ML17331B343

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Notice of Violation from Insp on 940216-0321.Violation Noted:Attachment 2,rev 15,CS-4, RCS Drain to One to Two Feet Below Reactor Vessel Flange W/Fuel in Core, Inappropriate to Circumstances
ML17331B343
Person / Time
Site: Cook 
Issue date: 04/01/1994
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17331B342 List:
References
50-315-94-04, 50-315-94-4, NUDOCS 9404140026
Download: ML17331B343 (2)


Text

NOTICE OF VIOLATION Indiana Michigan Power Company Docket No. 50-315 Donald C.

Cook Nuclear Power Plant License Nos.

DRP-58 During an NRC inspection conducted from February 16 through March 21,

1994, violations of NRC requirements were identified.

In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"

10 CFR Part 2, Appendix C (1993),

the violations are listed below:

A.

10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," requires that activities affecting quality shall be prescribed by a procedure of a type appropriate to the circumstances and shall be accomplished in accordance with these procedures.

Procedures shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities -have been satisfactorily accomplished.

Procedure OHI-221, "Maintenance of Operations Department Logs,"

Revision 15, step 3.2. l.b for.the control room log and step 3.3. l.b for the shift supervisor log book, requires that all significant shift activities and events, and all pertinent information that would assist in the reconstruction of a plant event be recorded.

Contrary to the above:

As of February 16,

1994, Procedure 01-OHP 4021.002.005, Attachment No. 2, Rev.

15,'CS-4, "RCS Drain to One to Two Feet Below Reactor Vessel Flange with Fuel in Core,"

was inappropriate to the circumstances in that appropriate acceptance criteria for the volume of.water to be drained and a correlation between level indication readings and plant reference elevations were not included.

The procedure also did not contain adequate instructions to vent the reactor coolant system from 5 psig to 0 psig in a controlled manner.

2.

On February 16 through 18, 1994, pertinent information that would assist in the reconstruction of the reactor coolant system draindown event, including the volume of RCS to be drained, was not logged in the control room log or shift supervisor log book, as required by procedure OHI-221.

B.

This is a Severity Level IV violation (Supplement I).

10 CFR Part 50, Appendix B, Criterion XII states, in part,

"...measure shall be established to assure gages and instruments used in activities affecting quality are properly calibrated to maintain accuracy within necessary limits."

Contrary to the above, on February 16 through 18, 1994, pressurizer relief tank (PRT) level instrument, NLA-351, known to have an accuracy outside of necessary limits, was used to monitor level in the PRT during draindown of the RCS.

940414002h 940401 PDR ADOCK 05000315 8

PDR

C.

This is a Severity Level IV violation (Supplement 1).

10 CFR Part 50, Appendix 8, Criterion XVI, requires, in part, that the cause of significant conditions adverse to quality be identified and corrective action taken to preclude repetition.

Contrary to the above, the corrective actions for an August 5,

1993, draindown event were inadequate to preclude repetition of a similar condition that occurred during the February 16 - 18,
1994, draindown event.

During the draindown process in February 1994, operations personnel experienced difficulties in determining if flow existed through the reactor head vent bullseye..

The bullseye was the only means available to determine RCS level when level was between the bottom of the pressurizer and'the top of the vessel head.

On August 5,

1993, when the reactor coolant system was being drained to repair a reactor head
conoseal, failure to see flow through the bullseye resulted in the reactor being drained to a lower level than anticipated prior to valving in sight glass, NGG-100.

This is a Severity Level IY violation {Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Donald C.

Cook is hereby required to submit a written statement or explanation to the U.S; Nuclear Regulatory Commission, ATTN:

Document Control

Desk, Washington, D.C.

20555 with a copy to the U.S: Nuclear Regulatory Commission, Region III, 801 Warrenville Road, Lisle, Illinois 60532-4351, and a copy to the NRC Resident Inspector at the Big Rock Point Nuclear Plant within 30 days of the date of the letter transmitting this Notice of Violation (Notice).

This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation:

(1) the reason for the violation, or, if contested, the basis for disputing the violation, {2) the corrective steps that have been taken and the results

achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.

If an adequate reply is not received within the time specified in this Notice, an order or a demand for information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken.

Where good cause is shown, consideration will be given to extending the response time.

Dated. + Lisle, Illi ois this Q~ day of 1994