ML17334B768
| ML17334B768 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 05/07/1998 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Fitzpatrick E AMERICAN ELECTRIC POWER CO., INC. |
| Shared Package | |
| ML17334B769 | List: |
| References | |
| 50-315-98-09, 50-315-98-9, 50-316-98-09, 50-316-98-9, EA-98-150, EA-98-151, EA-98-152, EA-98-186, NUDOCS 9805190010 | |
| Download: ML17334B768 (11) | |
See also: IR 05000315/1998009
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
SUBJECT: Forwards insp repts 50-315/98-09
&. 50-316/98-09.Fifteen
violations being considered for escalated
enforcement
action.
.CATEGORY 2e
'I
CCESSION NBR:9805190010
DOC.DATE: 98/05/07
NOTARIZED: NO
FACIL:50-315 Donald C.
Cook Nuclear Power Plant, Unit 1, Indiana
50-316 Donald C.
Cook Nuclear Power Plant, Unit 2, Indiana
AUTH.NAME
AUTHOR AFFILIATION
GROBE,J.A.
Region
3
(Post
820201)
RECIP.NAME
RECIPIENT AFFILIATION
FITZPATRICK,E.
American Electric Power Co., Inc.
DOCKET ¹
M
05000315
M
05000316
DISTRIBUTION CODE: IE01F
COPIES
RECEIVED:LTR
ENCL
SIZE:
. TITLE: General
(50 Dkt)-Insp Rept/Notice of Violation Response
NOTES:
RECIPIENT
ID CODE/NAME
PD3-3
INTERNAL: AEOD/SPD/RAB
DEDRO
NRR/DRCH/HHFB
NRR/DRPM/PERB
OE DIR
RGN3
FILE
01
COPIES
LTTR ENCL
1
1
1
1
1
1
1
1
1
1
1
1
1
'
RECIPIENT
ID CODE/NAME
STANG, J
LE CENTE
PECB
NUDOCS-ABSTRACT
OGC/HDS3
COPIES
LTTR ENCL
1
1
1
1
1
1
1
1
1
1
1
1
0
R
TERNAL: LITCO BRYCE,J H
NRC PDR
1
1
1
1
NOAC
NUDOCS FULLTEZT
1
1
1
1
D
0
"~gg gpo pgoQ
~CC PgOPPV
a
M
E
N
NOTE TO ALL "RZDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRZBUTZON LZSTS
OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL
DESK
(DCD)
ON EXTENSION 415-2083
TOTAL NUMBER OF COPIES
REQUIRED:
LTTR
17
ENCL
17
a
II
May 7,
1998
EA Nos.98-150; 98-151;98-152; 98-186
Mr. E. E. Fitzpatrick
Executive Vice President
Nuclear Generation Group
American Electric Power Company
500 Circle Drive
Buchanan, Ml 49107-1395
SUBJECT:
NRC INSPECTION REPORT NO. 50-315/98009(DRS); 50-316/98009(DRS)
Dear Mr. Fitzpatrick:
.On April 15, 1998, the NRC completed an inspection at your D. C. Cook, Units 1 and 2 reactor
facilities. The purpose of this inspection was to determine the safety significance and
regulatory impact of 34 concerns identified during the 1997 Architectural and Engineering (AE)
inspection (50-315/97201; 50-316/97201).
The enclosed report presents the results of this
inspection.
Based on the results of this inspection, 15 apparent violations were identiTied and are being
considered for escalated enforcement action in accordance with the "General Statement of
Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600.
These apparent violations are grouped into three programmatic areas:
design control, 10 CFR 50.59 safety evaluations, and corrective actions.
Eight apparent violations of 10 CFR 50, Appendix B, Criterion III, "Design Control," were
identified. Specifically, three engineering calculations were not adequately verified or checked.
Two of these examples pertained to refueling water storage tank (RWST) level measurement
biases and instrument measurement
uncertainties not being accounted for in the development
of the RWST low and low-low level setpoints.
The third example involved the containment
sump level post-accident instrument uncertainties.
In addition, five examples were identified
where the plant design basis was not correctly translated into specifications, drawings,
procedures, and instructions.
Three of these examples pertained to the containment
recirculation sump design basis.
For example, the sump water volume requirement lacked
documentation to demonstrate that sufficient water was available to prevent air entrainment in
the emergency core cooling and containment spray pumps, the sump roof% inch vent hole
installation commitment was not incorporated into the safety analysis report, and the sump
/. inch particulate retention requirement was not maintained.
The fourth example involved a
calculated component cooling water (CCW) flowvalue that exceeded the Updated Final Safety
Analysis Report (UFSAR) design value. The fifth example involved an RWST Appendix R
volume requirement that was not incorporated in a shutdown risk procedure.
Collectively, these
apparent violations represent a programmatic breakdown in the maintenance and control of
facilitydesign.
98051900i0
980507
ADQCK 05000315
8
E. Fitzpatrick
Six apparent violations of 10 CFR 50.59, "Changes, Tests and Experiments," were identified
where inadequate safety evaluations were performed.
Several safety evaluations inadequately
addressed
system operations that were outside UFSAR stated design values.
For example, the
units were operated above the ultimate heat sink (lake) temperature value, the CCW system
design temperature value was exceeded,
the units were operated with less than the stated
reactor coolant pump thermal barrier CCW flowvalue, and the spent fuel pool time-to-boil
margin was reduced during a dual train CCW and emergency service water outage.
In addition,
the safety evaluation for changes to emergency operating procedure Nos. 01(02)-OHP
4023.ES-1.3, "Transfer to Cold Leg Recirculation," failed to identify that the changes created a
single failure vulnerability. Collectively, these apparent violations represent a programmatic
breakdown in the implementation of the safety evaluation process to identify unreviewed safety
questions.
One apparent violation of 10 CFR 50, Appendix B, Criterion XVI,"Corrective Action," was
identified. The control room temperature evaluation calculation identified in 1990 that high
emergency service water (lake) temperatures would reduce the qualified life of control room
components needed for plant shutdown, however, this condition had not been appropriately
evaluated.
No Notice of Violation is presently being issued for these apparent violations.
In addition, be
advised that the number and characterization of the apparent violations described in the
enclosed inspection report may change as a result of further NRC review.
An open predecisional enforcement conference to discuss these apparent violations has been
scheduled for May 20, 1998. The decision to hold a predecisional enforcement conference
does not mean that the NRC has determined that violations occurred or that enforcement action
will be taken.
This conference willbe held to obtain information to enable the NRC to make an
enforcement decision, such as a common understanding of the facts, root causes,
missed
opportunities to identify the apparent violations sooner, corrective actions, significance of the
issues, and the need for lasting and effective corrective action.
In addition, this is an
opportunity for you to provide any information concerning your perspectives on:
1) the severity
of the violations, 2) the application of the factors that the NRC considers when it determines the
amount of a civil penalty that may be assessed
in accordance with Section VI.B.2 of the
Enforcement Policy, and 3) any other application of the Enforcement Policy to this case,
including the exercise of discretion in accordance with Section Vll.
The remaining nineteen AE team identified unresolved items appear to be violations of NRC
requirements.
However, it appears that the actions necessary to correct these issues would be
similar to planned or completed actions that you willdiscuss during the scheduled predecisional
enforcement conference.
Therefore, no Notice of Violation is presently being issued for these
violations.
I
E. Fitzpatrick
You will be advised by separate correspondence
of the results of our deliberations on this
matter.
No response regarding these apparent violations is required at this time.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure willbe placed in the NRC Public Document Room.
We willgladly discuss any questions you have concerning this inspection.
Sincerely,
original /s/ J. A. Grobe
John A. Grobe, Director
Division of Reactor Safety
Docket Nos.
50-315, 50-316
Enclosure:
Inspection Report Nos. 50-315/98009(DRS);
50-316/98009(DRS)
cc w/encl:
John Sampson, Site Vice
President
A. A. Blind, Vice President
Nuclear Engineering
Douglas Cooper, Plant Manager
Richard Whale, Michigan Public
Service Commission
Michigan Department of
Environmental Quality
Emergency Management
Division, Ml Department
of State Police
DOCUMENT NAME: g:hdrsttdcc98009.drs
(See Previous Concurrence)
To recshre a co
of this document, Indicate In the boxt 'C'
without atlachmenVendosure'E'
with attachment/endosure'N'
No
OFFICE
Rill:DRS
NAME
DButler:sd
DATE
05/
/98r
RIII:DRS'
RIII:
S
RGardner
BB
s
05/ T/98
t 05/
/98
RIII:DRS
BClayton
05/
/98
Rill
JGr
05/
OFFICIALRECORD COPY
fi,
lu
~
E. Fitzpatrick
a common understanding of the facts, root causes,
missed opportunities to identify the
'pparent
violations sooner, corrective actions, significance of the issues, and the need for
lasting and effective corrective action.
In addition, this is an opportunity for you to provide any
information concerning your perspectives on: 1) the severity of the violations, 2) the application
of the factors that the NRC considers when it determines the amount of a civil penalty that may
be assessed
in accordance with Section VI.B.2 of the Enforcement Policy, and 3) any other
application of the Enforcement Policy to this case, including the exercise of discretion in
accordance with Section Vll.
You will be advised by separate correspondence
of the results of our deliberations on this
matter.
No response
regarding these apparent violations is required at this time.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its
enclosures willbe placed in the NRC Public Document Room.
We willgladly discuss any questions you have concerning this inspection.
Sincerely,
John A. Grobe, Director
Division of Reactor Safety
Docket Nos.: 50-315, 50-316
Enclosure:
Inspection Report Nos. 50-315/98009(DRS);
50-316/98009(DRS)
cc w/encl:
John Sampson, Site Vice
President
A. A. Blind, Vice President
Nuclear Engineering
Douglas Cooper, Plant Manager
Richard Whale, Michigan Public
Service Commission
Michigan Department of
Environmental Quality
, Emergency Management
Division, MI Department
of State Police
DOCUMENT NAME: g:hdrsltdcc98009.drs
TO reoehre a COO
Of thle dOCument. tndteate In the bOtu 'C'
WithcutattaChment/Cnotceure'P
u
With anaohment/Cnotccure
'N ~ NO
OFFICE
Rill
E Rill
Rill
Rill
Rill
NAME
DButler:sd
DATE
05/+/98
RGardneri9i"
05/
/98
BB
ess
05/
/98
BCI
05/
/9
JGrobe
05/
/98
OFF/CIAL RECORD COPY
E. Fitzpatrick
g)~r'~ti
J. Lieberman, OE w/encl
J. Goldberg, OGC w/encl
B. Boger, NRR w/encl
Project Mgr., NRR w/encl
A. Beach w/encl
J. Caldwell w/encl
B. Clayton w/encl
DRP w/encl
TSS w/encl
DRS w/encl
Rill PRR w/encl
PUBLIC IE-01 w/encl
Docket File w/encl
GREENS
IEO (E-Mail)
DOCDESK (E-Mail)
il
II