ML17319A753
| ML17319A753 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 01/22/1981 |
| From: | Baker K, Connaughton K, Holzmer M, Peschel J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17319A751 | List: |
| References | |
| 50-315-80-20, 50-316-80-16, NUDOCS 8103130119 | |
| Download: ML17319A753 (17) | |
See also: IR 05000315/1980020
Text
U.S.
NUCLEAR REGULATORY COMMISSION
OFFICE
OF INSPECTION AND ENFORCEMENT
REGION III
Reports
No. 50-315/80-20;
50-316/80-16
'ocket Nos. 50-315;
50-316
Licenses
No. DPR-58;
Licensee:
American Electric Power Service Corporation
and Michigan Power
Company
2 Broadway
New York, NY
10004
Facility Name:
D.
C.
Cook Nuclear Plant Units
1 6 2
Inspection At:
D.
C.
Cook Site,
Bridgman,
MI
Inspection Conducted:
November 17-21,
1980 and January
13,
1981
Inspectors:
.
M. Peschel
K. R. Baker
A.
Con aughton
I
l>l<A ~h /x.~
M. M.&6lzmer
( Z2. Ri
Approved By: .. Baker, Chief,
Nuclear Support Section
2
Ins ection
Summar
Ins ection on November
17-21
1980 and Januar
13
1981
(Re orts No. 50-315/80-20
No. 50-316/80-16)
Areas Ins ected:
Maintenance
procedures;
maintenance activities; surveillance
procedures;
surveillance activities;
ISI procedures
and activities for pumps
and valves;
licensee
event reports followup and plant tours.
The inspection
involved
a total of 151 inspector-hours
onsite by four NRC inspectors
including
zero inspector-hours offshifts.
Results:
Of the seven areas
inspected,
two apparent
items of noncompliance
were
identified; Inadequate
pump run time during
a surveillance
(Paragraph
3B); and
failure to establish
reference
values for pump inlet pressures
for the ISI
program
(Paragraph
3C).
sl osis 9 Ill"
ill
DETAILS
1.
Personnel
Contacted
>D. Shaller, Plant Manager
"-R. Keith, Operations
Superintendent
R. Dudding, Maintenance
Superintendent
"'E. Smarella,
Technical Superintendent
- "J. Stietzel,
QA Supervisor
D. Campbell,
Production Supervisor
>H. Bolinger, ISI Supervisor
W. Golden,
Performance
Engineer
R. Wagner,
Performance
Engineer
E. Kant, Performance
Engineering Supervisor
D. Duncan,
CSI Supervisor
-B. Svensson,
Assistant Plant Manager
T. Beilman, Senior
gA Auditor
The inspectors
also contacted several'ther
licensee
employees,
including operators,
plant engineering
and administrative personnel.
"Denotes
those attending
the exit interview.
2.
Maintenance
a
~
Maintenance Activities
Maintenance activities of safety related
systems
and components
listed below were observed/reviewed
to ascertain
that they were
conducted in accordance
with approved procedures,
regulatory
guides
and industry codes or standards
and in conformance with
Technical Specifications.
The following items were considered
during this review:
The
limitipg conditions for operation
were met while components
or
systems
were
removed
from service;
approvals
were obtained
prior to initiating the work; activities were accomplished
using approved procedures
and were inspected
as applicable;
functional testing and/or calibrations
were performed prior to
returning components
or systems
to service; quality control
records
were maintained; activities were accomplished
by qualified
personnel;
parts
and materials
used were properly'certified;
radiological controls were implemented;
and, fire prevention
controls were implemented.
The following maintenance activities were observed/reviewed:
Unit
1
Unit
1
J.O.
63382
BIT valve replacement
J.O.
63529
West containment
spray
pump weld
repair
"2-
Unit
1
Unit
1
Unit
1
J.O.
55989
J.O.
63544
J.O.
63366
Unit
1
Unit
1
Unit
1
J.O.
59088
J.O.
63554
J.O.
12037
Unit
1
Unit
1
Unit
1
Unit
1
Unit
1
Unit 2
J.O.
12023
J.O.
63393
J.O.
55205
J.O.
63328
J.O.
57377
J.O.
25179
Unit 2
Unit 2
J.O.
24096
J.O.
20665
Unit
1
J.O.
63795
IAB emergency diesel timing check
West MiR pump cleaning
East centrifugal charging
pump seal
rebuilding
West motor driven auxiliary feed
pump
valve repair
Incore flux mapping system drive motor
repair
Containment pressure
indicator repair
Wind speed
and direction recorder
repair
1-CD emergency diesel valve repair
PORV motor repair
RCP seal repair
No.
3 accumulator valve repair
MCC breaker
replacement
Pressurizer
level control circuit
repair
Comparator
and rate circuit repair
Modification of ice condensor
door
frames
The inspector noted several
instances
where Forms
No.
PMI
2290-1
and No. 2290-3 were not fully completed'he
licensee's
management
agreed to take, action to improve performance in this
area.
During a tour it was noted the Unit
1 pressurizer
power operated
relief valve, NRV-151, was closed.
The PORV's had recently
undergone
tests
by the operations
department
to determine
which
valves
were leaking.
A job order had not yet been issued for
this valve.
The licensee
agreed
to insure
a job order was
issued for this valve.
No items of noncompliance
were identified.
b.
Preventive
Maintenance
The preventive maintenance
system
was reviewed to determine if
it was current for safety related
components.
The inspector
observed that attachment
30 of the preventive
maintenance
system,
Plant Winterizing, had not been
completed
in October
as required by the system.
The licensee
stated that
much of the work has been completed
and stated that the remainder
would be completed in a timely manner.
The preventive maintenance
system at present
does not have
a
central status
system,
and many procedures
have
hand written
changes
and additions.
The system is in the process of being
reorganized with a new control system.
The licensee
has
begun
- 3-
a typing and the review/approval
process
to allow the
new
system to be implemented in a timely manner.
No items of noncompliance
were identified.
c.
Facility Procedures
The facility maintenance
procedures
listed below were reviewed
to verify that they were adequate
and consistent with Technical
Specifications.
1.
Maintenance
Procedures
12
MHP
5021.002.003
12
MHP
5021.003.001
12
MHP
5021.009.001
12
MHP
5021.032.001L
MHP
5021.032.001K
2.
Preventive
Maintenance
Procedures
Attachment
10
Attachment
26
No items of noncompliance
were identified.
3.
Surveillance
a.
Procedures
The inspector
reviewed several surveillance tests
selected
from
the Technical Specifications to ensure that the tests
were
covered
by properly approved procedures;
that these
procedures
contained
adequate
preparation
or prerequisites,
included
acceptance
criteria,
and provided for system restoration following
testing.
The following procedures
examined:
OHP.4030.STP.004
OHP.4030.STP.005
OHP.4030.STP.030
THP.4030
~ THP.352
OHP.4030.STP.007
THP.4030.STP.205
THP.4030.STP.216
OHP.4030.STP.013
OHP.4030.STP.020
Athough acceptance
criteria were specified in a section of each
procedure,
there
were
some instances
in which acceptance
criteria
sections
could have been
more complete.
An example is the
15
minute minimum pump run time required by the monthly surveillance
on the Unit
1 centrifugal charging
pumps
as specified in Technical Specification 4.1.2.3.c.
Acceptance criteria for pump run
4
times are not listed in the surveillance
procedure,
although
start
and stop time are recorded.
Other Unit
1 pumps require
the
15 minute minimum run during the monthly surveillances.
No items of noncompliance
were identified.
b.
Completed Surveillances
Completed surveillances
were reviewed for Unit
1 to verify that
surveillances
were performed within the required periodicity
and that the results
were within the Technical Specifications.
A check for completeness
of surveillance
records
was also
made.
Unit
1 Technical Specification 4.1.2.3.c
requires that the
centrifugal charging
pumps
(CCP) be run for a minimum of 15
minutes during the monthly surveillance.
Contrary to the above requirement,
the Unit
1 West
CCP was run for
only five minutes during the monthly surveillance
OHP.4030.STP.004
conducted
on June
16,
1980.
Inclusion of the
15 minute acceptance
criteria in this and
other test procedures,
as discussed
in Paragraph
A (Procedures)
above,
would have possibly prevented this noncompliance.
The
inspector
emphasized
the value of a review of all test procedures
for which this criterion is applicable.
This is an item of noncompliance identified in Appendix A
(50-315/80-20"01).
Records of completed surveillance tests
are required to be
maintained by Technical Specification 6.10.l.d.
The licensee
was unable to produce for review the following of completed
Unit
1 surveillances.
Surveillance Test
Sheet
No.
Date(s)
~Con onent
OHP.4030.STP.030
OHP.4030.STP.030
OHP.4030.STP.030
OHP.4030.STP.030
OHP.4030.STP.030
OHP.4030.STP.013
OHP.4030.STP.020
OHP.4030 'TP.020
OHP.4030.STP.004/005
6.7
6.7
6.5
6.5
6.5
6.1
6.2
6.2
All
January
1-24,
1980
June
1,
1980
June 3,4,5,15,
1980
May 2,
1980
April 14,29,30,
1980
January
31,
1980
February,
1980
May,
1980
July,
1980
N/A
N/A
N/A
N/A
N/A
No.
1 H2 Recombiner
East Train
West Train
Both Pumps
The licensee
has
agreed to locate these
records.
This is con-
sidered
an unresolved
item pending the licensee locating these
records
(50-315/80-20-01).
- 5-
c
~
ISI Operatility Testing Program - Pumps
The inspector
reviewed the licensee's
pump testing program to
verify compliance with the requirements
of 10 CFR 50.55a(g).
Pump test records
revealed that tests
had been
conducted
on all
applicable
pumps at the required frequencies
with properly
approved procedures.
Test methods
were found to be satisfactory.
The licensee
has not established
reference
values for pump
inlet pressure
as required by ASME Section XI Article IWP-3110.
Reference
values provide
a basis for establishing
acceptable
instrument accuracy
not, only to comply with the
requirements,
but to provide confidence in test data
used to
measure
pump performance
and establish
pump operability.
This is an item of noncompliance identified in Appendix A (50-315/80-20-02)
and (50-316/80-16-01).
d.
ISI Operability Testing Program - Valves
The inspector
reviewed the licensee's
valve testing program to
verify compliance with the requirements
of 10 CFR 50.55a(g).
Examination of the licensee's
approved ISI valve test program,
status
summaries
and several test procedures
revealed that the
licensee
has performed tests at the required frequencies
against
appropriate
acceptance
criteria.
The licensee is currently in
the process of revising the test program.
The revised program's
requirements will be reflected in the program status
summary
which, according to the licensee, will be updated biweekly.
No items of noncompliance
were identified.
4.
Licensee
Event
Re ort Followu
a
~
(Closed) Unit
1 I.icensee
Event Report
(LER) 80-15/03L-0 dated
July 29,
1980 was reviewed.
This report stated that while in
Mode
6 the train "B" centrifugal charging
pump failed,
due to a
broken shaft, while the train "A" diesel
was out of service.
were halted
and the train "A" diesel
was
placed in service.
The train "B" charging
pump was subsequently
repaired using
a "new" design shaft.
The failed shaft problem
has
been
a recurring problem with the "old" design shaft.
All
pumps
now in operation are using the "new" design shaft.
No
further problems are anticipated.
This item is considered
closed.
No items of noncompliance
were identified.
b.
(Closed) Unit 2 Licensee
Event Report
(LER) 80-26/03L-0 were re-
viewed.
Two check valves
(R-156 and R-157) were recently determined
by the licensee
to be containment isolation valves.
This LER was
submitted to satisfy reporting requirements
concerning previous
-6-
events involving the valves.
The valves were not included in
the type
C leak test prior to November
1978.
Check valve R156
had been installed backward.
On November
18,
1978,
R156 was
removed
and reinstalled correctly.
Both valves success-
fully passed
the type
C leak test
and were included in the
applicable surveillance test procedure.
The inspector verified
implementation of these corrective actions.
This item is
considered
closed.
No items of noncompliance
were identified.
C.
(Closed
) Unit
1 Licensee
Event Report
(LER) 80-25/03L-0 was
reviewed.
On September
29,
1980,
a glycol isolation valve was
determined
upon failure to fully close during containment
isolation valve testing.
The valve was exercised until it
functioned correctly.
Corrective action by the licensee
consisted
of increasing surveillance test frequency
from quarterly to
monthly.
The inspector learned that the valve failed the first
monthly surveillance
performed
on November
13,
1980.
The
licensee
was informed that increased
surveillance testing
as
a
proposed corrective action in the forthcoming LER would be
considered
inadequate
and that cause identification and
a
timely fix should be addressed.
No items of noncompliance
were identified.
d.
(Open) Unit 2 Licensee
Event Report
(LER) 80-32/03L-0 was
reviewed.
This IER stated that on September
4,
1980 during
a
surveillance test to return the East
RHR pump to service after
maintenance
the
pump was unstable
and declared
This was stated
to be the first event of this type.
The licensee
stated that the test procedure
did not provide for removing all
air in the system during filland vent and that the procedure
was
changed to correct this.
The inspector
reviewed the following
records
associated
with the event:
(1)
Unit 2 Control Room Iog July 1,
1980 to September
4,
1980
(2)
Clearance
Permit I.og July 20 to September
4,
1980
(3)
Monthly Opera)jng Reports for September,
August and
July,
1980.
(4)
Condition Report - C/R No. 2-8-80-237
(5)
Condition Report - C/R No. 2-9-80-254
(6)
Job Order Number 00354
(7)
Job Order Number 24250
(8)
1-0HP.4030.STP.005
Revision
8 dated April 2,
1980 with
ten temporary sheets
(9)
2-0HP.4030.STP.005
Revision
3 dated
June
19,
1979 with
17 temporary sheets
1/
I.etters
D. V. Shaller to Director,
OMI and
PC
USNRC dated October
14,
September
12,
and August 6,
1980.
" 7-
(10) 2-0HP.4021.008.001
Filling and Venting of Emergency
Core Cooling System Revision
1 dated April 18,
1978
(ll) SOE Log July 23 to September
4,
1980
(12) Operations
Department
DIR dated October
20 transmitting
completed
STP's to vault.
The report was found to be incorrect
and inaccurate in the
areas
as listed below:
(a)
The surveillance test
was conducted
as
a routine monthly
test
(2-0HP.4030.STP.005),
not a test performed to return
the East
RHR pump to service.
Clearance
Permit logs and
the logs
show that the last time the system
had been
removed
from service
was July 23,
1980 at
1855 hours0.0215 days <br />0.515 hours <br />0.00307 weeks <br />7.058275e-4 months <br /> for work on
IRV-310.
The system
was logged
as being returned to service
on July 24,
1980.
(b)
The problem had been observed
on August 4,
1980 while
performing routine surveillance test 2-0HP.4030.STP.005.
Log entries
on August 4,
1980
show the
pump was started
at 0359 hours0.00416 days <br />0.0997 hours <br />5.935847e-4 weeks <br />1.365995e-4 months <br />
and stopped at 0401 hours0.00464 days <br />0.111 hours <br />6.630291e-4 weeks <br />1.525805e-4 months <br />
due to poor suction
pressure.
At 0425 hours0.00492 days <br />0.118 hours <br />7.027116e-4 weeks <br />1.617125e-4 months <br /> the
pump was started after venting.
At 0428 it was stopped
again because
of poor suction.
At
0540 the
pump was again started after venting. It was run
until 0643 hours0.00744 days <br />0.179 hours <br />0.00106 weeks <br />2.446615e-4 months <br />.
A condition report (2-8-80-237)
was
initiated.
The licensee classified the event
as not re-
quiring a LER.
The originator of the condition report con-
ducted the investigation.
The investigation
was essentially
a rehash of the event with the following statement, "I do
not have
any explanation for the air in the system."
PSNRC
review accepted this.
This condition report appears
to have
received
a superficial investigation
and review.
A review
of the operating
and maintenance
history would have revealed
that the maintenance
on July 23,
1980 had been the source of
the air.
The decision that the event
was not reportable at
that time was very questionable
and in retrospect
represents
noncompliance with Technical Specification 6.9.1.8 reporting
requirements.
(c)
Records
show that the last maintenance
performed
on
the East
RHR train prior to the event
was July 23,
1980.
Valves IRV-310 and
RH 128E had packing leaks
repaired
(Job Orders
00354 and 24250).
The East
train was
removed
from service
on July 23,
1980 at
1855 hours0.0215 days <br />0.515 hours <br />0.00307 weeks <br />7.058275e-4 months <br />
and returned to service
on 1035 hours0.012 days <br />0.288 hours <br />0.00171 weeks <br />3.938175e-4 months <br />
on
July 24,
1980.
The logs do not show that the East
RHR pump was operated
to verify operability nor could
-8-
a completed surveillance test be found that indicated
the train was tested.
The Clearance
Permit 22056
under which the repairs
had been
made
has
been destroyed
(allowable under the licensee's
administrative procedure).
Discussions with the personnel
who developed
the
clearance
indicate that the East
RHR pump was not
tagged out, only the heat
exchanger
and associated
valves.
It is not clear at this time if the heat
exchanger
was drained to facilitate the repairs or if
the fluid drained out of the heat exchanger
during
the repairs.
In any case it does not appear that any
operability test of the
pump was conducted following
the return to service.
The licensee
has
a procedure
for filling and venting, 2-0HP.4021.008.001.
No
completed sign off for this procedure
could be found.
A review of the procedure indicates't
would have
been usable for filling and venting with changes
to
the initial conditions.
It is not clear that changes
to the surveillance pro-
cedure
2-0HP.4030STP.005 will prevent the event from
happening
again
as the procedure
was not used to
return the system to operation.
The real problem
appears
to be lack of an effective policy on the
return to service of safety related
equipment that
include an evaluation of the method of removal from
service,
maintenance
performed,
procedures
used
and
what procedures
are to be used during the return to
service
and that, equipment
be test operated.
The air introduced into the East
RHR train degraded
the performance
'f
that train such that it could not be relied upon to fulfillthe
LCO with respect
to a large break loss of coolant accident
and
insure continued operation of the East
RHR pump during small break
loss of coolant accident.
In the case of the large
LOCA the air induced into the
RHR pump
suction by the miniflow line from the heat exchanger outlet would
produce
a reduction in head
developed
by the pump,
as observed
by
the licensee
on August 4 and September
4,
1980.
This would delay
injection by this
RHR pump as reactor coolant system pressure
would
need to decay further than that assumed in the accident analysis
before injection occurred.
Also the entrained air in the injection
water would reduce the injection flow rate until flushed into the
In case of a small break
LOCA the
RHR pump would be required to
operate for a period of time on miniflow,
This is the
same
mode of
operation that the pump is tested
under during the monthly surveillance
test.
During the August and September tests
the operators
intervened
and stopped
the pump when the pressures
and currents
were erratic,
indicating cavitation and abnormal
pump performance.
Given these
indications they would have probably also stopped
the pump in the
event of a
LOCA to prevent
damage
to the pump.
Hence, it would have
been unavailable until the operator
had time to investigate
the cause
of the erratic performance.
The following caution notes
from the
pump technical
manual are quoted to show the manufactures
concern
regarding operation of the
pump with air in the system.
CAUTION
"BEFORE STARTING OR WHILE OPERATING THE PUMP THE CASING AND SUCTION
LINE MUST BE COMPLETELY FILLED WITH THE LIQUID BEING PUMPED.
THE
ROTATING PARTS
DEPEND
ON THIS LIQUID FOR LUBRICATION AND THE PUMP
MAY SEIZE IF OPERATED WITHOUT LIQUID.
THE CASING AND SUCTION LINE
MUST BE FILLED WITH LIQUID DURING STARTING, OPERATION AND SHUTDOWN
PERIODS."
CAUTION
"1.
NEVER OPERATE THE RESIDUAL HEAT REMOVAL PUMPS
WITHOUT PUMP/SYSTEMS
BEING COMPELTELY PRIMED.
2
.
~
~
~
~
~
~
~ J
~
3.
~
~
~
~
~
~
4.
WHEN OPERATING FOR
SOME TIME AT REDUCED CAPACITY) MUCH OF THE
PUMP
HORSEPOWER WILL GO INTO THE LIQUID IN THE FORM OF HEAT.
A BY-PASS MUST BE PROVIDED UNDER THESE CONDITIONS TO PREVENT THE
LIQUID FROM BECOMING HOT ENOUGH IN THE PUMP TO VAPORIZE.
FOR
CONTINUOUS PUMP OPERATION,
THE MINIMUMFLOW FOR SAFE
OPERATION OF THIS PUMP IS 500 GPM."
The function of the East
RHR train could have been significantly degraded
during this time period
as described
above but it still may have provided
a portion of its design capability for accident mitigation.
The Technical
Specification Limiting Conditions for Operations implicitly require the
equipment
be at full capacity
and reliability.
This was not the case
with the East
RHR train between July 23,
1980
and September
4,
1980.
On January
13,
1981
a meeting
was held in the Region III office to discuss
this event with the licensee.
Attending for the licensee
were:
J. Dolan, Vice Chairman Engineer
R. Hunter, Executive Vice President for Construction
and Nuclear Engineering
B. Svensson,
Assistant Plant Manager
R. Keith, Operations
Superintendent
A. Grimes, Chief Mechanical Engineer
S. Milioti, Assistant Division Head Nuclear Engineering
Region III personnel
attending were:
J. Keppler, Regional Director
R. Heishman,
Chief, Reactor Operations
and Nuclear Support Branch
A. Davis, Deputy Director
10-
C. Norelius, Regional Enforcement Coordinator
D. Boyd, Section Chief, Projects
Section
4
K. Baker, Section Chief, Nuclear Support Section
2
E. Swanson,
Senior Resident
Inspector
The licensee outlined the results of his review.
The licensee believes
that the quarterly portion of the surveillance test introduces
the air
into the systems.
The licensee is investigating this and other possible
causes.
The licensee
stated
the problem had occured
again during the
January
4,
1981 test.
The licensee
stated that the test frequency
would be increased
to weekly until the source of the air was identified.
In addition he would analyze
the effects of the air on system performance
during large
and small loss of coolant accidents.
This matter is considered
unresolved
pending completion of the licensee's
review and subsequent
review of these results
by Region III.
5.
Tours
The inspectors
toured various portions of the facility to observe
activities in progress.
The inspector noted that fire doors
on the north end of the Auxiliary
feed water pump area
were wired and blocked open.
These
doors are
U.L. three hour rated doors.
This is considered
an unresolved
item
pending review of the licensee's fire hazard analysis
and NRR's
SER.
(50-315/80-20-02)
(50-316/80-16-01)
6.
Unresolved
Items
Unresolved
items are matters
about which more information is required
in order to ascertain
whether they are addeptable
items,
items of
noncompliance
or deviations.
Unresolved
items during this inspection
are discussed
in Paragraphs
3,
4 and 5.
7.
Exit Interview
The inspectors
met with licensee
representatives
(denoted in Para-
graph
1) at the conclusion of the inspection
on November 21,
1980.
The inspectors
summarized
the purpose,
scope
and findings of the
inspection.
- 11 "
I
I