ML20155J991
| ML20155J991 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 06/16/1988 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Sylvia B DETROIT EDISON CO. |
| Shared Package | |
| ML20155J994 | List: |
| References | |
| EA-88-104, NUDOCS 8806210081 | |
| Download: ML20155J991 (4) | |
See also: IR 05000341/1987048
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JUN i 61988
Docket No. 50-341
License No. NPF-43
EA 88-104
The Detroit Edison Company
ATTN:
B. Ralph Sylvia
Group Vice President
Nuclear Operations-
6400 North Dixie Highway
Newport, Michigan 48166
Gentlemen:
SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL
PENALTIES (NRC INSPECTION REPORTS NO. 50-341/87048(DRP)
AND NO. 50-341/88014(DRP))
This refers to the special inspections conducted on October 18, 1987 to
March 31, 1988, and January 17 to April 28, 1988, at the Enrico Fermi Atomic
Power Plant, Unit 2, authort:ed to operate under NRC Operating License
No NPF-43. These inspections examined the circumstances surrounding a
Primary Containment Radiation Monitoring (PCRM) system containment isolation
valve design control problem and an inoperable Noninterruptible Air System
Control Air Compressor (NIAS CAC).
The potential loss of primary containment
integrity, due to PCRM system isolation valves failing to meet 10 CFR Part 50,
Appendix A General Design Criterion (GDC) 56, was identified by you and.
reported on October 17, 1987. The failure to enter Technical Specification
action statements due to inoperability of a Standby Gas Treatment subsystem,
a Control Room Emergency Filtration System flowpath damper and a Main Steam
Isolation Valve Leakage Control subsystem which was caused by the ou'. of
service Division II NIAS CAC wat identified by the NRC. The details are
contained in the subject inspection reports which were sent to you by letters
dated May 9, 1988 and May 13, 1988, respectively.
On April 28, 1988, an
enforcement conference was held between Dr. C. J. Paperiello and other members
of my staff and you and other members of your staff during which the violations,
the root causes, and your corrective actions were discussed.
CERTIFIED MAIL
RETURN RECETPT REQUESTED
8806210081 880616
ADOCK 05000341
Q
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The Detroit Edison Company
2
The design control violation, which is described as Part A of the enclosed
Notice of Violation and Proposed Imposition of Civil Penalties (Nr+1ce),
resulted from a failure to determine that the 1984 modification to the
containment isolation valve design was not an acceptable alternative to
In addition, when the modification was made, you failed to request
a change to Technical Specifications to include the automatic isolation valves
and procedures were not put in place to periodically test these valves in
accordance with the applicable portions of 10 CFR Part 50, Appendix J and
other testing requirements (logic testing, functional testing, and positive
indicator checks). A temporary exemption from GDC 56 was granted by the NRC
o.
November 13, 1987, to be effective through the end of the local leak rate
outage in March 1988.
To support operation with this exemption, you committed
to upgrade the effectiveness of the isolation scheme to include treating the
subject valves as primary containment isolation valves in a manner consistent
with Technical Specifications, revising the Emergency Operating Procedures and
enhancing operator training.
On March 29, 1988, the NRC staff approved an
amendment to the Fermi 2 operating license which accepted your permenant
redesign of the containment isolation configuration as an acceptable
alternative to those specified by GDC 56.
The Technical Specification action statement violations, which are described
in Part B of the enclosed Notice, resulted from the failure to recognize
that the operation of the Division II NIAS CAC was required to support the
operability of a Standby Gas Treatment subsystem, Control Room Emergency
Filtration System damper and Main Steam 1 solation Valve Leakage control
subsystem.
This failure led to exceeding, by approximately thirteen days,
two Technical Specification action statements that required the unit to be
shut down.
Specifically, the action statements for the Standby Gas Treatment
and Control Room Emergency Filtration Technical Specification required the
unit to be placed in COLD SHUTDOWN within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> following the end of the
allowed seven days of inoperability specified in the action statements.
In
this case, however, that seven day period ended at 10:15 p.m. on January 21,
198S, and notwithstanding the fact that the affected systems remained
inoperable, the unit continued to operate in violation of the Technical
Specifications until February 3, 1988.
Your engineering staff did not provide
adequate guidance on the system interfaces to other departments and your
operations staff was not sufficiently inquisitive to identify these violations
when the Division II NIAS CAC was taken out of service.
These violations are
another example of the Fermi organization failing to fully appreciate its
Technical Specification requirements.
The violations described in the Notice
resulted in significant degradations in the plant's ability to respond to
certain types of accidents.
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The Detroit Edison Company
3
JUN 161989
To emphasize the importance of proper system design in accordance with
regulatory requirements and the need to understand the affects of auxiliary
equipment on system operability and your Technical Specifications, I have been
authorized, af ter consultation with the Director, Office of Enforcement, and
the Deputy Executive Director for Regional Operations, to issue the enclosed
Notice in the amount of Two Hundred Thousand Dollars ($200,000) for the
violations described in the enclosed Notice.
In accordance with the "General
Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2,
Appendix C (1988) (Enforcement Policy), the violations described in Parts A
and B of the enclosed Notice have separately been categorized at Severity
Level III. The base value of a civil penalty for a Severity Level III
violation is $50,000.
The escalation and mitigation factors in the
Enforcement Policy were considered.
The base civil penalty amount for the
violation in Part A has been increased 50% because of the minimal corrective
actions that were taken initially which necessitated NRC intervention and
by an additional 50% because of your poor past performance in the area of
engineering and technical support which included a previous civil penalty
(EA 87-232) for failures in this area. Mitigation of the civil penalty for
identification and reporting was considered but deemed inappropriate because
of your failure to fully recognize the scope of the problem at the time the
initial modification was made. The base civil penalty amount has been
increased by 100 percent for the violation in Part B because of your poor
past performance in handling out of service equipment, which was discuseed
in the Plant Operations section of the most recent Systematic Assessement of
Licensee Performance, as well as for the inadequate engineering and technical
support mentioned abova, which in this case allowed plant operations personnel
to operate the plant in a degraded conditon.
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's "Rules of Practice," 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.
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The Detroit Edison Company
4
JUN 161988
The responses directed by this letter and the enclosed Notice are not subject
to the clearance procedures of the Office of Management and Budget, as required
by the Paperwork Reduction Act of 1980, Pub.
L., No.96-511.
Sincerely,
Original cigned by
L. Eert Davia
A. Bert Davis
Regional Administrator
Enclosures:
1.
Proposed Imposition of
Civil Penalties
2.
Inspection Reports
No. 50-341/87048(CRP);
No. 50-341/88014(DRP)
cc w/ enclosures:
Patricia Anthony, Licensing
P. A. Marquardt, Corporate
Legal Department
DCD/DCB (RIDS)
Licensing Fee Management Branch
Resident Inspector, RIII
Project Manager, NRR
Ronald Callen, Michigan
Public Service Commission
Harry H. Voight, Esq.
Michigan Department of
Public Health
Monroe County Office of
Civil Preparedness
SECY
CA
OGPA
J. M. Taylor, DEDRO
J. Lieberman, OE
L. Chandler, OGC
T. Murley, NRR
RAO:RIII
PAO:RIII
SLO:RIII
M. Stahulak, RIII
Enforcement Coordinators
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