ML17333A286
| ML17333A286 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 01/22/1996 |
| From: | Kropp W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17333A285 | List: |
| References | |
| 50-315-95-14, NUDOCS 9602060021 | |
| Download: ML17333A286 (15) | |
See also: IR 05000315/1995014
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION III
REPORT
NO.
50-315/95014
~FACI ITY
Donald C.
Cook Nuclear Generating
Plant
LICENSEE
Company
Donald C.
Cook Nuclear Generating
Plant
1 Riverside Plaza
Columbus,
OH 43216
DATES
December
20,
1995 through January
16,
1996
INSPECTORS
B. L. Bartlett, Senior Resident
Inspector
D. J. Hartland,
Resident
Inspector
C. N. Orsini, Resident
Inspector
APPROVED
BY
4e
W. g; Kropp
Chief
Reactor
P ojects
Branch
3
Date
AREAS
INSPECTED
A special,
unannounced
inspection of the circumstances
surrounding the
inoperability of the Unit
1 Mest Centrifugal Charging
Pump
(CCP).
The areas
inspected primarily involved Instrumentation
and Control
(ISC) technician
performance,
training,
and the quality of procedures
as they related to the
calibration of safety-related
induction coil relays.
9b020b002i
9bOi25
.PDR
ADQCK 050003i5
8
xec tive Summ
A self-revealing
event occurred
where the licensee
subsequently
identified
that the Unit I Mest
CCP had been inoperable for 6 months.
It was identified
that
a lack of requalification training for the
I&C technicians,
a poor
procedure,
and
a poor review of as-found data contributed to this event.
In
addition, the licensee
had
an unnecessary
delay in determining the operability
and reportability of the as-found condition following the self-revealing
failure on September
12,
1995.
iI'
INSPECTION DETA
S
1.0
Summar
of
vent
On September
12,
1995, Unit I was in a refueling outage with all fuel removed
from the reactor vessel.
During the time the core was unloaded,
the licensee
performed full flow testing of the emergency
core cooling system
(ECCS).
During the full flow testing,
the West Centrifugal Charging
Pump
(CCP) tripped
on
a sensed
overcurrent after
7 minutes of full flow.
The licensee's
evaluation determined that the overcurrent relay was improperly set since the
last calibration
on March 15,
1995.
The licensee
has
two CCPs in each unit as required
by technical specification
(TS).
Each
CCP performs the dual role of CCP and of being the high-head
safety injection pump.
During normal operation,
the
do not draw as
much
current
as when used for high-head safety injection.. During a loss-of-coolant
accident
(LOCA), reactor coolant system
(RCS) pressure
would drop, the
discharge
flow rate would increase
and the motor amperage
drawn would
increase.
A timed overcurrent relay (I-51-TA8) was in the circuit in order to protect
the motor from harm during long term (seconds
to several
minutes) overcurrent
situations.
The relay was
a General Electric model
66 type
IAC (Induction
Disc Current sensing relay).
The greater the sensed
the shorter
the time delay.
For overcurrents just slightly above the setpoint,
the relay
would normally take
a number of minutes to trip.
That the relay tripped
7
minutes into what would otherwise
be
a normal
run indicated that the setpoint
was close to the normal operating condition.
2.0
oot
C
ses
The licensee
and the inspectors
identified the following root causes for this
event:
The primary root cause
was the lack of requalification training which
lead to personnel
error on the part of the
IKC technicians.
The two
technicians
involved in the March 15,
1995, calibration
had been
properly trained in 1992.
However, the lead technician
had not
performed
any relay calibrations since this training.
The lead
technician
had calibrated the relay using
a wrong technique
as
a result
of his unfamiliarity.
The second technician
had
been qualified on this
type of relay on August 25,
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 this calibration.
Licensee
dent fied
The calibration procedure,
12IHP6030.IMP.014,
was written such that it
did not assist
the technicians
in the performance of their duties.
The
calibration procedure for this type of relay had 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
t
~r
amount of detail required in the procedure
was small.
Since then, the
licensee's
practice
was to have
any qualified I5C technician
capable of
calibrating relays.
This necessarily diluted the experience that any
one technician would gain, thus causing the procedure quality to become
inadequate.
Ins ector Identified
4
The as-found data taken
by the technicians
in the March 1995 calibration
was not identified as being erroneous.
The as-found data
showed that
the I times
(1X) overcurrent setpoint
was high, while the
3 times
(3X)
overcurrent setpoint
was low.
When the data
was reviewed following the
surveillance,
this should have
been identified as inconsistent with this
type of instrument.
Both setpoints
would either
be high or they would
both
be low, it would not be possible to have
one setpoint low and the
other setpoint high.
In addition, the
3X overcurrent
was by itself so low that it should
have
been identified as warranting further attention.
Using the calibration
curves of the relay, it was possible to identify during the event
assessment
that if the
3X overcurrent data
was correct, that the
pump
would have tripped
on sensed
overcurrent during normal operation.
ice see
dentif'ed
3.0
i e see
rr c 've
ct ons
~
Relay I-51-TAB was recalibrated
and returned to service..
~
The two IKC technicians
involved had their relay qualifications voided
and were to be requalified
on the calibration of IAC relays.
~
Periodic requalification for technicians
was added to the licensee's
training program.
- The training program was to continue to assess
the
need for additional training.
~
The calibration procedure
was enhanced
by increasing
the level of detail
in the procedure.
~
All relays monitoring safety related motors that had not been tested
by
other surveillances
have
been
checked to verify their calibration.
The
licensee
stated that only one other relay was identified as being out of
calibration.
The Unit I West containment
spray
pump was identified as
being low, but was assessed
as still operable.
~
Until all technicians
were re-trained,
only those technicians that were
tested
using
bench devices
would be allowed to calibrate
IAC relays.
4.0
Ins ecto
se
s
e t o
icens
e Action
4.1
Review of As-found Data
One of the root causes
identified by the licensee
was that the review of
as-found data in Harch of 1995 should
have identified that calibration
~
~
g
-:
0 1
~<<O'I
tlP'IPN hV'%t + 1I%
4.2
technique
used to obtain the data
was incorrect.
However none of the
licensee's
corrective actions stated
in Licensee
Event Report 315/95-011
Revision 0,
addressed
this failure.
C
b ti
oce
ev
o
The calibration procedure
was revised
by the licensee
as stated in their
LER.
This revision was initially weak in that it failed to use the
same
terminology that was in the
18C technicians training program (for
example it did not use "just flicker").
Subsequently,
the licensee
revised the procedure to supply additional information.
This additional
information did supply the
IKC technicians with sufficient detail
and
also
added other enhancements.
As such,
the inspectors
concerns
were
resolved.
4.3
Time iness f
ve t Assessme t
4,4
The inspectors
determined that the licensee
promptly assessed
the trip
of the Unit
1 Mest
CCP following the failure to run on September
12,
1995.
The onsite efforts to identify the root cause
and its
implications were excellent.
Timeliness
o
0 er bilit
Re ortabilit
On September
22,
1995, site personnel
requested
the assistance
of
corporate
engineering
in assessing
the operability of the
CCP with the
relay set too low. It took corporate engineering until November 20,
1995, to respond.
It appeared
that corporate engineering failed to
place the appropriate priority on this response.
In addition,
once
corporate
engineering
made the determination of inoperability, corporate
licensing did not realize that
a high head safety 'injection pump being
inoperable for 6 months would be reportable to the
NRC.
These
two
factors combined,
added
up to an unnecessary
delay in reporting of about
2 months.
4.5
Perfo mance of the Technici
ns
During the performance of the surveillance
on March 15,
1995, the
technicians failed to question the as-found data which would have
shown
that his technique
was incorrect.
In addition, the second
technician,
who had
been trained
more recently than the lead technician,
did not observe
in detail or question the lead technician.
The
questioning
by the second technician did not occur even though
he
observed different lead technicians
performing the calibration using
different techniques.
5.0
Potential
Vio
tions
The following potential violations were identified:
Technical Specification 3.5.2 requires,
in part,
"Two independent
subsystems
shall
be
OPERABLE with each
subsystem
comprised of:
a.
One
OPERABLE centrifugal charging pump,...."
The applicability of this
TS is Modes
1, 2,
and 3.
Action a. States,
"With one
ECCS subsystem
restore the
subsystem
to OPERABLE within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in HOT SHUTDOWN
within the next
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."
b.
Contrary to the above,
from 4:31 a.m.
on March 15,
1995, until
11: 17 a.m.
on July 30,
1995, the Unit
1 West (Train B) centrifugal
charging
pump was inoperable
due to
a mis-calibrated overcurrent
relay and the unit was not placed in hot shutdown.
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:
1.
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 />,
2.
At least
HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,
and
3.
At least
COLD SHUTDOWN within the subsequent
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."
Contrary to the above,
both
CCPs were inoperable
which is
a condition
not covered
by TS 3.5.2
and the unit was not placed in hot shutdown:
~
On July 10,
1995,
from 1:00 a.m. until 2:50 a.m.
on July 12, the
Emergency Diesel Generator Train "A," the emergency
power source
for the East
CCP,
was out of service while in Mode l.
~
On July 19,
1995, for 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />
and 35 minutes the East
CCP was
removed
from service while in Mode 3.
C.
10 CFR 50, Appendix 8, Criterion V, states
that activities affecting
quality shall
be prescribed
by documented
procedures
of a type
appropriate to the circumstances.
Contrary to the above, calibration procedure,
12IHP6030. IMP.014,
was not
appropriate for calibrating
a
GE model
66 type
IAC (Induction Disc
Current sensing)
relay.
This procedure
was originally written for
technicians
that specialized
in the calibration of relays
and had not
been
changed
since the mid-1970s.
The licensee's
practice for
calibrating relays
changed
to allow less specialized
18C technicians
to
calibrate relays.
However, the procedure
was not revised to contain
6.0
sufficient detail for this reduction in technician proficiency to ensure
proper calibration of the
GE model
66 type
IAC relay.
Sa et
Si
e
6.0
The inoperability of the Unit
1 West
CCP for 6 months
was considered
significant in that
an
ECCS component
was incapable of performing its
intended safety function assuming
a single failure.
In addition, there
was at least
one period in which no
CCP was capable of acting
as
a high
head safety injection pump.
Han
ement
eb
efin
7.0
The inspectors
met with licensee
representatives
(denoted in
Section 7.0) after the inspection
on January
16,
1996, to discuss
the
scope
and findings of the inspection.
During the exit meeting,
the
inspectors
discussed
the likely informational content of the inspection
report
and documents
or processes
reviewed
by the inspectors
during the
inspection.
Licensee representatives
did not identify any such
documents
or processes
as proprietary.
Pe
so
s
o t
censee
e sonnel
- A. A. Blind, Site Vice President
- J. R. Sampson,
Plant Manager
- K. R. Baker, Assistant
Plant Manager-Production
- H. E. Barfelz, Superintendent,
Nuclear Safety 5 Analysis
~J.
D. Allard, Maintenance
Superintendent
- H. Depuydt,
Licensing Activity Coordinator
- D. Walker, Haintenance
Procedures
'C.
Miles, Maintenance
Supervisor,
Instrumentation
8 Controls
+A. Lotfi, Supervisor,
Site Design
- G. Gurnow, Plant Engineering,
Maintenance
ISC
- E. Morris, Plant Performance
Assurance
Supervisor
- D. Willeman, Training
- J. Sankey,
Plant Engineering
- B. Nichols, Acting Operations
Superintendent
- T. Walsh,
General
Supervisor - Support
- P. McCarty, Procedure
Supervisor - Maintenance
U.S. Nuclear
Re ulator
Commission
NRC
- D. Hartland
- C. Orsini
- B. Bartlett
- B. Fulle}
- Denotes those present
during the exit meeting
on January
16,
1996.
January
25,
1996
EA 96-020
Mr. E.
E. Fitzpatrick
Senior Vice President
Nuclear Generation
Company
1 Riverside Plaza
Columbus,
OH
43216
SUBJECT:
NRC SPECIAL INSPECTION
REPORT
NO. 50-315/95014(DRP)
Dear Mr. Fitzpatrick:
This refers to the special
safety inspection
conducted
by Messrs.
B. Bartlett,
D. Hartland,
and
C. Orsini of this office from December, 20,
1995,
through
January
16,
1996.
The inspection
included
a review of activities at your
Donald C.
Cook Nuclear Plant, Units
1 and 2.
At the conclusion of the
inspection,
the findings were discussed
with those
members of your staff
identified in the enclosed report.
Areas
examined during the inspection
are identified in the report.
The
inspectors
reviewed the circumstances
surrounding the inoperability of the
Unit
1 Mest Centrifugal Charging
Pump
(CCP).
Mithin these
areas,
the
inspection consisted of a selective
examination of procedures
and
representative
records,
observations,
and interviews with personnel.
Based
on the results of this inspection,
three apparent violations (Section
5.0) were identified and are being considered for escalated
enforcement action
in accordance
with the "General
Statement of Policy and Procedure for NRC
Enforcement Actions" (Enforcement Policy),
The apparent
violations involved a personnel
error and procedural
weakness
that left one
CCP unable to meet its technical specification
(TS) requirement for
operability from March 15,
1995 to September
13,
1995.
The circumstances
surrounding
these
apparent violations, the significance of the issues,
and the
need for lasting
and effective corrective action were discussed
with members
of your staff at the inspection exit meeting
on January
16,
1995.
As
a
result, it may not be necessary
to conduct
a predecisional
enforcement
conference
in order to enable the
NRC to make
an enforcement decision.
However,
a Notice of Violation is not presently being issued for these
inspection findings.
Before the
NRC makes its enforcement decision,
we are
providing you an opportunity to either
(1) respond to the apparent violations
addressed
in this inspection report or (2) request
a predecisional
enforcement
conference.
If you choose to provide
a response,
your response
should
be submitted within
30 days of this letter
and
be clearly marked
as
a "Response
to Apparent
Violations in Inspection
Report
No. 50-315/95014(DRP)"
and should include for
each apparent violation:
(1) the reason for the apparent violation, or, if
E.
E. Fitzpatrick
contested,
the basis for disputing the apparent violation, (2) the corrective
steps that have
been t >ken and the results
achieved,
(3) the corrective steps
that will be taken to avoid further violations,
and (4) the date
when full
compliance will be achieved.
In addition,
we request your response
address:
(1) the potential of other maintenance activities being conducted
using
technicians
who have not maintained proficiency by requalification training or
on the job performance of specialized
procedures;
and (2) the factors
contributing to the delay in determining operability and reportability of the
Unit
1 West
CCP following the event.
Your response
should
be submitted
under
oath or affirmation and
may reference
or include previous docketed
correspondence, if the correspondence
adequately
addresses
the required
response.
If an adequate
response
is not received within the time specified
or an extension of time has not been granted
by the
NRC, the
NRC will proceed
with its enforcement decision or schedule
a predecisional,enforcement
conference.
If you choose
not to provide
a response
and would prefer participating in a
predecisional
enforcement
conference,
please
contact Hr. Wayne Kropp at (708)
829-9633 within 15 days of the date of this letter.
In addition,
please
be advised that the number
and characterization
of
apparent violations described
in the enclosed
inspection report
may change
as
a result of further
NRC review.
You will be advised
by separate
correspondence
of the results of our deliberations
on this matter.
In accordance
with 10 CFR 2.790 of the NRC's "Rules of Practice,"
a copy of
this letter, its enclosure(s),
and your response (if you choose to provide
one) will be placed in the
NRC Public Document
Room (PDR).
To the extent
possible,
your response
should not include
any personal
privacy, proprietary,
or safeguards
information so that it can
be placed in the
PDR without
redaction.
The responses
to the apparent violations described
in the enclosed
inspection
report are not subject to the clearance
procedures
of the Office of Management
and Budget
as required
by the Paperwork Reduction Act of 1980,
Pub.
L.
No.96-511.
Sincerely,
Docket No.
50-315
License
No.
/s/William L. Axelson
W. L. Axelson, Director
Division of Reactor Projects
Enclosure:
Inspection
Report
No. 50-315/95014(DRP)
See Attached Distribution
I
E.
E. Fitzpatrick
Distribution:
cc w/encl:
A. A. Blind, Site Vice President
John
Sampson,
Plant Hanager
James
R. Padgett,
Hichigan Public
Service
Commission
Hichigan Department of
Public Health
Distribution:
Docket File w/encl
PUBLIC IE-01 w/encl
OC/LFDCB w/encl
SRI D. C. Cook w/encl
RHB/FEES w/o encl
DRP w/encl
RIII'RR w/encl
D. C. Cook,
PH,
NRR w/encl
IPAS (E-Hail) w/encl
J.
Lieberman,
J. Goldberg,
R. Zimmerman,
Document:
R:)Insprptsgpowersgcookgdcc95014.drp
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