ML17334B364

Responds to NRC 900301 Ltr Re Violations Noted in Insp Repts 50-315/89-31 & 50-316/89-31.Corrective Actions:Reliability Centered Maint Program Initiated

ML17334B364
Person / Time
Site:	Cook
Issue date:	04/11/1990
From:	Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Davis A NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AEP:NRC:1125A, NUDOCS 9004200632
Download: ML17334B364 (38)

See also: IR 05000315/1989031

Text

\r Indiana'Achrga~Power Company~~0 80 c'.663'Nl7lAMA

NTCHIGAN POWER AEP:NRC:1125A

Donald C.Cook Nuclear Plant Units 1 and 2 Docket Nos.50-315 and 50-316 License Nos.DPR-58 and DPR-74 NRC INSPECTION

NOS.50-315/89031

AND 50-316/89031:

RESPONSE TO VIOLATION U.S.Nuclear Regulatory

Commission

Attn: Document Control Desk Washington, D.C.20555 Attn: A.B.Davi.s April ll, 1990 Dear Mr.Davis: This letter is in response to Mr.H.J.Miller's letter dated March 1, 1990, which forwarded the report on the special maintenance

team inspection

conducted by Mr.Z.Falevits and others of your staff.This inspection

was conducted from December 4 through 8, and December 18 through 22, 1989, on activities

at the Cook Nuclear Plant associated

with the support and implementation

of maintenance

to ensure that plant structures, systems and components

reliably perform on demand.The Notice of Violation attached to Mr.Miller's letter identified

six weaknesses

and four Severity Level IV violations

relating to our maintenance

program.The weaknesses

are addressed in Attachment

1 to this letter.The violations

are addressed in Attachment

2 to this letter.A 14-day extension for our response was granted on March 15, 1990'his document has been prepared following Corporate procedures

that incorporate

a reasonable

set of controls to ensure its accuracy and completeness

prior to signature by the undersigned.

Sincerely, M.P.Al ich Vice President ldp Attachments

~)g4QOCk&2

90041 1 pgg ADQcK o>oog+~~~I pp 1/00

Mr.A.B.Davis AEP:NRC:1125A

cc: D.H.Williams, Jr.A.A.Blind-Bridgman R.C.Callen G.Charnoff NRC Resident Inspector-Bridgman NFEM Section Chief

ATTACHMENT

1 TO AEP:NRC:1125A

RESPONSE TO NRC-IDENTIFIED

WEAKNESSES

Attachment

1 to AEP:NRC:1125A

Page 1 NRC-Identified

Weakness (1)"Lack of or ineffective

action to correct numerous self identified

maintenance

problems identified

in February 1988, many of which were identified

by the team during this inspection." Response to Weakness (1)Corrective

Actions Taken As a result of the 1988 Maintenance

Self-Assessment

Report, AEPSC contracted

IMPELL to assist in identifying

and formulating

appropriate

corrective

actions to address the self-identified

deficiencies.

The results of thi,s effort are in a document entitled, D.C.Cook Plant PM Pro ram U rade Strate Document, dated November 1988.This study contained a strategy for AEP to accomplish

a planned upgrade of the Preventive

Maintenance (PM)Program at the Cook Nuclear Plant.It identified

reasonable

goals and achievable

objectives

for the PM Upgrade Program based on AEPSC/Cook

Nuclear Plant philosophy, resources and capabilities.

The specific implementation

tasks and strategic considerations

were presented for obtaining the desired upgrade results.This effort'ot only addressed improvements

in the PM Program itself, but also examined related organization

and automation

requirements

to support the improved PM Program.Based on the results of this study, numerous corrective

actions were initiated in January 1989.The first was the initiation

of a reliability-centered

maintenance (RCM)program.This major task has two phases: analysis and implementation.

AEPSC has been working closely with General Physics on the analysis portion that will form the foundation

of the RCM program.This work includes: defining system boundaries

and functions identifying

dominant failure modes determining

criti.cal failure modes and criti.cal components

identifying

applicable

and effective preventive

maintenance

tasks to prevent failures completing

analysis of selected plant systems

Attachment

1 to AEP:NRC:1125A

Page 2 Implementation

of the RCM Program began in August 1989 with the development

of plant procedures, identification

of system boundaries, and establishment

of an RCM database.The first syst: em analysis was completed in February 1990 on the feedwater system.Analysis of 22 additional

plant systems/functional

areas will take place over the next three years.Another outgrowth of the Maintenance

Self-Assessment

Report and the AEPSC/IMPELL

study was the development

of the System Engineer Program.The goal of the System Engineer Program is to provide training to enable individuals

to provide the engineering

expertise required for safe, efficient and reliable operation of systems for which they are responsible.

The System Engineer discharges

this responsibility

by performing

assigned tasks, and maintaining

cognizance

of all work associated

with the assigned system(s).

In addition, AEPSC contracted

TENERA Systems and Software to provide a computerized

maintenance

management

information

system.This system, referred to as the Nuclear Plant Maintenance

Module (NPM)System, discussed in more detail in our response to weakness (3), will allow plant staff to initiate, issue, prioritize

and track all maintenance

work at the plant.This same software is currently being used at Pacific Gas and Electric's

Diablo Canyon, and Public Service Electric and Gas's Salem and Hope Creek Generating

Stations.In addition, it was recently chosen by Electricite

de France for use in all fifty of its nuclear plants.These three programs, RCM, System Engineer and NPM, are just part of the actions that are being taken to respond to the Self-Assessment.

The November 1989 reorganization

of Cook Nuclear Plant's management

is another important element in the upgrade of our maintenance

program.The intent of the new organization

is to place emphasis on maintenance, outages, and human'resources, Other actions, which have or are being taken are as follows: o An AEP and Cook Nuclear Plant policy on maintenance

was developed and approved in December 1989 by AEP senior management.

An additional

plant-specific

maintenance

policy established

in accordance

with INPO guidelines

is being developed to clarify maintenance

philosophies

and responsibilities

for all maintenance

groups

Attachment

1 to AEP:NRC:1125A

Page 3 o Corporate reviews have been conducted, which have resulted in improvements

being made to shop areas used by the maintenance

groups o Staffing studies are being performed, which have already resulted in an increase in the number of engineers and radiation protection

technicians

on site.o Other programs of note that address maintenance

self-assessment

findings include the maintenance

procedure rewrite (See Weakness (6)), the long-range

plan and the outage guideline development

plan.(2)Benefits To Be Derived From Corrective

Actions RCM, the System Engineer Program and NPM were initiated to address many of the Maintenance

Self-Assessment's

identified

deficiencies.

When all of our efforts have been completely

implemented, each of the major findings of the self assessment

will have been addressed.,As a result of these corrective

actions.we anticipate

having a state of the art maintenance

program which will result in improved plant safety, reliability

and accountability.

(3)Date When Benefits Vill Be Realized As previously

stated, we started the RCM Program in August 1989.However, we anticipate

that the program will not be completely

implemented

for all the critical plant systems until the end of 1992.As each system is analyzed, benefits will be realized so that when this program is completed we will have a fully integrated

preventive

maintenance

program.The System Engineer Program, like RCM, is still in the early stages of implementation.

A document which clearly delineates

the responsibilities

of the engineers is currently in the final stages of review and approval.AEPSC's acquisition

of TENERA's NPM system was approved in December 1989.However, it will not be in place and operational

until August 1990, when data will be entered.Ve will be conducting

QA audits or surveillances

to access the status and effectiveness

of some of our corrective

actions as they develop.In addition, the Maintenance

Improvement

Plan will review and resolve, as appropriate, the Maintenance

Self-Assessment

items'he Improvement

Plan includes milestones

and a built-in mechanism that requires regular re-evaluation.

Attachment

1 to AEP:NRC:1125A

Page 4 While we are already realizing benefits from our efforts, we do not anticipate

the full benefit for several years.In order to effectively

implement programs as encompassing

and comprehensive

as these, significant

analysis, planning and coordination

are needed.As a result, their benefits will not be fully realized until mid 1993.

Attachment

1 to AEP:NRC:1125A

Page 5 NRC-Identified

Weakness (2)"An ineffective

preventive

maintenance

program that resulted, for example, in failures of 4KV circuit breakers" Response to Weakness We concur that the Preventive

Maintenance

Program can be improved and, as previously

discussed, we are taking steps to do so.However, Cook Nuclear Plant's availability

in 1989 is evidence that the present preventive

maintenance

program is effective.

During 1989, Cook Nuclear Plant generated 12 million net MWHRS, the most since 1984.The 69.3%availability

for Unit 1 in 1989 contributed

to an average availability

of 79.4%since 1985'lthough Unit 2 overall availability

has not been as high due to steam generator tube degradatidn, its 74.4%availability

in 1989 was the highest since 1983.On December 8, the 111-day record for the longest run with both units operating was broken.This record was extended to 140 days when Unit 2 was brought off-line for a surveillance

outage on January 6, 1990.Unit 1 ended 1989 with its longest run of 175 days and continued operating until March 17, 1990 (a Cook Nuclear Plant record run of 251 days)when the unit was brought off line for a planned surveillance

outage.As discussed in our response to NRC violation (2)of the inspection

report, the 4KV circuit breakers failure was detected during preventive

maintenance

testing.As a result, appropriate

corrective

action was.subsequently

taken which resulted in improvements

to our 4KV breakers.Also, we notified the industry of the problem via a Part 21 report.

Attachment

1 to AEP:NRC:1125A

Page 6 NRC-Identified

Veakness (3)"An extensive backlog of non-outage

corrective

maintenance

job orders partly caused by lack of integrated

planning and scheduling

methodology." Response to Weakness"Maintaining

the Cook Nuclear Plant involves the completion

of approximately

20,000 Job Orders annually.The relative priorities

of jobs change frequently

due to a number of factors, the primary reason being plant conditions.

Managing the information

contained within the backlog of yet-to-be completed Job Orders can be critical to plant availability

and reliability.

These efforts are presently hampered by the logistics of paper filing systems and computer tracking systems that lack needed flexibility

in hardware and software.(1)Corrective

Actions Taken The Cook Nuclear Plant Information

Management

System (IMS)plan, approved for development

in February of 1989 identified

nine computer system modules that, when completed, will form a single, integrated

information

management

system.This automated information

system will be used by both plant site and corporate personnel to support plant operation and maintenance.

It will provide for the scheduling

and initiation

of maintenance

tasks and support the assignment

of responsibilities

and accountabilities

for these tasks.Specifically, for maintenance, the Nuclear Plant Maintenance

Module (NPM)of the Cook Nuclear Plant's IMS plan will allow plant staff to initiate, issue, prioritize, and track all maintenance

work at the plant.The NPM module of the IMS plan will also maintain a history of maintenance

work.The primary objectives

of the NPM module are to improve plant availability

and to optimize the use of plant resources with the overall goal of reducing plant maintenance.

The NPM system is designed to allow any NPM user to initiate a structured

request that the user believes should be reviewed and, if warranted, acted upon.This action request feature provides a process for screening those actions requiring work, and will serve as a focal point for initiating

and tracking Job Orders.Plant personnel will enter data into the NPM system defining the component that needs work and briefly describing

that work.The system is designed to eliminate all paper in this process except the actual Job Order itself.

Attachment

1 to AEP:NRC:1125A

Page 7 The reviews that take place in the Job Order system are performed on-line.This on-line capability

allows for pending Job Orders to be sorted in various ways and the reviewing individuals

have'mmediate

access to this information.

Once reviews are performed the actual Job Orders can be printed for the work to be performed.

Once a Job Order has been initiated, starting from the very first entry into the system and not just from the time it gets printed, the Job Order processing

system can track the status of the Job Order.This is accomplished

through the use of status code fields.Some of the codes represent situations

such as waiting for materials, or waiting for approval of the reviews, or other types of conditions.

This feature is very helpful for planning and scheduling

the many Job Orders in the system.The NPM system will permit the plant staff to assign specific Job Orders, at the activity level, to a scheduled date, crew and supervisor.

Upon completion'f

the crew assignments

and confirmation

of permit requirements, the system produces a supervisory

assignment

report and prints the Job Order.The completed work package includes the Job Order, equipment descriptions, parts list, and testing forms along with other needed documents.

Once the work related to a Job Order has been completed and tested, the Job Order is reviewed and closed out, on-line.The NPM system maintains a complete history of all completed and closed-out

Job Orders.This feature allows for rapid access to all history on Job Orders.The NPM system prevents a Job Order from being closed-out

until all reviews and tests have been completed.

Zn addition, the NPM system will be a repository

for previous repetitive

tasks.This function eliminates

the need for individuals

to recreate Job Orders that are repetitive

in nature, The NPM system will automatically

generate the Job Orders,, according to the appropriate

due dates, or as directed by a planner.The NPM system will also provide for continuous

monitoring

of surveillance

tests and preventive

maintenance

work to meet regulatory

or plant requirements.

Once the repetitive

or preventive

maintenance

Job Orders are created, they are available for reviews and executions

in the same manner as any of the other Job Orders.This system will also be used to develop Job Orders for planned outages such as refueling outages.

Attachment

1 to AEP:NRC:1125A

Page 8 (2)Benefits To Be Derived From Corrective

Actions The data entered into the NPM system, and the processing

that the system does with this data, will eliminate the multiple manual data entry steps of our present process.Eliminating

redundant manual systems is of significance

itself.However, more importantly

are the anticipated

improvements

in plant availability

and labor productivity.

Along with improved ability to plan and schedule work comes an increased amount of time available for more careful consideration

of other aspects of the work to be performed, for example, personnel safety.Improvements

can be expected and will certainly be strived for.The NPM system will also identify and coordinate

maintenance

on related equipment and systems, thus decreasing

down time on components

removed from service.Quick access to the information

in the NPM data bases makes the supervisors

in both the operations

and maintenance

areas more aware of Job Order progress.It is anticipated

that the NPM system w'ill help us realize our goal of a non-outage

corrective

maintenance

job order backlog not in excess of 90 days.(3)Date When Benefits Will Be Achieved We currently anticipate

having the computerized

automated maintenance

system in place and operational

by August 1990.At that time, data validation

and loading, procedure changes and training of personnel will begin.

Attachment

1 to AEP:NRC:1125A

Page 9 NRC-Identified

Weakness (4)"Poor material condition especially

as evidenced by the high number of oil, steam and water leaks." Response to Weakness (1)Corrective

Actions Taken While it is AEPSC's policy to keep all of its facilities, in good material condition, we recognize the need for improvement

in this area.As a result, the management

of the Cook Nuclear Plant has launched a concerted effort to improve plant material condition.

This is evidenced by the allocation

of funds to support the following physical improvements

that are currently taking place: o Auxiliary building painting o Contaminated

equipment storage area expansion I o Decontamination

area redesign o Improved lighting o Installation

of 18 personnel whole body contamination

monitors It is Cook Nuclear Plant policy that no leak is considered

acceptable.

Consequently, during the 1988/1989 refueling outages we refurbished

about 1,780 valves and packed them with Chesterton

packing.A breakdown of this effort is as follows: Unit 1 Unit 2 Total Auxiliary Building Containment

Turbine Hall Miscellaneous

254 130 225 21 150 280 700 925 50 71 250 504 Nevertheless, a substantial

number of leaks still exist in the auxiliary building, ranging from small traces of dried boric acid to dripping.These leaks have been entered into a computer data base, have been chalked down, and job orders have been written.The leaks are currently being prioritized

and efforts will be made to repair them during the next refueling outage, if not before.

Attachment

1 to AEP:NRC:1125A

Page 10 The plant manager has reaffirmed

his commitment

to good plant material condition and personal accountability

by sending a memorandum

to each employee.This commitment

has been supported by continued radiation worker awareness training, and operator training on venting and draining.In addition, decontamination

efforts continue, which have already reduced the contaminated

area from approximately

45,000 feet in 1986 to the current 25,000 feet (excluding

laydown areas).Our goal is to reduce these contaminated

areas to 20,000 square feet in 1990 and 10,000 square feet prior to the outage in 1991.(2)Benefits To Be Derived from Corrective

Actions There are numerous benefits gained from having the plant in good physical condition, the most important of these being increased plant safety and reliability.

A related benefit is improved radiation protection

and worker safety.However, another important, but less quantifiable

benefit is the improvement

to worker morale.(3)Date When Benefits Will Be Realized While maintaining

the plant in good physical condition is an ongoing process, we anticipate

major improvements

within the next year.The refueling outage will facilitate

the refurbishment

of valises, as well as other repairs and modifications.

Attachment

1 to AEP:NRC:1125A

Page 11 NRC-Identified

Weakness (5)"Inadequate

trending, root cause analysis and action to correct, for example, numerous leaking safety relief valves." Response to Weakness (1)Corrective

Actions Taken This weakness is being addressed by three programs: the NPM system which is discussed in detail in our response to weaknesses

(1)and (3), the System Engineer Program, discussed in our response to weakness (1), and the RCM Program discussed in our response to weakness (1).(2)Benefits To Be Derived from Corrective

Actions The NPM system will provide for a complete component history.The component history will provide a chronological

listing of work, modifications

or inspections

that have been performed on a particular

component.

This process creates an indexed historical

record for components

or functional

equipment groups and catalogs completion

dates, failure codes, as-found and as-left conditions, parts replaced, test results, etc.The System Engineers are expected to identify and trend appropriate

system parameters, with the goal of obtaining pertinent data for system performance

and reliability

monitoring.

The parameters

trended shall be periodically

reviewed and approved to allow timely preventive

or corrective

actions to be implemented.

Based on the trended data, the System Engineer is expected to recognize significant

system/component

degradation

or abnormal operating conditions

from both a historical

basis, as well as current status.The System Engineer may require the support of technical experts to analyze specific areas of concern and will work closely with our Corporate Nuclear Engineering

Division engineers in this regard.The System Engineers are expected to perform root cause analyses on the systems assigned.Consequently, the System Engineers will be trained in root cause analysis.In addition, the System Engineer is expected to: Evaluate system/component

failure impact on plant safety and unit power operations

Prepare and perform special system/component

performance

tests.

Attachment

1 to AEP:NRC:1125A

Page 12 The RCM Program wt.ll contribute

to resolving this issue by identifying

dominant failure modes and critical components.

(3)Date When Benefits Will Be Realized As previously

stated, we expect the NPM system to be in place and operational

in August 1990.At that time, personnel training and data loading will begin.Several system engineers have been assigned at Cook Nuclear Plant and benefits have already been realized from this program.An effort is currently being made to recruit System Engineers.

However, we anticipate

it will take at least a year before the program is fully staffed.

Attachment

1 to AEP:NRC:1125A

Page 13 NRC-Identified

Weakness (6)"In several instances procedures

were not followed, were poor or did not exist especially

in the balance of plant area." Response to Weakness (1)Corrective

Actions Taken Key to the safe and efficient operation of any nuclear power plant is strict adherence to procedures.

As such, employees are shown during the Nuclear General Employee Training (NGET)classes, a videotape of David Williams, Jr., Senior Executive V.P., Engineering

and Construction, mandating the adherence to procedures.

It is AEPSC's long-standing

policy that failure to follow procedures

will result in disciplinary

action.In order for this policy to have any benefit, well-written

and accurate procedures

must be in place.Consequently, AEPSC is purchasing

PRONET and the services of consultant

procedure writers to upgrade or write 690 maintenance

procedures

(268 maintenance, 422 I&C).Critical balance of plant components

will be addressed as they arise in the RCM program.The Maintenance

Improvement

Plan provides guidance that clearly defines what procedure compliance

is.In addition, a procedure writer'/user's

guide will address the circumstances

for changing a procedure to ensure procedural

compliance.

(2)Benefits To Be Derived from Corrective

Actions PRONET is a state of the art computer system that integrates

writer's guidelines, word processing, graphics and data base functions into a centralized

procedure management

system.Development, commitment, scheduling

and reporting functions will be controlled

by this menu-driven

network.This integrated

approach will result in a program that reduces development

time and provides efficient long-term procedure maintenance

and commitment/reference

tracking.(3)Date When Benefits Will Be Realized Although a consultant

will train plant staff on the use of PRONET, the bulk of the procedure upgrade work will be performed by consultant

personnel.

By using contract workers we will not impact the plant staff.If the existing staff were used, it is anticipated

that the effort would take four to five years.This is considered

to be an unacceptable

time frame for this work.By using contract workers, we will obtain professionally

prepared procedures

in a reasonable

time frame.The effort is scheduled to be completed by December 1991.

ATTACHMENT

2 TO AEP:NRC:1125A

RESPONSE TO NRC-IDENTIFIED

VIOLATIONS

Attachment

2 to AEP:NRC:1125A

Page 1 NRC Violation 1"10 CFR 50, Appendix B, Criterion V, as implemented

by Section 1.7.5 of the Donald C.Cook Nuclear Plant Operational

Quality Assurance Program requires that activities

related to quality be prescribed

by documented

instructions, procedures, and drawings, that those activities

be accomplished

in accordance

with those instructions, procedures

and drawings, and that instructions, procedures

or drawings include appropriate

quantitative

or qualitative

acceptance

criteria for determining

that important activt,ties

have been satisfactorily

accomplished.

a~Procedure PMI-2290,"Job Orders," Revision 8, required in Sections 4.4.8 and 4.4.8.3 that upon completion

of the physical work, the job order tags be removed and discarded.

Contrary to the abo~e, tags 15119, 029643, B012209, B016950, B016832, and B017240 were not removed although the job orders were cancelled or completed.

As a result, status of equipment condi.tion

remained indeterminate

(315/89031-01A;

316/89031-01A)

~b.Request For Change 12-2180 required installation

of 200%overload motor protection

and that the thermal overload be set at the low trip current rating.Contrary to the above, on December 19, 1989, the inspectors

observed that the thermal overload heater associated

with residual heat removal loop isolation motor-operated

valve ICM-111 was set at the high trip current rating.Numerous additional

thermal overloads in the diesel generator motor control center were also observed to be the wrong size or set at the wrong current rating, which will result in premature removal of operating voltage from the motors (315/89031-01B;

316/89031-01B)

~c~Procedure PMI-2030,"Document Control," Revision 10, failed to include requirements

for the Master Drawing Indexes to be reviewed by intended users for the latest as built drawings located in the plant master file.Consequently, drawings issued by the document control center for field verifications

were not the latest as built drawings or revisions (315/89031-01C;

316/89031/01C).

The"Pump Operator's

Data" manual and the vendor manual for'he Auxiliary Feedwater (AFV)pump required that the pump packing be adjusted while the pump is operating.

Contrary to the above, this requirement

was not incorporated

into the AFV maintenance

procdures[sic).Although no problems were noted, inadequate

attention to this requirement

could result in rotor seizure, scored shaft sleeves, or burned packing (315/89031-01D;

316/89031-01D).

Attachment

2 to AEP:NRC:1125A

Page 2 Procedure 12 THP 6030 IMP.014"Protective

Relay Calibration", Revision 8, Step 8.1.2-2 specified that black electrical

tape be used when cleaning the disk and drag magnet mechanism on Time Overcurrent (IAC)relays.Contrary to the above, on December 5, 1989, a technician

was observed using an unused calibration

sticker to clean the 2AB EDG Time Overcurrent

test relay.As a result, cleanliness

of the contacts was questionable

(315/89031-01E;

316/89031-01E).

f.Procedure PMI-2010"Plant Manager and Department

Head Instructions, Procedures

and Index," Revision 17, Policy Statement 3.1, Section 3 required that"double asterisked" procedures

for plant activities

be"in-hand" when implementing

the procedure.

Contrary to the above, on December 6, 1989, the inspector observed an operator rack in"2A" Train Reactor Trip Bypass Breaker without having"in hand" double asterisked

procedure~12-OHP 4021.082.018"Racking In and Out Reactor Trip, Reactor Trip Bypass and MG Set Output Breakers," Revision 2.Even though no adverse affects were noted, in the past under similar circumstances, a reactor trip occurred (315/89031-01F;

316/89031-01F).

Procedure PMI-2010,"Plant Manager and Department

Head Instructions, Procedures

and Index," Revision 17, requires in Section 3.14.1 that all effective instructions

and procedures

be reviewed no less frequent than once every two years.Contrary to the above, maintenance

procedure MHI 2070, MHI 7090, PMI 4050, 12 THP 6030 IMP~071, and 12 THP IMP.062 were not reviewed in the last two years.As a result, the procedures

were not updated to reflect feedback and changes to preventive

maintenance

activities

(315/89031-01G;

316/89031-1G)." Response to Violation la Plant procedure PMI-2290 requires that tags placed at or near equipment needing repair be removed when the item is repaired or if the Job Order is cancelled.

As noted in the text, six Job Order tags were found in the plant for work that had been cancelled or completed which constitutes

failure to follow procedure.

The conclusion

made in Inspection

Report 89031 was that equipment status was"indeterminate." While the presence of Job Order tags was contrary to the requirements

of PMI-2290, the status of equipment/components

involved would not be affected.The information

placed on a tag identifies

to personnel 1)that a Job Order has been written for repair with number noted, 2)the nature of repairs/adjustments

required as determined

by the person initiating

the Job Order and 3)helps locate the specific component.

By itself, a Job Order tag has no impact on system or equipment operability, does

Attachment

2 to AEP:NRC.:1125A

Page 3 not indicate that equipment has been tagged out, and does not direct any other activity involving the equipment.

Other systems such as the clearance permit system logs and the deficiency

logs indicate the equipment status.(1)Corrective

Action Taken and Results Achieved Job Order tags identified

during the inspection

were subsequently

removed to achieve compliance

with applicable

sections of PMI-2290.(2)Corrective

Action Taken To Avoid Further Violation The Plant Manager will i.ssue a memo on procedural

compliance

to ensure that all personnel are fully aware of the meaning of compliance, consequences

of failure and what actions to take~when a procedure cannot be followed as written.The Maintenance

Improvement

Plan includes issuance of a department

policy on procedure compliance.

Included will be guidance on the monitoring

of the effectiveness

of procedure compliance.

Also a procedure writer'/user's

guide will address the circumstances

for changing a procedure to ensure procedural

compliance.

(3)Date When Full Com liance Will Be Achieved The final draft of the policy will be issued on July 15, 1990.Guidance on the effectiveness

monitoring

will be issued on August 15, 1990.The Plant Manager's memo will be issued on May 1, 1990.Response to Violation lb The Notice of Violation identified

that thermal overloads in the plant had been installed at an incorrect trip current rating.As a result of the inspection, plant personnel investigated

the problem and addressed it in Problem Report 90-81.(1)Corrective

Action Taken and Results Achieved The improper positioning

and/or mis-sizing

of the overload heaters resulted from errors made during initial installations.

Twenty overloads were inspected and evaluated by plant and AEPSC engineers.

Eleven were found to b'e correct.One was found on a breaker for a resistive heater where overload protection

was not considered

critical as molded case circuit breakers protection

was provided.On four breakers (including

ICM-111)the as-found heater size agreed with the calculated, but arrow position did not agree.Full load amps was at the dividing point for selecting up or down posi.tion.

Slight changes in motor protection

resulted but did not affect the operability

of load.Four feeders on BOP were found to be mis-sized.

Of those four

Attachment

2 to AEP:NRC:1125A-Page 4 one was mis-sized to a degree that replacement

was needed to ensure adequate protection.

Of the three other overload heaters, though improperly

set, would have provided thermal overload protection

for equipment.

Job Orders to correct these settings by October 30, 1990, have been written.(2)Corrective

Action Taken To Avoid Further Violation In the course of the plant's investigation

it was determined

that the mis-sizing

and/or mispositioning

of the thermal overloads had occurred during initial installation

in 1977 and 1978.Lacking vendor information, calculations

were most likely developed by plant personnel for positions/sizes

which in some of the cases, proved incorrect.

The design change process has evolved since that time to a level that reasonably

ensures that repetition

of a similar condition will not occur.Specifically, general procedures

now require that design calculations

be verified and documented

by qualified personnel.

(3)Date When Full Com liance Will Be Achieved Based on the engineering

evaluation

completed January 15,'990, the deficiencies

in the thermal overload heater settings would not have affected the operability

of the ICM-111 breaker.Other deficiencies

did not degrade the thermal overload protection

of the equipment breakers.Current procedures/practices

should prevent recurrence

of this problem.Response to Violation lc In the course of the inspection

it was found that a plant instruction

utilized for document control (drawings)

contained no provision mandating that the user of the index verify that it was the most recent update.We concur with the inspector's

conclusion

that an instruction

to users of the Master Drawing Index to ensure that it references

up-to-date

as-built drawings should be included in procedures.

(1)Corrective

Action Taken and Results Achieved As a result of the inspection, PMI-2030,"Document Control," was revised to instruct a Master Data Index user to ensure that it reflects the latest as-built drawings located in the plant's master file.(2)Corrective

Action Taken To Avoid Further Violation Revision 11 to PMI-2030 is being routed for approval from plant management.

The revision addresses the inspector's

concern noted in the Notice of Violation.

I Attachment

2 to AEP:NRC:1125A

Page 5 (3)Date When Full Com lienee Will Be Achieved The revised version of PMI-2030 will be effective by May 1, 1990.Response to Violation ld Procedural

revision to incorporate

a direction to run a pump in order to properly adjust packing is not viewed as necessary.

Personnel performing

packing adjustments

meet the requirements

of ANSI Standard N18-1 (4.5.3).Consistent

with that standard, maintenance

personnel receive formal training in subjects associated

with their position.Included in the plant's training is a course on pumps that directly references

the correct methodology

for adjusting the packing on pumps.This teaches maintenance

personnel that adjustments

will only be made to packing when the pump is operating.

As required by ANSI Standard N18-7, Section 4.1 (2), plant procedures

are developed with the objective of providing adequate information

to personnel involved in a given task considering

the skill they are provided through the training program.(1)Corrective

Action Taken and Results Achieved Those persons who would be involved in pump packing work are hired and trained consistent

with ANSI N18-1.(2)Corrective

Action Taken to Avoid Further Violation The hiring practices and training programs have proven adequate to prevent problems due to pump packing (3)Date When Full Com liance Will Be Achieved No violation occurred as practices are in accordance

with N18-1 and personnel are fully qualified.

Response to Violation le While the intent of Step 8.1.2-2 of maintenance

procedure 12 THP 6030.IMP.014

was to ensure that technicians

performing

cleaning would utilize tape or similar adhesive-backed

material.Black electrical

tape, was specified because it is a commonly available item.However, use of a calibration

sticker did-constitute

a violation of the procedure as written.(1)Corrective

Action Taken and Results Achieved Maintenance

supervision

reviewed the net effect of utilizing the sticker in the course of cleaning and determined

that satisfactory

results were obtained.No re-cleaning

was deemed

Attachment

2 to AEP:NRC:1125A

Page 6 necessary.

12 THP 6030.IMP.014

had been revised via a change sheet initiated April 2, 1990, to remove reference to black electrical

tape.(2)Corrective

Action Taken To Avoid Further Violation The Plant Manager will issue a memo on procedural

compliance

to ensure that all personnel are fully aware of the meaning of compliance, consequences

of failure and what actions to take when a procedure cannot be followed as written.The Maintenance

Improvement

Plan includes issuance of a department

policy on procedure compliance.

Included will be guidance on the monitoring

of the effectiveness

of procedure compliance.

Also a procedure writer'/user's

guide will address the circumstances

for changing a procedure to ensure procedural

compliance.

(3)Date When Full Com lienee Will Be Achieved The final draft of the policy will be issued on July 15, 1990.Guidance on the effectiveness

monitoring

will be issued on August 15, 1990.The Plant Manager's memo will be issued on May 1, 1990.Response to Violation lf (1)Corrective

Action Taken and Results Achieved The Auxiliary Equipment Operator (AEO)involved in this event had received training on the operation of reactor trip breakers and the existence of the procedure prior to this event.The AEO, however, overlooked

the reactor trip breaker procedure was required to be"in hand" whenever performing

racking operations.

Although the racking evolution was done in accordance

with the.procedure requirements, this event was a violation because the requirement

to have the procedure"in hand" was not satisfied.

A memorandum

was issued to Operations

personnel on January 19, 1990, to remind them of the"in hand" requirement

for the reactor trip breaker procedure.

(2)Corrective

Action To Be Taken To Avoid Further Violation The routine surveillance

procedures

for reactor trip breaker testing were revised on December 13, 1989, to reference the requirement

for having the reactor trip breaker racking procedure"in hand" for the racking evolutions.

The startup surveillance

procedures, which require racking of the reactor trip breakers, will be revised by June 4, 1990, to reference the requirement

for having the reactor trip breaker procedure"in hand."

Attachment

2 to AEP:NRC:1125A

Page 7 During the concluded, procedures

Therefore, past two years, QA audits/surveillances

have except for a"few isolated cases," double asterisked

have in fact been"in hand" when required.no generic programmatic

problem exists.(3)Date When Full Com liance Will Be Achieved Full compliance

was achieved on December 6, 1989, when the'involved AEO was reinstructed

of the"in hand" procedural

requirement.

Response to Violation lg Five procedures/instructions

were cited in the Notice of Violation as not having been reviewed within the two-year limit established

in plant procedure PMI-2010.However, in each case the documents had been reviewed and documentation

to that effect was on file.Upon request one of the inspectors

was provided with biannual review documents for IMP.071 and IMP.062.The instruction

does not require an approved revision within two.years, only a review prior to such revision.This information

may not have been adequately

communicated.

(1)Corrective

Action Taken and Results Achieved Further review of the Notice of Violation by the plant identified

that procedures/instructions

noted had received review as required by PMI-2010, Rev.17.(2)Corrective

Action Taken to Avoid Further Violation Tracking and review of procedures

is presently adequate.(3)Date When Full Com liance Will Be Achieved No violation occurred.

Attachment

2 to AEP:NRC:1125A

Page 8 NRC Violation 2"10 CFR 50, Appendix B, Criterion VIII, as implemented

by Section 1.7.8 of the Donald CD Cook Operational

Quality Assurance Program required that measures be established

for the identification

of materials, parts and components

such as by part number, serial number, or other appropriate

means on the item or records traceable to the item throughout

fabrication, installation

and use of the item.""Contrary to the above, identification

of materials and components

for traceability

was not accomplished

for cable extension portions and aluminum splicing sleeves for connections

to several safety-related

motor control centers installed under the Request For Change 1482 modification

(315/89031-02;

316/89031-02)." Response to Violation 2 RFC-1482 installed transition

pieces (sleeves)to splice copper to aluminum cables in various motor control centers.Per RFC instructions, the transition

pieces were to be installed in accordance

with Engineering

Design Specification (EDS)607 and EDS 608'he installation

took place between June of 1979 and September of 1981 when the final summary was issued.A search of the completed RFC package (including

installation

job orders)and of the microfilm of the completed job order packages revealed no documentation

of the parts (sleeves)used for the installation.

Individuals

who were involved with the Maintenance

Department

at that time stated that personnel would have installed the transition

pieces per the EDS as stated in the RFC.Inadequate

documentation

of material installed by a Job Order during the design change process was the root cause of this violation.

Additionally, there were inadequate

review of the completed job orders and the design change package upon completion.

(1)Corrective

Action Taken and Results Achieved The installation

took place approximately

10 years ago and was performed in accordance

with EDS 608, which was referenced

in the RFC package.Actual application

for the past ten years has functionally

demonstrated

the adequacy of subject materials'

Attachment

2 to AEP:NRC:1125A

Page 9 (2)Corrective

Action Taken To Avoid Further Violation Current procurement/dedication

practices ensure proper documentation

is developed to demonstrate

control over the suitability

of material, parts and components.

(3)Date When Full Com liance Will Be Achieved Current procedures/practice's

should prevent recurrence

of this problem and ensure future compliance.

Attachment

2 to AEP:NRC:1125A

Page 10 NRC Violation 3"10 CFR 50, Appendix B, Criterion XI, as implemented

by Section 1.7.11 of the Donald C.Cook Operational

Quality Assurance Program required that a test program be established

to assure testing to demonstrate

that systems and components

will perform satisfactorily

in service in accordance

with test procedures

which incorporate

requirements

and acceptance

limits contained in applicable

design documents, and that adequate test instrumentation

was available and used.""Contrary to the above, test instruments

were not sensitive or accurate enough to verify the calibration

of the undervoltage

relays that actuate the Emergency Diesel Generators.

Procedure 2 THP 6030 IMP.250,"4kV Diesel Start, 4kV ESS Bus Undervoltage

Relay Calibration," Revision 7, Section 3.0, required the use of a Westinghouse

type PA-161 AC anolog[sic]voltmeter or its equivalent

with equal or better accuracy and adequate range to measure the desired parameters.

However, the voltmeter had a tolerance of+1.5 volts that was not sufficiently

accurate to measure the desired parameter of 90.3 to 91.8 volts specified in Technical Specification 3.3.2.In addition, the voltmeter indicated to the nearest whole volt and did not have division markings between the numbers.Technicians

had to interpolate

results and record values to the nearest tenth of a volt while the voltmeter's

dial indicator was moving in the increasing

or decreasing

direction.

Furthermore, the technicians

used hand signals to communicate

the moment the under voltage relay operated.Based on the inaccuracy

and insensitivity

of the voltmeter, and poor testing technique, results of the undervoltage

test were not conclusive

(315/89031-03;

316/89031-03)." Response to Violation 3 The meter used was first specified in the original procedure developed before initial plant start-up.The specific reasons for using this meter could not be determined.

However, it is believed that this was the limit of the available technology

at that time.The only other meter available was a basic digital type, which could not be used due to the inherently

slow response and update time, causing a greater uncertainty

of specific setpoint value than the analog meter.

Attachment

2 to AEP:NRC:1125A

Page 11 (1)Corrective

Actions and Results Achieved Z&C now uses the Fluke Model 45 digital meter during testing of the 4KV diesel start and 4KV ESS bus undervoltage

relays.Recent developments

in digital meters which include faster response times and update times and minimum/maximum

modifier features has made their use acceptable.

The digital meter currently being used has an accuracy of+0.3 percent.The previous test method provided acceptable

results, based on the as-found values on the first use of the digital meters being in specification

by comparable

percentages.'2)

Corrective

Actions Taken To Avoid Further Violation The calibration

procedures

which currently allow use of either analog or digital meters will be changed to specify the use of the Fluke Model 45 digital meter, or its equivalent, to ensure consistent

use of a digital meter.(3)Date When Full Com lienee Will Be Achieved The procedure changes will be completed before April 30, 1990.

~~

Attachment

2 to AEP:NRC:1125A

Page 12 NRC.Violation 4"10 CFR 50, Appendix B, Criterion XVI, as implemented

in Section 1.7.16 of the Donald C.Cook Operational

Quality Assurance Program required that measures be established

to assure that conditions

adverse to quality were promptly identified

and corrected.

In the case of significant

conditions

adverse to quality, the measures shall assure that the cause of the condition was determined

and corrective

action taken to preclude repetition."Contrary to the above: The Plant Assessment

Group Committee's

review in March 1989 for Problem Report 89-245, concerned with the February 1989 failure of two safety-related

4kV breakers T-11D6 and T-1104 to close on demand during tests due to lubrication

hardening, failed to specify corrective

action to prevent recurrence.

Furthermore, no action was taken to inspect other 4kV breakers for common mode failure.Consequently, in March and April of 1989 seven additional

safety related and balance of plant breakers failed to close during testing, which was also caused by hardening of the lubricant on the breaker linkage (315/89031-04A;

316/89031-04A).

b.Corrective

action was neither prompt nor adequate to correct maintenance

related'roblems

identified

by the licensee in February 1988.In December 1989, 36 of these 71 self identified

findings and recommendations

were reopened.During this inspection

many of the same problems were identified

that reflect a significant

weakness in the corrective

action system (315/89031-04B;

316/89031-04B)." Response to Violation 4a Based on review of Problem Report 89-245, which was addressed in the Notice of Violation it is our position that no actual violation occurred.The February 27, 1989, condition was identified

during scheduled'preventive

maintenance

work and resulted in the problem report.That discovery, coupled with a similar condition also found during preventive

maintenance, resulted in a Part 21 report.The Part 21 investigation

revealed that vendor-specified

information

contained no instruction

for periodic lubrication

of the breakers.Similar breakers used in the plant had, until that time, passed test requirements'he

plant's actions which were taken promptly, included revision of the procedure based on new input from the manufacturer, initiation

of Job Orders to inspect all other similar breakers installed in both units, and establishment

of scheduled inspections

to identify possible repetition

of the

C.I 1

Attachment

2 to AEP:NRC:1125A

Page 13 condition in the future.The Notice of Violation incorrectly

concluded that no action was taken to inspect additional

breakers or develop corrective

action.Two subsequent

problem reports were initiated as a result of deficiencies

found in the inspections

and tests covered by our expanded action for Problem Report 89-245 and the associated

Part 21 review.Those reports were initiated to document the similar conditions

on the noted breakers.Within two months of the March 1, 1989, Part 21 report to the NRC, the plant had completed the inspections, cleaned and relubricated

the breakers in both units as recommended

by the revised vendor information, and documented

each case when a similar condition was found.(1)Corrective

Action Taken and Results Achieved The result of Problem Report 89-245, which was reviewed by the Plant Assessment

Group on March 17, 1989, was to inspect, clean and lubricate similar breakers in both units and document the results.(2)Corrective

Action Taken to Avoid Further Violation Procedure changes and inspections

were scheduled as a result of addressing

the problem reported in Problem Report 89-245 on similar breakers.These actions generated additional

Job Orders and condition reports which were referenced

in the inspection

report.(3)Date When Full Com liance Will Be Achieved No violation occurred.Response to Violation 4b As discussed in our response to Weakness (1), AEP has taken numerous corrective

actions to address the problems identified

by the Maintenance

Self-Assessment.

These actions include: o the development

of a RCM Program o the acquisition

of the Nuclear Plant Maintenance (NPM)Module o the development

of a System Engineer Program o the acquisition

of NUS's PRONET and the servt.ces of NUS's procedure writers.

Attachment

2 to AEP:NRC:1125A

Page 14 In order to effectively

implement programs as encompassing

and comprehensive

as these, significant

analysis, planning and coordination

are needed.As such, it will take several years to completely

implement some of the corrective

actions we have initiated.

(1)Corrective

Actions and Results Achieved Maintenance-related

problems identified

in the Maintenance

Self-Assessment

will be reviewed and resolved as appropriate, with implementation

of the Maintenance

Improvement

Plan.(2)Corrective

Actions Taken to Avoid Further Violation The Improvement

Plan includes milestones

and a built-in mechanism that requires regular re-evaluation

of the plan and monitoring

of its effectiveness

to ensure that it is providing the desired results and that there is continuing

improvement

in all maintenance-related

areas'3)Date When Full Com liance Will Be Achieved Resolution

and documentation

of the identified

items will be completed by June 1, 1991.