ML17333A486
| ML17333A486 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 06/28/1996 |
| From: | Fitzpatrick E AMERICAN ELECTRIC POWER CO., INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| AEP:NRC:1238A, NUDOCS 9607020220 | |
| Download: ML17333A486 (10) | |
Text
CATEGORY 1 REGULATORY ZNPORMATZON DISTRIBUTION SYSTEM (RIDE)
ACCESSION NBR:9607020220 DOC.DATE: 96/06/28 NOTARIZED: YES FACIL:50-315 Donald C.
Cook Nuclear Power Plant, Unit 1, Indiana M
50-316 Donald C.
Cook Nuclear Power Plant, Unit 2, Indiana M
AUTH.NAME AUTHOR AFFILIATION FITZPATRICK,E.E American Electric Power Co., Inc.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET t 05000315 05000316
SUBJECT:
Responds to NRC 960516 ltr re violations noted in insp repts 50-315/96-04
& 50-316/96-04 on 960227-0408.C/A:procedure 02-OHP 4021.001.003 revised to add maual reactor trip using normal procedure rev process. Supervisory personnel counseled, DZSTRZBUT1ON CODE:
IE01D COPIES RECEIVED:LTR L ENCL J SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:
RECIPIENT ID CODE/NAME PD3-1 PD INTERNAL: AEOD/SPD/RAB DEDRO NRR/DISP/PIPB NRR/DRPM/PECB NUDOCS-ABSTRACT OGC/HDS2 EXTERNAL: LITCO BRYCE,J H
NRC PDR COPIES LTTR ENCL 1
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1 RECIPIENT ID CODE/NAME HICKMAN,J Ee TC LE 'CENTER NRR PPfHHFB NRR/DRPM/PERB OE DIR RGN3 FILE 01 NOAC COPIES LTTR ENCL 1
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U 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 NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 17 ENCL 17
American Electric P~
1 Rwe:side Plaza Columbus. OH 4321 5 2373 614 223 1000 HP ANKRlCAN KLKCTRlC POWER June 28, 1996 AEP:NRC:1238A 10 CFR 2.201 Docket Nos.:
50-315 50-316 U.
S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.
C.
20555 Gentlemen:
Donald C.
Cook Nuclear Plant Units 1 and 2
NRC INSPECTION REPORTS NO. 50-315/96004 (DRP)
AND 50-316/96004 (DRP)
REPLY TO NOTICE OF VIOLATIONS This letter is in response to a letter from W. J.
Kropp dated May 16,
- 1996, that forwarded a notice of two violations of NRC requirements to Indiana Michigan Power Company.
The violations were identified during a routine safety inspection conducted by Messrs.
Bartlett, Hartland, and Orsini from February 27 through April 8, 1996.
Our response was due to you on June 17,
- 1995, however, a request was made that day and granted by Mr. Nick Jackiw of Region III, for a brief extension.
The first violation is associated with changing the intent of two plant procedures without the required safety reviews being performed.
As recommended in the violation notice, our response delineates the steps taken to ensure that no operational direction willbe provided to operators, outside of the operating procedures, when utilizing procedure PMI-4090, "Criteria for Conducting Infrequently Performed Tests or Evolutions".
The second violation is associated with failure to perform Post Accident Sampling System (PASS) quality control activities in accordance with procedures.
The violation deals with PASS program implementation.
We agree that these routine aspects of the sampling program did not meet procedural requirements, however, at no time was the capability to obtain PASS samples rendered inoperable by the events cited in the violation.
Q:) Qr)t~ j~
9607020220 960628 PDR ADQCK 05000315 8
U. S. Nuclear Regulatory Commission Page 2
AEP:NRC:1238A 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.
Sincerely, E.
E. Fitzpatrick Vice President SWORN TO AND SUBSCRIBED BEFORE ME
/W THIS
~ i'6 DAY OF
'./
~
1996 otary Public My Commission Expires:
)..F'
~
msg 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: 1238A REPLY TO NOTICE OF VIOLATION:
NRC INSPECTION REPORT NOS. 50-315/96004 (DRP)
AND 50-316/96004 (DRP)
Attachment 1 to AEP:NRC:1238A Page 1
During an NRC inspection conducted February 27 through April 8,
- 1996, two violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions" (60 FR 34381, June 30, 1995),
the violations and the Donald C.
Cook Nuclear Plant responses are provided below.
NRC Violation 1 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 (not) 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 exists to be conducted (up to) 14 days after implementation of the change.
Technical Specification 6.5.3.l.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-OHP 4030.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)
(minor changes to original Notice of Violation, to clarify)
Attachment 1 to AEP:NRC:1238A Page 2
es ons to V olatio dmission or Denial of the Alle ed V o etio Indiana Michigan Power Company admits to the violation as cited in the notice of violation.
2.
Reasons or the V o a o
Change sheet 3
to procedure 02-OHP 4021.001.003, "Power Reduction,"
was not identified as a change of intent because it did not accurately reflect the full scope of activities to be performed.
The guidance related to the method of
- shutdown, specifically to manually trip the reactor at 20$
- power, was being provided under the auspices of a Plant Manager's Instruction (PMI),
PMI-4090, "Criteria for Conducting Infrequently Performed Tests or Evolutions".
The product of this review also included guidance to start auxiliary feedwater pumps prior to the trip and to return to the normal power reduction procedure upon exiting the reactor trip response procedure.
However, the review process in PMI-4090 does not ask for a
review to determine that an unreviewed safety question does not exist.
PMI-4090 is designed to establish criteria for determining if infrequently performed tests or evolutions require additional controls due to 'their complexity and infrequency, and to define those additional controls as necessary.
It was a
proper and proactive use of PMI-4090 to perform a detailed review of the shutdown plan; however, it was not an appropriate vehicle for providing the operational direction to perform the plan.
The change sheet to the power reduction procedure listed only actions to verify automatic transfer of station electrical auxiliaries, as well as other unrelated changes.
Based on the concurrent preparation and review of the PMI-4090 review
- package, Change Sheet 3 to procedure 02-OHP 4021.001.003 was not properly identified as a change of intent.
In a similar manner, Change sheet 1 to surveillance procedure 02-OHP 4030.STP.026, "Auxiliary Power Transfer Test Surveillance Procedure,"
Revision 5,
was not properly identified as a change of intent.
This change was intended to complement the change to the power reduction procedure, allowing the surveillance procedure to be performed and take credit for the automatic transfer of electrical auxiliaries that would occur as a result of the planned reactor trip.
Attachment 1 to AEP:NRC:1238A Page 3
As before, due to the parallel development of the PMI-4090 review package, which inappropriately contained the reactor trip actions that would initiate the automatic transfer of auxiliaries, Change Sheet 1 to 02-OHP 4030.STP.026 was not properly identified as a change of intent.
3.
orre tive Aetio s aken nd esults Ac eved The NRC discussed their concerns with plant management on March 22, 1996.
In response, procedure 02-OHP 4021.001.003 was revised to add the manual reactor trip and other actions, using the normal procedure revision process, including the appropriate safety reviews, prior to tripping the unit on the following day.
It was concluded that the changes did not involve an unreviewed safety question.
Performance of surveillance procedure 02-OHP 4030.STP.026 was canceled.
4, orrective Actions Taken to Avoid Furthe Violatio s In general, PMIs are intended to provide information on what is to be accomplished, they are not intended to direct how work is to be performed, as was done in this case.
PMI-4090 and any other applicable plant administrative guidelines (PMIs
& Plant Manager Procedures (PMPs))
that could potentially provide inappropriate operational guidance or direction willbe revised to eliminate any such reference.
This will preclude the performance of actions outside the intended use of approved operating procedures.
Any necessary revisions to PMI-4090 willbe completed on or before July 19, 1996.
Review and revision of other applicable PMIs and PMPs will be completed on or before September 20, 1996.
5.
te e
u om anc i
e eyed Full compliance was achieved March 22, 1996, following the changes discussed in item 3 above.
NRC Violation 2 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
Attachment 1 to AEP:NRC:1238A Page 4
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 Quality 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 ADM.OOl, Revision 0, "Quality 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,
- 3) the October 1995 comparisons for the GC, boron, and nuclide activity; and 4) the November and December 1995 PASS boron samples.
b.
The following required corrective actions were not completed for the following monthly PASS sampling and analyses:
- 1) the August 1955 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 I04 from October 1995 to April 1996; b) chloride performance checks on instrument I06 from October 1995 to April 1996; c) sulphate performance checks on instruments I04 and I06 from October 1995 to April 1996.
This is a Severity Level IV violation (Supplement IV). (50-315; 50-316/96004-02)
Attachment 1 to AEP:NRC:1238A Page 5
Res onse to Violation 2 s
o or De a
o eedV Indiana Michigan Power Company admits to the violation as cited in the notice of violation.
2.
easons for t e Violatio The cause of the events identified is weakness in the implementation of the PASS readiness program.
Resources responsible for maintaining the PASS readiness program had been devoted to correcting long standing system maintenance and reliability concerns (dilution loop modification, on-line pH modification, complete PACHMS refurbishment, specific system training, etc.).
Consequently, oversight of some routine aspects of the sampling program declined.
At no time was the capability to obtain PASS samples
- degraded, nor was the PASS system rendered inoperable by the noted events.
3.
ect ve ct o s ake d
esult eyed Once identified by the inspectors during the IPAP, immediate action was taken to counsel the supervisory personnel responsible for the program.
The February 1996 sample comparisons data sheet was reviewed.
The comparisons were complete and any necessary follow-up action was taken for analyses not meeting acceptance criteria.
The March, April, and May 1996 comparison data have since been reviewed to ensure all appropriate actions were taken, which they were.
4.
Corrective Actions Taken to Avoid Furthe Violations A review and briefing session was performed relative to the requirements of 12 THP 6020 PAS.016 for the individuals responsible for the oversight, operation, performance, evaluation and maintenance of the PASS program.
- Further, this procedure was revised to:
- 1) implement statistical process control methodologies rather than fixed controls for the sampling and analysis program quality control; and
- 2) reduce or eliminate, as appropriate, sampling and analysis frequency requirements to afford supervision time for more rigorous oversight of the implemented program.
Additionally, a
PASS Readiness Report is periodically submitted to department management for oversight and review.
Attachment 1 to AEP:NRC:1238A Page 6
Procedure 12 THP 6020.ADM.001, "Quality Control" has been reviewed and revised to ensure that the requirements for evaluation and documentation of instrument trends and biases are clearly outlined.
5.
Date en ll Com ia c W
Be c ieve Full compliance was achieved February 29,
- 1996, with the review and approval of the February 1996 data sheet per the detailed review discussed in item 3 above.