ML20245E051
| ML20245E051 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/21/1989 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Edelman M TOLEDO EDISON CO. |
| Shared Package | |
| ML20245E055 | List: |
| References | |
| EA-89-049, EA-89-49, NUDOCS 8905020002 | |
| Download: ML20245E051 (4) | |
See also: IR 05000346/1988037
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April 21, 1989
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Docket No. 50-346
License No. NPF-3
EA 89-49
Toledo Edison Company
ATTN:
Mr. Murray R. Edelman
President
Edison Plaza
300 Madison Avenue
Toledo, Ohio 43652
Gentlemen:
SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY
(NRC INSPECTION REPORT NO. 50-346/88037[DRP])
This refers to an NRC inspection conducted during the period December 1, 1988
through February 10, 1989, which included review of an improper reactor
startup event on December 18, 1988, at the Davis-Besse Nuclear Power Station
in Oak Harbor, Ohio.
The results of the inspection were described in the
inspection report sent to you on February 24, 1989
On March 3, 1989, we held
an enforcement conference with Mr. D. Shelton and others of your staff to
discuss the violations, root causes, and corrective actions.
On December 18, 1988, at 0358, the Davis-Besse reactor was operating at
approximately two percent power when the control rod Group 3 safety rods
dropped into the reactor core as a result of a personnel error during
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maintenance troubleshooting. Operators in the Control Room erroneously assumed
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that the reactor was critical and started to recover the Group 3 rods despite
indications that the reactor remained subcritical.
As temperature decreased
to approximately 525 F, the operators realized that this was the minimum
temperature allowed by Technical Specifications for a critical reactor and at
0405 inserted the Group 3 rods into the core. At 0406 the operators proceeded
to shut down the reactor.
Four violations of NRC requirements were identified as a result of the
inspection conducted following this event and include:
(1) failure to follow
the Davis-Besse " Approach to Criticality" procedtre; (2) failure to establish
a procedure for mispositioned control rods; (3) failure to provide sufficient
information in narrative logs to enable reconstruction of events, and
(4) failure to properly log late entries.
The violations cited are indicative of a significant breakdown in the control
of licensed activities in the Control Room.
The NRC is particularly concerned
with the performance of individuals in the Control Room during the event. /11
Control Room personnel at the time of the Group 3 rod drop, assumed the reactor
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8905020002 890421
ADOCK 05000346
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Toledo-Edison Company-
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April 21, 1989
was still' critical despite indications to the contrary. The Shift Supervisor
directed that the Group 3 rods be latched and withdrawn even though the Shift
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Technical Advisor had recommended that the plant be tripped since it was inLa
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condition not covered by procedures. Once the Duty Operations Manager arrived
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in the Control Room, he observed that the reactor wasLsubcritical and that a
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cooldown of RCS was in progress.
However, after making his initial assessment,
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he made no recommendations to the Shift Supervisor contributing to the crew's
failure to recognize the event and take appropriate actions. While the
technical aspects of this event were not of high safety significance, we
believe the performance of the crew in responding to the event was seriously
deficient.
After this event, you removed the involved shift supervisor from his control
room operating crew responsibilities, and presently are re-evaluating his
performance as shift supervisor.
On March 10, 1989, we issued a Confirmatory
Action Letter confirming your cemitnwat to inform the NRC Region:III office
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of your basis for returning that Shift Supervisor to operating crew licensed'
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responsibilities.
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To emphasize the importance of operator attention and maintaining control
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of licensed activities in the Control Room, I have been authorized, after
consultation with the Director, Office of- Enforcement, and the Deputy Executive
Director for Nuclear Materials Safety, Safeguards and: Operations Support, to
issue the enclosed Notice of Violation and Proposed Imposition of. Civil Penalty
in the amount of Fifty Thousand Dollars ($50,000) 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,-53
Fed. Reg. 40019 (October 13, 1988) (Enforcement Policy), the violations
described in the enclosed Notice have been categorized.in the aggregate as a
Severity Level III problem. The escalation and mitigation factors in the
Enforcement Policy were considered, and no adjustment has been deemed
appropriate.
The violation in Section II of the enclosed Notice was not specifically discussed
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at the enforcement conference. However, after considering your interpretation
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of the words "during operation", contained in 10 CFR 50.72(b)(1)(ii), the NRC
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concluded that it was improper.
Operation of the plant involves many activities
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that take place prior to the plant achieving criticality, which is the point at
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which you assert " operations" begins.
Clearly, withdrawing control rods in
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order to achieve criticality is a significant evolution which involves operating
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the plant.
Given that this evolution was performed at Davis-Besse on
December 18, 1988, without proper procedural guidance, it should have been
reported to the NRC within one hour pursuant to 10 CFR 50.72 (b)(1)(ii)(C).
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-
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Toledo Edison'. Company
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April 21, 1989
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In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,
Title 10, Code of Federal Regulations, a copy of th's letter.'and its enclosure
will be placed in the NRC Public Document Room.
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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
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by the Paperwork Reduction Act of'1980, Pub. L., No.96-511.
Sincerely,
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Original. signed by
C. E. Norelius
A. Bert Davis
Regions 1 Admin'istrator
Enclosures:
1.
Proposed Imposition
of Civil Penalty
2.
Inspection Report
No. 50-346/88037(DRP))
cc w/ enclosures:
' Donald Shelton, Vice President,
Nuclear
L. Storz, Plant Manager
DCD/DCB (RIDS)
Licensing Fee Management Branch
Resident Inspector, RIII
James W. Harris, State of Ohio
Roger Suppes, Ohio
Department of Health
State of Ohio, Public
Utilities Commission
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Toledo Edison Company
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April 21, 1989
Distribution
SECY
CA
OGPA
DCD/DCB(RIDS)
J. M. Taylor, DEDR
H. Thompson, DEDS
J. Lieberman, OE
L. Chandler, OGC
T. Murley, NRR
RAO:RIII
PAO:RIII
SLO:RIII
M. Stahulak, RIII
Enforcement Coordinators,
RI, RII, RIV, and RV
.s
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