ML17334B412
| ML17334B412 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 02/27/1992 |
| From: | Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | Davis A NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| AEP:NRC:1148F, NUDOCS 9203020140 | |
| Download: ML17334B412 (11) | |
Text
ACCELERATED DI UTION DEMONS TION SYSTEM REGULATO INFORMATION DISTRIBUTION STEM (RIDS)
ACCESSION NBR:9203020140 DOC'.DATE: 92/02/27 NOTARIZED: NO 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 UTH.NAME AUTHOR AFFILIATION-ITZPATRICK,E.
Indiana Michigan Power Co. (formerly Indiana
& Michigan Ele RECIP.NAME 'ECIPIENT AFFILIATION DAVIS,A.B.
Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 920128 ltr re v'iolations noted in Insp Repts 50-315/91-27
& 50-316/91-27 on 911127-920114.Corrective actions:mandatory classroom training
& QA audits of safety review process conducted.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:
RECIPIENT ID CODE/NAME PD3-1 PD INTERNAL: AEOD AEOD/DSP/TPAB NRR HARBUCK,C.
NRR/DLPQ/LHFBPT NRR/DOEA/OEAB NRR/DST/DIR 8E2 NUDOCS-ABSTRACT OGC/HDS2 RGN3 FILE 01 EXTERNAL: EG&G/BRYCEiJ.H.
NSIC COPIES
,. LTTR ENCL 1
1 1
1 1
1 1
1 1
1
= 1 RECIPIENT ID CODE/NAME STANGiJ AEOD/DEIIB DEDRO NRR MORISSEAU,D NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NRR/PMAS/ILRB1 2 OE DIR RX~ILE 0 2 NRC PDR COPIES LTTR ENCL 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 NOTE TO ALL"RIDS" RECIPIENTS PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAMEFROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 22 ENCL 22
Indiana Michigan Power Company P,O. Box 1663l Coiumbus, OH 43216 INDIANA NICHI6lLN POWER AEP: NRC: 1148F Donald C.
Cook Nuclear Plant Units 1 and 2
Docket Nos, 50-315 and 50-316 License Nos.
DPR-58 and DPR-74 NRC INSPECTION REPORT NOS
~ 50-315/91027 (DRP)
AND 50-316/91027 (DRP);
RESPONSE
TO NOTICE OF VIOLATION U.S. Nuclear Regulatory Commission Attn:.Document Control Desk Washington, D AC. 20555 Attn: A.
BE Davis February 27, 1992
Dear Mr. Davis:
This letter is in response to.Mr.
W.
D. Shafer's letter dated January 28, 1992, which forwarded the report on the routine safety inspection conducted by members of your staff from November 27, 1991 through January 14, 1992, of activities at Cook Nuclear Plant Units 1 and 2.
The Notice of Violation attached to Mr. Shafer's letter identified one Severity Level IV violation associated with failure to perform evaluations to specifically determine that no unreviewed safety question would result from modifications made to the facility.
Our response to the Notice of Violation is provided in the attachment to this letter.
This document has been prepared following Corporate procedures that incorporate a
reasonable set of controls to ensure its accuracy and completeness prior to signature by the undersigned.
Sincerely, ED ED Fitzpatrick Vice President dag Attachment 9203020140 920227 PDR ADOCK 05000315 G
'PDR
A. B. Davis AEP: NRC: 1148F cc:
D. H. Williams, Jr.
A. A. Blind - Bridgman J.
R. Padgett G. Charnoff NRC Resident Inspector
- Bridgman NFEM Section Chief
Attachment to AEP:NRC:1148F
RESPONSE
Attachment to AEP:NRC:1148F Page 1
NRC Violation:
"10 CFR 50.59 requires the licensee to maintain records of changes in the facility and procedures made pursuant to this section -to the extent that these changes constitute changes in the facility as described in the Final Safety Analysis Report (FSAR).
These records must include a-written safety evaluation which provides the basis for the determination that the change does not involve an unreviewed safety question.
"Contrary to the above, the following examples of changes to the
- facility, as described in the
- FSAR, were implemented without verifying through written safety, evaluations that no unreviewed safety questions were involved:
RFC-2900 Added reactor coolant system wide-range temperature recorders to safety-related power circuits.
RFC-3053 Installed two new Reactor Coolant System wide-range pressure indicators, RFC-3071 Increased the sensitivity of the power-range nuclear instrumentation by installing two potentiometers and one resistor to the circuits.
MM-019 Removed internal parts from emergency diesel generator air start check valves.
MM-095 Modified the reactor trip and bypass breaker cabinets by installing volt-meters 'n order to identify possible failure of the P-4 contacts'he P-4 contacts actuate a turbine trip, upon a reactor trip.
MM-176 Modified the
'sneak circuit'n the motor driven auxiliary feedwater pump circuitry, which.was causing the pump to load onto the diesel generator out of sequence.
"This is a Severity Level IV violation (Supplement I)."
Attachment to AEP:NRC:1148F Page 2
Res onse to the Notice of Violation The response to the above Notice of Violation requires a brief description of the AEP Service Corporation (AEPSC) design change safety review process.
In general terms, the design change safety review process conducted by AEPSC is made up of technical and regulatory elements.
The technical review examines some twenty-three areas including seismic, 10CFR50 Appendix R, mechanical and electrical independence, redundancy and diversity,
- flooding, control room habitability, etc.
This review ensures that the proposed change is safe and does not compromise the plant's design basis.
The regulatory element, on the other hand, is designed to satisfy 10CFR50.59 requirements by addressing the need for prior NRC review and approval of proposed design changes.
Since the regulatory element is the sub]ect" of this violation, it is explained in more detail below.
The regulatory review is conducted per AEPSC procedures in accordance with the NSAC-125, "Guidelines for 10CFR50.59 Safety Evaluations."
Specifically, the safety reviewer assigned to review the proposed design change first examines the need for technical specification changes and then, ifappropriate, performs a
10CFR50.59(a)(l) screen to determine if the proposed change constitutes a
"change to the plant as described in the Safety Analysis Report."
10CFR50.59 and NSAC-125 allow us to examine the potential for changes to the UFSAR, reach a conclusion in that
- regard, and then apply that conclusion to answer the 10CFR50.59(a)(1) screening questions.
Discussions in December 1991 with both NUHARC and one of the principle authors of NSAC-125 confirmed that our existing procedure is consistent with NSAC-125.
An unreviewed safety question determination is performed to satisfy 10CFR50.59(a)(2) only when no technical specification changes are required and when the proposed change actually would result in an explicit or implicit change to the UFSAR.
Our training and procedures ensure that the safety reviewer performs the 10CFR50.59(a)(1) screen by considering both explicit and implicit effects on the UFSAR.
Explicit changes would result when the UFSAR description of the component/structure to be modified is clearly affected by the proposed change.
Implicit changes would result when no UFSAR description of the sub]ect component or structure exists or the description is not directly affected by the proposed
- change, but
,other descriptions in the UFSAR are affected.
Using the above criteria and procedures, re-screening per 10CFR50.59(a)(1) of the six modifications identified by the NRC determined that five of the six had been screened correctly, It was concluded that, with the exception of HM-019 regarding which
Attachment to AEP:NRC:1148F Page 3
there was an oversight by the safety reviewer that the UFSAR was
- affected, safety reviews had been conducted in full compliance with 10CFR50.59, NSAC-125, and our internal procedures.
Based on the above conclusion, the failure to perform an unreviewed safety question determination for MM-019 was due to human error and not to a deficiency in our safety review screening process.
Corrective Actions Taken and Results Achieved The six modifications identified by the NRC were re-reviewed and the results were documented in a safety review memorandum.
Review of these modifications confirmed that an unreviewed safety question does not exist as a result of these design changes.
The documentation supporting these conclusions'ill be added to the respective design change packages.
Corrective Action Taken to Avoid Future Violations With respect to the violation, two specific actions are being taken.
The fizst involves training and the second involves auditing by an independent organisation.
In the area of training, the 10CFR50.59 training at AEPSC has previously consisted of'annual classroom training which could be substituted by completing a reading assignment.
As a result of the Notice of Violation, 10CFR50.59 training at AEPSC will now consist of mandatory annual classroom training that will include a written examination.
Second, prior to the NRC inspection, an audit of the safety review process had been scheduled for the second quarter of 1992.
The
- audit, to be conducted by the Quality Assurance Division, will include a general review of the safety review process and an increased focus on the 10CFR50.59(a)(1) screening performed in safety reviews.
Depending on the results'f this
- audit, additional audits will be scheduled as necessary.
The above actions, mandatory classroom training and QA audits of the safety review process, willminimize the potential for similar future violations.
In addition, sampling of safety reviews for design changes that were appzoved prior to the incorporation of NSAC-125 and that have not yet been 'installed will be conducted.
The purpose of this review is to ensure that the conclusions in those safety reviews are consistent with the conclusions that would be reached using our present review process.
Attachment to AEP:NRC:1148F Date %hen Full Com lienee will be chieved Page 4
Full compliance was achieved on February 26,
- 1992, when th' unreviewed safety question determinations were completed for the six subject modifications.
A. B. Davis AEP: NRC: 1148F bc:
S. J.
Brewer D. H. Malin/K. J. Toth/J.
M. Girgis P. A. Barrett-M. L. Horvath - Bridgman - w/o J.
B. Kingseed J.
B.- Shinnock - w/o W.
G. Smith, Jr.
J.
F. Stang, NRC - Washington, D.C.
DC-N-6015.1 AEP:NRC:1148F