ML17334B514
| ML17334B514 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 07/11/1994 |
| From: | Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | Martin J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| AEP:NRC:1212E, NUDOCS 9407180184 | |
| Download: ML17334B514 (11) | |
Text
A%AMAXL L. L i.
(ACCELERATED RIDS PROCESSING)
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CESSION NBR:9407180184 DOC.DATE: 94/07/11 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 FITZPATRICK,E.
(formerly Indiana
& Michigan Ele RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 940715 ltr re violations noted.in insp rept 50-315/94-12 6 50-316/94-12.Corrective actions:fire watch training lesson plan was revised.
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/DEIB AEOD/DSP/TPAB DEDRO NRR/DRCH/HHFB NUDOCS-ABSTRACT OGC/HDS2 RES/HFB ERNAL EGGG/BRYCE IJ
~ H ~
NSIC COPIES LTTR ENCL 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
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1 RECIPIENT ID CODE/NAME HICKMAN,J AEOD/DSP/ROAB AEOD/TTC
= NRR/DORS/OEAB NRR/PMAS/IRCB-E OE QFILE 02 6
FILE 01 NRC PDR COPIES LTTR ENCL 1
1 1,
1 1
1 1
1 1
1 1
1 1
1 1
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1 NOTE TO ALL RIDS'ECIPIENTS:
PLEASE HELP US TO REDUCE iVASTE!CONTACTTHE DOCUMENTCONTROL DESK, ROOM Pl-37 (EXT. 504-2083 ) TO ELIMINATEYOUR NAMEFROM DISTRIBUTIONLISTS FOR DOCUMEiVTSYOU DON'T NEEDl TOTAL NUMBER OF COPIES REQUIRED:
LTTR 19 ENCL 19
Infiana Michigan Power Company P.O, Box 16631 Columbus, OH 43216 t&;"O'M,KA h"if CYESAA'QVZEP.
AEP:NRC:1212E 10 CFR 2.201 Donald C.
Cook Nuclear Plant Units 1 and 2
Docket Nos.
50-315 and 50-316 License Nos.
NRC INSPECTION REPORTS NO. 50-315/94012 (DRS)
AND 50-316/94012 (DRS)
REPLY TO NOTICE OF VIOLATION U.
S. Nuclear Regulatory Commission Document Control Desk Washington, D.
C.
20555 Attn:
Mr. J.
B. Hartin July ll, 1994
Dear Mr. Martin:
This letter is in response to a USNRC letter dated June 15,
- 1994, that forwarded a notice of violation to Indiana Michigan Power Company.
The notice of violation contained one violation identified during an inspection conducted by Mr. D. Schrum from June 1 through June 8,
1994.
The violation is associated with the failure to remove or cover combustible materials within 35 feet of welding, brazing, cutting, and grinding activities.
Our reply to the notice of violation is provided in, the attachment to this letter.
This letter is submitted pursuant to 10 CFR 50.54(f)
- and, as
- such, an oath statement is attached.
Sincerely, E.
E. Fitz atrick Vice President dr Attachments 9407180184 940711 PDR ADOCK 05000315 9
Mr. W. T. Russell AEP:NRC:1212E CC:
A. A. Blind G. Charnoff W. T. Russell, NRC
- Washington, D.C.
NRC Resident Inspector NFEM Section Chief J.
R. Padgett
STATE OF OHIO)
COUNTY OF FRANKLIN)
E. E. Fitzpatrick, being duly sworn, deposes and says that he is the Vice President of licensee Indiana Michigan Power
- Company, that he has read the forgoing response to NRC INSPECTION REPORTS NO. 50-315/94012 (DRS) AND 50-316/94012 (DRS), REPLY TO NOTICE OF VIOLATION and knows the contents thereof; and that said contents are true to the best of his knowledge and belief.
Subscribed and sworn to before me this ~l/
day of
, 19~
NOTARY UBLIC
-" AITA D. HILL
~ NOTARY PUGUC. STATE OF OlllO
ATTACHMENT TO AEP:NRC:1212E REPLY TO NOTICE OF VIOLATION
ATTACHMENT TO AEP:NRC:1212E Page
1 Background
An inspection was conducted by Mr. D. Schrum from June 1
through June 8,
1994.
The inspection consisted of plant area observations and reviews of fire protection surveillances, maintenance on fire protection equipment, fire brigade training and drills, fire reports, deviation
- reports, work requests, safety evaluations, and audits of fire protection activities.
During this inspection, one item was found to be in violation.
The violation was identified as the failure to remove or cover combustible materials within 35 feet of welding,
- brazing, cutting, and grinding activities.
This violation was set forth in a letter violation, dated June 15,
- 1994, from Mr. W. D.
and Outage
- Section, USNRC, Region III.
June 20, 1994.
Our response to the notice within this document.
containing the notice of
- Shafer, Chief, Maintenance The letter was received
'f violation is contained NRC Violation "Technical Specification 6.8.l.a requires adherence to fire protection implementing procedures.
Cook Nuclear Plant Manager's Instruction, PMI-2270, "Fire Protection," Revision 22, requires that a work area be cleared of all combustible materials below or within 35 feet of work or a non-flammable material be provided to cover or shield adjacent or lower equipment.
Contrary to the above:
On June 3, 1994, the inspector observed grinding, welding, and cutting activities in the turbine building that did not have combustibles removed or covered within 35 feet of these activities (50-315/316/94012-01(DRS)).
This is a Severity Level IV violation (Supplement I)."
Response
to Violation 1.
Admission or Denial of the Alle ed Violation Indiana Michigan Power Company admits to the violation as cited in the NRC notice of violation.
ATTACHMENT TO AEP:NRC:1212E Page 2
2.
Reasons for the Violatio Welding, burning, and grinding (WBG) permits are issued by fire technicians prior to the commencement of such activities.
In most of the recently issued WBG permits, requirements had not been specified for ensuring that the 35-foot radius area around each activity is clear of combustible materials or that all combustible materials in the area are covered.
Also, fire technicians and fire watch personnel had become lax in their enforcement of the 35-foot radius area.
3.
Corrective Actions Taken and Results Achieved Immediately after being notified by the NRC inspector on June 3 of the deviations with regard to the 35-foot radius area, the on-duty fire brigade personnel were dispatched to have each of the areas under active WBG permits cleaned up to conform to the 35-foot radius area requirements before any further work could be performed in these areas.
4.
Corrective Actions Take to Avoid Further Violatio s The requirement to remove or cover all combustibles within a 35-foot radius area of the work area is now being specified on all WBG permits.
Signs were posted by all WBG permits that were active as of June 3
that remind all workers of the requirements for the removal or covering of combustible materials.
Identical signs were also attached to the clipboards that belong to each fire watch.
An electronic mail message was sent by the fire protection supervisor to the superintendents of the site nuclear
- services, maintenance, and plant protection departments, the fire protection coordinators, and the fire technicians.
This electronic mail message was subsequently followed by a formal memorandum which was issued on June 9.
Both of these transmittals outlined what was found by the NRC inspector and what would be the expectations for WBG permit activities with regard to combustibles.
As part of their pre-shift briefings that occurred on or soon after June 3, all fire technicians reviewed the WBG requirements, which included the requirement to ensure that all combustibles within a 35-foot radius area be removed or covered.
On a similar schedule, all fire watch personnel were reminded of their responsibility to review the special requirements on WBG permits, their responsibility to notify their supervisor when WBG
ATTACHMENT TO AEP:NRC:1212E Page 3
permit requirements and conditions are not being
- met, and their authority to stop any job not being conducted in accordance with the special instructions of a WBG permit.
For future work involving WBG permits, this information is now being covered during all routine pre-job briefings.
On June 15, the fire watch training lesson plan was revised.
'As part of this revision, the old lesson plan was separated into six new lesson plans.
Two of these
- plans, "Fire Watch Duties and Responsibilities",
FW-C-9003, and "Fire Watch On-the-Job Training",
FW-L-9006, include, emphasis on the fire watch duties and responsibilities for WBG activities that was absent from the previous lesson plan.
5.
ate When Full Com liance Will Be Achieved Full compliance was achieved on June 3, 1994, with the clean up of the active WBG permit areas which brought all of these areas into compliance with the 35-foot radius area requirement for the removal or covering of combustible materials.