ML17334B635

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Notice of Violation from Insp on 970210-0314.Violation Noted:Two Procedures Involving Complex Jobs Where Reliance on Memory Cannot Be Trusted & Sequences Cannot Be Altered Were Not Designated as In-Hand Procedures
ML17334B635
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 05/30/1997
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17334B634 List:
References
50-315-97-03, 50-315-97-3, 50-316-97-03, 50-316-97-3, NUDOCS 9706060025
Download: ML17334B635 (4)


Text

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NOTICE OF VIOLATION ~

Indiana Michigan Power Company Donald C. Cook Nuclear Power Plant Docket Nos. 50-315; 50-316 Licenses No. DPR-58; DPR-74 During an NRC inspection conducted from February 10 to March 14, 1997, two violations of NRC requirements were identified.

In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

Technical Specification Section'6.8.1 requires that written procedures shall be established, implemented and maintained covering the activities referenced in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978.

The licensee utilizes Plant Manager'Instructions (PMI) to implement the Technical Specification requirements.

PMI 2011, "Procedure Use and Adherence," Section 3.1.1 designates that "In-Hand" procedures are indicated by a """"in the procedure number.

The facility's Quality Assurance Program document dated July 1995, Section 1.7.5.2.5 states, in part, "Examples of "In-Hand" procedures are those developed for extensive or complex jobs where reliance on memory cannot be trusted.

Further, those procedures which describe a sequence which cannot be altered, or require the documentation of data during the course of the procedure,'are considered."

Contrary to the above, the inspectors identified that two procedures involving complex jobs where reliance on memory cannot be trusted and the sequences cannot be altered were not designated as "In-Hand" procedures with the """":

12 OHP 4021.018.002, "Placing In Service and Operating the Spent Fuel Pit Cooling and Cleanup System," Revision 11, dated August 12, 1996, and 12 OHP 4021.018.013, "Filling, Emptying and Refilling Fuel Transfer Canal," Revision 7, dated January 7, 1997.

This is a Severity Level IVviolation (Supplement I).

2.

10 CFR 50.54(k), "Conditions of licenses" states "An operator or senior operator licensed pursuant to Part 55 of this chapter shall be present at the controls at all times during the operation of the facility." 10 CFR 55.59(a)(2) "Requalification requirements" states "Each licensee (individual licensed operator or senior operator) shall pass a comprehensive requalification written and an annual operating test."

Contrary to the above, the inspectors identified that during the 1996/1997 two year requalification cycle, the facility licensee failed to conduct a comprehensive requalification annual operating test for all licensed operators.

This is a Severity Level IVviolation (Supplement I).

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Notice of Violation

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~ 12 OHP 4021.018.013, "Filling, Emptying and Refilling Fuel Transfer Canal,"

Revision 7, dated January 7, 1997.

For example Data Sheet No.

1 which implements filling of the fuel transfer canal from the middle CVCS HUT contains instructions in section 4.1 that involves valve lineups on Lineup Sheet No.

1 (which contains 11 valves) be performed prior to doing equipment lineups involving the nitrogen system, and the starting and stopping of CVCS HUT recirculation pump.

Similar circumstances are contained in Data Sheets No. 2, 3, 4, and 5.

This is a Severity Level IVviolation (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, ATTN: 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 date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a ",Reply 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 iri 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 ~m 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 30th day of May 1997

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