ML17199G544
| ML17199G544 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 04/24/1987 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Oconnor J COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML17199G551 | List: |
| References | |
| EA-87-049, EA-87-49, NUDOCS 8704290022 | |
| Download: ML17199G544 (2) | |
Text
- . ;
Docket Nos. 50-237; 50-249 Licenses Nos. DPR-19; DPR-25 EA 87-49 Commonwealth Edison Company ATTN:
Mr. James J. 0 1Connor President Post Office Box 767 Chicago, IL 60690-0767 Gentlemen:
APR 2-4 1987
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT NOS. 50-237/87011(DRP) and NO. 50-249/87010(DRP))
- bfo
\\ f:\\~~
fl This refers to the NRC inspection conducted on February 28 - March 4, 1987, of activities authorized by NRC Operating Licenses No. DPR-19 and No. DPR-25 and the circumstances associated with Unit 3 exceeding a reactor water temperature technical specification limit of 212°F without having primary containment.
The event, which resulted in a violation of NRC regulatory requirements, was identified by your plant staff and reported to the NRC.
The details are provided in the subject inspection report which was sent to you by letter dated March 20, 1987.
An enforcement conference is usually held with licensee management to discuss significant violations.
In this instance, a management meeting had already been held on March 4, 1987 to discuss this event as well as other issues at Dresden and Mr. D. Farrar of your staff agreed that an enforcement conference was unnecessary.
This understanding and additional information related to the event were described in the letter to the NRC dated March 31, 1987.
The violation described in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) occurred when licensed operators failed to monitor the reactor water temperature for more than four hours.
During that period, reactor water temperature rose from 170°F and exceeded the 212°F technical specification limit for approximately 50 minutes, reached 223°F, and containment was not isolated as required by plant technical specifications.
Although there were at least three correct reactor water temperature indicators in the control room, four licensed operators or senior operators failed to observe any of these indicators.
Two principle factors contributed to this event:
- 1) your plant management and operators allowed multiple activities to distract control room personnel from monitoring important plant parameters and 2) your procedures did not adequately address how to establish, maintain, and monitor a plant cooldown.
These extraneous activities included back-shift telephone operator activities, 870*4290022 870424 PDR ADOCK 05000237 Q
Commonwealth Edison Company 2
APR 2 4 1987 numerous requests for high radiation area access, excessive surveillance and outage workload, and shift management meetings away from the control room.
Although we are concerned that licensed operators did not fully satisfy their responsibility for ensuring that the plant is operating safely, the NRC is equally concerned that the management system at Dresden permitted work activities to be conducted without adequate controls. This violation indicates the need for increased management attention to ensure that all control room personnel perform acceptably in an environment where they are aware of the operational status of plant equipment at all times.
To emphasize the importance of licensed operators fulfilling their responsibi-lities and continuous and effective management control to ensure that plant personnel are provided with an environment free from distractions, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Regional Operations, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Twenty-Five Thousand Dollars ($25,000) for the violation described in the enclosed Notice.
In accordance with the 11General Statement of Policy and Procedure for NRC Enforcement Actions, 11 10 CFR Part 2, Appendix C (1987) (Enforcement Policy),
the violation described in the enclosed Notice has been categorized at a Severity Level III.
The base value of a civil penalty for a Severity Level III violation is $50,000.
The NRC Enforcement Policy allows for reduction of a civil penalty under certain circumstances.
In this case, the base civil penalty has been reduced by 50 percent because of your unusually prompt and extensive corrective actions.
These actions included: (1) disciplining individuals directly involved in the event, (2) revising plant cooldown procedures, (3) relieving licensed operators from distracting work activities not related to their primary function, and (4) implementing an Error Free Operation Program.
Further mitigation was not applied because, although you promptly reported the event after it was discovered, numerous opportunities existed during the four-hour period for detecting the increasing reactor water temperature and therefore we have concluded that identification of the problem was not prompt.
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 actions you plan to prevent recurrence.
After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
In accordance with Section 2.790 of the NRC 1s 11 Rules of Practice, 11 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.