ML17329A014
| ML17329A014 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 04/26/1991 |
| From: | Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | Davis A NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| AEP:NRC:1148, NUDOCS 9105030128 | |
| Download: ML17329A014 (14) | |
Text
ACCELERATED DISTRIBUTION DEMONSTRATION Y
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
Qa NOTES:
CCESSION NBR:9105030128 DOC.DATE: 91/04/26 NOTARIZED: NO DOCKET FACIL:50-315 Donald C.
Cook Nuclear Power Plant, Unit 1, Indiana 05000315'0-316 Donald C.
Cook Nuclear Power Plant, Unit 2, Indiana 05000316 AUTH.NAME AUTHOR AFFILIATION FITZPATRICK,E.
(formerly Indiana
& Michigan Ele RECIP.NAME RECIPIENT AFFILIATION DAVIS,A.B.
'ocument Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 910329 ltr re violations noted in Insp Repts 50-315/91-05
& 50-316/91-'06 on 910304-14.Corrective actions:
]
design criteria, post-mod test procedure
& acceptance criteria for differential pressure valves will be reviewed.
DISTRIBUTION CODE:
IEOID COPIES RECEIVED:LTR ENCL g SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Vio ation Response RECIPIENT ID CODE/NAME PD3-1 PD INTERNAL: AEOD AEOD/TPAB NRR MORISSEAU,D NRR/DLPQ/LPEB10 NRR/DREP/PEPB9D NRR/DST/DIR SE2 NUDOCS-ABSTRACT OGC/HDS2 RGN3 FILE 01 EXTERNAL EG&G/BRYCEiJ H ~
NSIC COPIES LTTR ENCL 1
1 1
1 1
1 1
1 1
1 1
1
~ 1 1
1 1
1 1
1 1
1 1
1 1
RECIPIENT ID CODE/NAME COLBURN, T.
AEOD/DEIIB DEDRO NRR SHANKMAN,S NRR/DOEA/OEAB NRR/DRIS/DIR NRR/PMAS/ILRB12 OE ER FILE 2
NRC PDR COPIES LTTR ENCL 1
1 1
1 1
1 1
.1 1
1 1,
1 1
1' 1
1 1
1 1
NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE 'O'ASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOiI PI-37 (EXT. 20079) TO ELIMINATEYOUR NAAIEFROM DISTRIBUTION LISTS FOR DOCUfv!ENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 22 ENCL 22
indiana h1ichigan Power Company P.O. Box 16631 Coiurnbus, OH 432>
INDIAN NICHlGAN POMfF.R AEP: NRC: 1148 Donald C.
Cook Nuclear Plant Units 1 and 2
Docket Nos.
50-315 and 50-316 License Nos.
DPR-58 and DPR-74 INSPECTION REPORTS 50-315/91006 (DRS)
AND 50-316/91006 (DRS);
RESPONSE
TO NOTICE OF VIOLATION U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.
20555 Attn: A. B. Davis April 26, 1991
Dear Mr. Davis:
This letter is in response to Mr. M. P. Phillips'etter dated March 29, 1991, which forwarded the report of a routine safety inspection of activities at Cook Nuclear Plant Units 1 and 2 by your staff on March 4 through March 14, 1991.
The notice of violation attached to Mr. Phillips'etter identified four examples of violations of the requirements of 10CFR50, Appendix B, Criterion III (design control) which, when taken together, constituted a severity level IV violation.
Our response to the notice of violation 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,
~'Oc E.
E. Fitzpatrick Vice President dfw Attachment P10~0.".0i -'8 92042~~
pDp;
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Foe x/
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Mr. A." BE Davis AEP: NRC: 1148 cc:
D. H. Williams, Jr.
- w/o
. A. A. Blind - Bridgman - w/
J.
R. Padgett G. Charnoff T. E. Murley - NRC, Washington, D.
C. - w/
NRC Resident Inspector
- Bridgman - w/
NFEM Section Chief - w/
) I
~
~
ATTACHHENT TQ.AEP,;NRC;1148
,....v,g
RESPONSE
'I I ~
Attachment to AEP:NRC:1148 Page 1
NRC Violation p
"10CFR50, Appendix B, Criterion III, requires that design changes be subject to design control measures commensurate with those applied to the original design.
This design control includes the specifying of design bases and verifying that design through design.review andi.testing.;-The control of design shall be accomplished by establi.shing measures to ensure proper design interface snd. coordination"among-'.s participating organizations.
a.
Contrary to the above, a number of, designi.aontrol~andor.
interface deficiencies were identified as follows:
, ~ ~
.,ic System modification, RPC 2883, Revision"0,:.provided cooling to emergency diesel generator.(EDG):iroom solid state instrument panels.
The test guidance
-established by corporate design was not, completelyincorporated into the test procedure.
Purthezmore, test acceptance.
cri.teria deviations were not reported to corporate design for evaluation and calculations update.
b, System modificati.on, RFC 2883, Revision 0, contained no acceptance criteria for moni.toring differential pressure across the ventilation air filters.
In addition, the licensee's established monitoring criterion was without design basis and was inconsistent with the design calculation.
ce System modificati.on, RFC 2883, Revision 1, modified EDG zoom ventilation alarm logic.
However, the licensee's annunciatoz manual was not revised to reflect the new system configuration.
Furthermore, the change sheet made to address the above concern contained errors due to the lack of review by corporate design engineers.
d.
Uncontrolled pressure gauges were found to have been installed on three of the fouz diesel engine systems.
This work was accomplished without use of the licensee's modification program and showed no design control.
This is a Severity Level IV violation (Supplement I)."
8
Attachment to AEP:NRC:1148 Page 2
General Comment Several of the inspection issues were characterized as attributed to lack of design interface between corporate engineers and the site staff in various areas.
While the specific examples are individually addressed below, it is acknowledged that interfaces between the corporate engineers and the site staff have led to difficulties on several occasions, As a step towards addressing this matter, we are designating an individual to serve as the Nuclear Engineering Department (NED) - Site Liaison, The primary responsibility of this individual, who will be located at the Cook Nuclear Plant site, will be to facilitate improved interfaces between the NED in our Columbus offices and the Cook Nuclear Plant staff.
Additionally, this individual will be tasked with investigating apparent interface problems, and recommending improved interface practices to be delineated'in corporate and plant procedures.
This position will be effective June 1, 1991.
We are hopeful that this positive action will help to ensure the proper flow of interface information between the NED and the Cook Nuclear Plant, and to ensure the NED is providing appropriate support to the plant in the areas of operations, modifications and maintenance.
Response
to Item a.
Although the post-modification test procedure did not completely incorporate the test guidance established by the lead engineer, it was concluded that the design basis intent of the system was successfully verified by the post-modification testing performed by Cook Nuclear Plant personnel.
- However, the post-modification test acceptance criteria developed for RFC 2883, Revision 0, will be reviewed by the design change lead engineer and the post-modification test procedure (or portions thereof) will be revised as necessary.
(1)
Corrective Actions Taken and Results Achieved As stated above, it was concluded upon review.that. the design basis intent of the system was successfully" verified.
Any revisions to the post-modification test procedure that may result from the review discussed above will be implemented and the test results and any deviation from or revision to the test acceptance criteria will be reviewed and concurred with by the respective lead engineer.
Attachment to AEP:NRC:1148 Page 3
(2)
Corrective Action Taken to Avoid Further Violation The corporate-level design change procedure currently requires the engineer responsible for a design change to ensure that special non-routine functional testing is identified and that test acceptance criteria are established.
Additionally, this pxoceduxe requires the engineer to designate which test results require lead engineering acceptance prior to release of the modified system to operation.
While the current implementing plant pxocedures acknowledge these requirements, there is no definitive guidance on actions to be taken if test acceptance criteria cannot be met.
h specific requirement will be added to applicable procedures to require reporting of deviations from test criteria to the lead engineer for disposition.
(3)
Date When Pull Com liance Will Be Achieved Pull compliance will be achieved by July 31, 1991, at which time the actions discussed in (1) and (2) above will have been completed.
Response
to Item b.
Test guidance developed by the lead engineer for RPC 2883, Revision 0 identified differential pressure values across the ventilation air filters based on vendor data which was used in the original design calculation.
These values were not completely incozporated into the test procedure.
(1)
Corrective Actions Taken and Results Achieved The design criteria, post-modification test procedure and acceptance criteria will be reviewed and revised if necessary to maintain the validity of the design calculations and system configuration.
Any revisions to the post-modification test procedure that may result from this review will be implemented and the test results and any deviation from or revision to the test acceptance criteria will be reviewed and concurred with by the respective lead engineer.
These actions will confirm the adequacy of the installed system design, Test results will be used to establish monitoring criteria for the differential pressure across the ventilation air filters.
, httachment to hEP:NRC:1148 Page 4
(2)
Corrective hction Taken to hyoid Further Violation The corporate-level design change procedure currently requires the engineer responsible for a design change to ensure that required special non-routine functional testing is identified and that test acceptance criteria are established..
hdditionally, this procedure requires the engineer to designate which test results requ'ire lead engineer acceptance prior to release of the modified system for operation.
While the current implementing plant procedures acknowledge these requirements, there is no definitive guidance on actions to be taken if test acceptance criteria cannot be met.
h specific requirement will be added to applicable procedures to require reporting of deviations from test criteria to the lead engineer for disposition.
In addition, the importance of strict adherence to procedures has been xeinforced to the involved personnel.
(3)
Date When Full Com liance Vill Be hchieved Pull compliance will be achieved by July 31, 1991, at which time the actions discussed in (1) and (2) above will have been completed.
Response
to Item c.
RFC 2883, Revision 1, which modified the EDG room ventilation alarm logic, effected a change to the initiating devices for control room alarms.
hlthough these changes did not impact operator actions as delineated in annunciator response procedures, the initiating devices are listed in these procedures and, therefore, these procedures were impacted by this design
- change, The current plant procedure governing RFC design changes requires a review of design changes for plant procedure impacts.
These reviews were performed for the sub]ect design changes;
- however, the impact of the design changes on the annunciator response procedures was inadvertently missed during these reviews.
Vith regard to the noted change sheet errors, normal practice is to have plant procedure impact evaluations performed by the plant departments which are responsible for, and therefore most knowledgeable on, each type of procedure.
The deficiencies noted by the inspector in procedure changes issued during the inspection resulted from an attempt to respond.to the inspector's issues in too expeditious a
Attachment to AEP:NRC:1148 Page 5
manner.
Changes to four procedures were initiated from a "typical" procedure mark-up.
Due to the time constraints imposed by expediting these changes during the inspection, the procedure author did not notice subtle differences between the four procedures, and this resulted in the issuance of procedure changes with minor errors.
These errors are not, however, considered to have been the result of the lack of review by corporate design engineers.
(1)
Corrective Actions Taken and Results Achieved The annunciator response procedures have been revised to reflect the modifications made to the emergency diesel generator room ventilation alarm logic.
(2)
Corrective Action Taken to Avoid Further Violation Provisions are in place for evaluation of design change impacts on plant procedures.
h condition report was-written during the inspection to document the fact that the procedure impacts were missed 'during proceduie reviews for this design change.
The importance of adherence to procedures has been reinforced to Cook Nuclear Plant personnel, The provisions for evaluation of design change impacts on plant procedures will be reviewed and strengthened as necessary,to minimise the potential for this type of deficiency to occur in the future.
(3)
Date When Full Com lienee Will Be Achieved Full compliance was achieved on March 22,
- 1991, when the necessary revision to the annunciator response procedures was made.
The review discussed in (2) above will be completed by July 31, 1991.
Response
to Item d.
The uncontrolled pressure gauges identified in this finding were mounted at test points on the discharge piping of bypass lube oil pumps for D/Gs 1AB; 2AB, and
- 2CD, No evidence supporting when and why the gauges were installed has been discovered.
The gauges were general process gauges with no traceable identification.
Although appropriate design control procedures were in effect at the time, the personnel installing the gauges at the test connections did not adhere to the design control requirements, As a result, the gauges which may have been installed to monitor pump output
Attachment to AEP:NRC:1148 Page 6
pressures following pump maintenance or testing, were not removed as required.
Since adherence to the design control procedures in effect at the time would hive precluded the occurrence of this event, we do not consider there to have been any lack of design control, but rather a failure to comply with the established program in this instance.
(1)
Corrective Actions Taken and Results Achieved The uncontrolled gauges were removed via gob orders immediately upon discovery.
(2)
Corrective Action Taken to Avoid Further Violation Although the cause of this concern has not been identified, we believe that the uncontrolled gauges were likely installed as a temporary modification.
Therefore, formal training is under development to better educate plant personnel in the requirements of the temporary modification program.
Implementation of this training for management and technical staff has begun.
The temporary modification procedure (PMP 5040 NOD.001) is being revised to better define a temporary modification, involve Plant Engineering and Pro)ect Engineering in the review process and provide more definitive guidelines for processing a temporary modification.
(3)
Date Vhen Full Com liance Vill Be Achieved The revision to the temporary modification procedure and all training for management and technical staff will be completed by July 31, 1991.
Training programs for other selected plant personnel are still under development.
Ve expect to complete these training programs and training of operations and maintenance personnel by December 31, 1991.