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| | issue date = 10/18/1999 | | | issue date = 10/18/1999 |
| | title = LER 99-024-00:on 990708,literal TS Requirements Were Not Met by Accumlator Valve Surveillance.Caused by Misjudgement Made in Conversion from Initial DC Cook TS to W Std Ts.Submitted License Amend Request.With 991018 Ltr | | | title = LER 99-024-00:on 990708,literal TS Requirements Were Not Met by Accumlator Valve Surveillance.Caused by Misjudgement Made in Conversion from Initial DC Cook TS to W Std Ts.Submitted License Amend Request.With 991018 Ltr |
| | author name = BAKKEN A C, DEPUYDT M B | | | author name = Bakken A, Depuydt M |
| | author affiliation = INDIANA MICHIGAN POWER CO. | | | author affiliation = INDIANA MICHIGAN POWER CO. |
| | addressee name = | | | addressee name = |
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| =Text= | | =Text= |
| {{#Wiki_filter:VA.JRSVP.XJ.REGULATORY INFORMATION DISTRIBUTION SYSTEM(RIDS)<<SIACCESSION NBR:9910260103 | | {{#Wiki_filter:VA.J RSVP. X J. |
| 'OC.DATE: | | REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS) |
| 99/10/18NOTARIZED: | | <<S I ACCESSION NBR:9910260103 'OC.DATE: 99/10/18 NOTARIZED: NO DOCKET FACIL:50-315 Donald C. Cook Nuclear Power Plant, Unit 1, Indiana M 05000315 AUTH.Nlg!E .'UTHOR AFFILIATION DEPUYDT,M.B. ,Indiana Michigan Power Co. |
| NOFACIL:50-315 DonaldC.CookNuclearPowerPlant,Unit1,IndianaMAUTH.Nlg!E
| | BAKKEN,A.C. Indiana Michigan Power Co. |
| .'UTHORAFFILIATION DEPUYDT,M.B. | | RECIP.NAME RECIPIENT AFFILIATION |
| ,IndianaMichiganPowerCo.BAKKEN,A.C. | |
| IndianaMichiganPowerCo.RECIP.NAME RECIPIENT AFFILIATION DOCKET05000315
| |
|
| |
|
| ==SUBJECT:== | | ==SUBJECT:== |
| LER99-024-00:on 990708,literalTSrequirements werenotmetbyaccumlator valvesurveillance.
| | LER 99-024-00:on 990708, literal TS requirements were not met by accumlator valve surveillance. Caused by misjudgement made in conversion from initial DC Cook TS to W Std TS.Submitted A license amend request. |
| Causedbymisjudgement madeinconversion frominitialDCCookTStoWStdTS.Submitted licenseamendrequest.DISTRIBUTION CODE:IE22TCOPIESRECEIVED:LTR ENCLSIZE:TITLE:50.73/50.9 LicenseeEventReport(LER),IncidentRpt,etc.NOTES:ATERECIPIENT IDCODE/NAME LPD3-1COPIESLTTRENCL11RECIPIENT IDCODE/NAME STANG,JCOPIESLTTRENCL110INTERN.ILECENTERRES/DET/ERAB RGN3FILE01EXTERNAL:
| | T DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE: |
| LSTLOBBYWARDNOACPOORE,W.NRCPDR11111111111111NRR/DIPM/IOLBNRR/DSSA/SPLB RES/DRAA/OERAB LMITCOMARSHALLNOACQUEENER,DS NUDOCSFULLTXT111111111111DNNOTETOALL"RIDS"RECIPIENTS:
| | TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc. E NOTES: |
| PLEASEHELPUSTOREDUCEWASTE.TOHAVEYOURNAMEORORGANIZATION REMOVEDFROMDISTRIBUTION LISTSORREDUCETHENUMBEROFCOPIESRECEIVEDBYYOUORYOURORGANIZATION, CONTACTTHEDOCUMENTCONTROLDESK(DCD)ONEXTENSION 415-2083IFULLTEXTCONVERSION REQUIREDTOTALNUMBEROFCOPIESREQUIRED:
| | RECIPIENT COPIES RECIPIENT COPIES 0 ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL LPD3-1 1 1 STANG,J 1 1 INTERN . ILE CENTER 1 1 NRR/DIPM/IOLB 1 1 1 1 NRR/DSSA/SPLB 1 1 RES/DET/ERAB 1 1 RES/DRAA/OERAB 1 1 RGN3 FILE 01 1 1 EXTERNAL: L ST LOBBY WARD 1 1 LMITCO MARSHALL 1 1 NOAC POORE,W. 1 1 NOAC QUEENER,DS 1 1 NRC PDR 1 1 NUDOCS FULL TXT 1 1 D N |
| LTTR15ENCL15
| | NOTE TO ALL "RIDS" 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 ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 I FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 15 ENCL 15 |
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| IndianaMichiganPoweiCompanyCockNudearRaclOneCookRaceMgman.Ml491066164696lZINEMANAMICHIGANPOWEROctober18,1999UnitedStatesNudearRegulatory Commission DocumentControlDeskWashington, DC20555Operating LicenseDPR-58DocketNo.50-315DocumentControlManager:&hlhhl~tgtgDFRSDFD RRM~~.thfllghltlghltg:
| | Indiana Michigan Powei Company Cock Nudear Racl One Cook Race Mgman. Ml 49106 6164696l Z |
| LER315/99-024-00, "LiteralTechnical Specifications Requirement NotMetByAccumulator ValveSurveillance."
| | INEMANA MICHIGAN POWER October 18, 1999 United States Nudear Regulatory Commission Document Control Desk Washington, DC 20555 Operating License DPR-58 Docket No. 50-315 Document Control Manager: |
| Therearenocommitments identified inthissubmittal.
| | ~.thfll &hlh gh hl~tgtgDFRSDFD ltlghltg: RRM~ |
| Sincerely, A.Christopher Bakken,IIISiteVicePresident IsrdAttachment c:S.E.Dyer,NRCRegionIIIR.P.PowersP.A.BarrettR.F.GodleyR.WhaleD.HahnRecordsCenter,INPONRCResidentInspector 9910260103 991018PDRADOCK05000315SPDRAE/':~Iaiericn's EnetgI''nrlnl,'r da NRCForm366U.S.NUCLEARREGUlATORY COMMISSION (6-1998)LICENSEEEVENTREPORT(LER)(Seereverseforrequirednumberofdigits/characters foreachblock)APPROVEDBYORBNo.31504(04EXPIRES06)30/2001 ESTSAATED IKSIDENPERRESPONSETOCOLDLYIATIHTISSEQPOATORY WFORMAllON CIKIECAON REOUEST:50.0HRS.REPORTEDIESSONSLEARNEDAREWCORPOMTED WTOTIC~PROCESSAIEIFEDBACKTOSCMSTRY.FORWARDCOMMENTSREOARDINO BISICENESTNATETOTHEPFORllATION ANDRECORDSMANACEMENT lÃIANCHIT%Feej.IAS.NVCIEARRECIAATORY COMMISSOIL WASISNOTOIL OC20MSCC01. | | LER 315/99-024-00, "Literal Technical Specifications Requirement Not Met By Accumulator Valve Surveillance." |
| PIC)TOTHEP~REDVCTION reameroleoolor), | | There are no commitments identified in this submittal. |
| OFRCEOFMANAOEMENT AroIROSET,wASISNrnorA DC21500FACIUlYNAME(1)TITLE(0)CookNuclearPlantUnit1DOCKETNUMBER(2)05000-315 PAGE(0)1of3LiteralTechnical Specifications Requirement NotMetByAccumulator ValveSurveillance 07DAYYEAR081999EVENTDATE(5)1999LERNUMBER(6)SEQUENTIAL NUMBER024REVISIONNUMBER00REPORTDATE(7)MONTHDAYYEAR10181999AILINAMCookNuclearPlant2AIUTYHAMCKETNUMB05000-316 NUMOTHERFACILITIES INVOLVED(8)OPERATING MODE(9)20.2201(b)20.2203(a)(2)(v) 50.73(a)(2)(i) 50.73(a)(2)(viii)
| | Sincerely, A. Christopher Bakken, III Site Vice President Isrd Attachment c: S. E. Dyer, NRC Region III R. P. Powers P. A. Barrett R. F. Godley R. Whale D. Hahn Records Center, INPO NRC Resident Inspector 9910260103 991018 PDR ADOCK 05000315 S PDR AE/': ~I aiericn's Enetg I''nrlnl,'rda |
| THISREPORTISSUBMITTED PURSUANTTOTHEREQUIREMENTS OF10CFRIi:(Checkoneormore)(11)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)
| | |
| 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) 73.71OTHERSpeorrinADCraoIDerorrornNRCForm366AMs.MaryBethDepuydt,Regulatory Compliance TELEPHONE NUMBER(Inc4deAreaCode)(616)465-5901X1589COMPLETEONELINEFOREACHCOMPONENT FAILUREDESCRIBED INTHISREPORT(13)CAUSESYSTEMCOMPONENT MANUFACTURER REPORTABLE TOEPIXCAUSECOMPONENT MANUFACTURER REPORTABLE loEPIXSUPPLEMENTAL REPORTEXPECTED14)YES(IfYes,completeEXPECTEDSUBMISSION DATE)XNOEXPECTEDSUBMISSION DATE(15MONTHDAYAbstract(Limitto1400spaces,i.e.,approximately 15single-spaced typewritten lines)(16)OnJuly8,1999,duringareviewofTechnical Specifications (TS)surveillance procedures, itwasdiscovered thatTSSurveillance Requirement (SR)4.5.1.cwasnotbeingmetbytheassociated surveillance procedure.
| | NRC Form 366 (6-1998) |
| SR4.5.1.crequiresthatpowertotheRCSaccumulator isolation valvemotoroperatorbedisconnected by,"...removalofthebreakerfromthecircuit."
| | U.S. NUCLEAR REGUlATORY COMMISSION LICENSEE EVENT REPORT (LER) |
| Thesurveillance procedure doesnotmeettheliteralwordingofTSSR4.5.1.cinthatthebreakerisopenedandmaintained inthatpositionratherthanbeingphysically removed.ThisLERistherefore submitted inacco'rdance with10CFR50.73(a)(2)(i)(B),
| | ESTSAATED IKSIDEN PER WCORPOMTED WTO TIC ~ |
| asacondition prohibited bytheplant'sTechnical Specifications.
| | APPROVED BY ORB No. 31504(04 EXPIRES 06)30/2001 RESPONSE TO COLDLY IATIH TISS EQPOATORY WFORMAllONCIKIECAON REOUEST: 50.0 HRS. REPORTED IESSONS LEARNED ARE PROCESS AIEI FED BACK TO SCMSTRY. |
| Thiscondition resultedfromamisjudgment madeintheconversion fromtheinitialD.C.CookNuclearPlant(CNP)TStotheWestinghouse StandardTechnical Specifications (STS),asdescribed inNUREG-0452.
| | P~ |
| ThewordingappearstohavebeenadoptedfromtheSTSwithoutconsidering thetypeofbreakerinstalled fortheaccumulator isolation valves.Alicenseamendment requestwillbesubmitted tochangeTSSR4.5.1.c.Acomprehensive reviewoftheadequacyofTSsurveillance testprocedures isbeingperformed aspartofRestartActionPlan¹0001,"Programmatic Breakdown inSurveillance Testing."
| | FORWARD COMMENTS REOARDINO BISICEN ESTNATE TO THE PFORllATION AND RECORDS MANACEMENT lÃIANCH IT% Fee j. IAS. NVCIEAR RECIAATORY COMMISSOIL WASISNOTOIL OC 20MSCC01. PIC) TO THE REDVCTION reamer oleoolor), OFRCE OF MANAOEMENT Aro IROSET, wASISNrnorA DC (See reverse for required number of 21500 digits/characters for each block) |
| Theidentified condition hasnosafetysignificance becausepowerwasremovedfromtheaccumulator isolation valvecontrolcircuit,therebypreventing inadvertent valveoperation duetoasinglefailureinthevalvecontrolcircuitry.
| | FACIUlYNAME(1) DOCKET NUMBER (2) PAGE (0) |
| NRCFORM366(6-1998) 0NRCFORM366AU.S.NUCLEARREGULATORY COMMISSION (6-1998)LICENSEEEVENTREPORT(LER)TEXTCONTINUATION FACILITYNAME(1)CookNuclearPlantUnit1DOCKETNUMBER(2) 05000-315 YEARLERNUMBER(6)SEQUENTIAL NUMBERREVISIONNUMBERPAGE(3)2of31999-.02400TEXT(Ifmorespaceisrequired, useaddiiional copiesofNRCFormP66A)(17)Unit1wasinMode5,ColdShutdownUnit2wasinMode5,ColdShutdownOnJuly8,1999,duringareviewofTechnical Specifications (TS)surveillance procedures, itwasdiscovered thatTSSurveillance Requirement (SR)4.5.1.cwasnotbeingmetbytheassociated surveillance procedure.
| | Cook Nuclear Plant Unit 1 05000-315 1 of 3 TITLE(0) |
| SR4.5.1.crequiresthatpowertotheRCSaccumulator isolation valvemotoroperatorbedisconnected by,"...removalofthebreakerfromthecircuit."
| | Literal Technical Specifications Requirement Not Met By Accumulator Valve Surveillance EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED(8) |
| Thesuiveillance procedure, 01(02)-OHP-4030.STP.031, "Operation WeeklySurveillance Checks,"requirestheoperatortocheckthebreakerswitchintheOFFposition, butthebreakerisnotphysically removedfromthecubicle.Therefore, thesurveillance procedure doesnotmeettheliteralrequirement ofTSSR4.5.1.c.Thiscondition resultedfroma.misjudgment madeintheconversion fromtheinitialD.C.CookNuclearPlant(CNP)TStotheWestinghouse StandardTechnical Specifications (STS),asdescribed inNUREG-0452.
| | A ILI NAM CKET NUMB SEQUENTIAL REVISION Cook Nuclear Plant 2 05000-316 DAY YEAR NUMBER NUMBER MONTH DAY YEAR A IUTY HAM NUM 07 08 1999 1999 024 00 10 18 1999 OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR Ii: (Check one or more) (11) |
| TheNUREG-0452, "Standard Technical Specifications forWestinghouse Pressurized WaterReactors,"
| | MODE (9) 20.2201 (b) 20.2203(a)(2)(v) 50.73(a)(2)(i) 50.73(a)(2)(viii) |
| accumulator isolation valvesurveillance requirement appearstohavebeenadoptedwithoutconsidering Cookplantdesign.Duringconversion fromtheoriginaltotheSTS,itwaserroneously decidedthattheTSSRwouldbemetbyopeningthemoldedcasecircuitbreaker(MCCB)thatsuppliespowertotheaccumulator valveoperator, andmaintaining thebreakerintheOFFposition. | | POWER 20.2203(a)(1) 20.2203(a)(3)(i) 50.73(a)(2)(ii) 50.73(a)(2)(x) |
| Theinvestigation hasshownthatCNPpersonnel donotconsidertheMCCBscapableofbeing"rackedout"duetotheirphysicaldesign.Instead,whendirectedtorackoutthisstyleofbreaker,personnel understand thatrackoutmeanstoplacethebreakerintheOFFposition.
| | LEVEL (10) 0 50.73(a)(2)(iii) 73.71 20.2203(a)(2)(i) 20.2203(a)(3)(ii) 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) |
| Whilethesurveillance procedure actionsmeettheintentoftheTSbyplacingthebreakersintheOFFposition, theydonotmeettheliteralrequirement ofTSSR4.5.1.c.Thiscondition hasexistedsinceinitialplantstartup.OnSeptember 20,1999,thiscondition wasdetermined tobereportable; therefore, thisLERissubmitted inaccordance with10CFR50.73(a)(2)(i)(B),
| | Speorr in ADCraoI Derorr 20.2203(a)(2)(iv) 50.36(c)(2) 50.73(a)(2)(vii) or n NRC Form 366A LICENSEE CONTACT FOR THIS LER (12) |
| asacondition prohibited bytheplant'sTechnical Specifications.
| | TELEPHONE NUMBER (Inc4de Area Code) |
| Thegapintimebetweenthediscovery dateofJuly8,1999,andthereporting dateofSeptember 20,1999,wasduetotheneedforevaluation byD.C.CookNuclearPlant(CNP)staffandmanagement duetotheextendedhistoryoftheissue.TSSR4.5.1.crequiresthatweperiodically verify,"...thatpowertotheisolation valveoperatorisdisconnected byremovalofthebreakerfromthecircuit."
| | Ms. Mary Beth Depuydt, Regulatory Compliance (616) 465-5901 X 1589 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13) |
| ThebasisforthisTSsurveillance requirement isthat,"...astheseaccumulator isolation valvesfailtomeetsinglefailurecriteria, removalofpowertothevalvesisrequired."
| | REPORTABLE REPORTABLE lo CAUSE SYSTEM COMPONENT MANUFACTURER TO EPIX CAUSE COMPONENT MANUFACTURER EPIX SUPPLEMENTAL REPORT EXPECTED 14) EXPECTED MONTH DAY YES X SUBMISSION (If Yes, complete EXPECTED SUBMISSION DATE) NO DATE (15 Abstract (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16) |
| ThisCNPTSsurveillance requirement andbaseswereadopteddirectlyfromNUREG-0452, andnoplant-specific changesweremadetotheCNPrequirement.
| | On July 8, 1999, during a review of Technical Specifications (TS) surveillance procedures, it was discovered that TS Surveillance Requirement (SR) 4.5.1.c was not being met by the associated surveillance procedure. SR 4.5.1.c requires that power to the RCS accumulator isolation valve motor operator be disconnected by, "... removal of the breaker from the circuit." The surveillance procedure does not meet the literal wording of TS SR 4.5.1.c in that the breaker is opened and maintained in that position rather than being physically removed. This LER is therefore submitted in acco'rdance with 10 CFR 50.73(a)(2)(i)(B), as a condition prohibited by the plant's Technical Specifications. |
| Tophysically removeabreakerfromacircuit,thebreakerisrackedout.Theterm"rackout"meanstousetheinstalled rackingmechanism tophysically movetheswitchgear breakerawayfromthebusstabssuchthatthebreakerisnolongerincontactwiththebusbars.Additionally, rackingoutabreakerdisconnects thebreakerfromthecontrolcircuitsuchthatthebreakercannotoperate.Breakersthatarecapableofbeingrackedouthavebuilt-inmechanisms toallowtherackoutoperation, andaregenerally foundonswitchgear buses.Thesafety-related accumulator isolation valvesarepoweredfromtheAux600Vswitchgear busesthroughMotorControlCenters(MCCs).ThebreakersusedontheseMCCsarenotoftheswitchgear type,andhavenomechanism forbeingNRCFORM366A(6-1998)
| | This condition resulted from a misjudgment made in the conversion from the initial D.C. Cook Nuclear Plant (CNP) TS to the Westinghouse Standard Technical Specifications (STS), as described in NUREG-0452. The wording appears to have been adopted from the STS without considering the type of breaker installed for the accumulator isolation valves. A license amendment request will be submitted to change TS SR 4.5.1.c. A comprehensive review of the adequacy of TS surveillance test procedures is being performed as part of Restart Action Plan ¹0001, "Programmatic Breakdown in Surveillance Testing." |
| NRCFORM366AU.S.NUCLEARREGULATORY COMMISSION (6-1996)LICENSEEEVENTREPORT(LER)TEXTCONTINUATION FACIUTYNAME(1)CookNuclearPlantUnit1DOCKETNUMBER(2) 05000-315 YEARLERNUMBER(6)SEQUENTIAL NUMBERREVISIONNUMBERPAGE(3)3of31999-02400TEXTPfmorespaceisrequired, useadditional copiesofNRCFormP66A)(17)rackedout.Rather,thebreakersusedaresmallMCCBs,whicharecommonforasmallloadofthistypeandvoltage.TheMCCBsarehard-wired tothesupplylinesandloadsintheMCC,andaredifficult toremovefromtheircubicles.
| | The identified condition has no safety significance because power was removed from the accumulator isolation valve control circuit, thereby preventing inadvertent valve operation due to a single failure in the valve control circuitry. |
| Theterm"rackout"doesnotapplytoMCCBs.To"electrically" removetheaccumulator isolation valveMCCBfromthecircuit,theoperatormerelyhastoopenthebreakerandmaintainitintheOFFposition.
| | NRC FORM 366 (6-1998) |
| PlacingthebreakerinOFFde-energizes controlpowertothevalveoperator.
| | |
| Deliberate operatoractionbyphysically closingthebreakeratthelocalMCCpanelisrequiredtorestorevalveoperatorcontrolpower.Openingtheaccumulator valvebreakerwhenreactorsystempressureisgreaterthan2000psigpreventsthepotential foranactivefailureorinadvertent operation ofthevalveswitchfromthecontrolroomtocausethevalvestoclose.Noelectrical faultwillcausethebreakertoclose.Therefore, theintentoftheTSismet.Basedontheaboveinformation, theidentified condition hasnosafetysignificance. | | 0 NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (6-1998) |
| Openingtheaccumulator isolation valvebreakerorremovingthebreakerfromthecircuitbothremovepowertothecircuitandpreventinadvertent valveoperation duetoasinglefailureinthevalvecontrolcircuitry.
| | LICENSEE EVENT REPORT (LER) |
| Noimmediate corrective actionswererequiredbecausetheplantwasinanoperating Modewherethesurveillance requirement wasnotapplicable.
| | TEXT CONTINUATION FACILITYNAME (1) DOCKET NUMBER(2) LER NUMBER (6) PAGE (3) |
| Alicenseamendment requestwillbesubmitted byOctober22,1999,tochangeTechnical Specifications Surveillance Requirement 4.5.1.ctoread,"Atleastonceper31dayswhentheRCSpressureisabove2000psig,byverifying thatpowerisremovedfromeachaccumulator isolation valveoperator."
| | YEAR SEQUENTIAL REVISION Cook Nuclear Plant Unit 1 05000-315 NUMBER NUMBER 2of3 1999 024 |
| Aspreviously statedincorrespondence AEP:NRC:1260GH,datedMarch19,1999,"Enforcement Actions98-150,98-151,98-152and98-186,ReplytoNoticeofViolation DatedOctober13,1998,"acomprehensive reviewoftheadequacyofTSsurveillance testprocedures isbeingperformed.
| | . 00 TEXT (Ifmore space is required, use addiiional copies of NRC Form P66A) (17) |
| ThisactionisbeingtrackedbyRestartActionPlan40001,"Programmatic Breakdown inSurveillance Testing."
| | Unit 1 was in Mode 5, Cold Shutdown Unit 2 was in Mode 5, Cold Shutdown On July 8, 1999, during a review of Technical Specifications (TS) surveillance procedures, it was discovered that TS Surveillance Requirement (SR) 4.5.1.c was not being met by the associated surveillance procedure. SR 4.5.1.c requires that power to the RCS accumulator isolation valve motor operator be disconnected by, "... removal of the breaker from the circuit." The suiveillance procedure, 01(02)-OHP-4030.STP.031, "Operation Weekly Surveillance Checks," requires the operator to check the breaker switch in the OFF position, but the breaker is not physically removed from the cubicle. |
| NoneNRCFORM366A(6-1996)}}
| | Therefore, the surveillance procedure does not meet the literal requirement of TS SR 4.5.1.c. |
| | This condition resulted from a.misjudgment made in the conversion from the initial D.C. Cook Nuclear Plant (CNP) TS to the Westinghouse Standard Technical Specifications (STS), as described in NUREG-0452. The NUREG-0452, "Standard Technical Specifications for Westinghouse Pressurized Water Reactors," accumulator isolation valve surveillance requirement appears to have been adopted without considering Cook plant design. |
| | During conversion from the original to the STS, it was erroneously decided that the TS SR would be met by opening the molded case circuit breaker (MCCB) that supplies power to the accumulator valve operator, and maintaining the breaker in the OFF position. The investigation has shown that CNP personnel do not consider the MCCBs capable of being "racked out" due to their physical design. Instead, when directed to rack out this style of breaker, personnel understand that rack out means to place the breaker in the OFF position. While the surveillance procedure actions meet the intent of the TS by placing the breakers in the OFF position, they do not meet the literal requirement of TS SR 4.5.1.c. This condition has existed since initial plant startup. |
| | On September 20, 1999, this condition was determined to be reportable; therefore, this LER is submitted in accordance with 10 CFR 50.73(a)(2)(i)(B), as a condition prohibited by the plant's Technical Specifications. The gap in time between the discovery date of July 8, 1999, and the reporting date of September 20, 1999, was due to the need for evaluation by D.C. Cook Nuclear Plant (CNP) staff and management due to the extended history of the issue. |
| | TS SR 4.5.1.c requires that we periodically verify, "... that power to the isolation valve operator is disconnected by removal of the breaker from the circuit." The basis for this TS surveillance requirement is that, "... as these accumulator isolation valves fail to meet single failure criteria, removal of power to the valves is required." This CNP TS surveillance requirement and bases were adopted directly from NUREG-0452, and no plant-specific changes were made to the CNP requirement. |
| | To physically remove a breaker from a circuit, the breaker is racked out. The term "rack out" means to use the installed racking mechanism to physically move the switchgear breaker away from the bus stabs such that the breaker is no longer in contact with the bus bars. Additionally, racking out a breaker disconnects the breaker from the control circuit such that the breaker cannot operate. Breakers that are capable of being racked out have built-in mechanisms to allow the rack out operation, and are generally found on switchgear buses. |
| | The safety-related accumulator isolation valves are powered from the Aux 600V switchgear buses through Motor Control Centers (MCCs). The breakers used on these MCCs are not of the switchgear type, and have no mechanism for being NRC FORM 366A (6-1998) |
| | |
| | NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (6-1996) |
| | LICENSEE EVENT REPORT (LER) |
| | TEXT CONTINUATION FACIUTY NAME (1) DOCKET NUMBER(2) LER NUMBER (6) PAGE (3) |
| | YEAR SEQUENTIAL REVISION Cook Nuclear Plant Unit 1 05000-315 NUMBER NUMBER 3of3 1999 024 00 TEXT Pf more space is required, use additional copies of NRC Form P66A) (17) racked out. Rather, the breakers used are small MCCBs, which are common for a small load of this type and voltage. The MCCBs are hard-wired to the supply lines and loads in the MCC, and are difficultto remove from their cubicles. The term "rack out" does not apply to MCCBs. |
| | To "electrically" remove the accumulator isolation valve MCCB from the circuit, the operator merely has to open the breaker and maintain it in the OFF position. Placing the breaker in OFF de-energizes control power to the valve operator. |
| | Deliberate operator action by physically closing the breaker at the local MCC panel is required to restore valve operator control power. Opening the accumulator valve breaker when reactor system pressure is greater than 2000 psig prevents the potential for an active failure or inadvertent operation of the valve switch from the control room to cause the valves to close. No electrical fault will cause the breaker to close. Therefore, the intent of the TS is met. |
| | Based on the above information, the identified condition has no safety significance. Opening the accumulator isolation valve breaker or removing the breaker from the circuit both remove power to the circuit and prevent inadvertent valve operation due to a single failure in the valve control circuitry. |
| | No immediate corrective actions were required because the plant was in an operating Mode where the surveillance requirement was not applicable. |
| | A license amendment request will be submitted by October 22, 1999, to change Technical Specifications Surveillance Requirement 4.5.1.c to read, "At least once per 31 days when the RCS pressure is above 2000 psig, by verifying that power is removed from each accumulator isolation valve operator." |
| | As previously stated in correspondence AEP: NRC: 1260GH, dated March 19, 1999, "Enforcement Actions 98-150, 98-151, 98-152 and 98-186, Reply to Notice of Violation Dated October 13, 1998," a comprehensive review of the adequacy of TS surveillance test procedures is being performed. This action is being tracked by Restart Action Plan 40001, "Programmatic Breakdown in Surveillance Testing." |
| | None NRC FORM 366A (6-1996)}} |
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|---|
Category:LICENSEE EVENT REPORT (SEE ALSO AO
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ML17335A5531999-10-0707 October 1999
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ML17326A1291999-09-17017 September 1999
LER 99-022-00:on 990609,electrical Bus Degraded Voltage Setpoints Too Low for Safety Related Loads,Was Discovered. Caused by Lack of Understanding of Design of Plant.No Immediate Corrective Actions Necessary
ML17326A1121999-08-27027 August 1999
LER 99-021-00:on 990728,determined That GL 96-01 Test Requirements Were Not Met in Surveillance Tests.Caused by Failure to Understand Full Extent of GL Requirements. Surveillance Procedures Will Be Revised or Developed
ML17326A1011999-08-26026 August 1999
LER 99-020-00:on 990727,EDGs Were Declared Inoperable.Caused by Inadequate Protection of Air Intake,Exhaust & Room Ventilation Structures from Tornado Missile Hazards. Implemented Compensatory Measures in Form of ACs
ML17326A0911999-08-16016 August 1999
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
ML17326A0771999-08-0404 August 1999
LER 98-029-01:on 980422,noted That Fuel Handling Area Ventilation Sys Was Inoperable.Caused by Original Design Deficiency.Radiological Analysis for Spent Fuel Handling Accidents in Auxiliary Bldg Will Be Redone by 990830
ML17326A0741999-07-29029 July 1999
LER 99-018-00:on 990629,determined That Valve Yokes May Yield Under Combined Stress of Seismic Event & Static,Valve Closed,Stem Thrust.Caused by Inadequate Design of Associated Movs.Operability Determinations Were Performed for Valves
ML17326A0661999-07-26026 July 1999
LER 99-017-00:on 990625,noted That Improperly Installed Fuel Oil Return Relief Valve Rendered EDG Inoperable.Caused by Personnel Error.Fuel Oil Return Valve Was Replaced with Valve in Correct Orientation.With 990722 Ltr
ML17326A0651999-07-22022 July 1999
LER 98-014-03:on 980310,noted That Response to high-high Containment Pressure Procedure Was Not Consistent with Analysis of Record.Caused by Inadequate Interface with W. FRZ-1 Will Be Revised to Be Consistent with New Analysis
ML17326A0491999-07-13013 July 1999
LER 99-016-00:on 990615,TS Requirements for Source Range Neutron Flux Monitors Not Met.Caused by Failure to Understand Design Basis of Plant.Procedures Revised.With 990713 Ltr
ML17326A0331999-07-0101 July 1999
LER 99-004-01:on 971030,failure to Perform TS Surveillance Analyses of Reactor Coolant Chemistry with Fuel Removed Was Noted.Caused by Ineffective Mgt of Tss.Chemistry Personnel Have Been Instructed on Requirement to Follow TS as Written
ML17326A0151999-06-18018 June 1999
LER 99-014-00:on 990521,determined That Boron Injection Tank Manway Bolts Were Not Included in ISI Program,Creating Missed Exam for Previous ISI Interval.Caused by Programmatic Weakness.Isi Program & Associated ISI Database Modified
ML17325B6311999-06-0101 June 1999
LER 99-S03-00:on 990430,vital Area Barrier Degradation Was Noted.Caused by Inadequate Insp & Maint of Vital Area Barrier.Repairs & Mods Were Made to Barriers to Eliminate Degraded & Nonconforming Conditions
ML17325B6421999-06-0101 June 1999
LER 99-013-00:on 990327,safety Injection & Centrifugal Charging Throttle Valve Cavitation During LOCA Could Have Led to ECCS Pump Failure.Caused by Inadequate Original Design Application of Si.Throttle Valves Will Be Developed
ML17325B6351999-05-28028 May 1999
LER 99-S02-00:on 990428,vulnerability in Safeguard Sys That Could Allow Unauthorized Access to Protected Area Was Noted. Caused by Inadequate Original Plant Design.Mods Were Made to Wall Opening to Eliminate Nonconforming Conditions
ML17265A8231999-05-24024 May 1999
LER 98-037-01:on 990422,determined That Ice Condenser Bypass Leakage Exceeds Design Basis Limit.Caused by Pressure Seal Required by Revised W Design Not Incorporated Into Aep Design.Numerous Matl Condition Walkdowns & Assessments Made
ML17325B6001999-05-20020 May 1999
LER 99-012-00:on 990420,concluded That Auxiliary Bldg ESF Ventilation Sys Not Capable of Maintaining ESF Room Temps post-accident.Caused by Inadequate Control of Sys Design Inputs.Comprehensive Action Plan Being Developed
ML17325B5861999-05-10010 May 1999
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
ML17325B5811999-05-0404 May 1999
LER 99-011-00:on 990407,air Sys for EDG Will Not Support Long Operability.Caused by Original Design Error.Temporary Mod to Supply Makeup Air Capability in Modes 5 & 6 Was Prepared
ML17325B5771999-05-0303 May 1999
LER 99-010-00:on 990401,RCS Leak Detection Sys Sensitivity Not in Accordance with Design Requirements Occurred.Caused by Inadequate Original Design of Containment Sump Level. Evaluation Will Be Performed to Clearly Define Design
ML17325B5581999-04-16016 April 1999
LER 99-006-00:on 990115,personnel Identified Discrepancy Between TS 3.9.7 Impact Energy Limit & Procedure 12 Ohp 4030.STP.046.Caused by Lack of Design Basis Control.Placed Procedure 12 Ohp 4030.STP.046 on Administrative Hold
ML17325B5471999-04-12012 April 1999
LER 99-009-00:on 990304,as-found RHR Safety Relief Valve Lift Setpoint Greater than TS Limit Occurred.Cause Investigation for Condition Has Not Been Completed.Update to LER Will Be Submitted,Upon Completion of Investigation
ML17325B5321999-04-0707 April 1999
LER 99-S01-00:on 990308,discovered That Lock for Vital Gate Leading to Plant 4KV Switchgear Area Was Nonconforming & Vulnerable to Unauthorized Access.Caused by Inadequate Gate Design & Inadequate Procedures.Mods Are Being Made to Gate
ML17325B5161999-04-0101 April 1999
LER 99-007-00:on 981020,calculations Showed That Divider Barrier Between Upper & Lower Containment Vols Were Overstressed.Engineers Are Currently Working on Analyses of Loads & Stress on Enclosures
ML17325B5221999-03-29029 March 1999
LER 99-001-00:on 960610,degraded Component Cooling Water Flow to Containment Main Steam Line Penetrations,Identified on 990226.Caused by Inadequate Understanding of Design Basis.Additional Investigations Ongoing
ML17325B4801999-03-18018 March 1999
LER 99-004-00:on 971030,failure to Perform TS Surveillance Analyses of Rc Chemistry with Fuel Removed Was Noted.Cause of Event Is Under Investigation.Corrected Written Job Order Activities Used to Control SD Chemistry Sampling
ML17325B4741999-03-18018 March 1999
LER 99-005-00:on 940512,determined That Rt Breaker Manual Actuations During Rod Drop Testing Were Not Previously Reported.Caused by Lack of Training.Addl Corrective Actions,Including Preventative Actions May Be Developed
ML17325B4571999-02-24024 February 1999
LER 99-003-00:on 990107,CR Pressurization Sys Surveillance Test Did Not Test Sys in Normal Operating Condition.Caused by Failure to Recognize Door 12DR-AUX415 as Part of CR Pressure Boundary.Performed Walkdown of Other Doors
ML17335A5171999-02-11011 February 1999
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
ML17335A5141999-02-10010 February 1999
LER 99-001-00:on 990106,noted That GE Hfa Relays Installed in EDGs May Not Meet Seismic Qualification.Caused by Operating Experience Info Incorrectly Dispositioned in 1985. Updated LER Will Be Submitted by 990405
ML17335A5011999-02-0101 February 1999
LER 98-060-00:on 981231,identified That Rt Sys Response Time Testing Did Not Comply with TS Definition.Caused by Inadequate Procedures.Corrective Actions Will Be Developed & Update to LER Will Be Submitted by 990415.With 990201 Ltr
ML17335A4951999-01-29029 January 1999
LER 98-059-00:on 981230,interim LER -single Failure in Containment Spray Sys Could Result in Containment Spray Ph Outside Design Occurred.Investigation Into Condition Continuing.Update Will Be Submitted by 990514 Ltr
ML17335A4961999-01-27027 January 1999
LER 98-057-00:on 981228,discovered That AFW Valves Were Not Tested IAW Inservice Testing Program.Caused by Failure to Recognize Design Bases Features Re Afws by Personnel. Updated LER Will Be Submittted by 990415.With 990127 Ltr
ML17335A4921999-01-19019 January 1999
LER 98-052-01:on 981128,no Analysis for NSR Sc Manual Loader for Tdafwp Could Be Found in Original Design.Cause Due to All Failure Modes Not Considered When Compressed Air Sys Originally Designed.Performed Review of Components
ML17335A4721999-01-0606 January 1999
LER 98-055-00:on 981207,potential for Condition Outside of Design Bases for Rod Control Sys Was Noted.Caused by Calibration Error Coupled with Single Rod Failure.Condition Rept Investigation Is Ongoing
ML17335A4691999-01-0606 January 1999
LER 98-056-00:on 981211,hot Leg Nozzle Gaps Resulted in Plant Being in Unanalyzed Condition.Analyses Are Being Performed by W to Resolve Problem.Updated LER Will Be Submitted by 990211.With 990106 Ltr
ML17335A4661999-01-0505 January 1999
LER 98-049-00:on 981020,emergency Boron Injection Flow Path Was Inoperable.Caused by Original Design Deficiency. Engineering Evaluation of Event Is Continuing
ML17335A4631999-01-0404 January 1999
LER 98-054-00:on 981202,discovered That at Least One MSSV Had Not Been Reset as Required by Ts.Engineering Is Continuing Review of Extent of Condition for Event.Updated LER Will Be Submitted by 990129.With 990104 Ltr
ML17335A4481998-12-30030 December 1998
LER 98-053-00:on 981130,discovered Use of Inoperable Substitute Subcooling Margin Monitor.Caused by Condition Existing Since Installation of Plant Process Computer in 1992.Updated LER Will Be Submitted.With 981230 Ltr
ML17335A4581998-12-28028 December 1998
LER 98-052-00:on 981128,turbine Driven AFW Pump Speed Controller Failure Mode Occurred.Caused Because Not All Failure Modes Were Considered When Compressed Air Sys Was Originally Designed.Verified Current Design Change Process
ML17335A4281998-12-22022 December 1998
LER 98-051-00:on 981122,reactor Trip Signal from Manual Safety Injection Not Verified as Required by TS Surveillance,Was Discovered.Maintenance Currently Evaluating Significance & Cause of Event
ML17335A4111998-12-17017 December 1998
LER 98-047-00:on 981117,potential for Increase Leakage from Reactor Coolant Pump Seals Was Identified.Util Is Working with W to Resolve Issue.Current Expectations Are to Submit Update to LER by 990215.With 981217 Ltr
ML17335A4141998-12-16016 December 1998
LER 98-058-00:on 981216,postulated High Line Break Could Result in Condition Outside Design Bases for AF Occurred. Caused by Deficiencies Associated with Administration of HELB Program.Analysis of AF Will Be Completed by 990122
ML17335A4181998-12-16016 December 1998
LER 98-050-00:on 980814,ancillary Equipment Installed in Ice Condenser Was Not Designed to Withstand Design Basis Accident/Earthquake Loads.Caused by Lack of Established Design Criteria.Developed Design Criteria
ML17335A3871998-12-11011 December 1998
LER 98-031-01:on 980610,potential Common Mode Failure of RHR Pumps Were Noted.Caused by Inaccurate Values.Accurate Miniflow Numbers Have Been Determined by Flow Testing
ML17335A3821998-12-0808 December 1998
LER 98-039-01 Re EOP Step Conflicts with Small Break LOCA Analysis.Ler 98-039-00 Has Been Canceled.With 981208 Ltr
ML17335A3781998-12-0707 December 1998
LER 98-007-00:on 981106,high Energy Line Break Effects in Auxiliary FW Sys Was Noted.Cause of Event Is Under Investigation & Will Be Completed by 990220.Updated LER Will Be Submitted by 990310.With 981207 Ltr
ML17335A3771998-12-0303 December 1998
LER 98-046-00:on 981103,determined That Afs Was Unable to Meet Design Flow Requirements During Special Test.Caused by Failure to Consider All Aspects of Sys Operation in Design of Suction Basket Strainers.Sys Will Be Redesigned
ML17335A3741998-12-0202 December 1998
LER 97-011-02:on 970822,operation Was Noted Outside Design Bases for ECCS & CSP for Switchover to Recirculation Sump Suction.Caused by Ineffective Change Mgt.Revised Procedure for Switchover 01(02) Ohp 4023.ES-1.3
1999-09-17
[Table view]
Category:RO)
MONTHYEARML17335A5641999-10-18018 October 1999
LER 99-024-00:on 990708,literal TS Requirements Were Not Met by Accumlator Valve Surveillance.Caused by Misjudgement Made in Conversion from Initial DC Cook TS to W Std Ts.Submitted License Amend Request.With 991018 Ltr
ML17335A5531999-10-0707 October 1999
LER 99-023-00:on 990907,inadequate TS Surveillance Testing of ESW Pump ESF Response Time Noted.Caused by Inadequate Understanding of Plant Design Basis.Surveillance Tests Will Be Revised & Implemented
ML17326A1291999-09-17017 September 1999
LER 99-022-00:on 990609,electrical Bus Degraded Voltage Setpoints Too Low for Safety Related Loads,Was Discovered. Caused by Lack of Understanding of Design of Plant.No Immediate Corrective Actions Necessary
ML17326A1121999-08-27027 August 1999
LER 99-021-00:on 990728,determined That GL 96-01 Test Requirements Were Not Met in Surveillance Tests.Caused by Failure to Understand Full Extent of GL Requirements. Surveillance Procedures Will Be Revised or Developed
ML17326A1011999-08-26026 August 1999
LER 99-020-00:on 990727,EDGs Were Declared Inoperable.Caused by Inadequate Protection of Air Intake,Exhaust & Room Ventilation Structures from Tornado Missile Hazards. Implemented Compensatory Measures in Form of ACs
ML17326A0911999-08-16016 August 1999
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
ML17326A0771999-08-0404 August 1999
LER 98-029-01:on 980422,noted That Fuel Handling Area Ventilation Sys Was Inoperable.Caused by Original Design Deficiency.Radiological Analysis for Spent Fuel Handling Accidents in Auxiliary Bldg Will Be Redone by 990830
ML17326A0741999-07-29029 July 1999
LER 99-018-00:on 990629,determined That Valve Yokes May Yield Under Combined Stress of Seismic Event & Static,Valve Closed,Stem Thrust.Caused by Inadequate Design of Associated Movs.Operability Determinations Were Performed for Valves
ML17326A0661999-07-26026 July 1999
LER 99-017-00:on 990625,noted That Improperly Installed Fuel Oil Return Relief Valve Rendered EDG Inoperable.Caused by Personnel Error.Fuel Oil Return Valve Was Replaced with Valve in Correct Orientation.With 990722 Ltr
ML17326A0651999-07-22022 July 1999
LER 98-014-03:on 980310,noted That Response to high-high Containment Pressure Procedure Was Not Consistent with Analysis of Record.Caused by Inadequate Interface with W. FRZ-1 Will Be Revised to Be Consistent with New Analysis
ML17326A0491999-07-13013 July 1999
LER 99-016-00:on 990615,TS Requirements for Source Range Neutron Flux Monitors Not Met.Caused by Failure to Understand Design Basis of Plant.Procedures Revised.With 990713 Ltr
ML17326A0331999-07-0101 July 1999
LER 99-004-01:on 971030,failure to Perform TS Surveillance Analyses of Reactor Coolant Chemistry with Fuel Removed Was Noted.Caused by Ineffective Mgt of Tss.Chemistry Personnel Have Been Instructed on Requirement to Follow TS as Written
ML17326A0151999-06-18018 June 1999
LER 99-014-00:on 990521,determined That Boron Injection Tank Manway Bolts Were Not Included in ISI Program,Creating Missed Exam for Previous ISI Interval.Caused by Programmatic Weakness.Isi Program & Associated ISI Database Modified
ML17325B6311999-06-0101 June 1999
LER 99-S03-00:on 990430,vital Area Barrier Degradation Was Noted.Caused by Inadequate Insp & Maint of Vital Area Barrier.Repairs & Mods Were Made to Barriers to Eliminate Degraded & Nonconforming Conditions
ML17325B6421999-06-0101 June 1999
LER 99-013-00:on 990327,safety Injection & Centrifugal Charging Throttle Valve Cavitation During LOCA Could Have Led to ECCS Pump Failure.Caused by Inadequate Original Design Application of Si.Throttle Valves Will Be Developed
ML17325B6351999-05-28028 May 1999
LER 99-S02-00:on 990428,vulnerability in Safeguard Sys That Could Allow Unauthorized Access to Protected Area Was Noted. Caused by Inadequate Original Plant Design.Mods Were Made to Wall Opening to Eliminate Nonconforming Conditions
ML17265A8231999-05-24024 May 1999
LER 98-037-01:on 990422,determined That Ice Condenser Bypass Leakage Exceeds Design Basis Limit.Caused by Pressure Seal Required by Revised W Design Not Incorporated Into Aep Design.Numerous Matl Condition Walkdowns & Assessments Made
ML17325B6001999-05-20020 May 1999
LER 99-012-00:on 990420,concluded That Auxiliary Bldg ESF Ventilation Sys Not Capable of Maintaining ESF Room Temps post-accident.Caused by Inadequate Control of Sys Design Inputs.Comprehensive Action Plan Being Developed
ML17325B5861999-05-10010 May 1999
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
ML17325B5811999-05-0404 May 1999
LER 99-011-00:on 990407,air Sys for EDG Will Not Support Long Operability.Caused by Original Design Error.Temporary Mod to Supply Makeup Air Capability in Modes 5 & 6 Was Prepared
ML17325B5771999-05-0303 May 1999
LER 99-010-00:on 990401,RCS Leak Detection Sys Sensitivity Not in Accordance with Design Requirements Occurred.Caused by Inadequate Original Design of Containment Sump Level. Evaluation Will Be Performed to Clearly Define Design
ML17325B5581999-04-16016 April 1999
LER 99-006-00:on 990115,personnel Identified Discrepancy Between TS 3.9.7 Impact Energy Limit & Procedure 12 Ohp 4030.STP.046.Caused by Lack of Design Basis Control.Placed Procedure 12 Ohp 4030.STP.046 on Administrative Hold
ML17325B5471999-04-12012 April 1999
LER 99-009-00:on 990304,as-found RHR Safety Relief Valve Lift Setpoint Greater than TS Limit Occurred.Cause Investigation for Condition Has Not Been Completed.Update to LER Will Be Submitted,Upon Completion of Investigation
ML17325B5321999-04-0707 April 1999
LER 99-S01-00:on 990308,discovered That Lock for Vital Gate Leading to Plant 4KV Switchgear Area Was Nonconforming & Vulnerable to Unauthorized Access.Caused by Inadequate Gate Design & Inadequate Procedures.Mods Are Being Made to Gate
ML17325B5161999-04-0101 April 1999
LER 99-007-00:on 981020,calculations Showed That Divider Barrier Between Upper & Lower Containment Vols Were Overstressed.Engineers Are Currently Working on Analyses of Loads & Stress on Enclosures
ML17325B5221999-03-29029 March 1999
LER 99-001-00:on 960610,degraded Component Cooling Water Flow to Containment Main Steam Line Penetrations,Identified on 990226.Caused by Inadequate Understanding of Design Basis.Additional Investigations Ongoing
ML17325B4801999-03-18018 March 1999
LER 99-004-00:on 971030,failure to Perform TS Surveillance Analyses of Rc Chemistry with Fuel Removed Was Noted.Cause of Event Is Under Investigation.Corrected Written Job Order Activities Used to Control SD Chemistry Sampling
ML17325B4741999-03-18018 March 1999
LER 99-005-00:on 940512,determined That Rt Breaker Manual Actuations During Rod Drop Testing Were Not Previously Reported.Caused by Lack of Training.Addl Corrective Actions,Including Preventative Actions May Be Developed
ML17325B4571999-02-24024 February 1999
LER 99-003-00:on 990107,CR Pressurization Sys Surveillance Test Did Not Test Sys in Normal Operating Condition.Caused by Failure to Recognize Door 12DR-AUX415 as Part of CR Pressure Boundary.Performed Walkdown of Other Doors
ML17335A5171999-02-11011 February 1999
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
ML17335A5141999-02-10010 February 1999
LER 99-001-00:on 990106,noted That GE Hfa Relays Installed in EDGs May Not Meet Seismic Qualification.Caused by Operating Experience Info Incorrectly Dispositioned in 1985. Updated LER Will Be Submitted by 990405
ML17335A5011999-02-0101 February 1999
LER 98-060-00:on 981231,identified That Rt Sys Response Time Testing Did Not Comply with TS Definition.Caused by Inadequate Procedures.Corrective Actions Will Be Developed & Update to LER Will Be Submitted by 990415.With 990201 Ltr
ML17335A4951999-01-29029 January 1999
LER 98-059-00:on 981230,interim LER -single Failure in Containment Spray Sys Could Result in Containment Spray Ph Outside Design Occurred.Investigation Into Condition Continuing.Update Will Be Submitted by 990514 Ltr
ML17335A4961999-01-27027 January 1999
LER 98-057-00:on 981228,discovered That AFW Valves Were Not Tested IAW Inservice Testing Program.Caused by Failure to Recognize Design Bases Features Re Afws by Personnel. Updated LER Will Be Submittted by 990415.With 990127 Ltr
ML17335A4921999-01-19019 January 1999
LER 98-052-01:on 981128,no Analysis for NSR Sc Manual Loader for Tdafwp Could Be Found in Original Design.Cause Due to All Failure Modes Not Considered When Compressed Air Sys Originally Designed.Performed Review of Components
ML17335A4721999-01-0606 January 1999
LER 98-055-00:on 981207,potential for Condition Outside of Design Bases for Rod Control Sys Was Noted.Caused by Calibration Error Coupled with Single Rod Failure.Condition Rept Investigation Is Ongoing
ML17335A4691999-01-0606 January 1999
LER 98-056-00:on 981211,hot Leg Nozzle Gaps Resulted in Plant Being in Unanalyzed Condition.Analyses Are Being Performed by W to Resolve Problem.Updated LER Will Be Submitted by 990211.With 990106 Ltr
ML17335A4661999-01-0505 January 1999
LER 98-049-00:on 981020,emergency Boron Injection Flow Path Was Inoperable.Caused by Original Design Deficiency. Engineering Evaluation of Event Is Continuing
ML17335A4631999-01-0404 January 1999
LER 98-054-00:on 981202,discovered That at Least One MSSV Had Not Been Reset as Required by Ts.Engineering Is Continuing Review of Extent of Condition for Event.Updated LER Will Be Submitted by 990129.With 990104 Ltr
ML17335A4481998-12-30030 December 1998
LER 98-053-00:on 981130,discovered Use of Inoperable Substitute Subcooling Margin Monitor.Caused by Condition Existing Since Installation of Plant Process Computer in 1992.Updated LER Will Be Submitted.With 981230 Ltr
ML17335A4581998-12-28028 December 1998
LER 98-052-00:on 981128,turbine Driven AFW Pump Speed Controller Failure Mode Occurred.Caused Because Not All Failure Modes Were Considered When Compressed Air Sys Was Originally Designed.Verified Current Design Change Process
ML17335A4281998-12-22022 December 1998
LER 98-051-00:on 981122,reactor Trip Signal from Manual Safety Injection Not Verified as Required by TS Surveillance,Was Discovered.Maintenance Currently Evaluating Significance & Cause of Event
ML17335A4111998-12-17017 December 1998
LER 98-047-00:on 981117,potential for Increase Leakage from Reactor Coolant Pump Seals Was Identified.Util Is Working with W to Resolve Issue.Current Expectations Are to Submit Update to LER by 990215.With 981217 Ltr
ML17335A4141998-12-16016 December 1998
LER 98-058-00:on 981216,postulated High Line Break Could Result in Condition Outside Design Bases for AF Occurred. Caused by Deficiencies Associated with Administration of HELB Program.Analysis of AF Will Be Completed by 990122
ML17335A4181998-12-16016 December 1998
LER 98-050-00:on 980814,ancillary Equipment Installed in Ice Condenser Was Not Designed to Withstand Design Basis Accident/Earthquake Loads.Caused by Lack of Established Design Criteria.Developed Design Criteria
ML17335A3871998-12-11011 December 1998
LER 98-031-01:on 980610,potential Common Mode Failure of RHR Pumps Were Noted.Caused by Inaccurate Values.Accurate Miniflow Numbers Have Been Determined by Flow Testing
ML17335A3821998-12-0808 December 1998
LER 98-039-01 Re EOP Step Conflicts with Small Break LOCA Analysis.Ler 98-039-00 Has Been Canceled.With 981208 Ltr
ML17335A3781998-12-0707 December 1998
LER 98-007-00:on 981106,high Energy Line Break Effects in Auxiliary FW Sys Was Noted.Cause of Event Is Under Investigation & Will Be Completed by 990220.Updated LER Will Be Submitted by 990310.With 981207 Ltr
ML17335A3771998-12-0303 December 1998
LER 98-046-00:on 981103,determined That Afs Was Unable to Meet Design Flow Requirements During Special Test.Caused by Failure to Consider All Aspects of Sys Operation in Design of Suction Basket Strainers.Sys Will Be Redesigned
ML17335A3741998-12-0202 December 1998
LER 97-011-02:on 970822,operation Was Noted Outside Design Bases for ECCS & CSP for Switchover to Recirculation Sump Suction.Caused by Ineffective Change Mgt.Revised Procedure for Switchover 01(02) Ohp 4023.ES-1.3
1999-09-17
[Table view]
Category:TEXT-SAFETY REPORT
MONTHYEARML17335A5641999-10-18018 October 1999
LER 99-024-00:on 990708,literal TS Requirements Were Not Met by Accumlator Valve Surveillance.Caused by Misjudgement Made in Conversion from Initial DC Cook TS to W Std Ts.Submitted License Amend Request.With 991018 Ltr
ML17335A5531999-10-0707 October 1999
LER 99-023-00:on 990907,inadequate TS Surveillance Testing of ESW Pump ESF Response Time Noted.Caused by Inadequate Understanding of Plant Design Basis.Surveillance Tests Will Be Revised & Implemented
ML17335A5631999-09-30030 September 1999
Monthly Operating Rept for Sept 1999 for DC Cook Nuclear Plant,Unit 1.With 991012 Ltr
ML17335A5621999-09-30030 September 1999
Monthly Operating Rept for Sept 1999 for DC Cook Nuclear Plant,Unit 2.With 991012 Ltr
ML17335A5481999-09-30030 September 1999
Non-proprietary DC Cook Nuclear Plant Units 1 & 2 Mods to Containment Sys W SE (Secl 99-076,Rev 3).
ML17335A5451999-09-28028 September 1999
Rev 1 to Containment Sump Level Design Condition & Failure Effects Analysis for Potential Draindown Scenarios.
ML17326A1291999-09-17017 September 1999
LER 99-022-00:on 990609,electrical Bus Degraded Voltage Setpoints Too Low for Safety Related Loads,Was Discovered. Caused by Lack of Understanding of Design of Plant.No Immediate Corrective Actions Necessary
ML17326A1481999-09-17017 September 1999
Independent Review of Control Rod Insertion Following Cold Leg Lbloca,Dc Cook,Units 1 & 2.
ML17326A1211999-08-31031 August 1999
Monthly Operating Rept for Aug 1999 for Cook Nuclear Plant, Unit 2.With 990915 Ltr
ML17326A1201999-08-31031 August 1999
Monthly Operating Rept for Aug 1999 for Cook Nuclear Plant, Unit 1.With 990915 Ltr
ML17326A1121999-08-27027 August 1999
LER 99-021-00:on 990728,determined That GL 96-01 Test Requirements Were Not Met in Surveillance Tests.Caused by Failure to Understand Full Extent of GL Requirements. Surveillance Procedures Will Be Revised or Developed
ML17326A1011999-08-26026 August 1999
LER 99-020-00:on 990727,EDGs Were Declared Inoperable.Caused by Inadequate Protection of Air Intake,Exhaust & Room Ventilation Structures from Tornado Missile Hazards. Implemented Compensatory Measures in Form of ACs
ML17326A0911999-08-16016 August 1999
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
ML17326A0771999-08-0404 August 1999
LER 98-029-01:on 980422,noted That Fuel Handling Area Ventilation Sys Was Inoperable.Caused by Original Design Deficiency.Radiological Analysis for Spent Fuel Handling Accidents in Auxiliary Bldg Will Be Redone by 990830
ML17335A5461999-08-0202 August 1999
Rev 0 to Evaluation of Cook Recirculation Sump Level for Reduced Pump Flow Rates.
ML17326A0871999-07-31031 July 1999
Monthly Operating Rept for July 1999 for DC Cook Nuclear Plant,Unit 1.With 990812 Ltr
ML17326A0861999-07-31031 July 1999
Monthly Operating Rept for July 1999 for DC Cook Nuclear Plant,Units 2.With 990812 Ltr
ML17326A0741999-07-29029 July 1999
LER 99-018-00:on 990629,determined That Valve Yokes May Yield Under Combined Stress of Seismic Event & Static,Valve Closed,Stem Thrust.Caused by Inadequate Design of Associated Movs.Operability Determinations Were Performed for Valves
ML17326A0661999-07-26026 July 1999
LER 99-017-00:on 990625,noted That Improperly Installed Fuel Oil Return Relief Valve Rendered EDG Inoperable.Caused by Personnel Error.Fuel Oil Return Valve Was Replaced with Valve in Correct Orientation.With 990722 Ltr
ML17326A0651999-07-22022 July 1999
LER 98-014-03:on 980310,noted That Response to high-high Containment Pressure Procedure Was Not Consistent with Analysis of Record.Caused by Inadequate Interface with W. FRZ-1 Will Be Revised to Be Consistent with New Analysis
ML17326A0491999-07-13013 July 1999
LER 99-016-00:on 990615,TS Requirements for Source Range Neutron Flux Monitors Not Met.Caused by Failure to Understand Design Basis of Plant.Procedures Revised.With 990713 Ltr
ML17326A0331999-07-0101 July 1999
LER 99-004-01:on 971030,failure to Perform TS Surveillance Analyses of Reactor Coolant Chemistry with Fuel Removed Was Noted.Caused by Ineffective Mgt of Tss.Chemistry Personnel Have Been Instructed on Requirement to Follow TS as Written
ML17326A0511999-06-30030 June 1999
Monthly Operating Rept for June 1999 for DC Cook Nuclear Plant,Unit 2.With 990709 Ltr
ML17326A0501999-06-30030 June 1999
Monthly Operating Rept for June 1999 for DC Cook Nuclear Plant,Unit 1.With 990709 Ltr
ML17326A0151999-06-18018 June 1999
LER 99-014-00:on 990521,determined That Boron Injection Tank Manway Bolts Were Not Included in ISI Program,Creating Missed Exam for Previous ISI Interval.Caused by Programmatic Weakness.Isi Program & Associated ISI Database Modified
ML17325B6421999-06-0101 June 1999
LER 99-013-00:on 990327,safety Injection & Centrifugal Charging Throttle Valve Cavitation During LOCA Could Have Led to ECCS Pump Failure.Caused by Inadequate Original Design Application of Si.Throttle Valves Will Be Developed
ML17325B6311999-06-0101 June 1999
LER 99-S03-00:on 990430,vital Area Barrier Degradation Was Noted.Caused by Inadequate Insp & Maint of Vital Area Barrier.Repairs & Mods Were Made to Barriers to Eliminate Degraded & Nonconforming Conditions
ML17326A0061999-05-31031 May 1999
Monthly Operating Rept for May 1999 for Dcp.With 990609 Ltr
ML17326A0071999-05-31031 May 1999
Monthly Operating Rept for May 1999 for DC Cook Nuclear Plant,Unit 2.With 990609 Ltr
ML17325B6351999-05-28028 May 1999
LER 99-S02-00:on 990428,vulnerability in Safeguard Sys That Could Allow Unauthorized Access to Protected Area Was Noted. Caused by Inadequate Original Plant Design.Mods Were Made to Wall Opening to Eliminate Nonconforming Conditions
ML17265A8231999-05-24024 May 1999
LER 98-037-01:on 990422,determined That Ice Condenser Bypass Leakage Exceeds Design Basis Limit.Caused by Pressure Seal Required by Revised W Design Not Incorporated Into Aep Design.Numerous Matl Condition Walkdowns & Assessments Made
ML17325B6001999-05-20020 May 1999
LER 99-012-00:on 990420,concluded That Auxiliary Bldg ESF Ventilation Sys Not Capable of Maintaining ESF Room Temps post-accident.Caused by Inadequate Control of Sys Design Inputs.Comprehensive Action Plan Being Developed
ML17325B5861999-05-10010 May 1999
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
ML17325B5811999-05-0404 May 1999
LER 99-011-00:on 990407,air Sys for EDG Will Not Support Long Operability.Caused by Original Design Error.Temporary Mod to Supply Makeup Air Capability in Modes 5 & 6 Was Prepared
ML17325B5771999-05-0303 May 1999
LER 99-010-00:on 990401,RCS Leak Detection Sys Sensitivity Not in Accordance with Design Requirements Occurred.Caused by Inadequate Original Design of Containment Sump Level. Evaluation Will Be Performed to Clearly Define Design
ML17335A5301999-04-30030 April 1999
Monthly Operating Rept for Apr 1999 for DC Cook Nuclear Plant,Unit 1.With 990508 Ltr
ML17335A5291999-04-30030 April 1999
Monthly Operating Rept for Apr 1999 for DC Cook Nuclear Plant,Unit 2.With 990508 Ltr
ML17325B5581999-04-16016 April 1999
LER 99-006-00:on 990115,personnel Identified Discrepancy Between TS 3.9.7 Impact Energy Limit & Procedure 12 Ohp 4030.STP.046.Caused by Lack of Design Basis Control.Placed Procedure 12 Ohp 4030.STP.046 on Administrative Hold
ML17325B5471999-04-12012 April 1999
LER 99-009-00:on 990304,as-found RHR Safety Relief Valve Lift Setpoint Greater than TS Limit Occurred.Cause Investigation for Condition Has Not Been Completed.Update to LER Will Be Submitted,Upon Completion of Investigation
ML17325B5321999-04-0707 April 1999
LER 99-S01-00:on 990308,discovered That Lock for Vital Gate Leading to Plant 4KV Switchgear Area Was Nonconforming & Vulnerable to Unauthorized Access.Caused by Inadequate Gate Design & Inadequate Procedures.Mods Are Being Made to Gate
ML17325B5161999-04-0101 April 1999
LER 99-007-00:on 981020,calculations Showed That Divider Barrier Between Upper & Lower Containment Vols Were Overstressed.Engineers Are Currently Working on Analyses of Loads & Stress on Enclosures
ML17325B5491999-03-31031 March 1999
Monthly Operating Rept for Mar 1999 for DC Cook Nuclear Plant Unit 2.With 990408 Ltr
ML17325B5441999-03-31031 March 1999
Monthly Operating Rept for Mar 1999 for DC Cook Nuclear Plant,Unit 1.With 990408 Ltr
ML17325B5221999-03-29029 March 1999
LER 99-001-00:on 960610,degraded Component Cooling Water Flow to Containment Main Steam Line Penetrations,Identified on 990226.Caused by Inadequate Understanding of Design Basis.Additional Investigations Ongoing
ML17325B4801999-03-18018 March 1999
LER 99-004-00:on 971030,failure to Perform TS Surveillance Analyses of Rc Chemistry with Fuel Removed Was Noted.Cause of Event Is Under Investigation.Corrected Written Job Order Activities Used to Control SD Chemistry Sampling
ML17325B4741999-03-18018 March 1999
LER 99-005-00:on 940512,determined That Rt Breaker Manual Actuations During Rod Drop Testing Were Not Previously Reported.Caused by Lack of Training.Addl Corrective Actions,Including Preventative Actions May Be Developed
ML17325B5671999-03-0202 March 1999
Summary of Unit 1 Steam Generator Layup Chemistry from 980101 to 990218.
ML17325B4631999-02-28028 February 1999
Monthly Operating Rept for Feb 1999 for DC Cook Nuclear Power Station,Unit 2.With 990308 Ltr
ML17325B4621999-02-28028 February 1999
Monthly Operating Rept for Feb 1999 for DC Cook Nuclear Plant,Unit 1.With 990308 Ltr
ML17325B4571999-02-24024 February 1999
LER 99-003-00:on 990107,CR Pressurization Sys Surveillance Test Did Not Test Sys in Normal Operating Condition.Caused by Failure to Recognize Door 12DR-AUX415 as Part of CR Pressure Boundary.Performed Walkdown of Other Doors
1999-09-30
[Table view] |
Text
VA.J RSVP. X J.
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
<<S I ACCESSION NBR:9910260103 'OC.DATE: 99/10/18 NOTARIZED: NO DOCKET FACIL:50-315 Donald C. Cook Nuclear Power Plant, Unit 1, Indiana M 05000315 AUTH.Nlg!E .'UTHOR AFFILIATION DEPUYDT,M.B. ,Indiana Michigan Power Co.
BAKKEN,A.C. Indiana Michigan Power Co.
RECIP.NAME RECIPIENT AFFILIATION
SUBJECT:
LER 99-024-00:on 990708, literal TS requirements were not met by accumlator valve surveillance. Caused by misjudgement made in conversion from initial DC Cook TS to W Std TS.Submitted A license amend request.
T DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE:
TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc. E NOTES:
RECIPIENT COPIES RECIPIENT COPIES 0 ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL LPD3-1 1 1 STANG,J 1 1 INTERN . ILE CENTER 1 1 NRR/DIPM/IOLB 1 1 1 1 NRR/DSSA/SPLB 1 1 RES/DET/ERAB 1 1 RES/DRAA/OERAB 1 1 RGN3 FILE 01 1 1 EXTERNAL: L ST LOBBY WARD 1 1 LMITCO MARSHALL 1 1 NOAC POORE,W. 1 1 NOAC QUEENER,DS 1 1 NRC PDR 1 1 NUDOCS FULL TXT 1 1 D N
NOTE TO ALL "RIDS" 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 ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 I FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 15 ENCL 15
Indiana Michigan Powei Company Cock Nudear Racl One Cook Race Mgman. Ml 49106 6164696l Z
INEMANA MICHIGAN POWER October 18, 1999 United States Nudear Regulatory Commission Document Control Desk Washington, DC 20555 Operating License DPR-58 Docket No. 50-315 Document Control Manager:
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LER 315/99-024-00, "Literal Technical Specifications Requirement Not Met By Accumulator Valve Surveillance."
There are no commitments identified in this submittal.
Sincerely, A. Christopher Bakken, III Site Vice President Isrd Attachment c: S. E. Dyer, NRC Region III R. P. Powers P. A. Barrett R. F. Godley R. Whale D. Hahn Records Center, INPO NRC Resident Inspector 9910260103 991018 PDR ADOCK 05000315 S PDR AE/': ~I aiericn's Enetg Inrlnl,'rda
NRC Form 366 (6-1998)
U.S. NUCLEAR REGUlATORY COMMISSION LICENSEE EVENT REPORT (LER)
ESTSAATED IKSIDEN PER WCORPOMTED WTO TIC ~
APPROVED BY ORB No. 31504(04 EXPIRES 06)30/2001 RESPONSE TO COLDLY IATIH TISS EQPOATORY WFORMAllONCIKIECAON REOUEST: 50.0 HRS. REPORTED IESSONS LEARNED ARE PROCESS AIEI FED BACK TO SCMSTRY.
P~
FORWARD COMMENTS REOARDINO BISICEN ESTNATE TO THE PFORllATION AND RECORDS MANACEMENT lÃIANCH IT% Fee j. IAS. NVCIEAR RECIAATORY COMMISSOIL WASISNOTOIL OC 20MSCC01. PIC) TO THE REDVCTION reamer oleoolor), OFRCE OF MANAOEMENT Aro IROSET, wASISNrnorA DC (See reverse for required number of 21500 digits/characters for each block)
FACIUlYNAME(1) DOCKET NUMBER (2) PAGE (0)
Cook Nuclear Plant Unit 1 05000-315 1 of 3 TITLE(0)
Literal Technical Specifications Requirement Not Met By Accumulator Valve Surveillance EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED(8)
A ILI NAM CKET NUMB SEQUENTIAL REVISION Cook Nuclear Plant 2 05000-316 DAY YEAR NUMBER NUMBER MONTH DAY YEAR A IUTY HAM NUM 07 08 1999 1999 024 00 10 18 1999 OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR Ii: (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) 0 50.73(a)(2)(iii) 73.71 20.2203(a)(2)(i) 20.2203(a)(3)(ii) 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)
Speorr in ADCraoI Derorr 20.2203(a)(2)(iv) 50.36(c)(2) 50.73(a)(2)(vii) or n NRC Form 366A LICENSEE CONTACT FOR THIS LER (12)
TELEPHONE NUMBER (Inc4de Area Code)
Ms. Mary Beth Depuydt, Regulatory Compliance (616) 465-5901 X 1589 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)
REPORTABLE REPORTABLE lo CAUSE SYSTEM COMPONENT MANUFACTURER TO EPIX CAUSE COMPONENT MANUFACTURER EPIX SUPPLEMENTAL REPORT EXPECTED 14) EXPECTED MONTH DAY YES X SUBMISSION (If Yes, complete EXPECTED SUBMISSION DATE) NO DATE (15 Abstract (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16)
On July 8, 1999, during a review of Technical Specifications (TS) surveillance procedures, it was discovered that TS Surveillance Requirement (SR) 4.5.1.c was not being met by the associated surveillance procedure. SR 4.5.1.c requires that power to the RCS accumulator isolation valve motor operator be disconnected by, "... removal of the breaker from the circuit." The surveillance procedure does not meet the literal wording of TS SR 4.5.1.c in that the breaker is opened and maintained in that position rather than being physically removed. This LER is therefore submitted in acco'rdance with 10 CFR 50.73(a)(2)(i)(B), as a condition prohibited by the plant's Technical Specifications.
This condition resulted from a misjudgment made in the conversion from the initial D.C. Cook Nuclear Plant (CNP) TS to the Westinghouse Standard Technical Specifications (STS), as described in NUREG-0452. The wording appears to have been adopted from the STS without considering the type of breaker installed for the accumulator isolation valves. A license amendment request will be submitted to change TS SR 4.5.1.c. A comprehensive review of the adequacy of TS surveillance test procedures is being performed as part of Restart Action Plan ¹0001, "Programmatic Breakdown in Surveillance Testing."
The identified condition has no safety significance because power was removed from the accumulator isolation valve control circuit, thereby preventing inadvertent valve operation due to a single failure in the valve control circuitry.
NRC FORM 366 (6-1998)
0 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 024
. 00 TEXT (Ifmore space is required, use addiiional copies of NRC Form P66A) (17)
Unit 1 was in Mode 5, Cold Shutdown Unit 2 was in Mode 5, Cold Shutdown On July 8, 1999, during a review of Technical Specifications (TS) surveillance procedures, it was discovered that TS Surveillance Requirement (SR) 4.5.1.c was not being met by the associated surveillance procedure. SR 4.5.1.c requires that power to the RCS accumulator isolation valve motor operator be disconnected by, "... removal of the breaker from the circuit." The suiveillance procedure, 01(02)-OHP-4030.STP.031, "Operation Weekly Surveillance Checks," requires the operator to check the breaker switch in the OFF position, but the breaker is not physically removed from the cubicle.
Therefore, the surveillance procedure does not meet the literal requirement of TS SR 4.5.1.c.
This condition resulted from a.misjudgment made in the conversion from the initial D.C. Cook Nuclear Plant (CNP) TS to the Westinghouse Standard Technical Specifications (STS), as described in NUREG-0452. The NUREG-0452, "Standard Technical Specifications for Westinghouse Pressurized Water Reactors," accumulator isolation valve surveillance requirement appears to have been adopted without considering Cook plant design.
During conversion from the original to the STS, it was erroneously decided that the TS SR would be met by opening the molded case circuit breaker (MCCB) that supplies power to the accumulator valve operator, and maintaining the breaker in the OFF position. The investigation has shown that CNP personnel do not consider the MCCBs capable of being "racked out" due to their physical design. Instead, when directed to rack out this style of breaker, personnel understand that rack out means to place the breaker in the OFF position. While the surveillance procedure actions meet the intent of the TS by placing the breakers in the OFF position, they do not meet the literal requirement of TS SR 4.5.1.c. This condition has existed since initial plant startup.
On September 20, 1999, this condition was determined to be reportable; therefore, this LER is submitted in accordance with 10 CFR 50.73(a)(2)(i)(B), as a condition prohibited by the plant's Technical Specifications. The gap in time between the discovery date of July 8, 1999, and the reporting date of September 20, 1999, was due to the need for evaluation by D.C. Cook Nuclear Plant (CNP) staff and management due to the extended history of the issue.
TS SR 4.5.1.c requires that we periodically verify, "... that power to the isolation valve operator is disconnected by removal of the breaker from the circuit." The basis for this TS surveillance requirement is that, "... as these accumulator isolation valves fail to meet single failure criteria, removal of power to the valves is required." This CNP TS surveillance requirement and bases were adopted directly from NUREG-0452, and no plant-specific changes were made to the CNP requirement.
To physically remove a breaker from a circuit, the breaker is racked out. The term "rack out" means to use the installed racking mechanism to physically move the switchgear breaker away from the bus stabs such that the breaker is no longer in contact with the bus bars. Additionally, racking out a breaker disconnects the breaker from the control circuit such that the breaker cannot operate. Breakers that are capable of being racked out have built-in mechanisms to allow the rack out operation, and are generally found on switchgear buses.
The safety-related accumulator isolation valves are powered from the Aux 600V switchgear buses through Motor Control Centers (MCCs). The breakers used on these MCCs are not of the switchgear type, and have no mechanism for being NRC FORM 366A (6-1998)
NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION (6-1996)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACIUTY NAME (1) DOCKET NUMBER(2) LER NUMBER (6) PAGE (3)
YEAR SEQUENTIAL REVISION Cook Nuclear Plant Unit 1 05000-315 NUMBER NUMBER 3of3 1999 024 00 TEXT Pf more space is required, use additional copies of NRC Form P66A) (17) racked out. Rather, the breakers used are small MCCBs, which are common for a small load of this type and voltage. The MCCBs are hard-wired to the supply lines and loads in the MCC, and are difficultto remove from their cubicles. The term "rack out" does not apply to MCCBs.
To "electrically" remove the accumulator isolation valve MCCB from the circuit, the operator merely has to open the breaker and maintain it in the OFF position. Placing the breaker in OFF de-energizes control power to the valve operator.
Deliberate operator action by physically closing the breaker at the local MCC panel is required to restore valve operator control power. Opening the accumulator valve breaker when reactor system pressure is greater than 2000 psig prevents the potential for an active failure or inadvertent operation of the valve switch from the control room to cause the valves to close. No electrical fault will cause the breaker to close. Therefore, the intent of the TS is met.
Based on the above information, the identified condition has no safety significance. Opening the accumulator isolation valve breaker or removing the breaker from the circuit both remove power to the circuit and prevent inadvertent valve operation due to a single failure in the valve control circuitry.
No immediate corrective actions were required because the plant was in an operating Mode where the surveillance requirement was not applicable.
A license amendment request will be submitted by October 22, 1999, to change Technical Specifications Surveillance Requirement 4.5.1.c to read, "At least once per 31 days when the RCS pressure is above 2000 psig, by verifying that power is removed from each accumulator isolation valve operator."
As previously stated in correspondence AEP: NRC: 1260GH, dated March 19, 1999, "Enforcement Actions98-150, 98-151,98-152 and 98-186, Reply to Notice of Violation Dated October 13, 1998," a comprehensive review of the adequacy of TS surveillance test procedures is being performed. This action is being tracked by Restart Action Plan 40001, "Programmatic Breakdown in Surveillance Testing."
None NRC FORM 366A (6-1996)
