ML17333A787
| ML17333A787 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 02/20/1997 |
| From: | Fitzpatrick E AMERICAN ELECTRIC POWER CO., INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| AEP:NRC:1238J, NUDOCS 9702280185 | |
| Download: ML17333A787 (14) | |
Text
CATEGORY 1 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
'1 ACCESSION NBR:9702280185 DOC.DATE: 97/02/20 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.
American Electric Power Co., Inc.
RECAP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Forwards response to violations noted in Insp Repts 50-315/96-14
& 50-316/96-14.Corrective actions:safety screening a
SE for DCP 49 revised on 961206,to document potential implicit impact on SAR.
DISTRIBUTION CODE:
IEOID COPIES RECEIVED:LTR I
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SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:
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EXTERNAL:
RECIPIENT ID CODE/NAME PD3-3 PD AEOD/SPD/RAB DEDRO NRR/DISP/PIPB NRR/DRPM/PECB NUDOCS-ABSTRACT OGC/HDS2 LITCO BRYCEiJ H
NRC PDR COPIES LTTR ENCL 1
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1 RECIPIENT ID CODE/NAME HICKMANPJ e
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NRR/DRPM/PERB OE DIR RGN3 FILE 01 NOAC NUDOCS FULLTEXT COPIES LTTR ENCL 1
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1 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 18 ENCL 18
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Indiana Michigan Power Company 500 Circle Drive Buchanan, Ml 49107 1395 INDIANA NICHIGAN POWER February 20, 1997 Docket Nos.
50-315 50-316 AEP'NRC 1238J 10 CFR 2.201 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. 50-315/96014 (DRP)
AND 50-316/96014 (DRP)
REPLY TO NOTICE OF VIOLATION This letter is in response to a letter from J. L. Caldwell, dated January 22, 1997, that forwarded a notice of violation to Indiana Michigan Power Company.
The notice of violation contained one violation of NRC requirements identified during an NRC inspection conducted from October 13 through November 23, 1996.
The violation is associated with the quality of safety screenings and evaluations.
Our reply to the violation is provided in attachment 1 to this letter.
Attachment 2 provides minor corrections to the text in the inspection report and notice of violation.
Sincerely, ee'ice President Notary Public My Commission Expires:
JAN NATSON NOTARYPUBLIC, BERRIEN COUNtY,Ml MYCOMMISSION EXPIRES FEB.10, 1999 jen Attachment cc:
A. A. Blind A. B. Beach MDEQ -
DW & RPD NRC Resident Inspector J.
R. Padgett SWORN TO AND SUBSCRIBED BEFORE ME THIS ~0 DAY OF 1997
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9702280185 970220 PDR ADOCK 050003i5, 8
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ATTACHMENT 1 TO AEP:NRC:1238J REPLY TO NOTICE OF VIOLATION:
NRC INSPECTION REPORT NOS.
50-315/96014 (DRP)
AND 50<<316/96014 (DRP)
Attachment 1 to AEP:NRC:1238J Page 1
During an NRC inspection conducted from October 13 through November 23,
- 1996, one violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions" (60 FR 34381; June 30, 1995),
the violation and our response are listed below.
NRC Violation "10 CFR 50.59, "Changes, tests and experiments,"
section (b)(1),
requires, in part,
'The licensee shall maintain records of changes in the facility...
These records must include a written safety evaluation which provides the bases for the determination that the change... does not represent an unreviewed safety question (USQ).'ontrary to the
- above, the licensee failed to include in the written safety evaluation for Design Change Package 56 an adequate bases for the determination that the change to new models of isolation dampers in the spent fuel pool ventilation system did not represent a USQ.
This is a Severity Level IV violation (Supplement I)."
Res onse to NRC Violation Admission or Denial of the Alle ed Violation Indiana Michigan Power Company admits to the violation as cited in the NRC notice of violation.
2.
Reasons for the Violation Ne believe the notice of violation incorrectly referred to design change package (DCP) 56.
The body of the inspection report correctly refers to DCP 49.
During a review of 12-DCP-49, revision 0, "Spent Fuel Pool (AFX) Filtration System Bypass Damper Replacement,"
the i: ~pectors identified that the safety evaluation was inadequate.
Personnel had performed both a safety screening and a USQ determination as required by procedures.
The UFSAR did not contain specific design and operation information for the dampers, but did discuss the function of charcoal filter bypass.
The documented basis for determining that the damper replacement did not represent a
USQ relied upon the lack of specific design and operation information for the dampers in the UFSAR, and did not adequately discuss the functional and performance characteristics of the original and proposed replacement dampers.
As a result of the insufficient supporting information in the safety evaluation, it was iifficultto determine whether any significant differences in the function or operating characteristics of the original and replacement dampers existed.
The person who performed the safety screening and evaluation was trained to conduct these evaluations under procedure 227400-STG-5400-04, "Safety Reviews."
- However, the safety screening and evaluation did not,~eet the standards described
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Attachment 1 to AEP:NRC:1238J Page 2
in the subject procedure because consideration of implicit changes was not clearly documented.
The screening criteria presented in attachment 1 to 227400-STG-5400-04 states the following:
"A change to the plant as described in the SAR should be interpreted as any change to plant
- systems, structures, components, or site features which is not in accordance with system or component configuration as shown by drawings and text descriptions (explicitly or implicitly referred to) in the SAR.
This includes drawings, illustrations, schematic representations, safety analysis performance assumptions, as well as text descriptions."
The individual completing the evaluations apparently did not fullyunderstand the instructions in the procedure or did not apply sufficient attention to the requirements.
As a result, the individual concluded that the design change did not represent a
change to the plant as'escribed in the SAR because the component was not explicitly mentioned in Sections 9.9.3.2 or 14.2.1.1.
The basis for concluding that the design change did not have an implicit impact on the system operation and component configuration, as described in the
- SAR, was not clearly documented.
Therefore, it can be concluded that the primary reason for the violation involved a
failure to correctly follow instructions provided in the procedure.
In addition, review of the procedure used to conduct the safety screening and evaluation shows the procedure did not clearly stress the importance of documenting c"nsideration of potential implicit impact on the SAR.
- Thus, a contributing factor for the violation may have been inadequate documentation requirements in the procedure.
Corrective Actions Taken and Results Achieved The safety screening and safety evaluation for DCP 49 i.ere revised on December 6,
- 1996, to document the potential implicit impact on the SAR.
In addition, we are currently conducting a re-review of modifications that had not been released for unrestricted operation prior to November 27, 1996.
This is the date when the plant nuclear safety review committee was informed of the concern and the need to improve documentation standards.
This represents an on-going effort that includes outage and non-outage related modifications.
Corrective Actions to Avoid Further Violations Corrective actions to avoid further violations included a
special training session held on December 19, 1996, at the
- Buchanan, Michigan, headquarters.
Nuclear engineering personnel involved in the preparation of safety screenings and evaluations were informed of the need to consider both explicit and implicit impact on the
- SAR, and to clearly document such consideration in the safety screening and evaluation.
In
- addition, a
new safety screening and evaluation procedure is being prepared.
The procedure will further highlight the importance of clearly documenting both
Q 1
II
Attachment 1 to AEP:NRC:1238J Page 3
explicit and implicit impact on the SAR.
The procedure will be completed by May 31, 1997.
The 1997 nuclear engineering initial and requalification training for safety screenings and evaluations held in February was expanded to include specific examples of design changes with implicit impact on the SAR and to illustrate the new procedural requirements and management expectations for documenting implicit impact on the SAR.
The nuclear safety and design review committee subcommittee on proposed changes will conduct a self-assessment of the 50.59 program to determine its effective'ness in eliminating the occurrence of inadequate bases in safety screenings and evaluations.
The assessment will be completed by December 31, 1997.
Date When Full Com liance will be Achieved The safety screening and safety evaluation for DCP 49 were revised on December 6,
- 1996, to document the potential implicit impact on the
- SAR, thereby achieving full compl 'nce.
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ATTACHMENT 2 TO AEP:NRC:1238J'ORRECTIONS TO TEXT OF INSPECTION REPORT AND NOTICE OF VIOLATION
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Attachment 2 to AEP:NRC:1238J Page 1
'L'his attachment contains minor corrections to the text of the inspection report and notice of violation.
Page 14 of the inspection the safety evaluations preventive maintenance, "preventive maintenance" modifications".
report, firs
- bullet, "Reviewing for the minor modifications, We believe the words should be replaced with "plant 2.
Page 14 of the inspection report, second bullet, "Reviewing the safety evaluations for modifications being implemented while on line, prior to the start of the modifications".
Ne believe the words "prior to the start of the modifications" should be replaced with "prior to the release of the modification to operations".
In the notice of violation, third paragraph, we believe the reference to design change package 56 should be changed to design change package 49.