ML17319A989

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IE Insp Repts 50-315/81-14 & 50-316/81-18 on 810616-19 & 22-23.Noncompliance Noted:Failure to Follow Refueling Procedure FR-AEP-R5 & Lack of Program to Adequately Enforce Procedures & Maintain Controlled Conditions
ML17319A989
Person / Time
Site: Cook  
Issue date: 07/13/1981
From: Jackiw I, Ring M, Robinson D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17319A987 List:
References
50-315-81-14, 50-316-81-18, NUDOCS 8107270151
Download: ML17319A989 (10)


See also: IR 05000315/1981014

Text

U.S.

NUCLEAR REGULATORY COMMISSION

OFFICE

OF INSPECTION AND ENFORCEMENT

REGION III

Report No. 50-315/81-14;

50-316/81-18

Docket No. 50-315;

50-316

License

No. DPR-58;

DPR-74

Licensee:

American Electric .Power Service

Corporation

Indiana

and Michigan Power

Company

2 Broadway

New York, NY

10004

Facility Name:

D.

C.

Cook Nuclear Plant, Units

1 and 2

Inspection At:

D. C.

Cook Site,

Bridgman,

MI

Inspection Conducted:

June

16-19, 22-23,

1981

Inspectors:

M. A. Ring

7

/

D. L. Robin on~

Approved By: I.

.

c i , Acting Chic

Test Program Section

7 ~mls

Ins ection

Summa

Ins ection on June

16-19

22-23

1981

(Re ort No. 50-315/81-14'0-316/81-18)

refueling activities, refueling surveillance,

and maintenance activities during

the refueling outage.

The inspection involved a total of 70 inspector-hours

onsite by two NRC inspectors

including

10 inspector-hours

on off shifts.

Results:

Of the four areas

inspected,

two apparent

items of noncompliance

were

identified in two areas (failure to follow procedures

- Paragraphs

3 and 5;

failure to maintain adequate

cleanliness

- Paragraph

3).

8107270151

810715

PDR

ADOCK 05000315

6

PDR

DETAILS

Persons

Contacted

>D. Shaller, Plant Manager

-.E. Townley, Assistant Plant Manager

  • B. Svenson,

Assistant Plant Manager

+J. Stietzel, Quality Assurance

Supervisor

-H. Chadwell, Outage/Design

Change Coordinator

+R. Keith, Operations

Superintendent

E. Abshagen,

Assistant

Outage Planning Coordinator

D. Dudding, Maintenanace

Superintendent

H. Bolinger, In-service Inspection Coordinator

Additional plant technical

and administrative personnel

were contacted

during the course of the inspection by the inspector.

-Denotes

those attending the exit interview.

Pre aration for Refuelin

(Unit, 1

'I

The inspectors verified that technically adequate

procedures

for Unit 1

cycle V-VI were approved for fuel handling, transfers,

core verification,

inspection of .fuel to be reused

and handling of other core internals.

These procedures

were in a large part incorporated in the vendor Refuel-

ing Procedure

PP-AEP-R5 which the inspectors verified to have been re-

viewed and approved by the licensee in accordance

with Technical Speci-

fications.

The inspectors verified that the licensee

had submitted

a

proposed

core reload Technical Specification

change

to'NRR.

The

inspectors

also reviewed the licensee's

program for overall outage

control.

No items of noncompliance

or deviations

were identified.

Refuelin

Activities

The inspectors verified that prior to the handling of fuel in the core,

all surveillance testing required by the Technical Specifications

and

licensee's

procedures

had been

completed.

The inspectors verified that

during the outage the periodic testing of refueling related equipment

was being performed

as required by Technical Specifications.

The in-

spectors

reviewed the qualifications of the refueling contractor personnel

and verified that licensee staffing during refueling was in accordance

with Technical Specifications

and approved procedures.

The inspectors

also observed portions of three shifts of fuel handling operations

(removal, inspection

and insertion).

Prior to fuel handling operations

actually starting

and with the reactor

head

removed,

the inspectors

made

a tour of the Unit 1 containment

on June

17,

1981 and noted the following

.items:

a.

A radiation protection technician carried

a hand-held radiation

meter (Teletector)

across

the manipulator crane bridge and around

the refueling cavity without the meter being lanyarded to either

the individual or a fixture.

b.

On the left side of the refueling cavity (as

seen

from containment

access)

four five-gallon poly bottles

and

a one quart bottle were

left within the safety railing and not tied down.

c ~

On either side of the containment, within the safety railing,

radiation protection areas

had been created.

On the tour, four

duck feet were noted loose

on the left side of the cavity.

On

both sides, poly bags

had been taped to the safety railing to

serve

as trash containers.

The taping was

done in such

a manner

as to make full bags

(which was the condition during the tour)

very susceptible

to spilling over into the cavity pool.

d.

e.

At least

seven pens

(including a metal-encased felt marker) were

observed in use in the upper volume.

On the left side of the cavity (as

seen

from containment

access)

outside of the safety railing,

a pile of debris

had accumulated.

Pieces of herculite,

tape,

empty tape cores,

rubber gloves,

and

paper were lying in disarray

and were wet with condensation

and

dripping from a valve station directly overhead.

These

items .were contrary to licensee

procedures

FP-AEP-R5, Refueling

Procedure,

and PMSI-069, Unit 1 Refueling Outage which require loose

article controls such as; lanyards tied from hand tools to th'e person

using them or to a permanent fixture; the banning of pens

and marking

materials which will not float from the upper volume; loose materials

and equipment

removed or placed in a location where there is no pos-

sibility that they might become accidently dislodged

and fall into the

reactor cavity; eyeglasses

securely attached

to the wearer;

and dosi-

metry securely

taped to anti-contamination clothing (Anti-C's).

Following the June

17,

1981 tour, the problems noted were discussed

with the licensee

management

and the licensee

took some immediate steps

to correct part of the problem (such

as, removal of the trash).

However,

on June 21,

1981,

a contractor individual dropped his eyeglasses

into

the refueling pool,. and on June 22,

1981,

a headset

was pulled off of

the SRO-Core Alterations and into the pool.

During a dayshift tour

on June

22,

1981, five individuals were noted in the containment with-

out dosimetry taped to their Anti-C's, and

a rag and two 'pieces of tape

were noted floating in the pool over the fuel transfer canal area.

During a nightshift tour on June

22,

1981,

an additional five individuals

were noted without dosimetry, taped to their Anti-C's, and one individual

was noted carrying two hand tools around the cavity edge without lanyards.

0

1

E

N

The lack of an adequate

program to maintain cleanliness

and enforce the

licensee's

own'rocedures

as required by ANSI N45.2.3 is inconsistent

with 10 CFR Part 50, Appendix B, Criterion II, and is considered

to be

an -item of noncompliance

(315/81-14-01).

It should be noted that pre-

vious inspection reports 316/81-08,

315/81-12

and 315/80-01 discussed

similar cleanliness

and loose articles control problems.

4.

Maintenance-Refuelin

The inspectors

reviewed the reactor coolant pump seal inspections,

main

steam isolation valve disc guide replacement

and drain l'ine removal,

and the

RHR relief valve replacement

maintenance

work items in order to

determine whether the maintenance

procedures

included administrative

approvals for removal

and return of systems

to service;

hold points

for inspection/audit

and sign-off by gA or other licensee

personnel;

provisions for operational testing following maintenance;

provisions

for fire watch responsibiliti'es;

review of material certifications;

provisions for- assuring

LCO requirements

were met during repair; pro-

visions for housekeeping

during and following maintenance;

and

responsibilities for reporting defects to management.

The inspectors

observed portions of the main steam isolation valve and

RHR relief

valve work items to ensure

the work was being accomplished in accordance

with approved procedures.

No items of noncompliance

or deviations

were identified.

5.

Surveillance-Refuelin

0

The z.nspectors

observed

the Emergency Diesel Generator

System Periodic

Inspection,

12MHP5921.032,001I,

on Unit

1 for the

CD Diesel to verify

that the operation

was covered by properly approved procedures;

that

the procedures

used were consistent with regulatory requirements,

licensee

commitments,

and administrative controls; that minimum crew

requirements

were met, prerequisites

were completed,

special test

equipment

was calibrated

and in service,

and required data

was re-

corded for final review and analysi;s; that the qualifications of

personnel

conducting the inspection were adequate;

and that the

results

were adequate.

During the Diesel Generator

Inspection review, the inspectors

noted

that procedure

No. PMP2110.CPS.001,

Clearance

Permit, System,

requires

the following:

"When an Emergency Diesel Generator is to be removed

from service

the other Emergency Diesel Generator for that Unit is to be proven

operable

and will then be left running until the diesel engine

being removed from service

has been isolated,

the Clearance

Permit

tags placed

as required,

and the Clearance

Permit has been accepted

by the individual who will be performing the designated

work.

From a review of the clearance

permit, the system operating logs and

interviews with system operators, it appears

the licensee

did not comply

with the above requirement

when the

CD diesel generator

was removed from

service

on June

16,

1981, since the last running of the

AB diesel genera-

tor occurred

on June

13,

1981.

Failure to follow the requirements

of

procedure

PMP2110.CPS.001

is inconsistent with the Technical Specifica-

tions for Unit 1, Section 6.8 and is considered to be an item of noncom-

pliance (315/81-14-02).

Dama

ed Fuel Assembl

During refueling operations

on June

19,

1981,

a fuel assembly

was

damaged

by striking a shield wall retaining lip located in the re-

fueling cavity approximately six 'inches high and several feet west

of the reactor vessel,

The assembly

was being transported

towards

the fuel transfer area by the manipulator crane, but a fouled inter-

lock had apparently allowed the gripper "full up" indicating light

to come

on without the assembly being fully inside the gripper tube.

's

a result of the collision, one rodlet from the

15 x 15 assembly

dropped to the cavity floor and lodged behind

a ladder.

Three other

rodlets

appeared

bent.

Because

the process of retrieving the dropped

rodlet and analyzing the circumstances

surrounding the event were not

complete at the time-of the exit, it was agreed that the Senior Resident

Inspector would provide the complete

documentation of the event in his

report.

Unit 2 - Refuelin

While reviewing Unit

1 refueling operations,

the inspectors

also re-

viewed

some Unit 2 correspondence

which raised additional concerns

regarding the adequacy of the review process for the Unit 2 Cycle

3

Reload core relative to 10 CFR 50.59.

On March 17,

1981,

a

memo was issued

from J. I. Castresana,

Nuclear

Safety and Licensing Section

Head (Corporate) to J. F. Steitzel, Quality

Assurance

Supervisor

(Plant) stating that'

meeting of the

NSDRC had

been held on that date

and that it had concluded that the Unit 2 Cycle

3 Reload

"does not pose

an unreviewed safety question

and that no

Technical Specification

changes

are needed."

The

memo referenced

the

Westinghouse

reload safety evaluation report.

The inspector

reviewed

the minutes of the

NSDRC meeting

and noted that similar wording re-

garding no unreviewed safety question

and no Technical Specification

changes

was used.

On May

1 and May 7,

1981, letters

were sent from

R.

S. Hunter, Vice President of Indiana

and Michigan Electric Company

to Harold R. Denton, Director of NRR of the

NRC requesting Technical

Specification

changes for Unit 2 as

a result of the Cycle

3 Reload.

The May 7 letter referenced

the "Reload Safety Evaluation for D. C.

Cook

Nuclear Plant, Unit 2, Cycle 3" which was dated

December

1980.

This

evaluation

had indicated that Technical Specification

changes

would be

required

and had been issued prior to the

NSDRC meeting

and subsequent

memo.

The inspectors

were unable to obtain

a satisfactory explanation

a

~

e

4

of the above

sequence

of events.

Therefore,

the licensee is being re-

quested

to provide the inspectors

with details of how the NSDRC and the

Nuclear Safety

and Licensing Section developed

and issued

two contra-

dictory'assessments

of the Unit 2 Cycle

3 Reload utilizing apparently

the

same Reload Safety Evaluation Report.

This item is an unresolved

item (316/81-18-01)

pending receipt

and evaluation of the requested

information.

8.

Unresolved Item

Unresolved

Items are matters

about which more information is required

.in order to ascertain

whether they are acceptable

items,

Items of Non-

compliance,

or Deviations.

An unresolved

item disclosed during the

inspection is discussed in Paragraph

7.

9.

Exit Interview

The inspectors

met with licensee

representatives

denoted in Paragraph

1 at the conclusion of the inspection

on June

23,

1981.

The inspectors

summarized

the purpose

and the scope of the inspection

and the findings.

The licensee

acknowledged

the inspectors'tatements

with respect

to

the items of noncompliance

(Paragraphs

3 and 5).

Additionally, the

unresolved

item (Paragraph

7) was discussed

in a telephone

conversation

conducted

on July 2,

1981.

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