ML20100L019
| ML20100L019 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 11/16/1984 |
| From: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20100L018 | List: |
| References | |
| AEP:NRC:0907, AEP:NRC:907, NUDOCS 8412110396 | |
| Download: ML20100L019 (3) | |
Text
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INDIANA & MICHIGAN ELECTRIC COMPANY P.O. BOX 16631 COLUMBUS, OHIO 43216 November 16, 1984 AEP tNRC:0907 Donald C. Cook Nuclear Plant, Unit 2 bocket No. 50-316 License No. DPR-74 NRC REPORT NO. 50-316/84-13 (DRS)
Mr. James C. Keppler U.S. Nuclear Regulatory Cossaission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Dear Mr. Keppler This letter responds to Mr. W. S. Little's letter dated October 18, 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 May,29-31, August 13-14, and September 28, 1984 The Notice of Violation attached to Mr. Little's letter identified one item of noncompliance:
"10 CFR 50, Appendix B, Criterion V states " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings." 10 CFR 50, Appendix J, Paragraph III.A.3.b states, "Results from the supplemental test are acceptable provided the difference between the supplemental test data and the Type A test data is within 0.25 La.
If results are not within 0.25 La, the reason shall be determined, corrective action taken, and a successful supplemental test performed."
Contrary to the above, section 5.7 in procedure 12-THP-4030-STP-203, Revision 4 allows the licensee, if a supplemental test is not within the acceptance criteria, to move the starting point of the test, without first satisfying the aforementioned Appendix J requirements. This resulted in the licensee arbitrarily dropping the first seven sets of data (3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />) in the June 16, 1984 supplemental test without adequately determining the reason. The use of all the data would have resulted in a failed test."
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' Mr. James G. ' Keppler AEF:NRC:0907 Our response to Mr. Little's letter is as follows:
1.
Corrective Action Taken
'An entensive evaluation of the supplemental test and the plant procedure was performed after the test was completed. D e evaluation-revealed that an incorrect conversion factor had been t. sed to calculate the supplenestal leak. A calculation with the corrected imposed leak rate was then performed. The new calculation, which included all of the data sets
-(includius the discarded sets discussed below). revealed that the supplement test results were acceptable (i.e., withim 0.25 La).
2.
Correntive Action to be T-ban to Avoid Further Na- - lia=*e 10 CFR 50,' Appendix J states, in part, "If results (of the
- supplemental test] are not"within 0.25 La (or 0.25 Lt), the reason shall be determined,' corrective action taken, and a successful supplemental-test performed."-
The response to question 022.6(6) of the D. C. Cook Fs&R, Appendix q states, "The supplemental test shall be conducted for a minisme duration of six hours."
Approximately 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> into the supplemental test for the 1984 containment integrated leak rate test, the supplemental test dets was evatusted. ' Based on the evaluation at that time, the test data did not reflect a linear regression during the first few hours of the supplemental test. he, cognisant ladividuals deteralmed, at that time, that the reases for the moslinear regression was probably some lastability in the costalament durias the first few hours.
Knowing that the acceptance criteria were (1) results within 0.25 La and (2) a mialmum test duration of six houral no corrective action had to f be taken to attria a successfri test. The last eleven hours (well la encess of the required six hours) of the supplement test revealed that the O.25 La criterion had been met. m e, as required by 10 CFR 50 Appendix J, (1) the reason for the test results apparently not being'withis 0.25 La i
had been deterslaedt (2) no physical corrective actions were necessary; and (3) a successful supplemental test of adequate duration had been performed. Therefore, the above 10 CFR 50, Appendix J requirements and FSAR requirements were met.
l We believe that neither 10 CFR 50, Appendia J nor ANSI N45.4-1972 prohibit the discarding of initial supplemental test data. As indicated la 10 CFR 50, Appendix J, the concern of a supplemental test is a test of
" sufficient duration to establish accurately the change in leakage rate..."
Our test actions met this concern.
The statement in the NaC inspection report that the licensee arbitrarily dropped sets of data is not correct. As indicated above, i
casalsant individuals evaluated the issue and decided to discard the first l
sets of dets, based on the test requirements. Thus, the discarded data was l
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.Mr. James G. Keppler s.
initially dropped as'a' result of a real time evaluation. It was not discarded arbitrarily or as a result of an after the fact detailed analysis.
' The Notice of Violation indicates that the plant procedure was
' inadequate, in that, the procedure does not state that "If results are not within 0.25 La, the reason shall be determined, corrective action taken, and a successful supplemental test performed." - Though, we did not violate this _ Appendix J requirement, we will revise the plant procedure to include this requirement.
3.
Date When Full Comsliance Will be Achieved Full compliance with 10 CFR 50, Appendix B, Criterion Y will be achieved by revising the plant procedure before the next time it is used.
This document has been prepared following Corporate procedures which incorporate a reasonable set of controls to insure its accuracy and completeness prior to signature by the undersigned.
Very truly youra, I
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M F. A exich Vice President n{w th Attachment cc: John E. Dolan W. G. Smith, Jr. - Bridgman R. C. Callen G. Bruchmann G. Charnoff NRC Resident Inspector - Bridgman.
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