ML20129D801
| ML20129D801 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/12/1985 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20129D766 | List: |
| References | |
| EA-85-071, EA-85-71, NUDOCS 8507160655 | |
| Download: ML20129D801 (3) | |
Text
'
s NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY 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 time the security and fire protection computer was shutdown, the failure of a non-licensed operator 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 equiptrent or systems for maintenance or test be granted by the Shift 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 from servica, without permission being granted by the Shift Supervisor.
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 g 71g g h g6 O
July 12, 1985 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 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 Specification 3.2.5.
Collectively, the above three violations have been evaluated as a Severity Level III problem (Supplement I).
(Civil Penalty - $100,000 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 fwther 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 j
the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be j
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 i
f
July 12, 1985 Edison Company elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty such answer may:
(1) deny the violation listed in the Notice, 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-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 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 cL;w%Mg k
[JamesG.Keppler Regional Administrator Dated at Glen Ellyn, Illinois this ta# day of July 1985
U. S. NUCLEAR REGULATORY COMMISSION REGION III Report No. 50-346/85018(DRP)
Docket No. 50-346 License No. NPF-3 Licensee ~:
Toledo Edison Company Edison Plaza, 300 Madison Avenue Toledo, Ohio 43652
/
Facility Name:
Davis-Besse 1 Inspection At:
Oak Harbor, OH Inspection Conducted:
April 9 through May 31, 1985 Enforcement Conference:
May 24, 1985 Inspectors:
W. Rogers D. Kosloff M. Ring
-(?k Y PtLk Approved By:
M. Jackiw, Chief 6 [13 /8 i Projects Section 2E Date Inspection Summary Inspection on April 9 through May 31, 1985 (Report No. 50-346/85018(DRP))
A eas Inspectec:
Special inspection of the c1rcumstances surrounding three events:
removal of the security and fire protection computer from service without the shif t supervisor being informed; exceeding the thermal power for the reactor coolant flow available and having one channc1 of the reactor protection system set lower than the allowable setpoint; and the discovery of a non-licensed operator asleep while implementing a condition of the license.
The inspection involved 27 inspector-hours onsite by two NRC inspectors.
Results:
Three items of noncompliance were identified (failure to notify 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 failure to properly implement a condition of the license associated with operation of the startup feedwater pump).
spD
~
37 3 s i g s (p
~
V
O DETAILS 1.
Persons Contacted.
T. Murray, Assistant Vice President, Nuclear Mission 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 Edison Personnel R. Crouse, Vice President, Nuclear Mission T. Murray, Assistant Vice President, Nuclear Mission S. Quennoz, Plant Manager R. Peters, Nuclear Licensing Manager NRC Personnel J. Keppler, Administrator, Region III C. Norelius, Director, Division of Reactor Projects W. Shafer, Chief, Projects Branch 2 I. Jackiw, Chief, Projects Section 28 W. Rogers, Senior Resident Inspector D. Kosloff, Resident Inspector M. Ring, Reactor Inspector M. McCormick-Barger, Reactor Inspector B. Berson, Legal Counsel W. Schultz, Enforcement Coordinator 2.
Inoperable Fire Protection Computer 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 Shift 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 further 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 shift supervisor revealed that although 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 shutdown.
He established 2
fire watch patrols in accordance with existing plant procedures after his independent discovery that the computer had been shutdown.
During the enforcement conference the licensee stated that the areas in question were being patrolled due to fire protection equipment other than the fire detectors being out of service.
The licensee further stated that the security supervisor has been designated as the individual to inform the shift supervisor when the computer is taken out of service.
3.
Inaccurate Reactor Power Measurements The limiting condition for operation of Technical Specification 3.2.5 requires reactor coolant flow to be equal to or greater than a specific value.
The action statement associated with this limiting condition requires 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 discussed in Inspection Report No. 85009.
During the enforcement confer-ence the licensee confirmed that for approximately twelve hours one of the four reactor power indicators was set less than actual reactor power by 2.2% during the same time period in question.
This indicator provides an input to 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 by which the reactor power indicators are calibrated and which is the operators' primary indication of reactor thermal power.
4.
Startuo Feedwater Pumo Pipino 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-licensed operator.
The plant was in hot standDy and the SUFP was in operation.
Paragraph 2.C.(3)(t) of the facility's operating license requires 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 3
I room to trip the SUFP, and isolate tne SUFP/TPCW piping.
Failure to properly monitor the SUFP/TPCW piping status is considered an item of noncompliance (346/85018-03).
Subsequently, another licensee employee entered the room and awakened the operator in the presence of the inspector.
The inspector notified the operator's supervisors of the occurrence.
The licensee took disciplinary action against the sleeping individual.
5.
Enforcement Conference An Enforcement Conference was held on May 24, 1985 in the NRC Region III office to discuss the circumstances surrounding the violations identified during the inspection that was initiated on April 9, 1985.
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 managers.
The licensee representatives admitted they did not learn of the violations in a timely manner and were not directly involved in the corrective actions that were taken.
The plant manager described corrective actions that had been taken to resolve each of the violations.
The 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.
4