ML17332A260

Responds to NRC Re Violation Noted in Insp Repts 50-315/94-13 & 50-316/94-13.Corrective Actions:Work Control Process Code Was Changed on 2-MMO-240 Repair Job Order & CAP PMI-7030 Will Be Revised to Redefine Rework

ML17332A260
Person / Time
Site:	Cook
Issue date:	08/19/1994
From:	Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Martin J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AEP:NRC:1212G, NUDOCS 9408240071
Download: ML17332A260 (10)

Text

(ACCELERATED RIDS PROCESSING)

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

'CESSION NBR:9408240071 DOC.DATE: 94/08/19 NOTARIZED: YES DOCKET FACIL: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:

Responds to NRC 940720 ltr re violations noted in insp rept 50-315/94-13

& 50-316/94-13.Corrective actions:work control process code was changed on 2-MMO-240 repair job order PMI-7030 will be revised to redefine rework.

DISTRIBUTION CODE:

IE01D COPIES RECEIVED:LTR ENCL SIZE:

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

RECIPIENT ID CODE/NAME PD3-1 PD INTERNAL: AEOD/DEIB AEOD/S PD/RRAB DEDRO NRR/DRCH/HHFB, NUDOCS-ABSTRACT OGC/HDS2 RES/HFB EXTERNAL EG &G/ BRYCE i J

~ H ~

NRC PDR COPIES LTTR ENCL 1

1 1

1 1

1 1

1 1

1 1

1 1

1 1

1 1

1 1

1 RECIPIENT ID CODE/NAME HICKMAN,J AEOD/SPD/RAB AEOD/TTC NRR/DORS/OEAB NRR/PMAS/IRCB-E 0

R REG FIL 02 GN3 FILE 01 NOAC COPIES LTTR ENCL 1

1 1

1 1

1 1

1 1

1 1

1 1

1 1

1 1

1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE iVASTE!CONTACTTHE DOCUMENTCONTROL DESK, ROOM Pl-37 (EXT. 504-2083 ) TO ELIMINATEYOUR NAME F ROTI DISTRIBUTIONLISTS FOR DOCUMENTS YOU DON"I'EED!

TOTAL NUMBER OF COPIES REQUIRED'TTR 19 ENCL 19

Indiana Michigan Power Company P.O. Box 16631 Columbus, OH 43216 INDIANA NICHIGAN POWER AEP;NRC'1212G 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 NO. 50-315/94013 (DRP)

AND 50-316/94013 (DRP)

REPLY TO NOTICE OF VIOLATION U.

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

C.

20555 Attn:

Mr. J.

B. Martin August 19, 1994

Dear Mr. Martin:

This letter is in response to a USNRC letter dated July 20,

1994, that forwarded a notice of violation to Indiana Michigan Power Company.

The notice of violation contained one violation identified during a

routine safety inspection conducted by Messrs. J.

A. Isom, D. J. Hartland, and D. L. Shepard from June 4,

1994, through July 1, 1994.

The violation is associated with the repeated packing failures of a Unit 2 main steam test selector valve over a period of two years that resulted in several entries into four-hour limiting conditions of operation.

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 attached.

p~W)

Vice President ar Attachment 940S240071 94081 PDR ADDCI; 05000315PDFi'gy

/

Mr. J.

B. Martin AEP:NRC:1212G CC:

A. A. Blind G. Charnoff W. T. Russell, NRC - Washington, D.C.

NRC Resident Inspector NFEM Section Chief J.

R. Padgett

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 NO. 50-315/94013 (DRP)

AND 50-316/94013 (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.

Subscribed end sworn to before me this ~PE day of 19~EX NOTARY PUBLIC Ale D. HILL gpgpy pUQUC, STAIE pF plllp SSX SSh',IEISSISS EXPIRES~

ATTACHMENT TO AEP:NRC:1212G REPLY TO NOTICE OF VIOLATION

ATTACHMENT TO AEP:NRC:1212G Page

1 Background

A routine safety inspection was conducted by Messrs.

James A. Isom, David J. Hartland, and Douglas L. Shepard from Jurie 4, 1994, through July 1, 1994.

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

The violation was identified as the failure to correct che root cause for the repeated packing failures of a Unit 2 main steam test selector valve over a period of two years that resulted in several entries into four-hour limiting conditions of operation.

This violation was set forth in a letter containing the notice of violation, dated July 20, 1994, fromMr. E.

G. Greenman, Director, Division of Reactor Projects, USNRC, Region III.

The letter was received July 25, 1994.

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

NRC Violation "10 CFR 50, Appendix B, Criterion XVI, "Corrective Action,"

requires in part that "Measures shall be established to assure that conditions adverse to quality are promptly identified and corrected.

In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition."

Contrary to the

above, as of July 1, 1994, the licensee failed to replace the pitted valve stem on main steam stop valve (MSSV) dump valve test

selector, 2-MM0-240, a

significant condition adverse to quality.

Specifically, Action Request 25594 had been written on July 8,'992, to replace the pitted valve stem but was not scheduled to be performed until the refueling outage starting in September 1994.

Consequently, 2-MMO-240 had to be repacked five times, requiring entries into the four hour Limiting Condition of Operation (LCO),

as required by Technical Specification (TS) 4.7.1.5.1.

There were several opportunities since July 1992 to replace the stem without entering the LCO.

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

ATTACHMENT TO AEP:NRC: 1212G Page 2

Response

to Violation dmissio or Denial o the Alle ed Violat o Indiana Michigan Power Company admits to the violation as cited in the NRC notice of violation.

2.

easons for the Violatio The root cause for this violation has been identified as a

programmatic weakness in the plant's corrective action program.

In July 1992, Unit 2 was in Mode 3 (Hot Standby).

While repacking 2-MM0-240, the valve stem was found to be pitted, scored and in need of replacement.

At that time an Action Request was initiated to replace the stem.

Since a repair activity of this type requires cooldown to Mode 5

to perform, a scheduling code of U2R94 was assigned, adding the repair to the scope of the 1994 refueling outage.

At the time the U2R94 code was assigned, in the absence of prior failure history, this was the correct designation.

The valve stem replacement would only have been elevated to the forced outage schedule if the subsequent, repeated repairs had been identified as rework and an adverse trend.

Since the valve stem deficiency was first identified, 2-MMO-240 has been repacked five additional times.

Had the valve stem replacement been scheduled as a forced outage activity, there would have been two opportunities prior to the violation to complete the repair.

The first opportunity occurred in August 1993 when the unit experienced a reactor trip and forced outage.

The second opportunity occurred in January 1994 when the unit was removed from service to repair an unisolable steam leak on Steam Generator 21 blowdown line.

Repeated packing replacements were not identified in the plant's Corrective Action Program (PMI-7030) as an adverse trend.

PMI-7030, "Corrective Action Program,"

requires a

condition report to be written for similar corrective maintenance work within 90 days of the original deficiency.

Only the final packing failure on May 17, 1994, fell within the 90 day criteria, as this failure occurred 57 days after the previous repair on March 21, 1994.

ATTACHMENT TO AEP:NRC: 12120 Page 3

A rework condition report was not initiated following the May 17 failure due to an error in the Maintenance Administrative Procedure (MAP) ¹MA3.3-05, "Maintenance Planning".

MAP ¹MA3.3-05 incorrectly defined rework as similar work performed within 30 days of the original failure, rather than 90 days.

As a result of this error the maintenance planner failed to identify the reoccurrence of the packing leak on May 17,

1994, as falling within the definition of rework.

3.

Cor ective Actions Taken and esults eyed The work control process code was changed on the 2-MMO-240 repair Job Order.

The 2-MMO-240 repair task now appears on the forced outage

schedule, as well as within the scope of the refueling outage.

MAP

¹MA3.3-05, "Maintenance Planning,"

was revised to reflect the current definition of rework contained in PMI-7030.

4.

Corrective Actions Taken to Avoid Further Violations PMI-7030, "Corrective Action," will be revised to redefine rework.

The definition for rework will now include any corrective maintenance which requires entry into a Limiting Condition of Operation (LCO) if similar work has been performed on that equipment/component during the current operating cycle, including the previous refueling outage.

When rework of this type occurs, a Condition Report willbe written to aid in the identification/evaluation of an adverse trend.

The "90-day" standard will be retained for work upon equipment or components which do not initiate an LCO entry.

MAP ¹MA3.3-05, "Maintenance Planning," will be revised to refer to PMI-7030 for the above-described redefinition of rework.

These measures will assure that this type of condition will be precluded in the future.

5.

ate When Full Com lienee Will Be Achieved PMI-7030 and MAP modifications will be completed by September 30, 1994.

ATTACHMENT TO AEP:NRC:1212G Page 4

The valve stem replacement for 2-MMO-240 will be completed during the first Mode 5 forced outage of sufficient duration or the upcoming Unit 2

refueling

outage, scheduled to commence September 6, 1994, whichever occurs first.