ML17328A767
| ML17328A767 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 11/06/1990 |
| From: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | Davis A NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| AEP:NRC:1125G, NUDOCS 9011140007 | |
| Download: ML17328A767 (7) | |
Text
ACCELERATED DISTRIBUTION DEMONRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9011140007 DOC.DATE: 90/11/06 NOTARIZED: NO DOCKET FACXL:50-315 Donald C.
Cook Nuclear Power Plant, Unit 1, Indiana 05000315
'50-316 Donald C.
Cook Nuclear Power Plant, Unit 2, Xndiana 05000316 AUTH.NAME AUTHOR AFFILIATION ALEXICH,M.P.
Indiana Michigan Power Co. (formerly Indiana
& Michigan Ele RECIP.NAME RECIPXENT AFFILIATION R
DAVIS,A.B.
Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 901005 ltr re violations noted in Insp Repts 50-315/90-20
& 50-316/90-20.
D DISTRIBUTION CODE:
IE06D COPIES RECEIVED-LTR ENCL SIZE-TITLE: Environ
& Radiological (50 DKT)-Insp Rept/Notice of Violation Respons NOTES RECIPIENT XD CODE/NAME PD3-1 LA COLBURN,T.
INTERNAL: AEOD/ANDERSON,R COLLINS,D RGN 2
NMSS/SGTB 4E4 NRR/DREP/PRPB11 NUDOCS-ABSTRACT OGC/HDS1 RES RGN3 FILE 01 COPXES LTTR ENCL 1
0 1
1 1
1 1
1 1
1 2
2 1
1 1
1 1
1 1
1 RECIPXENT ID CODE/NAME PD3-1 PD AEOD/DSP NMSS/LLOB 5E4 NRR/DLPQ/LPEB10 NRR/PMAS/ILRB12
~MG~.
02 GN3 DRSS/RPB RGN4 MURRAY,B COPIES LTTR ENCL 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 S'XTERNAL:
EG&G SIMPSON, F NSXC 2
2 NRC PDR 1
1 D
NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACI'HE DOCUMENT CONTROL DESK ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 24 ENCL 23
Indiana Michigan~
Power Compan~
P.O. Box 16631 Cofumbus, OH 43216 INDIANA NICHIREN IaOMfER AEP:NRC:1125G 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 Report Nos.
50-315/90020 (DRSS) and 50-316/90020 (DRSS)
RESPONSE
TO NOTICE OF VIOLATION U.'S. Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555 ATTN:
A. B. Davis November 6, 1990
Dear Mr. Davis:
This letter is in response to Mr. L. R. Greger's letter dated October 5,
1990, which forwarded the report on the routine safety inspection conducted by members of your staff on August 27 through August 31, 1990, at the Cook Nuclear Plant.
The Notice of Violation attached to Mr. Greger's letter identified one Severity Level IV violation associated with the performance of radiological and physical hazards evaluations for a test of a chemical and volume control system safety valve.
Our response to the Notice of Violation is provided 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 dfw Attachment g
9011140007 901106 PDR ADOCK 05000315 Ll PDC
Mr. A. B. Davis AEP'NRC'1125G cc:
D. H. Williams, Jr.
A. A. Blind J.
R. Padgett G. Charnoff NRC Resident Inspector
- Bridgman NFEM Section Chief
ATTACHMENT TO AEP:NRC:1125G
RESPONSE
NRC Violation "10CFR20.201(b) requires that each licensee make or cause to be made such surveys as (1) may be necessary for the licensee to comply with the regulations in 10CFR Part 20 and (2) are reasonable under the circumstances to evaluate the extent of the radiation hazards that may be present.
10CFR20.201(a) defines a
survey as 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.
Contrary to the above, on July 11,
- 1990, a test of the operability of a highly contaminated Chemical Volume and Control System safety relief valve was conducted without adequately evaluating the extent of the radiological and physical hazards associated with the new test equipment being used.
The test malfunctioned which resulted in an employee receiving an unnecessary radiation exposure and a minor physical injury."
Response
to Violation The cited violation involves a contamination event that occurred during performance of a lift check test on a chemical and volume control system (CVCS) safety valve.
The test was performed using a newly-acquired test machine which, in order to more closely simulate actual in-service system conditions, provides a larger volume of air to the valve than that applied in prior lift check tests.
This was the first test performed using the new test rig on a contaminated valve.
Other tests had previously been performed on non-contaminated valves with the new rig, however, use of a HEPA venting system was not required.
As a result, the affect of the increased test air volume on the HEPA configuration used in testing the contaminated CVCS safety valve had not been assessed.
When the safety valve lifted (at approximately 600 psig),
a funnel being used as part of the HEPA venting system was blown from the valve and penetrated a wall of the temporary herculite tent surrounding the test rig.
The funnel struck a
radiation protection technician standing outside the enclosure, contaminating the technician and the surrounding area with contaminated water and hot particles (although the funnel tore the herculite, it remained inside the tent).
A dose evaluation performed after the event concluded that no exposure limits were exceeded as a result of the personnel contamination.
Our investigation has concluded that the cause of the event is attributable to the use of a temporary enclosure of insufficient volume to effectively contain the high volume of air produced by the new test rig when the safety valve lifted.
(1)
Corrective Action Taken and Results Achieved After the contamination event, work was immediately stopped and the test rig area (both inside and outside the temporary enclosure) was decontaminated.
A "Permacon" enclosure with rigid walls and sufficient volume to contain the test rig discharge from safety valve lift check testing was erected.
The Permacon enclosure also incorporates permanent ductwork for HEPA venting of the discharge.
The new enclosure has been used successfully in subsequent safety valve tests.
(2)
Corrective Action Taken to Prevent Further Uiolations Use of the enlarged, rigid wall test enclosure with permanently installed ductwork for HEPA venting the test air discharge volume will more effectively accommodate use of the new safety valve test rig.
The test procedure has also been revised to include additional precautions for controlling discharges from the safety valves being tested with the higher capacity tester.
ln addition, the Cook Nuclear Plant Radiation Protection Section now reviews all maintenance procedures involving work activities where potential radiation hazards exist.
This review, performed before the maintenance procedures are submitted to PNSRC for approval, will enable radiation protection personnel to specify any special precautions/controls required to ensure that potential radiation hazards are appropriately addressed in completing future maintenance procedures.
(3)
Date When Full Compliance will be Achieved Full compliance was achieved on July 11,
- 1990, when the safety valve test was discontinued and the valve restored to a safe configuration.
Compliance will be maintained through the actions discussed in (2).above.