ML20084C314
| ML20084C314 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 04/13/1984 |
| From: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20084C306 | List: |
| References | |
| AEP:NRC:0879, AEP:NRC:879, NUDOCS 8404270205 | |
| Download: ML20084C314 (5) | |
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INDIANA & MICHIGAN ELECTRIC COMPANY P.O. BOX 16631 COLUMBUS, OHIO 43216 April 13, 1984 AEP:NRC:0879 Donald C. Cook Nuclear Plant Nos. I and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 NRC Report No. 50-315/84-05(DRMSP); 50-316/84-05(DRMSP)
Mr. James G. Keppler, Regional Administrator U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
This letter responds to Mr. C. J. Paperiello's letter dated March 14, 1984, which forwarded the subject Inspection Report of the routine safety inspection conducted by your staff at the Donald C. Codk Nuclear Plant during the period February 13-17, 1984. The Notice of Violation attached to Mr. Paperiello's letter identified one (1) item of noncompliance, which is addressed in the Attschment to this letter.
As a point of clarification Section 8 (page 9) of the subject inspection report stated that a "brief insert" has been distributed on a semi-annual basis to all service customers. The insert is actually distributed on an annual basis.
This document has been prepared following Corporate procedures which incorporate a reasonable set of controls to Lnsure its accuracy and completeness prior to signature by the undersigned.
Very truly yours,
.P.
exich 0,jg[
Vice President 4
MPA/cm Attachments cc: John E. Dolan W. G. Smith, Jr. - Bridgman R. C. Callen G. Charnoff E. R. Swanson, NRC Resident Inspector - Bridgman PDR ADOCK 05000315 E?E g ( T8k 8404270205 840424 G
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ATTACHMENT TO AEP:NRC:0879 RESPONSE TO NOTICE OF VIOLATION ITEM 10 CFR 50.54(q) states in part that:
"A licensee authorized to possess and/or operate a nuclear power reactor shall follow and maintain in effect emergency plans which meet the standards in 50.47(b) of this part and the requirements in Appendix E to this part."
In addition, Technical Specifications 6.8.1.e states in part that, " Written procedures shall be established, implemented and maintained covering Emergency Plan implementation."
I PART (a) a.
Contrary to Section 2.2 of Emergency Plan Procedure PMP-2080.EPP.008, quarterly verifications of Exhibit A to this procedure were not performed during the fourth quarter of 1983.
RESPONSE TO PART (a}
1.
CORRECTIVE ACTIONS TAKEN__AND_R_E_S_U_LTS ACHIEVED The review process for the purpose of verifying individual telephone number listings (Exhibit A) as per Section 2.2 of the Emergency Plan Procedure PMP-2080-EPP.008 was started in December 1983. During this review, it became apparent that due to attrition and re-organization, several positions were in need of re-assignment. In addition, during Emergency Plan drills in December,1983, problems were discovered in the call tree sequence for activating the Emergency Operations Facility and the Joint Public Information Center. An interim call list, with verified telephone numbers, was established and supplied to Security personnel responsible for initiating the call trees. This call list was utilized during the annual Emergency Plan exercise in January, 1984.
4 The intent of the interim call list was to verify the call tree sequence and telephone numbers during the exercise and, if satisfactory, to issue the revised procedure and Exhibit "A" following that verification. Final revision of the procedure and the review process took longer than expected following the exercise. The revised procedure was issued March 8,1984.
2.
EgggC. TIVE_,A,C,T,10,N.S..T_AE_EN TO AVOID PRBI,(R N0_NCOMPLIANCE Although telephone number listings were verified during the required interval, the procedure was 'not revised and reissued due to attempts to combine the verification and procedure revision process.
quarterly reviews in the future will address only verification of individual telephone number ' listings, while procedure revisions will be addressed ' separately.
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3.
DATE WHEN FULL,C_0M_PMANCE_WILL BE ACHIEVE _D l
Pull compliance was achieved on March 8,1984, when the revision to PMP-2080.EPP.008 was issued.
PARTS (b). (c) and (d) b.
Contrary to Section 4.1 of Emergency Plan Procedure PMP-2082.EPP.009, quarterly completion of Exhibit C was not performed during the first three quarters of 1983; and completion of Exhibit B was not performed during the first half of 1983.
c.
Contrary to Section 4.2.1 of Emergency Plan Procedure PMP-2082.EPP 005, quarterly drills for Radiological Monitoring Team Activation and Health Physics were not documented for any quarter in 1983.
4 d.
Contrary to Section 12.3.15.1 of the Donald C. Cook Emergency Plan, Rev. 2, the semi-annual off-hours shif t augmentation drill was not performed during the first half of 1983.
RESPONSE T0_P_RTS (b). (c) and_,(d)
A 1.
CORRECTIVE ACTION,S, TM,EN_AND, RESykT) jCHIEVED Review of Emergency Planning requirements during August / September,1983, due to the appointment of a new site emergency preparedness coordinator, indicated the required quarterly and semi-annual drills, inventories, assignment up-dates, etc. had not been scheduled during the first three quarters of 1983.
Po11owing that discovery, the appropriate checklists were distributed in October,1983, for resolution and required drills were scheduled.
The majority of checklist items were resolved during October,192.
However, several items (i.e., review of training documentation, personnel assignments, procedure manuals and previous drill discrepancies) were not completed until January,1984 due to pisaning, training, etc. for the annus1 emergency plan exercise. The first of a series of drills aos completed on November 9,1983, stressing communications, radiological monitoring, health physics activities'and operator action. An off-hours shift augmentation drill was satisfactorily performed on December 16, 1983.
A review of Radiation Protection Section training records following the Pebruary,1984 RRC inspection revealed that emergency plan training had been performed and documented during May, June, July,1983, by the Radiation Protection Training Supervisor. The training involved activation and walk-throughs of the Radiological Monitoring Team and same Besith Physics activities. Participation by Radiation Protection personnel during pre-exercise drills during November / December,1983, constituted the quarterly drill requirement for the fourth quarter of 1983.
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CORRECTIVE ACTIONS TAKEN T0_ AVO_ID FURTHER. NOjLC_0MPLIANCE i
Checklists in Emergency Plan Procedure PMP-2082.EPP.008 will be revised to include verification that all required drills (Radiological Monitoring, Health Physics and off-shift augmentation) are conducted and documented within the required intervals. These i
checklists will be reviewed and approved by the Site Emergency Preparedness Coordinator. In addition, all periodic emergency P anning requirements will be entered on the Plant NTS computer l
l program for scheduling periodic surveillance requirements. The
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procedure revision and addition to the NTS program will be completed i
by September 1, 1984. The Site Emergency Preparedness Coordinator will schedule and track these items manually until that time.
3.
.DATE__WH1N_J_UJ L C0_MfLIAN_C_E_yJI_L_L_BE ACHIEVED All required drills were conducted by December 16,1983, as indicated above, with appropriate checklists comp leted in January, 1984. In addition controls are in place to assure that future drills j
will be appropriately scheduled and performed.
PART (e) a.
Contrary to Section IV.E.9.d of Appendix E to 10 CFR Part 50, communications with the NRC Headquarters and Regional office from the nuclear power reactor control room, Technical Support Center, and Emergency Operations Facility were not tested on a monthly basis prior to October,1983."
RESPONSE 70_PART_,(,e) 1.
C_0_R_RJ_CTJIVE_ ACTIONS _. TAKEN AND RESULTS ACHIEVED Following receipt of NRC Inspection Report 50-315/83-09; 50-316/83-10, dated September 8,1983, which requested clarification of various sections of the Donald C. Cock Emergency Plan, it became apparent that the 10 CFR 50, Appendix "E" requirement to perform a monthly test 'of communications facilities from the Technical Support Center and Emergency Operations Facility to the NRC Headquarters and Regional office had not been performed. The commanication link in each control room is tested daily via the NRC initiated call, although this had not been documented. As a result of the NNC Inspection Report 50-315/83-09; 50-316/83-10, the Operations Department added monthly testing of the Technical Support Center phone and documentation of the daily NRC-call to' their Master Surveillance Schedule. Initial testing of the TSC phone was performed on November 6 1983. Requirements for testing the phone in the Emergency Operations Facility were established in an Accounting
. Department Standing Order (0ASO.002, Rev.1 - B0F Test of ENS Phone)
' issued on December 14, 1983. The first test of this phone was conducted, however, on November 21, 1983.
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2.
CORRECTIVE ACTIONS TAKEN T0_ AVOID FURTHER_ NONCOMPLIANCE Establishment of the testing requirements and frequencies in Plant procedures as indicated above will ensure timely performance of these surveilicace requirements.
4 3.
DATE WHEN FULL COMPLI AN_C,E, WIL,L,,B,E_AC.HI_EVED E
Full compliance was achieved on November 21, 1983, following testing of all required telephone lines.
PART (f) f.
Contrary to Section IV.B of Appendix E to 10 CFR Part 50, Emergency Action Levels were not reviewed with the State and local governmental authorities on an annual basis prior to January, 1984.
RESPONSE T0_PART (f)_
1.
CORRETIVE ACTIONS TAKEN App _R,ES_ULTS ACHIEVED Review of the emergetcy planning requirements prior to January 1984 revealed that their was no exercise in calendar year 1983. So 3
no review was done, as normally occurs, prior to and during an exercise. 'Ihree days training of local and State officials occurred on January 3-5, 1984 prior to the January 25, 1984 exercise and EAL's were reviewed with State and local authorities on January 17, 1984 as your Inspection Report states.
2.
CORRECTIVE _ fCTIQNS Tg_EN T9_4}9ID,_FURTHER NONCOMPJ,IMCE, E
The 12 month calendar will be revised to include this Emergency Action Levels Review as required. Also it will be more explicitly stated in the training format of the NUREG-0654 Training Support Program developed by the Emergency Management Division, Michigan Department of State Police, Part I: Basics of Radiation and Plant Operations:
(Utility). The Plant Training Department will upgrade lesson plans and material to reflect appropriate EAL reviews as required.
3.
PATAyREN,,Fy,L,L_,C,0MP_L_I,MCE,yJJ.L _BE ACHIEVED Full compliance was achieved on January 17, 1984.
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