ML17332A357
| ML17332A357 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 10/21/1994 |
| From: | Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | Martin J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| AEP:NRC:1212H, NUDOCS 9410270332 | |
| Download: ML17332A357 (20) | |
Text
PAIC3R.I"EV 1
. (ACCELERATED RIBS PROC!'.SSIiG)
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CCESSION NBR:9410270332 DOC.DATE: 94/10/21 NOTARIZED: YES DOCKET N
FACIL:50-315 Donald C.
Cook Nuclear Power Plant, Unit 1, Indiana M
05000315 50-316 Donald C.
Cook Nuclear Power Plant, Unit 2, Indiana M
05000316 AUTH.NAME AUTHOR AFFILIATION FITZPATRICK,E.
RECIP.NAME RECIPIENT AFFILIATION MARTIN,J.B.
Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 940921 ltr re violations noted in insp repts 50-315/94-14
& 50-316/94-14 on 940702-0812.Corrective actions:procedures controlling operator tours have been revised to explicitly state expectations for performance.
DISTRIBUTION CODE:
- IEOID, COPIES RECEIVED:LTR
/ ENCLi SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of VioTation Response NOTES:
RECIPIENT ID CODE/NAME PD3-1 PD INTERNAL: AEOD/DEIB AEOD/SPD/RRAB DEDRO NRR/DORS/OEAB NRR/PMAS/IRCB-E a
OE DIR RES/HFB EXTERNAL: EG&G/BRYCE,J.H.
NRC PDR COPIES LTTR ENCL 1
1 1
1 1
1 1
1 1
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1 RECIPIENT ID CODE/NAME HICKMAN,J AEOD/SPD/RAB DRCH/HHFB NUDOCS-ABSTRACT OGC/HDS2 RGN3 FILE 01 NOAC COPIES LTTR ENCL 1
1 1
1 1
1 1
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1 VOTE TO ALL"RlDS" RECIPI EVTS: ',
PLEASE HELP llS TO RFDUCF. O'KSTE! COVTACT'I'IIEDOCI:iIE4TCONTROL DESK, ROOM PI -37 (EXT. 304- 083 ) TO F LIXIIVATE)'Ol'R iAi!LFRO! I DISTRI !ID'IIOV LIS'I'S I'OR DOCI.'!LILTI'S0'Ol.')OV"IL'I'.Ii!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 19 ENCL 19
Indiana Mmidga.
Power CompanI P.O Box 1863I Cn1omboa, OH 4825(
Z IMAMNA NICHlGAR PWM AEP:NRC:1212H 10 CFR 2.201 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 REPORTS NOS. 50-315/94014 (DRP)
AND 50-316/94014 (DRP)
REPLY TO NOTICE OF VIOLATION U. S. Nuclear, Regulatory Commission Document Control Desk Washington, D.
C.
20555 Attn:
Mr. J.
B. Martin October 21, 1994
Dear Mr. Martin:
This letter is in response to a
USNRC letter dated September 21,
- 1994, that forwarded a notice of violation to Indiana Michigan Power Company.
The notice of violation contained two violations 'identified during a routine safety inspection conducted by Messrs.
James A. Isom, David J. Hartland, and John H. Niesler from July 2,
- 1994, through August 12, 1994.
One violation is associated with operator tour record falsification issues.
The second violation is associated with the inadvertent blocking of emergency lighting due to the erection of scaffolding and herculite.
Our reply to the first violation of the notice of violation is provided in the attachment to this letter.
Corrective actions for the second violation were reviewed and found to be acceptable by the inspectors during the inspection.
No response with respect to the second violation is required by the aforementioned NRC letter.
9410270332 941021 PDR ADOCK 05000315 PDR
Mr. J.
B. Martin AEP:NRC'1212H This letter is submitted pursuant to 10 CFR 50.54(f) and, as such, an oath statement is attached.
Sincerely, E.
E. Fitzpatrick Vice President ar Attachment CC; A. A. Blind G. Charnoff NRC Resident Inspector NFEM Section Chief J.
R. Padgett W. T. Russell, NRC - Washington, D.C.
STATE OF OHIO)
COUNTY OF FRANKLIN)
E.
E. Fitzpatrick, being duly sworn, deposes and says that he is the Vice President of licensee Indiana Michigan Power
- Company, that he has read the foregoing response to NRC INSPECTION REPORTS NOS. 50-315/94014 (DRP) AND 50-316/94014 (DRP),
REPLY TO NOTICE OF VIOLATION and knows the contents thereof; and that said contents are true to the best of his knowledge and belief.
Subscribed and sworn to before me this ~~~
day of g-i 19 NOTARY PUBLIC t',CT~ D. HILL tIOTAPY PUoI.IC STATE OF OHIO
El
ATTAQMENT TO AEP:NRC: 1212H REPLY TO NOTICE OF VIOLATION
ATTACHMENT TO AEP:NRC:1212H Page
1 Background
A routine safety inspection was conducted by Messrs. J. A. Isom, D. J. Hartl'and, and J.
H. Niesler from July 2, 1994, through August 12, 1994.
During this inspection, two items were found to be in violation.
The first violation is associated with operator tour record falsification issues.
The second violation is associated with the inadvertent blocking of emergency lighting due to the erection of scaffolding and herculite.
These violations were set forth in a letter containing the notice of violation, dated September 21,
- 1994, from Mr. E.
G. Greenman, Director, Division of Reactor Projects, USNRC, Region III.
The letter was received September 27, 1994.
Our response to the first violation of the notice of violation is contained within this document.
Corrective actions for the second violation were reviewed by the inspectors during the inspection and found to be to their satisfaction.
Therefore, no response with respect to the second violation is required.
NRC Violation "10 CFR 50.9 requires that information required by statute or by the Commission's regulations,
- orders, or license conditions to be maintained by the applicant or the licensee shall be complete and accurate in all material respects.
Paragraph "a" of Unit 1 Technical Specifications 6.8.1 requires that written procedures shall be established, implemented, and maintained for applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978.
Paragraph 2.g in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978, requires that power operation and process monitoring activities shall be covered by written procedures.
Operation procedures, "Plant Tour Guidelines,"
01-OHP 5030.001.001, Revision 1, and 02-OHP 5030.001.001, Revision 1, requires that the operator performing the tour initial the datasheet indicating that a
tour of the associated areas was performed.
ATTAABKNTTO AEP: NRC: 1212H Page 2
Contrary to the above,'during 1993, twenty-five operators incorrectly initialed the tour datasheet indicating that a tour of an associated area was performed when the tour had not been performed.
This caused multiple instances of an inaccurate tour record to be generated.
This is a Severity Level IV violation (Supplement I)."
Response
to Violation sion o enia o t e e ed V o at Indiana Michigan Power Company admits to the violation as cited in the NRC notice of violation.
2.
aso e V o at o
The root cause was less than adequate management oversight of the operator tour performance in the following areas.
Implementation of management expectations for operator tour performance The procedural guidance for conducting operator tours was not clear as to what a tour was to accomplish.
The methods used to document tour performance did not ensure that an accurate record of tour performance was generated.
Staff responsibilities for assessing adequate tour performance The responsibility for periodic auditing of operator tour records was informally stated and tracked.
There was no feedback mechanism to alert management that the periodic audit was not performed or that it was overdue.
Supervisory monitoring of tour performance The monitoring of operator tour performance had been assigned to and was being performed by personnel in staff positions who were not directly responsible for the operators performing tours.
ATTAQiMENT TO AEP:NRC:1212H Page 3
Establishing accountability for effective operator tours Line management and tour operators have not been held accountable for the effectiveness of operator tours.
Although the third quarter 1993 audit of operator tours identified discrepancies between tour point signoffs and door entry records, no actions were taken to emphasize management and operator accountability for these discrepancies.
Management vigor and example in communication of expectations regarding operator tour performance Corporate and upper level plant management vigor and example in the area of operator tour performance are apparent by the documented record which clearly indicates management's concern and position on this subject.
While
'subsequent correspondence from the operations superintendent to all operations department personnel did emphasize the importance of integrity, it failed to mention the firm stance regarding actions delineated in the earlier upper level plant management correspondence.
Scheduling work activities to ensure tours are properly performed The operators who were assigned tour duties were also expected to respond to requests from the control room to perform various activities ranging from scheduled evolutions to emergent work.
Because these requests represented real time activities which were to be performed in sequence or were reactive in
- nature, the routine tour activities were performed as time became available.
ATTAAWENT TO AEP: NRC'1212H Page 4
3.
ect ve ct o e
d e
t v d Because operator tours are performed on a routine basis, corrective actions were not considered to be applicable.
When the discrepancies became known, tours of the areas in question had already been completed multiple times.
These subsequent tours revealed no previously unidentified problems in any of the areas.
4.
Corre tive Act o s Take to vo d rther Violations The procedures controlling operator tours have been revised to explicitly state the expectations for operator tour performance.
The revision also directs that operators carry tour data sheets on their rounds to immediately record the completion of tour activities.
An Operations Head Instruction, OHI-7011, has been implemented to address supervisory responsibility for checking tour records and individual operator accountability for tour discrepancies.
Shift meetings have been conducted to communicate and reaffirm the department management expectations for tour performance.
An Operations Head Instruction, OHI-5031, has been implemented to establish a high priority for the completion of operator tour duties.
5.
te e
Fu o
ance W
Ac ieved.
Allpreventive actions were completed by September 13, 1994, therefore, full compliance was achieved on that date.
I
indiana Michigan Power Company P.O. 8ox 16631 Columbus. OH 43216 Z
INDlANA NlCHIGAN POWER AEP:NRC'1212H 10 CFR 2.201 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 REPORTS NOS. 50-315/94014 (DRP)
AND 50-316/94014 (DRP)
REPLY TO NOTICE OF VIOLATION U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C.
20555 Attn:
Mr. J.
B. Martin October 21, 1994
Dear Mr. Martin:
This letter is in response to a
USNRC letter dated September 21,
- 1994, that forwarded a
notice of violation to Indiana Michigan Power Company.
The notice of violation contained two violations identified during a routine safety inspection conducted by Messrs.
James A. Isom, David J. Hartland, and John H. Niesler from July 2,
- 1994, through August 12, 1994.
One violation is associated with operator tour record falsification issues.
The second violation is associated with the inadvertent blocking of emergency lighting due to the erection of 'scaffolding and herculite.
Our reply to the first violation of the notice of violation is provided in the attachment to this letter.
Corrective actions for the second violation were reviewed and found to be acceptable by the inspectors during the inspection.
No response with respect to the second violation is required by the aforementioned NRC letter.
Mr. J.
B. Martin AEP: NRC: 1212H This letter is submitted pursuant to 10 CFR 50.54(f) and, as such, an oath statement is attached.
Sincerely, E.
E. Fitzpatrick Vice President Attachment cc:
A. A. Blind G. Charnoff NRC Resident Inspector NFEM Section Chief J.
R. Padgett wW. T. Russe11, NRC - WasEingten, D,C~
l 0
ATTAt29KNT TO AEP:HRC: I212H REPLY TO NOTICE OF VlOLATION
ATTAQQKNT TO AEP:NRC: 1212H Page
1 Background
A routine safety inspection was conducted by Messrs. J. A. Isom, D. J. Haztland, and J.
H. Niesler from July 2, 1994, through August 12, 1994.
During this inspection, two items were found to be in violation.
The first violation is associated with operator tour record falsification issues.
The second violation is associated with the inadvertent blocking of emergency lighting due to the erection of scaffolding and herculite.
These violations were set forth in a letter containing the notice of violation, dated September 21,
- 1994, from Mr. E.
G. Greenman, Director, Division of Reactor Projects,
- USNRC, Region IIX.
The letter was received September 27, 1994.
Our response to the first violation of the notice of violation is contained within this document.
Corrective actions for the second violation were reviewed by the inspectors during the inspection and found to be to their satisfaction.
Therefore, no response with respect to the second violation is required.
NRC Violation "10 CFR 50.9 requires that information required by statute oz by the Commission's regulations,
- orders, or license conditions to be maintained by the applicant or the 1'icensee shall be complete and accurate in all matezial respects.
Paragraph "a" of Unit 1 Technical Specifications 6.8.1 zequires that written procedures shall be established, implemented, and maintained for applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978.
Paragraph 2.g in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978, requires that power operation and process monitoring activities shall be covered by written procedures.
Operation procedures, "Plant Tour Guidelines,"
01-OHP 5030.001.001, Revision 1, and 02-OHP 5030.001.001, Revision 1, requires that the operator performing the tour initial the datasheet indicating that a
tour of the associated areas was performed.
ATTA(2QKNT TO AEP:NRC: 1212H Page 2
Contrary to the
- above, during 1993, twenty-five operators incorrectly initialed the tour datasheet indicating that a tour of an associated area was performed when the tour had not been performed.
This caused multiple instances of an inaccurate tour record to be generated.
This is a Severity Level IV violation (Supplement I)."
Response
to Violation s
o o
e ia o t e A
e ed V plat o Indiana N.chigan Power Company admits to the violation as cited in the NRC notice of violation.
2.
a o eVo to The root cause was less than adequate management oversight of the operator tour performance in the following areas.
Implementation of management expectati.ons for operator tour performance The procedural guidance for conducting operator tours was not clear as to what a tour was to accomplish.
The methods used to document tour performance did not ensure that an accurate zecord of tour performance was generated.
Staff responsibilities for assessing adequate tour performance The responsibility for periodic auditing of operator touz records was informally stated and tracked.
There was no feedback mechanism to alert management that the periodic audit was not performed or that it was overdue.
Supervisory monitoring of tour performance The monitoring of operator tour performance had been assigned to and was being performed by personnel in staff positions who were not directly responsible for the operators performing tours.
ATTAQBKNT TO AEP:NRC:1212H Page 3
Establishing accountability for effective operator tours Line management and tour operators have not keen held accountable for the effectiveness of operator tours.
Although the third quarter 1993 audit of operator tours identified discrepancies between tour point signoffs and door entry records, no actions were taken to emphasize management and operator accountability for these discrepancies.
Management vigor and example in communication of expectaCions regarding operator tour performance Corporate and upper level plant management vigor and example in the area of operator tour performance are apparent by the documented record which clearly indicates management's concern and position on this subject.
While subsequent correspondence from the operations superintendent to all operations departmenC personnel did emphasize Che importance of integrity, it failed to mention the firm stance regarding actions delineated in the earlier upper level plant management correspondence.
Scheduling work activities to ensure Cours are properly performed The operators who were assigned tour duties were also expected to respond to requests from the control room to perform various activities ranging from scheduled evolutions to emergent work.
Because these requests represented real Cime activities which were to be performed in sequence or were reactive in
- nature, the routine tour activities were performed as time became available.
ATTACHMENT TO AEP 'NRC '212H Page 4 3.
ect ve o
a e
a d e u ts ev d Because operator tours are performed on a routine basis, corrective actions were not considered to be applicable.
When the discrepancies became known, tours of the areas in question had already been completed multiple times.
These subsequent tours revealed no previously unidentified problems in any of the..areas.
Co e tive Act ons Taken to vo d ther Vio at o s The procedures controlling operator tours have been revised to explicitly state the expectations for operator tour performance.
The revision also directs that operators carry tour data sheets on their rounds to immediately record the completion of tour activities.
An Operations Head Instruction, OHI-7011, has been implemented to address supervisory responsibility for checking tour records and individual operator accountability for tour discrepancies.
Shift meetings have been conducted to communicate and reaffirm the department management expectations for tour performance.
An Operations Head Instruction, OHI-5031, has been implemented to establish a high priority for the completion of operator tour duties.
5.
ate en Co a ce V Be c
eved.
Allpreventive actions were completed by September 13, 1994, therefore, full compliance was achieved on that date.