ML17321A974

Responds to NRC 851002 Ltr Re Violations Noted in Insp Repts 50-315/85-24 & 50-316/85-24.Corrective Actions:Procedure Being Developed to Control Replacement & Transfer of Reactor Coolant Filters Via 33-gallon Drum

ML17321A974
Person / Time
Site:	Cook
Issue date:	11/08/1985
From:	ALEXICH M P INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	KEPPLER J G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
AEP:NRC:0954, AEP:NRC:954, NUDOCS 8512030161
Download: ML17321A974 (9)

See also: IR 05000315/1985024

Text

INDIANA 8 MICHIGAN ELECTRIC COMPANY P.O.BOX 16631 COLUMBUS, OHIO 43216 November 8, 1985 AEP:NRC:0954

Donald C.Cook Nuclear Plant Nos.1 and 2 Docket Nos.50-315 and 50-316 License Nos.DPR-58 and DPR-74 NRC Report Nos.50-315/85024 (DRS)and 50-316/85024 (DRS)Mr.James G, Keppler U.S.Nuclear Regulatory

Commission

Region III 799 Roosevelt Road Glen Ellyn, IL 60137 Dear Mr.Keppler: This letter is in response to Mr.tt.D.Shafer's letter dated October 2, 1985, which forwarded the subject inspection

reports of the routine safety inspection

conducted by your staff at the Donald C.Cook Nuclear Plant during the period September 3-13, 1985.The Notice of Violation attached to Mr.Shaferts letter identified

three violations.

Section 13 of the inspection

report identified

one weakness, The responses to these violations

and the weakness are addressed in the attachment

to this letter.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, Attachments

MPA/ad cc: John E.Dolan N.G.Smith, Jr.-Bridgman R.C.Callen G.Charnoff NRC Resident Inspector-Bridgman G.Bruchmann, 8512030161

851 108 PDR ADO'5000315

I 8 PDR M..Al ich Vice President p5~.gb NOV 1 2 I985

4~.14 4~~4

AEP:NRC:0954

Attachment

Page 1 NRC Item No.1"Technical Specification 6.8.1 requires establishment

and adherence to the applicable

procedures

recommended

in Appendix"A" of Regulatory

Guide 1.33, November 1972.Appendix"A~~includes procedures

for replacing important strainer s and filters and for limiting materials released to the environment.

a~Contrary to the above, on July 19, 1985, the licensee transported

a contaminated

reactor coolant filter using a 33-gallon drum instead of the Atcor transfer cask specified by Procedure 12 HHP 5021.001.001, Filter Replacement

By Transfer Cask, Additionally, no procedure was available to control the preparation

and transfer of the reactor coolant filter to the 55-gallon shipping drum.This resulted in a worker exceeding the quarterly author ized dose.b.Contrary to the above, from June 20 through September 13, 1985, the Hydro Nuclear dry active waste segregation

and volume reduction system was operated without an adequate established

procedure for limiting materials released to the environment

in that the system operators were not directed by procedure to follow manufacturer's

instructions

that specify the disposal as radioactive

waste of any parcel of system processed waste which has generated a bag monitor high count alarm.During the above stated time period, operators routinely reprocessed

the material in these parcels without treating it as detected radioactive

waste." Corrective

Actions Taken and Results Achieved The worker's TLD was immediately

pulled and sent in for early readout.The results showed that based on TLD, the administrative

limit was not exceeded.In addition, interim instructions

were issued on July 29, 1985, in the form of a Department

Head Letter, communicating

the conclusions

reached during the post-job ALARA review and alerting maintenance

personnel to the hazards associated

with changing highly radioactive

filters.'orrective

Action to be Taken to Avoid Further Violations

A procedure is being developed to control the replacement

and transfer of the reactor coolant filters via a 33-gallon drum from the filter location to the waste storage.';1e anticipate

having this procedure approved by February 1, 1986.Full compliance

will be achieved on February 1, 1986 when the procedure to control the Filter Replacement

and Transfer is approved.

I

AEP:NRC:0950

Attachment

Pa e 2 Res onse to Item~It is our belief that we did have in place a procedure to follow manufacturer's

instructions.

The plant procedure, 12 TRIP 6010 ENV.007 (DA11 II Segregation/Volume

Reduction Pr ocess Operations)

was developed from the manufacturer's

draft procedure, HHS-230.Step 6.5.6 of the plant procedure states that if a bag monitor alarm occurred, the box could be opened and reprocessed.

This direction is consistent

with the manufacturer's

instructions.

The manufacturer

has agreed that the plant procedure follows the manufacturer

s instructions, and thus, adequately

limits material released to the environment.

Corrective

Action Taken and Results Achieved Hone required.Corrective

Action to be Taken to Avoid Further Violations

Hone required.Date When Full C~om liance)fill be Achieved For the reasons stated above, we believe operation of the DA~8 II was never in non-compliance

with Technical Specification 6.8.1.HRC Item tfo.2"10 CFR 20.201(b)states that each licensee shall make or cause to be made such surveys as (1)nay be necessary for the licensee to comply with the regulations

of this part, and (2)are reasonable

under the circumstances

to evaluate the extent of radiat'on hazards that may be pr esent.As used in the regulations

in this part,"survey<means an evaluation

of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive

materials or other sources of radiation under a specific set of conditions.

Uhen appropriate, such evaluation

includes a physical survey of the location of materials and equipment, and measurements

of levels of radiation or concentrations

of radioactive

material present.a~Contrary to the above, on or before September 3, 1985, the licensee failed to adequately

evaluate the removable contamination

levels on equipment following attempted decontamination

to ensure compliance

with 10 CFR 20.101(a)and 10 CFR 20.103(a).

A drop light contaminated

to about 600,000 dpm/100 square centimeters

had been returned to a storage area reserved for mater'al that had been decontaminated

to less than 500 dpm/100 square centimeters.

1

AEP:NRC:0954

Attachment

Page 3 b.Contrary to the above, on September 3 and 4,~1985, adequate surveys of numerous small radioactive

material storage areas including the diving suit storage area had not been conducted to ensure compliance

with 10 CFR 20.203(b).

This resulted in improperly

posted or unposted radiation areas." Res onse to Item 2 a Corrective

Actions Taken and Results Achieved The entire storage area was posted as a contaminated

area.Corrective

Action to be Taken to Avoid Further Violations

The program to evaluate the removable contamination

on equipment following decontamination

to ensure compliance

with 10 CFR 20.101(a)and't0 CFR 20.103(a)appears to be adequate.The area where the contaminated

drop light was found is available to all plant personnel and it is likely that the noted material was placed in the area prior to decontamination.

A method to control the transport of radioactive

material within the controlled

areas will be established

in order to prevent the unauthorized

addition to or alteration

of the configuration

of material in these storage areas.This method will be established

and functional

by January 1986.Date (/hen Full Con liance Uill be Achieved Full compli;ance

was achieved on September 3, 1985 when the storage area was posted as a contaminated

area.Response to Item 2 b Corrective

Action Taken and Results Achieved The radioactive

material storage areas were immediately

resurveyed

upon discovery and properly posted.e Corrective

Actions Taken to Avoid Further Violations

See Response to Item 2 a.

AFP:NRC:0954

Attachment

Page 4 Date LJhen Full Com liance will be Achieved Full compliance

was achieved on September 4, 1985 when the areas were resur veyed and properly posted.NHC Xtem No"Technical Specification 6.11 requires adherence to radiation protection

procedures.

Procedure 12 TflP 6010.RAD.401, Access Control Facility and Controlled

Area Entry and Exit, requires thorough frisking or decontamination

following a portal monitor alarm.Contrary to the above, on September 5, 1985, the inspectors

observed two contractor

employees violate this personal monitoring

requirement, One of the workers left the main access control area without additional

frisking or decontamination

after receiving an alarm on the portal monitor.The second worker exited the controlled

area through a less sensitive portal monitor at the contractor

access control area without performing

additional

frisking or decontamination

after rece'ivin" several alarms on the main access control portal monitor.>>Corrective

Actions Taken and Results Achieved All contractors

will be notified by November 15, 1985 that any willful disregard of Plant safety rules or Plant regulations

regarding radiation protection

or monitoring

will render the contractor

and its employee(s)

subject to disciplinary

action.Co>r ective Actions Taken to Avoid Further Violations

Xnitial and on-going training will be given to all site and contractor

personnel to ensure they understand

the importance

of and their individual

responsibility

to the radiation protection

program.Date llhen Full Com liance'tU.ll be Achieved Notification

to contractors

will be accomplished

by November 15, 1985.Training will be on-going.

AEP<NRC:0954

Attachment

Page 5 NHC ldenti f ied';Jeakneos

"...the licensee should conduct a thorough evaluation

to identify licensee commitments, technical problems, design and procedural

solutions to identified

problems, and a corrective

action complet'on

schedule for ESF and non-ESF filtration

systems in a timely manner in the areas of (1)the potential for fire protection

deluge systen leakage or activation

damaging charcoal adsorbers, (2)filter housing drain line configuration

and valving, and (3)the potential for an incident similar to the one that occurred at the Hatch plant." Res onoe to':Jeakness

The first and third concerns discussed above will be rectified by RFC DC-12-2890.

This RFC was written to change the charcoal filters fire protection

deluge systens from automatic to manual.The D, C.Cook Plant has 19 filter units that are equipped with charcoal filters, and of these 19 units, 16 now have autonatic Fire Protection

Deluge Systems, one has,a manual system, and two have no internal fire protection

systems.Because of the low nass of combustibles

in these three nonautomatic

protected units, coupled with the low potential for charcoal icnition, automatic systems were not specified or installed in then.RFC DC-12-2890

addresses modifying 12 of these 16 units;the (4)recirculating

units in the lower containnents

are not easily accessible

during plant operation and therefore will renain automatic.

The RFC has two parts to be performed, The first part of the HFC is to clooe the gate valve upstream of the three-way valve for 12 of the 16 systems.This would stop the leal<age,problem

and prevent an inadvertent

actuation of the oysten.The second part is to replace the carbon steel check valves on the deluge drain piping with stainless steel swing check valves for 11 of the 16 systems.(One of the twelve systems utilizes a deluge valve and not a thrce-way valve, There is no, drain problem associated

with this unit.The drains from the fire protection

system serving the four filter units in the containment

use gate valves in lieu of check valves.These valves have not been a problem,)Experience

has shown that the carbon steel check valve-are subject to the corrosive action of the water and do not properly function, therefore, they will be'eplaced

by stainless steel check valves.The second concern identified

in the JJHC weakness will be corrected by Revision 2 of RFC DC-12-1316.

This revision and an addendum will modify the dr ain syotens of the charcoal and/or HEPA filter units to preclude any aS.r bypass.The D.C.Cook Plant has 27 filter units that are equipped with charcoal and/or llEPA filter sections;however, only 24 of these units h"ve drains.The three filter units that do not have drains are the aforementioned

units which have charcoal filters without an automatic fire protection

system.HFC DC-12-1316, Revision 2, has been written to modify 19 filter units to contain gate valves or plugs in each individual

drain line or drain, respectively.

Gate valves will be used instead of check valves to prevent water from backing up into the units.The (4)recirculating

units in the lower containnents

will not have their drains modified since these units function usintotal recirculation

to clean the lower containments>

atmosphere.

The TSC filtration

unit is already properly isolated, All of the wor!<covered by the two afor e-mentioned

HFC's will be conpleted by the end of 1986.

p C>~ss)