ML17331B440
| 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".