ML17334B724
| ML17334B724 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 04/10/1998 |
| From: | James Gavula NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17334B723 | List: |
| References | |
| 50-315-98-05, 50-315-98-5, 50-316-98-05, 50-316-98-5, NUDOCS 9804170065 | |
| Download: ML17334B724 (72) | |
See also: IR 05000315/1998005
Text
U.S. NUCLEAR REGULATORYCOMMISSION
REGION III
Docket Nos:
License Nos:
50-315; 50-316
Report Nos:
50-315/98005(DRS); 50-316/98005(DRS)
Licensee:
Indiana Michigan Power Company
Facility:
Donald C. Cook Nuclear Generating Plant
Location:
1 Cook Place
Bridgman, Ml 49106
Dates:
January 21 through February 27 and March 19, 1998.
Inspectors:
B. Bartlett, Senior Resident Inspector, D. C. Cook
D. Jones, Reactor Engineer
M. Hoimberg, Reactor Engineer
Approved by:
J. A. Gavula, Chief
Engineering Specialists Branch
1
Division of Reactor Safety
9804i70065 9804i0
ADQCK 050003i5
6
i
EXECUTIVE SUMMARY
D. C. Cook, Units 1 and 2
NRC Inspection Reports 50-315/98005; 50-316/98005
This nonroutine inspection focused on the conduct of past surveillance testing, corrective
actions and maintenance of the design basis for the ice condenser
in each Unit. The following
specific observations were made:
MairaMe~nn p
~
Eight apparent violations of 10 CFR 50 Appendix B (three Criterion V, four Criterion XI,
and one Criterion Vll)and two violations of technical specifications (TS) were identified
pertaining to inadequate surveillance testing of the 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 B, Criterion V were
identified for the licensee's failure to followthe procedure 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 for the ice condenser.
(Section M1.1)
~
Three apparent violations of 10 CFR 50 Appendix B, Criterion XVIwere identified for the
licensee's failure to identify conditions adverse to quality. Conditions not previously
identified by the licensee in the ice condenser included:
blocked flow passages,
missing
ice segments,
dented/buckled basket webbing, unweighable ice baskets, and
nonencapsulated
insulation.
(Section M2.1)
~
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)
~nein
e~rin
~
Four apparent violations of 10 CFR 50 Appendix B, Criterion XVIwere identified for the
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 for the ice baskets
with defective hold down bar welds.
(Section E2.1)
~
Collectively, the apparent violations identified in Sections M2.1 and E2.1 represent a
breakdown in the licensee's corrective action program for the ice condenser.
(Section E2.1)
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)
Four apparent violations of 10 CFR 50 Appendix B, Criterion III were identified
pertaining to the licensee's failure to follow the established design control process for ice
basket modifications. (Section E7.1)
Collectively, the apparent violations identiTied in Section E7.1 represent a programmatic
breakdown in the maintenance of the design basis for the ice condenser.
(Section E7.1)
TABLE OF CONTENTS
M1
Conduct of Maintenance
M1.,1
Ice Condenser Surveillance Testing
M1.1.b.1
b.1.1
b.1.2
b.1.3
M1.1.b.2
b.2.1
b.2.2
b.2.3
b.2.4
b.2.5
M1.1.b.3
b.3.1
M1.1.b.4
b.4.1
M1.1.c
Ice Condenser Flow Passage
Surveillance Testing
.
Inadequate
Instructions for Visual Examination of Flow Passages
..
No Systematic Method for Selection of Flow Passages ..........
Lack of Margin to Analysis Limitfor a Degraded Ice Condenser
Ice Weight Surveillance Testing
.
Lack of Margin to Analysis Limitfor Maximum Ice Basket Weight ..
Unanalyzed Condition Authorized
Procedure Change Process not Followed
Nonrepresentative
Selection of Ice Baskets ..
Ineffective Control of Contractors
Ice Basket Inspection Surveillance Testing
TS Requirement for Ice Basket Inspection not Met..............
Ice Condenser Door Surveillance Testing
Lack of Margin for Ice Condenser Door Surveillance Acceptance
Criterion
Conclusions on Surveillance Testing ..
6
6
6
6
7
7
8
8
9
9
10
11
12
12
12
12
13
M2.1.b.1
M2.1.b.2
M2.1.b.3
M2.1.b.4
M2.1.b.5
M2.1.b.6
M2.1.c
Blocked Ice Bed Flow Passages
Missing Ice Segments
in Lower Sections of Ice Baskets .........
Dented/Buckled Ice Basket Webbing Condition is Outside Design
Basis
Unidentified Nonencapsulated
Insulation ..
Unweighable Ice Baskets with Tom, Creased,
Dented, or Buckled
Webbing Damage.......
Ice Form Different Than as Described in the FSAR .............
Conclusions on Ice Condenser Materiel Condition ..............
M2
Maintenance and Materiel Condition of Facilities and Equipment
M2.1
Ice Condenser Materiel Condition ..
14
14
14
14
15
16
17
17
18
E2
Engineering Support of Facilities and Equipment
.
E2.1
Corrective Actions for Ice Condenser Component Damage
E2.1.b.1
Failed and Missing Ice Basket Sheet Metal Screws
b.1.1
Corrective Actions Process not Implemented for Ice Basket
Sheet Metal Screws
.
b.1.2
Unanalyzed Condition for Plant Operation with Missing Sheet
Metal Screws
E2.1.b.2
Loose and Missing U-bolt Nuts
E2.1.b.3
Separated
Ice Baskets
E2.1.b.4
Failed Fillet Welds at the Ice Basket Bottom Hold Down Bar
.
E2.1.c
Conclusions on Corrective Actions for Ice
Condenser'omponents
~
~
~
.18
. 18
18
18
19
20
21
21
23
'TABLEOF CONTENTS
(continued)
E7
Quality Assurance in Engineering Activities.
E7.1
Maintenance of the Ice Condenser Design Basis
.
E7.1.b.1
Design Basis for Ice Condenser not Updated
E7.1.b.2
Unauthorized Modification of Ice Basket Assemblies ..........
E7.1.b.3
Surveillance Procedure Used to Modifyand Remove Ice Basket
Cruciform Supports
E7.1.c
Conclusions on the Maintenance of the Ice Condenser Design
Basis
E7.2
Operability in Question for the As-Found Ice Condenser Condition
24
24
24
26
27
27
28
E8
Miscellaneous Engineering issues
X1
Exit Meeting Summary
.
28
29
M1
Conduct of Maintenance
M1.1
Ic
C nd
n
r
rveill nce T stin
a.
Ins ection
co
617
Inspectors reviewed completed surveillance tests, interviewed licensee staff and
contractors that conducted surveillance testing, and reviewed condition reports
pertaining to surveillance testing of the ice condenser.
b.
0
a
'
n
Fin 'n
b.1
Ice
ond
n
r Fl w P
sa
urv illanc T stin
b.1.1
In
uat
t
ion f rVi
IEx min
i n fFI wP
The licensee completed surveillance test procedure 12 EHP 4030 STP.250 "Inspection
of Ice Condenser Flow Passages,"
Revision
1 on January 5, 1998, for Unit 1 and on
November 15, 1997 for Unit 2. During these surveillances, 48 flow passages
in each
Unit were verified to be free of ice buildup greater than 3/8 inch thick.
On January 22, 1998, inspectors identified blocked flow passages
in each Unit (Section
M2.1.b.1), which prompted a licensee inspection of all flow passages
in both Units.
From this inspection, the licensee identified that 8 of the 48 flow passages
inspected
during the January 5, 1998 performance of the 12 EHP 4030 STP.250 for Unit 1, were
partially obstructed with ice greater than 3/8 inch thick. Additionally, 13 of the 48 flow
passages
previously inspected during the November 15, 1997 performance of STP.250
on Unit 2 were subsequently found partially obstructed with ice greater than 3/8 inch
thick. The contractor and an ice condenser system engineer that performed these
inspections, had used a six volt flashlight to verify the flow passages
free of
obstructions.
Step 3.2 of 12 EHP 4030 STP.250 stated that portable lights will be obtained as
necessary to inspect ice condenser passages.
No other explicit instructions were given
for the conduct of this visual examination.
This procedure did not require: the visual
examinations to be conducted from above and below the flow passages,
the installed
lighting in the lower ice condenser to be turned on, the use of special lighting methods
demonstrated
to be adequate
(e.g. narrow tube lighting lowered into the flow passage).
Further, this procedure did not require inspection personnel to pass a visual examination
nor did it invoke a visual examination qualification standard (e.g. American Society of
Mechanical Engineers Code VT-2'qualification).
'
The instructions provided in step 3.2 of 12 EHP 4030 STP.250 were inappropriate for
the circumstances
in that, the ice blockage had not been detected using the existing
instructions.
Failure to ensure appropriate instructions for the circumstances were
included in 12 EHP 4030 STP.250 is an apparent violation of 10 CFR 50 Appendix B,
Criterion V (EEI 50-315/98005-01(DRS);
b.1.2
S
t ma i
Meth
for Selection
f Fl w Pas
es
The inspector noted that the blocked flow passages
recently identified (see section
M2.1.b.1) were predominantly adjacent to radial row 1 and/or row 2 ice baskets in each
bay. The ice condens'er system engineer reported that past flow passage
selection did
not include preferentially selecting these areas for inspection, nor were flow passages
previously inspected in past surveillances excluded.
Step 3.3 of 12 EHP 4030 STP.250 required that the Lead Test Engineer identify the flow
passages
to be inspected.
The Test Engineer's selection process was arbitrary, in that
it did not include preferential selection of bay areas with a history of blockage problems
nor did it exclude flow passages
inspected during prior surveillances.
Thus, inspectors
concluded that the arbitrary selection process used was inadequate to ensure that a
degraded condition would be detected
in the ice condenser prior to reaching an
inoperable condition.
The instructions provided in Step 3.3 of 12 EHP 4030 STP.250 were inappropriate for
the circumstances,
in that the Test Engineer was allowed to use an arbitrary process,
vice a systematic process for selection of ice condenser flow passages
for inspection.
Failure to ensure appropriate instructions for the circumstances were included in 12
EHP 4030 STP.250 is an apparent violation of 10 CFR 50 Appendix B, Criterion V (EEI
50-315/98005-02(DRS);
b.1.3 L c
Ma
i
i
i f
D
A 15 percent blockage limitwas used in the analytical input value for groupings of bays
modeled in the Westinghouse analysis WCAP 11902 "Reduced Temperature and
Pressure Operation for Donald C. Cook Nuclear Plant Unit 1 Licensing Report," dated
October 1988.
Inspectors identified that the ice condenser could be considered
operable using criterion in procedure 12 EHP 4030 STP.250 and returned to service
with blocked flow passages
above the maximum assumed
in this analysis.
Option 2 of Step 7.1.3 and Step 7.2.3 "Operability Determination" of 12 EHP 4030
STP.250, authorized the licensee to consider the ice condenser operable, ifthe as-left
percentage of total upward flow area per bay blocked was less than 15 percent.
The
licensee searched surveillance records back to 1990 and identiTied that Option 2 had
been used for Unit 2 in January of 1994 and again in Aprilof 1996. The licensee stated
that the method used to determine the percentage blockage in each bay during these
past surveillances was based entirely on engineering judgement (e.g., no formal
calculations were performed).
Inspectors concluded that the licensee's reliance on
engineering judgement and lack of a required quantifiable calculation methodology (e.g.,
4
independent calculations comparing areas blocked with available bay flow passage
area) would result in a wide error margin.
The instructions provided in Step 7.1.3 and 7.2.3 of 12 EHP 4030 STP.250 did not
adequately incorporate the assumed analysis limitof 15 percent flow blockage.
Specifically, the 15 percent acceptance
criterion used in Steps 7.1.2 and 7.2.3 did not
account for surveillance measurement
errors. These measurement
errors, when
considered, would result in a flow passage
blockage acceptance
criterion in excess of
that analyzed.
Failure to adequately incorporate the acceptance
limits assumed
in the
accident analysis (WCAP 11902) for the percent of flow passage
blockage into 12 EHP
4030 STP.250 is an apparent violation of 10 CFR 50 Appendix B, Criterion XI (EEI
50-315/98005-03(DRS);= EEI 50-316/98005-03(DRS)).
b.2
rv ill n
T
I3.2.1
L
o
r in
An
I si
imitf r
m
B
e
i
From data provided in the FSAR, Appendix M, Table 4.3-1, the maximum analyzed
combined ice basket with ice weight (gross ice basket weight) assumed
in accident
analysis was 1776 pounds (Ibs). On March 1, 1990, the licensee accepted the
Westinghouse analysis
"Indiana Michigan Power D.C. Cook Nuclear Power Plant Ice
Condenser Seismic Load Study New Ice Basket Design," dated February 28, 1990, that
evaluated an increase in gross ice basket weight of up to 1877 lbs. Inspectors identified
that ice baskets with gross weight in excess of this analysis limitcould be accepted by
the licensee during the performance of 12 EHP 4030 STP.21'1 "Ice Condenser
Surveillance," Revision 2 and returned to service.
Attachment 4 of'12 EHP 4030 STP.211 allowed a maximum acceptable gross ice basket
weight of 1877 lbs. This 1877 Ibs limitdid not incorporate a margin for error associated
with the measurement
uncertainty in performing the basket weighing surveillance.
Further, repetitive weighing and averaging weights for the same ice basket was required
by the procedure to get an accurate ice basket weight, which indicated a substantial
margin of measurement
uncertainty.
Thus, inspectors concluded, that surveillance
measurement
errors, when considered, would result in a maximum gross ice basket
weight acceptance
criterion in excess of that previously analyzed.
The instructions provided in Attachment 4 of 12 EHP 4030 STP.211 did not adequately
incorporate the assumed analysis limitof 1877 Ibs for the gross ice basket weight.
Specifically, the 1877 Ibs gross ice basket weight acceptance
criterion used in
Attachment 4 did not account for surveillance measurement
errors, which when
considered, would result in a gross ice basket weight in excess of that analyzed.
Failure
to adequately incorporate the acceptance
limits assumed
in the accident analysis
(Indiana Michigan Power D.C. Cook Nuclear Power Plant Ice Condenser Seismic Load
Study New Ice Basket Design," dated February 28, 1990) for gross ice basket weight
into 12 EHP 4030 STP.211
is an apparent violation.of 10 CFR 50 Appendix B, Criterion
b.2.2
nanal zed Co
itio
hori
Table 6.0-1 of Appendix M of the FSAR lists a design basis loss of coolant accident
(DBA), uplift force of 2536 Ibs for the ice baskets.
To resist this force, the bottom of
each ice basket is pinned to the support structure using a clevice pin.. During a DBA the
forces generated
on unpinned ice baskets could cause them to be expelled upward out
of the ice bed, which would create an unanalyzed missile hazard.
Step 4.8 of. EHP 4030 STP.211, Revision 2, allowed up to 60 ice baskets to be unpinned
in operating Modes 3 and 4 to support ice basket weighing operations.
The earlier
version of this procedure (e.g., step 4.7 of 12 THP 4030 STP.211 "Ice Condenser
Surveillance," Revision 17) authorized unpinning of up to 60 ice baskets in operating
Modes
1 through 4. These procedure steps lacked instructions to implement the
TS 3.6.5.1 Action statement for an inoperable ice condenser.
Inspectors identified that
the ice condenser should have been considered inoperable during this step, because
unpinning of multiple ice baskets as allowed in EHP 4030 STP.211 represented
an
The instructions provided in Step 4.8 of 12 EHP 4030 STP.211 were inappropriate for
the circumstances,
in that no analysis existed to support operation with 60 unpinned ice
baskets and this step lacked instructions to implement the TS 3.6.5.1 Action statement
for an inoperable ice condenser.
Failure to ensure appropriate instructions (e.g., to
declare the ice condenser inoperable at step 4.8) were included in 12 EHP 4030
STP.211 is an apparent violation of 10 CFR 50 Appendix B, Criterion V (EEI
50-315/98005-05(DRS);
As of February 25, 1998, the licensee had not located an analysis to bound the
unpinning of ice baskets authorized and performed during past surveillance testing.
On
February 25, 1998, the licensee notified the NRC of this potentially unanalyzed condition
pursuant to the reporting requirements of 10 CFR 50.72(b)(2)(i) ~
b.2.3
On December
1, 1997, the licensee completed 12 EHP 4030 STP.211, Revision 2
through steps 7.5 for Unit 2. Inspectors identified hand written changes in the left hand
margin next to steps 7.1 through 7.5 on the completed copy of. this procedure.
These
changes, signed and dated on December
1, 1997, incorporated the newly proposed TS 4.6.5.1 acceptance
criterion for ice weight inventories.
The licensee intended to use this
change to meet the revised TS 4.6.5.1 acceptance
criterion authorized by the NRC on
January 2, 1998.
The licensee had made the change described above to the procedure acceptance
criterion without following the change process described in procedure PMI-2010
"Instructions, Procedures,
and Associated Indexes Policy," Revision 24. Specifically,
Section 4.6 of PMI-2010 required in part, the use of a procedure change sheet and a
review by personnel holding a Senior Reactor Operating License, neither of which
occurred in this case.
Failure to followthe procedure change process as described in PMI-2010 for changes
made on December 1, 1997, to 12 EHP 4030 STP.211, Revision 2 is an example of an
apparent violation of 10 CFR 50 Appendix B, Criterion V (EEI 50-315/98005-6a(DRS)).
On January 6, 1998, the licensee completed 12 EHP 4030 STP.211, Revision 2 through
steps 7.5 for Unit 1. Inspectors identified hand written changes in the left hand margin
next to steps 7.1 through 7.5 on the completed copy of this procedure.
These changes,
signed and dated January 6, 1998, incorporated the recently changed TS 4.6.5.1
acceptance
criterion for ice weight inventories.
The licensee had made the change described above, to the procedure acceptance
criterion, without following the change process described in procedure PMI-2010
"Instructions, Procedures,
and Associated Indexes Policy," Revision 24. Specifically,
Section 4.6 of PMI-2010 required in part, the use of a procedure change sheet and a
review by personnel holding a Senior Reactor Operating License, neither of which
occurred in this case.
Failure to follow the procedure change process as described in PMI-2010 for changes
made on January 6, 1998 to 12 EHP 4030 STP.211, Revision 2 is an example of an
apparent violation of 10 CFR 50 Appendix B, Criterion V (EEI 50-316/98005-6b(DRS)).
b.2.4Nnre
r
nt
iv
S
ct'
Ic
B
k
TS 4.6.5.1.b.2 required in part, that the licensee select a representative
sample of 144
ice baskets for weighing from radial rows 1,2,4,6,8 and 9. A software computer program
ICE-PICK is used by the licensee to randomly select a basket within each of the radial
basket rows (1,2,4,6,8,9) to meet the "representative" ice basket selection required.
However, this program excluded azimuthal rows 1,5 and 9 from the selection process
and did not exclude baskets weighed during previous surveillance tests.
The licensee
reported that an average of at least 23 baskets were repetitively selected for the 1996
and 1997 surveillances used to calculate ice inventory for each Unit.
Historical data provided by the licensee, indicated that 223 Unit 1 and 171 Unit 2 ice
baskets had never been weighed since original plant construction and start of
commercial operation.. These ice baskets were predominantly the azimuthal row 5 ice
baskets.
The licensee had excluded ice baskets in azimuthal rows 1,5 and 9 in their
normal selection process, because of interference with intermediate deck door support
structures, which are not normally removed due to the extensive restoration required.
In
August of 1997, the licensee selected and weighed a test sample of 54 Unit 2 ice
baskets in azimuthal row 5 and identified "light"ice baskets (e.g., ice baskets containing
less than 1333 Ibs of ice). Of these baskets, 40 contained less than the current TS
surveillance minimum 1333 Ibs of ice and 13 of these baskets contained less than the
preceding TS minimum of 1220 Ibs of ice. The lightest azimuthal row 5 basket
contained only 800 Ibs of ice. Thus, the licensee's sampling process which excluded
azimuthal row 5 ice baskets did not represent this population of "light"ice baskets.
10
1
Inspectors identified that percentages
of ice baskets in radial rows
1 and 9 had not been
weighed as frequently as baskets in other radial rows.
From data taken since 1994 on
Unit 1, an average of 48 percent of radial row 1 baskets and 51 percent of radial row 9
baskets had not been weighed.
These percentages
of unweighed baskets were
significantly higher in row 1 and 9 than for any other radial row. Further, the ice baskets
which had not been weighed recently in radial row 1 and 9 may correlate with ice
baskets which had larger segments of missing ice in the lower part of the ice basket
(Section M2.1.b.2). Thus, repetitive weighing of the same ice baskets in radial row 1
and 9 from one surveillance to the next, created a nonrepresentative
sample, in that the
potentially "light"nonweighed baskets with missing ice were not represented.
Based on the information discussed above, inspectors concluded that the licensee had
been selecting a nonrepresentative
sample of ice baskets when performing ice weight
surveillances.
The selected ice baskets constituted a nonrepresentative
sample, in that
azimuthal row 5 ice baskets were exclude, which were "lighter" than other azimuthal
rows. Further, the selection was nonrepresentative
in that the same ice baskets were
repetitively weighed (particularly in radial rows
1 and 9) between sequential
surveillances due to the failure to track and exclude previously weighed ice baskets.
Failure to select a representative
sample of ice baskets to weigh is an apparent violation
of TS 4.6.5.1.b.2 (EEI 50-315/98005-07(DRS);
The licensee had completed 12 EHP 4030 STP.211 on December 1, 1997 for Unit 2 and
on January 6, 1998 for Unit 1. The licensee used these procedures to establish that ice
inventory requirements for average bay group ice weight of 1333 Ibs and total ice
inventory met TS 4.6.5.1.b.2.
However, these calculations of ice inventory did not
include an adjustment for the recent data collected on "light"azimuthal row 5 baskets.
On February 11, 1998, the licensee notified the NRC (pursuant to requirements of 10 CFR 50.72(b)(2)(i)) that the ice weights used to determine TS compliance that may not
constitute a representative
sample and potentially represented
The licensee also documented the concern as to whether the ice weights used to
demonstrate TS compliance constituted a representative
sample in CR 98-500.
b.2.5 Ineffectiv
r
f
tr
t
Damage to numerous Unit 1 and Unit 2 ice baskets had been documented
in
condition/problem reports CR 98-388, CR 97-3244, PR 88-914, CR 12-05-85-1036, CR
1-08-83-771 and CR 1-07-83-647.
This ice basket damage, typically tom ice basket
webbing, creased
ice baskets and bent upper ice basket rims, potentially rendered the
affected ice baskets unweighable or incapable of sustaining the original ice basket
. design loadings.
The licensee attributed this damage to activities performed by
contractors during the ice basket weighing surveillance test.
Historically, the licensee had used contractor services to perform the ice basket
weighing for surveillance procedure 12 EHP 4030 STP.211 (formerly 12 THP 4030
STP.211).
10 CFR 50 Appendix B, Criterion Vllrequires in part, that the licensee
assess
the quality by contractor services at intervals commensurate
with the nature of
11
the work. In this case, the licensee controls were ineffective to assess
and control the
quality of work performed by contractors performing the ice basket weighing surveillance
testing.
As a consequence
of this failure, a,large number of ice baskets had sustained
damage over many years, some of which put ice baskets outside the original design
basis.
Failure to adequately assess
the control of quality for contractor services for ice
condenser surveillance testing is an apparent violation of 10 CFR 50 Appendix B,
Criterion Vll (EEI 50-315/98005-08(DRS);
b.3
B
k tin etin
rvilln
T
in
b.3.1 TS Re uire
ent
Ice Baske
s ection not M t
TS surveillance requirement 4.6.5.1.d required in part, that the licensee visually inspect
accessible portions of at least two ice baskets from each 1/3 of the ice condenser and
verify that the ice baskets are free of detrimental wear, cracks, corrosion or other
damage.
A visual inspection of the accessible portions of the lower basket assembly
was not required by 12 EHP 4030 STP.212 "Ice Condenser Basket Inspection,"
Revision 0.
On March 21, 1997, the licensee completed 12 EHP 4030 STP.212 "Ice Condenser
Basket Inspection," Revision 0 for Unit 1. This inspection included a visual examination
to identify damage on six ice baskets in accordance with TS 4.6.5.1.d requirements.
During this inspection, ice basket 6-3-4 was visually examined, found free of damage
and returned to service.
However, on February 14, 1998, the licensee identified that
Unit 1 ice basket 6-3-4 had a 3 inch by 8 inch dent in the webbing
1 foot above the
bottom of this basket and a missing sheet metal screw in the bottom basket rim.
b.4
The damage identified on February 14, 1998, for ice basket 6-3-4 had not been
identified during the prior surveillance test, because
12 EHP 4030 STP.212 did not
include an inspection requirement for the lower ice basket area.
Further, based on a
scoping test completed by the licensee on a dented/buckled basket on February 12,
1998 (Section M2.1.b.3), the dented webbing could potentially decrease
the
compressive strength of this basket below the original design strength of a new basket.
Thus, the licensee failed to identify potentially detrimental damage in ice basket 6-3-4
during the March 21, 1997 inspection as required by TS 4.6.5.1.d.
Failure to include
requirements in 12 EHP 4030 STP.212 to perform inspection of accessible areas of the
lower ice basket is an apparent violation of TS 4.6.5.1.d (EEI 50-315/98005-09(DRS);
Ice Con en e
Do
Surv 'lian
T
b.4.1
rD
ill
A
t n
C'he
door operability acceptance
criteria were at the maximum values allowed by TS 4.6.5.3 in procedures
12 EHP 4030 STP.207 "Ice Condenser Lower Inlet Doors,"
Revision 0 and 12 EHP 4030 STP.245 "Inspection of Ice Condenser Intermediate Deck
Doors," Revision 0. A margin for error associated
with the measurement
uncertainty in
12
]
'l
~l
performing the door surveillance testing had not been incorporated into the acceptance
criteria used in these procedures.
Surveillance procedure 12 EHP 4030 STP.207 specified a lower ice condenser door
maximum opening torque of 675 inch-pounds and 195 inch-pounds (at 40 degrees
open).
These values did not account for surveillance measurement
errors, which when
considered would result in acceptance
criteria in excess of the limits specified in TS 4.6.5.3.1.b item
1 and 2. Failure to adequately incorporate the acceptance
limits
specified by TS 4.6.5.3.1.b item
1 'and 2 into 12 EHP '4030 STP.207 is an apparent
violation of 10 CFR 50 Appendix B, Criterion XI (EEI 50-315/98005-10(DRS);
50-316/98005-10 (DRS)).
Surveillance procedure 12 EHP 4030 STP.245 specified ice condenser intermediate
deck door maximum opening resistance forces of 37.4 Ibs, 33.8 Ibs, 31.8 Ibs and 31.0
lbs. These values did not account for surveillance measurement
errors, which when
considered would result in an acceptance
criterion in excess of the limits specified in
TS 4.6.5.3.2.b.
Failure to adequately incorporate the acceptance
limits specifie by TS 4.6.5.3.2.b into 12 EHP 4030 STP.245 is an apparent violation of 10 CFR 50 Appendix
B, Criterion XI (EEI 50-315/98005-11(DRS);
EEI 50-316/98005-11
(DRS)).
b.4.2 NRC inspection report 50-369/97-16; 50-370/97-16 documented that 10 of 48 lower ice
condenser inlet doors had failed to meet TS surveillance requirements for opening
torque and were therefore rendered inoperable at the McGuire facility Unit 2. This
problem was caused by the door flashing dragging against the floor. The floor had been
raise 0.75 inches above the original grade level, due to freeze thaw cycles which
introduced water into the concrete flooring.
For D.C. Cook, the licensee staff stated that the ice beds had never been "melted out"
and thus water had not been introduced into the lower wear slab.
No condition reports
had been issued that documented
a lower inlet door surveillance failure attributed to this
condition nor were any visual indications present to indicate ice condenser floor
movement.
Thus, inspectors concluded that this problem had not occurred at D.C.
Cook.
I 'son Surv ill n e
estin
Inspectors identified eight apparent violations of 10 CFR 50 Appendix B (three Criterion
V, four Criterion XI, and one Criterion Vll)and two apparent violations of TS. 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.
Further, two examples
of an apparent violation of 10 CFR 50 Appendix B, Criterion V were identified for the
licensee's failure to followthe procedure change process for changes made to
completed surveillance tests.
Collectively, these apparent violations represent a
breakdown in the surveillance testing program for the ice condenser and contributed to
a questionable state of operability for the as-found condition of the ice condenser.
13
M2
Maintenance and Material Condition of Facilities and Equipment
M2.1<
Ice
nd ns r Mat ri
I Condition
a.
In
cti
S
27
Inspectors performed walkdowns of the ice condenser for each Unitto evaluate the
materiel condition.
rvations
nd Fin in
b.1
BI
d I
Bed Fl
P
Areas between ice baskets (flow passages)
allow steam released
in a loss of coolant
accident to travel through the ice bed and condense which reduces the post accident
containment pressure.
On January 22, 1998, inspectors identified multiple flow
passages
obstructed by ice in Unit 2. As a corrective action for this finding, the licensee
initiated an inspection of flow passages
in every bay of both Units to identify blockage.
On January 27, 1998, the licensee identified blocked flow passages
in every bay for
both Units and estimated that 10 to 20 percent of the ice condenser flow passage
area
was blocked by ice. The plant design basis analysis (Westinghouse WCAP-11902
"Reduced Temperature and Pressure Operation for Donald C. Cook Nuclear Plant Unit
1 Licensing Report" dated October 1988 ) had assumed
15 percent of the flow passage
area blocked in groups of ice bays.
The licensee declared the ice condensers
inoperable on January 28, 1998 and documented the condition in CR 98-0326.
Both
Units were in cold shut down at the time and the ice condenser operability was not
required until hot plant operation (e.g., Modes 1-4). These blocked passages
likely
existed during past plant operation and had not been identified due to inadequate
surveillance testing (Section M1.1.b.1.1).
On January 28, 1998, the licensee notified the NRC (pursuant to requirements of
10 CFR 50.72(b)(2)(i)) of the blocked ice condenser flow passages,
that potentially
represented
an unanalyzed condition. Because of this condition and other unanalyzed
conditions identified herein, the licensee staff reportedly intended to complete a detailed
analysis to demonstrate that the ice condenser was capable of performing its design
function during previous operating periods (Section E7.2).
b2
i
m nt
in Lower Se
ti ns
Ic
B
The TS 4.6.5.1 basis for operability of the ice condenser assumed that ice is evenly
distributed through the containment bays.
Inspectors performed a sample inspection of
portions of several bays in the Unit 1 and 2 lower ice condenser and identified ice
baskets with missing ice segments
(6 to 18 feet in height). The predominant number of
ice baskets with larger missing ice segments appeared
to exist for ice baskets in radial
rows 8 and 9. Inspectors reviewed the dates when the licensee had last weighed four
Unit 2 ice baskets (in radial rows 8 and 9) with 12 feet or more of missing ice. Of these
14
four Unit 2 ice baskets, two had not been weighed in over 10 years and two had no
recorded weight since the beginning of plant operation.
Ice baskets are not refilled
unless they are weighed and found to be "light." Thus, ice baskets not recently weighed
with observed missing ice segments were potentially "lighter" than the average basket
weights specified by the TS. Further, light ice baskets potentially affected the
assumption that the ice was evenly distributed through ice condenser bays and
impacted the methodology used to select a representative
sample of ice baskets for
weighing (Section M1.1.b.2.4).
As a corrective action for the missing ice segments,
the licensee performed a visual
inspection of the lower segments of all accessible ice baskets and identified missing ice
segments
in every bay. On February 11, 1998, the licensee documented
in CR 98-500
that radial row 8, 9 and azimuthal row 5 ice baskets showed visual evidence of ice loss
due to sublimation. The sublimation of ice in the ice condenser has been demonstrated
to be less than five percent per year. Thus, the ice baskets with significant missing.ice
segments
(as discussed above) had developed over many years without identification or
evaluation by system engineers or other members of the licensee staff during ice
condenser walkdowns. The ice condenser performs a passive safety function and
licensee staff reported that the ice condenser historically had not been considered a
"system."
The licensee is required by 10 CFR 50 Appendix B, Criterion XVI, to establish measures
to ensure that conditions adverse to quality are promptly identified and corrected.
In this
case the licensee had failed to promptly identify, evaluate or implement corrective
actions for the missing ice segments, which is an apparent violation of 10 CFR 50
Appendix B, Criterion XVI (EEI 50-315/98005-12(DRS);
b.3
D nte
Buckl d lce B
ket W bb'
ii ni
t id
the D
i n B sis
An ice basket profile roundness tolerance (reference WCAP 8887 and 8304) is specified
for basket fabrication. Changes to the basket roundness profile potentially affect the
ability of the ice basket to sustain a compressive load. Under design basis accident
conditions the ice baskets are subject to compressive loadings.
On February 4, 1998, the inspectors identified seven Unit 2 ice baskets with a six-inch
long horizontal crease or buckled area of webbing approximately
1 foot above the
bottom of the basket.
This buckled webbing changed the ice basket roundness profile
and potentially affected the ice basket design compressive strength.
As a corrective
action, the licensee included a search for dented/crumpled
ice baskets in the inspections
of all accessible lower basket assemblies
in each unit to identify missing screws.
From
this inspection, the licensee generated
a preliminary list of damaged baskets.
In excess
of 40 Unit 1 baskets and in excess of 100 Unit 2 baskets were identified with dents or
buckled/crushed
areas in the lattice webbing near the bottom of the basket.
The licensee staff stated that the likely cause of the dented/buckled damaged to the ice
baskets was dropping of the baskets, or jacking the baskets from below, in an attempt to
loosen the baskets for surveillance testing.
Based on observed corrosion at buckled
15
L
0
webbing locations (protective coating was damaged) and the number of damaged ice
baskets, the inspectors concluded that the damage had occurred over an extended
period of time. Further, these dented/buckled ice baskets were readily visible and yet
this damage had heretofore not been identified during ice condenser walkdowns by
system engineers."
In this instance, the licensee staff had numerous opportunities to identify and correct
the dented baskets during past surveillance testing or ice condenser walkdowns.
Failure to promptly identify, evaluate or implement corrective actions for the
Unit 1 and 2 ice baskets with dented/buckled webbing located near the bottom ice
basket rim assembly,
is an apparent violation of 10 CFR 50 Appendix B, Criterion XVI
On February 12, 1998, the licensee conducted a scoping test on a Unit 1 ice basket,
which contained a dented/buckled section of webbing approximately
1 foot above the
bottom of the basket.
This test was, intended to apply a compressive axial and lateral
load equivalent to that used to qualify the design basis (dead load combined with
operational basis earthquake) of an undamaged
basket (reference WCAP 8304). This
basket began to fail with plastic deformation (crumple) under a compressive load of less
than half that used to qualify the design of an undamaged
basket.
On February 12,
1998, the licensee notified the NRC (pursuant to reporting requirements of.10 CFR 50.72(b)(2)(i)) that this ice basket, represented
a condition outside the plant's design
basis.
b.4
U ide
i
Nn
Section 3.1.6 "Loose Insulation" of Appendix M of the FSAR discusses
the use of an
airtight polyethylene bag to encapsulate
insulation, to prevent loose insulation during a
DBA. Loose insulation could be returned to the sump and potentially clog emergency
core cooling system suction strainers following a DBA.
On February 19, 1998, inspectors identified a blanket of "loose" (nonencapsulated)
fiberglass insulation between the entry doorway bulkhead and the bay 24 east wall in
the Unit 1 lower ice condenser.
Inspectors estimated that this nonencapsulated
insulation was potentially a 10 feet by 10 feet piece of fiberglass insulation with cutouts
for the door and structural support materials.
This condition had likely existed since
original plant construction.
On February 20, 1998, the licensee issued CR 98-0634 to
document and evaluate this condition applicable to both Units.
In this instance, the licensee staff had numerous opportunities to identify and evaluate
the nonencapsulated
insulation during past surveillance testing or ice condenser
walkdowns.
Failure to promptly identify, evaluate or implement corrective actions for
the nonencapsulated
insulation in the Unit 1 and 2 ice condensers,
is an apparent
violation of 10 CFR 50 Appendix B, Criterion XVI(EEI 50-315/98005-14(DRS);
16
I ~
4
i~,
Ijj
b.5
Unw i habl
B
t
'hT r
D nt
rB
k
W
in
D ma
Inspectors noted tom'ligaments, bent rims and missing screws at the upper rim
area of ice basket assemblies.
The licensee had previously identified (reference
CR 2-12-88-1719 and CR 1-04-89-702) in excess of 200 Unit 2 ice baskets and in
excess of 300 Unit 1 ice baskets with damage to upper areas of ice baskets
(predominantly tom webbing and bent rims).
In some cases, this damage to the
upper rim areas prevented the use of test equipment to liftthe ice basket for the ice
basket weight surveillance, which rendered the ice basket unweighable.
The licensee could not readily identify the damaged ice baskets in service that had been
rendered unweighable, because
this type of information was not tracked.
The licensee
initiated actions to visually inspect and map the ice baskets still. in service with damage
near the upper rim areas.
The licensee stated that the probable cause of the ice basket damage in upper areas of
the basket was rough handling (e.g., attempts to free baskets frozen in) during past
surveillance. weighing activities (M1.b.2.5.).
Inspectors identified that damaged
unweighable ice baskets in radial rows 1,2,4,6,8,9 could affect the ability of the licensee
to perform representative
sampling of ice baskets (Section M1.b.2.4). Inspectors
identified that during the April 24, 1996 performance of EHP 4030 STP.211 for Unit 2,
sixteen radial row nine and ten radial row one ice baskets could not be weighed due to
damaged rims or being frozen in. Additionally, unweighable baskets cannot be refilled
without repairs, since baskets loaded without subsequent weighing could potentially
exceed the maximum allowable ice basket weights assumed
in the design basis
analysis.
b.6
I eF
Di
n
Section 1.1 of the FSAR, Appendix M, described the form of ice used to fillthe ice
baskets as 2 inch by 2 inch by 1/8 inch flake ice. Further, Section 5.3.3 of the FSAR
stated that long-term ice storage tests have shown that the ice can be stored without
significant weight loss or physical distortion. Contrary to this description, inspectors
observed that ice baskets recently filled contained a course loose granular form of ice
and that ice baskets not recently filled had sublimated into a solid mass of ice.
To address this change in ice form, the licensee provided a letter from Westinghouse
dated February 10, 1998, which referenced Westinghouse testing conducted in 1960
that tested ice in the form of chips, cubes, blocks and spheres.
These tests reportedly
demonstrated
that ice condenser performance was insensitive to extreme changes
in
ice heat transfer surface area.
Additionally, a 1973 Westinghouse test was referenced
which included 0.75 Ibs of water per foot per basket.
The water was added to represent
the Iong term storage condition of the ice. The licensee also referenced the Atomic
Energy Commission (AEC) questions and responses
on this subject during the initial
plant licensing.
Licensee responses
to the AEC for this concern included, "Ice storage
17
tests have shown that ice can be stored for long periods without significant degradation"
and "Results of these tests show no significant difference in the properties of various
forms of ice."
Based on the information discussed
above, the existing changes
in ice form appeared
to
be bounded by tests and evaluations reviewed during initial plant licensing.
However,
the licensee's failure to update the description of the ice form changes in the FSAR was
considered an apparent violation of 10 CFR 50.71(e) requirements and is discussed
in
section E7.1.
Conclusions on Ic
Con
n
r Mat ri
I C
n iti
Inspectors identified three apparent violations of 10 CFR 50 Appendix B, Criterion XVI
for the licensee's failure to identify conditions adverse to quality. Conditions not
previously identified by the licensee in the ice condenser included: blocked flow
passages,
missing ice segments,
dented/buckled basket webbing, unweighable ice
baskets, and nonencapsulated
insulation.
Further, these conditions had existed for an
extended period of time, without identificatio by system engineers or licensee staff.
Collectively, these problems contributed to a poor state of materiel condition in each ice
condenser, such that the ability of the ice condenser to perform its design function was
in question.
E2
Engineering Support of Facilities and Equipment
E2.1
C rre tive Actions
rlc
Cond nse
Com one
Dama
e
i n
72
Inspectors interviewed engineering staff and reviewed engineering corrective actions
documented
in problem/ condition reports for damaged
ice condenser components..
b.
rv tion
nd F'ndin
b.1
F iled
ndMi
in
B
k t
h
t
I
rw
b.1.1
rre tiv A ti n
roc
not I
I men
f rl e B
k t
h et
tal
rew
Ice baskets segments (typically 12 feet in length) are coupled together using sheet
metal screws arranged in pairs at 60 degrees intervals around the circumference of the
ice basket.
Twelve screws on each basket segment are installed at the coupling joint.
Missing screws at the intermediate or lower coupling joints could allow an ice basket to
separate and become a missile hazard under design basis accident loads.
NRC
18
inspection report 50-390/97-04; 50-391/97-04 documented that broken ice basket sheet
metal screws had been found in the ice melt tank at another ice condenser plant (Watts
Bar).
For D.C. Cook, an ice condenser system engineer identified four ice basket sheet metal
screw heads in the ice melt system filteron January 22, 1998. The licensee had not
initiallyrecorded these screws missing from ice baskets, nor others found in prior
outages on condition reports.
The system engineer estimated that approximately two
dozen sheet metal screw parts had been found in the ice melt system filters since 1991.
The licensee staff had believed that the source of these screws was the top basket rim
or separated
baskets, which had been restrained through modifications and thus had no
safety significance.
Inspectors'uestions
into the definitive source and significance of
these missing sheet metal screws prompted a licensee inspection of ice baskets in each
Unit for missing screws (Section E2.1.b.1.2).
The licensee's failure to promptly identify
and initiate corrective actions for the ice basket sheet metal screws found in the ice melt
cleanup system filters during previous outages is an apparent violation of 10 CFR 50
Appendix B, Criterion XVI (EEI 50-315/98005-15(DRS);
U
al z
C d't'PI
i nw'thMi
in
h
t
I
r ws
The scope of the licensee's ice basket inspection for missing sheet metal screws
consisted of a visual inspection of accessible areas of the bottom basket coupling rings
for ice baskets
in both Units. The accessibility of the bottom basket coupling ring area
of some ice baskets was limited by ice buildup or physical interferences with ice
condenser components.
For example, of the 81 ice baskets per bay, the licensee was
not able to perform a complete inspection on up to 22 baskets per bay in Unit 2 and up
to 18 baskets per bay in Unit 1
~ In addition to the bottom basket areas, the licensee
performed a camera aided visual examination of the intermediate coupling joints and
stiffening rings on ice baskets in each unit (a population of 60 to 100 baskets for each
Unit was planned).
From the inspections discussed above, in excess of 40 Unit 1 and in excess of 90 Unit 2
ice baskets were identified with missing sheet metal screws at the lower ice basket
coupling ring. In addition, several ice baskets had been identified to have one or two
missing screws at intermediate coupling rings in the ongoing full length camera aided
inspections.
The licensee had Westinghouse complete an evaluation (documented in a
memorandum dated February 13, 1998) of the missing sheet metal screws.
In this
evaluation Westinghouse concluded that the ice basket column would continue to meet
the design function (based on allowable shear stress in the sheet metal screws) with 8
of 12 screws on a basket segment at the coupling union on a case by case basis.
At the
19
conclusion of the inspection period the licensee had identified the following ice baskets
with more than 4 missing sheet metal screws at the bottom basket coupling ring.
Unit
No.
Basket No. (Bay, Azimuthal Row, Radial Row)
No. Of Missing Screws
2-1-6
3-4-8
24-4-8
8-2-9
14-6-8
19-7-9
22-8-9
11 of 12
12 of 12
9of12
6 of 12
9 rivets and 3 screws
12 of 12
5 of 12
On February 14, 1998, the licensee notified the NRC (pursuant to requirements of
10 CFR 50.72(b)(2)(i)) that two Unit 1 baskets missing more than 4 sheet metal screws
represented
an unanalyzed condition outside the plant's design basis.
At of the
conclusion of the inspection period, the licensee had not determined the cause of the
failed sheet metal screws.
b.2
Lo se and
is's
On November 2, 1990, the licensee documented
in PR 90-1639 a broken U-bolt and 19
missing nuts from Unit 1 ice baskets and 12 missing U-bolt nuts from Unit 2 ice baskets.
The cause of the missing fasteners was attributed to loosening of the nuts caused by
vibrating tools used during the ice basket emptying process.
Licensee corrective
actions included replacing missing nuts and inspecting a selection of basket nuts to
identify any loose or missing fasteners.
Preventative actions included revising 12 THP
4030 STP.211 to require all baskets which are vibrated to be inspected for broken
U-bolts, and loose or missing nuts..
On April 23, '1992, the licensee documented
in PR 92-0360 that 10 percent of all Unit 2
U-bolt basket nuts were loose and 5 Unit 2 baskets had missing U-bolt nuts. Again, the
cause of the loose fasteners was attributed to vibrating tools used during ice basket
emptying.
On August 19, 1992, the licensee identified in PR 92-1386, missing nuts and an
unspecified number or percentage of loose nuts for Unit 1. The cause of the loose and
missing nuts was documented as unknown. The preventative action was to continue to
do inspection of nuts during 12 THP 4030 STP.211.
Step 4.17 of EHP 4030 STP.211 (formerly 12 THP 4030 STP.211) allowed replacing
loose or missing fasteners from the bottom ice basket U-bolts without restrictions or
20
instructions.
Step 5.4.3.3 required missing or broken U-bolts to be documented on a
condition report and Attachment 4 of this procedure.
However, this step only required
documenting loose nuts in Attachment 4, vice on a condition report. Thus, inspectors
were concerned that loose U-bolt nuts could be an ongoing problem for a number of ice
baskets and not identified in condition reports.
Loose or missing U-bolt nuts can allow the ice baskets to be displaced horizontally
under design basis accident loads such that other baskets may be contacted,and
damaged.
The licensee's preventative actions implemented in PR 90-1639 did not
prevent recurring loose and missing U-bolt nuts.
Further, existing surveillances
requirements did not require repeat occurrences of this condition adverse to quality
to be entered into th'e corrective action process.
Failure to implement corrective
actions which preclude recurrence of this significant condition (loose U-bolt nuts)
adverse to quality is an apparent violation of 10 CFR 50 Appendix B, Criterion XVI
b.3
rated
B
s
In 1983, the licensee identified separation of sections of the Unit 1 ice baskets 17-2-9,
20-6-8 and 20-8-8 and documented this condition in CR 1-07-83-647 and
CR 1-08-83-771.
The bay 20 ice baskets had failed during weighing activities with
less than 1000 Ibs of liftingforce applied.
This amount of force was below the
design forces for the basket and the licensee had not determined the cause for these
basket section failures in response to these condition reports.
On February 28, 1997, during surveillance testing, the top three feet of ice basket
20-9-8 had separated.
The licensee documented this condition in CR 97-554, and did
not identify a definitive cause, nor implement preventative actions for this condition.
These ice baskets, which failed below the design loadings, could have separated under-
DBA blowdown loadings and become missile hazards.
Failure to implement corrective
actions for these separated
Unit 1 ice baskets, which precluded repetition of this
significant condition adverse to quality, is an apparent violation of 10 CFR 50
Appendix B, Criterion XVI (EEI 50-315/98005-1 7(DRS)).
b.4
Fill
W
I
h
B
B tt
IdD
B
On July 22, 1992, the licensee had identified 22 Unit 1 and 3 Unit 2 ice baskets which
had settled (bottom rim displaced relative to the hold down bar) and documented this
condition in PR 92-1181.
Two ice baskets had been removed to examine the inner
bottom basket rim area, which was not directly accessible to an in-situ examination.
This examination revealed that the filletweld joining the bottom basket (/~ inch by 4 inch
by 11.6 inch) hold down bar had failed allowing separation of this bar from the bottom
basket rim.
The cause of these weld failures was determined to be manufacturing induced flaws,
vice service induced.
The metallurgical report (Gelles Laboratories, Inc. dated
21
August 1992) conclusions stated "No evidence of service caused failure was found" and
"..the galvanizing operation may not have been done correctly" and "The lack of fusion
appears to be caused by improper joint cleaning." Further, this report had
recommended
that the licensee perform mechanical testing of selected ice baskets to
ascertain the capability of these baskets.
The licensee's corrective actions for the known (settled) ice baskets with failed fillet
welds included installing restrainer bars over the failed Unit 2 baskets and replacing
the bottom rims for the Unit 1 baskets.
However, corrective actions documented
in
PR 92-1181 did not include identificatio of the full scope of ice baskets with failed fillet
welds caused by manufacturing defects.
The licensee chose not to attempt to identify
other ice baskets with flawed/failed filletwelds due to in-situ accessibility limitations.
Instead, the licensee performed analyses and evaluations to accept this condition.
In a licensee memorandum dated July 27, 1992, the licensee evaluated the effect of the
broken filletwelds on the ice basket during a DBA. In this evaluation, the licensee
stated in part, that the stiffness of the end grid is several orders of magnitude lower than
the stiffness of the bottom rim and of the Y~ inch bar, causing it to deflect out of the way
during a DBA uplift condition and causing the bar to engage the lower rim inner lip with
minimal displacement and no impact. The evaluation success
criteria established
by the
licensee were that bending and shear stresses of the bottom rim would remain within
allowable values, for the material.
Based on this evaluation, the licensee concluded that
the ice baskets could resist all loads despite the broken weids.
On 'July 27, 1992, Westinghouse expressed
a concern pertaining to the dynamic effects
of a DBA blowdown on baskets with broken weids that had settled.
For baskets in a
settled position, the lip of the bottom rim of the basket would be subject to additional
loads due to the impact on the /~ inch bar as the baskets is accelerated
upwards by the
blowdown forces generated
by the DBA. Westinghouse could not provide reasonable
assurance
that the settled baskets would not become missile hazards when subject to a
DBAplus design basis earthquake loads.
On August 13, 1992, the licensee performed another evaluation and developed a
mathematical model of the dynamics of the ice basket loadings to address the
Westinghouse concern discussed
above.
The licensee reportedly incorporated the
blowdown loads provided by Westinghouse and the displacement load/resistance
curves (developed from a single static pull test performed on August 8, 1992) into their
mathematical model of dynamic loads.
For the design ice basket weights, the model
reportedly established:
whether the bottom basket rim assembly would stop the motion
of the dropped baskets, how much displacement is required, what residual capacity of
the assembly is to resist static blowdown forces and the dynamic forces on the support
structure.
Based on the results of this test and calculation of kinetic energy to which the
baskets could be exposed, the licensee concluded that ice baskets would not become
missile hazards.
The FSAR Appendix M, Section 3.1.4 provided the original design criterion and load,
factors for the ice baskets.
The licensee testing and analysis had accepted plastic
22
ll
deformation (displacement) of the ice basket bottom rim assembly without applying
design bases lateral loads, which was outside the original ice basket design basis
described in Appendix M of the FSAR. Further, the licensee analysis incorporated the
results from a single load test, which may not represent the bounding case, nor provide
an adequate statistical design basis.
Section 3.1.5 of Appendix M required in part, that
the licensee obtain AEC (now NRC) approval for analysis criterion other than previously
accepted by the AEC in Section 3.1.4 of Appendix M. As of February 27, 1998, the
licensee had not submitted their July 27 and August 13, 1992 analysis for ice baskets
with failed filletwelds to the NRC for evaluation.
Inspectors concluded that as of February 27, 1998, the licensee had not taken adequate
corrective actions as discussed above for this condition adverse to quality. Specifically,
the licensee failed to apply the applicable FSAR design criteria or seek NRC approval of
the alternative analysis used in the engineering evaluation (dated July 27 and August
13, 1992) that accepted the affected ice baskets.
Failure to implement adequate
corrective actions for this condition (ice baskets with flawed/failed filletwelds) adverse to
quality is an apparent violation of 10 CFR 50 Appendix B, Criterion XVI
In a letter dated August 31, 1992, the licensee documented that a four hour event
notification pursuant to 10 CFR 50.72(b)(2)(i) requirements was made on August 4,
1992 for the ice baskets found in this condition.
In this letter the licensee also stated
"Since duplicate reporting is discouraged by the NRC, a separate
Part 21 Notification
was not made." The licensee concluded that their analysis demonstrated
that the
baskets'with degraded welds would not become missile hazards and thus, this condition
was not reportable and recommended
retraction of the NRC notification made on
August 4, 1992.
However, as discussed above, this condition was outside the original
design basis for the ice baskets and the 10 CFR 50.72 event notification appeared
valid. Thus, for the failed basket welds caused by manufacturing defects, inspectors
were concerned that 10 CFR 50.72 and 10 CFR 21 reporting requirements had not
been properly evaluated.
Inspectors considered this an unresolved item pending
review of the licensee basis of the applicability of these requirements to this
issue'URI
50-315/98005-19(DRS);
Conclu 'ons
n Corrective Actions for Ice Cond nser C m
ts
Inspectors identified four apparent violations of 10 CFR 50 Appendix B, Criterion XVI,
for the 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,
implement effective corrective actions to prevent recurrence of loose U-bolt nuts and
separated
ice baskets, and take appropriate corrective actions for the ice baskets with
defective hold down bar welds.
Collectively, the corrective action violations identified in
Sections M2.1 and this section represent a breakdown in the corrective action program
for the ice condenser..
23
(J
l
j,',
fl
E7
Additionally, the inspectors identified an unresolved item pertaining to the licensee's
application of 10 CFR 50.72 and 10 CFR 21 reporting requirements associated with the
failed basket hold down bar filletwelds.
Quality Assurance in Engineering Activities
E7.1
in
n
fh
I
n
B
In
in
77
Inspectors reviewed select analyses and modifications made to ice condenser
components since original construction and reviewed the current description of the ice
condenser in Section 5.3.3 and Appendix J and M of the FSAR.
b.
rv tin
n
Fin
b.1
D
i Ba'fr
C
10 CFR 50.71(e) requires in part that the licensee periodically update the FSAR as
originally submitted in the application for an operating license.
Appendix J and M of the
FSAR were submitted as part of the FSAR in the original license application for D.C.
Cook.
Inspectors identified that these appendices
had not been updated over the life of
the plant. The licensee issued CR 98-0444 to document the failure to update the FSAR,
Appendix M..
The cover page for Appendix J and M of the FSAR stated that "The appendix is
presented as information current during the OL [Operating License) review, and is
reproduced as an historical record." These appendices
contained the detailed original
design description and analysis for the ice condenser.
Due to the licensee's failure to
maintain these appendices
current, the design basis and descriptions of ice condenser
components had become out of date.
Inspectors identified specific analysis and
modifications affecting the design basis or original ice condenser component
descriptions, which had not been incorporated into Appendix J or M of the FSAR as
discussed
below.
b.1.1 WCAP-11902 "Reduced Temperature and Pressure Operation for Donald C. Cook
Nuclear Plant Unit 1 Licensing Report," dated October 1988, was used as the basis to
establish an upper allowable limitfor ice condenser fiow passage
blockage, which the
licensee incorporated into 12 THP 4030 STP.211 (currently 12 EHP 4030 STP.211).
As of February 27, 1998, the analysis limits established
in WCAP 11902 for the ice
condenser had not been incorporated into Appendix M or J of the FSAR. Failure to
incorporate ice condenser flow passage
blockage limits as established
in
WCAP-11902 into the FSAR is an apparent violation of 10 CFR 50.71(e)
b.1.2 The FSAR, Appendix M, Figure 6.4.1 details the configuration of the ice basket bottom
rim assembly.
A bolted rectangular tube support is depicted in this drawing, vice the as-
24
built solid hold down bar support attached with filletwelds for ice baskets in the plant.
As of February 27, 1998, the licensee has not updated Figure 6.4.1 to match the as-built
configuration.
Failure to update the FSAR to incorporate the as-built ice basket
configuration is an apparent violation of 10 CFR 50.71(e) (EEI 50-315/98005-21(DRS);
b.1.3 The FSAR, Appendix M, Section 1.1 described the form of ice used to fillice baskets as
2 inch by 2 inch by 1/8 inch flake ice. Further, Section 5.3.3 of the FSAR stated that
long-term ice storage tests have shown that the ice can be stored without significant
weight loss or physical distortion. Contrary to this description, since the beginning of
commercial operation, the ice baskets have been refilled with ice in course granular
form, which had sublimated into a solid mass of ice for baskets not recently filled. As of
February 27, 1998, the licensee has not updated these FSAR sections to reflect the
actual form of ice used.
Failure to update the description of the ice form in the FSAR
to match the as-used
ice form is an apparent violation of 10 CFR 50.71(e) (EEI
50-315/98005-22(DRS);
b.1.4 The licensee modified a Unit 2 ice basket 2-3-8 in February of 1989, by adding 4 pipe
structural supports and a cable under modification 02-MM-032. As of February 27,
1998, the licensee had not updated the ice basket descriptions in Appendix M of the
FSAR to identify this modified Unit 2 ice basket.
Failure to update the FSAR
descriptions for this modified ice basket is an apparent violation of 10 CFR 50.71(e)
b.1.5 The licensee modified Unit 1 ice baskets 12-2-4, 12-84, 14-7-8, 3-3-9, 1-7-9, 13-7-9,
16-7-9 and 18-7-9, in July of 1989 by adding 4 pipe structural supports and a cable to
each ice basket under modification 01-MM-048. As of February 27, 1998, the licensee
had not updated the ice basket description in Appendix M of the FSAR to identify these
modified Unit 1 ice baskets.
Failure to update the FSAR descriptions for this modified
ice basket is an apparent violation of 10 CFR 50.71(e) (EEI 50-315/98005-24(DRS)).
b.1.6 Westinghouse letter "Indiana Michigan Power D.C. Cook Nuclear Power Plant Ice
Condenser Seismic Load Study New Ice Basket Design," dated February 28, 1990,
was used as the basis to establish the maximum gross basket weight limitof 1877 Ibs,.
which the licensee incorporated into 12 THP 4030 STP.211 "Ice Condenser
Surveillance" (currently 12 EHP 4030 STP.211).
As of February 27, 1998, the
licensee had not updated data in table 4.3-1 of Appendix M of the FSAR, that reflect a
maximum analyzed gross ice basket weight limitof 1776 lbs. Failure to update the
FSAR sections to incorporate the revised maximum analyzed gross ice basket weight
is an apparent violation of 10 CFR 50.71(e) (EEI 50-315/98005-25(DRS);
b.1.7 On October 14, 1992, the licensee authorized the use of Westinghouse drawings
1851E35, Revision 7 and 1880E22, Revision 6 to construct replacement ice baskets
from short 2 or 3-foot segments, vice the original 12-foot segments described in
Appendix M of the FSAR. This change in ice basket design resulted in a heavier ice
basket with more coupling joints and sheet metal screws.
As of February 27, 1998, the
25
~
'
lj
licensee failed to revise the FSAR, Appendix M, to incorporate the change made to
replacement Unit 1 and 2 replacement ice baskets fabricated from short ice basket
subassemblies
(2 or 3-foot segments).
'Failure to update the FSAR to incorporate the
replacement ice basket design is an apparent violation of 10 CFR 50.71(e)
b.2
Un
hori
M
ifi
ti n fl
B
A
Inspectors identified modiTications to Unit 1 and Unit 2 ice baskets which had been.
installed without following established design control processes.
Between February 14 through 17, 1998, licensee staff conducted inspections of
accessible areas of the lower ice basket to identify damage and nonconforming
conditions in response to missing screws and other basket damage discussed
herein.
From a preliminary list of damaged baskets created by licensee staff during this
inspection, the inspectors identified and visually confirmed unauthorized modifications
made to Unit 1 and Unit 2 ice baskets as discussed
below.
b.2.1 On February 19, 1998, inspectors identified that Unit 1 ice baskets 4-1-9, 5-9-1 and
20-3-6 had a galvanized bolt installed in place of the clevis pin that connected the ice
basket to the support structure.
The licensee was unaware of when this modification
was installed, since it had not been authorized.
Failure to followestablished design
control processes. for this modification to these ice baskets is an apparent violation of
10 CFR 50 Appendix B, Criterion III (EEI 50-315/98005-27(DRS);
b.2.2 On February 19, 1998, inspectors identified that Unit 2 ice basket 1-7-9 had a six inch
wide curved sheath of sheet metal installed onto the ice basket mesh, beginning just
above the bottom of the ice basket and running vertically upwards as far as could be
seen (greater than 12 feet). The licensee was unaware of when this modification was
, installed, since it had not been authorized. Failure to followestablished design control
processes
for this modification to ice basket 1-7-9 is an apparent violation of 10 CFR 50
Appendix B, Criterion III (EEI 50-315/98005-28(DRS);
b.2.3 On February 19, 1998, inspectors identified that Unit 2 ice basket 14-6-8 had 9 rivets
installed in place of sheet metal screws in the bottom ice basket rim coupling. The
licensee was unaware of when this modification was installed, since it had not been
authorized.
Failure to follow established design control processes
for this modification
to ice basket 14-6-8 is an apparent violation of 10 CFR 50 Appendix B, Criterion III
At the conclusion of the inspection period, the licensee had not determined the potential
safety consequences
for past plant operation with these unauthorized modifications.
26
J
'
b.3
Surv
ill n ePr
ce
r
U edt Mod'nd Rem v
I
B
k t
ru if rmSu
orts
The ice basket cruciform supports attach to the coupling and stiffening ring locations (at
six foot intervals) and prevent ice in the basket's from displacing axially in the event of a
loss of ice by sublimation or due to accident conditions.
On November 18, 1988, the licensee initiated a modification RFC-DC-12-1937 to
change the design or remove cruciform supports from ice baskets in,Unit 1 and Unit 2.
A licensee letter dated January 31, 1990, documented that drawings for ice baskets
modified in this manner would not be updated because
these drawings were not
retained by the licensee and the drawings in this modification package would serve as
the permanent plant record for the affected ice baskets.
After closure of RFC-DC-12-1937, the licensee changed Attachment 4 and 5 of
12 EHP 4030 STP.211 (formerly 12 THP 4030 STP.211) to authorize changing basket
cruciforms or deletion of cruciforms.
Specifically, Attachment 4 and 5 of this procedure
allowed deletion of the bottom three cruciforms from Radial row 7, 8 or 9 ice baskets
and/or the installation of replacement cruciforms of a new design.
These modifications
were not required to be updated on the ice basket drawings.
On February 3, 1998, the inspectors requested
a list of all baskets with cruciform
supports that had been deleted or modified during performance of 12 EHP 4030
STP.211.
As of February 27, 1998, the licensee was unable to compile a list of ice
baskets modified under 12 EHP 4030 STP.211, due to the extensive resources required
to review the previous surveillance test data to identify the modified ice baskets.
The inspectors concluded that the open ended modification process authorized in
12 EHP 4030 STP.211, did not ensure that updated drawings were maintained for the
specific ice baskets with deleted or modified cruciform supports.
10 CFR 50 Appendix
B, Criterion III requires in part that controls will be in place to ensure that modifications
are controlled....
In this case the licensee chose not to maintain current drawings of ice
baskets with the modified cruciform design.
Further, the use of a surveillance procedure
to perform modifications was outside of the licensee's established design control
process.
Failure to followthe existing design control processes
in modification of ice
basket cruciforms is an apparent violation of 10 CFR 50 Appendix B, Criterion III
e
'ntnn
t
Ic
on
nerDeinB
is
Inspectors identified seven apparent violations of 10 CFR 50.71(e) pertaining to the
licensee's failure to update the FSAR Appendices J or M which contained the detailed
description and design basis for the ice condenser.
Additionally, inspectors identified
four apparent violations of 10 CFR 50 Appendix B, Criterion III, pertaining to the
licensee's failure to follow the established design control process for ice basket
.
modifications. Collectively, these apparent violations represent a programmatic
breakdown in the maintenance of the design basis for the ice condenser.
27
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p
~
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I
E7.2
0
ra ilit in
ti fr eA-F un
n
n
r
nd'i
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). The licensee had
issued a condition report 98-0388 to document all damage to ice baskets, including
damage previously identified. As part of the investigation for this condition rep'ort, the
licensee had reportedly contracted with Westinghouse to undertake an assessment
of
the overall ice condenser operability for the as-found condition of the ice condenser.
Pending review of the licensee's evaluation of past plant operation with the ice
condenser
in the as-found state, inspectors considered this an unresolved item
E8
Miscellaneous Engineering Issues (92700)
E8.1
I L'v
L
-
1
4-: Interim LER- Restricted Ice
Condenser Flow Passages
Found to Constitute an Unanalyzed Condition, issued,
February 23, 1998.
This issue was reported to the NRC on January 22, 1998, pursuant to requirements of
10 CFR 50.72(b)(2)(i) and is discussed
in Sections M1.1.b.1 and M2.1.b.1. The impact
of this condition on the as-found condition of the ice condenser for past plant operations
will be assessed
by the licensee and tracked by the NRC in resolution of an unresolved
'tem
Therefore, this LER is
closed.
E8.2
Cl
ed
Li
R
o
LE
-
1
-: InterimLER-Lackof
Adequate Number of Screws in Ice Basket Coupling Rings Determined to Constitute
Unanalyzed Condition, issued February 23, 1998.
This issue was reported to the NRC on February 14, 1998, pursuant to requirements of
10 CFR 50.72(b)(2)(i) and is discussed
in Section E2.1.b.1.2.
The impact of this
condition on the as-found condition of the ice condenser for past plant operations will be
assessed
by the licensee and tracked by the NRC in resolution of an unresolved item
Therefore, this LER is
closed.
E8.3
Clo ed
Lic n e
vent R
L
0-
5
0 6-: InterimLER-Procedure
Option for Weighing of Ice Baskets in Modes 3 and,4 Determined to be a Potentially
Unanalyzed Condition, issued March 3, 1998.
This issue was reported to the NRC on February 25, 1998, pursuant to requirements of
10 CFR 50.72(b)(2)(i) and is discussed
in Section M1.1.b.2.2.
The failure of the
licensee to provide adequate instructions for entry into an unanalyzed condition
(unpinning 60 ice baskets) is considered an apparent violation of 10 CFR 50 Appendix
B, Criterion V (EEI 50-315/98005-05(DRS);
Corrective
actions will be addressed
by the licensee in resolving this violation, therefore, this LER is
closed.
28
'J
4
p I
Cl
E8.4
I
Li en
Ev n R
rt LER
5 -31 /
0 7-0: Interim LER-Ice Condenser
Weights Used to Determine Technical Specification Compliance Not Representative
This issue was reported to the NRC on February 11, 1998, pursuant to requirements of
10 CFR 50.72(b)(2)(i) and is discussed
in Section M1.1.b.2.4. The failure of the
licensee to select a representative
sample of ice baskets to weigh is a violation of TS 4.6.5.1.b.2 (EEI 50-315/98005-07(DRS);
Corrective
actions willbe addressed
by the licensee in resolving this violation, therefore, this LER is
closed.
E8.5
Clo e
Li
n e
Ev nt R
o
L R
-
1
9
0 - OFailureof Ice Baskets to
Withstand Simulated Accident Loadings During Testing Results in Unanalyzed Condition
This issue was reported to the NRC on February 12, 1998, pursuant to requirements of
10 CFR 50.72(b)(2)(i) and is discussed
in Section M2.1.b.3. The failure of the licensee
to identify/evaluate buckled webbing in lower section of ice baskets is a violation of TS 4.6.5.1.b.2 (EEI 50-315/98005-13(DRS);
Corrective
actions willbe addressed
by the licensee in resolving this violation, therefore, this LER is
closed.
X1
Exit Meeting Summary
The inspectors presented the inspection results to members of licensee management at the
conclusion of the inspection on February 27, 1998, and in a final phone exit held March 19,
1998. The licensee acknowledged the findings presented
and did not identify any of the
potential report input as proprietary.
29
III
I
!
I
il
t
0
PARTIALLIST OF PERSONS CONTACTED
Ameri
n
I
ri
P wr
A. Blind, Vice President Nuclear Engineering
J. Boesch, Maintenance Superintendent
D. Cooper, Plant Manager
S. Farlow, Supervisor l&C Engineering
M. Finissi, Supervisor, Electrical Systems
E. E. Fitzpatrick, Executive Vice President Nuclear Generation Group
D. Hafer, Manager, Plant Engineering
M. Kelly, Nuclear Licensing
B. Kovarik, Safety-related Mechanical Systems
F. Pisarsky, Supervisor, Mechanical Component Engineering
J. Sampson, Site Vice President
P. Schoepf, Supervisor, Safety-related Mechanical Systems
D. Sudhoff, Safety-related Mechanical Systems
A. Tetslaff, Safety-related Mechanical Systems
S. Wolf, Performance Assurance
Duk
P w rC
n
B. Lamb
D. Myer
R. Proctor
mri
nN
I
L. Demski
M. Poluhanyiz
We
'n
J. Matusz
S. McKenzie
C. Scrabis
othBnd
i
J. Swidwa
Hrld
II
i
S. Aiken
K. Kamps
N. Lee
30
I
q
F
'I
INSPECTION PROCEDURES USED
IP 61700
IP 92700
Design Changes and Modifications
Surveillance Procedures
and Records
Maintenance Program Implementation
Onsite Review of LERs
Corrective Action
ITEMS OPENED, CLOSED, AND DISCUSSED
ITE
OP
NED
50-315/98005-01(DRS)
50-316/98005-01(DRS)
50-315/98005-02(DRS)
50-316/98005-02(DRS)
50-315/98005-03(DRS)
50-316/98005-03(0RS)
50-315/98005-04(DRS)
50-316/98005-04(DRS)
50-315/98005-05(DRS)
50-316/98005-05(DRS)
50-31 6/98005-06a(DRS)
50-315/98005-06b(DRS)
50-315/98005-07(DRS)
50-316/98005-07(DRS)
50-315/98005-08(DRS)
50-316/98005-08(DRS)
50-315/98005-09(DRS)
50-316/98005-09(DRS),
50-315/98005-10(DRS)
50-316/98005-10(DRS)
50-315/98005-11(DRS)
50-316/98005-11(DRS)
50-315/98005-12(DRS)
50-316/98005-12(DRS)
EEI
EEI
EEI
EEI
EEI
EEI
Inadequate instructions for inspection of flow
passages
Inadequate instructions for selecting flow
passages
Insufficient margin to analysis limitfor evaluating
a degraded
ice condenser
Insufficient margin to analysis limitfor maximum
gross ice basket weight
Inadequate instructions for entry into an
unanalyzed condition (unpinning 60 ice baskets)
Failure to followthe procedure change process
for a completed surveillance test
Failure to followthe procedure change process
for a completed surveillance test
Failure to select a representative
sample of ice
baskets to weigh per TS 4.6.5.1.b2
Failure to assess
and control the quality of work
by ice condenser contractors
Failure to inspect accessible areas of the lower
ice basket per TS 4.6.5.1.d
Insufficient margin to TS 4.6.5.3.1.b limitfor
lower ice inlet door opening torque
InsUfficient margin to TS 4.6.5.3.2.b limitfor
intermediate deck door opening force
Failure to identify/evaluate missing ice segments
in lower section of ice baskets
31
J
t'
ITEMS OPENED
50-315/98005-13(DRS)
50-316/98005-13(DRS)
50-315/98005-14(DRS)
50-316/98005-14(DRS)
50-315/98005-15(DRS)
50-316/98005-15(DRS)
50-315/98005-16(DRS)
50-316/98005-16(DRS)
50-315/98005-17(DRS)
EEI
EEI
Failure to identify/evaluate buckled webbing in
lower section of ice baskets
Failure to identify/evaluate fibrous material in the
ice condenser
Failure to promptly identify/evaluate missing ice
basket sheet metal screws
Failure to prevent recurrence of loose U-bolt
nuts
Failure to prevent recurrence of separated
ice
baskets
50-315/98005-18(DRS) 'EI
50-316/98005-18(DRS)
Failure to take prompt effective corrective action
ice baskets with failed filletwelds
50-315/98005-19(DRS)
50-316/98005-19(DRS)
50-315/98005-20(DRS)
50-316/98005-20(DRS)
50-315/98005-21(DRS)
50-316/98005-21(DRS)
50-315/98005-22(0RS)
50-316/98005-22(DRS)
50-316/98005-23(DRS)
50-315/98005-24(DRS)
50-315/98005-25(DRS)
50-316/98005-25(DRS)
50-315/98005-26(DRS)
50-316/98005-26(DRS)
50-315/98005-27(DRS)
EEI
EEI
EEI
EEI
Applicabilityof 10 CFR 50.72 and 10 CFR 21
reporting requirements to the ice baskets with
failed filletwelds
WCAP-11902 analysis not incorporated into the
FSAR per 50.71e
As-built ice basket bottom assembly not
incorporated into the FSAR per 50.71e
As-used ice form not incorporated into the FSAR
description per 50.71e
Ice basket modified by 02-MM-032 not
incorporated into the FSAR description per
50.71e
Ice baskets modified by 01-MM-048 not
incorporated into the FSAR description per
50.71e
ice basket seismic load study,
dated February 28, 1990 not incorporated into
the FSAR per 50.71e
Revised replacement ice basket design not
incorporated into the FSAR per 10 CFR 50.71e
Unauthorized modification (bolt vice pin) installed
in three Unit 1 ice baskets
32
,
II
<
e
I
ij
I
TEM
NED
50-316/98005-28(DRS)
50-316/98005-29(DRS)
50-315/98005-30(DRS)
50-316/98005-30(DRS)
50-315/98005-31(DRS)
50-316/98005-31(DRS)
EEI
Unauthorized modification (sheath of sheet
metal) installed on a Unit 2 ice basket.
Unauthorized modification (rivets vice screws)
installed on a Unit 2 ice basket.
Failure to follow design controls for ice basket
cruciform modifications
As-found operability of ice condenser
in question
for past plant operation
I
E
L
50-315/98004-00
50-315/98005-00
50-315/98006-00
50-315/98007-00
50-315/98008-00
ITEMS D S
S
LER
LER
LER
LER
LER
t
Restricted ice condenser flow passages
found to
constitute an unanalyzed condition
Lack of an adequate number of screws in the ice
basket coupling rings an unanalyzed condition
Procedure option for weighing of ice baskets in
Modes 3 and 4 determined to be a potentially
Ice condenser weights used to determine TS
compliance not representative
Failure of ice baskets to withstand simulated
accident loadings during testing results in an
None
33
4'
J
$ t
(
'i
LIST OF ACRONYMS
CFR
CR
LER
NRC
PR
TS
Code of Federal Regulations
Condition Report
Design Basis Loss of Coolant Accident
Division of Reactor Projects
Division of Reactor Safety
Escalated Enforcement Item
Final Safety Analysis Report
Licensee Event Report
Nuclear Regulatory Commission
'Operating License
Public Document Room
Problem Report
Surveillance Test Procedure
Technical Specification
Updated Final Safety Analysis Report
Unresolved Item
34
lg
f;l
I>
II
PARTIALLIST OF DOCUMENTS REVIEWED
~Proc ~r
EP-10 "Ice Basket Installation Procedure," Revision 2.
12 CHP 5021.MCD.004 "Removal and Replacement of Ice Condenser Baskets," Revision 2.
PMI-2010 "Instructions, Procedures,
and Associated Indexes Policy," Revision 24.
12 EHP 4030 STP.250 "Inspection of Ice Condenser Flow Passages,"
Rebision 1.
12 EHP 4030 STP.211 "Ice Condenser Surveillance," Revision 2.
12 EHP 4030 STP.212 "Ice Condenser Basket Inspection," Revision 0.
12 EHP 4030 STP.207 "Ice Condenser Lower Inlet Doors," Revision 0.
12 EHP 4030 STP.245 "Inspection of Ice Condenser Intermediate Deck Doors," Revision 0.
12 EHP 4030 STP.246 "Inspection of Ice Condenser Floor Drain Valves," Revision 0.
12 THP 6020 CHM.106 "IceCondenser," Revision 0.
Probl
or
nditi n
ort
PR-87-0163- Bay 11 intermediate deck door inoperable due to ice.
PR-87-0176- More than 3/8 inch of ice was found on ice condenser structure in bay 1 and bay
11 rows 8 and 9.
PR-87-0465- In Unit 2 upper containment ice condenser,
two center intermediate deck doors
were frozen shut by accumulated
ice.
PR-87-0466- The intermediate deck doors between air handler units 42A, 43A, 42B, and 43B
were found frozen shut by ice'uildup.
PR-87-0467- Start of ice build-up on Unit 1 ice condenser doors.
PR-87-0804- More than 3/8 inch of ice/frost was found in the ice bed in rows
1 and 9 bays
3,4,8,11 and 17 during flow passage
inspection.
PR-88-0146- During testing of Unit 1 ice condenser intermediate deck doors, 7 of 192 doors
failed to meet the opening acceptance
criteria.
PR-88-0215- More than 3/8 inch of ice/frost was found in bay 4 between rows
1 and 2 baskets.
PR-88-0427- The chemical sections current practice is to analyze an individual sample on a
weekly basis, combining of the samples isn't performed as required by technical specifications.
PR-88-0624- 12 THP 4030 STP.207 did not have proper documentation for declaring the ice
condenser inoperable during the testing of the lower inlet doors.
PR-88-0902- Chemical analysis on the ice condenser indicated that the boron concentration
was below the TS limits.
PR-88-0914- Several ice condenser baskets have webbing damage.
PR-89-0458- Damage to ice condenser baskets caused by ice basket weighing.
PR-89-0908- An ice basket in bay 21 has PH and boron concentration below TS.
PR-89-1 239- Inadequate procedure guidance in 12 THP 4030 STP.211 ice condenser
surveillance.
The maximum basket weight was in error.
PR-89-1368- 6/1 3/86 memorandum incorrectly stated the maximum ice basket weight limit.
PR-90-0313- Loose chunk of ice found on one flow passage.
PR-90-0817- Ice condenser lower inlet doors blew open.
. PR-90-0979- Ice condenser divider barrier seal had numerous cracks.
PR-90-1016- Discrepancy with plant drawings and FSAR concerning installation of ice
condenser divider barrier seals.
PR-90-1 326- Five Unit 1 intermediate deck doors stuck shut.
35
4-'
4'
1z
PR-90-1639- Broken U-bolt and missing nuts in Unit 1 and 2 ice condensers.
PR-90-2064- Ice condenser bed inoperable due to maximum bed temperature above 27
degrees.
PR-91-0171- Lower 95 percent confidence limitof boron concentration less than TS.
PR-91-'0257- Unit 2 ice condenser bed inoperable due to bed temperature above 27 degrees.
PR-91-0330- Flow path bypassing the ice condenser bed would exist during accident.
PR-91-0745- Unit 2 ice condenser intermediate deck doors frozen shut.
PR-91-1206- Areas not inspected for flow blockage during TS surveillance.
PR-92-0360- Two ice baskets found in Unit 2 missing U-bolt nuts.
PR-92-1181- Unit 1 ice basket bottom cross bar displaced into basket bottom on four baskets.
PR-92-1386- Ice condenser basket U-bolt nuts missing or loose.
CR-93-0488- Ice condenser intermediate deck door 4A frozen shut.
CR-93-0524- Ice condenser intermediate deck door frozen shut.
CR-93-1242- Five intermediate deck doors frozen shut.
CR-94-0075- Intermediate deck door frozen shut.
CR-94-0398- Unit 1 debris in ice baskets and basket ligament damage.
CR-94-0427- Five ice baskets exceeded
maximum allowed weight.
CR-94-0744- Ice condenser intermediate deck door 8B failed surveillance test.
CR-94-1825- Debris found in ice condenser floor drains.
CR-94-1894- Calibration documentation not available for ice basket weighing.
CR-94-1902- Three ice baskets exceeded
maximum allowed weight.
CR-95-1482- Debris found in ice condenser floor drain.
CR-95-1666- Ice basket retainer beam unsecured.
CR-96-0253- Ice condenser intermediate deck door 9A failed surveillance test.
CR-96-0355- Debris fell into ice basket.
CR-96-0708- Extra displaced cruciforms found in bottom of ice baskets.
CR-96-0875- Two intermediate deck doors frozen over.
CR-96-1611- Ice buildup behind plexiglass.
CR-96-2114- Loose tape on ice condenser top deck doors.
CR-97-0370- Debris found in ice condenser.
CR-97-0554- Three feet of ice basket separated
during weighing.
CR-97-2010- Unit 2 ice condenser top deck doors inoperable due to blockage by maintenance
equipment.
CR-97-2569- Ice condenser stage working fluid not in accordance with FSAR.
CR-97-2655- Duct tape inside ice condenser.
CR-97-2730- Discrepancy between FSAR and TS value for boron concentration.
CR-97-2806- Gray duct tape in the Unit 2 ice condenser.
CR-97-3244- Damaged Unit 2 ice basket had missing screws in bottom rim.
CR-97-3423- Intermediate deck doors 9A and 20B failed to meet acceptance
criterion.
CR-98-0076- Intermediate deck door 19G failed acceptance
criterion.
CR-98-0077- Debris found in upper ice condenser.
CR-98-0126- Damaged lower inlet door shock absorbers.
CR-98-0268- Gray duct tape found in Unit 2 lower ice condenser.
CR-98-0306- Four ice basket screw heads found in ice melt system filter.
CR-98-0357- Loose tape on ice condenser top deck doors.
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02-MM-032- Repair damaged Unit 2 ice basket 2-3-8.
01-MM-048 - Repair of eight damaged Unit 1 ice baskets.
12-PM-299 - Modify piping on boron solution pump.
RFC-DC-12-762 - Add valve and drain line for air handling units.
RFC-DC-12-943 - Lower ice condenser door seal test.
RFC-DC-01-1272 - Install foam strip to lower ice condenser inlet doors.
RFC-DC-12-1478 - Replace ice condenser door seals.
RFC-DC-12-1576 - Modifyice condenser lower access door.
RFC-DC-12-1670 - Replace ice condenser glycol valves.
RFC-DC-12-1702- Replace ice condenser lower door frame plate.
RFC-DC-01-1762 - Replace lower ice condenser door adjustment spring.
RFC-DC-12-4049 - Replace fabric on ice condenser deck doors.
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WCAP - 8304 "Stress and Structural Analysis and Testing of Ice Baskets," dated May 1974.
WCAP - 8887."Ice Basket Stress Analysis - D.C. Cook," dated March 1977.
WCAP-11902 "Reduced Temperature and Pressure Operation for Donald C. Cook Nuclear
Plant Unit 1 Licensing Report," dated October 1988.
Westinghouse letter "Indiana Michigan Power D.C. Cook Nuclear Power Plant Ice Condenser
Seismic Load Study New Ice Basket Design," dated February 28, 1990.
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