ML17328A032
| ML17328A032 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 05/11/1989 |
| From: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | Davis A NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| AEP:NRC:1090B, NUDOCS 8905170193 | |
| Download: ML17328A032 (6) | |
Text
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DE MONSTRAT1 ON SYSTEM REGULATORY INFORMATION DISTRIBUTXON SYSTEM (RXDS)
CESSION NBR:8905170193 DOC.DATE: 89/05/11 NOTARIZED: NO DOCKET FACIL:50-315 Donald C.
Cook Nuclear Power Plant, Unit 1, Indiana 05000315 50-316 Donald C.
Cook Nuclear Power Plant, Unit 2, Indiana 05000316 AUTH.NAME AUTHOR AFFILIATION ALEXICH,M.P.
(formerly Indiana
& Michigan Ele RECIP.NAME RECIPIENT AFFILIATXON DAVIS,A.B.
Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 890407 ltr re violations noted in Insp Repts 50-315/89-09
& 50-316/89-09.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR L ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:
RECIPIENT ID CODE/NAME PD3-1 PD INTERNAL: AEOD AEOD/TPAD NRR SHANKMAN,S NRR/DLPQ/PEB 11 NRR/DOEA DIR 11 NRR/DREP/RPB 10 NRR/PMAS/ILRB12 OE LIEBERMAN,J E~I 02 EXTERNAL: LPDR NSIC COPIES LTTR ENCL 1
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1 RECIPIENT ID CODE/NAME STANG,J AEOD/DEIIB DEDRO NRR/DEST DIR NRR/DLPQ/QAB 10 NRR/DREP/EPB 10 NRR/DRIS DIR 9A NUDOCS-ABSTRACT OGC/HDS1 RGN3 FILE 01 NRC PDR COPIES LTTR ENCL 1
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LTTR 24 ENCL 24
Indiana Michigan Power Company P.O. 8ox 16633 Columbus. OH 43216 INDIANA IitNICHIGAN POWER AEP:NRC:1090B Donald C.
Cook Nuclear Plant Units 1 and 2
Docket Nos.
50-315 and 50-316 License Nos.
DPR-58 and DPR-74 NRC INSPECTION REPORT NOS.
50-315/89009 (DRP)
AND 50-316/89009 (DRP);
RESPONSE
TO VIOLATION U.
S. Nuclear Regulatory Commission Document Control Desk Washington, D.
C.
20555 Attn:
A. B. Davis May 11, 1989
Dear Mr. Davis:
This letter is in response to W. L. Axelson's letter dated April 7, 1989, which forwarded the report on the routine safety inspection conducted by members of your staff.
This inspection was conducted from February 8 through March 21, 1989 on act'ivities at the Cook Nuclear Plant.
The Notice of Violation attached to Mr. Axelson's letter identified one violation associated with 'the performance of maintenance activities.
This violation is addressed in the attachment to this letter.
This document has been prepared following Corporate procedures that incorporate a reasonable set of controls to ensure its accuracy and completeness prior to signature by the undersigned.
Sincerely,
/
M. P. Alexi Vice President MPA/eh Attachment cc'D.
H. Williams, Jr.
W.
G. Smith, Jr.
- Bridgman R.
C. Callen G. Charnoff G.
Bruchmann A. B. Davis
- Region III NRC Resident Inspector
- Bridgman 8905170i9
< 85'O~i i PDR ADOCK 050003i~i PDC
ATTACHMENT TO AEP'NRC:1090B
RESPONSE
Attachment to AEP:NRC:1090B Page 1
NRC VIOLATION "Units 1 and 2 Technical Specifications 6.8.1.a require written procedures shall be established covering items recommended in Appendix "A" of Regulatory Guide 1.33, November 1972, which includes (at Section I.l) procedures for maintenance activities involving more than "skills normally possessed by qualified maintenance personnel".
Technical Specification 6.8.2 requires these procedures shall be reviewed by the PNSRC and approved by the Plant Manager prior to implementation.
Contrary to the above, maintenance of a unique kind, involving safety related Unit 1 4KV breaker triggering mechanism inspection, cleaning and lubrication, was performed on February 21,
- 1989, and other dates pursuant to a "guideline" which had neither been reviewed by PNSRC nor approved by the Plant Manager prior to implementation.
B.
Also contrary to the above, maintenance of a unique kind, involving safety related Unit 2 main steam stop valve hydraulic actuator pressure relief valve setting, was performed on March 2, 1989 pursuant to a "guideline" which had neither been reviewed by PNSRC nor approved by the Plant Manager prior to implementation.
This is a Severity Level IV violation (Supplement I)."
RESPONSE
TO VIOLATION We believe that the work performed in the two instances cited was in accordance with Technical Specification (T/S) 6.8.1 and our commitment to Reg..Guide 1.33.
As noted in the text of the NRC Inspection Report, the Guidelines were appropriately researched and followed, the work was documented on individual Job Orders, and the information is retrievable.
This is consistent with the requirements of the governing approved plant procedure (PMI-2290) which provides for performance of maintenance activities in accordance with documented instructions traceable to approval by the Cognizant Engineer.
This requirement has been implemented in the past as a standard maintenance
- practice, and was formally adopted in Revision 8 to PMI-2290 which was effective March 1,
1989.
In the case of the 4KV breaker inspection cleaning and lubrication, the instructions contained in the Guideline for cleaning and relubricating the triggering mechanism were taken from written instructions received directly from the
Attachment to AEP:NRC:1090B Page 2
manufacturer's representative and received written concurrence from the AEPSC Cognizant Engineer.
The Guideline for maintenance on the Unit 2 main steam stop valve pressure relief valve was taken from the vendor's technical manual which had also been formally approved by the Cognizant Engineer.
It should also be noted that with regard to the 4KV breaker maintenance, the cleaning and lubrication of breakers is a frequently performed task.
The Guideline used for performance of this maintenance activity did not require maintenance personnel to perform any tasks beyond those that could be expected to be performed during any breaker maintenance.
The distinction in the cited instance is that prior to initiation of the maintenance activity a specific lubricant type and breaker cycling requirement was specified.
The actual application of the lubricant and cycling of the breakers are both activities that fall within the skills normally possessed by qualified maintenance personnel.
(1)
Corrective Actions Taken and Results Achieved As noted above, we believe that the work performed in the instances cited was in accordance with the applicable approved plant procedures and T/S requirements.
In addition, it is noteworthy that the inspection report acknowledges that the work was completed using technically clear and correct instructions.
'(2)
Corrective Action Taken to Avoid Further Violation We recognize the value of including in formal procedures those guidelines generated for the performance of infrequent tasks of a limited scope as well as relevant portions of those generated during pre-planning of more complex work activities (as noted in the NRC inspection report for example, we plan to incorporate the breaker linkage cleaning and lubrication Guideline into an existing plant procedure which addresses periodic breaker inspection and cleaning activities).
We will continue this practice in the future.
We will review PMI-2290 to identify any areas in the procedure that can'e expanded to provide a clearer distinction between activities requiring a formally approved procedure and those for which Guidelines are appropriate.
The results of our review will be provided to the Inspector to ensure that any remaining NRC concerns have been adequately addressed.
Attachment to AEP:NRC:1090B Page 3
(3)
Date When Full Com liance Will Be Achieved The activities discussed in (2) above will be completed by June 30, 1989.