ML17328A911

Notice of Violation from Insp on 820412-0610.Violation Noted:Redundant Trains of Following Sys Not Provided W/Acceptable Fire Protection

ML17328A911
Person / Time
Site:	Cook
Issue date:	03/06/1991
From:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17328A907	List: ML17328A910 ML17328A911
References
50-315-91-01, 50-315-91-1, 50-316-91-01, 50-316-91-1, EA-82-139, NUDOCS 9103130098
Download: ML17328A911 (10)

Text

Enclosure 3

NOTICE OF VIOLATION Indiana and Michigan Electric Company D.C.

Cook Nuclear Plant, Units 1 and 2

Dockets No. 50-315 and 50-316 Licenses No.

DPR-58 and DPR-74 EA 82-139 As a result of an NRC inspection conducted at the D.C.

Cook Nuclear Plant during the period April 12 through June 10, 1982, and an NRC investigation conducted during the period April 8, 1902 through December 15, 1983, violations of NRC requirements were identified.

These violations are related principally to compliance with fire protection requirements set forth in 10 CFR Section 50.48 and Appendix R to 10 CFR Part 50.

In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," the violations are set forth below:

I.A. Section 186 of the Atomic Energy Act of 1954, as

amended, requires that information provided to the Commis'sion by an applicant or licensee shall be complete and accurate in all material respects.

10 CFR 50.48(b) requires that all nuclear power plants licensed 'to operate prior to January 1,

1979 satisfy the applicable requirements of Appendix R

to 10 CFR Part 50 including, specifically, the requirements of Sections III.G, III.J, and III.O.

D.C.

Cook Nuclear Plant, Units 1 and 2, were licensed to operate prior to January 1, 1979.

10 CFR 50.48(c)(5) required that, by March 19,

1981, the licensee submit plans and schedules for meeting the completion schedules in 10 CFR 50.48(c)(2), (c)(3), and (c)(4) fear modificatjons necessary to satisfy the applicable provisions of Appendix R to 10 CFR Part, 50.

In response to these requirements the licensee submitted a letter (AEP:NRC:00428A) dated March 27, 1981, that stated in part, "The attachment to this letter provides our response, regarding the provisions of Appendix R

to 10 CFR 50 which are applicable to the D.C.

Cook Nuclear Plant...set forth in Section III.G, "Fire Protection of Safe Shutdown Capability";

III.J, "Emergency Lighting"; and III.O, "Oil Collection Systems for Reactor Coolant Pump...."

The attachment to this letter demonstrates that the Cook Plant is already in compliance with the applicable provisions of Appendix R...."

The attachment to the licensee's letter states, in part, "This attachment provides our response to Sections III.G, III.J, and III.O of Appendix R to 10 CFR 50 as required by 10 CFR 50.48 (c)(5).

The infor-mation and references provided below demonstrate compliance with those sections of Appendix R and, as such, no further plant modifications are necessary."

The licensee further states in that attachment, "No further actions need to be taken with regard to Section III.G of Appendix R for the

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Notice of Violation Cook Plant....

No further actions are necessary with regard to Section III.J of Appendix R for the Cook Plant....

This system fully meets the requirements of Section III.O of Appendix R and no further action is required for Cook Plant.".

Contrary to the above, the statements made in the March 27, 1981 submittal contained inaccurate information on material matters.

The statements were inaccurate in that, as of the date of the licensee's March 27, 1981 letter, the licensee did not meet the requirements in Sections III.G, III.J, and III.O of Appendix R to 10 CFR Part 50, as described in Item B below.

The statements were material in that, had the true situation been known, the licensee would have been required to initiate actions to achieve compliance.

B. '0 CFR 50.48(b) requires that the D.C.

Cook Nuclear Plant, Units 1 and 2, shall satisfy the requirements of 10 CFR 50, Appendix R, Section III.G, "Fire Protection of Safe Shutdown Capability", Sectio'n III.J, "Emergency Lighting", and Section III.O, "Oil Collection System for Reactor Coolant Pump."

1.

10 CFR 50, Appendix R, Section III.G.l.a., requires that fire protection features shall be provided for structures,

systems, and components important to safe shutdown.

Those features shall be capable of limiting fire damage so that one train of systems necessary to achieve and maintain hot shutdown conditions from either the, control room or emergency control station is free of fire damage.

Section III.G.2 specifies three acceptable designs of fire protection features for redundant trains of structures,

systems, and components required,to achieve and maintain hot shutdown conditions.

Section III.G.3.a. requires that indepen-dent alternative or dedicated shutdown capability shall be provided where the fire protection features for structures,

systems, or components whose functions are required for hot shutdown do not satisfy Section III.G.2.

Contrary to the above, during the April 1982 inspection, it was discovered that:

a ~

Redundant trains of the following systems, whose function was required to achieve and maintain hot shutdown conditions for the D.C.

Cook Nuclear Plant, Units 1 and 2, were not provided with acceptable fire protection in accordance with 10 CFR Part 50, Appendix R, Section III.G.2, or independent alternative or dedicated shutdown capability in accordance with 10 CFR Part 50, Appendix R, Section III.G.3:

Component Cooling Water System Non Essential Service Water System Essential Service Water System Control Air/Plant Air System

Notice of Violation 3

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b.

In addition, the control rooms and cable vaults, which contain control and instrumentation cabling for the redundant trains of systems necessary to achieve and maintain hot shutdown conditions for Units I and 2, were not provided with acceptable fire protection in accordance with 10 CFR Part 50, Appendix R, Section III.G.2, or independent alternative or dedicated shutdown capability in accordance with 10 CFR Part 50, Appendix R, Section III.G.3.

2.

10 CFR Part 50, Appendix R, Section III.J, requires that emergency lighting units with at least an eight hour battery power supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes to those areas.

Contrary to the above, as of April 16, I982, the. battery powered

-emergency lighting units provided throughout Units 1 and 2 were rated to supply emergency lighting for less than six'hours and the following three areas were not provided with any battery powered emergency lighting:

a.

Unit I, Elevation 612', quadrant 2 Cable Tunnel.

Access through this area is necessary to reach local shutdown indication panels and emergency shutdown stations, b.

Unit 2, Elevation 612', quadrant 2 Cable Tunnel.

Access through this area 'is necessary to reach local shutdown indication panels and emergency shutdown stations, and c.

Unit 2, Elevation 609', Auxiliary Building West End.

This area contains an emergency shutdown station outside the Unit 2 Volume Control Tank enclosure.

3.

10 CFR Part 50, Appendix R, Section III.O requires that the reactor coolant pump lube ication oil collection system shall be

designed, engineered, and installed so that there is reasonable assurance that the system will withstand the Safe Shutdown Earthquake and that oil leakage shall be collected and drained to a vented closed container that can hold the entire lube oil system inventory.

Contrary to the above, as of June 10,

1982, the design, engineering, and installation of the lubricating oil collection system included a sight glass on the oil collection tank; The licensee could not provide reasonable assurance that the tank sight glass could with-stand the Safe Shutdown Earthquake.

Additionally, the oil collection tank was only large enough to hold approximately one'-fourth of the entire lube oil system inventory for the four reactor coolant pumps in each unit.

Notice of Violation C.

D.

Section 186 of the Atomic Energy Act of 1954, as

amended, requires that information provided to the Commission by an applicant or licensee shall be complete and accurate in all material respects.

On January 26, 1981, the licensee submitted to NRC copies of Revision' of the D.C.

Cook Emergency Plan dated January 2, 1981.

This Plan was submitted for review and evaluation as part of the NRC appraisal program.

The Plan stated, "The EOF is a required emergency response facility located to provide continuous coordination and evaluation of licensed activities during an emergency having or potentially having environmental consequences....

Once activated and staffed the func-tions of the EOF shall be to evaluate the magnitude and effects of actual or potential radioactive releases from the plant and to recommend appropriate offsite protective measures.

To accomplish these functions, facilities shall be provided in the appropriate areas of the EOF for the evaluation of all pertinent radiological, meteorological, and plant system data...

EOF personnel shall also coordinate the offsite radiological monitoring during nuclear emergencies and recovery operations."

Contrary to the above, the statements in the January 26, 1981 submittal contained inaccurate information on material matters.

The statements were inaccurate because the licensee's EOF was not capable of functioning as described in its Emergency Plan.

The EOF facilities were inadequate in that:

(.1) the Recovery Center portion of the

EOF, which was to serve as the command center for the direction of all recovery operations, contained only tables, chairs and two telephones; (2) no records, status

boards, maps, evacuation

plans, FSAR, or dose assessment capability was provided in the EOF for the evaluation of pertinent radiological, meteorological, arid plant systems data; and (3) even if such equipment had been available at other locations, no adequate procedures were available to equip the EOF, rior were personnel trained or designated to equip the EOF to enable evaluation of actual or potential radiological releases from the plant or to recommend appropriate off-site protective measures.

The statements were material

because, had the staff known the true situation, the licensee would have been required to initiate actions to implement the emergency plan description in the EOF.

Section 186 of the Atomic Energy Act of 1954, as

amended, requires that information provided to the Corrmission by an applicant or licensee shall be complete and accurate in all material respects.

Facility Operating License No.

DPR-74 for D.C.

Cook Nuclear Plant, Unit 2, was issued on December 23, 1977.

'mendment No.

12 of Facility Operating License No.

DPR-74 for D.C. Cook Nuclear Plant, Unit 2, was issued on July 31, 1979.

The NRC Safety Evaluation Report dated July 31, 1979 supporting that license amendment stated, "Accordingly, to increase the margin of safety, we require an electrical power H

1

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Notice of Viol ation E.

network to be available to power the systems and any components associated with achieving and maintaining hot shutdown as part of the alternate emergency shutdown method.

,We have discussed this matter with the licensees and they have agreed to meet this requirement."

In the attachment to a letter submitted to the NRC on March 27, 1981 (AEP:NRC:00428A), the licensee

stated, in part, "In addition, we have provided in both Units 1 and 2 local manual control capability of the emergency diesel generators as part of the alternate local shutdown system in accordance with Unit 2 License Condition 2.C.3(o)(c).

This provides the local shutdown system with the capability of performing its function given a loss of offsite power."

Contrary to the above, the statement made in the attachment to the licensee's letter (AEP:NRC:00428A) dated March 27, 1981, contained inaccurate information on material matters.

The statement was inaccurate in that the local shutdown system could not perform its function given a loss of offsite power.

While equipment modifications had been made, operating procedures had not been written and on-shift operating crews were not trained to provide that capability until after the April 12 through 16, 1982 NRC inspection at the D.C.

Cook Nuclear Plant.

This inaccurate statement was material because the NRC issued an SER and license amendment based upon the licensee's commitment to provide the capability and, had the true situation been known, the licensee would have been required to implement that ca pa bility.

t Technical Specification 6.8.l.f for Units 1 and 2 requires that written procedures be established, implemented, and maintained covering the fire protection program implementation.

Contrary to the above, at the time of the April 1982 inspection, adequate written procedures had not been established, implemented and maintained covering alternate shutdown capability for Units 1

and 2 in the event of loss of control of safe shutdown equipment due to a fire.

The "Alternate Emergency Shutdown and Cooldown Procedure Due to Loss of Normal and Preferred Alternate Methods" contained deficiencies which could have precluded the operators from satisfac-torily performing that emergency procedure.

The procedure would have been needed to achieve and maintain hot shutdown conditions and to cool down to cold shutdown conditions following loss of the control of safe shutdown equipment from either the Control Rooms or Hot Shutdown Panels due to fire.

Selected examples of the deficiencies that existed are listed below:

1.

For Unit 1, Procedure No.

+~1-OHP 4023.001.001, Revision No. 4, issued June 5, 1979, with Temporary Procedure Sheets No.

1 and No. 2, issued February 10, 1981:

Notice of Violation (a)

(b)

(c)

(d)

Procedure text at page 10 of 22, step 5.4.3 incorrectly identified the Unit 2 Motor Driven Auxiliary Feedwater Pump (HDAFP) when it should have been the Unit 1 West HDAFP.

Additionally, Attachment 3, page 15 of 37 contained the same error of identification and required the modification of the circuit breaker for the Unit 2 HDAFP, not the Unit 1 West HDAFP.

With normal valve alignment, the Unit 2 MDAFP cannot provide feedwater to the Unit I steam generators.

Procedure text at page 15 of 22, step 5.8.23-1 directed the operator to, "Close QRV-251 and QRV-200."

These valves are the charging flow control valve and the reactor coolant pump seal back pressure regulating valve, respectively.

They are pneumatic flow control valves which are not to be directly

operated, but rather to be supplied with control air from an emergency valve station that would have been tied into QRV-251 and QRV-200 for emergency local operation 'in prece-ding steps.

Neither the procedure nor any operating signs at the emergency valve station informed the operator of the, amount of air pressure to be supplied from the emergency valve station regulators such that QRV-251 and QRV-200 would receive the proper pneumatic closing signal.

When asked by the inspector, the licensed senior reactor operator accom-panying the inspector durino the procedure walk-through could not state the proper value of air pressure to be supplied., page 19 of 37 contained a procedure to modify Breaker I-AB-D for the control air compressor.

Part of Step 5.2 of this procedure directs the operator to jumper terminal point 22 to terminal point I in breaker compartment R3D.

There was no terminal point labeled "22" in breaker compartment R3D.

Breaker modification procedures for several 4KV and 600V breakers were included as A tachments IA and 2 of the procedure.

Modifications to each of the breakers involved lifting leads and installing jumpers on terminal block "AJ."

During the walk-through of the procedure, the label for terminal block "AJ" was observed missing from eleven breakers.

2.

For Unit 2, Procedure No. **2-OHP 4023.001.001, Revision No. 1, issued June 5, 1979, included a Temporary Procedure Sheet No.

5 dated Hay 5, 1981, which changed Attachmert 3, procedure H.5.4.

Procedure H.5.4 modified the control for the Unit I MDAFP breaker.

Temporary Procedure Sheet No.

5 merely changed the

Notice of Violation title of the affected component from Unit 1

MDAFP to West

MDAFP, but did not change the breaker modification steps in the proce-dure for such items as terminal points to be jumpered and cable tag numbers for the cable whose leads were to be lifted.

Thus, the procedure would have required the modification of the breaker for the Unit 1

MDAFP instead of the Unit 2 West NDAFP.

With normal valve alignment, the Unit 1 NDAFP cannot provide feedwater to the Unit 2 steam generators.

II.

Section 186 of the Atomic Energy Act of 1954, as

amended, requires that information provided to the Commission by an applicant or licensee shall be complete and accurate in all material respects.

A.

Following a site visit conducted by the staff as a part of the NRC review of the D.C.

Cook Nuclear Plant, Units 1 and 2, fire protection

program, the staff requested by letter dated July 11, 1977 that the licensee provide information concerning unprotected

'openings observed in areas protected by gas agent extinguishing systems.

The licensee's response dated August 19, 1977, stated, in part, "There are no unpro-tected openings in the boundaries of an area in Unit 1 protected by a gas agent extinguishing system... all ventilation openings are equipped with self-closing rated fire dampers" (emphasis supplied by licensee).

Contrary to the above, the statement made in the licensee's letter dated August 19, 1977 contained inaccurate information on material matters.

It was inaccurate

'in that it was determined during the April 12 through 16,

1982, NRC inspection that the 1AB and 1CD

'mergency Diesel Generator Rooms, which are protected by carbon dioxide gas agent extinguishing systems, had ventilation penetrations in the boundary walls that were not equipped with fire dampers.

This inaccurate statement was material in that had the true situation been known, the licensee would have been required to initiate action to achieve compliance.

B.

On January 9, 1984, an application for renewal of Reactor Operator License OP-30026 was received by the NRC and signed by the applicant, the site training coordinator, the plant superintendent

.and a vice president, stating that the applicant had satisfactorily completed the approved requalification program.

Contrary to the above, the application contained an inaccurate statement on material matters.

The statement was inaccurate because the individual had not satisfactorily completed the approved requali-fication program.

The statement was material because had the NRC

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Notice of Violation, staff known that the individual had not completed the training, License OP-30026 would not have been renewed.

FOR THE NUCLEAR REGULATORY COYHISSION pj~

A. Bert Davis Regional Administrator Dated at Glen Ellyn, Illinois this 6th day of March 1991