IR 05000315/1981001
| ML17326A890 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 03/18/1981 |
| From: | Dubry N, Hayes D, Swanson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17326A888 | List: |
| References | |
| 50-315-81-01, 50-315-81-1, 50-316-81-01, 50-316-81-1, NUDOCS 8105110513 | |
| Download: ML17326A890 (9) | |
Text
"(Qs U.S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
. Report No. 50-315/81-01; 50-316/81-01 Docket No. 50-315; 50-316 License No. DPR-58; DPR-74 Licensee:
American Electric Power Service Corporation Indiana 6 Michigan Electric,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:
January 1-31, 1981 x'iJ--g'nspectors:
E. K. Swanson y<4 /-
N. E. DuBry, y~/j~i~j.
Approved By:
D.
W. Hayes, Chief
~-~ Reactor Projects Section 1B Ins ection Summa Ins ection on Januar 1-31 1981 (Re ort No. 50-315/81-01 50-316/81-01)
Areas Ins ected:
Routine, onsite regular and backshift inspection by the resident inspectors.
Areas" inspected include Operational Safety Verifi-cation, Maintenance Observation, Surveillance Observation, Licensee Event report reviews, IE Bulletin followup, onsite review committee activities, followup on previous inspection findings, procedures for anticipated tran-sients without scram, significant events review, and TMI-2 Action Plan items.
The inspection involved a total of 176 inspector-hours onsite by two NRC inspectors including 49 inspector-hours on off-shifts.
Results:
Of the ten areas inspected no items of noncompliance or deviations were identified in seven areas.
Three items of noncompliance were identified in three areas ( failure to follow procedures/inadequate management controls, paragraphs 6,
1];
- failure to report significant event, paragraph 10; non-compliance with limiting condition for operation, paragraph 5b).
DETAILS 1.
Persons Contacted-D. Shaller, Plant Manager-B. Svensson, Assistant Plant Manager R. Keith, Operations Superintendent
>E. Smarella, Technical Superintendent R. Dudding, Maintenance Superintendent J. Stietzel, QA Supervisor D. Duncan, CSI Supervisor D. Palmer, Radiation Protection Supervisor T. Kriesel, Environmental Supervisor The inspectors also contacted a number of licensee employees and in-formally interviewed operators, technicians and maintenance personnel during the inspection.
>Denotes personnel who attended the exit interview.
2.
0 erational Safet Verification i
.
The inspector observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the month of January, 1981.
The inspector verified the operability of selected emergency systems, review'ed tagout records and verified proper return to service of affected components.
Tours of the auxiliary building and turbine building 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 inspector by observation and direct interview verified that the physical'ecurity 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 January, 1981, the inspector walked down the accessibl'e portions of the Unit 2 containment spray systems to verify operability.
The inspector also witnessed portions of'he radioactive waste system controls associated with radwaste shipments and barreling.
t These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under technical specifications, 10 CFR, and adminis-trative procedures.
"2-
3.
Monthl Maintenance Observation Station maint!enance activities of safety related systems and com-ponents 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; 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 pre-vention 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:
Repair and Test of Pressurizer Safety Valve (SV-45)
MHP 5021.001.004 MHP 4030.STP.001 Unit
Core Cooling Operability Test -
10 HP 4030 STP 005 BIT Pressure Transmitter -
1 THP 6030 IMP 015
"S" SI Pump Removed from Service for Maintenance Repair Urgent Failure Alarm - Rod Control System Unit 2 Maintenance on the No.
4 B.A. Transfer Pump Maintenace Repair Procedure for the Boric Acid Transfer Pump
MHP 5021.007.001 Boron Injection Flow Path and Boric Acid Transfer Pump Operability 20 HP 4030 STP.002 Following completion of maintenance on the No.
4 Boric Acid Transfer Pump, the inspector verified that these systems had been returned to service properl.
Monthl Surveillance Observation The inspector observed technical specifications required surveil-lance testing on the Power Range Nuclear Instruments and Steam Pressure Protection Sets and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that limiting conditions for operation were met 1 that removal and restoration of the affected components were accomplished, that test results conformed with technical specifi-cations 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 re-viewed and resolved by appropriate management personnel.
The inspector also witnessed portions of the following test activ-ities:
Emergency Core Cooling System Surveillance.
The following procedures were also reviewed:
2 THP 6030 IMP 231
OHP 4030 STP 005 2 THP 4030 STP 150 2 THP 4030 STP 145 1 THP 4030 STP
.044 1 THP 6030 IMP 131
- Power Range Nuclear Instrument Calibration (N41-44)
- ECCS (For Unit 2 on 1-12-81)
- Steam Pressure Protection Set III
- Rx Logic Train "A and B" - Trip Breakers
"A 6 B" (Train A)
Rx Trip Breaker Surveillance Test
- Power Range Nuclear Instrument Calibration (N41-N44)
5.
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 pre-vent recurrence had been accomplished in accordance with technical specifications.
df Unit
78-070/03L-0 80-018/03L-0 80-022/03L-0 80-024/03L-0 Failure of VCR-10 TAVE Less Than 541~ F R-ll, R-12 Inoperable Ice Condenser Doors Inoperable Event Report 78-070/03L-0 was submitted nearly two years late.
The inspector reviewed the circumstances surrounding the failure to report the event and is satisfied that the present equality Assurance Group's tracking of the status of responses due should be adequate to prevent further recurrence.
-4-
Unit 2 79-041/03L-0 79-041/03L-1 80-028/03L"0 80-029/03L-0 80-030/03L-0 80-031/03L-0 81-001/03L-0 AEO 81-001/04T-0 H2 Recombiner Fail to Reach Temperature Supplement SI Relay Timer out of Tolerance R-ll Paper Drive Malfunction R-ll, R-12 Sample Pump Seized Containment Hi-Hi Pressure Out of Tolerance W RHR Pump Control Power Lost Unmonitored Blowdown Abnormal Environment Occurrence (AEO)
On January 12, 1981, at 2200 hours0.0255 days <br />0.611 hours <br />0.00364 weeks <br />8.371e-4 months <br />,'blowdown was shifted to the startup tank at which time it was noted that the sample line for steam generator 21 indicated no flow.
The shiftover to normal tank was accomplished on January 13, 1981 at 0318 hours0.00368 days <br />0.0883 hours <br />5.257936e-4 weeks <br />1.20999e-4 months <br />.
The fact that the indication was correct was confirmed by maintenance on January 15, 1981 and this was made known to management on January 21, 1981 and reported to the NRC on January 22, 1981 at 1330 hours0.0154 days <br />0.369 hours <br />0.0022 weeks <br />5.06065e-4 months <br />'t was verified that there was no apparent change in activity of steam generator 21 during the period.
Appendix B Technical Specification (T.S.) 2.4.2.g states:
"The radioactivity in steam generator blowdown shall be continuously monitored and recorded.
Whenever these monitors are inoperable, the blowdown flow shall be diverted to the waste management system
,and the direct release to the environment terminated;"
The failure to immediately divert the blowdown flow to the waste management system, when the ability to identify and quantify a potential release to the environment did not exist, is an item of noncompliance.
In the event of an AEO as defined in Section 1.1 a report shall be submitted under one of the report schedules described below.
reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone, telegraph, or facsimile transmission to the Director of the NRC Regional Office and within 10 days by a written report to the Director, Office of Nuclear Reactor Regulation.
As noted above, a period considerably in excess of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> elapsed between the discovery of the no flow indication and the prompt report to the NRC.
This event and the tardiness of the report reflect two concerns.
First, that plant personnel are not adequately familiar with the Appendix B Technical Specifications and secondly, that communica-tions within the plant appear inadequat (
6.
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 information presented 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 licensee was as described in the written response.
(Open)
IE Bulletin 80-11 "Masonry Wall Design" required a two part response, due on July 8, 1980 and November 10, 1980.
The licensee's first response was dated July 10, 1980 and only after queries as to the status of the second response did the licensee furnish a partial response and request for extension on January 14, 1981.
As discussed with the licensee on January 2,
1981, there appears to be a breakdown of the system which tracks commitments and required responses.
This concern is further heightened by other findings of missed commitments discussed in paragraph 11.
h (Closed)
IE Bulletin 79-21 "Temperature Effects on Level Measurements."
The licensee's initial response to the bulletin due on September
1979, was not sent until November ll, 1979.
That response was to realign setpoints in a more conservative direction.
During the review of the bulletin, the inspector discovered the licensee received a
recommendation letter of corrective actions to be taken from the vendor.
Thhe licensee is re-evaluating their corrective action since it was not the favored recommendation.
The inspector will continue to follow the licensee's re-evaluation effort.
7.
Onsite Review Committee The inspector examined the onsite review functions conducted during the period January 5-30, 1981 to verify conformance with t'echnical specifications and other regulatory requirements.
This review included:
changes since the previous inspection in the charter and/or administrative procedure governing review group activities; review group membership and qualifications; review group meeting frequency and quorum; and, activities reviewed including proposed technical specification changes, noncompliance items and corrective action, proposed facility and procedure changes and proposed tests and experiments conducted per
CFR 50.59, and others required by technical specifications.
The inspector is not satisfied with the quality of review provided by the committee and has unresolved questions in the area of 10 CFR 50.59 review of changes, tests and experiments and the documentation of the basis for the decisions.
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Followu on Previous Ins ection Findin s
(Closed)
(50-315/80-16) Deficiency:
Failure to follow procedure (Ca
.
( alibration of feedwater flow transmitters).
The inspector reviewed changes to the subject procedure (RTHP 6040 Per.
020)
and found that temporary sheet two dated December 12, 1980 implemented an acceptable change to the calibration requirements for the feedwater flow trans-mitters.
This i'tern is considered closed.
9.
Antici ated Transient Without Scram (ATWS)
The inspector reviewed the licensee's emergency and abnormal operating procedures addressing the plant responses to anticipated transient without scram (ATWS) events.
Procedures reviewed by the inspector included:
Abnormal Procedure 12-OHP 4022.001.001 12-OHP 4022.005.002 12-OHP 4022.012.001
"Emergency Shutdown including Reactor Scram."
"Emergency Boration."
"Failure of Control Bank to Move."
Emergency Procedure 12-OHP 4023.001.001 12-OHP 4023.001.002
"Alternate Emergency Shutdown and Cooldown Procedure Due to Loss of Normal and Preferred Alternate Methods."
"Emergency Procedures Immediate Actions and Diagnostics."
Plant Manager Instructions PMI 1020
"Reactor Operators:
Authorities and Responsi-bilities for Safe Operation and Shutdown."
The inspection was completed on January 20, 1981 and the licensee was found to have met the acceptance criteria with the following exceptions.
The licensee's formal procedures do not address what actions (in order of preference)
to take in the event that manual scram initiation is ineffective.
Independent interviews with licensed operators, operating engineers, shift operating engineers, and the plant operation's superintendent indicate they would first initiate BIT injection and then proceed to open the output breakers of the rod drive MG sets.
They feel this is a more conservative approach by affecting a more rapid plant shutdown than emergency boration initiatio. Si nificant Event Unit 1 - Boron In'ection Tank Out of S ecification At 11:00 a.m.
on January 12, 1981, the Boron Injection Tank (BIT) was sampled and found to contain a concentration of 19,300 ppm boron (less
'han the Technical Specification (T.S.) minimum of 20,000 ppm).
As required by the T.S. action statement of 3.5.4.1, the BIT was placed in recirculation with an alternate storage tank of higher concentration.
Power reduction commenced at 12:00 (Noon) since the BIT was not yet within specifications.
At 1:26 p.m.
a sample of the BIT was 21,459 ppm and the power reduction was terminated.
In leakage and dilution of the BIT from the charging system are suspected as being the cause, but no corrective maintenance has been accomplished.
Sampling frequency has been increased to prevent further recurrence.
\\
The inspector became aware of the situation when he entered the control room at approximately 1:15 p.m.
on a routine tour.
CFR 50.72 requires the following:
Each licensee of a nuclear power reactor licensed under 50.21 or 50.22 shagl notify the NRC Operations Center as soon as possible and in all cases within one hour by telephone of the occurrence of any of the following significant events and shall identify that event as being reported pursuant to this section:.....
Any event requiring initiation of shutdown of the nuclear power plant in'ccordance with Technical Specification Limiting Conditions for Operation.
The licensee did not make the required notification to the NRC within the required time frame.
This is an item of noncompliance.
ll. TMI - Action Plan Items III.D.3.3 - The licensee's January 9,
1981 letter (AEP:NRC:0398)
was reviewed.
Equipment discussed was inspected with the follow-ing results:
"Two Eberline PING-1 airborne particulate and radioiodine monitor."
These instruments are "PI" not "PING-1".
Of the three Eberline Model PING-1A monitors one is out of calibration and the equipment necessary to perform the calibration is being procured.
The Silver Zeolite cartridge purge unit discussed was not installed on January 9,
1981 and the fact was made known to licensee management on the same date.
The installation was evidently scheduled to have been done by January 1,
1981, as was indi-cated in a draft reply the inspector was allowed to examine.
After receipt of the formal response on January 12, 1981,
.
it was again discussed.
It was installed on January 13, 1981.
Subsequent correspondence dated January 16, 1981 (AEP:NRC:
00 398B) stated that the proposed implementation date for this item of January 31, 1981 was inadvertently omitte 'i This item is closed for task action plan purposes and is addressed in Appendix A to this report.
II.E.1.1 The evaluation 'by the NRC of the Auxiliary Feedwater (AFW)
system dated October 6, 1980, did not take into account the licensee's submittal of November 3, 1980 as implied by the licensee's January 8,
1981 letter. It is also noteworthy that the evaluation addresses several outstanding commitments and unacceptable items.
One referenced licensee response of December ll, 1979 (AEP:NRC: 00300) included a commitment to install an automatic pump trip on low suction pressure which would alarm in the control room by January 1,
1981.
On January 13, 1981, the inspector found that due to procure-ment problems it would not be installed in the near future.
The licensee was notified of this in a periodic exit meeting.
On January 27, 1981, the licensee's letter (AEP:NRC: 00300E)
revised the installation date for this item to April 30, 1981.
This revised date is acceptable to the NRC as discussed with the NRR Project Manager.
It is unacceptable that the licensee was apparently not aware of the committed install-ation date and submitted their letter after the commitment date had passed.
This item was addressed as a deviation from a commitment in Appendix A to IE Inspection Reports 50-315/80-21 and 50-316/80-17.
These two action plan items and also the late response addressed in Paragraph 5 indicate that the management tracking system which tracks responses and commitments is inadequate to insure that committed and required actions will be taken promptly and that incomplete action items are known at all levels of management.
Corporate office procedure AEPSC General Procedure No. 32, "Preparation of Submittals to the U.
S.
Nuclear Regulatory Commission" was reviewed by the inspector.
It appeared to adequately assign responsibilities and establish methods for tracking commitments and responses, insuring that submittals to the NRC are factual, and scheduling the steps necessary to meet submittal dates so that extensions can be requested prior to the deadline date.
However, the several findings related to these areas addressed by this procedure indicate that it.is not being complied with.
12.
Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1) throughout the month and at the conclusion of the inspection and summarized the scope and findings of the inspection activities.
The licensee acknowledged the inspection findings and violations discussed in Paragraphs 5, 6, 10, 11.