IR 05000316/1992022
| ML17334B452 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 02/08/1993 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| Shared Package | |
| ML17334B453 | List: |
| References | |
| EA-92-252, NUDOCS 9302120088 | |
| Download: ML17334B452 (8) | |
Text
FORD 1 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CESSION NBR:9302120088 DOC.DATE: 93/02/08 NOTARIZED:
NO
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DOCKET ACIL:50-316 Donald C.
Cook Nuclear Power Plant, Unit 2, Indiana M
05000316 AUTH.NAME AUTHOR AFFILIATION DAVIS,A.B.
Region 3 (Post 820201)
RECIP.NAME RECIPIENT AFFILIATION FITZPATRICK,E.
Indiana Michigan Power Co. (formerly Indiana
& Michigan Ele SUBJECT:
Forwards notice of violation
& proposed imposition of civil penalty in amount of
$ 37,500,as result of insp rept 50-316/92-22 on 921203-18.
DISTRIBUTION CODE:
IEOlD COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:
D RECIPIENT 1D CODE/NAME PD3-1 PD INTERNAL: AEOD AEOD/DSP/TPAB DEDRO NRR/DLPQ/LHFBPT NRR/DOEA/OEAB NRR/PMAS/ILPB 1 NRR/PMAS/1LRB12 R
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EXTERNAL: EG&G/BRYCEgJ.H.
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1 RECIPIENT ID CODE/NAME DEANiW AEOD/DEIB AEOD/TTC NRR MORISSEAUiD NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NRR/PMAS/ILPB
NUDOCS-ABSTRACT OGC/HDS2 RGN3 FILE
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0 NOTE TO ALL RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK.
ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAhIE FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR
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UNITED STATES NUCLEAR REGULATORY COMMISSION R EG ION II I 799 ROOSEVELT ROAO GLEN ELLYN, ILLINOIS 60137 February 8, 1993 Docket No. 50-316 License No.
DPR-74 EA 92-252 Indiana Michigan Power Company ATTN:
Mr. E. Vice President Nuclear Operations Division
- 1 Riverside Plaza-Columbus, OH 43216
Dear Mr. Fitzpatrick:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY
$37I500 (NRC INSPECTION REPORT 50-316/92022)
This refers to the special safety inspection conducted during the period from December 3 through 18, 1992, at the D.
C.
Cook Nuclear Plant Unit 2 to review circumstances surrounding an incident on September 28, 1992, in which an emergency diesel generator (EDG) tripped due to low lube oil pressure.
You reported this event to the NRC on November 20, 1992.
The report documenting the inspection was sent to you by letter dated December 31, 1992.
The inspection identified a significant-violation of NRC requirements, and on January 8,
1993, an enforcement conference was conducted in the Region III office.
The report summarizing the enforcement conference was sent to you by letter dated January 15, 1993.
On September 28, 1992, with'Unit 2 in Mode 5 (cold shutdown),
"AB" was started for a routine surveillance test.
Twenty-four seconds after the start, the EDG tripped on low-low lube oil pressure.
The lube oil level indicator for the EDG indicated 309 gallons, but a dip stick measurement indicated there were only 127 gallons in the tank.
The administrative low level limit'equired for engine operation is 400 gallons.
The EDG became inoperable due to" loss of oil inventory sometime following the last successful test of the EDG on September 1,
1992.
The oil loss was the result of a seal leak on the "Before and After" pump.
A maintenance work request had been written on May 9, 1992, to fix the leak, and chemistry personnel had notified operations personnel on June 12 of the continued. leaking of the oil.
Despite the recognition of the leak, the adverse CERTIFIED MAIL RETURN RECEIPT RE UESTED
'II302120088 930208 PDR ADOCK 050003i6
PDR Yp
February 8, 1993 trend in oil level was not addressed through any compensatory actions such as periodically adding oil.
Contributing to the problem was the fact that the oil level indicator had not been calibrated for several years and was inaccurate, and the lube oil tank low level alarm failed to actuate on the low level.
Also, the operator's
"rounds" sheets were deficient in that they did not have acceptance criteria or action statements for the operators when they discovered low levels of oil.
The technical specifications (TS) require that both EDGs be operable for operation in Modes 1-4, and Unit 2 was in Modes 1-4 until September 25, 1992, when Mode 5 was entered.
With one EDG inoperable, the inoperable EDG is required to be restored to an operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the unit must be put in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Because the significance of the oil leak went unnoticed the diesel was not returned to operable status within the time required nor was the unit placed in Mode
as required.
Therefore, in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
CFR 2, Appendix C, the violation has been categorized at Severity Level III.
The violation, described in Section I of the enclosed Notice of Violations and Proposed Imposition o'f Civil Penalty, concerns a
significant failure to assure that emergency power would have-been available if needed.
There were several contributing causes for the violation:
(1) the failure to recognize the downward trend of the oil level, (2) the failure to identify that the level had fallen below the administrative limit even though the gauge so indicated, (3) the lack of acceptance criteria in the procedure, (4) the level indicator problems, (5) the failure of the low level alarm, and (6) the failure to act on the information provided by.the chemists'f the continuing leaking of the oil.
We acknowledge your immediate corrective actions to restore the oil level to its normal operating range, to repair the oil seal, and to check the EDG bearings for damage.
We also acknowledge your comprehensive longer term corrective actions such as:
(1)
revising the surveillance procedures, (2) reviewing the work request prioritization process, (3) involving the system engineers in the work control process, (4) creating a work classification organization, and (5) perform an engineering
=review of the EDG lube oil sump tank level indication design.
While the actions described above should prevent this event or similar ones from occurring again, you should remember that there is no procedural substitute for tenacity and -questioning attitudes on the part of all of the separate organizations at the plant.
Had aggressive followup been taken by any-of the groups
February 8, 1993 that were aware of the leakage, this problem would likely have been avoided.despite the procedural and other inadequacies that existed.
To emphasize the need for you to assure that, problems with systems important to safety are corrected promptly and that your staff takes a more questioning attitude when presented with anomalous information on such systems, I have been authorized,*
after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research, to issue the enclosed Notice of Violations and Proposed Imposition of Civil Penalty in the amount of
$37,500 for the Severity Level III violation.
The base value of a civil. penalty for a Severity Level III violation is
$50,000.
The escalation and mitigation factors in the Enforcement Policy were considered.
The base civil penalty was mitigated 25% because you demonstrated initiative in identifying the root cause of this self-disclosing event.
It was also mitigated 50% because of your comprehensive corrective actions.
The base civil penalty was further mitigated by 504 for your good prior performance.
Mitigation for this factor can be as high as 100>; however, your overall performance in Operations was rated Category 2 in the last SALP period and normally this would not be sufficient cause for mitigation.
Partial mitigation is appropriate in this case because, among other things, there have been no escalated enforcement actions taken against the D.
C.
Cook license in the last two years and no violations in Operations have occurred in the last two years.
The base civil penalty was also escalated by 100% for your failure to identify the potential for EDG inoperability earlier even though you had severa'l opportunities,to do so.
No escalation or mitigation was considered appropriate for'he other factors.
Therefore, based on the above, the base civil penalty was decreased by 25 percent.
Two additional violations not assessed a civil penalty were identified and are described in Section II of the enclosed Not'ice; One violation concerns the failure to correct the oil leakage problem when it was first identified.
The other violation concerns the lack of acceptance criteria for lube oil volume in the surveillance procedure.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when. preparing your response.
In your response, you should document the specific actions taken and any additional acti'ons you plan to prevent recurrence.
- After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
February 8, 1993 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.
The response directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980I PL 96 51 1 ~
Should you have any questions concerning this letter, please contact us.
Sincerely, p
A. Bert Davis Regional Administrator Enclosure:
'-.
Notice of Violation and Proposed Imposition of Civil Penalty cc w/enclosure:
A. A. Blind, Plant Manager DCD/DCB (RIDS)
OC/LFDCB Resident Inspector, RIII James R. Padgett, Michigan Public Service Commission EIS Coordinator, USEPA Region 5 Office Michigan Department of Public Health D. C..Cook, LPM, NRR
February 8, 1993 DISTRIBUTION SECY CA JTaylor, EDO JSniezek, DEDR JLieberman, OE LChandler, OGC JGoldberg, OGC TMurley, NRR JPartlow, NRR Enforcement Coordinators RI, RII, RIV, RV FIngram, GPA/PA DWilliams, OIG
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BHayes, OI EJordan, AEOD OE:Chron OE'EA (2)
DCS RAO:RIII SLO:RIII PAO RIII IMS:RIII