ML17335A299
| ML17335A299 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 10/13/1998 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Powers R AMERICAN ELECTRIC POWER CO., INC. |
| References | |
| GL-89-10, NUDOCS 9810200334 | |
| Download: ML17335A299 (17) | |
Text
October 13, 1998 Mr. R. P. Powers Senior Vice President Nuclear Generation Group American Electric Power Company 500 Circle Drive Buchanan, Ml 49107-1395
SUBJECT:
CASE SPECIFIC CHECKLIST UPDATE FOR THE DONALDC. COOK PLANT
Dear Mr. Powers:
This letter is to inform you of actions being taken by the NRC to change the Case Specific Checklist for the Donald C. Cook Nuclear Power Plant which identified specific issues requiring resolution prior to restart of the Cook Plant. 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. A recent NRC inspection has identified unsatisfactory progress in your Generic Letter 89-10 Program pertaining to operability of motor operated valves.
SpeciTically, in excess of 40 safety related valves were identified by your staff as potentially inoperable.
Therefore, the 0350 panel has concluded that this item must be resolved prior to restart of Unit 1. The operability of motor operated valves in your GL 89-10 program has been included in the revised Case Specific Checklist of Enclosure 1. includes a summary on the status of implementing NRC Inspection Manual Chapter 0350, "Staff Guidelines for Restart Approval." Enclosure 2 remains unchanged at this time but may also 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.
98i0200334 98iOi3 PDR ADQCK 050003i5 P
R. Powers 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, Origina1 Signed by John A. Grobe John A. Grobe, Director Division of Reactor Safety Docket Nos.: 50-315; 50-316 License Nos.: DPR-58; DPR-74
Enclosures:
1.
Case Specific Checklist 2.
Guidelines for Restart Approval cc w/encl:
J. Sampson, Site Vice President 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 DOCUMENT NAME: G:ADRS(DCC10098.WPD To receive a copy of this document, indicate in the box C
~ Copy without attachment/enciosure E
Copy with attachment/enclosure N
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R. Powers Distribution:
RRB1 (E-Mail)
RPC (E-Mail)
Project Mgr., NRR w/encl J. Caldwell, Rillw/encl C. Pederson, Rillw/encl B. Clayton, Rill w/encl SRI DC Cook w/encl DRP w/encl TSS w/encl DRS (2) w/encl Rill PRR w/encl PUBLIC IEZ1 w/encl Docket File w/encl GREENS IEO (E-Mail)
DOCDESK (E-Mail)
ENCLOSURE 1 CASE SPECIFIC CHECKLIST ITEM NUMBER DESCRIPTION SOURCE DOCUMENTS STATUS 1A 1B 1C 1D 1E 2B Programmatic Breakdovm in Surveillance Testing Inadequate instructions in surveillance tests.
Acceptance criterion lack sufficlent margin to analysts limit.
Failure to meet technical specification requirements Preconditioning of equipment prior to surveillance testing.
Failure to assess and control the quality of contractors performing surveillance testing, Corrective Action Program Breakdown Failure to promptly identify and evaluate conditions adverse to quality.
inadequate corrective actions for previously Identified conditions adverse to quality.
IR 98004,5,7,9 and 97017 IR 98005 IR 98005,7 and LER 9801541 IR 98007 IR 98005 IR 98005 IR 98004,5,9 and 97017 LERs 98010, 98017 Open Open Open Open Open Open Open Programmatic Breakdown in the Maintenance ofthe Design Basis 3A 3B 3C 3D 4A 4B Inadequate design control pertaining to uncontrolled and/or unintended changes in the plant design.
Failure to update the Final Safety Evaluation Report.
Failure to consider instrument uncertainties, setpoints and/or instrument blas.
Inadequate consideration for system/component failure modes.
Safety Evaluations Failure to'perform safety evaluations or safety evaluation screenings.
Inadequate safety evaluations Operator Training Issues IR 98004,5,7,9 and 97017 IR 98005 IR 98009 IR 98009 IR 98004,7 IR 98004,9 Open Open Open Open Open Open
ITEM NUMBER 5A 5B SC 5D 10 16 DESCRIPTION Training staff ability to develop technically accurate examination material in accordance with examination guidelines was considered poor.
Operator ability to determine the correct Protective AcUon RecommendaUons forthe emergency event wasin quesUon.
High failure rate for the operator examinations Indicated that the applicants were not well prepared.
Applicant abilities to communicate and diagnose events, during the dynamic simulator scenarios was considered weak.
Resolution of Ice Condenser Issues ResoluUon of Non-Safety Related Cables Going to Shunt Trip Coils Resolution of Hydrogen Recombiner Operability Issues Resolution of Distributed IgniUon Technical SpeciflcaUon Issue ResoluUon of Containment Spray System Operability Issues Resolution of Hydrogen MiUgaVon System Operability and Materiel Condition Issues Resolution of Containment Uner Pitting Resolution of operability of motor operated valves in the GL 89-10 Program SOURCE DOCUMENTS IR 97305 IR 97305 IR 97305 IR 97305 F. tR~ei4Ãi IR 98005 LERs 98004, 5,6,7,8,10,15,17,24,2 5,26,32,35 LER 98016 IR 98007 LER 98009, 98019 IR 98007 LER 98022 IR 98007 LER 98001 LER 98011 CR 98-2246, 3555 &
3920 STATUS Open Open Open Open Open Open Open Open Open Open Open 13 14 15 L4&gZ(kSfPN4'4XN~~Y&ii)RiN'E~A~ ~~
Systems and Containment Readiness Assessments ProgrammaUc Readiness Assessment Functional Area Readiness Assessment Licensee's Restart Open Plan Licensee's Restart Open Plan Licensee's Restart Open Plan IR -
Inspection Report CR - Condition Report GL - Generic Letter LER - Licensee Event Report
ENCLOSURE 2 D.C. COOK 0350 GUIDELINES FOR RESTART APPROVAL b.
ITEM NUMBER C.1.1 Root Cause Determination Potential Root causes of the conditions requiring the shutdown and any associated problems were thoroughly evaluated STATUS (Open/Close)
Open c.
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.
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.
Open Open Open g.
The population of potential root causes and their respective evaluations have been independently reviewed by the licensee's oversight committee.
Open C.1.2. Corrective Action Development a.
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 b.
Each of the corrective actions is assigned an appropriate priority based on safety significance to ensure the proper resources and attention are devoted.
c.
Proposed corrective actions identify the desired conditions to be achieved and are adequate to preclude repetition.
d.
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 SpeciTication changes, etc.).
e.
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.
f.
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.
Open Open Open Open Open Open
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.
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 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.
Open Open Open Open Open Open Open Open
I
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 willbe tracked and trended to ensure completion.
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 Open 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.
~'pen 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 modiTication process.
g.
Effectiveness of licensing support.
Open Open Open Open C.3.3 Operator Issues d.
Effectiveness of restart simulator/required training necessary to re-familiarize personnel with operating conditions.
e.
Assessment of plant staff performance during restart.
Sustained control room observations by NRC personnel.
Open Open C.4 Assessment of Physical Readiness ofthe Plant a.
Operability of Technical Specification systems, specifically those with identified operational, design, and maintenance issues.
Open
.b.
e.
Operability of required secondary and support systems.
Results of pre-startup testing.
Adequacy of system lineups.
Adequacy of surveillance tests/test program.
Significant hardware issues resolved (i.e., equipment with poor material condition, equipment ageing, modifications).
Open Open Open Open Open g.
Adequacy of the power ascension testing program.
Effectiveness of the plant maintenance program.
Maintenance backlog managed and impact on operation assessed.
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 news media Open Open Open
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