ML17332A437

Forwards Revised Response to Violation 2 from NOV Dtd 931123 Associated W/Insp Repts 50-315/93-12 & 50-316/93-12. Corrective Actions:I to I Converter Removed from Circuitry on 940912

ML17332A437
Person / Time
Site:	Cook
Issue date:	11/28/1994
From:	Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Martin J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AEP:NRC:1184H1, NUDOCS 9412020086
Download: ML17332A437 (15)

Text

indiana Michigan Power Company P.O. Box i6631 Columbus, OH 432 s6 Z

INOlANA NK8l6rlPl laQlRfER AEP NRC 1184H1 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 NO. 50-315/93012 (DRS)

AND 50-316/93012 (DRS)

REPLY TO NOTICE OF VIOIATION (SYSTEM BASED INSTRUMENTATION AND 'CONTROL INSPECTION)

U. S. Nuclear Regulatory Commission Document Control Desk Vashington, D. C. 20555 Attn: J. B. Martin November 28, 1994

Dear Mr. Martin:

By letter dated January 4, 1994, (AEP:NRC:1184H), we responded to a Notice of Violation dated November 23, 1993, associated with the subject NRC inspection. The violations were associated with 1) errors in a setpoint calculation for refueling water storage tank level instrumentation and 2) the lack of an unreviewed safety question determination for Temporary Modification 2-93-015, which I I installed an to converter in the Unit 2 feedwater pump control circuitry.

By letter dated October 4, 1994, the NRC expressed concern with our response to violation No. 2. Our revised response to violation No. 2 is contained in the attachment to this letter.

J. B. Martin AEP:NRC:1184Hl 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 eh Attachments CC: A. A. Blind G. Charnoff NFEM Section Chief NRC Resident Inspector - Bridgman J. R. Padgett W. T. Russell - NRC Region III

ATTAQBKNT TO AEP:HRC:118481 RESPONSE TO NRC CONCERNS REGARDING REPLY TO NOTICE OF VIOIATION: NRC INSPECTION REPORT NOS. 50-315/93012(DRS) AND 50-316/93012(DRS)

ATTACHMENT TO AEP:NRC: 1184H1 PAGE 1 C es o e t Re "With regard to your response to violation No. 2, we disagree with your position that this violation does not represent a departure 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'SC, 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.

Please provide your response to this concern within 30 days of this letter."

s se In response to the concerns raised in the NRC's letter of October 4, 1994, we are amending our original response to violation 2 from the Notice of Violation. The revised response is contained below.

d V a Indiana Michigan Power admits to the violation as cited in the'RC Notice of Violation.

2. easo V ate The reason for the violation is a difference in

ATTACHMENT TO AEP:NRC: 118481 PAGE 2 interpretation of the requirements of 10 CFR 50.59.

Quoth respect to the design change of the I to I converter (Temporary Modification TM 2-93-015),

neither the function of the main feedwater pumps as described in the UFSAR (to provide feedwater flow to the steam generators) nor the method of performing the function as described in the UFSAR (with variable speed pumps) was impacted by the change.

Additionally, complete loss of feedwater (independent of the specific reason) was already an analyzed UFSAR Chapter 14 event. Thus, in the judgment of the individuals performing the screening;- the change represented neither an explicit nor an implicit change to the UFSAR, and therefore an unreviewed safety question determination was not performed.

3. ve The I to I converter was removed from the circuitry on September 12, 1994.

e ve t Prior to the SBICI inspection, we were performing Uareviewed Safety Question determinations for all Request for Changes and Minor Modifications (generally safety related/safety interface changes), regardless of the results of the 10 CFR 50.59 screening.

Followiag the SBICI, we modified the Temporary Modification process such that Unreviewed Safety Question determiaations are now performed for all temporary modifications iavolving safety related and/or seismic class I or II equipment. Additionally, we will modify our design change process such that we perform Unreviewed Safety Question determinations for the balance of the design changes (Plant Modifications and non-safety related/non-seismic class I or II Temporary Modifications). This chaage will be implemented by December 31, 1994, for design changes for which physical work is not in progress as of that date.

e u v Pull compliance was achieved on September 12, 1994, when the I to I converter was removed from the circuitxy.

(ACCELEIUKTED Ril)S I'ROCI;SSIio)

REGULATORY XNFORMATION DISTRIBUTION SYSTEM (RIDS)

CESSION NBR:9412020086 DOC.DATE: 94/11/28 NOTARIZED: YES DOCKET

'ACIL: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 AFFILIATXON FITZPATRICK,E. Indiana Michigan Power Co. (formerly Indiana (t'ichigan Ele RECIP.NAME RECIPXENT AFFILIATION MARTIN,J.B. Document Control Branch (Document Control Desk)

SUBJECT:

Forwards revised response to violation 2 from NOV dtd 931123 associated w/Insp Repts 50-315/93-12 6 50-316/93-12.

Corrective actions:I to I converter removed from circuitry on 940912.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

'TITLE: General (50 Dkt)-Insp Rept/Notice of Vio ation Response NOTES RECXPIENT COPIES RECIPXENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD3-1 PD 1 1 HICKMAN,J 1 1 INTERNAL: AEOD/DEIB 1 1 AEOD/SPD/RAB 1 .1 AEOD/S PD/RRAB 1 1 AEOD/~C 1 1 DEDRO 1 1 ~FILE CENTET5 02 1 1 NRR/DORS/OEAB 1 1 NRR/'DRCH/HHFB 1 1 NRR/PMAS/IRCB-E 1 1 NUDOCS-ABSTRACT 1 1 OE DIR 1 1 OGC/HDS2 1 1 RGN3 FILE 01 1 1 ERNAL: LITCO BRYCE,J H 1 1 NOAC 1 1

'RC PDR 1 1 YOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE 4VASTE! COSTA('.T'I'I IE DQCL'ifEiT CONTROL DESK, ROOif Pl-37 (EXT. 5()4-00S3 ) TO I;LlhflNATE5'Ol'R XA) IL: I'ROTI DISTRIIIU'I'!ONLIS'I'S I:OR DO(.".Uif[ X'I'S YOU l)ON "IIII:.I)!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 18 ENCL 18

fridicrc- fi'..* >>.q.

Power Compan~

P.O Box 16li);

Columba.< Oil -".:"r IMOMRA NlCHISAF4 PMFA AEP'NRC:1184H1 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 NO. 50-315/93012 (DRS)

AND 50-316/93012 (DRS)

REPLY TO NOTICE OF VIOLATION (SYSTEM BASED INSTRUMENTATION AND CONTROL INSPECTION)

U. S. Nuclear Regulatory Commission Document Control Desk Vashington, D. C. 20555 Attn: J. B. Martin November 28, 1994

Dear Mr. Martin:

By letter dated January 4, 1994, (AEP:NRC:1184H), we responded to a Notice of Violation dated November 23, 1993, associated with the subject NRC inspection. The violations were associated with 1) errors in a setpoint calculation for refueling water storage tank level instrumentation and 2) the lack of an unreviewed safety question determination for Temporary Modification 2-93-015, which installed an I to I converter in the Unit 2 feedwater pump control circuitry.

By letter dated October 4, 1994, the NRC expressed concern with our response to violation No. 2. Our revised response to violation No. 2 is contained in the attachment to this letter.

9412020086 9'41128 PDR ADOCK 05000315 g PDR

J. B. Martin AEP'NRC'1184Hl This letter is submitted pursuant to 10 CFR 50.54(f) and, as such, an oath statement is attached.

Sincerely, Vice President eh Attachments CC: A. A. Blind G. Charnoff NFEM Section Chief NRC Resident Inspector - Bridgman J. R. Padgett W. T. Russell - NRC Region III

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 Reply to Notice of Violation '(System Based Instrumentation and Control Inspection), and knows the contents thereof; and that said contents are true to the best of his knowledge and belief.

Subscribed and sworn to before day of me 19 ~.

this ~%~4 NOTAR PUBLIC

"' ') Hl'L tlOTV" FL'BUG. STATE GF GHt0

0 ATTAQBKNT TO AEP'NRC'1184H1 RESPONSE TO NRC CONCERNS REGARDING REPLY TO NOTICE OF VIOIATION'RC INSPECTION REPORT NOS. 50-315/93012(DRS) AND 50-316/93012(DRS)

ATTACHMENT TO AEP:NRC'1184Hl PAGE 1 NRC Res on e to Re "With regard to your response to violation No. 2, we disagree with your position that this violation does not represent a departure 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 system with respect to, among others, the probability of .'ontrol 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.

Please provide your response to this concern within 30 days of this letter."

es onse to C Co ce In response to the concerns raised in the NRC's letter of October 4, 1994, we are amending our original response to violation 2 from the Notice of Violation. The revised response is contained below.

dm so D e e ed V o at o Indiana Michigan Power admits to the violation as cited in the'RC Notice of Violation..

2. easo eVoato The reason for the violation is a difference in

ATTACHMENT TO AEP: NRC: 1184Hl PAGE 2 interpretation of the requirements of 10 CFR 50.59.

With respect to the design change of the I to I converter (Temporary Modification TM 2-93-015),

neither the function of the main feedwater pumps as described in the UFSAR (to provide feedwater flow to the steam generators) nor the method of performing the function as described in the UFSAR (with variable speed pumps) was impacted by the change.

Additionally, complete loss of feedwater (independent of the specific reason) was already an analyzed UFSAR Chapter 14 event. Thus, in the ]udgment of the individuals performing the screening, the change represented neither an explicit nor an implicit change to the UFSAR, and therefore an unreviewed safety question determination was not performed.

3. ect v t s a e d u c eved The I to I converter was removed from the circuitry on September 12, 1994.

4. o ective tio s ke o vo F e V at ns Prior to the SBICI inspection, we were performing Unreviewed Safety Question determinations for all Request for Changes and Minor Modifications (generally safety related/safety interface changes), regardless of the results of the 10 CFR 50.59 screening.

Following the SBICI, we modified the Temporary Modification process such that Unreviewed Safety Question, determinations are now performed for all temporary modifications involving safety related and/or seismic class I or II equipment. Additionally, we will modify our design change process such that we perform Unreviewed Safety Question determinations for the balance of the design changes (Plant Modifications and non-safety related/non-seismic class I or II

,Temporary Modifications). This change will be implemented by December 31, 1994, for design changes for which physical work is not in progress as of that dates

5. v d Full compliance was achieved on September 12, 1994,

-when the I to I converter was removed from the circuitry.