ML20133B796
Text
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y JUN 18 G85 MEMORANDUM FOR:
Jane A. Axelrad, Director, Enforcement Staff, IE -
FROM:
William H. Schultz, Enforcement Coordinator, Region III
SUBJECT:
TOLEDO EDISON COMPANY - DAVIS-BESSE PROPOSED CIVIL PENALTIES The enclosed documents propose civil penalty action under the General Policy and Procedure for NRC Enforcement Actions and are submitted for your review and concurrence.
As was the case with the previous Davis-Besse civil penalty action (EA 84-95, November 21, 1984) we are concerned primarily with a serious lack of communication between si+9 and corporate management as well as between senior corporate managers.
We believe 100% escalation of the base civil penalty is warranted because of the licensee's poor past performance in the area of management control systems (75%) and on the narrow focus of corrective action (25%).
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...... ; -a W. H. Schultz
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Enforcement Coordinator Region III
Enclosures:
1.
Draft letter to licensee w/ Notice of Violation and Proposed Imposition of Civil Penalties 2.
Draft Inspection Report No. 50-346/85018(DRP) cc w/ enclosures:
J. Lieberman, ELD Regional Enforcement Coordinators, RI, RII,RIV, and RI 8510D70115 BSD717 PDR CCPW13 NRCC CORRESPONDENCE PDR RIII RQ RIII RLII RIII toes as-Be@{)] son g4 NMIfus/kja Schultz Da7s K ' pipr 1
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Docket No. 50-346 EA 85-Toledo Edison Company ATTN:
Mr. John P. Williamson Chairman and Chief Executive Officer Edison Plaza 300 Madison Avenue Toledo, OH 43652 Gentlemen:
This refers to the safety inspection conducted by Messrs. W. Rogers, D. Kosloff, and M. Ring of the Region III staff during the period April 9 through May 31, 1985 of activities at the Davis-Besse Nuclear Power Station authorized by
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Operating License No. NPF-3.
The results of the inspection were discussed on May 24, 1985 during an Enforcement Conference held in the Region III office between Mr. R. P. Crouse and others of your staff and me and others of the NRC staff.
The following violations were identified during the inspection.
On April 9, 1985 the security-fire / radiation computer was taken out of service and the shift supervisor was not notified at the time the computer was actually shut down.
The shift supervisor did not learn of the computer shutdown until he was informed about two hours after the shutdown that the computer was being l
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returned to service.
This violation resulted from a failure to effectively implement a program in which the operating status of equipment was to be made known to cognizant plant personnel at all times.
As a result, when the computer was shut down the shift supervisor was unable to take timely compensa-tory measures.
We are aware that additional compensatory measures were not necessary because measures had already been taken in response to other problems related to fire protection.
However, the pre-existing compensatory measures do not mitigate the inadequate communications between the security and operations personnel.
On April 19 and 20, 1985 Davis-Besse recorded a reactor coolant flow rate approximately 2% low; however, the thermal power was not limited as required.
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Licensee personnel failed to appreciate that a valved-out component continued to provide input to the computer.
On April 24, 1985 a non-licensed operator who had been assigned to monitor the Startup Feedwater Pump / Turbine Plant Cooling Water piping status in the Auxiliary Feedwater Pump room was found by an NRC inspector to be asleep and therefore was not capable of performing his intended safety function.
We were advised during the enforcement conference that site management failed to advise corporate management of the sleeping individual.
In fact, corporate management first learned of the violation several days later when informed by NRC.
These three violations when considered individually are not a cause for signifi-l cant safety concerns.
However, we note that Davis-Besse continues to have l
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Toledo Edison Company 3
problems that should be avoided by an effective and comprehensive corrective action program developed in response to previously expressed NRC concerns and by the adequate implementation of such a program.
NRC believes a root cause of your poor performance in this regard is that Davis-Besse management has not had effective communication and has not developed adequate control systems to ensure that problems are identified, root causes are found, and generic corrective actions are taken.
These failures cause us to question Toledo Edison management's ability to provide proper oversight of plant activities and adequate management direction.
NRC believes that senior management must provide timely and effective means of knowing when either a significant problem exists at their plant or when multiple less significant problems, which are indications of weaknesses in plant operations, exist at the plant.
To emphasize the need for you to correct these deficiencies and to ensure that adequate corrective actions will be taken to preclude repetition of them, 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 Penalties in the cumulative amount of One Hundred Thousand Dollars
($100,000) for these violations.
The serious lack of management control and communication at all levels together with the three violations led us to cate-gorize this as a Severity Level III problem in accordance with the General Policy and Procedure for NRC Enforcement Actions, 10 CFR Part 2, Appendix C, as revised, 49 GR 8583 (March 8, 1984).
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Toledo Edison Company 4
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The base civil penalty for a Severity Level III problem is $50,000.
- However, the base amount has been increased by 100% because of prior similar problems (A $20,000 Proposed Imposition of Civil Penalties was issued on November 21, 1984) and because your corrective actions were focused narrowly on the specific violations rather than broadly on the general area of concern.
You are required to respond to the enclosed Notice and you should follow the instructions specified therein when preparing your response.
Your response should specifically address the corrective actions you will take to increase management involvement and oversight and to reduce personnel errors.
Your reply to this letter and the results of future inspections will be considered in determining whether further enforcement action is warranted.
In accordance with 10 CFR 2.790, " Rules of Practice," a copy of this letter and the enclosure will be placed in the NRC Public Document Room.
4 The responses directed by this letter and the accompanying Notice are not subject to the clearance procedure of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Sincerely, James G. Keppler Regional Administrator
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES Toledo Edison Company Docket No. 50-346 Davis-Besse Nuclear Power Station License No. NPF-3 An inspection conducted during the period April 9 through May 31, 1985 identified three violations of NRC requirements.
These violations are (1) to failure to follow a procedure that required responsible individuals to be notified at the time the security and fire protection computer was shutdown,
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(2) failure to limit thermal power as required when the reactor coolant flow rate decreased, and (3) failure of a non-licensed operator to monitor piping status in the Auxiliary Feedwater Pump area because he was sleeping.
These violations are examples of a substantial breakdown in management control systems at the Davis-Besse facility and demonstrate the licensee's continuing failure to ensure adequate control over plant equipment.
In particular, these violations and the licensee's corrective actions discussed during the enforce-ment conference reveal a significant inability of the licensee to ensure that the status of plant equipment is communicated to an understood by cognizant irjividuals, that violations, once they are recognized by plant personnel,
2 receive appropriate attention by senior site and corporate management; and that proposed corrective actions are likely to address the root cause of the underlying problems.
This problem is especially significant because similar management control problems were identified previously and resulted in the issuance of a Notice of Violation and Proposed Imposition of Civil Penalties in November 1984.
To emphasize the need for the licensee to focus broadly on the general areas of concern that resulted in these violations, improve the control of licensed activities, and overcome the serious lack of communication between site and corporate management as well as between senior corporate management personnel, the NRC proposes to impose civil penalties in the cumulative amount of $100,000.
In accordance with the General Policy and Procedure for NRC Enforcement Actions, 10 CFR Part 2, Appendix C, and the Policy as revised, 49 FR 8583 (March 8, 1984) 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 penalties are set forth below.
A.
10 CFR 50, Appendix B, Criterion XIV, " Inspection, Test, and Operating Status," states that measures shall be established for indicating the operating status of structures, systems, and components of the nuclear power plant.
3 The Toledo Edison Nuclear Quality Assurance Manual (NQAM) section 14.0 states that the plant manager is responsible for establishing.and maintaining a program in which the operating status of equipment is known at all times.
Section 14.1.1.1 states that permission to release equipment or systems for maintenance or test is granted by the Shift Supervisor and that granting of such permission shall be documented.
Contrary to the above, the licensee did not implement a program in which the operating status of equipment is known at all times in that on April 9, 1985 the shift supervisor was not informed that the security-fire /
radiation computer was taken out of service.
B.
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% flow is outside its 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 (nine hours) thermal power was approximately 98%.
This exceeded the thermal power limit.
4 C.
Amendment No. 83 of Facility Operating License No. NPF-3 adds paragraph 2.C(3)(t) '.hich states that 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 operation of the SUFP, the NRC inspector observed that a non-licensed operator who had been assigned to monitor the SUFP/ Turbine Plant Cooling Water (TPCW) piping status in the AFW Pump room was asleep and, therefore, failed to perform the required monitoring.
Collectively, the above three violations have bere avaluated 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
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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 reouired above under 10 CFR 2.201, Toledo Edison Company may pay the Cfvil Penalties in the amount of $100,000 or may protest imposition of the Civil Penalties in whole or in part, by a written answer.
Should Tolede Edison Company fail to answer within the time specified, ti.e Director, Office of Inspection and Enforcement will issue an order imposing the Civil Penalties proposed above.
Should Toledo Edison Company elect to file an answer in accordance with 10 CFR 2.205 protesting the Civil Penalties 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 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 penalty.
In requesting mitigation of the proposed penalties, 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
6 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 at 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 James G. Keppler Regional Administrator Dated at Glen Ellyn, Illinois this day of June, 1985
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JUN 171985 Docket 50-346
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Toledo Edison Company ATTN:
Mr. Richard P. Crouse i
Vice President Nuclear Edison Plaza 300 Madison Avenue Toledo, OH 43652 Gentlemen:
This refers to the special inspection conducted by Messrs. W. Rogers, D. Kosloff and M. Ring of the Region III staff during the period April 9 through May 31, 1985, of activities at the Davis-Besse Nuclear Power Station authorized by Operating License No. NPF-3.
The results of the inspection were discussed on May 24, 1985, during an Enforcement Conference held in the Region III office between you and others of your staff and Mr. J. G. Keppler and other members of the NRC staff.
The inspection report identifies areas examined during the inspection.
Within these areas, the inspection consisted of a selective examination of procedures s'"i representative records, observations, and interviews with personnel.
We are releasing this report at this time for your information.
You will be notified by separate correspondence of our decision regarding enforcement action based on the findings of this inspection.
No written response is required until you are notified of the proposed enforcement action.
In accordance with 10 CFR 2.790, " Rules of Practice," a copy of this letter and the enclosure will be placed in the NRC Public Document Room.
We will gladly discuss any questions you have concerning this inspection.
Sincerely,
" Original signed by C.E. Morelius' C. E. Norelius, Director Division of Reactor Projects
Enclosure:
Inspection Report No. 50-346/85018(DRP) cc w/ enclosure:
S. Quennoz, Plant Manager Harold W. Kohn, Ohio EPA James W. Harris, State of Ohio Robert H. Quillin, Ohio Department of Health RIII RIII RIlh RIII I
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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 M T eu.L Approved By:
M. Jackiw, Chief 4 [13 /8 i
' Projects Section 28 Date Inspection Summary Inspection on April 9 through May 31, 1985 (Recort No. 50-346/85018(DRP))
Areas Inspected:
Special inspection of the circumstances surrounding three events:
removal of the security and fire protection computer from service without the shift supervisor being informed; exceeding the thermal power for the reactor coolant flow available and having one channel 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).
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3 DETAILS 1.
Persons Contacted T. Murray, Assistant Vice President, Nuclear Mission
- 5. 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, Reg 1on 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 i
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
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detectors being out of service.
The licensee further stated that the t
security supervisor has been designated as the individual to-inform the shif t 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.
Startup Feedwater Pumo Piping 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 standby and the SUFP was in operation.
Paragraph 2.C.(3)(t) of the facility's operating license requiresthatthelicenseestationanind{vidualintheSUFP/AFWParea 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
room to trip the SUFP, and isolate the 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 and 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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TOLEDO EDISON Quality Assurance Manual November 7.1984
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arenovaa 13tSPECTION, TEST. AND OPERATING STATUS
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!&.U'Furpose This section establishes measures to indicate by the ura of markings.
such as stamps, tags labels, routing cards, or other suitable means.
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- the inspection, test and operating status of structures, systems, and f
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14.1 Operating System Status 14.1.1 The Plant Manager. Davis-Besse is responsible for establish-ing and maintaining a program in which the operating, inspec-tion.andteststatusofstructures,fystems,andcoapunents is known at all times. This program shall meet the require-seats of ANSI N18.7 as endorsed by NRC Regulatory Guide 1.33 and contain the following provisions.
14.1.1.1 Permission to release equipment or systesw for maintenance or test is granted by the Shif t Super-vi_sor. Prior to granting permission. the Shift Supervisor shall verify that the equipment or es.s system can be relamo d, and determine how long it may be out of service. Granting of such permission shall be documented. Attsation shall be given to the potentially degraded degree of protection when j
one subsystem of a redundant safety system has been j
removed for maintenance.
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POWER DISTR!8UTION LIMITS ONS PARAMETDS LIMITING CDNDITION FOR OPDATIoh 3.2.5 The ftllowing DNS related parameters shall be asinthined within the limits shoun on Table 3.2-1.
t Rasctor Coolant Not Leg'iemperature
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b.
Ranctor Coolant Pressure i
c.
ReactorCoolankFlowRata APM ! CAB LITY: W DE 1 ACTION:
If parsanter a or b above saceeds its limit, restore the partanter 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 reduce THDunL POWS to less than 55 of RATED TIERML POWS within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
i If parameter e escoeds its limit, either:
1.
Restore the parameter 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 l
2.
Limit THDUEL POWER at least 25 below RATED THERML MRfER for each 11 parameter e is outside its limit fbr four pump operation within the mest 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. er limit THERML POWS et least 25 belos 755 of RATED THUDIAL PWR for each 15 parameter c is outside its limit fbr 3 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 />.
SURVEILLANCE REQUIRDEICf5 l
l 4.2. 5.1 Each of the parameters of Table 3.2-1 shall be verified to be i
within their limits at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
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l 4.2.5.2 The Reactor Coolant system total flow rate shall be deterutned to be within its limit ty asasurement at least once per 18 months.
DRVIs-BESSE UNIT 1 3/4 2-13 Amentient No. 64 h
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LIMITS 0M Four Reactor Three Reactor r
Coolant pumps Coolant Pumps E
parameter Operating Operating 4
Reactor Coolant Not Leg
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I Temperature TH Reactor Coolant Pressure, psig.III 1.2062.7 t 2068.7UI III 2
1 97,340 Reactor Coolant Flow Rate, gpm 1 396.880 I
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f WApplicable to the loop with 2 Reactor Coolant pops Operating.
s (2) Limit not applicable during either a THERMd POWER ramp increase in excess of 55 of y
RATED THERMAL POWER pef minute or a THERMAL POWER step' increase of greater than 105 3
of RATED THERMAL POWER I%
(3IThese flows include a flow rate uncertainty of 2.51.
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NUCLEAR REGULATORY COMMISSION i
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TOLEDO EDISON COMPANY AND THE CLEVELAND ELECTRIC ILLtMINATING COWANY DOCKET NO. 50-346 DAVIS-BESSE NUCLEAR P0lER STATION, UNIT NO 1 APNOMENT TO FACILITT OPERATING L1 CENSE
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Amenhnt No.83 License Mo. WPF-3
- 1. The Nuclear Regulatory Cossatssion (the Comiission) has found that:
A. The application for asenhnt by the Toledo Edison Cowany)and the Cleveland Electric Illuminating Company (the lice *.aes dated
- r November 12,1984, complies with the standards and requirements of the Atomic Energy Act of 1954, as asended (the Act) and the
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Comeission's rules and regvlations set forth in 10 CFR Chapter I; 8.
The facility will operate in conformity with the application, the pd provisions of the Act, and the rules and re9ulations of the Comission; C.
Thereisreasonableassurance(1)thattheactivitiesauthorizedby this amendment can be conducted withaut endangering the health and safetyofthepublic,and(ii)thatsuchactivitieswillbeconducted in compliance with the Commission's regulations; D.
The issuance of this amendment will not be 16treical to the cassen defense and security or to the health and safety of the public; and l
I E. The issuance of this amen k nt is in accordance with 10 CFR Part 51 of the Counission's regulations and all applicable requirusents have been satisfied.
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- 2. Accordingly, Facility (Operating License No. NPF-3 is hereby amended by adding paragraph 2.C. 3)(t) to read as follows:
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O Toledo Edison shall operate the Startup Feedwater Pump (SUFP) Systa with '
the following operational restrictions:
1.
Toledo Edison will station an operator in the Startup Feeduster Puup/ Auxiliary Feedsater Pure (SUFP/ATV) area during operation of the SUFF to unnbr SUFP/ Turbine Plant Cooling Water (TPCW) pioino status in the AFW Pump Rooms. In the event of SUFP/TPCW pipe leakage, the operstar will trip the SU9 locally or notify the Control Room to trip the SUFP, and isolate the $UFP/TPCW piping.
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2.
Toledo Edison will isolate and mai,ntain isolation outside the $UFP/AFV area of the SUFP section, discharge, and turbine plant cooling water r
piping, when the SUFP is not in operation (Modes 1, 2 a,nd 3).
3.
Toledo Edison will install a 50FP, associated piping, and valves, to remove the hazards to the Afil pues before cessmencing Cycle 6.
3.
This license asenkt is effective as of its date of issuance.
FOR THE W CLEAR REGULATORY COPFISSION Gus C. Laines. Assistant Director
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s THE ATTACHED DOCUMENTS ARE SENSITIVE PRE-DECISIONAL ESCALATED ENFORCEMENT MATTERS UNDERGOING HEADQUARTERS REVIEW. AS SUCH, THEY ARE EXEMPT FROM PUBLIC DISCLOSURE UNDER THE FREEDOM 0F INFORMATION ACT.
WE REQUEST THAT THE SUBCCMMITTEE LIMIT REPRODUCTION AND DISSEMINATION OF THESE DOCUMENTS TO THE MAXIMUM EXTENT POSSIBLE.
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UNKNOWN DOCUMF.NT INDEX Date Unknown:
Agenda for SALP Meeting (3 pgs.')
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Date Unknown: Toledo Edison SALP Presentation (15 pgs.)
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.a PURPOSE OF MEETJf1E 1.
STAFFING PROBl_EM 2.
STATUS OF PROGRAM UPGRADING 3.
SECURITY ISSUES n
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i STAFFING 1.
IMMEDIATE CONCERN
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OPERATING SHI FTS ARE CONCERNED ABOUT SA FETY.
2.
BASES OF CONCERN A.
PAY B.
TRAINING C.
0WRTIME D.
LOSS 0 F EXPERIENCED PEOPLE E.
DELAYS IN HANDLING WORK REQ WSTS 3.
OTHER CONSIDERATIONS A.
HISTORY
- PROBLEMS FROM BEGINNING
- MANY PLANT PROBLEMS
- LONG " LEARNING CWW"
- SERIES OF MANAGEMENT MEETINGS AIMED AT IMPROVING PERFORMANCE
- MEAS WABLE PROGRESS MADE IN MANY AREAS
- STAFFING GOALS NOT ACHIEWD AND EXPERIENCED PERSONNEL LOSSES HAD INCREASED Om CONCERNS B.
B&W PLANT DESIGN (TMD C.
IMPACT O F ORDERS AND BULLETINS D.
IMPACT 0 F NmEG 0660
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STAFFING (CONT'D) 4.
NRC C0tlCLUSIONS A.
OPERATING SHI FTS MUST BE STRENGTHENED IMiEDI ATELY FOR CONTIN UED OPERATION (E.G., USE O F CONSULTANTS OR CONTRACT PERSONNEL).
B.
PROMPT STEPS MUST BE INITIATED TO STRENGTHEN ORG AN IZATION FOR LONGER TERM OPERATION (E.G., INPO).
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TOLEDO EDISON SALP PRESENTATION
- s Introduction W. A. Johnson j
il Program Overview R. P. Crouse S
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SALP Functional Areas T. D. Murray J
M Sunimary W. A. Johnson E.,
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i ELEM ENTS.-.O F A..- N.E. F F ECT. IV E P ROG R AM
- Resources
- Management Tools
- Training 1
- Management involvement l
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HISTORIC _AL COMMITMENT o investment in Nuclear Program S680 Million At Commercial Operation S900 Million At The End Of 1983
= Staffing Levels 340 January,1980 590 - January,1985 F
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I NUCl. EAR MISSION MANN!NG 1980 1985 i
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Period 4
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}l 1980 1981 1982 1983 1984 1985 d
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COMMITMENT TO RESOURCES Staffing Recruiting
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Six Operating Shif ts e S1.75 Million Laboratory And Classroom Upgrade
- S13 Million Training Simulator
- S13 Million Personnel Shop Facility ll f
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F C_OMMITMENT TO MAN _A_GEMENT TOOLS e Upgraded Goals And Objectives Program o Expanded Performance Measures e Nuclear Personnel Unit I
e Expanded Commitment Tracking
- Reorganization Of Project Management
- New Prioritization And Scheduling Process e Simplified Station Directives i
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.C_O M MIT_M_E N T TO._T R AINI N G o INPO Accreditation o MBO Training 3 QA Training o Emergency Plan Training e Operations Training Shif t t
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- Management Plant Visits 1
- Special Assignment Of Company President To Nuclear Program o Presidential Site Visits
- Monthly Presidential Strategy Meetings
- Routine Meetings With The Operations Committee Of The Board Of Directors h
- Focused Attention By President On Commitment Tracking Reports S
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1 PLANT OPERA _TIONS
= Well Qualified Operators o Reactor Trip Frequency Decreased; 1983 12,1984 4
= Significant Plant Performance Improvement e Symptom Related Emergency Procedures (ATOG)
Implemented e improved Management Directive Systems e Safety Tagging Verification Improved
- Key Staff Positions Filled
- Maintenance Work Order Review And Guidance
- Nuisance Alarms Reduced 50 Percent i
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1 f3 M AIN T.E..N A N CE o Filled Maintenance Department Head Position p
3 o Maintenance Staff Reorganization 3
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- Maintenance Staff increased 25 Percent y
e Quality Circle Program in Place e MBO Program Being implemented p
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- Procedure Review Performance Improved f
w o Computerized Maintenance Manaaement System f.i (DBMMS) 2ti e Focused Attention On Problem Areas
[fi1 e Expanded Maintenance Coverage Planned For 1985 y
,s e Maintenance Department Personnel Training I'
6ll e DBMMS Equipment Data Base Project p
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. FIRE PROTECTION Significant Resource Commitment To Fire Protection Submitted Plans To NRC For Fire Protection Regulatory Compliance Onsite Fire Protection Staff I
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- Excellent 1983 Full Scale Exc rcise
- Detailed QA Independent Audit
- External Review Of Emergency Preparedness Program e Construction Of Emergency Operations Center For Ottawa County
- Corporate Radiological Ernergency Response Plan &
Procedures e 1985 Training Schedule issued For All Emergency Response Programs (Corporate And Station) in Conjunction With Nuclear Training Department
- Major Revision To The Emergency Duty Officer Program
- Detailed Activities Scheduling System I
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QUALITY PROGRAfAS & ADMINISTRATIVE CONTROLS o Significant Upgrading And Control Of Design Drawings o E'asign Document Control Organization Established
- Auditor Staffing increased a Full Time QA instructor Added
- Expanded General Training in Quality Assurance o Area Specific QA Training
- Technical Training For OA Staff
- Expanded OA Audit Teams Supplemented By Technical Personnel
- Balance-Of-Plant Coverage By QA
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.TR AINING e Staffing Almost Doubled
- S13 Million Plant Simulator Project
- S1.75 Million Classroom And Laboratory improvements
- Minimal Use Of Contracted Instructors e increased Management Attention To Training Schedule Compliance 1985 Training Schedule Developed Jointly With Area Supervisors Basic Training Procedures Complete INPO Accreditation Program Underway I
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PLANNED _OVERSIGH_T ACT_lONS o Management Plant Visits i
o Special Assignment Of Company President To Nuclear i
Program o Presidential Site Visits o Monthly Presidential Strategy Meetings o Routine Meetings With The Operations Committee f
Of The Board Of Directors o Focused Attention By President On Comm'iment t
Tracking Reports s
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