ML20207R288

Discusses Safety Insp Repts 50-315/86-42 & 50-316/86-42 on 860915-1113 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000

ML20207R288
Person / Time
Site:	Cook
Issue date:	03/12/1987
From:	Davis A 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
ML20207R289	List: ML20207R288
References
EA-87-013, EA-87-13, NUDOCS 8703170065
Download: ML20207R288 (4)

See also: IR 05000315/1986042

Text

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MAR 121987 N

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] Docket No. 50-316 <

License No. OPR-74

EA 87-13

American Electric Power Service

Corporation

Indiana and Michigan Electric Company

ATTN: Mr. John E. Dolan

Vice Chairman

Engineering and Construction

1 Riverside Plaza

Columbus, OH 43216

Gentlemen:

SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY

(NRC INSPECTION REPORTS NO. 50-315/86042(DRP); NO. 50-316/86042(DRP))

This refers to the routine inspection conducted during the period September 15

through November 13, 1986, of activities authorized by NRC Operating License

No. DPR-74 for the D.C. Cook Nuclear Plant, Unit 2. As a result of this

inspection, one violation of NRC requirements was identified. The results of

the inspection were provided in the above referenced report sent to you by

letter dated January 16, 1987. An enforcement confere,ce was held in the

Region III office on January 21, 1987, between you and other members of your

staff, and myself and other members of the Region III and NRR staff to discuss

the violation. '

The event described in the enclosed Notice of Violation and Proposed Imposition

of Civil Penalty (Notice) involved your operations staff rendering both Unit 2

independent emergency core cooling system (ECCS) subsystems not operable while

Unit 2 was cperating in Mode 1, in violation of the Technical Specification

! Limiting Condition for Operations. The north safety injection pump was not

operable in that it had been isolated and de-energized, and the south safety

injection pump was not operable in that two of its four injection flow paths

had been isolated. This condition existed for approximately twenty hours and

was identified several days later during a records review by the NRC Resident

Inspection Staff.

CERTIFIED MAIL

RETURN RECEIPT REQUESTED

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8703170065 870312

gDR ADOCK 05000315

PDR

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American Electric Power Service 2 NAR 121987

Corporation

Your after-the-fact evaluation of this condition determined that a twenty-three

(23) percent reduction in the design margin of the Final Safety Analysis Report

ECCS analysis had existed and that the ECCS would still have been capable of

meeting its safety function. However, the violation is of concern to the NRC

because several licensed operators or senior operators either reviewed this

condition prior to its implementation or were later cognizant of its existence

and were not aware that this condition was contrary to Technical Specifications.

This deficiency demonstrates the importance of a comprehensive knowledge of

system operability requirements and the needed attention to detail by operations

staff when removing equipment from service or operating with equipment out

of service. To emphasize the significance of this deficiency, 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 Fifty Thousand Dollars ($50,000) for the

violation described in the enclosed Notice. In accordance with the " General

itatement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2,

Appendix C (1986) (Enforcement Policy), the violation, as described in the

enclosed Notice, has been categorized as a Severity Level III. The base civil

penalty for a Severity Level III violation is $50,000. The escalation and

mitigation factors in the Enforcement Policy were considered and no adjustment

has been deemed appropriate.

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

action you plan to prevent recurrence. After reviewing your response to this

Notice, including your corrective actions, the NRC will determine whether

further NRC enforcement action is necessary to ensure compliance with

regulatory requirements.

In accordance with 2.790 of the NRC's " Rules of Practice," Part 2, Title 10,

Code of Federal Regulations, a copy of this letter and its enclosure will be

olaced in the NRC Public Document Room.

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American Electric Power Service 3

NMR 121987

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,_

6r101:11 sicStd BP

A fr.n krei's

A. Bert Davis

Acting Regional Administrator

Enclosures:

1. Notice of Violation

and Proposed Imposition of Civil

Penalty .

Inspection Reports

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2.

No. 50-315/86042(DRP);

No. 50-316/86042(DRP)

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

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American Electric Power Service .4

MAR 121987

Corporation

cc w/ enclosures:

PDR

LPOR

ACRS

SECY

CA .

J. Taylor, IE

A. Beach, IE

P. Milano, IE

J. Lieberman, OGC

Enforcement Coordinators

RI, RII, RIII, RIV, RV

i J.. Sniezek, DED/ROGR

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B. Hayes, 01-

,S. Connelly, CIA

J. C. Rooks, AE0D

EA File

ES File

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