ML20204F306
| ML20204F306 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 07/29/1986 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Sylvia B DETROIT EDISON CO. |
| Shared Package | |
| ML20204F313 | List: |
| References | |
| EA-86-112, NUDOCS 8608040150 | |
| Download: ML20204F306 (4) | |
See also: IR 05000701/2010015
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July 29, 1986
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Docket No. 50 341
License No. NPF-43
EA 86-112
The Detroit Edison Company
ATTN:
B. Ralph Sylvia
Group Vice President-Nuclear
6400 N. Dixie Highway
Newport, MI 48166
Gentlemen:
SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES
NRC INSPECTION REPORT NO. 50-341/85040(DRP)
This refers to the inspection conducted by the NRC during the period July 1 -
October 15, 1985, of activities authorized by NRC License No NPF-43 for
Fermi-2.
Inspection Report 50-341/85040 (DRP) identified violations of NRC
requirements and was
Some of the violations
were associated with'provided to you on January 7, 1986.
the July 1-2, 1985 roa pull error and subsequent events
and were the subject of separate correspondence.
The other results of this
inspection were discussed on July 17, 1986 during an enforcement conference
held at the Fermi-2 site between you and other members of your staff and
Mr. J. G. Keppler, Regional Administrator, and other members of the NRC staff.
Some of the incidents described in the inspection report were identified by
your personnel and reported to the NRC.
Item A of the enclosed Notice of Violation and Proposed Imposition of Civil
Penalties (Notice) involves the failure to provide a flow path during the
period July 23-29, 1985 for the Emergency Equipment Service Water (EESW) system
which is required to provide cooling water to the Division 1 emergency core
cooling systems and Division 1 emergency diesel generators. The Fermi-2
license contains a'special condition with which the licensee must comply until
its alternate shutdown capability in the event of a fire has been established.
This condition requires the removal of power from a cooling tower bypass valve
to prevent its spurious closure and interruption of the flow of the EESW.
In
this instance, a Reactor Building rounds operator who had been required to
stroke the bypass valve was not given clear instructions to leave the valve
open and he closed the valve. Although an alternate flow path would have
satisfied the license condition, the alternate flow path was also unavailable
because the valves used for the alternate flow path were closed.
Item B of the Notice involves a violation of primary containment integrity during
the period June 21 to September 2, 1985 as a result of conditions existing in
the containment monitoring system and the Division 2 hydrogen recombiner. On
September 2, 1985, the licensee determined that one valve in the containment
monitoring system had been left open after installation of the valve and the
CERTIFIED MAIL
iiETURN RECEIPT REQUESTED
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The Detroit Edison Company
2
July 29, 1986
line had been left uncapped resulting in an open pathway between primary
containment and the reactor building.
In addition, on August 28, 1985, the
Division 2 hydrogen recombiner was discovered by the licensee to have leakage
in excess of allowable containment leakage limits.
This condition had been in
existence since June 21, 1985 when maintenance was performed on the system to
replace a blower seal. Both of these violations of primary containment
integrity had resulted from the sign-off on work orders that the work and
testing had been completed before leakage testing had been performed.
Item C of the Notice involves the removal from service of the Reactor Core
Isolation Cooling (RCIC)/ Core Spray System (CSS) room cooler from July 23 24,
1985, which made the RCIC system and Division 1 of the CSS inoperable. This
condition was caused by the placement of the control switch for the room cooler
in the off-reset position and was discovered by your personnel on July 24, 1985.
However, it is not clear what caused the placement of the control switch in the
off-reset position.
The root cause of the above violations appears to be inadequate work control
meatares to ensure that work activities are accomplished in a controlled manner
and in accordance with established procedures, work is fully completed,
applicable inspections are performed, and the systems are tested to ensure
that the system will function as intended.
In addition, Item C involved an
incident in which shift turnovers of control room personnel did not identify
the significance of the off-normal condition of the room cooler. On March 13,
1986, you were cited for a Severity Level IV violation related to the failure
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of control room personnel to identify that the seismic monitor was in an
off-normal condition. These violations and other findings in Inspection
Report 50-341/85040 indicate the need for increased management attention to
assure that control room personnel are aware of the operational status of plant
equipment at all times.
To emphasize the need for proper work control measures, including adherence to
work procedures and awareness of the status of work activities, and attention
to other than normal conditions by control room personnel, I have been
authorized, after consultation with the Director, Office of Inspection and
Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition
l
of Civil Penalties in the amount of Seventy-five Thousand Dollars ($75,000) for
i
the violations set forth in the enclosed Notice.
In accordance with the " General
l
Statemeat of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2,
l
Appendix C (1986) (Enforcement Policy), the violations described in the enclosed
i
Notice have each been categorized as a Severity Level III violation. 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
,
l
circumstances. These violations are symptomatic of the management weaknesses
i
that led to the July 1-2, 1985 rod pull error and resulted in the proposed
'
$300,000 civil penalty for that event.
In addition, the violations occurred
during the same time period (June-September 1985). You have taken extensive
actions to correct these violations during the past several months including
the implementation of:
a control room specific Reactor Operations Improvement
Plan; independent investigations of operating activities and communications by
.
'
The Detroit Edison Company
3
July 29, 1986
an Independent Overview Committee; and a broad based Nuclear Operations
Improvement Plan. Accordingly, in recognition of your corrective actions and
the prior civil penalty for similar management problems, the base civil penalty
for each violation has been reduced by 50 percent.
Because you have already instituted extensive corrective action as described
above and we view these programs to have encompassed the problems identified in
this letter and Inspection Report 50-341/85040 (DRP), no response to the Notice
of Violation except for payment of the proposed civil penalty is required.
If
~
you choose to respond to the Notice of Violation, you should follow the
instructions specified in the enclosed Notice when preparing your response.
The NRC will continue to monitor the effectiveness of your corrective action
programs in determining whether further enforcement action is necessary to
ensure compliance with regulatory requirements.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,
Title 10, Code of Federal Regulations, a copy of this letter and its enclosure
will be placed in the NRC Public Document Room.
The responses directed by this letter and the enclosed Notice are not subject
to the clearance procedure of the Office of Management and Budget, as required
by the Paperwork Reduction Act of 1980, PL 96-511.
Sincerely,
kipinal s,1$ned by
Jess G. Kewt r
James G. Keppler
Regional Administrator
Enclosure: Notice of Violation
and Proposed Imposition of Civil
Penalties
cc w/ enclosure:
L. P. Bregni, Licensing
'
Engineer
P. A. Marquardt, Corporate
Legal Department
Licensing Fee Management Branch
Resident Inspector, RIII
Ronald Callen, Michigan
Public Service Commission
Harry H. Voigt, Esq.
Nuclear Facilities and
Environmental Monitoring
Section
Monroe County Office of
Civil Preparedness
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RII
RIII
RI I
RIII
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Nor
p'kst
Schultz
vis
Ke'pl
vis
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, as
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The Detroit Edison Company
4
July 29, 1986
Distribution-(continued)
,
LPDR
SECY
CA
- JTaylor, IE
JGKeppler, RIII
JAxelrad, IE
HWong, IE
JLieberman, ELD
JSniezek, DED/ROGR
Enforcement Coordinators
RI, RII, RIII, RIV, RV
FIngram, PA
HDenton, NRR
BHayes, 01
SConnelly, 0IA
JCrooks, AE00
EDO Rdg File
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