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)

See also: IR 05000315/1988024

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 to 881201 ltr re violations

noted in Insp Repts 50-315/88-24

&50-316/88-28.

DISTRIBUTION

CODE: IEOID COPIES RECEIVED:LTR

I ENCL Q SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice

of Vi&o ation Response NOTES'ECIPIENT

ID CODE/NAME PD3-1 PD INTERNAL: AEOD DEDRO NRR/DEST DIR NRR/DLPQ/QAB

10 NRR/DREP/EPB

10 NRR/DRIS DIR 9A NUDOCS-ABSTRACT

OGC/HDS1 RGN3 FILE 01 EXTERNAL: LPDR NSIC COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME STANG,J AEOD/DEIIB

NRR SHANKMAN,S

NRR/DLPQ/PEB

ll NRR/DOEA DIR 11 NRR/DREP/RPB

10 NRR/PMAS/ILRB12

OE LIEBERMAN,J

~TED~02 NRC PDR RESL MARTIN,D COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 2 2 1 1 1 1 1 1 1 1 1 1 NOTE IO ALL"RZre" RECIPrWrS~PLEASE HELP US'IO REDUCE WASTE!CXWI'ACT'IHE DOCVMEhZ CXNIROL DESK, RDQM Pl-37 (EXT.20079)%0 EXZKOXR YOUR NAME PKH DIPX1UBUTIGN

LISTS KE KGCBKNIS YOU DCNPT NEED)D S 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 ADGCK 050003/~Q 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 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 Permits'~" 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 fulfill their 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.