ML17325B614
| ML17325B614 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 05/21/1999 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Powers R AMERICAN ELECTRIC POWER CO., INC. |
| Shared Package | |
| ML17325B615 | List: |
| References | |
| 50-315-99-09, 50-315-99-9, 50-316-99-09, 50-316-99-9, NUDOCS 9906030001 | |
| Download: ML17325B614 (10) | |
See also: IR 05000315/1999009
Text
Nay 21>
1999
Mr. R. P. Powers
Senior Vice President
Nuclear Generation Group
American Electric Power Company
500 Circle Drive
Buchanan, MI 49107-1395
SUBJECT:
NRC INSPECTION REPORT 50-315/99009(DRS); 50-316/99009(DRS)
Dear Mr. Powers:
On April23, 1999, the NRC completed a special inspection conducted at your Buchanan
Michigan Corporate facility. This inspection was an examination of activities under your license
as they relate to your implementation of the Expanded System Readiness
Review (ESRR)
program at your D. C. Cook Units 1 and 2 reactor facilities. The NRC understands
that these
reviews are intended to provide assurance
that safety-related plant systems fultilltheir design
basis safety functions and to determine system restart readiness.
Effective implementation of
the ESRR process willaddress portions of Case Specific Checklist items No. 3, "Programmatic
Breakdown in the Maintenance of the Design Basis," and No. 13, "Systems and Containment
Readiness Assessment," that were established through the NRC's Manual Chapter 0350, "Staff
Guidelines for Restart Approval." The NRC willcontinue to monitor and assess
the
effectiveness of the problem identification phase of your system readiness evaluations.
The
enclosed report documents the results of the inspection.
Overall, the implementation of,the ESRR process observed was considered effective. The
inspection focused on the reactor coolant and the control room instrumentation distribution
system assessments.
For these systems, the scope of the planned review areas were broad
and generally consistent with the purpose of the review effort to confirm the performance of
system safety functions.
Further, the breadth and depth of material reviewed for these system
assessments
was appropriate and ESRR teams were effective at identiTication of substantive
design issues potentially impacting system safety functions.
However, the failure of the reactor
coolant ESRR team to identify nonconservative assumptions for reactor coolant system
inventory in station blackout calculations demonstrated
a lapse in the technical rigor for this
assessment
and indicated a need for more focus on the quality of the review effort. Additionally,
inspectors were concerned that lack of control of indices of vendor analysis could adversely
impact the ESRR team assessments
which rely on the material in these index lists to identify the
up to date source materials for the system reviews.
I
The system readiness review board (SRRB) was observed to be following a structured review
process that offered a consistent approach for effectively reviewing the large amount of
information contained in a typical ESRR system report. The AuxiliaryBuilding Ventilation
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R. Powers
-2-
System ESRR report presentation demonstrated
the ESRR team manager's thorough
understanding of the system under review and of the relative significance of the system findings
and assessments.
However, the inspectors were concerned that performing significant
additional licensing basis reviews (e.g., review of the historical design and licensing basis
notebooks) following the SRRB approval process could change the system assessments
and
serve to "bypass" the SRRB review process step.
Your staff's prompt actions to suspended
the
systems scheduled for SRRB review and approval pending the receipt and review of the
historical design and licensing basis notebooks by the ESRR teams demonstrated
an effective
response to this concern.
Based on the results of this inspection, the NRC has determined that three violations of NRC
requirements occurred.
The first violation pertained to the Unit 1 tube plugging and sleeving
activities which have occurred outside a formal design control process and represented
a design
control process bypass.
The nonproceduralized
process used for these activities did serve to
accomplish some of the key functions of a formal design control process such as safety
evaluations, analysis and technical specification changes.
However the processes
used were
not effective in review of the vendor analysis, use of plant drawing controls or consideration of
vendor specified testing. This violation appears to be another manifestation of the design
control breakdown that contributed to the extended shutdown and improvement initiatives under
way at D. C. Cook.
The second and third violation pertained to inadequate operability determination screenings of
safety related equipment that indicate a lapse in rigor for the performance of operability
determination screenings.
Further, the inspectors identified several examples of operability
determinations that contained poor quality engineering assessments
and a large backlog {in
excess of 500 items) of operability questions which have not received timely engineering
resolution.
These issues are of concern as they demonstrate poor engineering support for the
operability determination process.
These violations are being treated as Non-Cited Violations {NCVs), consistent with Appendix C
of the Enforcement Policy. These NCVs are described in the subject inspection report. Ifyou
contest the violation or severity level of these NCVs, you should provide a response within
30 days of the date of this inspection report, with the basis for your denial, to the Nuclear
Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with
copies to the Regional Administrator, Region III, and the Director, Office of Enforcement, United
States Nuclear Regulatory Commission, Washington, DC 20555-0001.
Appendix C of the Enforcement Policy requires that for Severity Level IVviolations to be
dispositioned as NCVs, they be appropriately placed in a licensee corrective action program.
'mplicit
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 signiTicant
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 and design
control program improvement efforts are underway and captured in the D. C. Cook Plant Restart
~O
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R. Powers
-3-
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, the
enclosure, and your response to this letter, ifyou choose to provide one, willbe, placed in the
NRC Public Document Room.
We willgladly discuss any questions you have concerning this inspection.
Sincerely,
John A. Grobe, Director
Division of Reactor Safety
Docket Nos. 50-315; 316
Enclosure:
Inspection Report 50-315/99009(DRS);
50-316/99009(DRS)
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:DRSiDCC99009.wpd
- SEE PREVIOUS CONCURRENCE
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R. Powers
-3-
Plan which is under the formal oversight of the NRC through the NRC Manual Chapter 0350 process, "Staff Guidelines for Restart Approval.n Consequently, these issues willbe
dispositioned as NCVs.
In accordance with 10 CFR 2.790 of the NRC'S "Rules of Practice," a copy of this letter, the
enclosure, and your response to this letter, ifyou choose to provide one, will be placed in the
NRC Public Document Room.
We willgladly discuss any questions you have concerning this inspection.
Sincerely,
Original /s/ J.
A. Grobe
John A. Grobe, Director
Division of Reactor Safety
Docket Nos. 50-315; 316
Enclosure:
Inspection Report 50-315/99009(DRS);
50-316/99009(DRS)
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:DRS)DCC99009.wpd
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OFFICE
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OFFICIALR
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R. Powers
Distribution:
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