ML20129D762

Discusses Insp on 850409-0531 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty.Actions Taken to Address Concerns of 1982 & 1983 SALPs Ineffective & Causes of Violations Similar to Failures Noted in Current Insp

ML20129D762
Person / Time
Site:	Davis Besse
Issue date:	07/12/1985
From:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Williamson J TOLEDO EDISON CO.
Shared Package
ML20129D766	List: ML20129D762 ML20129D801
References
EA-85-071, EA-85-71, NUDOCS 8507160645
Download: ML20129D762 (4)

See also: IR 05000409/2005031

Text

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July 12, 1985 /

Docket No. 50-346

EA 85-71

Toledo Edison Company

ATTN: Mr. John P. Williamson

Chairman and Chief Executive Officer

Edison Plaza

300 Madison Avenue

Toledo, OH 43652

Gentlemen:

This refers to the safety inspection conducted by Messrs. W. Rogers, D. Kosloff,

and M. Ring of the Region III staff during the period April 9 - May 31, 1985

of activities authorized by Operating License No. NPF-3 for the Davis-Besse

Nuclear Power Station. Three violations of Technical Specification and

procedural requirements, as well as other failures to comply with NRC regulatory

requirements, were identified during this inspection. The results of this

inspection were discussed on May 24, 1985 during an Enforcement Conference

held in the Region III office between Mr. R. P. Crouse and others of your

staff and myself and others of the NRC staff.

Violation I in the enclosed Notice of Violation and Proposed Imposition of

Civil Penalty (Notice) involved a failure to effectively implement a program

in which the operating status of equipment was to be made known to cognizant

plant personnel at all times. This failure was a result of inadequate

communications between security and operations personnel. Specifically, on

April 9, 1985, the security-fire / radiation computer was taken out of service and

the shift supervisor was not notified at the time the computer was actually

shutdown. The shift supervisor did not learn of the computer shutdown until

he discovered it two hours later. As a result, while the computer was shutdown,

the shift supervisor was unable to take timely compensatory measures to ensure

adequate fire protection controls were maintained. We are aware that additional

compensatory measures were not actually necessar3 because measures had already

been taken in response to other problems related to fire protection. However,

the pre existing compensatory measures do not excuse the inadequate communications

between the security and operations personnel.

Violation II in the enclosed Notice involves failure to monitor pipe leakage

from the Startup Feedwater Pump / Turbine Cooling Water systems. Monitoring was

specifically required by a License Condition because pipe leakage or rupture

in this area had not been analyzed for the effects of jet impingement, pipe

whip, and flooding upon the auxiliary feedwater pumps. On April 24, 1985,

the non-licensed operator who had been assigned to monitor the Startup Feedwater

Pump / Turbine Plant Cooling Water piping status in the Auxiliary Feedwater Pump

CERTIFIED MAIL

RETURN RECEIPT REQUESTED

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Toledo Edison Company -2- July 12, 1985

Room was found by an NRC inspector to be asleep. Therefore, he would not have

been able to perform his required function which was to trip the Startup Feedwater

Pump locally or notify the Control Room operator to trip the pump if leakage

occurred. We are also concerned that corporate management was not promptly

informed of this incident by site management.

Violation III in the enclosed Notice involves the failure to maintain proper

reactor power for the indicated reactor coolant flow rate. On April 19 and 20,

1985, the licensee recorded reactor coolant flow rate values approximately 2%

below the Technical Specification flow rate limit. Licensee personnel failed

to recognize that a valved-out component continued to provide erroneous input

to the computer heat balance calculation. This affects the operator's primary

indication of thermal power and as a result, the thermal power was not reduced

to the correct thermal power limit required by Technical Specification requirements.

To emphasize the importance of effective communications within your organization

to ensure that when problems are identified, root causes are found and adequate

corrective actions are taken, 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 cumulative amount

of One Hundred Thousand Dollars ($100,000). These violations are categorized

as a Severity Level III problem in accordance with the " General Statement of

Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C

(1985). The base civil penalty for a Severity Level III problem is $50,000.

However, the base amount has been increased by 100% because of Davis-Besse's

previous poor performance discussed below.

During a September 23, 1982 Systematic Assessment of Licensee Performance (SALP),

we identified weaknesses in the licensee's ability to recognize requirements

for equipment operability. In March of 1983, as a result of an Enforcement

Conference, the licensee committed to implement a Comprehensive Corrective

Action Program to address these and other concerns. These concerns were

expressed again during an October 28, 1983 SALP. However, actions taken to

address these concerns were ineffective and similar violations were identified

which resulted in the issuance of a Notice of Violation and Proposed Imposition

of Civil Penalties in November 1984. This enforcement action was based on

failures to ensure that the status of plant equipment was understood by the

responsible individuals and failure to take adequate corrective actions. The

air conditioning portions of both trains of the Control Room Emergency Ventilation

System were removed from service without complying with station procedures,

thus rendering the system inoperable in violation of Technical Specification

requirements. In addition, removal of one of two Number One Emergency Diesel

Generator ventilation fans for maintenance made the Number One Emergency Diesel

Generator inoperable and Technical Specification action statements could not

be satisfied due to the failure of the licensee to recognize this condition.

Problems were also identified with the Startup Feedwater Pump System, yet the

licensee failed to ensure that adequate actions were taken to correct the

problems identified and to preclude repetition of the problems.

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Toledo Edison Company -3- July 12, 1985

The causes of the previous violations were similar to some of the failures identified

during the April 1985 inspection which are the subject of the enclosed Notice,

and it appears that the licensee still has not developed adequate management

controls to ensure that problems are communicated to the appropriate responsible

individuals so that root causes can be identified and generic corrective actions

taken. As is evident from the recent events which occurred on June 9, 1985,

problems continue to exist at Davis Besse and additional enforcement action may

be required.

You are required to respond to the enclosed Notice and you should follow the

instructions specified therein when preparing your response. Your reply to this

letter and the results of future inspections will be considered in determining

whether further enforcement action is warranted.

In accordance with 10 CFR 2.790, " Rules of Practice," a copy of this letter and

the enclosure will be placed in the NRC Public Document Room.

The responses directed by this letter and the accompanying Notice are not subject

to the clearance procedure of the Office of Management and Budget as required by

the Paperwork Reduction Act of 1980, PL 96-511.

Sincerely.

Oricinal 3ig,ed by

00 Gs Vm plar

James G. Keppler

Regional Administrator

Enclosures:

1. Notice of Violation and

Proposed Imposition of

Civil Penalty

2. Inspection Report

No. 50-346/85018(DRP)

cc w/ enclosures:

R. P. Crouse, Vice President Nuclear

S. Quennoz, Station Superintendent

DMB/ Document Control Desk (RIDS)

Resident Inspector, RIII

Harold W. Kohn, Ohio EPA

James W. Harris, State of Ohio

Robert H. Quillin, Ohio

Department of Health

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Toledo Edison Company -4- July 12, 1985

Distribution

PDR

SECY

CA

ACRS

JTaylor, IE

RVollmer, IE

JKeppler, RIII

JAxelrad, IE

JCollins, IE

ABBeach, IE

JLieberman, ELD

VStello, DED/ROGR

Enforcement Coordinators

RI, RII, RIII, RIV, RV

HDenton, NRR

BHayes, 01

SConnelly, OIA

FIngram, PA

JCrook, AE00

EJordan, IE

JPartlow, IE

BGrimes, IE

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