EA-96-020 - D.C. Cook 1 (Indiana Michigan Power Company)
Mr. E. E. Fitzpatrick
Senior Vice President
Indiana Michigan Power Company
1 Riverside Plaza
Columbus, OH 43216
SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-315/95014(DRP))
Dear Mr. Fitzpatrick:
This refers to the inspection conducted on December 20, 1995, through January 16, 1996, at Donald C. Cook Nuclear Plant. The purpose of the inspection was to review the circumstances surrounding your identification on November 20, 1995, that the Unit 1 West Centrifugal Charging Pump (CCP) had been rendered inoperable by an overcurrent relay calibration conducted in March 1995. The report documenting the inspection was sent to you by letter dated January 25, 1996, and you declined an opportunity to participate in a predecisonal enforcement conference.
Based on the information developed during the inspection and the information that you provided in a Licensee Event Report dated December 20, 1995, and in your response to the inspection report dated February 26, 1996, the NRC has determined that violations of NRC requirements occurred. The violations are cited in the enclosed Notice of Violation and the circumstances surrounding them are described in detail in the subject inspection report.
On September 12, 1995, while Unit 1 was in a refueling outage with all fuel removed from the reactor vessel, full flow testing of the emergency core cooling system was performed. During the testing the West CCP tripped on a sensed overcurrent after 7 minutes of full flow. Your investigation following the event determined that the time overcurrent relay for the pump had been improperly set since its last calibration on March 15, 1995. This mis-calibration of the relay rendered the West CCP inoperable until Unit 1 was shut down for the refueling outage on July 30, 1995. Also, the Unit 1 East CCP was unavailable for approximately 68 hours during this period.
The primary root cause of the event was the lack of proficiency (requalification training) which led to personnel error on the part of the Instrumentation and Control (I&C) technicians. The lead technician was qualified on the relay in February 1992. However, the lead technician had not performed any relay calibrations since his qualification and calibrated the relay in March 1995 using a wrong technique. The second technician was qualified on the relay in August 1993 and had assisted other lead technicians in the performance of this type calibration. However, he did not question or closely observe the lead technician in the performance of the March 1995 calibration.
Second, the calibration procedure for the relay remained essentially unchanged since it was written in the mid-1970s. At that time, technicians specialized in the calibration of relays and as such the amount of detail required in the procedure was small. Since then, D. C. Cook's practice was to have all qualified technicians capable of calibrating relays. This diluted the proficiency that any one technician would gain. Therefore, the procedure was not adequate for the current level of proficiency.
The violations represent a significant failure to comply with the action statement for a Technical Specification limiting condition for operation where the appropriate action was not taken within the required time. Therefore, the violations are classified in the aggregate in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, as a Severity Level III problem.
In accordance with the Enforcement Policy, a base civil penalty in the amount of $50,000 is considered for a Severity Level III problem. Where there has been escalated enforcement within the past 2 years, Section VI.B.2 of the Enforcement Policy requires consideration of credit for both Identification and Corrective Action. In this case, credit was warranted for your identification of the violation. Credit was also warranted for your comprehensive corrective actions. The West CCP relay was recalibrated and 14 other relays monitoring motors for pumps that did not receive full flow testing following relay calibration were checked. Seven additional relays, which were calibrated by the involved second technician and are monitoring an energized bus, will have their calibrations checked once appropriate plant conditions can be established. The training qualification cards for the involved technicians have been pulled and they will not perform relay calibrations until requalification has been completed. Additionally, the training program has been enhanced such that during I&C crew training sessions relay calibrations are covered. Until all technicians have undergone crew training on relay calibrations, only those technicians who have demonstrated proficiency under supervision are performing calibrations on safety related protective relays.
The calibration procedure for the relay has been enhanced. The concept of the two person work team and the responsibilities of the team members are being reinforced with the I&C technicians and the first line supervisors. Maintenance Standard GEN-02, "First Line Supervisor Pre-Job Activities" is being revised to include the topics of worker proficiency and supervisory guidance, as well as the need to maintain a questioning attitude. The revised crew training sessions include discussion of the need for all members of the crew performing a task and the personnel reviewing completed work to maintain a questioning attitude.
Therefore, to encourage prompt identification and comprehensive correction of violations, I have been authorized, after consultation with the Director, Office of Enforcement, not to propose a civil penalty in this case. However, significant violations in the future could result in a civil penalty.
The NRC has concluded that information regarding the reason for the violations, and the corrective actions taken and planned to correct the violations and prevent recurrence is already adequately addressed on the docket in Inspection Report No. 50-315/95014(DRP), LER 95-011-00, and your letter dated February 26, 1996. Therefore, you are not required to respond to this letter unless the description in the docketed materials referenced above does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be placed in the NRC Public Document Room (PDR).
Sincerely, Hubert J. Miller Regional Administrator
Docket No. 50-315
License No. DPR-58
Enclosure: Notice of Violation
A. A. Blind, Site Vice President
John Sampson, Plant Manager
James R. Padgett, Michigan Public Service Commission
Michigan Department of Public Health
Indiana Michigan Power Company Docket No. 50-315 Donald C. Cook Nuclear Plant License No. DPR-58 EA 96-020
During an NRC inspection conducted on December 20, 1995, through January 16, 1996, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
A. Technical Specification 3.5.2 requires, in part, that two independent ECCS subsystems be operable with each subsystem comprised of one operable centrifugal charging pump in Modes 1, 2, and 3. With one ECCS subsystem inoperable, restore the inoperable subsystem to operable status within 72 hours or be in Hot Shutdown within the next 12 hours.
Technical Specification 3.0.3 requires, in part, when a Limiting Condition for Operation is not met, except as provided in the associated Action requirements, within one hour action shall be initiated to place the unit in a Mode in which the Specification does not apply by placing it, as applicable, in at least Hot Standby within the next 6 hours, at least Hot Shutdown within the following 6 hours, and at least Cold Shutdown within the subsequent 24 hours.
1. Contrary to the above, from 4:31 a.m. on March 15, 1995, until 11:17 a.m. on July 30, 1995, while in Modes 1, 2 or 3, the Unit 1 West (Train B) centrifugal charging pump was inoperable, a period greater than 84 hours, and Unit 1 was not placed in Hot Shutdown. (01013)
2. Contrary to the above, from 1:00 a.m. on July 10, 1995, until 2:50 a.m. on July 12, 1995, while in Mode 1, and for 17 hours and 35 minutes on July 19, 1995, while in Mode 3, both centrifugal charging pumps were inoperable and action was not taken within one hour to place Unit 1 in at least Hot Standby within the next 6 hours, at least Hot Shutdown within the following 6 hours, and at least Cold Shutdown within the subsequent 24 hours. (01023)
B. 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances.
Contrary to the above, as of March 15, 1995, calibration procedure No. 12 IHP 6030 IMP.014, Revision 8, for calibrating General Electric Model 66 type IAC induction disc current sensing relays, was not appropriate for the current level of proficiency of the I&C technicians. For example, the procedure did not define the "pick-up" current for an induction disc relay as the value at which the continuity light "just flickers." (01033)
This is a Severity Level III problem (Supplement I).
The NRC has concluded that information regarding the reason for the violations, and the corrective actions taken and planned to correct the violations and prevent recurrence is already adequately addressed on the docket in Inspection Report No. 50-315/95014(DRP), LER 95-011-00, and a letter from the Licensee dated February 26, 1996. However, you are required to respond to the provisions of 10 CFR 2.201 if the description in the docketed materials referenced above does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a "Reply to a Notice of Violation," and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region III, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
Dated at Lisle, Illinois
this 11th day of March 1996