ML17319A716

Responds to NRC 810102 Ltr Re Violations Noted in IE Insp Repts 50-315/80-15 & 50-316/80-14.Corrective Actions:Need for Clear Guidance in Determining Occurrence Reportability Emphasized W/Staff

ML17319A716
Person / Time
Site:	Cook
Issue date:	01/23/1981
From:	Hunter R INDIANA MICHIGAN POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML17319A715	List: ML17319A716
References
AEP:NRC:00512, AEP:NRC:512, NUDOCS 8102230115
Download: ML17319A716 (6)

Text

INDIANA L MICHIGAN ELECTRIC COMPANY

p. o. box 18 SOWLtNG GREEN STATION NEW YORK, N. Y. 10004 4

January 23, 1981 AEP:NRC:00512 Donald C. Cook Nuclear Plant Unit Nos. 1 and 2, Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 IE Inspection Report Nos. 50-315/80-15; 50-316/80-14 1

Mr. James G. Keppler, Regional Director U.S. Nuclear Regulatory Coranission Office of Inspection and Enforcement Region III Glen Ellyn, Illinois 60137

Dear Mr. Keppler:

This letter is our response to the Notice of Violation attached as Appendix 'A'o Mr. R. F. Heishman's letter of January 2, 1981. In accord-ance with Appendix 'A'o Mr. Heishman's letter this response is being submitted under oath and affirmation.

On July 28, 1980, while Unit No. 2 was operating in Mode 1, the nitrogen cover pressure on one of the four accumulator tanks exceeded the upper limit of 644 psig specified in Technical Specification 3.5.1.d. for approximately ten minutes. The maximum pressure experienced was 650 psig.

This event was in fact the result of the failure of the high/low pressure alarm to clear during operator action to increase cover gas pressure. The transient nature of this event and the magnitude of the pressure excursion

(+6 psi) coupled with the normal accuracy of the pressure monitor (+ 14 psi) and the apparent lack of adverse safety significance led to the Plant Staff's request that personnel from American Electric Power Service Corporation (AEPSC) investigate the reportability of the event.

The results of the AEPSC review indicated that there was no reasonable adverse safety implications associated with the subject event. It was recognized that the apparent nitrogen overpressure did constitute entry into the 'Action Statement'f Specification 3.5.1.d., however, the reviewers Felt that the reporting criteria of Specification 6.9.1.9.b, "...operation 8 X O2230 C l5: 1981 QAII 2 8

Mr. James G. Keppler AEP:NRC:00512 in a degraded mode...", had not been fulfilled as the apparent cover gas overpressure did not impair the ability of the affected accumulator to perform its safety function. The AEPSC response to the Plant Staff's request failed to provide clear guidance as to the reportability of the subject event.

Effective corrective action by the operator(s) returned the accumulator cover gas pressure to within the limits of Specification 3.5.1.d. in ap-proximately ten minutes; well within the time period of one hour allowed by the 'Action Statement'f the Specification. The reportability of this event has been discussed with those members of the AEPSC staff involved with the aforementioned review. Particular emphasis was placed on the need for the AEPSC office to provide clear and concise guidance to the Plant Staff in matters such as the one discussed herein. These actions should be sufficient to prevent reoccurrence of similar events.

I Very truly yours,

. S. unter Vice President cc: John E. Dolan R. C. Callen G. Charnoff R. M. Jur gensen D. V. Shaller Region III Site Inspector

~ ~

STATE OF NEM YORK }

COUNTY OF NEM YORK)

J R. S. Hunter, being .duly sworn, deposes and says he is the I

Vice President of Licensee Indiana and Nichigan Electric Company, that he has read the foregoing response to the NRC Notice of Violation contained in IE Inspection Reports No. 50-315/80-15 and No. 50-316/80-14 and knows the contents thereof, and the said contents are true to the best of his knowledge and belief.

Subscribed and sworn to before this ~S yl of me day Gtt660ttY M. GtilttCAM Notary ublic Notary Public, State ot ttev> Ydk t'o. 31-4643431 Duatitic5 trr 1'v Yo'tc Counhr~

Commission Exp!res March 30, 1981,

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