ML17325B382
| ML17325B382 | |
| Person / Time | |
|---|---|
| Site: | Cook |
| Issue date: | 03/01/1990 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17325B381 | List: |
| References | |
| 50-315-89-31, 50-316-89-31, NUDOCS 9003140287 | |
| Download: ML17325B382 (4) | |
Text
NOTICE OF VIOLATION Indiana Michigan Power Company Donald C.
Cook 1 and 2
Docket No. 50-315; 50-316 License No. DPR-58; DPR-74 As a result of the inspection conducted on December 4 through 8, and December 18 through 22,
- 1989, and in accordance with 10 CFR Part 2, Appendix C General Statement of Policy and Procedure for NRC Enforcement Actions (1988),
the following violations were identified:
1.
10 CFR 50, Appendix B, Criterion V, as implemented by Section 1.7.5 of the Donald C.
Cook Operational guality Assurance Program requires that activities related to quality be prescribed by documented instructions, procedures, and drawings, that those activities be accomplished in accordance with those instructions, procedures and drawings, and that instructions, procedures, or drawings include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Procedure PMI-2290, "Job Orders," Revision 8, required in Sections 4.4.8 and 4.4.8.3 that upon completion of the physical work, the job order tags be removed and discarded.
Contrary to the above, tags
- 15119, 029643,
- B012209, B016950,
- 8016832, and B017240 were not removed although the job order s were cancelled or completed.
As a
- result, status of equipment condition remained indeterminate (315/89031-01A; 316/89031-01A).
Request For Change 12-2180 required installation of 200% overload motor protection and that the thermal overload be set at the low trip current rating.
Contrary to the above, on December 19, 1989, the inspectors observed that the thermal overload heater associated with residual heat removal loop isolation motor-operated valve 1CH-111 was set at the high trip current rating.
Numerous additional thermal overloads in the diesel generator motor control center were also observed to be the wrong size or set at the wrong current rating, which will result in premature removal of operating voltage from the motors (315/89031-01B; 316/89031-01B).
Procedure PHI-2030, "Document Control;" Revisior 10, failed to include requirements for the Master Drawing Indexes to be reviewed by intended users for the latest as built drawings located in the plant master file.
Consequently, drawings issued by the document control center for field verifications were not the latest as built drawings or revisions (315/89031-01C; 316/89031"01C).
d.
The "Pump Operator's Data" manual and the vendor manual for the Auxiliary Feedwater (AFM) pump required that the pump packing be adjusted while the pump is operating.
Contrary to the above, this requirement was not incorporated into the AFW maintenance procdures.
Although no problems were noted, inadequate attention to this requirement could result in rotor seizure, scored shaft sleeves, or burned packing (315/89031-01D; 316/89031-01D).
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Procedure 12 THP 6030 IMP.014 "Protective Relay Calibration", Revision 8, Step 8.1.2-2 specified that black electrical tape be used when cleaning the disk and drag magnet mechanism on Time Overcurrent (IAC) relays.
Contrary to the above, on December 5,
- 1989, a technician was observed using an unused calibration sticker to clean the 2AB EDG Time Overcurrent test relay.
As a result, cleanliness of the contacts was questionable (315/89031-01E; 316/89031-01E).
f.
Procedure PMI-2010 "Plant Manager and Department Head Instructions, Procedures and Index", Revision 17, Policy Statement
- 3. 1, Section
- 3. l. 1 required that "double asterisked" procedures for plant activities be "in-hand" when implementing the procedure.
Contrary to the above, on December 6,
1989, the inspector observed an operator rack in "2A" Train Reactor Trip Bypass Breaker without having "in hand" double asterisked procedure
""12-OHP 4021.082.018 "Racking In and Out Reactor Trip, Reactor Trip Bypass and MG Set Output Breakers,"
Revision 2.
Even though no adverse affects were noted, in the past under similar circumstances, a reactor trip occurred (315/89031-01F; 316/89031-01F).
g.
Procedure PMI-2010, "Plant Manager and Department Head Instructions, Procedures and Index," Revision 17, requires in Section
- 3. 14. 1 tnat all effective instructions and procedures be reviewed no less frequently than once every two years.
Contrary to the above, maintenance procedures MHI 2070, MHI 7090, PMI 4050, 12 THP 6030 IMP.071, and 12 THP IMP.062 were not reviewed in the last two years.
As a result, the procedures were not updated to reflect feedback and changes to preventive maintenance activities (315/89031-01G; 316/89031-01G).
This is a Severity Level IV violation (Supplement 1) 2.
10 CFR 50, Appendix B, Criterion VIII; as implemented by Section 1.7.8 of the Donald C.
Cook Operational Quality Assurance Program required that measures be established for the identification of materials, parts and components such as by part number, serial number, or other appropriate means on the item or records traceable to the item throughout fabrication, installation and -use of the item.
Contrary to the above, identification of materials and components for traceability was not accomplished for cable extension portions and aluminum splicing sleeves for connections to several 'safety-related motor control centers installed under the Request For Change 1482 modification (315/89031-02; 316/89031-02).
This is a Severity Level IV violation (Supplement 1).
3.
10 CFR 50, Appendix B, Criterion XI, as implemented by Section 1.7. 11 of the Donald C.
Cook Operational Quality Assurance Program required that a
test program be established to assure testing to demonstrate that systems and components will perform satisfactorily in service in accordance with test procedures which incorporate requirements and acceptance limits con-tained in applicable design documents, and that adequate test instrumentation was available and used.
Contrary to the above, test instruments were not sensitive or accurate enough to verify the'alibration of the undervoltage relays that actuate the Emergency Diesel Generators.
Procedure 2 THP 6030 IMP.250, "4kV Diesel
- Start, 4kV ESS Bus Undervoltage Relay Calibration," Revision 7, Section 3.0, required the use of a Westinghouse type PA-161 AC anolog voltmeter or its equivalent with equal or better accuracy and adequate range to measure the desired parameters.
However, the voltmeter had a tolerance of +1.5 volts that was not sufficiently accurate to measure the desired parameter of 90.3 to 91.8 volts specified in Technical Specification 3.3.2.
In addition, the voltmeter indicated to the nearest whole volt and did not have division markings between the numbers.
Technicians had to interpolate results and record values to the nearest tenth of a volt while the voltmeter's dial indicator was moving in the increasing or decreasing direction.
Furthermore, the technicians used hand signals to communicate the moment the under voltage relay operated.
Based on the inaccuracy and insensitivity of the voltmeter, and poor testing technique, results of the undervoltage test were not conclusive (315/89031-03; 316/89031-03).
This is a Severity Level IV violation (Supplement 1).
4.
10 CFR 50, Appendix B, Criterion XVI, as implemented by Section 1.7.16 of the Donald C.
Cook Operational Quality Assurance Program required that measures be established to assure that conditions adverse to quality were promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition was determined and corrective action taken to preclude repetition.
Contrary to the above:
The Plant Assessment Group Committee's review in March 1989 for Problem Report 89-245, concerned with the February 1989 failure of two safety-related 4kV breakers T-1106 and T-1104 to close on demand during tests due to lubrication hardening, failed to specify corrective action to prevent recurrence.
Furthermore, no action was taken to inspect other 4kV breakers for common mode failure.
Consequently, in Yiarch and April of 1989 seven additional safety related and balance of plant breakers failed to close during testing, which was also caused by hardening of the lubricant on the breaker linkage (315/89031-04A; 316/89031-04A).
b.
Corrective action was neither prompt nor adequate to correct maintenance related problems identified by the licensee in February 1988.
In December
- 1989, 36 of these 71 self identified findings and recommenda-tions were reopened.
During this inspection many of the same problems were identified that reflect a significant weakness in the corrective action system (315/89031-04B; 316/89031-04B).
This is a Severity Level IV violation (Supplement 1).
pursuant to the provisions of 10 CFR 2.209, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each violation (1) the corrective actions that have been taken and the results achieved; (2) the corrective actions that will be taken to avoid further violations; and (3) the date when full compliance will be achieved.
Consideration may be given to extending your response time for good cause shown.
Dated f
/VWD H
. Hiller, Director Division of Reactor Safety