ML17325B085

Responds to NRC 881201 Ltr Re Violations Noted in Insp Repts 50-315/88-24 & 50-316/88-28.Corrective Actions:Actions in Progress to Reemphasize Fire Watch Personnel Responsibilities While Performing Fire Watches

ML17325B085
Person / Time
Site:	Cook
Issue date:	01/04/1989
From:	Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Davis A NRC, NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
AEP:NRC:1060M, NUDOCS 8901130235
Download: ML17325B085 (7)

Text

'.CCELKRATED 91FI'KBUTJON DEMONSTRA.T10Yi SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ESSION NBR:8901130235 DOC.DATE: 89/01/04 NOTARIZED: NO FACIL:50-315 Donald C. Cook Nuclear Power Plant, Unit 1, Indiana &

50-316 Donald C. Cook Nuclear Power Plant, Unit 2, Indiana &

AUTH. NAME AUTHOR AFFILIATION ALEXICH,M.P. Indiana Michigan Power Co. (formerly Indiana & Michigan Ele RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds 50-315/88-24 to 881201 ltr re violations noted in Insp Repts 50-316/88-28.

DISTRIBUTION CODE: IEOID TITLE: General COPIES RECEIVED:LTR (50 Dkt) -Insp Rept/Notice of I

Vi&o ENCL ation Q SIZE:

Response

NOTES'ECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD3-1 PD 1 1 STANG,J 1 1 INTERNAL: AEOD 1 1 AEOD/DEIIB 1 1 DEDRO NRR/DEST DIR NRR/DLPQ/QAB 10 1

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NRR/DREP/EPB 10 1 1 NRR/DREP/RPB 10 2 2 NRR/DRIS DIR 9A 1 1 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 OE LIEBERMAN,J 1 1 OGC/HDS1 1 1 ~TED~ 02 1 1 RGN3 FILE 01 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 RESL MARTIN,D 1 1 D

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TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24 I

Indiana ISchigan Power Company P.O. Box 16631 Columbus, OH >32'6 INDIANA MICHIGAN POWER AEP:NRC:1060M Donald C. Cook Nuclear Plant Units 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 INSPECTION REPORTS 50-315/88024 (DRP) AND 50-316/88028 (DRP); RESPONSE TO VIOLATION U.S. Nuclear Regulatory Conunission Attn: Document Control Desk Washington, D.C. 20555 Attn: A. B. Davis January 4, 1989

Dear Mr. Davis:

This letter is in response to Mr. W. L. Axelson's letter of December 1, 1988, that forwarded the report on the routine safety inspection conducted on September 22 through November 16, 1988, on activities at the Cook Nuclear Plant Units 1 and 2 ~ The Notice of Violation attached to Mr. Axelson's letter identified one violation, which is addressed in the attachment to this letter.

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. Alexich Vice President ldp Attachment cc: D. H. Williams, Jr.

W. G. Smith, Jr. - Bridgman R. C. Callen G. Charnoff NRC Resident Inspector - Bridgman G. Bruchmann 8901 13023~( ~~90104 PDR Q

ADGCK 050003/~

PDC

45 ATTACHMENT TO AEP:NRC:1060M RESPONSE TO VIOLATION

Attachment to AEP:NRC:1060M Page 1 Violation "Unit 2 Technical Specification 6.8.1.f requires procedures to be implemented covering the Fire Protection Program.

Safety Procedure SP-03.00, "Hot Work Permits" is such a procedure. It requires that fire watches shall be present, with a fire extinguisher in their possession, during and for 30 minutes'fter any hot work for which the Permit specifies a fire watch.

Contrary to the above, at approximately 11:00 a.m. on October 28, 1988, no fire watch was present covering welding of a Unistrut attachment on steam generator No. 21, under Hot. Work Permit No. 1247, even though the Permit specified a fire watch.

This is a Severity Level IV violation (Supplement I)."

1.0 Res onse to Violation The failure to post a fire watch cited in the NRC Notice of Violation occurred during the performance of welding as part of the Steam Generator Repair Project (SGRP) at Cook Nuclear Plant Unit 2. The SGRP involved various hot work activities requiring fire watch personnel. Our SGRP contractor, MK-Ferguson, is responsible for Permits' the actual performance of this work under the supervision of MK-Ferguson's safety supervisor who has the responsibility to ensure that the work is performed in accordance with MK-Ferguson's Safety Procedure SP-03.00, "Hot Work " SGRP fire watch personnel are assigned to MK-Ferguson to provide the required fire watches and to respond to potential fire situations.

Before performance of hot work, the MK-Ferguson safety supervisor completes the hot work permit required by procedure SP-03.00 and notifies the SGRP fire watch supervisor if a fire watch is necessary in order to have fire watch personnel assigned to the job. In the case of the cited violation, the need for a fire watch was properly communicated to the SGRP fire watch supervisor by the MK-Ferguson safety supervisor and a fire watch was assigned.

However the fire watch left his assigned station before completion of the hot work. This was in violation of Safety Procedure SP-03.00.

2.0 Corrective Action Taken and Results Achieved Prior to the October 28, 1988 violation, actions were in progress to reemphasize to fire watch personnel their responsibilities while performing fire watches, including the requirements for the operability and use of fire extinguishers ~ In addition, as part of these ongoing

Attachment to AEP:NRC:1060M Page 2 actions, a second SGRP fire watch supervisor was added to each shift to further ensure that SGRP fire watch personnel properly fulfilltheir responsibilities in monitoring hot work activities. The Cook Nuclear Plant Fire Protection Coordinator, MK-Ferguson safety supervisors, SGRP fire watch supervisors and SGRP fire watches also met jointly to review hot work procedural requirements and the importance of maintaining attentiveness to assigned fire watch activities.

Increased monitoring performed since October 28 by SGRP fire watch supervision, MK-Ferguson safety supervisors and the Cook Nuclear Plant Fire Protection Coordinator has found proper fire watch coverage for all hot work activities observed at the SGRP.

3.0 Corrective Action to Avoid Further Violations To avoid further violations in this area, the following additional administrative controls have been initiated for the SGRP:

1. Shift meetings with MK-Ferguson safety supervisors and fire watch supervisors to discuss hot work activities and manpower requirements to ensure proper hot work coverage.

"2. Shift meetings with fire watch supervisors and fire watch personnel to review fire watch responsibilities and attentiveness to fire watch assignments and equipment.

3. Tours by the plant Fire Protection Coordinator to ensure proper manning and equipment exists at the site of hot work performance.

4.0 Date When Full Com liance Will Be Achieved The corrective actions discussed in Section 2.0 were completed November 16, 1988. Actions discussed in Section 3.0 will continue through the remaining period of performance of the SGRP.