ML20214F805

Discusses Safety Insp on 860714-0811 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $25,000.Violations Represent Significant Breakdown in Sys Designed to Control & Prevent Occurrences

ML20214F805
Person / Time
Site:	Cook
Issue date:	11/18/1986
From:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Dolan J AMERICAN ELECTRIC POWER SERVICE CORP., INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
Shared Package
ML20214F809	List: ML20214F805 ML20214F818
References
EA-86-150, NUDOCS 8611250439
Download: ML20214F805 (4)

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NOV i 81986 Docket Nos. 50-315 and 50-316 Licenses Nos. DPR-58 and 74 EA 86-150 ,

American Electric Power Service Corporation Indiana and Michigan Electric Company ATTN: Mr. John E. Dolan Vice President 1 Riverside Plaza Columbus, OH 43216 Gentlemen:

SUBJECT:

NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORTS N0. 50-315/86029 and 50-316/86029)

This refers to the special safety inspection conducted during the period July 14 through August 11, 1986, at the Donald C. Cook Nuclear Plant of activities authorized by NRC License Nos. DPR-58 and 74. This inspection reviewed the circumstances associated with the inoperability of two of four power range excore nuclear instruments during a Unit 2 reactor startup. This discrepancy was identified by your staff and reported to the NRC on July 14, 1986. The results of the inspection were discussed on July 29, 1986, during an enforcement conference held in the Region III office between you and others of your staff and Mr. A. B. Davis and the NRC staff. A copy of the inspection report was sent to you by letter dated September 4, 1986.

Violations I.A.1 and I.A.2 in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) involved personnel failing to follow procedures when attempting to establish a correct wiring and drawing configu-

, ration for power range nuclear instrument channels NI-41 and NI-42. After you determined on May 31, 1986 that both power range nuclear instrument channels appeared to be incorrectly drawn and/or wired, personnel failed to follow procedures and initiate a Condition Report to resolve the problem. The Condition Report would have caused you to analyze tha discrepancies and may have averted the inoperability of'these nuclear instrumentation channels when their operabil-ity was required. In addition, conflicting statements on information tags and lifted lead tags for power range nuclear instrument channel NI-42 contributed to a personnel error that resulted in channel inoperability.

Violation I.B in the enclosed Notice involved your failure to realize that channels NI-41 and NI-42 were inoperable because of the wiring errors that resulted in non-conservat.ive neutron flux trip setpoints. The Unit 2 reactor was operated up to 9 percent power for over four days with two of the four power range nuclear instruments inoperable in violation of your Technical Specification requirements.

8611200439 861118 PDR ADOCK 05000315 Ig G PDR

American Electric Power 2 NOV 181986 Service Corporation The viola ans described above collectively represent a significant breakdown in syste, , designed to control and prevent such occurrences. The initial wiring errors were compounded by the failure to properly implement procedures designed to control drawings, tagging, lifting wires, post maintenance testing verifications and issuance of Condition Reports. These multiple errors are indicative of a lack of attention to detail regarding procedures used for maintenance of safety systems.

To emphasize the importance of maintaining safety-related equipment operable and of having disciplined control of activities through proper use of work and design control documentation and deficiency reporting systems, I have been authorized, after consultation with the Director, Office of Inspection and Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Twenty-Five Thousand Dollars ($25,000) for Violation I described in the enclosed Notice. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986) (Enforcement Policy), the violation has been classified in the aggregate as a Severity Level III problem. The base civil penalty for a Severity Level III problem is $50,000. However, the NRC Enforcement Policy allows for reduction of a civil penalty under certain circumstances. In this case, the base civil penalty is reduced by 50 percent because of your unusually prompt and extensive corrective actions that included: (1) procedure enhance-ments, (2) documented independent verification on all lifting / landing of leads, (3) establishment of turnaround time limits for Condition Report processing and feedback to the originator, and (4)' deletion of information tags from the list of approved tags. Further mitigation was not given for your reporting of this event because of the time it took you to detect and correct the violation.

Violation II in the enclosed Notice occurred when personnel failed to follow procedures and make a timely notification to your shift supervisor after discovering that the two power range nuclear instrument channels were inoperable.

This violation has been characterized as a Severity Level IV violation.

You are required to respond to this letter and should follow the instruction specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions, the NRC will determined whether further enforcement action is necessary to ensure compliance with NRC regulatory requirements.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Room.

'American Electric ~ Power 3 NOV 101996 Service Corporation The responses 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 1980, PL 96-511.

Sincerely, cr:g:n,1 cie:va by Jf.21 G,liiJ'Iir James G. Keppler Regional Administrator

Enclosures:

1. Notice of Violation and Proposed Imposition of Civil Penalty

2. Inspection Reports No. 50-315/86029 No. 50-316/86029 cc w/ enclosures:

W. G. Smith, Jr. , Plant Manager DCS/RSB (RIDS)

Licensing Fee Management Branch Resident Inspector, RIII Ronald Callen, Michigan Public Service Commission EIS Coordinator, USEPA Region 5 Office Nuclear Facilities and Environmental Monitoring Section RIII RI RIII RIII RIII N o Ic ltz Da is

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