IR 05000346/1985040

Discusses Insp Rept 50-346/85-40 on 851104-860314 & Forwards Notice of Violation.No Civil Penalty Will Be Proposed for Violations.Corrective Actions Will Be Reviewed on case-by-case Basis & Appropriate Enforcement Action Taken

ML20204F374
Person / Time
Site:	Davis Besse
Issue date:	07/30/1986
From:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Smart P TOLEDO EDISON CO.
Shared Package
ML20204F379	List: IR 05000346/1985040 ML20204F415
References
EA-86-072, EA-86-72, NUDOCS 8608040171
Download: ML20204F374 (4)

Text

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) Ih1 WW July 30, 1986 Docket No. 50-346 License No. NPF-3 EA 86-72 Toledo Edison Company ATTN: Mr. Paul M. Smart President and Chief Operating Officer Edison Plaza 300 Madison Avenue Toledo, OH 43652 Gentlemen:

Subject: NOTICE OF VIOLATION (INSPECTION REPORT NO. 50-346/85040 [DRP])

This refers to the inspection conducted during the period of November 4, 1985 -

March 14, 1986 at the Davis-Besse Nuclear Power Station of activities authorized by NRC License No. NPF-3. The inspection identified violations of NRC requirements. A copy of the Inspection Report (50-346/85040 [DRP]) was sent to you by letter dated May 5, 1986. A number of violations addressed in the report were identified by your personnel and reported to the NRC. The violations were discussed with Mr. L. Storz of your staff on February 28 and March 28, 198 In response to previous violations for which civil penalties were assessed you committed to certain corrective actions. These corrective actions resulted in your identification of significant deficiencies in the design, control of design changes, testing, and corrective actions associated with the control room emergency ventilation system (CREVS). As a result, it was determined that the CREVS was not maintained in an operable status under certain condition In addition, the inspection indicated that you failed to provide a timely report to the NRC when the CREVS was found to be inoperable under certain condition Underlying these deficiencies was the lack of understanding on the part of Toledo Edison Company personnel of the requirement for operability of the CREVS subsystems to ensure that the CREVS remains operabl Item I in the enclosed Notice of Violation involves the failure to maintain both

trains of the CREVS operable under certain conditions. One condition occurred July 2 to August 4,1977 when both water and air cooled condensing units were simultaneously inoperable. The other condition existed possibly since initial plant operation and made CREVS inoperable when outside air temperatures were below 15 Item II in the enclosed Notice involves the failure of design and design change control measures which permitted the installation of additional electrical equipment in the control room and caused the design cooling capacity of the CREVS to be exceeded. In addition, the design control measures did not assure that piping was protected from tornado missiles as described in the Davis-Besse Updated Safety Analysis Report Section 9. I I j

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Toledo Edison Company 2 July 30, 1986 Item III involves the failure of testing programs to identify that air flow dampers operated improperly, that control circuits for service water supply valves prevented the valves from opening, and that door seal gaskets were not installed following door replacemen Item IV involves the failure of Toledo Edison Company personnel to take prompt corrective actions after it was identified that low temperatures made the CREVS inoperable and that a control room door did not have sealing casket Item V involves the failure to establish procedures regarding nonessential heat loads in the co, trol room to maintain the subsystems of the CREVS in an operable status to assure the operability of the CREV Item VI involves the failure to promptly notify the NRC under 10 CFR 50.72 of the inoperability of the CREVS when outside air temperatures were below 15 The root causes of these violations appear to be: Toledo Edison personnel did not clearly understand the function of the CREVS subsystems in assuring system operability; design and design control measures were not properly carried out; control room procedures were not established; surveillance and post-maintenance testing did not demonstrate that systems performed as intended; and corrective actions for identified deficiencies were not promptly take In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violations have been classified in the aggregate as a Severity Level III problem. Normally a civil penalty is considered for a Severity Level III violation or problem. However, after consultation with the Director, Office of Inspection and Enforcement, I have decided that a civil penalty will not be proposed in this case. The root causes for the violations appear to be the sane as for the violations associated with the 1985 loss-of-feedwater incident that resulted in the proposed 5900,000 civil penalty and previous escalated enforcement actions, and they predated the

$900,000 civil penalty. Subsequent to the June 9, 1985 loss-of-feedwater event, and in response to the proposed $900,000 civil penalty, Toledo Edison Company initiated extensive corrective actions to improve regulatory performance and made organizational changes to address the identified areas of concern. We have been monitoring the efforts in these areas and note that significant progress has been and is being made to identify and address deficiencies. Most of the violations described in the Notice of Violation were identified through your corrective action programs. In view of these circumstances, no civil penalty is being proposed for these violations. However, it should be noted that additional violations identified as a result of your corrective actions will be reviewed on a case-by-case basis and appropriate enforcement action may be take 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 to resolve the CREVS and similar design problems and any additional actions you plan to prevent recurrenc After reviewing your response to this Notice, including your proposed corrective actions, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirement .

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Toledo Edison Company 3 July 30, 1986 In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, i$tle 10, Code of Federal Regulations, a copy of this letter and the enclosures will be placed in the NRC's Public Document Roo The responses directed by this Notice, are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-51

Sincerely, OrJgical Jaues e, ;g)eppgergood by James G. Keppler Regional Administrator Enclosures: Notice of Violation cc w/ enclosures:

L. Storz, Plant Manager DCS/RSB (RIDS)

Licensing Fee Management Branch 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 30, 1986 D_i stribution:

POR LPDR NSIC SECY CA

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J. Taylor, IE

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J. Axelrad, IE H. Wong, IE J. Keppler, RIII J. Sniezek, DEDROGR F. Ingram, PA J. Lieberman, 0GC Enforcement Coordinators RI, RII, RIII, RIV, RV H. Denton, NRR B. Hayes, OI S. Connelly, OIA IE:ES File IE:EA File EDO Rdg File DCS NRC Resident Inspector State of Ohio Public Utility Commission

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