ML17334A719
| ML17334A719 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 05/27/1998 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Sampson J AMERICAN ELECTRIC POWER CO., INC. |
| References | |
| NUDOCS 9806050210 | |
| Download: ML17334A719 (25) | |
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UNITEDSTATES NUCLEAR REGULATORYCOMMISSION REGION III 601 WARRENVILLEROAD LISLE, ILLINOIS605324351 r
Nay 27, 1998 Mr. John Sarnpson Site Vice President Nuclear Generation Group American Electric Power Company 500 Circle Drive Buchanan, Ml 49107-1395
SUBJECT:
PLANT PERFORMANCE REVIEW (PPR) - D. C. COOK
Dear Mr. Sampson:
The NRC staff recently completed the semiannual Plant Performance Review (PPR) of the Donald C. Cook Nuclear Power Plant. The staff conducts these reviews for all operating nuclear power plants to develop, an integrated understanding of safety performance.
The results are used by NRC management to facilitate planning and allocation of inspection resources.
The PPR for the Donald C. Cook plant involved the participation of all technical divisions in evaluating inspection results and safety performance information for the period of October 1997 through March 1998.
PPRs provide NRC management with a current summary of licensee performance and serve as inputs to the NRC Systematic Assessment of Licensee Performance (SALP) and senior, management meeting {SMM)reviews.
Enclosure 1 contains a historical listing of plant issues, referred to as the Plant Issues Matrix
{PIM),that were considered during this PPR process to arrive at an integrated view of licensee performance trends.
The PIM includes only items from inspection reports or other docketed correspondence between the NRC and American Electric Power Company.
The PPR may also have considered some predecisional and draft material that does not appear in the attached PIM, including observations from events and inspections that had occurred since the last NRC inspection report was issued, but had not yet received full review and consideration.
This material willbe placed in the PDR as part of the normal issuance of NRC inspection reports and other correspondence.
This letter advises you of our planned inspection effort resulting from the Donald C. Cook PPR process.
It is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite. details our inspection plan for the next 6 months.
The rationale or basis for each inspection outside the core inspection program is provided so that you are aware of the reason for emphasis in these program areas.
Resident inspections are not listed due to their ongoing and continuous nature.
In addition to the inspections indicated in Enclosure 2, other inspections willbe conducted as part of the Manual Chapter 0350 process.
Some of these inspections are indicated on the inspection plan. Other inspections will be added based on completion of corrective actions and improvement initiatives.
98060502%0 980M7 PDR ADQCK 05000315 8
J. Sampson We willinform you of any changes to the inspection plan.
Ifyou have any questions, please contact me at 630/829-9700.
Sincerely, n A. Grobe, Director ivision of Reactor Safety Docket Nos.: 50-315, 50-316 License Nos.:
Enclosures:
1.
Plant Issues Matrix 2.
Inspection Plan cc w/encls:
Don Hafer, Acting Chief-Nuclear Engineer Douglas Cooper, Plant Manager Richard Whale, Michigan Public Service Commission Michigan Department of Environmental Quality Emergency Management Division, Ml Department of State Police David A. Lochbaum, Union of Concerned Scientists
J. Sampson We willinform you of any changes to the inspection plan.
Ifyou have any questions, please contact me at 630/829-9700.
Sincerely,
/s/ John A. Grobe John A. Grobe, Director Division of Reactor Safety Docket Nos.: 50-315, 50-316 License Nos.:
Enclosures:
1.
Plant Issues Matrix 2.
Inspection Plan cc w/encls:
Don Hafer, Acting Chief Nuclear Engineer Douglas Cooper, Plant Manager Richard Whale, Michigan Public Service Commission Michigan Department of Environmental Quality Emergency Management Division, Ml Department of State Police David A. Lochbaum, Union of Concerned Scientists DOCUMENT NAME: G:ttCOOKttINSPPLN6.DCC To receive a co ot this document, indicate in the box nc" ~ co unthout attachment/enctosure "E a co urrth attachment/enc/osure N'
No OFFICE RIII NAME Bu ss nh DATE 05 98 Rill Grob 05/
98 OFFICIAL RECORD COPY
J. Sampson Distribution:
Project Mgr., NRR w/encls C. Paperiello, Rill w/encls J. Caldwell, Rill w/encls B. Clayton, Rill w/encls SRI D. C. Cook w/encls DRP w/encls TSS w/encls DRS (2) w/encls Rill PRR w/encls PUBLIC IE-01 w/encls Docket File w/encls GREENS IEO (E-Mail)
DOCDESK (E-Mail)
PLANTtSSUES MATRIX DC Cook ENCXQSURE 1 5/22/98 Search Sorted by Date (Descending) and SMM Codes (Ascending):
Search Column "- "Date";
Beginning Date = "10/10/97";
Ending Date =
3/31/98"
¹ DATE TYPE SOURCE ID BY SALP MM CODE DESCRIPTION 1
3/31/1998 EEI 2
3/19/1998 Negative 3
3/19/1998 EEI 4
3/19/1998 EEI 5
3/19/1998 EEI 6
3/19/1998 EEI 7
3/19/1998 EEI 8
3/19/1998 EEI IR 98009 IR 98005 IR 98005 IR 98005 IR 98005 IR 98005 IR 98005 IR 98005 NRC Engineering NRC Maintenance 4A 48 4C 2A 28 3A NRC Maintenance 28 1A NRC Maintenance 28 2A NRC Maintenance 28 2A NRC Maintenance 28 2A NRC Engineering 4A 48 4C NRC Engineering 4A 48 4C A/E Team Followup Inspection approximately 16 apparent violations being considered for escalated enforcement The ice condenser was degraded to a poor state of materiel condition such that the operability of the ice condenser was in question.
(Section M2.1)
Eight apparent violations of 10 CFR 50 Appendix 8 (three Criterion four Criterion XI,'and one Criterion Vll)and two violations of technical specifications (TS) were identified pertaining to inadequate surveillance testing ofthe ice condenser.
Specifically, these violations pertained to inadequate instructions, inadequate acceptance limits, inadequate control of contractors, failure to implement TS requirements and entry into an unanalyzed condition for ice condenser surveillance testing.
(Section M1.1)
Two examples of an apparent violation of 10 CFR 50 Appendix 8, Criterion Vwere identified forthe licensee's failure to followthe procedul'e change process for changes made to completed surveillance tests.
(Section M1.1)
Collectively, the apparent violations associated with surveillance testing activities represented a breakdown in the surveillance testing program forthe ice condenser.
(Section M1.1)
Three apparent violations of 10 CFR 50 Appendix 8, Criterion XVIw identified forthe licensee's failure to identify conditions adverse to quality. Conditions not previously identified by the licensee in the ice condenser included: blocked flowpassages, missing ice segments, dented/buckled basket webbing, unweighable ice baskets, and nonencapsuiated insulation. (Section M2.1)
Collectively, the apparent violations identified in Section E7.1 represent a programmatic breakdown in the maintenance of the design basis for the ice condenser.
(Section E7.1)
Seven apparent violations of 10 CFR 50.71(e) were identified pertaining to the licensee's failure to update the Final Safety Analysis Report (FSAR) Appendices J and M, which contained the detailed description and design basis for the ice condenser.
(Section E7.1)
Page 1 of 18
PLANTISSUES MATRIX DG Gook 5/22/98 Search Sorted by Date (Descending) and SMM Codes (Ascending):
Search Column = "Date; Beginning Date = "10/10/g7";
Ending Date = "3/31/I
- DATE TYPE SOURCE ID BY SALP MM CODE DESCRIPTION 9
3/19/1998
~ EEI IR.98005 NRC Engineering 4C 4A 4B Four apparent violations of 10 CFR 50 Appendix B, Criterion IIIwere identified pertaining to the licensee's failure to followthe established design control process for ice basket modifications.
(Section E7.1) 10 3/19/1998 EEI IR 98005 NRC Engineering SC 2A 2B Four apparent violations of 10 CFR 50 Appendix B, Criterion XVIwere Identified forthe licensee's failure to identify and correct conditions adverse to quality on ice condenser components.
Specifically, these~
violations pertained to the licensee's failure: to implement prompt corrective actions for missing ice basket sheet metal screws, to implement effective corrective actions for preventing the recurrence of loose U-bolt nuts and separated ice baskets, and to take appropriate corrective actions forthe ice baskets with defective hold down bar welds.
(Section E2.1) 11 3/'l9/1998 EEI IR 98005 NRC Engineering 5C 2A 2B Collectively, the apparent violations Identified in Sections M2.1 and E2.1 represent a breakdown in the licensee's corrective action program forthe ice condenser. (Section E2.1) 12 2/27/1998 Positive 13 2/27/1998 EEI IR 97017 IR.97017 NRC Maintenance 2A 4B NRC Operations 2B The corrective action implemented subsequent to the final evaluations of material condition problems in containment were extensive.
The licensee. removed over 13,000 pounds of various materials from the containments, including insulation, coatings (paint) ~ labels, rust, tape, high efficiency particulate air (HEPA) filters, granular charcoal, and other foreign material.
In Unit 1, paint was removed from the lower containment floordown to the base concrete and new coatings were ~
applied.
Equipment such as welding machines, vacuums, and man~
used. during outages were also removed (Section E1.1.b.3).
The containment inspection tours procedure which defined how to perform containment inspections, was inappropriate to the circumstances in that it made no reference to inspection for fibrous material or insulation that could clog the recirculation sump. This is an apparent violation and is being considered for escalated enforcement (Section E1.1.b.7).
Page 2 of 18
PLANTISSUES MATRIX DC Cook Searchsorted Date Descendi andSMMCodes Ascendi:
SearchCotumn
= "Date";
Beginning Date = "1O/10/97";
EndlngDate "-"3/31/9F 5/22/98 DATE TYPE SOURCE ID BY SALP MM CODE DESCRIPTION 14 2/27/1998 EEI IR 97017 NRC Engineering 4A A lack of design control led to the installation of Fiberfrax, a fibrous damming material found inside both containments that could potentially cause blockage of the containment recirculation sump screens during the recirculation phase of a loss of coolant accident (LOCA) resulting in Insufficient emergency core cooling water flowto the reactor vessel.
The lack of sufficient measures to assure that the design basis was correct translated into specifications to control the installation of material tha could potentially have an adverse effect on the safety-related function ofthe containment system is an apparent violation and is being considered for escalated enforcement (Section E1.1.b.7).
15 2/27/1998 EEI IR 97017 NRC Engineering 4A 4B 4C The installation, replacement, and repair procedure for silicone fire bamer penetration seals, was inappropriate to the circumstances in that it did not require that fibrous damming material be removed or encapsulated following seaiing operations.
This is an apparent violation and is being considered for escalated enforcement (Section E1.1.b.7).
NRC Engineering 4B 2A 17 2/27/1998 EEI IR 97017 Licensee Engineering 4C 16 2/27/1998 Negative IR 97017
-The initial engineering evaluations performed to determined whether or not the recirculation sump was operable in the as-found condition were
~
not well supported and did not fullyaddress the amount of debris found in containment.
Subsequent engineering evaluations and support to restore the containment material condition were thorough.
Engineering personnel also did an extensive evaluation of the coatings on equipment that could have an adverse effect on the performance of the recircuiati n sump screens following a LOCA (Section E1.1.b.6).
The installation of unjacketed fibrous insulation inside of both containments could potentially cause blockage of the containment recirculation sump screens during the recirculation phase of a loss of coolant accident resulting in insufficient emergency core cooling water flowto the reactor vessel.
The lack of sufficient measures to assure that the design basis was correctly translated into instructions which would be changed in a controlled manner is an apparent violation and is being considered for escalated enforcement (Section E1.1.b.7).
18 2/27/1998 URI IR 97017 URI NRC Engineering 4C 97017-05 One unresolved item relative to TS operability of the as-found condition ofthe containment recirculation sump was also identified.
The unresolved item willbe dispositioned subsequent to the completion of a detailed analysis by the engineering department (Section E1.1.b.7).
'Page 3 of 18
PLANTISSUES MATRIX DC Cook Search Sorted by Date (Descending) and SMM Codes (Ascending):
Search Coturnn = Date; Beginning Date ~ "10/10/97";
Ending Date =
"3/31/g8'/22lb8
¹ DATE TYPE SOURCE ID BY SALP MM CODE DESCRIPTION 20 2/20/1998 Positive IR 97025 NRC Operations 2A 5A. 4A 19 2/20/1998 VIO/SL-IV IR 97025 NRC Maintenance 2A The questionable material condition ofthe SSPS master relay dust covers resulted in both trains of SSPS being declared inoperable for operability under seismic conditions. A violation was identified when the licensee failed to make a timely report to the NRC concerning an unanalyzed condition that significantly compromised plant safety.
An'nresolved Item was opened to track the review of additional data to determine when licensee personnel were aware ofthe degraded condition of the SSPS relays (Section M2.1).
The inspectors concluded that cold weather preparations had been properly implemented.
The inspectors also concluded that it was prudent to procure a stand-by boiler in order to ensure that safety-related equipment and other plant spaces were not adversely affected by cold weather in the event the plant heating boiler was unable to operate (Section 01.2).
21 2/20/1998 Negative 22 2/20/1998 Positive 23 2/20/1998 URI IR 97025 IR 97025 IR 97025 NRC Maintenance 3A NRC Maintenance 3A NRC Engineering 4B 5C The Instrumentation and Control (l&C)technician work on the Solid State Protection System (SSPS) relay repairs was noteworthy. An exception to this good performance was a personnel error by an l8C technician on another activity which resulted in an invalid reactor trip signal.
In addition, the inspectors determined that the required report regarding the.
inadvertent trip signal was not going to be made to the NRC until after the inspectors questioned the lack of a report (Section M1.1).
The inspectors concluded that the work activities observed were performed in a quality manner with procedures present and in use. T~
high quality of the Instrumentation and Control (l&C)technician work on the Solid State Protection System (SSPS) relay repairs was especially noteworthy (Section M1.1).
Performance testing of the containment hydrogen skimming system continued during this inspection report period. Computer modeling and engineering assessments were being performed in an effort to determine the as-found operability and to ensure the system would be returned to an operable condition. An unresolved item on the as-found condition of the hydrogen skimming system remained open. The inspectors concluded that the Licensee Event Report (LER) issued contained inappropriate statements (Section E1.1).
Page 4 of 18
PLANTISSUES MATRIX DC Cook 5/22/98 SearchSortedbyDate(Descending) andSMMCodes(Ascending):
Search Column "-Date";
Beginning Date ~
10/10/g7";
Ending Date = "3/31/ga"
¹ DATE TYPE SOURCE ID BY SALP MM CODE DESCRIPTION 24 2/20/1998 VIO/SL-IV IR 97025 NRC Engineering 4C 5C 25 2/17/1998 LER LER 315-98009 NRC Maintenance 2B 26 2/12/1998 LER LER 315-98008 Licensee Maintenance 2B 2A During a review of selected LERs, the inspectors identified one event"'hat was improperly retracted and another event that was not reported in a timely manner. Athird LER had an Insufficient basis for retraction until the licensee performed additional calculations in response to inspector" questions.
One violation for failure to submit a timely LER was issued (Section E8.1).
Hydrogen recombiner surveillance requirement not being met results unanalyzed condition Failureof ice basket to withstand simulated accident loadings during testing results in unanalyzed condition.
27 2/11/1998 LER 28 1/29/1998 LER
~
29 I/22/1998 LER 30 1/22/1998 LER LER 315-98007 NRC Maintenance 4C LER 315-98006 NRC Maintenance 4B LER 315-98004 NRC Maintenance 2A 4A LER 315-98005 Licensee Maintenance 4A 2A ice Condenser Weights Used to Determine Technical Specification Compliance Not Representative Procedural Option for Weighing of Ice Baskets in Modes 3 and 4 Determined to be a Potentially Unanalyzed Condition Restricted Ice Condenser Flow Passages Found to Constitute an Unanalyzed Condition Lack of Adequate Number of Screws in Ice Basket Coupling Rings Determined to Constitute Unanalyzed Condition 31 1/16/1998 Positive 32 1/16/1998 Negative 33 1/16/1998 Positive 34 1/16/1998 Positive 35 1/16/1998 Positive IR 98003 IR 98003 IR 98003 IR 98003 IR 98003 NRC Operations 1A NRC Operations 3B NRC Operations 3B NRC Operations 3B NRC Operations 3B Page5of 18 Control room conduct of operations and decorum were effective at maintaining appropriate focus on plant and system evolutions.
(Secti 01.1)
Some operator performance weaknesses for communications and crew briefs were observed during the requalification operating examination.-
(Section 05.3)
Licensee documentation and evaluation of operator performance showed improvement since the previous LOR program inspection.
(Section 05.3)
Appropriate security measures were implemented throughout the annual requalification examination.
(Section 05.3)
LOR program adequately revised to administer comprehensive examinations (Section 05.3.1)
PLANT ISSUES MATRIX DC Cook 5/22/98 Search Sortedby Date (Descenrfeg) and SMM Codes(Ascending):
Search Cotumn = "Date";
Beginning Date ~ "10/10/97";
Ending Date = "3/31/ga"
¹ DATE TYPE SOURCE ID BY SALP MM CODE DESCRIPTION 36 1/16/1998
. NCV 37 1/16/1998 Negative 38 1/16/1998 Positive 39 1/16/1998 Positive 40 1/16/1998 Positive 41 1/16/1 998 Positive 42 1/16/1998 Positive 43 1/13/1998 EEI 44 1/13/1998 Positive IR 98003 IR 98003 IR 98003 IR 98003 IR 98003 IR 98003 IR 98003 IR 98006 IR 98006 NRC Engineering 3B NRC Maintenance 3B NRC Operations 3B NRC Operations 3B NRC Operations 3B NRC Engineering 3B NRC Plant 1C 3A Support NRC Plant 2A Support NRC Operations 5A The engineering support personnel training program failed to maintain a systems approach to training (NCV 50-315/316-98003-01).
(Section E5.1)
II Implementation of a systems approach to training for the maintenance
~ and technical training programs was adequate with known weaknesses in the area of continuing technical training and program evaluation.
(Section M5.1)
Overall examination material improved since the previous annual LOR program NRC inspection, although some job performance measure (JPM) and written examination deficiencies continued to exist. (Section 05.2)
In general, the requalification examination material bank contained the minimum attributes to provide an adequate evaluation of operator skills.
(Section 05.2)
In general, the annual requalification examination met the minimum criteria in accordance with the guidance given in NUREG 1021, "Operator Licensing Examination Standards for Power Reactors," Interim Revision 8. (Sections 05.2, 05.3)
Licensee corrective actions forthe engineering support personnel training program appeared adequate and were on schedule.
(Section E5.1)
The inspectors determined that the licensee's Training Department feedback process was satisfactorily implemented.
(Section 5.4)
The licensee failed to maintain positive control over a radioactive material shipment, resulting in its leaving the site without the driver having the required shipping paperwork or emergency response instructions. Two apparent violations of regulatory requirements were identified. (Section R1.1)
The overall calibration and maintenance system for the portable instrument program was effectively implemented with the exception of the inspector identified RM-14/RM-20 response check weakness.
(Section R2.1)
Page 6 of 18
PLANT, ISSUES MATRIX DC Cook 5/22/98 Search Sortedby Date(Descending) and SMM Codes (Ascending):
Search Cotumn = "Date";
Beginning Date = "1O110/97; Ending Date =
3f31198" DATE TYPE SOURCE ID BY SALP MM CODE DESCRIPTION 46 1/13/1998 Positive IR 98006 NRC Plant Support 2A 1C 5A 47 1/13/1998 VIO/SL-IV IR 98006 NRC Plant 3A Support 45 1/13/1998 Positive NRC Plant 2A Support Material condition of the Aptec PMW-3, PCM-1 B whole body friskers and portal monitors was good, and workers used this equipment appropriately.
Calibrations and tests were performed at the required c
frequencies and response test results were good.
Independent reviews indicated that the monitoring instrumentation was capable of detecting the established external and internal personal radioactive contaminatio limits. (Section R2.2)
Rugs with low levels of contamination build-up on them were being cleaned outside of the protected area.
The contamination to the soil was Identified and remediated, and corrective actions were appropriate.
(Section R1.2)
A procedural violation was identified forworkers who did not check their electronic dosimetry prior to entering the radiologically controlled area to ensure that they were tumed on. The licensee's review of this matter..
had not sufficiently considered the procedural requirement that workers check their electronic dosimetry.
(Section R4.1) 48 1/13/1998 VIO/SL-IV 49 1/13/1998 VIO/SL-IV IR 98006'R 98006 NRC Plant 3A 3B Support NRC Plant 5A Support A procedural violation was identified when workers in the lower ice condenser were found not wearing two pairs of gloves as required by the radiation work permit. This violation, as well as the violations cited in sections R4.1 and R4.2, in the aggregate, indicate a decline in radiation worker performance.
Of further concern was the fact that workers had been disregarding the RWP dress requirements for two to three week and RP had failed to identify this practice.
(Section R4.3)
Aworker's failure to contact radiation protection after alarming the security gate house portal monitors was a procedural violation.
Additionally, of concern, was the licensee's conclusion regarding where the hot particle had come from. The condition report concluded that it had come from outside the radiologically controlled area and even possibly outside the buildings but did not address other more likely scenarios.
Further, the inspectors were concerned that the condition report addressing the procedural violation had not been responded to at the time of the inspection.
(Section R4.2) 50 1/13/1998 Negative IR 98006 IR 98006 NRC Plant Support 5C 5A The licensee was effective at identifying problems, but was not as effective in resolving and/or documenting them.
(Section R7.1)
Page 7 of 18
PLANT ISSUES MATRIX DC Cook 5/22/98 Search Sorted by Date (Descending) and SMM Codes (Ascending):
Search Coiumn = "Date";
Beginning Date =
10/10/97";
Ending Date = "3I31iM'.
¹ DATE TYPE SOURCE ID BY SALP MM CODE DESCRIPTION IR 98002 51 1/9/1998 Positive NRC Plant 1C 3A Support The self evaiuations performed by the plant protection department were good. Effective corrective actions were taken to resolve identified problems.
(Section F7) 52 1/9/1998 Positive 53 1/9/1998 Positive 54 1/9/1998 Positive 55 1/9/1998 Positive IR 98002 IR 98002 IR 98002 IR 98002 NRC Plant 2A Support NRC Plant 2A 4B Support NRC Plant 3B Support NRC Plant 5A 3A Support Material conditions ofthe fire protection equipment appeared to be good. Minimal amounts of combustible and impairments were noted in the plant. (Section F2)
The licensee was proactive in performing 100 percent destructive testings of gap seals.
(Section F3)
The training provided to the fire brigade appeared to be adequate.
The annual physical examinations were kept up-to-date.
(Section F5)
The performance of the observed fire drillwas good with two weaknesses.
The area to the equipment lockers of the brigade members was partially obstructed and the brigade leader did not dispatch another person as a communication linkwhen encountering radio problems (Section F4).
56 1/9/1998 Positive 57 1/8/1998 LER 58 1/7/1998 LER IR 98002 NRC Plant 5C SA Support LER 315-98003 Self-Maintenance 3A Revealed LER 315-98002 Licensee Maintenance 2A 4A The corrective actions taken to resolve problems noted during welding, burning and grinding activities appeared to be adequate and were driven.
by self evaluations (Sections F1 and F7).
Degraded Solid State Protection System Master Relays Result in Condition Outside the Design Basis Missed Procedure Step Results in Engineered Safety Features and Reactor Protection System Actuation 59 1/7/1998 Negative (50.72 event Licensee Maintenance 3A notification 33505 (retracted))
60 1/4/1998 LER LER 315-98001 Licensee Engineering 2A 4A During a surveillance procedure an l&Ctechnician missed a step to reset the solid state protection system memory resulting in a reactor trip while shutdown and the reposition of the main steam isolation valve dump valves.
Containment AirRecirculation System Flow Testing Results Indicate Condition Outside the Design Basis Page8of 18
PLANTISSUES MATRIX DC Cook 5/22/98 Search Sorted by Date (Descending) and SMM Codes (Ascending):
Search Column -" "Date";
Beginning Date = 10/1087";
Ending Date = "3I31lM D'ATE TYPE SOURCE ID BY SALP MM CODE DESCRIPTION 62 12/27/1997 NCV IR 97024 NCV Licensee Maintenance 2A 61 12/27/1997 VIO/SL-IV IR 97024 VIO NRC Engineering 1A The inspectors identiTied a violation in which the licensee failed to treat the manual backwashing of the ESW strainers in accordance with quality standards commensurate with the importance ofthe safety functions to be performed.
The licensee committed to complete the corrective actions necessary prior to placing either unit in Mode 4, Hot Shutdown (Section E1.1):
A non-cited violation was issued when licensee personnel identified t non-safety-related parts were used during maintenance activities on the Unit 2 AB diesel generator.
The licensee looked for other instances where non-safety-related parts could have been used and identified one other example (Section M4.1).
63 12/27/1997 URI 64 12/27/1997 URI IR 97024 URI Licensee Maintenance 2A 4B IR 97024 URI Licensee Maintenance 2A 4B Licensee personnel identified a blocked hydrogen skimmer connection to a steam generator enclosure.
The blockage of this line, coupled with failure of the opposite train skimmer, could have resulted in an excessive buildup of hydrogen gas in the steam generator enclosure following a postulated loss of coolant accident.
This issue is considered an unresolved item pending the results of testing the individual flow connections from each containment enclosure (Section M1.2).
During periodic maintenance on the Unit 2 upper containment airlock, licensee mechanics found that the "0" ring seal material installed on tlie inner bulkhead interlock shaft was Teflon packing rather than the specified EPDM elastomer.
This is considered an unresolved item pending the results of the root cause assessment and a detetminatio~
the safety significance of the use ofTeflon seals (Section M1.3).
65 12/27/1997 Negative IR 97024 Self-Maintenance 4B 5B Revealed The licensee's efforts to modify the Unit 2 AB diesel generator (D/G) reflected a weakness in design control in that multiple changes were made to engine components without a thorough understanding of the interrelations of proposed modifications. The engine timing change, performed to reduce cylinder pressure, in conjunction with the fuel line
- changes, resulted in several other engine parameter changes which were not anticipated by the licensee.
The troubleshooting and analyses required to correct the engine parameters resulted in a significant delay in the licensee's restoration of the 2 AB D/G to service (Section M2.3).
Page 9 of 18
PLANT1SSUES MATRIX DG Gook 5/22/98 Search Sorted by Date (Descending) and SMM Codes (Ascending):
Search Column = "Date; Beginning Date =
10/10/97";
Ending Date = "3/31/Mr
¹ DATE TYPE SOURCE ID SY SALP MM CODE DESCRIPTION 66 12/10/1997
. LER LER 316-97010 Licensee Maintenance 3A 2A Use of Teflon Packing on Containment AirlockDoor Interlock Shaft Results in Potentially Degraded Condition 67 11/26/1997 Strength 68 11/26/1997 Positive IR 97022 IR97022 NRC Plant 1B Support NRC Plant 1B Support The seal forthe inner bulkhead interlock shaft was found to consist of, Teflon packing rings rather than the specified EPDM elastomer.
The emergency preparedness program was in a commendable state operational readiness and emergency response facilities were welt-maintained, as evidenced by their material condition. A new Emergency Operations Facility, located in a portion of the Buchanan Office Building should be a program enhancement when completed.
Plant personnel performed effectively during two actual activations of the Emergency Plan. Quality assurance oversight of the program was very competent.
Licensee personnel performed appropriately during two actual activations (Unusual Events) of the Emergency Plan. A procedure had been developed for review of actual events.
Review ofthe events was very good. (Section P1.1) 69 11/26/1997 LER LER 316-97009 Licensee Maintenance 2A Blockage of Containment AirRecirculation Inlet Line Results in Condition Outside Design Bases 70 11/26/1997 Positive 71 11/26/1997 Positive IR 97022 IR 97022 NRC Plant 2A Support NRC Plant 3A 1C Support Page 10 of 18 One of two Train B inlet lines forthe hydrogen removal and air recirculation from the Unit 2 number 2 and 3 Steam Generator enclosures was found to have been blocked by concrete. The blocka occurred during the Unit 2 Steam Generator replacement in 1988.
Each emergency response facilitywas well maintained and in an excellent operational state of readiness.
The proposed EOF had adequate space, lighting, telephone and electrical outlets. The proposed layout of the facilitywas acceptable.
An appropriate plan forturnover from the old facilityto the new.
(Section P2.1)
Procedure reviews indicated that EP procedures provided detailed guidance on responding to declared emergencies.
No procedural problems were identified. Condition Report documentation indicated that plant staff made good use of an Operating Experience report to identify a problem, and had taken aggressive actions to correct the lack of current respirator qualifications for members ofthe Emergency Response Organization (ERO). (Section P3)
PLANTISSUES MATRIX DC Cook 5/22/98 Search Sorted by Date (Descending) and SMM Codes (Ascending):
Search Column = "Date";
Beginning Date =
10/10/g7";
Ending Date = "3/31/M' DATE TYPE SOURCE ID BY SALP MM CODE DESCRIPT(ON 72 11/26/1997 Strength 73 11/26/1997 Positive 74 11/21/1997 Positive 76 11/21/1997 Positive 75 11/21/1997 Weakness IR 97022 IR 97022 IR 97023 IR 97023 IR 97023 NRC Plant Support 3B NRC Operations 1C 5A NRC Operations 5A NRC Operations 5A 3A NRC Plant 3C 1C Support The EP training program was very effective. Drillswere used as an efficient and performance-based requalificatlon method. Training records were complete, indicated that ERO members were trained within the required frequency.
The quality of drill critiques improved during.
1997. The ERO's staffing levels were excellent for all key and support positions. (Section P5)
The overall effectiveness of the licensee's emergency preparedness facilities, equipment, training, and organization was effective. (Sections P2.1, P3, PS, and P6)
The inspectors determined that the reviewed procedures adequately addressed the licensee's goals and expectations for effectively implementing the corrective action process and the audit and self-assessment programs.
The ability of the licensee to track and trend conditions Identified in conditions reports was marginal. The initial input of text data had problems due to the limited data field and the reliance of clerical staff.to summarize the technical data into the small field. The causal codes failed to provide a meaningful sort capability which left the staff with a need to manually sort through numerous pages of data printouts and,.
conditions reports.
Finally the root cause investigations were not part of the KTP and had no automated method of tracking and trending the findings.
The corrective action program was in transition and progress has been made in improving the quality of CR content.
The licensee identified the.
problem with the training department not writing CRs, and not conforming to the new program and management expectations.
The staff was identifying good items as they performed their normal work.
77 11/21/1997 Weakness IR 97023 Licensee Engineering 5A 3B During the latter part of this inspection period, the inspectors became aware that in two recent self-initiated audits, you identified a number of issues involving'inadequate training and qualifications of engineering personnel.
Page 11 of 18
PLANT ISSUES MATRIX DC Cook 5/22/98 Search Sorted by Date (Descending) and SMM Codes (Ascending):
Search Column =
Date";
Beginning Date ~ "10/10/97";
Ending Date = "3/31/98"
¹ DATE TYPE SOURCE ID BY SALP MM CODE DESCRIPTION 78 11/21/1997 Negative IR 97023 NRC Operations 5C 5A The audit/surveillance program covered the required areas and was identifying problems and concerns.
Audit findings were documented in condition reports, which were used fortracking and to obtain corrective actions. The inspectors concluded that the licensee's suiveillances and audits were effectively being conducted to identify problems and concerns.
However, as noted in previous licensee findings and independently confirmed by the NRC, the followup (resolution) ofthe~
identified problems and concerns was not being resolved in a timely fashion.
79 11/21/1997 Negative IR 97023 80 11/16/1997 VIO/SL-IV IR 97024 VIO NRC Operations 5C 5A NRC Operations 2A 4B The licensee was effective in identifying problems through audits and through the staff observing problems during their daily activities.
However, the ability of the licensee to followthrough to completion on corrective or preventative action was questionable.
The inspectors identified a violation in which the licensee had been removing control room annunciators from service without maintaining records which contained a written safety evaluation as required by 10 ~
CFR 50.59 (Section 03.1).
81 11/7/1997 Negative 82 11/7/1 997 NCV 83 11/7/1997 URI IR 97018 NRC Plant 2A Support IR 97018 NCV NRC Maintenance 2A IR 97018 URI Self-Maintenance 2A 4B Revealed The inspectors identified lights under a temporary trailer that were inoperable.
The specific root cause was not identified (Section S2).
The inspectors identified unsecured foreign material near the recirculation sump in the Unit 2 lower containment.
The sump was n~
required by Technical Specifications to be operable, and the amount~
material would not have significantly degraded the performance of the
. sump. This was a violation of minor significance (Section M4.1).
Following a failure of the 2 AB D/G flywheel end exhaust manifold bracket, the licensee discovered that required Jam nuts on the bracket bolts were missing from two emergency diesel generators, 1CD D/G and 2 AB D/G. The licensee speculated that the missing jam nuts may have allowed the bracket bolt to come loose, resulting in a fatigue failure of the bracket; however, the minor modification package paperwork indicated that the jam nuts had been installed. An unresolved item was opened pending a review of the licensee's investigation into the root cause of the bracket failure (Section M2.2).
Page 12 of 18
PLANT1SSUES MATRIX DC Cook 5/22/98 SearchSortedbyDate(Descending)andSMMCodes(Ascending):
SearchColumn "-"Date";
Beginning Date ~ "10/10/97";
Ending Date = "3/31/98"
¹ DATE TYPE SOURCE ID BY SALP MM CODE DESCRIPTION IR 97018 84 11/7/1997 Positive NRC Maintenance 2B The control air system safety valves appeared to be properly installed and dedicated as safety grade components.
The inspectors questioned the use of work procedures annotated for non-safety-related work to install safety-related valves; however, no violations of NRC requirements were identified (Section M3.1).
85 11/7/1997 NCV IR 97018 NCV Licensee Operations 3A The licensee Identified that during a 4 day period six human performance errors by licensed and non-licensed operators occurred.
None ofthe errors resulted In personnel injuries, equipment damage or an engineered safety features actuation. A non-cited violation for a failure to followprocedures was issued (Section 01.2).
86 11/7/1997 LER LER 97028 NRC Plant 4A Support 10 CFR 50, Appendix R, Section III G.2.(b) requires a twenty foot separation between trains with no intervening combustible materials with fire detection and suppression installed. At Cook Nuclear Plant, fire stops were being used to prevent the possible spread of fire across the twenty foot separation space at two locations in the AuxiliaryBuilding (el.
587'nd 609') where there are intervening combustibles (open cable trays) inside the twenty foot separation space.
However, an exemption to 10 CFR 50, Appendix R, Section G.2.(b) had not been requested.
, 87 11/7/1 997 VIO/SL-IV IR 97018 VIO NRC Operations 4B 88 11/7/1997 VIO/SL-IV IR 97018 VIO NRC Operations 4B The inspectors concluded that the licensee's initial plans and procedures
'o cross-tie safety-related electrical buses lacked adequate analysis and controls to support plant operation in the proposed configuration. Two examples of a violation for procedural inadequacy were identified. T~
inspectors were concerned that the licensee did not conduct an adeq~
evaluation of cross-tying 250 Vdc buses until questioned by the inspectors (Section 03.1).
The inspectors identified a discrepancy between the pressurizer pressure low safety injection set point as referenced in emergency operating procedure E-0 and as listed on a control board operator aid. While evaluating the inspectors'uestions concerning this discrepancy, the licensee identified discrepancies between the plant set-point document and reactor trip set points as listed E-0. The inaccurate procedure was a third example of a violation of NRC requirements (Section 03.2).
Page 13 of 18
PLANT ISSUES MATRIX DC Cook 5/22/98 SearchSortedbyDate(Descending)andSMMCodes(Ascending):
Searchcolumn
= "Date";
Beginning Date =
10/10/97";
Ending Date =
3/31/g8" D'ATE TYPE SOURCE ID BY SALP MM CODE DESCRIPTION 89 11/7/1997 Positive 90 10/31/1997 Negative IR 97018 NRC Engineering 4B IR 97020 NRC Plant 3A Support Engineering personnel were involved in several of the issues discussed in this report (refer to Section 03.1, Procedures for Cross-Tying 250 Vdc Buses During Maintenance Activities (Unit 2), and Section 03.2, Emergency Operating Procedures Containing.Incorrect Set points).
Engineering support to the rest of the licensee organization appeared to be good, but the support was supplied in response to NRC questions (Section E1).
As-low-as-is-reasonably-achievable (ALARA)controls were effective in maintaining the station dose totals below the goal. However, the inspector was concerned by the lack of conservative decision making that allowed work under a radiation work permit to continue until the dose estimate had been exceeded by 33 percent (Section R1.1).
91 10/31/1997 Positive IR 97020 NRC Plant 3A Support The reactor head set was well controlled. The inspector observed good communications between the radiation protection technicians (RPTs) and other workers regarding ALARAconcerns at the pre-job briefing.
Although communications between the two RPTs went well, there was some difficultyin communications between the other workers during the work evolution (Section R1.2).
92 10/28/1997 LER LER 315-97027 Other Engineering 4A Westinghouse Integral Fuel Burnable Absorber (IFBA) Fuel Rods 93 10/24/1997 LER LER 97008 Self-Operations 2A 1B Revealed The licensee was informed by Westinghouse that in the process of developing new fuel rod cladding corrosion and rod internal pressure ~
models it was determined that these new models showed a decrease rod internal pressure margin. This decrease in margin has the potential to place plants in a condition that is outside of their design basis with respect to pellet-to-clad gap re-opening.
On October 24, 1997 at 0008 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> with Unit 2 in Mode 6, Refueling, an unplanned ESF actuation occurred. A high radiation alarm and high fail signal were generated by the Train A Upper Containment Area Radiation Monitordue to equipment failure. The high radiation alarm resulted in a Containment Ventialtion Isolation. The associated isolation valves closed as designed.
Page 14 of 18
PLANTISSUES MATRIX OC Gook 5/22/98 Search Sorted by Date (Descending) and SMM Codes (Ascending):
Search Column = Date";
Beginning Date =
10/10$7";
Ending Date = "3I31$F DATE TYPE SOURCE ID BY.
SALP MM CODE DESCRIPTION 94 10/17/1997 Weakness 95 10/17/1997 VIO/SL-IV 96 10/17/1997 Negative IR 97019 IR 97019 IR 97019 NRC Plant Support NRC Plant Support NRC Plant Support 38 1C 3C 3C 1C Staff reductions significantly affected the capability of conducting non-Appendix 8 training. The licensee eliminated table top tactical response drills, the combat weapons course, and shift deployment exercises. The elimination of much of the non-appendix 8 progam was considered a weakness in the contingency response program.
(Section S5.1)
Actual site security response drills conducted during February and Ju~
1997 demonstrated response team members were located distant fro~'
some plant vital areas making it unlikely responders could interdict adversaries before reaching target sets.
This is a violation of 10 CFRiu 73.55(a) and 10 CFR 73.55(h)(4) Qi(A). (Section S4.1)
The number of required armed responders specified in the approved security plan was not met on eighteen occasions between October 26, 1996 and May 31
~ 1997 when the weapons of one to two guards per shift were removed and their radio frequencies switched to the fire protection radio channel, in order forthese individuals to participate as members of the site fire brigade during the routine monthly fire brigade drills (Section S4.2).
97 10/15/1997 Negative 98 10/15/1997 Negative 99 10/15/1997 Positive 100 10/15/1997 Positive IR 97015 IR 97015 IR 97015 IR 97015 NRC Operations 1C NRC Maintenance 28 NRC Maintenance 28 1C NRC Operations 28 48 The inspectors observed that the licensee was not evaluating cascading Technical Specifications consistently in order to determine the operability of supported equipment.
The Inspectors'eview did not identify any violations ofTechnical Specifications (Section 02.1).
The inspectors reviewed the reference and acceptance parameter ranges for inservice testing of American Society of Mechanical Engineers (ASME) Code Class 1, 2, and 3 pumps.
Not all reference ranges were within a 2 percent of the reference parameter as required (Section M1.4).
The licensee initiated an extensive upgrade program in response to previous NRC concerns with new fuel receipt. The inspectors observed portions of the licensee's handling of new fuel in preparation for the Unit 2 refueling outage and Identified no new concerns (Section M4.1).
During a followup review of an automatic start signal to the turbine driven auxiliary feedwater pump, the inspectors determined that a modification was already in progress to prevent inadvertent start signals in the future (Section 02.2).
Page15of 18
PLANT ISSUES MATRIX DC Cook 5/22/98 Search Sorted by Date (Descending) and SMM Codes (Ascending):
Search Cotumn = Date";
Beginning Date = "10/10/97";
Ending Date = "3/31/98 D'ATE TYPE SOURCE ID BY SALP MM CODE DESCRIPTION 101 10/15/1997 Positive IR 97015 NRC Plant Support 3A The inspectors observed appropriate and safe laboratory techniques during a receipt. analysis of emergency diesel generator fuel oil (Section R4.1).
102 10/15/1997 Positive IR 97015 NRC Maintenance 3A Maintenance worker and licensed operator performance during the replacement of cell ¹34 to the safety related Unit 2 CD battery was-good. Excellent communications and coordination were observed by inspectors (Section M1.3).
103 10/15/1997 URI IR 97015 URI NRC Plant
.Support 5A During a review of an Operating Experience report, the licensee identified that the program for maintaining operator respirator qualifications did not include a provision for ensuring that the operators maintained corrective lenses available when necessary.
The program also failed to include provisions fortracking respirator qualification for members of the emergency response organization who were required to be respirator qualified (Section P5.1).
104 10/15/1997 Positive IR 97015 NRC Maintenance 5B 3A The licensee's troubleshooting efforts following a failure of the 2 AB emergency diesel generator voltage regulator were aggressive and thorough (Section M1.2).
105 10/14/1997 Negative IR 97018 IFI NRC Maintenance 2A The 2 AB D/G experienced a number of electrical and mechanical failures since May 1997. Two valid run failures resulted in the 2 AB D/G being placed on an accelerated testing frequency.
The inspectors were concerned that these failures were indicative of poor material conditio~
An inspection followup item was opened to track resolution of the material condition of the 2 AB D/G (Section M2.1).
106 10/14/1997 LER IR 97020, LER Licensee Plant 3B 97007 Support Page 16 of 18 Radiation protection (RP) personnel identified that a contractor had arrived at the facilitywith several hot particles located in his shoe.
The RP department was evaluating where and when the contractor had become contaminated with these particles. A preliminary estimate determined that the dose was approximately 82.7 rads to the skin, which would be an exposure in excess of the 10 CFR 20.1201 limits. The RP staff was able to demonstrate that the contamination did not originate at the station based on the results ofthe entrance whole body count, so the inspector determined that no violation of NRC requirements had occurred at D. C. Cook. This estimate was a preliminary number and further investigation by RP personnel, as well as the final dose assigned to the contractor, will be reviewed in future inspections (Section R1.3).
PLANT 1SSUES MATR1X DC Cook 5/22/98
. SearchsortedbyDate(Descending)andSMMCodes(Ascending):
SearchColurnn
= "Date";
Beginning Date =
1O/10I97";
Ending Date = "3/31Ig8"
¹ DATE TYPE SOURCE ID BY SALP MM CODE DESCRIPTION 107 10/)4/1997 Positive 108 10/14/1997 Positive IR 97016 IR 97016 NRC Maintenance 5C NRC Maintenance 5C Two findings remained open.
The first involved the required refueling cycle evaluation which was scheduled for completion on January 31, 1998. The second item was related to the acceptability of reliability performance criteria.
Five findings involving availability performance criteria, quarterly assessments, masking of components, structure monitoring, and aud'orrective actions were closed.
109 10/10/1997 LER LER 316-97006 Ucensee Maintenance 2A Equipment in Containment Rendered Inoperable Due to Faulted Floodup Tubes An inspection of unit 2 floodup tubes conducted during its current refueling outage identified three tubes containing cables connected to safety related components with through wall holes caused by welding activities.
Page 17 of 18
GENERAL DESCRIPTION OF PIM TABLELABELS 5/22/98 DATE TYPE A counter number used for NRC internal editing.
The date of the event or significant issue.
For those items that have a clear date of occurrence use the actual date. Ifthe actual date is not known, use the date the issue was identified. For issues that do not have an actual date or a date of identification, use the LER or ins ection reoort date..
FIIe categorization of the issue - see the TYPE ITEM CODE table.
SOURCE The document that contains the issue information: IR for NRC Inspection Report or LER for Ucensee Event Report ID BY Identification ofwho discovered the issue - see table.
SALP SMM CODES SALP Functional Area Codes - Engineering, Maintenance, Operations, Plant Support and AII/Multiple(i.e., more than one SALP area affected).
Senior Manager Meeting Codes - see table.
DESCRIPTION Details ofthe issue from the LER text or from the IR Executive Summaries.
DEV ED EEI" LER Licensln Misc NCV N
ative Positive Stren th URI~
VIO/SL-I VIO/SL-II VIO/SL-III VIO/SL-IV Weakness TYPE ITEM CODE Deviation from NRC Re uirements Escalated Discretion - No Civil Pena Escalated Enforcement Issue - Waitin Final NRC Action License Event Re oit to the NRC Licensin Issue from NRR Miscellaneous Emer enc Pre aredness Findin, etc.
Non-Cited Violation Individual Poor Ucensee Performance Individual Good Licensee Performance Overall Stron Ucensee Performance Unresolved Ins ection Item Notice of Violation-Severi Level I Notice of Violation-Seve Level II Notice of Violation - Seve Level III Notice of Violation - Seve Level IV Overall Weak Ucensee Performance Licensee he licensed util'D BY NRC e Nuclear R ulato Commission Self-Revealed Identification b an event e.g.,
ui ment breakdown Identification unknown Other NOTES EEls are apparent violations of NRC requirements that are being considered for escalated enforcement action in accordance
~
with the "General Statement of Policy and Procedure for NRC Enforcement Action" (Enforcement Policy), NUREG-1600.
However, the NRC has not reached its final enforcement decision on the issues Identified by the EEls and the PIM entries may be modified when the final decisions are made.
Before the NRC makes its enforcement decision, the licensee willbe provided with an opportunity to either (1) respond to the apparent violation or (2) request a predecisionai enforcement conference.
URls are unresolved items about which more information is required to determine whether the issue in question is an acceptable item, a deviation, a nonconformance, or a violation. However, the NRC has not reached its final conclusions on the issues, and the PIM entries may be modified when the final conclusions are made.
SENIOR MANAGEMENTMEETING CODES Operational Performance:
A-Normal B - During Transients C - Programs and Processes Material Condition:
A-Equipment Condition B - Programs and Processes Human Performance.
A-Work Performance B - Knowledge, Skills, and Abilities C - Work Environment Engineering/Design:
A-Design B - Engineering Support C - Programs and Processes Problem Identification and Resolution:
A-Identification B - Analysis C - Resolution Page 18 of 18
DONALDC. COOK INSPECTION/ACTIVITYPLAN ENCLOSURE 2 IP - Inspection Procedure Tl - Temporary Instruction Core Inspection - Minimum NRC Inspection Program (mandatory all plants)
INSPECTION/
ACTIVITY IP 82701 IP 81700 IPs 40500 and 37550 TITLE/
PROGRAM AREA EP Ins ection Securit Ins ection Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems/Onsite En ineerin NUMBEROF NRC INSPECTORS/
INDIVIDUALS TBD
~
PLANNED DATES October 1998 BD 5/5-5/8/98 TBD TYPE OF INSPECTION/ACTIVITY-COMMENTS Core Core Core and Regional Initiative IP 84750 Radiation Protection TI 2515/107 MOVinspection IP 83750/84750 Radiation Protection 7/20-24/98 11/30-12/3/98 09/28-10/12/98 Core Core Regional Initiative