ML17333A620
| ML17333A620 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 10/21/1996 |
| From: | Fitzpatrick E AMERICAN ELECTRIC POWER CO., INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| AEP:NRC:1238C, NUDOCS 9610300237 | |
| Download: ML17333A620 (13) | |
Text
Indiana Michigan Power Company 500 Circle Drive Bvchanan, Ml 49107 1395
, October 21, 1996 INOIANA NICHIGAN POMfER AEP:NRC:1238C 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. 50-315/96006 (DRP)
AND 50-316/96006 (DRP)
REPLY TO NOTICE OF VIOLATIONS This letter is in response to a letter from J.
L. Caldwell dated September 19, 1996, that forwarded a notice of violation to Indiana Michigan Power Company.
The notice of violation contained two violations of NRC requirements identified during, a routine safety inspection conducted by Messrs.
B.
- Bartlett, D.
- Hartland, C. Orsini, and R. Lerch from May 26 through July 13, 1996.
The violations are associated with untimely performance of prompt operability evaluations and untimely corrective action.
We understand the significance of the violations, as the identification and resolution of deficiencies is intrinsic to the continued safe operation of the plant, and we assure you that our performance in this regard does not reflect our management expectations.
Our reply to the violations is provided in the attachment to this letter.
Sincerely, E.
E. Fit trick Vice President
/mb Attachment CC:
A. A. Blind A. B. Beach MDEQ -
DW 6 RPD NRC Resident Inspector J.
R. Padgett 96i0300237 96i021 PDR ADOCK 05000315 6
ATTACHMENT TO AEP'NRC:1238C REPLY TO NOTICE OF VIOLATION:
NRC INSPECTION REPORT NOS.
50-."'15/96006 (DRP)
AND 50-316/96006 (DRP)
0
Attachment to AEP:NRC:1238C Page 1
On July 13,
- 1996, the NRC completed an inspection of the Cook Nuclear Plant units 1 & 2 reactor facilities.
Violations of NRC requirements were identified during this inspection.
In accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions," (60 FR 34381; June 30, 1995) the violations and the Cook Nuclear Plant responses are listed below.
NRC Violation No.
1 "D.
C.
Cook Plant Technical Specification 6.8
~ 1 states, in
- part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978 'he following were examples oi'ailure to follow procedures:
Regulatory Guide 1.33, Appendix A, paragraph l.b requires that a procedure be written delineating the authorities and responsibilities for safe operation and shutdown.
Plant Managers Instruction (PMI) 7030, "Corrective Action,"
was written in accordance with RG 1.33.
Step 5.31 requires in part, that a prompt operability determination "...must be made expeditiously following identification of a potentially degraded condition that has the potential to impact SSC operability."
Step 6.9.a, requires an originator to initiate a
condition report for known or suspected adverse conditions/events.
Contrary to the above:
On April 13,
- 1996, the licensee failed to properly perform and document a prompt operability determination for both of the Unit 1
emergency diesel generators (D/G) and the other. Unit 2 D/G (2 AB) following the identification of a potentially generic condition of failed Cam follower springs on the 2
CD D/G.
b.
On May 3, 1996, the Unit 2 West Essential Service Water (ESW) strainer discharge check valve leaked-by sufficient to cause the pump to rotate backwards, however a
prompt operability evaluation was not performed until prompted by the inspectors on July 9, 1996.
On December 27,
- 1995, the Unit 1 CD emergency diesel generator (D/G) neutral grounding'esistor was identified by licensee personnel to be incorre'ctly configured (nominally 6 ohms but it was wired such that it was actually 2.3 ohms).
The prompt operability evaluation was not performed until January 5,
1996.
'ttachment to AEP:NRC:1238C Page 2
This is a
severity level IV violation (Supplement I).
(50-315/316-96006-01)."
Res onse to NRC Violation No.
1 1.
Admission or Denial o
the Alle ed Violatio Indiana Michigan Power Company admits to the violation as cited in the NRC notice of violation.
2.
Reasons for the Violatio The examples cited in the notice of violation point to a
weakness in the understanding of management expectations for the prompt inil.iation of condition reports and for the expeditious performance of operability determinations that would occur as a result of condition reports being initiated.
The intent of the procedure requirements was to ensure timely initiation of condition reports and timely operability determination.
The terms "prompt" and "expeditiously" were used in the procedure;
- however, absent clear understanding of management expectations, the terms are subject to interpretation.
Our investigation showed that operability determinations would have been performed and documented had condition reports been promptly initiated for the conditions in items b and c above.
In addition, an operability determination would have been performed had a
condition report been initiated following the identification that the condition in item a was a generic condition.
3.
Corrective Actions Taken and Results Achieved As indicated in the inspection
- report, operability evaluations were subsequently performed for each of the examples cited in the notice of violation.
Corrective actions taken and results achieved relative to the weakness in the understanding of management expectations for the prompt initiation of condition reports are addressed in the response to violation no
~
2e Corrective Actions to Avoid Further Violations Corrective actions to avoid further violations relative to the weakness in the understanding of management expectations for the prompt initiation of condition reports are addressed in the response to violation no.
2.
'Attachment to AEP:NRC:1238C Page 3
To address the weakness in the understanding of management expectations relative to expeditious performance of operability determinations, Plant Manager Standing Order (PMSO)
No.
- 173, "PMI-7030 Operability Determinations,"
was issued July 19, 1996.
The PMSO states management expectations for operability determinations required by PMI-7030.
The standing order provides direction regarding timeliness and the points to be addressed by operability determinations.
5.
Date When Full Com liance will be Achieved Because of the dependence of operability determinations on the prompt initiation of condition
- reports, management expectatzons were communicated to appropriate nuclear personnel in a
letter dated October 7,
1996.
Meetings to reinforce the expectations were completed as of October 18,
- 1996, thereby achieving full compliance.
NRC Violation No.
2 "10 CFR 50, Appendix B, Criterion XVI, "Corrective Action"
- required, in part, that conditions adverse to quality be promptly identified and corrected.
Contrary to the above:
On February 5,
- 1996, NRC inspectors identified to licensee management that instruments used to verify Technical Specifications required temperatures were not in a calibration program.
This deficiency had been communicated from the operations staff to engineering prior to January 1996, but no action via the corrective action process had been initiated.
- Further, a
condition report (CR) was not issued for 2 days after the identification by the NRC.
b.
On February 7, 1996, the inspectors identified possible auxiliary feedwater system piping support deficiencies and a CR was not initiated until four days later.
On February 6,
- 1996, a
CR for the boric acid system heat trace high temperature conditions had not been written until two days after NRC inspectors questioned the system status.
Previously, local high temperature indications had been illuminated and known to equipment operators and engineering, but corrective action was not initiated.
In February 1996, following installation, but prior to placing a
temporary modification which installed a
'ttachment to AEP:NRC:1238C Page 4
"COSMOS" analytic panel on the component cooling water system in operation, the completed package was required by temporary modification procedure PMP 5040 MOD.001 to be returned to the control room and placed in the TM log.
The unit had been in service for about 30 days,
- however, the package had not been returned to the control
- room, and operators were not aware that the unit was in" service.
This did not meet the requirements of the procedure and a condition report was not written to address this issue.
This is a
Severity Level IV violation (Supplement I)
(50-315/316-96006-02)."
Res onse to NRC Violation No.
2 Admission or Denial of the Alle ed Violation Indiana Michigan Power Company admits to the violation as cited in the NRC notice of violation.
Reasons for the Violation The examples cited in the notice of violation point to a
weakness in the understanding of management expectations for the prompt initiation of condition reports.
Due to this weakness, the examples described in violation no.
2 were not promptly identified and corrected.
Corrective Actions Taken and Results Achieved As stated in the notice of violation, condition reports were subsequently written to address examples a, b, and c.
A condition report was written October 4, 1996, to address item d.
Management expectations were disseminated via letters from senior management to all applicable personnel.
The letters addressed when and for what conditions a
condition report is to be initiated.
Followup meetings are being held within each appropriate organization to reinforce management expectations relative to promptly writing condition reports.
Corrective Actions to Avoid Further Violations The guidance disseminated via the management expectations letters noted in section 3 above will be incorporated into a management instruction or procedure by December 31, 1996.
'Attachment to AEP:NRC:1238C Page 5
Date When Full Cpm liance will be Achieved Management expectations were communicated to appropriate nuclear personnel in a
letter dated October 7,
1996.
Meetings to reinforce the expectations were completed as of October 18,
- 1996, thereby achieving full compliance.
J