ML17332A404

Provides Response to Violations Noted in Insp Repts 50-315/94-18 & 50-316/94-18.Corrective Action:Request Tags Identified by Inspector as Not Being Removed Verified on 941027,to Have Since Been Removed

ML17332A404
Person / Time
Site:	Cook
Issue date:	11/16/1994
From:	Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AEP:NRC:12121, NUDOCS 9411220274
Download: ML17332A404 (10)

Text

!ACCELERATEDRIDS PROCESSING)

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ESSION NBR:9411220274 DOC.DATE: 94/11/16 NOTARIZED: YES DOCKET ACII~.50-315 Donald C.

Cook Nuclear Power Plant, Unit 1, Indiana M

05000315 50-316 Donald C.

Cook Nuclear Power Plant, Unit 2, Indiana M

05000316 AUTH.NAME AUTHOR AFFILIATION FITZPATRICK,E.

Indiana Michigan Power Co.

(formerly Indiana

& Michigan Ele RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Provides response to violations noted in Insp Repts 50-315/94-18

& 50-316/94-18.Corrective action:request tags identified by inspector as not being removed verified on 941027,to have since been removed.

DISTRIBUTION CODE:

IE01D COPIES RECEIVED LTR ENCL SIZE:

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

RECIPIENT ID CODE/NAME PD3-1 PD INTERNAL: AEOD/DEIB AEOD/S P D/RRAB DEDRO NRR/DORS/OEAB NRR/PMAS/IRCB-E OE DIR RGN3 FILE 01 ERNAL: LITCO BRYCE, J H

NRC PDR COPIES LTTR ENCL 1

1 1

1 1

1 1

1 1 '

1 1

1 1

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1 1

RECIPIENT ID CODE/NAME HICKMAN,J AEOD/SPD/RAB AEOD/ggC

~ILE'ENTE~R 02 NRR/DRCH/HHFB NUDOCS-ABSTRACT OGC/HDS2 NOAC COPIES LTTR ENCL 1

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1 VOTE TO ALL"RIDS" RECIPI E YTS:

PLEASE HELP US TO REDUCE KVASTE!CONTACI THE DOCL'iIEYTCONTROL DESK, ROOh I PI-37 (EXT. 504.2083

) TO ELDIIiATEYOUR iAiILFROil DISTRIBUTION LISTS I'OR DOCL'4IEi'I'S i'OU DOY"I' L'I D!

TOTAL NUMBER OF COPIES REQUIRED:

LTTR 18 ENCL 18

I

Indiana michigan Power Cnm~

I'.G. Bi~z 168'<

Cninmi)i.'s,OfI 4"'i' IMblANA marquee.'iVER AEP:NRC:1212I 10 CFR 2.201 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 REPORTS NOS. 50-315/94018 (DRP)

AND 50-316/94018 (DRP)

REPLY TO NOTICE OF VIOLATION U.

S. Nuclear Regulatory Commission Document Control Desk Washington, D.

C.

20555 Attn:

Mr. J.

B. Martin November 16, 199II

Dear Mr. Martin:

This letter is in response to a USNRC letter dated October 21,

1994, th'at forwarded a

notice of violation to Indiana Michigan Power Company.

The notice of violation contained one violation'dentified

'uring a routine safety inspection conducted by Messrs.

James A. Isom, David J. Hartland, D. L. Shepard, M. P. Huber, J.

F. Schapker, and C. N. Orsini from August 13 through September 23, 1994.

The violation is associated with the failure to remove action request tags upon resolution of the deficiencies documented on the tags.

Our reply to the notice of violation is provided in the attachment to this letter.

This letter is submitted pursuant to 10 CFR 50.54(f) and, as such, an oath statement is att'ached.

Sincerely, Vice President Attachments 9411220274 941116 PDR ADOCK 05000315 PDR gpwi I

Mr. J.

B. Martin AEP:NRC:12121 CC:

A. A. Blinds G. Charnoff NRC Resident Inspector NFEM Section Chief J.

R. Padgett W. T. Russell, NRC - Washington, D.C.

STATE OF OHIO)

COUNTY OF FRANKLIN)

E. E. Fitzpatrick, being duly sworn, deposes and says that he is the Vice President of licensee Indiana Michigan Power Company, that he has read the foregoing response to NRC INSPECTION REPORTS NOS. 50-315/94018 (DRP) AND 50-316/94018 (DRP), REPLY TO NOTICE OF VIOLATION and knows the contents thereof; and that said contents are true to the best of his knowledge and belief.

cM Subscribed snd sworn to before ne this ~sC day of 19~v NOTARY PUBLIC Pt7f t) tjIi

~

NOTARY FU"LIC. STATE. CF CHl0

ATTACHM1WZ TO AEP 'NRC: 1212I REPLY TO NOTICE OF VIOLATION

ATTAQKENT TO AEP:NRC: 1212I Page

1 Background

A routine safety inspection, was conducted by Messrs. J. A. Isom, D. J. Hartland, D. L. Shepard, M. P. Huber, J.

F. Schapker, and C. N. Orsini from August 13 through September 23, 1994.

During this inspection, one item was found to be in violation.

The violation is associated with the failure to remove action request tags upon resolution of the deficiencies documented on the tags.

This violation was set forth in a letter containing the notice of violation, dated October 21,

1994, from Mr. E.

G. Greenman,

Director, Division of Reactor

Projects, USNRC, Region III.

The letter was received October 27, 1994.

Our response to the notice of violation is contained within this document.

NRC Violation "Technical Specification 6.8.l.a requires that written procedures shall be established, implemented, and maintained for applicable procedures recommended in Appendix "A" of Regulatory.Guide 1.33, Revision 2, February 1978.

Regulatory Guide 1.33, paragraph 9.e.l of Appendix "A," requires that procedures for the control of maintenance include information such as the method for obtaining permission and clearance for. operation personnel to work and for logging of such work.

Procedure NPM-02CM, Revision 4,

"Nuclear Plant Maintenance System Process Instruction,"

requires the logging and removing of action request tags associated with equipment requiring corrective maintenance.

Specifically, paragraphs 5.2.1.B.4 and 5.13.3.g require that all action request tags be removed upon successful completion of the corrective maintenance or upon rejection of the action request following initial review.

Contrary to the

above, on September 26 and 28,

1994, licensee personnel failed to remove Action Request tags from the Unit 2 turbine-driven auxiliary feedwater (TDAFW) pump trip and throttle valve (T&TV) and from a local control panel located in the Unit 2 "CD" emergency 'iesel generator (EDG) despite resolution of the deficiencies documented on the subject tags.

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

ATTACHMENT TO AEP 'NRC: 1212I Page 2

Response

to Violation For clarification purposes:

The notice of violation indicates that an action request tag was not removed from the Unit 2 turbine-driven auxiliary feedwater (TDAWP) pump trip and throttle valve (T&TV).

Through subsequent discussion with the resident inspector, it has been determined that it was the Unit 1 TDAFW'pump T&TV which was involved, not the Unit 2 TDAFV pump T&TV.

dm ssio or Denia o

the Alle ed V olatio Indiana Michigan Power Company admits to the violation as cited in the NRC Notice of Violation, with note to the above clarification.

2.

easons for t e V plat o The process at Cook Nuclear Plant for documenting and physically accounting for the use, location, and removal of action request tags is not adequate to assure tag removal after action requests are rejected or work has been completed.

3.

rective Act o s Ta en a d Results c ieved The action request tags that were identified by the inspector as not having been removed were verified on October 27, 1994, to have since been removed.

4, Co ect ve ct o s ake o

vo d t e Vio a s

The plant process willbe revised to implement a different method for documenting and physically accounting for the

use, location, and removal of action request tags.

This process change is scheduled for implementation by June 1, 1995.

This date is based on the estimated amount of time required to develop,

review, and train on the new process.

The concern of failing to remove action request tags is that it may inhibit personnel from initiating new action requests or may result in an inaccurate assessment in the plant of the condition of plant components.

Historically, the plant action request tag use,

location, and removal process has not lead to a significant safety concern or inaccurate assessment of plant components.

Also, it is not expected that during the time to implement the new process that such conditions would evolve, based on equipment surveillance requirements and the ability of plant personnel to access the action request system and evaluate action request status independent of tag placement.

ATTACHMENT TO AEP:NRC: 1212I Page 3

However, in the interim, the production superintendents willsensitize their personnel to the existing circumstances and expectations.

In addition, an action request tag review and validation process willbe initiated to assure achievement of full compliance by June 1, 1995.

5.

C a

ew e

c ve Full compliance will be achieved by June 1,

1995, with the implementation of the revision to the action request process.