ML20141J396
| ML20141J396 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 04/21/1986 |
| From: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| AEP:NRC:0948D, AEP:NRC:948D, NUDOCS 8604280129 | |
| Download: ML20141J396 (13) | |
Text
,.)., ).g, INDIANA & MICHIGAN ELECTRIC COMPANY P.O. BOX 16631 COLUMBUS,OH:0 43216 April 21, 1986 AEP:NRC:0948D Donald C. Cook Nuclear Plant Unit Nos. 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 RESPONSE TO NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES Mr. James M. Taylor, Director-Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Taylor:
This letter responds to Mr. J. G. Keppler's letter dated March 26, 1986, which transmitted the Notice of Violation and Proposed Imposition of Civil Penalties. The Notice of Violation addressed seven violations (A throuhh G) of Technical Specification requirements and proposed a civil penalty of
$100,000. All the violations are addressed in the attachment to this letter.
Violations A and B have been grouped together and a single, comprehensive response provided for both.
We have taken extensive corrective actions, including those actions discussed in our March 4, 1986 response to the SALP 5 Board Report, which we believe indicate that prompt management attention has been focused on the NRC concerns.
Pursuant to the subject letter, we have enclosed a check in the amount of
$100,000 in full payment of the proposed civil penalty.
Very truly yours, T
M.of. Alex ch Vice Pres dent Attachment MPA/rjn cc: James G. Keppler - Regional Administrator, U.S. NRC John E. Dolan W. G. Smith, Jr. - Bridgman R. C. Callen G. Bruchmann G. Charnoff NRC Resident Inspector - Bridgman 9604290129 860421 PDR ADOCK 05000315 g
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Mr. James M. Taylor AEP:NRC:0948D State of Ohio County of Franklin M. P. Alexich, 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 NRC letter dated March 26, 1986 and knows the contents thereof; and that said contents are tree to the best of his knowledge and belief.
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Subscribed and sworn to me this 3/h day of April, 1986.
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@otary Pub 1'icf I umanay mis s rl
ATTACHMENT TO AEP:NRC:0948D NOTICE OF VIO1ATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES
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- - Attcchment to AEP:NRC:0948D Pags 1 NRC Violations A and B "A.
Technical Specification 4.6.1.2 for Unit 1, implemented by D. C. Cook Procedure 1 THP 4030 STP.202, ' Containment Integrated Ler.k Rate Surveillance Test' requires that containment leak rates be determined in conformance with the criteria specified in Appendix J of 10 CFR Part 50.
Appendix J, Paragraph III. A.l(d) requires that portions of systems penetrating containment be appropriately vented,-drained or isolated during the test.
Contrary to the above, on August 18, 1985, during performance of an integrated leak rate test (ILRT) on Unit 1 per procedure 1 THP 4030 STP
.202, portions of systems penetrating containment were not appropriately vented, drained or isolated in that fifteen vents, drains, and valves as described in NRC Inspection Report 50-316/85027 were improperly aligned during the test.
B.
10 CFR Part 50, Appendix B, Criterion XIV, ' Inspection. Test and Operating Status,' as implemented by the D. C. Cook Operations Quality Assurance Program, Section 1.7.14, requires that measures be 9stablished for indicating the operating status of structures, systems and components, such as by tagging valves and switches, to prevent inadvertent operatio.t.
Contrary to the above, on August 18, 1985, and during the performance of an ILRT on Unit 1, the licensee's procedure,,1 THP 4030 STP.202, which was used to perform the test, did not require measures such as tagging valves to prevent inadvertent operation. As a result of not tagging the valves, licensee personnel repositioned eight valves after the ILRT valve lineup required by procedure was completed.
The ILRT was then performed with these valves in the incorrect position."
Resconse to NRC Violations A and B l
Admission or Penial of the Allered Violation Indiana & Michigan Electric Company admits that on, August 18, 1985 D. C. Cook personnel failed to maintain the correct alignment of valves during the performance of an ILRT on Unit 1.
Reasons for the Violation Based on our evaluation of the August 18,1985 Unit 1 ILRT and as discussed in our letter to you dated November 27, 1985, we have concluded that there were i
two major contributors to the problems experienced during the test.
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- The first major contributor was that our procedure 1 THP 4030.STP.202 did not l
indicate with sufficient clarity how certain vents were to be completely established.
Specifically, the procedure did not specify removal of plugs, gauges, etc., along with valve manipulation when establishing a vent. To l
prevent this from recurring, the ILRT procedure will be revised before its l
next use to specify separate actions for valve manipulations and plug removal, I
etc.
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Attach: nt to AEP:NRC:0948D Page 2 The second major contributor was lack of positive administrative controls (e.g., tagging) to identify the test boundary (i.e., components involved in the test) and to prohibit the uncoordinated manipulation of test boundary components.
To prevent this from recurring, formal administrative interface controls will be established prior to the next ILRT to include such things as tagging components as ILRT components, and indoctrinating appropriate plant staff about the nature of the controls and their responsibilities related to the controls.
In addition to the above, there was also indication that additional awareness may be needed by the Plant staff to identify when potential interface problems may occur in other relatively complex activities.
Therefore, we have issued directives to remind supervisors that they should be alert to potential inte rf ace problems prior to implementing complex activities.
Corrective Stens That Have Been Taken and Results Achieved As a result of the discrepancies noted during the ILRT, the following actions were taken:
1.
All the discrepant boundary conditions were corrected and independently verified.
2.
The ILRT was repeated satisfactorily.
3.
Those portions of the test boundary inside containment were verified for correct alignment following the second ILRT.
Corrective Steos That Will Be Taken to Avoid Further Violations In addition to the steps discussed above, we have taken the following steps to further minimize the probability of discrepancies during an ILRT.
1.
Specific instructions for the conduct of valve lineups and checking of valve position have been implemented.
These instructions have also been incorporated into the operator training program.
2.
A memorandum has been issued to each operator stressing the importance of independent verificatior. and proper signoffs.
3.
Meetings were conducted with the supervisors of each operating shif t to verbally emphasize independent verifications.
4.
The two individuals involved with the ILRT problems were counseled by the Operations Superintendent in the presence of their Shift Supervisor.
This session emphasized the importance of their actions in valve positioning and independent verification as well as their personal accountability for licensed duties. Additionally, a special 60-day observation period was conducted to review their performance in light of the ILRT events. The individuals performed satisfactorily during this observation period.
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areachmane en AEp NRC Q)46D Page 3
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i Date When Full Como11ance Achieved Full compliance was achieved on August 18, 1985, when the second Unit 1 ILRT was concluded satisfactorily.
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NRC Violation C "C.
Technical Specification 3.7.5.1 for Unit 2 requires the control room emergency ventilation system to be operable in Modes 1, 2, 3, and 4.
Technical Specification 3.0.4 prohibits entry into an operational mode unless the conditions of the Limiting Conditions for Operations (LCO) are met without reliance on provisions contained in the action statement.
Contrary to the above, on August 19, 1985 at 0023 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br />, with the control room emergency ventilation system inoperable, Unit 2 entered operational J
Mode 4 and by August 21, 1985 at 1401 hours0.0162 days <br />0.389 hours <br />0.00232 weeks <br />5.330805e-4 months <br />, had entered Mode 1 while in the referenced action statement."
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Response to NRC Violation C t
i' Admission or Denial of the Alleged Violation Indiana & Michigan Electric Company admits to the facts as stated above.
Reasons for the Violation e
on August 16, 1985 surveillance test under procedure 12 THP 4030.STP.229 was conducted following completion of modifications to the Unit I control room j
ventilation system.
During the test, the Unit 2 damper was improperly set to the makeup setting for fire protec. ion pressurization and full-closed for cleanup and emergency pressurization. The correct positions should have been j
full open for fire protection pressurization and the makeup setting for cleanup and emergency pressurization.
Procedures 12 THP 4030.STP.229, j
" Control Room Emergency Ventilation System Filter Efficiency Charcoal and HEPA Filter Leak Test," and 12 THP 6040.PER.094, " Control Room Ventilation Balancing," did not specify a functional check following any arm adjustments.
i Therefore, the improper setting was not discovered immediately.
Corrective Steos That Have Been Taken ar.d Results Achieved i
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On August 29, 1985, we determined that the Unit 2 damper had been improperly positioned. The damper was correctly adjusted and verified operable on August 29, 1985.
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Corrective Steos Taken to Avoid Further Violation Procedure 12 THP 4030.STP.229 and 12 THP 6040.PER.094 were revised by September 17, 1985, and now require a functional check following damper adj us tments.
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Date When Full Comoliance Achieved Full compliance was achieved on August 29, 1985, when the Unit 2 control room l
damper was correctly adjusted and verified operable,
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'A'ttachment to AEP:NRC:0948D' Page 4 NRC Violation D "D.
10 CFR Part 50, Appendix J, Paragraph III D.2(b)(ii), as implemented by D. C. Cook Procedure 12 THP 4030 STP.204, ' Personnel Air Lock Leakage and Interlock Surveillance Tesc.' requires that whenever air locks are opened diiring periods when technical specifications do not require containment integrity, they shall be tested at the end of that period at a pressure equal to or greater than the calculated peak containment i
internal pressure related to the design basis accident (P,).
Contrary to the above, on July 28, 1985, when the Unit 2 air lock interlock was restored after a period when containment integrity was not required by plant Technical Specifications, the licensee failed to implement Procedure 12 THP 4030 STP.204 and therefore did not test the airlock at P,."
Resoonse to NRC Violation D Admission or Denial of the Alleged Violation Indiana & Michigan Electric Company agrees that we did not address the 10 CFR 50, Appendix J. Paragraph III.D.2(b)(ii) requirements as stated abo *e.
As noted below, our actions were based on our interpretation of the current Technical Specifications (T/Ss).
I Reason for the Violation Our past practice was, we believe, fully in conformance with our T/Ss, which do not address this requirement in 10 CFR 50, Appendix J. Paragraph III.D.2(b)(ii). This interpretation was further enhanced by the asterisk next to T/S item 4.6.1.3.a. which specifically states " Exemption to Appendix J of 10 CFR 50."
Corrective Steos That Have Been Taken and Results Achieved On August 16, 1985 we successfully performed procedure 12 THP.4030.STP.204,
" Personnel Airlock Leakage and Interlock Surveillance Test," for Unit 2 airlock.
Corrective Steos That Will Be Taken to Avoid Further Violation e
We will now perform 12 THP.4030.STP.204 following periods when containment integrity is not required, per the requirements of 10 CFR 50, Appendix J, Paragraph III.D.2(b)(ii).
Date
- hen Full Como11ance Achieved Full compliance to 10 CFR 50, Appendix J requirements was achieved on August 16, 1985, when the Unit 2 airlock was demonstrated fully operable.
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Attachment to AEP:NRC:0948D Pcgs 5 NRC Violation E "E.
Technical Specification 3.3.2.1 for Units 1 and 2 requires that the r
engineered safety feature actuation system (ESFAS) instrumentation channels shall be operable with their trip setpoints consistent with the values shown in the ' Trip Setpoint' column of. Table 3.3-4.
Table 3.3-4, l
Item 6b, which lists the 4 kv Bus Loss of Voltage instrument channel for the motor driven auxiliary feedwater pumps (MDAFP) requires a 3196+18,
-36 volt trip setpoint with a 2+0.2 second time delay.
l Technical Specification 4.3.2.1.1 for Units 1 and 2 requires that each ESFAS instrumentation channel shall be demonstrated operable by the performance of a channel calibration for the modes and at the frequencies shown in Table 4.3-2.
Table 4.3-2, Item 6b, which lists the MDAFP 4 kv Bus Loss of Voltage instrument channel, requires that a channel calibration be performed at each refueling prior to operation in Modes 1, l
2 and 3.
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Technical Specification 4.3.2.1.3 for Units 1 and 2 require [sicj that the ESFAS response time for each ESFAS function shall be demonstrated to be within the limit at least once per 18 months.
Procedure 12 THP 6030 IMP.250, Revision 6, is the implementing document i
for surveillance required for the MDAFP 4 kv Bus Loss of Voltage instrumentation.
l Contrary to the above, during all refuelings that occurred prior to August 23, 1985, the licensee's channel calibration surveillance procedure 12 THP 6030 IMP.250 for the Unit 1 arid 2 MDAFP 4 kv Bus Loss j
of Voltage instrument channel was not adequate in that it did not include a calibration of the two-second time delay function."
Resnonse to NRC Violation T Admission or Denial of the_Allered Violation l
l Indiana & Michigan Electric Company admits that calibration of the two-second l
time delay did not occur peior to August 23, 1985.
Reason for the Violation A procedure was not established to check the time delay on the 4 kv Loss of Voltage Start Channel for the Motor Driven Auxiliary Feedwater Pumps. We believe that this omission was an oversight of one item addressed by a T/S line item that required more than one survelliance action.
Corrective Steos That Have Been Taken and Results Achieved Procedural changes have been made to assure the time delay is checked. The time delay was successfully demonstrated when this oversight was identified.
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Attechment en AEP:NRC:0948D Peg 2 6 Corrective Steps That Vill Be Taken to Avoid Further Violation Based on our review of all T/S instrumentation surveillances, we have l
confirmed one additional oversight of this type (i.e., more than one action l
required by one T/S item).
The additional oversight involved the requirement to test reactor trip system instrumentation within seven days prior to startup.
l We had adequately established the periodic trip system surveillance requirement, but not the associated seven-day requirement. We have modified our surveillance program to address the seven-day requirement.
Date When Full Comoliance Achieved Full compliance was achieved on August 23, 1985, when operability of the time delay was successfully demonstrated.
NRC Violation F "F.
Technical Specification 4.3.1.1.1 for Units 1 and 2 requires each reactor trip system instrumentation channel to be demonstrated OPERABLE [ sic] by the performance of a channel calibration for the modes and frequencies shown in Table 4.3-1.
Table 4.3-1, items 7 and 8, Overtemperature Delta T and Overpower Delta T instrumentation channels respectively, requires that a channel calibration be performed at each refueling prior to operation in Modes 1 and 2.
Technical Specification 4.3.2.1.1 as implemented by procedures THP 6030 IMP.194 through IMP.197 for Units 1 and 2 requires each engineered safety feature instrumentation channel calibration for the modes and frequencies shown in Tcble 4.3-2.
Table 4.3-2, Item 4d, which lists the instrumentation channel for low low m erage coolant temperature, requires that a channel calibration be performed at each refueling prior to operation in Modes 1, 2. and 3.
Technical Specification 4.6.4.2.b.1 for Units 1 and 2 requires the electric hydrogen recombiner (EHR) instrumentation to be demonstrated operable by the performance of a channel calibration at least once per 18 months.
Procedure 12 THP 6030 IMP.140 contains the surveillance requirements for the EHR instrumentation.
l Technical Specification 4.4.6.1.c.
for Units 1 and 2 re guires the l
containment humidity monitor (CRM) to be demonstrated c ierable by the l
performance of a channel calibration at least once per 18 months.
Procedure 12 THP 6030 IMP.050 contains the surveillance requirements for the CHM.
Technical Specification Definition 1.9 defines a channel calibration to encompass the entire channel including the sensor.
Contrary to the above, for all refuelings prior to August 1985, the licenree's channel calibration procedures referenced above for the Overtemperature Delta T, Overpower Delta T, low-low average coolant temperature, and the electric hydrogen recombiner instrumentation channels, and the containment humidity monitor for Units 1 and 2 did not adequately demonstrate operability for the required modes in that channel calibration procedures did not include the sensors."
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Attcchment to AEP:NRC:0948D Pega 7 Response to NRC Violation F Admission or Denial of the Allered Violation Indiana & Michigan Electric Company admits that the following instrument channel calibration tests for the following instruments did not include the sensors:
AT/T Protection Set Channels
[ResisEance Temperature Devices (RIDS) not calibrated]
Hydrogen Recombiner
[Thermocouples not calibrated]
Containment Humidity Monitor l
[ Humidity Detector not calibrated]
Reason for the Violation We erroneously believed that the respective T/S requirements would be fulfilled by the channel calibration test procedures that were developed for the above instrumants.
Corrective Steos That Have Been Taken and Results Achieved Based on discussions with NRR, Region III, and Westinghouse Electric Co., we have developed a test and successfully performed cross-calibrations which demonstrate satisfactory calibration accuracy of the RTDs.
The plant practices have been modified to assure RTDs are included in future calibrations.
The manufacturer's instructions for the hydrogen recombiner thermocouples state that the criterion for determining if the test thermocouples are not f
working is comparison of the temperatures.
The instruction also provides the criteria for making the temperature comparison.
Based on a discussion with l
your staff on October 2, 1985, the manufacturer's instructions were concluded to be an acceptable method of testing the thermocouples.
Since this has been the method of testing the thermocouples, we believe no violation of T/S occurred.
The containment humidity monitors have now been physically removed and recalibrated by the manufacturer. Calibration per the manufacturer's technical manual instructions, which excludes the temperature sensor, previously been performed every 18 months.
The monitors sensor had p.
21y been subject to a recalibration by the manufacturer every three years.
Removal and recalibration of the sensor has now been established on an 18-month basis.
Corrective Steos That Will Be Taken to Avoid Further_Miglation A review was performed to ensure that calibration and response time testing appropriately included sensors.
Attcchment to AEP:NRC:0948D Paga 8 Four instrumentation surveillances were determined to not include the sensors.
Calibration practices have been revised to assure that the sensors related to this instrumentation are included in the surveillances.
- Meteorological
- Containment Sump Level
- Gland Seal Exhaust System Flow Rate
- Subcooling Margin Monitor -- Vide Range Resistance Temperature Devices However, even though we will continue to remove the meteorological instruments on a semiannual basis we believe this is neither practical nor beneficial to the overall reliability of the system. Removal of the sensors also exposes plant personnel to the unnecessary risk of climbing the tower on which they are mounted.
Testing of the Steam Jet Air Ejector Flow Rate monitor was not established in our surveillance program. We have modified our surveillance program to address this monitor.
l Date When Full Comoliance Achieved Full compliance was achieved by November 27, 1985.
NRC Violation G "G.
Technical Specification 4.3.1.1.1 for Unit 2 requires each reactor trip i
system instrumentation channel to be demonstrated operable by performance l
of a channel functional test for the modes and frequencies shown in Table 4.3 1.
Table 4.3-1 requires that monthly channel functional tests be performed far Item 16, 'Undervoltage - Reactor Coolant Pumps' and Item 17, 'Underfrequency - Reactor Coolant Pumps' for operation in Mode 1 and Item 19, ' Safety Injection Input from ESF' for operation in Modes 1 and 2.
Technical Specification 4.3.2.1.1 for Unit 2 requires each engineered safety feature actuation system instrumentation channel to be demonstrated operable by the performance of channel functional tests at the required frequencies and for plant operation in the modes shown in Table 4.3-2.
Table 4.3-2 for Unit 2 requires that the following monthly channel functional tests be performed:
Modes 1. 2. 3. 4 Item la Safety Injection - Manual Initiation Item 2a Containment Spray - Manual Initiation Item 3a(1) Manual Phase A Containment Isolation Item 3b(1) Man al Phase B Containment Isolation Item 3c(1) Manual Containment Purge and Exhaust Isolation
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'Actachment to AEP:NRC:u94ED Pegs 9 Modes 1. 2. 3 l
l Item 4a Manual Steam Line Isolations; Item 4d, Steam Line Isolation -
1 Steam Flow in Two Steam Lines High Coincident With Tavg Low-Low Item 4d Steam Line Isolation - Steam Flow in Two Steam Lines High Coincident with Tavg Low-Low Item Sa Turbine Trip /Feedwater Isolation Steam Generator Water Level l
High High 1
I e
l Item 6a Motor Driven AFW Pump - Generator Water Level Low-Low i
Item 7a Turbine Driven AFW Pumps - Steam Genorator Water Level l
Low-Low 1:em 7b Reactor Coolant Pump Bus Undervoltage Contrary to the above, during testing prior to August 22, 1985, the licensee did not perform channel functional tests for the above listed instrumentation channels at the required monthly frequencies."
Resoonse to NRC Violation C Admission or Denial of the Allered Violation Indiana & Michigan Electric Company admits that monthly channel function tests were not performed at the required monthly frequencies for the cited I
instrumentation channels.
Reason for the Allered Violation We erroneously believed that the T/S surveillance frequencies for the channel functional tests were being tracked correctly by the computerized Nuclear Test Scheduler (NTS).
Corrective Steos That have Been and Results Achieved l
Fourteen Reactor Protection System or Engineered Safety Features Actuation System instruments were affected by this Nuclear Test Scheduler (NTS). The NTS has been revised to specify monthly surveillance intervals
',r these instruments.
Surveillances of those instruments have now been performed which are consistent with a monthly test interval.
Corrective Steos Which Will Be Taken to Avoid Further Violation L
l A review was performed to ensure all instrumentation surveillances were being l
performed at the correct interval.
The results of the review and associated corrective steps are as follows:
Testing of the reactor trip system instrumentation seven days prior to startup was not established in our surveillance program.
We have i
modified our surveillance program to address the seven day requirement.
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Attcchment to AEP:NRC:0948D Pcg3 10 Requirements to perform surveillances on the following four instrumentation channels are not explicitly stated in T/Ss. We have now established surveillance frequencies for this instrumentation which are consistent with associated instrumentation that is clearly addressed by the T/Ss.
- Reactor Coolant Pump Position Trip
- Auxiliary Building Unit Vent Radiation Monitoring Sample Flow Post Accident Containment Pressure Monitor
- Reactor Coolant System Leakage Detection (Ice Condenser Drain-Pot Level)
Date When Full Comoliance Will Be Achieved Full compliance was achieved by November 27, 1985.
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