IR 05000315/1988004
| ML17325A625 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 02/18/1988 |
| From: | Ted Carter, Choules N, Jablonski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17325A623 | List: |
| References | |
| 50-315-88-04, 50-315-88-4, 50-316-88-05, 50-316-88-5, NUDOCS 8802230128 | |
| Download: ML17325A625 (10) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-315/88004(DRS);
50-316/88005(DRS)
Docket Nos.
50-315; 50-316 Licensee:
Indiana Michigan Power Company 1 Riverside Plaza Columbus, OH 43216 Licenses No.
D.
C.
Cook Nuclear Plant Units 1 and
Inspection At:
D.
C.
Cook Site, Bridgman, Michigan Corporate Office, Columbus, Ohio Inspection Conducted:
January 19-21, and 27-28, 1988 Inspectors:
Ned C.
Choules Pre F8 Date Theadore H. Cart Da e Approved By:
Frank J.
Ja lo ski, Chief Maintenance and Outages Program Section Date Ins ection Summar Ins ection on Januar 19-21 and 27-28 1988 Re orts No.
50-315/88004(DRS No. 50-316/88005 DRS on previous inspection findings in accordance with inspection Modules 92701 and 92702.
Results:
One violation was identified (failure to perform a safety evaluation, Paragraph 2m).
Of 14 inspection findings and observations reviewed, 14 were closed.
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DETAILS 1.
Persons Contacted American Electric Power Service Cor oration AEPSC)
"M. Alexich, Vice President Nuclear Operations
"P. Barrett, Manager, Nuclear Safety and Licensing
"P. Schoept, Project Engineer, Mechanical Engineering
"S. Steinhart, Assistant Division Manager, Mechanical Engineering,
"B. Sweeney, Section Manager, equality Assurance Indiana and Michi an Electric Com an I 8 MEC
- "W. Smith, Jr., Plant Manager
"*M. Barfelz, Safety and Assessment
""A. Blind, Assistant Plant Manager
- "L. Gibson, Assistant Plant Manager, Technical Support
""B. Svensson, Licensing Activities Coordinator Nuclear Re ulator Commission NRC
""B. Jorgensen, Senior Resident Inspectoi
"Indicates those attending the exit meeting at the AEPSC Corporate Offices in Columbus, Ohio on January 21, 1988.
~"Indicates those attending the exit meeting at the D.
C.
Cook Plant on January 28, 1988.
Other license personnel were contacted as a matter of routine during the inspection.
2.
Licensee Actions on Previous Ins ection Findin s a ~
(Closed)
Unresolved Item (315/85007-02; 316/85007-02):
Corrective action involving AEPSC internal audit gAVP-84-01 regarding nuclear material and fuel management procedures.
Sixteen quality related procedures were scheduled to be prepared or revised, eight of which were verified complete as documented in Inspection Report 50-315/316-85005.
The remaining eight procedures were reviewed by the inspectors.
Six were issued as section or division procedures and two were included in general procedures, all of which were adequate.
This item is close (Closed) Violation (315/85007-05C;. 3l6/85007-05C):
Failure to process condition reports in accordance with Plant Manager Instruction No.
7030.
The licensee's response dated June 14, 1985, indicated the review and closeout of all condition reports was being expedited.
A followup inspection documented in Inspection Report 50-315/316-86043, performed in December 1986, showed a large number of condition reports issued in 1985 and earlier remained open.
The inspectors reviewed the backlog of condition reports issued during 1986 and earlier, and determined that only two condition reports issued during 1985 and earlier, and twelve condition reports issued during 1986 remained open.
It appeared that there were adequate reasons for the condition reports to remain open.
The licensee's control and disposition of condition reports appears to be greatly improved.
This item is closed.
(Closed) Violation (315/85026-02; 316/85026-02):
Failure to take proper corrective action to prevent mixing of swing and piston check valves.
Licensee actions to resolve this issue were described in the response dated December 20, 1985.
Licensee actions were reviewed in June 1987 and the status documented in Inspection Report 50-315/316-87022 which indicated that verification of some limited accessible valves for type and manufacturer remained to be completed.
The licensee completed the inventory and identification of installed check valves.
Valve list drawings were revised to indicate the type of check valves and the manufacturer.
The licensee also included other types of safety related valves during review and update of the valve drawing list.
This item is closed.
(Closed) Violation (315/85026-03; 316/85026-03):
Failure to adequately control Requests for Field Change (RFCs).
The inspectors verified that the licensee had completed the corrective actions described in response to this item dated December 20, 1985.
The licensee improved control of the closeout of RFCs.
The RFC closeout status report and an as built drawing report were issued monthly.
The licensee made progress in the closeout of RFCs and as built drawing revisions.
In January 1987, there were 302 RFCs in closeout, and in January 1988, there were 202.
Since 1984, 1728 drawings had been revised.
In 1984 there were 2760 as built drawings to be revised.
As of December 31, 1987, 1894 drawing were to be revised.
This item is closed.
(Closed)
Recommendation (315/85026-R03; 316/83026-R03):
The relative importance of engineering reviews of RFC's should be recognized and appropriate action taken to ensure timely completion.
This item is closely related to the item discussed in Section d.
The licensee recognized the need for timely engineering reviews and has initiated actions to assure timely completion.
This item is close (Closed)
Unresolved Item (315/85026-04; 316/85026-04):
System misclassified ASME Class III rather the Class II that raised concerns about the adequacy of similar technical reviews.
The inspectors reviewed results of a historical review of 52 RFCs performed in 1985 perfor'med under the guideline established in a document entitled "Design Verification of Past Design Activities Performed In Conjunction With D.
C.
Cook Nuclear Plant."
One of the items included in the review was verification that RFC's specified the applicable codes and standards.
There were no cases where the wrong codes and standards were specified.
This item is closed.
(Closed) Violation (315/86005-02A; 316/86005-02A):
Failure to provide independent design review verification.
The inspectors verified from review of procedure PMI 5040 that the licensee revised the procedure to require post installation verification of all documents utilized during the installation process, as described in the licensee response dated April 28, 1986.
Interviews with engineering personnel indicated that training regarding design review verification had been completed as described in the response.-
(Closed) Violation (315/86005-02B; 316/86005-02B):
Modifications made to steam generators blowdown tanks were not documented on the tank drawing.
The inspectors verified that the tank drawing was revised to show the modifications as described in the licensee response dated April 28, 1986.
The inspectors also verified that a
memorandum was issued to appropriate personnel, as indicated in the licensee response, to reemphasize the need to update drawings when changes were made.
This item is closed.
(Closed)
Unresolved Item (315/86005-06):
Replacement of Unit 1 airlock door seals was beyond the manufacturer's stated life.
As indicated in Inspection Report 50-315/316-86043, replacement of the seals was scheduled for the next Unit 1 refueling outage in May 1987.
The inspectors determined from review of job orders 000576, 000577, 000578 and 000579 that the Unit 1 airlock door seals were replaced during September 1987 with qualified compression seals manufactured from ethylene propylene polydienemers (EPDM).
This item is closed.
(Closed) Violation (315/86019-01; 316/86019-01):
Purchase orders for procurement of services were misclassified as non-safety related.
The licensee's response dated July 10, 1986, described the guidelines to be followed for procurement of services.
These guidelines were issued to all Division Managers, which the inspectors verified had occurred on July 10, 1986.
The inspectors also verified that procurement procedures
PMP 3010 FDC.001 and GPO No. 4.0 were revised to include the guidelines.
The inspectors reviewed three purchase orders for safety related services and verified that proper classifications were made and requirements of the guidelines had been implemented.
This item is close (Closed)
Unresolved Item (315/86019-04; 316/86019-04):
Possible inadequacy in receipt inspection.
The inspectors conducted interviews with two corporate quality assurance personnel to determine the extent of source inspection of purchase order items.
Engineering determines when source inspection is required.
Interviews indicated that some source inspection is performed but not on a broad scale.
The inspector reviewed receipt inspection records at the plant for nine 1987 purchase order items that included motors, clamps for a crane rail, air seals, fuses, expansion joints, pipes, flange elbows and gaskets.
Dimension measurements were made on most items.
Motor insulation was checked and fuses were destructively tested.
Generic receipt inspection specifications for different types of material and equipment had been prepared.
The receipt inspection program appeared to be adequate.
This item is closed.
(Closed) Violation (315/86031-1B; 316/86031-1B):
equal ity assurance records did not show any follow up action -for the release of a shipment of fuses placed on hold.
In response to this item on'ctober 10, 1986, the licensee indicated that the fuses were tested with new measuring equipment after the fuses were placed on hold.
These tests verified the original tests and the hold was lifted in February 1986, based on verbal communication between the vendor and the licensee.
The inspectors reviewed documentation of the tests transmitted from the vendor to the licensee on October 3, 1986.
No problems were identified.
This item is closed.
(Closed)
Open Item (315/86025-04; 316/86025-04):
Installation of a butterfly valve without a Request For Change (RFC).
As discussed in Inspection Report 50-315/316-86025, on May 19, 1985, the licensee replaced the Unit 1 Centerline butterfly containment isolation valve, CCM-451, with a Pratt butterfly valve.
The valve was replaced as a normal maintenance item as documented on job order No.
97850.
As required by Section 5. 2 of PMI 5040,
"Design Change Control,"
Revision 6, an RFC (a design change determined to be safety related)
was not'used because at that time the valve designator did not distinguish between the two valves; therefore, maintenance personnel assumed the valves were identical.
As a result, a documented safety evaluation was not made to determine if there was any difference in weight that could effect the seismic evaluation.
Routine maintenance activities are not normally required to be reviewed according to 10 CFR 50.59 provided that, for example, components are replaced with an identical component.
In many cases, engineering judgement is sufficient to show that a change does not affect safety; however, there should be evidence that all critical and salient aspects of a change were considered and how an evaluator reached the stated conclusion.
If not identical, as a minimum, for
I4
replacement of valves, design parameters such as size, operating time, pressure and temperature, and failure position should have been evaluated.
Failure to submit a RFC for a written safety evaluation of the change from the Centerline butterfly valve to a Pratt butterfly valve on Unit 1 containment isolation valve CCM-451 is a Violation of 10 CFR 50 Appendix B. Criteria V (315/88004-01).
After the change out of the valve was identified in Inspection Report 50-315/316-86025, the licensee completed a seismic review of the Pratt valve on September 5,
1986, and concluded there was no effect on seismic considerations.
On December 9,
1985, the licensee issued instructions requiring AEPSC engineering to perform an evaluation of valve replacements and document the results.
This instruction was issued as a result of the violation discussed in Section 2c.
Also as discussed in Section 2c, the licensee revised valve drawing lists to indicate the type of valve and manufacturer so valves of the same type, but made by a different manufacturer, do not have the same valve designator.
At the time of the inspection, the licensee was in the process of preparing a
minor modification procedure that AEPSC engineering agreed to use in future valve replacements.
The minor modification procedure will require a 10 CFR 50.59 safety evaluation for safety related changes.
Since corrective action for this violation has been completed, no response to this violation is required.
(Closed)
Unresolved Item (315/87002-20; 316/87002-20):
Radiation Protection (RP) records problems.
Four areas of concerns were identified for this item that are discussed below:
(1)
Excessive time to update the RP Record Retention Schedule.
RP revised procedure 12 THP 6010.RA0.700,
"Radiation Protection (RP) Record Retention Schedule and Document Control" to specify steps to take to update the Retention Schedule.
This should improve the time required to update the Retention Schedules.
(2)
Receipt records for sources destroyed or lost.
The licensee searched for source receipt records.
When a record could not be found, the source was disposed and a
new replacement source with receipt records was obtained.
(3)
Calibration records for 14 instruments not listed on RP Records Retention Schedule.
The inspectors verified from review of the current Records Retention Schedule that the 14 instruments had been added to the schedul (4)
Record not sent to the records storage vault on time.
This problem was caused'hen the Environmental and Radiation
.
Protection group was divided into separate groups.
The Record Retention Schedule inadvertently indicated both groups were to send the same records to the vault.
The Record Retention Schedule has been revised to correct this problem.
The above items were identified by the licensee guality Assurance department on Condition Reports.
These Condition Reports were closed.
guality Assurance plans to perform an audit in the Radiation Protection records area within the next six months to verify implementation of proposed corrective action.
This item is closed.
0.
The areas examined during this inspection primarily included follow-up of matters in the broad areas of corrective action, procurement, design interfaces,,
and work control processes.
Based on results of the inspection it was concluded that:
The violation described in 2m was not significant because system safety was not compromised.
~
Management involvement and control in assuring safety was greatly improved in the areas of corrective action, and design interfaces.
~
Management's approach to resolution of technical issues from a safety stand point was generally responsive and technically sound.
Significant improvements were noted in the control of condition reports and requests for change.
One violation was identified.
Exit Interview I
The inspectors met with licensee representatives (denoted in Paragraph 1)
at AEPSC Offices in Columbus, Ohio on January 21, 1988, and at D.
C.
Cook on January 28, 1988, and summarized the purpose and findings of the inspection.
The inspectors discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection.
The licensee did not identify any such documents or processes as proprietary.