ML20209G572
| ML20209G572 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 09/05/1986 |
| From: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| AEP:NRC:1006, NUDOCS 8609150004 | |
| Download: ML20209G572 (4) | |
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hm8 INDIANA & MICHIGAN ELECTRIC COMPANY I
P.O. BOX 16631 COLUMGUS, OHIO 43216 September 5, 1986 AEP:NRC:1006 Donald C. Cook Nuclear Plant Unit Nos. 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 NRC INSPECTION REPORT NOS. 50-315/86025 (DRP)
AND 50-316/86025 (DRP)
Mr. James G. Keppler, Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Dear Mr. Keppler:
This letter is in response to Mr. W. G. Guldemond's letter dated August 5, 1986, which forwarded the report on the routine safety inspection conducted by members of your staff.
This inspection was conducted from June 17 through July 28, 1986 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. These violations are addressed in the attachment to this letter.
This document has been prepared following Corporate procedures which incorporate a reasonable set cf controls to insure its accuracy and completeness prior to signature by the undersigned.
Very truly yours, n
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C M.
A exich Vice President cm Attachment cc: John E. Dolan
[f W. G. Smith, Jr. - Bridgman R. C. Callen whl G. Bruchmann G. Charnoff NRC Resident Inspector - Bridgman
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- 1986, 8609150004 860905 PDR ADOCK 05000315 G
1 Attachtsnt to AEP:NRC:1006 Pags 1 RESPONSE TO NRC INSPECTION REPORT 50-315/86025 AND 50-316/86025 NRC VIOLATION NO. 1
" Unit 1 Technical Specification 6.8.1.a requires procedures shall be established, implemented and maintained covering the applicable procedures recommended in Appendix
'A' of Regulatory Guide 1.33 November, 1972 which includes (Section E) procedures for correcting abnormal, offnormal or alarm conditions.
Contrary to the above, procedures either were not established or were not maintained for correcting alarm conditions for annunciators number 75 through 80 on Annunciator Panel Number 4 (ESW/CCW) in the Unit 1 main control room.
The alarm response procedure (1-OHP 4014.104 ' Annunciator No. 4 Response - Essential Service and Component Cooling') was found by the inspector on July 2, 1986 to address the subject annuciator numbers as though they were blank (i.e., ' spares') when, in fact, each annunciates an offnormal automatic safety-related pump start."
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The following corrective actions have been completed in response to the items identified in the above violation.
On July 2, 1986 the NRC resident inspector notified the Operations Department of the discrepancies on each unit's essential service and component cooling water annunciator panels. On July 7, 1986, an approved change sheet was issued to resolve the discrepancies noted on the Unit i essential service / component cooling water annunciator panel.
In addition to the above, an audit of each control room annunciator panel and plant sub panel was completed on July 10, 1986.
The audit consisted of comparing a controlled copy of the annuciator response procedure with its associated panel.
Such a comparison identified 1) whether or no' t each annunciator window with a legend had a response instruction page(s) and 2) whether or not blank annunciator windows were correctly represented by
" blank" designation pages.
Besides the inspection report items one additional discrepancy was found for Unit 1 panel 2 drop 150. The discrepancy (missing annunciator response) was corrected by an approved procedure change sheet on July 8, 1986.
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER VIOLATION The discrepancies resulted from inconsistent practices associated with the i
use of the design change forms.
Therefore, plant procedure PMI-5040, Design Change Control Program, will be revised to ensure that attributes of the design change forms are consistently addressed.
4 DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED f
Full compliance was achieved by July 8, 1986, when the. annunciator discrepancies were corrected, PMI-5040 will be revised by January 1, 1987.
Attcchm2nt to AEP:NRC:1006 Pags 2 NRC VIOLATION NO. 2
" Unit 2 Technical Specification 3.5.1.b requires each reactor coolant system accumulator shall be OPERABLE with a contained borated water volume between 929 and 971 cubic feet when the reactor is in MODES 1 or 2, or in MODE 3 above 1000 psig pressurizer pressure. Associated ACTION requirement (a.) specifies that with one accumulator inoperable, restore the inoperable accumulator to OPERABLE status within one hour or be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Contrary to the above, with Unit 2 in MODE 1 at approximately 12:30 p.m.
on July 15, 1986 the contained water volume for the No. 22 accumulator was measured (in inches above the lower instrument tap) to be about 105 inches.
which equates to approximately 900 cubic feet. An error was made in communicating this measurement, and the licensee continued to operate the Unit in MODES requiring OPERABLE accumulators until the deficient volume for the subject accumulator was recognized at 4:20 p.m. and corrected by 9:20 p.m. on July 18, 1986; a period of approximately 81 hours9.375e-4 days <br />0.0225 hours <br />1.339286e-4 weeks <br />3.08205e-5 months <br />."
RESPONSE TO NRC CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Immediate corrective / preventive action taken on the discovery date July 18, 1986 consisted of:
- 1) promptly increasing accumulator volume to within Technical Specification limits and verifying acceptable boron concentration, and 2) obtaining independently verified ultrasonic test (Ur) level indication at least once cvery 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
This ensures Technical Specification compliance until such time as the process instrumentation is repaired and returned to service.
A contributing factor to this event was loss of the UT data sheet due to contamination and the technician's subsequent reliance on memory when relaying the UT results. The personnel responsible for the July 15, 1986 report have been instructed in the appropriate methods for maintaining cleanliness of written documents while in a contaminated environment and the importance of transmitting accurate information utilized to evaluate plant conditions. These persons have since demonstrated the necessary skills to prevent a recurrence of this event during activities performed under similar circumstances.
To enhance the effectiveness of communications between Quality Control and Operations personnel, when UT level determination is required, the data sheet (s) within the UT procedure have been revised to require:
1) independent verification of test results; and 2) Unit Supervisor /SRO review and signature.
In addition, administrative controls have been established to insure that accumulator levels more conservative than Technical Specification requirements are maintained during the period in which ultrasonic measurements are relied upon to demonstrate Technical Specification compliance.
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Attechment to AEP:NRC: 1006 Paga 3 e
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER VIOLATION Diagnostic testing will be performed on the accumulator volume instrumentation during the next unit outage (tentatively Spring of 1987).
Followin6 testing and determination of the root cause for the erroneous system response, corrective action will be taken.
DATE WHE3 FULL COMPLIANCE WILL BE ACHIEVED Full compliance with Technical Specifications was achieved on July 18, 1986.
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