ML17333A458

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Notice of Violation from Insp on 960227-0408.Violation Noted:On 960322,licensee Utilized Temporary Change Process & Did Not Perform Safety Review Prior to Issuing Listed Changes to Procedures Which Changed Intent of Procedure
ML17333A458
Person / Time
Site: Cook  
Issue date: 05/16/1996
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17333A459 List:
References
50-315-96-04, 50-315-96-4, 50-316-96-04, 50-316-96-4, NUDOCS 9605290170
Download: ML17333A458 (4)


Text

NOTICE OF VIOLATION Indiana Michigan Power Company Donald C.

Cook Nuclear Power Plant Docket No. 50-315; 5-316 License No.

DPR-58; DPR-74 During an NRC inspection conducted from February 27 through April 8,

1996, two violations of NRC requirements were identified.

In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"

NUREG-1600, the violations are listed below:

Technical Specification 6.5.3. 1 states that procedures required by Technical Specification 6.8 and other procedures which affect plant nuclear safety, and changes

thereto, shall be prepared,
reviewed, and approved. It further states that temporary changes that do change the intent of the approved procedure can be approved by two members of the plant staff, with at least one individual holding a senior reactor operator license and allows the safety review to determine if an unreviewed safety question exist to be conducted until 14 days after implementation of the change.

Technical Specification 6.5.3.1.e states that each review shall include a determination of whether or not an unreviewed safety question is involved.

Contrary to the above, on March 22,

1996, the licensee utilized the temporary change process and did not perform a safety review prior to issuing the following changes to procedures that changed the intent of the approved procedure.

a)

Change Sheet 3 to procedure 02-OHP 4021.001.003, "Power Reduction,"

was issued to revise the method of a planned reactor shutdown from an orderly reactor shutdown from power to a manual reactor trip from a power level that would result in the automatic starting of engineered safety feature equipment (ESF).

b)

Change Sheet 1 to surveillance procedure 02-0HP4030.STP.026, "Auxiliary Power Transfer Test Surveillance Procedure,"

Revision 5, revised when to perform the TS surveillance.

Instead of performing the surveillance when the reactor was shutdown (Mode 5

or 6), the revision allowed the surveillance to be performed at power (Mode 1) using an actual ESF actuation (reactor trip).

This is a Severity Level IV violation (Supplement I). (50-316/96004-01) 9605290l70 960516 PDR ADQCK 050003i5 8

Pl)R

0

Notice of Violation Technical Specification (TS) 6.8 requires that procedures and programs be established, implemented, and maintained.

TS 6.8.3 requires, in part, that a program for post accident sampling be implemented to ensure the capability to analyze reactor coolant samples.

TS 6.8. 1 requires that procedures recommended in Regulatory Guide 1.33, Revision 2, be established, implemented, and maintained.

Regulatory Guide 1.33, Section 8.a, in part, recommends procedures to ensure that instruments and measuring equipment, such as laboratory equipment, are properly calibrated and adjusted at specified periods to maintain accuracy.

Procedure 12 THP 6020 PAS.016, "Post Accident Sampling equality Assurance,"

revision 2, requires:

1) monthly comparisons between post accident sampling system and the results obtained via routine sampling and analysis and 2) corrective actions for monthly comparisons between PASS results and the results obtained via routine sampling and analysis which do not meet the licensee's acceptance criteria.

Procedure 12 THP 6020 ADH.OOI, Revision 0, "equality Control," which defines the program to ensure accurate analytical results are obtained From laboratory instruments, requires that quality control data be evaluated for defined trends and biases, and that the cause and corrective action taken be documented in the appropriate log book.

Contrary to the above, The following required monthly PASS sampling and analysis were not completed:

1) the August 1995 pH, oxygen, and gas chromatograph (GC) samples;.
2) the September 1995 boron comparison;
3) the October 1995 comparisons for the GC, boron, and nuclide activity; and 4) the November and Dece'mber 1995 PASS boron samples.

The following required corrective actions were not completed for the following monthly PASS sampling and analyses:

1) the August 1995 monthly boron comparisons; 2)

September 1995 monthly comparisons for the GC, pH, and nuclide activity; and 3) October 1995 monthly comparison for pH.

C.

The trends and/or biases on the following instruments were not evaluated nor documented:

a) chloride performance checks on instrument 104 from October 1995 to April 1996; b) chloride performance checks on instrument 106 from October 1995 to April 1996;c) sulphate performance checks on instruments I04 and 106 from October 1995 to April 1996.

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

(50-315; 50-316/96004-02).

Notice of Violation Pursuant to the provisions of 10 CFR 2.201, Indiana Michigan Power Company is hereby required to submit a written statement or explanation to the U.S.

Nuclear Regulatory Commission, ATTN:

Document Control

Desk, Washington, D.C.

20555 with a copy to the Regional Administrator, Region III, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).

This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation:

(1) the reason for the violation, or, if contested, the basi's for disputing the violation, (2) the corrective steps that have been taken and the results

achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.

Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response.

If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued to show cause why the license should not be modified, suspended, or

revoked, or why such other action as may be proper should not be taken.

Where good cause is shown, consideration will be given to extending the response time.

8ecause your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the POR without reduction.

However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the

PDR, and provide the legal basis to support your request for withholding the information from the public.

Dated at Lisle, Illinois, this 16th day of May 1996