ML20098G328
| ML20098G328 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 09/28/1984 |
| From: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| AEP:NRC:0899, AEP:NRC:899, NUDOCS 8410040379 | |
| Download: ML20098G328 (4) | |
Text
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INDIANA & MICHIGAN ELECTRIC COMPANY P.O. BOX 16631 COLUMBUS, OHlO 43216 September 28, 1984 AEP:NRC:0899 i
E Donald C. Cook Nuclear Plant Docket Nos. 50-315 and 50-316 l
Licenas Nos. DPR-58 and DPR-74 NRC Rhi>0T.T NOS. 50-315/84-12 (DRP); 50-316/84-14 (DRP)
Mr. James G. Keppler U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, r 60137
Dear Mr. Keppler:
This letter responds to Mr. W. D. Shafer's letter dated August 29, 1984 which forwarded the subject Inspection Report of the routine safety inspection conducted by your staff at the Donald C. Cook Nuclear Plant during the period June 11, 1984 through July 27, 1984. The notice of violation attached to Mr.
Shafer's letter identified four items of noncompliance. Our responses are as follows:
ITEM OF NONCOMPLTANCE - 1 Unit 2 Technical Specification 6.8.1.a requires that written procedures shall be established, implemented and maintained covering the activities
_ recommended in Appendix "A" of Regulatory cuide 1.33, November 1972. This includes procedures for loss of coolant.
Contrary to the above, with the unit in Mode 4 and manual valve RH-104W closed the procedure for initiation of Emergency Core Cooling did not provide the instruction necessary to establish flow to the residual heat removal pump during the recirculation phase of operation.
RESPONSE TO ITEM OF NONCOMPLIANCE 1.
Corrective Action Taken Instructions have been added to procedures 1-OHP 4022.008.002 and 2-OHP 4022.008.002 (Initiation of Recirculaton Phase) to direct the operator to open or verify open RH-104 E & W.
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' Mr. Jdmes G. Ireppler AEP:NRC:0899 2.
Corrective Action to' he Taken to Avoid Further Nonoomo11ance No further. actions are necessary.
- 3.. Ilmte when Full Ca=nliance Will be Anhieved Full compliance was achieved on July 2,1984, Wien the procedures were changed.
l-ITEM OF NONCMPLIANCE - 2 Unit 2 Techn' ical Specification 3 3 2.1 states... "the Engineered Safety Feature Actuation system (ESFAS) instrumentation channels and interlocks shown in Table 3.3-3 shall be operable..." Table 3.3-3, line to requires that for l
three loop operation in Modes 1, 2, and 3, the channel (s) associated with the Lprotective functions derived from the out-of-service Reactor Coolant Loop shall
'be placed in the tripped mode.
~ Contrary to the'above, on July 10,1984 at 0240 with the plant in Mode 3, the reactor coolant pump for loop 3 was secured without placing the channels associated with the protective functions derived from the out-of-cervice reactor. coolant loop in the tripped mode.
RESPONSE TO ITEM OF NONC MPLIANCE 1.
Corrective Action Taken
- The condition went undetected until 0755 hours0.00874 days <br />0.21 hours <br />0.00125 weeks <br />2.872775e-4 months <br /> on July 10, 1984 when it was pointed out to the oncoming Unit Supervisor at which time the protective
' function inputs were defeated. While reviewigg the incident, it was
- discovered that T had drifted to below 541 F by 0633 due to the pump
. being off. AtthII8 time we were no longer in noncompliance with the Action Statement.
- 2. - corrective Antion to be Taken to Avoid Further Nonnamnlianne w
The operators' were instructed (via an Operating Memo) to maintain all four c
Reactor Coolant Pumps (RCP) in service when above 541 F.
If a pup naast be taken out 'of service, then the RCS T aust be reduced below 541 F within one hour. The meno was issued on Juff818, 1984 I
The plant's shutdown procedure was revised on September 18, 1984 and the Reactor Coolant Pump operation procedure was reviscd gn September 6,1984
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for both Units to ensure T is reduced to below 541 F within one hour r
whenever there are less thIE8four RCPs running.
Tite plant's heatup and startup procedures are being revised to include the above requirements. The expected date for the completion of these revisions is November 1, 1984.
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Additionally, training will be done on this specific subject during the lioonaed operator requalification program. This initial training will be -
i completed by November 1,1984.
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Mr. James G. Keppler AEP:NRC:0899
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Date When Full ConD11ance Will be Achieved h
Full compliance fgr the specific cited incident was achieved when T drifted below 541 F at 0633 hours0.00733 days <br />0.176 hours <br />0.00105 weeks <br />2.408565e-4 months <br /> on July 10, 1984.
Other related"YE corrective actions are expected to be completed by November 1,1984.
. ITEM OF NONCOMPLIANCE - 9 Unit 1 Technical Specification 6.8.1. A requires implementation of N
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procedures recommended in Appendix "A" of Regulatory Guide 1.33, November 1972.
[s q This includes procedure for correcting abnormal, off-normal or alarm ic conditions.
Contrary to the above, on July 23, 1984, an alarm was received for Loop 1, 2, 3, 4 T*E8 low-low without the licensee implementing all of the action of annunciat response procedure 1 OHP 4024.111.002.
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- 3ESPONSE TO ITEM OF NONCCMPLIANCE r
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1.
Corrective Action Taken 5
At 1030 hours0.0119 days <br />0.286 hours <br />0.0017 weeks <br />3.91915e-4 months <br /> on July 25, 1984 when the noncompliance was identified, the remaining required procedural actions were taken. As a point of clarification the alarm had come in at 1407 hours0.0163 days <br />0.391 hours <br />0.00233 weeks <br />5.353635e-4 months <br /> on July 24, 1984 instead of July 23, 1984 as identified in the inspection report.
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Corrective Action to be Taken to Avoid Further Noncomnliance An Operating Memo was issued on August 29, 1984 reinstructing the operators to follow the guidance available in the annunciator response procedures in regards to svent-initiated surveillance requirements.
E An Operations Department Performance Engineer has been assigned the task of reviewing all of the annunciator response procedures in order to identify event-initiated.ourveillance requirements. An administrative system is i
being developed to flag these conditions to the operators and establish
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controls for logging requirements associated with the surveillances.
3 Date When Full Comoliance Will be Achieved Compliance with the specific citation was achieved on July 25, 1984 when the remaining procedural actions were taken.
L The review of the annunciator procedures is scheduled to be completed by 1
December 3,1984 with the administrative controls in place by December 31, i
p 1984.
ITEM OF NONCOMPLIANCE - 4 s
Unit 1 Technical Specificatian 6.8.1.o states written procedures shall be established, implemented and maintained for surveillance and test activities of y-safety related equipment. The Emergency Core Cooling System Operability w
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' Surveillance Test (1 OHP 4030 STP.005) at paragraph 4.1 requires that this test 1
. shall be performed on only one Emergency Core Cooling system train at a time.
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. ' Mr. James G. Keppler AEP:NRC:0899 Contrary to the above, on July 16,1984 at 0445, while performing 1 OHP 4030 STP.005 to verify operability of the "S" Safety Injection pump check valves, the licensee made two Safety Injection Pugs inoperable.
RESPONSE TO ITEM OF NONCCMPLIANCE
-1.
Corrective Action Tagga The'immediate action tauen was to reopen the valve for the pump not under test. The total time both pumps were inoperable was three to five minutes.
2.
Corrective Action to be Taken to Avoid Further Nonnamnlianne The procedure for performing this test is complicated and involves, testing all three ECCS pumps as a train oriented test. Therefore, this test
. procedure is being divided into six separate procedures, one for. each pump per each train. This change should significantly improve the test procedure clarity and the communication problems associated with this event.
3 Date When Full Ca=nlianne Will be Anhieved Full compliance for the specific cited incident, was achieved whhn the valve for the pump, not under test, was reopened. Procedures are scheduled to be completed by March 29, 1985.
This document has been prepared following Corporate procedures which incorporate a reasonab:a set of controls to insure its accuracy and completeness prior to signature by the undersigned.
Very truly yours,
[fy; o r
M.
. Al xich 9-Vice President.
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. Attachment ac: John E. Dolan W. G. Smith, Jr._- Bridgman R. C. Callen G. Charnorf E. R. Swanson, NRC Resident Inspector - Bridgman
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