ML17321A974

Responds to NRC 851002 Ltr Re Violations Noted in Insp Repts 50-315/85-24 & 50-316/85-24.Corrective Actions:Procedure Being Developed to Control Replacement & Transfer of Reactor Coolant Filters Via 33-gallon Drum

ML17321A974
Person / Time
Site:	Cook
Issue date:	11/08/1985
From:	Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
AEP:NRC:0954, AEP:NRC:954, NUDOCS 8512030161
Download: ML17321A974 (9)

Text

INDIANA 8 MICHIGAN ELECTRIC COMPANY P.O. BOX 16631 COLUMBUS, OHIO 43216 November 8, 1985 AEP:NRC:0954 Donald C. Cook Nuclear Plant Nos. 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 NRC Report Nos. 50-315/85024 (DRS) and 50-316/85024 (DRS)

Mr. James G, Keppler U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Dear Mr. Keppler:

This letter is in response to Mr. tt. D. Shafer's letter dated October 2, 1985, which forwarded the subject inspection reports of the routine safety inspection conducted by your staff at the Donald C. Cook Nuclear Plant during the period September 3-13, 1985. The Notice of Violation attached to Mr.

Shaferts letter identified three violations. Section 13 of the inspection report identified one weakness, The responses to these violations and the weakness are addressed in the attachment to this letter.

This document has been prepared following Corporate procedures which incorporate a reasonable set of controls to insure its accuracy and completeness prior to signature by the undersigned.

Very truly yours, M.. Al ich Vice President p5~

Attachments MPA/ad cc: John E. Dolan

. gb N. G. Smith, Jr. - Bridgman R. C. Callen G. Charnoff NRC Resident Inspector - Bridgman G. Bruchmann

, 8512030161 NOV 1 2 I985 851 108 I

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AEP:NRC:0954 Attachment Page 1 NRC Item No. 1 "Technical Specification 6.8. requires establishment and adherence to the 1

applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, November 1972. Appendix "A~~ includes procedures for replacing important strainer s and filters and for limiting materials released to the environment.

a~ Contrary to the above, on July 19, 1985, the licensee transported a contaminated reactor coolant filter using a 33-gallon drum instead of the Atcor transfer cask specified by Procedure 12 HHP 5021.001.001, Filter Replacement By Transfer Cask, Additionally, no procedure was available to control the preparation and transfer of the reactor coolant filter to the 55-gallon shipping drum. This resulted in a worker exceeding the quarterly author ized dose.

b. Contrary to the above, from June 20 through September 13, 1985, the Hydro Nuclear dry active waste segregation and volume reduction system was operated without an adequate established procedure for limiting materials released to the environment in that the system operators were not directed by procedure to follow manufacturer's instructions that specify the disposal as radioactive waste of any parcel of system processed waste which has generated a bag monitor high count alarm. During the above stated time period, operators routinely reprocessed the material in these parcels without treating it as detected radioactive waste."

Corrective Actions Taken and Results Achieved The worker's TLD was immediately pulled and sent in for early readout. The results showed that based on TLD, the administrative limit was not exceeded.

In addition, interim instructions were issued on July 29, 1985, in the form of a Department Head Letter, communicating the conclusions reached during the post-job ALARA review and alerting maintenance personnel to the hazards associated with changing highly radioactive filters.

'orrective Action to be Taken to Avoid Further Violations A procedure is being developed to control the replacement and transfer of the reactor coolant filters via a 33-gallon drum from the filter location to the waste storage. ';1e anticipate having this procedure approved by February 1, 1986.

Full compliance will be achieved on February 1, 1986 when the procedure to control the Filter Replacement and Transfer is approved.

I AEP:NRC:0950 Attachment Pa e 2 Res onse to Item~

It is our belief that we did have in place a procedure to follow manufacturer's instructions. The plant procedure, 12 TRIP 6010 ENV. 007 (DA11 II Segregation/Volume Reduction Pr ocess Operations) was developed from the manufacturer's draft procedure, HHS-230. Step 6.5.6 of the plant procedure states that reprocessed.

ifThis direction a bag monitor alarm occurred, the box could be opened and is consistent with the manufacturer's instructions. The manufacturer has agreed that the plant procedure follows the manufacturer s instructions, and thus, adequately limits material released to the environment.

Corrective Action Taken and Results Achieved Hone required.

Corrective Action to be Taken to Avoid Further Violations Hone required.

Date When Full C~om liance )fill be Achieved For the reasons stated above, we believe operation of the DA~8 II was never in non-compliance with Technical Specification 6.8.1.

HRC Item tfo. 2 "10 CFR 20.201(b) states that each licensee shall make or cause to be made such surveys as ( 1) nay be necessary for the licensee to comply with the regulations of this part, and (2) are reasonable under the circumstances to evaluate the extent of radiat'on hazards that may be pr esent.

As used in the regulations in this part, "survey< means an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions. Uhen appropriate, such evaluation includes a physical survey of the location of materials and equipment, and measurements of levels of radiation or concentrations of radioactive material present.

a~ Contrary to the above, on or before September 3, 1985, the licensee failed to adequately evaluate the removable contamination levels on equipment following attempted decontamination to ensure compliance with 10 CFR 20.101(a) and 10 CFR 20.103(a). A drop light contaminated to about 600,000 dpm/100 square centimeters had been returned to a storage area reserved for mater'al that had been decontaminated to less than 500 dpm/100 square centimeters. 1

AEP:NRC:0954 Attachment Page 3

b. Contrary to the above, on September 3 and 4, 1985, adequate surveys of

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numerous small radioactive material storage areas including the diving suit storage area had not been conducted to ensure compliance with 10 CFR 20.203(b). This resulted in improperly posted or unposted radiation areas."

Res onse to Item 2 a Corrective Actions Taken and Results Achieved The entire storage area was posted as a contaminated area.

Corrective Action to be Taken to Avoid Further Violations The program to evaluate the removable contamination on equipment following decontamination to ensure compliance with 10 CFR 20.101(a) and 't0 CFR 20.103(a) appears to be adequate. The area where the contaminated drop light was found is available to all plant personnel and it is likely that the noted material was placed in the area prior to decontamination.

A method to control the transport of radioactive material within the controlled areas will be established in order to prevent the unauthorized addition to or alteration of the configuration of material in these storage areas. This method will be established and functional by January 1986.

Date (/hen Full Con liance Uill be Achieved Full compli;ance was achieved on September 3, 1985 when the storage area was posted as a contaminated area.

Response to Item 2 b Corrective Action Taken and Results Achieved The radioactive material storage areas were immediately resurveyed upon discovery and properly posted.

e Corrective See Response Actions Taken to Avoid Further Violations to Item 2 a.

AFP:NRC:0954 Attachment Page 4 Date LJhen Full Com liance will be Achieved Full compliance was achieved on September 4, 1985 when the areas were resur veyed and properly posted.

NHC Xtem No "Technical Specification 6.11 requires adherence to radiation protection procedures. Procedure 12 TflP 6010.RAD.401, Access Control Facility and Controlled Area Entry and Exit, requires thorough frisking or decontamination following a portal monitor alarm.

Contrary to the above, on September 5, 1985, the inspectors observed two contractor employees violate this personal monitoring requirement, One of the workers left the main access control area without additional frisking or decontamination after receiving an alarm on the portal monitor. The second worker exited the controlled area through a less sensitive portal monitor at the contractor access control area without performing additional frisking or decontamination after rece'ivin" several alarms on the main access control portal monitor.>>

Corrective Actions Taken and Results Achieved All contractors will be notified by November 15, 1985 that any willful disregard of Plant safety rules or Plant regulations regarding radiation protection or monitoring will render the contractor and its employee(s) subject to disciplinary action.

Co>r ective Actions Taken to Avoid Further Violations Xnitial and on-going training will be given to all site and contractor personnel to ensure they understand the importance of and their individual responsibility to the radiation protection program.

Date llhen Full Com liance 'tU.ll be Achieved Notification to contractors will be accomplished by November 15, 1985.

Training will be on-going.

AEP<NRC:0954 Attachment Page 5 NHC ldenti fied ';Jeakneos

"...the licensee should conduct a thorough evaluation to identify licensee commitments, technical problems, design and procedural solutions to identified problems, and a corrective action complet'on schedule for ESF and non-ESF filtration systems in a timely manner in the areas of (1) the potential for fire protection deluge systen leakage or activation damaging charcoal adsorbers, (2) filter housing drain line configuration and valving, and (3) the potential for an incident similar to the one that occurred at the Hatch plant."

Res onoe to ':Jeakness The first and third concerns discussed above will be rectified by RFC DC-12-2890. This RFC was written to change the charcoal filters fire protection deluge systens from automatic to manual. The D, C. Cook Plant has 19 filter units that are equipped with charcoal filters, and of these 19 units, 16 now have autonatic Fire Protection Deluge Systems, one has,a manual system, and two have no internal fire protection systems. Because of the low nass of combustibles in these three nonautomatic protected units, coupled with the low potential for charcoal icnition, automatic systems were not specified or installed in then. RFC DC-12-2890 addresses modifying 12 of these 16 units; the (4) recirculating units in the lower containnents are not easily accessible during plant operation and therefore will renain automatic. The RFC has two parts to be performed, The first part of the HFC is to clooe the gate valve upstream of the three-way valve for 12 of the 16 systems. This would stop the leal<age,problem and prevent an inadvertent actuation of the oysten. The second part is to replace the carbon steel check valves on the deluge drain piping with stainless steel swing check valves for 11 of the 16 systems. (One of the twelve systems utilizes a deluge valve and not a thrce-way valve, There is no, drain problem associated with this unit. The drains from the fire protection system serving the four filter units in the containment use gate valves in lieu of check valves. These valves have not been a problem,) Experience has shown that the carbon steel check valve- are subject to the corrosive action of the water and do not properly function, therefore, they will be'eplaced by stainless steel check valves.

The second concern identified in the JJHC weakness will be corrected by Revision 2 of RFC DC-12-1316. This revision and an addendum will modify the dr ain syotens of the charcoal and/or HEPA filter units to preclude any aS.r bypass.

The D. C. Cook Plant has 27 filter units that are equipped with charcoal and/or llEPA filter sections; however, only 24 of these units h"ve drains. The three filter units that do not have drains are the aforementioned units which have charcoal filters without an automatic fire protection system. HFC DC-12-1316, Revision 2, has been written to modify 19 filter units to contain gate valves or plugs in each individual drain line or drain, respectively. Gate valves will be used instead of check valves to prevent water from backing up into the units. The (4) recirculating units in the lower containnents will not have their drains modified since these units function usin total recirculation to clean the lower containments> atmosphere. The TSC filtration unit is already properly isolated, All of the wor!< covered by the two afor e-mentioned HFC's will be conpleted by the end of 1986.

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