U.S. NUCLEAR REGULATORY COMMISSION

Region III Office of Public Affairs

801 Warrenville Road, Lisle, IL 60532-4351

NEWS ANNOUNCEMENT: RIII-97-86 Sept. 22, 1997

CONTACT: Jan Strasma 630/829-9663

Angela Dauginas 630/829-9662

E-mail: opa3@nrc.gov

NOTE TO EDITORS:

The NRC staff has issued the attached Confirmatory Action Letter

to American Electric Power Co., documenting the utility's

agreement to evaluate and resolve a number of issues related to

the functioning of certain safety systems and components at the

D. C. Cook Nuclear Power Station near Bridgman, Michigan.

The two units at the station were shut down earlier this month to

resolve a question on the adequacy of water flow during the longterm reactor cooling mode following a potential major reactor

accident.

This water flow issue and other issues were identified during an

NRC engineering and design team inspection which was completed

September 12 and in additional inspections and reviews by the NRC

Region III staff.

The utility will meet with the NRC staff prior to returning the

two units to service. No date has been set for the meeting,

which will be open to public observation.

#
September 19, 1997

CAL No. RIII-97-011

Mr. E. E. Fitzpatrick

Executive Vice President

Nuclear Generation Group

American Electric Power Company

500 Circle Drive

Buchanan, MI 49107-1395

SUBJECT: CONFIRMATORY ACTION LETTER

Dear Mr. Fitzpatrick:

In August of this year, an NRC Architect and Engineering (AE) team

began inspection activities at your D. C. Cook facility. During

this inspection, the AE team identified issues which resulted in

concerns with the operability of safety related systems and

components. In response to these inspection findings your

personnel began evaluating these issues and also identified

operability concerns with some components. In response to one of

these issues you elected to shutdown both units until you could

resolve the issue.

In a letter (AEP:NRC:1260G1, copy attached) from you to the NRC

on September 18, 1997, you identified several issues and the

actions you intend to take on those issues prior to start up of

either unit at the D. C. Cook facility. These items are repeated

below as items (1) through (7) along with additional concerns of

our own.

(1) Recirculation Sump Inventory/Containment Dead Ended

Compartments Issue (AEP)

Analyses will be performed to demonstrate that the

recirculation sump level is adequate to prevent vortexing, or

appropriate modifications will be made.

(2) Recirculation Sump Venting Issue (AEP)

Venting will be re-installed in the recirculation sump

cover. The design will incorporate foreign material
exclusion requirements for the sump.

(3) Thirty-six Hour Cooldown, with One Train of Cooling (AEP)

Analyses will be performed that will demonstrate the

capability to cool down the units consistent with design

basis requirements and necessary changes to procedures will

be completed.

(4) ES-1.3 (Switchover to Recirculation Sump) Procedure (AEP)

Changes to the emergency procedure used for switchover of the

emergency core cooling and containment spray pumps to the

recirculation sump will be implemented. These changes will

provide assurance there will be adequate sump volume, with

proper consideration of instrument bias and single failure

criteria.

(5) Compressed Air Overpressure Issue (AEP)

Overpressure protection will be provided downstream of the 20

psig, 50 psig, and 85 psig control air regulators to mitigate

the effects of a postulated failed regulator.

(6) Residual Heat Removal (RHR) Suction Valve Interlock Issue

(AEP)

A Technical Specification change to allow operation in Mode

4 with the RHR suction valves open and power removed is being

processed. Approval of this change by the NRC will be

required prior to restart.

(7) Fibrous Material in Containment (AEP)

Removal of fibrous material from containment that could clog

the recirculation sump will be completed.

(8) Refueling Water Storage Tank (RWST) Mini-flow Recirculation

Lines (NRC)

Only two of six mini-flow recirculation line valves have

leakage verification tests. Justification will be provided

that the total leakage for the six valves is less than 10 gpm

to ensure that Part 100 dose rates are not exceeded if

containment sump water were to leak back to the RWST during a

design basis accident.
(9) Instrument Uncertainties Incorporated into Procedures and

Analyses (NRC)

Emergency procedures and other important-to-safety

procedures, calculations, or analyses will be reviewed to

account for instrument uncertainties.

With regard to item (4) above, I would remind you of the need to

ensure the revised procedure is validated and all licensed

operating crews are trained on its use.

It is my understanding that you will perform the actions described

in items (1) through (8) above for each D. C. Cook unit prior to

restart of the respective unit. Further, I understand AEP will

meet with the NRC to discuss resolution of all of the above issues

(including item (9)), as appropriate, prior to restarting the D.

C. Cook Units.

Lastly, given the limited scope of our inspection and its

substantial findings, it is necessary to determine the extent of

these problems and their potential impact on other systems. It is

my understanding, in the short term, you will perform an

assessment to determine whether these types of engineering

problems exist in other safety related systems and whether they

affect system operability. In the long term, you will evaluate

your programs for improvements to assure these kinds of

engineering problems are promptly identified, thoroughly

evaluated, and resolved.

Nothing in this confirmatory action letter is intended to preclude

you from taking actions which you deem necessary to place the

plant in a safe condition or maintain it in a safe condition in

the event of changing conditions.

Pursuant to Section 182 of the Atomic Energy Act, 42 U.S.C. 2232,

you are required to:

(1) Notify me immediately in writing if your understanding

differs from that set forth above;

(2) Notify me if for any reason you cannot complete the

actions within the specified schedule and advise me in

writing of your modified schedule of the change; and

(3) Promptly notify me in writing if for any reason you

cannot complete the actions discussed above.
Issuance of this Confirmatory Action Letter does not preclude

issuance of an order formalizing the above commitments or

requiring other actions on the part of the licensee; nor does it

preclude the NRC from taking enforcement action for violations of

NRC requirements that may have prompted the issuance of this

letter. In addition, failure to take the actions addressed in

this Confirmatory Action Letter may result in enforcement action.

In accordance with 10 CFR 2.790 of the NRC’s “Rules of Practice,”

a copy of this letter and your response will be placed in the NRC

Public Document Room (PDR). To the extent possible, your response

should not include any personal privacy, proprietary, or

safeguards information so that it can be placed in the PDR without

redaction. However, if you find it necessary to include such

information, you should clearly indicate the specific information

that you desire not to be placed in the PDR, and provide the legal

basis to support your request for withholding the information from

the public.

Sincerely,

/signed/

A. Bill Beach

Regional Administrator

Docket No. 50-315; 50-316