Text

Forwards Insp Rept 50-346/98-02 on 980107-0218 & Nov. Violations Identified Re Failure to Execute Procedures Properly by Licensed Operators
	ML20216D871
Person / Time
Site:	Davis Besse
Issue date:	03/10/1998
From:	Grant G; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Jeffery Wood; CENTERIOR ENERGY
Shared Package
ML20216D875	List: ML20216D871; ML20216D881; ML20216D886;
References
	50-346-98-02, 50-346-98-2, EA-98-080, EA-98-80, NUDOCS 9803170324
	Download: ML20216D871 (6)
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g UNITED STATES

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$ S REGION N

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March 10, 1998

EA 98-080

Mr. John K. Wood

Vice President- Nuclear

'

Davis-Besse Nuclear Power Station

5501 North State Route 2

Oak Harbor, OH 43449

SUBJECT: NOTICE OF VIOLATION AND EXERCISE OF ENFORCEMENT DISCRETION;

INSPECTION REPORT NO. 50-346/98002(DRP)

Dear Mr. Wood:

On February 18,1998, the NRC completed an inspection at your Davis-Besse site. The

enclosed report presents the results of that inspection.

During the six-week period covered by this inspection report, activities at the Davis-Besse facility

were generally characterized by safe and conscientious plant operations. The control room staff

responded well to equipment problems and material deficiencies. We are concemed, however,

about two violations of NRC requirements that were identified. The first violation pertains to two

examples of a failure to execute proc,edures property by licensed operators. These examples are

of concem because inattention-to 'Jetail resulted in operators: (1) momentarily stopping reactor

coolant pump seal water flow when a seal water retum valve was inadvertently closed during

routine testing; and (2) causing a letdown system relief valve to lift when a procedural step to

open a bypass valve was missed prior to commencing reactor coolant system purification

activities. In the second violation, although sufficient information was available on December 12,

1997, to determine that the safe shutdown emergency diesel generator speed circuitry design

was not in accordance with 10 CFR Part 50, Appendix R, a one-hour report was not made to the

NRC until December 18,1997.

These violations are cited in the enclosed Notice of Violation (Notice), and the circumstances

surrounding the violations are described in detail in the enclosed report. Please note that you are

required to respond to this letter and should follow the instructions specMed in the enclosed

Notice when preparing your response. The NRC will use your response, in part, to determine

whether further enforcement action is necessary to ensure compliance with regulatory

requirements.

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J. Wood -2-

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l Once it was identified that the emergency diesel generator speed sensing circum was not

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protected from hot shorts which could occur during a fire postulated by 10 CFR Part 50,

Appendix R, and that this condition was outside the design basis of the plant, this original design

l issue was handled very effectively. The condition was reported to the NRC, a temporary

'

modification was implemented to isolate the speed sensing circuit from the control room, and all

l other control circuits were reviewed to verify that they were adequate:ly protected for a hot short

condition. We note that you plan to install a permanent modification to the speed sensing circuit

i

to correct this design deficiency.

l The ARC notes that this original design deficiency pertaining to 10 CFR Part 50, Appendix R, i

requirements was identified through a review of a condition report from another facility.

Conective a::tions taken and planned were comprehensive and should prevent recurrence. The.

design deficiency was subtle in nature and was not likely to be identifwKi by routine surveillance

activities.

l

This design issue is an apparent violation of NRC requirements which could be considered for

i escalated enforcement and subject to a civil penalty. However, after consultation with the

l Director Office of Enforcement and the Regional Administrator, I have been authorized to not

issue a Notice of Violation and not propose a civil penalty in this case in accordance with the i

provisions provided in Section Vll.B.3 of the NRC's Enforcement Policy. This decision was made

after consideration that: (1) the violation was ider.tified by the engineering staff; (2) corrective .

actions, both taken and planned, were comprehensive and timely; (3) the condition was subtle in

nature and not likely to be disclosed through routine surveillance or quality assurance activities;

and (4) the violation is not reasonably linked to current performance. The exercise of discretion

acknowledges the effort made to identify and correct subtle violations that would not be identified

by routine efforts before the degraded safety systems are called upon.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its !

enciosures, and your response will be placed in the NRC Public Document Room.

Sincerely,

Geoffrey E. Grant, Director

Division of Reactor Projects

Docket No.: 50-346

License No.: NPF-3

Enclosures: 1. Notice of Violation

2. Inspection Report

No. 50-346/98002(DRP)

See Attached Distnbution

.

..

J. Wood 3

cc w/encis: John P. Stetz, Senior

Vice President- Nuclear

J. H. Lash, Plant Manager

J. L. Freels, Manager

Regulatory Affairs

State Liaison Officer, State

of Ohio

Robert E. Owen, Ohio

Department of Health

C. A. Glazer, State of Ohio,

Public Utilities Commission

i

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!

. I

- J. Wood -2-

!

Once it was identsfied that the emergency diesel generator speed sensing circuit was not .

protected from hot shorts which could occur during a fire postulated by 10 CFR Part 50, !

Appendix R, and that this condition was outside the design basis of the plant, this original design :

issue was handled very effectively. The condition was reported to the NRC, a temporary !

l modification was implemented to isolate the speed sensing circuit from the control room, and all !

i other control circuits were reviewed to verify that they were adequately protected for a hot shost '

l condition. We note that you plan to install a permanent modification to the speed sensing circuit

i

to correct this design deficiency.

The NRC notes that this original design deficiency pertaining to 10 CFR Part 50, Appendix R,

requirements was identified through a review of a condition report from another facility.-

Corrective actions taken und planned wsre comprehensive and should prevent recurrence. The !

design deficiency was subtle in nature and was not likely to be identified by routine surveillance j

l activities.

l'

l This design issue is an apparent violation of NRC requirements which could be considered for

escalated enforcement and subject to a civil penalty. However, after consultation with the

Dircctor Office of Enforcement and the Regional Administrator, I have been authorized to not

issue a Notice of Violation and not propose a civil penalty in this case in accordance with the

l provisions provided in Section Vll.B.3 of the NRC's Enforcement Policy. This decision was made

l after consideration that: (1) the violation was identified by the engineering staff; (2) corrective

action!., both taken and planned, were comprehensive and timely; (3) the condition was subtle in

l nature and not likely to be disclosed through routine surveillance or quality assurance activities;

and (4) the violation is not reasonably linked to current performance. The exercise of discretion j

acknowledges the effort made to identify and correct subtle violations that would not be identified

'

by routirse efforts before the degraded safety systems are called upon.

i

l In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its

l enclosures, and your response will be placed in the NRC Public Document Room. ,

Sincerely,

i'

l

s/ Marc L. Dapas for

Geoffrey E. Grant, Director

Division of Reactor Projects

i Docket No.: 50-346

l License No.: NPF-3

Enclosures: 1. Notice of Violation '

2. Inspection Report

, No. 50-346/98002(DRP)

See Attached Distnbution l

l Document name: G:\davi\dav98002.drp SEE PREVIOUS CONCURRENCES :

To receive a copy of thle document. Inecate in the bos "C" o Copy without attactWencI T e Copy with attacfWenci aff" a leo copy

Rlli Rlli Rlli

'

OFFICE

NAME Kozak:nmu Clayton GrantM[M

DATE 03/ /98 03/ /98 03//8/98

OFFICIAL RECORD COPY

_

,

l

.

J. Wood -2-

Once your staff identified that the EDG speed sensing circuit was not protected from hot shorts

which could occur during a fire postulated by 10 CFR Part 50, Appendix R, and that this condition

was outside the design basis of the plant, this originaldesign issue was handled very effectively.

The condition was reported to the NRC, a temporary modification was implemented to isolate the

speed sensing circuit from the control room, and all other control circuits were reviewed to verify

that they were adequately protected for a hot short condition. We note that you plan to install a

permanent modification to the speed sensing circuit to correct this design deficiency.

The NRC notes that this original design deficiency pertaining to 10 CFR Part 50, Appendix R,

requirements was identified by your staff through a review of a condition report from another

facility. Corrective actions taken and planned were comprehensive and should prevent

recurrence. The design deficiency was subtle in nature and was not likely to be identified by

routine surveillance activities.

This design issue is an apparent violation of NRC requirements which could be considered for

escalated enforcement and subject to a civil penalty. However, after consultation with the

Director Office of Enforcement and the Regional Administrator, I have been authorized to not

issue a Notice of Violation and not propose a civil penalty in this case in accordance with the

provisions provided in Section Vll.B.3 of the NRC's Enforcement Policy. This decision was made

after consideration that: (1) the violation was identified by your engineering staff; (2) corrective

actions, both taken and planned, were comprehensive and timely; (3) the condition was subtle in

nature and not likely to be disclosed through routine surveillance or quality assurance activities;

and (4) the violation is not reasonably linked to current performance. The exercise of discretion

'

acknowledges your good effort to identify and correct subtle violations that would not be identified

by routine efforts before the degraded safety systems are called upon;

! In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its

!

enclosures, and your response will be placed in the NRC Public Document Room (PDR).

l

sincerely,

!

,

Geoffrey E. Grant, Director

l Division of Reactor Projects

i

Docket No.: 50-346

l License No.: NPF 3

{ Enclosures: 1. Notice of Violation

l 2. Inspection Report

j No. 50-346/98002(DRP)

See Attached Distribution

Document name: G:\davi\dav98002.drp

To receive a copy of this document, Indicate in the box "C" a Copy without attach / encl *E" a Copy with attach /enci "N" a No copy

OFFICE Rlli b Rill , Rill

NAME Kozak: nmo klayto h4 Grant l

DATE 03/ NV98 03/ 8 03/ /98

y plCIAL RECORD COPY

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I J. Wood -3-

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cc,w/encis: John P. Stetz, Senior

Vice President - Nuclear

J. H. Lash, Plant Manager

l J. L. Freels, Manager !

Regulatory Affairs l

l State Liaison Officer, State 1

l of Ohio

i

Robert E. Owen, Ohio

Department of Health

l C. A. Glazer, State of Ohio, ,

i Public Utilities Commission

Distnbutiog:

Docket File w/encis SRI Davis-Besse w/encls

PUBLIC IE-01 w/encls A. B. Beach w/encis

Project Manager, NRR w/encis Deputy RA w/encls

Rlli Enf. Coordinator w/encls Rill PRR w/encls

LEO w/encls (E-mail) DRS (2) w/encls i

TSS w/encls DOCDESK (E-mail)

DRP w/encls GREENS

J. Lieberman, OE w/encls B. Boger, NRR w/encls

J. Goldberg, OGC w/encls

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ML20216D871

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