ML17333A934

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-315/97-02 & 50-316/97-02 on 970327.Informs That Addl Info Needed to Evaluate Effectiveness of Corrective Actions
ML17333A934
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 07/01/1997
From: Grant G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Fitzpatrick E
AMERICAN ELECTRIC POWER CO., INC.
References
50-315-97-02, 50-315-97-2, 50-316-97-02, 50-316-97-2, NUDOCS 9707100181
Download: ML17333A934 (12)


See also: IR 05000315/1997002

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UNITED STATES

NUCLEAR REGULATORYCOMMISSION

REGION III

801 WARRENVILLEROAD

LISLE. ILLINOIS60532-4351

July 1,

1997

Mr. E. E. Fitzpatrick

Executive Vice President

Nuclear Generation Group

American Electric Power Company

500 Circle Drive

Buchanan,

Ml 49107-1395

SUBJECT:

NRC INSPECTION REPORT NO. 50-315/316-97002(DRP)

AND NOTICE OF

VIOLATION

Dear Mr. Fitzpatrick:

This will acknowledge receipt of your letter dated April 28, 1997, in response to our letter

dated March 27, 1997, transmitting a Notice of Violation and Notice of Deviation.

The

Notice of Violation concerned four violations.

Our letter requested that you address any

broad corrective actions to address

procedural adherence

and procedural adequacy

issues.

We are still reviewing the implementation of your planned or proposed corrective actions;

however, our review has indicated that some of your corrective actions may be too

narrowly focused or appear vague.

For example, in your discussion of the corrective

actions taken to avoid further violations for using "in hand" procedures,

you state:

"Maintenance work activities were essentially halted while expectations for in-hand

procedure

use were communicated to maintenance

department personnel."

This action does not discuss the specifics of the maintenance

department's

expectations.

It also does not address the use of in-hand procedures

by other departments,

and whether

the expectations for the other departments

are consistent with the expectations that now

exist in the maintenance

department.

Also, the corrective actions taken to avoid further violations for the fuel handling

procedure violation state, in part, that:

".... At this time, it is believed that increased management

attention an'd support

for strict and diligent use of these [foreign material exclusion and heavy load lifting)

program controls will be sufficient to avoid further violations."

Similar to the corrective action discussed

above, this action does not clearly state what is

encompassed

by increased management

attention.

Attachment 3 to your letter discusses

the broad corrective actions taken to address

procedural adherence

and procedure adequacy.

In the "Background" section of

Attachment 3, you state that:

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E. Fitzpatrick

-2-

"... there was a concerted effort in 1996 to raise standards

and general plant

awareness

of the critical nature of strict procedural adherence

and adequacy.

Plant

wide "time outs" were held that stressed

the necessity for strict adherence

and

self-checking.

Management expectations

of strict adherence

were clearly

communicated."

In the "Raising the Performance Level" section, you state that:

".... A group-wide "time out" for the entire AEP nuclear generation group (AEPNGG)

will be held in May 1997 to launch this period of high visibility management

focus

on procedure adherence.

Additional "time outs" will be held during this time to

maintain emphasis and review effectiveness."

It appears that the effort conducted in early 1996 was not effective in preventing the

procedural adherence

and adequacy problems identified in the latter half of 1996 and early

1997.

Your response

does not address the specific nature of the corrective actions which

are to take place during the "time outs," nor does it indicate how the "time out" will differ

from the time out conducted in 1996.

The NRC needs this information to assess

the

adequacy of your corrective actions.

In order for the NRC to be able to evaluate the adequacy of your corrective actions, we

request that you provide additional information discussed

above.

This information,

combined with your April 28 response will provide us with the ability to measure the

effectiveness of your corrective actions.

Sincerely,

Geoffrey E. Grant, Director

Division of Reactor Projects

Docket Nos.: 50-315. 50-316

License Nos: DPR-58, DPR-74

CC:

A. A. Blind, Site Vice President

John Sampson,

Plant Manager

James

R. Padgett, Michigan Public

Service Commission

Michigan Department of

Environmental Quality

ill

l

E. Fitzpatrick

-2-

"... there was a concerted effort in 1996 to raise standards

and general plant

awareness

of the critical nature of strict procedural adherence

and adequacy.

Plant

wide "time outs" were held that stressed

the necessity for strict adherence

and

self-checking.

Management expectations of strict adherence

were clearly

communicated."

In the "Raising the Performance Level" section, you state that:

"~ ~ ~ ~ A group-wide "time out" for the entire AEP nuclear generation group (AEPNGG)

will be held in May 1997 to launch this period of high visibility management

focus

on procedure adherence.

Additional "time outs" will be held during this time to

maintain emphasis and review effectiveness."

It appears that the effort conducted in early 1996 was not effective in preventing the

procedural adherence

and adequacy problems identified in the latter half of 1996 and early

1997.

Your response

does not address the specific nature of the corrective actions which

are to take place during the "time outs," nor does it indicate how the "time out" will differ

from the time out conducted in 1996.

The NRC needs this information to assess

the

adequacy of your corrective actions.

In order for the NRC to be able to evaluate the adequacy of your corrective actions, we

request that you provide additional information discussed

above.

This information,

combined with your April 28 response

will provide us with the ability to measure the

effectiveness of your corrective actions.

Sincerely,

Geoffrey E. Grant, Director

Division of Reactor Projects

Docket Nos.: 50-315. 50-316

License Nos: DPR-58, DPR-74

CC:

A. A. Blind, Site Vice President

John Sampson,

Plant Manager

James

R. Padgett, Michigan Public

Service Commission

Michigan Department of

Environmental Quality

~Dis rib

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Docket File

PUBLIC IE-01

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Rill Enf. Coordinator

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JL Caldwell

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Document:

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SEE PREVIOUS CONCURRENCES

To receive a copy of this document, indicate in the box "C" = Copy without attach/encl

"E" = Copy with attach/encl

"N" = No copy

OFFICE

RIII

NAME

Jackiw:nh

DATE

06/ /97

Rill

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06/ /97

Rill

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06/ /97

Rill

Grant

06/ /97

1

OFFICIAL RECORD COPY

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E. E. Fitzpatrick

In order for the NRC to be able to evaluate the effectiveness of your corrective actions, we

request that you provide additional information discussed

above.

This information,

combined with your April 28 response

will provide us with the ability to measure the

adequacy of your corrective actions.

Sincerely,

Docket Nos.: 50-315. 50-316

License Nos: DPR-58, DPR-74

Geoffrey E. Grant, Director

Division of Reactor Projects

CC:

Pu

Docket File

PUBLIC IE-01

OC/LFDCB

SRI D. C. Cook

Rill Enf. Coordinator

A. A. Blind, Site Vice President

John Sampson,

Plant Manager

James

R. Padgett, Michigan Public

Service Commission

Michigan Department of

blic Health

DRP

Rill PRR

D. C. Cook, PM, NRR

A. B. Beach

Deputy RA

Document:

G:<Cook.ir<06057ty.dcc

To receive a copy of this document, indicate in the box "C" = Copy without attach/encl

"E" = Copy with attach/encl

"N" = No copy

OFFICE

DATE

Rill

Ja

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06+/97

Rill

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Rill

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06/

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OFFICIAL RECORD COPY

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UNITED STATES

NUCLEAR REGULATORYCOMMISSION

REGION III

801 WARRENVILLEROAD

LISLE. ILLINOIS60532-4351

July 1,

1997

Mr. E. E. Fitzpatrick

Executive Vice President

Nuclear Generation Group

American Electric Power Company

500 Circle Drive

Buchanan, Ml 49107-1395

SUBJECT:

NRC INSPECTION REPORT NO. 50-315/316-97002(DRP)

AND NOTICE OF

VIOLATION

Dear Mr. Fitzpatrick:

This will acknowledge receipt of your letter dated April 28, 1997, in response to our letter

dated March 27, 1997, transmitting a Notice of Violation and Notice of Deviation.

The

Notice of Violation concerned four violations.

Our letter requested that you address any

broad corrective actions to address procedural adherence

and procedural adequacy

issues.

We are still reviewing the implementation of your planned or proposed corrective actions;

however, our review has indicated that some of your corrective actions may be too

narrowly focused or appear vague.

For example, in your discussion of the corrective

actions taken to avoid further violations for using "in hand" procedures,

you state:

"Maintenance work activities were essentially halted while expectations for in-hand

procedure

use were communicated to maintenance department personnel."

This action does not discuss the specifics of the maintenance department's

expectations.

lt also does not address the use of in-han'd procedures

by other departments,

and whether

the expectations

for the other departments

are consistent with the expectations that now

exist in the maintenance

department.

Also, the corrective actions taken to avoid further violations for the fuel handling

procedure violation state, in part, that:

".... At this time, it is believed that increased management attention and support

for strict and diligent use of these tforeign material exclusion and heavy load lifting)

program controls will be sufficient to avoid further violations."

Similar to the corrective action discussed

above, this action does not clearly state what is

encompassed

by increased management attention.

Attachment 3 to your letter discusses

the broad corrective actions taken to address

procedural adherence

and procedure adequacy.

In the "Background" section of

Attachment 3, you state that:

E. Fitzpatrick

"... there was a concerted effort in 1996 to raise standards

and general plant

awareness

of the critical nature of strict procedural adherence

and adequacy.

Plant

wide "time outs" were held that stressed

the necessity for strict adherence

and

self-checking.

Management expectations of strict adherence

were clearly

communicated."

In the "Raising the Performance Level" section, you state that:

".... A group-wide "time out" for the entire AEP nuclear generation group (AEPNGG)

will be held in May 1997 to launch this period of high visibility management

focus

on procedure adherence.

Additional "time outs" will be held during this time to

maintain emphasis

and review effectiveness."

It appears that the effort conducted in early 1996 was not effective in preventing the

procedural adherence

and adequacy problems identified in the latter half of 1996 and early

1997.

Your response

does not address the specific nature of the corrective actions which

are to take place during the "time outs," nor does it indicate how the "time out" will differ

from the time out conducted

in 1996.

The NRC needs this information to assess

the

adequacy of your corrective actions.

In order for the NRC to be able to evaluate the adequacy of your corrective actions, we

request that you provide additional information discussed

above.

This information,

combined with your April 28 response

will provide us with the ability to measure the

effectiveness of your corrective actions.

Sincerely,

Geoffrey E. Grant, Director

Division of Reactor Projects

Docket Nos.: 50-315. 50-316

License Nos: DPR-58, DPR-74

cc:

A. A. Blind, Site Vice President

John Sampson,

Plant Manager

James

R. Padgett, Michigan Public

Service Commission

Michigan Department of

Environmental Quality

~Dis ribution:

Docket File

PUBLIC IE-01

OC/LFDCB

SRI DC Cook

Rill Enf. Coordinator

TSS

DRP

RIII PRR

DC Cook PM, NRR

AB Beach

JL Caldwell

DRS (2)

n

n

n

~

~

Document:

G:FCook.irh06057ty.dcc

SEE PREVIOUS CONCURRENCES

To receive a copy of this document, indicate in the box "C" = Copy without attach/encl

"E" = Copy with attach/encl

"N" = No copy

OFFICE

RI I I

NAME

Jackiw:nh

DATE

06/ /97

Rill

Burgess

06/ /97

Rill

Gardner

06/ /97

Rill

Grant

06/ /97

OFFICIAL RECORD COPY

E. E. Fitzpatrick

-3-

In order for the NRC to be able to evaluate the effectiveness of your corrective actions, we

reqgest that you provide additional information discussed

above.,

This information,

combined with your April 28 response will provide us with the ability to measure the

adequacy of your corrective actions.

Sincerely,

Geoffrey E. Grant, Director

Division of Reactor Projects

Docket Nos.: 50-315. 50-316

License Nos: DPR-58, DPR-74

CC:

Pub

Docket File

PUBLIC IE-01

OC/LFDCB

SRI D. C. Cook

RIII Enf. Coordinator

A. A. Blind, Site Vice President

John Sampson,

Plant Manager

James

R. Padgett, Michigan Public

Service Commission

Michigan Department of

lic Health

DRP

RIII PRR

D. C. Cook, PM, NRR

A. B. Beach

Deputy RA

Document:

G:>Cook.ir<06057ty.dcc

To receive a copy of this document, indicate in the box "C" = Copy without attach/encl

"E" = Copy with attach/encl

"N" = No copy

OFFICE

Rill

Ja:dp

DATE

06

/97

Rill

B

s

06/ /97

RIII

Gardner

06/ /97

OFFICIAL RECORD COPY

Rill

Grant

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