ML17332A330

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-315/93-12 & 50-316/93-12
ML17332A330
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 10/04/1994
From: Wright E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Fitzpatrick E
INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
References
NUDOCS 9410070014
Download: ML17332A330 (2)


See also: IR 05000315/1993012

Text

October 4,

1994

Indiana Michigan Power

Company

ATTN:

Mr. E.

E. Fitzpatrick

Vice President

1 Riverside

Plaza

Columbus,

OH

43216

SUBJECT:

NOTICE OF VIOLATION:

NRC

INSPECTION

REPORT

NOS.

50-315/93012(DRS);

50-316/93012(DRS)

Dear Mr. Fitzpatrick:

Thank you for your January

4,

1994, letter informing us of the steps

you have

taken to correct the violations addressed

in Inspection

Report

Nos.

50-314/93012(DRS);

50-316/93012(DRS).

The inspection report was

transmitted

by our November 24,

1993, letter.

With regard to your response

to violation No. 2,

we disagree

with your

position that this violation does not represent

a departure

from compliance

with NRC regulations.

Specifically,

we do not agree with your interpretation

of 10 CFR 50.59 that the specific speed control circuitry needs to be

explicitly described

in the

UFSAR to prompt

a safety evaluation.

It is our

position that if the structure,

system or component

(SSC)

being modified can

affect the performance of a larger

SSC, in this case

the speed

control circuit

affecting the feedwater

pump,

then

a safety evaluation

must

be performed.

The steam generator

feedwater control system,

the feedwater

system,

and the

feedwater

pump's variable

speed

mechanical

drive are addressed

in the

UFSAR.

In particular,

UFSAR Section

10.5. 1. 1 states that "the variable

speed turbine

driven main feedwater

pumps are designed to provide the required feedwater

flow to the steam generators."

The steam generator

feedwater

system is

an

important system in ensuring

continued heat

removal

from the reactor core.

A

safety evaluation

should

have

been

performed to assess

the potential

consequences

of modifying the turbine's

speed control

system with respect to,

among others,

the probability of occurrence of a loss of feedwater accident.

Because

your screening

process

apparently

focuses

only on structures,

systems,

or components

which are explicitly described

in the

UFSAR, the potential

exists for modifications to be implemented without

a thorough safety

evaluation.

9'4i0070014 9'4i004

PDR

ADOCK 050003i5

8

PDR

l

/ u8L(C ~e-0(

E.

E. Fitzpatrick

October 4,

1994

Please

provide your response

to this concern within 30 days of this letter.

Sincerely,

Docket No. 50-315

Docket No. 50-316

G.

C. Wright, Chief

Engineering

Branch

Enclosure:

Ltr dtd 01/04/94,

E.

E. Fitzpatrick to J.

B. Hartin

cc w/o encl:

A. A. Blind, Plant Manager

cc w/encl:

James

R. Padgett,

Michigan Public

Service

Commission

EIS Coordinator,

USEPA

Region

5 Office

Michigan Department of Public Health

Distribution

Docket File w/encl

PUBLIC IE-01 w/encl

OC/LFDCB w/encl

RIII PRR w/encl

RI,

D.

C.

Cook w/encl

LPH,

NRR w/encl

DOCUMENT NAME:

G:DCCOOK.RES

To receive a copy of this document, Indicate in the box 'C" ~ Copy w/o attach/encl 'P ~ Copy with attach/encl 'N'

No copy

OFFICE

RIII:DRS

Falevits kjc+

DATE

hS/ ~/94

RI II:DRP

Kro

RIII:DRS

Gardner W

N/S/94

09/I> /94

OFFICIAL RECORD

COPY

RIII:DRS

Wri ht

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(94