ML17194A990
| ML17194A990 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 11/30/1981 |
| From: | Youngblood B Office of Nuclear Reactor Regulation |
| To: | Delgeorge L COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 8201140026 | |
| Download: ML17194A990 (8) | |
Text
NOTICE.OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALITES Commonwealth Edison Company Dresderr Nuclear Station Units 2 and 3 Docket Nos.
50-237 and 50-249 License No~.
DPR-19 and DPR-25 EAs91-164 and 91-165 During NRC inspections conducted from August 29 through November 12, 1991, violations of NRC requirements were identified.
In accordance with the 11General Statement of Policy and Pr:ocedure for NRC Enforcement Actions, 11 10 CFR Part 2,
- Appendix C (1991), the Nuclear Regulatory Commi ss i o_n proposes to impose civil penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act); 42 U.S.C. 2282, and 10 CFR 2.205.
The particular violations and a~sociated civil penalties are sef forth below:
I.
Vi o 1 at ion Assessed a Civil Penalty Associated with Post-Maintenance Testing' 10 CFR Part 50, Appendix B, Cr.iterion XI, "Test Control,
11 requires, in part; t~at a. test program be established to assure that all testing
- required to demonstrate that systems and components will perform satisfactorily in service is identified and performed in.accordance with written test procedu~es which incorporate the requi~ements and acceptance limits contained in applicable design documents.
The test program shall include operational tests of systems and components during nuclear power plant operation, and the test results shali be documented and evaluated to assure that test requirements have been satisfied.
Table 3.7.i of the Technical Specifications lists Unit 3 Drywell Vent Valve N-0. 3-1601-24 as a primary containment isolati.on-valve which is normally in the closed position.
Contrary to the above, the Dresden *Test Control Program failed to demonstrate that Unit 3 Drywell Vent Valve No. 3-1601-24, a primary containment isolation valve which is normally in the closed position, would perform satisfactorily in s~rvice. Specifically, the operator piston rod for Unit 3 Drywell Vent Valve No. 3-1601-24, was replaced on February 3, 1990, leaving the valve partially open, and the licensee failed to test Unit 3 Drywell Vent Valve No. 3-1601-24 to ascertain if the valve. was.in the clos~d position.
This is a Severity Level III violation (Supplement I).
Civil Penalty - $75,000.
9201140026 920109 PDR ADOCK 05000237 G
II.
Violations Assessed a Civil Penalty.Associated with Procedural Adherence and Adequacy A.
10 CFR Part 50, Appendi~ B, Criterion V requires, in p~rt, that**
act,ivities affecting quality shall be prescribed by documented instructions, procedures, or drawings, and shall be accomplished in accordance with these instructioni, procedures, or drawings.
- 1.
Technical. Specification Limit{ni Condition fo~' Op~ration 3.7.A.l.~. requires the torus maximum b~lk water tem~erature to be 95 degrees F.
No action.statement is specified in 3.7.A.l.c.
for torus maximum bulk wate~ tempetatur~ gre~ter than 95 degrees F.
Technical Specification 3.0.A states, in part, in the event a*
Limiting Condition for* Operation cannot be satisfied because of.*
tircumstances in excess of those addresied in the sp~cifi~ation, the.unit shall be placed in at least hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in cold shutdown within the followi'ng 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless corrective measures are completed that satisfy the Limiting Conditions for Operation.
Operations Department Technical Specification Interpretation No. 2, 11Technical Specification 3.0.A Implementation," appro.ved July 25, 1988 requires, in p*art, that if no action statement was specified, then Technical Specification 3.0.A action statement governed and a shutdown be initiated immediately with recirculation flow.
Contrary to the above, on September 1, 1991, at approximately 7:59 p.m., when the Technical Specification Limiting Condition for Operation 3.7.A.l.c. for Unit 2 torus maximum bulk water temperature was exceeded and no action statement was specified, licensed operators failed to initiate a shutdown of Unit 2 immediately with recirculation flow.
- 2.
Dresden Administrative Procedure (OAP) 7-05, "Operating Logs and
- Records, 11 Revision 9, approved August 30, 1990,*Step B.2.b(3),
requires the Unit Log to contain a list of all alarms and abnormal conditions found upon assuming the shift or occurring during the course of the shift, except those denoting normal conditions, a brief narrative of unusual performance of the plant and any efforts made to determine the cause, and Technical Specification Limiting Conditiors for Operation that occur during the shift.
- 3.
Contrary to the above, from the afternoon of August 30, 1991, through.day shift September 1, 1991, the Unit 2 operating log did not document the receipt or presence of the "High Pressure
.Coolant Injection Turbine Inlet Drain Pot High Level 11 alarm, an off-normal condition,* or provide a brief narrative of the efforts to determine the cause of the alarm (three separate instances of cycling the bypass valve, placement of the drain pot in an abnormal lineup, and two occurrences of checking local equipment) and the afternoon shift log entry of September l, 1991, did not identify that a Technical Specification Limiting Condition for Operation 3.7.A.l.c was applicable to the 95 degrees F torus temperature.
OAP 7-02, 11Conduct of Operations, 11 Revision 16, approved August 9, 1991, Step B.2.b(4) requires for the Shift Control Room Engineer (SCRE) shift turnover to include a discussion of unit status.
Contra-ry to the above, during SCRE shift turnover at approximately 7:00 a.m. on September 1, 1991, the offgoing_SCRE did not adequat~ly discuss Unit 2 statu~ with the oncoming SCRE in that the offgoing SCRE did not metition the high pressure coolant injection (HPCI) drain pot abnormal lineup.
- 4.
OAP 7-01; 110perations Department Organization, 11 Revision 15, approved August 19, 1991, Step B.5.d and e, requires the Shift Control Room Engineer (SCRE) to assist the Shift Engineer (SE).
i" interpreting and applying the requirements of Technical Specifications and to notify the SE of any abnormal operating conditioris.
Contrary to the above, during the afternoon shift of September l',
1991, *the SCRE di~ not assist th~ SE in interpreting and applying the requirements of Technical Specifications or notifying the SE of an abnormal operating conditiori in that the SCRE did not inform the SE that the Technical Specification limit/emergency operating procedure entry condition for high torus temperature*
was reached and, when the SE independently noted the high torus temperature, the SCRE did not inform the SE that 95 degrees F was a Technical Specification limit.
Also, on the midnight shift of September 2, 1991, a significant delay (at least two hours) occurred prior to the SCRE interpreting the abnormal operating condition and informing the SE of Technical Specification concerns associated with hi~h torus temperature.
Notice of *Violation 4
B.
- 5.
OAP 7-01, "Operations Department Organization," Revision 15, approved August 19, 1991, Steps B.4.j and B.5.c(3), require that the'SE*b.e responsible for direct observations_ of each_ unit by overview of the control.boards at lea.st twice a shlft in the control room and keeping informed of* any off-normal conditions that may exist or occur during the shift and that the SCRE.
maintain an in-depth knowledge of plant and equipment status.
OAP 7-02, "Conduct of Shift Operations," Revision 16*, approved August 9, 1991, Steps B.2.a(5) and B.2.b(4), require that on turnover the SE walk the unit panels and the SCRE walk the unit pan~ls, performing a thorough review of system configurations, aJarms, and indications.
Contrary to the above, the SE and SCRE for the day shift of September -1, 1991, did not maintain adequate overview of the control boards, perform.adequate panel walkdowns, keep i~fo~med of off-normal conditions, perform a thorough review of system configurations and alarms, and maintain an in-depth knowledge of plant equip~ent and status, in that the SE and the SCRE wer~ not cognizant of the HPCI drain pot alar~ or drain *pot abnormal system lineup (which occurred_on the previous shift).
- 6.
OAP 7-01, 110perations Department Organization," Revision 15, approved August 19, 1991, Step B.6.c(l); requires the Shift_
Supervisor (Licensed) to ensure that the SE and the SCRE were properly informed of all conditions which could adversely affect plant operations.
Contrary to the above, on the afternoon shift of August 30, 1991, the Shift Supervisor (Licensed) did not notify or inform the SE or SCRE of the HPCI drain pot alarm on Unit 2, a condition which could adversely affect plant qperations.
- 7.
OAP 7...:01, 110perations Department Organization," Revision 15, approved August 19, 1991, Step B.9.1, requires the Nuclear Station Operator ( NSO) to notify the proper authorities regarding unusual conditions.
- Contrary to the above, on the day shift of September 1, 1991, upon receipt of a torus high temperature alarm on Unit 2, the NSO did not inform the proper authority, the SE, who had temporarily relieved the SCRE, of the unusual conditi6n of the HPCI drain pot abnormal lineup.
10 CFR Part 50, Appendix B, Criterion V requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings,.and shall be accomplished i~
accordance with these instructions, procedures, or drawings.
Notic~ of Violation 5
OAP 7-:-02, "Conduct of Shift Operations*, 11 Revision 16, approved August 9, 1991, Step 8.21.b(3), requires o~erati~ns personnel to reference and follow the procedure for the entire evolution for complex or infrequently performed evolutions.
DOP 500-4, "Reactor Mode Switch to Shutdown When All Drives are Fully
- Inserted, 11 Revision 0, approved October 28, 1988, Step F.2, requires, in part, discharge each accumulator as follows:
when water stops flowing out the drain ~nd accumulator pressure reads appro~imately 600 p~ig~ close the drain v~lve 3-0305-107 on the accumulator being discharged.
Contrary to the above, on September 23, 1991, operations personnel did not reference and follow DOP 500-4, Revision 0, for the entire infrequently performed evolution required to place the mode switch to shutdown for Unit 3, in that all hydraulic ~antral uriits drain valves were left open.
. C.
10 CFR Part 50, Appendix B, Criterion V requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawing*s, of a type appropriate to the circumstances.
Contrary to the above, plant administrative procedures were not appropriate to the circumsta~ces in the following cases:
- 1.
OAP 7-02,-"Conduct of Shift Operations, 11 Revision 16, approved August 9, 1991, did not give specific guidance regarding performance of interim turnovers, resulting in an inadequate SCRE interim turnover during the day shift of September 1, 1991, in that receipt of a Unit 2 high torus temperature alarm was not mentioned:
- 2.
OAP 3-05, "Out-Of-Service and Persona 1 Protection Cards, 11 Revision 23, approved September 7, 1991, failed to require valves used for an out-of-service (GOS) boundary to be p 1 aced in a controlled status.
When OOS III-1306 dated September 25, 1991, was established to isolate the control air to the scram air header, it did not specify the hydraulic control unit drain valves as part of the OOS boundary to be in a controlled status.
Failure to control the drain valves (tag them closed) resulted in a contaminated water spill in the Unit 3 reactor building on September 25, 1991.
D~
Technical Specification 6.2.A.7 requires detailed written procedure~
covering surveillance and testing requirements be adhered to.
B.
- Contrary to the above, on September 13, 1990, the licensee failed to assure tha*t applicable regulatory requirements and design basis for the Unit 2 Reactor Building trackway outer door *seal were correctly translated into procedures and instructions. Specifically, during replacement of the outer door seal, the licen~ee modified the applicable design basis from a passive seal to an active seal without revising the applicable operating-procedures to specify the steps required to activate the seal.
This is a Severlty Level IV violation (Supplement I).
Technical Specification Section 6~2, 11 Plant Operating Procedures, 11 requires adherence to detailed written procedures, including normal operation of systems and components involving nuclear safety of the
- facility, Dresden Administrative Procedure 13-3, 11Unit 2 Reactor Building Trackway Interlock Door Access Control, 11 Revision 1, dated -
August 22, 1989, which in part implements Technical Specification Section 6.2, requires the trackway inner door of the Unit 2 Reactor
.Building be continuously attended at all times when the door is in the open position.
Contrary to the above, from 8:45 a.m. to 2:00 p.m. on June 24, 1991, the trackway inner door of the Unit 2 Reactor Building was not continuously attended at all times when* the door was in the open position.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, the Commonwealth Edison Compahy (Licensee) is hereby required to submit a written statement of explanation to the Director, Office of. Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notic_e of Violation and Proposed Imposition of Civil Penalties (Notice).
This reply should be clearly marked as a 11 Reply to a Notice of Violation" and should include for each alleged violation:
(1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, and if denied, the reasons why, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps that Will be taken to avoid further violations, and (5) the date when full compliance is achieved.
If an adequate reply is not received within the time specified in this Notice, an order or a demand for information may be issued as to why the license should no~ be modified, suspended, or revoked or why such other actions as may be proper should not be taken.
Consideration 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.
No4ice of Violation 8
Withtn the same time as provided for the response required under 10 CFR 2.201, the Licensee may pay the civil pen a 1 ties by 1 etter addressed to the Di rector, Office Of Enforcement, U.S. Nuclear Regulatory Commission, with a check,* draft, money order, or electronic transfer payableto the Treasurer of the United States in the amount of the civil penalties proposed above, 6r may protest imposition of the civil penalties in whole or in part, by a written answer
. addressed to the Director, Office of Enforcement, U. S.. Nuclear Regulatory Commission.
~hould the Licensee fail to answer within the time specified, an order imposing th~ civil penalties will be issued.
Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, in whole o~ in part, such answer should be clea~ly marked as an*
11Answer to a,
Notice of Violation 11 ar,id may:
(1) deny the violations listed in this Notice in whole or in part, (2) demonstrate extenuating circumstances, (3) show ~rror in this Notice, or (4) show other reasons why the penalties should not be imposed.
In addition to protesting the civil penalties in whole or in part, such answer may request remission or mitigation of the penalties.
In requesting mitigation.of the proposed penalties, the factors addressed in Section V.B of 10 CFR Part 2, Appendix C (1991), 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 parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition.
The attention of the Licensee is directed t6 the other provi~irins of 10 CFR 2.205, regarding the procedure for imposing a civil penalties.
Upon failure to pay any civil penalties due which subsequently has been determined in accordance with the appli~able provisions of 10 CFR 2.205, this matter.may be referred to the Attorney General, and the penalties, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282(c).
The responses noted above (Reply to Notice of Violation, letter with payment of civil penalties, and Answer to a Notice,of Violation) should be addressed to:
Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, ATTN:
Document Control pesk, Washington, D.C. 20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region III, 799 Roosevelt Road, Glen Ellyn, Illino*is 60137, and a copy to the NRC Resident Inspector at the Dresden Nuclear Power Station.
Dated at Glen Ellyn, Illinois, this 1Jl..-day of January 1992 FOR THE NUCLEAR REGULATORY COMMISSION A. Bert Davis Regional Administrator
6 DTS 300-02, 11Control Rod Drive Scram Testing and Scram Valve Tim.ing
- Test, 11 Revision 14, approved.January 22, 1991, Sec:tion_ F., steps 2 and 3, require the controi rod selected for scraniming to qe withdrawn to position.48. prior to closing its charging water valve.
Steps 9
- and 10 require the previously _scrammed control rod be withdrawn to its intended position before repeating the scram sequence for the next cohtrol rod.
Contrary to the -above:
- 1.
At approximately 3:25 a.m., on.October 6,-1991~ a licensed operator did not adhere to the written surveil 1 ance procedure in
. that the charging water valve for control rod P-10, the. control rod selected for scramming, was closed before withdrawing the control rod to position 48.
- 2.
- At approximately 3:25 a.m., on October 6, 1991, a licensed operato~ did not adhere to the written surveillance procedure in..
that the previously scrammed control rod, L-11, was not withdrawn.
to its intended positi~n b~fore contr6l r6d P-10 was scrammed.
E:
Dresden Technical Specification 6.2.A.2 require~, in part, that detailed written procedures covering refueling operations be prepared, approved, and adhered to.
Dresden Fuel Handling Procedure 800-32, 11 Fuel Movement Within the Spent Fuel Pools, 11 Revision 3, approved July 31, 1990, step F.l.t, states that after unlatching the grappl~. raise the grapple approximately 4 inches and -attempt to rqtate the mast.
If the mast*
rotates, the fuel assembly has disengaged from the grapple.
Contrary to the above, on October 18, 1991; at approximately 10:15 p.m., subsequent to unlatching the grapple from a fuel asse~bly
- in location J-9 in the Unit 3 spent fual pool, fuel handlers did not raise the grapple four inches or rotate the mast -to verify that the grapple was disengaged from the fuel assembly.
Thi"s is a Severity Level III problem (Supplement I).
Civi.l Penalty - $112,500 (assessed equally among eleven violations).
III. Violations Not Assessed a Civil Penalty A.
- 10 CFR Part 50, Appendix B, Criterion III,. "Design Control, 11 requires in part that measures be established to.assure that applicable regula.tory requirements and the design basis as specified in the license application for those structures, systems, ahd.components to.
which this appendix applies, are correctly translated into specifications~ drawings! procedures, and instructions.