ML17333A836

Notice of Violation from Insp on 970105-0215.Violation Noted:Inspectors Identified That on 970128,licensee Personnel Performed New Fuel Unloading Work for Unit 1 W/O Using Listed Procedure

ML17333A836
Person / Time
Site:	Cook
Issue date:	03/27/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17333A835	List: ML17333A834 ML17333A836 ML17333A837
References
50-315-97-02, 50-315-97-2, 50-316-97-02, 50-316-97-2, NUDOCS 9704040119
Download: ML17333A836 (6)

Text

N Tl E

F Vl LATI N Indiana Michigan Power Company Donald C. Cook Nuclear Power Plant Docket No. 50-315; 50-316 License No. DPR-58; DPR-74 During an NRC inspection conducted from January 5, 1997 to February 15, 1997, seven violations of NRC requirements were identified.

In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-'I 600, the violations are listed below:

1.

D. C. Cook Plant Technical Specification 6.8.1 stated, in part, that written

'rocedures shall be established, implemented and maintained covering the applicable procedures recommended in Appendix "A" of Regulatory Guide (RG) 1.33, Rev 2, February 1978.

Regulatory Guide 1.33, Appendix A, paragraph 1.d, required that a procedure be written to establish the controls for procedure adherence.

Plant Manager' Instruction (PMI) 2011, "Procedure Use and Adherence," was written in accordance with RG 1.33.

a)

PMI-2011 Section 3.1.1 that established in-hand procedure requirements (indicated by a """"in the procedure number), stated that technical documents which were intended to be used by qualified individuals during the performance of an activity were required to be designated "in-hand."

In-

. hand procedures were required to be at the job-site.

Contrary to the above, i)

The inspectors identified that on January 28, 1997, licensee personnel performed new fuel unloading work for unit 1 without using procedure ""12MHP4050.FDF.001, "Receipt and Storage of New Fuel Assembly Shipping Containers," in-hand.

The inspectors identified that on January 28, 1997, licensee personnel performed new fuel unloading work for unit 1 without using procedure ""12MHP4050.FDF.002, "Unloading of New Fuel Assemblies from Shipping Containers," in-hand.

This is a Severity Level IVviolation.

b)

PMI-2011, Section 3.1.1 required, in part, that in-hand procedures (indicated by a """"in the procedure number) shall be performed as follows: read the step, perform the step, document completion of the step, and proceed to the next step.

9704040119 970327

'DR ADOCK 05000315 8

PDR

Notice of Violation Contrary to the above, the inspectors identified that written procedures were not adequately implemented in that on January 25, 1997, licensee personnel performed

""12MHP4050.FDF.005, "Handling of New Fuel Assemblies for Inspections and Associated Work," for twelve fuel assemblies without replacing the. floor plug in the new fuel storage vault after seating each fuel assembly as required by the procedure.

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

2.

D. C. Cook Plant Technical Specification 6.8.1 stated, in part, that written procedures shall be established, implemented and maintained covering the applicable procedures recommended in Appendix "A" of Regulatory Guide (RG) 1.33, Rev 2, February 1978.

RG 1.33, Appendix A, paragraph 9.e, required that procedures be written to control maintenance, repair, replacement and modification work.

Maintenance Head Instruction (MHI) 4053, "Control of Heavy Loads," was written in accordance with RG 1.33.

Section 3.6, "Lifting Devices (Slings)," step 3.6.2 required, in part, that the guidelines set forth in ANSI B30.9-1971, "Slings," be followed.

ANSI B30.9-1971, "Slings," Section 9-1.9, "Safe Operating Practices," step 9-1.9.1b required that the sling shall have suitable characteristics and rated capacity for the load and environment.

Contrary to the above, the inspectors identified that written procedures were not adequately implemented in that on February 3, 1997, licensee personnel lifted a load of new fuel assemblies weighing approximately 6,325 pounds using a lifting sling that was not rated for the load.

This lifting sling was rated for 6,000 pounds and was previously used at least 12 times between January 25, 1997, and February 3, 1997, for identical lifts..

This is a Severity Level IV violation (Supplement I) ~

3.

D. C. Cook Plant Technical Specification 6.8.1 stated, in part, that written procedures shall be established, implemented and maintained covering the applicable procedures recommended in Appendix "A" of Regulatory Guide (RG) 1.33, Rev 2, February 1978.

RG 1.33, Appendix A, paragraph 9.e, required that procedures be written to control maintenance, repair, replacement and modification work.

Notice of Violation a.

Plant Manager's Instruction (PMI) 2220, "Foreign Material Exclusion," was written in accordance with RG 1.33.

Section 6.0, "Responsibilities," step 6.2, stated, "Line supervision is responsible for monitoring work and ensuring FME [Foreign Material Exclusion] controls are adequate and being implemented."

Contrary to the above, on January 28, 1997, NRC inspectors identified that procedures were not adequately implemented in that foreign material was found on the ledge of the open new fuel storage vault. The mechanical maintenance supervisor assigned to new fuel receipt did not monitor the work, and failed to ensure that adequate FME controls were being implemented.

This is a Severity Level IV violation. (Supplement 1).

b)

Plant Manager's Instruction (PMI) 2220, "Foreign I'Jlaterial Exclusion," was written in accordance with RG 1.33.

Plant Manager's Procedure (PMP) 12 PMP 2220.001.001 was writ;~n tc implement PMI 2220.

Step 5.2.5 required, "[W]hileworking within the FMEZ [Foreign Material Exclusion Zone], 'Clean-As-You-Go'ork practice shall be maintained to minimize the potential for introduction of foreign roaterials into any equipment or system."

Contrary to the above, on January 28, 1997, NRC inspectors identified that procedures were not adequately implemented in that foreign material was found on the ledge of the open new fuel storage vault (NFSV). The work crew did not clean the ledge of the NFSV after removing the shield plug, which created the potential for the introduction of foreign materials into the NFSV.

This is a Severity Level IV violation. (Supplement 1).

c)

Plant Manager's Instruction (PMI) 2220, "Foreign Material Exclusion," was written in accordance with RG 1.33.

Plant Manager's Procedure (PMP) 12 PMP 2220.001.001 was written to implement PMI 2220.

Step 5.1.3 required, "Ifevaluation (performed in step 5.1.1 of the procedure) results in an FMEZ [Foreign Material Exclusion Zone] designation of FMEZ-1 or FMEZ-2, then the work group supervisor shall complete a Foreign Material Exclusion Requirement/Work Practices Determination, Attachment 2, to determine appropriate FME requirements, work practices, and post-job inspections."

Step 5.1A required, "A copy of the completed Attachment 2 should be included in the work package and should be used in the pre-job brief."

Contrary to the above, Attachment 2 to 12 PMP 2220.001.001 was not completed for work performed in an FMEZ on January 28, 1997, was not included in the work package and was not used in the pre-job brief.

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

Notice of Violation 4.

10 CFR 50, Appendix B, Criterion V, stated that activities affecting quality shall be prescribed by documented procedures of a type appropriate to the circumstances.

Contrary to the above, fuel handling procedures

""12MHP4050.FDF.001, "Receipt and Storage of New Fuel Shipping Containers," ""12MHP4050.FDF.002, "Unloading of New Fuel Assemblies From Shipping Containers,"

""12MHP4050.FDF.005, "Handling of New Fuel Assemblies for Inspections and Associated Work," were inadequate in that the procedures had errors in work step sequencing; the procedures lacked foreign material exclusion practices; and the procedures contained no detail on rigging requirements and control of heavy loads requirements.

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

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, AT i N: 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 oate of the letter transmitting this Notice of Violation!Notice). This reply should be clearly marked as a ".". ply to a Notice of Violation" and should include for each violation:

(1) the reason for the violation, or, if contested, the basis 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 previously 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 as to 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.

Because 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 PDR without redaction.

If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you ~mu specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable

response, please provide the level of protection described in 10 CFR 73.21.

Dated at Lisle, Illinois this 27th day of March 1997