ML20205B740

Responds to NRC Re Violations Noted in Insp Repts 50-315/87-03 & 50-316/87-03.Corrective actions:post-maint Testing Performed on Valve 1-IMO-215 & Review of Component Cooling Water Pump Discharge Pressure Conducted

ML20205B740
Person / Time
Site:	Cook
Issue date:	03/23/1987
From:	Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Davis A NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AEP:NRC:1025, NUDOCS 8703300034
Download: ML20205B740 (4)

Text

s ,

INDIANA & MICHIGAN ELECTRIC COMPANY P.O. BOX 16631 COLUMBUS. OHIO 43216 March 23, 1987 AEP:NRC:1025 Donald C. Cook Nuclear Plant Unit Nos. 1 and 2 1

Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 NRC INSPECTION REPORT NOS. 50-315/87003 (DRP)

AND 50-316/87003 (DRP)

U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Attn: A. B. Davis

Dear Mr. Davis:

This letter is in response to Mr. W. G. Culdemond's letter dated February 19, 1987, which forwarded the report on the routine safety inspection conducted by members of his staff. This inspection was conducted from December 16, 1986 through January 26, 1987 on activities at the D. C. Cook Nuclear Plant Units 1 and 2. The Notice of Violation attached to Mr. Guldemond's letter identified two violations which are addressed in the attachment to this letter.

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, M. P. Al xich Vice President cm Attachment cc: John E. Dolan W. G. Smith, Jr. - Bridgman R. C. Callen G. Bruchmann G. Charnoff NRC Resident Inspector - Bridgman 8703300034 870323 PDR ADOCK 05000315 O PDR j-

Att chment to AEP:NRC:1025 Pag 2 1 4

Inspection Report 315/87003; 316/87003 NRC Violation No. 1

" Unit 1 Technical Specification 6.8.1 requires written procedures be implemented covering applicable procedures of Appendix ' A' of Regulatory Guide 1.33 dated November, 1972. This includes, at Section I.1, procedures for maintenance which can affect the performance of safety related equipment. PMI-5070, Attachment 2, requires that testing of safety related valves be performed '...immediately or as soon as conditions permit....'

Contrary to the above, on December 6, 1986 the licensee performed

. maintenance on safety related valve 1-IM0-215 involving adjustment of stem packing and with plant conditions permitting, failed to test the valve for an interval of about five hours."

Response to NRC Violation No. 1 Corrective Action Taken and Results Achieved Post-maintenance testing was performed on valve 1-IMO-215 immediately upon discovery that testing had not been done following the completion of packing adjustment. The valve performed satisfactorily during the testing after the packing adjustment. It should also be noted that the valve was always in its proper position to perform its primary safety function.

Correction Action To Be Taken To Avoid Further Violation Operating memo 86-220(A) was sent to all Shift Supervisors on December 11, 1986 explaining that technical specification, containment isolation, and ISI power-operated valves shall be considered inoperable at the start of packing adjustments until they have satisfactorily completed ISI timing tests following the packing adjustment. The Operations Department has also developed administrative aids to readily identify items that are inoperable solely because of the lack of post-maintenance testing.

In addition, a memo was sent to maintenance personnel on December 17, 1986 explaining the reasons for this violation and emphasizing that it is absolutely r.ecessary that they understand the operability status of a component during and following repairs.

Date When Full Comoliance Achieved Full compliance was achieved at 1527 hours0.0177 days <br />0.424 hours <br />0.00252 weeks <br />5.810235e-4 months <br /> on December 6, 1986, when valve 1-IMO-215 was satisfactorily tested and declared operable.

'Attechnent to AEP:NRC:1025 Paga 2

~

f NRC Violation No. 2 "10 CFR Part 50, Appendix B, Criterion V, ' Instructions, Procedures, and

- Drawings,' as implemented by the Donald C. Cook Updated Quality Assurance Plan, Paragraph 2.7.5, ' Instructions, Procedures and Drawings' requires activities affecting quality to be prescribed by instructions, procedures or drawings appropriate to the circumstances, including appropriate quantitative or qualitative acceptance criteria for determining important activities have been satisfactorily accomplished.

Contrary to the above, the licensee's procedures for determining minimum acceptable Unit 1 component cooling water pump discharge pressures did not contain appropriate acceptance writeria, in that compliance to the discharge pressure values contained in the procedures could be achieved while violating the values required by Unit 1 Technical Specifications."

Resoonse to NRC Violation No. 2 Corrective Action Taken and Results Achieved i After the NRC notified us of the violation, we initiated an internal investigation. The results of the investigation and additional corrective

, action are discussed below.

A review of past surveillance data was conducted to determine if there were cases in which the CCW pump discharge pressure did not meet the Technical Specification acceptance criteria. Tests were found in which the actual discharge pressure of the East CCW pump was below the Technical Specification acceptance criteria. In four of these instances, a series of subsequent acceptable test results indicate that the pump performance had not, in fact, degraded.

The remaining unacceptable tests occurred on the East pump over a four-month period. The East pump was repaired at the end of the four-month period due to pump noises. The discharge pressure during the last test prior to the pump repair was less than one psig below the East pump Technical Specification limit. We note that the discharge pressure for the East pump was above the minimum Technical Specification requirements of the West pump. We believe, therefore, that the East pump was capable of performing its design function and in our judgment the discrepant test results had no effect on the health and safety of the public.

A review of the discharge pressure acceptance criteria for the other Technical Specification pumps determined that the acceptance criteria for the Unit One Essential Service Water (ESW) pumps had the potential for being nonconservative. Surveillance test data for the past six years were reviewed, and all the discharge pressures were found to be acceptable. The ESW surveillance procedures were changed March 4, 1987 to remove the potential for being nonconservative.

, , , - - m-e--

Attcchment to AEP:NRC:1025 Pegs 3

.e In addition, D. C. Cook Technical Data Book Figure 12.2 was revised on January 22, 1987 to give precise diacharge pressure acceptance criteria for the East, West and Spare Component Cooling Water (CCW) pumps. The criteria are now consistent with the Technical Specifications.

Corrective Action To Be Taken To Avoid Further Violations We concluded that the use of incorrect acceptance criteria was a result of failing to consult the appropriate base documents when revising the Technical Data Book. Therefore, PMI-4010. " Plant Operations Policy," which provides instructions for originating, revising and reviewing information for the Technical Data Book, will be enhanced to ensure that the appropriate base documents are reviewed. This change will prevent the events which led to the use of the non-conservative CCW pump discharge pressure acceptance criteria.

Date When Full Como11ance Achieved Full compliance was achieved on January 22, 1987, when the Technical Data Book was revised to give precise discharge pressure acceptance criteria for the CCW pumps. PMI-4010 will be revised by June 4, 1987.

i i~

a ----v-- - - - , ,-- -,----. ,, ,-- - , - - - - ----r --n,. -r , , - - ,-~--r--- --,--m-- -e - , - - - - -- -