ML17335A564

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

ML17335A564
Person / Time
Site:	Cook
Issue date:	10/18/1999
From:	Bakken A, Depuydt M INDIANA MICHIGAN POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-99-024, NUDOCS 9910260103
Download: ML17335A564 (6)

Text

VA.J RSVP.X J.REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)<<S I ACCESSION NBR:9910260103

'OC.DATE: 99/10/18 NOTARIZED:

NO FACIL:50-315 Donald C.Cook Nuclear Power Plant, Unit 1, Indiana M AUTH.Nlg!E

.'UTHOR AFFILIATION DEPUYDT,M.B.,Indiana Michigan Power Co.BAKKEN,A.C.

Indiana Michigan Power Co.RECIP.NAME RECIPIENT AFFILIATION DOCKET 05000315

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 license amend request.DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE: TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc.NOTES: A T E RECIPIENT ID CODE/NAME LPD3-1 COPIES LTTR ENCL 1 1 RECIPIENT ID CODE/NAME STANG,J COPIES LTTR ENCL 1 1 0 INTERN.ILE CENTER RES/DET/ERAB RGN3 FILE 01 EXTERNAL: L ST LOBBY WARD NOAC POORE,W.NRC PDR 1 1 1 1 1 1 1 1 1 1 1 1 1 1 NRR/DI PM/IOLB NRR/DSSA/SPLB RES/DRAA/OERAB LMITCO MARSHALL NOAC QUEENER,DS NUDOCS FULL TXT 1 1 1 1 1 1 1 1 1 1 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:&hlh hl~tgtgDFRSDFD RRM~~.thfll gh ltlghltg: 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,'r da NRC Form 366 U.S.NUCLEAR REGUlATORY COMMISSION (6-1998)LICENSEE EVENT REPORT (LER)(See reverse for required number of digits/characters for each block)APPROVED BY ORB No.31504(04 EXPIRES 06)30/2001 ESTSAATED IKSIDEN PER RESPONSE TO COLDLY IATIH TISS EQPOATORY WFORMAllON CIKIECAON REOUEST: 50.0 HRS.REPORTED IESSONS LEARNED ARE WCORPOMTED WTO TIC~PROCESS AIEI FED BACK TO SCMSTRY.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 P~REDVCTION reamer oleoolor), OFRCE OF MANAOEMENT Aro IROSET, wASISNrnorA DC 21500 FACIUlY NAME (1)TITLE (0)Cook Nuclear Plant Unit 1 DOCKET NUMBER (2)05000-315 PAGE (0)1 of 3 Literal Technical Specifications Requirement Not Met By Accumulator Valve Surveillance 07 DAY YEAR 08 1999 EVENT DATE (5)1999 LER NUMBER (6)SEQUENTIAL NUMBER 024 REVISION NUMBER 00 REPORT DATE (7)MONTH DAY YEAR 10 18 1999 A ILI NAM Cook Nuclear Plant 2 A IUTY HAM CKET NUMB 05000-316 NUM OTHER FACILITIES INVOLVED (8)OPERATING MODE (9)20.2201 (b)20.2203(a)(2)(v) 50.73(a)(2)(i) 50.73(a)(2)(viii)

THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR Ii: (Check one or more)(11)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 Speorr in ADCraoI Derorr or n NRC Form 366A Ms.Mary Beth Depuydt, Regulatory Compliance TELEPHONE NUMBER (Inc4de Area Code)(616)465-5901 X 1589 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TO EPIX CAUSE COMPONENT MANUFACTURER REPORTABLE lo EPIX SUPPLEMENTAL REPORT EXPECTED 14)YES (If Yes, complete EXPECTED SUBMISSION DATE)X NO EXPECTED SUBMISSION DATE (15 MONTH DAY 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 Plan¹0001,"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 FACILITY NAME (1)Cook Nuclear Plant Unit 1 DOCKET NUMBER(2)05000-315 YEAR LER NUMBER (6)SEQUENTIAL NUMBER REVISION NUMBER PAGE (3)2of3 1999-.024 00 TEXT (If more 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)Cook Nuclear Plant Unit 1 DOCKET NUMBER(2)05000-315 YEAR LER NUMBER (6)SEQUENTIAL NUMBER REVISION NUMBER PAGE (3)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 difficult to 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)