ML20214A125
| ML20214A125 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 05/13/1987 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20214A096 | List: |
| References | |
| EA-87-050, NUDOCS 8705190277 | |
| Download: ML20214A125 (5) | |
Text
r NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Detroit Edison Company Docket No. 50-341 Fermi 2 License No. NPF-43 EA 87-50 During NRC inspections conducted from October 17, 1986 through February 10, 1987, 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 (1987), the Nuclear Regulatory Commission proposes to i~90se a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205. The particular violations and associated civil penalty are set forth below:
A.
Technical Specification (TS) Limiting Condition for Operation _(LCO) 3.5.1.c requires that the High Pressure Coolant Injection (HPCI) system be operable when the unit is in Operational Condition 1 or Operational Condition 2 cr 3 with reactor steam dome pressure greater than 150 psig.
The HPCI system may be inoperable provided that, among other systems, the Reactor Core Isolation Cooling (RCIC) system is operable.
TS LCO 3.7.4 requires that the RCIC system be operable when the unit is in Operational Cunditions 1, 2, or 3 with reactor steam dome pressure greater than 150 psig. The RCIC system may be inoperable provided that the HPCI system is operable.
TS LCO 3.5.1.c and 3.7.4 specify an operable flow path to be capable of taking suction from the suppression chamber and transferring the water to the reactor vessel.
When an LCO or its associated action statement cannot be met, TS 3.0.3 requires that action be initiated within one hour to place the unit in an Operational Condition in which the LCO does not apply.
Contrary to the above:
1.
On October 9, 1986, between the hours of 8:40 and 10:40 a.m. and between the hours of 12:55 and 2:55 p.m., while the unit was in Operational Condition I with reactor stream dome pressure greater than 150 psig, both the RCIC and HPCI systems were made inoperable during performance of Surveillance Procedure 44.030.154 by closing and de-energizing those systems' suppression chamber suction valves.
Action was not initiated within one hour to place the unit into an Operational Condition in which TS LCOs 3.5.1.c and 3.7.4 did not apply.
2.
On December 24, 1986, between the hours of 12:50 and 5:00 p.m.,
while the unit was in Operational Condition 2 with reactor steam l
dome pressure greater than 150 psig and the HPCI system inoperable, i
8705190277 870514 PDR ADOCK 05000341 G
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the RCIC system was made inoperable by valving out the RCIC flow transmitter during performance of Surveillance Procedure 44.110.04.
Action was not initiated within one hour to place the unit into an Operational Condition in which TS LCOs 3.5.1.c and 3.7.4 did not apply.
3.
On December 26, 1986, between the hours of 1:30 and 3:50 p.m.,
while the unit was in Operational Condition 2 with reactor steam dome pressure greater than 150 psig and the HpCI system inoperable, the RCIC system was rendered inoperable after calibration and troubleshooting activities when the system flow controller was set at 505 gpm instead of the required 605 gpm flow rate. Action was not initiated within one hour to place the unit into an Operational Condition in which TS LCOs 3.5.1.c and 3.7.4 did not apply.
B.
TS LCO 3.10.2.b allnws, when the unit is in Operational Condition 1 or 2, the bypassing of the sequence constraints imposed on control rod groups by the Rod Sequence Control System (RSCS) required by TS LC0 3.1.4.2 when performing control rod scram testing provided the Rod Worth Minimizer (RWM) is operable. TS Surveillance Requirement 4.10.2 requires that the following verification be performed when operation occurs under TS LC0 3.10.2.b:
Within eight hours prior to bypassing any sequence constraint and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while a sequence constraint is bypassed, verify the operability of the RWM and verify that movement of control rods between 50% rod density and the RSCS preset power level is blocked or limited to the single notch mode.
Contrary to the above, during the period between 10:00 p.m. on November 3, 1986, and 10:15 p.m. on November 5, 1986, while the unit was in Operational Condition 2 and the sequence constraints imposed on control rod groups by the RSCS were bypassed during control rod scram testing, the verifications specified in TS Surveillance Requirement 4.10.2 were not performed at the required frequencies.
The RWM was only verified operable on November 4, 1986, at 4:35 a.m. and 5:15 p.m. and on November 5, 1986, at 7:30 p.m.
The movement of control rods between 50% rod density and the RSCS preset power level was only verified to be blocked or limited to the single notch mode on November 4, 1986, at 6:30 p.m. and November 5, 1986, at 7:09 p.m.
C.
TS LC0 3.6.1.3.b requires that each primary containment air lock shall be operable with an overall leakage less than or equal to 0.05 La at 56.5 psig when the unit is in Operational Condition 1, 2, or 3.
TS Surveillance Requirement 4.6.1.3.c.1 requires that an air lock leakage test at 56.5 psig be conducted prior to fuel loading and every six months to verify that the overall air lock leakage rate is within its limit.
TS 4.0.4 requires that entry into an Operational Condition shall not be made unless the applicable LCD surveillance requirements have been satisfied within the required surveillance interval.
Contrary to the above, the unit entered Operational Conditions 1, 2, and 3 at various times between 4:35 a.m. on January 24, 1987, and 9:30 a.m. on February 2, 1987, in violation of TS 4.0.4, in that TS Surveillance Requirement 4.6.1.3.c.1 was not satisfied within in the required interval.
The testing interval expired on January 12, 1987. Testing conducted on February 2, 1987 disclosed that the overall air lock leakage exceeded the allowed leakage rate of 0.05 La at 56.5 psig.
D.
TS LC0 3.6.6.1 requires that two independent drywell and suppression chamber hydrogen recombiner systems shall be operable when the Unit is in Operational Conditions 1 or 2.
TS Surveillance Requirement 4.6.6.1.a specifies testing to demonstrate hydrogen recombiner system operability be performed every six months to verify that the recombiner system heater outlet gas temperature increases to greater than 1150'F within 75 minutes and is maintained at that temperature for one hour.
TS 4.0.4 requires that entry into an Operational Condition shall not be made unless the applicable LCO surveillance requirements have been satisfied within the required surveillance interval.
Contrary to the above, the unit entered Operational Condition 2 on eleven occasions between August 29, 1985, and December 19, 1986, in violation of TS 4.0.4 in that the test procedure to implement TS Surveillance Requirement 4.6.6.1.a did not verify that the recombiner system heater outlet gas temperature increased to greater than 1150 F within 75 minutes and was maintained at that temperature for one hour under emergency conditions with the Residual Heat Removal system operating. Testing conducted on January 8 and 9,1987 disclosed that the Division II hydrogen recombiner system was inoperable and could only reach 761*F within 75 minutes due to an original equipment deficiency not disclosed during preoperational testing.
E.
TS LCO 3.3.2 and the associated Table 3.3.2-1, Section 2.C, require that the Reactor Water Cleanup System (RWCU) isolation actuation instrumentation
~for the heat exchanger / pump area ventilation differential temperature high function be operable when the unit is in Operational Condition 1, 2 or 3.
Further, with the one channel inoperable, the licensee is required to close the affected system isolation valves within one hour and declare the affected system inoperable.
TS 3.0.4 requires that entry into an Operational Condition shall not be made unless the applicable LCOs are met without reliance on the provisions of the action requirements.
Contrary to the above, on December 18, 1986 the unit entered Operational Condition 2 and 3 in violation of TS 3.0.4 and remained in Operational Condition 2 until December 20, 1986 in violation of LC0 3.3.2 with the RWCU isolation actuation instrumentation for the heat exchanger / pump area 4
ventilation differential temperature high function inoperable without satisfying the applicable action requirements. The trip function was made inoperable on December 3, 1986 when the leads for the thermocouples in one of the differential temperature trip systems had been reversed and improperly landed following a surveillance test.
F.
TS Surveillance Requirement 4.4.3.1.b requires that the drywell floor drain and the drywell equipment drain sump pump-run-time systems receive a channel functional test at least once per 31 days and a channel calibration test at least once per 18 months when the unit is in Operational Conditions 1, 2 or 3.
TS 4.0.4 requires that entry into an Operational Condition shall not be made unless the applicable LCO surveillance requirements have been satisfied within the required time interval.
Contrary to the above, the unit entered Operational Conditions 2 and 3 in violation of TS 4.0.4 several times between August 1985 and October 1986 without satisfying TS Surveillance Requirement 4.4.3.1.b in that the procedure to implement this requirement did not include channel functional and calibration testing for the drywell floor drain and equipment drain sump pump-run-time systems.
G.
TS Surveillance Requirement 4.3.7.12 and the associated Table 4.3.7.12-1, Section 2.b, require a daily channel check for the noble gas activity monitor in the offgas system at the 2.2 minute delay piping during main condenser air ejector operation.
Contrary to the above, from the beginning of facility operation to September 16, 1986, the required daily channel check for the noble gas activity monitor in the offgas system at the 2.2 minute delay piping during main condenser air ejector operation had not been performed.
This is a Severity Level III problem (Supplement I).
Cumulative Civil Penalty - $100,000 (assessed equally among the violations).
Pursuant to the provisions of 10 CFR 2.201, Detroit Edison Company (Licensee) is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission within 30 days of the date of this Notice.
This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each alleged violation:
(1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, (3) the corrective steps that have been taken and the i
results achieved, (4) the corrective steps that will be taken to avoid further violations, and (5) the date when full compliance will be achieved.
If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. 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.
I l
Within the same time as provided for the response required above under
-10 CFR 2.201, the Licensee may pay the civil penalty by letter. addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission with a check, draft, or money order payable to the Treasurer of the United States in the cumulative amount of the civil penalty proposed above, or the cumulative amount of the civil penalties if more than one civil penalty is proposed, or may protest imposition of the civil penalty in whole or in a part by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission. Should the Licensee fail to answer within the time specified, an order imposing the civil penalty will be issued. Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, such answer should be clearly marked as an " Answer to a Notice of Violation" and 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 penalty in whole or in part, such an'swer-may' request remission or mitigation of the penalty.
I In requesting mitigation of the proposed penalty, the five factors addressed
~
in Section V.B of 10 CFR Part 2, Appendix C (1987), should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth sepaiately i
from the statement or explanation in reply pursuant to 10 CFR 2.201, but m y
-incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. The attention of the Licensee r
is directed to the other provisions of 10 CFR 2.205, regarding the ' procedure i
for imposing a civil penalty.
Upon failure to pay any civil penalty due which subsequently has been 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 acD on pursuant to Section 234c of the Act, 42 U.S.C. 2282c.
l' The responses to the Director, Office of Enforcement, noted above (Reply to i
a Notice of Violation, letter with payment of civil penalty, and Answer to l
a Notice of Violation) should be addressed to: Director, Office.of Enforcement, l
U.S. Nuc1 car Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, for the appropriate Region, and, if applicable, a copy to the NRC Resident Inspector, at the facility which is the subject of this Notice.
FOR THE NUCLEAR REGULATORY COMMISSION w JJ a--~~b A. Bert Davis Regional Administrator Dated at Glen Ellyn, Il this I P day of May 1987
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