ML20115C615
| ML20115C615 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 03/13/1985 |
| From: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20115C592 | List: |
| References | |
| AEP:NRC:0928, AEP:NRC:928, NUDOCS 8504180482 | |
| Download: ML20115C615 (9) | |
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-lNDIANA & MICHIGAN ELECTRIC COMPANY P.O. BOX 16631 COLUMBUS, OHlO 43216 t
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March 13, 1985 j
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AEP:NRC:0928 b
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Donald C.-Cook Nuclear Plant Unit Nos. 1 and 2~
i Docket Nos. 50-31$ and 50-316 License Nos. DPR-58 and DPR-74 Nhc I.E. INSPECTION REPORT NO.'50-315/85-02 (DRSS);
50-116/85-02 (DRSS)
Mr. James G. Keppler Regional Administrator U. S. Nuclear.Regulakory Commission Region.III i
799 Roosevelt Road
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Glen Ellyn,JIllinois 60137
Dear Mr. Kappler:
This letter. responds to Mr. J. A. Mind's letter dated February 11 1985, which forwarded the subject Inspection Report of the routine safety inspection conducted by your staff at:the 1
i Donald C. Cook Nuclear Plant during the period Januan 7-11 1985.
The Appendix to Mr. Hind's.-letter identified four violations,Lin the area of Energency Preparedness.
Also, the subject Inspection Report identifi M Open Item 50-315/85-02-01, 50-316/85-02-01.
l As requested by Mr. J. A. Hind's letter attached are the i
responses to the four violations (Attachment A) and to Open' Item 50-315/85-02-01, 50-316 Attachment B is made pu/85-02-01 (Attachment B).
The response to j
i rsuant to section 50.54(f) of Title 10,-
l Code of Federal Regulations.
i Mr. Hind's letter also requested that we address the problem i
of inconsistencies between and within the Emergency Plan and Emergency Plan Procedures.
We recgnize the necessity for one individual.at:the site to-oversee all the Emergency Plan i
Procedures as well as the Emergency Plan.
However as a result of staff turnover and the time involved in locating a, qualified
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person to fill the position of Emergency Preparedness Coordinator 2
we have been unable to assign this review responsibility to one individual.
We are actively seeking to fill the position of Emergency Preparedness Coordinator and' intend to do so in the near I
future. EIn addition, the Corporate office will begin reviewing i
Emergency Plan Procedure revisions for inconsistencies between and i~
within the Emergency Plan-and Emergency Plan ~ Procedures.
This added review in addition to the hiring of a full time Energency' Preparedness Coordinator should eliminate the problem of inconsistencies in the Emergency Plan and Emergency; Plan
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. Procedures.
g4190 8l f MAR 151985 I
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Mr. James G. Keppler AEP:NRC:0928 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, t
M. P. Alexich
$ g5)
Vice President edg-Enclosures cc:
John E. Dolan W. G. Smith, Jr.
George Bruchmann R.
C. Callen G. Charnoff NRC Resident Inspector - Bridgman Y
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1 ATTACHMENT A Response to Four Violations in part, that o
Technical Specification 6.8.2 states,ically as set forth in "1.
procedures are to be ' reviewed period the administrative procedures.'
Procedure PMI-2010, Revision 10, states that-'all effective instructions and procedures shall be reviewed biennially'.
Contrary to the above, procedure PMI-2070, Revision 6, dated September 5, 1979, has not been reviewed on a biennial
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. schedule.
j-This is a Severity Imvel V violation (Supplement VIII)."
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RESPONSE
Corrective Actions Taken and Results Achieved ~
1
" Training" Cook
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PMI-2070,ining progra,m; establishes guidance for all D. C.
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Plant tra s.
It was recognized that PMI-2070 j
required substantial revision as part of a coordinated effort i
to achieve INPO accreditation.
This review process began on April-30, 1984.
The review comparing this PMI to the Codes 4
and Standards Matrix was completed on November 28, 1984.
Corrective Actions Taken to Avoid Further Noncompliance PMI-2070, Revision 7, was approved by the Plant Nuclear Safety Review Committee (PNSRC) on February-26, 1985 and became effective March 5,.1985.
This procedure will be reviewed. biennially.
Date When Full Compliance Will Be Achieved Full compliance was achieved on February 26, 1985.
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"2.
10 CFR 50.54(q) requires in part, that a licensee authorized to operate a nuclear powe,r reactor shall follow and maintain in effect emergency plans which meet the standards in j
this p(b) of this part and the requirements in Appendix E to,.
50.47 art.
10 CM Part 50 Appendix E,Section IV.F states,'
t in art, that the prgram ko provide for training of i
emp oyees shall include a description of specialised initial i
tra ning and periodic retraining programs to be provided to L
each-of the following categories of emergency personnels a.
Directors and organization;/or coordinators of the plant emergencyand b. Personnel responsible j
assessment, including control' room shift personnel.
Section 12.3.15.1.2 of the Donald C. Cook Nuclear Plant Emergency i
Plan states, in part, that.specialised initial training and retraining for personnel responsible for accident assessment is provided.-
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Page Two Contrary to the above, no specialized initial training or periodic retraining is or has been provided to personnel who j
are assigned to key radiation protection and assessment positions.
l This is a Severity Level IV violation (Supplement VIII)."
l
RESPONSE
t Corrective Actions Taken and Results Achieved In October of 1984, a-draft outline of a training program j.
that satisfies 10 CFR Part 50, Appendix E, Section IV.F, sub-l j
items a'and b was prepared. - A plan and schedule to implement-this program was approved on February 7, 1985.
The first lecture was conducted on February 25, 1985.
Corrective Actions Taken to Avoid Further Noncompliance f
i PMP-2082.EPP.006 ItwillprovikencyPlanTraining",isnowbeing "Emer revised.
e for the initial training and periodic retraining required by 10 CFR Part 50,ill beAppendix E,Section IV.F, sub-items a and b..The program w j
conducted on a calendar year cycle.
l Date When Full Compliance Will Be Achieved Principal participants in the on-site Emergency Response Organization will complete the initial training program by April 18, 1985.
The balance of the participants including i
shift supervisors, will complete the initial-tralning program by Decader 31, 1985.
PMP-2082.EPP.006 will be revised by j_
July 31, 1985.
i "3.
10 CFR 50.54(q) requires that. nuclear power reactor licensees follow and maintain in effect emergency plans which meet the i
requirements of Appendix E to 10 CM Pad 50 and the planning standards of 50.47 that a licensee's e(b).
Section IV.B of Appendix E requires
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mergency plans shall include information l
to demonstrate compliance with the following:
l The means for determining the magnitude and for continually assessing.the impact of the release of i
radioactive material shall be described, including l
emergenq action levels that are to be used as criteria for notification and particiption of local and State agencies, the Commission and other Federal agencies, e
determining gency action, levels that are to be used for i
and the emer when and what type of protective measures should be considered within and outside the site boundary to protect. health and safety.
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e Attachment A AEP:NRC:0928 Page Three.
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Section 12.3.3.2.2 of the D.
C. Cook Nuclear Plant Emergency i
Plan states in part that the Plant Manager is designated the onsite Emegency Coordinator, and that upon initiation of the i-Emergency Plan, the Plant Manager will. assume full i
responsibility for recommending offsite emergency actions to
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the State and County response agencies.
Section 12.3.3.1 of the Emergency Plan states in part that the Shift Supervisor is the individual responsible for the emergency response functions until relieved by the Plant Manager.
1 Contrary to the above, individuals designated to fill emergency roles can not function as required in that the 4
i majority of the Shift Supervisors who have the initial I
responsibility and authority of the Onsite Emergency i
1
- Coordinator to make offsite prctactive action i
recommendations, were incapable during this inspection of j
determining when and what tWe of protective measures should be considered outside the alte boundary to protect public health and safety.
j This is a Severity Level IV violation (Supplement VIII)."
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RESPONSE
j Corrective Actions Taken and Results Achieved l
i Shift Supervisors have been designated to attend the training required for on-Site Emergency Coordinators as part of the i
Emergency Preparedness Training Program.
This includes a i
specific module on Protective Action Recommendations.
This Emergency Preparedness Training Program was initiated on j
February 25, 1985.
corrective Actions Taken to Avoid Further Noncompliance i
j PMP-2082.EPP.006, " Emergency Plan Training" is now being l
revised.
It will provide for participation,of Shift Supervisors in the On-Site Emergency Coordinator portions of j
the Emergency Preparedness Training Program.
Date When Full Compliance Will Be Achieved r
l Shift Supervisors will complete the training required for on-Site Emergency coordinators as part of the hergency Preparedness Training Program by December 31, 1985.
PMP-2082.EPP.006 will be revised by July 31, 1985.
I "4.
10 CFR Part 50 Appendix E, Section IV.B states in part that
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licensee's ara, required to have emergency action levels that
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are to be used as criteria for determining the need for i
notification and participation of local and State agencies,.
the Commission, and other Federal agencies...
10 cm Part I-50, Appendix E,Section IV.C states-in part that the
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Attachment A AEP:NRC:0928 Page Four j
i emergency classes defined shall include: (1) notification of
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unusual event, (2) alert, (3) site area emergency, and (4) i general emergency.
10 CFR Part 50, Appendix E IV.D.3 states i
L in part that a licensee shall have the capability to notify l
responsible State and local governmental agencies within 15 l
minutes after declaring an emergency.
I Contrary to the above, on April 4, 1984, after a loss of both emergency diesels for Unit 2, a notification of unusual event i
was not declared until 37 minutes after the declaration of an unusual event was required based on this event, the rewired notifications to offsite authorities were not completed until l-54 minutes after the initiation of the event.
l This is a Severity Level IV violation (Supplement VIII)."
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RESPONSE
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Corrective Action Taken and Results Achieved
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We share the concern that it took 37 minutes to classify this i
event.
Shift Supervisors have been designated to attend the training required for on-Site Emergency Coordinators as part of the 2mergency Preparedness Training Program.
This i
training includes a s acific module' entitled " Emergency 1
Classification System.
This Emergency Preparedness Training j
Program was initiated on February 25, 1985.
1 In regards to the required notification of.offsite j!
authorities, we believe that our personnel acted in both an appropriate and timely manner, in accordance with our i
Emergency Plan Procedures.
In the event cited above, i.
notification of the Michigan State Police and the Berrien County Sheriff's Department was completed within :L5 minutes and 17 minutes, including an a,nnotation by shift personnel i
respectively of the declaration of the
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-Unusual Event, i
that the State Police were having difficulty ~with their phone.
We repost that consideration be given to withdrawing
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this Item of Noncompliance in light of this information.
. Corrective Actions Taken to Avoid Further Noncompliance PMP-2082.EPP.006
" Emergency Plan Training" is now being l
revised.
Itwillprovideforparticipation,ofShift Supervisors in the On-site Emergency Coordinators portions of the Emergency Preparedness Training.
Date When Full Compliance Will Be Achieved i
Shift Supervisors will complete the training required for on-l Site Emergency Coordinators as part of the mergency Preparedness Training Program by December 31, 1985.
PMP-l 2042.EPP.006 will be revised-by July =31, 1985.
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ATTACHMENT B i.
Open Item-50-315/85-02-01, 50-316/85-02-01 1
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"... In a' letter from Mr. R. F..Hering (AEP) to Mr. James l
G. Keppler CNRC) dated April 27, 1984 (AEP:NRC30879A, licensee l
representat:ves stated that, " Emergency Plan.Procedur)es have been revised to require the use of the 50-foot level instrumentation as l
the primary source for wind speed and wind direction in dose assessment calculations."
However, PMP 2080.EPP.006, " Initial
. Dose Assessment," was not revised to incorporate the use of 50 l
. foot level data until December 28, 1984, and no temporaq chan e to this procedure was made in the time between NRC identificat on i
of this item and the December procedure revision.
After several discussions with licensee representatives during the inspection, it appeared the failure to revise PMP 2080.EPP.006 was inadvertent.
The April 27, 1984 letter was sent either assuming PMP 2080.EPP.006 had already been revised, or had overlooked the j
fact that it needed to be revised.
However, the fact that PMP 2080.EPP.006 was using the 150-foot level instrumentation in lieu of the 50-foot instrumentation was acceptable on an interin basis for use in dose assessment calculations i
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(1)
Reasons Why The Statement Occurred L
j During the NRC Inspection of Jarauaq 7-11, 1985 the NRC reviewed open item 50-315/84-05-06, 50-316/84-03-06.
This open j'
item, first identified during the routine safety inspection j
conducted on February 13-17, 1984, required the licensee to revise 4
PMP 2080.EPP.006 and PMP 2081.EPP.014 to reflect the use of the L
l 50-foot wind level as the primary source of wind speed.
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The PNSRC met on April 26, 1984 to review the proposed April i
i 27, 1984 letter from Mr. R. F. Hering to Mr. James G. Keppler as l
Nuclear Replatory Commission"paration of Submittals to the U. S.
per General Procedure 32, " Pre The proposed response to open j
Item 50-315/84-05-06, 50-316/84-05-06 which was revised by the i
PNSRC~ctated that,'" Emergency Plan Procedures will be revised by June 1, 1984 to require the use of the 50-foot level instrumentation as the primary source for wind speed and wind l
directions in dose assessment calculations."
l During this same April 26,-1984 meeting the PN8RC also Assessment."porary Page 4 to PMP 2081.EPP.014 "Off-Site Dose approved tem j
Temporary Page 4 incoqorated the recommendation made by the NRC to upgrade PMP 2081.EPP.014 to reflect ~the use j
of the 50-foot level of data as the primary source.
Upon approving Temporary Page 4 to PMP 2081.EPP.014, the j
PNSRC, unaware that PMP 2080.EPP.006 also needed to be uMraded, j
recommended that the respnse to @n Item 50-315/84-05-D6, 50-316/84-05-06 be changed to state uat "Emergeng Plan Procedures.
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have been revised to require the use of-the 50-foot level instrumentation as the primary source-for wind speed and wind j
direction in dose assessment calculations."
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1 Attachment B Page Two f
l This recommendation was then incorporated into the response i
to the NRC concerning Opn Item 50-315/84-05-06, 50-316/84-05-06 resulting in an inadvenent error in the April 27, 1984 letter i
j from Mr. R. F. Hering to Mr. James G. Keppler.
I Another possible contributing factor to this inadvertent error was the lack of specificity in the Action Item Tracking procedures.y pertaining to the action item to revise the twoIn this instsnce the entry made System entr i
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Tracking System did not identify by number the two procedures j
requiring the change, thus resulting in the action' item being i
closed upon the issuance of Temporary Page 4 to PHP 2081.EPP.014.
i While the necessity of revising a second procedure escaped the PNSRC, de languageofPkartmentalactionwasbeingtakentorevisethe P 2080.EPP.006 to conform to the revised 4
However the change was included in the revision to the procedure Incorporating other routine changes, and was not processed nor approved e p ditiously.
The revision to PMP 2080.EPP.006 was approved on Mcember 28, 1984.
4 (2)
Corrective Steps Which Have Been Taken PHP 2080.EPP.006 was modified to incorporate the i
recommendation made by the NRC to change it to reflect the use of i
l the 50-foot level of data as the primary source.
This action closed open Item 50-315/84-05-06, 50-316/84-05-06.
I (3)
Corrective Action Which Will be'Taken i
j We strongly believe that what occurred was a randon, inadvertent error.-
I&MECo has a detailed review process, in i
place for assuring that what is stated to the NRC either verbally j
or written, is accurate.' General Procedure 32, " Preparation of Submittals to the U. S.
Nuclear Regulatory Commission" requires j
for inspection reports that the preparer's supervisor, the Nuclear Safety and Licensing Manager, the MPSC @ Manager, the Plant Manager / Plant Nuclear Safety Review Committee and submittal signatory all review the content of NRC responses for accuracy and completeness.
Additional layers of review or additional l
i procedural changes would be unduly burdensome without a commensurate benefit in the quality of NRC submittals.
We will l
however, through our Quality Assurance Department, issue a statement that reaffirms the purposes and re g irements that General Procedure 32 imposes and reminds individuals using the i
Action Iten Tracking System to be specific when making. entries i
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into the system.
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(4)
Date When Full compliance Will Be Achieved i
The statement was issued March 8, 1985.
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Attachment B Page Three OATH AND AFFIRMATION STATEMENT STATE OF OHIO COUNTY OF FRANKLIN M. P. ALEXICH, being duly sworn, deposes and says that he is the Vice President of Licensee Indiana &-Michigan Electric Company, that he has read the foregoing Attachment B to AEP:NRC:0928 and knows the contents thereof; and that said contents are true to the best of his knowledge and belief.
p P. hiexich Subscribed and sworn to before me this [Hk day of March, 1985.
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