IR 05000315/2002006

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IR 05000315-02-006(DRP) & IR 05000316-02-006(DRP), on 07/01- 09/30/2002, D.C. Cook Nuclear Plant, Units 1 and 2 of Event Follow-up to Public Radiation Safety. Violation Noted & Considered as Unresolved Item Pending Final Safety Significance
ML023030330
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 10/28/2002
From: Anton Vegel
Division Reactor Projects III
To: Bakken A
American Electric Power Co
References
IR-02-006
Download: ML023030330 (65)


Text

October 28, 2002

SUBJECT:

D. C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2 NRC INSPECTION REPORT 50-315/02-06(DRP); 50-316/02-06(DRP)

Dear Mr. Bakken:

On September 30, 2002, the NRC completed an inspection at your D. C. Cook Nuclear Power Plant, Units 1 and 2. The enclosed report documents the inspection findings which were discussed on October 2, 2002, with Mr. J. Pollock and other members of your staff.

This inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, one finding whose significance is to be determined was identified (Section 4OA3.2). This issue was determined to be a violation of NRC requirements and is considered to be an unresolved item pending a final safety significance determination.

The NRC has increased security requirements at the D. C. Cook Nuclear Power Plant in response to terrorist acts on September 11, 2001. Although the NRC is not aware of any specific threat against nuclear facilities, the NRC issued an Order and several threat advisories to commercial power reactors to strengthen licensees capabilities and readiness to respond to a potential attack. The NRC continues to monitor overall security controls and will issue temporary instructions in the near future to verify by inspection the licensees compliance with the Order and current security regulations.

In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter and its enclosures will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

A. We will gladly discuss any questions you have concerning this inspection.

Sincerely,

/RA/

Anton Vegel, Chief Branch 6 Division of Reactor Projects Docket Nos. 50-315; 50-316 License Nos. DPR-58; DPR-74

Enclosure:

Inspection Report 50-315/02-06(DRP);

50-316/02-06(DRP)

REGION III==

Docket Nos:

50-315; 50-316 License Nos:

DPR-58; DPR-74 Report No:

50-315/02-06(DRP); 50-316/02-06(DRP)

Licensee:

Indiana and Michigan Electric Company Facility:

D. C. Cook Nuclear Power Plant, Units 1 and 2 Location:

1 Cook Place Bridgman, MI 49106 Dates:

July 1, 2002 through September 30, 2002 Inspectors:

B. Kemker, Senior Resident Inspector D. Passehl, Senior Project Engineer S. Orth, Senior Project Engineer R. Lerch, Senior Project Engineer P. Pelke, Project Engineer A. Dunlop, Reactor Engineer I. Netzel, Reactor Engineer G. ODwyer, Reactor Engineer R. Winter, Reactor Engineer W. Slawinski, Senior Radiation Specialist Approved by:

A. Vegel, Chief Branch 6 Division of Reactor Projects

Table of Contents

SUMMARY OF FINDINGS

.................................................... 3

Summary of Plant Status:..................................................... 4 1.

REACTOR SAFETY...................................................4 1R04 Equipment Alignment............................................. 4 1R05 Fire Protection.................................................. 5 1R06 Flood Protection Measures........................................ 6 1R11 Licensed Operator Requalification................................... 7 1R12 Maintenance Effectiveness........................................ 7 1R13 Maintenance Risk Assessments and Emergent Work Evaluation........... 8 1R15 Operability Evaluations

........................................... 9 1R16 Operator Workaround........................................... 10 1R17 Permanent Plant Modifications..................................... 10 1R19 Post Maintenance Testing........................................ 11 1R20 Refueling and Outage Activities.................................... 12 1R22 Surveillance Testing............................................. 12 1R23 Temporary Plant Modificaitons..................................... 13 1EP6 Drill Evaluation................................................. 14 2.

RADIATION SAFETY................................................. 14 2OS1 Access Controls to Radiologically Significant Areas..................... 14 2OS3 Radiation Monitoring Instrumentation and Protective Equipment........... 16 2PS1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems

3.

SAFEGUARDS...................................................... 22 3PP3 Response to Contingency Events.................................. 22 4.

OTHER ACTIVITIES.................................................. 23 4OA1 Performance Indicator Verification.................................. 23 4OA3 Event Follow-up................................................ 25 4OA6 Management Meetings........................................... 31 KEY POINTS OF CONTACT................................................. 32 LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED............................ 33 LIST OF ACRONYMS USED................................................. 34 LIST OF DOCUMENTS REVIEWED

........................................... 35

SUMMARY OF FINDINGS IR 05000315-02-06(DRP), IR 05000316-02-06(DRP), on 07/01/2002-09/30/2002, Indiana and Michigan Electric Company, D. C. Cook Nuclear Power Plant, Units 1 and 2. Event Follow-up.

Public Radiation Safety.

This report covers a 12-week period of inspection by resident and region based inspectors.

The radioactive gaseous and liquid effluent treatment and monitoring program inspection was conducted by a regional senior radiation specialist. The inspectors identified one finding, which is an apparent violation whose significance is to be determined. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609, "Significance Determination Process," (SDP). The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG 1649, "Reactor Oversight Process," Revision 3, dated July 2000.

A.

Inspector Identified Findings

Cornerstone: Initiating Events



TBD. An Apparent Violation of 10 CFR 50, Appendix B, Criterion V,

"Instructions, Procedures, and Drawings," was self-revealed. The licensee failed to provide an appropriate procedure for testing the Unit 1 pressurizer power operated relief valves (PORVs), causing an uncontrolled release of reactor coolant system inventory to the pressurizer relief tank. This issue was self-revealed on June 5, 2002, when pressurizer PORV 1-NRV-153 inadvertently opened while testing actuation logic circuitry for pressurizer PORV 1-NRV-151.

The surveillance test procedure failed to provide adequate control of 1-NRV-151 and 1-NRV-153, which have a common automatic opening signal. The release rate exceeded the 25 gallons-per-minute limit established for declaring an Unusual Event in accordance with the licensees Emergency Plan.

The inspectors assessed this finding using the Significance Determination Process. The inspectors concluded that this issue could be reasonably viewed as a precursor to a significant event and was therefore more than a minor concern. The inspectors also concluded that this finding was associated with the initiating events cornerstone and adversely affected the cornerstone objective.

Specifically, the uncontrolled release of reactor coolant system inventory upset plant stability and challenged the inventory control safety function. The inspectors determined that the unit was in a configuration where a single active failure or personnel error could have resulted in a rapid loss of reactor coolant system inventory and therefore required a Phase 2 SDP analysis for shutdown risk. The safety significance of this finding is "To Be Determined" (TBD) pending the completion of additional staff review. (Section 4OA3.2)

Licensee Identified Violations

None

REPORT DETAILS

Summary of Plant Status:

Unit 1 operated at or near full power during this inspection period.

Unit 2 operated at or near full power during this inspection period with the following exceptions:



On July 22, 2002, Unit 2 experienced an automatic reactor trip when the main turbine tripped due to a low condenser vacuum while cycling circulating water isolation valves on the main condenser for waterbox debris flushing. The main steam isolation valves were shut after the trip to arrest an excessive reactor coolant system cooldown due to auxiliary steam loads. The licensee performed a reactor startup and synchronized the unit to the grid on July 23, 2002.



On July 27, 2002, the licensee performed a reactor shutdown to replace a circulating water pump discharge valve that had failed closed. Following the replacement of the valve and some additional forced outage maintenance activities, the licensee performed a reactor startup and synchronized the unit to the grid on August 3,

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R04 Equipment Alignment

.1 Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant systems:

Initiating Events Cornerstone



Unit 2 West Component Cooling Water System Train



Unit 2 CD Emergency Diesel Generator Mitigating Systems Cornerstone



Unit 2 West Charging and Safety Injection System Train



Unit 1 West Residual Heat Removal System Train The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones. The inspectors reviewed operating procedures, Technical Specification (TS) requirements, Administrative Technical Requirements, system diagrams, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components were aligned correctly.

In addition, the inspectors reviewed the issues that the licensee entered into its corrective action program to verify that identified problems were being entered into the program with the appropriate characterization and significance. The inspectors also reviewed the licensees corrective actions for equipment alignment related issues documented in selected condition reports (CRs).

b. Findings

No findings of significance were identified.

.2 Complete System Walkdown

a. Inspection Scope

The inspectors performed a complete system walkdown of the following risk-significant system:

Mitigating Systems Cornerstone



Unit 1 and 2 Essential Service Water (ESW) System The inspectors reviewed ongoing system maintenance, open job orders, and design issues for potential effects on the ability of the ESW system to perform its design functions. The inspectors ensured that the configuration of the system was in accordance with applicable operating procedure checklists. The inspectors verified acceptable material condition of system components, availability of electrical power to system components, and that ancillary equipment or debris did not interfere with system performance.

b. Findings

No findings of significance were identified.

1R05 Fire Protection

.1 Routine Resident Inspector Tours

a. Inspection Scope

The inspectors performed fire protection walkdowns of the following risk-significant plant areas:

Initiating Events Cornerstone



Unit 1 Engineered Safety Features (ESF) Motor Control Center Room (Zone 41)



Unit 2 ESF Motor Control Center Room (Zone 45)

Mitigating Systems Cornerstone



Unit 1 "N" Train Battery Room (Zone 106)



Unit 2 "N" Train Battery Room (Zone 107)



Unit 1 Turbine Driven Auxiliary Feedwater Pump Room (Zone 17E)



Unit 2 Turbine Driven Auxiliary Feedwater Pump Room (Zone 17F)



Unit 2 Auxiliary Feedwater Corridor (Zone 17C)



Unit 1 East Main Steam Valve Enclosure (Zone 33)



Unit 2 West Main Steam Valve Enclosure (Zone 34)



Unit 1 AB Emergency Diesel Generator Room (Zone 16)



Unit 2 AB Emergency Diesel Generator Room (Zone 19)

The inspectors verified that fire zone conditions were consistent with assumptions in the licensees Fire Hazard

Analysis.

The inspectors walked down fire detection and suppression equipment, assessed the material condition of fire control equipment, and evaluated the control of transient combustible materials.

b. Findings

No findings of significance were identified.

1R06 Flood Protection Measures

a. Inspection Scope

The inspectors reviewed and assessed flood protection measures for internal flooding events. The inspectors evaluated whether the licensee took appropriate precautions to mitigate the risk from internal flooding events. Specifically, the inspectors performed the following:



reviewed the Updated Final Safety Analysis Report (UFSAR) and other selected design basis documents to identify those areas susceptible to internal flooding;



reviewed the licensees probabilistic risk analysis and associated flood protection reports to identify risk significant flood areas and protective features;



reviewed abnormal and alarm response procedures associated with the diagnosis and mitigation of flooding events;



performed a walkdown of the Turbine Building sub-basement, the auxiliary feedwater pump area, the emergency diesel generator rooms, the refueling water storage tank pipe tunnels, the Auxiliary Building sub-basement, and the ESW system pipe tunnel to evaluate whether appropriate flood protection controls were being maintained;



reviewed selected station operating procedures used to identify and mitigate internal flooding events; and



interviewed selected operating and engineering staff regarding internal flooding protection controls.

In addition, the inspectors reviewed the issues that the licensee entered into its corrective action program to verify that identified problems were being entered into the program with the appropriate characterization and significance. The inspectors also reviewed the licensees corrective actions for flood protection related issues documented in selected CRs.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification

.1 Resident Inspector Quarterly Review

a. Inspection Scope

The inspectors assessed licensed operator performance and the training evaluators critique during licensed operator annual requalification evaluations in the D.C. Cook Plant operations training simulator on August 13, 2002 and September 24, 2002. The inspectors focused on alarm response, command and control of crew activities, communication practices, procedural adherence, and implementation of emergency plan requirements.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors evaluated the licensees handling of selected degraded performance issues involving the following risk-significant structures, systems, and components (SSCs):

Mitigating Systems Cornerstone



Auxiliary Feedwater System



600 Volt Alternating Current Safety-Related Power



Emergency Diesel Generators The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the SSCs. Specifically, the inspectors independently verified the licensees handling of SSC performance or condition problems in terms of:



appropriate work practices,



identifying and addressing common cause failures,



scoping of SSCs in accordance with 10 CFR 50.65(b),



characterizing SSC reliability issues,



tracking SSC unavailability,



trending key parameters (condition monitoring),



10 CFR 50.65(a)(1) or (a)(2) classification and reclassification, and



appropriateness of performance criteria for SSCs/functions classified (a)(2)and/or appropriateness and adequacy of goals and corrective actions for SSCs/functions classified (a)(1).

In addition, the inspectors reviewed the issues that the licensee entered into its corrective action program to verify that identified problems were being entered into the program with the appropriate characterization and significance. The inspectors also reviewed the licensees corrective actions for maintenance effectiveness related issues that were documented in selected CRs.

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Evaluation

a. Inspection Scope

The inspectors reviewed the licensees evaluation and management of plant risk for maintenance activities on the following equipment:

Initiating Events Cornerstone



Unit 2 Reserve Feed Transformer



Unit 2 East Component Cooling Water System Train Barrier Integrity Cornerstone



Unit 1 East Containment Spray System Train Mitigating Systems Cornerstone



Unit 2 Pressurizer Power Operated Relief Valves (PORVs)



Unit 2 East Charging System Train



Unit 2 West Component Cooling Water System Train



Unit 2 West Essential Service Water Pump These activities were selected based on their potential risk significance relative to the reactor safety cornerstones. As applicable for each of the above activities, the inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensees probabilistic risk analyst and/or shift technical advisor, and verified that plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify that risk analysis assumptions were valid and applicable requirements were met.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following CRs to ensure that either:

(1) the condition did not render the involved equipment inoperable or result in an unrecognized increase in plant risk, or
(2) the licensee appropriately applied TS limitations and appropriately returned the affected equipment to an operable status.

Barrier Integrity Cornerstone



CR 02113065 2-OHP-4030-STP-007E, East Containment Spray System Operability Test, Does Not Have a Maximum of 60 Gallons Per Minute Water Flow Rate from the Spray Additive Tank Line with Spray Pump on Recirculation as Stated in TS Bases Section 3/4.6.2.2



CR 02264018 Unit 1 Control Room Door (1-DR-AUX412B) Was Propped Open Without Specific Procedure Guidance to Allow it to Be Open Mitigating Systems Cornerstone



CR 02122057 1-IMO-911 Could Not Be Set Within the Prescribed Thrust Limitations Provided in VDS-1-IMO-911



CR 02116032 1-HV-AES-2 Exhaust Fan Was Found in Standby With its Backdraft Damper Stuck Partially Open and the Fan Rotating Backwards



CR 02125016 Potentially High Boron Concentration (Above 2600 Parts Per Million) in Unit 1 Reactor Coolant System in Mode 4 Shortly Before Entering Mode 5 In addition, the inspectors reviewed the issues that the licensee entered into its corrective action program to verify that identified problems were being entered into the program with the appropriate characterization and significance. The inspectors also reviewed the licensees corrective actions for issues potentially affecting the operability of safety related SSCs that were documented in selected CRs.

b. Findings

No findings of significance were identified.

1R16 Operator Workarounds

.1 Semiannual Review of the Cumulative Effect of Operator Workarounds

a. Inspection Scope

The inspectors reviewed the cumulative effect of operator workarounds, control room deficiencies, and degraded conditions on equipment availability, initiating event frequency, and the ability of the operators to implement abnormal or emergency operating procedures. During this review the inspectors considered the cumulative effects of operator workarounds on the following:



the reliability, availability and potential for mis-operation of a system;



the ability of operators to respond to plant transients or accidents in a correct and timely manner; and



the potential to increase an initiating event frequency or affect multiple mitigating systems.

In addition, the inspectors reviewed the issues that the licensee entered into its corrective action program to verify that identified problems were being entered into the program with the appropriate characterization and significance. The inspectors also reviewed the licensees corrective actions for issues potentially affecting the functionality of mitigating systems or on the operators response to initiating events that were documented in selected CRs.

b. Findings

No findings of significance were identified.

1R17 Permanent Plant Modifications

a. Inspection Scope

The inspectors reviewed the engineering analyses, modification documents and design change information associated with the following permanent plant modification:

Barrier Integrity Cornerstone



Design Change 1-DCP-5173, "Unit 1 Provide Essential Service Water Minimum Flow Path Via Containment Spray System Heat Exchanger," Revision 0



Design Change 2-DCP-5174, "Unit 2 Provide Essential Service Water Minimum Flow Path Via Containment Spray System Heat Exchanger," Revision 0 The modification provided a minimum flow path for the ESW pumps through the containment spray system heat exchangers to eliminate a potential common mode failure concern for the emergency diesel generators. During this inspection, the inspectors evaluated the implementation of the design to verify that:



the compatibility, functional properties, environmental qualifications, seismic qualification, and classification of materials and replacement components were acceptable;



the affected operating procedures and training were identified and necessary changes were completed;



the pressure boundary integrity was not compromised;



the implementation of the modifications did not impair key safety functions;



no unintended system interactions occurred;



the system performance characteristics affected by the modification continued to meet the design basis; and



the modification design assumptions were appropriate.

Completed activities associated with the implementation of the modification were also inspected and the inspectors discussed the modification with the responsible engineers and operations staff. In addition, the inspectors reviewed the applicable sections of the TS, UFSAR, and 10 CFR 50.59 safety evaluation associated with the design change packages.

b. Findings

No findings of significance were identified.

1R19 Post Maintenance Testing

a. Inspection Scope

The inspectors reviewed the post maintenance testing requirements associated with the following scheduled maintenance activities:

Barrier Integrity Cornerstone



Unit 1 East Containment Spray System Train Maintenance Mitigating Systems Cornerstone



Unit 2 AB Emergency Diesel Generator Maintenance



Unit 2 North Safety Injection Pump Maintenance



Unit 2 East Auxiliary Feedwater Pump Maintenance



Unit 2 East Centrifugal Charging System Train Maintenance



Unit 2 East Component Cooling Water System Train Maintenance



Unit 2 West Component Cooling Water System Train Maintenance



Unit 2 West Essential Service Water Pump Replacement The inspectors selected these post maintenance testing activities because the systems were identified as risk significant in the licensees risk analysis. The inspectors reviewed the scope of the work performed and evaluated the adequacy of the specified post maintenance testing. The inspectors verified that the post maintenance testing was performed in accordance with approved procedures, that the procedures clearly stated acceptance criteria, and that the acceptance criteria were met. During this inspection, the inspectors interviewed operations, maintenance and engineering department personnel and reviewed the completed post maintenance testing documentation.

In addition, the inspectors reviewed the issues that the licensee entered into its corrective action program to verify that identified problems were being entered into the program with the appropriate characterization and significance. The inspectors also reviewed the licensees corrective actions for post maintenance testing related issues documented in selected CRs.

b. Findings

No findings of significance were identified.

1R20 Refueling and Outage Activities

.1 Unit 2 Forced Outage

a. Inspection Scope

On July 27, 2002, the licensee performed a reactor shutdown to replace a circulating water pump discharge valve that had failed closed. Shear pins that connect the number 23 circulating water pump discharge valves (2-WMO-23) disk to the stem severed, causing the valve to fail closed. The unit was ramped down at approximately 20 percent per hour and the reactor was tripped at 11:50 p.m. from 15 percent power. The licensee entered Mode 4 (Hot Shutdown) to perform additional maintenance work. The licensee performed a reactor startup and synchronized the unit to the grid on August 3, 2002.

The inspectors evaluated the licensees conduct of forced outage activities to assess the licensees control of plant configuration and risk management actions. The inspectors reviewed the cause for the valve failure as well as the extent of condition of other circulating water pump discharge valves. The inspectors observed portions of the restart activities to verify that requirements of the TS and administrative procedure requirements were met prior to changing operational modes or plant configurations.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing

a. Inspection Scope

For the surveillance test procedures listed below, the inspectors observed selected portions of the surveillance test and/or reviewed the test results to determine whether risk significant systems and equipment were capable of performing their intended safety functions and to verify that testing was conducted in accordance with applicable procedural and TS requirements:



01-IHP-4030-SMP-103, "Reactor Coolant Flow Protection Set III Functional Test and Calibration," Revision 4



01-IHP-4030-SMP-104, "Delta T/Tavg Protection Set I Functional Test and Calibration," Revision 4



02-OHP-4030-STP-30, "Daily and Shiftly Surveillance Checks," Revision 39



02-IHP-4030-STP-511, "Train B Reactor Protection System and Engineered Safety Features Reactor Trip Breaker and Solid State Protection System Automatic Trip/Actuation Logic Functional Test," Revision 4



12-EHP-6040-PER-323, "Flux Mapping System Operation and Supportive Data Collection," Revision 4a The inspectors reviewed the test methodology and test results in order to verify that equipment performance was consistent with safety analysis and design basis assumptions.

In addition, the inspectors reviewed the issues that the licensee entered into its corrective action program to verify that identified problems were being entered into the program with the appropriate characterization and significance. The inspectors also reviewed the licensees corrective actions for surveillance testing related issues documented in selected CRs.

b. Findings

No findings of significance were identified.

1R23 Temporary Plant Modifications

a. Inspection Scope

The inspectors reviewed the temporary modification listed below to verify that the installation was consistent with design modification documents and that the modification did not adversely impact system operability or availability:



2-TM-00-57, "On-line Leak Repair of 2-FW-118-4," Revision 1 The temporary modification installed a temporary leak seal on the south bearing cover for the number 4 steam generator feedwater header containment isolation check valve (2-FW-118-4). A steam leak developed at the flange where the cover is fastened to the valve body that could not be corrected by normal maintenance practices with the unit on line. The inspectors verified that configuration control of the modification was correct by reviewing design modification documents and confirmed that appropriate post-installation testing was accomplished. The inspectors interviewed engineering and maintenance department personnel and reviewed the design modification documents and the 10 CFR 50.59 evaluation against the applicable portions of the UFSAR.

b. Findings

No findings of significance were identified.

1EP6 Drill Evaluation

a. Inspection Scope

The inspectors observed the conduct of the licensees third quarter announced emergency planning drill that was conducted in the licensees control room simulator and emergency response facilities on August 22, 2002. The inspection effort was focused on evaluation of the licensees classifications, notifications, and protective action recommendations for the simulated event. The inspectors also evaluated the licensees conduct of the training evolution, including the licensees critique of performance to identify weaknesses and deficiencies.

b. Findings

No findings of significance were identified.

RADIATION SAFETY

Cornerstone: Occupational Radiation Safety

2OS1 Access Control to Radiologically Significant Areas (71121.01)

.1 Plant Walkdowns and Radiological Boundary Verification

a. Inspection Scope

The inspector conducted walkdowns of selected radiologically controlled areas to verify the adequacy of radiological area boundaries and postings. Specifically, the inspector walked down all locked high radiation area (LHRA) boundaries (excluding LHRAs located within other LHRAs) in the Auxiliary Building to determine if these areas and selected high radiation areas were properly posted and controlled in accordance with 10 CFR 20 and the licensees TS. The inspector also observed the radiological conditions of work areas within those high and locked high radiation areas walked down to assess the radiological housekeeping and contamination controls.

b. Findings

No findings of significance were identified.

.2 High Risk Significant, High Radiation Area, and Very High Radiation Area Access

Controls

a. Inspection Scope

The inspector reviewed the licensees procedures and practices for the control of access to radiologically significant areas (high, locked high, and very high radiation areas) and assessed compliance with those procedures, the licensees TS and the requirements of 10 CFR 20.1601 and 20.1602. Implementation of a recently developed procedure and technical/administrative guidelines for the verification and control of radiologically significant areas were also reviewed for adequacy and conformity with regulatory requirements. In particular, the inspector reviewed the licensees practices for the control of keys to LHRAs and very high radiation areas including the review of key issuance and tracking logs and key inventory surveillance records for 2002 thru July, the use of access control guards to control entry into such areas, and the licensees methods for independently verifying proper closure and latching of LHRA doors. The inspector also reviewed evolving communication plans and interface practices between radiation protection (RP) and plant operations staff to assess the licensees communication protocols relevant to changing plant conditions that could alter radiological area status. Additionally, the inspector attended a pre-job briefing for the transfer of a reactor cavity filter from one LHRA to another, to determine if radiological information was adequately exchanged and if plans for area access control were sound and met regulatory requirements.

b. Findings

No findings of significance were identified.

.3 Radiation Work Permit Reviews

a. Inspection Scope

The inspector reviewed several radiation work permits (RWPs) for work that was recently completed in radiologically significant areas. Electronic dosimeter alarm setpoints for both dose rate and integrated dose were evaluated to verify conformity with work area radiological conditions given the work activity. The inspector also reviewed work instructions specified in the RWPs and in pre-job briefing information in order to evaluate access control restrictions for compliance with TS and the licensees access control procedures.

b. Findings

No findings of significance were identified.

.4 Control of Non-Fuel Materials Stored in the Spent Fuel Pool

a. Inspection Scope

The inspector reviewed the licensees radiological controls and practices for the storage of highly activated or contaminated materials (non-fuel) in the spent fuel pool. A foreign material exclusion (FME) maintenance procedure which contained provisions for temporary storage of material in the spent fuel pool was reviewed along with the most recent pool inventory record, and a walkdown of the spent fuel pool area was conducted. The inspector discussed with RP staff the administrative and physical controls that would be considered should temporary storage of highly activated/contaminated material in the spent fuel pool be necessary to ensure consistency with the licensees FME procedure and with Regulatory Guide 8.38, Information Notice 90-33, and applicable Health Physics Positions in NUREG/CR-5569.

Plans to develop a RP procedure or expand the existing FME procedure to fully address the regulatory guidance and standardize the licensees practices were discussed with RP management.

b. Findings

No findings of significance were identified.

.5 Identification and Resolution of Problems

a. Inspection Scope

The inspector reviewed the licensees CR database and several individual CRs related to access, posting and key controls for radiologically significant areas that were generated in 2002 through July 22, 2002. The review was performed to determine the scope and extent of problems identified by the licensee. The inspector evaluated the effectiveness of the licensees corrective action process to identify and characterize individual problems and potential trends and to develop corrective actions to prevent recurrence. The inspector also reviewed the licensees planned actions to address deficiencies with its access control program that were identified during a recent industry assist inspection.

b. Findings

No findings of significance were identified.

2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03)

.1 Walkdowns of Radiation Monitoring Instrumentation

a. Inspection Scope

The inspector conducted walkdowns of selected area radiation monitors (ARMs) to verify they were located as described in the UFSAR, to determine if they were optimally positioned relative to the potential source(s) of radiation they were intended to monitor, and to assess their material condition. The inspector also reviewed the status of repair or troubleshooting activities associated with those ARMs that the inspector observed had work request tags, to verify that instrument problems were being addressed in an appropriate and timely manner.

b. Findings

No findings of significance were identified.

.2 Tests and Calibrations of Radiation Monitoring Instrumentation

a. Inspection Scope

The inspector selectively reviewed radiological instrumentation associated with monitoring transient high and/or very high radiation areas and instruments used for remote emergency assessment to verify that the instruments had been calibrated consistent with industry standards and in accordance with station procedures. The inspector reviewed alarm setpoints for selected ARMs to verify that they were established consistent with the UFSAR and TS. Specifically, the inspector reviewed calibration procedures and the most recent calibration records and/or source characterization/verification documents for the following radiation monitoring instrumentation and instrument calibration equipment:



Unit 1 North Seal Water Injection Filter Cubicle ARM



Unit 2 South Seal Water Injection Filter Cubicle ARM



Unit 1 West Centrifugal Charging Pump Room ARM



Unit 1 and Unit 2 High Range Containment Radiation Monitors



Radcal Corporation Model 20X5-180 Ion Chamber and Model 2025 Electrometer (Instrument Calibrator Output Measurement Equipment)



J. L. Shepherd Model M89 Instrument Calibrators The inspector evaluated RP technician performance while selected instruments used for surveys of personnel and equipment prior to unconditional release from the radiologically controlled area were source checked, to determine if those checks were completed adequately and in conformance with station procedures. Alarm setpoints for these instruments were also reviewed to determine if they were established at levels consistent with industry standards and regulatory guidance provided in Health Physics Positions Number 72 and Number 250 of NUREG/CR-5569. An inspector identified deficiency with the methodology of source checking the portal radiation monitors used at station egress locations was assessed to verify that it did not impact instrument operability or compromise detector alarm function verification. Additionally, the inspector reviewed the most recent calibration record and procedure for one of the licensees portal monitors used at the north guard post to monitor staff as they leave the plant restricted area. The review was performed to ensure the monitor was calibrated adequately and as required by procedure and that the instruments alarm setpoint was established consistent with industry guidance.

b. Findings

No findings of significance were identified.

.3 Respiratory Protection Program

a. Inspection Scope

The inspector reviewed aspects of the licensees respiratory protection program for compliance with the requirements of Subpart H of 10 CFR 20, and to ensure that self-contained breathing apparatus (SCBA) were properly maintained and ready for emergency use. Specifically, the inspector reviewed SCBA equipment inspection, functional test and maintenance procedures and records for selected periods in 2002 through July, for all SCBA units staged for emergency use and located in various areas of the plant. The review was performed to determine if the equipment was properly maintained consistent with industry standards and station procedures.

The inspector walked-down the SCBA air bottle filling station in the Operations Support Center and SCBA equipment storage locations in the Unit 1 and Unit 2 Control Rooms, the Operations Support Center, the RP Access Control Building, and at the 633 foot elevation of the Turbine Building. The inspector examined several SCBA units that were stored in these areas to assess their material condition, and to verify that air bottle hydrostatic tests were current and that bottles were pressurized to meet procedural requirements. The inspector discussed SCBA equipment inspection and functional testing with a RP technician that performed these activities to verify that surveillances were completed adequately and that the equipment was properly maintained. The inspector also reviewed training certificates and training matrices for selected RP staff to determine if those licensee personnel performing SCBA equipment maintenance and inspection were qualified consistent with industry standards.

The inspector performed a review to determine if a sufficient cadre of the licensees emergency response organization that could be called upon to perform vital emergency response activities that required use of respiratory protection equipment were trained and qualified in SCBA use. Specifically, the inspector reviewed respiratory protection training and SCBA qualification records for current operations on-shift staff, the stations fire brigade and members of the licensees RP and maintenance staffs to ensure personnel qualifications were maintained consistent with the licensee's emergency plan and procedures.

b. Findings

No findings of significance were identified.

.4 Identification and Resolution of Problems

a. Inspection Scope

The inspector reviewed the results of a self-assessment that focused on SCBA qualifications and that was completed by the licensee's emergency preparedness staff in January 2001, and the licensees CR database and several individual CRs related to radiation monitoring instrumentation and SCBA equipment generated in 2002 through July 22, 2002. The review was performed to evaluate the effectiveness of the licensees self-assessment and corrective action program to identify problems, to characterize and prioritize problems, and to develop appropriate corrective actions. Plans to address inspector identified deficiencies with SCBA training relative to air bottle change-out and to ensure that all appropriate emergency response staff consistently maintain SCBA qualifications were discussed with station and RP management.

b. Findings

No findings of significance were identified.

Cornerstone: Public Radiation Safety

2PS1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (71122.01)

.1 Walkdowns of Liquid and Gaseous Effluent Monitoring and Control Systems

a. Inspection Scope

The inspectors performed walkdowns of the major components of the liquid and gaseous effluent monitoring and release systems, including point of discharge effluent radiation monitors, liquid radioactive waste (radwaste) processing tanks, gas decay tanks and steam generator blowdown flash tanks, to verify that the current system configuration was as described in the Updated Final Safety Analysis Report (UFSAR)and was consistent with the Offsite Dose Calculation Manual (ODCM), and to assess equipment material condition.

The inspectors also walked down the radwaste system control panel, reviewed the status of work requests for selected effluent related systems and discussed processing equipment reliability, use and operating practices with environmental staff.

b. Findings

No findings of significance were identified.

.2 Radioactive Effluent Release Data, Dose Calculations, and ODCM Changes

a. Inspection Scope

The inspectors reviewed the 1999, 2000, and 2001 Annual Radioactive Effluent Release Reports and selected radioactive effluent release data for 2002 through September 2002 to verify that the radioactive effluent control program was implemented as described in the ODCM and to ensure that any anomalies in the release data were adequately understood by the licensee and were properly assessed and reported. The inspectors evaluated the licensees methodology for the calculation of offsite dose and selectively reviewed results of both liquid and gaseous effluent sample analyses for 2002, to verify that the licensee properly calculated dose from effluents consistent with the ODCM. The inspectors also reviewed revisions made to the ODCM in calendar years 2000 and 2001 and the justifications for other than editorial changes, to verify they were completed and reported in accordance with Technical Specifications and the ODCM.

b. Findings

No findings of significance were identified.

.3 Liquid and Gaseous Effluent Releases

a. Inspection Scope

As there were no liquid batch releases performed during the inspection, the inspectors reviewed the release packages for two liquid effluent batch release completed in 2001 and for one completed in 2002. The review was conducted to verify that the licensees release procedures and practices, including dose projections to members of the public and use of station specific scaling factors, were technically sound and conformed to ODCM methodology and Technical Specification requirements. The inspectors also reviewed selected batch (containment pressure reliefs and containment purge/vent) and continuous gaseous effluent release data including results of chemistry sample analyses, to independently verify that the data was properly used to complete calculations of offsite dose consistent with ODCM methodology and the licensees procedures. For those release packages reviewed, the inspectors also examined the discharge monitor alarm set points and the set point calculation methodology to verify they were established in accordance with the ODCM and the licensees procedure. The inspectors accompanied a chemistry technician during a weekly change-out and analysis of the particulate and iodine unit vent effluent samples, to verify that practices and analytical techniques were technically sound and consistent with procedure.

Additionally, the inspectors reviewed chemistry data for selected periods in 2002 to verify that compensatory samples were taken and analyzed as required by the ODCM during periods when effluent monitors were out of service.

b. Findings

No findings of significance were identified.

.4 Liquid and Gaseous Effluent Monitor Calibration

a. Inspection Scope

The inspectors reviewed records of instrument calibrations performed since the last inspection for selected point of discharge effluent radiation monitors and flow meters, to determine if they had been calibrated consistent with industry standards and in accordance with station procedures and the ODCM. Specifically, the inspectors reviewed the calibration records for the following effluent radiation detectors and flow monitors:

  • Unit 2 Condenser Air Ejector Exhaust
  • Unit 1 and Unit 2 Vent Exhaust
  • Common Unit Liquid Radwaste Discharge Line
  • Unit 1 Gland Seal Exhaust Flow Monitor
  • Unit 1 Vent Flow Monitor
  • Unit 2 Gland Seal Exhaust Flow Monitor
  • Unit 2 Vent Flow Monitor The inspectors also reviewed supporting health physics calculations that established calibration constants, reference source responses and alarm set point values for these monitors, to verify the technical viability of the calibration program and for compliance with ODCM criteria. Additionally, the inspectors examined effluent monitor performance and overall radiation monitoring system health information for 2001-2002 and discussed monitor troubleshooting efforts and associated remedial actions with the assigned system engineer, to assess the adequacy of the licensees efforts to identify problems and improve the overall reliability of the effluent radiation monitoring and control system.

b. Findings

No findings of significance were identified.

.5 Air Cleaning System Surveillance Tests

a. Inspection Scope

The inspectors reviewed the most recent results for both trains of the Unit 1 and Unit 2 Engineered Safety Features (ESF) ventilation system exhaust air filter testing to verify that test methodology, frequency and test results met Technical Specification requirements. Specifically, the inspectors evaluated the test methodology and reviewed the test results of in-place high efficiency particulate air (HEPA) and charcoal absorber penetration tests, laboratory tests of charcoal absorber methyl iodide penetration, in-place combined HEPA filter and charcoal absorber train pressure drop tests and tests to demonstrate automatic start of the standby fans.

b. Findings

No findings of significance were identified.

.6 Analytical Instrumentation Quality Control and Inter-laboratory Comparison Program

a. Inspection Scope

The inspectors reviewed the chemistry departments quality control data for selected periods in 2002 through September for those instrumentation systems used to quantify effluent releases. The review was performed to assess equipment performance and to verify that testing was completed consistent with station procedures. This included a review of the chemistry counting laboratory gamma spectroscopy systems and liquid scintillation counters. The inspectors also reviewed the most recent energy calibration records, efficiency checks and lower limit of detection (LLD) determinations for all spectroscopy systems used to analyze effluent samples. The review was performed to determine if calibration and efficiency check acceptance criteria and ODCM specified LLDs were met and if the calibrations were conducted in accordance with procedure.

The inspectors reviewed the results of the first and second quarter 2002 radiochemistry inter-laboratory cross checks to determine if the cross check program was adequately implemented consistent with industry standards and to verify the quality of the radioactive effluent analyses performed by the licensee.

b. Findings

No findings of significance were identified.

.7 Identification and Resolution of Problems

a. Inspection Scope

The inspectors reviewed a 2001 radiation protection department self-assessment of effluent sampling/analysis and ODCM implementation, performance assurance department field observations reports and audits completed in 2001 through September 2002, and condition reports (CRs) generated during approximately the 12-month period preceding the inspection that related to ODCM implementation and the liquid and gaseous effluent monitoring and control program. The documents were reviewed to evaluate the licensees ability to assess the effluent control program, to identify repetitive problems or trends, contributing causes and extent of condition, and to implement corrective actions to achieve lasting results.

b. Findings

No findings of significance were identified.

SAFEGUARDS

Cornerstone: Physical Protection

3PP3 Response to Contingency Events (71130.03)

The Office of Homeland Security (OHS) developed a Homeland Security Advisory System (HSAS) to disseminate information regarding the risk of terrorist attacks. The HSAS implements five color-coded threat conditions with a description of corresponding actions at each level. NRC Regulatory Information Summary (RIS) 2002-12a, dated August 19, 2002, "NRC Threat Advisory and Protective Measures System," discusses the HSAS and provides additional information on protective measures to licensees.

a. Inspection Scope

On September 10, 2002, the NRC issued a Safeguards Advisory to reactor licensees to implement the protective measures described in RIS 2002-12a in response to the Federal Governments declaration of threat level "Orange." Subsequently, on September 24, 2002, the OHS downgraded the national security threat condition to "Yellow" and a corresponding reduction in the risk of a terrorist threat.

The inspectors interviewed licensee personnel and security staff, observed the conduct of security operations, and assessed licensee implementation of the threat level "Orange" protective measures. Inspection results were communicated to the region and headquarters security staff for further evaluation.

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES

4OA1 Performance Indicator Verification

.1 Unplanned Scrams per 7000 Critical Hours and Scrams with Loss of Normal Heat

Removal

a. Inspection Scope

Initiating Events Cornerstone The inspectors verified the Unplanned Scrams per 7000 Critical Hours and the Scrams with Loss of Normal Heat Removal performance indicators for both units. The inspectors reviewed each licensee event report (LER) from October 2001 to June 2002, determined the number of scrams that occurred, evaluated each of the scrams against the performance indicator definitions, and verified the licensees calculation of critical hours for both units.

b. Findings

No findings of significance were identified.

.2 Unplanned Power Changes per 7000 Critical Hours

a. Inspection Scope

Initiating Events Cornerstone The inspectors verified the Unplanned Power Changes per 7000 Critical Hours performance indicator for both units. The inspectors reviewed power history data for both operating units from October 2001 to June 2002, determined the number of power changes greater than 20 percent full power that occurred, evaluated each of those power changes against the performance indicator definition, and verified the licensees calculation of critical hours for both units.

b. Findings

No findings of significance were identified.

.3 Safety System Unavailability

a. Inspection Scope

Mitigating Systems Cornerstone The inspectors verified the following performance indicators for both units:



Safety System Unavailability - Emergency AC [Alternating Current] Power,



Safety System Unavailability - Auxiliary Feedwater,



Safety System Unavailability - High Pressure Safety Injection, and



Safety System Unavailability - Residual Heat Removal.

The inspectors reviewed operating logs, maintenance history and surveillance test history for unavailability information for these systems from October 2001 to June 2002.

The inspectors also verified the licensees calculation of required hours for both units and evaluated applicable safety system equipment unavailability against the performance indicator definition. The inspectors interviewed engineering and operations staff to determine whether the performance indicator data was being collected and reported consistent with the guidance contained in NEI [Nuclear Energy Institute] 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 2.

b. Findings

No findings of significance were identified.

.4 Occupational Exposure Control Effectiveness

a. Inspection Scope

Occupational Radiation Safety Cornerstone The inspector evaluated the RP departments performance indicator data analysis methods and associated records to determine if the licensee had accurately assessed and reported the performance indicator for the Occupational Radiation Safety Cornerstone in accordance with the criteria specified in NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Revisions 1 and 2. Specifically, the inspector reviewed the licensees CR database and selected CRs generated between December 2001 and July 2002, and selected radiologically controlled area egress transaction dose information and electronic dosimetry alarm reports generated in 2002 through July. The review was performed to identify any access control or unintended dose performance indicator occurrences that were not recognized by the licensee and to verify the licensees performance indicator results for the Occupational Radiation Safety Cornerstone. The inspector also reviewed performance indicator verification records completed by the RP staff for the first two quarters of 2002, and discussed performance indicator data collection and analysis processes with the RP departments performance indicator data steward to determine if the program was implemented consistent with the licensees performance indicator procedure and the NEI guideline.

b. Findings

No findings of significance were identified.

.5 Radiological Effluent Technical Specification (RETS)/ODCM Radiological Effluent

Occurrence PI

a. Inspection Scope

The inspectors reviewed the licensees assessment of its public radiation safety performance indicator for RETS/ODCM radiological effluent occurrences to determine if the indicator was adequately assessed and reported. Specifically, the inspectors reviewed CRs generated during the 12-months preceding the inspection to identify any potential occurrences such as unmonitored, uncontrolled or improperly calculated effluent releases that may have impacted offsite dose. Also, the inspectors evaluated the licensees methods for determining offsite dose and selectively verified that gaseous and liquid effluent release data and associated offsite dose calculations performed since this indicator was last reviewed in November 2001 were accurate. The inspectors discussed the RETS/ODCM PI data collection and analysis process with the data steward for this indicator to verify that the indicator was assessed consistent with industry guidelines as provided by the applicable revision of Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline.

b. Findings

No findings of significance were identified.

4OA3 Event Follow-up

.1 Unit 2 Reactor Trip and Restart Following Loss of Main Condenser Vacuum

a. Inspection Scope

On July 22, 2002, Unit 2 experienced an automatic reactor trip in response to a main turbine trip on low condenser vacuum. Immediately prior to the main turbine trip, operators were flushing the main condenser waterboxes of debris by cycling the circulating water inlet isolation valves. The licensee did not expect to have condenser vacuum lower to below the turbine trip setpoint and determined that the apparent cause for the loss of vacuum condition was degraded condenser performance. The licensee restarted Unit 2 on July 23, 2002, after cleaning and inspecting the main condenser water boxes. The inspectors assessed control room operator performance immediately following the reactor trip, reviewed the post trip report, and observed portions of the reactor restart activities. The inspectors also reviewed the LER for this event.

b. Findings

(Closed) LER 50-316-2002-006-00: "Unit 2 Reactor Trip Due to Low Condenser Vacuum." The inspectors concurred with the licensees conclusion that the safety significance of this event was minimal. The licensee entered this event into its corrective action program as CR 02203001. This event did not constitute a violation of NRC requirements. This LER is closed.

.2 Pressurizer Power Operated Relief Valve Inadvertently Opened During Testing

Resulting in a Loss of Reactor Coolant System Inventory and an Unusual Event

a. Inspection Scope

On June 5, 2002, with Unit 1 in Mode 4 (Hot Shutdown), pressurizer PORV 1-NRV-153 inadvertently opened while testing actuation logic circuitry for pressurizer PORV 1-NRV-151. Approximately 100 gallons of reactor coolant was released to the pressurizer relief tank. The release rate exceeded the 25 gallons-per-minute limit established for declaring an Unusual Event in accordance with the licensees Emergency Plan. The inspectors reviewed the circumstances associated with this event, including the root cause determination, operator response during the event, and corrective actions.

b. Findings

An Apparent Violation of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," was self-revealed. The licensee failed to provide an appropriate procedure for testing the Unit 1 pressurizer PORVs, causing an uncontrolled release of reactor coolant system inventory to the pressurizer relief tank. Pending additional evaluation, the safety significance of this issue is "To Be Determined" (TBD).

Discussion On June 5, 2002, while performing testing to verify the automatic opening of pressurizer PORV 1-NRV-151, pressurizer PORV 1-NRV-153 also opened unexpectedly. With the associated PORV block valve for 1-NRV-153 open, approximately 100 gallons of reactor coolant was released to the pressurizer relief tank. The reactor coolant inventory transfer was immediately apparent to control room operators via alarms and indications, resulting in a 15 second response time for operators to close the block valve and terminate the reactor coolant discharge.

Three pressurizer PORVs are provided on each unit. The PORVs are designed to operate manually and automatically through a complex series of control and actuation circuits. The control circuits include interlocks and common actuation signals for the PORVs and pressurizer heaters that are needed to control pressurizer pressure. A common signal operates both 1-NRV-151 and 1-NRV-153. Another common signal operates the third PORV (1-NRV-152) and energizes/de-energizes pressurizer heaters.

The TS require periodic testing of the circuitry to verify proper operation from the pressure sensing instruments through operation of the valves and heaters. One of the required tests performed during refueling outages verifies that each valve will open upon receipt of a signal from the actuation circuitry.

The licensee recently changed the surveillance test procedure to allow testing each PORV individually rather than together, as the testing was previously conducted. The licensees root cause evaluation concluded that the procedure change did not contain adequate instructions to establish initial test conditions to prevent unintended opening of both interlocked valves 1-NRV-151 and 1-NRV-153 while one valve was being tested.

The licensee subsequently revised the procedure and performed the testing satisfactorily on June 6, 2002.

Analysis The inspectors assessed this finding using the Significance Determination Process (SDP). The inspectors concluded that this issue could be reasonably viewed as a precursor to a significant event and was therefore more than a minor concern. The inspectors also concluded that this finding was associated with the initiating events cornerstone and adversely affected the cornerstone objective. Specifically, the uncontrolled release of reactor coolant system inventory upset plant stability and challenged the inventory control safety function. Because Unit 1 was in a shutdown mode during this period, the inspectors performed a Phase 1 SDP review of this issue using the guidance provided in NRC Inspection Manual Chapter 0609, Appendix G, "Shutdown Operations Significance Determination Process." Based on the above information, the inspectors concluded that the most appropriate Appendix G checklist to use for this issue was the checklist for "Pressurized Water Reactor Hot Shutdown Operation - Time to core boiling less than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />." Because, operator intervention was required to manually close the affected PORV block valve, the inspectors concluded that the unit was in a configuration where a single active failure or personnel error could have resulted in a rapid loss of reactor coolant system inventory as described in Section II.B.(2) of the checklist. Consequently, the inspectors concluded that this issue increased the likelihood of a loss of reactor coolant system inventory and therefore required a Phase 2 SDP analysis. The inspectors discussed the safety significance of this issue with the Regional Senior Reactor Analyst; and, pending the completion of a Phase 2 analysis, the safety significance of this issue is to be determined.

Enforcement 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to the above, the licensee failed to provide a procedure of a type appropriate to the circumstances for testing the Unit 1 pressurizer PORVs, which is an activity affecting quality. Specifically, the instructions contained in 1-IHP-4030-102-017, "Pressurizer Power Operated Relief Valve (PORV) Actuation Channel Calibration with Valve Operation (for Modes 1, 2, and 3)," Revision 1, failed to provide adequate control of pressurizer PORVs 1-NRV-151 and 1-NRV-153, which have a common automatic opening signal. This issue was self-revealed on June 5, 2002, when pressurizer PORV 1-NRV-153 inadvertently opened while testing actuation logic circuitry for 1-NRV-151, causing an uncontrolled release of reactor coolant system inventory to the pressurizer relief tank. This issue is considered to be an Unresolved Item pending a final safety significance determination (URI 50-315-02-06-01(DRP)). The licensee entered this violation into its corrective action program as CR 02157039.

.3 (Closed) LER 50-315-2002-003-00:

"Main Steam Safety Valves Exceed Allowable Lift Setpoints." During surveillance testing of the Unit 1 main steam safety valves (MSSVs)on May 2 and 3, 2002, the licensee identified that 7 of 20 MSSVs failed to meet the TS acceptance criteria for the lift setpoint. As a result of each MSSV test failure, the licensee entered the appropriate TS Limiting Condition for Operation and restored each valve to an operable condition within the TS allowed outage time. The valve lift test failures were due to metallic bonding between the stainless steel valve disk and nozzle resulting in an increase in each of the valves lift setpoint. The licensee performed an evaluation of the impact of the MSSV surveillance testing results on the transient and accident analysis described in the UFSAR and concluded that the out of tolerance conditions were bounded by the 110 percent secondary system design pressure assumed in the analysis. The inspectors reviewed and concurred with the licensees evaluation. The licensee entered this event into its corrective action program as CR 02122063, CR 02123003, CR 02123037, CR 02123039, CR 02123049, CR 02123050, and CR 02123053. This event did not constitute a violation of NRC requirements. This LER is closed.

.4 (Closed) LER 50-315-2002-005-00:

"Unit 1 Manual Trip Due to Trip of East Main Feedwater Pump." On June 14, 2002, operators manually tripped Unit 1 in response to a main feedwater pump trip. The feedwater pump condenser became clogged with zebra mussel shells and lost vacuum when a circulating water pump was started, transporting debris to the feedwater pump condenser. The inspectors concurred with the licensees conclusion that the safety significance of this event was minimal. The licensee entered this event into its corrective action program as CR 02165064. This event did not constitute a violation of NRC requirements. This LER is closed.

.5 (Closed) LER 50-315-2002-006-00:

"Switchyard Fire Results in Violation of Technical Specification 3.0.5." On June 12, 2002, an explosion of a current transformer in a 345 kilo-volt breaker and fire in the switchyard resulted in the loss of the preferred offsite power source to the Unit 1 and Unit 2 ESW pumps. Since the Unit 2 East ESW pump was out-of-service for planned maintenance and the Unit 1 West ESW pump was considered inoperable in accordance with TS 3.7.4.1 because the cross-tie valves between the units were open to maintain the Unit 2 East ESW header pressurized, the licensee entered TS 3.0.5 for both units. The licensee requested and received enforcement discretion for an additional 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to accomplish restoration of the Unit 2 East ESW pump to preclude a required dual unit Mode 3 (Hot Standby) entry. The inspectors reviewed the event and the licensees request for enforcement discretion in NRC Inspection Report 50-315/316-02-07(DRP). The inspectors concluded that the enforcement discretion was necessitated by the coincidental performance of pre-planned maintenance on the Unit 2 East ESW pump during the event; therefore, entry into TS 3.0.5 was not due to a failure to comply with regulatory requirements. The inspectors determined that the information provided in LER 50-315-2002-006-00 did not raise any new issues or change the conclusions of the initial reviews documented in NRC Inspection Report 50-315/316-02-07(DRP). The NRC staff concluded that there was no net increase in risk associated with extending the allowed outage time for TS 3.0.5 from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to a total of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The licensee entered this event into its corrective action program as CR 02163045. This violation of TS 3.0.5 is a violation of minor significance that is not subject to enforcement action in accordance with Section VI of the NRCs Enforcement Policy. This LER is closed.

.6 (Closed) LER 50-315-2002-007-00:

"Technical Specification 3.3.3.1 Required Special Report for Inoperable Radiation Monitors." The action statement for TS 3.3.3.1 associated with radiation monitors 1-VRA-1310 (upper containment high range radiation monitor) and 1-MRA-1702 (steam generator number 3 PORV outlet monitor) requires that the radiation monitors be returned to operable status within 7 days of the event or that a special report be written and issued to the NRC within 14 days of the event. On June 23, 2002, the licensee identified that radiation monitor 1-VRA-1310 had been inoperable for 12 days as a result of maintenance performed on another radiation monitor. At the time of the maintenance activity, the licensee was unaware of the interactions between the two monitors. During its review of that event, the licensee identified that a human performance error during a calibration on April 12, 2002 had rendered another radiation monitor 1-MRA-1702 inoperable for a period of 79 days. At the time of discovery, the licensee corrected the problem and entered the issues into its corrective action program as CR 02174004 and CR 02199084. In both cases, the time of discovery resulted in the licensee exceeding the requirement for a 14-day special report. The failure to issue a special report to the NRC within 14 days of the event is a violation of TS 3.3.3.1. This finding constitutes a violation of minor significance that is not subject to enforcement action in accordance with Section VI of the NRCs Enforcement Policy. This LER is closed.

.7 (Closed) LER 50-315-2000-008-00:

"Failure to Test Essential Service Water Valves in Accordance with Technical Specifications." This issue was previously discussed in Section E2.2 of NRC Inspection Report 50-315/316-00-01(DRP). The inspectors identified that the ESW outlet valves for the component cooling water heat exchangers were tested in one direction only; however, testing the valves to both open and close was necessary to meet TS surveillance requirement 4.7.4.1.b. The licensees failure to adequately test these valves is a violation of TS 4.7.4.1.b. The inspectors reviewed the revised test procedures that included the required test provisions. Because these valves subsequently passed surveillance testing, this issue is considered to be of minor safety significance. The licensee entered this event into its corrective action program as CR P-00-04744 and CR 00314038. This finding constitutes a violation of minor significance that is not subject to enforcement action in accordance with Section VI of the NRCs Enforcement Policy. This LER is closed.

.8 (Closed) LER 50-315-2000-008-01:

"Failure to Test Essential Service Water Valves in Accordance with Technical Specifications," Supplement 1. The licensee submitted Supplement 1 to LER 50-315-2000-008-00 to provide additional information concerning the analysis of the event, the cause, and corrective actions. The inspectors determined that the information provided in Supplement 1 to LER 50-315-2000-008-00 did not raise any new issues or change the conclusion of the initial review, which was documented above in Section 4OA3.7. This LER is closed.

.9 (Closed) LER 50-315-2000-009-00:

"Failure to Perform Technical Specification Valve Position Surveillance on Leak-off Valves." The licensee identified that prior to 1997, the TS containment integrity surveillance test requirement of verifying valve position every 31 days was not met for two containment isolation valves in Unit 1. This constituted a violation of Technical Specification 4.6.1.1.a.1. The surveillance procedure was revised to verify the correct position of the affected valves. Because these leak-off valves were located in a sealed enclosure with limited access, this issue is considered to be of minor safety significance. The licensee entered this event into its corrective action program as CR 00341030. This finding constitutes a violation of minor significance that is not subject to enforcement action in accordance with Section VI of the NRCs Enforcement Policy. This LER is closed.

.10 (Closed) LER 50-316-2000-013-00:

"Safety Injection Valve Closure at High Power Levels Could Result in Exceeding Peak Centerline Temperature Limits." The licensee was performing Unit 2 valve testing at full power which put the unit in an improper alignment for brief periods. This constituted a violation of 10 CFR 50, Appendix B, Criteria III, "Design Control." The procedures were revised to perform this testing when the plant was shutdown. Unit 1 procedures were also revised although the requirement did not apply to Unit 1 power levels. Because the testing was performed for very short durations and on an 18 month interval, this issue is considered to be of minor safety significance. The licensee entered this event into its corrective action program as CR P-00-11217. This finding constitutes a violation of minor significance that is not subject to enforcement action in accordance with Section VI of the NRCs Enforcement Policy. This LER is closed.

.11 (Closed) LER 50-315-1999-012-01:

"Auxiliary Building ESF Ventilation System May Not Be Capable of Maintaining ESF Room Temperatures Post-Accident, Supplement 1.

On April 20, 1999, the licensee discovered several issues that, when taken in aggregate, resulted in insufficient assurance that the ESF ventilation system was capable of performing its safety and accident mitigation functions. The inspectors reviewed the original LER in NRC Inspection Report 50-315/316-99-29(DRS) and concluded that this was a minor issue. The licensee submitted Supplement 1 to LER 50-315-1999-012-00 to provide new information concerning the analysis of the event and corrective actions. The cause for this event was the licensee's failure to adequately control design basis calculations and supporting documentation. This constituted a violation of 10 CFR 50, Appendix B, Criteria III, "Design Control." The licensee entered this event into its corrective action program as CR P-99-08841. The inspectors determined that the licensees corrective actions were adequate to prevent recurrence.

This finding constitutes a violation of minor significance that is not subject to enforcement action in accordance with Section VI of the NRC's Enforcement Policy.

This LER is closed.

.12 (Closed) LER 50-315-1999-001-01:

"General Electric HFA Relays Installed in Emergency Diesel Generators May Not Meet Seismic Qualifications," Supplement 1.

On January 6, 1999, it was determined that General Electric HFA safety related relays installed in plant system circuits may not be properly configured in accordance with vendor instructions for relay contact adjustment and servicing, and therefore, may not meet seismic qualification. The inspectors reviewed the original LER and determined that this was a minor issue. The licensee submitted Supplement 1 to LER 50-315-1999-001-00 to provide new information concerning the analysis of the event and corrective actions. The extent of condition was identified and all affected relays were reconfigured and calibrated to restore operability. The inspectors determined that the information provided in Supplement 1 to LER 50-315-1999-001-00 did not raise any new issues or change the conclusion of the initial review, which was documented in NRC Inspection Report 50-315/316-99-29(DRS). The licensee entered this event into its corrective action program as CR P-99-00270. This LER is closed.

4OA6 Meetings

.1 Interim Exits

The results of the Occupational Radiation Safety - Radiation Monitoring Instrumentation and Access Control to Radiologically Significant Areas Inspection were presented to Mr. J. Pollock and other members of licensee management at the conclusion of the inspection on July 26, 2002. The licensee acknowledged the findings presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified. The inspector subsequently discussed changes to the original characterization of the findings with Mr. D. Wood on August 16, 2002.

.2 Resident Inspectors Exit

The inspectors presented the inspection results to Mr. J. Pollock and other members of licensee management at the conclusion of the inspection on October 2, 2002. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary.

Proprietary information was examined during this inspection but is not specifically discussed in this report. The inspectors subsequently discussed changes to the original characterization of the findings with Mr. J. Pollock on October 18, 2002.

.3 Exit Meeting

Exit Meeting Senior Official at Debrief:

Joseph Pollock Date:

September 27, 2002 Proprietary Information:

None Subjects:

Public Radiation Safety - Radioactive Gaseous and Liquid Effluent Monitoring and Control Change to Inspection Findings:

None KEY POINTS OF CONTACT Licensee M. Allen, Assistant Maintenance Director C. Bakken, Senior Vice President, Nuclear Generation D. Foster, Environmental Specialist J. Gebbie, Plant Engineering Assistant Director S. Greenlee, Nuclear Technical Services Director J. Grimm, System Engineer G. Harland, Work Control/Maintenance Director R. LaBurn, General Supervisor, Radiation Protection Production E. Larson, Operations Director R. Meister, Regulatory Affairs Specialist J. Molden, Acting Plant Manager D. Moul, Operations Staff Manager D. Noble, Technical Support, Radiation Protection/Environmental T. Noonan, Performance Assurance Director J. Pollock, Site Vice President B. Robinson, Radiation Protection Superintendent M. Scarpello, Regulatory Compliance Supervisor T. Summers, Chemistry Superintendent D. Wood, Radiation Protection/Environmental Manager T. Woods, Licensing Supervisor LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-315-02-06-01 URI Pressurizer power operated relief valve inadvertently opened during testing resulting in a loss of reactor coolant system inventory and an unusual event (Section 4OA3.2)

Closed 50-315-1999-001-01 LER General Electric HFA Relays installed in emergency diesel generators may not meet seismic qualifications (Section 4OA3.12)50-315-1999-012-01 LER Auxiliary Building ESF ventilation system may not be capable of maintaining ESF room temperatures post-accident (Section 4OA3.11)50-315-2000-08-00 LER Failure to test essential service water valves in accordance with Technical Specifications (Section 4OA3.7)50-315-2000-08-01 LER Failure to test essential service water valves in accordance with Technical Specifications (Section 4OA3.8)50-315-2000-09-00 LER Failure to perform Technical Specification valve position surveillance on leak-off valves (Section 4OA3.9)50-315-2002-03-00 LER Main steam safety valves exceed allowable lift setpoints (Section 4OA3.3)50-315-2002-05-00 LER Unit 1 manual trip due to trip of east main feedwater pump (Section 4OA3.4)50-315-2002-06-00 LER Switchyard fire results in violation of Technical Specification 3.0.5 (Section 4OA3.5)50-315-2002-07-00 LER Technical Specification 3.3.3.1 required special report for inoperable radiation monitors (Section 4OA3.6)50-316-2000-13-00 LER Safety injection valve closure at high power levels could result in exceeding PCT limits (Section 4OA3.10)50-316-2002-06-00 LER Unit 2 reactor trip due to low condenser vacuum (Section 4OA3.1)

Discussed None LIST OF ACRONYMS USED AC Alternating Current ADAMS Agency-wide Documents and Management System ANSI American National Standards Institute ARM Area Radiation Monitor ASME American Society of Mechanical Engineers CFR Code of Federal Regulations CR Condition Report DCP Design Change Procedure DRP Division of Reactor Projects DRS Division of Reactor Safety ECCS Emergency Core Cooling System EHP Electrical Maintenance Head Procedure ESF Engineered Safety Features ESW Essential Service Water FME Foreign Material Exclusion HEPA High Efficiency Particulate Air HSAS Homeland Security Advisory System IHP Instrument Maintenance Head Procedure LER Licensee Event Report LHRA Locked High Radiation Area LLD Lower Limit of Detection MHP Maintenance Head Procedure MSSV Main Steam Safety Valves NOED Notice of Enforcement Discretion NRC Nuclear Regulatory Commission OA Other Activities ODCM Offsite Dose Calculation Manual OHS Office of Homeland Security OHP Operations Head Procedure PARS Publically Available Records PI Performance Indicator PMI Plant Managers Instruction PMP Plant Managers Procedure PORV Power Operated Relief Valve Radwaste Radioactive Waste RETS Radiological Effluent Technical Specification RIS Regulatory Information Summary RP Radiation Protection RWP Radiation Work Permit SCBA Self-contained Breathing Apparatus SDP Significance Determination Process SSC Structures, Systems, and Components STP Surveillance Test Procedure TS Technical Specification UFSAR Updated Final Safety Analysis Report URI Unresolved Item LIST OF

DOCUMENTS REVIEWED

The following is a list of licensee documents reviewed during the inspection, including

documents prepared by others for the licensee. Inclusion on this list does not imply the NRC

inspectors reviewed the documents in their entirety, but rather, that selected sections or

portions of the documents were evaluated as part of the overall inspection effort. Inclusion of a

document in this list does not imply NRC acceptance of the document, unless specifically stated

in the inspection report.

1R04

Equipment Alignment

1R04.1 Partial System Walkdowns

Unit 2 West Component Cooling Water System Train

D. C. Cook Nuclear Plant Updated Final

Safety Analysis Report (UFSAR)

2-OHP-4021-016-003

Operation of the Component Cooling

Water System During Startup and Power

Operations

Revision 13

2-OHP-5030-001-001

Operations Plant Tours

Revision 20

OP-2-5135-36

Flow Diagram Component Cooling Water

Pumps and Component Cooling Water

Heat Exchangers Unit Number 2

Revision 36

PMP-4043.SLV.01

Sealed/Locked Valve List

Revision 4

Unit 2 West Charging and Safety Injection System Train

01-OHP-4021-008-002

Placing Emergency Core Cooling System

in Standby Readiness

Revision 15b

OP-2-55129-39

Flow Diagram Chemical and Volume

Control System Reactor Letdown and

Charging Unit Number 2

Revision 39

Condition Report (CR)

248048 (1)

NRC Identified a Discrepancy Between

the Normal Operating Procedure and the

Operations Flow Print for the Residual

Heat Removal Heat Exchanger Outlet

Sample Valve 1-RHR-120E/W

September 5, 2002

CR 02249046 (1)

Drawing OP-1-5143 Shows 1-IRV-300

and 1-IRV-311 as Open. NRC Inspector

Noted That These Are Normally Closed

Valves.

September 6, 2002

Unit 1 West Residual Heat Removal System Train

01-OHP-4021-008-002

Placing Emergency Core Cooling System

in Standby Readiness

Revision 15b

OP-1-5143-59

Flow Control Diagram Emergency Core

Cooling (Residual Heat Removal) Unit 1

Revision 59

Clearance Order

22825

East Residual Heat Removal Pump

September 3, 2002

CR 02248048 (1)

NRC Identified a Discrepancy Between

the Normal Operating Procedure and the

Operations Flow Print for the Residual

Heat Removal Heat Exchanger Outlet

Sample Valve 1-RHR-120E/W

September 5, 2002

Unit 2 CD Emergency Diesel Generator

2-OHP-4021-032-

008CD

Operating Diesel Generator 2CD

Subsystems

Revision 2

OP-2-5151C-47

Flow Diagram Emergency Diesel

Generator "CD" Unit 2

Revision 47

OP-2-5151D-56

Flow Diagram Emergency Diesel

Generator "CD" Unit 2

Revision 56

CR 02263059 (1)

2-LDA-245-V1, 2-LDA-245 High Pressure

Side Root Valve Has a Small Packing

Leak Evidenced by Droplet Formed

Around the Packing. Leakage Is Too

Small to Be Quantified in Drops Per

Minute.

September 20,

2002

CR 02263060 (1)

2-DL-156C, CD Emergency Diesel

Generator Full Flow Lube Oil Filter

QT-112-CD Bypass Valve, Has a Small

Packing Leak Evidenced by Lube Oil

Around the Packing Gland. Leakage Is

Too Small to Quantify in Drops Per

Minute.

September 20,

2002

CR 02263061 (1)

2-LDA-235-V2, 2-LDA-235 CD

Emergency Diesel Generator Full Flow

Lube Oil Filter QT-112-CD High D/P

Alarm Switch Low Pressure Side Root

Valve Has a Small Packing Leak. Leak

Was Too Small to Quantify in Drop Per

Minute.

September 20,

2002

CR 02264012 (1)

2-DW-246C, CD Emergency Diesel

Generator Jacket Water Surge Tank

Instrument Column Drain Valve,

Handwheel is Against Piping that

Prevents it from Cycling in Full Range

from Fully Closed to Fully Open

September 20,

2002

CR 02264017 (1)

2-DL-156C, CD Emergency Diesel Full

Flow Lube Oil Filter Bypass Valve is

Missing a Stem Spacer Between the

Handwheel and the Valve Bonnet,

Making the Valve Handwheel Loose

September 20,

2002

CR 02264019 (1)

There is No Pipe Cap Installed

Downstream of the Following Jacket

Water Sample Valves (One for Each

Diesel Generator), 2-ED-228A, 2-DG-

28C, 1-DG-227A & 1-DG-227C. CR

Generated to Request Clarification if Pipe

Caps Are Required

September 20,

2002

Miscellaneous Condition Reports

CR 02193057

Procedure Step Missed in Performance

of 1-OHP-4021-082-026

July 12, 2002

CR 02198040

While Performing 12-THP-6020-CHM-

2, the Condensate Chemical Feed

Tank Overflowed Approximately 100

Gallons

July 17, 2002

CR 02220039

Upon Stopping Unit 1 East ESW Pump,

the Unit 1 East ESW Pump Restarted

When the Control Switch Was Placed

Back in Auto

August 8, 2002

CR 02227065

2-AUX-432, Main Steam to 125 Pounds

Auxiliary Steam Pressure Reducing Valve

2-SRV-402 Inlet Shutoff Valve Was

Found in the Incorrect Position

August 15, 2002

CR 02227067

2-AUX-431, Main Steam to 125 Pounds

Auxiliary Steam Header Pressure

Reducing Valve 2-SRFV-400 Inlet Valve

Was Found Out of Position

August 15, 2002

CR 02246010

While Securing the Control Air

Compressor, a Mis-communication

Resulted in the Closing of 1-PA-128.

This Resulted in a Momentary Loss of Air

Supply to the Unit One Control Air

Header and a Lowering Pressure.

September 3, 2002

1R04.2 Complete System Walkdown

Unit 1 and 2 Essential Service Water System

D. C. Cook Nuclear Plant UFSAR

Clearance Order

22729

2-PP-7W West ESW Pump

Replacement-ground Clearance

Revision 0

Clearance Order

22726

2-PP-7W West ESW Pump

Replacement-ground Clearance

Revision 0

2-OHP-4021-019-001

Operation of the Essential Service Water

System

Revision 25

OP-1-5113-79

Flow Diagram Essential Service Water

System Unit 1

Revision 79

OP-2-5113-71

Flow Diagram Essential Service Water

System Unit 2

Revision 71

OP-1-5113A-6

Flow Diagram Essential Service Water

System Unit 1

Revision 6

OP-2-5113A-8

Flow Diagram Essential Service Water

System Unit 2

Revision 8

CR 02249018

License Renewal Project Not Able to

Locate Two ESW Valves on a Flow

Diagram

September 9, 2002

CR 02249020

License Renewal Project Identified

Potential Discrepancies in Pipe Class

Flags

September 9, 2002

1R05

Fire Protection

1R05.1

Routine Resident Inspector Tours

D. C. Cook Nuclear Plant UFSAR,

Section 9.8.1, "Fire Protection System"

D. C. Cook Nuclear Plant Fire Hazards

Analysis, Units 1 and 2

Revision 8

D. C. Cook Nuclear Plant Units 1 and 2

Probabilistic Risk Assessment, Fire

Analysis Notebook

February 1995

PMP 2270.CCM.001

Control of Combustible Materials

Revision 1

PMP 2270.FIRE.002

Responsibilities for Cook Plant Fire

Protection Program Document Updates

Revision 0

PMP 2270.WBG.001

Welding, Burning and Grinding Activities

Revision 0

PMP 5020.RTM.001

Restraint of Transient Material

Revision 1

Plant Managers

Instruction (PMI) 2270

Fire Protection

Revision 26

2-PPP-2270-066-001

Portable Fire Extinguisher Inspections

Revision 0a

D. C. Cook Fire Pre-Plan 078

Revision 1

D. C. Cook Fire Pre-Plan 094

Revision 1

Drawing 12-5267-10

D. C. Cook Fire Facilities Basement Plan

Revision 10

1R06

Flood Protection Measures

D. C. Cook Nuclear Plant UFSAR

D. C. Cook Nuclear Plant Units 1 and 2

Probabilistic Risk Assessment, Internal

Flooding Analysis Noted

April 1992

Engineering Action Plan 01-626, Address

Rain Intrusion/Surface Runoff

June 2001

01-OHP 4024.118

Annunciator #118 Response: Main and

Feed Pump Turbine

Revision 8

2-OHP-4024.218

Annunciator #218 Response: Main and

Feed Pump Turbine

Revision 8

01-OHP 4024.124

Annunciator #124 Response:

Containment

Revision 4

2-OHP-4024.224

Annunciator #224 Response:

Containment

Revision 3a

01-OHP-4024.105

Annunciator #105 Response:

Containment Spray

Revision 8

2-OHP-4024.205

Annunciator #205 Response:

Containment Spray

Revision 6

01-OHP-4024.106

Annunciator #106 Response: Residual

Heat Removal

Revision 8

2-OHP-4024.206

Annunciator #206 Response: Residual

Heat Removal

Revision 6

01-OHP-4024.116

Annunciator #116 Response:

Condensate

Revision 10

2-OHP-4024.216

Annunciator #216 Response:

Condensate

Revision 7

1R11

Licensed Operator Requalification Training

1R11.1 Resident Inspector Quarterly Review

Licensed Operator Requalification

Training Simulator Evaluation Scenario

for August 13, 2002

Licensed Operator Requalification

Training Simulator Evaluation Scenario

for September 24, 2002

1R12

Maintenance Effectiveness

PMP-5035-MRP-001

Maintenance Rule Program

Administration

Revision 4

PMI-5035

Maintenance Rule Program

Revision 9

Auxiliary Feedwater System

Maintenance Rule (a)(1) Action Plan

Auxiliary Feedwater System

Revision 1

Maintenance Rule Scoping Document

Auxiliary Feedwater System

Revision 1

Two-year Unavailability Report for the

Auxiliary Feedwater System

July 16, 2002

CR 02020014

Unit 2 West Motor Driven Auxiliary

Feedwater Pump Coupling Has Thrown a

Substantial Amount of Coupling Grease

on the Inside of the Coupling Guard and

on the Skid below the Coupling

January 20, 2002

CR 02041027

During 2-PP-3E Pump Start Outboard

Packing Gland Reached 190 Degrees

February 10, 2002

CR 02042004

2-PP-3E Outboard Packing Needs to Be

Re-packed

February 11, 2002

600 Volt Safety Related Power

Maintenance Rule Scoping Document

4kV/600V Electrical Distribution System

Revision 4

CR 02139005

Two Fuses Failed Over-current Test

May 19, 2002

CR 02189031

Indication on 1-MFC-111 is Erratic

July 8, 2002

CR 02095031

Relay Found Stuck During Surveillance

April 5, 2002

CR 02102011

Charger 600 Volt Starter Overload Is

Tripping

April 12, 2002

CR 02125063

Breaker Failed Test During Performance

of Surveillance

May 5, 2002

CR 02132013

During Breaker Over-current Testing, the

Breaker Failed to Trip after the Maximum

Allowable Time

May 12, 2002

Emergency Diesel Generators

Maintenance Rule Scoping Document

Emergency Diesel Generators

Revision 2

JO 01046020

DCP-744, 1-OME-150-CD, Install New

High Pressure Fuel Injector Lines

July 12, 2001

JO 02103011

1-PP-163-6R-CD, Replace Pump/Repair

as Needed

April 14, 2002

1-DCP-744

Upgrade of Emergency Diesel Generator

High Pressure Fuel Injector Lines

May 27, 2002

CR 02103011

The Unit 1 CD Emergency Diesel

Generator #6 Rear Fuel Injector Appears

to Be Mechanically Bound

April 13, 2002

Miscellaneous Condition Reports

CR 02019002

Unit 2 N-31 Source Range Detector

Indicates Approximately 1 Decade Lower

than Other Channels

January 19, 2002

CR 02032010

Unit 2 CD2 Battery Charger Tripped Off

When Alternating Current Source Was

Cross-tied.

February 1, 2001

CR 02037084

2-ESW-141, All Internal Parts of the

Valve Except Rubber Inserts Are Missing

February 6, 2002

CR 02054026

2-NRV-151, Pressurizer Train B Pressure

Relief Valve has Seat Leakage

February 23, 2002

CR 02054035

2-NRV-151, 2-NRV-152 and 2-NRV-153

Had to Be Reworked to Stop Leakage

after Maintenance Work to Refurbish the

Actuators During U2C13

February 23, 2002

CR 02055010

2-NRV-151, Pressurizer Train B Pressure

Relief Valve, Leaks-by

February 24, 2002

CR 02056091

2-PP-45-3 "Y" Axis Vibration Probe

Failed and Is Currently Defeated

February 25, 2002

CR 02060013

The 10 Meter Backup Wind Speed

Sensor Appears to Have Failed

March 1, 2002

CR 02060048

2-MRV-220 Repair Required Downpower

to Less Than 5 Percent, Which Was an

Unplanned Power Reduction Greater

Than 20 Percent and Caused a Plant

Level Event for Maintenance Rule

Purposes

March 1, 2002

CR 02081006

Found That There is No Display on the

Face of 2-MU-253 and the Alarm Is in for

this Math Unit

March 22, 2002

CR 02079004

2-SV-78-CD2 CD 2 Air Receiver Safety

Valve Was Discovered Lifting and Would

Not Reseat

March 30, 2002

CR 02092038

Steam Jet Air Ejector Radiation Monitor

Failed its Surveillance

April 2, 2002

CR 02113065

2-OHP-4030-STP-007E, East

Containment Spray System Operability

Test, Does Not Have a Maximum of 60

Gallons Per Minute Water Flow Rate for

from the Spray Addictive Tank Line with

Spray Pump on Recirculation as Stated

in TS Bases Section 3/4.6.2.2

April 23, 2002

CR 02115039

Insulator for Disconnect for K1 Breaker

Damaged During Maintenance

April 25, 2002

CR 02115046

2-ERS-2300 Declared Inoperable.

Sample Pump Will Not Start

April 25, 2002

CR 02128037

1-CCW-135 Is Leaking by During Local

Leak Rate Testing at a Rate Greater than

Allowed

May 8, 2002

CR 02136085

Tracking CR for (a)(1) Presentation for

Maintenance Preventable Functional

Failure

May 16, 2002

1R13

Maintenance Risk Assessments and Emergent Work Evaluation

PMP-2291-OLR-001

On-Line Risk Management

Revision 2

PMP-2291-SCH-001,

Data Sheet 1

Work Control Activity Scheduling Process

Sponsored Work Authorization

August 29, 2002

NUMARC 93-01

Industry Guideline for Monitoring the

Effectiveness of Maintenance at Nuclear

Power Plants, Section 11, "Assessment

of Risk Resulting From Performance of

Maintenance Activities"

Revision 2

Unit 2 Pressurizer Power Operated Relief Valves (PORVs) Troubleshooting

Daily Shift Managers Logs

August 20, 2002

through

August 21, 2002

Unit 2 Pressurizer PORV (2-NRV-151,

2, 153) Troubleshooting Team Meeting

Minutes

August 20, 2002

Unit 2 Pressurizer PORV (2-NRV-151,

2, 153) Troubleshooting Team Meeting

Minutes

August 21, 2002

CR 02228055

2-NRV-151 Has Excessive Seat Leakage

August 16, 2002

CR 02230010

2-NRV-153 Is Leaking Past Its Closed

Seat

August 18, 2002

CR 02230011

2-NRV-152 Leaks Past Its Closed Seat

August 18, 2002

Unit 2 West Component Cooling Water System Train Maintenance

PMP-2291-OLR-001

Data Sheet 1

On-Line Risk Management Work

Schedule Review and Approval Form

Cycle 42, Week 3

July 14, 2002

through July 20,

2002

Unit 2 East Component Cooling Water System Train Maintenance

Daily Shift Managers Logs

August 28, 2002

PMP-2291-OLR-001,

Data Sheet 1

On-Line Risk Management Work

Schedule Review and Approval Form

Cycle 42, Week 9

August 27, 2002

through

August 30, 2002

Unit 2 East Charging System Train Maintenance

Daily Shift Managers Logs

August 28, 2002

PMP-2291-OLR-001,

Data Sheet 1

On-Line Risk Management Work

Schedule Review and Approval Form

Cycle 42, Week 9

August 25, 2002

through

August 31, 2002

Unit 1 East Residual Heat Removal System Train Maintenance

PMP-2291-OLR-001,

Data Sheet 1

On-Line Risk Management Work

Schedule Review and Approval Form

Cycle 42, Week 9

August 25, 2002

through

August 31, 2002

Unit 2 West Component Cooling Water System Train Maintenance

On-Line Risk Management Work

Schedule Review and Approval Form

Cycle 42, Week 3

July 14, 2002

through

July 20, 2002

Unit 2 West Essential Service Water Pump Maintenance

On-Line Risk Management Work

Schedule Review and Approval Form

Cycle 42, Week 11

September 8, 2002

through

September 14,

2002

NRC Letter to Mr. A. C. Bakken III

Subject: Donald

C. Cook Nuclear Plant,

Units 1 and 2 - Issuance of Amendments

(TAC NOS. MB5729 and MB5730)

{License Amendments 270 and 251,

Respectively}

September 9, 2002

Safety Evaluation for License

Amendment 270 to Unit One License and

License Amendment 251 to Unit Two

License

September 9, 2002

PMP 2291-OLR.001

Data Sheet 1

Work Schedule Review and Approval

Form Cycle 42, Week 11 and Cycle,

Week

September 8, 2002

through September

14, 2002

Safety Monitor Printout for 140 Hour

Allowed Outage Time License Condition

Case

July 24, 2002

CR 02253016

UFSAR Section 9.8.3.4, Item 5 Issued in

Version 17.3 Did Not Name Both

Probabilistic Risk Assessment Elements

September 11,

2002

Unit 2 Reserve Feed Transformer Maintenance

PMP-4100-SDR-001

Plant Shutdown Safety and Risk

Management

Revision 5a

PMP-5035-MRP-001

Maintenance Rule Program

Administration

Revision 4

On-Line Risk Management Work

Schedule Review and Approval Form

Cycle 42, Week 5

July 28, 2002

through

August 3, 2002

Unit 1 On-Line Risk Status and

Unit 2 Shutdown Risk Status

July 30, 2002 and

July 31, 2001

American Electric Power Eastern System

Emergency Operating Plan

Version 3.1

June 2001

1R15

Operability Evaluations

D. C. Cook Nuclear Plant Unit 1 and 2

Technical Specifications

D. C. Cook Nuclear Plant UFSAR

Generic Letter 91-18

Information to Licensees Regarding NRC

Inspection Manual Section on Resolution

of Degraded and Nonconforming

Conditions

Revision 1

PMP-7030-ORP-001

Operability Determinations

Revision 9

PMP 4030-001-001

Impact of Safety Related Ventilation on

the Operability of Technical Specification

Equipment

Revision 4

Calculation

MD-12-RH-129-N

Maximum Differential Pressure During

Operation of Centrifugal Charging Pump

Suction Valves 1-IMO-910, 1-IMO-911,

2-IMO-910, & 2-IMO-911

Revision 2

CR 01020010

2-HV-AES-2 Fan Was Discovered

Rotating Backwards Due to Backdraft

Damper Being Open

January 20, 2001

CR 02113065

2-OHP-4030-STP-007E, East

Containment Spray System Operability

Test, Does Not Have a Maximum of 60

Gallons Per Minute Water Flow Rate for

from the Spray Addictive Tank Line with

Spray Pump on Recirculation as Stated

in TS Bases Section 3/4.6.2.2

April 23, 2002

CR 02116032

1-HV-AES-2 Exhaust Fan Was Found in

Standby With its Backdraft Damper Stuck

Partially Open and the Fan Rotating

Backwards

April 26, 2002

CR 02122057

1-IMO-911 Could Not Be Set Within the

Prescribed Thrust Limitations Provided in

VDS-1-IMO-911

May 2, 2002

CR 02125016

Potentially High Boron Concentration

(Above 2600 Parts Per Million) in Unit 1

Reactor Coolant System in Mode 4

Shortly Before Entering Mode 5

May 5, 2002

CR 02141011

During the Performance of 1-EHP-4030-

28-229, Section 4.7, Outside Air Control

Room Ventilation Dampers Would Not

Seal

May 21, 2002

CR 0214013

Unit 1 "CD" Engine 4R Cylinder Injector

Return Line has Separated Ferrule

May 21, 2002

CR 02186022

Procedure Noncompliance on Call Made

on CR 02137011 for Inservice Testing

Stroke Time Failure of Steam Generator

PORV 2-MRV-233

July 5, 2002

CR 02238004

Significant Ice Buildup Was Found in

Unit 1 Ice Condenser During Operations

Ice Tour

August 25, 2002

CR 02245008

Thermal Power Calorimetric in Unit Two,

Displayed "Unknown" Quality for Loop 3

and 4 Enthalpy While 2-FPI-230, S/G #3

Feed Pressure Channel was being

Calibrated

September 2, 2002

CR 02264018

Unit 1 Control Room Door Was Propped

Open Without Specific Procedure

Guidance to Allow It to Be Open

September 21,

2002

1R16

Operator Workarounds

PMP-4010-OWA-001

Oversight and Control of Operator

Workarounds

Revision 1

NRC Inspection Manual

Temporary Instruction

2515/138

Evaluation of the Cumulative Effect of

Operator Workarounds

Work Around Review Board Meeting

Agenda

July 24, 2002

Work Around Review Board Meeting

Minutes

July 24, 2002

Work Around Review Board Meeting

Agenda

September 25,

2002

Unit 1 Operator Workarounds

July 16, 2002

Unit 2 Operator Workarounds

July 16, 2002

Unit 1 Operator Workarounds

September 23,

2002

Unit 2 Operator Workarounds

September 23,

2002

Unit 1 Operator Workarounds

Contingency Actions for Reactor

Operators

September 24,

2002

Unit 1 Operator Workarounds

Compensatory Actions for Auxiliary

Equipment Operators

September 24,

2002

Unit 2 Operator Workarounds

Contingency Actions for Reactor

Operators

September 24,

2002

Unit 2 Operator Workarounds

Compensatory Actions for Auxiliary

Equipment Operators

September 24,

2002

CR P-99-03751

Demineralized Water Makeup to Control

Room Air Conditioning Units Appears

Possibly to Have a Design to Be

Operated in the Automatic Mode and We

Operate in the Manual Mode

February 26, 1999

CR 02106030

Generate a Routine Task to Cycle ESW

Valve 1-ESW-115 on a Monthly Basis

April 16, 2002

CR 02106032

Generate a Routine Task to Cycle ESW

Valves 2-ESW-240 and 2-ESW-145 on a

Monthly Basis

April 16, 2002

CR 02140025

1-QFC-411 Did Not Show Any Indication

of Flow with Flow Actually Present

May 20, 2002

CR 02152005

The Control Valve Does Not

Automatically Control the Pressure in the

Chilled Water System for the Control

Room Air Conditioning System

June 1, 2002

CR 02210010 (1)

Operator Workaround Board Aggregate

Impact Attachment and Minute Meetings

Were Not Performed in Accordance with

Procedure

July 29, 2002

CR 02229001

The Makup Pump South Middle Prefilter

Automatic Regeneration Timer Control

Box Does Not Function as Designed

August 17, 2002

CR 02230003

While Operating the Steam Generator

Blowdown System on the Normal Blow

Down Tank with the Effluent Aligned to 2-

DRV-350 Frequent Blow Down Low

Sample Alarms Were Received

August 18, 2002

CR 02231001

1-SV-101 (Nitrogen Supply Header to

Accumulator Tanks Safety Valve) Lifted

During Performance of

01-OHP-4021-008-006 (Adjusting

Pressure in Accumulator)

August 19, 2002

CR 02234103

The Screen Save Time Out Function on

the Radiation Monitoring System Control

Terminal in the Radiation Protection

Office Varies From Less Than One

Minute to Over Seven Minutes

August 22, 2002

CR 02236013

1-CMO-429-PI Control Room Position

Indicator Doesnt Move While Valve is

Operated and Is Indicating Approximately

Percent Open with the Valve Fully

Closed

August 24, 2002

CR 02246018

2-WMO-101 Low Pressure Turbine "A"

Northeast Circulating Water Inlet Valve

Continues to Drift Off the Open Seat and

Not Evaluated for Operator Workaround

or Repetitive Action on Equipment

Condition

September 3, 2002

1R17

Permanent Plant Modifications

Design Change

Procedure (DCP) 5173

Unit 1 Provide Essential Service Water

Minimum Flow Path Via Containment

Spray System Heat Exchanger

Revision 0

DCP 5174

Unit 2 Provide Essential Service Water

Minimum Flow Path Via Containment

Spray System Heat Exchanger

Revision 0

Owners Acceptance

Review of AEP-01-119

Large Break Loss of Coolant Accident

Evaluation for Reduced Containment

Spray Temperature

September 17,

2001

AEP-99-480

Westinghouse Sub-atmospheric

Containment Evaluation Report

December 20,

1999

1R19

Post Maintenance Testing

Unit 2 West Component Cooling Water System Train Maintenance

Job Order (JO)

C0192651

Perform Inservice Stroke Time Test of

2-CMO-414

July 21, 2002

JO R0220063

Perform Operability Test of 2-PP-10W

Supply Breaker

July 21, 2002

JO R0222866

Place in Service (Post Maintenance Test)

2-PP-10W

July 21, 2002

JO R0228055

Support Leak Check and Perform Post

Maintenance Test of 2-PP-10W

July 21, 2002

JO R0229289

West Component Cooling Water Loop

Surveillance

July 21, 2002

JO R0231895

West Component Cooling Water Loop

Flow Path Verification

July 21, 2002

2-OHP-4030-216-020W

West Component Cooling Water Loop

Surveillance Test

Revision 1

Engineering Programs

Technical Data Book

Figure 2-15.1

Safety Related Pump Inservice Test

Hydraulic Reference

Revision 59

Engineering Programs

Technical Data Book

Figure 2-15.2

Safety Related Pump Inservice Test

Vibration Reference

Revision 52

Engineering Programs

Technical Data Book

Figure 2-19.1

Power Operated Valve Stroke Time

Limits

Revision 56

Unit 2 East Auxiliary Feedwater Pump Maintenance

2-OHP-4030-STP-017E

East Motor Drive Auxiliary Feedwater

System Test

Revision 10

Engineering Programs

Technical Data Book

Figure 2-15.1

Safety Related Pump Inservice Test

Hydraulic Reference

Revision 60

Engineering Programs

Technical Data Book

Figure 2-15.2

Safety Related Pump Inservice Test

Vibration Reference

Revision 53

Engineering Programs

Technical Data Book

Figure 2-19.1

Power Operated Valve Stroke Time

Limits

Revision 56

Engineering Control

Package 1-2-F2-01

Feedwater Flow Instrumentation

Revision 19

CR 02219071

Increasing Vibration Levels on 2-PP-3E

Motor

August 7, 2002

CR 02221033

While Performing 02-OHP-4030-STP-

017E, Erratic Flow Oscillations Were

Observed on the Common Emergency

Leak-off/Test Line Test Instrument

August 9, 2002

CR 02221037

Job Order Step Was Not Completed As

Written

August 9, 2002

CR 02226074 (1)

Completeness of Documentation and

Review Issues Associated With Recent

Performances of 02-OHP-4030-STP-

017E Identified by NRC Senior Resident

Inspector

August 14, 2002

Unit 1 East Residual Heat Removal System Train Maintenance

JO R0209505

Lubricate and Clean Residual Heat

Removal Pump 1-PP-35E Motor

September 5, 2002

01-OHP-4030-STP-050E

East Residual Heat Removal Train

Operability Test Modes 1-4

Revision 9

Unit 2 North Safety Injection Pump Maintenance

2-OHP-STP-051N

North Safety Injection Pump System Test

Revision 11

OP-2-5142-44

Flow Diagram Emergency Core Cooling

Revision 44

Unit 2 AB Emergency Diesel Generator Maintenance

JO R0097099-03

Post Maintenance Test for Time Delay

Relay 2-62-1-LQBA-DGAB

September 21,

2002

JO R0097141-05

Support Instrument Maintenance Post

Maintenance Test of AB Diesel Time

Delay Relays

September 21,

2002

JO R0216722-02

Rack Out/Rack In 2-T21A11 for Post

Maintenance Test

September 21,

2002

JO R0216737-02

Rack In and Cycle 2-21A5

September 21,

2002

JO R0216751-02

Rack Out/Rack In 2-T21B4

September 21,

2002

JO R0216756-03

2-T-131-5, Verify Operability

September 21,

2002

JO R0216757-03

2-T-131-6, Verify Operability

September 21,

2002

JO R0221576-02

2-QT-111-AB, Run Pump to Verify Proper

Operation

September 21,

2002

JO R0232273-01

Quarterly Inservice Test AB1 Fuel

Transfer Pump

September 21,

2002

JO R0233374-01

AB Emergency Diesel Generator

Alternate ESW Supply Valve Testing

September 21,

2002

JO R0234524-02

STP 027AB Diesel Generator 2AB Slow

Start

September 21,

2002

2-OHP-4030-STP-

27AB

AB Diesel Generator Operability Test

(Train B)

Revision 18

2-OHP-4021-082-020

Removal and Restoration of Power to

600 Volt Bus 21A and Associated Motor

Control Centers

Revision 3

2-OHP-4021-032-008AB

Operating DG2AB Subsystems

Revision 2

Unit 2 West Essential Service Water Pump Replacement

2-DCP-5260-TP-U2W

Unit 2 West Essential Service Water

Pump Performance and Full Flow Test

September 17,

2002

2-LDCP-5260

Essential Service Water Pump Upgrades

for Reliability

Revision 0

2-OHP-4030-219-022W

West Essential Service Water System

Test

Revision 2

Engineering Programs

Technical Data Book

Figure 2-15.1

Safety Related Pump Inservice Test

Hydraulic Reference

Revision 61

Engineering Programs

Technical Data Book

Figure 2-15.2

Safety Related Pump Inservice Test

Vibration Reference

Revision 54

Engineering Programs

Technical Data Book

Figure 2-19.1

Power Operated Valve Stroke Time

Limits

Revision 56

Unit 2 East Centrifugal Charging System Train Maintenance

JO R022245101

Lube and Clean 2-PP-50E-MTR

August 29, 2002

JO R022245202

Clean Filter/Lube Couplings

August 29, 2002

JO R022777602

Drain and Refill Speed Increaser

August 29, 2002

2-OHP-4030-STP-052E

East Centrifugal Charging Pump

Operability Test

Revision 11

Engineering Programs

Technical Data Book

Figure 2-15.1

Safety Related Pump Inservice Test

Hydraulic Reference

Revision 60

Engineering Programs

Technical Data Book

Figure 2-15.2

Safety Related Pump Inservice Test

Vibration Reference

Revision 53

Unit 2 East Component Cooling Water System Train Maintenance

JO R022779501

Drain and Refill Unit 2 East Component

Cooling Water Pump Oil Reservoir

August 29, 2002

JO R021620801

Calibrate Protective Relays for Breaker

August 29, 2002

2-IHP-6030-RLY-002

General Electric Type PJC Instantaneous

Relay Calibration and Maintenance

Revision 2

2-OHP-4030-216-020E

East Component Cooling Water Loop

Surveillance Test

Revision 1

Engineering Programs

Technical Data Book

Figure 2-15.1

Safety Related Pump Inservice Test

Hydraulic Reference

Revision 60

Engineering Programs

Technical Data Book

Figure 2-15.2

Safety Related Pump Inservice Test

Vibration Reference

Revision 53

Engineering Programs

Technical Data Book

Figure 2-19.1

Power Operated Valve Stroke Time

Limits

Revision 56

Miscellaneous Condition Reports

CR 02194001

Loss of Oil Level in 2-PP-4 (Turbine

Driven Auxiliary Feedwater Pump)

Turbine Oil Sump

July 13, 2002

1R20

Refueling and Outage Activities

1R20.1 Unit 2 Forced Outage

D. C. Cook Nuclear Plant Unit 2

Technical Specifications

D. C. Cook Nuclear Plant UFSAR

01-OHP-4021-001-004

Plant Cooldown From Hot Standby to

Cold Shutdown

Revision 36

OHP 4021-017-002

Placing In Service The Residual Heat

Removal System

Revision 16

01-OHP-4021-001-002

Reactor Startup

Revision 27a

01-OHP-4030-114-030

Daily and Shiftly Surveillance Checks

Revision 0

PMP 4100-SDR-001

Plant Shutdown Safety and Risk

Management

Revision 5, C1

Daily Shift Managers Logs

July 27, 2002

through

August 2, 2002

CR 02208007

2-WMO-23 Appears to Have Failed

Closed

July 27, 2002

1R22

Surveillance Testing

D. C. Cook Nuclear Plant UFSAR

D. C. Cook Nuclear Plant Technical

Specifications

2-OHP-4030-STP-030

Daily and Shiftly Surveillance Checks

performed on July 2, 2002 for Unit 2

Revision 39

EHP 6040-PER-323

Flux Mapping System Operation and

Supportive Data Collection

Revision 4a

2-IHP-4030-STP-511

Train B Reactor Protection System and

Engineered Safety Features Reactor Trip

Breaker and Solid State Protection

System Automatic Trip/Actuation Logic

Functional Test

Revision 4

01-IHP-4030-SMP-103

Reactor Coolant Flow Protection Set III

Functional Test and Calibration

Revision 4

01-IHP-4030-SMP-104

Delta T/Tavg Protection Set I Functional

Test and Calibration

Revision 4

CR 02135079

On May 15, 2002, During the Unit 2

Power Ascension, the N-35 Rod Stop

Bistable Actuated Prior to the Blocking of

P-10. It Was Subsequently Determined

that the N-35 and N-36 Trip and Rod

Stop Setpoints/Resets Need to Be Reset

May 15, 2002

CR 02204023

Inservice Test for the 1W Containment

Spray Pump Was Completed Without

Using the Correct Reference Values

July 23, 2002

1R23

Temporary Plant Modifications

D. C. Cook Nuclear Plant UFSAR

Temporary Modification

2-TM-00-57-R1

On-line Leak Repair of 2-FW-118-4

March 19, 2002

2-EHP-5040-MOD-001

Temporary Modifications

Revision 9

2-MHP-5021-001-051

Installation of Temporary On-line Leak

Sealing

Revision 7

JO 00267043-01

2-FW-118-4 Temporary Leak Seal

April 12, 2002

CFR 50.59 Safety

Screening 2000-2016-00

2-FW-118-4 Temporary Leak Seal

September 29,

2000

CFR 50.59

Applicability

Determination

2002-0494-00

Temporary Modification 2-TM-00-57-R1

March 15, 2002

NRC Inspection Manual

Part 9900 Technical

Guidance

On-line Leak Sealing Guidelines for

ASME [American Society of Mechanical

Engineers] Code Class 1 and 2

Components

July 15, 1997

NRC Information Notice 93-90

Unisolatable Reactor Coolant System

Leak Following Repeated Applications of

Leak Sealant

December 1, 1993

CR 02263047 (1)

Completed Procedure was not Vaulted as

Required

September 20,

2002

CR 02263057 (1)

The Completed Signed Off Version of the

Furmanite package/procedure Could Not

Be Located

September 20,

2002

1EP6

Drill Evaluation

Cook Nuclear Plant Emergency Plan

Training Drill Scenario August 22, 2002

Revision 1

Desktop Guide for Emergency Planning

Performance Indicators

Revision 2

PMP-2080-EPP-107

Notifications

Revision 16

2OS1 Access Controls for Radiologically Significant Areas

2-THP-6010-RPP-006

Radiation Work Permit Processing

Revision 17

PMP-6010-RPP-003

High, Locked High, and Very High

Radiation Area Access

Revision 10

2-THP-6010-RPP-016

Radiation Protection Department Shift

Technician Responsibilities

Revision 4

THG.026

Locked High Radiation Area and Very

High Radiation Area Shiftly Verification

Process

Revision 0

Administrative Guideline

High, Locked High and Very High

Radiation Area Controls

Revision 0

Radiation Protection Department Key

Inventory Log

January 1, 2002

through

July 23, 2002

Radiation Protection Department Key

Issuance/Return Log

January 1, 2002

through

July 23, 2002

PMP-2220-001-001

Foreign Material Exclusion

Revision 2a

Non Fuel Related Spent Fuel Pool

Inventory

July 2002

CR 02055004

Key Log Inventory Not Performed

February 24, 2002

CR 02126004

Locked High Radiation Area Posting

May 5, 2002

CR 02153015

601 Pipe Tunnel Floor Hatch Improperly

Posted

June 2, 2002

CR 0219900

Results of Institute of Nuclear Power

Operations Assist Visit

July 18, 2002

2OS3 Radiation Monitoring Instrumentation and Protective Equipment

2-THP-6010-RPP-500

Radiation Protection Instruments

Revision 1

2-THP-6010-RPI-500

Instrument Issue and Operational Testing

Revision 13

2-THP-6010-RPI-805

Radiation Monitoring System Setpoints

Revision 14

Activity Information for Instrument Check

Sources

Various Dates

Form RP-572-a

Portal Monitor Calibration Data Sheet

(Monitor # POR-454)

April 20, 2002

Form RP-818-b

DA1-8 Area Monitor Calibration Data

Sheet (U-1 North Seal Water Injection

Filter Cubicle)

July 18, 2001

Form RP-818-b

DA1-8 Area Monitor Calibration Data

Sheet (U-2 South Seal Water Injection

Filter Cubicle)

March 5, 2002

Form RP-818-b

DA1-8 Area Monitor Calibration Data

Sheet (U-1 West Centrifugal Charging

Pump Room)

July 18, 2001

2-THP-6010-RPC-818

Eberline Radiation Monitoring System

DA1-8 Area Monitor Calibration

Revision 1

2-THP-06010-RPC-566

Source Characterization and Verification

for the J. L. Shepherd Models M89 and

M142-S

Revision 5b

2-THP-06010-RPC-566,

Data Sheet 1

Shepherd Model 89 Exposure Rate

Verification Data Sheet (Instrument M89-

and M89-2)

January 30, 2002

Global Calibration Laboratory Calibration

Data Sheet (Ion Chamber Model 20X5-

180, Serial # 21822 and Electrometer

Model 2025, Serial # 5878)

May 2002

UFSAR, Table 11.3-1

Radiation Monitoring System Channel

Sensitivities and Detecting Medium

Revision 17

1-IHP-6030-IMP-311

Calibration of High Range Containment

Radiation Monitor VRA-1310

December 20,

2001

1-IHP-6030-IMP-312

Calibration of High Range Containment

Radiation Monitor VRA-1410

December 15,

2001

2-IHP-6030-IMP-411

Calibration of High Range Containment

Radiation Monitor VRA 2310

March 13, 2002

2-IHP-6030-IMP-412

Calibration of High range Containment

Radiation Monitor VRA 2410

September 13,

2001

2-IHP-6030-IMP-679

Seal Water Filter Cubicle Area Radiation

Monitor 2-ERS-8400 Functional Check

and Instrument Calibration

Revision 2

1-IHP-6030-IMP-579

Seal Water Filter Cubicle Area Radiation

Monitor 1-ERS-7400 Functional Check

and Instrument Calibration

Revision 1

2-THP-6010-RPP-201

Maintenance and Repair of Respiratory

Devices

Revision 6

SCBA Inventory and Location Chart

Undated

RP Form 201-02

SCBA Inspections

May 2002 through

July 2002

List of Users Qualified to Perform SCBA

Inspections/Tests

Undated

MSA Training Certificate

Certificate for Specified RP Technician

July 24, 2001

MSA Instruction Manual

Portable Regulator Tester III

Undated

SCBA Regulator Calibration Log

July 24, 2002

PMP-6010-RPP-201

Control and Use of Respiratory

Protection Devices

Revision 10

SCBA Training/Qualification Matrices For

Selected Emergency Response

Organization Members

July 25, 2002

D. C. Cook Emergency

Plan

Planning Standard J - Protective

Response

Revision 17

Self-Assessment

SA-2001-SPS-002

SCBA Qualifications of Maintenance

Personnel Assigned to the Operations

Staging Area

January 29, 2001

CR 02048049

Back-up Compressor Grade-D Air

Sample

February 17, 2002

CR 02050073

Breathing Air Quality Checks

February 19, 2002

CR 02052015

Emergency Response Air Packs Not

Serviced Timely

February 21, 2002

2PS1

Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems

Annual Radioactive Effluent Release

Report

January 1, 1999 to

December 31,

1999

Annual Radioactive Effluent Release

Report

January 1, 2000 to

December 2000

Annual Radioactive Effluent Release

Report

January 1, 2001 to

December 31,

2001

PMP-6010-OSD.001

Offsite Dose Calculation Manual

Revision 17

2-THP-6010-RPI-805

Radiation Monitoring System Setpoints

Revision 14

2-THP-6010-RPI-805;

Data Sheet 1

Setpoint Determination for Unit 1

Condenser Exhaust Low Range Noble

Gas

April 17, 2002

2-THP-6010-RPI-805;

Data Sheet 1

Setpoint Determination for Unit 2 Unit

Vent Low Range Noble Gas

March 27, 2002

RP-8053

RMS High Alarm Setpoint/General

Parameter Change; Unit 1 Essential

Service Water Heat Exchanger

August 17, 1996

2-THP-6020-CHM-308

Effluent Batch Releases

Revision 5d

2-THP-6010-RPP-603

Gaseous Waste Releases (Manual

Calculations)

Revision 10b

01-EHP-4030.128.228A

1-HV-AES-1 Engineered Safety Feature

Ventilation Surveillance

November 21,2001

2-EHP-4030.228.228B

2-HV-AES-2 Engineered Safety Feature

Ventilation Surveillance

December 7, 2001

2-EHP-4030.228.228A

2-HV-AES-1 Engineered Safety Feature

Ventilation Surveillance

October 1, 2001

01-EHP-4030.128.228B

1-HV-AES-2 Engineered Safety Feature

Ventilation Surveillance

December 11,

2001

01-EHP-4030.128.228B

1-HV-AES-2 Engineered Safety Feature

Ventilation Surveillance

August 13, 2002

2-THP-6010-RPP.007

RP Calculation for Determination of

Reference Response to Beta Disc

Source Set for Eberline RDA-3A

Detectors

2-THP-6010-RPC-810

Data Sheet 1; Calibration Record for Unit

Condenser Air Ejector Exhaust Monitor

September 5, 2001

2-THP-6010-RPC-810

Data Sheet 1; Calibration Record for Unit

Vent Exhaust Monitor

October 16, 2001

2-THP-6010-RPC-810;

Data Sheet 1

Calibration Record for Unit 1 Vent

Exhaust Monitor

July 13, 2001

Form RP 8021

Calibration Record for Unit 1 Steam

Generator Blowdown Monitor

July 6, 2002

Form RP 8021

Calibration Record for Unit 2 Steam

Generator Blowdown Monitor

July 6, 2002

Form RP-8021

Calibration Record for Unit 1 Essential

Service Water Monitor (East Heat

Exchanger)

August 13, 2002

Form RP-8021

Calibration Record for Unit 1 Essential

Service Water Monitor (West Heat

Exchanger)

January 9, 2002

Form RP-8021

Calibration Record for Unit 2 Essential

Service Water Monitor (East Heat

Exchanger)

January 7, 2002

Form RP-8021

Calibration Record for Unit 2 Essential

Service Water Monitor (West Heat

Exchanger)

March 28, 2002

2-THP-6010-RPC-810;

Data Sheet 1

Calibration Record for Common Unit

Liquid Radwaste Line

November 15,

2001

1IHP-4030-SMP.301

Turbine Gland Seal Exhaust Condenser

Vent Gaseous Effluent Flow Functional

Test and Calibration

November 30,

2001

1IHP-4030-SMP.302

Auxiliary Building Ventilation Gaseous

Effluent Flow Functional Test and

Calibration

November 30,

2001

IHP-4030-SMP.401

Turbine Gland Seal Exhaust Condenser

Vent Gaseous Effluent Flow Functional

Test and Calibration

November 30,

2001

IHP-4030-SMP.402

Auxiliary Building Ventilation Gaseous

Effluent Flow Functional Test and

Calibration

November 30,

2001

THP-6010-RPP.007

RP Calculation for Determination of Low

Range Noble Gas Detector Calibration

Constant

June 18, 1997

2-THI-2291-ADM-012

Work Control Process

Revision 2c

2-THP-6020-CHM-322

Vent Stack Gaseous Sampling

Revision 1

Results of Radiochemistry Cross Check

Program

First and Second

Quarters 2002

Energy Calibration Records for Gamma

Spectroscopy Equipment

July 1, 2002

Efficiency Check Records for Gamma

Spectroscopy Equipment

April and May 2002

LLD Determinations for Gamma

Spectroscopy Equipment

May 2002

CR 02270029

Poor Quality Evaluation of CR 02204001

September 27,

2002

Ten Year Summary Data for Liquid and

Gaseous Effluent Releases

CR 02253014

Chemistry Liquid Scintillation Counter

Beta/Alpha Analysis Methods Found

Outside of Acceptance Criteria

September 10,

2002

CR Data Base Listing for Effluent

Monitoring and Controls

September 2001 -

September 2002

CR 0204001

Late Channel Functional Test

July 23, 2002

Radiation Monitoring System Health

Data, A(1) Action Plans, and Reliability

Improvement Plans for Variety of Effluent

Monitors

2001 - September

2002

RP Self-Assessment

Report

ODCM and Effluents

August 2001

Performance Assurance

Field Observation

Gas Decay Tank Release

January 27, 2002

Performance Assurance

Field Observation

Readiness to Perform Steam Generator

Drains

January 22, 2002

Performance Assurance

Audit (PA-01-06)

Chemistry Program

January 11, 2002

4OA1 Performance Indicator (PI) Verification

NEI 99-02

Regulatory Assessment Performance

Indicator Guideline

Revision 2

Special Plant Procedure

2060-SFI-101

PI Data Gathering

Revision 0

PMP 7110.PIP.001

Regulatory Oversight Program PI

Revision 1

Radiologically Controlled Area Electronic

Dosimetry Exit Transactions Summary

Report

January 1, 2002

through

July 18, 2002

CR Database for All Radiation Protection

Department Initiated or Assigned Issues

January 1, 2002

through

July 18, 2002

Letter from

J. Pollock, American Electric

Power, to the US NRC, Subject: "Cook

Unit 1 and 2 -- 4Q2001 -- PI Data

Elements (QR and CR)"

January 17, 2002

Letter from

J. Pollock, American Electric

Power, to the US NRC, Subject: "Cook

Unit 1 and 2 -- 1Q2002 -- PI Data

Elements (QR and CR)"

April 19, 2002

Letter from

J. Pollock, American Electric

Power, to the US NRC, Subject: "Cook

Unit 1 and 2 -- 2Q2002 -- PI Data

Elements (QR and CR)"

July 18, 2002

Unavailability Report for Emergency

Diesel Generators

October 1, 2001

through

June 30, 2002

Unavailability Report for Auxiliary

Feedwater System

October 1, 2001

through

June 30, 2002

CR 01355058 (1)

Inconsistent Reporting of Unavailable

Hours for the Maintenance Rule and the

Reactor Oversight Process for the Same

Conditions

December 21,

2001

CR 01355071 (1)

Safety System Unavailable Hours

Reported in the Reactor Oversight

Process for the 4Q2000 and 1Q2001

Were Reported for the Wrong Train

December 21,

2001

Chemistry Radiochemical Analysis

Results for Selected Periods in 2002,

Offsite Dose Calculation Data Sheets for

Selected Periods in 2001 and 2002 and

Liquid /Gaseous Effluent Dose Summary

Information for November 2001 -

September 2002

4OA3 Event Follow-up

4OA3.1 Unit 2 Reactor Trip and Restart Following Loss of Main Condenser Vacuum

NRC Event Notification 38993

Unit 2 Automatic Reactor Trip Due to

Loss of Main Condenser Vacuum

July 22, 2002

PMP 4010.TRP.001

Data Sheet 1

Unit Two Reactor Trip Review Report

July 22, 2002

LER 316-2002-006-00

Unit 2 Reactor Trip Due to Low

Condenser Vacuum

September 6, 2002

2-OHP-4021-057-006

Operation of Main and Feed Pump

Condensers

Revision 11

Shift Managers Daily Logs

July 22, 2002

CR 02203001

Unit 2 Reactor Automatically Tripped

From 100 Percent Power While Flushing

Main Turbine Condenser Waterboxes

July 22, 2002

CR 02203007

Excessive Reactor Coolant System

Cooldown After Automatic Unit 2 Reactor

Trip

July 22, 2002

CR 02203019

The Closure Time for Unit 2 Main Turbine

Stop Valve "C" Was Abnormally Slow

After the Turbine Trip

July 22, 2002

CR 02203023

Procedure Enhancement for

OHP-4021-057-006, Attachment 9,

"Flushing of Circulating Water Side of

Condenser Halves"

July 22, 2002

CR 02203026

2-MRV-230, The Steam Generator #2

Main Steam Stop Drifts Closed If the

Control Switch is Not in the Open

Position

July 22, 2002

4OA3.2

Pressurizer Power Operated Relief Valve Inadvertently Opened During

Testing Resulting in a Loss of Reactor Coolant System Inventory and an

Unusual Event

NRC Event Notification 38967

Unit 1 Declared an Unusual Event Due to

Reactor Coolant System Leakage

Greater Than 25 Gallons-Per-Minute

During Surveillance Testing

June 6, 2002

01-OHP-4030-102-017

Pressurizer PORV Actuation Channel

Calibration with Valve Operation (for

Modes 1, 2, and 3)

Revision 0

01-OHP-4030-102-017

Pressurizer PORV Actuation Channel

Calibration with Valve Operation (for

Modes 1, 2, and 3)

Revision 1

Daily Shift Managers Logs

June 5, 2002

through

June 6, 2002

CR 02157039

Pressurizer PORV 1-NRV-153 Opened

During Testing with its Block Valve Open,

Causing an Unexpected Release of

Reactor Coolant System Inventory into

the Pressurizer Relief Tank

June 6, 2002

CR 02157101

Evaluate Timeliness of NRC Notification

for Unusual Event Declared Based on

PORV Opening on June 5, 2002 at 23:00

June 6, 2002

4OA3.3

LER 315-2002-003-00, "Main Steam Safety Valves Exceeded Allowable Lift

Setpoints"

LER 315-2002-003-00

Main Steam Safety Valves Exceeded

Allowable Lift Setpoints

June 28, 2002

American Society of

Mechanical Engineers

(ASME) / American

National Standards

Institute (ANSI)

OMa-1988

Addenda to ASME/ANSI OM-1987,

Operation and Maintenance of Nuclear

Power Plants

February 15, 1989

NUREG 1482

Guidelines for Inservice Testing at

Nuclear Power Plants

April 1995

CR P-99-09868

High Failure Rate of the Main Steam

Safety Valves "As Found" Lift Pressure

April 29, 1999

CR 02122063

1-SV-2A-2 Failed the As Found Set Point

Test

May 2, 2002

CR 02123003

1-SV-1B-3 Failed the As Found Set Point

Test

May 3, 2002

CR 02123037

1-SV-2B-1 Failed the As Found Set Point

Test

May 3, 2002

CR 02123039

1-SV-1B-1 Failed the As Found Safety

Valve Testing

May 3, 2002

CR 02123049

1-SV-1A-4 Failed the As Found Safety

Valve Testing

May 3, 2002

CR 02123050

1-SV-2B-4 Failed the As Found Set Point

Test

May 3, 2002

CR 02123053

1-SV-1B-4 Failed the As Found Set Point

Test

May 3, 2002

CR 02125027

Main Steam Safety Valves Failed As

Found Test and Were Not Adjusted As

Required by the Code

May 5, 2002

CR 02198006

Incorrect Information Within Reportability

Evaluation for CR 02122063

July 17, 2002

4OA3.4

LER 315-2002-005-00, "Unit 1 Manual Trip Due to Trip of East Main

Feedwater Pump"

LER 315-2002-005-00

Unit 1 Manual Trip Due to Trip of East

Main Feedwater Pump

August 13, 2002

CR 02165064

Manual Reactor Trip Due to a Loss of the

East Main Feedwater Pump Following

Start of the #13 Circulating Water Pump

June 14, 2002

4OA3.5

LER 315-2002-006-00, "Switchyard Fire Results in Violation of Technical Specification 3.0.5"

LER 315-2002-006-00

Switchyard Fire Results in Violation of

Technical Specification 3.0.5

August 2, 2002

NOED-02-3-002

NRC Letter to Mr.

A. C. Bakken III,

Subject: "Notice of Enforcement

Discretion for Indiana Michigan Power

Company Regarding

D. C. Cook, Units 1

and 2 (NOED-02-3-002)"

June 18, 2002

CR 02163045

1-52-L Has Had a Catastrophic Failure

Resulting in a Loss of Offsite Power

Sources Supplied to Reserve Feed

June 12, 2002

4OA3.6

LER 50-315-2002-007-00, "Technical Specification 3.3.3.1 Required Special

Report for Inoperable Radiation Monitors"

LER 50-315-2002-007-00

Technical Specification 3.3.3.1 Required

Special Report for Inoperable Radiation

Monitors

August 22, 2002

CR 02174004

While Performing 1-OHP-4030-114-030,

Daily Surveillance Found that the Wrong

Parameters Were in the File for 1-VRA-

1310 Containment High Range Area

Monitor

June 23, 2002

CR 02199084

An Opportunity Existed to Avoid a

Licensee Event Report, but was Missed

July 18, 2002

4OA3.7

LER 50-315-2000-008-00, "Failure to Test Essential Service Water Valves in

Accordance with Technical Specifications"

LER 50-315-2000-008-00

Failure to Test Essential Service Water

Valves in Accordance with Technical

Specifications

December 12,

2000

CR P-00-04744

ESW from East/West Heat Exchanger

Outlet Valves Past Operabilty Concern

March 27, 2000

CR 00314038

The Condition Evaluation for Condition

Report 00-04744 Was Inadequate

November 9, 2000

4OA3.8

LER 50-315-2000-008-00, "Failure to Test Essential Service Water Valves in

Accordance with Technical Specifications"

LER 50-315-2000-008-01

Failure to Test Essential Service Water

Valves in Accordance with Technical

Specifications

December 7, 2001

4OA3.9

LER 315-2000-009-00, "Failure to Perform Technical Specification Valve

Position Surveillance on Leak-off Valves"

LER 315-2000-009-00

Failure to Perform Technical

Specification Valve Position Surveillance

on Leak-off Valves

January 8, 2001

01-OHP-4030-STP-010

Containment Isolation

Revision 18

2-OHP-4030-208-053A

ECCS [Emergency Core Cooling System]

Valve Operabilty Test Train A

Revision 0

2-OHP-4030-208-053B

ECCS Valve Operabilty Test Train B

Revision 0

DCC-NEMP-306-QCN

Containment Isolation System

Licensing/Design Bases Requirements

Revision 1

Design Information

Transmittal B-02045-00

Containment Isolation Barrier Review

June 6, 2001

OP-1-5146A-34

Ice Condenser Refrigeration Unit 1

Revision 34

OP-2-5146A-19

Ice Condenser Refrigeration Unit 2

Revision 19

CR 00341030

Inadequate Surveillance of 1-RH 110E/W

for Containment Integrity

December 6, 2000

4OA3.10

LER 50-316/2000-013-00, "Safety Injection Valve Closure at High Power

Levels Could Result in Exceeding Peak Centerline Temperature Limits"

LER 50-316/2000-013-00

Safety Injection Valve Closure at High

Power Levels Could Result in Exceeding

Peak Centerline Temperature Limits

October 13, 2000

CR P-00-11217

Unit 2 Outside Safety Limits During High

Head Safety Injection Discharge Valves

Testing

August 11, 2000

4OA3.11

LER 50-315-1999-012-01, "Auxiliary Building ESF [Engineered Safety

Features] Ventilation System May Not be Capable of Maintaining ESF Room

Temperatures Post-Accident"

LER 50-315-1999-012-01

Auxiliary Building ESF Ventilation System

May Not be Capable of Maintaining ESF

Room Temperatures Post-Accident

March 15, 2002

LER 50-315-1999-012-00

Auxiliary Building ESF Ventilation System

May Not be Capable of Maintaining ESF

Room Temperatures Post-Accident

May 20, 1999

Institute of Nuclear Power

Operations Significant

Event Report 63-83

Joy Fan Blades Failures

November 8, 1983

CR P-99-07026

Component Cooling Water Pump Area

Supply Fans have no Missile Protection

March 29, 1999

CR P-99-08841

Insufficient Assurance that the Auxiliary

Building Ventilation is Capable of Meeting

its Safety and Accident Mitigation

Functions

April 20, 1999

4OA3.12

LER 50-315-1999-001-01, "General Electric HFA Relays Installed in

Emergency Diesel Generators May Not Meet Seismic Qualification"

LER 50-315-1999-01-01

General Electric HFA Relays Installed in

Emergency Diesel Generators May Not

Meet Seismic Qualification

December 8,2000

LER 50-315-1999-01-00

General Electric HFA Relays Installed in

Emergency Diesel Generators May Not

Meet Seismic Qualification

February 10, 1999

Information Notice 83-19

General Electric Type HFA Relay Contact

Gap and Wipe Setting Adjustments

May 5, 1993

Information Notice 88-69

Movable Contact Finger Binding in HFA

Relays Manufactured by General Electric

September 29,

1988

Daily Shift Managers Logs

April 7, 1999

through

July 5, 1999

CR P-99-00270

HFA Relays Installed in the Plant May

Not Satisfy Seismic Requirements

January 6, 1999

(1) Condition report written as a result of inspection activities.