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| {{#Wiki_filter:CATEGORYj.REGULATORY INFORMATION DISTRIBUTION SYSTEM(RIDS)ACCESSION NBR:9610110377 DOC.DATE: | | {{#Wiki_filter:CATEGORY j.REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)ACCESSION NBR:9610110377 DOC.DATE: 96/09/27 NOTARIZED: |
| 96/09/27NOTARIZED: | | NO DOCKET~~FACIL:50-315 Donald C.Cook Nuclear?ower Plant, Unit 1, Indiana M 05000315 50-316 Donald C.Cook Nuclear Power Plant, Unit 2, Indiana M 05000316 AUTH.NAME AUTHOR AFFILIATION FITZPATRICK,E. |
| NODOCKET~~FACIL:50-315 DonaldC.CookNuclear?owerPlant,Unit1,IndianaM0500031550-316DonaldC.CookNuclearPowerPlant,Unit2,IndianaM05000316AUTH.NAMEAUTHORAFFILIATION FITZPATRICK,E.
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| AmericanElectricPowerCo.,Inc.RECIP.NAME RECIPIENT AFFILIATION DocumentControlBranch(Document ControlDesk)
| | American Electric Power Co., Inc.RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk) |
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| SUBJECT: Providescomments&addisuppoting inforeNRCIntegrated InspRepts50-315/96-05 | | SUBJECT: Provides comments&addi suppoting info re NRC Integrated Insp Repts 50-315/96-05 |
| &50-316/96-05. | | &50-316/96-05. |
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| DISTRIBUTION CODE:IEOIDCOPIESRECEIVED:LTR | | DISTRIBUTION CODE: IEOID COPIES RECEIVED:LTR |
| /ENCLISIZE:TITLE:General(50Dkt)-Insp Rept/Notice ofViolation ResponseNOTES:INTERNAL: | | /ENCL I SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES: INTERNAL: RECIPIENT ID CODE/NAME PD3-3 PD AEOD/SPD/RAB DEDRO NRR/DISP/PIPB NRR/DRPM/PECB NUDOCS-ABSTRACT OGC/HDS2 COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME HICKMANPJ NRR/DRCH/HHFB NRR/DRPM/PERB OE DIR RGN3 FILE 01 COPIES LTTR ENCI 1 1 1 1 1 1 1 1 1 1 1 1 1 1 EXTERNAL: LITCO BRYCE,J H NRC PDR 1 1 1 1 NOAC 1 1 E NOTE TO ALL"RIDSN RECIPIENTS: |
| RECIPIENT IDCODE/NAME PD3-3PDAEOD/SPD/RAB DEDRONRR/DISP/PIPB NRR/DRPM/PECB NUDOCS-ABSTRACT OGC/HDS2COPIESLTTRENCL11111111111111RECIPIENT IDCODE/NAME HICKMANPJ NRR/DRCH/HHFB NRR/DRPM/PERB OEDIRRGN3FILE01COPIESLTTRENCI11111111111111EXTERNAL: | | PLEASE HELP US TO REDUCE WASTE.TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRZBUTION 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 0' |
| LITCOBRYCE,JHNRCPDR1111NOAC11ENOTETOALL"RIDSNRECIPIENTS:
| | Indiana Michigan Power Company 500 Circle Drive Buchanan, Ml 491071395 INDIANA NICHIREN POVFER September 27, l996 AEP:NRCr1238B 10 CFR 50.4 Docket Nos.: 50-315 50-316 U.S.Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.20555 Gentlemen: |
| PLEASEHELPUSTOREDUCEWASTE.TOHAVEYOURNAMEORORGANIZATION REMOVEDFROMDISTRZBUTION LISTSORREDUCETHENUMBEROFCOPIESRECEIVEDBYYOUORYOURORGANIZATION, CONTACTTHEDOCUMENTCONTROLDESK(DCD)ONEXTENSION 415-2083TOTALNUMBEROFCOPIESREQUIRED:
| | Donald C.Cook Nuclear Plant Units 1 and 2 NRC INSPECTION REPORTS NO.50-315/96005 (DRP)AND 50-316/96005 (DRP)This letter is in response to a letter from W.L.Axelson dated July 23, 1996, that forwarded NRC Integrated Inspection Report 50-315/316-96005 (DRP), covering the period from April 9-May 25, 1996.During discussions with the NRC Region III staff following our systematic assessment of licensee performance (SALP)board 13 report, we were strongly encouraged to respond to our inspection reports to provide additional information that we believe to be pertinent. |
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| IndianaMichiganPowerCompany500CircleDriveBuchanan, Ml491071395 INDIANANICHIRENPOVFERSeptember 27,l996AEP:NRCr1238B 10CFR50.4DocketNos.:50-31550-316U.S.NuclearRegulatory Commission ATTN:DocumentControlDeskWashington, D.C.20555Gentlemen:
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| DonaldC.CookNuclearPlantUnits1and2NRCINSPECTION REPORTSNO.50-315/96005 (DRP)AND50-316/96005 (DRP)ThisletterisinresponsetoaletterfromW.L.AxelsondatedJuly23,1996,thatforwarded NRCIntegrated Inspection Report50-315/316-96005 (DRP),coveringtheperiodfromApril9-May25,1996.Duringdiscussions withtheNRCRegionIIIstafffollowing oursystematic assessment oflicenseeperformance (SALP)board13report,wewerestronglyencouraged torespondtoourinspection reportstoprovideadditional information thatwebelievetobepertinent.
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| Wegenerally agreewiththeinformation presented intheinspection reportandfindittobeareasonable representation oftheinspection period.However,withregardtocertainareasofthereport,wewouldliketoprovidecommentsandadditional supporting information.
| | We generally agree with the information presented in the inspection report and find it to be a reasonable representation of the inspection period.However, with regard to certain areas of the report, we would like to provide comments and additional supporting information. |
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| Thesecommentsreflectareaswherewebelieveinsufficient creditwasgivenforpositiveperformance attheplant,orissuesthatwebelievecouldhavebeenmoreappropriately characterized.
| | These comments reflect areas where we believe insufficient credit was given for positive performance at the plant, or issues that we believe could have been more appropriately characterized. |
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| Ourcommentsareprovidedintheattachment tothisletter.
| | Our comments are provided in the attachment to this letter. |
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| Sincerely,gd~p~VicePresident jenAttachment 96iOff0377 960927PDRADOCK050003158PDR U.S.NuclearRegulatory Commission Page2AEP:NRC:1238B cc:A.A.BlindA.B.BeachMDEQ-DW&RPDNRCResidentInspector J.R.Padgett | | Sincerely,gd~p~Vice President jen Attachment 96iOff0377 960927 PDR ADOCK 05000315 8 PDR U.S.Nuclear Regulatory Commission Page 2 AEP:NRC:1238B cc: A.A.Blind A.B.Beach MDEQ-DW&RPD NRC Resident Inspector J.R.Padgett |
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| ATTACHMENT TOAEP'NRC'1238B REPLYTONRCINSPECTION REPORTNOS.50-315/96005 (DRP}AND50-316/96005 (DRP) | | ATTACHMENT TO AEP'NRC'1238B REPLY TO NRC INSPECTION REPORT NOS.50-315/96005 (DRP}AND 50-316/96005 (DRP) |
| Attachment toAEP:NRC:1238B Page1Wegenerally agreewiththeinformation presented intheinspection reportandfindittobeareasonable representation oftheinspection period.However,thereareareasinthereportforwhichwewishtoprovidecomments. | | Attachment to AEP:NRC:1238B Page 1 We generally agree with the information presented in the inspection report and find it to be a reasonable representation of the inspection period.However, there are areas in the report for which we wish to provide comments.These comments reflect areas where we believe insufficient credit was given for positive performance at the plant, or issues that we believe could have been more appropriately characterized. |
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| Thesecommentsreflectareaswherewebelieveinsufficient creditwasgivenforpositiveperformance attheplant,orissuesthatwebelievecouldhavebeenmoreappropriately characterized.
| | There are two issues in this inspection report for which we would like you to consider additional information. |
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| Therearetwoissuesinthisinspection reportforwhichwewouldlikeyoutoconsideradditional information.
| | 1996 Unit 2 Refuel n Outa e The period of time covered by this routine inspection encompassed a major portion of the seven week outage;however, there is only one sentence in the report which sheds any light on the scope of this very successful outage.As we stated in our formal response to the SALP board 13 report, we believe this outage should be recognized as an indicator of improvement in our work control process and standards, internal teamwork and communications, maintenance performance, and commitment to excellence in operations. |
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| 1996Unit2RefuelnOutaeTheperiodoftimecoveredbythisroutineinspection encompassed amajorportionofthesevenweekoutage;however,thereisonlyonesentenceinthereportwhichshedsanylightonthescopeofthisverysuccessful outage.AswestatedinourformalresponsetotheSALPboard13report,webelievethisoutageshouldberecognized asanindicator ofimprovement inourworkcontrolprocessandstandards, internalteamworkandcommunications, maintenance performance, andcommitment toexcellence inoperations.
| | Pre-Planned Entr into a Notification of Unusual Event Un t 2 On Sunday, April 14, 1996, after appropriate safety and management reviews and after removing all fuel from the reactor vessel, both emergency diesel generators were removed from service.In strict compliance with our emergency plan, a notification of unusual event (NOUE)was made.Because this was a voluntary entry into conditions requiring off-site and NRC notifications, rather than an unplanned event-driven situation, efforts were made to clearly communicate to all involved agencies, the non-safety significance of the required notifications. |
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| Pre-Planned EntrintoaNotification ofUnusualEventUnt2OnSunday,April14,1996,afterappropriate safetyandmanagement reviewsandafterremovingallfuelfromthereactorvessel,bothemergency dieselgenerators wereremovedfromservice.Instrictcompliance withouremergency plan,anotification ofunusualevent(NOUE)wasmade.Becausethiswasavoluntary entryintoconditions requiring off-siteandNRCnotifications, ratherthananunplanned event-driven situation, effortsweremadetoclearlycommunicate toallinvolvedagencies, thenon-safety significance oftherequirednotifications.
| | To emphasize the need for accuracy and timeliness of all emergency plan notifications, regardless of the safety significance, it has been a long standing practice at Cook Nuclear Plant to conservatively classify events in strict compliance with our existing emergency plan even though the reactor is void of all fuel and clearly the safety intent of the emergency plan does not apply.We had originally scheduled the performance of maintenance on the two diesel generators at separate times in the outage schedule.However, delays were encountered during work on the 2CD engine, encroaching on the original schedule for work on the 2AB engine.It was decided to remove the 2AB engine from service and perform work on it simultaneously. |
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| Toemphasize theneedforaccuracyandtimeliness ofallemergency plannotifications, regardless ofthesafetysignificance, ithasbeenalongstandingpracticeatCookNuclearPlanttoconservatively classifyeventsinstrictcompliance withourexistingemergency planeventhoughthereactorisvoidofallfuelandclearlythesafetyintentoftheemergency plandoesnotapply.Wehadoriginally scheduled theperformance ofmaintenance onthetwodieselgenerators atseparatetimesintheoutageschedule.
| | This decision was made, and the subsequent action taken on very short notic Attachment to AEP:NRC:1238B Page 2 Prior to this, it had been planned to remove, both trains of essential service water (ESW), and both trains of component cooling water (CCW).This would have had the effect of removing both diesels, and would have required an intentional entry into a NOUE.While this plan was later changed such that the dual service water train outage did not occur, the extensive up front planning and safety reviews had been conducted, and were determined to adequately cover the action of removing and working on both diesels simultaneously. |
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| However,delayswereencountered duringworkonthe2CDengine,encroaching ontheoriginalscheduleforworkonthe2ABengine.Itwasdecidedtoremovethe2ABenginefromserviceandperformworkonitsimultaneously.
| | Because the final decision to work on both engines simultaneously was made on short notice, a plant nuclear safety review committee (PNSRC)meeting was called on Sunday morning to review the safety and shutdown risk reviews covering this new work, prior to implementing the decision.The major emphasis of this review was to ensure a suitable and reliable heat sink for the spent fuel pool.The resident received an information call at the conclusion of the meeting prior to taking action to remove the diesel generators and the entry into the NOUE.In the inspection report, the resident inspector drew the following conclusions about the event;"The inspectors determined that this evolution had minimal safety consequence given the plant conditions. |
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| Thisdecisionwasmade,andthesubsequent actiontakenonveryshortnotic Attachment toAEP:NRC:1238B Page2Priortothis,ithadbeenplannedtoremove,bothtrainsofessential servicewater(ESW),andbothtrainsofcomponent coolingwater(CCW).Thiswouldhavehadtheeffectofremovingbothdiesels,andwouldhaverequiredanintentional entryintoaNOUE.Whilethisplanwaslaterchangedsuchthatthedualservicewatertrainoutagedidnotoccur,theextensive upfrontplanningandsafetyreviewshadbeenconducted, andweredetermined toadequately covertheactionofremovingandworkingonbothdieselssimultaneously.
| | The licensee made effective use of the extensive preparations for the dual train ESW/CCW outage..." We agree with these conclusions drawn by the resident inspector. |
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| Becausethefinaldecisiontoworkonbothenginessimultaneously wasmadeonshortnotice,aplantnuclearsafetyreviewcommittee (PNSRC)meetingwascalledonSundaymorningtoreviewthesafetyandshutdownriskreviewscoveringthisnewwork,priortoimplementing thedecision.
| | However, the inspection report qualifies these conclusions with related concerns, several of which we wish to comment on.The inspector's conclusion statement goes on to say;"...However, the need for the licensee to intentionally enter a NOUE for seven days was not demonstrated." We have acknowledged that in light of the plant condition and minimal safety consequences, this decision was made in support of our outage schedule.However, we do not believe that the decision was inappropriately influenced by the desire to remain on schedule.In the past, in strict accordance with the emergency plan, we have entered similar conditions while the reactor is void of fuel which, however, still require classification as an NOUE.Senior management requires that all planned maintenance activities have a safety benefit.If this benefit is not demonstrated, the maintenance is not authorized. |
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| Themajoremphasisofthisreviewwastoensureasuitableandreliableheatsinkforthespentfuelpool.Theresidentreceivedaninformation callattheconclusion ofthemeetingpriortotakingactiontoremovethedieselgenerators andtheentryintotheNOUE.Intheinspection report,theresidentinspector drewthefollowing conclusions abouttheevent;"Theinspectors determined thatthisevolution hadminimalsafetyconsequence giventheplantconditions.
| | In this case the benefit of removing the diesel generators was to determine quickly the root cause of the failure of the CAM follower springs.Considering the inconsequential effect it had on shutdown safety, we believe the h'g il c ll 4 Attachment to AEP:NRC:1238B Page 3 benefit of quickly identifying the root cause of the failure was significant. |
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| Thelicenseemadeeffective useoftheextensive preparations forthedualtrainESW/CCWoutage..."
| | This prompt action had the concurrent benefit of avoiding outage delay.We are not aware of methodologies or standards for demonstrating a balance between improving the material condition of plant equipment versus the need to enter a condition meeting classification requirements per our emergency plan.This particular requirement for entering an unusual event has long been considered of minimal safety consequence for public safety by the NRC.This is evidenced by the fact that it is being removed from the requirements for utilities pursuing changes to their emergency action levels (EALs)using guidance developed under the auspices of NUHARC and endorsed by the NRC and FEHA.Another concern expressed in the inspection report reads: "The licensee had made no effort to pursue a prompt revision of the emergency classification criteria in an effort to avoid the NOUE.Unrelated to this event the licensee had previously submitted a request to the NRC to change the criteria, but this change was not yet final.The licensee made no effort to have the NRC increase the priority of their change request." Our formal submittal for a wholesale conversion of Cook Nuclear Plant's EALs from the old NUREG-0654 Appendix 1 guidance to the new NUMARC/NESP-007 guidance has been on the docket in some form or another since 1994.We are currently expecting approval in mid to late October of this year.A minimum implementation schedule, once the NRC approves the change, is fourteen weeks long.This includes pr'ocedure modification, training and verification, prior to making the change official.Even if NRR had been willing to increase the priority being afforded our EAL submittal, it would not have constituted a practical solution to the problem.This issue represents one item in a substantial submittal package, and would have required a separate effort for onsite implementation if approved.None of this could have been accomplished in the time frame in which this situation arose, and subsequent scheduling decisions were made.Moreover, we believe it is unreasonable to hold a licensee accountable for NRC priorities which are not within a licensee's contro it |
| Weagreewiththeseconclusions drawnbytheresidentinspector.
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| However,theinspection reportqualifies theseconclusions withrelatedconcerns, severalofwhichwewishtocommenton.Theinspector's conclusion statement goesontosay;"...However, theneedforthelicenseetointentionally enteraNOUEforsevendayswasnotdemonstrated."
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| Wehaveacknowledged thatinlightoftheplantcondition andminimalsafetyconsequences, thisdecisionwasmadeinsupportofouroutageschedule.
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| However,wedonotbelievethatthedecisionwasinappropriately influenced bythedesiretoremainonschedule.
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| Inthepast,instrictaccordance withtheemergency plan,wehaveenteredsimilarconditions whilethereactorisvoidoffuelwhich,however,stillrequireclassification asanNOUE.Seniormanagement requiresthatallplannedmaintenance activities haveasafetybenefit.Ifthisbenefitisnotdemonstrated, themaintenance isnotauthorized.
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| Inthiscasethebenefitofremovingthedieselgenerators wastodetermine quicklytherootcauseofthefailureoftheCAMfollowersprings.Considering theinconsequential effectithadonshutdownsafety,webelievethe h'gilcll4 Attachment toAEP:NRC:1238B Page3benefitofquicklyidentifying therootcauseofthefailurewassignificant.
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| Thispromptactionhadtheconcurrent benefitofavoidingoutagedelay.Wearenotawareofmethodologies orstandards fordemonstrating abalancebetweenimproving thematerialcondition ofplantequipment versustheneedtoenteracondition meetingclassification requirements perouremergency plan.Thisparticular requirement forenteringanunusualeventhaslongbeenconsidered ofminimalsafetyconsequence forpublicsafetybytheNRC.Thisisevidenced bythefactthatitisbeingremovedfromtherequirements forutilities pursuingchangestotheiremergency actionlevels(EALs)usingguidancedeveloped undertheauspicesofNUHARCandendorsedbytheNRCandFEHA.Anotherconcernexpressed intheinspection reportreads:"Thelicenseehadmadenoefforttopursueapromptrevisionoftheemergency classification criteriainanefforttoavoidtheNOUE.Unrelated tothiseventthelicenseehadpreviously submitted arequesttotheNRCtochangethecriteria, butthischangewasnotyetfinal.ThelicenseemadenoefforttohavetheNRCincreasethepriorityoftheirchangerequest."
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| Ourformalsubmittal forawholesale conversion ofCookNuclearPlant'sEALsfromtheoldNUREG-0654 Appendix1guidancetothenewNUMARC/NESP-007 guidancehasbeenonthedocketinsomeformoranothersince1994.Wearecurrently expecting approvalinmidtolateOctoberofthisyear.Aminimumimplementation schedule, oncetheNRCapprovesthechange,isfourteenweekslong.Thisincludespr'ocedure modification, trainingandverification, priortomakingthechangeofficial.
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| EvenifNRRhadbeenwillingtoincreasetheprioritybeingaffordedourEALsubmittal, itwouldnothaveconstituted apractical solutiontotheproblem.Thisissuerepresents oneiteminasubstantial submittal package,andwouldhaverequiredaseparateeffortforonsiteimplementation ifapproved.
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| Noneofthiscouldhavebeenaccomplished inthetimeframeinwhichthissituation arose,andsubsequent scheduling decisions weremade.Moreover, webelieveitisunreasonable toholdalicenseeaccountable forNRCpriorities whicharenotwithinalicensee's contro it
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ML17325B5971999-05-20020 May 1999 Forwards LER 99-012-00,re Auxiliary Building ESF Ventilation Sys Not Being Capable of Maintaining ESF Room Temps post-accident.Commitment,listed ML17335A5281999-05-12012 May 1999 Forwards DC Cook Nuclear Plant Fitness for Duty Program Performance Dtd for six-month Period of 980701-1231,IAW 10CFR26.71(d).Info Was Delayed Due to Administrative Error in Regulatory Affairs Dept ML17335A5271999-05-11011 May 1999 Forwards Details Re Sources & Levels of Insurance Maintained for DC Cook,Units 1 & 2,as of 990401,per 10CFR50.54(w)(3). Info Was Delayed Beyond Required Date Due to Internal Oversight ML17325B5841999-05-10010 May 1999 Forwards LER 99-002-00 Re TS 4.0.5 Requirements Not Being Met Due to Improperly Performed Test.Commitments Identified in Ler,Listed ML17325B5871999-05-0707 May 1999 Forwards Current Revs of Expanded Sys Readiness Review (Essr) Implementing Procedures,For Info Purposes to Support Current NRC Insps.Current Esrr Schedule Provided for Info Purposes,Reflecting Revised Target Dates ML17325B5791999-05-0404 May 1999 Forwards LER 99-011-00,concerning Air Sys for EDG Not Supporting Long Term Operability.Commitments Made by Util Listed ML17325B5821999-05-0404 May 1999 Provides Addl Background,Description & Clarification of Previous & Revised Commitments Re UFSAR Revalidation Effort. Commitment Change Involved Alignment of UFSAR Revalidation Program Methodology to Strategy Contained in Current Plan ML17325B5741999-05-0303 May 1999 Forwards LER 99-010-00 Re RCS Leak Detection Sys Sensitivity Not in Accoradnce with Design Requirements.Listed Commitments Identified in Submittal ML17325B5631999-04-22022 April 1999 Forwards Results of Independent Chemical Evaluations Performed from Sept 1997 Through Feb 1999,re Resolution of Issues Related to License Amend 227 ML17325B5561999-04-16016 April 1999 Forwards LER 99-006-00, Fuel Crane Loads Lifted Over SFP Could Impact Energies Greater than TS Limits, IAW 10CFR50.73.Submittal Was Delayed to Allow for Resolution of Questions.Commitment Made by Licensee,Listed ML20205P0591999-04-14014 April 1999 Ninth Partial Response to FOIA Request for Documents.App Records Already Available in Pdr.Records in App T Encl & Being Made Available in Pdr.App U Records Being Released in Part (Ref FOIA Exemption 7).App V Records Withheld Entirely ML17325B5451999-04-12012 April 1999 Forwards LER 99-009-00 Re as-found RHR Safety Relief Valve Lift Setpoint Greater than TS Limit.Commitments Identified in Submittal Listed ML17325B5301999-04-0707 April 1999 Forwards LER 99-S01-01, Vulnerability in Locking Mechanism of Four Vital Area Gates, Per 10CFR50.73.Commitments Made by Util,Listed ML17325B5241999-04-0505 April 1999 Forwards Revs 0 & 1 to Cook Nuclear Plant Restart Plan, Dtd 980307 & 0407.Rev 5 Is Current Cook Nuclear Plant Restart & Supercedes Previous Revs in All Respects ML17325B5121999-04-0101 April 1999 Forwards LER 99-007-00, Calculations Show That Divider Barrier Between Upper & Lower Containment Vols May Be Overstressed. Commitments Made by Util Are Listed 1999-09-30
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML17335A5511999-10-0707 October 1999 Forwards LER 99-023-00, Inadequate TS Surveillance Testing of ESW Pump ESF Response Time. Commitments Identified in LER Listed ML20217D9361999-09-30030 September 1999 FOIA Request for Document Re Section 9.7 of SE by Directorate of Licensing,Us Ae Commission in Matter of Indiana & Michigan Electric Co & Indiana & Michigan Power Co,Dc Cook Nuclear Plan,Units 1 & 2 ML17326A1541999-09-20020 September 1999 Provides Notification of Change in Senior Licensed Operator Status.Operating Licenses for CR Smith,License SOP-30159-4 & Tw Welch,License SOP-30654-2 Are No Longer Required & Should Be Withdrawn ML17326A1261999-09-17017 September 1999 Forwards LER 99-022-00 Re Electrical Bus Degraded Voltage Setpoints Too Low for Safety Related Loads.Listed Commitment Identified in Submittal ML17326A1441999-09-17017 September 1999 Submits Trace on Second Shipment of Two Plant,Unit 2 Steam Generators.Info Re Shipment Submitted ML17326A1531999-09-16016 September 1999 Submits Info Pertaining to Plant Proposed Operator Licensing Exam Requirements Through Yr 2003.NRC Form 536, Operator Licensing Exam Data, Which Provides Required Info Encl ML17326A1101999-08-27027 August 1999 Forwards LER 99-021-00, GL 96-01 Test Requirements Not Met in Surveillance Tests. List of Commitments Identified in LER Provided ML17326A0991999-08-26026 August 1999 Forwards LER 99-020-00,re EDGs Being Declared Inoperable. Commitments Made by Util Are Listed ML17326A1221999-08-23023 August 1999 Forwards Revised Page 2 to 1998 Annual Environ Operating Rept, for DC Cook Nuclear Plant,Correcting Omission to App I ML17326A0981999-08-23023 August 1999 Forwards fitness-for-duty Program Performance Data for Period of 990101-0630 for DC Cook Nuclear Plants,Units 1 & 2,per 10CFR26.71(d) ML17326A0891999-08-16016 August 1999 Forwards LER 99-019-00,re Victoreen Containment High Range Monitors Not Beign Environmentally Qualified to Withstand post-LOCA Conditions.Commitments Made by Util Are Listed ML17326A0811999-08-10010 August 1999 Notifies NRC of Changes in Commitments Made in Response to GL 98-01,supplement 1, Yr 2000 Readiness of Computer Sys Ar Npps, Dtd 990623 ML17326A0821999-08-0606 August 1999 Informs That Util Is Submitting Encl Scope & Objectives for 991026 DC Cook Nuclear Plant Emergency Plan Exercise to G Shear of NRC Plant Support Branch.Exercise Will Include Full State & County Participation ML17326A1451999-08-0404 August 1999 Requests Withholding of WCAP-15246, Control Rod Insertion Following Cold Leg Lbloca. ML17326A0751999-08-0404 August 1999 Forwards LER 98-029-01, Fuel Handling Area Ventilation Sys Inoperable Due to Original Design Deficiency. Supplemental Rept Represents Extensive Rev to Original LER & Replaces Rept in Entirely.Commitment Listed ML17326A0721999-07-29029 July 1999 Forwards LER 99-018-00 Re Refueling Water Storage Tank Suction Motor Operated Valves Inoperable,Due to Inadequate Design.Listed Commitments Were Identified in LER ML17326A0711999-07-27027 July 1999 Responds to 980123 RAI Re NRC GL 87-02, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors,Unresolved Safety Issue (USI) A-46. ML17326A0601999-07-22022 July 1999 Forwards UFSAR, IAW 10CFR50.71(e) & Rept of Changes,Tests & Experiments as Required by 10CFR50.59(b)(2) for DC Cook Nuclear Plant,Units 1 & 2.Without UFSAR ML17326A0631999-07-22022 July 1999 Forwards LER 98-014-03, Response to High-High Containment Pressure Procedure Not Consistent with Analysis of Record. Revised Info Marked by Sidebars in Right Hand Margin. Commitments Made by Util,Listed ML17326A0311999-07-0101 July 1999 Forwards LER 99-004-01 Re Failure to Perform TS Surveillance Analyses of Reactor Coolant Chemistry with Fuel Removed. Commitments Made by Util Are Listed ML17326A0281999-06-28028 June 1999 Provides Response to 981116 & 960228 RAIs Re GL 92-01. Revised Pressurized Thermal Shock Evaluation Based on New Weld Chemistry Info & Copy of W Rept WCAP-15074, Evaluation of 1P3571 Weld Metal from Surveillance Programs... Encl ML17326A0241999-06-23023 June 1999 Responds to GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. Y2K Readiness Disclosure for Plant & List of Commitments Encl ML17326A0121999-06-18018 June 1999 Forwards LER 99-014-00 Re Requirement of TS 4.0.5 Not Met for Boron Injection Tank Bolting.Commitments Identified in Submittal Listed ML17326A0111999-06-11011 June 1999 Provides Response to NRC RAI Re GL 97-01, Degradation of Crdm/Cedm Nozzle & Other Vessel Closure Head Penetrations. ML17325B6401999-06-0101 June 1999 Forwards LER 99-013-00 Re Safety Injection & Centrifugal Charging Throttle Valve Cavitation During LOCA Could Lead to ECCS Pump Failure.Listed Commitments Identified in Submittal ML17325B6281999-06-0101 June 1999 Forwards LER 99-S03-00,re Nonconforming Vital Area Barriers.Commitments Made by Util Are Listed ML17325B6331999-05-28028 May 1999 Forwards LER 99-S02-00,re Vulnerability in Safeguard Sys That Could Allow Unauthorized or Undetected Access to Protected Area.Commitments Made by Util Are Listed ML17265A8201999-05-24024 May 1999 Forwards LER 98-037-01,representing Extensive Rev to Original LER & Replacing Rept in Entirety.Listed Commitments Identified in Submittal ML17325B6111999-05-21021 May 1999 Forwards Annual Radioactive Effluent Release Rept for 980101-1231 for DC Cook Nuclear Plant,Units 1 & 2. Transmittal of Submittal Was Delayed Due to Administrative Error in Regulatory Affairs Dept ML17325B6031999-05-21021 May 1999 Provides Response to NRC GL 98-04, Potential for Degradation of ECCS & Containment Spray Sys After LOCA Because of Const & Protective Coating Deficiencies & Foreign Matl in Containment. ML17325B5971999-05-20020 May 1999 Forwards LER 99-012-00,re Auxiliary Building ESF Ventilation Sys Not Being Capable of Maintaining ESF Room Temps post-accident.Commitment,listed ML17335A5281999-05-12012 May 1999 Forwards DC Cook Nuclear Plant Fitness for Duty Program Performance Dtd for six-month Period of 980701-1231,IAW 10CFR26.71(d).Info Was Delayed Due to Administrative Error in Regulatory Affairs Dept ML17335A5271999-05-11011 May 1999 Forwards Details Re Sources & Levels of Insurance Maintained for DC Cook,Units 1 & 2,as of 990401,per 10CFR50.54(w)(3). Info Was Delayed Beyond Required Date Due to Internal Oversight ML17325B5841999-05-10010 May 1999 Forwards LER 99-002-00 Re TS 4.0.5 Requirements Not Being Met Due to Improperly Performed Test.Commitments Identified in Ler,Listed ML17325B5871999-05-0707 May 1999 Forwards Current Revs of Expanded Sys Readiness Review (Essr) Implementing Procedures,For Info Purposes to Support Current NRC Insps.Current Esrr Schedule Provided for Info Purposes,Reflecting Revised Target Dates ML17325B5821999-05-0404 May 1999 Provides Addl Background,Description & Clarification of Previous & Revised Commitments Re UFSAR Revalidation Effort. Commitment Change Involved Alignment of UFSAR Revalidation Program Methodology to Strategy Contained in Current Plan ML17325B5791999-05-0404 May 1999 Forwards LER 99-011-00,concerning Air Sys for EDG Not Supporting Long Term Operability.Commitments Made by Util Listed ML17325B5741999-05-0303 May 1999 Forwards LER 99-010-00 Re RCS Leak Detection Sys Sensitivity Not in Accoradnce with Design Requirements.Listed Commitments Identified in Submittal ML17325B5631999-04-22022 April 1999 Forwards Results of Independent Chemical Evaluations Performed from Sept 1997 Through Feb 1999,re Resolution of Issues Related to License Amend 227 ML17325B5561999-04-16016 April 1999 Forwards LER 99-006-00, Fuel Crane Loads Lifted Over SFP Could Impact Energies Greater than TS Limits, IAW 10CFR50.73.Submittal Was Delayed to Allow for Resolution of Questions.Commitment Made by Licensee,Listed ML17325B5451999-04-12012 April 1999 Forwards LER 99-009-00 Re as-found RHR Safety Relief Valve Lift Setpoint Greater than TS Limit.Commitments Identified in Submittal Listed ML17325B5301999-04-0707 April 1999 Forwards LER 99-S01-01, Vulnerability in Locking Mechanism of Four Vital Area Gates, Per 10CFR50.73.Commitments Made by Util,Listed ML17325B5241999-04-0505 April 1999 Forwards Revs 0 & 1 to Cook Nuclear Plant Restart Plan, Dtd 980307 & 0407.Rev 5 Is Current Cook Nuclear Plant Restart & Supercedes Previous Revs in All Respects ML17325B5121999-04-0101 April 1999 Forwards LER 99-007-00, Calculations Show That Divider Barrier Between Upper & Lower Containment Vols May Be Overstressed. Commitments Made by Util Are Listed ML17325B5141999-03-30030 March 1999 Forwards Rept on Status of Decommissioning Funding.Attached Rept Includes Amount of Decommissioning Funds Estimated to Be Required Pursuant to 10CFR50.75(b) & (C) ML17325B5191999-03-29029 March 1999 Forwards LER 99-001-00,re Degraded Component Cw Flow to Containment Main Steam Line Penetrations.Commitment, Listed ML20204F6401999-03-19019 March 1999 Responds to NRC 981013 NOV & Proposed Imposition of Civil Penalty.Violations Cited in Subject NOV Were Initially Identified in Referenced Five Insp Repts.Corrective Actions: Ice Condensers Have Been Completely Thawed of Any Blockage ML17325B4751999-03-18018 March 1999 Forwards LER 99-004-00,re Failure to Perform TS Surveillance Analyses of Reactor Coolant Chemistry with Fuel Removed. Commitment Made by Util,Listed ML17325B4721999-03-18018 March 1999 Forwards LER 99-005-00,re Reactor Trip Breaker Manual Actuations During Rod Drop Testing Not Previously Reported. Listed Commitments Identified in Submittal ML17325B4641999-03-17017 March 1999 Withdraws Response to Issue 1 of NRC Cal,Dtd 970919. Comprehensive Design Review Effort in Progress to Validate Resolution of Issue for Future Operation 1999-09-30
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Inspection Report - Cook - 1996005 |
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CATEGORY j.REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)ACCESSION NBR:9610110377 DOC.DATE: 96/09/27 NOTARIZED:
NO DOCKET~~FACIL:50-315 Donald C.Cook Nuclear?ower Plant, Unit 1, Indiana M 05000315 50-316 Donald C.Cook Nuclear Power Plant, Unit 2, Indiana M 05000316 AUTH.NAME AUTHOR AFFILIATION FITZPATRICK,E.
American Electric Power Co., Inc.RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT: Provides comments&addi suppoting info re NRC Integrated Insp Repts 50-315/96-05
&50-316/96-05.
DISTRIBUTION CODE: IEOID COPIES RECEIVED:LTR
/ENCL I SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES: INTERNAL: RECIPIENT ID CODE/NAME PD3-3 PD AEOD/SPD/RAB DEDRO NRR/DISP/PIPB NRR/DRPM/PECB NUDOCS-ABSTRACT OGC/HDS2 COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME HICKMANPJ NRR/DRCH/HHFB NRR/DRPM/PERB OE DIR RGN3 FILE 01 COPIES LTTR ENCI 1 1 1 1 1 1 1 1 1 1 1 1 1 1 EXTERNAL: LITCO BRYCE,J H NRC PDR 1 1 1 1 NOAC 1 1 E NOTE TO ALL"RIDSN RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE.TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRZBUTION 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 0'
Indiana Michigan Power Company 500 Circle Drive Buchanan, Ml 491071395 INDIANA NICHIREN POVFER September 27, l996 AEP:NRCr1238B 10 CFR 50.4 Docket Nos.: 50-315 50-316 U.S.Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.20555 Gentlemen:
Donald C.Cook Nuclear Plant Units 1 and 2 NRC INSPECTION REPORTS NO.50-315/96005 (DRP)AND 50-316/96005 (DRP)This letter is in response to a letter from W.L.Axelson dated July 23, 1996, that forwarded NRC Integrated Inspection Report 50-315/316-96005 (DRP), covering the period from April 9-May 25, 1996.During discussions with the NRC Region III staff following our systematic assessment of licensee performance (SALP)board 13 report, we were strongly encouraged to respond to our inspection reports to provide additional information that we believe to be pertinent.
We generally agree with the information presented in the inspection report and find it to be a reasonable representation of the inspection period.However, with regard to certain areas of the report, we would like to provide comments and additional supporting information.
These comments reflect areas where we believe insufficient credit was given for positive performance at the plant, or issues that we believe could have been more appropriately characterized.
Our comments are provided in the attachment to this letter.
Sincerely,gd~p~Vice President jen Attachment 96iOff0377 960927 PDR ADOCK 05000315 8 PDR U.S.Nuclear Regulatory Commission Page 2 AEP:NRC:1238B cc: A.A.Blind A.B.Beach MDEQ-DW&RPD NRC Resident Inspector J.R.Padgett
ATTACHMENT TO AEP'NRC'1238B REPLY TO NRC INSPECTION REPORT NOS.50-315/96005 (DRP}AND 50-316/96005 (DRP)
Attachment to AEP:NRC:1238B Page 1 We generally agree with the information presented in the inspection report and find it to be a reasonable representation of the inspection period.However, there are areas in the report for which we wish to provide comments.These comments reflect areas where we believe insufficient credit was given for positive performance at the plant, or issues that we believe could have been more appropriately characterized.
There are two issues in this inspection report for which we would like you to consider additional information.
1996 Unit 2 Refuel n Outa e The period of time covered by this routine inspection encompassed a major portion of the seven week outage;however, there is only one sentence in the report which sheds any light on the scope of this very successful outage.As we stated in our formal response to the SALP board 13 report, we believe this outage should be recognized as an indicator of improvement in our work control process and standards, internal teamwork and communications, maintenance performance, and commitment to excellence in operations.
Pre-Planned Entr into a Notification of Unusual Event Un t 2 On Sunday, April 14, 1996, after appropriate safety and management reviews and after removing all fuel from the reactor vessel, both emergency diesel generators were removed from service.In strict compliance with our emergency plan, a notification of unusual event (NOUE)was made.Because this was a voluntary entry into conditions requiring off-site and NRC notifications, rather than an unplanned event-driven situation, efforts were made to clearly communicate to all involved agencies, the non-safety significance of the required notifications.
To emphasize the need for accuracy and timeliness of all emergency plan notifications, regardless of the safety significance, it has been a long standing practice at Cook Nuclear Plant to conservatively classify events in strict compliance with our existing emergency plan even though the reactor is void of all fuel and clearly the safety intent of the emergency plan does not apply.We had originally scheduled the performance of maintenance on the two diesel generators at separate times in the outage schedule.However, delays were encountered during work on the 2CD engine, encroaching on the original schedule for work on the 2AB engine.It was decided to remove the 2AB engine from service and perform work on it simultaneously.
This decision was made, and the subsequent action taken on very short notic Attachment to AEP:NRC:1238B Page 2 Prior to this, it had been planned to remove, both trains of essential service water (ESW), and both trains of component cooling water (CCW).This would have had the effect of removing both diesels, and would have required an intentional entry into a NOUE.While this plan was later changed such that the dual service water train outage did not occur, the extensive up front planning and safety reviews had been conducted, and were determined to adequately cover the action of removing and working on both diesels simultaneously.
Because the final decision to work on both engines simultaneously was made on short notice, a plant nuclear safety review committee (PNSRC)meeting was called on Sunday morning to review the safety and shutdown risk reviews covering this new work, prior to implementing the decision.The major emphasis of this review was to ensure a suitable and reliable heat sink for the spent fuel pool.The resident received an information call at the conclusion of the meeting prior to taking action to remove the diesel generators and the entry into the NOUE.In the inspection report, the resident inspector drew the following conclusions about the event;"The inspectors determined that this evolution had minimal safety consequence given the plant conditions.
The licensee made effective use of the extensive preparations for the dual train ESW/CCW outage..." We agree with these conclusions drawn by the resident inspector.
However, the inspection report qualifies these conclusions with related concerns, several of which we wish to comment on.The inspector's conclusion statement goes on to say;"...However, the need for the licensee to intentionally enter a NOUE for seven days was not demonstrated." We have acknowledged that in light of the plant condition and minimal safety consequences, this decision was made in support of our outage schedule.However, we do not believe that the decision was inappropriately influenced by the desire to remain on schedule.In the past, in strict accordance with the emergency plan, we have entered similar conditions while the reactor is void of fuel which, however, still require classification as an NOUE.Senior management requires that all planned maintenance activities have a safety benefit.If this benefit is not demonstrated, the maintenance is not authorized.
In this case the benefit of removing the diesel generators was to determine quickly the root cause of the failure of the CAM follower springs.Considering the inconsequential effect it had on shutdown safety, we believe the h'g il c ll 4 Attachment to AEP:NRC:1238B Page 3 benefit of quickly identifying the root cause of the failure was significant.
This prompt action had the concurrent benefit of avoiding outage delay.We are not aware of methodologies or standards for demonstrating a balance between improving the material condition of plant equipment versus the need to enter a condition meeting classification requirements per our emergency plan.This particular requirement for entering an unusual event has long been considered of minimal safety consequence for public safety by the NRC.This is evidenced by the fact that it is being removed from the requirements for utilities pursuing changes to their emergency action levels (EALs)using guidance developed under the auspices of NUHARC and endorsed by the NRC and FEHA.Another concern expressed in the inspection report reads: "The licensee had made no effort to pursue a prompt revision of the emergency classification criteria in an effort to avoid the NOUE.Unrelated to this event the licensee had previously submitted a request to the NRC to change the criteria, but this change was not yet final.The licensee made no effort to have the NRC increase the priority of their change request." Our formal submittal for a wholesale conversion of Cook Nuclear Plant's EALs from the old NUREG-0654 Appendix 1 guidance to the new NUMARC/NESP-007 guidance has been on the docket in some form or another since 1994.We are currently expecting approval in mid to late October of this year.A minimum implementation schedule, once the NRC approves the change, is fourteen weeks long.This includes pr'ocedure modification, training and verification, prior to making the change official.Even if NRR had been willing to increase the priority being afforded our EAL submittal, it would not have constituted a practical solution to the problem.This issue represents one item in a substantial submittal package, and would have required a separate effort for onsite implementation if approved.None of this could have been accomplished in the time frame in which this situation arose, and subsequent scheduling decisions were made.Moreover, we believe it is unreasonable to hold a licensee accountable for NRC priorities which are not within a licensee's contro it