IR 05000315/1996009
| ML20138J742 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 01/31/1997 |
| From: | Grant G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Fitzpatrick E AMERICAN ELECTRIC POWER CO., INC. |
| References | |
| NUDOCS 9702070505 | |
| Download: ML20138J742 (4) | |
Text
January 31, 1997
SUBJECT:
NOTICE OF VIOLATION AND UNRESOLVED ITEMS (NRC INSPECTION REPORT NOS. 50-315/316-96009(DRS))
Dear Mr. Fitzpatrick:
This will acknowledge receipt of your letter dated December 30,1996,in response to our letter dated November 14,1996, transmitting a Notice of Violation associated with
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l Inspection Report Nos. 50-315/316-96009(DRS). This report summarized the results of the Maintenance Rule Baseline Inspection at your Donald C. Cook Nuclear Plant, Units 1
l and 2.
We have reviewed your corrective actions for the two violations and the unresolved item
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concerning the potential for masking of component failures. We have no further questions L
on these issues at this time. These corrective actions will be examined during future
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inspections.
Your letter went on to address our concern over the potential misclassification of an event where an operator incorrectly opened a disconnect while conducting a lineup for a battery
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drawdown test. Our report stated that while the event was properly classified as a functional failure, its relationship to overall maintenance was not recognized and, consequently, the event was not classified as a maintenance preventable functional failure.
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You disagreed with that assessment, citing portions of NUMARC 93-01 and the
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" Questions and Answers from Workshops."
It remains our position that the event should be classified as a n;aintenance preventable functional failure. Our bases follow:
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NUMARC 93-01, Appendix B, Maintenance Guideline Definitions, on page B-1
states, in part, " Maintenance includes not only those activities traditionally associated with identifying and correcting actual or potential degraded
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conditions...but extends to all supporting functions for the conduct of these
activities." It is our view that establishing a lineup for a test is a supporting function.
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j The NRC's policy statement on maintenance of nuclear power plants was published
in the Federal Register on March 23,1988. This policy statement is referenced in NUMARC 93-01, Revision 0,in the definition of maintenance. This document defines the activities that form the basis of a maintenance program.
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E. January 31, 1997 The policy statement states that activities that form the basis of a maintenance program include surveillance, post maintenance testing and return to service activities. Based on this, the staff determined that operator errors that cause equipment failures should be considered maintenance preventable functional failures if the operators are participating in surveillance, post maintenance testing, or return to service activities following maintenance. This includes operator errors in removing a system from service prior to surveillance testing or maintenance.
Regarding your reference to the " Questions and Answers from Workshops," we
refer you to a letter from Suzanne Black, NRC, to Mr. Ray Ng of NEl, dated June 29,1994, discussing industry's use of tL.._.stions and answers from the 1993 maintenance rule workshops. The letter states, in part, that "the staff's responses could change as~more experience is gained during the implementation of the rule. Therefore, licensees should understand that these answers represent the staff's current thinking and that information gathered during future site visits, future workshops, or other activities prior to the implementation date of the rule, July 10,1996, may affect these answers."
We note that the battery system is considered to have already reached the allowable limit of two maintenance preventable functional failures. Proper classification of this event results in exceeding that limit. We will examine your response to this issue in a future inspection.
Should you have any further questions, please contact me or Wayne Kropp of my staff.
Sincerely, j
l Original Signed by Geoffrey E. Grant Geoffrey E. Grant, Director Division of Reactor Safety i
Docket Nos. 50 315: 50-316 License Nos. DPR-58; DPR-74 Enclosure:
Ltr 12/30/96 E. E. Fitzpatrick, AEP, to US NRC w/ enc!
Distribution:
See attached list SEE ATTACHED CONCURRENCES DOCUMENT NAME: G:\\DRS\\DCC01297.DRS To receive a copy of this document. Indicate in the box *C' = Copy w/o attach /enci *E' = Copy w/ attach /enci *N' = No copy 0FFICE Rill:DRS l
Rill:DRS I
Rill:DRP l
Rill:DRS
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NAME Farber Kropp Burgess Leach /Grakt\\
DATE 01/
/97 01/
/97 01/
/97 01/ 3 ( /97( A 0FFICIAL RECORD COPY
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The policy statement states that activities that form the basis of a maintenance program include surveillance, post maintenance testing and return to service activities. Based on this, the staff determined that operator errors that cause equipment failures should be considered maintenance preventable functional failures if the operators are participating in surveillance, post maintenance testing, or return to service activities following maintenance. This includes operator errors in removing a system from service prior to surveillance testing or maintenance.
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Regarding your reference to the " Questions and Answers from Workshops," we q
i refer you to a letter from Suzanne Black, NRC, to Mr. Ray Ng of NEl, dated June 29,1994, discussing industry's use of the questions and answers from the 1993 maintenance rule workshops. The letter states, in part, that "the staff's responses could change as more experience is gained during the implementation of the rule. Therefore, licensees should understand that these answers represent the staff's current thinking and that information gathered during future site visits, future workshops, or other activities prior to the implementation date of the rule, i
July 10,1996, rnay affect these answers."
We note that the battery system is considered to have already reached the allowable limit
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of two maintenance preventable functional failures. Proper classification of this event results in exceeding that limit. Gesc';uently, an cvaluation of tM naad en ninca tw batterv wetem 5 categgry (6)(1) ond d;;;!cp apprcpriate gee!r !: reg rei We will examine your response to this issue in a future inspection.
Should you have any further questions, please contact me or Wayne Kropp of my staff.
Sincerely, Geoffrey E. Grant, Director Division of Reactor Safety Docket Nos. 50-315; 50-316 License Nos. DPR-58; DPR-74 Enclosure:
Ltr 12/30/96 E. E. Fitzpatrick, AEP, to US NRC w/enci Distribution:
See attached listing DOCUMENT NAME: G:\\DRS\\DCC01297.DRS To receive a copy of this document, indicate in the box "C" = Copy w/o httach/enct T = Copy w/ attach /enci"N" = No copy 0FFICE Rlll:DRS l 16 RIII:DRS.
l Rill:DRPt, l6 RIII:DRS l
NAME Farber MP Kropp V Burge@#V)
Leach / Grant DATE 01/ M /97 01/ 2% /97 01/ ~b /97 01/
/97 0FFICIAL RECORD COPY
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h E. January 31, 1997 cc w/o encl:
A. A. Blind, Site Vice President l
John Sampson, Plant Manager cc w/ encl:
James R. Padgett, Michigan Public Service Commission Michigan Department of Public Health Distribution:
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Docket File w/ encl Rill PRR w/enci Enf. Coordinator, Rlll w/enci I
. lE-01 "w/enci"N SRI, D. C. Cook w/ enc!
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A. B. Beach, Rlli w/encI DRS w/enci W. L. Axelson, Rlll w/ encl
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Porer Company
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500 Circle Dnve
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Bachaaan. MI 491071395
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hlDCHIGAN POWER i
l December 30, 1996 AEP:NRC:1238E 10 CFR 2.201 a
Docket Nos.:
50-315 50-316 i
U.
S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.
C.
20555
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Gentlemen:
I Donald C. Cook Nuclear Plant Units 1 and 2 i
NRC INSPECTION REPORTS NO. 50-315/96009(DRS)
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AND 50-316/96009(DRS) REPLY TO NOTICE OF VIOLATIONS This letter is in response to a letter from G.
E.
Grant, dated November 14, 1996, that forwarded a notice of.two violations and one unresolved item to Indiana Michigan Power Company.
The violations were identified during an inspection of the implementation of 10 CFR 50.65, " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."
The two violations were the failure to set adequate reliability performance criteria, commensurate with safety, for systems, structures, and components of high safety significance, and the failure to establish an appropriate basis for the instituted unavailability goal of the containment hydrogen control system.
The unresolved item was identified regarding the possibility that problems with certain systems, structures, and components could be masked by their functional failure definitions.
Our response was due to you on December 14, 1996; however, we requested an extension to January 2, 1997 on November 25, 1996, j
which was granted by Mr. M. Farber, of Region III.
An additional
I extension to January 17, 1997 was granted by Mr.
W.
Kropp, of Region III.
However, this additional time was not needed as the letter was completed prior to the expiration of the first exeension.
Our reply to the violations and our response to the unresolved item are provided in the attachment to this letter. The reply does not contain any personal privacy, proprietary, or safeguards information.
Sincerely, SWORN TO AND SUBSCRIBED BEFORE ME
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THIS3oD DAY OF bombOL 1996 OAA tIL$h E.
E. Fit atrick Vice President Notary Public My Commission Expires:
jmb JAN WATSON Attachment NOTARY PUBUC BERRIENCOUNTY Mi MY COMMISSION EXPfRES FEB.10,1999 JAN 0'a
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Nuclear Regulatory Commission AEP:NRC:1238E Page 2
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cc
'A. A. Blind A.
B. Beach MDEQ - DW & RPD NRC Resident Inspector J.
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Padgett l
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ATTACHMENT TO AEP:NRC:1238E REPLY TO NOTICE OF VIOLATION:
NRC INSPECTION REPORT NOs. 50-315/96009 (DRS)
AND 50-316/96009 (DRS)
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Attachment to AEP:NRC 1238E j.
Page 1
During. an NRC inspection conducted September
through i
j September 13, 1996, on the implementation of the Maintenance Rule, j
two violations of NRC requirements were identified. In accordance with - the " General Statement of Policy and Procedures for NRC Enforcement Actions," (NUREG-1600) the violations and the Donald C.
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i Cook Nuclear Plant responses are provided below. Additionally, we d
were requested to respond to an unresolved item.
Our response to
.this item is also provided below.
.NRC Violation I
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"10 CFR 50.65 (a) (1) requires, in part, that each holder of an operating license under 50.21(b) or 50.22 shall monitor the performance or condition of structures, systems, or components
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i against licensee-established goals.
Such goals shall be established commensurate with safety.
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Contrary to the above, as of September 9,1996, the licensee failed f
to establish appropriate reliability goals or performance criteria j
commensurate with safety for 18 high safety significant structures,
systems, or components.
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This a Severity Level IV violation."
l Resconse to NRC Violation I
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Admission or Denial of the Alleced Violation Indiana Michigan Power Company admits to the violation as
j cited in the NRC notice of violation.
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Reason for the Violation
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The " maintenance rule" is the first performance based rule,
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and, as a result, acceptable methods to achieve compliance with the rule were not completely understood between the
industry and the NRC.
We implemented the rule in accordance j
with industry guidance that was thought to be acceptable to j
the NRC.
We now understand that a more exact cc.telation between reliability performance criteria and the PRA is
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expected.
3.
Corrective Actions Taken and Results Achieved i
A review of all recent NRC and industry guidance on the subject was performed.
The maintenance rule coordinator attended the recent NEI/NRC workshop on the maintenance rule baseline inspections (MRBIs) wherein this industry issue was l
discussed in detail.
Additionally, discussions were held with other licensees who have had maintenance rule baseline inspections performed.
As a result, an understanding was gained of the NRC expectations regarding the linking of reliability to the PRA/IPE/IPEEE.
In order to determine reliability goal and performance criteria commensurate with safety, a plan has been developed to determine the link between counting functional failures per unit time and the reliability assumptions used in the PRA for all risk significant SSCs at Cook Nuclear Plant.
For normally operating SSCs, this will require determining the ratio of allowed functional failures to a specified number of
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Attachment to AEP:NRC:1238E Page 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> the SSC is operated during a given time period.
For standby SSCs, the number of demands, either actual or estimated, placed on the SSC during a given time period will be used to relate to the PRA reliability inputs.
4.
Corrective Actions Taken to Avoid Further Violations As stated above, our program was developed in a manner consistent with then current industry guidance for compliance.
We continue to maintain initiatives to stay abreast of the
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expectations for maintenance rule compliance, including:
membership in the Winston & Strawn Maintenance Rule Inspection Clearinghouse; maintaining a presence at industry n = tings (NEI);
active networking with industry peers; and monitoring results of the MRBIs.
5.
Date When Full Comoliance Will Be Achieved The linking of reliability to the PRA/IPE/IPEEE, and associated procedure changes, will be completed by August 29, 1997. This time is needed to ensure we develop a process that properly considers the complexity of the task.
NRC Violation II
"10 CFR 50.65, ' Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants' requires, in part, structures, systems, or components be monitored against licensee-established goals as described in 50.65(a) (1) unless it has been demonstrated that the performance or condition of a system, structure, or component is being effectively controlled through the performance of appropriate preventive maintenance as described in 50.65 (a) (2).
i contrary to the above, the licensee failed to establish an appropriate basis for the instituted unavailability goal chosen to demonstrate that the performance or condition of the containment hydrogen control system was being effectively controlled through adequate preventive maintenance.
This is a Severity 1.evel IV violation."
Response to NRC Violation II 1.
Admission or Denial of the Alleaed Violation Indiana Michigan Power Company admits to the violation as cited in the NRC notice of violation.
2.
Reason for the Violation Prior to the inspection, a condition report was written for the high unavailability of the containment hydrogen control system (CHCS) SSCs.
That condition report resulted i
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l Attachment to AEP:NRC:1238E i
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i iri the establishment of (a) (1) goals for each of the four t2ains of post accident containment hydrogen monitoring system (PACHMS), a constituent system of the CHCS SSC, of
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77G hours per year. This was based on the premise that annually there would be 56 hours6.481481e-4 days <br />0.0156 hours <br />9.259259e-5 weeks <br />2.1308e-5 months <br /> of preventive maintenance l
and cue failure per train. The failure was assumed to cause 3n unavailability period equal to the Technical Specification 3.6.4.1 Allowable Outage Time, thirty days.
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Thus, a limit of 56 hrs + (24 hrs X 30 days) = 776 hrs was
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i developed. There was insufficient analysis of past PACHMS j
unavailability; thus, the basis for the goal was not
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rigorously established.
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This occurred because procedure EHI-5035, " Maintenance Rule
Program Administration," did not provide adequate guidance
regarding goal setting for (a) (1) SSCs.
Specifically, it j
did not:
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direct that the performance history be considered;
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contain a caution there may be no correlation between
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LCO durations and appropriate performance expectations.
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The specific needs of the maintenance rule require this supplemental guidance be included in the procedure in j
addition to our generic corrective action program guidance.
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3.
Corrective Actions Taken and Results Achieved i
The per train PACHMS (a) (1) unavailability goal was reduced to 296 hours0.00343 days <br />0.0822 hours <br />4.89418e-4 weeks <br />1.12628e-4 months <br /> per year on December 2, 1996.
This value
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includes allowances for calibration, repair time resulting
from one failure per year, and one day of planned
corrective maintenance per year.
The goal bases for the other systems classified as (a) (1)
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i (pe st accident sampling and auxiliary feedwater) were re-
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reviewed.
It was concluded that investigations and
established goals were adequate for these systems.
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4.
Corrective Actions Taken to Avoid Purther Violations i
Additional guidance will be added by January 31, 1997, to Procedure EHI-5035, " Maintenance Rule Program Administration," on the conduct of maintenance rule
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condition report investigations. This guidance will d
correct the deficiencies noted in " Reasons for the i
violation" above.
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5.
Date When Full Comoliance Will Be Achieved
Full compliance was achieved on December 2, 1996, when the
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unavailability goal was reduced to 296 hours0.00343 days <br />0.0822 hours <br />4.89418e-4 weeks <br />1.12628e-4 months <br />.
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Unresolved Item i
In additioat to the above two violations, the notice of violation j
contained the following unresolved item which is addressed below, i
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Attachment to AEP:NRC:1238E Page 4 UNR 50-315/96009-06(DRS) and UNR 50- 316 /96 00 9- 06 (DRS )
The unresolved item concerned the possibility problems with certain SSCs could be masked by our functional failure (FF)
definitions.
Specifically,
" Reviewing CRs and work orders for the air system, the team found a number of instances of what appeared to be FFs as defined by the licensee's program."
" Based on the team's findings, the licensee agreed to reevaluate the FF definition for the air dryers, considering the active system components and the effects on the SSCs."
"In addition to examining the relevant parts of the maintenance rule program, the team reviewed CRs and work
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orders for the vital batteries and discovered an occurrence where an operator, in preparing for a test, opened an incorrect disconnect, deenergizing a bus.
While this was properly classified as an FF, its relationship to overall maintenance was not recognized. Consequently, this occurrence was not appropriately classified as an MPFF.
The FF definition for the batteries was based on entry into Technical Specification 3.8.2.3, which requires a DC bus, a 250 VDC battery, and a full capacity charger.
Since each battery had two chargers, a charger failure would not result in an LCO entry; repeated charger failures would not trigger an FF nor be tracked under the maintenance rule. "
" Based on the team's findings, the licensee agreed to reevaluate the battery charger failures and the appropriate classification of FFs."
Actions Taken i
Relative to the air dryers, their maintenance rule function is to
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act as a path for compressed air, the motive force, to controls and valves.
Our failure definition was narrowly worded as if the dryers were merely pipes. That is, it listed loss of pressure boundary as the sole example of a failure. We have since changed that definition to one which better reflects the complexity of the dryers and possible failures that could impact the delivery of compressed air.
Examples include failures such as plugged
filters and failed desiccant bed screens. These failures would have been recognized as functional failures even before the rewording of the failure definition.
For the battery chargers, we now consider a loss of an individual battery charger as being a functional failure, and this clarification has been added to the database. A re-review of
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battery train condition reports written in the last three years was performed using this new guidance. The unit 2 N train was identified as having three functional failures during this period. However, only two of the functional failures were categorized as maintenance preventable. Therefore, the SSC did not exceed the allowable limit of two functional failures.
For other systems not mentioned in the inspection report, we will perform a review of functional failure definitions to determine
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Attachment to AEP:NRC 1238E Page 5 whether masking of equipment failures is occurring. This will be completed by February 28, 1997.
I Regarding the case where the operr. tor opened an incorrect disconnect in conducting a lineup for a battery drawdown test, we have reevaluated this incident and do not consider this a maintenance preventable functional failure (MPFF). This is based on the examples given in Section 9.4.5 of NUMARC 93-01.
One example provides that failures due to operational errors are not
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i considered MPFFs.
In addition, Item 31 of Section 12 of Appendix C (Questions and Answers from Workshop) of the proceedings from the 1993 NUMARC Industry Workshops on Implementation of the Maintenance Rule states that operational activities (i.e., tag-outs) are not maintenance related and therefore would not create an MPFF.
The NRC was present at these workshops, and later accepted these QEAs ao guidance. Based on this NUMARC guidance, our program makes the determination of MPFF on a case-by-case basis based on which workgroup performs the action.
If the action is something only operators would perform, then that inappropriate action would not be considered a MPFF.
However, if an operator inappropriately performs an action that-maintenance personnel also normally perform (such as topping off a lube oil reservoir) then that would be a MPFF.. Performing lineups for battery drawdown tests is something that only operators normally perform. Therefore, we do not consider this a MPFF.
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