ML20133B529
| ML20133B529 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 01/30/1985 |
| From: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20133B528 | List: |
| References | |
| AEP:NRC:0906B, AEP:NRC:906B, NUDOCS 8508060199 | |
| Download: ML20133B529 (2) | |
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INDIANA & MICHIGAN ELECTRIC COMPANY P.O. BOX 16631 COLUMBUS, OH K) 43216 January 30, 1985 AEP:NRC:0906B Donald C. Cook Nuclear Plant Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 SUPPLEMENTAL RESPONSE TO NRC REPORT NOS. 50-315/84-13 (DRS); 50-316/84-15 (DRS)
Mr. James G. Keppler U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
As discussed with Mr. W. Little and others of your staff on January 8, 1985, we are providing the following as a supplement to our response (AEP:NRC:0906, dated November 29, 1984) to the subject inspection report.
SUPPLEMENTAL RESPONSE TO ITEM 9.b We have drafted a procedure that:
o Defines the actions necessary to document valve failures by the ISI Section.
o Defines the mechanics used to evaluate valve failures.
This procedure is currently being reviewed and is targeted for approval by March 15, 1985. This commitment supersedes the commitment in letter AEP:NRC:0906, Response 3.b.3 to proceduralize an interim measure for documenting valve failures.
As addressed in AEP:NRC:0906, an assessment of our valve program is to be completed by February 15, 1985.
The assessment should determine the program modifications that are needed to address tracking of valve failure rates and trending activities. We will provide a written description of the results of the assessment by April 1,1985. The description will discuss the modifications which will be incorporated into our valve program and a target date when the modifications will be incorporated.
The assessment, which has started, is addressing tLe following concerns:
B508060199 850731 PDR ADOCK 05000315 REB 4 1985 G
Mr. James G. Kcpplsr AEP:NRC 0906B The need for tracking valve failure rates for use in conjunction o
with a maintenance / replacement program.
o ~The necessity of developing a formal matrix of identical valves to be used in assessing 1the potential failure of valves identical to one that has failed. As an additional interim measure, should a valve failure be identified, an expedited review will be performed to identify valves that are identical (physically the same, used it the same service, and made by the same manufacturer) to the failed valve. The identical valves will then be assessed to assure continued operability.
SUPPr.RMENTAL RRADONSE TO ITEM 9.o(1)
Controls are being established to assure that appropriate corrective actions are taken to restore valves prior to discontinuing increased surveillance frequency (i.e., removing the valve from the increased frequency list). Specifically, the draft procedure (addressed above in Item 3.b) defines the course of action that will be taken to address valves placed.on increased frequency and to assure corrective action is taken, when necessary.
SUPPt RMENTAL DRRDOESE TO ITEM 9.e(2)
Infrequently stroked valves which exceed the timing criteria of ASME -
XI paragraph IWV-3410 and have to be placed on increased frequency will be evaluated. This evaluation will consider both valve performance capability on a component level and safety system response time requirements.
However, in all cases should a valve exceed its safety limit the valve will be declared inoperable and corrective action will be taken.
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 yours, 1N M
M.
. Al ich 3
g Vice President Y'
on Attachment oo: John E. Dolan W. G. Smith, Jr. - Bridgman R. C. Callen G. Bruchmann G. Charnoff NRC Resident Inspector - Bridgman f
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