ML17328A199

Responds to NRC Re Violations Noted in Insp Rept 50-315/89-20.Corrective Action:Administrative Requirements Procedure Reviewed to Include Verification That Acceptance Criteria Have Been Fulfilled Before Operation of Equipment

ML17328A199
Person / Time
Site:	Cook
Issue date:	10/13/1989
From:	Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AEP:NRC:1090K, NUDOCS 8910180322
Download: ML17328A199 (9)

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REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

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CESSION NBR: 8910180322

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DOC. DATE: 89/10/13 NOTARIZED: NO DOCKET ACIL:50-315 Donald C.

Cook Nuclear Power Plant, Unit 1, Indiana 05000315 AUTH.NAME AUTHOR AFFILIATION ALEXICH,M.P.

Indiana Michigan Power Co.

(formerly Indiana &'ichigan Ele RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC '890809 ltr re violations noted in Insp Rept 50-315/89-20.

DISTRIBUTION CODE.. IEOID COPIES RECEIVED.LTR J ENCL I SIZE.

TITLE: General (50 Dkt)-Insp Rept/Notice, of Violation Response NOTES

'ECIPIENT ID CODE/NAME PD3-1 PD INTERNAL: AEOD AEOD/TPAD NRR SHANKMAN,S NRR/DLPQ/PEB NRR/DREP/EPB 10

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1 RECIPIENT ID CODE/NAME GIITTER,J.

AEOD/DEIIB DEDRO NRR/DEST DIR NRR/DOEA DIR 11 NRR/DREP/RPB 10 NUDOCS-ABSTRACT OGC/HDS 1 RES MORISSEAUg D NRC PDR COPIES LTTR ENCL 1

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ENCL 23

Indiana Michigan Power Company P.O. Box 1663>

Cofufnbus, 0H 432 I6 lNEWAMA NiCHIGAN PMfER AEP:NRC:1090K Donald C.

Cook Nuclear Plant Unit 1 Docket No. 50-315 License No.

DPR-58 INSPECTION REPORT 50-315/89020;

RESPONSE

TO UNRESOLVED ITEM

'.S.

Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.

20555 Attn: A. B. Davis October 13, 1989

Dear Mr. Davis:

This letter. is in response to R.

W. Cooper's letter dated August 9, 1989, which forwarded the.report of the special safety inspection conducted from May 22 through May 25,

1989, and on July 7, 1989, on activities at Donald C.

Cook Nuclear Plant Unit 1.

Our letter (AEP:NRC:1090G) of September 8,

1989, responded to the severity level IV violation cited in the Notice of Violation attached to Mr. Cooper's letter.

Through subsequent

'discussions with your staff we understand that the originally cited level IV violation has been reduced-to severity level V, We appreciate your favorable consideration of our request in this area, Mr. Cooper's letter also requested a description of actions we have taken with regard to an unresolved item identified during the inspection.

Due to an oversight this information was not included as part of our September 8 response to the Notice of Violation.

The attachment to this letter provides the requested response to the unresolved item.

This 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. Alex ch Vice President ldp Attachment

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Mr. A. B. Davis AEP:NRC:1090K cc:

D. H. Williams, Jr, A. A. Blind - Bridgman R.

C. Callen G, Charnoff NRC Resident Inspector

- Bridgman NFEM Section Chief

Mr. A.

BE Davis AEP'NRC:1090K bc:

S. J.

Brewer/B.

P.

Lauzau T. 0. Argenta/R.

F. Kroeger P,

A. 'Barrett - w/o J.

G, Feinstein

- w/o M. L. Horvath - Bridgman - w/o J.

F

~ Kurgan - w/o J. J.

Markowsky J.

B. Shinnock - w/o S,

H. Steinhart/S.

P.

Hodge J. Giitter, NRC - Washington, D.C.

DC-N-6015.1 AEP:NRC:1090K

ATTACHMENT TO AEP:NRC: 1090K

RESPONSE

TO UNRESOLVED ITEM 315/89020-02

Attachment to AEP:NRC:1090K Page 1

NRC Unresolved Item During the Region,III inspection of maintenance activities performed on the Unit 1 CD emergency diesel, the following unresolved item was generated:

";..the inspector noted that the measurement of main bearing clearance for No. 4 bearing required by Paragraph 7.2.1 of Procedure 12MHP4030.STP.046, "Emergency Diesel Generator Syst: em 18 Month Inspection," Revision,l, was recorded as

.09.

The acceptance criteria specified in the procedure was

.007 to

.014.

The recorded value was more than six times the maximum allowed value.

This recorded deviation was not noted by licensee personnel prior to engine start or on subsequent reviews and therefore, there was no assurance that inspection requirements were met.

Based on discussions with the licensee, it appeared that the value was improperly recorded.

In

addition, because of the overspeed

problem, the bearing was changed and new measurements were taken.

These measurements were well within the specified tolerances.

Due to the bearing

change, no hardware problems were evident, however, it appeared that additional management attention should be provided.in this area as future incidents of this type could result in significant hardware damage.

This matter is unresolved pending review during a subsequent inspection (315/89020-02)."

Response-to Unresolved Item Our investigation of the instance cited in the unresolved item concluded that the initial main bearing clearance measurements were within the acceptance criteria but were incorrectly recorded in completing the maintenance procedure in that 0.09 inch was recorded versus the actual measured clearance of.009 inch, The decimal point in the recorded value was indistinct and the recorded value was therefore apparently misread during subsequent review.

Consequently, the error in the recorded value was not identified in the course of normal supervisory approval of the completed.

procedure, The unresolved item stated above also raised the more general issue of the adequacy of existing controls in ensuring that, following maintenance/inspection activities, equipment is not operated until it is confirmed that all hardware acceptance criteria have been satisfied.

We have reviewed our procedures of the type identified in the unresolved item and have confirmed that supervisory reviews of the completed procedures include verification that acceptance criteria have been fulfilled before equipment is operated.

Our review of the existing administrative requirements in this area has

. therefore concluded that 'the procedural controls presently in place are appropriate to minimize the potential for post-maintenance/

Attachment to AEP:NRC:1090K Page 2

inspection damage to equipment resulting from operation of the equipment before all acceptance criteria have been fulfilled.

We will, however, reemphasize to involved personnel the importance of

,accurate documentation of the completion of procedure steps and compliance with the requirements of existing procedures.

In

addition, we will monitor this area through our condition report s'stem to ensure that any adverse trends can be quickly identified and appropriate corrective action taken.