ML17334B585

Provides Supplemental Info Re Response to Violations Noted in Insp Repts 50-315/95-12 & 50-316/95-12.Corrective Actions:New Foreign Matl Exclusion Program Established

ML17334B585
Person / Time
Site:	Cook
Issue date:	04/08/1996
From:	Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AEP:NRC:1224E1, NUDOCS 9604150155
Download: ML17334B585 (11)

Text

CATEGORY 1 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9604150155 DOC.DATE:

~ 96/04/08 NOTARIZED: YES DOCKET ACIL:50-3l5 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. ~ Indiana Michigan Power Co. (formerly Indiana ~ & Michigan Ele

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RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Provides supplemental info re response to violations noted in insp repts 50-315/95-12 a foreign matl exclusion program established.

50-316/95-12.Corrective'ctions:new DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD3-1 PD 1 1 HICKMAN,J 1 1 INTERNAL: AEOD/SPD/RAB 1 1 1 1 DEDRO 1 1 F E CENTER 1 1 NRR/DISP/PIPB NRR/DRPM/PECB 1 1 R~ FB 1 1 1 1 NRR/DRPM/PERB 1 1 NUDOCS-ABSTRACT 1 1 OE DIR 1 1 OGC/HDS2 1 1 RGN3 FILE 01 1 1 ERNAL: LITCO BRYCE,J H 1 1 NOAC 1 1 NRC PDR 1 1 D 0

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NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESKi 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 17 ENCL . 17

i indiana %chigan Power Company P.O. Box 16631 Mumbeo, OH 43216 INDlANA NICHl64N POWER April 8; AEP:NRC:1224El 1996'ocket Nos.: 50-315 50-316 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. 50-315/95012 (DRP)

AND 50-316/95012 (DRP)

REPLY TO NOTICE OF VIOLATIONS:

SUPPU2KNTAL INFORMATION Our letter AEP:NRC:1224E, dated January 29, 1996, provided our response to a letter from W. J. Kropp dated December 28, 1995, that forwarded a notice of violation to Indiana Michigan Power Company.

The violation was associated with debris inside 'the unit 1 containment building. Subsequently, our Senior Resident Inspector requested that we provide additional information on actions we are taking in regard to foreign material exclusion. The information is provided in the attachment to this letter.

E. E. Fitzpatrick Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS~ DAY OF 1996 Notary Public eh 15001~

9604150i55 960408 PDR ADQCK 050003f5 8 PDR

U. S. Nuclear Regulatory Commission AEP:NRC:1224E1 Page 2 Attachment cc: A. A. Blind G. Charnoff H. J. Miller NFEM Section Chief NRC Resident Inspector - Bridgman J. R. Padgett

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ATTAAQ6?NT TO AEP:NRC:122481 FOREIGN MATERIAL EXCLUSION (FHE) PROGRAM

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'>~a~ cued This letter provides additional information regarding our response to a letter from W. J. Kropp dated December 28, 1995, that forwarded a notice of violation to Indiana Michigan Power Company.

The violation was identified during a routine safety inspecCion tour conducted by Messrs. Bartlett, Hartland, Orsini, Dunlop, Winter, and Belanger from October 12, 1995, through December 4, 1995. The violation was associated with debris inside upper conCainment.

On October 16, 1995, during a tour of the unit 1 upper containment, the inspectors identified trash and debris in general areas. The inspection was performed after the containment closeout was completed. The inspectors determined that our corrective actions for a similar condition in 1994 did not prevent a recurrence.

The violation was specific to a procedural violation, i.eep our failure to comply with the requirement of procedure OHP 4030.001.001, "Containment Inspection Tour," to remove all trash and loose debris from all areas of upper containment and the ice condenser. Correspondingly, our response to the violation addressed oux failure Co comply with. the procedural requirements.

On March 29, 1996, our Senior Resident Inspector requested that we provide additional information regarding improvements made to our overall foreign material exclusion (FME) program. These improvements were made as a resulC of our review of the above noted inspector concerns and INPO SOER 95-1, "Reducing Events Resulting From Foreign Matexial Intrusion." The 'improvements have not been fully implemented as we are in a transition from our old process Co the new process.

ctions Take Following the issuance of INPO SOER 95-1 and the notice of violation, a team was established to review the information and develop corrective actions. The result was the development of a BK program that is comprehensive and minimizes procedural 'ew complexity. The new BK program was made effective March 27, 1996, with full implementation required within 45 days. ImplemenCation of the program is thxough Plant Manager Instruction (PMI) 2220, "Foreign Material Exclusion," and Plant Manager Procedure (PMP)"":-/

2220.001. 001, "Foreign Material Exclusion." Ma] or changes made"'.=.i;~y-'-":" -: i.'-"., -'."i with the new BK prodrem:include the definition od pHE zones"..et'nK(@jgi'".':i"::i"."-"'

institution of a front end approach, i,ee p enhanced planning,':.4/~-',,-".

verses the inspeorion/retrievel method previous employed. 'img.",":.i"'

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'ATTACHMENT"TO AEP:MG: 122481 The objecCives of the PMX are to: 1) provide direction to ensure thaC plant systems and components are maintained to an appropriaCe degree of cleanliness during the performance of any activity which exposes the internals of a system or component; and 2) to ensure that each system and component is capable of safe and efficienC operation after work activities are complete. This program applies to all plant systems and components.

The objectives of Che supporting PMP are Co: 1) establish guidance for performing general work, inspections, and other activities in a manner which could reduce or eliminate the introduction of foreign material into a system or equipment.; 2) esCablish guidance for retrieving any foreign material that may have entered a system or component; 3) establish the spent fuel pool (SFP), transfer canal, and refueling cavity as well as the surrounding and overlying spaces as FME,zones, and establish a procedure for conducting work activities or inspections near or around the SFP, transfer canal, or refueling cavity; and 4) establish the minimum requirements for conducting a post-job inspection upon completion of any job activity performed within an BK zone.

Also contained in the PMP is special consideration for containment.

It is made clear in the PMP that containmenC is considered,to be a system.

Actions taken to facilitate transition 'from the old standard to the new include Che following.

An FME training video has been issued and reviewed by appropriate personnel. The BK training tape provides management expectations and increases employee awareness of the new FME program.

The BK training Cape has been incorporated into the General Employee Training (GET) and associated GET requalification programs.

c, Visual aids have been posted throughout Che plant to increase personnel FME awareness.

d. A meeting was held with contractor supervisors prior to the unit 2 refueling outage in which the subject of FME throughout the planC was discussed. Emphasis was placed on our previous pooi containment cle'anlines's performance and the fact that containment is a system.

e~ Meetings were held with first line supervisors Co review the intenC and expecCations of the new BK program.

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Periodic management FHE tours throughout the plant were established to provide oversight during the unit 2 refueling outage to facilitate transition to the new BK program standard.

Since Che unit 2 refueling outage is occurring during the transition period, a containment cleanup proj ect plan, U2R96 Project Plan Number 11, was developed Co aid in meeting the new standard on containment close-out. ParC of the projecC plan includes radiation protection department personnel conducting regular and routine decontamination and cleaning tours in the containment building to enhance the day to day appearance of containment and to reduce the amount of cleaning to be done at the end of the outage.

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