ML20040E032
| ML20040E032 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 01/19/1982 |
| From: | Hering R INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | Keppler Jg NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20040E022 | List: |
| References | |
| AEP:NRC:00643, AEP:NRC:643, NUDOCS 8202020504 | |
| Download: ML20040E032 (4) | |
Text
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lNDIANA & M!CHIGAN ELECTRIC COMPANY P. O. 80 X 18 BOWLING GREEN ST ATION N EW YORK, N. Y.10004 January 19, 1982 AEP:NRC:00643 Donald C. Cook Nuclear Plant Unit Nos. 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 IE REPORT NOS. 50-315/81-24 AND 50-316/81-26 Mr. James G. Keppler, Regional Administrator U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
The Attachment to this letter provides our response to the Notice of Violation contained in Appendix A to TE Inspection Report Nos.
50-315/81-24 and 50-316/81-26 transmitted to us in Mr. R. L. Spessard's letter of December 1, 1981. A extension to respond was granted by your office on December 30, 1981 at our request.
A further one week extension was granted by your office on January 12, 1982.
This document has been prepared following Corporate procedures which incorporate a reasonable set of controls to ensure its accuracy and completeness prior to signature by the undersigned.
Very truly yours, A
R. F. Hering
/os Vice President Attachments cc: John E. Dolan - Columbus R. W. Jurgensen W. G. Smith - Bridgman R. C. Callen G. Charnoff Joe Williams, Jr.
NRC Resident Inspector at Ccok Plant - Bridgman R, S. I!unter 8202020504 820127 DR ADOCK 0500031s JAN 2 2 M PDR
2 s-STATE OF NEW YORK )
COUNTY OF NEW YORK)
R. F. Hering, being duly' sworn, ' deposes and says that he is the Vice President of Licensee Indiana & Michigan Electric Company, that he has read the foregoing response to the Notice of Violation contained in Appendix A to IE Inspection Report Nos. 50-315/81-24 and 50-316/81-26 and knows the contents thereof; and that said contents are true to the best of his knowledge and belief.
N, 8ame of Signe/
Subscribed and sworn to before me this M day of Jsnuary, 19 8L i
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' RESPONSE TO ITEM 1 OF APPENDIX A on July 23, 1981 at 1316 hours0.0152 days <br />0.366 hours <br />0.00218 weeks <br />5.00738e-4 months <br />, Unit 2 Reactor Coolant System Loop 4 T
_ Delta-T, and T-cold were observed to be operating abnormallyf8,he operators believed that the channels had f ailed and, in T
accordance with Plant practices, notified the Control and Instrument Section at 1325 hours0.0153 days <br />0.368 hours <br />0.00219 weeks <br />5.041625e-4 months <br />.
In this case, a breakdown in communications occurred and Control and Instrument Section personnel were of the opinion that the problem was minor instrument drift which would not require rapid response on their part.
Due to other unrelated but demanding activitics in the Control Room, approximately one hour elapsed before the operators realized that the Control and Instrument Section had not reuponded to the notification.
Another call was made and the affected channels were placed in the trip mode at 1455 hours0.0168 days <br />0.404 hours <br />0.00241 weeks <br />5.536275e-4 months <br />, approximately ten minutes af ter the Control and Instrument technicians arrived in the Control Room.
Investigation revealed that the Loop 4 T-cold RTD had opened (failed high). A spare RTD was placed in service and the channels were declared operable at 1730 hours0.02 days <br />0.481 hours <br />0.00286 weeks <br />6.58265e-4 months <br /> the same day.
Our practice of having Operations inform the Control and Instrument Section of abnormal instrument performance, and then for the Control and Instr' ment Section to take the necessary actions (placing u
the channel (s) in the trip mode, if required) was reviewed. We believe this practice to be acceptable based on our past six years of operating in this manner and by our compliance with the one hour time limit when instruments have failed.
We believe that in this case the operators should have been aggressive in their attempts to comply with the Technical Specifications and should have initiated actions to place the Unit in at least Hot Standby within six hours as required by Technical Specification 3.0.3 when the affected channels had not been placed in the trip mode within one hour.
To prevent this from recurring, the event has been discussed with the Operations and Control and Instrument Section personnel involved, with emphasis placed on the need for good communications and the need to respond in a timely manner.
We will re-emphasize to the operators the necessity of adherence to the one hour time limit and the requirements of Technical Specification 3.0.3 when an instrument channel has failed and is obviously inoperable.
If these requirements cannot be met, then the requirements of the Technical Specification Action Statement will be completed.
All Control and Instrument Section and licensed Operations Department personnel will be required to review this event and the need for immediate response and completion of the appropriate action will be re-emphasized.
This review will be completed by February 28, 1982.
A Plant Manager's Standing Order (PMS0) is being prepared specifically delineating and emphasizing the responsibilities of the Control Room operators and the Control and Instrument Section when an instrument channel indication deviates from other channels measuring the same pararcter. The PMSO will'be completed by February 28, 1982.
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,O RESPONSE TO ITEM 2 0F APPENDIX A on June 12,-1981, while the Unit was in Mode 6, Surveillance Procedure. 1 THP 4030 STP.2178, " Diesel Generator Load Shedding _and Performance", was started.
On that day test results for the degraded bus voltage relay (62-1-T-11A) indicated a response time of 2 minutes 6.5 seconds.
This was 0.5 seconds above the Technical Specification tolerance.
This event was not reported immediately as the person collecting data failed to ' realize that this was slightly above the Technical Specification tolerance limits.
A Condition Report would normally have been initiated at this time.
The performance of this surveillance procedure depends on the availability of the equipment and when the equipment is turned over to the individuals performing the surveillance.
Therefore, a considerable time period is required to complete this surveillance procedure. During the final procedure review by _ the Section Supervisor, it was recognized that the response time of the degraded bus voltage relay was above the Technical Specification tolerance.
This review took place on July 21, 1981, and the required condition report was initiated on that date.
A job order was also initiated and the Agastat timer was _ reset and tested to be within Technical Specification toleranct ' before entering Mode 4.
The LER was submitted within 30 days of the late that the Condition Report was prepared.
The independent review by the Section Supervisor is designed to detect any oversight (as occurred in this situation) and to allow problems to be corrected before entering an operating mode where the equipment is required to be operabic.
In this case the problem was corrected before entering Mode 4 (the applicable mode).
Thus, at no time was there any danger to the health and safety of the public.
To prevent reoccurrence a training session has been held with all Performance Engineering personnel involved in surveillance testing.
This session stressed the importance of Technical Specification tolerances and the appropriate reporting requirements when a Technical Specification tolerance is exceeded.
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