AEP-NRC-2024-78, Reply to a Notice of Violation: EA-24-047
| ML24267A169 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 09/23/2024 |
| From: | Ferneau K Indiana Michigan Power Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk, NRC/RGN-III |
| References | |
| AEP-NRC-2024-78, EA-24-047 | |
| Download: ML24267A169 (1) | |
Text
Indiana Michigan Power INOIANA Cook Nuclear Plant MICHIGAN One Cook Place POWEii " Bridgman, Ml 49106 indianamichiganpower.com An MP Company
BOUNDLESS ENERGY-
September 23, 2024 AEP-NRC-2024-78 10 CFR 2.201
Docket Nos.: 50-315 50-316
U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001
Donald C. Cook Nuclear Plant Unit 1 and Unit 2 Reply to a Notice of Violation: EA-24-047
Reference :
- 1. Letter from P. Zurawski, Nuclear Regulatory Commission, to Q. S. Lies, Indiana Michigan Power Company, "Donald C Cook Nuclear Plant - NRC Inspection Report 05000315/2024011 and 0500316/2024011 and Notice of Violation," dated August 30, 2024.
This letter provides Indiana Michigan Power Company's (l&M), licensee for Donald C. Cook Nuclear Plant (CNP) Unit 1 and Unit 2, response to Notice of Violation EA-24-047 which is contained in Reference 1.
By Reference 1 the Nuclear Regulatory Commission identified two Severity Level IV problems that occurred at CNP. Specifically, seven operators resumed licensed activities without performing a plant tour and reviewing shift relief turnover procedures as required by 1 0 CFR 55.53(f). As a result, CNP failed to maintain the minimum licensed operator staffing requirements as required by 10 CFR 50.54(m)(2)(i).
The enclosure to this letter details results of causal analysis and actions taken to prevent recurrence as requested by Reference 1 and in accordance with 10 CFR 2.201.
U.S. Nuclear Regulatory Commission AEP-NRC-2024-78 Page 2
There are no new regulatory commitments made in this letter. Should you have any questions, please contact Mr. Michael K. Scarpello, Regulatory Affairs Director, at (269) 466-2649.
Sincerely,
Kelly J. Ferneau Site Vice President
KMH/sjh
Enclosure:
Reply to a Notice of Violation: EA-24-047
c: J.B. Giessner-NRC Region Ill NRC Resident Inspector R. M. Sistevaris -AEP Ft. Wayne, w/o enclosures S. P. Wall - NRC Washington, D.C.
A J. Williamson - AEP Ft. Wayne, w/o enclosures Enclosure to AEP-NRC-2024-78 Reply to a Notice of Violation: EA-24-047
By Reference 1, the Nuclear Regulatory Commission identified two Severity Level IV problems that occurred at Cook Nuclear Plant (CNP). Specifically, seven operators resumed licensed activities without performing a plant tour and reviewing shift relief turnover procedures as required by 10 CFR 55.53(f).
As a result, CNP failed to maintain the minimum licensed operator staffing requirements as required by 10 CFR 50.54(m)(2)(i).
Indiana Michigan Power Company, the licensee for Donald C Cook Nuclear Plant (CNP) is providing the response to Notice of Violation EA-24-047, as requested by Reference 1 and in accordance with 10 CFR 2.201.
VIOLATION A:
l&M failed to maintain procedure OHl-2070, "Operations Training and Qualification," such that it allowed the licensee to mark "N/A" on Step "F" in Attachment 5, "New or Inactive License/STA Upgrade Record," of the procedure. Marking this step "N/A" allowed operators to forgo completing a plant tour and review of shift relief turnover procedures prior to the re-activation of their license's as required by 10 CFR 55.53(f). This resulted in seven licensed operators not complying with regulations.
(1) The reason for the violation, or, if contested, the basis for disputing the violation or severity level
Response
On 4/15/2021, CNP site procedure, OHl-2070, Attachment 5, Revision 72, had changed the requirement for the plant tour of reactivation of licenses to be discretionary instead of mandatory per the Code of Federal Regulations (10 CFR 55.53(f)). This resulted in seven licensed operators not complying with regulations. This occurred when the seven licensed operators were reinstating their licenses after a period of inactive duty and used the allowed "N/A" for the procedure step requiring a plant tour and reviewing shift relief turnover procedures. The Apparent Cause Evaluation determined that OHl-2070 was revised in error due to the procedure writer and qualified technical reviewer failing to identify that changing the plant tour requirement to discretionary for reactivation of licenses was a regulatory requirement per 10 CFR 55.53.
(2) The corrective steps that have been taken and the results achieved
Response
The corrective actions taken were as follows:
- 1. On 2/27/24, the seven operators were disqualified and removed from Licensed Operator duties until each operator could conduct a plant tour and review shift relief turnover procedures with an active Senior Reactor Operator. Five of the seven operators documented the actions required by OHl-2070, Attachment 5, Step F, and were returned to Licensed Operator duties on 3/1/24. The remaining two of seven operators conducted the actions required by OHl-2070, Attachment 5, Step F, and were returned to Licensed Operator duties on 3/11/24.
- 2. On 3/4/24, procedure OHl-2070, Attachment 5, was revised to remove the ability to mark the step to "complete a plant tour with an active Senior Reactor Operator" as not applicable. to AEP-NRC-2024-78 Page 2
- 3. On 3/21/24, a Crew Noteworthy formal written communication was distributed to all Licensed Operators describing the OHl-2070 procedure changes and requirement to complete a plant tour and review shift relief turnover procedures, prior to reinstatement of licenses, during parallel watches.
- 4. The Severity Level IV problem was entered into CNPs Corrective Action Program, and an Apparent Cause Evaluation was conducted. The result of the Apparent Cause Evaluation was as follows:
- a. Apparent Cause was determined to be that the procedure writer and qualified technical reviewer failed to identify that changing the plant tour requirement to discretionary for reactivation of licenses was a regulatory requirement per 10 CFR 55.53.
- b. A contributing cause was determined to be that the requirement for plant tour and review of shift relief turnover procedures in OHl-2070 was generic and did not reference the specific regulatory requirement.
- c. A contributing cause was determined to be that the Attachment 5 in OHl-2070 for reactivating licenses combines new licenses and reactivating licenses, causing confusion.
- d. As discussed in #2 above, on 3/4/24, procedure OHl-2070, Attachment 5, was revised to remove the ability to mark the step to "complete a plant tour with an active Senior Reactor Operator" as not applicable. Additional procedure enhancements are identified as discussed below.
(3) The corrective steps that will be taken
Response
- 1. Additional procedure enhancements have been identified for OHl-2070 and will be implemented. The procedure enhancements will separate requirements for new licenses from inactive licenses, specify plant tour locations for greater clarity, and will add references to 10 CFR 55.53.
- 2. Provide training on the requirements of 10 CFR 55.53, "Condition of Licenses," to Licensed Operators.
(4) The date when full compliance will be achieved
Response
Full compliance was achieved on March 11, 2024.
VIOLATION B:
On 11 occasions between October 14, 2023, to November 14, 2023, the licensee failed to maintain the minimum licensed operator staffing requirements as required by 10 CFR 50.54(m)(2)(i).
(1) The reason for the violation, or, if contested, the basis for disputing the violation or severity level
Response
l&M failed to ensure that seven inactive licensed operators performed a complete tour of the plant and review shift relief turnover procedures prior to the resumption of functions authorized by their individual licenses issued under 10 CFR Part 55 when OHl-2070 allowed for these steps to be N/A'd. Since these seven operators had to be considered disqualified dating back to the date they to AEP-NRC-2024-78 Page 3
were incorrectly re-activated, it resulted in failure to meet minimum licensed operator staffing requirements.
(2) The corrective steps that have been taken and the results achieved
Response
The corrective actions taken were as follows:
- 1. On 2/27/24, the seven operators were disqualified and removed from Licensed Operator duties until each operator could conduct a plant tour and review shift relief turnover procedures with an active Senior Reactor Operator. Five of the seven operators documented the actions required by OHl-2070, Attachment 5, Step F, and were returned to Licensed Operator duties on 3/1/24. The remaining two of seven operators conducted the actions required by OHl-2070, Attachment 5, Step F, and were returned to Licensed Operator duties on 3/11/24.
- 2. On 3/4/24, procedure OHl-2070, Attachment 5, was revised to remove the ability to mark the step to "complete a plant tour with an active Senior Reactor Operator" as not applicable.
- 3. On 3/21/24, a Crew Noteworthy formal written communication was distributed to all Licensed Operators describing the OHl-2070 procedure changes and requirement to complete a plant tour and review shift relief turnover procedures, prior to reinstatement of licenses, during parallel watches.
- 4. The Severity Level IV problem was entered into CNPs Corrective Action Program, and an Apparent Cause Evaluation was conducted. The result of the Apparent Cause Evaluation was as follows:
- a. Apparent Cause was determined to be that the procedure writer and qualified technical reviewer failed to identify that changing the plant tour requirement to discretionary for reactivation of licenses was a regulatory requirement per 10 CFR 55.53.
- b. A contributing cause was determined to be that the requirement for plant tour and review of shift relief turnover procedures in OHl-2070 was generic and did not reference the specific regulatory requirement.
- c. A contributing cause was determined to be that the Attachment 5 in OHl-2070 for reactivating licenses combines new licenses and reactivating licenses, causing confusion.
- d. As discussed in #2 above, on 3/4/24, procedure OHl-2070, Attachment 5, was revised to remove the ability to mark the step to "complete a plant tour with an active Senior Reactor Operator" as not applicable. Additional procedure enhancements are identified as discussed below.
(3) The corrective steps that will be taken
Response
- 1. Additional procedure enhancements have been identified for OHl-2070 and will be implemented. The procedure enhancements will separate requirements for new licenses from inactive licenses, specify plant tour locations for greater clarity, and will add references to 10 CFR 55.53.
- 2. Provide training on the requirements of 10 CFR 55.53, "Condition of Licenses," to Licensed Operators.
(4) The date when full compliance will be achieved
Response
Full compliance was achieved on March 11, 2024. to AEP-NRC-2024-78 Page 4
Reference:
- 1. Letter from P. Zurawski, Nuclear Regulatory Commission, to Q. S. Lies, Indiana Michigan Power Company, "Donald C Cook Nuclear Plant - NRC Inspection Report 05000315/2024011 and 0500316/2024011 and Notice of Violation," dated August 30, 2024