ML17331B440

Responds to Violations Noted in Insp Repts 50-315/94-06 & 50-316/94-06.Corrective Actions:Procedure 12 Thp 6010 RPP.606 Revised to Include WD-490 in Valve Lineup

ML17331B440
Person / Time
Site:	Cook
Issue date:	05/25/1994
From:	Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Martin J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AEP:NRC:1212B, NUDOCS 9406230229
Download: ML17331B440 (8)

Text

ACCELERATED DOCUMENT DISTRIBUTIONSYSTEM

SUBJECT:

Responds to violations noted in insp repts 50-315/94-06 50-316/94-06.Corrective actions:Procedure 12 THP 6010 RPP.606 revised to include WD-490 in valve lineup.

DISTRIBUTION CODE:

IE06D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: Environ

& Radiological (50 DKT)-Insp Rept/Notice of Violation Respons I D

NOTES:

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9406230229 DOC.DATE: 94/05/25 NOTARIZED: YES DOCKET ¹

,'ij 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 R RECIP.NAME RECIPIENT AFFILIATION MARTINFJ.B.

Document Control Branch (Document Control Desk)

RECIPIENT ID CODE/NAME PD3-1 PD INTERNAL: AEOD/DSP NMSS/SGTB 4E4 NRR/PMAS/ILRBl2 NUDOCS-ABSTRACT OGC/HDS2 RES RGN3 FILE Ol TERNAL: NRC PDR COPIES LTTR ENCL 1

1 1

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1 1

1 1

1 1

RECIPIENT ID CODE/NAME HICKMAN,J AEOD/TTC NRR/DREP/PRPB10 NRR/PMAS/IRCB-E OE DI RQ FILE 02 RGN DRSS/RPB RGN4/FIPS NSIC COPIES LTTR ENCL 1

1 1

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D D

D NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDl D

TOTAL NUMBER OF COPIES REQUIRED:

LTTR 19 ENCL 19

Indiana Michigan Power Company P.O. Box 1663 I Coiumbus, OH 43246 lNDIANA NECHlGAN POWM AEP:NRC:1212B-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. 50-315/94006 (DRSS)

AND 50-316/94006 (DRSS)

REPLY TO NOTICE OF VIOLATION U.

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

C.

20555 Attn:

Mr. J.

B. Martin May 25, 1994

Dear Mr. Martin:

This letter is in response to a USNRC letter dated April 29,

1994, that forwarded a Notice of Violation (NOV) to Indiana Michigan Power Company.

The NOV contained one violation which was self-identified by the licensee and noted during a-routine radiation protection inspection conducted by Mr. C.

R.

Cox from March 28 through April 1, 1994.

The violation is associated with the proceduralized activities that led to the spent resin spill in the 587'rumming room on March 19, 1994.

In response to the event, prompt action was taken to suspend all resin transfer activities.

Corrective actions, in the form of procedure revisions, were instituted to prevent recurrence prior to resumption of such activities.

Our reply to 'the notice of violation is provided in the attachment to this letter.

This letter is submitted pursuant to 10 CFR 50 '4(f) and, as such, an oath statement is attached.

Sincerely, pp~pcW E.

E. Fitzpatrick Vice President dr 9'406230229 9'40525

.PDR ADOCK 05000315 9

PDR

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 forgoing response to NRC INSPECTION REPORTS NO. 50-315/94006 (DRSS)

AND 50-316/94006 (DRSS),

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 and sworn to before me this ~~4 day of 19 NOTAR PUBLIC RlTA D. HE'LL NOTARY PUDuC. STATE OP OHt."

Mr. J.

B. Martin 2

AEP:NRC:1212B Attachments CC:

A. A. Blind G. Charnoff NFEM Section Chief NRC Resident Inspector

- Bridgman, MI NRC Resident Inspector

- Big Rock Point Nuclear Plant J.

R. Padgett W. T. Russell, NRC - Washington, D.C.

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

ATTACHMENT TO AEP:NRC:1212B Page

1 Background

A routine radiation protection inspection was conducted by Mr. C.

R.

Cox from March 28 through April 1, 1994.

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

The violation was identified as inappropriateness of procedures with regard to the activities that led to the spent resin spill in the 587 drumming room on March 19, 1994.

This violation was set forth in a letter containing the notice of violation, dated April 29,

1994, from Mr. John A. Grobe, Acting Chief, Reactors Support Programs Branch.

The letter was received May 10, 1994.

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

NRC Violation I "10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," requires that activities affecting quality be prescribed by a procedure of a type appropriate to the circumstances and shall be accomplished in accordance with these procedures.

Contrary to the above:

On March 18,

1994, Procedure 12 THP 6010 RPP.606, "Operation of the Radi.oactive Waste Water Demineralizer System (RWDS),"

was inappropriate to the circumstances in that the valve lineup failed to identify a valve required to be opened for the evolution to be completed successfully.

2.

On March 19,

1994, Procedure 02 OHP 4021.007.002, "Reactor Coolant Demineralizer Resin Sluicing and Replacement,"

was inappropriate to the circumstances in that the procedure failed to identify alternative flow paths and the valves whose positions needed to be verified to prevent those alternative flow paths.

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

ATTACHMENT TO AEP,:NRC:1212B Page 2

Response

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

2.

Reasons for the Violation The valve lineup for procedure 12 THP 6010 RPP.606, "Operation of the Radioactive Waste Water Demineralizer System (RWDS)," failed to identify WD-490 due to the procedure author's misinterpretation of valve information when transitioning from one flow print to another.

The author incorrectly assumed that WD-498 was identified on two prints when in fact WD-498 was on one print and WD-490 was on the other.

Subsequent procedure reviews performed prior to the procedure approval failed to identify the original error.

Procedure 02 OHP 4021.007.002, "Reactor Coolant Demineralizer Resin Sluicing and Replacement," failed to identify alternative flow paths

""and the valves whose positions needed to be verified closed to prevent those paths from being used.

This was due to the basic assumption that the subject valves are normally maintained in the closed position and, therefore, a check was not necessary.

Corrective Actions Taken and Results Achieved On March 18, 1994, procedure 12 THP 6010 RPP.606, "Operation of the Radioactive Waste Water Demineralizer System (RWDS)," was revised to include WD-490 in the valve lineup.

On March 25,

1994, procedure 02 OHP 4021.007.002, "Reactor Coolant Demineralizer Resin Sluicing and Replacement,"

was revised

-to include verification of the subject alternate flow paths and the associated valves which positions needed to be verified.

Corrective Actions Taken to Avoid Further Violations The procedure used by the radiation protection department for procedure preparation, review and maintenance will be revised to enhance reviews performed to ensure procedure accuracy.

This revision will be completed prior to July 1, 1994.

ATTACHMENT TO AEP:NRC:1212B Page 3

In the cover letter to the subject notice of violation/inspection

'eport, it was requested that our response include a review of similar evolutions that 'require coordination between different groups and the steps taken to improve the coordination and communications between such groups.

Review and assessment of coordination and communication between different groups is an integral part of our corrective action program.

Previous assessment lead to the initiation of a comprehensive improvement plan within the Chemistry Department.

Similarly, a self assessment of recent events related to coordination and communication within the Operations Department has resulted in the initiation of significant changes within this department.

The latest analysis of our Corrective Action Program Data Base revealed that communications remain a challenge.

This information has been provided to the appropriate management personnel.

We will continue to monitor performance in these areas and provide feedback relative to the effectiveness of performance improvement initiatives.

Teamwork and Communication are critical to the success of any operation and the, importance of each has consistently been emphasized during State of the"Plant Sessions conducted by the Vice President-Plant Manager and attended by plant and contract personnel.

In addition, the AEP Nuclear Organization has initiated an integrated Team Building process.

This integrated Team Building process was initiated by Senior Management and is designed to enhance

teamwork, coordination and communication throughout the whole organization.

Also, the radiation protection department will review similar procedural evolutions that require coordination between different groups and will delineate within these procedures individual responsibilities for command and control of the activity from both an intradepartment and interdepartment coordination perspective.

This review will be completed prior to July 1, 1994.

Procedure changes required as a result of this review will be completed prior to May 1, 1995.

In addition, the operations department will review this event with the operations procedure group and will determine if changes are necessary to the current procedure development process.

This review will be completed prior to July 1, 1994.

Process changes required as a result of this review wi13. be completed prior to May 1, 1995.

Date When Full Com lienee Vill Be Achieved Full compliance was achieved on March 25, 1994, with the revision to Procedure 02 OHP 4021.007.002, "Reactor Coolant Demineralizer Resin

'Sluicing and Replacement".