ML20205T182

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Discusses Insp on 860318-21 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $200,000
ML20205T182
Person / Time
Site: Peach Bottom 
Issue date: 06/09/1986
From: Murley T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Daltroff S
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
Shared Package
ML20205T187 List:
References
EA-86-059, EA-86-59, NUDOCS 8606130069
Download: ML20205T182 (4)


Text

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JUN 0 91986 Docket No.

50-278 License No. OPR-56 EA 86-59 Philadelphia Electric Company ATTN: Mr. S. Daltroff Vice President Electric Production 2301 Market Street Philadelphia, Pennsylvania 19101 Gentlemen:

Subject:

NOTICE OF VIOLATION AND PR0p0 SED IMPOSITION OF CIVIL PENALTIES (NRC Inspection Report No. 50-278/86-09)

This refers to an NRC special inspection conducted on March 18-21, 1986 of activities authorized by NRC Operating License No. OPR-56 at the Peach Bottom Atomic Power Station, Unit 3.

The circumstances associated with the withdrawal of a control rod during reactor startup in a sequence different from that specified in the control rod program were reviewed. The incident, which resulted in violations of the station's Technical Specifications, was identi-fied by members of your staff and promptly reported to the NRC. The details are provided in Inspection Report (50-278/86-09) sent to you by letter dated March 25, 1986. On March 27, 1986, an enforcement conference was conducted with Mr. V. Boyer and you and members of your staffs to discuss the incident, the related violations, their causes, and your corrective actions.

These violations are described in the enclosed Notice of Violation and Proposed Imposition of Civil Penalties and resulted from numerous personnel errors by several licensed personnel, including the Shif t Supervisor and Shif t Superin-tendent, both of whom are licensed senior reactor operators. The violations occurred when automatic systems were inoperable or bypassed and the compensa-tory measures required by Technical Specifications were not properly implemented. The incident was initiated when the licensed reactor operator performing the startup withdrew the wrong control rod from the core. The Rod Worth Minimizer (RWM), designed to detect such an occurrence, was inoperable at the time. As required by the Peach Bottom Technical Specifications, a second licensed operator had been assigned to independently verify the correct rod selection and withdrawal sequence; however, he did not identify this error.

In addition, an opportunity occurred to identify and correct the error when the procedural step was reached to withdraw the control rod which had been already mistakenly pulled but neither of the reactor operators identified the prior error.

CERTIFIED MAIL R_ETURN RECE Di REQUESTED E

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Philadelphia Electric Company 2

Subsequently, when the Rod Sequence Control System (RSCS) prevented further rod withdrawals because the missed rod had not yet been withdrawn, the Shift Supervisor and Shift Superintendent, both of. whom were supposed to be oversee-ing and managing the startup activities, apparently assumed the missed rod was in the full-out position, and they physically performed the manipulation to bypass the RSCS position for that rod to the full-out position. The RSCS was bypassed without assuring that the control rod was in its correct position.

Although alternate means of verifying control rod position were available, such as the plant process computer printout and the full core display showing control rod position, these means apparently were not used. These facts indicate a failure on the part of your supervisory staff to properly oversee reactor operations in the control room.

These personnel errors by four licensed individuals indicate that a pattern of inattention to detail, failure to adhere to procedural requirements, and a generally complacent attitude of staff toward performance of their duties continues to exist at Peach Bottom. On June 21, 1985, an enforcement conference was conducted with you and members of your staff to discuss the apparent inattentiveness of a licensed operator while at the controls of the reactor.

Further, on June 18, 1984, a $30,000 civil penalty was issued for violations of the station's Technical Specifications involving control room personnel errors including two instances when heatup rates were exceeded, and one instance when the reactor vessel was pressurized above limits.

In addition, two civil penalties, in the respective amounts of $100,000 and $40,000, were issued in 1983 for four violations of containment integrity that resulted from the failure of non-licensed individuals to follow procedures. The latest incident demonstrates that the actions taken to correct this pattern have not been effective. We view such problems as being indicative of a lack of management involvement in and attention to station activities to assure that the station personnel respect, understand the need for, and adhere to your policies and procedures for the safe operation of the facility.

To emphasize the need for increased management involvement and attention in station activities to assure improved personnel performance, 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 Penalty in the amount of $200,000 for the two 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 (1985), the violations have been categorized as two Severity Level III problems. Although the base civil penalty for eacn Severity Level III problem is $50,000, the civil penalty for each problem has been increased by 100*I, because:

(1) in each case, an opportunity existed for a licensed individual to detect and correct the red pull error, but the error was not recognized, and (2) the enforcement history at Peach Bottom regarding your staff's adherence to procedures has been poor. The errors by the licensed individuals are being considered to determine whether any further corrective actions are appropriate.

OFFICIAL RECORD COPY CP PKG PB REV 5 - 0002.0.0 06/06/86

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Philadelphia Electric Company 3

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, 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 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 procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

Sincerely, Original signed by Thomas 2.MurleE Thomas E. Murley Regional Administrator

Enclosure:

Notice of Violation and Proposed Imposition of Civil Penalty cc w/ encl:

R. S. Fleischmann, Manager (Receives All 2.790 Information)

John S. Kemper, Vice President, Engineering and Research Troy B. Conner, Jr., Esquire W. H. Hirst, Director, Joint Generation Projects Department, Atlantic Electric Eugene J. Bradley, Esquire, Assistant General Counsel (Without Report)

Raymond L. Ilovis, Esquire Themas Magette, Power Plant Siting, Nuclear Evaluations (Without Report)

W. M. Alden, Engineer in Charge, Licensing Section Public Document Room (PDR) local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Commonwealth of Pennsylvania 0FFICIAL RECORD COPY CP PKG PB REV 5 - 0003.0.0 06/06/86

Philadelphia Electric Company 4

DISTRIBUTION RegionTDHket Room (w/ concurrences)

SECY CA J. Taylor, IE J. Axelrad IE H. Wong, IE T. E. Murley, RI J. Lieberman, ELD J. Sniezek, OED/ROGR Enforcement Coordinators RI, RII, RIII, RIV, RV F. Ingram, PA J. Crooks, AE00 B. Hayes, OI S. Connelly, OIA J. Partlow, H. Denton, NRR D. Nussbaumer, OSP IE/ES File IE/EA File EDO Rdg File DCS l

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