ML20247J275
| ML20247J275 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 05/22/1989 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1-875, CAL-RIII-89-08, CAL-RIII-89-8, NUDOCS 8906010088 | |
| Download: ML20247J275 (9) | |
Text
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TOLEDO
%ms EDISON A Centerar Energy Compary l
DONALD C. SHELTON Vce Presdent-Nuclear
' Docket Number 50-346' Id'SI "S 23 l
License Number NPF-3 Serial Number 1-875-May 22, 1989 Director, Office of Enforcement United States Nuclear Regulatory Commission Document Control Desk Vashington, D. C.
'20555
Subject:
Response to Notice of Violation and Proposed Imposition of Civil Penalty (NRC Inspection Report Number 50-346/88037 [DRP])
Gentlemen:-
. Toledo Edison herewith provides its response to the ' subject Notice of
'i Violation and Imposition of Civil Penalty, issued on April 21, 1989 (Log Number-1-2075), related to the control rod Group 3 drop and subsequent reactor l
startup event on December 18, 1988. Toledo Edison admits the violations occurred and accepts the Civil Penalty.
Payment of the Civil Penalty.in the __
full amount of $50,000.has been made via wire transfer to the Treasurer of the United States on this date.
I If you have any questions concerning this matter, please contact Mr. R. V. Schrauder, Nuclear Licensing Manager, at (419) 249-2366.
Very truly yours,
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RMC/dlm I
Attachments.
J i
cct P. M. Byron, DB-1 NRC Resident Inspector 1
.A. B. Davis, Regional Administrator, NRC Region III J.'M. Taylor, Deputy Executive Director for Regional Operations T. V. Vambach, DB-1 NRC Senior Project Manager 8906010088 890522 g
{DR ADOCK0500g6 iy THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. OHIO 43G52
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Dockst Nu2b:r 50-346 Lic nsa Nuzb;r NPF-3 Serial Number 1-875 4
Enclosure Page 1 f
i RESPONSE TO NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT NUMBER 50-346/88037 [DRP])
FOR J
DAVIS-BESSE NUCLEAR POVER STATION UNIT NO. 1 i
Attached is Toledo Edison's response to the Notice of Violation and Proposed Imposition of Civil Penalty as issued by letter dated April 21, 1989. This response is submitted pursuant to 10CFR50.54(f).
By:
D. C. Shelton, Vice President, Nuclear Sworn and subscribed before me this 22nd Day of May, 1989.
N6tary'Public, State of Ohio LAURIE A.HlNKLE Nobry Public.Sbte of Ohio (Ay Commission Expires May 15.1991
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Dock 2t Numbrr 50-346 Liesnsa Nurbar NPF-3 Sarici Numbar 1-875
, Attechm:nt P. age 1 Violation I.A.1' 10 CFR.Part 50, Appendix B, Criterion V, requires, in part, that activities affecting quality be prescribed by documented instruction, procedures, or drawings. Tbc activities shall be accomplished.in accordance with these-instructions, procedures, or drawings.
1.
Davis-Besse Procedure DB-PF-06203, " Approach to Criticality" outlines the steps necessary.to take the
-reactor from Hot Standby (Mode 3) to Startup (Mode 2) including the requirement that all regulating rods be inserted, estimated critical position be calculated, and the Mode 2 checklist be completed.
Contrary to the above, at 0404, on December 18, 1988, with the reactor suberitical (Mode 3), Control Room-personnel withdrev the Group 3 rods without first inserting regulating rods 5-7, thus failing to follow the steps outlined.in DB-PF-06203, " Approach to Criticality." Specifically, with the reactor suberitical, the licensee should have inserted all regulating rods, estimated critical position, and completed the Mode 2 checklist prior to taking the reactor critical.
Admission or Denial of the Alleged Violation Toledo Edison admits the alleged violation as stated.
Reason for the Violation The reason for the violation was personnel error in that the operating shift crew did not recognize, in dropping the Group 3 rods, the reactor may have become suberitical.
Additionally, the Shift Supervisor directed the crew to make the recovery'without fully weighing the advice of the Shift Technical Advisor (STA),. consulting with.the Operations Manager, or adequate procedure guidelines for conducting a reactor startup for these conditions.
Corrective Action Taken and the Results Achieved Training for initial license candidates and licensed operators was previously conducted prior to the December 18, 1988 event in various settings (i.e.,
classroom, simulator, on-the-job) that addressed the knowledge and skills associated with recognizing a suberitical reactor and various events that may place the reactor in such a condition.
Licensed operators have received J
classroom training on this event, with emphasis on the following:
Suberitical reactor training The point of adding heat and its significance I
The meaning of intermediate range indication The lessons learned from this event J
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i t-Docket Number S0-346 i
Licensa Number NPF-3 LSariel Number 1-875
-Attachment
~Page 2 l
Classroom training on DB-0P-02516, CRD Malfunctions, as revised on March 15, 1989, has been conducted for licensed operators. This training emphasized the requirements for multiple rod drop recovery. The classroom training cited was completed April 28, 1989.
In' addition, based on the poor judgment exercised, the Shif t Supervisor was removed from licensed duties pending the completion of a re-evaluation of his performance.
In accordance with the NRC's Confirmatory Action Letter, CAL-RIII-89-008, dated March 10, 1989 (Log Number 1-2042), Toledo Edison vill inform NRC Region III of the basis for returning this individual to licensed duties.
Corrective Action That Vill Be Taken To Avoid Further Violations The next simulator training cycle at the B&W Power Safety Simulator in Lynchburg, Virginia vill include reactivity events at low power to ensure the lessons learned from this event have been adequately addressed.
Date When Full Compliance Vill Be Achieved Classroom training has been completed.
Simulator training vill be completed by November 3, 1989.
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Dockst Number 50-346
- Lic;ns: Nu;bsr NPF-3 g
S:riz1 Numb:r 1-875
-Attachment
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Page 3 4
Violation I.A.2 Davis-Besse Procedure DB-0P-00005, " Operator Logs and l
Reading Sheets," outlines the instructions for maintaining narrative logs to ensure that day-to-day operation of the plant is properly, documented.
a.
Section 6.1.4 of DB-0P-00005, "Logkeeping," requires that late entries into the log be made by entering the words " late entry" or "LE" to the left of the margin.
Contrary to the above, on December 18, 1988, during an incident where the Group 3 Safety Control nods unexpectedly dropped into the core, the Shift Supervisor made a late entry, pertaining to the plant's entry into Mode 3, into the logbook which did not specify " late entry" or "LE" to the left margin.
Specifically, the Shift Supervisor entered a statement at 0358 which read, " Group 3 safety rods dropped -
Plant entered Mode 3."
b.
Section 6.1.1 of DB-0P-00005 requires that narrative logs shall be written in sufficient detail to enable the reconstruction of events which have occurred.
Contrary to the above, the Reactor Operator log did not contain sufficient detail to enable reconstruction of the December 18, 1988 Group 3 Safety Control Rod drop event.
Specifically, the log had only two entries relating to the event. The two entries were that the rods had dropped into the core and that Tave was less than 525'F.
The log did not contain other occurrences such as the withdrawal of Group 3 rods, the subsequent insertion of those rods, and the insertion of the regulating rods.
Admission or Denial of the Alleged Violation a.
Toledo Edison admits the alleged violation.
b.
Toledo Edison admits the alleged violation.
Reason for the Violation The late entry into the logbook vas not made since the Shift Supervisor a.
believed that entering further information into the unit log at the time of a previous log entry, even though the additional information was discovered some time after the previous entry was made, was correct and did not require a late entry notation.
b.
The Unit and Reactor Operator Logs did not contain the details of the discussions between the Shift Technical Advisor and the Control Room shift members which would have further enabled a reconstruction of events which led to decisions made during the Group 3 rod drop event. The reason for this violation was personnel error by the Shift Supervisor and Reactor Operator in that they did not feel the short duration discussion varranted entry into the log book.
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Dock t Numb:r 50-346 Licensa Numb:r NPF-3 Suriel Numb 2r 1-875 i
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. Attachment Page 4 Corrective Actions Taken and Results Achieved
- a. and b.
Operations personnel have been counseled in logkeeping practices as part of the lessons learned from this event.
Procedure DB-0P-00005, Operator Logs and Reading Sheets, is being revised to to provide instructions for the Unit Log and Reactor Operator Log to include a precise chronology of events.
Further clarification of late entries and additional explanation of logable information (including the results of discussions and briefings conducted during events during the shift) are being incorporated in this revision.
Corrective Actions to be Taken to Avoid Further Violations
- a. and b.
The R0 and SR0 training programs will be revised to include instructional and practical factors on proper logkeeping for normal, off-normal, and emergency plant operations. Additionally, as part of the simulator training and evaluations program, logkeeping vill be evaluated.
Revision of DB-0P-00005 and the training programs should preclude recurrence.
Date When Full Compliance Vill Be Achieved
- a. and b.
Counseling of personnel has been completed to provide for improved logkeeping practices.
DB-0P-00005 vill be completed by May 22, 1989. The training programs will be revised by August 11, 1989, with the simulator evaluations to begin by August la, 1989.
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Dock 3t Nuxb;r 50-346 Lic:nsa Numb:r NPF-3 S: riel Numb:r 1-875 Attachment Page 5 Violation I.B:
Technical Specification 6.8.1.a requires that written-procedures be established for combating emergencies and other significant events, including events involving mispositioned control rods as listed in Appendix A of Regulatory Guide 1.33, November 1972.
Contrary to the above, on December 18, 1988, the licensee experienced a multiple control rod drop event and was unable to recover using Abnormal Procedure DB-0P-02516, "CRD Malfunctions." Specifically, DB-0P-02516 was inadequate, in that it did not contain guidance on how to recover from multiple rod drop events as listed in Regulatory Guide 1.33, Appendix A.
Admission or Denial of the Alleged Violation Toledo Edison admits to the alleged violation as stated.
Reason for the Violation The reason that the Davis-Besse "CRD Malfunctions" procedure did not contain guidance on recovery from multiple rod drops was due to procedural inadequacy.
This procedural inadequacy was caused, in part, by the fact that multiple rod drop events at low power have not been addressed as a concern by the nuclear industry in general. Throughout thr industry, multiple rod drop scenarios have only been addressed at select.itili ties. These scenarios have not received the attention of the industry at large in that they were not analyzed by Nuclear Steam Supply System (NSSS) vendors (possibly due to the low probability of occurrence) and were not recognized by the NSSS vendors or the industry as a reactivity management event.
Corrective Action Taken and Results Achieved Interim guidance was issued to licensed operators regarding multiple rod drops on December 23, 1988.
In addition, a Standing Order was issued on February 8, 1989 to provide increased emphasis on this type of reactivity management event. The Standing Order was incorporated in the CRD Malfunctions procedure on March 15, 1989.
Corrective Actions Taken to Avoid Further Violations The above corrective actions should preclude further violations regarding dropped rods.
In addition, the Babcock & Wilcox (B&V) Owners Group Ad Hoc Vorking Group, under the direction of the B&V Owners Group Steering Committee, l
has completed a review of recent complex events at B&V reactors, including the
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Davis-Besse December 18, 1988 event. A key recommendation of the Group was to l
provide procedural guidance for recovery from events with more than one l
dropped rod or for dropped rods that cause the reactor to go suberitical.
Toledo Edison is actively involved in this effort and, based on the recommendations of the Owners Group Steering Committee, vill continue to follow this subject, and others as identified, to further upgrade procedures 1
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as appropriate.
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Docht Number" 50-346
.j Lic;nss Numb;r NPF-3 S; rial Numbsr 1-875-
'l Attachrent-
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Page 6_
Date Vhen Full Compliance Vill Be Achieved Full compliance was achieved on March 15, 1989 when the CRD Malfunctions 1
procedure was revised.
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Dick 2tNuhbhr50-3461
.Lic:nra Numb 2r NPF-3
.Ssrial Numb 2r 1-875
- . Attachment
'Page'7 Violation.II.
10 CFR 50.72(b)(1)(ii)(c) requires'that the licensee shall notify the Nuclear Regulatory Commission (NRC) as soon as practical and in all cases _vithin one hour of any event or-condition during operation that results in the nuclear power plant-being in a condition not covered by the plant's-operating and emergency procedures.
Contrary to the above, on December 18, 1988 with the plant in Mode 3, a recovery from a multiple dropped control rod event, a condition not covered by plant operating and emergency procedures, was initiated and the NRC was not-notified of that condition within one hour.
Admission or Denial of the Alleged Violation Toledo Edison admits the alleged violation as stated.
Reason for the Violation Toledo Edison did not determine that the event was reportable until January 24, 1989.. Therefore, the need to report the event within one-hour in accordance with 10CFR50.72 was discussed with the NRC NRR Senior Project Manager for Davis-Besse on that date.
Subsequently, the Senior Resident Inspector for Davis-Besse stated he and the NRR Senior Project Manager had agreed no_immediate notification was warranted for the event. Toledo Edison admits its interpretation of "in operation", as discussed in the Log Number 1-2075. dated April 21, 1989, which transmitted the Notice of Violation, is in error.
Corrective Action Taken and Results Achieved Toledo Edison has redefined "in operation" as being opposite to the reactor being " shutdown".
" Shutdown" is now defined as "all regulating rods in the core and reactor shutdown margin being maintained." If regulating rods are not in the core or the required shutdown margin is not maintained by boration, the reactor vill be considered to be "in operation".
Corrective Action That Vill Be Taken to Avoid Further Violations Station procedure DB-TS-00004, Control of Condition Adverse to Quality, has been revised to incorporate the revised definition.
Date When Full Compliance Vill Be Achieved Full compliance has been achieved with the Revision to DB-TS-00004.
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