IR 05000409/2005031
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' t UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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MSMNGTON, D. C. 20555
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July 16, 1985
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Y The Honorable Edward Markey, Chairman Subcomittee on Energy Conservation and Power
'Comittee on Energy and Commerce United States House of Representatives Washington, DC 20515
Dear Mr. Chairman:
Enclosed please find a notice of violation issued to Toledo
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Edison Company for violations at the Davis Besse Nuclear Power
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Station.
Sincerely,
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An M arlto M er, Dir ctor Office of Congre al Affairs
Enclosure:
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As stated
Inspection Report
No. 50-346/85018(DRP)
cc w/ enclosures:
R. P. Crouse, Vice President Nuclear
S. Quennoz, Station Superintendent
DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII-
James W. Harris, State of Ohio
Robert H. Quillin, Ohio
Department of Health
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Toledo. Edison Company
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July 12, 1985
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Distribution
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JTaylor, IE
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RVollmer,-IE
JKeppler, RIII
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JAxel' rad, IE
JCollins, IE
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ABBeach, IE
JLieberman, ELD
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VStello, DED/ROGR
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Enforcement Coordinators
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HDenton, NRR
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BHayes, OI
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SConnelly, OIA
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FIngram, PA
JCrook, AE00
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EJordan, IE
JPartlow, IE
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' PROPOSED IMPOSITION OF CIVIL PENALTY
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Toledo Edison Company
Docket No. 50-346
Davis-Besse Nuclear Power Station
License No. NPF-3
EA 85-71
An inspection conducted during-the period April 9 - May 31,1985 identified
three violations of NRC requirements.
These violations involved the failure to
follow a procedure that required responsible individuals to be notified at the
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time' the security and fire protection computer was shutdown, the failure of a
non-licensed op3rator to monitor piping status in the Auxiliary Feedwater Pump
area because he was sleeping, and the failure to limit thermal power as required
by the Technical Specifications when the reactor coolant flow rate decreased.
To emphasize the importance of effective communications within your organization-
and to ensure that when problems are identified, root causes are found and
adequate corrective actions are taken, the NRC proposes to impose a civil penalty-
in the~ amount of One Hundred Thousand Dollars ($100,000).
In accordance with
the " General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C (1985), and pursuant to Section 234 of the Atomic
Energy Act of 1954, as amended, 42 U.S.C. 2282, PL 96-295, and 10 CFR 2.205,
the particular violations and the associated civil penalty is set forth below:
I.
10 CFR Part 50, Appendix B, Criterion XIV, " Inspection, Test, and Operating
Status," requires measures be established for indicating the operating
status of structures, systems, and components of the nuclear power plant.
The Toledo Edison Nuclear Quality Assurance Manual (NQAM) Section 14.0
requires that the plant manager be responsible for establishing and maintaining
a program in which the operating status of equipment is known at all times.
Section 14.1.1.1 of the NQAM requires that permission to release equipment
or systems for maintenance or test be granted by the Shif t Supervisor.
Contrary to the above, on April 9,1985, the licensee did not implement its
program to ensure that the operating status of equipment is known at all
times.
The security-fire / radiation computer was removed f rom service,
without permission being granted by the Shif t Suoervisor.
The Shift
Supervisor became aware of the computer shutdown when the computer was
being returned to service.
II. Amendment No. 83 of Facility Operating License No. NPF-3 adds paragraph
2.C(3)(t) which states, " Toledo Edison shall operate the Startup
Feedwater Pump (SUFP) with'the following operational restrictions:
1. Toledo Edison will station an operator in the Startup Feedwater Pump /
Auxiliary Feedwater Pump (SUFP/AFW) area during operation of the SUFP to
monitor SUFP/ Turbine Plant Cooling Water (TPCW) piping status in the AFW
Pump Rooms."
Contrary to the above, at approximately 1210 on April 24, 1985, during
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July 12, 1985
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operation of the SUFP, the NRC inspector observed that a non-licensed
operator who had been assigned to monitor the SUFP/TPCW piping status in
the AFW Pump Room was asleep and, therefore, failed to perform the
required monitoring.
III. Technical Specification 3.2.5 requires that if the reactor coolant flow
rate exceeds its limit, then flow must be restored to within its limit
within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or thermal power must be limited at least 2% below rated
' thermal power for each 1% of flow that is outside the limit for four pump
operation within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
Contrary to the above, from 1150 on April 19, 1985 to 0250 on April 20,
1985, while at approximately 98% power, the licensee recorded a reactor
coolant flow rate 1.79% to 2.065% low.
Since flow was not restored to
its limit within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, thermal power was required to be limited to
between 96.42% and 95.87%.
From approximately 1720 on April 19, 1985
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until approximately 0220 on April 20, 1985 (9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />), thermal power was
approximately 98%.
This exceeded the thermal power limit of Technical
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Specification 3.2.5.
Collectively, the above three violations have been evaluated as a
Severity Level III problem (Supplement I).
(Civil Penalty - 5100,000 assessed equally among the violations)
Pursuant to the provisions of 10 CFR 2.201, Toledo Edison Company is hereby
required to submit to the Director, Office of Inspection and Enforcement,
U. S. Nuclear Regulatory Commission, Washington, DC 20555 and a copy to the
Regional Administrator, U. S. Nuclear Regulatory Commission, Region III,
799 Roosevelt Road, Glen Ellyn, IL 60137, within 30 days of the date of this
Notice a written statement or explanation, including for each alleged violation,
(1) admission or denial of the alleged violation; (2) the reasons for the
violation, if admitted; (3) the corrective steps which have been taken and the
results achieved; (4) the corrective steps which will be taken to avoid further
violations; and (5) the.date when full compliance will be achieved.
Considera-
tion may be given to extending the response time for good cause shown.
Under
the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be
submitted under oath or affirmation.
Within the same time as provided for the response required above under
10 CFR 2.201, Toledo Edison Company may pay the civil penalty in the amount
of $100,000 or may protest imposition of the civil penalty in whole or in
part, by a written answer.
Should Toledo Edison Company fail to answer
within the time specified, the Director, Office of Inspection and Enforcement
will issue an order imposing the civil penalty proposed above.
Should Toledo
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July 12, 1985
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Edison Company elect to file an answer in accordance with 10 CFR 2.205
protesting the civil pena.lty such answer may:
(1) deny the violation listed
in the Notict, in whole or in part; (2) demonstrate extenuating circumstances;
(3) show error in this Notice; or (4) show other reasons why the penalty should
not be imposed.
In. addition to protesting the civil penalty, in whole or in
part, such answer may request remission or mitigation of the penalty.
In
requesting mitigation of the proposed penalty, the five factors contained in
Section V(b) of 10 CFR Part 2, Appendix C should be addressed.
Any written
answer in accordance with 10 CFR 2.205 should be set forth separately from
the statement or explanation in reply pursuant to 10 CFR 2.201, but may
incorporate statements or explanations by specific reference (e.g., citing
page and paragraph numbers) to avoid repetition.
Toledo Edison Company's
attention is directed to the other provisions of 10 CFR 2.205 regarding the
procedures for imposing a civil penalty.
Upon failure to pay any civil penalty due, which has been subsequently deter-
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mined in accordance with the applicable provisions of 10 CFR 2.205, this
matter may be referred to the Attorney General, and the penalty unless
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compromised, remitted, or mitigated, may be collected by civil action
pursuant to Section 234c of the Act, 42 U.S.C. 2282.
FOR THE NUCLEAR REGULATORY COMMISSION
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[JamesG.Keppler
Regional Administrator
Dated at Glen Ellyn, Illinois
this
sa* day of July 1985
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION III
Report Nc. 50-346/85018(ORP)
Docket hc. 50-346
License No. NPF-3
Licensee:
Toledo Edison Company
Edison Plaza, 300 Madison Avenue
Toledo, Ohio 43652
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Facility Name:
Davis-Besse 1
Inspection At:
Oak Narbor, OH
Inspection Conductec: April 9 through May 31, 1985
Enforcement Conference:
May 24, 1985
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Inspectors:
W. Rogers
D. Kosloff
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M. Ring
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Approved By:. M. Jackiw, Chief
Projects Section 2E
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Date
InspectionSummareg
Inspection on April 9 throuch May 31, 1985 (Report No. 50-346/85018(DRP))
Areas Inspectec:
removal of the security and fire protection computer frorr
events:
without the shif t supervisor being informed; exceeding the thermal power for
tne reactor coolant flow available and having one channel of the reacto
protection system set' lower than the allowable setpoint; and the discovery of
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a non-licenseo operator asleep while implementing a condition of the license.
The inspection involved 27 inspector-hours onsite by two NRC inspectors
_Res ults:
Three items of nonennpliance were identified (failure to notify
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appropriate personnel that fire detection equipment was removed from service;
failure to perform the action statements of Technical Specification 3 2 5
associated with reactor power and reactor protection system setpoints; and
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failure to properly implement a condition of the license associated with
operation of the startup feedwater pump).
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OETAILS
1.
Persons Contact'e'd
T. Murray, Assistant Vice Presioent, Nuclear M1sslor
S. Quennoz, Plant Manager
W. O' Conner, Operations Superintendent
L. Simon, Operations Supervisor
J. Lingenfelter, Technical Superintendent
The inspectors also interviewed other licensee employees, including
members of the technical, operations, maintenance, I&C, training and
health physics staff.
Enforcement Conference on May 24, 1985
Toledo Edisor. Personnel
R. Crouse, Vice President, Nuclear Mission
T. Murray, Assistant Vice President, Nuclear Mission
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S. Quennoz, Plant Manager
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R. Peters, Nuclear Licensing Manager
NRC Personnel
J. Kepoler, Administrator, Region III
C. Nerelius, Director, Division of Reactor Projects
W. Shafer, Chief, Projects Branch 2
I. Jackiw, Chief, Prelects Section 2B
W. Rogers Senior Resident Inspector
D. Kosloff, Resident Inspector
M. Ring, Reactor Inspector
M. McCormick-Barger, Reactor Inspector
E. Berson, Legal Counsel
W. Senuitz, Enforcement Coordinator
2.
Inocerable Fire Protection Comcuter
While reviewing the unit log on April 9, 1985 the inspector noted that
the security and fire protection computer had been shutdown for
maintenance from 0915 to 1120 and the Snift Supervisor had no knowledge
of the shutdown.
The Toledo Edison Nuclear Quality Assurance Manual
(NQAM) Section 14.0 requires that the plant manager establishes and
maintains a program in which the operating status of equipment is known
at all times.
Section 14.1.1.1 of the NQAM furtner requires that the
shift supervisor grant permission to release equipment or systems for
maintenance or test.
Failure to inform the shift supervisor of the
equipment status at all times is considered a violation (346/85018-01).
A discussion of the occurrence with the shif t supervisor revealed that
althougn he had'been informed that the security and fire protection
computer was to be shutdown for maintenance that morning he was not
notified at the time the computer was actually shutcown.
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fire watch patrols in accordance with existing plant procedures af'ter
his independent discovery that the computer had been shutcown.
During
the enforcement conference the licensee stated that the areas in cuestion
were being patrolled due to fire protection equipment other than the fire
detectors being out,of service.
Tne licensee further stated that the
security supervisor has oeen designatec as the inc1vidual to inforir the
shift supervisor wnen the computer is taken out of serv 1ce.
3.
_ Inaccurate Reactor Power Measurements
The limiting condition for operation of Technical Specif' cation 3.2.5
recuires reactor coolant flow to be equal to or greater than a specific
' val ue.
Tne action statement associated with this limiting condition
recuires that, within four hours, reactor power be reduced by 2% for
every 1% that flow is less than the given value.
From approximately 1720
on April 19, 1985 until approximately 0220 on April 20, 1985 thermal
power was approximately 98%.
At this time the limit for thermal power
was between 96.42% and 95.8%.
failure to maintain proper reactor power
for the indicated reactor coolant flow is considered an item of
noncompliance (346/85018_02).
The events surrounding this condition are
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discussed in Inspection Report No. 85009.
During the enforcement confer-
ence the licensee confirmed that for approximately twelve hours one of the
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four reactor power indicators was set less than actual reactor power by
2. 3 during the same time period in question.
This indicator provides
an input te the Reactor Protection System (RPS).
These examples were the
result of the licensee's failure to recognize that a feedwater flow
indicator that had failed a week before provided an input to the computer
heat balance calculation which is the standard Dy which the reactor power
indicators are calibrated and which is the operators' primary indication
of reactor thermal power.
4.
Startuo Feedwater Pumo Pioina Monitoring
While touring the startup feedwater pump / auxiliary feedwater pump
(SUFP/AFWP) area on April 24, 1985 at approximately 1210 the inspector
observed that the only other person in the room was a sleeping
non-licensec operator.
The plant was in hot standoy and tne SUFP was in
operation.
Paragraph 2.C.(3)(t) of the facility's operating license
reautres that the licensee station an individual In the SUFP/AFWP area
during operation of the SUFP to monitor the SUFP/ turbine plant cooling
water (TPCW) piping status in the room.
In the event of SUFP/TPCW pipe
leakage the operator is to trip the SUFP locally or notify the control
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room to trip the SUFP, and isolate tne SUFP/TPCW piping.
Failure te
properly monitor the SUFP/TPCW piping status is considered an item of
noncompliance (346/85018-03).
Suosecuently, anotner licensee employee
entered the room and awakened the operator in the presence of the
inspector.
Tne inspector notified the operator's supervisors of the
occurrence.
The lieensee took disciplinary action against the sleeping
individua'..
5.
Enforcement Conference
An Enforcement Conference was held on May 24, 1995 in the NRC Region III
office to discuss the circumstances surrounding the violations identified
during the inspection that was initiated on April 9, 1985.
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The meeting was opened by Mr. J. G. Keppler, Regional Administrator.
He
described in general terms the violations that were identified during the
inspection.
The licensee representatives were informed that individually
the three violations were not cause for serious concern; however, more
importantly there was an apparent overall breakdown in communication
between site and corporate management as well as between corporate
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manage rs.
The licensee representatives admitted they did not learn of
the violations in a timely manner and were not directly involved in the
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corrective actions that were taken.
The plant manager described
corrective actions that had been taken to resolve each of the violations.
Tne NRC staff concluded that these actions addressed the specific problems
but did not adequately deal with the root cause which was lack of manage-
ment oversight ano communication.
The licensee representatives expressed
their concern, said they understood the problem and would take immediate
steps to ensure that Davis-Besse management would become more involved in
plant operation.
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