IR 05000315/1986008

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Insp Repts 50-315/86-08 & 50-316/86-08 on 860219-0331. Violation Noted:Failure to Properly Post Contaminated Area. on 860402,licensee Provided Documentation of Corrective Actions.Corrective Action Acceptable & Item Closed
ML17324A781
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 04/16/1986
From: Burgess B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17324A779 List:
References
50-315-86-08, 50-315-86-8, 50-316-86-08, 50-316-86-8, NUDOCS 8604230280
Download: ML17324A781 (20)


Text

U.S.

NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-315/86008(DRP);

50-316/86008(DRP)

Docket Nos.

50-315; 50-316 Licensee:

American Electric Power Service Corporation Indiana and Michigan Electric Company 1 Riverside Plaza Columbus, OM 43216 Licenses No. DPR-58; DPR-74 Facility Name:

Donald C.

Cook Nuclear Power Plant, Units 1 and

Inspection At:

Donald C.

Cook Site, Bridgman, MI Inspection Conducted:

February 19 through March 31, 1986 Inspectors:

B.

L. Jorgensen J.

K. Meller C.

L. Wolfsen Approved By:

.

L. Burges

, Chief Reactor Projects Section 2A Date Ins ection Summar Ins ection on Februar 19 throu h March 31 1986 Re orts No. 50-315/86008 DRP No. 50-316/86008 DRP Areas Ins ected:

Routine unannounced inspection by the resident inspectors of licensee actions on previously identified items; operational safety verification; surveillance; maintenance; reportable events; management meeting; Part 21 reports; and, preparation for refueling.

The inspection involved a total of 296 inspector-hours by three NRC inspectors including 40 inspector-hours during off-shift and an additional 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> for the management meeting.

Results:

Of the nine areas inspected, no violations or deviations were identified in eight areas.

One violation ( Level IV - failure to properly post a contaminated area, Paragraph 3.d)

was identified in the remaining area.

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DETAILS 1.

Persons Contacted a.

Inspection:

February 19 through March 31, 1986

  • A. Blind, Acting Plant Manager B. Svensson, Assistant Plant Manager T. Kriesel, Technical Superintendent, Physical Sciences J. Allard, Maintenance Superintendent K. Baker, Operations Superintendent J. Stietzel, Quality Control Superintendent
  • T. Bei lman, Planning Supervisor L. Gibson, Technical Superintendent, Engineering J.

Sampson, Operations, Production Supervisor D. Wizner, Maintenance, Production Controller

"M. Horvath, Quality Assurance Supervisor P.

Leonard, Administrative Compliance Coordinator, QC

"R. Clendenning,'adiation Protection Supervisor

"J. Fryer, Environmental Supervisor

  • T. Postlewait, Performance Supervisor
  • R. Kroeger, Q.A. Manager The inspector also contacted a number of other licensee and contract employees and informally interviewed operations, maintenance, and technical personnel.
  • Denotes personnel attending exit interview Apri 1 4, 1986.

b.

Management Meeting:

March 7, 1986 American Electric Power J.

E. Dolan, Vice Chairman, Engineering and Construction M. P. Alexich, Vice President, Nuclear A. A. Blind, Acting Plant Manager J.

G. Feinstein, Manager, Nuclear Safety and Licensing R.

F. Kroeger, Manager, Quality Assurance Several other members of the plant and corporate staffs were in attendance U.

S. Nuclear Re ulator Commission J.

G. Keppler, Regional Administrator, Region III E.

G.

Greenman, Director, Division of Reactor Projects B. J.

Youngblood, Director, PWR Project Directorate P4, NRR D.

L. Wigginton, Licensing Project Manager, NRR C.

W. Hehl, Chief, Projects Section 2A B.

L. Jorgensen, Senior Resident Inspector, D.

C.

Cook J.

K. Heller, Resident Inspector, D.

C.

Cook

I AU

2.

Licensee Actions on Previousl Identified Items a.

(Open) Violation (316/83004-01)

and Open Itern (316/83004-04)

as updated in Inspection Reports No. 316/85016(DRP)

and No. 316/85022(DRP):

The test program could not demonstrate Containment Spray Additive System operability.

By letter (AEP:NRC:0944C) dated February 28, 1986 from IMEC (Alexich) to NRR (Denton) the licensee requested deletion of the Spray Additive Tank from the Technical Specifications.

Included with the request was the vendor analysis for deletion of the Spray Additive Tanks.

This item will be closed when NRR approves the AEP request.

(Open) Violation (315/86005-04):

Failure to perform a safety review of temporary modifications prior to installation; specifically, temporary modifications consisting of installation of herculite over the diesel generator ventilation damper, wiring the dampers open, and lifting leads to the damper motors for Unit 1 AB and CD diesel generator rooms.

The safety evaluation was performed at the Plant Nuclear Safety Review Committee (PNSRC) meeting No.

1867 on February 14, 1986.

The meeting determined these temporary modifica-tions did not constitute an unreviewed safety question as defined in

CFR 50.59.

Also, the licensee has been unable to obtain qualified replacement damper motors, but will expedite a permanent design change as soon as the motors become available.

C.

(Closed)

Open Item (315/86004-04):

In 1983 the load sequencing time was omitted for a Containment Spray Pump.

The requirement to include the load sequencing time when determining the lE Containment Spray Pump ESF response time was marked "N/A" because the appropriate steps in a referenced document were not performed.

Failure to include load sequencing time would normally be a violation, however the inspector found that a Safety Injection and Blackout Sequencer Agastat Timer Calibration (**12THP 6030 IMP.160), for the subject containment spray pump, was performed at about that time.

Using the as-left data the inspector was able to verify that the ESF response time for the 1E Containment Spray Pump was satisfactory.

The inspector reviewed PMI 6040, Revision 3 "Performance/Engineering Test Procedure" and found that appropriate administrative controls are now in effect to assure that an "N/A" is not incorrectly used.

No violations or deviations were identified.

3.

0 erational Safet Verification a.

The inspector observed control room operation including manning, shift turnover, approved procedures and Limiting Condition for Operation (LCO) adherence, and reviewed applicable logs 'and conducted discussions with control room operators during the inspection period.

Observations of-the control room monitors, indicators, and recorders were made to verify the operability of

emergency systems, radiation monitoring systems, and nuclear and reactor protection systems, as applicable.

Reviews of surveillance, equipment condition, and tagout logs were conducted.

Proper return to service of selected components was verified.

Tours of the auxiliary building, turbine building, Unit 2 containment building, and screenhouse were made to observe accessible equipment conditions, including fluid leaks, potential fire hazards, and control of activities in progress.

Unit 1 operated routinely at approximately 90 percent power throughout the inspection period.

The inspector performed a

walkdown and review of accessible portions of the Unit 1 Auxiliary Feedwater System (AFS) using Licensee Drawings OP-1-5106A and OP-12-5106A and Procedure 1-OHP 4021

~ 056.001 "Filling and Venting Auxiliary Feedwater System and Placing System in Standby Readiness."

Correct flowpath valve positions were verified and no condition was noted which degraded the system or its major components.

Unit 2 operated at approximately 80 percent power at the beginning of the inspection period and commenced a refueling/maintenance/EEg outage on February 28, 1986 at 2136 hours0.0247 days <br />0.593 hours <br />0.00353 weeks <br />8.12748e-4 months <br />.

Outage duration is estimated at 90 days.

Prior to shutdown on February 28, 1986, with the reactor in Mode 1, portions of Procedure 2-OHP 4021.008.002

"Placing the ECCS in Standby Readiness" were used to verify remote operated valve positions in the control room for the Safety Injection and Residual Heat Removal systems.

No discrepancies were observed.

On March ll, 1986, with Unit 2 in Mode 5, the NRC was notified of multiple ESF actuations.

The inspector reviewed the subject Condition Report No. 2-03-86-290.

The initial event was caused by shorted control power wires in a nuclear instrumentation power range drawer N41A.

The second challenge occurred when the shorted wires were disconnected and taped, and the third ESF challenge resulted when the Control Room Instrument Distribution (CRID) IV breaker was inadvertently tripped and reset instead of CRID I'his was due to inadequate labeling of the GRID's, which has been corrected.

Further review will be completed pending receipt of the Licensee Event Report (LER) due April 9, 1986.

During a tour of the 650 foot level of the auxiliary building on March 4, 1986 at approximately 1445 hours0.0167 days <br />0.401 hours <br />0.00239 weeks <br />5.498225e-4 months <br /> the inspector found a

partially enclosed contaminated area by the glycol pumps.

When entering from the center stairway, passage was blocked by a barrier, but when coming from the South stairway via the ice machine room there was neither a barrier nor step off pad.

Discussion with the Radiation Protection Supervisor revealed that the area was a

contamination area and had been inadequately established.

The licensee's initial actions were to properly post the area and initiate Radiological Deficiency Report 86-17 I e

Licensee Procedure

THP 6010.RAD.404, "Establishing Posted Areas,"

stipulates that barriers and rope should be located such that there will be no normal access from a posted area to an unposted area (Paragraph 6.4.7)

and that a step off pad be constructed at each entrance (Paragraph 6.4.8).

Unit 1 and 2 Technical Specifications 6.8. l.a require written procedures shall be established, implemented and maintained concerning the activities recommended in Appendix "A" of Regulatory Guide 1.33, November 1972.

Appendix "A," Section G

requires

"Procedures for Control of Radioactivity."

THP 6010 RAD.404 addresses this requirement.

Failure to implement

THP 6010 RAD.404 as described above is a violation of Technical Specification 6.8. l.a (Violation 315/86008-01; 316/86008-01).

On April 2, 1986, the licensee provided the inspector with documentation of corrective actions and actions to prevent recurrence which included formal reprimand of the technician involved in the posting inadequacy and a letter to all Radiation Protection personnel describing the incident and steps to be taken to prevent recurrence.

The concerns addressed were the timeliness of posting, po'sting in accordance with procedures, and posting deficiencies.

The licensee's corrective action appears adequate to resolve the violation.

The inspector has no more questions pertaining to the violation.

As such, no response to the violation is requested, and this item is considered closed.

e

~

New component identification tags are being installed to more adequately identify equipment, piping, valves, etc..

These seem to be a "plus" in the Regulatory Improvement Program, except the inspector found that some of the tags have already been altered with

"magic markers."

The altered tags were on root and isolation valves for Barton transmitters located in the Unit 1 Non Essential Service Water (NESW) valve gallery.

This was discussed with the Operations Superintendent.

These reviews and observations were conducted to verify that facility operation was in conformance with the requirements established per Technical Specifications, 10 CFR, and Administrative Requirements.

One violation and no deviations were identified.

4.

Surveillance The inspector reviewed Technical Specifications required surveillance testing as described below 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 properly 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 deficiencies identified during the testing were properly reviewed and resolved by appropriate management personnel.

a.

Miscellaneous Review of the test data and observation of the performance of all or part of the following tests were completed:

"~12 THP 4030 STP.227

~*1 OHP 4030 STP.007E

    • 1 OHP 4030 STP.007W

"Multiple Entry Personnel Airlock Leakage Surveillance Test."

"East Containment Spray Pump Operability."

"West Containment Spray Pump Operability."

"*12 THP 6030 IMP.160

"Safety Injection and Blackout Sequence Agastat Timer Calibration."

""2 THP 4030 STP.203

"Type "B" 8 "C" Leak Rate Tests."

"AFW Data Gathering" The inspector reviewed completed Unit 1 test data for

  • "12 THP 6030 IMP.160, performed July 1982, May 1983, and February 1985.

The inspector verified that the data meets the acceptance criteria and that the acceptance criteria meets the appropriate Technical Specification.

No major problems were found, however the February 1985 test used a data sheet from a previous revision of IMP 160'his was discussed at the management interview b.

Local Leak Rate Testin The licensee performed Local Leak Rate Testing (LLRT) on Containment Penetration Boundaries (CPB)

and Containment Isolation Valves (CIV)

using Procedure

    • 2 THP 4030 STP.203

"Type "B" 5 "C" Leak Rate Tests."

The inspector observed several portions of the test; reviewed the procedure, data sheets, and Job Orders; verified that the tests were performed at Pa (12 psig);

and, that when penetrations exceeded the cumulative maximum allowable leak rate of 0.60 La they were reported as unacceptable.

On March 15, 1986 at 1530 hours0.0177 days <br />0.425 hours <br />0.00253 weeks <br />5.82165e-4 months <br /> the licensee identified leakage in excess of 0.60 La past check valve 2-CS-321, "Unit 2 normal charging header outboard isolation valve."

Repairs and additional testing are continuing.

The Tests observed were:

Step 061 Ice Condenser Air Handler Unit Drai Step 062 CLV and CUV Drain Header.

Step 063 RCDT Drain Header Step 068 RHR Recirculation

"E" Step 069 RHR Recirculation

"W" Step 072 Refueling Cavity Drain Step 073 Hot Leg Sample Line.

Step 076 Pressurizer Relief Tank Sample.

Step 121 Post Accident Sampling Supply.

The calibration frequency of the Leak Rate Monitor (LRM) flow meters (five years)

was questioned since they are portable and appear subject to damage during transportation.

Plant ATE equipment calibration requirements specify the five year frequency based on reliability of the meters.

The inspector noted that ANSI/ANS 56.8-1981

"Containment System Leakage Testing Requirements,"

recommends calibration of the LRM no more than six months before the LLRT.

The licensee is not committed to this ANSI standard.

The inspector also noted that post calibration of the equipment (after the LLRT tests are complete) is not a requirement, but would appear to be a good engineering practice.

These items were discussed at the exit interview.

It was also noted that the LRM had been calibrated with Teflon tape in place to secure some of the fittings.

This was questioned, since the LLRT procedure now restricts the use of Teflon Tape.

The licensee advised that the procedure does not require removal/replacement of previously installed Teflon Tape, as was the case here.

No violations or deviations were identified.

5.

Maintenance Station maintenance activities of safety-related systems and components listed below were 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 post maintenance testing ("B" & "C" Leak Rate Testing)

was performed as applicabl P

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The following maintenance activities were reviewed:

Unit

JO 93791 (File:ME-VCR-ECR-31)

JO 96073 (Fi le: ME-VCR-ECR-31)

JO 97830 (File:ME-VCR-ECR-31 and 32)

JO 97833 (File:ME-VCR-VCR-103)

JO 99849 (File:ME-VCR-VCR-103)

JO 97829 (File:ME-VCR-ECR-33 and 35.

Investigate excessive closing time of 1-ECR-31 Remove VCR-103 and transport to machine shop for modifications and then reinstall.

Repair excessive leakage for valves ECR-31 and ECR-32.

Repair excessive leakage for valves VCR-103 and and 203.

Investigate excessive closing time of VCR-103.

Repair excessive leakage for valves ECR-33 and ECR-35.

JO 97844 Repair excessive leakage for valves ECR-417.

(Fi 1 e: ME-VCR-ECR-417)

Unit 2 JO 35327 (File:ME-VCR-VCR-202)

JO 43302 (File:ME-VCR-VCR)

JO 35332 (File:ME-VCR-VCR-204)

Modify valve VCR-202 per RFC-DC-12-2877.

Inspect VCR-105, 202, 204 and 205.

Modify valve VCR-204 per RFC-DC-12-2877 The inspector found minor documentation problems.

First, Job Order (JO)

93791 identifies that l-ECR-31, "Containment Isolation Valve-Containment Airborne Radiation Monitor," had excessive closing times.

The repairs included replacement of some internal components.

The retest included stroke timing but did not indicate that the appropriate

"B" 5 "C" Leak Rate Test was performed.

In fact, the supplemental Job Order (JO)

was marked "H/A."

The supplemental JO, as described in PMI 2290,

"Job Orders," is utilized when assistance from another department is needed.

The inspector discussed this with the cognizant Performance Engineer for "B" 5 "C" Leak Rate Testing and found that a separate Job Order (JO 100262)

was written to perform the testing.

In this case the appropriate testing was done; however, the paper trail proving operability is not clea Secondly, the block in the lower right hand corner of the JO provides a

date/time for job completed, operability, verification, and return to service.

For most of the JO's reviewed, the space was marked "N/A."

For some of the JO's reviewed the "N/A" was appropriate; however, for JO 99849 "N/A" does not appear appropriate.

JO 99849 was written because 1-VCR-103 "Purge Supply Air To Lower Containment" had excessive closing times.

The repair involved installation of a guick Exhaust Valve.

After the repair the valve was stroked satisfactorily and was returned to service.

However, the block was marked "N/A."

These examples were discussed at the exit interview.

No violations or deviations were identified.

Re ortable Events Through direct observation, discussions with licensee personnel, and review of records, the following Licensee Event Reports (LERs) were reviewed.

The review addressed compliance to reporting requirements and, as applicable, accomplishment of immediate corrective action.

If indicated "closed," the review showed appropriate corrective action to prevent recurrence had been accomplished in accordance with applicable requirements.

(Closed)

LER 315/85010-00:

Dose Equivalent Iodine 131 in excess of Technical Specification limits following a controlled shutdown.

Evalua-tion of reporting requirements concluded that this report was not mandatory.

Review of the technical aspects of the event has been completed and will be documented in Inspection Reports No. 50-315/86009(DRS);

No. 50-316/86009(DRS).

An updated LER 315/85010-01 (3/20/86) reported that corrective action, including fuel sipping, had been performed during the Unit 1 ten year ISI/refueling outage.

Twenty three leaking fuel assemblies were identified and replaced.

All current Cycle 9 data indicated that the action taken resolved the iodine spiking which occurred during Unit 1 Cycle 8 operation.

This item is considered closed.

No violations or deviations were identified.

Mana ement Heetin A management meeting was held on March 7, 1986 at the Donald C.

Cook Plant site.

The licensee scheduled the meeting to discuss the SALP response (Inspection Reports No. 50-315/85001; No. 50-316/85001)

and describe non-regulatory programs that will help improve plant performance.

A brief tour of the Auxiliary Building, Control Room, and Turbine Building was conducted.

Attendance at the meeting was as described in Paragraph 1.b above.

Part

Re ort (Open) Part 21 (315/86002-PP; 316/86002-PP):

Limitorque motor operators.

IE Information Notice 86-03 was written to alert licensee of potential generic problems regarding environmental qualification of electrical

wiring used in Limitorque motor valve operators.

In response to this Notice the licensee initiated a program, using Procedure 12-MHP-SP-107, to verify the wiring of the Limitorque valves.

The inspector reviewed 12-MHP-SP-107 and accompanied maintenance personnel as they verified the wiring for 2-IMO-210 and 2-IM0-211, "Containment Spray Pump Discharge Valves," and 2-IM0-911, "Charging Pump Suction From the RWST."

The licensee's program appears to address the concerns of the Notice This item is being left open pending review by Region III environmental qualification specialists.

(Open) Part 21 (315/86003-PP; 316/86003-PP):

Consolidated Pipe and Valve Supply Company has indicated there may be a problem with materials supplied to the Midland and Donald C.

Cook Nuclear Power Stations.

Executives at Golden Gate Forge and Flange (a subcontractor of Consolidated)

have been indicted and charged in Federal Court for falsifying material/test certifications.

The inspector discussed this Part 21 with plant personnel and found that:

a.

Consolidated Pipe and Valve Supply Company has provided.the licensee with a list of components supplied to D.

C.

Cook.

b.

The licensee has determined the disposition of the components.

c.

The licensee has a contract with CONAN to determine the composition of the components.

Initial review indicates that the composition of these component was as specified on the purchase order.

d.

A number of components have been installed.

The components of greatest interest are those located on the Unit 1, Loop 3, Cold Leg RTD manifold line vent.

The licensee has determined that Unit 1 may continue to operate.

The PNSRC meeting minutes documenting this justification may be reviewed at a later date.

e.

The licensee has not determined if the installed components must be replaced.

f.

The licensee has contacted other qualified suppliers to determine if Golden Gate was a subcontractor and may have been a supplier.

The inspector has provided this information to Region III DRP management, and Region V OI investigators.

No violations or deviations were identified.

9.

Pre aration For Refuelin The inspector verified that the licensee had established:

a.clear definition of lines of supervision; requirements for shift manning; training and qualification of key refueling personnel; quality control accountability; and, radiation monitoring and radiological controls.

The licensee also established controls for maintaining shutdown margin and

reactivity monitoring, radiation moni toring, decay heat removal, and containment integrity.

Further inspection coverage will be ongoing during the core unload and refueling activities.

The SALP 5 report (Inspection Reports No. 50-315/85001; No. 50-316/85001)

documented that some bundles in the Spent Fuel Pool (SFP) were mispositioned.

The root cause appeared to be the SFP fuel handling machine indexing indicators.

The existing indexer had two similar indicators, one marking the original and the other marking the modified (high density)

storage rack location.

The initial corrective action was to make the desired indicator more pronounced, which was done.

The inspector reviewed the modification and felt confusion could still occur because two indexing indicators still existed.

After reevaluation, the licensee removed the second indicator.

This subsequent corrective action appears acceptable.

The inspector noted, during inspection of the SFP bridge crane, that temporary bracing held in place by C-clamps was still installed.

The bracing was used to increase stiffness during removal and replacement of the bridge, but is not to remain installed during fuel handling with the bridge crane.

The Maintenance Department was notified and they removed the braces and clamps prior to the start of fuel handling.

No violations or deviations were identified.

10.

Mana ement Interview The inspector met with the licensee representatives (denoted in Paragraph l.a above) following completion of the inspection on April 4, 1986.

The inspector summarized the scope and findings of the inspection as described in these details.

a.

One apparent Violation was specifically discussed (Paragraph 3.d)

b.

Documentation discrepancies noted in review of completed surveillance (Paragraph 4.a)

and maintenance (Paragraph 5)

activities were discussed.

c.

Calibration practices relating to Leak Rate Monitor instrumentation were discussed (Paragraph 4.b).

The inspector asked those in attendance whether they considered any of the items discussed to contain information exempt from disclosure.

No items were identified.

A