ML17333A744

Submits Response to Violations Noted in Insp Repts 50-315/96-11 & 50-316/96-11.Corrective Actions:Immediate Operability Determination Concluded No Operability Concerns Existed for Essential Svc Water Pumps

ML17333A744
Person / Time
Site:	Cook
Issue date:	01/17/1997
From:	Fitzpatrick E AMERICAN ELECTRIC POWER CO., INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AEP:NRC:1238G, NUDOCS 9701230053
Download: ML17333A744 (11)

Text

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

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ACCESSION NBR:9701230053 DOC.DATE: 97/Ol/17 NOTARIZED: YES DOCKET FACIL: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, AFFILIATION ITZPATRICK,E. American Electric Power Co., Inc.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Submits response to violations noted in Insp Repts 50-315/96-11 6 50-316/96-11.Corrective actions:immediate operability determination concluded no operability concerns existed for essential svc water pumps.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:

RECIPIENT COPIES RECIPIENT COPIES 0

'ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD3-3 PD 1 1 HICKMANiJ 1 1 INTERNAL: AEOD/SPD/RAB 1 1 AEO C 1 1 DEDRO 1 1 LE CENTE 1 1 NRR/DISP/PIPB 1 1 DRC FB 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 ERNAL: LITCO BRYCEiJ H 1 1 NOAC 1 1 D NRC PDR 1 1 E

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN SD-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

l Indiana Michigan Power Company 500 Circle Drive Buchanan, Ml 49107 1395 Z

INDIANA MICHIGAN POWER January 17, 1997 AEP:NRC:1238G 10 CPR 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. 50-315/96011 (DRP)

AND 50-316/96011 (DRP) REPLY TO NOTICE OF VIOLATIONS This letter is in response to a letter from J. L. Caldwell dated December 5, 1996, that forwarded a notice of violation to Indiana Michigan Power Company. The notice of violation contained one violation of NRC requirements identified during a routine safety inspection conducted by Messrs. B. Bartlett, B. Puller, and J. Maynen from September 1 through October 12, 1996. The violation is associated with a failure to follow plant procedures in the installation of a temporary modification.

Our response was due to you on January 4, 1997; however, on December 16, 1996, we requested an extension to January 17, 1997, which was granted by Mr. L. Miller, Jr., of Region III.

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

Sincerely, SWORN TO AND SUBSCRIBED BEFORE ME Pe Fitz E. E. t ick THISJ9 DAY OF ~@<K 1997 Vice President Notary Public jen My Commission Expires:

Attachment CC: A. A. Blind JAN WATSON A. B. Beach NOTARY PUBUO, BERRIEN COUNTY, Ml MDEQ - DW 6 RPD MY COMMISSION EXPIRES FEB. 10, 1999 NRC Resident Inspector J. R. Padgett 970i230053 970ii7 PDR ADOCK 050003i5 8 PDR

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l ATTACHMENT TO AEP:NRC: 1238G REPLY TO NOTICE OF VIOLATION: NRC INSPECTION REPORT NOS. 50-315/96011 (DRP) AND 50-316/96011 (DRP)

Attachment to AEP:NRC: 1238G Page 1 During an NRC, inspection conducted from September 1 through October 12, 1996, one violation of NR" requirements was identified.

In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation and the Donald C. Cook Nuclear Plant response are provided below.

NRC Violation "Technical Specification (TS) 6.8, Procedures and Programs, 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, Rev 2, February 1978.

Regulatory Guide (RG) 1.33, Quality Assurance Program Requirements (Operations), Appendix A, states that safety-

" lated maintenance activities should be covered by written procedures.

Plant Managers Procedure (PMP) 5040 MOD.001, Revision 5,

'Temporary Modifications,'mplements, in part, TS 6.8 and RG 1.33, and requires that temporary modification installations be performed in accordance with the controls delineated therein. PMP 5040 MOD.001 defines a temporary modification as "Any short term configuration that exists on plant systems, components, or structures ... which does not conform to approved plant drawings ... and is being used to maintain operation of the plant."

Contrary to the above:

On September 3, 1996, the NRC inspectors identified that the licensee -had opened three small penetrations through a wall separating the mild environment of the safety related essential service water pumps from the potentially harsh environment of the turbine building. The openings did not conform to approved pla'nt .drawings, but the licensee failed to utilize the temporary mod'ification process required by PMP 5040 MOD.001 when removing the penetration covers.

This is a Severity Level IV violation."

Res onse to NRC Violation Admission or Deni l of he Alle d Violation Indiana Michigan Power Company admits to the violation as cited in the NRC Notice of Violation.

2. Reasons for th Viola i n The cause of the violation was a weakness in the temporary modification process. The temporary modification process allowed for use and connection of equipment outside the temporary modification process, as long as the points connecting to the plant systems were designed for that purpose, i.e., service connections. Under such conditions however, a technical review, including the impact of the penetration of barriers, was not required.

, II Attachment to AEP:NRC:1238G Page 2 Corr ctive Actions Tak n and R sul s A hieved An immediate operability determination concluded no operability concerns existed for the essential service water pumps from the potentially harsh environment of the turbine building based on the opening of the three penetrations.

As a control mechanism fnr the openings, a closure cap and an HELB boundary label are provided on each side of the subject penetrations.

The NOV identified three small penetrations through a wall separating the mild environment of the safety related essential service water pumps from the potentially harsh environment of the turbine building.

Of the three holes, one was servicing the plant biocide program, another had an air line running through it, and the third was servicing the reverse osmosis system to the makeup plant'.

The following actions were taken for the penetrations.

a) For the penetration associated with the biocide program, a temporary modification was performed in accordance with the temporary modification procedure, PMP 5040 MOD.001. The temporary modification review addressed removal of the HELB penetration cover.

b) For the penetration that had an air line running through it, the air line was removed and closure caps were installed. This restored the penetration to the approved plant drawing.

c) For the penetration supporting the reverse osmosis system, an HELB barrier evaluation was performed supporting continued use of the penetration.

Disposition and evaluation of the three penetrations were complete by November 14, 1996. In addition, actions were initiated to formally accept the subject HELB penetrations, either in the closed or open position, as part of the approved plant design. The approved plant drawing to reflect this condition was in place on January 16, 1997. 'I

Attachment to AEP:NRC:1238G Page 3

4. C rrectiv Ac ions to Avoid Furth r Viola ion The temporary modification procedure, PMP 5040 MOD.001, was revised to provide guidance regarding control of service connections and the need for a technical review. In addition, the technical review requirements of the procedure were revised to address HELB barriers.

In conjunction with this, the HELB procedure, PMP 4030.001 002, was revised to more clearly define HELB

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barrier requirements. The revision includes the requirement for an HELB review as part of the work control planning process.

In addition, the following changes were made to integrate the HELB program into plant processes.

Maintenance procedure, PMP 5020.001.001, "Maintenance Permits," was revised to address HELB boundaries when drilling through concrete.

Two construction procedures, 12 CHP 5021.CCD.007, "Masonry Block, Brick and Facing Installation," and 12 CDP 5021.CCD.015, "Removable High Density Block Fire Walls," were revised to address HELB boundaries.

Da e Wh n Full C m li n will be A hieved Full compliance was achieved on November 14, 1996, following disposition and evaluation of the three penetrations.

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