ML18219D099
| ML18219D099 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 08/16/1978 |
| From: | Tillinghast J Indiana Michigan Power Co, (Formerly Indiana & Michigan Power Co) |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| AEP:NRC:00067 | |
| Download: ML18219D099 (8) | |
Text
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REGULATORY INFORMATION DISTRIBUTION SYSTEM <BIDS)
DISTRIBUTION FOR INCOMING MATERIAL 50-315 16 EC:
-DENTON H R ORG:
TILL INGHAST J DOCDATE: 08/16/78 NRC IN Cc MI PWR DATE RCVD: 08/21/78 OCTYPE:
LETTER NOTARIZED:
YES COPIES RECEIVED UBJECT:
LTR 1
ENCL 0 URNISHING INFO CONCERNING DIFFERENCE IN CONFIGURATION OF SILICONE FOAM FIRE HEALS BETWEEN UNIT 1
Cc 2i AND THE ASTM E119 TEST CONDUCTED ON 31/12/78... NOTARZIED 08/16/78.
LANT NAME: COOK UNIT COOK UNIT 2 REVIEWER INITIAL:
XJM DISTRIBUTER INITIAL:
DISTRIBUTION OF, THIS MATERIAL IS AS FOLLOWS 4+++++<+++++++++<+
NOTES:
I 5 E 3 CYS ALL MATERIAL FIRE PROTECTION INFORMATION (AFTER ISSUANCE OF
<DISTRIBUTION CODE A006)
OL).
FOR ACTION:
INTERNAL:
EXTERNAL:
BR EF ORB01 BC++LTR ONLY(4)
REG FILE LTR ONLY<i)
R ONLY(2)
AUXILIARYSYS BR4+LTR ONLY(2)
PLANT SYSTEMS BR>+LTR ONLY(5)
R.
MURANKA++LTR ONLY( 1)
LPDR S ST.
JOSEPH MI++LTR ONLY(1)
TERA+4LTR ONLY<1)
NSIC++LTR ONLY(i)
ACRS CAT B~LTR ONLY(16)
NRC PDR++LTR ONLY<i)
OELD+<LTR ONLY(i)
WAMBACH~+LTR ONLY(1)
HANAUER++f TR ONLY< 1 )
DISTRIBUTION:
LTR 39 Sl ZE:
2P ENCL 0 END CONTROL NBR:
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INDIANA l MICHIGAN POWER COMPANY P. O. BOX 18 Bo WLIN G G RE EN ST A T ION NEW YORK, N. Y. 10004 August 16, T978; AEP:NRC:0006k.
C/'onald C.
Cook Nuclear Plant Unit Nos.
1 and 2
Docket Nos.
50-315 and 50-316 License Nos.
DPR-58 and DPR-74 Silicone Foam Fire Seals Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue
- Bethesda, Maryland 20014
Dear Mr. Denton:
This letter serves to document a telephone conversation held on June 28, 1978 between Mr. R. J.
Daley (AEPSC) and Mr. P. Matthews of the USNRC concerning, (1) the difference in configuration of silicone foam fire seals between Unit No.
1 and Unit I'Io.
2 of the Donald C.
Cook Nuclear Plant and, (2)
The ASTM E119 Test conducted on January 12, 1978.
The differences between the Unit 1 and Unit 2 fire seals concern caulking methods.
In Unit 1, gaps between the cable trays and the opening through which they pass were sealed with a perimeter bead of gun caulk silicone.
In Unit 2, the gun caulk silicone was again specified and was applied to a 1" depth over 9" of refractory fiber in the gap.
Both of these configurations were tested on January 12, 1978 with the result that no breakthrough of flame or heat occurred over the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> test period.
This indicated that the Unit 1 method of perimeter caulking alone would have been sufficient.
The other difference between the Unit 1
and Unit 2 installation concerns a 12" long bead of gun caulk silicone, measured from the face of the opening, to the top and bottom of the joint between the sides of cable trays which are touching.
This method was employed in Unit 2 and no problems were encountered with respect to the ASTM E119 test conducted on January 12, 1978.
Unit 1 does not have caulking on trays which are similarly arranged and was not tested.
g~o 4
August 16,1978 AEP:NRC:00067 The beads of caulk in the test arrangement, formed a "worst case" condition in that a chimney of varying width was created from the exposed to the unexposed side of the test slab.
This configuration was closely watched during the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> test and at no point was flame, smoke, or heat observed on the unexposed side of the test slab.
AEPSC therefore concludes that caulking between trays was an unnecessary precaution in Unit 2 and consequently does not propose to backfit the caulking to trays in Unit l.
Very truly yours, JT:em
(.(( w(Et, n TiTlinghast r
ce President Sworn and subscribed to before me this /6~
day of August 1978 in New York County, New York Notary Public KA'1'HLEEN BARRY NOTARY r'U8f.iC, Steto ol New York No. 41-4606792 Quefiiied in Ctueons
- County, Cerfificeto filed in Mew York Courtly Conerussion ctrprres rrtarch 30, 197+
cc:
R.
C. Callen P.
W. Steketee R. Walsh R. J. Vollen G. Charnoff R.
W. Jurgensen D.
V Shaller - Bridgman
1" AUG 16 Hys Am'erican Electric Power Service Corporation Indiana and Hichigan Power Company ATTI'I:
Hr. John Tillinghast
,Yice Chairman, Engineering
. and Construction 2 Broadway New York, NY 10004 Gentlemen:
'ocket No. 50-'316 An inspection performed at your Donald C.
Cook Nuclear Plant, Unit 2 on June 19, 22, 23 and 29, 1978, focused on an event which occurred on
'June 15, 1978.
This event was documented in your report dated June 29, 1978.
The event consisted of both emergency diese'I.generators being removed from service during maintenance while the Unit was operating at 605 power.
An.item of noncompliance related to this event is set forth in Appendix A to this letter.
.Three recent safety-related events at the D. C.
Cook fIuclear Power plant, involving incorrect valving and switching of safety-related equipment, indicate an existing deficiency in plant management controls.
.The first two of these events were discussed by J; G. Keppler, Director, Region III, with you and others of your staff at a meeting on June 16, 1978.
The discussion included our concerns that if management action was not taken, increased personnel errors may lead to events of greater safety significance.
Because of the significance of this latest event,=
and in view of the previous meeting on this subject, the enforcement aspects of'his case have been escalated from our Regional Office to
'eadquarters for handling.
'- The series of three events which occurred since hovember 1977 is of concern to us.
Nhile your letters of June 29, 1978 and June 30, 1978 identify some general as well as specific corrective act'ions you have already taken or plan to take to improve management controls, your response to the specific item of noncompliance -should further amplify your corrective actions as they relate to the following:
/
1.
Specific time tables to accomplish the corrective actions for Items E3 and E4 of fir. Shaller's June 29, 1978 letter and the corrective
. actions'escribed in your June 30, 1978 letter.
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C American Electric Power Supply Corporation Indiana and Michigan Power Company 4 +~X AUG 1 6 1979 2.
3.
I Plans for improving your management controls as they relate to both Corporate and Site Management involvement in the revie>>,
- solution, and followup of corrective actions for problems with safety-related'equipment or operations.
Of special interest are your plans for improving corporate management involvement in assuring corrective actions for repetitive problems.
Plans for improving your site management'ontrols as they relate to the operational and maintenance control of safety-related equipment.
Specific plans for improvement in the identification and labeling of equipment, rooms, valves and piping so as to reduce the possi-bility for personnel operating error.
5.
Plans to improve supervision and audit of ongoing operations to insure that operations important to plant safety continue to be properly carried out.
Sincerely, "Distribution LPDR TIC Norman C. Moseley, Director State of Michigan
'Division of Reactor Operations J.
G. Davis Inspection H.
C. Moseley
.Office of Inspection and F.
- Ingram, PA Enforcement 8; P. Murray, ELD J.
Lieberman, ELD M. Grossman, ELD E. A. Reeves, DOR
- 0. Crooks, 0,"IPA:MPA 0.
G. Abston, IA H. P. Ellis T. 1l. Brockett F. J.
Nolan, ROI:IE IE Files Central Files IE Reading File
/
Enclosure:
Appendix A, Notice of Violation r
SEE PREVIOUS YELLOW FOR CONCURREHCES Your response to this letter and the results of future inspections to review your corrective actions will determine if additional escalation
=of enforcement action is appropriate.
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A endix A NOTICE OF VIOLATION American Electric Power Ser vice Corporation Indiana and Michigan Power Company Docket No. 50-316 During an inspection of activities under License No.
DPR-74 conducted on June 19, 22~
~3 and 2>> 1978'he following apparent item of noncompliance was identified.
This item is considered to be an infraction.
Technical Specification 6.8.1 requires written procedures be estab-
- lished, implemented, and maintained.
Plant Manager Instruction (PMI)
- 2110, "Equipment Control-Clearance Permit System;"
and Plant Manager Procedure (PMP) 2110.CPS.001, "Clearance Permit System," establish the administrative controls for removing equipment from service.
The PMP states "A Clearance Permit must be obtained for any work which, for the safety of personnel and equipment, requires a certain definite arrange-ment or position of controls, circuit breakers,
- switches, valves, etc."
Clearance Permit No. 9350 dated June 15, 1978 was issued to clear the "82 C-D Diesel."
Among other things, the Permit provides for placement of the generator breakers in lockout and removing the starting air pilot valves from service.
That same procedure also states "All Clearance points shall be physically reviewed by the person obtaining the Clearance Permit before he accepts the Clearance Permit."
Contrary to the above, on June 15, 1978, when the Unit 2 C-D Diesel generator was being removed from service for maintenance work authorized by Clearance Permit iVo. 9350, the starting air pilot valves on the A-B diesel generator rather than the C-D diesel generator were removed from'ervice.
Also contrary to the above, the person obtaining the clearance permit did not review all clearance points before accepting the clearance permit.
This failure to follow procedures resu'lted in both Unit 2 diesel generators (A-8 and C-D) being out of service for approximately three hours while Unit 2 was operating at about 601 power,.
I As you are aware from the "Criteria for Determining Enforcement Action,"
which was provided to NRC licensees by letter dated December 31, 1974, the enforcement act":ons available to the NRC include administrative actions in the form of written notices of violation,.civil monetary penalties, and orders pertaining to the modification, suspension or revocation of the license.
After careful evaluation of the item of noncompliance set forth above and the enforcement history at the D. C.
Cook facility,.we conclude that a Notice of Violation is the appropriate action at this time.
Appendix A 0 MG 18 gyp This notice is sent to you pursuant to the provisions of Section 2.201 of the NRC's Rules of Practice, Part 2, Title 10, Code of Federal Regulations.
Section 2.201 requires you to submit to this office within twenty (20) days of your receipt of this notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further noncompliance; and (3) the date when full com-pliance will be achieved.