ML17328A823

Responds to NRC 901119 Ltr Re Violations Noted in Insp Rept 50-316/90-22.Corrective Actions:Written Mgt Directive Initiated to Mechanic & Mechanic Supervisor Outlining Nature of Procedural Violation

ML17328A823
Person / Time
Site:	Cook
Issue date:	12/19/1990
From:	Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Davis A NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AEP:NRC:1125J, NUDOCS 9012260238
Download: ML17328A823 (13)

Text

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ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

CCESSION NBR:9012260238 DOC.DATE:

~ 90/12/19 NOTARIZED: NO DOCKET FACIL:50-316 Donald C. Cook Nuclear Power Plant, Unit 2, Indiana

~ & 05000316 AUTHOR AFFILIATION AUTH. NAME ALEXICH,M.P. Indiana Michigan Power Co. (formerly Indiana & Michigan Ele RECIP.NAMiE -

RECIPIENT, AFFILIATION DAVIS,A.B. Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 901119 ltr re violations noted in Insp Rept 50-316/90-22.Corrective actions:written mgt directive initiated Eo mechanic & mechanic supervisor outlining nature D of procedural violation.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

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

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL "ID CODE/NAME LTTR ENCL D PD3-1 PD 1 1 COLBURN,T. 1 1 D,

INTERNAL: AEOD AEOD/DEIIB 1 1 AEOD/TPAB DEDRO 1 1 S' NRR NRR SHANKMAN,S 1 1 MORISSEAU,D'RR/DLPQ/LPEB10 NRR/DOEA/OEAB ~

1 1 NRR/DREP/PEPB9D NRR/DRIS/DIR 1 1 NRR/DST/DIR SE2 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT OE 1 1 OGC/HDS1 G FI 02 1 1 RGN3 FILE 01 EXTERNAL EG&G/BRYCE i J ~ H ~ NRC PDR 1 1 NSIC D

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NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE O'ASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM PI-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCU) IENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 22

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PKFf; AEP: NRC: 1125 J Donald C. Cook Nuclear Plant Un' 2 Docket No. 50-316 License No. DPR-74 INSPECTION REPORTS 50-315/90022 (DRP) AND 50-316/90022 (DRP); RESPONSE TO NOTICE OF VIOLATION U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Attn: A. B. Davis December 19, 1990

Dear Mr. Davis:

This letter is in response to Mr. B. Clayton's letter dated November 19, 1990, which forwarded the report of a routine safety inspection conducted by members of your staff from August 29 thiough October 9, 1990, on activities at Cook Nuclear Plant Units 1 and 2.

The Notice of Violation attached to Mr. Clayton's letter identified one Severity Level IV violation associated with performance of maintenance activities in Unit 2 without approved procedures. The attachment to this letter provides our response to the Notice of Violation.

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. Alexich Vice President ldp Attachment y0122g0238 5'0i21Y PDR ADOCI 0-000~16 gp<0 Q PDR

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Mr. A. B. Davis AEP:NRC:1125J cc: D. H. Williams, Jr.

A. A. Blind,- Bridgman J. R. Padgett G. Charnoff NRC Resident inspector - Bridgman NFEM Section Chief

ATTACHMENT TO AEP:NRC:1125J RESPONSE TO NOTICE OF VIOLATION

Attachment to AEP:NRC:1125J Page 1 NRC Violation "Unit 2 Technical Specification 6.8.1 requires that written procedures shall be established, implemented and maintained such as those listed in Appendix A of Regulatory Guide 1.33, November 1972. Appendix A of Regulatory Guide 1.33 includes (Section I.l) procedures for performing maintenance which can affect the performance of safety-related equipment and requires that these procedures be performed in accordance with written proceduree.

Technical Specification 6.8.2 required that each procedure used for activities referenced in Unit 2 Technical Specification 6.8 ' shall be reviewed by the Plant Nuclear Safety Review Committee (PNSRC) and approved by the Plant Manager.

Contrary to the above, the following examples of a violation of this requirement were identified:

Licensee procedure PMI 2010 required that any procedure designated with a double asterisk be present and used at the job site. On August 16, 1990, maintenance involving the reassembly of the seal assembly on the, Unit 2 North Safety Injection Pump, was performed incorrectly and without the use of Procedure *~12 MHP 5021.008.001, a procedure with a double asterisk.

b. On September 19, 1990, maintenance to replace"a diaphragm on safety related valve 2-NRV-153 was performed, without a procedure.

c. On October 1, 1990, maintenance involving the installation of a diaphragm on the air actuator of power operated relief valve 2-NRV-152 was performed without the use of a procedure reviewed by the PNSRC and approved by the Plant Manager.

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

Response to Violation Part a.

During the recently completed Unit, 2 refueling outage planned maintenance was performed on the No. 2 north safety injection pump.

The maintenance activities included replacement of the rotating assembly, bearings, gaskets and mechanical seals. The job order covering these activities called for the use of procedure No.

• • 12 MHP 5021.008.001, "Safe'ty Injection Pump Disassembly, Repair and Reassembly." Installation of the pump seal assembly was completed using only attachment 2 to the procedure (a schematic drawing of the seal assembly) in violation of PMI 2010 which requires that the entire procedure be present at the job site. In addition, due to procedural discrepancies as to the exact number of

4 Attachment to AEP:NRC:1125J Page 2 seal rings to be reinstalled, the wrong numbers were used (one seal ring was reinstalled versus the required three). This error was subse'quently corrected when it was discovered during pose-maintenance testing of the pump.

Corrective Action Taken and Results Achieved Once the leakage at the seals had been identified, Maintenance personnel again worked on the Unit 2 north safety injection pump.

The referenced procedure was utilized as required and the repairs were completed and post-maintenance testing done with satisfactory results.

Corrective Action Taken to Avoid Further Violation A written management directive was initiated to the mechanic and his supervisor, outlining the nature of the procedural violation, its impact, and specific guidelines for avoiding similar situations in the future. The involved procedure has been rewritten eliminating discrepancies in text, drawings and parts lists, and is now available for use by Maintenance personnel. The Maintenance Superintendent undertook meetings with all department personnel to outline the requirements for procedural compliance. Meetings incorporated previously initiated policies from plant. and corporate management.

Date When Full Compliance Will Be Achieved Letters of instruction were given to the personnel involved on December 19, 1990. Procedure **12MHP 5021.008.001 was revised to eliminate discrepancies on~October 25, 1990.

Response to Violation Parts b. and c.

As stated in the Notice of Violation, repairs to the PORVs had been accomplished without a specific plant procedure. Successful repairs were ultimately made on both valves in accordance with plant procedure PMI-2290 (Job Orders). As permitted by PMI-2290, job order packages included repair plans (vs. procedure) which thoroughly outlined details needed to perform the work correctly.

It was not intended that the use of the plan take on the appearance of being an approved plant procedure. We believe that the use of a detailed repair plan instead of an approved plant procedure was appropriate for the maintenance activities in question and was consistent with PMI-2290. We recognize, however, that there is room for interpretation as to when work may be performed on the basis of "skill of the trade" without the use of approved procedures. As a result, the use of repair plans has been suspended until planned corrective actions can be completed. A procedure was subsequently developed for repairs to these types of valves, which was taken directly from the repair plan and contained no changes in content.

Attachment to AEP:NRC:1125J Page 3 Corrective Action Taken and Results Achieved In both valve repair evolutions,-Job Orders were initiated which included repair plans specific to the task. The plant's instruction (PMI-2290) was complied, with and both valves were repaired and tested for operability with satisfactory results.

Corrective Action Taken to Avoid Further Violation The use of repair plans has been suspended. In an effort to more clearly define what types of maintenance activities require approved procedures for performance, we will review work control m'ethods in place at other facilities which have been identified as successful by the industry and the Commission. The information acquired from our review will be incorporated into a proposed standard which we will discuss with your staff at a meeting on or before June 1, 1991.

If the proposed standard 'is acceptable, an implementation schedule will be established.

Date When Full Compliance Will Be Achieved Full compliance was achieved on December 19, 1990, with the suspension of the use of maintenance plans.

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