Similar Documents at Cook |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217J4721999-10-15015 October 1999 Forwards NRC Physical Security Insp Repts 50-315/99-27 & 50-316/99-27 on 990920-24.Two Violations Noted & Being Treated as Ncvs,Consistent with App C of Enforcement Policy. Areas Examined Exempt from Disclosure,Per 10CFR73.21 IA-99-379, First Final Response to FOIA Request for Documents.Documents Listed in App a Being Released in Entirety1999-10-0808 October 1999 First Final Response to FOIA Request for Documents.Documents Listed in App a Being Released in Entirety ML20217D9241999-10-0808 October 1999 First Final Response to FOIA Request for Documents.Documents Listed in App a Being Released in Entirety ML17335A5511999-10-0707 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Licenses for CR Smith,License SOP-30159-4 & Tw Welch,License SOP-30654-2 Are No Longer Required & Should Be Withdrawn ML17326A1441999-09-17017 September 1999 Submits Trace on Second Shipment of Two Plant,Unit 2 Steam Generators.Info Re Shipment Submitted 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 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 ML20196K5961999-06-30030 June 1999 Ltr Contract:Task Order 40, DC Cook Extended Sys Regulatory Review Oversight Insp, Under Contract NRC-03-98-021 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. ML17325B6281999-06-0101 June 1999 Forwards LER 99-S03-00,re Nonconforming Vital Area Barriers.Commitments Made by Util Are Listed 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 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 ML20207A9201999-05-21021 May 1999 Ack Receipt of 990319 Response to Notice of Violation & Proposed Imposition of Civil Penalty .On 981124, Licensee Remitted Check for Payment of Civil Penalties. Licensee Requests for Extension for Response,Granted 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 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
[Table view] |
Text
P CATEGORY 1P REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9803030308 DOC.DATE: 98/02/23 NOTARIZED: YES DOCKET ¹ 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 AFFILXATXON FITZPATRICK,E. Indiana Michigan Power Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 980123 ltr re violations noted in insp repts 50-315/97-24 &. 50-316/97-24. Corrective actions:blocks in alarm tiles were removed from both units annunciator panels.
DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt) -Insp Rept/Notice of Violation Response E
NOTES:
RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL XD CODE/NAME LTTR ENCL PD3-3 PD 1 1 STANG, J 1 1 INTERNAL: AEOD/SPD/RAB 1 1 AEOD T~ 1 1 DEDRO 1 1 ER 1 1 NRR/DRCH/HHFB 1 1 &/CPM PECB 1 1 NRR/DRPM/PERB 1 1 NUDOCS-ABSTRACT 1 1 OE DIR 1 1 OGC/HDS2 1 1 RGN3 FILE 01 1 1 XTERNAL: LITCO BRYCE,J H 1 1 NOAC 1 1 NRC PDR 1 1 NUDOCS FULLTEXT 1 1 D 0,
N NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS CONTROL OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 17 ENCL 17
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Indiana Michiga Power Company 500 Circle Drive.
Buchanan. Ml 49107 1395 INDIANA NICHIGAN POWER February 23, 1998 AEP: NRC: 1260L Docket Nos.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop 0-P1-17 Washington, D. C. 20555-0001 Gentlemen:
Donald C. Cook Nuclear Plant Units 1 and 2 RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-315/97024 (DRP)
AND 50-316/97024 (DRP)
This letter is in response to a letter from Geoffrey E. Grant, dated January 23, 1998, that forwarded a notice of violation.'he violations of NRC requirements were identif ied during a routine resident inspection conducted from November 8, 1997, through December 27, 1997. The first violation is associated with the failure to perform a 10 CFR 50.59 safety evaluation for physically or electronically blocking control room annunciators that are described in the updated final safety analysis report. The second violation is associated with the failure to provide a procedure for an activity affecting quality.
Our reply to these violations is provided in the attachment to this letter.
Sincerely, E. E. Fitzpatrick Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS 43 DAY OF 1998 HoicU// rr )~~r~ ~~men COY'ly Ml Coper@<'e 'a&~'o Pfh, 'l6, 2C01 Notary Pu xc My Commission Expires Cr
/vlb '/r Attachment Illlllffllllff Ill!Ililllllllf illfllffff 9803030308 980223 PDR ADOCK 05000315 8 PDR
U.S. Nuclear Regulatory Commission AEP: NRC: 1260L Page 2 A. Abramson A. B. Beach MDEQ '- DH & RPD NRC Resident Inspector R. Sampson
M Il
ATTACHMENT TO AEP:NRC: 1260L RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-315/97024 (DRP)
AND 50-316/97024 (DRP)
,Attachment to AEP:NRC:1260L Page 1 During an NRC inspection conducted from November 8, 1997, through
~
December 27, 1997, two violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions", NUREG-1600, the violations are listed below.
NRC Violation No. 1 "10 CFR 50.59, "Changes, Tests, and Experiments," requires, in part, that the licensee shall maintain records of changes in the facility as described in the Safety Analysis Report. These records must include a written safety evaluation which provides the basis for the determination that the change does not involve an unreviewed safety question.
Contrary . to the above, on November 16, 1997, . the inspectors identified a failure to maintain records which contained a written safety evaluation for three control room annunciators. The three annunciators were physically or electronically blocked, preventing them from operating, constituting a change to the facility as described in Chapters 7.5 and 10.3 of the Safety Analysis Report.
This is a Severity. Level ZV violation (Supplement Z) ."
Res onse to NRC Violation No. 1 Admission or Denial of the Alle ed Violation We admit to the violation as cited in the NRC notice of violation.
2 ~ Reason for the Violation During a routine tour of the control rooms, the inspector questioned the method of removing control room annunciators from service. After reviewing the blocked alarm log the inspector determined that three annunciators described in the updated final safety analysis report (UFSAR) had been blocked since July 1996. The existing -requirements for blocking alarms was given in OHZ-2211, which stated that a technical review was to be performed by a senior reactor operator prior to removal of an alarm from service. This review focused on technical specification requirements and compensatory actions. Although the existing operating instruction required a technical review of the conditions prior to blocking an alarm, there was insufficient guidance to provide assurance that consideration would be given to equipment described in the UFSAR and the potential need for a 10 CFR 50.59 screening.
The cause of this event was a procedural "inadequacy of the instruction that delineates the requirements for blocking an alarm. The instruction, OHZ-2211, required a technical of conditions prior to blocking an alarm. However, it 'eview did not address consideration for performing a 10 CFR 50.59 evaluation prior to blocking an alarm. Zt was not recognized that blocking these alarms without a 10 CFR 50.59 evaluation constituted a change to the plant.
Attachment to AEP:NRC:1260L Page 2
- 3. Corrective Action Taken and Results Achieved To correct this situation, blocks in the alarm tiles were removed from both units'nnunciator panels. The blocked alarms were reviewed to determine if any were associated with failed or out of service equipment. Alarms associated with failed or out of service equipment were reblocked, consistent with the guidance in generic letter 91-18, revision 1. When the alarms were unblocked, both units were in a shutdown condition. No significant plant status changes were taking place. Thus, the removal of these blocks did not cause a significant impact on the plant operation.
4 ~ Corrective Actions to Avoid Further Violations To prevent further violations, OHI-2211 was revised to require that alarms are not blocked without consideration of the need for a 10 CFR 50.59 screening. The procedure allows an alarm to be blocked apply:
if any of the following conditions
~ the component or system the alarm supports is inoperable or not required to be in service for the given plant conditions;
~ the alarm is declared inoperable and corrective action is initiated;
~ the alarm has been determined not to be a part of the design bases as described in the UFSAR; or
~ the 10 CFR 50.59 process has determined that blocking is acceptable's part of our architect engineering (AE) inspection response actions, an assessment is being conducted to identify other processes that have the potential to make changes without performing a 10 CFR 50.59 screening. A review of processes is being conducted, including interviews with supervisors to determine any processes that may have the potential to make changes. Samples of the output of these processes are being reviewed to determine whether changes have been made in accordance with 10 CFR 50.59. The review is focused on determining if:
~ there were any changes that should receive a
'10 CFR 50.59 screening;
~ there were any operability issues caused by such changes; or
~ there were any unreviewed safety questions The assessment is still in progress. We will submit the results and final conclusions of this assessment, including any programmatic changes required as a result of our review, in a future transmittal. The preliminary results show that while changes were made that should have received a 10 CFR 50.59 screening, no operability issues or unreviewed safety questions resulted from this failure to perform the 10 CFR 50.59 screenings.
lii Attachment to AEP:NRC:1260L Page 3 In addition, we will be conducting organization-wide training on understanding change. This training will support the need to recognize the potential for future changes that could bypass the 10 CFR 50.59 process. This training will be completed prior to restart.
- 5. Date When Full Com liance Will Be Achieved.
Full compliance was achieved on January 19, 1998, after the blocks were removed from all alarms and the revision to OHI-2211 became effective.
NRC Violation No. 2 "10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions,,
procedures, or drawings.
Contrary to the above, on December 18, 1997, the inspectors identified that a procedure of a type appropriate to the circumstances did not exist for an activity affecting quality, the manual backwashing of the ESW pump discharge strainers, a support system necessary to ensure ESW system operability.
This is a Severity Level IV violation (Supplement I).
Res onse to NRC Violation No. 2 Admission or Denial of the Alle ed Violation We admit to the violation as cited in (:he NRC notice of violation.
Reasons for the Violation The essential service water system (ESW) is a safety related system that provides cooling to safety related equipment during normal operations and accident conditions. The initial design of the ESW system included a non-safety related strainer backwash system. The ESW strainer backwash system for both units is powered by the non-safety related unit 1 control air system. The solenoid valves that supply air to the backwash control valve actuators are supplied by a class 1E electrical system, but the valves themselves are not class 1E equipment. In the event of a loss of offsite power (LOOP) with a containment spray signal, emergency power.
is not automatically available for the control air compressors. This would result in the loss of the ability to automatically backwash the ESW strainers or to determine the differential pressure across the strainers. The safety related ESW system is vulnerable to a passive failure due to strainer fouling that could be complicated by a failure of the non-safety related control air system. In order to support the continued operability of the ESW system after a LOOP, it strainers.
would be necessary to manually backwash the Historically, manually backwashing the ESW strainers has been considered skill of the trade and no procedures or training were provided.
,'l Attachment to AEP:NRC:1260L Page 4 This situation was first questioned in inspection report 50-315/316-96007 as unresolved item number 3. The inspector had observed that an ESW pump discharge strainer had been removed from service without the associated ESW train being declared inoperable. The inspector questioned the adequacy of the basis for the strainers not being a support system required for ESW'ystem operability. The design basis of the ESW system, including the justification for classifying the backwash system as non-safety related was provided to the inspector, who then requested that the office of Nuclear Reactor Regulation (NRR) review the information and reach a conclusion as to the need for operable strainers to support an operable ESW train. The NRR response was that procedures for manually backwashing the strainers should be considered safety related. In addition, NRR concluded that the emergency procedures for responding to a LOOP should contain the appropriate actions to take backwash capability is lost.
if automatic strainer However, because a procedure to manually backwash the ESW strainers did not exist and the operators had not been trained to perform a manual backwash, we were not in conformance with the requirements of 10 CFR Part 50, Appendix B, Criterion V.
This condition was caused by the failure to recognize, during the initial design of the ESW system, that a procedure for the manual backwash system was necessary if the control air system failed. As a result, the safety related ESW system could have been vulnerable to a passive failure due to strainer fouling that could be complicated by a failure of the non-safety related control air system.
Corrective Action Taken and Results Achieved To correct this condition the following procedure changes were made:
01-OHP 4024.104 and 02-OHP 4024.204, "Annunciator Response ESW and Component Cooling", were revised to require a manual backwash of the ESW strainers per 12 OHP 4021.019.001 if the control air system is unable to operate the backwash valve; 12-OHP 4021.019.001, "Operation of the Essential Service Water System", was revised to include instructions for manually backwashing the strainers; 1-0HP-4022.064.002, "Loss of Control Air Recovery", was revised to include monitoring ESW strainer differential pressure and initiation of manual backwash if needed; OHI-4011, "Shift Staffing", was revised to require that in modes 1-4, one person be assigned to each unit to manually backwash the ESW strainer if necessary, and one person be assigned to monitor the ESW pump strainer differential pressure; and 1-OHP 4021.001.001 and 2-OHP 4021.001.001, "Plant Heatup from Cold Shutdown to Hot Standby", were revised to require verification of OHI-4011 minimum staffing requirements as well as the monitoring of the ESW pump strainer differential pressure per 12-OHP 4021. 019. 001.
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Attachment to AEP:NRC:1260L Page 5 The operator training necessary to carry out these actions has been completed. These actions considered information notice 97-78, "Crediting of Operator Actions in Place of Automatic Actions and Modifications of Operator Actions Including Response Times."
Design change DCP-870 was made to simplify the ability to perform the manual backwash. This design change included:
~ installation of replaceable tanks of compressed air in each ESW pump room; modification of the control air connections to the ESW backwash valve actuators to quick disconnect fittings, pre-staged hoses, and quick connect fittings for the connection of the air tanks to the ESW backwash valve actuators in each ESW pump room; and
~ installation of seismically qualified scaffolding and ladders to allow clear access for operators to connect the air tank to the ESW backwash valve actuators.
A long term resolution of this condition is currently under development. A design change is .being developed to include appropriate alarms/indications, type of backup system, and the appropriate power source.
Corrective Actions to Avoid Further Violations As a result of'he NRC AE inspection, a short term action was undertaken to review failure modes and effects analysis of non-safety related systems interfacing with safety related systems. The review concluded that the current non-safety related systems will not cause a safety related system to fail in a non-conservative or unanalyzed manner. This review is documented in attachment 4 of our letter AEP:NRC:1260G3, dated December 2, 1997. This review provides reasonable assurance that single failure of a non-safety related system component will not result in common mode failure of redundant safety related equipment.
Date When Full Com liance Will Be Achieved Full compliance was reached on January 6, 1998, when training on the new procedure to manually backwash the ESW strainers was completed.
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