IR 05000315/1998026
| ML17335A475 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 01/08/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17335A474 | List: |
| References | |
| 50-315-98-26, 50-316-98-26, NUDOCS 9901130082 | |
| Download: ML17335A475 (17) | |
Text
U.S. NUCLEAR REGULATORYCOMMISSION
REGION III
Docket Nos:
License Nos:
50-315; 50-316 DPR-58; DPR-74 Report Nos:
50-315/98026(DRS); 50-316/98026(DRS)
Licensee:
Indiana and Michigan Power 500 Circle Drive Buchanan, Ml 49107-1395 Facility:
Donald C. Cook Nuclear Generating Plant Location:
1 Cook Place Bridgman, Ml 49106 Dates:
Inspectors:
November 30 through December 10, 1998 I. N. Jackiw, Engineering Specialist Approved by:
Ronald N. Gardner, Chief Engineering Specialist Branch 2
'790ii30082 990i08 PDR ADOCK OM003i5
POR
EXECUTIVESUMMARY I
D. C. Cook Units 1 and 2 NRC Inspection Report 50-315/98026(DRS); 50-316/98026(DRS)
This inspection reviewed the licensee's corrective actions for issues identified by NRC inspections and licensee event reports submitted to the NRC. The inspector determined that the licensee was effective in identifying and implementing corrective actions specific to the notices of violation, unresolved items, inspector follow-up items and licensee event reports that were reviewed.
Root cause evaluations were performed for each event/issue as appropriate.
(All Sections)
~
Appropriate staff was involved in the corrective action activities.
(AllSections)
Re ort Details III. En ineerin This inspection involved the review of the licensee's corrective action relative to NRC identified issues and licensee identified issues as reported in licensee event reports (LER). The inspector reviewed licensee responses, safety evaluations and interviewed cognizant licensee personnel.
E8 Miscellaneous Engineering Issues E8.1 Closed Licensee Event Re ort 50-316/93-005:
Reactor Coolant System (RCS) loop temperature indications and pressure indications were routed through the Local Shutdown Instrument (LSI) panels to the Control Room.
Upon completion of certain design changes in 1986, RCS loop temperature and pressure indications were routed through the LSI panels to the Control Room. Thus, a potential fire which could fail all of the LSI panels would also fail this indication in the control room, thereby not complying with the requirements of 10 CFR 50 Appendix R. Such a fire was possible in any fire zone where both the normal and alternate power supply cables to the LSI panels were routed. This condition was corrected in 1990 with the completion of design'changes, which provided additional Control Room RCS temperature and pressure indication, which was not routed through the LSI panels.
The licensee's subsequent investigation concluded that the condition reported on 4-20-93 was not reportable because the
. requirements of Appendix R III.G.1 were met in fire zones 23, 24, 26 and 27 without automatic fire suppression.
Therefore, the licensee concluded that this condition was not reportable per 10CFR50.72(b)(ii)(B).
However, the licensee issued an interim LER because their investigation of the 4-20-93 condition identified new conditions that were still preliminary in nature and under review.
The conditions described in this LER occurred in-the-past and did not reflect the current conditions physically in place at Cook Nuclear Plant.
Since the interim report was issued, these conditions had been evaluated in detail. This evaluation involved an extensive review-of all electrical circuits associated with the safe shutdown instrumentation for both units. As a result, a number of changes were made to the safe shutdown equipment database.
These changes included adding cables and correcting errors in cable routing. The fact that these cables were not previously in the database, or in some cases, had an incorrect routing listed, was also evaluated for impact on Appendix R compliance.
No additional cases of non-compliance with Appendix R were identified. This LER is considered closed.
E8.2 Closed Unresolved Item URI 50-315/94010-02'0-316/94010-02:
Falsification of Fire Watch Tours. The licensee informed the Senior Resident Inspector that fiv'e instances were identified.involving falsification of fire watch tours during a licensee self-assessment audit. The licensee identiTied one fire watch person as the responsible individual for falsifying these records.
In response to this finding, the licensee reviewed an additional ten-percent of the fire watch tours and did not identify any additional problems.
The licensee also reviewed/evaluated all the fire watch tours performed by the subject
individual. No problems were identified. The inspector determined that the licensee's corrective actions regarding this issue were appropriate.
Failure to follow procedures for performing fire watch tours is a violation. This non-repetitive, licensee-identified and corrected violation is being treated as a Non-Cited Violation consistent with Section VII.B.Iof the NRC Enforcement Policy (50-315/98026-04; 50-316/98026-04)(DRS).
This URI is considered closed.
Closed Licensee Event Re ort LER 50-315/94013:
Fire Protection in Zone 29G Found Outside Design Basis.
While performing a revalidation of the Appendix R Safe Shutdown Analysis, it was discovered that certain cables associated with the Units 1 and 2 Essential Service Water (ESW) system were not enclosed in a one-hour rated fire barrier in Fire Zone (FZ) 29G, and an unsealed penetration existed between Fire Zones 29G and 29A. This was contrary to the conditions outlined in an exemption request for 10 CFR 50, Appendix R, Section III.G.2, which had been submitted in early 1983. A postulated fire in FZ 29G could result in the loss of both Unit 1 ESW pumps and the loss of the nonoperating Unit 2 ESW pump.
Upon discovery, fire watches were immediately established in the affected fire zones in accordance with Technical Specifications 3.7.10.
A Fire Probabilistic Risk Assessment (PRA) evaluation of this condition was performed using Fire-Induced Vulnerability Evaluation (FIVE) Methodology techniques to examine the safety significance of this condition. Under Appendix R requirements, the worst case scenario would result in one operable ESW pump. A calculation was performed for this scenario to show that one ESW pump could provide sufficient flow to safely shutdown both units without exceeding runout conditions. The licensee concluded that this condition had little safety significance due to the availability of fire detection and low combustibility loading in the fire zones.
This conclusion was supported by the thermal/hydraulic analysis of the service water system which indicated that one operable ESW pump could deliver the required flow to support safe shutdown functions.
Failure to provide one-hour rated fire barriers in FZ 29G was contrary to 10 CFR 50, Appendix R. This non-repetitive, licensee-identified and corrected violation is being treated as a Non-Cited Violation consistent with Section VII.B.Iof the NRC Enforcement Policy. (50-315/98026-01)(DRS).
This LER is considered closed.
Closed Licensee Event Re ort LER 50-315/950001:
Fire Stops Found Not Installed in Several Unit 1 Containment Cable Trays. While performing a re-validation of the Appendix R Safe Shutdown Analysis, it was discovered that fire stops were not installed in several Unit 1 containment cable trays as required to comply with Appendix R,Section III.G.2.d. A postulated fire could have resulted in the loss of redundant channels of instrumentation relied upon by the Appendix R safe shutdown analysis to achieve safe shutdown.
The postulated fire in Unit 1 containment annular area could result in the'loss of redundant channels of steam generator level indication and RCS temperature indication required for safe shutdown.
The licensee determined that the failure to install the required fire stops was attributed to a combination of factors.
Personnel responsible for developing the design changes necessary to bring the plant into compliance with Appendix R did not have a comprehensive understanding of the requirement Additionally, several unrelated design changes were being processed simultaneously which involved the same safe shutdown instrumentation.
The location of instrumentation circuits inside containment was changing while Appendix R compliance modifications were being developed, contributing to the confusion.
The inspector noted that the following actions were taken by the licensee:
at the time the condition was discovered, the thermister detection string located in the affected cable tray was verified operable, and hourly monitoring of containment temperatures was initiated; a modification was initiated to install the required stops; procedures for the Appendix R revalidations were revised to include independent verifications; and, AEP'ersonnel assigned to perform the safe shutdown reanalysis, were required to become familiar with the Appendix R requirements.
This non-repetitive licensee identified and corrected violation is being treated as a Non-Cited Violation consistent with Section VII.B.Iof the NRC Enforcement Policy.
(50-315/98026-02)(DRS).
This LER is considered closed.
Closed Licensee Event Re ort LER 50-316/95001:
Unit 2 Fire Detection System Made Inoperable Without Compensatory Action Due to Personnel Error. On January 6, 1995, the licensee discovered that the Unit 2 fire detection monitor panel switch EIIS/IC-HS) had been placed in the "off'osition following the performance of a surveillance.
This was contrary to surveillance procedure 12 THP 6030.IMP.153 which stated that the technician at the panel is responsible for ensuring that the control room alarm'functions are restored prior to leaving the test panel unattended.
In the
"off'osition, visual and audible alarms associated with the Unit 2 fire detection zones would not alarm in the Control Room.
It was determined that the switch had been in the
"off'osition for approximately three hours, during which time all Unit 2 fire detection was inoperable without the appropriate compensatory measures being taken.
During the period that the fire detection system was inoperable, a "Fire System Actuation" or "CO2 Header Pressurized" alarm would still have annunciated in the control room for the areas provided with fire suppression capabilities. A lack of understanding of the function of the switch by the operators contributed to this event.
It was not understood until after the event, while reviewing the applicable print, that placing the switch to "off'ould defeat all Unit 2 fire detection.
Upon discovery, the switch was restored to the "on" position and testing was completed.
To prevent recurrence, the licensee placed labels on the control panel for each unit at the monitor switch. The label cautions personnel against leaving the switch in the
"off'osition and states the results of leaving it in that configuration, including the Technical Specification, which must be entered.
The inspector determined that appropriate actions were taken by the licensee.
Failure to followprocedures, resulting in the Unit 2 fire detection being made inoperable, is a violation. This non-repetitive licensee identified and corrected violation is being treated as a Non-Cited Violation consistent with Section VII.B.Iof the NRC Enforcement Policy (50-316/98026-03)(DRS),
This LER is considered close Closed Violation 50-315/96013-01 50-316/96013-01:
Failure to Establish Adequate Instructions/Failure to Follow Procedures.
The inspectors identified three examples of problems with procedure usage and adherence:
maintenance work package for a.
centrifugal charging pump failed to include adequate instructions for lube oil sample collection; a maintenance procedure failed to contain adequate minimum thread engagement acceptance criteria; and, maintenance personnel failed to perform bolting on safety-related equipment in accordance with a required maintenance procedure.
The inspector reviewed, the licensee's response and determined that the specific conditions identified in the violation had been adequately addressed.
This item is considered closed.
Closed Violation 50-315/96013-02 50-316/96013-02:
Failure to Incorporate Correct Acceptance Limits. The inspectors identified that the correct acceptance limits to assure that the centrifugal charging pumps could perform their boron injection function had not been incorporated in the licensee's inservice,testing program.
The inspector reviewed the licensee's response regarding this violation and noted that adequate actions were taken to address the specific issues identified in the violation. Specifically, the IST program was revised to include appropriate limits to ensure that each units'CPs can supply adequate boron from the RWST. This item is considered closed.
Closed Ins ection Follow-u Item IFI 50-315/96013-04'50-316/9013-04:
Charging System Flow Calculations Unavailable.
The licensee performed a charging system flow calculation and determined the allowable CCP performance degradations to ensure adequate RCS boration capacity from the RWST. Following a review of the licensee's calculation, the inspectors developed additional questions regarding this matter. The inspector reviewed the licensee's response to these questions and determined that the questions had been adequately addressed.
This item is considered closed.
Closed Licensee Event Re ort LER 50-315/97003:
Outside the Design Basis Due to Potential Safety Injection Pump Runout.
During preparations to increase water level in an emergency core cooling system accumulator, questions were raised by the control room operators related to the operability of the safety injection pumps during accumulator level adjustment.
Specifically, a question was raised regarding the potential
,for diverting safety injection flowfrom the injection flowpath during the accumulator level
'adjustment evolution. The potential for exceeding the design runout flow limitfor the safety injection pumps during accumulator level adjustments was identified on February 5, 1997, based on preliminary pump runout calculations.
Until February of 1997, however, fillingaccumulators while aligned for emergency core cooling support had been the standard practice throughout the lifetime of the plant.
The licensee conducted an evaluation to determine the potential impact of creating an unanalyzed flowpath through the accumulator fillline. It was determined that a potential existed for the safety injection pump runout flow to exceed its runout design flow limit during the injection phase of an emergency core cooling system actuation with an accumulator fillline open. The inspector noted that the licensee's corrective actions involved revising plant operating procedures to require that the operating safety injection pump be declared inoperable and the system cross-tie valve be closed during
accumulator level adjustment evolutions. The inspector also noted that the licensee's evaluation of this matter appears to have captured all the issues raised during the analysis of this condition. This LER is considered closed.
E8.10 Closed Licensee Event Re ort LER 50-315/97013:
Failure to Procedurally Control RWST Level in Modes 586 Results in Plant, Operating in an Unanalyzed Condition. The license determined that there were two calculations in effect for the Refueling Water Storage Tank (RWST) water level required for RCS makeup following an Appendix R fire. The calculation of record required that an additional 87,000 gallons of water be available in the RWST to deal with certain Appendix R fire scenarios.
During modes
through 4, plant procedures adequately ensured that this requirement was met.
However, in modes 5 and 6, procedures appeared to be inadequate to meet this water level requirement.
The licensee's investigation into this matter found that for each period when the water level requirements were not satisfied, due to insufficient RWST level, the required fire watches were established to provide equivalent shutdown capability as mandated by the technical specification action statement.
Based on this determination, the licensee retracted this LER. The inspector verified that the licensee's determination was appropriate.
Closed Licensee Event Re ort LER 50-315/97016:
Operation of the Residual Heat Removal System Contrary to the UFSAR Could Result in a Condition That Would Prevent the Fulfillrrientof the Safety Function of a System.
The licensee reported that the current operating procedures for the Residual Heat Removal (RHR) system did not prevent the operation of both RHR pumps when the Reactor Coolant System (RCS) is open to atmosphere.
This is contrary to Updated Final Safety Analysis Report (UFSAR)
Section 9.3.3 which states, "Only one residual heat removal (RHR) pump will be operated when the reactor coolant system is open to the atmosphere to prevent damaging both pumps in the unlikely event that suction should be lost." The disposition of this event is discussed in detail in NRC Inspection Report 50-315/98021; 50-316/98021 (DRP). This LER is considered closed.
E8.12 0 en Licensee Event Re ort LER 50-315/97019:
Operation Contrary to the Design Bases with Residual Heat Removal (RHR) Suction Valves Automatic Closure Interlock Defeated in Modes 4 and 5. During a NRC Architect Engineer Design Inspection, it was identified that the interlocks associated with the RHR suction valves were defeated in the normal operating configuration. This practice began in order to prevent inadvertent auto-closure of these valves which would result in loss of RHR suction during shutdown cooling operation.
The procedure for this activity was contrary with the Updated Final Analysis Report and the Technical Specification requirements.
The licensee determined that the cause of this event was an inadequate safety review during the procedure review process.
On September 19, 1997, the licensee formally requested an amendment to remove the surveillance related to the automatic valve closure of the RHR system suction valves from the RCS.
In addition, the licensee initiated a design change package to document this as a design change.
This LER willremain open pending inspector review of the design change documentation and related Technical Specification amendmen V. Mana ement Meetin s X1 Exit Meeting Summary The inspector presented the inspection results to licensee personnel after the conclusion of the inspection on Decembe'r 10,1998.
No proprietary information was identified by the license PARTIALLIST OF PERSONS CONTACTED Licensee M. DePuyot, Supervisor, Nuclear Licensing M. Greendonner, Plant Protection J. Grier, Principal Engineer, Nuclear Engineering D. Kosloff, Nuclear Licensing
=
W. Shafer, Nuclear Licensing J. St. Amon, Nuclear Engineering R. Stevens, Nuclear Licensing INSPECTION PROCEDURES USED IP 92700 Onsite Review of LERs
.
IP 92702 Follow Up on Corrective Actions for Violations and Deviations
ITEMS DISCUSSED 50-315/97019 ITEMS OPENED, CLOSED, AND DISCUSSED LER Operation Contrary to the Design Bases with Residual Heat Removal (RHR) Suction Valves Automatic Closure Interlock Defeated in Modes 4 and 5 ITEMS OPENED 50-315/98026-01 50-315/98026-02 50-316/98026-03 50-315/98026-04 50-316/98026-04 ITEMS CLOSED 50-316/93-005 50-315/94010-02 50-316/94010-02.
50-315/94013 50-315/950001 50-316/95001 50-315/96013-01 50-316/96013-01 50-315/96013-02 50-316/96013-02 50-315/96013-04 50-316/9013-04 50-315/97003 50-315/97013 NCV Fire Protection in Zone 26G Found Outside Design Basis NCV Fire Stops no Installed in Several Unit 1.Containment Cable Trays NCV Unit 2 Fire Detection System Made Inoperable Without Compensatory Actions NCV Falsification of Fire Watch Tours LER RCS loop temperature indications and pressure indic'ations were routed through the LSI panels to the Control Room.
URI Falsification of Fire Watch Tours LER Fire Protection in Zone 29G Found outside Design Basis LER Fire Stops Found not Installed in Several Unit 1 Containment Cable Trays LER Unit 2 Fire Detection System Made Inoperable Without Compensatory Action Due to Personnel Error VIO.
Failure to establish adequate instructions/failure to follow procedures.
VIO Failure to incorporate correct acceptance limits IFI Charging system fiow calculations unavailable LER Outside the Design Basis Due to Potential Safety Injection Pump Runout.
LER Failure to Procedurally Control RWST Level in Modes 5&6 Results in Plant Operating in an Unanalyzed Condition
50-315/97016 50-315/98026-01 50-315/98026-02 50-316/98026-03 50-315/98026-04 LER Operation of the Residual Heat Removal System Contrary to the UFSAR Could Result in a Condition That Would Prevent the Fulfillment of the Safety Function of a System NCV Fire Protection in Zone 26G Found Outside Design Basis NCV Fire Stops no installed in Several Unit 1 Containment Cable Trays NCV Unit 2 Fire Detection System Made Inoperable Without Compensatory Actions NCV Falsification of Fire Watch Tours
AEP AR bcc CC CFR CR DCC D/G DRP DPR EDT EEI ESF IFI IR JO LCO LER LOCA MI NVC NOV NRC NRR OHI PMI P,MP PPA PDR QC RG ROC RWP STP UFSAR URI VIO LIST OF ACRONYMS V
American Electric Power Action Request blind carbon copy carbon copy, Code of Federal Regulations Condition Report Donald C. Cook Emergency Diesel Generator Division of Reactor Projects Demonstration Power Reactor Eastern Daylight Time Apparent Violation Engineered Safety Feature Inspector Followup item
Inspection Report
Job Order
Limiting Condition for Operation
Licensee Event Report
Loss of Coolant Accident
Noncited Violation
Nuclear Regulatory Commission
Nuclear Reactor Regulation
Operations Head Instruction
Plant Manager's Instruction
Plant Manager's Procedure
Plant Performance Assurance
Public Document Room
Quality Control
Regulatory Guide
Restart Oversight Committee
Radiation Work Permit
Surveillance Test Procedure
Updated Final Safety Analysis Report
Unresolved Item
Violation
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