Text

Forwards Analytical Results from 801216 Confirmatory Measurements Split Sample.Comparison Results Documented in Insp Repts 50-315/80-22 & 50-316/80-18.Results of Spiked Particulate Filter Analysis Will Be Submitted Separately
	ML17331A791
Person / Time
Site:	Cook
Issue date:	08/31/1981
From:	Shaller D; INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Nicholson N; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
	NUDOCS 8109100406
	Download: ML17331A791 (116)
	v • d • e

~,'J gO INDIANA&MICHIGAN EIECTBIC COMPANY DONALD C.COOK NUCLEAR PLANT P.o.Box 458, Bridgman, Michigan 49106 (616)465-5901 IE HQ PIXiE OQPg August 31, 1981 Ms.N.Nicholson Office of Inspection and Enforcement United Stated Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Dear Ms.Nicholson:

Attached find the analytical results from the December 16, 1980 Confirmatory Measurements Split Sample.The majority of these results were submitted during the inspection visit and discussed at an exit interview held on site December 17, 1980.The results of the comparison was documented on Inspection Report 50-315/80-22; 50-316/80-18.

Results of the analysis of a spiked particulate filter will be forwarded separately once the sample is received for analysis.Should you have any questions please feel free to contact me.Very truly yours, pjv cc: J.E.Dolan R.S.Hunter R.W.Jurgensen R.F.Kroeger K.J.Vehstedt E.Swanson/N.

DuBry RO: III R..C.Callen MPSC G.Charnoff, Esq.J.M.Hennigan W.Lavallee EPRI PNSRC J.F.Stietzel E.L.Townley bcc: E.A.Smarrella J.T.Wojcik 810'7100406 810831 PDR ADQCK 05000315 P PDR~~D.V.Shaller Plant Manager, OSSS>SEP 5)9g-(b d~fI 4~J

'I RSX-.203 12-16-80 8 1008 I-131 Xe-133 Xe-135 Cs-136 I-133 Cs-134 Cs-137 Nb 95 Co-58 Mn-54 Co-60 8a-24 H-3 Sr-89 Sr-90 gross 8-y 4.404 x 10 4+1.54 x 10 6 pCi/cc 1.189 x 10<,a 2.76 x 10 6 pCi/cc 7.858 x 106+1.03 x 10 7 pCi/cc 2.11 x 10 5+8.73 x 10 6 pCi/cc 7.422 x 10 5+1.40 x 10 6 pCi/cc 4.021 x 10 5+1.09 x 10 6 pCi/cc 7.701 x 10~+1.26 x 10 7 pCi/cc ,3.23 x 10.4+8.31 x 10 6 pC,i/cc 1..471 x 10 5+1.27 x 10 7 pCi/cc 1.513.x 10 5+8.78 x,l0 6 pCi/cc 6.298 x 10 4+1.12 x 10 6 pCi/cc 2.075 x 102+'2.03 x".10 3 pCi/cc 4.90 x 10 6+4.90 x 10 7 pCi/cc 3.20 x 10 7+3.20 x 10 8 pCi/cc 2.70 x 10 4-+2.70 x 10 5 pCi/cc 4.39 x 10+4.40 x 10 pCi/cc 81 Gas Decay Tank 12-17-80 8 0952 Xe-133 1.255 x 10 4+1.08 x 10 6 pCi/cc Kr-85 7.227 x 10 5+1.05 x 10 6 pCi/cc Xe-131M 8.752 x 10 a 5.65 x 10 pCi/cc Unit 1 Vent Stack-Charcoal Cartridge 12-16-80 8 0957 I-131 2.692 x 10 13+3.96 x 10 14 pCi/cc I-133 1.777 x 1012+2.29 x 10 14 pCi/cc Xe-133 7:60 x 10 13+8.40 x 10 14 pCi/cc Xe-135 3.00 x 10+3.90 x 10 pCi/cc Unit 1 Vent Stack-Gas Marinelli 12-16-80 8 0957 Xe-133 1,.087 x 10+3.25 x 10 pCi/cc Unit 1 Vent Stack-Particulate Filter-no activity detected (

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~pS Ately c>~4 0 n 0 I Ol'l g+r~~O++*++UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 789 ROOSEVELT ROAO GLEN ELLYN, ILLINOIS 60137 1981 Docket No.50-315 Docket No.50-316 American Electric Power Service Corporation Indiana and Michigan Power Company ATTN: 'r.John E.Dolan Vice Chairman Engineering 2 Broadway New York, NY 10004 Gentlemen:

This refers to the routine safety inspection conducted by Mr.M.P.Phillips and Miss N.A.Nicholson of this office on December 15-17, 1980, of activities at the Donald C.Cook Nuclear Plant, Units 1 and 2, authorized by NRC Operating Licenses No.DPR-58 and No.DPR-74 and to the discussion of our findings with Mr.B.Svensson and others of your staff at the conclusion of the inspection.

The enclosed copy of our inspection report identifies areas examined during the inspection.

Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.

In addition, our Mobile Laboratory was at the site during the inspection to perform independent measurements of radio-activity.No items of noncompliance with NRC requirements were identified during the course of this inspection.

In accordance with Section 2.790 of the NRC's"Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room, except as follows.If this report contains information that you or your contractors believe to be proprietary, you must apply in writing to this office, within twenty-five days of the date of this letter, to withhold such information from public disclosure.

The application must include a full statement of the reasons for which the information is considered proprietary, and should be prepared so that proprietary information identified in the application is contained in an enclosure to the application.

American Electric Power Service Corporation-2-(y a~n'Gn<Me will gladly discuss any questions you have concerning this inspection.

Sincerely, sf~A.B.Davis;Chief Fuel Facility and Materials Safety Branch

Enclosure:

IE Inspection Reports No.50-315/80-22 and No.50-316/80-18

REGION III Reports No.'50-315/80-22; 50-316/80-18, Docket Nos.50-315;50-316 Licenses No.DPR-58;DPR-74 Licensee: American Electric Power Service Corporation Indiana and Michigan Power Company 2 Broadway New York, NY 10004 Facility Name: D.C.Cook Nuclear Plant, Units 1 and 2 Inspection at: D.C.Cook Site, Bridgeman, MI Inspection ucted: 'c ber 15-17, 1980 Inspectors:

M..Ilips N..Aigholson-Approved: V.g.Pa eriello, Chief Environmental and Special Projects Section C2 Ins ection Summa Ins ection on December 15-17 1980 (Re orts No.50-315/80-22'0-316/80-18)

Areas Ins ected: Routine unannounced inspection of Confirmatory Measurements, including collection of samples, analysis onsite with the Region III Mobile Laboratory, and discussion of results.The inspection involved 49 inspector-hours on site by two NRC inspectors'esults:

For the one area inspected, no apparent items of noncompliance or deviations were identified:

DETAILS 1.Persons Contacted*B.Svensson, Assistant Plant Manager+J.Stietzel, guality Assurance Supervisor

+J.Wojcik, Plant Chemistry Supervisor-J.Ersland, Chemistry Supervisor

-'enotes those present at the exit interview..

2~Results of Co erative Anal ses Results of comparative analyses performed on samples split and analyzed in the RIII Mobile Laboratory onsite during this inspection are shown in Table I.The criteria for comparing measurement results are given in Attachment 1.For 19 sample comparisons, the licensee's results yielded 16 agreements or possible agreements.

The licensee failed to quantify Na-24 and Co-58 on Qe particulate filter coygted.These were at a level of 2.1 x 10 pCi/ml and 2.0 x 10 p Ci/ml respectively, and are considerably lower than the Environmental Technica/1Specification Value for the Lower Limit of Detection, which is 10 pCi/ml.Because of the low activity, and lack of sufficient number of isotopes, the licensee agreed to count a particulate spike sample within seven days after receipt.The licensee failed to quantify Xe-131m in the gas sample.Although the counting equipment used did detect the presence of this isotope's energy line, it reported the activity as Ce-139, and gave a possible identification as Xe-133m.Xe-133m does not have any gamma rays associated with this energy, but Xe-131m does.The licensee felt this was an obvious software problem and is currently in discussions with the supplier of the counting equipment to resolve this misi$enti-fication.The Xe-131m in the sample was at a level of 7.0 x 10 PCi/ml, which is lower than the Environmental Techgical Specification Value for the Lower I,imit of Detection, which is 10/Ci/ml.3.Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)at the conclusion of the inspection on December 17, 1980.The inspectors summarized the scope and findings of the inspection.

The licensee made the following remarks in response to certain of the items discussed by the inspectors.

a.Agreed to also analyze the two liquid samples collected for tritium, Sr-89, Sr-90, and gross beta (to be counted at 1:00 p.m.Eastern Standard Time on January 14, 1981)." 2-b.Agreed to analyze a particulate spike sample within seven days of receipt and then return the spike with a copy of the results.

Attachments:

l.Attachment 1, Criteria for Comparing Analytical Measurements 2.Table I, Confirmatory Measurements Program Results-3-ATTAC)MENT 1 CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS This attachment provides criteria for comparing results of capability tests and verification measurements.

The criteria are based on an empirical relationship which combines prior experience and the a

REGION III 789 ROOSEVELT ROAD GLEN EL'LYN, ILLINOIS 60137 February 4, 1981 Docket No.50-315 Docket No.50-316 American Electric Power Service Corporation Indiana and Michigan Power Company ATTN: Mr.John E.Dolan Vice Chairman Engineering 2 Broadway New York, NY 10004 Gentlemen:

This refers to the routine inspection conducted by Messrs.E.R.Swanson and N.E.DuBry of this office on December 1-31, 1980, of activities at the D.C.Cook Nuclear Plant Units 1 and 2, authorized by NRC Operating License No.DPR-58 and No.DPR-74 and to the discussion of our findings with Mr.Shaller and others of your staff at the conclusion of the inspection.

The enclosed copy of our inspection report identifies areas examined during the inspection.

Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.

During this inspection, certain of your activities appeared to be in non-compliance with NRC requirements, as described in the enclosed Appendix A.The inspection showed that action had been taken to correct the identified noncompliance and to prevent recurrence.

Consequently, no reply to this noncompliance is required and we have no further questions regarding this matter at this time.Certain other activities, set forth in Appendix A to this letter, appear to be a deviation from commitments which you have made in previous correspondence with the Commission.

Please advise us in writing within twenty-five days of the date of this letter of the corrective action you have taken or plan to take, showing the estimated date of completion with regard to this deviation.

~,'American Electric Power Service" 2-Corporation February 4, 1981 Ve will gladly discuss any questions you have concerning this inspection.

Sincerely,

Enclosures:

1.Appendix A, Notice of Violation 2.IE Inspection Report No.50-315/80-21 and No.50-316/80"17 R.F.Heishman, Chief Reactor Operations and Nuclear Support Branch

REGION III Reports No.50-315/80-21; 50-316/80-17 Docket Nos.50-315;50-316 Licenses No.DPR-58;DPR-74 I,icensee:

American Electric Power Service Corporation Indiana and Michigan Power Company 2 Broadway New York, NY 10004 Facility Name: D.C.Cook Nuclear Power Plant, Units 1 and 2 Inspection At:" D.C.Cook Site, Bridgman, MI Inspection Conducted:

December 1-31, 1980 Inspectors:

E.R.Swanson Approved By: D.C.Boyd, Chief, Projects Section 4 2,-Z-8'/z'>>z-'/Ins ection Summa Ins ection on December 1-31 1980 (Re orts No.50-315/80-21 50-316/80-17)

Areas Ins ected: Routine, onsite regular and backshift inspection by the resident inspector.

Areas inspected included operational safety verification, inspection during long term shutdown, surveillance observation, maintenance observations, IE Bulletin and IE Circular followup, licensee event report reviews, plant trips, and independent inspection efforts.The inspection involved a total of 178 inspector-hours onsite by two NRC inspectors including 49 inspector-hours on the off-shifts.

Results: Of the nine areas inspected, no items of noncompliance or deviations were identified in eight areas.Two items of noncompliance were identified in two areas (violation, level IV-exceeding an action statement, paragraph 8;violation level VI-failure to meet commitment-paragraph 10d).

~~

DETAILS Persons Contacted R.Hunter, Vice President, AEP+D.Shaller, Plant Manager*B.Svensson, Assistant Plant Manager+E.Townley, Assistant Plant Manager+R.Keith, Operations Superintendent

E.Smarella, Technical Superintendent

R.Dudding, Maintenance Superintendent

+J.Stietzel, gA Supervisor

+D.Duncan, CGI Supervisor

D.Palmer, Radiation Protection Supervisor M.Kriesel, Environmental Supervisor R.Jurgenson, Assistant Vice President, AEP The inspectors also conducted a number of interviews with operators, technicians, and maintenance personnel during the inspection.

Denotes those present at the exit interview.

erational-Safet Verification The inspector observed control room operations, reviewed selected logs and records to identify significant changes and trends;to assure required entries were being made;to verify operating memos and instructions conform to Tech-nical Specifications; to check correctness of communications about equipment operational status;and to verify conformance to limiting conditions for operation during the month of December 1980.The inspector also conducted discussions about selected annunciators with the control room operators and supervision to assure they were knowledgeable of plant conditions and that corrective action, if required, was being taken.Tours of the Unit 2 reactor compartment (lower level), the auxilary building, and turbine buildings were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations and to verify that maintenance requests had been initiated for equipment in need of maintenance.

The in-spector by tours of the montoring stations, observations, and direct interview verified that the physical security plan was being implemented in accordance with the station security plan.The inspector observed plant housekeeping/cleanliness conditions and verified implementation of radiation protection controls.During the month of December 1980, the inspector walked down the accessible portions of the Unit 1 high head and boron injection portion of the CVCS which is part of the ESF systems to verify operability.

These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under technical specifications, 10 CFR, and administrative pro-cedures.-2-

~~

3.Ins ection Durin Lon Term Shutdown The inspector observed the continued shutdown control room operations of Unit 2, reviewed applicable logs and conducted discussions with operators and others during early December 1980.The inspectors checked the oper-ability of selected emergency systems and verified proper return to service of affected components.

The inspectors observed portions of the mutliple restarts of Unit 2.The inspectors also observed the shutdown operations of Unit 1 in late December 1980.4.Monthl Surveillance Observation The inspector observed technical specifications required surveillance testing on the Pressurized Pressure Protection Set II (2 THP 4030 STP 112)and Steam Generator Water Level Protection Set III (2 THP 4030 STP 117)and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that limiting conditions for operation were met, that removal and restoration of the affected components were accomplished, that test results conformed with technical specifications and procedure re-quirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during the testing were pro-perly reviewed and resolved by appropriate management personnel.

The inspector also witnessed portions of the following test activities:

Procedure No.Title 2 THP 4030 STP 104 Overtemperture and Overpower Protection Set I.2 THP 4030 STP 118 Steam Generator Water I,evel Protection Set IV.12 THP 6030 IMP 142 Cardox System Surveillance.

5.Monthl Maintenance Observation Station maintenance activities of safety related systems and components listed below were observed/reviewed to ascertain that they were conducted in accordance with approved procedures,'egulatory guides and industry codes or standards and in conformance with technical specifications.

The following items were considered during this review: the limiting condi-tions for operation were met while components or systems were removed from service;approvals were obtained prior to initiating the work;activities were accomplished using approved procedures and were inspected as applicable;,functional testing and/or calibrations were performed prior to returning com-

~E ponents or systems to service;quality control records were maintained; act-ivities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and, fire prevention controls were implemented.

Work requests were reviewed to determine status of outstanding jobs and to assure that priority is assigned to safety related equipment maintenance which may affect system performance.

The following maintenance activities were observed/reviewed:

Procedure No.Title 2 THP 6030 IMP 229 12 MHP 4050 FDF 001 6.IE Bulletin Followu Source Range Nl Calibration on N-32.Receipt, Storage, and Preliminary Inspection of New Fuel Assembly Shipping Container.

For the IE Bulletins listed below the inspector verified that the written response was within the time period stated in the bulletin, that the written response included the information required to be reported, that the written response included adequate corrective, action commitments based on information presentation in the bulletin and the licensee's response, that licensee manage-ment forwarded copies of the written response to the appropriate onsite manage-ment representatives, that information discussed in the licensee's written response was accurate, and that corrective action taken by the licensee was as described in the written response.IEB No.80-21 Title Valve Yokes Supplied by Malcolm Foundry Company, Inc.80-23 Failures of Solenoid Valves Manu-factured by Valcor Engineering Corp.The inspectors are still following the licensee's re-evaluation of IEB 79-21"Temperature Effects on Level Measurements".

7.IE Circular Followu For the IE Circulars listed below, the inspector verified that the Circular was received by the licensee management, that a review for applicability was performed, and that if the circular were applicable to the facility, appropri-ate corrective actions were taken or were scheduled to be taken.4 4'V-~

IEC No.Title 79-17 Contact Problem in SB-12 Switches on G.E.Metalclad Ckt B.80-23 Potential Defects in Beloit Emergency Diesels.Also, IE Circular 79-05,"Moisture Leakage in Stranded Wire Conductors," has been closed out.It was noted that there have been similar occurrences when water leaked through a conduit and contaminated the turbine building sub-basement in July-1980.8.Licensee Event Re orts Followu Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomp-lished in accordance with technical specifications.

Unit 1 80-20/03L-0 Unit 2 79-26(Sup)/03x-1 80"25/03L-0 80-27/03L-0 LER 80-033/01-T-0 (Unit 2)During preparations for changing operational modes on December 4, 1980 Surveillance Test+-"02-OHP 4030 STP.007 was performed on the containment spray (CTS)system.This required valve aligments including closure of CTS-124E and CTS-128E on the discharge of the East CTS Heat Exchanger.

These valves were found to be closed during a tour of the Auxiliary Equipment Operator on December 14, 1980.The two valves were opened re-storing operability by 0700 on the 14th.Investigation revealed these valves had been shut on December 4, 1980 at about 1000 hours0.0116 days 0.278 hours 0.00165 weeks 3.805e-4 months to perform the surveillance test on East CTS Pump.The valves are shut to prevent inadvertent spray to the containment while test-ing the pump.After pump testing was complete, an Auxiliary Equipment Operator was assigned to restore the flow path to normal.CTS-124E and CTS-128E are required to be locked and sealed open in the flow path.The Auxiliary Equipment Operator locked and sealed CTS-124E and CTS"128K in the shut position, but initialled the Checkoff Sheet as having locked and sealed the two valves in the open position.Numerous mode changes (9)were made during the period of December 4-14 each of which constitutes a violation of Technical Specification (T.S.)3.0.4 which requires the system to be operable prior to entering the next.higher A~~

mode.Also, exceeded was the T.S.3.6.2.1 which allows one of the two CTS headers to be inoperable for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months before taking specified actions.This is an item of noncompliance violation category IV as specified in Appendix A.The inspector reviewed the licensee's corrective actions and determined them to be adequate to prevent further recurrence.

Additionally, Plant Manager Instruction, PMI-2110, had been revised by tem-porary sheet on December 9, 1980 to require independent verification of restoration of valve lineups on all ECCS equipment prior to declaring oper-able after maintenance or surveillance testing.Had this been in effect 1/on December 4, 1980, this event would have been much less likely to occur.-Following the plant trips on December 14, 1980 due to a malfunction in the Unit 2 main generator pilot exciter the inspector ascertained the status of the reactor and safety.systems by observation of control room indicators and discussions with licensee personnel concerning plant parameters, emergency system status and reactor coolant chemistry.

The inspector verified the establishment of proper communications and reviewed the corrective actions taken by the licensee.All systems responded as expected, and the plant was returned to operation on December 16, 1980.10.Inde endent Ins ection (a)Bomb Threat: A bomb threat was received by the licensee via a telephone.

The inspector observed the licensee's implementation of their security plan which included notification of local law enforcement agencies, coordination of plant wide search, communications during the event, and decision making.The threat was determined to be a hoax, no bomb was found.1980 of the Unit 2 Residual Heat Removal System Check Valves: RH-133, RH-134, SI-170 L2, SI-170 L3.The procedure used (12-THP-SP.003)

was reviewed with it's temporary changes TP-1 and TP-2.The inspector verified that calibrated equipment was used in performing the test.An effort was not made to quantify isolation valve leakage since the initial test met the acceptance criterion of~5 GPM total leakage.The test was performed at a primary system pressure of 400 psig.The results were as follows: 1/A managment enforcement meeting was held in the Region III offices on January 13, 1981 to discuss this event.Details of this meeting will be discussed in a seperate report.-6-Valve Desired Actual Rh"122 6 RH 134 SI-170 L2 SI-170 I3 All 4 2 GPM.10 observable 1 GPM 2.02 gpm 1 GPM 1.12 gpm 5 GPM 3.24 gpm Steam Generator Tube Wear: On November 4, 1980, the Resident Inspector was notified of visible damage to several inner-row tubes in a Unit 2 steam generator.

Eddy current testing was in progress to detect a minor tube leak on this steam generator, and when the secondary side hand holes were opened the tube lane blocking device was found loose.Four tubes were found to have 50$wastage and one tube with 20$wastage.These were adjacent to the tube lane blocking devices which had apparently been moving due to the flow.Subsequent checks of the Unit 1 steam generators in late December revealed similar wear in two steam generators.

The blocking devices were found properly secured indicating they had been loose during a previous operating period.All tubes with significant wear were plugged and the procedure revised to pervent further recurrence.

Salem Unit 1 has experienced similar wear in three of four steam generators and as a result plugged all of the tubes adjacent to the tube lane blocking devices.A draft IE Circular was submitted on this subject.Auxilia Feedwater S stems:, As tasked by the Safety Evaluation Report related to Amendment 42 to License No.DPR-58 and Amendment 24 to License No.DPR-74, the inspector reviewed various procedures and modi-fications affecting the Auxiliary Feedwater System as discussed below: Recommendation GS-4: Procedure OHP-4022.055.003 is the abnormal operating procedure titled"Loss of Condensate to Auxiliary Feedwater Pumps".The inspector determined that it adequately delineates the coordination and actions required to align Essential Service Water to supply the three Auxiliary Feedwater Pumps.Recommendation GS-5: OAP-4023.001.007 including Temporary Sheet No.1 was found to specify actions necessary for manual initiation of the Turbine Driven Auxiliary Feedwater Pump (TDAFP).The inspector also found that emergency lighting was installed in the TDAFP rooms and that emergency radios are available in the Shift Operating Engineer's office for use during AC power loss.Recommendation GS-6: Verification of valve alignment after testing and maintenance is required by Temporary Sheet No.8 to OHP-4030.STP.017 dated August 4, 1980.OHP-4021.001.002"Plant Startup from Hot Standby to Minimum Load" was reviewed and it was found that the procedure did not call for operating all auxiliary feedwater pumps.During the Unit 2 startup on December 7, 1980 the TSAFP was not used to provide water to any steam genertors, though it was otherwise demonstrated operable by the surveillance test.When the disparity between the licensee's December ll, 1979 letter and current operating procedures was pointed out to the licensee a Temporary Sheet was added to the procedure requiring the flow verification described in recommendation GS-6.Recommendation GL-4: The licensee's December 11, 1979 letter (AEP:NRC: trip on low suction pressure which will alarm in the control room.It states that"This modification will be made by'January 1, 1981." The associated design change RFC-12-2460 has not been completed as scheduled.

As a result of these discussions the licensee issued a letter, dated January 27, 1981, to H.Denton, indicating their intention to complete this modification by April 30, 1981.This is a deviation from a commitment and is a severity level VI viohtion as stated in Appendix A.16.Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)throughout the month of December 1980 and summarized the scope and findings of the inspection activities.

-8-0 R t MAy 20 i~el Docket No.50-315 Docket No.50"316 American Electric Power Service Corporation Indiana and Michigan Power Company ATTN: Mr.John E.Dolan Vice Chairman Engineering 2 Broadway New York, NY 10004 Gentlemen:

Thank you for your letter.dated April 28, 1981, supplementing your letter of February 23, 1981, relative to the steps you have taken to correct the noncompliance which we brought to your attention in Inspection Report Nos.50-315/80-20 and 50-316/80-16 forwarded by our letter dated January 23, 1981, and further discussed in our letter dated March 31, 1981.We will examine these matters during a subsequent inspection.

'Your cooperation with us is appreciated.

Sincerely, C.E.Norelius, Acting Director Division of Engineering and Technical Inspection cc: D.V.Shaller, Plant Manager cc w/ltr dtd 4/28/81: Central Files Reproduction Unit NRC 20b AEOD Resident Inspector, RIII PDR Iocal PDR NSIC TIC Ronald Callen, Michigan Public Service Coamission RIII RIII Sp ard RI o s RII Co on INDIANA II MICHIGAN ELECTRIC COMPANY P.O.BOX 18 BOWLIN G GR E EN STATION NEW YORK, N.Y.10004 April 28, 1981 AEP:NRC:0516A Donald C.Cook Nuclear Plant Unit Nos.1 and 2 Docket Nos.50-315 and 50-316 License Nos.DPR-58 and DPR-74Mr.James G.Keppler, Regional Director U.S.Nuclear Regulatory Commission Office of Inspection and Enforcement Region III Glen Ellyn, Illinois 60137 References:

(1)NRC IE Inspection Report Nos.50-315/80-20;

~50-316/80-16 dated January 23;1981 (2)Submittal No.AEP:NRC:0516 dated January 23, 1981

Dear Mr.Keppler:

This letter responds to your March 31;1981 letter which supplemented Appendix A of Inspection Report No.50-315/80-20 and 50-316/80-16 (Reference 2).Indiana&Michigan Electric Co.has established low and high limits for pumps tested as per ASME Section XI requirements.

These limits were established according to Table IWP-3100-2, sub-note 1 which allows the owner to establi'sh acceptable limits.If within the 96 hour0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months review period permitted in IWP-3220, a suction pressure is found outside these limits, the pump will be placed in the'ALERT'tatus and test frequency shall be doubled until the cause of the deviation is determined and corrected (ref.IWP-3230).

If within this same.time period, the suction pressure is found below the established

'allowable range', the pump status will be changed to'required action'.At this time the pump shall be declared inoperable and not returned to service until the condition has been corrected (ref.IWP-3230).

Nr.James G.Keppler AEP:NRC:0516A The limits were established as per IWP-3110 which'requires reference values to be at points of operation readily duplicated during subsequent in-service testing.Based on this, the normal expected range of pump running and not running suction pressures for all plant conditions was used to establish the reference low and high suction pressures for each pump.An instrument error of+2X of instrument range was then added as allowed by IWP-4110,'guality'.

The pressure measurement instruments range on each pump was verified not to exceed four times the reference values in accordance with IWP-4111,'Range'.The new suction pressure ranges and their required actions have been incorporated into plant procedure 12 THP 4030 STP.222,'SI Pump Test Program'.The ISI Pump Test Program is now consistent with the requirements of ASNE Section XI.Very truly yours,R.S.Hunter Vice President cc: R.C.Callen G.Charnoff John E.Dolan-.Columbus R.W.Jurgensen D.V.Shaller-Bridgman Region III Resident Inspector at Cook Plant-Bridgman

" March 31, 1981 Docket No.50-315 Docket No.50-316 American Electric Power Service Corporation Indiana and Michigan Power Company ATTN: Mr.John E.Dolan Vice Chairman Engineering 2 Broadway New York, NY 10004 Gentlemen:

This letter supplements our letter of March 12, 1981 regarding Inspection Report No.50-315/80-20aand 50-316/80-16 forwarded by our letter dated January 23, 1981.Hith regard to Item 1 of Appendix A of the subject letter we will examine this matter during a subsequent inspection.

Hith regard to your response to Item 2 of Appendix A, we feel that a mis-understanding has been created Qy a misstatement contained in Item 4.c.of the Details section of the inspection report.Specifically, the worII'accuracy'as inappropriately used, where the intended meaning was ,'Precision!'tem 4,c should have read as follows:....Reference values provide a basis for establishing acceptable instrument precisio'n not only to comply with ASIIE Section XI requirements, but to provide confidence in test data used to measure pump performance and estab-lish pump operability.

It was not our intent to challenge your ability to comply with paragraphs IHP 4110'guality'r IHP 4113'Calibration's addressed in your response.Paragraph IHP 4111'Range'tates,"The full scale range of each instrument shall be not greater than four times the reference value"...It is our position that compliance with paragraphs IHP 4110 and IHP 4111 together, assures a nominal precision with which pump inlet pressure is measured.The maximum range requirement of paragraph IHP 4111 is expressed in terms.of the reference value required to be established in accordance with paragraph IHP 3110.0~~lCal'SURNAME/OATE)3/27/81 RI I I, Pesch'el/cs RIII Hol zmeP'~.SI77I&(onnao n RI I!Bak RIII Heis an~~NRC FORM 3l8 I10i80)NRCM 0240 OFFICIAL RECORD COPY e USGPO.7980 329.9'

American Electric Power Service Corporation-2-March 31, 1981 The item of noncompliance was issued against the.-requirements of ASME Section XI, paragraph INP 3110 pursuant to 10 CFR 50.55a(g)and remains an item of noncompliance in the absence of specific written relief from these requirements granted by the NRC.Me request that you submit, within 25 days of this letter, a written'tatement or explanation in reply for this item of noncompliance including:

(1)corrective action taken and results achieved;(2)corrective action to be taken to avoid further noncompliance:

and'(3)the date when full comp-liance will be achieved.Your cooperation with us is appreciated.

Sincerely, R.F.Heishman, Acting Director Division of Resident and Project Inspection CC: Mr.D.V.Shaller, Plant Manager Central Files Reproduction Unit NRC 20b AEOD Resident Inspector, RIII PDR Local PDR NSIC TIC Ronald Callen, Michigan Public Service Commission

<gla REdd+P 0 Cy~c O I cA 0 1 o~+a*++UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 799 ROOSEVELT ROAD GLEN ELLYN, ILLINOIS 60137 January 23, 1981 Docket No.50-315 Docket No.50-316 American Electric Power Service Corporation Indiana and Michigan Power Company ATTN: Mr.John E.Dolan Vice Chairman Engineering 2 Broadway New York, NY 10004 Gentlemen:

This refers to the routine inspection conducted by K.R.Baker, J.M.Peschel, M.M.Holzmer, K.A.Connaughton of this office on November 17-21, 1980 and January 13, 1981, of activities at Donald C.Cook Nuclear Plant, Units 1 and 2 authorized by NRC Operations Licenses No.DPR-58 and No.DPR-74 and to the discussion of our findings with Mr.Shaller and others of your staff at the conclusion of the inspection.

The enclosed copy of our inspection report identifies areas examined during the inspection.

Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.

During this inspection, certain of your activities appeared to be in non-compliance with NRC requirements, as described in the enclosed Appendix A, and a written response is required.

A merican Electric Power Service Corporation-2-January 23, 1981 We will gladly discuss any questions you have concerning this inspection.

Sincerely, R.F.Heishman, Chief Reactor Operations and Nuclear Support Branch

Enclosures:

1.Appendix A, Notice of Violation 2.IE Inspection Reports No.50-315/80-20 and No.50-316/80-16

REGION III Reports No.50-315/80-20; 50-316/80-16 Docket Nos.50-315;50-316 Licenses No.DPR-58;DPR-74 Licensee: American Electric Power Service Corporation Indiana and Michigan Power Company 2 Broadway New York, NY 10004 Facility Name: D.C.Cook Nuclear Plant Units 1 6 2 Inspection At: D.C.Cook Site, Bridgman, MI Inspection Conducted:

November 17-21, 1980 and January 13, 1981 Inspectors:

.M.Peschel K.R.Baker~~~.~.A.Con aughton , xiii~<~M.M.&61zmer Approved By:..Baker, Chief, Nuclear Support Section 2 Ins ection Summar Ins ection on November 17-21 1980 and Janua 13 1981 (Re orts No.50-315/80-20.

'No.50-316/80-16)

Areas Ins ected: Maintenance procedures; maintenance activities; surveillance procedures; surveillance activities; ISI procedures and activities for pumps and valves;licensee event reports followup and plant tours.The inspection involved a total of 151 inspector-hours onsite by four NRC inspectors including zero inspector-hours offshifts.

Results: Of the seven areas inspected, two apparent items of noncompliance were identified; Inadequate pump run time during a surveillance (Paragraph 3B);and failure to establish reference values for pump inlet pressures for the ISI program (Paragraph 3C).

DETAILS 1.Personnel Contacted wD"R.R.'E 4J D.H.W..R.E.D.T.Shaller, Plant Manager Keith, Operations Superintendent Dudding, Maintenance Superintendent Smarella, Technical Superintendent Stietzel, QA Supervisor Campbell, Production Supervisor Bolinger, ISI Supervisor Golden, Performance Engineer Wagner, Performance Engineer Kant, Performance Engineering Supervisor Duncan, CSI Supervisor Svensson, Assistant Plant Manager Beilman, Senior QA Auditor The inspectors also contacted several other licensee employees, including operators, plant engineering and administrative personnel.

""Denotes those attending the exit interview.

2.Maintenance a~Maintenance Activities Maintenance activities of safety related systems and components listed below were observed/reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides and industry codes or standards and in conformance with Technical Specifications'he following items were considered during this review: The limitipg conditions for operation were met while components or systems were removed from service;approvals were obtained prior to initiating the work;activities were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibrations were performed prior to returning components or systems to service;quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and, fire prevention"controls were implemented.

The following maintenance activities were observed/reviewed:

Unit 1 Unit 1 J.O.63382 J.O.63529 BIT valve replacement West containment spray pump weld repair-2-Unit 1 Unit 1 Unit 1'.O.55989 J.O.63544 J.O.63366 Unit 1 Unit 1 Unit 1 J.O.59088 J.O.63554 J.O.12037 Unit.1 Unit 1 Unit 1 Unit 1 Unit 1 Unit 2 J.O.12023 J.O.63393 J.O.55205 J.O.63328 J.O.57377 J.O.25179 Unit 2 Unit 2 J.O.24096 J.O.20665 Unit 1 J.O.63795 IAB emergency diesel timing check West RHR pump cleaning East centrifugal charging pump seal rebuilding West motor driven auxiliary feed pump valve repair Incore flux mapping system drive motor repair Containment pressure indicator repair Wind speed and direction recorder repair 1-CD emergency diesel valve repair PORV motor repair RCP seal repair No.3 accumulator valve.repair MCC breaker replacement Pressurizer level control circuit repair Comparator and rate circuit repair Modification of ice condensor door frames The inspector noted several instances where Forms No.PMI 2290-1 and No.2290-3 were not fully completed.

The licensee's management agreed to take action to improve performance in this area.During a tour it was noted the Unit 1 pressurizer power operated relief valve, NRV-151, was,closed.

The PORV's had recently undergone tests by the operations department to determine which valves were leaking.A job order had not yet been issued for this valve.The licensee agreed to insure a job order was issued for this valve.No items of noncompliance were identified.

b.Preventive Maintenance The preventive maintenance system was reviewed to determine if it was current for safety related components.

The inspector observed that attachment 30 of the preventive maintenance system, Plant Winterizing, had not been completed in October as required by the system.The licensee stated that much of the work has been completed and stated that the remainder would be completed in a timely manner.The preventive maintenance system at present does not have a central status system, and many procedures have hand written changes and additions.

The system is in the process of being reorganized with a new control system.The licensee has begun

a typing and the review/approval process to allow the new system to be implemented in a timely manner.No'items of noncompliance were identified.

c.Facility Procedures The facility maintenance procedures listed below were reviewed to verify that they were adequate and consistent with Technical Specifications.

1.Maintenance Procedures 12 MHP 5021.002.003 12 MHP 5021.003'01 12 MHP 5021.009.001 12 MHP 5021.032.001L MHP 5021.032.001K 2.Preventive Maintenance Procedures Attachment 10 Attachment 26 No items of noncompliance were identified.

3.Surveillance

~~a.Procedures The inspector reviewed several surveillance tests selected from the Technical Specifications to ensure that the tests were covered by properly approved procedures; that these procedures contained adequate preparation or prerequisites, included acceptance criteria, and provided for system restoration following testing.The following procedures examined: OHP.4030.STP.004 OHP.4030.STP.005 OHP.4030.STP.030 THP.4030.THP.352 OHP.4030.STP.007 THP.4030.STP.205 THP.4030.STP.216 OHP.4030~STP.013 OHP.4030.STP.020 Athough acceptance criteria were specified in a section of each procedure, there were some instances in which acceptance criteria sections could have been more complete.An example is the 15 minute minimum pump run time required by the monthly surveillance on the Unit 1 centrifugal charging pumps as specified in Technical Specification 4.1.2.3.c.

Acceptance criteria for pump run 4 times are not listed in the surveillance procedure, although start and stop time are recorded.Other Unit 1 pumps require the 15 minute minimum run during the monthly surveillances.

No items of noncompliance were identified.

b.Completed Surveillances Completed surveillances were reviewed for Unit 1 to verify that surveillances were performed within the required periodicity and that the results were within the Technical Specifications.

A check for completeness of surveillance records was also made.Unit 1 Technical Specification 4.1.2.3.c requires that the centrifugal charging pumps (CCP)be run for a minimum of 15 minutes during the monthly surveillance.

Contrary to the above requirement, the Unit 1 West CCP was run for only five minutes during the monthly surveillance OHP.4030.STP.004 conducted on June 16;1980.Inclusion of the 15 minute acceptance criteria in this and other test procedures, as discussed in Paragraph A (Procedures)

above, would have possibly prevented this noncompliance.

The inspector emphasized the value of a review of all test procedures for which this criterion is applicable.

This is an item of noncompliance identified in Appendix A (50"315/80"20"01).

Records of completed surveillance tests are required to be maintained by Technical Specification 6.10.1.d.The licensee was unable to produce for review the following of completed Unit 1 surveillances.

Surveillance Test Sheet No.Date(s)~Com anent OHP.4030.STP.030 6.7 OHP.4030.STP.030 6.7 OHP.4030.STP.030 6.5 OHP.4030.STP.030 6.5 OHP.4030.STP.030 6.5 OHP.4030.STP.013 6.1 OHP.4030.STP.020 6.2 OHP.4030.STP.020 6.2 OHP.4030.STP.004/005 All January 1-24, 1980 June 1, 1980 June 3,4,5,15, 1980 May 2, 1980 April 14,29,30, 1980 January 31, 1980 February, 1980 May, 1980 July, 1980 N/A N/A N/A N/A N/A No.1 H2 Recombiner East Train West Train Both Pumps The licensee has agreed to locate these records'his is con-sidered an unresolved item pending the licensee locating these records (50-315/80-20-01).

-5-

c~ISI Operatility Testing Program" Pumps The inspector reviewed the licensee's pump testing program to verify compliance with the requirements of 10 CFR 50.55a(g).

Pump test records revealed that tests had been conducted on all applicable pumps at the required frequencies with properly approved procedures.

Test methods were found to be satisfactory.

The licensee has not established reference values for pump inlet pressure as required by ASME Section XI Article IWP-3110.Reference values provide a basis for establishing acceptable instrument accuracy not only to comply with the ASME Section XI requirements, but to provide confidence in test data used to measure pump performance and establish pump operabil'ity.

This is an item of noncompliance identified in Appendix A (50-315/80-20-02)

and (50-316/80-16-01).

d.ISI Operability Testing Program-Valves The inspector reviewed the licensee's valve testing program to verify compliance with the requirements of 10 CFR 50.55a(g).

Examination of the licensee's approved ISI valve test program, status summaries and several test procedures revealed that the licensee has performed tests at the required frequencies against appropriate acceptance criteria.The licensee is currently in the process of revising the test program.The revised program's requirements will be reflected in the program status summary which, according to the licensee, will be updated biweekly.No items of noncompliance were identified.

4.Licensee Event Re ort Followu a~(Closed)Unit 1 Licensee Event Report (LER)80-15/03L-0 dated July 29, 1980 was reviewed.This report stated that while in Mode 6 the train"B" centrifugal charging pump failed, due to a broken shaft, while the train"A" diesel was out of service.Core alterations were halted and the train"A" diesel was placed in service.The train"B" charging-pump was subsequently repaired using a"new" design shaft.The failed shaft problem has been a recurring problem with the"old" design shaft.All pumps now in operation are using the"new" design shaft.No further problems are anticipated.

This item is considered closed.No items of noncompliance were identified.

b.(Closed)Unit 2 Licensee Event Report (LER)80-26/03I,-O were re-viewed.Two check valves (R-156 and R-157)were recently determined by the licensee to be containment isolation valves.This LER was,, submitted to satisfy reporting requirements concerning previous-6-

events involving the valves.The valves were not included in the type C leak test prior to November 1978.Check valve R156 had been installed backward.On November 18, 1978, check valve R156 was removed and reinstalled correctly.

Both valves success-fully passed the type C'leak test and were included in the applicable surveillance test procedure.

The inspector verified implementation of these corrective actions.This item is considered closed.No items of noncompliance were identified.

c~(Closed)Unit 1 Licensee Event Report (LER)80-25/03L-0 was reviewed.On September 29, 1980, a glycol isolation valve was determined inoperable upon failure to fully close during containment isolation valve testing.The valve was exercised until it functioned correctly.

Corrective action by the licensee consisted of increasing surveillance test frequency from quarterly to monthly.The inspector learned that the valve failed the first monthly surveillance performed on November 13, 1980.The licensee was informed that increased surveillance testing as a proposed corrective action in the forthcoming LER would be considered inadequate and that cause identification and a timely fix should be addressed.

No items of noncompliance were identified.

d.(Open)Unit 2 Licensee Event Report (LER)80-32/03L-0 was reviewed.This LER stated that on September 4, 1980 during a surveillance test to return the=East RHR pump to service after maintenance the pump was unstable and declared inoperable.

This was stated to be the first event of this type.The licensee stated that the test procedure did not provide for removing all air in the system during fill and vent and that the procedure was changed to correct this.The inspector reviewed the following records associated with the event: (1)Unit 2 Control Room Log July 1", 1980 to September 4, 1980 (2)Clearance Permit Log July 20 to September 4, 1980 (3)Monthly Opera)j,ng Reports for September, August and July, 1980.-(4)Condition Report-C/R No.2-8-80-237 (5)Condition Report-C/R No.2-9-80-254 (6)Job Order Number 00354 (7)Job Order Number 24250 (8)1-0HP.4030.STP.005 Revision 8 dated April 2, 1980 with ten temporary sheets (9)2-0HP.4030.STP.005 Revision 3 dated June 19, 1979 with 17 temporary sheets 1/Letters D.V.Shaller to Director, OMI and PC USNRC dated October 14, September 12, and Augu'st 6, 1980.

(10)2-0HP.4021.008.001 Filling and Venting of Emergency Core Cooling System Revision 1 dated April 18, 1978 (ll)SOE Log July 23 to September 4, 1980 (12)Operations Department DIR dated October 20 transmitting completed STP's to vault.The report was found to be incorrect and inaccurate in the areas as listed below: (a)The surveillance test was conducted as a routine monthly test (2-0HP.4030.STP.005), not a test performed to return the East RHR pump to service.Clearance Permit logs and the logs show that the last time the system had been removed from service was July 23, 1980 at 1855 hours0.0215 days 0.515 hours 0.00307 weeks 7.058275e-4 months for work on IRV-310.The system was logged as being returned to service on July 24, 1980.(b)The problem had been observed on August 4, 1980 while performing routine surveillance test 2-0HP.4030.STP.005.

Log entries on August 4, 1980 show the pump was started at 0359 hours0.00416 days 0.0997 hours 5.935847e-4 weeks 1.365995e-4 months and stopped at 0401 hours0.00464 days 0.111 hours 6.630291e-4 weeks 1.525805e-4 months due to poor suction pressure.At 0425 hours0.00492 days 0.118 hours 7.027116e-4 weeks 1.617125e-4 months the pump was started after venting.At 0428 it was stopped again because of poor suction.At 0540 the pump was again started after venting.It was run until 0643 hours0.00744 days 0.179 hours 0.00106 weeks 2.446615e-4 months .A condition report (2-8-80-237)

was initiated.

The licensee classified the event as not re-quiring a LER.The originator of the condition report con-ducted the investigation.

The investigation was essentially a rehash of the event with the following statement,"I do not have any explanation for the air in the system." PSNRC review accepted this.This condition report appears to have received a superficial investigation and review.A review of the operating and maintenance history would have revealed that the maintenance on July 23, 1980 had been the source of the air.The decision that the event was not reportable at that time was very questionable and in retrospect represents noncompliance with Technical Specification 6.9;1.8 reporting requirements.(c)Records show that the last maintenance performed on the East RHR train prior to the event was July 23, 1980.Valves IRV-310 and RH 128E had packing leaks repaired (Job Orders 00354 and 24250).The East RHR train was removed from service on July 23, 1980 at 1855 hours0.0215 days 0.515 hours 0.00307 weeks 7.058275e-4 months and returned to service on 1035 hours0.012 days 0.288 hours 0.00171 weeks 3.938175e-4 months on July 24, 1980.The logs do not show that the East RHR pump was operated to verify operability nor could"8-a completed surveillance test be found that indicated the train was tested.The Clearance Permit 22056 under which the repairs had been made has been destroyed (allowable under the licensee's administrative procedure).

Discussions with the personnel who developed the clearance indicate that the.East RHR pump was not tagged out, only the heat exchanger and associated valves.It is not clear at this time if the heat exchanger was drained to facilitate the repairs or if the fluid drained out of the heat exchanger during the repairs.In any case it does not appear that any operability test of the pump was conducted following the return to service.The licensee has a procedure for filling and venting, 2-0HP.4021.008.001.

No completed sign off for this procedure could be found.A review of the procedure indicates it would have been usable for filling and venting with changes to the initial conditions.

It is not clear that changes to the surveillance pro-cedure 2-0HP.4030STP.005 will prevent the event from happening again as the procedure was not used to return the system to operation.

The real problem appears to be lack of an effective policy on the return to service of safety related equipment that include an evaluation of the method of removal from service, maintenance performed, procedures used and what procedures are to be used during the return to service and that equipment be test operated.The air introduced into the East RHR train degraded the performance

'f that train such that it could not be relied upon to fulfill the LCO with respect to a large break loss of coolant accident and insure continued operation of the East RHR pump during small break loss of coolant accident.In the case of the large LOCA the air induced into the RHR pump suction by the miniflow line from the heat exchanger outlet would produce a reduction in head developed by the pump, as observed by the licensee on August 4 and September 4, 1980.This would delay injection by this RHR pump as reactor coolant system pressure would need to decay further than that assumed in the accident analysis before injection occurred.Also the entrained air in the injection water would reduce the injection flow rate until flushed into the Reactor Coolant System.In case of a small break LOCA the RHR pump would be required to operate for a period of time on miniflow.This is the same mode of operation that the pump is tested under during the monthly surveillance test.During the August and September tests the operators intervened and stopped the pump when the pressures and, currents were erratic,

indicating cavitation and abnormal pump performance.

Given these indications they would have probably also stopped the pump in the event of a LOCA to prevent damage to the pump.Hence, it would have been unavailable until the operator had time to investigate the cause of the erratic performance.

The following caution notes from the RHR pump technical manual are quoted to show the manufactures concern regarding operation of the pump with air in the system.CAUTION"BEFORE STARTING OR WHILE OPERATING THE PUMP THE CASING AND SUCTION LINE MUST BE COMPLETELY FILLED WITH THE IIQUID BEING PUMPED.THE ROTATING PARTS DEPEND ON THIS LIQUID FOR LUBRICATION AND THE PUMP MAY SEIZE IF OPERATED WITHOUT LIQUID.THE CASING AND SUCTION LINE MUST BE FILLED WITH LIQUID DURING STARTING, OPERATION AND SHUTDOWN PERIODS." CAUTION NEVER OPERATE THE RESIDUAL HEAT REMOVAI PUMPS WITHOUT PUMP/SYSTEMS BEING COMPELTELY PRIMED.2.3.4.~~~~~~~~WHEN OPERATING FOR SOME TIME AT REDUCED CAPACITY, MUCH OF THE PUMP HORSEPOWER WILL GO INTO THE LIQUID IN THE FORM OF HEAT.A BY"PASS MUST BE PROVIDED UNDER THESE CONDITIONS TO PREVENT THE LIQUID FROM BECOMING HOT ENOUGH IN THE PUMP TO VAPORIZE.FOR CONTINUOUS PUMP OPERATION, THE MINIMUM FLOW FOR SAFE OPERATION OF THIS PUMP IS 500 GPM." The function of the East RHR train could have been significantly degraded during this time period as described above but it still may have provided a portion of its design capability for accident mitigation.

The Technical Specification Limiting Conditions for Operations implicitly require the equipment be at full-capacity and reliability.

This was not the case with the East RHR train between July 23, 1980 and September 4, 1980.On January 13, 1981 a meeting was held in the Region III office to discuss this event with the licensee.Attending for the licensee were: J.'Dolan, Vice Chairman Engineer R.Hunter, Executive Vice President for Construction and Nuclear Engineering B.Svensson, Assistant Plant Manager R.Keith, Operations Superintendent A.Grimes, Chief Mechanical Engineer S.Milioti, Assistant Division Head Nuclear Engineering Region III personnel attending were: J.Keppler,-Regional Director R.Heishman, Chief, Reactor Operations and Nuclear Support Branch A.Davis, Deputy Director 10-

/

C.Norelius, Regional Enforcement Coordinator D.Boyd, Section Chief, Projects Section 4 K.Baker, Section Chief, Nuclear Support Section 2 E.Swanson, Senior Resident Inspector The licensee outlined the results of his review.The licensee believes that the quarterly portion of the surveillance test introduces the air into the systems.The licensee:is investigating this and other possible causes.The licensee stated the problem had occured again during the January 4, 1981 test.The licensee stated that the test frequency would be increased to weekly until the source of the air was identified.

In addition he would analyze the effects of the air on system performance during large and small loss of coolant accidents.

This matter is considered unresolved pending completion of the licensee's review and subsequent review of these results by Region III.5.Tours The inspectors toured various portions of the facility to observe activities in progress.The inspector noted that fire doors on the north end of the Auxiliary feed water pump area were wired and blocked open.These doors are U.L.three hour rated doors.This is considered an unresolved item pending review of the licensee's fire hazard analysis and NRR's SER.(50 315/80 20 02)(50-316/80-16-01)

6~Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are addeptable items, items of noncompliance or deviations.

Unresolved items during this inspection are discussed in Paragraphs 3, 4 and 5.7.Exit Interview The inspectors met with licensee representatives

{denoted in Para-graph 1)at the conclusion of the inspection on November 21, 1980.The inspectors summarized the purpose, scope and findings of the inspection.

"11-s~~mfa'l as February 19, 1981 Docket No.50-315 Docket No.50-316 American Electric Power Service Corporation Indiana and Michigan Power Company ATTN: Mr.John E.Dolan Vice Chairman Engineering 2 Broadway New York, NY 10004 lE RLE COPY Gentlemem:

We will examine these matters during a s Your cooperation with us is appreciated.

Thank you for your letter dated January 28, 1981, informing us of the steps you have taken to correct the noncompliance which we brought to your attention in Inspection Report No.50-315/80-19 and No.50-316/80-15 fowarded by our letter dated January 6, 1981;Extension January 15,'981.ubsequent inspection.

Sincerely, R.F.Heishman, Chief Reactor Operations and Nuclear Support Branchcc w/ltr dtd 1/28/81: D.V.Shaller, Plant Manager Central Files Reproduction Unit NRC 20b AEOD Resident Inspector, RIII PDR Local PDR NSIC TIC Ronald Callen, Michigan Public Service Commi sion'/'III'~RIII Bwanson/jp Boyd 2/12/81 RII H hman 815

(NDIANA g MICHIGAN ELECTRIC COMPANY P.O.BOX 18 BOWLIHG GREEH STATIOH HEW YORK, H.Y.10004 January 28, 1981 AEP:NRC:00511 Donald C.Cook Nuclear Plant Unit Nos.1 and 2 Docket Nos.50-315 and-50-316 License Nos.DPR-58 andDPR-74 IE Inspection Report Nos.50-315/80-19 and 50-316/80-15 Mr.James G.Keppler, Regional Director U.S.Nuclear Regulatory Commission Office of Inspection and Enforcement Region III Glen Ellyn, Illinois 60137

Dear Mr.Keppler:

The attachment to this letter provides our response to the Notice of Violation contained in Appendix A of IE Inspection Report Nos.50-315/80-19 and 50-316/80-15 which we received on January 6, 1981.On January 15, 1981 Mr.Heishman of your Staff granted our request'for an extension to respond to the Notice of Violation within 25 days from the date on which we received the inspection report.Very truly yours, CC: R.C.Callen ohn E.Dolan ice President G.Charnoff R.S.Hunter R.W.Jurgensen D.V.Shaller-Bridgman Region III Resident Inspector at Cook Plant-Br idgman STATE OF NEW YORK COUNTY OF NEW YORK John E.Dolan, being duly sworn, deposes and says that he is the Vice President of Licensee Indiana 8 Michigan Electric Company, that he has read the foregoing response to the notice of violation contained in IE Inspection Report Nos.50-315/80-19 and 50-316/80-15 and knows the contents thereof;and that said contents are true to the best of his knowledge and belief.Subscribed and sworn to before me this 8 day of U~ev'8)QPiFV."PiY fA.CVPilCAlf No)AY Fog",,'.o cf fry'fir Yoifr Vo.3:-1..13'31 Qoslif,cd m tlc,s Yo:fr Couofff Commfssion Explrcs 1 forclr 30, 19.4k

ATTACHMENT TO AEP:NRC;0511 In accordance with the requirements of the notice subject of this response we provide the following information:

a)The reason for the items of noncompliance is that during the period of time that this inspection was conducted we were implementing design changes in the Cook Plant which required pulling cables through penetration fire seals in the cable vault.It was during the implementation ,of these changes that the two of them were made non-functional thereby exceeding the limiting condition of operation of Technical Specification 3/4.7.10.b)The corrective steps taken were to immediately repair the penetration fire seals by either the plant approved temporary repair mechanism or repaired permanently utilizing the plant approved repair procedure.

They were subsequently inspected and accepted on December 4, 1980, by the Plant gC Department..

c)To preclude further items of n'on-compliance, a memo from the Cook Plant Construction Department was trans-mitted on December 8, 1980 to all contractors reiterating the Donald C.Cook Nuclear Plant's requirements on pene-tration fire seals.In addition Plant Manager Instruction PMI-2270, entitled"Fire Protection and Safety Equipment", was revised by a temporary change sheet which amplifies the requirements and the responsibilities for those people who have the potential for breaching or coming across a fire seal within the plant that has been breached.Full compliance was achieved by the issuance of these documents.

l~E Docket No.50-315 Docket No.50-316 American Electric Power Service Corporation Indiana and Michigan Power Company ATTN: Mr.John E.Dolan Vice Chairman Engineering 2 Broadway New York, NY 10004 Gentlemen:

This refers to the inspection conducted by Messrs.E.R.Swanson and N.E.DuBry of this office on November 1-30, 1980, of activities at D.C.Cook Nuclear Plant Units 1 and 2 authorized by NRC Operating License No.DPR-58 and No.DPR-74 and to the discussion of our findings with Mr.Shaller'at the conclusion of the inspection.

The enclosed copy of our inspection report identifies areas examined during the inspection.

Within these areas, the inspection consisted of a selective examination of procedures and repres'entative records, observations, and interviews with personnel.

During this inspection, certain of your activities appeared to be in noncompliance with NRC requirements, as described in the enclosed Appendix A, and a written response is required.In accordance with Section 2.790 of the NRC's"Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter, the enclosures, and your response to this letter will be'laced in the NRC's Public Document Room, except as follows.If the enclosures contain information that you or your contractors believe to be proprietary, you must apply in writing to this office, within twenty-five days of the date of this letter, to withhold such information from public disclosure.

The application must include, a full statement of the reasons for which the information is considered proprietary, and should be prepared so that proprietary information identified in the application is contained in'n enclosure to the application.

.

American Electric Power Service Corporation 2-We will gladly discuss any questions you have concerning this inspection.

Sincerely,

Enclosures:

1.Appendix A, Notice of Violation 2.IE Inspection Report No.50-315/80-19 and No.50-316/80-15 R.F.Heishman, Chief Reactor Operations and Nuclear Support Branch

REGION III Reports No.50-315/80-19; 50-316/80-15 Docket Nos.50-315;50-316 Licenses No.DPR-58;DPR-74 Licensee: American Electric Power Service Corporation Indiana and Michigan Power Company 2 Broadway New York, NY 10004 Facility Name: D.C.Cook Nuclear Power Plant, Units 1 and 2 Inspection At: D.C.Cook Site, Bridgman, MI Inspection Conducted:

November 1-31, 1980 Inspectors:

E.R.Swanson Approved By: D.C.Boyd, Chief, Projects Section 4/Z-Z3-8'ns ection Summa Ins ection on November 1-30 1980 (Re orts No.50-315/80-19 50-316/80-15)

Areas Ins ected: Routine, onsite regular and backshift inspection by the resident inspector.

Areas inspected included operational safety verification, inspection during long term shutdown, maintenance observations, surveillance observation, new fuel receipt, accessible portions of Unit 1 and Unit 2 facilities, followup on previously identified items, and independent inspection.

The inspection involved a total of 126 inspector-hours onsite by two NRC in-spectors including 56 inspector-hours off-shifts.

Results: Of the seven areas inspected, no items of noncompliance or deviations were identified in six areas.One item of noncompliance was identified in one area (violation, level IV-failure to establish fire watch-paragraph 8).

DETAILS 1.Persons Contacted-D.Shaller, Plant Manager-B.Svenson, Assistant Plant Manager"-E.Townley, Assistant Plant Manager;R.Keith, Operations Superintendent

""E.Smarella, Technical Superintendent R.Dudding, Maintenance Superintendent D.Duncan, CSI Supervisor

""J.Stietzel, gA Supervisor D.Palmer, Radiation Protection Supervisor The inspectors also contacted a number of operators, technicians, and maintenance personnel including somecontact workers.':Denotes those present at the exit interview.

2.Follow u On Previous Ins ection Findin s (Closed)Noncompliance (315/80-02, 316/80-02):

Review of standing orders not done.The inspector interviewed operators, reviewed records and discussed corrective action taken with licensee management.

As delineated in the March 12, 1980 response.There were some minor record keeping errors.The inspector considers the corrective action taken adequate to preclude further noncompliance in this area.3.0 erational Safet Verification The inspector observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the month of November 1980.The inspector verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected components.

Tours of auxiliary buildings and turbine buildings were conducted to observe plant equip-ment.conditions, including potential fire hazards, fluid leaks, and excessive vibrations and to verify that maintenance requests had been initiated for equipment in need of.maintenance.

The inspector by observation and direct interview verified that the physical security plan was being implemented in accordance with the station security plan.The inspector observed plant housekeeping/cleanliness conditions and verified implementation of radiation protection controls.During the month of November, 1980, the inspector walked down the accessible por-tions of the Unit 2 intermediate head safety inspection systems to verify operability.

The inspector also witnessed portions of the radio-active waste system controls associated with radwaste shipments and barreling.

"2-These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under technical specifications, 10 CFR, and administrative procedures.

Ins ection Durin Lon Term Shutdown Following the Unit 2 shutdown the inspectors have observed the shutdown control room operations, reviewed applicable logs, and conducted discussions with control room operators and others during the month of November 1980.The inspectors verified the operability of selected emergency systems and verified proper return to service of affected components.

Tours of the Unit 2 containment, the fuel handling areas, the auxiliary building and the turbine building were made to observe plant equipment conditions, in-cluding potential fire hazards, fluid leaks, and that maintenance requests had been initiated for equipment in need of maintenance.

The inspectors witnessed work in progress on the Reactor Coolant Pump Oil Spill Guard verification.

By observation and direct interview the inspector verified that the physical security plan was being implemented in accordance with the station security plan.Monthl Surveillance Observation The inspector observed technical specifications required surveillance testing on the.con'tainment air radio gas monitor (2 THP 4030 STP 153), containment air particulate process monitor (2 THP 4030 STP 152)and con-tainment area monitor at the personnel lock (2 THP 4030 STP 155)and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that limiting conditions.

for operation were met, that removal and restoration of the affected components were accomplished, that test results conformed with technical specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personnel.

The inspector also witnessed portions of the following test activ-ities: Procedure No.120 HP 4030 STP 016 20 HP 4021.032.001 12 THP 6030I MP142 1 THP 4030 STP.027 Title RCS Leak Test Starting, Parelleling, and Loading the Emergency Diesel Cardox System Surveillance Power Range Nuclear Instrument Protection Set I.Review of Plant 0 erations During the month of November 1980 the inspector reviewed the following activities:

Review and Audits On November 25, 1980, the inspector sat in on a safety review committee meeting.The inspector verified that provisions of technical specifications dealing with membership, review process, frequency, and qualifications were met.The inspector also verified that decisions made were reflected in the meeting minutes and that corrective actions proposed were taken.On November 25, 1980, the inspector witnessed an audit conducted by the licensee's offsite audit team and verified conformance with technical specifications and gA procedures.

T~aainin The inspector attended two of the licensee's operator requalification lecture series and verified that lesson plan objectives were met and that training was in accordance with the approved operator requalifi-cation program schedule and objectives.

The inspector verified by direct questioning of one new, one existing, and one temporary employee that administrative controls and procedures, radiological health and safety, industrial safety, controlled access and security procedures, emergency plan, and quality assurance training were provided as required by the licensee's technical specifications; verified by direct questioning of one craftsmen and one technician that on-the-job training, formal technical training commensurate with job classification, and fire fighting training were provided.C.Emer enc Pre aredness The inspector observed and verified that the emergency equipment, facilities and systems described in the emergency plant are in place and operable.It was noted that the major revision to the Emergency Plan is not yet approved for us by the NRC.The inspectors verified that systems and equipment to be used for monitoring release of radioactivity are operable as described in the Plan and as required by the Technical Specifications.

It was noted that at one time two of three secondary side monitors were out of service..A drill was held to exercise the coodination between the local hospital, ambulance service and the plant staff in the handling of a contaminated, injured person.The inspectors also witnessed the annual'ite emergency drill on November 25, and attended the critique following the drill.7.Monthl Maintenance Observation Station maintenance activities of safety related systems and components listed below were observed/reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides and industry codes or standards and in conformance wi.th technical specifications.

The following items were considered during this review: the limiting conditions for operation were met while components or systems were removed from service;approvals were obtained prior to initiating the work;activi-ties were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibrations were performed prior to returning components or systems to service;quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were imple-mented;and, fire prevention controls were implemented.

Work requests were reviewed to determine status of outstanding jobs and to assure that priority is assigned to safety related equipment maintenance which may affect system performance.

The following maintenance activities were observed/reviewed:

Procedure No.Title 12 MHP 4050 FDF.001 Receipt, Storage, and Preliminary Inspection of New Fuel Assembly Shipping Containers 12 MPH 4040 FDF.002 Unloading of New Fuel Assemblies From Shipping Containers 12 MPH 4050 FDF.011 Auxiliary Building Crane Operating Instructions 12 THP 6010 RAD 601 12 PMP 4040 SNM.001 Receipt of Radioactive Material SNM Accountability Mannal for the D.C.Cook Plant 12 MHP 4050 FDF.005 12 MPH 4050 FDF.006 12 MHP-SP-RFC-2483 1 THP 6010 Rad 594 1 THP 6010 IMP.012 Inspection of New Fuel Assemblies Storage of New Fuel Assemblies Reactor Coolant Pump Motor Modification RMS Radiogas Cap Source Calibration RMS (Six Trgud-Gas)

Calibration Following completion of maintenance on the Radiation Monitoring System, the, inspector verified the systems had been returned to service properly.The reator collant pump modification was not complete during the period of the report and they had not been returned to service.8.Inde endent Ins ection During the inspection period a significant number of penetration fire barriers were repaired utilizing 12 MHP 5021.021 Revision 1.While-5-A'

inspecting the outgoing work on November 24, the inspector noted a non-functional fire barrier between the control room and the cable vault which was being reparied, but with no one around.Technical Specification 3.7.10 requires a continuous fire watch to be established within one hour of the barrier becoming non-functional.

The operators were also unaware of the opening and had a fire been detected in the cable vault and the CO system initiated, the control room would have been made uninhabitable.

Further discussions with the contractor and plant personnel revealed that 2 these is no direction available to them as to what a fire watch is, or what his responsibilities and duties are.The lack of a fire watch is an item of noncompliance, violation category IV.The question of what a fire watch is and his duties is an unresolved item.While further inspecting the cable vault, penetration W-5095 was also discovered to be non-functional as the inspector could see thru the wall to the Turbine Building.This condition existed for several days and the hole was labeled with tape indicating that it was not to be sealed.This item supports the above noncompliance.

In their response to a similar item'of noncompliance (50-3j.5/78-09), the licensee stated that a fire detection system is an adequate substitute for a fire watch though the Technical Specification does not make allowance for this.The inspector also stated that the non-functional barrier might render the CO and Halon suppression systems inoperable by not being able to adequately contain the gas and provide the neccessary pressure and concentration.

2 9.Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)throughout the month and at the conclusion of the inspection on November 26, 1980, and summarized the scope and findings of the inspection activities.

The licensee acknowledged comments made concerning fire barriers as detailed in paragraph 8.

February 5, 1981~Docket No.50-315 Docket No.50-316 American Electric Power Service Cdrporation Indiana and Michigan Power Company ATTN: Mr.John E.Dolan Vice Chairman Engineering 2 Broadway New York, NY 10004 Gentlemen:

Thank you for your letter dated January 23, 1981, informing us of the steps you have taken to correct the noncompliance identified in our letter dated January 2, 1981, Inspection Reports No.50"315/80-15 and No.50-316/80-14.

We will examine your corrective action during a future znspectxon.

Your cooperation with us is appreciated.

Sincerely, R.F.Heishman, Chief Reactor Operations and Nuclear Support Branch cc: D.V.Shaller, Plant Manager i, cc w/ltr dtd 1/23/81: Central Files Reproduction Unit NRC 20b AEOD Resident Inspecto'r, RIII PDR Local PDR NSIC TIC Ronald Callen, Michigan Public Service Commission RIII RII Boy/so Heis an 2/3/81

z/Aging (lNDIANA 5 MICHIGAN ELECTRIC COMPANY P.O.SOX 1B BOWLING GREEN STATION HEW YORK, H.Y.10004 January 23, 1981 AEP:NRC:00512 Donald C.Cook Nuclear Plant Unit Nos.1 and 2 Docket Nos.50-315 and 50-316 License Nos.DPR-58 and DPR-74 IE Inspection Report Nos.50-315/80-15; 50-316/80-14 Mr.James G.Keppler, Regional Director U.S.Nuclear Regulatory Comssion Office of Inspection and Enforcement Region III Glen Ellyn, Illinois 60137

Dear Mr.Keppler:

Th1s letter is our response to the Notice of Violation attached as Appendix'A'o Mr.R.F.Heishman's letter of January 2, 1981.In accord-ance with Appendix'A'o Mr.Heishman's letter this response is being submitted under oath and affirmation.

On July 28, 1980, while Unit No.2 was operating in Mode 1, the nitrogen cover pressure on one of the four accumulator tanks exceeded the upper limit of 644 psig specified in Technical Specification 3.5.1.d.for approximately ten minutes.The maximum pressure experienced was 650 psig.This event was in fact the result of the failure of the high/low pressure alarm to clear during operator action to increase cover gas pressure.The transient nature of this event and the magnitude of the pressure excursion{+6 psi)coupled with the normal accuracy of the pressure monitor (+14 psi)and the apparent lack of adverse safety significance led to the Plant Staff's request that personnel from American Electric Power Service Corporation (AEPSC)investigate the reportability of the event.The results of the AEPSC review indicated that there was no reasonable adverse safety implications associated with the subject event.It was recognized that the apparent nitrogen over pressure did constitute entry into the'Action Statement'f Specification 3.5.l.d., however, the reviewers felt that the reporting criteria of Specification 6.9.1.9.b,"...operation yg~N 28 f9'

Nr.James G.Keppler AEP:NRC:00512 in a degraded mode...", had not been fulfilled as the apparent cover gas overpressure did not impair the ability of the affected accumulator fo perform its safety function.The AEPSC response to the Plant Staff's request failed to provide clear guidance as to the reportability of the subject event.Effective corrective action by the operator(s)

returned the accumulator cover gas pressure to within the limits of Specification 3.5.1.d.in ap-proximately ten minutes;well within the time period of one hour allowed by the'Action Statement'f the Specification.

The reportability of this event has been discussed with those members of the AEPSC staff involved with the aforementioned review.Particular emphasis was placed on the need for the AEPSC office to provide clear and concise guidance to the Plant Staff in matters such as the one discussed herein.These actions should be sufficient to prevent reoccurrence of similar events.Very truly yours, onter Vice President cc: John E.Dolan R.C.Callen G.Charnoff R.M.Jurgensen 0.V.Shaller Region III Site Inspector O.

STATE OF NEW YORK)COUNTY OF NEW YORK)R.S.Hunter, being duly sworn, deposes and says he is the Vice President of Licensee Indiana and Michigan Electric Company, that he has read the foregoing response to the NRC Notice of Violation contained in IE.Inspection Reports No.50-315/80-15 and No.50-316/80-14 and knows the contents thereof, and the said contents are true to the best of his knowledge and belief.yL Subscribed and sworn to before me this~S day of 1981 Notary ublic GfteGoffY M.GfiftlCAN gofary fsoftfic, State of!;err York No.31-464343f

/~hr CommfssIon Expires March 30, 198!;

INDlANA 5 MICHiGAN ELECTRlC COMPANY P.O.BOX 18 BOWLING GREEN STATIOH HEW YORK, N.Y.10004 January 23,-1981 AEP:NRC:00512 Donald C.Cook Nuclear Plant Unit Nos.1 and 2 Docket Nos.50-315 and 50-316 License Nos.DPR-58 and DPR-74 IE Inspection Report Nos.50-315/80-15; 50-316/80-14 Mr.James G.Keppler, Regional Director U.S.Nuclear Regulatory COImIIission Office of Inspection and Enforcement Region III Glen Ellyn, Illinois 60137

Dear Mr.Keppler:

This letter is our response to the Notice of Violation attached as Appendix'A'o Mr.R.F.Heishman's letter of January 2, 1981.In accord-ance with Appendix'A'o Mr.Heishman's letter this response is being submitted under oath and affirmation.

On July 28, 1980, while Unit No.2 was operating in Mode 1, the nitrogen cover pressure on one of the four accumulator tanks exceeded the upper limit of 644 psig specified in Technical Specification 3.5.l.d.for approximately ten minutes.The maximum pressure experienced was 650 psig.This event was in fact the result of the failure of the high/low pressure alarm to clear during operator action to increase cover gas pressure.The transient nature of this event and the magnitude of the pressure excursion (+6 psi)coupled with the normal accuracy of the pressure monitor{+14 psi)and the apparent lack of adverse safety significance led to the Plant Staff's request that personnel from American Electric Power Service Corporation (AEPSC)investigate the reportability of the event.The results of the AEPSC review indicated that there was no reasonab1e adverse safety implications associated with the subject event.It was recognized that the apparent nitrogen overpressure did constitute entry into the'Action Statement'f Specification 3.5.l.d., however, the reviewers felt that the reporting criteria of Specification 6.9.1.9.b,"...operation qg.28 1981 Nr.James G.Keppler<<2 AEP NRC 00512 in a degraded mode...", had not been fulfilled as the apparent cover gas, overpressure did not impair the ability of the affected accumulator to perform its safety function.The AEPSC response to the Plant Staff's request failed to provide clear guidance as to the reportability of the subject event.Effective corr'ective action by the operator(s)

returned the accumulator cover gas pressure to within the limits of Specification 3.5.1.d.in ap-proximately ten minutes;well within the'time period of one hour allowed by the'Action Statement'f the Specification.

The reportability of this event has been discussed with those members of'he AEPSC staff involved with the aforementioned review.Particular emphasis was placed on the need for the AEPSC office to provide clear and concise guidance to the Plant Staff in matters such as the one discussed herein.These actions should be sufficient to prevent reoccurrence of similar events.Very truly yours, S.unter Vice President cc: John E.Dolan R.C.Callen G.Charnoff R.W.Jurgensen D.V.Shaller Region III Site Inspector

STATE OF NEW YORK)COUNTY OF NEW YORK)R.S.Hunter, being duly sworn, deposes and says he is the Vice President of'icensee Indiana and Michigan Electric Company, that-he has read the foregoing response to the NRC Notice of Violation contained in IE Inspection Reports No.50-315/80-15 and No.50-316/80-14

!and knows the contents thereof, and the said contents are true to the best of his knowledge and belief.yL Subscribed and sworn to before me this~Z day of 1981 Notary ublic GllPGPllY M.GLiPilCAN NOl Public.Slate ol sle r York No.31-4643431 gvaiificO ln N:w Yo:k CounfY~cofhrnlssIon ExPkes t,larch 30, 1981

Docket No.50-315 Docket No.50-316 American Electric Power Service Corporation Indiana and Michigan Power Company ATTN: Mr.John E.Dolan Vice Chairman Engineering 2 Broadway New York, NY 10004 Gentlemen:

This refers to the routine inspection conducted by Messrs.E.Swanson and N.DuBry of this office on September 28-October 31, 1980, of activities at the D.C.Cook Nuclear Plant, Units 1 and 2 authorized by NRC Operating License No.DPR-58 and No.DPR-74 and to the discussion of our findings with Mr.D.V.Shaller at the conclusion.

of the inspection.

The enclosed copy of our inspection report identifies areas examined during the inspection.

Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and.interviews with personnel.

During this inspection, certain of your activities appeared to be in non-compliance with NRC requirements, as described in the enclosed Appendix A, and a written response is required.

.A II 0 American Electric Power Service-2-0 Corporation Ve will gladly discuss any questions you have concerning this inspection.

Sincerely,

Enclosures:

1.Appendix A, Notice of Violation 2.IE Inspection Reports No.50-315/80-15 and No.50-316/80-14

REGION III Reports No.50-315/80-15; 50-316/80-14 Docket Nos.50-315;50-316 Licenses No.DPR-58;DPR-74 Licensee: American Electric Power Service Corporation Indiana and Michigan Power Company 2 Broadway New York, NY 10004 Facility Name: D.C.Cook Nuclear Power Plant, Units 1 and 2 Inspection At: D.C.Cook Site, Bridgman,'I Inspection Conducted:

September 28, 1980-October 31, 1980 Inspectors:

E.R.Swanson N.E.DuBry Approved By: D.C.Boyd, Chi: f, Projects Section 4 Ins ection Summar Ins ection on Se tember 28 1980-October 31 1980 (Re orts No.50-315/80-15 50-316/80-14 Areas Ins ected: Operational safety verification, maintenance, surveillance, licensee event report followup, review of plant operations, plant trips and safety system challenges, organization and administration, unplanned gaseous release, venting and'urging of containment, and Category"A" task action plan requirements (NUREG 0578).The inspection involved a total of 257 inspector-hours onsite by two NRC inspectors including 75 inspector-hours onsite during off-shifts.

Results: Of the twelve areas inspected, no items of noncompliance or deviations were identified in eleven areas.One item of noncompliance was identified in one area (failure to report-paragraph 8).

DETAILS Persons Contacted-D.Shaller, Plant Manager"-B.Svensson, Assistant Plant Manager R.Begor, Staff Assistant"-E.Townley, Assistant Plant Manager R.Lease, Operator Superintendent E.Smarella, Technical Superintendent R.Dudding, Maintenance Superintendent

"-J.Stietzel, QA Supervisor T.Beilman, Senior QA Auditor G.Caple, Department Assistant, QA M.McAllister, Stores Supervisor D.Duncan, Plant CGI Supervisor D.Bischoff, Performance Engineer for CGI T.Kriesel, Environmental Coordinator J.Ho, Senior Engineer (Nuclear)J.Fryer, Radiation Protection Foreman D.Palmer, Radiation Protection Supervisor

"-Denotes those present at the exit interview.

The inspectors also interviewed other licensee employees during the course of this inspection.

They included radiation protection techni-cians, senior reactor, reactor and auxiliary operators,.members of the security force, and office personnel.

0 erational Safet Verification The inspector observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the month of September and October.The inspector verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected components.

Tours of Auxiliary building, Spent Fuel Storage area, Turbine Building, and Security facilities were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations and to verify that maintenance re-quests had b'een initiated for equipment in need of maintenance.

The inspector by observation and direct interview verified that the physical security plan was being implemented in accordance with the station security plan.The inspector observed plant housekeeping/cleanliness conditions and verified implementation of radiation protection controls.During the month of October, the inspector walked down the accessible portions of the Unit 2 ECCS accummulator systems to verify operability.

The inspector also witnessed portions of the radioactive waste system controls associated with radwaste shipments and barreling.

These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under ,technical specifications, 10 CFR, and administrative procedures.

3.Monthl Maintenance Observation Station maintenance activities of safety related systems and components listed below were observed/reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides and industry codes or standards and in conformance with technical specifications.

The following items were considered during this review: the limiting conditions for operation were met while components or systems were removed from service;approvals were obtained prior to initiating the work;activi-ties were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibrations were performed prior to returning components or systems to service;quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were imple-mented;and, fire prevention controls were implemented as necessary.

The following maintenance activities were observed/reviewed:

Title Procedure Fire Seal Installation 12-MHP-5021-001"031 Installation of fire seals is currently being examined by a regional investigator and a specialist inspector.

4.Monthl Surveillance Observation The inspector observed technical specifications required surveillance testing on the Unit 2"West" Motor Driven Auxiliary feed pump (2-0HP-4040STP.017)

and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that limiting conditions for operation were met, that removal and restoration of the affected components were accomplished, that test results conformed with technical specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personnel.

, The inspector also witnessed portions of the following test activities:

Unit 1 steam generator flow mismatch protection set (1THP4030STP021), Units 1 and 2 diesel generator load testing, Unit 1 diesel generator fire pump test (1-0HP-4030-STP-120), and heat tracing surveillance testing in Unit 2.-3" The inspector observed that testing was scheduled in accordance with technical specification requirements, and that qualified personnel were using approved procedures to perform the tests.IE Bulletin Followu For the IE Bulletins listed below the inspector verified that the written response was within the time period stated in the bulletin, that the written response included the information required to be reported,.that the written response included adequate corrective action commitments based on informa-tion presentation in the bulletin and the licensee's response, that licensee management forwarded copies of the written response to the appropriate onsite management representatives,.

that information discussed in the licensee's written response was accurate, and that corrective action taken by the li-censee was as described in the written response.IEB 80-18-Maintenance of Adequate Flow Through Centrifugal Charging Pumps After Steam Line Break IEB 80-12 Decay Heat Removal System Operability IEB 79-03A Longitudinal Weld Defects in ASME SA-312 Type 30455 Pipe A review of licensee actions regarding IE Bulletin 79-21"Temperature Effects-on Level Measurements" found that procedures and modified setpoint had been promulgated per response letter to the Commission on May 22, 1980.(AEP:NRC:00271B)

The inspector inquired as to what steps were being taken by the licensee following their receipt of the June 22, 1980, letter from their vendor (AEg-80-66)

delinea'ting corrective action to beconsidered.

Licensee representatives stated that re-evaluation was being done.This matter will continue to be followed by the inspector.

Licensee Event Re orts Followu For the IE Circulars listed below, the inspector verified that the Circular was received by the licensee management, that a review for applicability was performed,'and that if the circular were applicable to the facility, appropriate corrective actions were'taken or were scheduled to be taken.Unit 1 RO 50<<315/80-23/036-0 IE Circular Followu For the IE Circulars listed below, the inspector verified that the Circular was received by the licensee management, that a review for applicability was performed, and that if the circular were applicable to the facility, appropriate corrective actions were taken or were scheduled to be taken.IEC 80-12 IEC 80-11 Valve-Shaft-To-Actuator Key May Fall Out of Place When Mounted Below Horizontal Axis Emergency Diesel Lube Oil Cooler Failures

IEC 80-09 IEC 80-05 IEC 80-04 IEC 80-02 IEC 80"01 IEC 79-25 IEC 79"23 IEC 79-22 IEC 79-20 IEC 79-19 IEC 79-13 IEC 79-12 IEC 79-10 IEC 79-09 IEC 79-04 IEC 79-02 Problems with Plant Internal Communications Systems Emergency Diesel Generator Lube Oil Addition and Onsite Supply Securing of Threaded Locking Devices on Safety-Related Equipment Nuclear Power Plant Staff Work Hours Service Advice for GE Induction Disc Relays A Shock Arrester Strut Assembly Interference Motor Starters and Contactors Failed to Operate Stroke Times for PORV'S Failure of GTE Sylvania Relay, Type PM, Bulletin 730 S, Catalogue 5012-ll-AC (12V AC Coil)I,oose Locking Devices on Ingersoll-Rand Pumps Replacement of Diesel Fire Pump Starting Contactors Potential Diesel Generator Turbocharger Problem Pipefitting Manufactured From Wrong Material Split or Punctured Diaphragm's on SCBA's.Loose Packing Nut on Limitorque Moto Valve Operators Failure of POR 120V Vital A/C Power Supply 8.Review of Plant 0 erations During the months of September through October the inspector reviewed the following activities:

Procurement The inspector reviewed procurement and storage activities to ascertain whether the purchase of components, materials and supplies used for safety related functions, is in conformance with the licensee's approved gA program and implementing procedures; non-conforming items are segre-gated and marked accordingly; applicable preventive maintenance is per-formed;housekeeping and environmental requirements are met;and, limited shelf-life items are controlled.

The following components were inspected.

(1)GE GE RTV-133 Fire Retardant Caulking (2)DOW silicone foam (3)Retrofit locknut kits for Ingerso1.1-Rand pumps T~rainin The inspector verified by direct questioning of one new, one existing, and one temporary employee that administrative controls and procedures, radiological health and safety, industrial safety, controlled access and security procedures, emergency plan, and quality assurance training were provided as required by the licensee's technical specifications; verified by direct questioning of one craftsmen and one technician that on-the-job training, formal technical training commensurate with job classification, and fire fighting training were provided.-5-c.Environmental Protection The inspector discussed the installation and operability of environ-mental monitoring and sampling stations with licensee representatives.

The inspector also reviewed with the contracted vendor the monitoring frequency of TLD, air sampling, and milk sampling collections.

Loca-tion of sample stations of present and proposed (TMI Lessons Iearned Emergency Upgrade)were reviewed with licensee and the vendor repre-sentative.

d.Emer enc Pre aredness The inspectors observed the emergency preparedness drill conducted by FEMA on October 9, 1980, and viewed the functioning of the licensee's Technical Support Center.The inspector's visited the Berrian County Emergency Operations Center and the Joint Public Information Cen'ter and verified the agencies are familiar with their roles in the emer-gency plan.Attendance at the critique on October 10, 1980, revealed that FEMA gave the drill a passing grade and that the final report would be issued at a later date.A sampling of equipment used during the drill was found to be returned to its proper location after the drill exercise.e.Licensee Action Concernin Identified Problems The inspector reviewed Condition Reports generated during the months of July, August, and September, 1980, for trends or recurring failures and resolution of identified discrepancies involving safety-related components.

Condition Report No.2-7-80-226 describes an event on July 28, 1980, when a Unit 2 accumulator was charged with nitrogen over the technical specification limit and was restored to within the limits specified in approximately ten minutes.The event was properly reviewed by plant management and classified as not reportable, with the QA Super-visor dissenting.

As discussed in the exit meeting held on October 24, 1980, Technical Specification 6.9.1~9.b reporting requirement is applic-able (operation in a degraded mode permitted by a limiting condition for operation).

As detailed in Appendix A, this is an item of noncom-pliance.9.Plant Tri s-.Safet S stem Challen es Following the plant trips and safety system challenge of Unit 1 on October 11, 1980, while conducting control valve testing the inspector ascertained the status of the reactor and safety systems by observation of control room indicators and discussions with licensee personnel con-cerning plant parameters, emergency system status and reactor coolant chemistry.

The inspector verified the establishment of proper communica-tions and reviewed the corrective actions taken by the licensee.All systems responded as expected, and the plant was returned to operation on October 12, 1980.<<6--

A ground fault in the Unit 2 main generator (Brown-Boveri)

resulted in a plant trip on October 18, 1980..All systems, with the exception of one source range channel, responded as expected.The source range channel was restored to operations within an hour.The plant has been shutdown and cooled down while the licensee conducts extensive repairs on the main generator.

Estimated date of plant operational restoration is mid-December, 1980.10.Or anization and Administration The inspector reviewed the organizational structure of the offsite and onsite facility organization contained in the Technical Specifications and determined the following:

a~Figure 6.2.-2 of the Technical Specifications for both units does not reflect the assignment of an Assistant Plant Manager (two are current-ly assigned), a Staff Assistant, an Outage/Design Change Coordinator, a Chief Security Supervisor or an, Environmental Coordinator.

Personnel who have changed assignments in the last year include: (1)assignment (2)assignment (3)assignment (4)assignment (5)assignment (6)assignment of T.of R.of H.of F~of C.of D.A.Kreisel as Environmental Supervisor S.Kieth as Operation Superintendent M.Chadwell as Design Change Coordinator W.Schaub as Chief Security Supervisor (Acting)A.Ross as Nuclear Engineer R.Campbell as Production Supervisor, Operations The qualifications of the above personnel were found to meet Technical Specification or gA Program requirements.

b.Figure 6.2.-1 of the Technical Specifications does not reflect the current Offsite Management and Technical Support Organization due to several recent changes in corporated structure.

No significant changes in personnel have occured, but some reorganization has taken'place.The licensee has submitted Technical Specification change requests for Unit 1 on December 22, 1978;for Unit 2 on February 13, 1979, and has updated their submittals by telephone as recently as June 10, 1980.No items of noncompliance or deviations were identified.

ll.Un lanned Gaseous Release On October 17, 1980, the licensee experienced an unplanned gaseous radio-active release from the auxiliary building vent stack.Investigation re-vealed that the source was due to off-gassing of overflow to the auxiliary building clean sump.The overflow had been caused by the waste system tanks being o'verfilled while attempting to valve in the reactor coolant filter in the CVCS system due to a leaking drain valve.The release was primarily xenon-133 and was 1..6$of Technical Specification limits based on integrated measurements during the release.Three workers near.the scene received-7-minor contamination, they were decontaminated and released.The licensee took immediate corrective action when the cause was discovered and has'eplaced the leaking drain valve to preclude recurrence.

12.Ventin and Pur in of Containment (Task II.E.4)The inspector reviewed all available correspondence and guidance concern-'ng the issue of containment purge and vent., The licensee has committed in a June 8, 1979, letter (AEP:NRC:00114A)

"....to limit purging of Unit 1 in Modes 1, 2, 3 and 4 to 90 hours0.00104 days 0.025 hours 1.488095e-4 weeks 3.4245e-5 months per year until the issue is finally resolved".

Unit 2 is restricted by Technical Specifications from purging during Modes 1, 2, 3 and 4.As summarized in a November 8, 1979, letter (AEP:NRC:00295)

the licensee has responded to all questions, sub-mitted the results of purge valve testing and analyses, provided justifica-tion for unrestricted purging of both units, submitted details of the review of overriding of safety actuation signals, and requested NRC action on their requests for a Technical Specification change on Unit 2 and removal of the 90 hour0.00104 days 0.025 hours 1.488095e-4 weeks 3.4245e-5 months restriction on Unit 1.Further correspondence on December 5, 1979 (AEP:NRC:00295A)

states that since the installed Radiation Monitoring System (as described in the FSAR)does cause purge system isolation, the monitors (designed as control grade)are not part of the Safegaurds System, but pro-vide additional inputs and enhance the defense-in-depth philosophy.

Mr.Schwencer's letter to Mr.Dolan (IQi)on February 11, 1980, requested further commitment to Interim Position No.1.By letter dated March 10, 1980 (AEP:NRC:00370)

the licensee committed to comply with the position which follows: Whenever the containment integrity is required, emphasis should be placed on operating the containment in a passive mode as much as possible and on limiting all purging and venting times to as low as achievable.

To justify venting or purging, there must be an established need to improve working conditions to perform a safety related sur-veillance or safety related maintenance procedure.(Examples improved working conditions would include deinerting, reducing temperature"-, humidity"=, and airborne activity sufficiently to permit efficient per-formance or to significantly reduce occupational radiation exposures), It was also stated in the letter that even in complying with the position for Unit 1, the licensee may need to purge in excess of 90 hours0.00104 days 0.025 hours 1.488095e-4 weeks 3.4245e-5 months per year as was previously discussed (AEP:NRC:00114A).

Inspection during the period covered by this report and efforts detailed IE Inspection Reports 50-315/80-08 and 50-316/80-07, paragraph 14, verified that the licensee is in compliance with the stated position.According to records maintained in the control room, Unit 1 has been purged for less than 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months in the current calendar year.By letter of March 25, 1980 (AEP:NRC:00295B)

the licensee responded to questions and further committed to install safety grade/class 1E containment radiation monitoring channels to provide initiation of containment ventilation isolation.

This is to be installed during the first outage of sufficient duration subsequent to equipment delivery.-8-13.CATEGORY"A" TMI TASK ACTION PLAN RE UIREMENTS On February 26, 1980, a meeting was held betwe en NRR and licensee repre-sentatives to review the implementation of Category"A" requirements of NUREG-0578.

Supplemental information requested at this meeting was pro-vided by letter on March 10, 1980 (AEP:NRC:00334B).

Ah evaluation of compliance was issued by the Division of Operating Reactors on March 20, 1980, to J.Dolan which included items to be followed up by the Office of Inspection and Enforcement (OIE).The following is a list of areas inspected during the month of October, 1980, to complete the evaluation of actions taken by the licensee.NUREG 0578 Number (Task Number)2.1.3.b(II.F.2)

Subcoolin Meter-Procedures were reviewed for backup methods and operators were interviewed and found knowledgeable of procedures'lso reviewed in IE Reports 50-315/80-04 and 50"316/80-03.

2.1.4(II.E.4.2)

Containment Isolation-12-DHP 4030 STP035"Sealed Valve Position Logging" provides adequate administra-tive control to assure that manual isolation valves are in the correct position and provides for periodic verification that normally closed valves and locked doors.2.1.5.c H dro en Recombiner Procedures-1-DHP 4022'.034.004 and 2-DHP 4022.034.004 were reviewed and operators interview to ascertain their level of familiarity.

Recombiners were covered in training and most operators were familiar with their operation by having performed the semi-annual surveillance test.2.1.6.a(III.D.1.1)

Leak Reduction Pro ram-PMI 5031, 12-OHP 4030.STP.038 and 12-THP-SP-015 were reviewed and found to implement an effective program for identifying and correcting leaks.Results of both the gaseous and liquid leak tests that have been performed were reviewed.Signi-ficant leaks identified were promptly corrected.

2.1.6.b(II.B.

2)Desi n Review Shieldin and Environmental Qualifica-tions-Licensee committed to submit response on environmental qualifications to the NRC by April 15, 1980, in their March 10, 1980 letter (AEP:NRC;00334B).

By letter of May 15, 1980, (AEP:NRC:00334D)

the licensee transmitted an executive summary of the Plant Shielding Design review and Equipment Radiation Environmental Qualification review and stated that the detailed report would be available at the plant for OIE review.In-formal communications indicate it might be available by the end of November.

2.1.8.a(II.B.3)

Post Accident Sam lin Ca abilit-112-THP-SP-13 was reviewed and found to adequately prescribe sampling and analysis methods utlizing the modified systems equipment'escribed in the March 10, 1980.submittal.

The equipment was verified to be available.

These interim measures will be further reviewed by a special Health Physics group.2.1.8.b(II.F.1)

Increased Ran e of Radiation Monitors-12-THP-SP-1 and 12-THP-SP-16 were reviewed and found to be adequate for the measures described.

Portable instruments are available to be utilized as described in the March 10, 1980 submittal.

They are not installed as inferred by the March 20, 1980 evaluation.

Equipment and modifica-tions are installed and accomplished as described.

These interim measures will be further reviewed by a special Health Physics group.2.1.8.c(III.D.3.3)

Radioiodine Instrumentation-12-THP-SP-14 was reviewed and found to be adequately

'implement the provisions described in the March 10, 1980 submittal.

Two NMC CAMs and three PING-1A monitors are available (not"4 PINE-lA" as stated in the March)0, 1980 submittal).

These interim measures will be further reviewed by a special Health Physics group.Note: The above referenced Special Procedures were not available in the Technical Support Center (TSC)as the inspector logically expected since the TSC is the controlling station for these support functions.

2.2.1.a(I.A.1.2)

Shift Supervisor Responsibilities-PMS0.046 and OSO.031 specify the responsibilities of the plant Senior Operating Engineer and further delineate which of the non-safety related duties may be delegated to other persons.14.Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)throughout the month and summarized the scope and findings of the inspection activities.

The licensee acknowledged the comments the inspector made concerning the noncompliance discussed in Paragraph 8.10-

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IR 05000315/1980022

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Dear Mr.Keppler:

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1980 Quarterly Integrated 1Q (0) 2Q (0) 3Q (0) 4Q (0) Assessments Mid Cycle End of Cycle 22(0) Security Operator Exams Emergency Planning Other

IR 05000315/1980022

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Dear Ms.Nicholson:

Enclosure:

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Dear Mr.Keppler:

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Dear Mr.Keppler:

Dear Mr.Keppler:

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