ML17326A901
| ML17326A901 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 05/19/1981 |
| From: | Heishman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17326A900 | List: |
| References | |
| 50-315-81-03, 50-315-81-3, 50-316-81-03, 50-316-81-3, NUDOCS 8106020535 | |
| Download: ML17326A901 (6) | |
Text
o A~eadix A NOTICE GF VIOLATION American Electric Power Service Corporation License No. DPR-58 License No. DPR-74 As a result, of the inspection conducted on February 1-28,
- 1981, and in accord-ance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violations, were identified:
1.
Technical Specification 6.5.1.7.b states, in part:
"The PNSRC shall:
Render determinations in writing with regard to whether or not each item considered under 6.5.1,6(a) through (e).
..constitutes an unreveiwed safety question."
Paragraph 6.5.1.6 includes:
a ~
Review of (1) all procedures required by Specification 6.8 and changes
- thereto, (2) any,other proposed procedures or changes thereto as determined by the Plant Manager to affect nuclear safety.
e b.
Review of all proposed tests and experiments that affect nuclear safety.
c.
Review of all proposed changes to Appendix "A" Technical Specifications.
d.
Review of all proposed changes or modifications to plant systems or equipment that affect nuclear safety.
e.
Investigation of all violations of the Technical Specifications including the preparation and forwarding of reports covering evaluation and recommendations to prevent recurrence to the Chairman of the NSDRC.
- Also, 10 CFR 50;59 requires that records of changes in the facility, changes in the procedures, and tests and experiments ".
. shall include a written safety evaluation which provides the bases for the determination that the change, test or experiment does not involve an unreviewed safety question."
Contrary to the above:
a.
A modification was made to the Unit 1 Ice Condenser after the review determined that it was not safety-related and did not document a Safety Evaluation (RFC-01-1819).
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Appendix A C ~
A modification was made to the Main Steam System after the review was completed and documented an apparently unreviewed safety question concerning seismic qualification (RFC12-1814).
Numerous tests and procedure changes were completed for which either no safety evaluation was documented or the basis for the 10 CFR 50.59 determination was not documented.
This is a Severity I,evel IV violation (Supplement 1.D.1).
2.
Technical Specification 3.5.2 action statement states:
In the event the ECCS is actuated and injects water into the Reactor Coolant System, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 90 days describing the circum-stances of the actuation and the total accumulated actuation cycles to date.
Contrary to the above", a'safety injection'ccurred on October ll, 1980, and the report was not submitted until February 6, 1981.
s.
This is a Severity Level V violation (Supplement 1.E).
Technical Specification 6.8.2 states:
Each procedure and administrative policy of Technical Specification 6.8.1, and changes
- thereto, shall be reviewed by the PNSRC and approved by the Plant Manager prior to imple-mentation and reviewed periodically as set forth in administrative procedures.
Administrative Procedure PMI 2010 states in part:
a ~
Cancelled procedures, shall be labelled "CANCELLED" on the cover sheet and a brief summary of why the Procedure or Instruction is being cancelled.
b.
All Instructions and Procedures will be reviewed on an annual basis for a two year period commencing with commercial operation (Unit 1:
August 23, 1975.
Unit 2:
July 1, 1978)
After this two year period the review cycle shall not exceed two (2) years.
Instructions and Procedures applicable to both units are subject to the two year review cycle.
A revision to an Instruction or Procedure (though not the issuance of a Temporary Change Sheet) is also considered as a review of that Instruction or Procedure.
An Instructions and Procedures review schedule record shall be maintained by Departments with the following information:
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Appendix A 3
Instruction or Procedure identification; last review date; next scheduled review date; who performed review; and review status (acceptable, revision required, etc.).
c.
Standard distribution indicates the "original" is to get the Master File and copies to the control rooms,.
Contrary to the above:
a.
Cancelled Procedures were incompletely documented.
eg:
1-OHP4030 STP.006 and 2-OHP 4022.002.002 b.
Approximately 50$ of the procedures inspected had not received a
timely review.
eg:
1-OHP 4022.001.001, 2-OHP 4021.008.001, 1-OHP 4023.001.001,
.2-01P 4023.016.001-," "
1-0HP-4030.STP.031, and 2-OHP 4030.STP.031 c ~
Distribution of procedures was incomplete.
eg:
2-OHP 4030 STP.030 and 1-OHP 4030 STP.015, Master File
.revision had been superceded; 2-OHP"4021.008.003 and 1-OHP 4021-051-005, Master File was missing a procedure; and 1-OHP 4023.053.001, Control Room copy missing pages.
This is a Severity Level V violation (Supplement I.E)
Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within twenty-five days of the date of this Notice a written statement or explanation in reply, including for each item of noncompliance:
(1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full com-pliance will be achieved.
Under the authority of Section 182 of the Atomic Energy Act of 1954, as
- amended, this response shall be submitted under oath or affirmation.
D~t~d hlAY 18 t88f R. F. Heishman, Acting Director Division of Resident and Project Inspection