ML17335A134
| ML17335A134 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 07/30/1998 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Sampson J AMERICAN ELECTRIC POWER CO., INC. |
| References | |
| NUDOCS 9808050011 | |
| Download: ML17335A134 (10) | |
Text
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~o NUCLEAR REGULATORYCOMMISSION REGION III 801 WARRENVILLEROAD LISLE, ILLINOIS605324351 July 30, 1998
'Mr. John Sampson Site Vice President Nuclear Generation Group American Electric Power Company.
500 Circle Drive Buchanan, Ml 49107-1395
SUBJECT:
'RC OVERSIGHT PANEL FOR THE DONALDC. COOK PLANT Dear Mr. Sampson This letter is to inform you of actions being taken by the NRC to provide focussed and coordinated regulatory oversight of the Donald C. Cook Nuclear Plant as a result of the number of recently identified issues requiring resolution prior to restart of the Cook Plant.
On March 19, 1998, the NRC issued the Systematic Assessment of Licensee Performance (SALP) report documenting our assessment of your performance.
The SALP report indicated that performance in the area of Engineering declined..You have acknowledged and are taking steps to resolve the'roblems discussed at the meeting and in the report.
In response to findings of an NRC architect/engineering inspection and to fibrous material found inside containment, a Confirmatory Action Letter was issued on September 19, 1997. The Confirmatory Action Letter described nine technical issues requiring corrective actions and an assessment Cook Plant would perform to determine ifthe engineering deficiencies affected system operability or existed in other safety-related systems.
Several public meetings were held in December 1997,and January 1998 to discuss the corrective actions and progress on the short-term engineering assessment.
Investigation of the magnitude and safety significance of these problems led to an extended plant shutdown, and has required significant corrective actions to address identified safety system and engineering program deficiencies.
While the nine technical issues have been addressed, the Confirmatory Action Letter remains open pending the completion of the short-term assessment program.
An NRC inspection of the ice condenser system identified a number of material condition and design deficiencies that challenged the operability of the ice condenser.
Your staffs evaluation and the NRC inspection findings, combined with the identification of trash and debris located throughout the ice condenser, resulted in your declaring both Unit 1 and Unit 2 ice condensers inoperable.
To ensure that the ice condensers are properly restored to their original design specifications, we acknowledge senior plant management's decision to de-ice Unit 1 and Unit 2 ice condensers and make extensive repairs.
This action willextend the dual unit shutdown for several months.
CII80805001i 980730 PDR ADQCK 050003i5' PDR
J. Sampson To address the above and other issues, American Electric Power management has initiated or completed a number of corrective actions.
A Restart Plan has been implemented requiring plant management review and evaluation of restart issues and other items developed from safety system watkdowns.
As you know, a Manual Chapter 0350 panel has been established for the Donald C. Cook plant consisting of regional and headquarters personnel.
The panel continues to review information related to plant performance and is evaluating the effectiveness of your corrective actions.
As you are aware, the NRC intends to continue to have periodic meetings with American Electric Power and plant management, as appropriate, to discuss progress toward resolving those issues necessary for plant startup.
Two meetings have been held, and meeting summaries have been issued documenting the meeting results.
These meetings willcontinue to be open to the public.
As a part of the actions derived from your startup plan, two Technical Specification changes have been submitted for NRC review. As we discussed during the last public 0350 meeting, the NRC willneed prompt notification of any additional licensing actions to ensure that they can be processed, ifnecessary, prior to plant startup.
Enclosure 1 includes the Case Specific Checklist for the Donald C. Cook Nuclear Power Plant.
The checklist specifies activities the NRC considers necessary to be addressed prior to restart.
These items were derived from the NRC's review of inspection activities including the Confirmatory Action Letter and Architect Engineering followup inspections, the Ice Condenser and Fibrous Material inspections, and the corrective actions used to formulate your startup plan.
The checklist willperiodically be revised to reflect changes in plant performance noted by the NRC's Oversight Panel.
The NRC willmonitor your performance in these areas. includes a summary on the status of implementing NRC Inspection Manual Chapter 0350, "Staff Guidelines for Restart Approval." Enclosure 2 also contains a line item to address the response to and closure of the concerns expressed by the petitioner in an October 9, 1997, 10 CFR 2.206 petition. Enclosure 2 willalso be periodically revised to reflect closure of items and changes to plant performance noted by the NRC's Oversight Panel.
The NRC may take other actions deemed necessary to ensure adequate NRC oversight of activities at the Donald C. Cook Nuclear Plant. Ifyou have questions regarding the NRC actions discussed above, please contact Mr. Bruce Burgess at 630/829-9629 or me at 630/829-9700.
J. Sampson 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.
Sincerely,
/s/John A. Grobe Docket Nos.: 50-315; 50-316 License Nos.:
DPR-58; DPR-74 John A. Grobe, Director Division of Reactor Safety
Enclosures:
1.
Case Specific Checklist 2.
Guidelines for Restart Approval ccw/o encls:
R. Eckstein, Chief Nuclear Engineer D. Cooper, Plant Manager R. Whale, Michigan Public Service Commission Michigan Department of Environmental Quality Emergency Management Division, Ml Department of State Police D. Lochbaum, Union of Concerned Scientists To receive o copy of thle document, indlcete In th N
a No co o
C
~ Copy without ettechment/encloeure E
DOCUMENT NAME: G:>cook>0350 r2.dcc I
py with ettechment/enclocure OFFICE NAME DATE Rill Burges 07 98 Rill Grobe 07/@98 NRR
/
Bella 07 8
OFFICIALRECORD COPY
J. Sampson Distribution RRB1 (E-Mail)
Project Mgr., NRR w/encls C. Paperiello, Rill w/encls J. Caldwell, Rillw/encls B. Clayton, Rill w/encls SRI DC Cook w/encls DRP w/encls TSS w/encls DRS (2) w/encls Rill PRR w/encls y: PUBLIC IB@f-w/encls Docket File w/encls GREENS DOCDESK (E-Mail)
ENCLOSURE 1 CASE SPECIFIC CHECKLIST ITEM NUMBER SOURCE DOCUMENT ro rammatic Issues STATUS 1.
Programmatic Breakdovm In Surveillance Testing 2.
Corrective Action Program Breakdovm Programmatic Breakdovm in the Maintenance of the Design Basis Safety Evaluations:
Failure to perform and inadequate evaluations S.
Operator Training Issues NRC Inspection Reports 315/97017, 315/98004, 98005, 98007, Ucensee Event Reports 315/9804, 05, 06, 07, 08, 10, 15, and 17; 316/98004 NRC Inspection Reports 315/97017, 97201 315/98004, 98005, Ucensee Event Reports 315/9844, 05, 06, 07, 08, 10, 15, and 17; 316/98-04 NRC Inspection Reports 315/97017, 97201 315/98004, 98005, Ucensee Event Reports 315/98004, 05, 06, 07, 08, 10, 15, and 17; 316/98004 NRC Inspection Reports 315/97017 and 98004 NRC Inspection Reports 315/98305.OL Open Open Open Open Open S
tern S ecifiic Issues 6.
Resolution of Ice Condenser Issues 7.
Resolution of Non<afety Related Cables Going To Shunt Trip Coils.
Resolution of Hydrogen Recombiner Operability Issues 9.
Resolution of Distributed Ignition Technical Specification Issue 10.
Resolution of Containment Spray System Operability Issues 11.
Resolution of Hydrogen Mitlgafion System Operability and Material Condition Issues 12.
Resolution of Containment Liner Pitting NRC Inspection Report 315/98005 Ucensee Event Report 315/98-16.
Licensee Item Number 2,031 NRC Inspection Report 315/98007, Licensee Event Reports 315/9849, and 19.
NRC Inspection Report 315/98007.
Ucensee Event Report 315/98-22, Ucensee Containment Spray System Assessment.
'Ucensee Event Reports 315/98%1, and 316/97-09.
Licensee Event Report 315/98%1.
estart Plan Open Open Open Open Open Open Open 13.
Systems and Containment Readiness Assessments Ucensee's Restart Plan Open 14.
Programmatic Readiness Assessments Ucensee's Restart Plari Open 15.
Functional Area Readiness Assessments Ucensee's Restart Plan Open
ENCLOSURE 2 D.C. COOK 0350 GUlDELINES FOR RESTART APPROVAL ITEM NUMBER STATUS (Open/Close) b.
C.1.1 Root Cause Determination Potential Root causes of the conditions requiring the shutdown and any associated problems were thoroughly evaluated The scope of the analysis considered the applicability of related issues on similar systems, structures, components, procedures, processes, or activities at their own and other industry facilities in an attempt to identify trends or generic industry concerns.
Rationale for rejecting potential root causes was clearly defined and documented for all root causes evaluated.
Open Open Open f.
The licensee's rationale for terminating the root cause and causal factors analyses was based on a documented process that provides a reasonable basis for all conclusions reached.
g..
The population of potential root causes and their respective evaluations have been independently reviewed by the licensee's oversight committee.
Open Open h.
C.1.2. Corrective Action Development The proposed corrective actions are clearly cross-referenced to all of the associated root causes and causal factors they are intended to correct, as appropriate Each of the corrective actions is assigned an appropriate priority based on safety significance to ensure the proper resources and attention are devoted.
Proposed corrective actions identify the desired conditions to be achieved and are adequate to preclude repetition.
Corrective actions are sufficiently detailed to ensure that all activities related to completion of the corrective action have been identified (i.e., procedure or drawing changes, Technical Specification changes, etc.).
Corrective actions include restoring systems and equipment to service and verifying they can perform their intended safety functions through post maintenance or post, modification testing.
The licensee performed safety evaluations to ensure that corrective actions (e.g., procedure changes or modifications) did not result in a loss of safety margin.
The licensee adhered to applicable industry codes and standards during the development and analysis of corrective actions.
The licensee expanded the scope of the corrective actions to consider all of the causal factors that contributed to the deficiency or problem, including potential generic concerns.
Open Open Open Open Open Open Open Open
Development of the corrective actions included insights from the organizations or individuals that may have contributed to the event, those responsible for developing the corrective actions, and those responsible for implementing the corrective actions.
Interim corrective actions have been developed and documented when permanent corrective action willtake an excessive amount of time to implement or cannot be completed before the licensee plans to restart the facility.
Allcorrective actions have been incorporated into a comprehensive corrective action plan, which has been approved by the licensee's independent oversight committee.
Open Open Open C.1.3 Corrective Action Plan Implementation and Effectiveness Each of the corrective actions is assigned a required start and completion date commensurate with the complexity and safety significance of the action.
An organization,and individual have been designated with lead responsibility for each of the corrective actions.
The responsible individual has sufficient authority, resources, and management support to ensure the action willbe adequately completed.
The licensees has defined objectives to be achieved from implementing the corrective action plan, including interim objectives to assess the progress of the plan. The
.objectives are focused on ensuring a lasting improvement in the operation and maintenance of the plant.
Whenever possible, the licensee's objectives are based on a measurable set of criteria that the licensee can readily track and trend, as appropriate, to provide continuous monitoring of the implementation and effectiveness of the corrective action plan.
These measures should form the acceptance criteria for closure and provide precursor indication 'of declining performance.
The licensee has anticipated and addressed potential conflicts of implementing the corrective action plan with existing facilityoperational (maintenance, engineering, etc.)
practices, regulatory requirements, or personnel activities.
The corrective action plan contains guidance for the licensee to assess changing information or conditions to determine whether the licensee must modify the corrective action plan.
The licensee has developed training on both the lessons learned from, the event analysis and root cause determination and the technical and administrative changes made to the facilities or practices that includes a discussion regarding why the changes are necessary.
The corrective action plan includes requirements to have self-assessments, and as necessary independent assessments, of the implementation and effectiveness of the plan.
In cases where long term actions remain to be accomplished, the licensee has clearly documented when the action willbe complete, the basis for the delay in completing the actions, and how the action will be tracked and trended to ensure completion.
II Open Open Open Open.
Open Open Open Open Open Open
k.
The licensee has established a predefined time frame following completion of the corrective actions during which they willcontinue to monitor the effectiveness of the corrective actions.
Open C.2.1. Self-Assessment Capability a.
Effectiveness of Quality Assurance Program.
c.
Effectiveness of licensee's Independent Review Groups.
d.
Effectiveness of licensee's Independent Review Groups.
Open Open Open C.3.1. Assessment of Staff a.
Demonstrated commitment to achieving improved performance through the results of the programmatic readiness assessment.
d.
Understanding of plant issues and corrective actions.
Open Open C.3.2 Assessment of Corporate Support a.
Demonstrated commitment to achieving improved performance through the results of the programmatic'readiness assessment.
e.
Effectiveness of corporate engineering support.
f.
Effectiveness of corporate design modification process.
g.
Effectiveness of licensing support.
Open Open Open Open C.3.3 Operator Issues Effectiveness of restart simulator/required training necessary to re-familiarize personnel with operating conditions.
Assessment of plant staff performance during restart.
Sustained control room observations by NRC personnel.
Open Open CA Assessment of Physical Readiness of the Plant a.
Operability of Technical Specification systems, specifically those with identified operational, design, and maintenance issues.
b.
Operability of required secondary and support systems.
c.
Results of pre-startup testing.
d.
Adequacy of system lineups.
e.
Adequacy of surveillance tests/test program.
f.
Significant hardware issues resolved (i.e., equipment with poor material condition, equipment ageing, modifications).
Open Open Open Open Open Open
g.
Adequacy of the power ascension testing program.
h.
Effectiveness of the plant maintenance program.
I.
Maintenance backlog managed and impact on operation assessed.
j.
Adequacy of plant housekeeping and equipment storage.
Open Open Open Open C.5 Assessment of Compliance with Regulatory Requirements a.
Applicable license amendments have been issued.
b.
Applicable exemptions have been granted.
c.
Applicable'reliefs have been granted.
d.
Imposed Orders have been modified or rescinded.
e.
Confirmatory Action Letter conditions have been satisfied.
f.
Significant enforcement issues have been resolved.
g.
Allegations have been appropriately addressed.
h.
10 CFR 2.206 Petitions have been appropriately addressed.
Open Open Open Open Open Open Open Open C.6 Coordination With interested Agencies And Parities e.
Appropriate State and local Officials f.
Appropriate public interest groups g.
Local net media Open Open Open