSEEEVENTREPORT(LER)(Seereverseforrequirednumberofdigits/characters foreachblock)APPROVEOBY0MBNO.3(504)104 EXPIRES05/30/2001 ESTPAATED SVRDENPERRESPONSETOCOMPLYWITHTI43MANDATORY eIFORMATION COLLECTION REOVEST:500HRS.REPORTEDLESSONSLEARNEDAREerCORPORATED trfoTHELICENSINO PROCESSANOFEDSACKTOINDVSTRYFORWARDCOIVFAENTS REOARDINO SVRDENESTSJATETOTHEeIFORMATKNI ANORECORDSMANAGEMENT SRANCHIT%FaaxV.SNVCLEARREOIAATORY COLSJISSIOH.
{{#Wiki_filter:NRC Form 366 U.S.NUCLEAR REGULATORY COMMISSION (6-1996)LICENSEE EVENT REPORT (LER)(See reverse for required number of digits/characters for each block)APPROVEO BY 0MB NO.3(504)104 EXPIRES 05/30/2001 ESTPAATED SVRDEN PER RESPONSE TO COMPLY WITH TI43 MANDATORY eIFORMATION COLLECTION REOVEST: 50 0 HRS.REPORTED LESSONS LEARNED ARE erCORPORATED trfo THE LICENSINO PROCESS ANO FED SACK TO INDVSTRY FORWARD COIVFAENTS REOARDINO SVRDEN ESTSJATE TO THE eIFORMATKNI ANO RECORDS MANAGEMENT SRANCH IT%Faax V.S NVCLEAR REOIAATORY COLSJISSIOH.
WASHNOTON.
WASHNOTON.
OC20555000I, ANOTOTHEPAPERWORK REDVCTION PROJECT(3I500IDII OFFCEOFScrNAOEMENT ANDSVOOETWASHrNOTONi DC20500FACILITYNAME(1)CookNuclearPlantUnit1DOCKETNUMBER(2) 05000-315 PAOE(3)1of4TITLE(4)Victoreen Containment HighRangeRadiation MonitorsNotEnvironmentally Qualified toWithstand Post-LOCA Conditions EVENTDATE(5)LERNUMBER(6)REPORTDATE(7)OTHERFACILITIES INVOLVED(8)MONTHDAY0716YEAR1999YEARSEQUENTIAL NUMBER1999-019REVISIONNUMBER00MONTH08DAY16YEAR1999FACILITYNAMED.C.Cook-Unit2FACILITYNAMEDOCKETNUMBER05000-316 DOCKETNUMBEROPERATING MODE(9)THISREPORTISSUBMITTED PURSUANTTOTHEREQUIREMENTS OF10CFRIi:(Checkoneormor20.2201(b)20.2203(a)(2)(v) 50.73(a)(2)(i) e)(11)50.73(a)(2)(viii)
OC 20555000I, ANO TO THE PAPERWORK REDVCTION PROJECT (3I500IDII OFFCE OF ScrNAOEMENT AND SVOOET WASHrNOTONi DC 20500 FACILITY NAME (1)Cook Nuclear Plant Unit 1 DOCKETNUMBER(2) 05000-315 PAOE (3)1 of4 TITLE (4)Victoreen Containment High Range Radiation Monitors Not Environmentally Qualified to Withstand Post-LOCA Conditions EVENT DATE (5)LER NUMBER (6)REPORT DATE (7)OTHER FACILITIES INVOLVED (8)MONTH DAY 07 16 YEAR 1999 YEAR SEQUENTIAL NUMBER 1999-019 REVISION NUMBER 00 MONTH 08 DAY 16 YEAR 1999 FACILITY NAME D.C.Cook-Unit 2 FACILITY NAME DOCKET NUMBER 05000-316 DOCKET NUMBER OPERATING MODE (9)THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR Ii: (Check one or mor 20.2201 (b)20.2203(a)(2)(v) 50.73(a)(2)(i) e)(11)50.73(a)(2)(viii)
POWERLEVEL(10)020.2203(a)(1) 20.2203(a)(2)(i) 20.2203(a)(2)(ii) 20.2203(a)(2)(iii) 20.2203(a)(2)(iv) 20.2203(a)(3)(i) 20.2203(a)(3)(ii) 20.2203(a)(4) 50.36(c)(1) 50.36(c)(2)
POWER LEVEL (10)0 20.2203(a)(1) 20.2203(a)(2)(i) 20.2203(a)(2)(ii) 20.2203(a)(2)(iii) 20.2203(a)(2)(iv) 20.2203(a)(3)(i) 20.2203(a)(3)(ii) 20.2203(a)(4) 50.36(c)(1) 50.36(c)(2)
LICENSEECONTACTFORTHISLER(12)50.73(a)(2)(ii) 50.73(a)(2)(iii) 50.73(a)(2)(iv) 50.73(a)(2)(v) 50.73(a)(2)(vii) 50,73(a)(2)(x) 73.71OTHERSpeo/YinAbstractbetorvornNRCForm3SSA NAMEMs.BrendaW.O'ourke,Compliance EngineerTELEPHONE NUMBER0ndrrdeAreaCode)(616)465-5901x2604COMPLETEONELINEFOREACHCOMPONENT FAILUREDESCRIBED INTHISREPORT13CAUSESYSTEMCOMPONNTMAIJUFACTUR RREPORTABLE TOEPIXCAUSESYSTEMCOMPONENT MANUFACTURER REPORTABLE TOEPIXSUPPLEMENTAL REPORTEXPECTED14YESIIYescomleteEXPECTEDSUBMISSION DATEXEXPECTEDSUBMISSION DATE15MONTHDAYYEARAbstract(Limitto1400spaces,I.e.~approximately 15single-spaced typewritten lines)(16)OnMay21,1999,duringanEnvironmental Qualification (EQ)programself-assessment, preliminary reviewidentified thatthecontainment highrangeradiation monitors(HRRM)maynotbeenvironmentally qualified towithstand theeffectsofaLossofCoolantAccident(LOCA).Theself-assessment foundthatD.C.Cook'sevaluation ofNRCInformation Notice(IN)97-45,"Environmental Qualification Deficiency forCablesandContainment Penetration Pigtails,"
LICENSEE CONTACT FOR THIS LER (12)50.73(a)(2)(ii) 50.73(a)(2)(iii) 50.73(a)(2)(iv) 50.73(a)(2)(v) 50.73(a)(2)(vii) 50,73(a)(2)(x) 73.71 OTHER Speo/Y in Abstract betorv or nNRCForm3SSA NAME Ms.Brenda W.O'ourke, Compliance Engineer TELEPHONE NUMBER 0ndrrde Area Code)(616)465-5901 x2604 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT 13 CAUSE SYSTEM COMPON NT MAIJUFACTUR R REPORTABLE TO EPIX CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TO EPIX SUPPLEMENTAL REPORT EXPECTED 14 YES IIYes com lete EXPECTED SUBMISSION DATE X EXPECTED SUBMISSION DATE 15 MONTH DAY YEAR Abstract (Limit to 1400 spaces, I.e.~approximately 15 single-spaced typewritten lines)(16)On May 21, 1999, during an Environmental Qualification (EQ)program self-assessment, preliminary review identified that the containment high range radiation monitors (HRRM)may not be environmentally qualified to withstand the effects of a Loss of Coolant Accident (LOCA).The self-assessment found that D.C.Cook's evaluation of NRC Information Notice (IN)97-45,"Environmental Qualification Deficiency for Cables and Containment Penetration Pigtails," failed to adequately address the susceptibility of the containment HRRMs to moisture intrusion.
failedtoadequately addressthesusceptibility ofthecontainment HRRMstomoistureintrusion.
IN'97-45 identified that electrical signal cables and connectors found in HRRMs are sensitive to moisture exposure effects, such as from a LOCA or pipe break event.Industry events have identified that moisture intrusion into the cable jacket and connectors has resulted in erratic indication of radiation levels and loss of HRRM function.Based on continued evaluation of the EQ deficiencies, the Unit 1 and 2 HRRMs were declared inoperable on July 16, 1999.The apparent cause was inadequate design control.In response to NRC IN 89-63, a design change to the HRRM system added drainage features to several components.
IN'97-45identified thatelectrical signalcablesandconnectors foundinHRRMsaresensitive tomoistureexposureeffects,suchasfromaLOCAorpipebreakevent.Industryeventshaveidentified thatmoistureintrusion intothecablejacketandconnectors hasresultedinerraticindication ofradiation levelsandlossofHRRMfunction.
However, the EQ requirement that the HRRM system be leaktight against possible moisture intrusion was not considered.
Basedoncontinued evaluation oftheEQdeficiencies, theUnit1and2HRRMsweredeclaredinoperable onJuly16,1999.Theapparentcausewasinadequate designcontrol.InresponsetoNRCIN89-63,adesignchangetotheHRRMsystemaddeddrainagefeaturestoseveralcomponents.
A permanent solution for the susceptibility of the HRRMs to moisture intrusion will be developed to support HRRM operability in Modes 1-4.Options for the permanent solution are currently under review and the method selected will be implemented prior to Mode 4 for each unit.An evaluation of the as-built configuration for other low signal current application EQ equipment is also being performed to identify other electrical equipment that may be susceptible to moisture intrusion due to a LOCA and/or pipe break condition.
However,theEQrequirement thattheHRRMsystembeleaktight againstpossiblemoistureintrusion wasnotconsidered.
This evaluation will be completed by September 30, 1999.This condition has minimal safety significance due to the availability of alternate post-accident radiation monitoring instrumentation.
Apermanent solutionforthesusceptibility oftheHRRMstomoistureintrusion willbedeveloped tosupportHRRMoperability inModes1-4.Optionsforthepermanent solutionarecurrently underreviewandthemethodselectedwillbeimplemented priortoMode4foreachunit.Anevaluation oftheas-builtconfiguration forotherlowsignalcurrentapplication EQequipment isalsobeingperformed toidentifyotherelectrical equipment thatmaybesusceptible tomoistureintrusion duetoaLOCAand/orpipebreakcondition.
'3)'T)08240285 3)'T)08'PDR ADOCK 050003i 5 S PDR
Thisevaluation willbecompleted bySeptember 30,1999.Thiscondition hasminimalsafetysignificance duetotheavailability ofalternate post-accident radiation monitoring instrumentation.
'3)'T)08240285 3)'T)08'PDRADOCK050003i5SPDR


NRCFORM366AU.s.NUCLEARREGULATORY COMMISSION (6-1998)LICENSEEEVENTREPORT(LER)TEXTCONTINUATION FACILITYNAME(1)CookNuclearPlantUnit1DOCKETNUMBER(2) 05000-315 YEARLERNUMBER(6)SEQUENTIAL NUMBERREVISIONNUMBERPAGE(3)2of4TEXT(lfmorespaceisrequired, useadCh'tional copiesofNRCForm(366A)(17)Conditions PriortoEventUnit1wasinMode5,ColdShutdownUnit2wasinMode5,ColdShutdown1999-01900DescritionofEventOnMay21,1999,duringanEnvironmental Qualification (EQ)programself-assessment, preliminary reviewidentified thattheRadiation Monitoring System's(RMS)[EIIS:IL]
NRC FORM 366A U.s.NUCLEAR REGULATORY COMMISSION (6-1998)LICENSEE EVENT REPORT (LER)TEXT CONTINUATION FACILITY NAME (1)Cook Nuclear Plant Unit 1 DOCKET NUMBER(2)05000-315 YEAR LER NUMBER (6)SEQUENTIAL NUMBER REVISION NUMBER PAGE (3)2of4 TEXT (lf more space is required, use adCh'tional 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 1999-019 00 Descri tion of Event On May 21, 1999, during an Environmental Qualification (EQ)program self-assessment, preliminary review identified that the Radiation Monitoring System's (RMS)[EIIS:IL]Victoreen containment high range radiation monitors (HRRM)may not be environmentally qualified to withstand the effects of a Loss of Coolant Accident (LOCA).The self-assessment found that D.C.Cook's evaluation of NRC Information Notice (IN)97-45,"Environmental Qualification Deficiency for Cables and Containment Penetration Pigtails," failed to adequately address the susceptibility of the containment HRRMs to moisture intrusion.
Victoreen containment highrangeradiation monitors(HRRM)maynotbeenvironmentally qualified towithstand theeffectsofaLossofCoolantAccident(LOCA).Theself-assessment foundthatD.C.Cook'sevaluation ofNRCInformation Notice(IN)97-45,"Environmental Qualification Deficiency forCablesandContainment Penetration Pigtails,"
IN 97-45 identified that electrical signal cables[EIIS:CBL1]
failedtoadequately addressthesusceptibility ofthecontainment HRRMstomoistureintrusion.
and connectors
IN97-45identified thatelectrical signalcables[EIIS:CBL1]
andconnectors
[EIIS:CON]
[EIIS:CON]
foundinHRRMsaresensitive tomoistureexposureeffects,suchasfromaLOCAorpipebreakevent.Industryeventshaveidentified thatmoistureintrusion intothecablejacketandconnectors canresultinerraticindication ofradiation levelsincontainment.
found in HRRMs are sensitive to moisture exposure effects, such as from a LOCA or pipe break event.Industry events have identified that moisture intrusion into the cable jacket and connectors can result in erratic indication of radiation levels in containment.
Inaddition, Supplement 1toIN97-45identified thatHRRMshaveexperienced significant positiveandnegativecurrentflowasaresultofinducedcurrentsinRockbestos coaxialsignalcableswhenexposedtohightemperature transient conditions.
In addition, Supplement 1 to IN 97-45 identified that HRRMs have experienced significant positive and negative current flow as a result of induced currents in Rockbestos coaxial signal cables when exposed to high temperature transient conditions.
Asaresult,thedetection functionoftheHRRMswouldbeimpacted.
As a result, the detection function of the HRRMs would be impacted.Recent evaluation of the HRRM EQ deficiencies identified that in response to NRC IN 89-63,"Possible Submergence of Electrical Circuits Located Above the Flood Level Because of Water Intrusion and Lack of Drainage," D.C.Cook added drainage features (e.g., weep holes and slits in sealtite flex conduit)to the HRRM electrical enclosures (conduit and junction boxes[EIIS:JBX])
Recentevaluation oftheHRRMEQdeficiencies identified thatinresponsetoNRCIN89-63,"Possible Submergence ofElectrical CircuitsLocatedAbovetheFloodLevelBecauseofWaterIntrusion andLackofDrainage,"
in containment.
D.C.Cookaddeddrainagefeatures(e.g.,weepholesandslitsinsealtiteflexconduit)totheHRRMelectrical enclosures (conduitandjunctionboxes[EIIS:JBX])
However, this resulted in a non-leaktight HRRM configuration, potentially exposing the moisture sensitive components to LOCA conditions.
incontainment.
Based on above information, it was concluded that the Unit 1 and 2 HRRMs would not be capable of performing their intended design function.As a result, on July16, 1999, the HRRMs were declared inoperable at 1558 hours.Cause of Event The apparent cause was inadequate design control.In response to NRC IN 89-63, a design change to the HRRM system added drainage features to several components.
However,thisresultedinanon-leaktight HRRMconfiguration, potentially exposingthemoisturesensitive components toLOCAconditions.
However, the EQ requirement that the HRRM system be leaktight against possible moisture intrusion was not considered.
Basedonaboveinformation, itwasconcluded thattheUnit1and2HRRMswouldnotbecapableofperforming theirintendeddesignfunction.
Subsequent opportunities to identify this condition were missed during D.C.Cook's evaluation of IN 97-45 and its supplement.
Asaresult,onJuly16,1999,theHRRMsweredeclaredinoperable at1558hours.CauseofEventTheapparentcausewasinadequate designcontrol.InresponsetoNRCIN89-63,adesignchangetotheHRRMsystemaddeddrainagefeaturestoseveralcomponents.
The concerns identified in the Information Notice were determined not to be applicable to D.C.Cook because the HRRMs use Brand Rex signal cabling versus Rockbestos cabling as described in IN 97-45.Anal sis of Event This LER is being submitted in accordance with the requirements of 10CFR50.73(a)(2)(i)(B) for a condition prohibited by plant Technical Specifications.
However,theEQrequirement thattheHRRMsystembeleaktight againstpossiblemoistureintrusion wasnotconsidered.
TS 3.3.3.1 requires the containment HRRMs to be operable in Modes 1-4.UFSAR Section 11.3, states that the Radiation Monitoring System is designed to perform two basic functions:
Subsequent opportunities toidentifythiscondition weremissedduringD.C.Cook'sevaluation ofIN97-45anditssupplement.
1)warn of any radiation hazards which might develop, and 2)give early warning which might lead to a radiation hazard or plant damage.The RMS instruments are located at selected points in and around the plant to detect, compute, and record radiation levels.The components of the RMS are designed to operate during all expected environmental conditions for normal operation, and specific components are designed to operate during adverse or accident conditions.
Theconcernsidentified intheInformation Noticeweredetermined nottobeapplicable toD.C.CookbecausetheHRRMsuseBrandRexsignalcablingversusRockbestos cablingasdescribed inIN97-45.AnalsisofEventThisLERisbeingsubmitted inaccordance withtherequirements of10CFR50.73(a)(2)(i)(B) foracondition prohibited byplantTechnical Specifications.
The subject radiation monitors include the Victoreen containment high range radiation monitors (1-VRA-1310/1410 and 2-VRA-2310/2410) which provide indication of containment radiation levels during post-LOCA conditions and are utilized in assessing possible core damage.NRC FORM 366A (6-1998)
TS3.3.3.1requiresthecontainment HRRMstobeoperableinModes1-4.UFSARSection11.3,statesthattheRadiation Monitoring Systemisdesignedtoperformtwobasicfunctions:
NRC FORM 366A U.s.NUCLEAR REGULATORY COMMISSION (6-1998)LICENSEE EVENT REPORT (LER)TEXT CONTINUATION FACILITY NAME (1)Cook Nuclear Plant Unit 1 OOCKET NUMBER(2)05000-315 YEAR 1999 LER NUMBER (6)SEQUENTIAL NUMBER 019 REVISION NUMBER 00 PAGE (3)3of4 TEXT (if more space is required, use addi(tonal copies of NRC Form (366A)(17)A typical HRRM consists of a detector, associated Brand Rex triaxial cabling, conduit, junction boxes and Amphenol connectors.
1)warnofanyradiation hazardswhichmightdevelop,and2)giveearlywarningwhichmightleadtoaradiation hazardorplantdamage.TheRMSinstruments arelocatedatselectedpointsinandaroundtheplanttodetect,compute,andrecordradiation levels.Thecomponents oftheRMSaredesignedtooperateduringallexpectedenvironmental conditions fornormaloperation, andspecificcomponents aredesignedtooperateduringadverseoraccidentconditions.
Amphenol connectors are located at the penetration pigtails and other electrical cable connections, and at a junction box located at the top of the containment penetration flood-up tubes.Each Amphenol connector is enclosed in a Raychem boot seal, with the associated detector cabling contained within a conduit system.The junction box and conduit system contain weep holes which were added in response to NRC IN 89-63.EQ testing performed by Victoreen in 1978 experienced numerous failures in attempting to qualify a connector assembly for in-containment LOCA use.The only documented successful simulated LOCA testing was for cable and connectors that were enclosed in leaktight conduits.This configuration prevents moisture intrusion into the cable and connectors during post-LOCA conditions.
Thesubjectradiation monitorsincludetheVictoreen containment highrangeradiation monitors(1-VRA-1310/1410 and2-VRA-2310/2410) whichprovideindication ofcontainment radiation levelsduringpost-LOCA conditions andareutilizedinassessing possiblecoredamage.NRCFORM366A(6-1998)
NRC IN 97-45, identified potential EQ deficiencies associated with Rockbestos coaxial cables and Amphenol connectors used in containment HRRM systems.Subsequent vendor EQ testing concluded that moisture could permeate the HRRM coaxial cable jacket during p LOCA and cause partial shorting of the monitor signal at the connectors.
NRCFORM366AU.s.NUCLEARREGULATORY COMMISSION (6-1998)LICENSEEEVENTREPORT(LER)TEXTCONTINUATION FACILITYNAME(1)CookNuclearPlantUnit1OOCKETNUMBER(2) 05000-315 YEAR1999LERNUMBER(6)SEQUENTIAL NUMBER019REVISIONNUMBER00PAGE(3)3of4TEXT(ifmorespaceisrequired, useaddi(tonal copiesofNRCForm(366A)(17)AtypicalHRRMconsistsofadetector, associated BrandRextriaxialcabling,conduit,junctionboxesandAmphenolconnectors.
Because of the small signal current output from the HRRMs (nominally pico-amperes), partial shorting of the signal could result in loss of HRRM function.In addition, Supplement 1 identified that HRRMs cabling is susceptible to thermally-induced currents as a result of extreme temperature transients.
Amphenolconnectors arelocatedatthepenetration pigtailsandotherelectrical cableconnections, andatajunctionboxlocatedatthetopofthecontainment penetration flood-uptubes.EachAmphenolconnector isenclosedinaRaychembootseal,withtheassociated detectorcablingcontained withinaconduitsystem.ThejunctionboxandconduitsystemcontainweepholeswhichwereaddedinresponsetoNRCIN89-63.EQtestingperformed byVictoreen in1978experienced numerousfailuresinattempting toqualifyaconnector assemblyforin-containment LOCAuse.Theonlydocumented successful simulated LOCAtestingwasforcableandconnectors thatwereenclosedinleaktight conduits.
Thermally-induced currents have been found to impact the accuracy of the HRRMs.E In 1990, drainage features were added to D.C.Cook's HRRM system in response to NRC IN 89-63.Industry concerns were identified regarding the lack of drainage holes in containment electrical enclosures that may become submerged during a LOCA event.Without the appropriate drainage, water could collect inside the enclosures and cause shorting of the electrical components contained in the enclosures.
Thisconfiguration preventsmoistureintrusion intothecableandconnectors duringpost-LOCA conditions.
Although D.C.Cook's HRRM conduit system contains weep holes, the moisture intrusion potential of the subject connectors is much more limited than that described in the Victoreen test reports and NRC IN 97-45.In these tests, the coaxial cable and sealed connectors were directly exposed to steam and spray conditions, whereas D.C.Cook's cable and sealed connectors are contained within a conduit system.Because of the additional protection given by the conduit system, the maximum amount of moisture that could potentially come in contact with the connectors is limited by the internal free air space of the conduit.During the increasing containment pressure portion of a LOCA transient, the steam would fill the conduit, displacing the air inside the conduit and result in the trapped steam condensing on the colder cable and conduit internal walls.This amount of moisture intrusion is much more limited than would occur in an open system (i.e., with no conduit enclosure).
NRCIN97-45,identified potential EQdeficiencies associated withRockbestos coaxialcablesandAmphenolconnectors usedincontainment HRRMsystems.Subsequent vendorEQtestingconcluded thatmoisturecouldpermeatetheHRRMcoaxialcablejacketduringpLOCAandcausepartialshortingofthemonitorsignalattheconnectors.
The design function of the containment HRRMs is to provide operators with post-LOCA indication of containment radiation levels which are also utilized in assessing possible core damage.Although the identified EQ deficiencies could render the HRRMs inoperable following a LOCA, alternative means of performing this monitoring function exist through other post-accident monitoring instrumentation.
BecauseofthesmallsignalcurrentoutputfromtheHRRMs(nominally pico-amperes),
This includes the post-accident monitoring system and the post-accident grab sample pallet in accordance with plant emergency procedures.
partialshortingofthesignalcouldresultinlossofHRRMfunction.
Based on the above information, the identified condition has minimal safety significance due to the availability of alternate post-accident radiation monitoring instrumentation.
Inaddition, Supplement 1identified thatHRRMscablingissusceptible tothermally-inducedcurrentsasaresultofextremetemperature transients.
Corrective Actions A permanent solution for the susceptibility of the HRRMs to moisture intrusion will be developed to support HRRM operability in Modes 1-4.Options for the permanent solution are currently under review and will be implemented prior to Mode 4 for each unit.An evaluation of the as-built configuration for other low signal current application EQ equipment is being performed to identify other additional electrical equipment that may be susceptible to moisture intrusion due to a LOCA or pipe break condition.
Thermally-induced currentshavebeenfoundtoimpacttheaccuracyoftheHRRMs.EIn1990,drainagefeatureswereaddedtoD.C.Cook'sHRRMsysteminresponsetoNRCIN89-63.Industryconcernswereidentified regarding thelackofdrainageholesincontainment electrical enclosures thatmaybecomesubmerged duringaLOCAevent.Withouttheappropriate
The evaluation will include a review of the current EQ Program documentation regarding requirements for NRC FORM 366A (6-1998)
: drainage, watercouldcollectinsidetheenclosures andcauseshortingoftheelectrical components contained intheenclosures.
NRC FORM 366A U.S.NUCLEAR REGULATORY COMMISSION (6-1 998)LICENSEE EVENT REPORT (LER)TEXT CONTINUATION FACILITY NAME (1)Cook Nuclear Plant Unit 1 DOCKET NUMBER(2)05000-315 YEAR 1999 LER NUMBER (6)SEQUENTIAL NUMBER 019 REVISION NUMBER 00 PAGE (3)4 of 4 TEXT (lf more space is required, use additional copies of NRC Eorm (366A)(17)leaktight electrical enclosures.
AlthoughD.C.Cook'sHRRMconduitsystemcontainsweepholes,themoistureintrusion potential ofthesubjectconnectors ismuchmorelimitedthanthatdescribed intheVictoreen testreportsandNRCIN97-45.Inthesetests,thecoaxialcableandsealedconnectors weredirectlyexposedtosteamandsprayconditions, whereasD.C.Cook'scableandsealedconnectors arecontained withinaconduitsystem.Becauseoftheadditional protection givenbytheconduitsystem,themaximumamountofmoisturethatcouldpotentially comeincontactwiththeconnectors islimitedbytheinternalfreeairspaceoftheconduit.Duringtheincreasing containment pressureportionofaLOCAtransient, thesteamwouldfilltheconduit,displacing theairinsidetheconduitandresultinthetrappedsteamcondensing onthecoldercableandconduitinternalwalls.Thisamountofmoistureintrusion ismuchmorelimitedthanwouldoccurinanopensystem(i.e.,withnoconduitenclosure).
This evaluation will be completed by September 30, 1999.Based on results of the evaluation, appropriate corrective actions will be taken to address any identified EQ discrepancies.
Thedesignfunctionofthecontainment HRRMsistoprovideoperators withpost-LOCA indication ofcontainment radiation levelswhicharealsoutilizedinassessing possiblecoredamage.Althoughtheidentified EQdeficiencies couldrendertheHRRMsinoperable following aLOCA,alternative meansofperforming thismonitoring functionexistthroughotherpost-accidentmonitoring instrumentation.
AEP:NRC:1260GH,"Enforcement Actions 98-150, 98-151, 98-1 52 and 98-186 Reply to Notice Of Violation October 13, 1998", dated March 19, 1999, responded to identified programmatic weaknesses in the plant Design and Licensing Basis and the Training and Qualification of personnel.
Thisincludesthepost-accident monitoring systemandthepost-accident grabsamplepalletinaccordance withplantemergency procedures.
The Engineering Leadership Plan establishes a configuration management program to control plant design and a new design control process, which includes design verification, design document control, vendor technical documentation control and testing of design changes.As part of the Restart effort, an improved operating experience program is being developed.
Basedontheaboveinformation, theidentified condition hasminimalsafetysignificance duetotheavailability ofalternate post-accident radiation monitoring instrumentation.
In addition, the Expanded System Readiness Review project teams are evaluating operating experience information to assess whether applicable industry'issues have been adequately addressed for applicability to D.C.Cook.Previous Similar Events None NRC FORM 366A (6-1998)}}
Corrective ActionsApermanent solutionforthesusceptibility oftheHRRMstomoistureintrusion willbedeveloped tosupportHRRMoperability inModes1-4.Optionsforthepermanent solutionarecurrently underreviewandwillbeimplemented priortoMode4foreachunit.Anevaluation oftheas-builtconfiguration forotherlowsignalcurrentapplication EQequipment isbeingperformed toidentifyotheradditional electrical equipment thatmaybesusceptible tomoistureintrusion duetoaLOCAorpipebreakcondition.
Theevaluation willincludeareviewofthecurrentEQProgramdocumentation regarding requirements forNRCFORM366A(6-1998)
NRCFORM366AU.S.NUCLEARREGULATORY COMMISSION (6-1998)LICENSEEEVENTREPORT(LER)TEXTCONTINUATION FACILITYNAME(1)CookNuclearPlantUnit1DOCKETNUMBER(2) 05000-315 YEAR1999LERNUMBER(6)SEQUENTIAL NUMBER019REVISIONNUMBER00PAGE(3)4of4TEXT(lfmorespaceisrequired, useadditional copiesofNRCEorm(366A)(17)leaktight electrical enclosures.
Thisevaluation willbecompleted bySeptember 30,1999.Basedonresultsoftheevaluation, appropriate corrective actionswillbetakentoaddressanyidentified EQdiscrepancies.
AEP:NRC:1260GH, "Enforcement Actions98-150,98-151,98-152and98-186ReplytoNoticeOfViolation October13,1998",datedMarch19,1999,responded toidentified programmatic weaknesses intheplantDesignandLicensing BasisandtheTrainingandQualification ofpersonnel.
TheEngineering Leadership Planestablishes aconfiguration management programtocontrolplantdesignandanewdesigncontrolprocess,whichincludesdesignverification, designdocumentcontrol,vendortechnical documentation controlandtestingofdesignchanges.AspartoftheRestarteffort,animprovedoperating experience programisbeingdeveloped.
Inaddition, theExpandedSystemReadiness Reviewprojectteamsareevaluating operating experience information toassesswhetherapplicable industry'issues havebeenadequately addressed forapplicability toD.C.Cook.PreviousSimilarEventsNoneNRCFORM366A(6-1998)}}

Revision as of 09:18, 6 July 2018

LER 99-019-00:on 990716,noted Victoreen Containment Hrrms Not Environmentally Qualified to Withstand post-LOCA Conditions.Caused by Inadequate Design Control.Reviewing Options to Support Hrrms Operability in Modes 1-4
ML17326A091
Person / Time
Site: Cook American Electric Power icon.png
Issue date: 08/16/1999
From: OROURKE B W
AMERICAN ELECTRIC POWER CO., INC.
To:
Shared Package
ML17326A090 List:
References
LER-99-019, NUDOCS 9908240285
Download: ML17326A091 (5)


Text

NRC Form 366 U.S.NUCLEAR REGULATORY COMMISSION (6-1996)LICENSEE EVENT REPORT (LER)(See reverse for required number of digits/characters for each block)APPROVEO BY 0MB NO.3(504)104 EXPIRES 05/30/2001 ESTPAATED SVRDEN PER RESPONSE TO COMPLY WITH TI43 MANDATORY eIFORMATION COLLECTION REOVEST: 50 0 HRS.REPORTED LESSONS LEARNED ARE erCORPORATED trfo THE LICENSINO PROCESS ANO FED SACK TO INDVSTRY FORWARD COIVFAENTS REOARDINO SVRDEN ESTSJATE TO THE eIFORMATKNI ANO RECORDS MANAGEMENT SRANCH IT%Faax V.S NVCLEAR REOIAATORY COLSJISSIOH.

WASHNOTON.

OC 20555000I, ANO TO THE PAPERWORK REDVCTION PROJECT (3I500IDII OFFCE OF ScrNAOEMENT AND SVOOET WASHrNOTONi DC 20500 FACILITY NAME (1)Cook Nuclear Plant Unit 1 DOCKETNUMBER(2) 05000-315 PAOE (3)1 of4 TITLE (4)Victoreen Containment High Range Radiation Monitors Not Environmentally Qualified to Withstand Post-LOCA Conditions EVENT DATE (5)LER NUMBER (6)REPORT DATE (7)OTHER FACILITIES INVOLVED (8)MONTH DAY 07 16 YEAR 1999 YEAR SEQUENTIAL NUMBER 1999-019 REVISION NUMBER 00 MONTH 08 DAY 16 YEAR 1999 FACILITY NAME D.C.Cook-Unit 2 FACILITY NAME DOCKET NUMBER 05000-316 DOCKET NUMBER OPERATING MODE (9)THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR Ii: (Check one or mor 20.2201 (b)20.2203(a)(2)(v) 50.73(a)(2)(i) e)(11)50.73(a)(2)(viii)

POWER LEVEL (10)0 20.2203(a)(1) 20.2203(a)(2)(i) 20.2203(a)(2)(ii) 20.2203(a)(2)(iii) 20.2203(a)(2)(iv) 20.2203(a)(3)(i) 20.2203(a)(3)(ii) 20.2203(a)(4) 50.36(c)(1) 50.36(c)(2)

LICENSEE CONTACT FOR THIS LER (12)50.73(a)(2)(ii) 50.73(a)(2)(iii) 50.73(a)(2)(iv) 50.73(a)(2)(v) 50.73(a)(2)(vii) 50,73(a)(2)(x) 73.71 OTHER Speo/Y in Abstract betorv or nNRCForm3SSA NAME Ms.Brenda W.O'ourke, Compliance Engineer TELEPHONE NUMBER 0ndrrde Area Code)(616)465-5901 x2604 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT 13 CAUSE SYSTEM COMPON NT MAIJUFACTUR R REPORTABLE TO EPIX CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TO EPIX SUPPLEMENTAL REPORT EXPECTED 14 YES IIYes com lete EXPECTED SUBMISSION DATE X EXPECTED SUBMISSION DATE 15 MONTH DAY YEAR Abstract (Limit to 1400 spaces, I.e.~approximately 15 single-spaced typewritten lines)(16)On May 21, 1999, during an Environmental Qualification (EQ)program self-assessment, preliminary review identified that the containment high range radiation monitors (HRRM)may not be environmentally qualified to withstand the effects of a Loss of Coolant Accident (LOCA).The self-assessment found that D.C.Cook's evaluation of NRC Information Notice (IN)97-45,"Environmental Qualification Deficiency for Cables and Containment Penetration Pigtails," failed to adequately address the susceptibility of the containment HRRMs to moisture intrusion.

IN'97-45 identified that electrical signal cables and connectors found in HRRMs are sensitive to moisture exposure effects, such as from a LOCA or pipe break event.Industry events have identified that moisture intrusion into the cable jacket and connectors has resulted in erratic indication of radiation levels and loss of HRRM function.Based on continued evaluation of the EQ deficiencies, the Unit 1 and 2 HRRMs were declared inoperable on July 16, 1999.The apparent cause was inadequate design control.In response to NRC IN 89-63, a design change to the HRRM system added drainage features to several components.

However, the EQ requirement that the HRRM system be leaktight against possible moisture intrusion was not considered.

A permanent solution for the susceptibility of the HRRMs to moisture intrusion will be developed to support HRRM operability in Modes 1-4.Options for the permanent solution are currently under review and the method selected will be implemented prior to Mode 4 for each unit.An evaluation of the as-built configuration for other low signal current application EQ equipment is also being performed to identify other electrical equipment that may be susceptible to moisture intrusion due to a LOCA and/or pipe break condition.

This evaluation will be completed by September 30, 1999.This condition has minimal safety significance due to the availability of alternate post-accident radiation monitoring instrumentation.

'3)'T)08240285 3)'T)08'PDR ADOCK 050003i 5 S PDR

NRC FORM 366A U.s.NUCLEAR REGULATORY COMMISSION (6-1998)LICENSEE EVENT REPORT (LER)TEXT CONTINUATION FACILITY NAME (1)Cook Nuclear Plant Unit 1 DOCKET NUMBER(2)05000-315 YEAR LER NUMBER (6)SEQUENTIAL NUMBER REVISION NUMBER PAGE (3)2of4 TEXT (lf more space is required, use adCh'tional 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 1999-019 00 Descri tion of Event On May 21, 1999, during an Environmental Qualification (EQ)program self-assessment, preliminary review identified that the Radiation Monitoring System's (RMS)[EIIS:IL]Victoreen containment high range radiation monitors (HRRM)may not be environmentally qualified to withstand the effects of a Loss of Coolant Accident (LOCA).The self-assessment found that D.C.Cook's evaluation of NRC Information Notice (IN)97-45,"Environmental Qualification Deficiency for Cables and Containment Penetration Pigtails," failed to adequately address the susceptibility of the containment HRRMs to moisture intrusion.

IN 97-45 identified that electrical signal cables[EIIS:CBL1]

and connectors

[EIIS:CON]

found in HRRMs are sensitive to moisture exposure effects, such as from a LOCA or pipe break event.Industry events have identified that moisture intrusion into the cable jacket and connectors can result in erratic indication of radiation levels in containment.

In addition, Supplement 1 to IN 97-45 identified that HRRMs have experienced significant positive and negative current flow as a result of induced currents in Rockbestos coaxial signal cables when exposed to high temperature transient conditions.

As a result, the detection function of the HRRMs would be impacted.Recent evaluation of the HRRM EQ deficiencies identified that in response to NRC IN 89-63,"Possible Submergence of Electrical Circuits Located Above the Flood Level Because of Water Intrusion and Lack of Drainage," D.C.Cook added drainage features (e.g., weep holes and slits in sealtite flex conduit)to the HRRM electrical enclosures (conduit and junction boxes[EIIS:JBX])

in containment.

However, this resulted in a non-leaktight HRRM configuration, potentially exposing the moisture sensitive components to LOCA conditions.

Based on above information, it was concluded that the Unit 1 and 2 HRRMs would not be capable of performing their intended design function.As a result, on July16, 1999, the HRRMs were declared inoperable at 1558 hours0.018 days <br />0.433 hours <br />0.00258 weeks <br />5.92819e-4 months <br />.Cause of Event The apparent cause was inadequate design control.In response to NRC IN 89-63, a design change to the HRRM system added drainage features to several components.

However, the EQ requirement that the HRRM system be leaktight against possible moisture intrusion was not considered.

Subsequent opportunities to identify this condition were missed during D.C.Cook's evaluation of IN 97-45 and its supplement.

The concerns identified in the Information Notice were determined not to be applicable to D.C.Cook because the HRRMs use Brand Rex signal cabling versus Rockbestos cabling as described in IN 97-45.Anal sis of Event This LER is being submitted in accordance with the requirements of 10CFR50.73(a)(2)(i)(B) for a condition prohibited by plant Technical Specifications.

TS 3.3.3.1 requires the containment HRRMs to be operable in Modes 1-4.UFSAR Section 11.3, states that the Radiation Monitoring System is designed to perform two basic functions:

1)warn of any radiation hazards which might develop, and 2)give early warning which might lead to a radiation hazard or plant damage.The RMS instruments are located at selected points in and around the plant to detect, compute, and record radiation levels.The components of the RMS are designed to operate during all expected environmental conditions for normal operation, and specific components are designed to operate during adverse or accident conditions.

The subject radiation monitors include the Victoreen containment high range radiation monitors (1-VRA-1310/1410 and 2-VRA-2310/2410) which provide indication of containment radiation levels during post-LOCA conditions and are utilized in assessing possible core damage.NRC FORM 366A (6-1998)

NRC FORM 366A U.s.NUCLEAR REGULATORY COMMISSION (6-1998)LICENSEE EVENT REPORT (LER)TEXT CONTINUATION FACILITY NAME (1)Cook Nuclear Plant Unit 1 OOCKET NUMBER(2)05000-315 YEAR 1999 LER NUMBER (6)SEQUENTIAL NUMBER 019 REVISION NUMBER 00 PAGE (3)3of4 TEXT (if more space is required, use addi(tonal copies of NRC Form (366A)(17)A typical HRRM consists of a detector, associated Brand Rex triaxial cabling, conduit, junction boxes and Amphenol connectors.

Amphenol connectors are located at the penetration pigtails and other electrical cable connections, and at a junction box located at the top of the containment penetration flood-up tubes.Each Amphenol connector is enclosed in a Raychem boot seal, with the associated detector cabling contained within a conduit system.The junction box and conduit system contain weep holes which were added in response to NRC IN 89-63.EQ testing performed by Victoreen in 1978 experienced numerous failures in attempting to qualify a connector assembly for in-containment LOCA use.The only documented successful simulated LOCA testing was for cable and connectors that were enclosed in leaktight conduits.This configuration prevents moisture intrusion into the cable and connectors during post-LOCA conditions.

NRC IN 97-45, identified potential EQ deficiencies associated with Rockbestos coaxial cables and Amphenol connectors used in containment HRRM systems.Subsequent vendor EQ testing concluded that moisture could permeate the HRRM coaxial cable jacket during p LOCA and cause partial shorting of the monitor signal at the connectors.

Because of the small signal current output from the HRRMs (nominally pico-amperes), partial shorting of the signal could result in loss of HRRM function.In addition, Supplement 1 identified that HRRMs cabling is susceptible to thermally-induced currents as a result of extreme temperature transients.

Thermally-induced currents have been found to impact the accuracy of the HRRMs.E In 1990, drainage features were added to D.C.Cook's HRRM system in response to NRC IN 89-63.Industry concerns were identified regarding the lack of drainage holes in containment electrical enclosures that may become submerged during a LOCA event.Without the appropriate drainage, water could collect inside the enclosures and cause shorting of the electrical components contained in the enclosures.

Although D.C.Cook's HRRM conduit system contains weep holes, the moisture intrusion potential of the subject connectors is much more limited than that described in the Victoreen test reports and NRC IN 97-45.In these tests, the coaxial cable and sealed connectors were directly exposed to steam and spray conditions, whereas D.C.Cook's cable and sealed connectors are contained within a conduit system.Because of the additional protection given by the conduit system, the maximum amount of moisture that could potentially come in contact with the connectors is limited by the internal free air space of the conduit.During the increasing containment pressure portion of a LOCA transient, the steam would fill the conduit, displacing the air inside the conduit and result in the trapped steam condensing on the colder cable and conduit internal walls.This amount of moisture intrusion is much more limited than would occur in an open system (i.e., with no conduit enclosure).

The design function of the containment HRRMs is to provide operators with post-LOCA indication of containment radiation levels which are also utilized in assessing possible core damage.Although the identified EQ deficiencies could render the HRRMs inoperable following a LOCA, alternative means of performing this monitoring function exist through other post-accident monitoring instrumentation.

This includes the post-accident monitoring system and the post-accident grab sample pallet in accordance with plant emergency procedures.

Based on the above information, the identified condition has minimal safety significance due to the availability of alternate post-accident radiation monitoring instrumentation.

Corrective Actions A permanent solution for the susceptibility of the HRRMs to moisture intrusion will be developed to support HRRM operability in Modes 1-4.Options for the permanent solution are currently under review and will be implemented prior to Mode 4 for each unit.An evaluation of the as-built configuration for other low signal current application EQ equipment is being performed to identify other additional electrical equipment that may be susceptible to moisture intrusion due to a LOCA or pipe break condition.

The evaluation will include a review of the current EQ Program documentation regarding requirements for NRC FORM 366A (6-1998)

NRC FORM 366A U.S.NUCLEAR REGULATORY COMMISSION (6-1 998)LICENSEE EVENT REPORT (LER)TEXT CONTINUATION FACILITY NAME (1)Cook Nuclear Plant Unit 1 DOCKET NUMBER(2)05000-315 YEAR 1999 LER NUMBER (6)SEQUENTIAL NUMBER 019 REVISION NUMBER 00 PAGE (3)4 of 4 TEXT (lf more space is required, use additional copies of NRC Eorm (366A)(17)leaktight electrical enclosures.

This evaluation will be completed by September 30, 1999.Based on results of the evaluation, appropriate corrective actions will be taken to address any identified EQ discrepancies.

AEP:NRC:1260GH,"Enforcement Actions98-150, 98-151, 98-1 52 and 98-186 Reply to Notice Of Violation October 13, 1998", dated March 19, 1999, responded to identified programmatic weaknesses in the plant Design and Licensing Basis and the Training and Qualification of personnel.

The Engineering Leadership Plan establishes a configuration management program to control plant design and a new design control process, which includes design verification, design document control, vendor technical documentation control and testing of design changes.As part of the Restart effort, an improved operating experience program is being developed.

In addition, the Expanded System Readiness Review project teams are evaluating operating experience information to assess whether applicable industry'issues have been adequately addressed for applicability to D.C.Cook.Previous Similar Events None NRC FORM 366A (6-1998)