ML17328A156

Responds to NRC 890801 Ltr Re Violations Noted in Insp Repts 50-315/89-21 & 50-316/89-21.Corrective Actions:Rcs Flow Verification Test Procedure Will Be Revised to Require Test Data Be Forwarded for Evaluation

ML17328A156
Person / Time
Site:	Cook
Issue date:	09/15/1989
From:	Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Davis A NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AEP:NRC:1090F, NUDOCS 8909220178
Download: ML17328A156 (12)

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SSION NBR:8909220178 DOC.DATE: 89/09/15 NOTARIZED: NO DOCKET IL: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. Indiana Michigan Power Co. (formerly Indi.ana & Michigan Ele RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 890801 50-315/89-21 & 50-316/89-21.

ltr re violations noted in Insp Repts DISTRXBUTION CODE: IE01D COPIES RECEXVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation esponse NOTES:

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INDMNA NlCHlGAN PWKR AEP: NRC: 1090F Donald C. Cook Nuclear Plant Unit 2 Docket No. 50-316 License No. DPR-74 INSPECTION REPORTS 50-315/89021 (DRP) AND 50-316/89021 (DRP); RESPONSE TO VIOLATION U. S. Nuclear Regulatory Commission Document Control Desk, Washington, D. C. 20555-Attn; A, B. Davis September 15, 1989

Dear Mr. Davis:

This letter is in response to W. L. Axelson's letter dated August 1, 1'989, which forwarded the report on the routine safety inspection conducted by members of your staff. This inspection was conducted from June 7 through July 18, 1989 on activities Donald C. Cook Nuclear Plant Units 1 and 2. The Notice of at'he Violati'on attached to Mr. Axelson's letter identified one severity level IV violation associated with Unit 2 overtemperature and overpower delta-T reactor trip setpoints. In a phone conversation on August 31, 1989, Mr. Axelson approved an extension of our violation response time to September 15, 1989. Our violation response is provided 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. . Ale ich Vice President'PA/eh Attachment

Mr. A. B. Davis AEP: NRC: 1090F cc: D. H. Villiams, Jr.

V. G. Smith, Jr. - Bridgman R. C. Callen G. Charnoff NFEM Section Chief A. B. Davis - Region III NRC Resident Inspector - Bridgman

Mr. A. B. Davis AEP:NRC:1090F bc: S. J. Brewer/B. P. Lauzau T. 0. Argenta/R. F. Kroeger P, A. Barrett - w/o attachment J. G. Feinstein - w/o attachment M. L. Horvath - Bridgman - w/o attachment J. F. Kurgan - w/o attachment J. J. Markowsky J, B. Shinnock - w/o attachment S. H. Steinhart/S. P. Hodge J. Giitter, NRC - Vashington, D. C.

AEP:NRC'1090F DC-N-6015.1

ATTACHMENT TO AEP;NRC:1090F RESPONSE TO VIOLATION

ATTACHMENT TO AEP:NRC:1090F Page 1 NRC Violation "Unit 2 Technical Specification 2.2.1 requires reactor trip system instrumentation setpoints shall be set consistent with Trip Setpoint values shown in Table 2.2-1. For Over-temperature Delta-T and Overpower Delta-T the maximum channel trip points shall not exceed computed trip points by more than 3.3 percent and 2.6 percent Delta-T span respectively.

Technical Specification 3.3.l.l-requires the Overtemperature and Overpower Delta-T channels OPERABLE in MODEs 1 and 2, but provides that with the number of OPERABLE channels one less than the total number of channels, STARTUP and/or POWER OPERATION may proceed if the inoperable channel is placed in the tripped condition within one hour.

Contrary to the above, Unit 2 was in POWER OPERATION subsequent to March 31, 1989, with Channel 2 Overtemperature and Overpower Delta-T trip points outside their respective accuracy ranges (both were over 4 percent high) and therefore inoperable, but the inoperable channels were not placed in the trip condition, pending data evaluation, until May 24, 1989.

This is a Severity Level IV violation (Supplement I)."

Response to Violation At the time of the cited violation, Unit 2 had returned to full power operation following .the steam generator repair project (SGRP) outag'e. An extended set, of calorimetric data was taken at approximately 99% power on March 31, 1989 to verify reactor coolant system flow (as required by Technical Specifi'cations) and to verify reactor control system inputs. These data were taken in conjunction with our ongoing program for improvement of control

~room indication accurac'y and control system response, Although it was expected that some flow redistribution would occur as a result of the Unit 2 steam generator repair, we failed to recognize that this redistribution would significantly affect loop delta-Ts used for calibration of the overpower and overtemperature reactor trip channels. The delta-T values used previously for calibration of the trip channels were based on data obtained during initial startup testing with periodic minor adjustments based on channel check information. No specific procedural requirement was in place to compare the delta-T obtained from measured calorimetric data to the Technical Specification (T/S) in order to confirm T/S compliance for the overtemperature and-. overpower delta-T trip

ATTACHMENT TO AEP:NRC:1090F Page 2 setpoints each time a unit was brought to power operation.

Consequently, it was not until May 24, 1989, while plant Instrumentation and Control (I&C) Section personnel were reviewing a fob order on the Unit 2 loop 2 delta-T control room indicators, that concern was raised over whether the instrument loop as calibrated placed the loop 2 overpower delta-T and overtemperature delta-T setpoints outside the T/S LCO.

(1) Corrective Actions Taken and Results Achieved The Unit 2 loop 2 overpower and overtemperature delta-T trip setpoints were found to be outside the T/S on May 24, 1989. Upon discovery of this condition, the affected channel was immediately placed in the tripped condition. The control loop was subsequently recalibrated and declar'ed operable on May 25, 1989.

(2) 'orrective Action Taken to Avoid Further Violation The reactor trips associated with Power Range Nuclear Instrumentation, Intermediate Range Instrumentation, Flux Rate, Reactor Coolant Flow, Overpower Delta-T, and Over-temperature Delta-T are all fuel cycle dependent in that the configuration of the core can affect both Neutron Leakage and Reactor Coolant Flow. In addition, delta-T can be affected by other contributors to changes in reactor flow (for example, steam generator tube plugging). There are procedures in place to assure that, except for Overpower Delta-T and Overtemperature Delta-T, these parameters are measured and are in compliance with Technical Specifications.

The Technical Specifications also contain appropriate notes to allow verification and calibration of these circuits during power ascension. Prior to occurence of the event discussed above Overpower Delta-T and Overtemperature Delta-T were not treated in the same manner.

In order to prevent a recurrence of this problem, the reactor coolant system (RCS) flow verification test procedure will be revised to require that when performing flow verification testing the test data showing the measured reactor coolant system delta-T and percent reactor power be forwarded to plant IGC for evaluation. Criteria will be established within the RCS flow verification procedure to require performance of an expedited evaluation to confirm T/S compliance if the measured delta-T (scaled to 100% power) on any loop decreases from the value on which the current calibration was performed by more than a conservatively

ATTACHMENT TO AEP:NRC:1090F Page 3 selected tolerance. In addition, a T/S amendment that allows for entry into modes 2 and 1 until verification testing of.

overpower and overtemperature delta-T trips can be accomplished is currently in management review in preparation for submittal to the NRC. The verification test will be performed as part of the power escalation program.

(3) Date When Full Com liance Vill Be Achieved Full compliance was achieved on May 24, 1989 when the Unit 2 loop 2 overpower and overtemperature delta-T channels were placed in the tripped condition. The channels were subsequently recalibrated and declared operable on May 25, 1989.

The procedural revisions discussed in Item (2) above are expected to be completed prior to the end of the Unit 2 refueling outage scheduled to commence in June, 1990.