ML20065H856
| ML20065H856 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 09/14/1982 |
| From: | Hering R INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20065H851 | List: |
| References | |
| AEP:NRC:0735, AEP:NRC:735, NUDOCS 8210050276 | |
| Download: ML20065H856 (3) | |
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lNDIANA & MICHIGAN ELECTRIC COMPANY P. O. SOX 18 SOWLING GREEN ST ATION N EW YORK, M. Y.10004 September 14, 1982 AEP:NRC:0735 Donald C. Cook Nuclear Plant Units No.1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 IE INSPECTION REPORTS NO. 50-315/82-12 (DPRP) AND NO. 50-316/82-12 (DPRP)
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 the Appendix to IE Inspection Reports No. 50-315/82-12 (DPRP) and No. 50-316/82-12 (DPRP).
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,
.. l/
R. F. Hering
/os Vice President ec: John E. Dolan - Columbus R. S. Hunter M. P. Alexich R. W. Jurgensen W. G. Smith, Jr. - Bridgman R. C. Callen G. Charnoff Joe Williams, Jr.
NRC Resident Inspector at Cook Plant - Bridgman 8210050276 820924
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Attachment to AEP:NRC:0735 Donald C. Cook Nuclear Plant Unit Nos. I and 2 Response to Notice of Violation
- Item of Noncompliance (Paraphrased) 10 CFR 50, Appendix B, Criterion III states that, " Measures shall be established for the identification and control of design interfaces and for coordination among participating design organizations.
These measures shall include the-establishment of procedures among participating design organizations for the review, approval, release, distribution, and revision of documents involving design interfaces."
" Design Changes, including field changes, shall be subj ect to design control measures commensurate with those applied to the original design".
As written in AEPSC General Procedure No. 25, " Engineering Design Changes", "Once the onsite work required to implement the original change has been completed, the RFC cannot be further modified".
Contrary to the above, the NRC inspection found: that a revision was made to RFC DC-02-2248 af ter work was completed and the RFC was closed; documentation of the revision was not sent to the Plant Outage / Design Change Coordinator; and the revision was not subjected to a review commensurate with the review applied to the original change.
Response to the Item of Noncompliance The RFC revision mentioned in the report consisted of a change to the mounting brackets for the turbine control and stop valve limit switches.
Our investigation into the circumstances-surrounding this occurrence revealed the following:
1)
Due to high level vibrations, the switches of concern tended to fail after short periods of use. For this reason a new design for mounting these switches was developed and implemented in RFC-DC-02-2248.
2)
After RFC-DC-02-2248 was installed and closed, some of the turbine control and stop valve limit switches failed again due to high 1evels of vibration. These failures led to a joint effort, by both the Cook Plant and the Electrical Generation Section in New York to design a new mounting scheme for the switches.
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When the new design of the mounting brackets was completed, it was then reviewed and approved for installation by the cognizant Electrical Generation engineer. The approval for installation was received-from the cognizant engineer,- Electrical Engineering Division, in a letter dated December 2, 1981.
The change was installed as recommended.
Both the approval for installation and the installation itself were done in a manner contrary to existing administrative controls placed on performance of such work.
Corrective Action Taken and Results Achieved To comply with the requirertents of existing administrative controls (AEPSC General Procedure No.
25,
" Engineering Design Changes"),
RFC-02-2611 was initiated to authorize the design change of the mounting system for' the stop valve limit switches.
In addition, the Plant Manager will issue by September 30, 1982, a memorandum to all involved Plant Departments re-emphasizing the-
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procedural requirements for installation of any new design changes or revisions to previously approved or installed design changes.
By the same date, the AEPSC Manager of Quality Assurance will issue another memorandum re-emphasizing that procedural requirements must be adhered to unless relief is granted by authorized management action.
Date When Full Cc:apliance will be Achieved Upon review of RFC-02-2611 as per AEPSC General Procedure No. 25, and issuance of the memorandums from the Plant Manager and the AEPSC Manager of Quality Assurance, full compliance will have been achieved.
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