ML17333A348

Forwards Response to Violations Noted in Insp Repts 50-315/95-13 & 50-316/95-13.Corrective Actions:Appropriate Scheduling Logic Changes Have Been Incorporated for Both Turbine Driven Afp,Preclude TS Surveillance

ML17333A348
Person / Time
Site:	Cook
Issue date:	03/09/1996
From:	Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AEP:NRC:1224G, NUDOCS 9603150080
Download: ML17333A348 (14)

Text

CATEGORY 1 REGUI ATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

CESSION NBR:9603150080 DOC.DATE: 96/03/09 NOTARIZED: YES DOCKET CIL:50-33.b 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. Indiana Michigan Power Co. (formerly Indiana & Michigan Ele RECIP.NAME RECIPIENT AFFILIATION Document .Control Branch (Document Control Desk)

SUBJECT:

Forwards response to violations noted in Insp Repts 50-315/95-13 a 50-316/95-13.Corrective actions:appropriate scheduling logic changes have been incorporated for both turbine driven AFP,preclude TS surveillance.

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 PD3-1 PD 1 1 HICKMANIJ 1 1 INTERNAL: AEOD/DEIB 1 1 AEOD/SPD/RAB 1 1 O~ 1 1 DEDRO 1 1 FILE CENTER 1 1 NRR/DI SP/PIPB 1 1 HHFB 1 1 NRR/DRPM/PECB 1 1 NRR/DRPM/PERB 1 1 NUDOCS-ABSTRACT 1 1 OE DIR 1 1 OGC/HDS2 1 1 RGN3 FILE 01 1 1 D

EXTERNAL: LITCO BRYCE,J H 1 1 NOAC 1 1 NRC PDR 1 1 0 U

N NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE) CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN 5D-5(EXT. 415-2083) TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDI TOTAL NUMBER OF COPIES REQUIRED: LTTR 18 ENCL . 18

indiana Michigan Power Company PO Box 16631 Columbus, OH 43216 INDMNA NICHEGAN POWER March 9, 1996 AEP: NRC: 1224G 10 CFR 2.201 Docket Nos.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 1 Gentlemen:

Donald C. Cook Nuclear Plant Units 1 and 2 NRC INSPECTION REPORTS NO. 50-315/95013 (DRP)

AND 50-316/95013 (DRP)

REPLY TO NOTICE OF VIOIATIONS This letter is in response to a letter from W. J. Kropp dated February 8, 1996, that forwarded a notice of violation to Indiana Michigan Power Company. Two violations were identified during a routine safety inspection conducted by Messrs. Bartlett, Hartland, Orsini, Paul, Fuller, and Shah from December 5, 1995, through January 16, 1996. One violation is associated with Technical Specification surveillances which were not 'accomplished under suitably controlled conditions. The second violation is associated with not testing the Unit 2 CD diesel generator within the required surveillance interval including the maximum allowable extension.

Our reply to the violations is provided in the attachment to this letter. The reply does not contain any personal privacy, proprietary, or safeguards information.

pM E. E. Fitzpatrick Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF 1996 Notary P blic

~-p/

9603150080 960309 PDR ADOCK 05000315 8 PDR

U. S. Nuclear Regulatory Commission AEP:NRC:1224G Page 2 pit Attachment CC: A. A. Blind G. Charnoff H. J. Miller NFEM Section Chief NRC Resident Inspector - Bridgman J. R. Padgett W. T. Russell - NRC NRR

ATTACHMENT TO AEP:NRC:1224G REPLY TO NOTICE OF VIOLATION'RC INSPECTION REPORT NOS. 50-315/95013 (DRP)

AND 50-316/95013 (DRP)

ATTACHMENT TO AEP NRC 1224G Page 1 During an NRC inspection conducted December 5, 1995, through January 16, 1996, two violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Piocedures for NRC Enforcement Actions," (60 FR 34381, June 30, 1995) the violations and the Donald C. Cook Nuclear Plant response are provided below.

C Violat on I "10 CFR 50, Appendix B, Criterion II, '~ality Assurance',

requires, in part, that activities affecting quality shall be accomplished under suitably controlled conditions. Surveillance testing required by Technical Specifications (T/S) to verify operability of equipment is an activity affecting quality.

Contrary to the above, T/S surveillances were not accomplished under suitably controlled conditions, in that:

l. In May and September 1994, the Unit 2 turbine driven auxiliary feedwater pump (TDAFP) trip and throttle valve was tested and the pump operated just prior to performing the T/S required surveillance 4.7.1.2.'.

On numerous occasions, including January 16, 1996, the Unit 2 AB emergency diesel generator (D/G) was rolled per surveillance procedure, OHP 4030 STP.027AB/CD. This roll used the starting air system and was performed prior to the part of. the surveillance that verified the D/G capability to meet T/S fast start criteria. This resulted in exercising several components in the starting air system prior to verifying the D/G fast start capabilities.

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

es onse to NRC Violation dmission or Denial of t e lie ed Violatio Indiana Michigan Power admits to the violation as cited in the NRC Notice of Violation, except that, as a matter of record, the two instances cited with regard to the TDAFPs are incorrect: they occurred in April 1994 on the Unit 2 TDAFP and in September 1994 on the Unit 1 TDAFP.

In addition, the resident inspector brought to our attention a third instance of preconditioning that he discovered concerning a monthly preventive maintenance (PM) activity to lubricate and exercise the fuel racks on'the D/Gs. This is planned and scheduled independently of the monthly D/G T/S surveillance. On January 23, 1996, the resident inspector observed that the PM activity occurred prior to the T/S

ATTACHMENT TO AEP NRC 1224G Page 2 surveillance on the same day. This additional instance is also addressed in our response below.

2. easons o the Vio at o The reason for this violation is the absence of guidance that ensures that T/S surveillances are performed without preconditioning of the component or equipment prior to performing the surveillance.

3. Corrective Actions Taken and Results Achieved With regard to the TDAFPs, appropriate scheduling logic changes have been incorporated for both TDAFPs that preclude the T/S surveillance from being preceded by trip and throttle valve testing and pump operation. All quarterly T/S surveillances on TDAFPs since December 1995 have been performed using the revised scheduling logic. All of these T/S surveillances were completed with satisfactory results.

With regard to the Unit 2 AB D/G, appropriate procedure and work control process changes have been incorporated to modify how the D/G T/S surveillance is performed. These changes were made in accordance with the guidelines that were provided to the NRC in our letter AEP:NRC:1224D, dated January 6, 1996, which was made in response to unresolved item 95010-01. All D/Gs at Cook Nuclear Plant are presently considered operable.

With regard to the D/G fuel racks, notes have been added to the job orders for the PM tasks that will preclude the PM task from being scheduled immediately prior to the T/S surveillance.

4. Corrective Actions Taken to Avoid Further Violations In response to this notice of violation, a multi-disciplinary task force was created to address the issue of preconditioning on a generic basis. The task force is developing a program designed to ensure that preconditioning prior to T/S surveillances does not recur.

To preclude preconditioning, the following actions have been taken or are planned.

Written guidance will be issued by March 15, 1996, to address potential preconditioning concerns that may arise in the immediate future for associated T/S surveillance activities during the Unit 2 refueling outage and Units 1 and 2 normal plant operations. The guidance will provide direction in identification and

ATTACHMENT TO AEP 'NRC: 1224G Page 3 timely resolution of possible preconditioning items as they arise.

T/S surveillance procedures performed on an operating unit s equipment will be reviewed to identify and correct any procedures in which preconditioning is inadvertently caused by actions taken in procedure steps preceding the actual surveillance procedure steps. This will be accomplished prior to January 31, 1997.

T/S surveillance procedures performed during outages will be reviewed to identify and correct any procedures in which preconditioning is inadvertently caused by actions taken in procedure steps preceding the actual surveillance procedure steps. This will be accomplished on a schedule consistent with the procedure review requirements for future refueling outages: for Unit 1, September 1, 1996, for the spring 1997 refueling outage; for Unit 2, May 1, 1997, for the autumn 1997 refueling outage.

During work control process schedule periods in which a T/S surveillance is scheduled to be performed on equipment which is required to support an operating unit, should there be any type of potentially preconditioning activity scheduled for that same equipment during the same period, the situation will be evaluated to determine if the T/S surveillance should be performed prior to the other activities. Guidance will be provided to appropriate personnel to identify and address any preconditioning issues during the execution of the T/S surveillances. The scheduling philosophy and programmatic enhancements will be implemented prior to July 6, 1996.

5. ate w en ull Com 1 a ce W be c ivd Full compliance has been achieved with regard to the cited instances pertaining to the TDAFPs and D/Gs, and with regard to the additional item identified by the resident inspector.

With regard to ensuring that preconditioning does not recur at Cook Nuclear Plant, full compliance will be achieved on or prior to May 1, 1997, with the completion of the full review of all T/S surveillance procedures.

ATTACHMENT TO AEP:NRC: 1224G Page 4 C Violation II "Technical Specification 4.0.2 states that each surveillance requirement shall be performed within the specified time interval with a maximum allowable extension not to exceed 25% of the specified surveillance interval.

Technical Specification 4.8.1.1.2 states, in part, that each diesel generator shall be demonstrated operable .. in accordance with the

~

frequency specified in Table 4.8-1.

Table 4.8-1 states, in part, that if the number of failures in the last 20 valid tests is greater than or equal to 2, then the diesel generator shall be tested at least once per 7 days.

Contrary to the above, from January 5 to January 15, 1996, with two failures in the last 20 valid tests, the licensee did not test the Unit 2 CD diesel generator (D/G) within the required surveillance interval including the maximum allowable extension.

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

es onse to NRC Violation dm ssion or Den al o t e A e ed V o at o Indiana Michigan Power a'dmits to the violation as cited in the NRC Notice of Violation.

2. easons for the Violation The cause of the violation is personnel error. Unit 2 T/S Table 4.8-1 states that the number of D/G "failures" and the number of "valid tests" shall be determined in accordance with criteria specified in Regulatory Guide 1.108. On December 29, 1995, while the Unit 2 CD D/G was undergoing post-maintenance testing, the D/G experienced an incomplete start. Initially, in accordance with Unit 2 T/S Table 4.8-1 and Regulatory Guide 1.108, this incomplete start was considered a failure, and an increased-frequency surveillance schedule was established as required by T/S.

However, on January 2, 1996, based on an NRC letter stating that Regulatory Guide 1.108 had been incorporated into Regulatory Guide 1.9, engineering personnel incorrectly applied Regulatory Guide 1.9 to the incomplete start. This resulted in the improper categorization of the D/G incomplete start as "not a failure". T/Ss require performance of a weekly surveillance if there have been two failures within the last 20 diesel generator starts. Because the December 29, 1995, incomplete start was no longer considered a failure, the engineers believed that the weekly surveillance

ATTACHMENT TO AEP 'NRC: 1224G Page 5 requirement specified in T/Ss did not apply. The increased-frequency surveillance schedule was cancelled.

3. Corrective Actions a e a d esu ts eve Following additional review, it was determined that the criteria in Regulatory Guide 1.108 should have been applied to the December 29, 1995, D/G incomplete start. The incomplete start was reel,assified as a failure. The surveillance procedure was promptly performed on the Unit 2 CD D/G and the D/G was declared operable and placed on an increased-frequency surveillance schedule.

4. Corrective Actions Taken to Avoid Furt er V olations The engineering personnel involved with this event have been counseled on the need for strict compliance with the T/Ss and referenced documents. A T/S change request has been submitted for NRC consideration. The change, if approved, would modify T/S 3.8.1.1 to reference Regulatory Guide 1.9 instead of Regulatory Guide 1.108 for determination of diesel generator "failures" and "valid tests".

5. Date when Full Com liance Vill be Achieved Full compliance was achieved at 1648 hours0.0191 days <br />0.458 hours <br />0.00272 weeks <br />6.27064e-4 months <br /> on January 15, 1996, when operability of the Unit 2 CD diesel generator was demonstrated by successful completion of the surveillance procedure.

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