ML17325B000
| ML17325B000 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 10/28/1988 |
| From: | Will Smith INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | Davis A NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8811070106 | |
| Download: ML17325B000 (15) | |
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ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:8811070106 DOC.DATE: 88/10/28 NOTARIZED:
NO DOCKET FACIL:50-316 Donald C.
Cook Nuclear Power Plant, Unit 2, Indiana 05000316 AUTH.NAME AUTHOR AFFILIATION SMITH.W.G.
(formerly Indiana
& Michigan Ele RECIP.NAME RECIPIENT AFFILIATION DAVIS,A.B.
Document Control Branch (Document Control Desk)
SUBJECT:
Special rept re absence of backup power for greater than 30 days for WMDAFP
& LSI.
DISTRIBUTION 'CODE:
IE22D COPIES RECEIVED:LTR
(
ENCL SIZE:
TITLE: 50.73 Licensee Event Report (LER), Incident Rpt, etc.
NOTES:
RECIPIENT ID CODE/NAME PD3-1 LA SCOTT,W INTERNAL: ACRS MICHELSON ACRS WYLIE AEOD/DSP/TPAB DEDRO NRR/DEST/CEB 8H NRR/DEST/ICSB 7
NRR/DEST/MTB 9H NRR/DEST/RSB 8E NRR/DLPQ/HFB 10
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NRR/DOEA/EAB 11 NRR/DREP/RPB 10 NUDOCS-ABSTRACT RES/DSIR/EIB RES/DSR/PRAB EXTERNAL EG&G WILLIAMSI S H ST LOBBY WARD NRC PDR NSIC MAYS,G COPIES LTTR ENCL
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1 1
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1 1
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RECIPIENT ID CODE/NAME PD3-1 PD ACRS MOELLER AEOD/DOA ARM/DCTS/DAB NRR/DEST/ADS 7E NRR/DEST/ESB 8D NRR/DEST/MEB 9H NRR/DEST/PSB 8D NRR/DEST/SGB 8D NRR/DLPQ/QAB 10 NRR/DREP/RAB 10 RR~
/SIB 9A 02 RES/DSR DEPY RGN3 FILE 0 1 FORD BLDG HOY,A LPDR NSIC HARRIS,J COPIES LTTR ENCL.
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8 NOSE LO ALL "RIDS" RZCIPIENTS:
PLEASE HELP US IO REDUCE WASTE!
CXRI'ACI'K DOCUMEÃI'ONTROL DESK ROOM P1-37 (EXT. 20079)
TO EZZMINATE YOUR NME FRQH DISTRIBUTION LIPIS H)R DOCllMEXZS YOU DGNiT NEED)
Sj A
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 43 ENCL 42
Indiana Michige~
Power Company~
CooI Noeiear PianI PO. Box 468 B~idoman Mi 49106 O'Iv~. 69vi INQMMA NICHE6Alk" PM%P October 28, 1988 Donald C.
Cook Nuclear Plant Unit No.
2 Docket No. 50-316 License No.
DPR-74 U.S. Nucl'ear Regulatory Commission Document Control Desk Washington D.C.
20555 ATTN:
A. B. Davis:
Dear Mr. Davis:
This special report is being submitted in accordance with the our commitment to administratively implement the proposed Technical Spec-ifications required for support of the alternate safety shutdown or emergency remote shutdown of the opposite fire affected Unit.
Reference letters AEP:NRC:0692AJ dated May 30,
- 1986, and AEP:NRC:0692AR dated June 23, 1986.
The Unit 2 West Motor Driven Auxiliary Feedwater Pump (WMDAFP) and the Unit 1 Local Shutdown Instrumentation (LSI) were without backup power for greater than thirty (30) days.
Backup power is required to take credit for this, equipment per our 10CFR50 Appendix R analysis.
An outage of more than thirty (30) days requires a Special Report be submitted per our initially proposed Technical Specifications.
Simultaneously with the WilDAFP being without backup power, the East Motor Driven Auxiliary Feedwater Pump (EMDAFP) was unavailable due to performance of scheduled outage work.
As a result, there were no available auxiliary feedwater pumps, with backup power, for alternate safe shutdown in support of the opposite Unit.
A brief time line follows which depicts the originally proposed equip-ment outage schedules, reasons for exceeding these schedules and the expected equipment restoration schedule.
Pc;11O7()10(g 881028 P6R ADOCK 050OO316 PDC
U.S. Nuclear Re atory Commission October-28, 1988 Page 2
August 1, 1988:
The A Train Emergency Diesel Generator is removed from service for a scheduled 51 day outage.
Since this diesel provides backup power to the
- EMDAFP, the RiDAFP is verified available in support of Unit l.
Scheduled plant outage work on the EMDAFP is also commenced on this date.
This outage work includes two Plant Modifications.
September 2,
1988:
Modification
$/1 on the EMDAFP is scheduled for completion, however due to physical design problems this modification is extended to October 17, 1988.
September 9,
1988:
September 19, 1988:
Modification jj2 on the EMDAFP is completed.
The R1DAFP is removed from service for lubrication.
This started the 30 day period of unavailability for the Auxiliary Feedwater Pumps.
September 21, 1988:
The Train A Emergency Diesel Generator is returned to service.
Due to the problems with Modifcation //1 on the EMDAFP it remains unavailable.
The Train B
Emergency Diesel Generator is removed from service leaving both the WliDAFP and LSI instrumentation without backup power supplies.
This started the 30 day period of unavailability for the LSI instrumentation.
October 8, 1988:
The Unit 2 Condensate Storage Tank (CST) is isolated for hydrostatic testing.
Due to problems found during this testing it is unavailable until 10/24/88.
October 17, 1988:
Modification /jl to the EMDAFP is complete, but it was decided not to test the pump to officially declare it operable due, to the fact that sodium dye had been injected into Unit 2 CST.
Due to the various cross connects in the Auxiliary Feedwater System there was a significant risk that Unit 1's operating Steam Generators would become contaminated with the dye.
The EMDAFP could have been run in an emergency to supply Unit 1 with water from the Unit 1
CST, but its availability could not be "proved" until it could be tested on the Unit 2 CST.
October 24, 1988:
The Unit 2 CST restored to availability.
October 26, 1988:
The Unit 2 EMDAFP is available in support of Unit 1
for alternate safe shutdown purposes, with backup power supply.
U.S. Nuclear Re atory Commission October 28, 1988 Page 3
November ll, 1988:
The Train B Emergency Diesel is scheduled to be returned to service on this date.
This will restore backup power to the WMDAFP and ISI instrumentation.
During the period of time in which both Auxiliary Feedwater pumps were unavailable, compensatory action in the form of the fire watches were utilized in the affected plant areas..
These same compensatory measures will continue for the LSI instrumentation until its backup power supply is restored to operable status.
Respectfully, 1 gJR.
J W.
G. Smith, Jr.
cc:
D. H. Williams, Jr.
A. B. Davis (Region III) l1. P. Alexich R. F. Kroeger H. B. Brugger R.
W. Jurgensen NRC Resident Inspector J.
Stang (NRC)
R.
C. Callen G. Charnoff, Esq.
Dottie Sherman (ANI Library)
D. Hahn INPO PNSRC A. A. Blind P.
A. Barrett/P.
Lauzau
Distribution Sheet Distri19.txt Priority: Normal From: Stefanie Fountain Action Recipients:
NRR/DLPM/LPD3-1 J Stang Internal Recipients:
TTC C-TNN RidsEdoMailCenter RGN 3.FILE 01 OGC/RP OE NRR/DRIP/REXB NRR/DIPM/OLHP NRR/DIPM/IIPB
-ILE-CENTER DEDRO ACRS Copies:
Not Found Not Found Not Found 1
OK Not Found Not Found Not Found 1
Not Found 1 'ot Found Not Found Not Found Not Found Not Found External Recipients:
NRC PDR NOAC INEEL Marshall Total Copies:
16 Not Found Not Found Not Found
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Item: ADAMS Document Library: ML ADAMS"HQNTAD01 ID: 993350034
Subject:
Response to Notice ofViolation noted in inspection report 50-316/99-017.Corrective acti ons taken:Surveillance Procedure 02-OHP 4030.STP.054E,rev 7 was placed on administ rative hold until safety evaluations for changes 2 8 3 can be completed.
Body:
PDR ADOCK05000316 Q Page 1
~ k 7
Docket: 06000316, Notes: N/A Distri49.txt Page 2
Indiana michigan One Cookie Mgnm. Ml49106 616466901 November 19, 1999 C1 199-22 Docket No.:
50-316 US Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop 0-P1-17 Washington, DC 20555 Donald C. Cook Nuclear Power Plant, Unit2
. RESPONSE TO NOTICE OF VIOLATION50-316/99017-01 On September 22, 1999, the U. S. Nuclear Regulatory Commission issued Inspection Report 50-315(316)/99017.
This inspection report contained, in-part, Notice Of Violation (NOV) 50-316/99017-01
~
This NOV cited an example of Indiana Michigan Power Company's (1&M)failure to meet the requirements of 10 CFR 50.59. I&Macknowledges and accepts this violation.
During I&M's investigation into the cause of the cited violation, a second example of a failure to meet the requirements of 10 CFR50.59 was identified.
Therefore, during the week of October 17, 1999, I&M.metwith the NRC Senior Resident Inspector assigned to Cook Nuclear Plant. This meeting focused on the status ofI&M'sNOV investigation activities, the projected completion date for the investigation, and the need for a 30 day extension on the NOV response due date. I&Mrequested and was granted a 30 day extension on its NOV response due
. date.
The due date was moved from October 22,
- 1999, to November 21, 1999.
This letter transmits I&M'sresponse to the NOV. Attachment 1 of this letter contains a discussion ofI&M's evaluation of, and corrective actions associated with, the NOV. of this letter contains a list of commitments associated with the NOV.
'EP:America's Ence@'arlner @
pgp~ A,~.ic.,~w>.<h a9/4
U. S. Nuclear Regulatory Commission Page 2 C1 199-22 Should you have any question, please contact Robert C. Godley, Director of Regulatory Affairs, at (616) 466-2698.
Sincerely, A. C. Bakkea2lL Site Vice President
/dms Attachments c:
J. E. Dyer MDEQDW &RPD NRC Resident Inspector R. Whale
ATTACHMENT1 TO C1199-22 Restatement OfThe Violation:
10 CFR 50.59 requires, in part, that the licensee shall maintain records of changes in procedures made pursuant to this section, to the extent that these changes constitute changes in the facilityas 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.
The UFSAR, in Section 9.3, "Residual Heat Removal," stated that, "The cooldown rate of the reactor coolant is controlled by regulating the flow through the tube side of the residual heat exchangers.
A bypass line, which serves both residual heat exchangers, is used to regulate the temperature of the return flow to the reactor. coolant system as well as maintain,a constant flow through the RHR system."
Contrary to the above, on May 21, 1999, the licensee performed a surveillance test on the Unit 2 East Residual Heat Removal (RHR) Train using the Component Cooling Water System to regulate the temperature ofthe return flowto the reactor coolant system.
The licensee performed the surveillance test using Change2 to Surveillance Procedure 02-OHP4030.STP.054E, "East Residual Heat Removal Train Operability Test - Shutdown,"
Revision 7, without having performed a full safety evaluation.
The. licensee failed to restore compliance after Non-Cited Violation 50-316/99004-04 was identified in March 1999 for the same issue (Violation 50-316/99017-01 (DRP)).
This is a Severity Level IVviolation (Supplement 1).
Admission/Denial OfThe Violation:
Indiana Michigan Power (1&M)admits to the Notice ofViolation (NOV).
. During the investigation of this violation it was determined that an additional violation of 10 CFR 50.59 occurred involving Change 3 to surveillance procedure 02-OHP 4030. STP.054E.
Reasons For The Violation:
Back round Iriformation:
During plant shutdown conditions, Cook Nuclear Plant (CNP) Operations personnel use the RHR system'to provide core cooling.
This activity is accomplished, in part, by controlling reactor coolant flow through the RHR heat exchanger.
The control of reactor coolant flow through the heat exchanger is accomplished by throttling the RHR heat exchanger outlet and bypass valves.
The performance of this activity is discussed in Section 9.3, "Residual Heat Removal," ofthe Updated Final Safety Analysis Report (UFSAR).
Attachment 1 to C1199-22 Page2 During extended outages (i.e., when decay-heat loads are very low), the RHR heat exchanger outlet valve is throttled to a point where turbulence is induced on the downstream side of the RHR heat exchanger outlet valve.
This turbulence results in the system flow instrumentation responding erratically.
To address this concern, Operations developed an informal strategy of throttling RHR heat exchanger outlet flow in combination with the throttling of Component Cooling Water (CCW) to the RHR heat exchan'ger.
This action reduces the amount. of turbulence, while at the same time ensuring adequate core cooling. Although the throttling of CCW flowto the RHR heat exchangers has been a long standing practice, it is not discussed as a shutdown cooling method in the UFSAR.
Change 2 to Surveillance Procedure 02-OHP4030.STP.054E, Revision7, added procedural guidance (embedded in a note) that relied on this practice.
This procedural change assumed that, under very low decay heat conditions, Component Cooling Water to the RHR heat exchanger could be throttled in place of Reactor Coolant System (RCS) fiow rate through the RHR heat exchanger.
The procedure developer and screeners/evaluators failed to recognize that the practice assumed by the change needed to be evaluated against UFSAR Section 9.3.
Shortly after issuance of Change No. 2, the process for maintaining reactor coolant temperature was questioned.
To address the question, Operations issued Change 3 to Surveillance Procedure
'02-OHP 4030.STP.054E, Revision7, which formalized the practice assumed by Change 2.
Subsequently, IEc M received Non-Cited Violation (NCV) 99004-04.
The individual who was assigned the responsibility for evaluating NCV 99004-04 incorrectly believed the NCV was adequately addressed by the issuance of Change 3. This error led the evaluator to believe that all of the immediate corrective actions were completed and the concern had been resolved.
Therefore, CNP failed to resolve the concern in a timely and effective manner.
NOV 99017-01 was received in September 1999.
During the course of the subsequent investigation, it was discovered that Change 3 to 02-OHP 4030.STP.054E, Revision 7, also did not have a safety evaluation as required by 10 CFR 50.59.
The 10 CFR 50.59 evaluation of Change 2 to Surveillance Procedure 02-OHP 4030.STP.054E, Revision 7, has been completed.
This evaluation determined that this change in operating practice did not constitute an unreviewed safety question.
Reason For Violation:
The cause ofthis violation was an organizational mindset that controlling the RCS temperature via manipulation of CCW flowrate to the RHR heat exchanger was not a change to the plant or procedures as described in the UFSAR, because this activity had been a long-standing practice.
This mindset resulted in IAM's failure to meet the screening requirements set forth in 10 CFR 50.59 for two consecutive changes to Surveillance Procedure 02-OHP 4030.STP.054E, Revision 7.
Attachment 1 to C1199-22 Page 3 The mindset discussed in the causal statement above also played a contributing role in CNP's failure to implement prompt corrective actions.
Specifically, the responsible individuals failed to identify and understand that Change 2
to Revision 7
of Surveillance Procedure 02-OHP 4030.STP.054E resulted in a change to a station procedure as described in the USFAR.
In response to NCV 99004-04, CNP initiated Condition Report 99-14175.
This condition report contained a statement that led the evaluator to assume Change 3, Revision 7, of Surveillance Procedure 02-OHP 4030.STP.054E had been evaluated and adequately addressed and corrected the NRC's concern.
This also contributed to the delay in. resolving the identified non-compliance.
Corrective Steps That Have Been Taken And Results Achieved:
To ensure the NRC identified concern, as well as the extent of the concern were adequately understood and corrected, Operations reevaluated Condition Report 99-14175.
This condition report documents the results of our root cause'valuation, cause and extent evaluation, and our corrective action plan.
Surveillance Procedure 02-OHP 4030.STP.054E, Revision 7, was placed on administrative hold until safety evaluations for Changes 2 and 3 could be completed.
Change 2 to Revision 7 of Surveillance Procedure 02-OHP 4030.STP.054E, has been evaluated and found to be acceptable.
This action was completed on October 19, 1999.
Case Specific Checklist 0350 Restart Action Plan 4, "Safety Evaluations,"
discusses the corrective actions taken/planned to enhance CNP programs for implementing requirements established in 10 CFR 50.59.
The actions discussed in this Restart Action Plan have significantly improved the CNP 10 CFR 50.59 process.
The Operations Procedure Group supervisor discussed the screening errors with the procedure writers group..
This action was taken to ensure all individuals understand management's expectations for properly performing 10 CFR 50.59 screening activities.
Corrective Steps That WillBe Taken To Avoid Further Violations:
All 50.59 qualified screeners and evaluators willreview a summary of Violation 99017-01 and 18'cM's response.
This action willbe completed by December 10, 1999:
I&Mwill include this violation response in the lessons learned section of the 10 CFR50.59 training program. This action willbe completed by March 1, 2000.,
Attachment 1 to C1199-22 Page 4 Date Full Compliance WillBe Achieved:
Surveillance Procedure 02-OHP-4030.STP.054E was placed on administrative hold until it is properly evaluated in accordance with the requirements set forth in 10 CFR 50.59. CNP is in full compliance with the requirements of 10 CFR 50.59.
ATTACHMENT2 TO C1199-22 Commitments Associated WithLetter C1199-22 All 50.59 qualified screeners and evaluators willreview a summary of Violation 99017-01 and IAM'sresponse. This'action willbe completed by December 10, 1999.
ISLAM will include this violation response in the lessons learned section of the 10 CFR50.59 training program. This action willbe completed by March 1, 2000.