IR 05000315/1982011
| ML20058F238 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 07/14/1982 |
| From: | Dubry N, Hayes D, Swanson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20058F222 | List: |
| References | |
| 50-315-82-11, 50-316-82-11, NUDOCS 8207300369 | |
| Download: ML20058F238 (9) | |
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U.S. NUCLEAR RECULATORY COMMISSION
REGION III
O Reports No. 50-315/82-11(DPRP); 50-316/82-11(DPRP)
Docket Nos. 50-315; 50-316 Licenses No. DPR-58; DPR-74 Licensee: American Electric Power Service Corporation Indiana and Michigan Electric Company 2 Broadway New York, NY 10004 Facility Name: Donald C. Cook Nuclear Power Plants, Units 1 and 2 Inspection At: Donald C. Cook Site, Bridgman, MI Inspection Conducted: May 1 through June 15, 1982
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Inspecto :
. R. Swans 7-14-6 Z u,dw
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E. Dubh 7-Id" b 2
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Approved By: D ' W.'I a s, Cliie f V [2'
Reactor Projects dection 1B
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Inspection Summary Inspection on May 1 through June 15, 1982 (Reports No. 50-315/82-11(DPRP);
50-316/82-11(DPRP))
Areas Inspected: Routine, onsite regular and backshift inspection conducted by two resident inspectors.
Areas inspected included: Followup on Previous Inspection Findings, Operational Safety Verification, Surveillance Observation, Maintenance Observation, Licensee Event Reports, Plant Trips, Technical Specification Waiver, Design Change Errors and Regional Requests. The in-spection included a total of 240 inspection-hours onsite by two NRC inspectors including 40 inspector-hours onsite during off-shift hours.
Results: Of the nine areas inspected no items of noncompliance or deviation were identified in seven areas. One item of noncompliance was identified in each of the other two areas. Failure to take adequate and timely correc-tive action, Paragraph 2, and failure to maintain penetration fire barrier functional, Paragraph 3.
8207300369 820715 PDR ADOCK 05000315 D
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d DETAILS
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Persons Contacted
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- W.
Smith, Jr., Plant Manager
- B.
Svensson, Assistant Plant Manager
- E. Townley, Assistant Plant Manager
- E.
Smarrella, Technical Superintendent
- J.
Stietzel, Quality Assurance Supervisor
- K.
Baker, Operations Superintendent R. Dudding, Maintenance Superintendent
- P.
Jacques, Fire Protection Coordinator
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- Denotes those present at exit interviews.
The inspectors also contacted a number of licensee and contract employees and informally interviewed operation, technical, and maintenance personnel during this inspection period.
2.
Followup on Previous Inspection Findings (Closed) Noncompliance Item (50-316/82-04-02): Hydrostatic testing was done without procedure adherence. The engineering evaluation and results j
of the second hydrostatic test was reviewed. Approved procedures were used in performing the test.
The inspectors have no other questions at this time.
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(Closed) Noncompliance Item (50-315/82-04-03; 50-316/82-04-03):
Calibration and parformance evaluation of surveillance and maintenance test equipment was reviewed.
It was verified that the licensee has changed the procurement requirements to outside vendors to require a QA program approved by the buyer, and the supplier of the service to
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furnish "as found/as left" data.
f (Open) Noncompliance Item (50-315/82-04-02):. Updates of plant drawing to reficct currect "as built" conditions were not timely. The inspector reviewed the temporary change to PMI 5040 and other aspects of'this This item will remain open until the revisions to licensee's area.
Design Control program is completed. An evaluation by the inspectors
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will then be made of the corrective actions.
(Closed) Noncompliance Item (50-315/81-13-01): Failure to perform surveillance in a timely manner. The inspector reviewed the licensee's efforts in this area and found that they have reviewed Operations Department procedures to assure surveillances are completed in accord with Technical Specifications. The master surveillance schedule has been reviewed and computerized so that applicable procedures are performed at the proper frequency. Maintenance and Technical depart-ments have reviewed Technical Specifications and applicable procedures i
to insure required surveillances are being done. These departments are maintaining two computer programs (one onsite/one offsite) and
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retaining the manual tracking system, until computer reliability is proven, to quarantee compliance.
(Closed) l'nresolved Item (50-315/80-20-04; 50-316/80-16-02):
Considerable attention has been given to insuring the operability of fire doors since this discovery. The licensee now considers fire doors and dampers as part of the " fire barriers protecting safety related areas" as specified in Appendix A Technical Specification 3.7.10.
Although recent instances of noncompliance abound, they reflect an increased awareness and understanding of fire protection requirements on the part of the plant staff (many were licensee identified).
(Closed) Unresolved Item (50-315/80-20-03): Records for seven surveil-lance requirements were not located during the inspection conducted on November 17-21, 1980.
Subsequent investigation by the licensee dis-covered that the suspected missing data sheets were either not required due to the plant operating modo, or were located in the plant files.
The licensee has implemented additional controls to track the completion and filing of these records to prevent recurrence.
(Open) Noncompliance Item (50-315/81-28-01; 50-316/81-32-01): As part of the Donald C. Cook Quality Assurance Program, safety related items (N items) are to be included in a "N-List".
During previous inspection j
in early 1980 and late 1981, the controls for maintaining this document as an up-to-date, reliable reference were found to be inadequate.
Revisions to these controls were made in February 1980 and May 1982.
(See Inspection Reports 50-315/80-01; 50-316/80-01 and 50-315/81-28; 50-316/81-32)
To verify the adequacy of a newly updated N-List the inspector looked to see if the Divider Barrier Seal was listed.
It was not listed.
This seal covered by Technical Specification 3/4.6.5.9 is part of con-tainment and is considered to be safety related.
It has been found to be deteriorating during recent inspections on both units. As a result of this deterioration the licensee contacted the material supplier (UNIR0YAL) and was advised to utilize a similar, but superior material. This required a Technical Specification change and review by numerous persons and committees.
In spite of these reviews and high visibility, the material was procured as an open stock, non-safety related item (QA-S vs. QA-N) and the supplier, UNIROYAL, was not an approved vendor of "N" materials (Qualified Supplies List, Rev.
8,~ January 22, 1982). The N-List is utilized by persons preparing purchase orders in determining the procurement requirements and is therefore considered a causative factor in the supplier not being qualified.
This repetitive problem of establishing effective administrative controls to meet the requirements of 10 CFR 50 Appendix A, General Design Criteria I, is being cited as a failure to take effective and timely corrective action to prevent recurrence.
(315/82-11-01; 316/82-11-01)
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J (Cicsed) Unresolved Item (50-315/80-20-05; 50-316/80-16-03): Residual Heat Removal (RHR) train inoperability due to air in the system is discussed in detail in IE Reports 50-315/80-20; 50-316/80-16. This
event was a topic of the Enforcement Conference held on January 13, 1981 (Reports 50-315/81-02; 50-316/81-02) where the licensee committed
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to conduct further evaluation of the effects of air an the system during large and small break LOCA's, and to discover the cause of the air being introduced into the system.
Internal memoranda dated April 13, and August 10, 1981 respond to the discussions of the Enforcement Conference and conclude that..." adequate (LOCA) protection was avail-able at all times" and that air was introducted by maintenance and I
half-loop operation without being properly returned to service.
Further, the surveillance test run on August 4, 1980, when the pump had to be vented, did not result in the system being verified as fully i
operable as discovered by subsequent surveillance testing on September 4, 1980.
Corrective actions recommended in the August 10, 1981 memorandum to the plant manager to prevent recurrence of air in-leakage were appar-ently not fully impicmented. A note was added to the ECCS operability test (OHP 4030 STP.005) which explains how to sweep the air from the system if it was drained for maintenance and the Reactor Coolant System fill and vent procedure specified how to restore the RHR system after half-loop operation. The inspector is not aware of any corrective actions taken that are adequate to insure that a proper post-mainten-ance operability test will be performed. This is another example of failure to take timely and effective corrective action and this item is being upgraded from an unresolved matter to an item of noncompliance.
(315/82-11-01; 50-316/82-11-01)
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Operational Safety Verification The inspector observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the inspection period of May 1 through June 15, 1982. The inspector verified the operability of selected emergency systems, reviewed (
tagout records and verified proper return to service of affected
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components. Tours of the auxiliary building, turbine building,
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screenhouse, and plant perimeter were were conducted to observe plant equipment conditions, including potential fire hazards, fluid
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leaks, and excessive vibrations and to verify that maintenance requests had been initiated for equipment in need of maintenance.
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The inspector by observation and direct interview verified that the physical security plan was being implemented in accordance with the station security plan.
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l The inspector observed plant housekeeping / cleanliness conditions i
and verified implementation of radiation protection controls. During
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the period of May 1 through June 15, 1982, the inspector walked down
the accessible portions of the Unit 2 Boron Injection and Boric Acid Recirculation Systems; Unit 1 Charging System alignment, and portions of the vital electrical distribution systems to verify operability.
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These reviews and observations were conducted to verify that facility operations were in conformance with the requirement established under Technical Specifications, 10 CFR, and administrative procedures. The inspector also witnessed portions of the radioactive waste system controls associated with radwaste shipments and barreling.
During these observations the inspector identified the following:
Contrary to Technical Specification 3.7.10 which states, "All pene-tration fire barriers protecting safety related areas shall be func-tional at all times"; the inspector observed welding cables blocking open the fire doors to the Unit 1 access to the auxiliary feedwater pipe corridor and the Unit 2 turbine driven auxiliary feed pump room.
These cables had been placed there for a maintenance job, and no personnel were present as a continous fire watch. This is a violation as set forth in the Appendix to the reoort transmittal letter.
(50-315/82-11-02; 50-316/82-11-02)
4.
Surveillance Observation The inspector observed technical specifications required surveil-lance testing on the Unit 1 East Centrifugal Charging Pump, **12 OHP 4030 STP.005; RMS Radiogas Cap Source Calibration, 1 THP 6010 RA594; and Axial Power Distribution Monitoring System Channel Function Test, **12 THP 4030 STP.352; and Unit 2 Steam Generator Water Level Protection Set IV,
- 2 THP 4030 STP.118; Reactor Trip Breaker, 2 THP 4030 STP.044; and Reactor Logic Trains A&B, 2 THP 4030 STP.145, 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:
Unit 1
- 1 OHP 4023.001.001 Alternate Emergency Shutdown and Cooldown Procedure due to Loss of Normal and Preferred l
Alternate Methods.
1 THP 4030 STP.362 Incore/Excore Detector Calibration Unit 2
- 2 THP 4030 STP.117 Steam Generator Water Level Protection Set III Surveillance l
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- 2 THP 6030 IMP 253 Feed Flow Transmitter Protection Set III Calibration.
2 THP 4030 STP.150 Steam Pressure Protection Set III Surveillance
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12 THP 6030 IMP 079 Foxboro Electronic Recorder Calibration (RHR Temperature MR15)
5.
Maintenance Observations Station maintenance 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
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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.
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:
Unit 1
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Repair of Steam Generator #12 Feed Regulator Valve (FMO-202)
1 MHP 5021.003.002 Maintenance Repair Procedure for the Reciprocating Charging Pump
- 12 MHP 5021.003.001 Maintenance Repair Procedure for the Centrifigal Charging Pump (1 "E" CCP)
- 1 MHP SP.043 Special Procedure for repair of the Unit 1
"E" Centrifugal Charging Pump Casing.
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Unit 2 Repair of Seal Leak on 2 "W" Centrifugal Charging Pump.
- 12 MHP 5030.001.002 Maintenance Inspection Procedure of Safety Related Fire Dampers (Control Room Press-urization System).
Review of Licensee's inspection resulta pertaining to the 2 "W" Component Cooling Water Pump bearings.
Repair of the Flow Meter flange leak in Boric Acid to Blender pathway (causing shorting in heat tracing)
Following completion of maintenance on the Unit 1 "E" Centrifugal Charging Pump, the inspector verified that'this system had been returned to service properly.
6.
Licensee Event Reports Followup 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 accomplished in accordance with technical specifications.
Unit 1 R0 82-016-03 Control Room Air Handling Unit Inoperable Unit 2 (Closed) 50-316/82-023/03L-0: Containment Spray Nozzles Obstructed.
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The inspector observed the immediate corrective action of the licensee's representative removing the obstruction on the nozzle. The memo caution-ing plant personnel on obstructing these nozzles and its distribution i
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to plant departments was also reviewed. The licensee has committed l
to performing a visual inspection of Unit 1 spray nozzles during the l
next outage.
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Plant Trip
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Following the Unit i reactor trip on low stator water flow (turbine
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i trip / reactor trip) from 100% power on May 19, 1982, the inspector
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determined the status of the reactor and safety systems by observa-tion of control room indicators and discussions with licensee
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personnel concerning plant parameters and emergency system status.
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The inspector verified the establishment of proper communications and reviewed the corrective actions taken by the licensee.
The trip occurred when plant personnel were making control air system alignment changes in preparation for work on the administration building's air lines. Prints were net used and the valves were not labelled requiring walkdown of the airlines.
The operators inadvertantly valved out the air supply to the transmitter for the indication of " stator water flow" which produced a generator trip.
Following the trip the licensee experienced feedwater regulation valve problems to steam generator 12; when attempts were made to isolate the flow the feedwater isolation valve (FMO.202) was damaged.
The damage caused a 56 hour6.481481e-4 days <br />0.0156 hours <br />9.259259e-5 weeks <br />2.1308e-5 months <br /> reactor startup delay while portions of the valve assembly (FM0 202) were replaced.
The plant was returned to operation at 6:15 p.m. EDT on May 21, 1982 and paralled to the grid at 8:09 p.m. EDT.
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Technical Specification Waiver At 1:14 p.m. on June 4, 1982, the licensee declared the Unit 1 "E" Centrifugal Charging Pump (CCP) inoperable due to high vibration.
Technical Specification 3.5.2 allows 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore operability or requires reactor shutdown. On June 7, 1982 at 1:14 p.m. EDT the licensee received a one hour verbal extention and at 2:14 p.m. EDT they received a requested 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> one time extension of repair time from the Office of Nuclear Reactor Regulation. The inspector followed the maintenance efforts (Paragraph 5) surrounding this pump. On June 9, 1982, the inspector observed the performance of the applicable portion of the Emergency Core Cooling System Operability Test, and the collection of pump curve data. The pump was declared operable at 2:40 p.m. EDT and placed on line for service.
At 4:02 p.m. EDT on June 9, 1982, the pump was again declared inoperable while problems with the shaft driven lube oil pump for the CCP were looked into. The licensee again declared the "E" CCP operable at 10:30 p.m. EDT, approximately 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> before the Technical Specifica-tion time limit expired, after deciding to place the auxiliary oil pump in "run" as needed. The shaft driven oil pump will be repaired in the upcoming Unit 1 outage.
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Design Change Error At approximately 8:30 a.m. EDT on June 8, 1982, the licensee was receiv-
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ing caustic solution for use in the water makeup treatment plant.
Maintenance workers in the area noted excessive gassing coming from the acid tank vent and notified the control operator in charge of the filling operation.
Filling was secured after 3 to 4 minutes and the acid tank temperature-increased to approximately 235
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On investi-gation it was found that the side by side acid and caustic connections
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had been incorrectly labled during a recent plant modification. This modification was installed according to approved design drawings, however, after the event the drawings were discovered to be incorrect.
The system had not been walked down and this was the first addition since the system change had been made. The caustic-acid addition system is not safety related and therefore no item of noncompliance is being issued for this event.
10.
Regional Requests The resident inspector was requested by Region III.to determine the manufacturer of installed bullet resistant fire doors and determine if the licensee had documentation specifically confirming that the
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doors had been tested and approved for fire resistance by a nationally recognized laboratory.
It was determined that the doors were manua-factured by Bullet Proof Equipment Company, Inc.
The licensee, as a result of the inspectors inquiry, obtained the documentation from the manufacturer that specifically confirmed the doors, as supplied, had been tested and approved by a nationally recognized laboratory (Underwriter Laboratory).
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Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1) throughout the month at the conclusion of the inspection and on June 28, 1982. The inspector summarized the scope and findings of the inspection activities. The licensee acknowledged the findings and the receipt of the noncompliance items (Paragraphs 2 and 3) and con-firmed the commitment in paragraph 6.
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