IR 05000315/1988014
| ML17325A856 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 06/21/1988 |
| From: | Burgess B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17325A854 | List: |
| References | |
| 50-315-88-14, 50-316-88-16, NUDOCS 8807060364 | |
| Download: ML17325A856 (34) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-315/88014(DRP);
50-316/88016(DRP)
Docket Nos.
50-315; 50-316 Licensee:
Indiana and Michigan Electric Company 1 Riverside Plaza Columbus, OH 43216 Licenses No.
Donald C.
Cook Nuclear Power Plant, Units 1 and
Inspection At:
Donald C.
Cook Site, Bridgman, Michigan Inspection Conducted:
April 26 through June 13, 1988 Inspectors:
B.
L. Jorgensen J.
K. Heller B.
M. Stapleton
~ / ~iMcr Approved By:
ruce L. Burgess, Ch ef Reactor Projects Section 2A Date Ins ection Summar Ins ection on A ril 26 throu h June
1988 Re orts No.
50-315/88014(DRP
~/
of:
actions on previously identified items; plant operations; radiological controls; maintenance; surveillance; fire protection', security; outages; reportable events; Bulletins and Notices; NRC Region III requests; training and qualification effectiveness; management meeting; and meeting among NRC and community leaders.
One Safety Issues Management System (SINS) item (Bulletin 88-01, Multi-plant Action MPA No.
B100 - see Paragraph ll) was reviewed during this inspection.
8807060364 880622 PDR ADOCK 05000315
Results:
Of the 14 areas inspected, no violations or deviations were identified in 13 areas.
One violation was identified (failure to follow procedure, Paragraph 6.f) in the remaining area.
Miscellaneous minor weaknesses were noted which had in common the fact they involved cleanly "wrapping up" activities (e.g.,
complete/accurate paperwork, jobsite cleanup and hurrying at step-off pads).
A strength noted during the inspection was timely management involvement in items identified as problems or potential problems, such as ALARA re-examination of ongoing jobs, thorough upgrade of a weak maintenance procedure, and strong pursuit of maintenance observations (pump bearing/oil)
and testing questions (thimble tubes, seismic monitors, and trevitest method).
DETAILS 1.
Persons Contacted a.
Ins ection of A ril 26 throu h June
1988 A'W A'A A'J B.
kJ E.
T.
AJ
L.
M.
D.
JcJ*J Smith, Jr., Plant Manager Blind, Assistant Plant Manager, Administration Rutkowski, Assistant Plant Manager, Production Gibson, Assistant Plant Manager, Technical Support Svensson, Licensing Activity Coordinator Baker, Operations Superintendent Sampson, Safety and Assessment Superintendent Morse, equality Control Supervisor Beilman, 18C/Planning Superintendent Droste, Maintenance Superintendent Postlewait, Technical Superintendent, Engineering Matthias, Administrative Superintendent H'orvath, equality Assurance Supervisor Loope, Radiation Protection Supervisor Wojcik, Technical Superintendent, Physical Science Kauffman, Construction Manager The inspector also contacted a number of other licensee and contract employees and informally interviewed operations, maintenance, and technical personnel.
"Denotes some of the personnel attending Management Interview on June 14, 1988.
b.
Mana ement Meetin of Ma
1988 U.S.
Nuclear Re ulator Commission Re ion III A.
B.
H. J.
J.
J.
F.
W.
B.
L.
J.
K.
H.
A.
W. J.
R.
C.
Davis, Regional Administrator Miller, Director, Division of Reactor Safety Harrison, Chief, Engineering Branch Jablonski, Chief, Maintenance and Outage Section Burgess, Chief, Projects Section 2A Heller, Resident Inspector Walker, Reactor Inspector Kropp, Reactor Inspector Kazmar, Project Inspector (2)
Indiana Michi an Power Com an D. Williams, Jr., Senior Executive Vice President M. Alexich, Vice President, Nuclear Operations R. Kroeger, Manager, guality Assurance P. Barrett, Manager, Nuclear Safety and Licensing
c.
Meetin with Communit Leaders on June
1988 (1)
U. S
~ Nuclear Re ulator Commission C. J. Paperiello, Deputy Regional Administrator R. Lickus, Office of State Affairs B.
L. Burgess, Chief, Reactor Projects Section 2A B.
L. Jorgensen, Senior Resident Inspector J.
K. Heller, Resident Inspector J.
F. Stang, Licensing Project Manager, Headquarters R.
C.
Kazmar, Project Inspector B.
W. Stapleton, Regional Administrator Staff (2)
Communit Officials Approximately 20 Community Officials attended, primarily representing Berrien County (health and law enforcement/
safety)
and Lake Charter Township.
2.
Actions on Previousl Identified Items 92703)
a.
Closed Confirmator Action Letter Item (315/88012-05 316/88014-05:
Analysis of the Unit 1 Turbine Driven Auxiliary Feedwater Pump outboard bearing oil for evidence of contaminants.
This was done and documented in Security Event Report No. 315/88002, Revision 1.
The licensee concluded that contaminants were not present in the oil and that no major degradation of the oil occurred.
b.
(Closed Confirmator Action Letter Item 315/88012-06.
316/88012-06:
Within 30 days provide an update to Region III on the specified inspections and on analysis of contaminants in the oil.
The licensee's inspection and analysis are documented in Security Event Report No. 315/88002, Revision 0, dated May 4, 1988, and Revision 1, dated May 27, 1988.
The inspector noted the Security Event Report (SER)
numbers above duplicate Licensee Event Report (LER) numbers.
This is not as recommended in NUREG 1103 "Security Event Reports."
The licensee was asked to assure that future SERs and LERs have unique numbers.
No violations, deviations, unresolved or open items were identified.
3.
0 erational Safet Verification 71707 71710 42700)
Routine facility operating activities were observed as conducted in the plant and from the main control rooms.
Plant startup, steady power operation, plant shutdown, and system(s)
lineup and operation we'e observed as applicable.
Weekly tours were conducted with plant management.
The performance of licensed Reactor Operators and Senior Reactor Operators, of Shift Technical Advisors, and of auxiliary equipment operators was observed and evaluated including procedure use and
adherence, records and logs, communications, shift/duty turnover, and the degree of professionalism of control room activities.
Evaluation, corrective action, and response for off normal conditions or events, if any, were examined.
This included compliance to any reporting requirements.
'bservationsof the control room monitors, indicators, and recorders were made to verify the operability of emergency systems, radiation monitoring systems and nuclear reactor protection systems, as applicable.
Reviews of surveillance, equipment condition, and tagout logs were conducted.
Proper return to service of selected components was verified.
a 0 Unit 1 operated routinely throughout the inspection period, typically at its administratively controlled power limit of 90-percent.
Early in the period, attempts to locate suspected condenser leakage (elevated chloride was present in secondary plant samples)
led to some reduced-power operations.
The chloride indications were ultimately found to be a consequence of back leakage from another system into the sampling line rather than being representative of a chloride problem in the secondary system as a whole.
b.
Unit 2 continued its scheduled refueling, testing and maintenance outage (including steam generator replacement)
throughout the inspection period.
Inspector review of a variety of Unit 2 activities is documented in Paragraph 9, "Outages."
c.
A system walkdown was conducted on the Unit 1 CD Emergency Diesel Generator Start Air using Valve Lineup Sheet No.
of Procedure 1-OHP 4021.037.004.
No violations, deviations, unresolved or'open items were identified.
Radi ol o ical Controls 71709 During routine tours of radiologically controlled plant facilities or areas, the inspector observed occupational radiation safety practices by the radiation protection staff and other workers.
Effluent releases were routinely checked, including examination of on-line recorder traces and proper operation of automatic monitoring equipment.
Independent surveys were performed in various radiologically controlled areas.
a 0 The inspector performed an independent survey of a radwaste shipment (spent resin cask)
on May 2, 1988.
Licensee activities in collecting contamination
"smears,"
surveying, securing and labeling'he shipment were observed.
The inspector's survey results indicated compliance with applicable transportation requirements and were in good agreement with licensee survey results'
Subsequently, the inspector reviewed selected shipping papers for this shipment (No.
RH-88-2) against requirements of the licensee's Procedure
PMP 3150 PCP.001 "Radiological Waste Shipment Check Off Sheet."
No problems were noted.
b.
During a tour of th'e Auxiliary Building on May 3, 1988, the inspector found that the Radiation/Contamination Status Sheet posted at the Unit 2 591-foot vestibule door did not accurately'eflect the location of the contamination boundary line in the room.
This was discussed with the auxiliary building job coverage radiation protection technician who had the status sheet revised.
On May 11, 1988, the inspector attended part of a licensee
"As Low As Reasonably Achievable" (ALARA) committee meeting, where routine business (review/approval of job plans and plan scope changes)
was followed by discussion of methods for minimizing personnel contamination (per-con) incidents.
One area of focus was step-off pad practices, since poor practices were suspected to cause or contribute to some per-cons.
The inspector had noted a few instances of hurrying or carelessness at step-off pads during routine tours, but the frequency of per-cons in 1988 remains less (by about a third) than in 1987.
Another ALARA meeting was attended on June 1, 1988.
This meeting re-examined the scope and controls relating to removal of the lower reactor vessel internals from the vessel and placement on the storage stand.
A misalignment had occurred in the initial attempt to place the internals and the alignment guide on one side of the lifting rig was damaged.
The inspector noted a challenging discussion of options was conducted and reasonable controls were established for proceeding with repairs.
d.
On May 11, 1988, the inspector observed an unattended portable radiation monitoring instrument (survey meter)
on a stair landing two flights above the Unit 2 upper containment personnel airlock.
Two individuals were observed to be working on a suspended platform below and north of this landing, some 10 and 20 feet away, respectively.
When questioned, the individuals acknowledged they had brought the survey meter into containment.
They were installing component identification tags on a variety of items in various areas of the upper containment, such that they were working in a variety of radiation levels, from less than 5 mRem/hr to about 50 mRem/hr (at the time, the reactor vessel head was off and "shine" from the exposed upper internals was causing generally elevated radiation especially in line-of-sight areas).
The workers had been informed what approximate radiation levels existed on the stairs, and they knew their Radiation Work Permit (RWP) number, but they did not understand the RWP specification "Portable Survey Meter Required,"
and they did not know the radiation levels on the platform where they were working.
This matter was referred to NRC Region III radiation specialists who were onsite for inspection during this time period - 'reference Inspection Reports No. 50-315/88011(DRSS);
50-316/88013(DRSS)
.
No violations, deviations, unresolved or open items were identifie \\
5.
Maintenance 62703 42700 Maintenance actsv)tres sn the plant were routinely inspected, including both corrective 'maintenance (repairs)
and preventive maintenance.
Mechanical, electrical, and instrument and control group maintenance activities were included as available.
The focus of the inspection was to assure the maintenance activities reviewed 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 was performed as applicable.
The following activities were inspected:
Job Order JO 710939:
Replace Valve 2-FMO-241.
This valve is one of 16 original Lunkenheimer gate-type valves in the auxiliary feedwater injection lines (eight valves per Unit) being replaced by Hammel Dahl globe-type valves per Design Change RFC-DC-12-2903.
The inspector observed a guality Control "hold point" inspection associated with authorizing continuation of repair of a previously rejected weld.
Procedure
""12 MHP 5050.SPC.002,
"Identification, Removal and Repair of Subsurface Conditions and Subsurface Indications" (Rev.
4 dated June 20, 1987)
was the governing procedure; it was present at the job site and was being carefully adhered to.
b.
Job Order 710940:
Replace Valve 2-FMO-242.
This valve is another of the eight Unit 2 valves being replaced under the design change referenced above.
The valve is a motor-operated valve which, according to workmen at the job site, had to have its motor-operator rotated 180-degrees to correct interference between the motor (as supplied)
and a concrete support column adjacent to the piping.
The inspector questioned the Design Change Coordinator (DCC) concerning how this apparent design deviation was handled.
The DCC showed (via Drawings C.0.-1-5504-6, Revision 6 dated November 13, 1987, and C.0.-2-5504-4-1, Revision 4-1 dated February 25, 1987) that the potential interference had been. previously, recognized and the design was developed with the motor oriented (in four cases
- two per Unit)
to prevent it.
The reorientation was to conform to the design change rather than deviate from it.
Documentation was also provided to show the manufacturer s concurrence (Limitorque Corp.) in the reorientation and to describe the procedure and mounting bolt re-torquing values.
Job Order 761910 705683 and 761911:
Implement Design Change RFC-DC-12-2997.
These activities each involved security door upgrades; typically, welding strengtheners into doors.
The "Welding Burning, Grinding (WBG) Permits" were specifically reviewed against administrative requirements with no problems noted.
Subsequently,
Cl
licensee Fire Protection Section personnel identified a failure to comply with the WBG permit for JO 761910 and initiated Condition Report/Problem Report No.88-299 for corrective action.
Further, a heavy tool. later found in the area of JO 76199 may have been left behind on completion of work - see Paragraph 8 "Security." If so, this is contrary to procedural requirements to clean up thoroughly after every job.
Job Order 002269:
Repair/Replace IE motor driven auxiliary feedwater pump room ventilation fans.
The inspector specifically verified compliance to administrative controls for scaffold design, review, approval and installation no problems were noted.
Job Order 017623:
Rebuild/replace 2W essential service water (ESW)
pump.
This activity is governed by Procedure
"*12 MHP 5021.019.001,
"Maintenance Repair Procedure'or ESW Pump," Revision 7, dated July 2, 1987.
This extensive activity was subject to multiple inspector visits.
On one occasion, the inspector found work in progress with the procedure absent from the job site.
Followup showed the activities being performed were not specifically addressed in the procedure.
The procedure was in the possession of the supervisor, who was using it for reference in conversations with the pump vendor concerning problems the crew was having in pump disassembly.
This led to procedure enhancements.
On another visit, the inspector found procedure steps (relating to micrometer and dial-indicator clearance and runout measurements)
which had no data recorded.
Followup showed all data (eight clearance measurements, five runout measurements)
had failed acceptance criteria.
This was a suspected condition which the supervisor documented separately and which mandated pump replacement.
The "as written" procedure contained only one data blank for runout and one for clearance.
This was corrected.
In subsequent discussions with the maintenance supervisor, the inspector learned of several more procedure enhancements identified as a consequence of this performance of the subject, infrequently done job.
Job Order 014385:
MOVATS testing of 2-WMO-754.
The inspector observed MOVATS testing of 2-WM0-754, (Essential Service Water Supply to the East MDAFP) using Procedure
""12 MHP-SP. 122 and confirmed an appropriate Clearance Pe'rmit (206373)
was in effect.
Upon entering the work area, the inspector found that the crew was on a break, but test equipment remained energized with the power cord passing through a fire door and connecting to an outlet outside the room.
The fire door was being held open by a fusible link, however the power cord would have prevented door closure.
When the crew returned to the work area they acknowledged that the cord prohibited door closure, but also stated that a roving fire watch was assigned.
This was confirmed and reviewed with the fire protection coordinator; all action/responses.
were found proper.
""2 THP SP. RFC-1864 "Unit 2 No.
11 Reactor/Vessel Stud Removal Procedure,"
Revision 0, dated May 6, 198 The No.
11 reactor vessel head stud had been stuck in the vessel flange, partially disengaged (but still with required minimum engagement)
for several years.
The subject special procedure, which formalized the contractor working procedure, was developed to remove the stuck stud during the current outage.
This was necessary to permit required equipment installation later to perform the 10-year reactor vessel inservice inspection.
The inspector reviewed the procedure and observed selected associated activities, including biological shield preparation and installation.
The inspector also reviewed selected licensee support documentation on this activity, which the licensee deemed to constitute both a
repair and a potential safety related design change.
The Plant Nuclear Safety Review Committee (PNSRC) meeting minutes for Meeting No.
2152 document review and approval of the activity as a
safety-related design change had the stud hole become damaged and
~ a repair sleeve/insert been required.
This proved unnecessary.
QA Department reviews, QC "hold points" and
CFR 50.59 reviews all appeared to have been correctly applied.
Further, the associated safety review memo specified (seven) conditions to be fulfilled for the procedure and design change documentation.
Job Order 023757:
Disassemble and store Unit 2 auxiliary feedwater pump terry turbine in dry lay-up for extended outage.
The inspector had no findings, but the licensee did find indications of coupling-end journal bearing wear and a slight darkening of lubricating oil.
These findings were documented for followup and correction on Problem Report No.88-285.
Job Order 716636 and JO 737128:
These jobs required at power entries into the Unit 1 lower containment, seal table adjustments, and movement of the incore flux detectors.
The inspector interviewed the technician assigned to the control room, who indicated that the crew had been briefed on the'igh radiation area that would result while moving the incore and on how to avoid the resulting potential exposure.
j.
RFC-12-2903:
of the inside and outside diameters of the upstream weld preparation area for 2-FM0-232.
No violations, deviations, unresolved or open items were identified.
Survei 1 l ance (61726 42700)
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 personne Cl
The fol lowing activities were inspected:
"~12 THP 6040 PER.328,
"Thimble Tube Cleaning" On May 3, 1988, the inspector observed a demineralized water flushing and air drying of three thimble tubes.
On May 24, 1988, the inspector informed licensee performance engineers concerning an NRC Region III report pertaining to inoperable movable incore detector thimbles.
Apparently, another utility has recently experienced sticking of movable incore detectors due to a buildup of gr aphite lubricant that had been applied to the thimbles during cleaning and lubrication performed in 1986.
At about that time frame, Westinghouse issued an advisory against such lubrication practices.
A performance engineer provided the inspector with a copy of WCAP-11359 "Investigation of Neutron Flux Detector Sticking,"
dated December 1986, and also informed the inspector that the sticking problem had been experienced at D.C.
Cook.
However, the current contractor has apparently refined the cleaning/
lubrication process to control the amount of lubricant applied.
The performance engineer stated that D.C.
Cook has not recently encountered a detector sticking problem.
""2 THP SP. 171, "Multifrequency Eddy Current Examinations of Incore Flux Thimble Tubing," Revision 0, dated April 29, 1988.
On May 5, 1988, the inspector observed initial attempts to insert an eddy current detector via a manual, hand-over-hand pushing process.
When this method proved unsuccessful in penetrating the full length of the thimble tube, it was abandoned in favor of the alternate, reel-driven detector system provided for by the procedure.
This method proved highly successful in acquiring full length data on all 58 thimble tubes.
Reference also Paragraph ll.b.
C.
""12 MHP 4030 STP.034,
"18 Month Surveillance Test Procedure for Plant 2AB Battery Emergency Load Discharge Test and Battery Charger Test," Revision 2, dated December 24, 1987.
d.
""12 THP 4030 STP.050,
"Steam Generator Protection Set III Surveillance Test (Monthly)."
"*12 THP 4030 STP.097,
"Seismic Monitoring Instrumentation Surveillance Test '(Monthly)," Revision 9 dated September 19, 1986.
The licensee's seismic monitoring system features an automatically actuated, four-channel, strong motion triaxial accelerographic detection and recording system.
Conduct of the subject system test on May 2, 1988, disclosed an irregularity.
One "as found" data trace was incomplete, containing a single test trace instead of two.
The problem was documented on Problem Report No.88-243 and the test completed successfully.
A faulty cassette was found as the cause; this was replaced.
4$
- "12 THP 4030 STP.211,
"Ice Condenser Surveillance."
While observing this activity in the Unit 2 upper ice condenser compartment on May 11, 1988, the inspector questioned several cre'ws (about six crews of two or three members were working) concerning status, problems encountered, procedures, etc.
These individuals were generally knowledgeable of the design and nature of the equipment with which they were working, and of the applicable procedures.
This reflected positively on crew training effectiveness in general; training had been separately observed by inspector attendance at a new crew training session.
One crew however, which was attempting to free a stuck ice basket for weighing, was observed to violate procedural limits for this activity relating to maximum lifting force permitted.
The procedure limits lifting force to 5,000 pounds, both in the "Precautions and Limitations" Section (Paragraph 4.3) and in the "Ice Basket Weighing" Section (Paragraph 5.6.3).
The subject crew, working with a hydraulic liftrig (equipped with on-line force monitoring) on Basket 3, Bay 5, Row 9 at about 2:00 p.m.
on May 11, 1988, were observed by the inspector to twice apply force clearly in excess of 5,000 pounds, with a maximum of 5,223 pounds observed before the inspector stopped the activity.
Exceeding the stated procedural limit is a violation of Technical Specification 6.8. l.c, which requires test procedures of this kind to be followed (Violation 316/88016-01).
The contractor supervisor and the licensee director of the testing were notified.
They immediately suspended the activity and reassigned the individual responsible to another job - one without procedural sensitivity.
A Condition Report/Problem Report No.88-275 was written to control and document followup.
Subsequently, the involved employee was disciplined and the specific importance of the lifting load limit was stressed in crew briefings on this event.
The performance engineer documented the shift briefing in a May 12, 1988, briefing paper which all ice crew members acknowledged by initialing.
An analysis of the implications of the noted excessive loading on the subject basket is underway; the basket will either be shown to be unaffected/undamaged or it will be repaired/replaced prior to return to service.
Based on the above, and on the apparent isolated nature of the occurrence, the inspector had no further questions concerning this matter.
Prior and subsequent NRC checks, and checks by licensee gA and gC noted no repetitions.
Violation 316/88016-01 is considered cl osed.
""12 MHP SP.126
"Main Steam Safety Setpoint Verification Using the Trevitest Equipment."
This test was observed during the previous inspection period.
Problems at another utility subsequently led'the inspector to ask that the licensee verify the Trevitest was acceptable.
The other utility encountered problems when testing the pressurizer code safety valves.
The licensee and the vendor concluded that the system configuration for the pressurizer code safety valves was
different because of a loop-seal.
The vendor supplied a letter to certify that testing of the D.C.
Cook main steam safety valves (no loop seals)
was done in accordance with ASME/ANSI PTC 25.3 1976 with an accuracy of plus or minus 1 percent.
One violation, and no deviations, unresolved or open items were identified.
7.
Fire Protection 64704)
Fire protection program activities, including fire prevention and other activities associated with maintaining capability for early detection and suppression of postulated fires, were examined.
Plant cleanliness, with a focus on control of combustibles and on maintaining continuous ready access to fire fighting equipment and materials, was included in the items evaluated.
Upon reviewing Job Order JO 761911 (See Paragraph 5.c) the inspector observed a copy of Attachment 2 to Procedure
gHP 2270 FIRF.Oll which appeared incomplete.
This attachment documents various fire checks associated with "hot work." It was dated May 17, but when noted by the inspector the following day, no entry showed the job
"secured."
When questioned, the licensee showed the job had been properly extended.
The outdated form was removed.
b.
On one building/area tour, the inspector noted a broken seal on a wheeled nitrogen-charged dry chemical fire extinguisher.
This was reported to the licensee, who established by inspection that the unit remained operable.
It was resealed and the inspector informed.
On May 25, 1988, the licensee properly completed a verbal and a
written notification to the NRC concerning a preplanned procedure to test the fire pump starting logic system.
The test, performed May 24, required disabling normally-automatic pumps such that proper operation of their backup pumps could be demonstrated.
Appropriate procedural and personnel provisions were made to assure full system capability could be quickly restored if necessary.
The minimal conditions lasted approximately five minutes, after which sufficient components could be restored to satisfy both the Technical Specification "least conservative" configuration and the continuing test requirements.
8.
No violations, deviations, unresolved or open items were identified.
(
During this inspection, the inspector conducted routine tours of the licensee's security system.
The tours consisted of direct observation, records review, and interviews of personnel.
Particular emphasis was placed on new aspects of the security program which will be utilized during the upcoming steam generator replacement.
The inspector observed vehicle searches during the back shift and personnel access through the 12,
new personnel access facility., The site security director accompanied the inspector in the access facility and described various features.
No discrepancies were noted and personnel appeared knowledgeable, of the job requirements.
During a routine tour of the plant, the inspector noticed a sledge hammer laying adjacent to and outside a vital area door.
No work was in progress at this time and no personnel were in the area.
The tool appeared to have been left earlier by construction personnel who had worked on the upgrade of the vital area door several days earlier.
A security supervisor was notified, but the tool was not removed until a second inquiry about a week later.
Though the tool was the responsibility of whoever brought it there (person unknown'-
see Paragraph 5.d
"Maintenance" ) and the security group is not specifically accountable, the inspectors had two concerns:
(1) a tool in close proximity to a vital area door could provide increased opportunity to an individual wanting access; and (2) security officers on tours had opportunity to report observing this tool earlier.
It does not appear that the matter was noted prior to the inspector's comments.
This is considered by the inspector to be an isolated incident and is not a violation of the licensee's security plan.
No violations, deviations, unresolved or open items were identified.
9.
Outa es (37700 42700 60710 86700 a.
Unit 2 continued its scheduled major outage which began April 23, 1988.
At the conclusion of the current inspection, the following had been accomplished:
(1)
Plant cooldown and isolation (2)
Reactor vessel head removal (3)
Removal of a "stuck" vessel head stud (see Paragraph 5. g)
(4)
Upper internals removal (5)
Complete core offload (6)
Lower internals removal (see Paragraph 4. c)
(7)
Vessel 10-year ISI equipment installation b.
The 10-year ISI inspections and fuel ultrasonic inspections were in progress.
The inspector observed various aspects of these activities, focusing on requirements relating to containment integrity and on compliance to applicable procedures,'oose parts controls were rigidly enforced around the refueling cavity during this time period.
Special test control tags identifying components not to be touched were in evidence.
Some problems were experienced in rigging/handling components with the polar crane, which licensee management was addressing.
C.
Effective with Unit 2 Technical Specification Amendment 100, issued during this period, an array of MODE 6 (refueling)
Technical Specifications were voided on completion of the core offload.
Appropriate administrative notifications, especially
d.
Operations Standing Order OS0.085, were in effect to make responsible personnel aware of these special provisions.
The inspection included review and observation'of the Unit 2 fuel off-load operation.
Procedures covering the following attributes were verified:
(1)
Periodic monitoring of spent fuel cooling prerequisites and contingency measur es; (2)
Handling and inspection of core internals; and (3)
Procedures for establishing and maintaining containment integrity during fuel moves.
The inspector observed fuel off-load activities during normal and off-normal hours on several shifts.
Specific activities were observed in the containment, spent fuel pool and the Unit 2 control room.
Administrative controls pertaining to staffing, plant conditions and procedure adherence were selectively verified.
The following procedures were utilized as part of this inspection.
(1)
~*1-OHP SP.064 - "Unit 2 Refueling Procedure."
(2)
Safety and Assessment Department Standing Order SADS0.007 Revision 1, "Logging of Tools During Refueling, Outage."
The procedure provides for full time safety and assessment personnel to implement positive control to prevent tools, equipment, procedures or other loose objects from being dropped into the reactor cavity.
No violations, deviations, unresolved or open items were identified.
10.
Re ortable Events 92700 The inspector reviewed the following Licensee Event Reports (LERs)
by means of direct observation, discussions with licensee personnel, and review of records.
The review addressed compliance to reporting requirements and, as applicable, that immediate corrective action and appropriate action to prevent recurrence had been accomplished.
a.
Closed LER 315/85072:
Calibration'of the reactor pit floor seismic monitoring instrumentation (strong motion triaxial accelograph)
exceeded the Technical Specification calibration frequency of 22 1/2 months (including grace period) by 35 days.
The missed calibration occurred between September 1983 and September 1985 and was identified by Quality Assurance Surveillance 12-87-210.
The Surveillance Report also states that the late test results were satisfactory and subsequent tests were completed on time or NRC permission was obtained to 'extend the calibration frequency.
Apparently the calibration was missed because the procedure was listed as "outage" which implied that the calibration need not be performed until the end of the outag To resolve this, each surveillance test is now scheduled by date.
Curr'ently, a review of the Technical Specifications is required prior to determining if a surveillance can be postponed.
Failure to comply with the Technical Specification calibration frequency is a violation of the Technical Specification.
However,
CFR Part 2, Appendix C at Paragraph V.A. states that a Notice of Violation will not normally be issued for a violation which meets all of the following:
identification by the licensee; fits a Severity Level IV or V; was reported, corrected and preventative action taken; and does not appear to be a violation that should have been prevented by licensee corrective actions for a previous violation.
It appears that this LER meets the above criteria; no violation was issued.
Closed LER 315/87011:
Eight of twenty main steam safety valves (MSSY) were found with lift setpoints below the Technical Specification required range.
In each case the MSSV lift setpoint was corrected and the MSSV proven operable prior to completion of the test.
The licensee investigation concluded that the previous testing method was inherently less accurate and had a high probability of contributing to the apparent MSSV setpoint drift.
The licensee safety analysis concluded that the out-of-specification setpoints would not have affected the capacity to relieve the steam generator pressure during an analyzed event.
This was the initial testing (for either Unit) using the new test methodology, called Trevitest (see also Paragraph G.g).
Closed LER 315/87016:
Emergency Core Cooling System Flow imbalance caused by normal system fluctuations.
During routine testing, the licensee found that the boron injection combined flow rates exceeded the maximum flow and exceeded the maximum variation between loops.
The licensee concluded that normal sys'em fluctuations caused the flow imbalances found.
The flow rates were reset prior to returning the system to service.
The licensee safety analysis concluded that the "as found" flow rates would not adversely affect core cooling in the event of design basis accidents.
The licensee has also concluded that these Technical Specifications should be considered for revision during the Technical Specification improvement program since they appear excessively restrictive.
Closed LER 315/87019:
The reactor coolant flow was reduced below the Technical Specification minimum during MODE 6 "refueling" operation.
The controlling procedure required reduced flow when reactor coolant was drained to half loop'to prevent air binding of the residual heat removal pumps due to vortexing.
The reduced flow is permitted in MODE 5, but not MODE 6.
Apparently, the procedure was written to MODE 5 requirements without considering the more restrictive MODE 6 requirement.
The reduced flow exceeded the Limiting Condition for Operation by 5 1/2 hours.
Upon discovery, the coolant level was raised and the flow increased.
The licensee has revised the appropriate procedures to address the MODE 6
requirement.
In addition, a Technical Specification amendment.
and safety analysis had been submitted prior to this event (in response to the vortexing problem) to allow reduced flow operation.
On September 22, 1987, this LER was submitted to the NRC Region III Enforcement Board.
Failure to comply with the Technical Specification minimum flow requirements during refueling is a violation.
However,
CFR Part 2, Appendix C at Paragraph V.A. states that a Not'ice of Violation wi 11 not normally be issued for a violation which meets all of the following:
identification by the licensee; fits a Severity Level IV or V; was reported, corrected and preventative action taken; and, does not appear to be a violation that should have been prevented by licensee corrective actions for a previous violation.
It appears that this LER meets the above criteria; no violation was issued.
Closed LER 315/87023:
Failure to provide electrical isolation between Local Shutdown and Indication (LSI) panels for Unit 1 and Unit 2.
This LER was reviewed in NRC Inspection Report No. 50-315/88003(DRS);
50-316/88004(DRS)
and at that time identified as a violation of 10 CFR 50, Appendix B, Criterion III for which a Notice of Violation was issued.
The LER remained open because the LER text did not include a discussion pertaining to the length of time (greater than 30-days)
between the event date and report date.
Revision 1 was submitted on February 18, 1988, and provided the sequence of events to explain the time lapse.
Closed LER 316/87006:
A breakdown in preoperational testing/
modification resulted in an improperly performed containment spray pump test.
During preoperational testing (1974)
a problem was identified with the Unit 1 containment spray pump flow'eters in that actual flow was greater than the range of the flow meter.
The problem appeared to apply to Unit 2 as w'ell.
Temporary modifications were made to the internals of the Unit 1 flow meter and to the face of the Unit 1 and Unit 2 meters.
Mhen repair parts were received, permanent modifications were made to Unit 1 only, however, the temporary face markings were not removed from either Unit.
During engineering reviews (June 1987) the error was found and resolved.
The inspector has reviewed the current administrative procedures/policies and they appear to contain sufficient detail to preclude a repetition of such an event.
(Closed)
LER 316/87010 and LER 315/88002:
Ice buildup in the Ice Condenser flow passages due to sublimation.
The buildup was removed when the flow passages were manually cleaned.
The safety. analysis indicates that 20-percent ice buildup is required before peak containment pressure would exceed design pressure.
The blockage discussed in these LERs is well below the 20-percent limit.
The licensee is currently working with other Ice Condenser utilities to resolve this and other common problems.
To date, the problem of sublimation has not been resolved.
Closed) Part
Re ort 315/85003-PP 316/85003-PP:
The licensee received a shipment of low-alloy low-hydrogen carbon steel weld rods (Heat No.
72181, Lot No.
026C003)
from Airco, Inc. with incomplete flux coating.
Approximately half of the weld rods were either used or discarded prior to identification of the problem.
The unused rods were returned to the supplier.
AEPSC reviews i'ndicated that the defective rods would produce welds containing porosity and oxidation, a condition detectable by NDE (visual) examination.
This examination is required for safety-related welds.
Interviews with welders indicated that they had seen some cases of incomplete flux coating and had discarded the defective rods.
The manufacturer concluded that the defective weld rods were caused by a manufacturing flaw that was isolated to the one lot shipped to'.C.
Cook.
(Closed) Part
Re ort 315/86003-PP 316/86003-PP):
Fittings from Golden Gate Forge and Flange company may not have the proper documentation.
Licensee Condition Report No. 12-03-86-330 documented that 148 flanges were sent to the D.C.
Cook plant and that Golden Gate Forge and Flange company may have falsified the mill test reports.
A test program was implemented to verify that the flanges were 304 stainless steel.
A sample of 97 flanges (66-percent)
were tested and confirmed to be 304 stainless steel.
In addition, the licensee contacted each of the 39 authorized suppliers of this class of material and confirmed that they had not used Golden Gate Forge and Flange as a source of supply.
Based on this review, the licensee
'concluded that the problem noted in this Part 21 was not a safety concern for D.C.
Cook.
No violations, deviations, unresolved or open items were identified.
ll.
NRC Com 1iance Bulletin and Information Notice 71707 92701 The inspector reviewed the NRC communications listed below and verified that:
the licensee has received the correspondence; the correspondence was reviewed by appropriate management representatives; a written response was submitted if required; and, appropriate plant-specific actions were taken.
NRC Bulletin Closed NRC Bulletin 88-01:
Defects in Westinghouse DS-206, DSL-206, DS-416, and DSL-420 circuit breakers used in Class lE applications.
The licensee's response (AEP:NRC: 1057-TACS 65955/65956)
dated April 14, 1988, documents that Westinghouse DS/DSL type circuit breakers are not used at the D.C.
Cook nuclear plant.
Therefore, the inspections of NRC Bulletin No. 88-01 are not applicable to the Cook Nuclear Plant.
b.
Information Notice (Closed NRC Information Notice 87-44:
"Thimble Tube Thinning in Westinghouse Reactors,"
issued September 16, 1987, and Supplement
issued March 28, 1988.
Numerous (at least 20) licensee's operating Westinghouse design reactors have detected thinning of the incore neutron monitoring system thimble tubes.
The phenomenon is believed to result from flow-induced vibration, since wear has generally been found in regions of variable flow.
The inspector reviewed and discussed licensee actions associated with this Notice.
For Unit 1, the licensee performed eddy cur rent testing of the thimble tubes in August 1985.
Results showed the examined portions of 47 tubes were in generally good condition, though full-length examinations had not been possible due to probe drive cable problems.
Two thimbles showed some thinning and four showed denting.
A re-examination is scheduled for the next Unit 1 refueling outage early next year.
For Unit 2, the licensee performed full length eddy current testing of all 58 thimble, tubes during the ongoing outage (see Paragraph 6.b)
and obtained substantially better data for analysis.
While final analytical results were not available on completion of this inspection, the licensee has determined some tube replacements will likely be required.
Procurement processes have been initiated to acquire sufficient new tubes (116).to replace all the original tubes in both units.
No violations, deviations, unresolved or open items were identified.
12.
Re ion III Re uests 92701 25593 The inspector prov)ded the licensee with a copy of a letter dated April 15, 1988, from Edward J.
Butcher, Chief, Technical Specification Branch, NRR, pertaining to containment isolation valve operability.
Apparently, another utility had posted an internal position that considered nonfunctioning containment isolation vales
"operable" if they are closed.
The referenced letter states the NRC position that nonfunctional containment isolation should be declared
"inoperable" and the applicable Action Statement complied with.
The inspector was requested to verify the highest Lake Michigan (Qltimate heat sink) water temperature considered in saf'ety analyses and to compare this to actual highest temperatures experienced.
The Final Safety Analysis Report (FSAR) assumes a high temperature of 76 degrees F in the design bases.
Actual temperatures up to 79 degrees F have been experienced.
The licensee has a separate safety analysis, however, evaluating temperatures up to 81 degrees F as acceptable from the perspective of negative impacts on parameters like safeguards systems cooling services, core decay heat removal, peak containment temperature, control room temperature, and functioning of the emergency diesel generators.
This review is documented via internal licensee memo dated September 28, 1987.
The licensee intends to update the FSAR with the 81 degree F value during his next routine revision (summer 1988)
and to perform additional studies at even higher temperatures.
t
'
i By letter dated May 23, 1988, from E.
G.
Greenman, Director, Division of Reactor Projects, the resident inspector was requested to verify that the licensee has included diesel generator fuel oil in the equality Assurance program.
The inspection guidance is contained in NRC inspection Manual - TI 2515/93 dated March 31, 1988.
The inspector interviewed personnel from the Chemistry, Site equality Assurance and Plant Stores Departments, and found that Ashland Petroleum Company currently has the contract to supply diesel generator fuel oil.
The licensee has chosen not to place this company on the qualified suppliers list because it is a distribution company with numerous suppliers.
Instead, the licensee tests each shipment of fuel oil by performing two analyses.
Prior to unloading, the licensee checks viscosity, specific gravity, flash point and appearance.
After the fuel oil is unloaded, a second sample is sent to an independent laboratory.
This sample is checked for the previously mentioned attributes and checked for cloud point, carbon residue, ash weight, distillation temperature, sulfur weight, copper strip corrosion, and cetane number.
The contract laboratory (Independent Laboratory of St.
Louis) is on the qualified suppliers list. It thus appears that the licensee has properly included the diesel fuel oil in the quality assurance program.
No violations, deviations, unresolved or open items were identified.
13.
Trainin uglification and Effectiveness 81501 a.
On May 18, 1988, the inspector attended the licensee's fitness for duty refresher training.
This training was conducted for supervisors and was led by a guest lecturer who is an expert in the field of behavioral observation.
The training appeared in-depth and utilized lecture, video tape, and role playing as the primary methods.
The training focused on supervisors being able to recognize atypical behavior and deal with it in a professional manner to protect the integrity of the work environment.
b.
The inspector toured the licensee's training center with the licensee's training coordinator.
The tour included a review of the licensee's site specific simulator and the chemistry, instrument and control, radiation protection, mechanical, welding, and video classrooms.
14.
Mana ement Meetin 30702 A management meeting, attended as indicated in Paragraph 1.b above, was held in the NRC Region III offices on May 23, 1988, to discuss procurement programs problems documented in NRC Inspection Report No.
50"315/87022(DRS);
50-316/87022(DRS).
AEP personnel stated that the NUS Corporation had been contracted by AEP to independently audit AEP gA procurement activities.
The NUS report included several findings some of which parallels those noted by the NRC in Inspection Report No. 50-315/316/87022.
(.
The meeting continued with an item by item discussion of the action to be taken by AEP to address the noted violations.
After some discussion for clarification, all proposed appeared acceptable.
Subsequently, by letter (AEP:NRC: 1042A) the licensee submitted an additional response describing'he actions discussed at the meeting.
This document and the described actions remain under evaluation in NRC Region III.
15.
Meetin With Communit Leaders (94600 A meeting attended as indicated in Paragraph 1.c above, was held at the Lake Charter Township Hall (Bridgman, Michigan) on June 6, 1988.
The purpose was to introduce the D.C.
Cook inspection staff, discuss current inspection activities, provide a brief overview of the SALP program and inspection programs, discuss the SALP-7 grades for D.C.
Cook and respond to questions.
The meeting started at 6:00 p.m.
and lasted one hour and 15 minutes.
16.
Mana ement Interview (30703)
The inspectors met with licensee representatives (denoted in, Paragraph 1)
on June 14, 1988, to discuss the scope and findings of the inspection.
In addition, the inspector asked those in attendance whether they considered any of the items discussed to contain information exempt from disclosure.
No items were identified.
20