ML17334A574

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Forwards Insp Repts 50-315/97-201 & 50-316/97-201 on 970804-0912.No Violations Noted.Team Identified Issues Re Design & Procedural Control,Ses,Engineering Judgement, Operability Determinations & Temporary Mods
ML17334A574
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 11/26/1997
From: Richards S
NRC (Affiliation Not Assigned)
To: Fitzpatrick E
INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
Shared Package
ML17334A575 List:
References
50-315-97-201, 50-316-97-201, NUDOCS 9712030221
Download: ML17334A574 (10)


See also: IR 05000315/1997201

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UNITED STATES

NUCLEAR REGULATORY COMMlSSlON

WASHINGTON, D.C. 2055&4001

Noverber 26,

1997

Mr. E.

E. Fitzpatrick

Vice President-

Nuclear

500 Circle Drive

Buchanan,

Michigan 49107-1395

SUBJECT:

DONALD C.

COOK,

UNITS

1

& 2 DESIGN

INSPECTION

{NRC INSPECTION

REPORT

NO. 50-315,

316/97-201)

Dear Mr. Fitzpatrick:

From August

4 through September

12,

1997,

the staff of the U.S. Nuclear

Regulatory

Commission

{NRC), Office of Nuclear Reactor Regulation

(NRR),

Events Assessment,

Generic

Communications

and Special

Inspection

Branch,

conducted

a design inspection at the D. C.

Cook Nuclear

Power Plant,

Units

1

& 2, of the Residual

Heat

Removal

(RHR) system,

the Component

Cooling

Mater

{CCM) system,

and their support-interface

systems.

The inspection

team

consisted of a team leader

from NRR and five contractor engineers

from the

Stone

& Mebster Engineering Corporation

{SMEC).

The primary objective of the

design inspection

was to evaluate

the capability of the selected

systems to

perform the safety functions required

by their design

bases,

the adherence

of

the systems

to their design

and licensing bases,

and the consistency

of the

as-built configuration

and system operations with the Updated Final Safety

Analysis Report

{UFSAR).

The findings of the inspection

were discussed

during

an exit meeting

on September

12,

1997,

and are presented

in the enclosed

report.

The team identified

a number of issues

concerning

design

and procedural

control, safety evaluations,

engineering

judgement, operability

determinations,

temporary modifications,

and consistency

between the

UFSAR and

Technical Specifications

(TS).

Some of these

issues

affected the ability of

the systems

to perform their safety functions.

Examples of these

issues

are

listed below.

(2)

Revisions

made in 1992 to the emergency

operating

procedure for the

manual

swapover

from the refueling water storage

tank

(RMST) to the

containment recirculation

sump during

a loss of coolant accident created

a single failure vulnerability that potentially could have

caused

both

trains of the centrifugal charging

and safety injection pumps to be

inoperable.

kp-I

Operational

changes after 1988, permitted the plant to operate

above the

design basis ultimate heat sink temperature

of 76'F without your staff

having performed

a

10 CFR Part 50.59 evaluation,

and without considering

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Mr. Fitzpatrick

Novarber

26,

1997

the impact this would have

on overall plant operation.

As a result,

an

apparent

unreviewed safety question

and unanalyzed

condition was created

in )988,

when the plant operated for 22 days with an averaged

ultimate

heat sink temperature

of 81'F, creating the potential for safety-related

equipment in the control

room to not perform its safety function under

design basis

assumptions.

{3)

The licensee

documented

in a letter to the

NRC, dated

December

29,

1978,

containment

sump enhancement

modiFications that consisted of installing

five 3/4-inch vent holes in the roof of the containment recirculation

sump.

However, the

UFSAR was not updated to reflect these

changes,

and

the vent holes

were in excess

of the 1/4-inch

sump particulate retention

design basis

value.

In addition,

these

vents were sealed

in 1996

and

1997 without performing

a

10 CFR Part 50.59 evaluation,

and without an

adequate

understanding

oF the commitment

made to the

NRC to maintain

vents in the containment recirculation

sump.

(4)

During the Unit 2 1996 refueling outage,

both

CCW and

ESW trains were

r moved from service contrary to the assumptions

contained

in Chapter

9

e

of the

UFSAR, with the intention by your stafF of performing

a dua 1

CCW/ESW train outage.

Although the dual train outage

was not fully

sustained

as originally planned

by your staff, this operational

condition would have placed the plant at increased risk, outside of its

design basis,

and in an unanalyzed

condition.

Th t

am also identified examples

involving:

(1) failure to account for

instrument bias

and establish

the proper refueling water storage

tank

(RW

)

ST

and containment level setpoints

necessary

to preclude

premature

manual

RWST

switchover

and subsequent

potential vortexing in the containment

sump,

{ )

failure to remove fibrous insulation material

from containment

cable trays,

that could potentially be swept into and block in excess of the design value

of 50 percent of the containment recirculation

sump screen

area,

and {3) the

creation of a common-mode failure vulnerability that could potentially clog

redundant trains of ECCS throttle injection valves

and containment

spray

nozzles.

On September

8,

1997, your staff initiated

a dual unit shutdown,

and issued

a

notification of an unusual

event

{NOUE), as

a result of the inability to

demonstrate

to the team that the

ECCS system would have performed its safety

function during post-LOCA conditions

under all postulated

accident

scenarios.

On September

19,

1997, the

NRC issued

a conFirmatory action letter listing

many of the issues

identified during this inspection.

Although Items

1, 2,

and

4 listed above

had

been

known and documented

by your

staff,

no apparent effective action was taken to correct the problems or their

root causes.

The team concluded that

a contributing cause to these

issues

and

others identified in the enclosed report was that prior to this inspection,

I

o

Mr. Fitzpatrick

Nov8iber 26,

1997

your staff had

an apparent

lack of understanding

of what constitutes

the

plant's design basis,

the role of the

UFSAR,

and

how each of these

are

affected

by 10 CFR Part 50.59.

We expect that your staff will evaluate

the applicability of the results

and

specific findings of this inspection to other systems

and components

throughout the plant.

In addition, your staff should evaluate

the findings of

this inspection against your February 6,

1997 response

to the

NRC 50.54(f)

letter concerning

the adequacy

and availability of design

bases

information.

Please

provide

a schedule,

within 60 days, detailing your plans to complete

the corrective actions for the open items listed in Appendix A to the enclosed

report.

This schedule will enable

the

NRC staff to plan for the reinspection

and closeout of these

items.

.

Docket Nos.:

50-315

and 50-316

Original signed by

Stuart A. Richards,

Chief

Events Assessment,

Generic Communications,

and Special

Inspection

Branch

Division of Reactor

Program

Management

Office of Nuclear Reactor Regulation

In accordance

with 10 CFR 2.790(a),

a copy of this letter and the enclosure

will be placed in the

NRC Public Document

Room.

Any enforcement

action

resulting from this inspection will be handled

by

NRC Region III via separate

correspondence.

Should you have

any questions

concerning the enclosed

inspection report,

please

contact the project manager,

Mr. John

B. Hickman at

(301) 415-3017.

1

Sincerely,

Enclosure:

Inspection

Report 50-315,316/97-201

cc w/enclosure:

See next page

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CONCURRENCE

DOCUMENT NAME:

A:iCOOK.RPT

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indicate in the box C=Co y u/o attachment/enclosure

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SARichards

ll 3

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OFFICIAL RECORD

COPY

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E. E. Fitzpatrick

indiana Michigan Power Company-

Donald C. Cook Nuclear Plant

Units 1 and 2

Regional Administrator, Region III

U.S. Nuclear Regulatory Commission

801 Warrenville Road

Lisle, IL 60532-4351

Attorney General

Department of Attorney General

525 West Ottawa Street

Lansing, Ml 48913

Township Supervisor

Lake Township Hall

P.O. Box 818

Bridgman, Ml 49106

AI Blind, Site Vice President

Donald C. Cook Nuclear Plant

1 Cook Place

Bridgman, Ml 49106

U.S. Nuclear Regulatory Commission

Resident Inspector's Office

7700 Red Arrow Highway

Stevensville, Ml 49127

Gerald Charnoff, Esquire

Shaw, Pittman, Potts and Trowbridge

2300 N Street, NW.

Washington, DC 20037

Mayor, City of Bridgman

P.O. Box 366

Bridgman, Ml 49106

Special Assistant to the Governor

Room

1 - State Capitol

Lansing, Ml 48909

Drinking Water and Radiological

Protection Division

Michigan Department of

Environmental Quality .

3423 N. Martin Luther King Jr Blvd

P.O. Box 30630 CPH Mailroom

Lansing, Ml 48909-8130

Steve J. Brewer

Indiana Michigan Power Company

Nuclear Generation Group

500 Circle Drive

Buchanan, MI 49107

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