ML17335A323
| ML17335A323 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 11/09/1998 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Powers R AMERICAN ELECTRIC POWER CO., INC. |
| Shared Package | |
| ML17335A324 | List: |
| References | |
| 50-315-96-12, 50-315-98-20, 50-316-96-12, 50-316-98-20, EA-98-509, GL-89-10, NUDOCS 9811130126 | |
| Download: ML17335A323 (6) | |
See also: IR 05000315/1998020
Text
CATEGORY 2
M
RIDS
DOCKET I
05000315
05000316
NOTES:
REGULATORY INFORMATION DISTRIBUTION SYSTE
(
)
7 ACCESSION NBR:9811130126
DOC.DATE
98/11/09
NOTARIZED: NO
CIL:50-315 Donald C.
Cook Nuclear Power Plant, Unit 1, Indiana
M
50-316 Donald C.
Cook Nuclear Power Plant, Unit 2, Indiana
M
UTH.NAME
AUTHOR AFFILIATION
GROBE,J.A.
Region
3
(Post
820201)
RECZP.NAME
RECIPIENT AFFILIATION
POWERS,R.P.
American Electric Power Co., Inc.
r
SUBJECT:
Forwards insp repts
50-315/98-20
S 50-316/98-20
on
980928-1002
& notice of enforcement discretion. Enforcement
discretion re failure to properly control
MOV calculations
&
effectively response
to industry info on valve performance'.4Z
TITLE: *General
(50 Dkt)-Insp Rept/Notice of Vio ation Response
RECIPIENT
ID CODE/NAME
PD3-3
COPIES
LTTR ENCL
1- .1
RECIPIENT
ID CODE/NAME
STANG, J
COPIES
LTTR ENCL
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INTERNAL: AEOD/SPD/RAB
DEDRO
NRR/DRCH/HOHB
NRR/DRPM/PERB
ME...DIR
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NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DZSTRZBUTION LISTS
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
November 9,
1998
EA 98-509
Mr. R. P. Powers
'enior Vice President
Nuclear Generation Group
American Electric Power Company
500 Circle Drive
Buchanan, Ml 49107-1395
SUBJECT:
NRC INSPECTION REPORT 50-315/98020(DRS); 50-316/98020(DRS) AND
NOTICE OF ENFORCEMENT DISCRETION
Dear Mr. Powers:
On October 2, 1998, the NRC completed a motor-operated valve (MOV) inspection at your
D. C. Cook. Units 1 and 2 reactor facilities. The purpose of the inspection effort was to
determine whether activities associated with Generic Letter (GL) 89-10, "Safety-Related Motor-
Operated Valve Testing and Surveillance," were sufficiently complete to recommend close-out of
the NRC's review of your MOV program.
The enclosed report presents the results of that
inspection.
, 'Areas examined during the inspection are identified in the'report.
Within these areas, the
inspection consisted of a selective examination of procedures and representative
records, and
interviews with personnel.
At the conclusion of the inspection, the findings were discussed with
you and members of your staff.
I
Even though some progress has been made over the past 2 years to complete your MOV
program, this inspection revealed that your MOV program was not sufficiently complete to close-
out the NRC's review of the actions taken in response to GL 89-10.
It was apparent that past
structural evaluations and developments in the area of MOVs were not adequately assessed,
resulting in a number of assumptions
in the design-basis MOVcalculations not being adequately
justified. This untimely assessment
resulted in MOVoperability issues and raised concerns
about the adequacy of the control of MOVcalculations.
Specifically, as a result of not
performing the structural weak link calculations as previously identified in Inspection Report
50-315/96012; 50-316/96012, 41 butterfly MOVs were initiallyidentified with possible structural
concerns.
Follow-up review by your staff resulted in 12 butterfly MOVs being declared
inoperable for not being able to meet their design continuous structural limit. This concern with
MOVcalculations was broader than the specified-12 MOVs as demonstrated
by the numerous
other potentially inoperable MOVs based on incorporation of recently published vendor
information, which had been known in the industry for several years, but your program did not
aggressively address this information prior to it becoming a operability concern.
The failure to properly control MOVcalculations and effectively respond to industry information
on valve performance resulted in violations of NRC requirements and represents
a significant
safety and regulatory concern.-However,
I have bebn authorized, after consultation with the
P8iii30i26
98ii09'DR
.ADOCK 050003i5
6
R..Powers
h,
Director, Office of Enforcement, and the Acting Regional Administrator, to exercise enforcement
discretion in accordance with Section VII.B.2, "Violations Identified During Extended Shutdowns
or Work Stoppages," of the uGerieral Statement of Policy and Procedures for NRC Enforcement
Actions (Enforcement Policy)," and not issue a Notice of Violation in this case.
The decision to
apply enforcement discretion was based on consideration of the following: (1) significant NRC
enforcement action (EAs98-150, 151, 152 8 186) has already been taken against the Indiana
Michigan Power Company for several programmatic breakdowns, including design control
issues; (2).the NRC has implemented NRC Manual Chapter 0350 (MC-0350), "Guidelines for
Restart Approval," at D. C. Cook to enhance oversight o4corrective actions and therefore
additional enforcement action is not considered necessary to achieve remedial action for the
violation due to Indiana and Michigan Power's commitment (MC-0350 restart check list item 16)
to address MOV issues prior to plant restart;-(3) the violation is related to a problem which was
present prior to the events leading to the shutdown; (4) the violation is not classified at a
Severity Level I; (5) the violation was not willful;and (6) through the MC-0350 process, NRC
approval of corrective actions, for those items defined to be within the scope of the process,
is
required prior to plant restart.
Prior.to close-out of NRC's review of the GL 89-10 program, the following three major areas will
require resolution: the 44 potentially inoperable MOVs, finalizing design-basis
calculations, and updating several program documents.
Issues requiring-further justiTication or
evaluation are identified throughout the inspection report. As discussed with your staff, NRC
review of your GL 89-10 program willrequire a subsequent
NRC inspection after the issues
identified during this inspection are adequately evaluated and resolved by your staff. This
closure of NRC review of your MOVprogram and any substantive issues revealed through your
self-assessment
has been listed in the NRC Manual Chapter 0350 Restart Panel's Case
Specific Checklist (Item 16).
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 No. 50-315/98020(DRS);
50-316/98020(DRS)
See Attached Distribution
DOCUMENT NAME: G:DRSiDCC98020.WPD
To recehre s co
of this document. Indlcste In the bord
t. ~
without sttschrnentlenctosure 'E'
withstts
trenctosure 'N ~ No
OFFICE
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OFFICIALRECORD COPY
R. Powers
-3-
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
'. Lochbaum, Union of Concerned Scientists
Distribution:
RRB1 (E-Mail)
RPC-(E-Mail)
J. Goldberg, OGC w/encl
J. Lieberman, OE w/encl
B. Boger, NRR w/encl
T. Scarbrough, NRR w/encl
Project Mgr., NRR w/encl
J. Caldwell, Rill w/encl
C.-Pederson,
Rill w/encl
.B. Clayton, Rill w/encl
SRI DVCook w/encl
DRP w/encl
TSS w/encl
DRS (2) w/encl
Rill PRR w/encl,
PUBLIC IE-01 w/encl
Docket File w/encl
GREENS
IEO (E-Mail)
DOCDESK (E-Mail)