ML17317A748

Responds to 781004 NRC Ltr Re Violations Noted in Inspec Repts#50-315/78-24 & #50-316/78-22.Corrective Actions: Procedures Rev to Include Requirements of Tech Spec 4.0.5 & 4.5.2.f.1,new Procedure 12THP 4030.STP.022 Established

ML17317A748
Person / Time
Site:	Cook
Issue date:	10/27/1978
From:	Dolan J AMERICAN ELECTRIC POWER CO., INC.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 7811210446
Download: ML17317A748 (8)

Text

AMERICAN ELECTRIC POWER Service Corporation 2 Broadway, Nna York, X Y. )0004 (2)2) 422.4800 JOZiV E.DOLLY Senior Enccnacc Vscc Prccidcnc Enginccring October 27, 1978 AEP:NRC:00100 Donald C. Cook Nuclear Plant Units 1 & 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 Mr. J. G. Keppler, Regional Director U.S. Nuclear Regulatory -Commission Office of Inspection and Enforcement Region III 799 Roosevelt Road Glen Ellyn,IL 60137

Dear Mr. Keppler:

Thi*s letter is in response to Mr. Gaston Fiorelli's letter dated October 4, 1978 which we received on October 6 and which transmitted to us IE Inspection Report Nos. 50-315/78-24; 50-316/78-22. Appendix A to that letter was a Notice of Violation citing three -infractions and one deficiency. The attachment to this letter is the required response to the Notice.

Very truly yours, JED:em hn E. Dolan attachment cc: R. C. Callen G. Charnoff P. W. Steketee R. J. Vollen R. Walsh D. V. Shaller-Bridgman R. W. Jurgensen 1 1978 c

Donald C. Cook Nuclear Plant Units 1 5 2 AEP:NRC:00100 Docket Nos. 50-315 8 5'0-316 License Nos. DPR-58 and DPR-74 Response to Notice of Violation Generated by IE Inspection Report Nos. 50/315/78-24; 50-316/78-22 Item 1 - Infraction

-"Technical Specification 3.7.1.2 requires when in Modes 1, 2 and 3 that an inoperable auxiliary feedwater pump be restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the plant be in Mode 4 within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Contrary to the above, results of the turbine driven auxiliary feedwater pump surveillance test conducted on June 7, 1978, in accordance with Technical Specification 4.7.,1.2.a.l indicated the pump to be inoperable with the plant in Mode 1 and the action required by Techni'cal Specification 3.7.1.2 was not taken."

Ex lanation The Surveillance Test Procedure being used by the Operator..to test the turbine driven auxiliary feed pump was inadequate.

The acceptance criteria of the procedure addressed only the requirements of Technical Specification 4.0.5.and did not in-clude the specific criteria for Technical Specification 4.7.1.2.a'.l.

When the Operator performed the test he was unaware of the latter requirements.

Corrective Actions Temporary changes to the procedures were made immediately after the discrepancy was found. The completely revised procedure was issued October 18, 1978. The procedure was revised to in-clude the specific requirements of Technical Specification 4.0:5 (ASME Section XI requirements). Subsequent testing proved the pump was operable.

The procedure revisions include specific criteria for guidance of the Operator to determine if the turbine driven auxiliary feedwater pump is satisfactory with regard to pressure and flow.

The procedure also includes acceptable ranges of vibration, lubrication and pump differential pressure. Providing this clear, concise, complete procedure will prevent recurrence.

AEP:NRC:00100 A meeting was held October 20, 1978 with the Shift Operating Engiaeerb to re-emphasize that Technical Specification require-ments must be fulfilled and that if equipment does not meet the requirements, then immediate action must be taken to de-clare the equipmertt inoperable and action must be taken to re-store the equipment to an operable condition within the required time frame or to follow the dictates of the Action Statements of the Technical Specifications.

Item 2 - Infraction "Technical Specification 4.5.2.f.l requires that the centrifugal charging pump be demonstr ated oper able every month by verifying the indicated discharge pressure to be > 2405 psig during test-ing required by Technical Specification 4.0.5 (ASNE Section XI testing).

Contrary to the above, testing conducted on April ll, 1978, as required by Technical Specification 4.0.5 did not verify dis-charge pressure to be > 2405 psig due to a leaking pressure gauge ((PI-253) coupling and retesting was not conducted after corrective maintenance was completed on the gauge coupling on April 12, 1978."

Ex lanation When the:leaking gauge connector was found .the Operator. correct;ly submitted a job order to effect repairs. However; the.- Operator--

then mistakenly signed off the surveillance .test instead of leaving it unsigned and marking it as incomplete testing on the toaster Test Schedule.

Corrective Actions The pump was retested after the error was found by the NRC inspectors and found to meet acceptance criteria.

The surveillance test" procedure was also revised to fully incor-porate the requirements of Tech. Spec. 4.5.2.f.l and 4.0.5.

This event was discussed with the Operator involved and at a Shift Operating Engineers'eeting on October 20, 1978. At the meeting it was emphasized that if equipment does not meet acceptance criteria the test documentation is not to be signed off, the Master Surveillance Schedule is to be marked incomplete, action is to be taken to declare the equipment inoperable, and the Action Statements of the Technical Specifications are to be complied with.

AEP:NRC:00100 Item- Infraction "Technical Specification 4.0.5 requires inservice testing of ASME Code Clasi 1, 2 and 3 pumps be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code 1974 Edition and Addenda through Summer 1975.

Contrary to the above,

a. Records of inservice tests for the period January 20, 1978 through March 3, 1978 did not include the identification of instruments used, comparisons with allowable ranges of test values and analysis of deviations as required by Section XI, Subarticle IWP-6240."

Corrective Action To preclude omissions of this data, procedure 12THP 4030.STP.022

" ISI Pump Test Program" entitled was issued on September 29, 1978. This procedure encompasses the following:-

a) Instrument calibration requirement; b) Allowable ranges of test data; c) The responsibility of evaluating accumulated data and direct'ing subsequent'action if deemed necessary.

Full compliance was achieved=on September 29, 1978.when procedure 12THP 4030.STP.022 was approved and issued.

b. "Records of inservice tests performed during the month of March 1978 on ECCS Train B were-not accessible as required by Section XI, Subarticle IWP-6260."

~E The testing of ECCS Train B was conducted on March 17, 1978, and signed off in the weekly surveillance log. Subsequent to this test the records were sent on their normal routing. However, to date the plant has been unable to 1'ocate these records.

Corrective Action All personnel engaged in filing, transmitting, and using documents associated with the Master File have been briefed concerning per-sonnel responsibilities in this area.

c. "The August 22, 1978 results of a component cooling water pump 2W test and the August 8, 1978 results of an essential service water pump 2E test were in the "Required Action Range" of Table IWP-3100-2 of ASME Code Section XI and the pumps were not declared inoperable as required by Section XI, Subarticle IWP-3230. Several other examples were noted where test results were in the "Alert Range" of Table IWP-3100-2 and testing frequencies were not doubled as required by Subarticle IWP-3230."

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AEP:NRC:00100

~I This discrepancy was due in part to the following: the data obtained were questioned by the ISI Supervisor and were being re-evaluated to determine a) the validity of the pump data obtained, or b) if the reference figures needed to be changed.

Subsequent engineeting reviews have determined that the data being generated were unsound.

Corrective Actions This situation has been rectified by transferring the test re-sponsibility to the Plant Performance Engineering Section effective October 1, 1978. The technical experience in this group better qualifies them to monitor and evaluate all aspects of the pump test program.

Subsequent to the reported audit, the component cooling water 2W pump was retested and proved operable. The essential service water 2E pump was also retested and proved operable upon renor-malization of reference values based upon the pump manufacturer's test curve..

I . ~Ii "Technical Specification 6.5.2.10.a requires minutes of each NSDRC meeting be prepared, approved and forwarded to the Senior Executive Vice President,. Engineering and Construction, AEPSC, wi.thin 14 days following each meeting.

Contrary to the above, the minutes of 'NSDRC Meeting No. 18 conducted on April 6, 1978 were -not prepared, approved and for-warded until July 18, 1978."

Corrective Actions Additional staff has recently been hired in the Nuclear Safety and Licensing Section. At the same time, the extra workload due to Unit 2 startup has declined. A high priority has'een assigned to the preparation of NSDRC meeting minutes to assure that the 14 day deadline is met for future meetings.