ML17325B592

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Forwards Insp Repts 50-315/99-04 & 50-316/99-04 on 990303-0416.Four Violations of NRC Requirements Occurred & Being Treated as non-cited Violations
ML17325B592
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 05/14/1999
From: Grobe J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Powers R
AMERICAN ELECTRIC POWER CO., INC.
Shared Package
ML17325B593 List:
References
50-315-99-04, 50-315-99-4, 50-316-99-04, 50-316-99-4, EA-99-116, NUDOCS 9905210214
Download: ML17325B592 (6)


See also: IR 05000315/1999004

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UNITED STATES

NUCLEAR REGULATORYCOMMISSION

REGION Ili

801 WARRENVILI.EROAD

LISLE. ILLINOIS60532.4351

Hay 14,

1999

EA 99-116

Mr. R. P. Powers

Senior Vice President

Nuclear Generation Group

American Electric Power Company

500 Circle Drive

Buchanan, Ml 49107-1395

SUBJECT:

D. C. COOK INSPECTION REPORT 50-315/99004(DRP); 50-316/99004(DRP)

Dear Mr. Powers:

On April 16, 1999, the NRC completed an inspection at your D. C. Cook Units 1 and 2 reactor

facilities. The inspection was an examination of activities conducted under your license as they

relate to compliance with the Commission rules and regulations and with the conditions of your

license.

Areas reviewed included Operations, Maintenance, Engineering, and Plant Support.

Within these areas, the inspection consisted of selective examinations of procedures and

representative

records, interviews with personnel, and observations of activities in progress.

The enclosed report presents the results of that inspection.

During this inspection period, we noted examples where'operators

demoristrated a conservative

'ecision-making

philosophy. We also observed that maintenance activities were generally

performed in accordance with approved procedures and utilized appropriate radiological

protection practices.

In addition, we noted that plant maintenance

and engineering personnel

expanded the scope of problem investigations, where appropriate, to include other equipment

and programs related to the failed equipment.

A particularly noteworthy example was the

decision to promptly inspect all 4 kilovoltbreakers following the identification of a loose anti-

shock spring in a 4 kilovoltbreaker.

In contrast to the improving performance described above, continuing problems were identified

with the corrective action program, the adequacy of maintenance and surveillance test

procedures, and the performance of required safety evaluations.

In addition, you did not

recognize that changes

in the reactor coolant system temperature also resulted in reactivity

changes until prompted by NRC inspectors.

Consequently, you did not know ifyou had

operated the facilityin compliance with your Technical Specifications until you subsequently

performed a detailed engineering evaluation of several evolutions which had the potential to

add positive reactivity. We also noted that your procedural controls on the usage of overtime

were weak which resulted in your staff having a difficulttime evaluating your overtime usage.

Your continued attention in these areas appears warranted.

Based on the results of this inspection, the NRC has determined that four violations of NRC

requirements occurred.

The first violation, which was identified by your staff, involved three

safety-related surveillance test procedures for the centrifugal charging pumps that contained

inadequate instructions to operate the pumps safely due to deficiencies in the procedure

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R. Powers

-2-

revision process.

The second. violation, which was identified by NRC inspectors, involved two

examples of condition reports that were inappropriately categorized as conditions adverse to

quality rather than as significant conditions adverse to quality. The third violation, which was

identified by NRC inspectors, involved the failure to perform a 10 CFR Part 50.59 safety

evaluation for a procedure change.

The fourth violation resulted from review of a 1996 event

report. That violation was identified by your staff and involved the failure to followthe

appropriate Technical Specification Limiting Condition for Operation Action Statement for an

inoperable pressurizer power operated relief valve.

These Severity Level IVviolations are being treated as Non-Cited Violations (NCVs).

Appendix C of the Enforcement Policy requires that for Severity Level IVviolations to be

dispositioned as NCVs, they be appropriately placed in the licensee's corrective action program.

Implicit in that requirement is that the corrective action program be fullyacceptable.

The

D. C. Cook Plant corrective action program was not adequate and has been the focus of

significant attention by your staff to improve the program. While your staff and the NRC have

not yet concluded that the corrective action program is fullyeffective, the corrective action

program improvement efforts are underway and captured in the D. C. Cook Restart Plan which

is under the formal oversight of the NRC through the NRC Manual Chapter 0350 Process,

"Staff Guidelines for Restart Approval." Consequently, these issues are being dispositioned as

NCVs.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its

enclosure willbe placed in the NRC Public Document Room.

Sincerely,

//s// J.

A. Grobe

John A. Grobe, Director

Division of Reactor Safety

Docket Nos. 50-315; 50-316

License Nos. DPR-58; DPR-74

Enclosure:

Inspection Report 50-315/99004(DRP);

50-316/99004(DRP)

cc w/encl:

A. C. Bakken III, Site Vice President

M. Rencheck, Vice President, Nuclear Engineering

R. Whale, Michigan Public Service Commission

Michigan Department of Environmental Quality

Emergency Management

Division

Ml Department of State Police

D. Lochbaum, Union of Concerned Scientists

DOCUMENT NAME: G'ACOONDCC99004.DRP

  • See previous concurrences

To receive a co

of this document, indicate in the box:

C

= Co

w/o attach/enct

6" = Co

w/attach/enct

N = ufo co

OFFICE

NAME

DATE

  • RIII:DRP

Cobe /k'c

05/07/99

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05/07/99

  • Rill:EICS

N

Cla

on

05/07/99

RIII:D

Gro

05/

/ 9

OFFIC!ALRECORD COPY

R. Powers

-2-

revision process.

The second violation, which was identified by NRC inspectors, involved two

examples of condition reports that were inappropriately categorized as conditions adverse to

quality rather than as significant conditions adverse to quality. The third violation, which was

identified by NRC inspectors, involved the failure to perform a 10 CFR Part 50.59 safety

evaluation for a procedure change.

The fourth violation, which was identified by your staff in

1996, involved the failure to followthe appropriate Technical SpeciTication Limiting Condition for

Operation Action Statement for an inoperable pressurizer power operated relief valve.

These Severity Level IVviolations are being treated as Non-Cited Violations (NCVs).

Appendix C of the Enforcement Policy requires that for Severity Level IVviolations to be

dispositioned as NCVs, they be appropriately placed in the licensee's corrective action program.

Implicit in that requirement is that the corrective action program be fullyacceptable.

The

D. C. Cook Plant corrective action program was not adequate

and has been the focus of

significant attention by your staff to improve the program.

While your staff and the NRC have

not yet concluded that the corrective action program is fullyeffective, the corrective action

program improvement efforts are underway and captured in the D. C. Cook Restart Plan which

is under the formal oversight of the NRC through the NRC Manual Chapter 0350 Process,

"Staff Guidelines for Restart Approval." Consequently, these issues will be dispositioned as

NCVs.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its

enclosure willbe'laced

in the NRC Public Document Room.

Sincerely,

John A. Grobe, Director

Division of Reactor Safety

Docket Nos. 50-315; 50-316

License Nos. DPR-58; DPR-74

Enclosure:

Inspection Report 50-315/99004(DRP);

50-316/99004(DRP)

cc w/encl:

A. C. Bakken III, Site Vice President

M. Rencheck, Vice President, Nuclear Engineering

D. Cooper, Plant Manager

R. Whale, Michigan Public Service Commission

Michigan Department of Environmental Quality

Emergency Management

Division

Ml Department of State Police

D. Lochbaum, Union of Concerned Scientists

DOCUMENT NAME: G: tCOOKttDCC99004.DRP

To receive a co

of this document, indicate in the box: "C" = Co

w/o attach/enct

E" = Co

w/attach/enct "N = No cop

OFFICE

RIII:DRP

NAME

Cobe /k c

DATE

05/

/99

Rl I I:DRP

/"-

Ve el

05/

/ 9

RIII:EICS

Cla

on

05/

/99

RIII:DR

Grob

05/

/

OFFICIAL RECORD COPY

R. Powers

-2-

revision process.

The second violation, which was identified by NRC inspectors, involved two

examples of condition reports that were inappropriately categorized as conditions adverse to

quality rather than as significant conditions adverse to quality. The third violation, which was

identified by NRC inspectors, involved the failure to perform a 10 CFR Part 50.59 safety

evaluation for a procedure change.

The fourth violation, which was identified by your staff in

1996, involved the failure to followthe appropriate Technical Specification Limiting Condition for

Operation Action Statement for an inoperable pressurizer power operated relief valve.

These Severity Level IVviolations are being treated as Non-Cited Violations (NCVs).

Appendix C of the Enforcement Policy requires that for Severity Level IVviolations to be

dispositioned as NCVs, they be appropriately placed in the licensee's corrective action program.

Implicitin that requirement is that the corrective action program be fullyacceptable.

The

D. C. Cook Plant corrective action program was not adequate

and has been the focus of

significant attention by your staff to improve the program. While your staff and the NRC have

not yet concluded that the corrective action program is fullyeffective, the corrective action

program improvement efforts are underway and captured in the D. C. Cook Restart Plan which

is under the formal oversight of the NRC through the NRC Manual Chapter 0350 Process,

"Staff Guidelines for Restart Approval." Consequently, these issues will be dispositioned as

NCVs.

In accordance with 10 CFR 2,790 of the NRC's "Rules of Practice," a copy of this letter and its

enclosure willbe placed in the NRC Public Document Room.

Sincerely,

John A. Grobe, Director

- Division of Reactor Safety

Docket Nos. 50-315; 50-316

License Nos. DPR-58; DPR-74

Enclosure:

Inspection Report 50-315/99004(DRP);

50-316/99004(DR

P)

cc w/encl:

A. C. Bakken III, Site Vice President

M. Rencheck, Vice President, Nuclear Engineering

D. Cooper, Plant Manager

R. Whale, Michigan Public Service Commission

Michigan Department of Environmental Quality

Emergency Management

Division

Ml Department of State Police

D. Lochbaum, Union of Concerned Scientists

DOCUMENT NAME: GACOONDCC99004.DRP

To receNe a co

of this document, indicate In the box:

C =

w/o attach/enct

E = Co

w/attach/enct

N = No co

OFFICE

NAME

RIII:DRP

Cobe /k'c

Cla

on

Ve el

Rill:DRP

8

Rill:EICS

Rill:DR

Grob

DATE

05/

/99

05/

/ 9

05/

/99

05/

/

OFFICIALRECORD COPY

R. Powers

-2-

revision process.

The second violation, which was identified by NRC inspectors, involved two

examples of condition reports that were inappropriately categorized as conditions adverse to

quality rather than as significant conditions adverse to quality. The third violation, which was

identified by NRC inspectors, involved the failure to perform a 10 CFR Part 50.59 safety

evaluation for a procedure change.

The fourth violation resulted from review of a 1996 event

report. That violation was identified by your staff and involved the failure to followthe

appropriate Technical Specification Limiting Condition for Operation Action Statement for an

inoperable pressurizer power operated relief valve.

These Severity Level IVviolations are being treated as Non-Cited Violations (NCVs).

Appendix C of the Enforcement Policy requires that for Severity Level IVviolations to be

dispositioned as NCVs, they be appropriately placed in the licensee's corrective action program.

Implicit in that requirement is that the corrective action program be fullyacceptable.

The

D. C. Cook Plant corrective action program was not adequate and has been the focus of

significant attention by your staff to improve the program.

While your staff and the NRC have

not yet concluded that the corrective action program is fullyeffective, the corrective action

program improvement efforts are underway and captured in the D. C. Cook Restart Plan which

is under the formal oversight of the NRC through the NRC Manual Chapter 0350 Process,

"Staff Guidelines for Restart Approval." Consequently, these issues are being dispositioned as

NCVs.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy'of this letter and its

enclosure willbe placed in the NRC Public Document Room.

Sincerely,

Docket Nos. 50-315; 50-316

License Nos. DPR-58; DPR-74

/s/ J.

A. Grobe

John A. Grobe, Director

Division of Reactor Safety

Enclosure:

Inspection Report 50-315/99004(DRP);

50-316/99004(DRP)

cc w/encl:

A. C. Bakken III, Site Vice President

M. Rencheck, Vice President, Nuclear Engineering

R. Whale, Michigan Public Service Commission

Michigan Department of Environmental Quality

Emergency Management

Division

Ml Department of State Police

D. Lochbaum, Union of Concerned Scientists

DOCUMENT NAME: G:<COOIQDCC99004.DRP

  • See previous concurrences

To receive a co

of this document, indicate In the box:

C = Co

wlo attach/end

E'

Co

wlattachlend

N" = No co

OFFICE

  • RIII:DRP
  • RillDRP

E

  • RillEICS

N

Rill:D

DATE

Cobe /k'c

05/07/99

Ve el

05/07/99

Cla

on

05/07/99

Gro

05/

/ 9

OFFIC/AL RECORD COPY

R. Powers

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