ML17335A497

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Forwards Insp Repts 50-315/98-17 & 50-316/98-17 on 980921- 1222.Violation Noted Re Use of Deficient Administrative Guideline to Assess safety-related Sys Operability & Suction Strainer Design.Enforcement Discretion Excercised.No NOV
ML17335A497
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 01/29/1999
From: Dyer J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Powers R
AMERICAN ELECTRIC POWER CO., INC.
Shared Package
ML17335A498 List:
References
50-315-98-17, EA-99-004, EA-99-4, NUDOCS 9902050220
Download: ML17335A497 (7)


See also: IR 05000315/1998017

Text

CATEGORY 2

REGULATORY INFORMATION,DISTRIBUTION SYSTEM (RIDS)

CCESSION NBR:9902050220

DOC.DATE: 99/01/29

NOTARIZED: NO

DOCKET I

FACIL:50-315 Donald C.

Cook Nuclear Power Plant, Unit 1, Indiana

M

05000315

50-316 Donald C.

Cook Nuclear Power Plant, Unit 2, Indiana

M

05000316

AUTH.NAME

AUTHOR AFFILIATION

DYERFJ.E.

Region

3

(Post

820201)

RECIP.NAME

RECIPIENT AFFILIATION

POWERS,R.P.

Americ'an Electric 'Power Co., Inc.

SUBJECT:

Forwards insp repts

50-315/98-17

E 50-316/98-17

on 980921-

1222.Violation noted re use of deficient administrative

guideline to assess

safety-related

sys operability

6 suction

strainer design. Enforcement discretion excercised.No

NOV.

DISTRIBUTION CODE: IEOIF

COPIES

RECEIVED:LTR J

ENCL J

SIZE: 3

. 23

TITLE: General

(50 Dkt)-Insp Rept/Notice of Violation Response

NOTES:

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ID CODE/NAME

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NOTE TO ALL "RZDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION 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

January

29,

1999

EA 99-004

Mr. R. P. Powers

Senior Vice President

Nuclear Generation Group

American Electric Power Company

500 Circle Drive

Buchanan, Ml 49107-1395

SUBJECT:

NRC INSPECTION REPORT 50-315/98017(DRS); 50-316/98017(DRS) AND

NOTICE OF ENFORCEMENT DISCRETION

Dear Mr. Powers:

On December 22, 1998, the NRC completed a special inspection at your D. C. Cook, Units 1

and 2 reactor facilities. The enclosed report presents the results of that inspection.

The inspection was an examination of activities conducted under your license as they relate to

your staff's conduct of a Safety System Functional Inspection (SSFI) on the AuxiliaryFeedwater

System (AFW) system, a special test conducted on the suction strainer for a motor-driven AFW

pump, and the effectiveness of your System Readiness

Review process in the light of the results

of the SSFI. The enclosed report documents the results of the inspection.

We concluded that the SSFI was a thorough examination of the AFW system, conducted in a

professional manner by a strong, experienced team of inspectors.

The number of deficiencies it

identified, coupled with their significance, revealed that the Level 1 System Readiness

Review

done on the AFW system was ineffective in identifying potential operability issues.

While some

aspects of the AFW System Readiness

Review lacked rigor, the fundamental flaw lies with the

process itself, in that it was too narrow in scope, did not examine the system retrospectively, and

did not integrate findings of other review programs into its conclusion.

Two violations of NRC requirements were identified during this inspection.

The first violation

involves the use of a deficient, informal, administrative guideline to assess

the operability of

safety-related systems.

Because your third-party Engineering Issues Review Group

independently identified this and you have developed comprehensive corrective actions, no

Notice of Violation is being issued in accordance with section VII.B.1, "Licensee Identified

Severity Level IVViolations," of the "General Statement of Policy and Procedures for NRC

Enforcement Actions (Enforcement Policy)." The second violation is related to the suction

strainer design in the Essential Service Water supply to the AFW system.

The AFW pump

suction strainer clogged with foreign material during a test to demonstrate that Essential Service

Water could supply adequate flow to the Unit 1 West Motor-driven AFW pump as required.

The

demonstrated

inability of this safety-related system to perform its safety function represents

a

significant safety and regulatory concern in that design control measures

failed to identify a

design flaw in the AFW system that has existed since the plant was licensed for operation.

'7'702050220

9'70i29

PDR

ADOCK 050003i5

8

PDR

R. Powers

-2-

This violation would normally be categorized at Severity Level III. However,

I have been

authorized, after consultation with the Director, Office of Enforcement, to exercise enforcement

discretion in accordance with Section VII.B.2, uViolations Identified During Extended Shutdowns

or Work Stoppages," of the uGeneral 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 & 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 of corrective actions and therefore

additional enforcement action is not considered necessary to achieve remedial action for the

violation; (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.

In accordance with 10 CFR 2.790 of the NRC'S "Rules of Practice," a copy of this letter, the

enclosure, and your response to this letter, ifyou choose to provide one, willbe placed in the

NRC Public Document Room (PDR).

We willgladly discuss any questions you have concerning this inspection.

Sincerely,

Original /s/ J. E. Dyer

James

E. Dyer

Regional Administrator

Docket Nos.: 50-315; 50-316

License Nos.: DPR-58; DPR-74

Enclosure:

Inspection Report 50-315/98017(DRS);

50-316/98017(DRS)

See Attached Distribution

DOCUMENT NAME: G:DRSiDCC98017.WPD

To receive a co

of thla document. Indicate In the botu

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without attachment/enctoeure

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with attachment/enctoaure

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OFFICIAL RECORD COPY

R. Powers

-3-

cc w/encl:

J. Sampson,

Site Vice President

M. Rencheck, Vice President, Nuclear Engineering

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

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. Dyer, Rill w/encl

J. Caldwell, Rill w/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 IE-01 w/encl

Docket File w/encl

GREENS

IEO (E-Mail)

DOCDESK (E-Mail)

1)