ML17333A842

Responds to NRC 970204 Ltr Re Violations Noted in Insp Repts 50-315/96-13 & 50-316/96-13.Corrective Actions:Instructions Requiring Filter Content Evaluation Removed from Charging Pump Recurring Tasks on 970211

ML17333A842
Person / Time
Site:	Cook
Issue date:	03/12/1997
From:	Fitzpatrick E AMERICAN ELECTRIC POWER CO., INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17333A841	List: IR 05000315/1996013 ML17333A842
References
NUDOCS 9704080224
Download: ML17333A842 (29)

See also: IR 05000315/1996013

Text

Indiana Michigan Power Company 500 Circie D;i'e Bucl anan.III 491071395 INDIANA MICHIGAN POWER March 12, 1997 AEP:NRC:1238F

10 CFR 2.201 Docket Nos.: 50-315 50-316 U.S.Nuclear Regulatory

Commission

ATTN: Document Control Desk Washington, D.C.20555 Gentlemen:

Donald C.Cook Nuclear Plant Units 1 and 2 NRC INSPECTION

REPORTS NOs.50-315/96013(DRS)

AND 50-316/96013 (DRS)REPLY TO NOTICE OF VIOLATIONS

This letter is in response to a letter from G.E.Grant, dated February 4, 1997, that forwarded a notice of three violations

and one notice of deviation to Indiana Michigan Power Company.The violations

and the deviation were identified

during a system operational

performance

inspection (SOPI)of the centrifugal

charging system portion of the emergency core cooling systems and the residual heat removal systems.Our response was due to you on March 6, 1997;however, we requested a brief extension to recover the time delay from when the report was issued to when it was received.The exten'sion

was granted by Ron Gare er of Region III, on February 14, 1997.The three violations

addressed the 1)failure to establish adequate instructions/failure

to follow procedures

as related to collection

of an oil sample, and adequate minimum thread engagement

acceptance

criteria;2)inadequate

test control as related to incorporating

charging pump acceptance

limits into the IST program;and 3)failure to perform adequate/timely

corrective

actions, as related to determining

the correct oil sight-glass

fill marks on safety-related pumps and motors, addressing

equipment deficiency

tagging problems, and locating/reconstituting

a centrifugal

charging pump net positive suction head calculation.

The deviation was from actions committed to in NUREG-0737

specifically

involving the source term used for a radiological

evaluation.

'7704080224

'970403 PDR ADOCK 05000315 8 PDR

4 0

U.S.Nuclear Regulatory

Commission

Page 2 AEP: NRC: 1238F Our reply to the violations

and deviation are provided in the attachment

to this letter.Also included are the results of our review of technical specification

clarifications, which we committed to perform at the December 13, 1996, exit meeting.The reply does not contain any personal privacy, proprietary, or safeguards

information.

Sincerely, PCw p-E.E.Fit patrick Vice President SWORN TO AND SUBSCRIBED

BEFORE ME TH s/X DAY QP)~'997 Notary Public My Commission

Expires: 2/Cr PING/vlb Attachment

JANlCE hl.BIG!<ERS Noey Pub5c, 88men CcunlY, M Qy Q0mmrssc p Eyp;re Fob,<6, 2N$cc: A.A.Blind&3L"%%~8eachh'~:q

MDEQ-DW R RPD NRC Resident Inspector J.R.'adgett

fl'

ATTACHMENT

TO AEP:NRC: 1238F REPLY TO NOTICE OF VIOLATION:

NRC INSPECTION

REPORTS NOs.50-315/96013 (DRS)AND 50-316/96013 (DRS)

Attachment

to AEP:NRC:1238F

Page 1 During an NRC system operational

performance

inspection

conducted November 18 through December 13, 1996, on the emergency core cooling system portion of the centrifugal

charging system and residual heat removal system three violations

and one deviation were identified.

In accordance

with the"General Statement of Policy and Procedures

for NRC Enforcement

Actions," (NUREG-1600)

the violations

and the responses are provided below.Additionally, we were requested to respond to the deviation, and to provide information

related to a commitment

regarding technical specification (T/S)clarifications

made at the December 13, 1996, exit meeting.Our response to these items is also provided below.NRC Violation A"10 CFR 50, Appendix B, Criterion V,'Instructions, Procedures, and Drawings,'equires, in part, that activities

affecting quality shall be prescribed

by instructions, procedures, or drawings of a type appropriate

to the circumstances

and shall be accomplished

in accordance

with these instructions, procedures, or drawings.Maintenance

procedure 12 MHP 5021.001.009, Revision 8,'Torque Selection,'ated

March 21, 1994, requires thread engagement

of at least 80 percent of nut height.Contrary to the above: On December 4, 1996, the i" spectors identified

that a maintenance

work package for the 1E centrifugal

charging pump, an activity af fecting quality,~failed to include adequate instructions

for lube oil sample collection.

On November 20, 1996, the inspectors

identified

that maintenance

procedure MDS-600,'General Erection Tolerances

for Pipe and Tube Supports/Restraints,'as

not of a type appropriate

to the circumstances

since it failed to contain adequate minimum thread engagement

acceptance

criteria for activities

af fecting quality.3.On November 21, 1996, the inspectors

identified

that maintenance

personnel failed to perform bolting on safety-related equipment in accordance

with maintenance

procedure 12MHP5021.001.009,'Torque Selection.'s

a result, nuts associated

with emergency core cooling system equipment were identified

with thread engagement

less than 80 percent of nut height.This a Severity Level IV violation." Res onse to NRC Violation Al 1.Admission or Denial of the Alle ed Violation indiana Michigan Power Company admits to the violation as cited in the NRC notice of violation.

Reason for the Violation The reason for the violation was failure to remove oil sampling instructions

from applicable

recurring tasks that were no'cnger needed after implementation

of a formal oil sampling program.

,I" tl

Attachment

to AEP:NRC:1238F

Page 2 The instructions

found in the job order activity associated

with the work on the lE centrifugal

charging pump instructed

personnel to: "Drain oil from filter into a container.

A.Deliver oil f rom CUNO f il ter to chem lab for analysis.(The results will go to the engineers for evaluation

of wear in system)." The job order activity instructions

were developed prior to implementation

of our formal oil analysis program.At the time it was input as a recurring task, it was intended to provide a rough indication

of gross machine problems.Subsequently, a formal oil analysis program was implemented, with proceduralized

sampling techniques

being utilized by chemistry personnel.

Under this sampling program, done quarterly (as opposed to filter change-outs

that are done yearly), wear, particles of considerably

less size than those detected via the filter change-out

method can be detected, thus giving much earlier indication

of machine problems.The instructions

in the recurring task were inadvertently

left in place after the formal program was instituted.

The oil collected via these instructions

is not analyzed by chemistry personnel;

and decisions as to the condition of the equipment are not based or.these samples.3.Corrective

Actions Taken and Results Achieved The instructions

requiring filter content evaluation

were removed from the charging pump recurring tasks on February 11, 1997~The 1E charging pump lube oil was sampled by chemistry personnel on September 12, 1996, prior to the filter change-out

observed on December 4, 1996, consistent

with the formal oil analysis program.4.Corrective

Actions Taken to Avoid Further Violations

A:eview of lube oil changes related to equipment included in tne oil analysis program was conducted.

Similar wording was found in recurring tasks for the motor-driven

and turbine-driven auxiliary feedwater pumps.This redundant wording will be removed prior to the next required date for filter change-out

for this equipment.

5.Date When Full Com liance Will Be Achieved Full compliance

was achieved on February 11, 1997, when the redundant instructions

were removed from the four charging pump's recurring.

tasks.Res onse to NRC Violation A2 6 A3 1.Admission or Denial of the Alle ed Violation Indiana Michigan Power Company admits to the violation as cited in the NRC notice of violation.

Attachment

to AEP:NRC:1238F

Page 3 Reason for the Violation The cause of the violation, as cited in A3, is a combination

of the way work was documented

and adherence to procedural

requirements

that were inconsistent.

The reference to MDS-600, cited in A2, as a"maintenance

procedure" requires clarification.

MDS-600 is not a procedure, it is a design standard that provides tolerances

for installation

and evaluation

of as-found conditions

for piping/tubing

supports.MDS-600 is not an applicable

reference and there is no hierarchial

connection

between MDS-600 and**12 MHP 5021.001.009.

3.Corrective

Actions Taken and Results Achieved Eight condition reports were written to document the inspection

team's concerns.Operability

reviews were performed based on the identified

deficiencies, and the affected equipment was determined

to be operable.Work history for each component was reviewed to assist in determining

the potential cause(s).In general, this review identified

a general time frame when the deficiency

was created, but not a specific work activity.Action requests were written to correct the deficiency

where an action request did not already exist, or the deficiency

was evaluated and found to be acceptable

as is.4.Corrective

Actions Taken to Avoid Further Violations

Maintenance

standing order, MSO.009, was issued on February 3, 1997.This document establishes

an acceptance

criteria of"flush or better" for thread engagement.

Further, it provides a policy for documenting

as-found thread engagement

deficiencies

so they can be evaluated and corrected.

Lastly, the policy provides for in-plant identification

of less than flush thread engagement

that has been evaluated and found to be acceptabl.This standing order strengthens

management

expectations

for thread engagement

and establishes

a mechanism for identification

of analyzed, acceptable

conditions.

A walkdown was performed of a random sample of plant components

of sufficient

size to provide a 99%confidence

level that these components

are a statistically

valid sample of the plane population

of components.

The as-found configuration

of the fasteners associated

with these components

was evaluated.

There were no fastener anomalies identified

that affected component functionality

or operability.

Plant management

has reinforced

procedural

adherence to all plant personnel.

• • 12 MHP 5021.001.009 was enhanced by the addition of acceptance

criteria of flush threads or better.

I

Attachment

to AEP:NRC.:1238F

5.Date When Full Com liance Will Be Achieved Page 4 Full compliance

was achieved on March 10, 1997.At that time the original 28 NRC-identified

thread engagement

deficiencies

were analyzed as not affecting operability/quality;

existing procedures, policies, and standards were upgraded;and the findings of the thread engagement

random sample concluded that there were no functionality/operability

concerns caused by thread engagement

deficiencies

associated

with any of the sampled components.

NRC Violation B"10 CFR 50, Appendix B, Criterion XZ,'Test Control,'equires, in part, that a test program be established

to assure that all testing required to demonstrate

that structures, systems, and components

will perform satisfactorily

in service is identified

and performed in accordance

with written test procedures

which incorporate

the requirements

and acceptance

limits contained in applicable

design documents.

Technical Specification 3.1.1.1,'Shutdown Margin-Tave greater than 200'F,'pecifies

a boration capability

of 10 gallons per minute (gpm)of 20,000 parts per million (ppm)boron solution or equivalent.

Contrary to the above, on December 11, 1996, the inspectors

identified

that the correct acceptance

limits to assure that the centrifugal

charging pumps could perform their boron injection function as specified in Technical Specification 3.1.1.1 had not been incorporated

in the licensee's

inservice testing (ZST)program.This is a Severity Level ZV violation." Res onse to NRC Violation B Admission or Denial of the Alle ed Violation Zndiana Michigan Power Company admits to the violation as cited in the NRC notice of violation.

2.Reason'for the Violation The reason for the violation was that a review to determine applicability

to the ZST program was not conducted prior to issuance of a technical specification (T/S)clarification

on T/S 3.1.1.1.T/S 3.1.1.1, Shutdown Margin-T,~greater than 2004F provides shutdown margin requirements

while in modes 1, 2, 3, or 4.The action statement for T/S 3.1.1.1 requires immediate and continuous

boration at greater than or equal to 10 gpm of a solution containing

greater than or equal to 20,000 ppm boron or"equivalent".

Westinghouse

performed an analysis to clarify the meaning of this statement if the refueling water storage tank (RWST)was used as a source of borated water.Westinghouse

defined"equivalence" as"xenon burnout equivalence", which is the capability

to inject sufficient

boron to adjust aoron concentration

to compensate

for xenon burnoutfrom its peak value Their analysis assumed a plant trip followed by a step return to 100%.power

Attachment

to AEP:NRC:1238F

Page 5 at peak xenon concentration.

Zn addition, they assumed that the reactor would be maintained

at full power during the transient.

The results of this analysis showed that a centrifugal

charging pump (CCP)flow of 120 gpm from the RWST could compensate

for xenon throughout

the transient if certain restrictions

were observed.On November 5, 1990, a revision to T/S clarification

no.7 was issued, which defined the 120 gpm of RWST water containing

2400 ppm boron as an acceptable

source of water to satisfy boration flow requirements

for T/S 3.1.1.1.Development

and issuance of this T/S clarification

was not coupled with a review of the test program to ensure the test program confirmed the ability of the CCPs to perform this function.This deficiency

was identified

by our engineers during efforts to respond to an inspector's

question on the design functions of the CCPs during the inspection.

Corrective

Actions Taken and Results Achieved Following identification

of this deficiency, a calculation

was performed to determine the maximum degradation

the CCPs could tolerate while still~eing able to deliver 120 gpm of RWST water to the reactor coolant system.This calculation

revealed that the CCPs could tolerate a degradation

of 9.5%for Unit 1 and 3.5%for Unit 2.A review of ZST data as far back as 1990 determined

that the pumps were capable of performing

this function.The ZST program has been revised to include limitations

for allowable degradation

of the CCPs to ensure that 120 gpm of 2400 ppm boron could be supplied from the RWST.Additionally, as a point of information, since the original analysis by Westinghouse, which defined the 120 gpm value of 2400 ppm boron included a very conservative

assumption

that a step increase in power to 100%occurred while at peak xenon, a reanalysis

was performed using a more realistic ramp rate of 10'k/hr, which is a limitation

contained in plant procedures.

This reanalysis

indicated that the boration flow requirements

of T/S 3.1.1.1 could be satisfied by as little as 60.1 gpm of 2400 ppm boron.We may relax the allowable degradation

for the CCPs based on this revised 60.1 gpm flow.Corrective

Actions Taken to Avoid Further Violations'ailure

to ensure the test program for the CCPs included provisions

to ensure the CCPs could deliver 120 gpm of 2400 ppm boron occurred as a result of failure to couple the development

and issuance of a T/S clarification

with appropriate

reviews of the test program.As noted in the SOPZ report, several examples were identified

where T/S clarifications

could not be justified.

During the exit meeting, we committed to perform a review of all of our T/S clarifications.

The results of this review are contained in the"Commitment"'ection of this attachment.

Additionally, as noted, improvements

will be made in the T/S clarificaticn

review process to ensure an adequate technical review of future clarifications.

Attachment

to AEP:NRC: 1238F Page 6 Date When Full Com liance Will Be Achieved Full compliance

was achieved on December 18, 1996, when the IST program was revised to include appropriate

limits to ensure that each units'CPs can supply 120 gpm of 2400 ppm boron from the RWST.Violation C"10 CFR 50, Appendix B, Criterion XVI,'Corrective

Actions,'equires, in part, that measures shall be established

to assure that conditions

adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances

are promptly identified

and corrected.

Contrary to the above: 2.3.Corrective

actions to address potentially

inaccurate

sight-glass fill marks for safety-related

pumps and motors, a condition adverse to quality, were not initiated until November 27, 1996, although in 1995 job orders were written to address potentially

inaccurate

sight-glass

fill marks on safety-related

pumps and motors, and on March 6, 1996, an action request was written to determine correct sight-glass

fill marks on safety-related.

pumps and motors.On December 5, 1996, the inspectors

identified

that the licensee failed to take corrective

actions to either locate or re-constitute

a centrifugal

charging pump net positive suction head (NPSH)calculation

although the calculation

had been identified

as missing about 18 months earlier.On December 4, 1996, the inspectors

determined

that the licensee failed to take timely corrective

actions to address equipment deficiency

tagging problems.Although the licensee had identified

that about 30 percent of plant components

in the work'control

system reviewed in a three week period were not properly tagged in the field, corrective

actions to a iress this concern had not been initiated.

This is a Severity Level IV violation." Res onse to NRC Violation Cl Admission or Denial of the Alle ed Violation Indiana Michigan Power Company admits to the violation as cited in the NRC notice of violation.

2.Reason for the Violation The cause of the untimely response for guidance on plant pump/motor

oil fill levels was the lack of a communication

protocol resulting in an unrecognized

request to engineering

personnel from operations

personnel for technical assistance.

The request for assistance

was made by means of an action request.Requests for engineering

direction are made within the nuclear plant maintenance (NPM)computer system by means of an evaluation

request.Different searches are required to locate action requests and evaluation

requests.Engineering

personnel did not search action requests because they were not an expected means for requesting

assistance.

Attachment

to AEP:NRC:1238F

Page 7 The request for guidance on plant pump/motor

oil fill levels was brought to engineering

management's

attention approximately

five months after the action-equest was initiated.

At that time engineering

personnel began work to provide the requested guidance.The background

research was completed and the guidance issued on December 5, 1996.Corrective

Actions Taken and Results Achieved The requested information

on pump/motor

oil fill levels was provided on December 5, 1996.A search of action requests assigned to engineering

personnel has been performed to ensure the responsible

groups are aware of assignments.

Additionally, as an interim action, plant personnel have been instructed

to make daily searches to ensure no new action requests for engineering

assistance

go unrecognized.

4, Corrective

Actions Taken to Avoid Further Violations

An acceptable

method for requesting

engineering

assistance

will be developed by March 21, 1997'.Date When Full Com liance Will Be Achieved Full compliance

was achieved on December 5, 1996, when the requested technical guidance was provided.Res onse to NRC Violation C2 Admission or Denial of the Alle ed Violation Indiana Michigan Power Company admits to the violation as cited in the NRC notice of violation.

2.Reason for the Violation In June 1995, as part of the design basis documentation (DBD)program, it was identified

that the NPSH calculation

for the CCPs cauld not be located.A DBD action item was init'ated in accordance

with DBD program procedures.

This item was classified

as an instance of a"missing reference document", a categorization

with a normal resolution

time of 60 days.Engineering

personnel involved in the classification

of this item were aware that an NPSH calculation

for the CCPs had been performed at one time,.even though it could not be located.Operability

was not considered

to be a concern because it was known that the calculation

had been performed but could not be found.Therefore, a high priority was not placeu on reconstituting

the calculation

or resolving the DBD action item.Corrective

Actions Taken and Results Achieved As noted in the SOPI report, a new calculation

was completed prior to and approved during the SOPI inspection, which confirmed adequate NPSH to the CCPs.Corrective

Actions Taken to Avoid Further Violations

Following the SOPI inspection, a review of all open DBD action items was performed, by January 15, 1997, to assess

0

Attachment

to AEP:NRC: 1238F Page 8 the appropriateness

of their classification.

A series of additional

DBD action items were formally entered into the corrective

action system (via condition reports)as a result of this review.The corrective

action system includes requir'ements

for determining

operability

in a timely manner.Entry into the corrective

action system ensures a review of these issues by our condition assessment

group (CAG).In its oversight function, the CAG assesses the need and makes assignments

for confirmatory

operability

determinations

or supplemental.

analysis.Beginning in January 1997, additional

resources were added to the DBD project to enable prompt closure of DBD action items.Specifically, the DBD project manager position, which had been vacant since September 1996, was filled and two additional

utility personnel and two contract personnel were assigned to the project.These personnel are aggressively

pursuing, resolution

of open DBD'action items.This augmentation

of personnel will.continue through late 1997, by which time we expect to have made significant

progress in the closure of DBD action items.Additionally, we are training members of our staff, who have ownership of the DBDs, to ensure they understand

the importance

of promptly resol"ing DBD action items and also to ensure they clearly understand

the process for effecting closure of these items.This training commenced in early February 1997 and will be completed by March 15, 1997.Finally, the DBD action item review process is being strengthened

to limit the number of ava.'lable

classifications

for DBD action items and also to ensure a more comprehensive

review of action items by appropriate

personnel.

Project instructions

related to action item processing

are being revised.These revisions will be completed by March 28, 1997.Date When Full Com liance Will Be Achieved Full compliance

was achieved on December 2, 1996, when a new calculation

was approved which confirmed adequate NPSH to the CCPs.Res onse to NRC Violation C3 Admission or Denial of the Alle ed Violation Indiana Michigan Power Company admits to the violation as cited in the NRC notice of violation.

2.Reason for the Violation The primary reason for the violation is that plant personnel were not sufficiently

aware of the guidance regarding when to hang deficiency

tags for corrective

maintenance.

This was further compounded

by the lack of clarity provided by the administrative

requirements

that def ine def i-iency tag hanging requirements.

Further, condition reports were not generated when missing deficiency

tags were identified

to prompt appropriate

actions via the plant's,corrective

action program.While written

Attachment

to AEP:NRC:1238F

Page 9 memoranda identifying

the missing deficiency

tags were generated, condition reports were not written and therefore, appropriate

attention and follow-through

were not instituted.

Zn all cases evaluated, the work control process had captured the identified

degraded component, ensuring that the deficient condition would be corrected in a timely manner.Corrective

Actions Taken and Results Achieved Recent plant management

actions have been taken to improve focus on promptly identifying

problems and corrective

actions dealing-with conditions

adverse to plant requirements.

A condition report was promptly written when the NRC noted the lack of timely corrective

action to address the identified

deficiency

tagging issue.The condition report 1)proposes that the material condition group replace missing tags when discovered, 2)recommends

changes to the governing document NPM-02CM, and 3)requests assistance

from computer personnel to modify existing NPM software to better support the rehanging of tags.The personnel responsible

for ident'ying

missing deficiency

tags were coached on the expectation

to generate additional

condition reports in the future.Corrective

Actions Taken to Avoid Further Violations

By April 1, 1997, the governing document.detailing when and how to tag deficiencies

will be revised and appropriate

personnel will be made aware of"the revised requirements.

Also, as of April 1, 1997, action requests generated that have not met the revised deficiency

tagging requirements

will be returned to the originating

personnel for resolution

before the action request will be processed further.By September 1, 1997, system walkdowns will have been performed to verify that deficiency

tags associated

with existing corrective

maintenance

action requests (those generated before April 1, 1997), comply with the revised requirements.

Date When Full Com liance Will Be Achieved Full compliance

will be achieved by April 1, 1997, when the deficiency

tagging requirements

have been revised and appropriate

personnel have been made aware of those requirements.

Further, condition reports will be written as of April 1, 1997, for any deficiency

tag not in compliance

with the revised requirement (regardless

of when the action request and associated

deficiency

tags were generated).

)I'

Attachment

to AEP:NRC:1238F

Deviation Page 10 In addition to the above three violations, the notice of violation contained'the following notice of deviation, which is addressed below.DEV 50-315 96013-09 DRS and DEV 50-316 96013-09 DRS'"During an NRC inspection

conducted November 18 through December 13, 1996, a deviation of your actions committed to in NUREG-0737, Section IZ.B.2 was identified.

In accordance

with the'General Statement of Policy and Procedures

for NRC Enforcement

Actions,'UREG-1600, the deviation is listed below: NUREG-0737, Section ZI.B.2,'Design Review of Plant Shielding and Environmental

Qualification

of Equipment for Spaces/Systems

Which May Be Used in Postaccident

Operations,'equires

that 50 percent of the total iodine and 100 percent of the noble gases are assumed to be released from the fuel~in the design basis accident radiological

analysis.Contrary to the above, on December 4, 1996, the inspectors

identified

that the licensee failed to correctly translate Section ZZ.B.2 of NUREG-07~7

into the centrifugal

charging pump emergency leakoff valve failure design basis accident radiological

analysis.As a result, only one percent fuel damage was assumed in the analysis and resulted in dose estimates lower than revised calculated

values." Res onse to NRC Deviation Reason for the Deviation In August 1991, a small break loss of coolant accident scenario run on the plant simulator identified

a flowpath that had the potential to divert water away from the emergency core cooling system and containment

building.The flowpath was from the safety injection system (SIS)ce trifugal charging pump discharge through an emergency leakof f valve, through the reactor coolant pump (RCP)seal return line safety valve to the volume control tank (VCT)and through the VCT safety valve to the chemical and volume control system holdup tanks.This condition was documented

in LER 91-007-00.

A review was conducted to assess the safety consequence

and implications

of the postulated

event.Analysis of the potential dose rate from the diverted water to the whole body at the site boundary was calculated

to be insignificant

compared to the 10 CFR 100 accident dose limit and even with the 10 CFR 20.105 dose limits for unrestricted

areas during normal operations, based on the assumption

of 1%failed fuels LER 91-007-01 provided original corrective

action for this scenario.The scenario of concern occurs following the switchover

of the CCP suction from the refueling water storage tank to the recirculation

sump via the residual heat removal (RHR)pumps.With the RHR pumps supplying suction to the CCPs, the pressure in the CCP emergency leakoff (ELO)lines could be in excess of the downstream

safety valve set pressure, and then approximately

60 gpm flow would be diverted from the ECCS to the VCT.Corrective

actions for this scenario included emergency operating procedure (EOP)

Attachment

to AEP:NRC:1238F

Page 11 modifications

to close the charging pump ELO valves as part of the switchover

from injection to recirculation

phase where the ECCS pumps take suction from the recirculation

sump.In June 1995, as part of our DBD program, it was identified

that the EOPs noted above can be implemented, but were not single failure proof.The DBD program includes a process to identify, classify (with respect to safety significance), and resolve action items identified

during the development

of DBDs.A DBD action'tem

was created to document that in the event the single failure is an ELO valve that'cannot be isolated, the leakage path to the VCT would still persist.Within the DBD program, this issue was classified

as a discrepancy

that was not safety significant, based on the analysis described, above and documented

in LER 91-007.The reliance on the prior analysis in LER 91-007, which provided a practical assessment

of safety significance

per 10 CFR 50.73, to classify the DBD action item as a non-significant

discrepancy

was incorrect because it did not consider design basis assumptions

for source term per NUREG-0737.

The misclassification

of the DBD action item was made by engineering

personn 1 who incorrectly

assumed that the analysis presented in LER 91-007 was also an adequate basis for classification

of th DBD action item.2.Corrective

Actions Taken and Results Achieved The EOPs have been modified to inst uct the operator to turn off a CCP for which the ELO valve cannot be closed.Flow through the idle pump of up to 5.2 gpm may still exist;therefore, instructions

have been added to isolate the valve manually.(The 5.2 gpm is within the 10 gpm value f or outside containment

leakage previously

evaluated and determined

acceptable

regarding offsite and control room doses.)The maximum dose'to personnel expected to isolate the valve is 0.28 rem 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the accident occurs.3.Correcti re Action's Taken to Avoid Further Deviations

Following the SOPI inspection, a review of all open DBD action items was completed on January 15, 1997, to assess the appropriateness

of their previous classification.

A series of additional

DBD action items were formally entered into the corrective

action system as a result of this review.Entry into the corrective

action system ensures a thorough screening of these issues by the CAG for assignment

to the appropriate

organization

for resolution.

The corrective

action system includes requirements

for determining

operability

in a timely manner.In its oversight function, the CAG asse'sses the need and makes assignments

for confirmatory

operability

determinations

or supplemental

analysis.The DBD action item review process is being strengthened

to limit the number of available classifications

for DBD action items and also to ensure a more comprehensive

review of action items by appropriate

personnel.

Project instructions

related to action item processing

are being revised.These revisions will be completed by March 28, 1997.

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4.Date When Full Com liance Will Be Achieved Page 12 Corrective

action was completed on December 13, 1996, when changes"ere made to the EOPs to instruct the operator to turn off a CCP for which the ELO valve cannot be closed.

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Page 13 Commitment

The inspection

report requested we respond in writing regarding our review of T/S clarifications.

The notice of violation contained the following discussion."The licensee had 37 technical specification

clarifications (TSCs)in effect.The inspectors

reviewed the TSCs listed below and questioned

whether the licensee could provide technical justification

to support the TSCs.Subsequently, the licensee determined

that the following clarifications

could not be technically

justified and should be canceled: TSC¹14 TSC¹l5 TSC¹48 Airborne Radioactivity

Monitor Operability

Diesel Generator Surveillance

Runs-Paralleled.

Grid Technical specification (TS)4.8.1.1.2.F.2

Leak Testing of AD and CD Fuel Oil Tanks and Associated

Piping The inspectors

did not identify any past use of the above TSCs that resulted in exceeding the action requirements

of the associated

technical specification.

The inspectors

concluded that the safety significance

of the TSC errors were minimal.The inspectors

concluded that the licensee's

approval of TSCs without appropriate

technical justification

was a weakness.At the end, of the inspection, the licensee committed to review all remaining TSCs to ensure they were still necessary and could be justified." Review Sco e The NRC inspection

report indicated that 37 TSCs were in effect at the time of the inspection.

A review of the active TSCs from the, TSC index indicated that there were actually 35 active TSCs.The three TSCs discussed in the inspection

report were canceled.The scope of the TSC review was of the remaining 32 active TSCs.Observation

and Findin s Nine TSCs were canceled They are as follows TSC¹5 TSC¹12 TSC¹26 TSC¹37 TSC¹38 TSC¹45 TSC¹47 TSC¹60 TSC¹61 Operable-Operability

Definition

-Attendant Xnstrumentation

D.C.Distribution

-Operating Steam Generator Stop Valve Operability

Definition

of Maintenance

on Emergency Core Cooling System Valves Turbine Driven Auxiliary Feedwater Pump Operability

Snubber Functional'est

Retest Results 10 CFR 50 Appendix R Equipment Operability

Auxiliary Feedwater System and Essential Service Water System Auxiliary Feedwater System Surveillance

Requirements

Of this group, two TSCs (¹5 and¹12), were canceled due to insufficient

technical bases to support the implied operability

provided by the TSC.Three TSCs (¹37,¹60 and¹61)were canceled

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Page 14 as they were implemented

in a manner inconsistent

with current expectations.

Four TSCs (¹26,¹38,¹45 and¹47)were determined

to be unnecessary.

One TSC (¹65), boric acid transfer pump operability, was revised to properly reflect its technical bases (refer to section 08.1 of the NRC inspection

report).The remaining 22 TSCs remain active.Conclusion

Based on the review of the existing TSCs, it follows that the TSCs were not well defined and were implemented

in a manner inconsistent

with current expectations.

The, program was utilized to capture many event driven decisions that would more appropriately

fit an operability

program, or should be translated

into approved procedural

controls.An improved TSC program will be developed by June 27, 1997.This program will provide a review of proposed new clarifications

to ensure adequate technical justification

is present prior to approval, and that a clarification

does not change or alter the requirement

of the specification

being clarified.

Additionally, the new program will reg'uire plant impact reviews as part of the implementation

process.The impact reviews will ensure appropriate

review and incorporation

of clarification

information

into plant procedures

and programs'he

impact review process is being incorporated

into the implementation

process to address a SOPI concern involving integration

of TSC¹7 into the plant's IST program.