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 B NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AEP:NRC:1212B, NUDOCS 9406230229
Download: ML17331B440 (8)

See also: IR 05000315/1994006

Text

ACCELERATED

DOCUMENT DISTRIBUTION

SYSTEM 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 DOCKET¹,'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 1 1 1 1 1 1 1 1 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 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 D 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 ELIMINATE YOUR 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".