ML20138L830
| ML20138L830 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 12/13/1985 |
| From: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20138L823 | List: |
| References | |
| EA-85-107, NUDOCS 8512200061 | |
| Download: ML20138L830 (9) | |
Text
e 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 EA 85-107 As a result of the inquiry conducted by the NRC Team in response to the loss of main anc auxiliary feedwater event that occurred on June 9,1985, and as a result of the inspections conducted during the period March 26 - September 9, 1985 by the Region III staff, violations of NRC requirements were identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the NRC proposes to impose civil penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as amended, ("Act"), 42 U.S.C. 2282, PL 96-295, and 10 CFR 2.205. The particular violations and associated civil penalties are set forth below:
I.
1C CFR Part 50, Appendix B, Criterion III, " Design Control," requires that design control measures provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of 4
alternate or simplified calculation methods, or by the performance of a suitable testing program.
A.
Contrary to the above, design control measures to verify or check design specifications established in 1983 for the setting of Limitorque motor-operated valve torque switch bypass settings were not adequate to assure the proper operation of valves AF599, AF608 and MS106 when called upon to perform their safety function.
The design control measures failed to identify that the specifications for the torque switch bypass switch settings were improper. Since these measures were inadequate, and since the licensee did not perform suitable testing to assure the valves would perform properly under all service conditions, these valves failed to operate properly on June 9,1985 when called upon to perform their intended safety function.
B.
Contrary to the above, as of June 9,1985 design control measures had failed to reveal design deficiencies (build-up of condensation) associated with the crossover steam piping and with steam supplied from the main steam system, and thus the auxiliary feedwater pump turbines would not function as required to mitigate the design basis accident described in the Updated Safety Analysis Report in Section 15.4.4, " Steam Line Break."
In addition, as of June 9, 1985 the licensee had not performed testing to assure the auxiliary feedwater pump turbines would perform under all predicted service conditions. At a result, on June 9, 1985, both auxiliary feedwater pump turbines tripped on overspeed, thus rendering the auxiliary feedwater system inoperable when called upon to perform its intended safety function.
II.
A.
10 CFR Part 50, Appendix B, Criterion XI, " Test Control" requires that the test program include, as appropriate, proof tests prior to installation, preoperational tests, and operational tests during nuclear power plant 851220006185121g e-PDR ADOCK 050 O
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operation of structures, systems and components.
In addition, 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings" requires that the testing procedures be appropriate to the circumstances.
Contrary to the above, as of June 9,1985, Test Procedure 273.01,
" Auxiliary Feedwater System Preoperational Test," Revision 1, dated November 18, 1976 and Surveillance Test 5071.02 " Auxiliary Feedwater System Refueling Test," Revision 11, dated May 16, 1985, were not appropriate to the circumstances in that they failed to assure that valves AF 599 and AF 608 would satisfactorily perform under potential service conditions. As a result, preoperational testing performed in accordance with Test Procedure 273.01 did not identify the inability of valves AF 599 and AF 608 to function at the design differential pressure. Surveillance testing performed in accordance with Surveillance Test 5071.02 did not identify the improperly set torque switch bypasses for valves AF 599, AF 608, and MS 106. Surveillance testing also did not identify the unbalanced torque switch for valve MS 106.
B.
10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and that the activities be accomplished 4
in accordance with these instructions, procedures, or drawings.
1.
Contrary to the above, Steps 7.3.1 and 7.3.2 of Maintenance Procedure 1410.32, " Removal and Repair of Limitorque Valve Controls,"
Revision 2, dated June 4, 1982, were not appropriate to the circumstances in that the instructions for setting the torque switch bypass switch were inadequate. As a result, as of June 9, 1985, the torque switch bypass switches for valves AF 599, AF 608 and MS 106 were not set to the design values.
2.
Contrary to the above, during a wiring check for the control power fuses for valve MS-106 by the licensee after the June 9,1985 event, a 15 amp fuse was found installed rather than a 10 amp fuse as required by Drawing E46B, Sheets 54A and 548, Revision 3.
3.
Contrary to the above, activities affectino quality had not been accomplished in accordance with Administrative Procedure 1844.00,
" Maintenance," Revision 13, dated November 28, 1984 Section 5.3.1,
" Skill of the Craft" in that the procedure requires activities such as the installation of locknuts to be performed with the " skill of the craft." However, troubleshooting performed by the licensee after the June 9,1985 event revealed that the spring pack locknut on valve AF 599 was installed backwards and was screwed in too tightly, compressing the spring pack assembly.
In addition, the locknut on valve MS 106 was not installed flush with the spring pack of the torque switch causing the valve to go closed with a r-
torque less than that specified by design. These improper installations did not satisfy the skill of the craft requirements of Administrative Procedure 1844.00.
C.
10 CFR Part 50, Appendix B, Criterion XI, " Test Control," requires that 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 procedures which incorporate the requirements and acceptance limits contained in applicable design documents.
Section XI of the ASME Boiler and Pressure Vessel Code (ASME Code) established an inservice test program to maintain a plant in a safe and expeditious manner. Table IWV-3700-1 of this Section requires that active valves be exercised quarterly.
The Table further requires that if such exercising is impractical during plant operation, then the valves should be exercised at cold shutdown. The Table does not require exercising of passive valves.
Contrary to the above, as of June 9, 1985, the licensee's test program had improperly designated valves AF 599 and AF 608 as passive instead of -
active as defined in Section XI, Article IWV-2100 of the ASME Code in that these valves are required to change position when actuated by the Steam and Feedwater Rupture Control System. Therefore, the valves were not exercised at the required frequency.
D.
10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action,"
requires that measures be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures must assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above, the licensee failed to determine the cause of the conditions and take adequate corrective action to preclude repetition of the following significant conditions adverse to quality:
1.
Valve AF 599 failed to open from the control room en March 3, 1984 during plant recovery following a reactor trip. The licensee's corrective action with regard to the failure of this valve was not adequate to preclude repetition of the failure in that the licensee did not identify the improper torque switch and torque switch bypass switch settings.
The determination of the cause of the failure and adequate corrective action could have prevented the later failure of valves AF 599 and AF 608 on June 9, 1985.
s F
2.
Source Range Monitor NI-2 failed to -indicate proper neutron level on March 25 and April 13, 1985. The cause of the conditions adverse to quality were not determined and adequate corrective actions were not taken.
3.
Spiking and erroneous count rates were experienced from January 1, 1985 through June 9, 1985 on Source Range Monitor NI-1.
Five maintenance work orders were initiated to correct these problems.
In each instance, the Technical Specification surveillance test was performed and the channel was declared operable, and the causes of the conditions adverse to quality were not determined.
4.
Steam and Feedwater Rupture Control System (SFRCS) half channel actuation trips were received on April 24, 1985 and June 2, 1985. The cause of these conditions adverse to quality was not determined and adequate corrective actions were not taken.
E.
10 CFR 50.55a(h) Protection Systems, requires that for construction permits issued after January 1,1971, protection systems must meet the requirements set forth in editions or revisions of the Institute of Electrical and Electronics Engineers Standard, " Criteria for Protection Systems for Nuclear-Power Generating Stations," (IEEE-279). The Licensee's Updated Safety Analysis Report (USAR), Chapter 7, Section
--7.4.2.3.1, " Compliance with IEEE Standard 279-1971," discusses adherence to Section 4 of IEEE-279 and in Paragraph (4.2) requires that no single failure prevent the Steam and Feedwater Rupture Control System (SFRCS) from performing its protective function.
Contrary to the above, as of June 9,1985, single failure of an auxiliary feedwater containment isolation valve to reopen in response to an SFRCS actuation signal following a main steam line break accident which initially.depressurizes both steam generators below the SFRCS setpoint as shown in the licensee's USAR Chapter 15, Figure 15.4.3, would prevent either auxiliary feedwater train from feeding the unaffected steam generator.
F.
10 CFR Part 50, Appendix B, Criterion II, " Quality Assurance Program" requires that the program provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.
Contrary to the above, as of June 9,1985 the training provided auxiliary operators on resetting the overspeed trip mechanism associated with the auxiliary feedwater pump turbines was not adequate to assure that suitable proficiency was achieved and maintained in that the operators had not been trained to reset the overspeed trip device for the auxiliary feedwater pump turbine under operating conditions.
Collectively, the above violations in Items I and II have been categorized as a Severity Level I problem (Supplement I).
Cumulative Civil Penalty - $800,000 assessed equally between the eight violations.
e 9
III.A.
Technical Specification 3.3.3.6, Post Accident Instrumentation, Table 3.3-10, Item 25 requires two auxiliary feedwater flow rate instruments to be in service per steam generator.
The action statement associated with the Limiting Condition for Operation requires that with the number of operable post-accident monitoring channels less than required by Table 3.3-10, either restore the inoperable channel to operable status within 30 days, or be in hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
i trary to the above, on June 3,1985, the licensee identified that one of the two auxiliary feedwater flow rate instruments, FI 4521, was improperly wired and thus inoperable since April 1, 1985.
During the period from April 13 - June 2, 1985, the Unit was in a mode requiring the instruments to be operable and the Limiting Condition for Operation was exceeaed.
B.
10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," requires that activities affecting quality be prescribed by documented instructions or procedures of a type appropriate to the circumstances and be accomplished in accordance with these instructions or procedures.
1.
Contrary to the above, an activity affecting quality was not accomplished in accordance with the administrative procedure established for control of jumpers and lifted wires. On March 26, 1985, an instrument and control technician removed Flow Rate Instrument (FI) 4521 from the control room to repair the indicator and did not tag the disconnected electrical lead as required by Administrative Procedure 1823.00, " Jumper and Lifted Wire Control Procedure," Revision 12, dated October 2, 1984. As a result, FI 4521 was reinstalled incorrectly.
2.
Contrary to the above, the written instruction " Maintenance Work Order MWO-1-85-1149-01" was inadequate. As a result, the post-maintenance testing performed on April 1,1985 did not detect that FI 4521 was not receiving the required signal from the auxiliary feedwater flow rate transnitter. As a result, FI 4521 was inoperable until discovered by the licensee on June 2, 1985.
Collectively the violations in Item III have been categorized as a Severity Level III problem (Supplement I).
Cumulative Civil Penalty - $50,000 assessed equally between the violations.
IV.
A.
1.
10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings" requires that activities affecting quality be prescribed by documented instructions or procedures of a type appropriate to the circumstances and be accomplished in accordance with these instructions or procedures.
In addition, Criterion X,
" Inspection," requires that a program for inspection of activities affecting quality be executed by or for the organization performing r-
l.
the activity to verify conformance with the documented drawings for accomplishing the activity. Bechtel Procedure PDP-2,
" Inspection Procedure for As-Built Configuration of Nuclear Safety-Related Piping Components IE Bulletin 79-14," Revision 4, dated May 3,1980, implemented the actions set forth in IE Bulletin 79-14 for verifying that piping as-built conditions meet design analysis requirements.
Contrary to the above, as of May 31, 1985, twelve r'.pe supports installed on the Auxiliary Feedwater Pump Turbine Steam Supply system were not installed in conformance with design drawings, notwithstanding inspections performed in 1980 to Procedure PDP-2.
In addition, these inspections discovered that the Quality Control Program in place as early as 1976 during plant construction did not provide verification of pipe support location, configuration, and orientation to assure installation was in accordance with design.
4 2.
10 CFR Part 50, Appendix B, Criterion XV, " Nonconforming 1
Materials, Parts, or Components," requires measuius be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation.
i The Toledo Edison Nuclear Quality Assurance Manual, Sections 15.0 and 15.1.3 which implement Criterion XV of 10 CFR 50, Appendix B, require that nonconformances be documented on nonconformance reports to prevent their 16sdvertent use.
Contrary to the above, in March 1985, Toleao Edison Company 1-Facility Engineering Department personnel used controlled sketches to document damaged Auxiliary Feedwater Pump Turbine Steam Supply hangers rather than nonconformance reports as required and, as a result, failed to prevent their inadvertent use or installation.
1 3.
10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action,"
requires that measures be established to assure that conditions adverse to quality such as deficiencies, deviations, defective material and equipment, and nonconformances, are promptly identified and corrected.
In the case of a significant condition adverse to quality, the measures must assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above, during March and April 1985, when substantial defects were identified in the Auxiliary Feedwater Pump Turbine Steam Supply pipe hangers by the licensee's site j
staff, the licensee failed to adequately assess individual and t
collective hanger failures to assure adequate evaluation of the root cause of the problem and to ensure that systems were operable in accordance with Technical Specification requirements.
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i B.
10 CFR 50.73 (a)(1),(2)(ii)(4), and (2)(ii)(B) require the licensee to submit a Licensee Event Report (LER) within 30 days after discovery i
of a condition that resulted in the nuclear plant being seriously j
degraded, or that resulted in the nuclear power plant being in an i
i unanalyzed condition that significantly compromised plant safety, or in a condition that was outside the design basis of the plant.
i Contrary to the above, the total extent of degradation of piping suspension systems installed on the Auxiliary Feedwater Pump Turbine j
Steam Supply piping and on the Auxiliary Feedwater Pump Discharge piping that resulted.in a condition that was outside the design basis i
of the plant and that was known to the licensee by March 31, 1985 was not reported to the NRC within 30 days as required, i
Collectively the violations in Item IV have been categorized as a Severity Level III problem (Supplement I).
Cumulative Civil Penalty - $50,000 assessed equally between 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, D.C. 20555 and a copy to the Regional Administrator, U.S. Nuclear Regulatory Connission, Region III, 799 Roosevelt Road, Glen Ellyn, IL 60137, within 30 days of the date of this Notics 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 ccmpliance will be achieved.
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.
Within the same time as provided for the response required above under 10 CFR 2.201, Toledo Edison Company may pay the civil penalties in the cumulative amount of Nine Hundred Thousand Dollars ($900,000) or may protest imposition of the civil penalties 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 penalties above. Should Toledo Edison Company elect to file an answer in accordance with 4
10 CFR 2.205 protesting the civil penalties such answer may:
(1) deny the violations listed in this 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 penalties, in whole or in part, such answer may request remission or mitigation of the i
penalties.
In requesting mitigation of the proposed penalties, the five factors contained in Section V.B of 10 CFR Part 2, Appendix C (1985) 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 j
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.
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Upon failure to pay any civil penalty due, which has been subsequently determined 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
,6 '
9 or
,s, J
s M. Tay Director
,, Office of Inspection and Enforcement V"
Dated at Bethesda, Maryland this /30 day of December 1985.
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Toledo Edison Company Distribution Resident Inspector, RIII Harold W. Kohn, Ohio EPA James W. Harris, State of Ohio Robert H. Quillin, Ohio Department of Health PDR LPDR SECY ACRS CA JMTaylor, IE RVollmer, IE JGKeppler, RIII JAxelrad, IE ABBeach, IE JLieberman, ELD VStello, DED/ROGR Enforcement Coordinators RI, RII, RIII, RIV, RV HDenton, NRR EJordan, IE JPartlow, IE BGrimes, IE BHayes, 01 SConnelly, 0IA JCrooks, AE0D EA File ES File ED0 Rdg File DCS
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