ML20073Q417

Responds to NRC Re Violations Noted in IE Insp Repts 50-315/83-03 & 50-316/83-03.Corrective Actions: Personnel Instructed in Proper Method of Sampling Control Tank Gas Space & Administrative Controls Implemented

ML20073Q417
Person / Time
Site:	Cook
Issue date:	04/04/1983
From:	Hunter R INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20073Q406	List: ML20073Q417
References
AEP:NRC:0791, AEP:NRC:791, NUDOCS 8304290105
Download: ML20073Q417 (2)

Text

,

lNDIANA & MICHIGAN ELECTRIC COMPANY

! P. O. BOX 18

'JWLING GREEN ST ATION N EW YORK, N. Y.10004 April 4, 1983 AEP :NRC:0791 Donald C. Cook Nuclear Plant Unit Nos. 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 IE INSPECTION REPORTS NO. 50-315/83-03 (DRMS) and NO. 50-316/83-03 (DRMS)

Mr. James G. Keppler Regional Administrator Office of Inspection and Enforcement Region III 799 Roosevelt Road Glen Ellyn, ILL 60137

Dear Mr. Keppler:

This letter and its Attachment respond to Mr. C. J. Paperiello's letter of March 3,1983 which forwarded to us the subject Inspection Reports. The Notice of Violation attached to Mr. Paperiello's letter identiffed two items of violation. The Attachment to this letter provides the required response to those two items.

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

Very truly yours, R. S. Hunter Vice ' resident RSH: sag cc: John E. Dolan - Columbus M. P. Alexich R. W. Jurgensen W. G. Smith, Jr. - Bridgman R. C. Callen G. Charnoff NRC Resilent Inspector at Cook Plant - Bridgman 8304290105 830427 RR 81983 PDR ADOCK 05000315 0

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ATTACHMENT TO AEP :NIIC:0791 s

' The Notice of Violation attached to IE Inspection Reports No. 50-315/

83-03 (DRMS)- and'No. 50-316/83-03 (LRMS) identifies;two violations uncovered during the NRC inspection conducted on February 14-15, 1983.

Quoting from the inspection report they are:

Item 1.

" Technical Specification 5.3.1 states, in part, that Edetailed written procedures shall be prepared and adhered

-to.

Contrary to the above, on February 11, 1983, a chemistry technician failed to operate sampling system valves in accordance with Procedure 12 THP 6020 LAB.038-during

-collection of a volume control tank gaseous sample..An

- unplanned airborne release resulted.

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

Item 2.

" Technical Specification 5.3.3 states, in part, that changes to plant procedures will be reviewed and approved in writing prior to implementation.

Contrary to the above, on February 11, 1983, management allowed the Unit i volume control tank to be. sampled using changes to Procedure THP 6020 LAB.038 which had not been reviewed and approved in writing, i

j-

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

RESPONSE TO ITEMS 1 AND 2 r-l l'

The events giving rise to the two violations detailed above were l

reported to the NRC in Revision 1 to Licensee Event Report No. 010.*

The LER describes the corrective action taken to avoid further noncompliance - Full compliance has been achieved as of the date of this letter. A copy of the LER is attached.

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, EVENT CESCRIPTION AND P903ABLE CONSECUENCES h toi:il0N -FEBRUARY 11,1983, AT 0900 HRS. A PLANNED GAS SAE.ING EVOLUTION WHICH PRODUCED AN '

!a i a l [ EXPECTED GAS' RELEASE:0F UNEXPEC1ED MAGNITUDE WAS DETECTED BY AN ELEVATED U i-

.ici.,il UNIT 2 VENT STACK GASEOUS MONITOR ~(IR-26 AND 2R-26 RESPECTIVELY) READING. 'THIS EVENT r

-lo i s i ICONTINUED UNTIL APPROXIMATELY 1040 HRS. ON FEBRUARY 11, 1983.

A SECOND EVENT (UNEXPECTr

u. u i LED, THEREFORE, UNPLANNED) OCCURRED AT 1340 HRS. ON FEBRUARY 11, 1983, WHICH WAS DETECTED i Io Iii lBY AN-ELEVATED UNIT 2 VENT STACV, GASE0US MONITOR (2R-26) READING. THIS EVENT CONTINUED-~t

.,o ilUNTIL APPROXIMATELY 1530 HRS. ON FEBRUARY 11, 1983.

(SEE ATTACHED' SUPPL'EMENT)

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. cAusE cE:CRIPTION AND CCRRECTIVE ACTICNS tilo!IDURING SAf1PLING~0F THE UNIT 1 VOLUME CONTROL-TANK (VCT) GAS SPACE. THE SAMPLE LINE I.

iIDRAIN VALVE-(NS-186) LOCATED IN THE NUCLEAR SAMPLING ROOM WAS INADVERTENTLY LEFT IN t: it t

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,,i-l lTHE OPEN POSITION. THIS ALLOWED GAS TO G0 FROM NS-186 THROUGH THE CLEAN SUMP TANK i

lTHE WASTE HOLDUP TANKS CONTINUING THROUGH THE AUXILIARY BUILDING VENTILATION SYST i,i:l i

i,14 lTHE UNIT VENT STACKS.

(SEE ATTACHED SUPPLEMENT) as

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-ATTACHMErlT TO LER#

SUPPLEriEt1T TO EVErlT'DESCRIPT10fl

.0N FEBRUARY 11, 1983,=AT 0900 HOURS A PLAN!1ED GAS SAMPLING EVOLUTI0fl

'UHICH PRODUCED AN EXPECTED __ GAS RELEASE OF UtlEXPECTED l1AGNITUDE WAS DETECTED BY AN ELEVATED UNIT 1 A!!D UNIT 2 VENT STACK GASEOUS !!ONITOR (IR-26 AND 2R-26.RESPECTIVELY) READING.

THIS EVENT CONTINUED UtlTIL APPR0XIMATELY.1040 HOURS ON FEBRUARY 11,1983. A SEC0tlD EVENT (Ut!-

EXPECTED, THEREFORE, UNPLANNED)' OCCURRED AT 1340 HOURS ON FEBRUARY 11, 1983, WHICH UAS DETECTED BY AN ELEVATED UNIT 2 VEllT STACK GASE0US MONITOR (2R-26) READI!!G. ' THIS EVENT C0tiTIflVED UNTIL APPR0XIt!ATELY 1530 HOURS Off FEGRUARY 11, 1983.

DURING THESE TIME PERIODS, A TOTAL OF 37.7 Ci UAS RELEASED AT A RATE OF 2.06 E-3 Ci/SEC, WHICH IS 4.81". OF TECHilICALSPECIFICATIONAPPE!!DIXB,SECTI0fl2.1.2.a(1).

C0tlSERVATIVELY ESTIMATIt!G THAT BOTH UtlIT'S DETECTORS INDICATED THE !!AXIMU!t RELEASE RATE sit 1ULTAt!E0VSLY, THE t1AXIrlUM TOTAL RELEASE RATE WAS 5.48 E-2 Ci/SEC WHICH-IS 92.39% OF TECilflICAL SPECIFICATI0tl APPENDIX B. SECTION 2.1.3.a(1).

THIS OCCURRED WITil00T THE SAMPLING AND ANALYTICAL REQUIREI1ENTS OF TECH-flICAL SPECIFICATI0tl APPENDIX B. 2.4.4.E.

SUPPLEt1EllT TO CAUSE DESCRIPTI0tl DURIllG SAf1PLING OF THE UtlIT 1 VOLUME C0flTROL TAtlK (VCT) GAS SPACE, THE SA!!PLE LINE DRAlti VALVE NS-186 LOCATED I:1 THE !!UCLEAR sat 1PLIrlG ROOM WAS INADVERTENTLY LEFT Ill THE OPEft POSITI0tl, UHEtt AT THIS POINT Ill THE PROCESS IT WAS PROCEDURALLY REQUIRED TO BE CLOSED.

THIS ALLOWED GAS D C0 FR0lt flS-18G THROUCH THE CLF.Afl SU!:P TAtlK TO THE WASTE HOLDUP TAtiKS 'CONTIrlUI!C TOUG!! THE A3XILIARY SUILDI!!G VENTILATIOil SYSTE'l TO 4

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r EATTACHMENT'TO LERe-SUPPLEMENT TO CAUSE DESCRIPTION, CONTINUED

-THE UNIT VENT STACK. WHILE? VALVING -It' THE SAMPLE CONTAINER A PIECE OF PLASTIC TUBING USED TO CONNECT.THE SAMPLE CONTAINER WITH THE SAFPLE PIPING SEPARATED AT THE CONNECTION CAUSIf!G ADDITIONAL RADIO--

GAS TO BE DISCHARGED TO TFE UNIT 1 VEf(T SUCK. THE SAMPLE POINT ROOT VALVE (1-CS-374) WAS CLOSED, TO-ISOLATE THE RELEASE.

AT APPR0XIMATELY

--1340 HOURS 1-CS-374 WAS OPENED, THE NORMAL OPERATING POSITION, WHICH CAUSED THE SECOND EVENT TO OCCUR, SINCE NS-186 WAS INADVERTENTLY LEFT

-IN THE OPEN POSITION.

IMMEDIATELY FOLLOWING DETECTION OF THE SECOND EVENT 1-CS-374 WAS RECLOSED. AT APPR0XIMATELY 1855 HOUR ON FEBRUARY 11, 1983, NS-186 UAS DISCOVERED OPEN AND PLACED IN THE CLOSED POSTION. VALVE 1-CS-374 WAS THEN RE0PENED WITH N0 GASE0US RELEASES BEING DETECTED.

TO PREVENT RECURRENCE OF THIS EVENT, THE FOLLOWING MEASURES HAVE BEEN TAKEN:

1)

THE PERSONNEL INVOLVED HAVE BEEN INSTRUCTED IN THE PROPER METHOD OF SAMPLING THE VCT GAS SPACE.

2)

ADMINISTPATIVE CONTROLS HAVE BEEN IMPLEMENTED REQUIRING THAT THE PROCEDURE FOR SAMPLING THE VCT GAS SPACE BE IN HAND DUR-ING THE SAMPLING PROCESS.

3)'

THE CHEMICAL SECTI0f! SAMPLE PROCEDURES WERE REVIEWED TO INSURE THAT EACH PROCEDURE REFLECTED THE CUMENT AND CORRECT METHOD OF SAMPLING.

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4)

A PRECAUTIONARY NOTE WAS ADDED TO THE SAMPLING PROCEDURE STATING THAT VCT SAMPLES WILL NOT BE TAKEN FOR TESTING OR TRAINING PURPOSES AND THAT THE VCT WILL ONLY BE SAMPLED BY DIRECTION OF THE PLANT CHEMICAL SUPERVISOR.

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St';j'LEf1ErlT T0 CAUSE DESCRIPTI0fi, C0flTIf!' ED J

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IMPR0VIrlG THE GErlERAL CONDITI0fl 0F~ THE SAMPLING SYSTEM BY:

VERIFYIrlG THAT 'ALL SAtiPLE VALVES -It! THE tiUCLEAR SA!1PLE R00ft HAVE IDEfiTIFICATI0rl TAGS; AND REPLACIllG HISSIllG VALVE HANDLES Otl SAllPLE VALVES. VALVE HAllDLES ARE CURREllTLY BEING FABRICATED FOR THIS PURPOSE.

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m-JATTACHMENT TO LER s

-IE INSPECTION _ REPORT 50-315/83-03, 50-316/83-03, COVERING THE SUBJECT g

0F THIS LER, ? LISTED SEVERAL UNRESOLVED ITEMS..THESE ARE DESCRIBED

'BELOW:

UNRESOLVED ITEM'- 315/83-03-01; 316/83-03-01

-N

O. PROCEDURE

CHANGE HAD BEEN APPROVED TO REFLECT THE IN0PERABLE FLOW MEASURING DEVICE OR USE OF THE MARINELLI SAMPLE VESSEL.

STATUS - S'EE PREVENTIVE MEAS'URE N0.2.

THE DEFECTIVE FLOW'INSTRU-MENT HAS BEEN REFLACED.

PROCEDURAL CHANGES HAVE BEEN MADE TO

~ ALLOW THE USE OF THE MARINELLI SAMPLE. VESSEL.-

UNRESOLVED ITEM. 315/83-03-02; 316/83-03-02 FAILURE TO OPERATE 1HE SAMPLING SYSTEM VALVES IN-ACCORDANCE WITH PROCEDURE 12.THP 6020 LAB.038.

STATUS - SEE PREVENTIVE MEASURE N0.2.

UNRESOLVED ITEM - 315/83-03-03; 316/83-03-03 SEVERA'. PROBLEMS WERE NOTED CONCERNING THE METHOD OF CALIBRATION OF 1R-26 AND 2R-26.

STATUS - NO. ADDITIONAL ATTEMPTS WILL BE MADE TO CALIBRATE 1R-26 AND 2R-26, OTHER THAN OUR CURRENT METHOD OF USING

~

CAP. SOURCES.

THESE RADIATION MONITORS ARE CURRENTLY SCHEDULED TO BE REPLACEb BY MAY 31, 1983.

MR. D.C. PALMER (PLANT RADIATION PROTECTION SUPERVISOR) CONTACTED MR.

i-P.C. LOVENDALE BY PHONE ON 3-18-83.

MR. LOVENDALE DID NOT EXPECT THE PLANT 70 1AKE FURTHER ACTION AT THIS TIME,

'ESPECIALLY WITH THE RADIOGAS MONITORS BEING REPLACED.

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' ATTACHMENT TO LER.

UNRESOLVED ITEM -i315/83-03-04; 316/83-03-04 LOSS OF THE UNIT 2 P-250 PRINT 0UT. COVERING THE PERIOD OF THE 3 RELEASE.

STATUS - WE ARE EXPLORING METHODS OF PREVENTING A RECURRENCE.

UNRESOLVED ITEM - 315/83-03-05; 316/83-03-05

~

THE FAILURE TO CLASSIFY THE RELEASE AS AN UNUSUAL EVENT AS RE-QUIRED'BY PMP 2080 EPP.001.

STATUS - THIS MATTER STILL REMAINS UNDER REVIEW IN LIGHT OF THE NEW RADIOLOGICAL TECHNICAL SPECIFICATION ArtiENDMENTS N0.69 TO UNIT ONE AND N0.51 TO UNIT TWO; AND THE NEW RADIATION MONITORS TO BE IN SERVICE BY MAY 31, 1983. THE OPERATING PERSONNEL HAVE BEEN MADE AWARE THAT ALL RELEASE MONITORS NEED TO BE CONSIDERED WHlfi CLASSIFYING A RELEASE IN

-ACCORDANCE WITH THE CURRENT EMERGENCY PLAN GUIDANCE.

UNRESOLVED ITEM - 315/83-03-06; 316/83-03-06 THE INSPECTORS NOTED SEVERAL PROBLEMS WITH THE GENERAL CONDITION OF THE NUCLEAR SAMPLING SYSTEM.

-STATUS - ADDRESSED IN THE BODY OF THE LER (REFER TO PREVENTIVE MEASURE ITEMS)

UNRESOLVED ITEM - 315/83-03-07; 316/83-03-07 DURING THE RELEASE, AT LEAST TWO CONTINU0US AIR MONITORS (CA'45)

ALARMED.

THE GAS ASSOCIATED WITH THIS RELEASE SHOULD HAVE RE-MAINED CONTAINED IN THE SAMPLING SYSTEM, WASTE DRAIN SYSTEM, AND AUXILIARY BUILDING VENTILATION SYSTEM. A LOSS'0F A FLOOR DRAIN LOOP SEAL MAY HAVE BEEN THE SOURCE.0F GAS IN THE AUXI-LIARY BUILDING THAT CAUSED THE CAM ALARMS.

> STATUS - THIS MATTER REMAINS UNDER REVIEU l