ML20041B790
| ML20041B790 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 12/30/1981 |
| From: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Dolan J AMERICAN ELECTRIC POWER SERVICE CORP., INDIANA MICHIGAN POWER CO. |
| Shared Package | |
| ML20041B791 | List: |
| References | |
| EA-82-003, EA-82-3, NUDOCS 8202250206 | |
| Download: ML20041B790 (4) | |
Text
._.
Docket Nos. 50-315 DOC 50-316
^
EA 82-03 ge n-American Electric Power Service Y
i Corporation IU Indiana and Michigan Power Company 2
ATTN:
Mr. John E. Dolan, Vice Chairman n -
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-l Engineering y
2 Broadway Q
f New York, NY 10004 O
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Gentlemen.
This refers to the routine safety inspections conducted at the Donald C. Cook Nuclear Plant, Units 1 and 2, during the period June 1 through August 13, 1981.
l The results of these inspections indicate, among other things, serious weak-nesses in the management of your fire protection program and conduct of contain-I ment leakage tests as evidenced by the significant number of violations of NRC regulatory requirements. Our concerns deal with three principal areas; (1) inadequate implementation of the fire protection program including failure to implement the inservice testing requirements for a number of systems; (2) material false statements; and (3) failure to maintain containment integrity.
In regard to the first concern, numerous instances were identified wherein timely tests and inspections were not conducted to assure acceptable per-formance of fire protection components.
For example, timely tests and inspections were not performed on spray and sprinkler systems and on fire detection supervisory circuits to assure that they were operable and on fire doors in fire barriers to verify that they were functional.
This is a matter of special concern in that your failure to perform timely tests and make the necessary inspections posed questions as to the operability of.the spray and sprinkler systems and the fire detection supervisory circuits and whether the fire doors in the fire barriers were functional.
In regard to the second concern, material false statements, the NRC staff, dur-ing a review of your fire protection program, sent four letters to you requesting specific information.
In response to these letters it was stated that various zones and areas were equipped with 1 -hour and 3-hour rated fire doors and administrative measures had been established to control storage of combustible materials in the vicinity of safety related systems.
However, the zones and areas were not equipped with the appropriately rated fire doors and there were no procedures to control the storage of combustible materials in the vicinity of safety related' systems.
In May 1978, the Indiana and Michigan Power Company was cited and civil penalties were proposed for material false statements with l
respect to the testing of electrical penetrations and instrument cable.
1 CERTIFIED MAIL RETURN RECEIPT REQUESTED 8202250206 811230
~
PDR ADOCK 05000315 j
C PDR
i American Electric Power !
Service Corporation Your response, dated June 15, 1978, to the NRC Notice of Violation described corrective actions to assure the unerring accuracy of submittals to the NRC.
Yeur corrective actions were found to be acceptable.
The material false statements cited in Appendix A to this letter occurred prior to the material false statements for which you previously were cited.
Inaccurate information could result in decisions which adversely affect the health and safety of the public.
Therefore, it is imperative that licensees exercise the utmost care in verifying the information furnished the NRC.
The third area of concern involves an incident in which containment integrity was not maintained while the facility was in hot standby and hot shutdown.
For a period of approximately 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> containment integrity was breached in that a containment sensing line plug which was removed to install a test instrument was not replaced followin completion of an Integrated Leak Rate s
Test.
While the incident had limited safety significance, we are concerned about the inadequacy of your test control procedures which failed to assure that the technician used the correct point to test the system and restore the system following completion of the test.
Although you did subsequentlQentify the containment breach, you. failed to notify or report the incident to - p Commission on a timely basis.
Similar events involving failure to assure the operability of safety systems following surveillance testing or maintenance were discussed with you during an enforcement conference on January 13, 1981.
t The safety significance of the above matters together with other items of non-compliance discovered during the inspections were discussed on August 4, 1981, during an enforcement conference in the Region III office between you and 1
members of your staff and Mr. J. G. Keppler and others of the NRC staff.
Accordingly, in order to emphasize the importance the NRC places on adequate 4
i management control and followup on matters such as these, we propose to impose civil penalties in the cumulative amount of Eighty Thousand Dollars for the items set forth in Appendix A to this letter.
These violations occurred under both the old and new enforcement policies.
Those violations that occurred 4
under the old policy have been evaluated using factors identified in the
" Criteria for Determining Enforcement Action," which was sent to NRC licensees 1
on December 31, 1974.
Those violations that encompassed both the old and new policies or occurred conipletely under the new policy have been categorized at the level described in accordance with the Interim Enforcement Policy published in the Federal Register 45 FR 66754 (October 7, 1980).
The base value for Severity Level III Violations, such as the fire protection program violation or the containment integrity violation, is normally $40,000.
Because you could have reasonably been expected to have implemented measures to avoid the i
containment integrity violation following our enforcement conference on January 13, 1981, an increase in the base value to $50,000 is appropriate.
However, after considering all the circumstances of this violation including your self-identification, we are reducing the adjusted amount ($50,000) of the civil penalty to $40,000.
American Electric Power Service Corporation The inspections also identified certain safety significant activities which deviate from commitments to the NRC and from applicable codes approved by the NRC.
The deviation is identified in the Notice of Deviation enclosed herewith as Appendix B and is an additional example of the breakdown in the management of your fire protection program.
You are required to respond to this letter and should follow the instructions in Appendices A and B when preparing your response.
Your reply to this letter and the results of future inspections will be considered in determining whether further enforcement action may be appropriate.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosures will be placed in the NRC Public Document Room.
The responses directed by this letter and the enclosed Appendices are not subject to the clearance procedures of the Office of Management and Budget, as required by the Paperwork Reduction Act of 1980, PL 96-511.
Sincerely,
- 0riginnt g5,cqny 7
R. C. DcYom:3=
Richard C. DeYoung, Director Office of Inspection and Enforcement
Enclosures:
1.
Appendix A - Notice of Violation and Proposed Imposition of Civil Penalties 2.
Appendix B - Notice of Deviation cc w/encls:
D. V. Shaller, Plant Manager J
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American Electric Power Service Corporation Distribution PDR CP Book Department of Public Health NSIC' APuglise, CON L-316 ATTN:
Mr. Donald E. VanFarowe, Chief LPDR E! Reading File Division of Radiological Health ACRS F.D0 Reading File P.O. Box 30035 SECY SMiner, NRR:0RB-1 Lansing, MI 48909 CA SVarga, NRR:0RB-1 VStello, DEDROGR RCDeYoung, IE Office of the Attorney
-JSniezek, IE ATTN:
Hon. Frank J. Kelley RWessman, IE Attorney General TBrockett, IE 7th Floor, Law Bldg.
4
.FIngram, PA Lansing, MI 48913 i
JMurray, ELD
- JLieberman, ELD Public Service Commission KCyr, ELD ATTN:
Mr. Daniel J. Demlow l
JCrooks, AE00 Chairman JJCummings, OIA Long Commerce Park 4
Director,El Staff P.O. Box 30221 l
.RI, RII, RIII, RIV, RV Lansing, MI 48909 IE-Files Central Files 3
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