ML20203G649
| ML20203G649 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, 05000000 |
| Issue date: | 04/23/1986 |
| From: | Eisenhut D Office of Nuclear Reactor Regulation |
| To: | Axelrad J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20197A618 | List: |
| References | |
| FOIA-86-684 EA-86-059, EA-86-59, NUDOCS 8604290211 | |
| Download: ML20203G649 (15) | |
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. APR 2 s ng MEMORANDUM FOR: Jane Axelrad, Director Enforcement Staff Office of Inspection and Enforcement FROM: Darrell G. Eisenhut, Deputy Director Office of Nuclear Reactor Regulation
SUBJECT:
ENFORCEMENT ACTION 86-59, PEACH BOTTOM, UNIT 3 The NRR staff has reviewed the enclosed draft enforcement package concerning two instances of personnel error by several licensed operators that are, in the Region's opinion, a continuation of a pattern of inattention to detail by plant staff. The first instance involved a failure on the part of the licensed operators to verify proper rod withdrawal when the Rod Worth Minimizer was out of service. The second instance cited was the failure of the Shift Superintendent and Shift Supervisor to verify proper rod position before the Rod Sequence Control System was bypassed. Both of these cited failures are Technical Specification violations. The Technical Specifications explicitly require that a second licensed operator verify that the operator at the reactor control console is following the control rod program when the Rod Worth Minimizer is out-of-service and verify that a control rod is in its correct position when the Rod Sequence Control System is bypassed.
Region I has proposed to treat these technical specification violations as a single Severity Level III violation with 100% escalation because of similar procedural errors such as two instances of excessive heatup rates in 1984 and an overpressurization of a reactor pressure vessel.
Based on our review of the draft enforcement package, we have concluded that the cited violations did occur and are related to a continuing pattern as charged. Therefore, we concur with the proposed enforcement action.
g:+f TJ.d D Darrell G. Eisenhut Deputy Director Offics of Nuclear Reactor Regulation
Enclosure:
Distribution As Stated Central File w/o Enclosure
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,/ APR 2 31986 MEMORANDUM FOR: Jane Axelrad, Director Enforcement Staff Office of Inspection and Enforcement FROM: Darrell G. Eisenhut, Deputy Director Office of Nuclear Reactor Regulation i
SUBJECT:
ENFORCEMENT ACTION 86-59, PEACH BOTTOM, UNIT 3 The NRR staff has reviewed the enclosed draft enforcement package concerning two instances of personnel error by several licensed operators that are, in the Region's opinion, a continuation of a pattern of inattention to detail by plant staff. The first instance involved a failure on the part of the licensed operators to verify proper rod withdrawal when the Rod Worth Minimizer was out of service. The second instance cited was the failure of the Shift Superintendent and Shif t Supervisor to verify proper rod position before the Rod Sequence Control System was bypassed. Both of these cited failures are Technical Specification violations. The Technical Specifications explicitly require that a second licensed operator verify that the operator at the reactor control console is following the control rod program when the Rod Worth Minimizer is out-of-service and verify that a control rod is in its correct position when the Rod Sequence Control System is bypassed.
Region I has proposed to treat these technical specification violations as a single Severity Level III violation with 100% escalation because of similar procedural errors such as two instances of excessive heatup rates in 1984 and an overpressurization of a reactor pressure vessel.
Based on our review of the draft enforcement package, we have concluded that the cited violations did occur and are related to a continuing pattern as charged. Therefore, we concur with the proposed enforcement action.
i Darrell G. Eisenhut, Deputy Director Office of Nuclear Reactor Regulation r
Enclosure:
As Stated CONTACT:
R. Scholl, ORAS X28443 l
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FROM: AXELRAD ORIO. DUE DATE: 04/22/86 TICKET NO: 869159 DOC DATE: 04/08/82 TO: EISENHUT NRR RCVD DATE: 04/09/84
- YELLOW **
FOR SIONATURE OF: DENTON DESC: CC:
PROPOSED CIVIL PENALTY - PEACH BOTTOM, UNIT 3 DENTON/EISENHUT PPAS MOSSBURG/ TOMS REFERRED TO: ORAS 040986 CONTACT: M . .
PLEASE REVIEW THE DUE DATE IMMEDIATELY:
IF THE DUE DATE DOES NOT ALLOW ADEQUATE REQUESTS FOR REVISION OF YELLOW TIME TO RESPOND TO THIS TICKET, YOU MAY TICKET DUE DATES MAY BE MADE, WITH REQUEST A REVISED DUE DATE. THE REQUEST JUSTIFICATION, THRU THE WEEKLY WITS MUST INCLUDE A VALID JUSTIFICATION AND UPDATE UP TO ONE WEEK AFTER ASSION-BE MADE THROUGH YOUR CORRESPONDENCE CO- MENT BY NRR MAIL ROOM. THE NEW DUE ORDINATOR TO THE NRR MAIL ROOM (DORIS DATE, IF APPROVED BY NRR MAILROOM, MOSSBURO, -28970) WILL BE USED TO TRACK DIVISION COR-RESPONDENCE COMPLETION SCHEDULES.
PLEASE DO NOT HAND CARRY CONCURRENCE PACKAGES TO DIRECTORS OFFICE
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WITHOUT FIRST OOING THRU THE NRR MAIL ROOM.
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%.....M FROM: AXELRAD ORIO. DUE DATE: 04/22/86 TICKET NO: 869159 DOC DATE: 04/08/86 TO: EISENHUT NRR RCVD DATE: 04/09/86
- YELLOW **
FOR SIGNATURE OF: DENTON DESC: CC:
PROPOSED CIVIL PENALTY - PEACH BOTTOM, UNIT 3 DENTON/EISENHUT PPAS MOSSBURG/ TOMS REFERRED TO: ORAS 040986 CONTACT: HOLAHAN I
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PLEASE REVIEW THE DUE DATE IMMEDIATELY:
IF THE DUE DATE DOES NOT ALLOW ADEQUATE REQUESTS FOR REVISION OF YELLOW TIME TO RESPOND TO THIS TICKET, YOU MAY TICKET DUE DATES MAY BE MADE, WITH REQUEST A REVISED DUE DATE. THE REQUEST JUSTIFICATION, THRU THE WEEKLY WITS MUST INCLUDE A VALID JUSTIFICATION AND UPDATE UP TO ONE WEEK AFTER ASSIGN-BE MADE THROUGH YOUR CORRESPONDENCE CO- MENT BY NRR MAIL ROOM. THE NEW DOE ORDINATOR TO THE NRR MAIL ROOM (DORIS DATE, IF APPROVED BY NRR MAILROOM, MOSSBURG, -28970) WILL BE USED TO TRACK DIVISION COR-RESPONDENCE COMPLETION SCHEDULES.
PLEASE DO NOT HAND CARRY CONCURRENCE PACKAGES TO DIRECTORS OFFICE
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WITHOUT FIRST GOING THRU THE NRR MAIL ROOM.
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FILE ORIGINAL IN:
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HOLOHAN (NRR)
R SURNETT Thank you, Jane A. Axelrad Of rector Enforcement Staff IF YOU HAVE COMNTS, PLEASE CONTACT RDIGER AYS OR J. AXE IF AT ALL POSSISLE.
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MEMORANDUM FOR: James M. Taylor, Director, IE FROM: Thomas E. Murley, Regional Administrator, RI
SUBJECT:
PROPOSED CIVIL PENALTY - PEACH BOTTON, UNIT 3 Enclosed for your review and concurrence is a proposed enforcement action (letter and " Notice of Violation and Proposed Imposition of Civil Penalty") for two violations of the technical specifications which occurred at Peach Bottom, Unit 3. The violations involved (1) failure of two licensed operators to implement required procedural controls while the Rod Worth Minimizer was inoperable, and (2) failure of the Shift Superintendent and Shift Supervisor, 4
both of whom are senior licensed operators, to implement required procedural controls prior to bypassing the Rod Sequence Control System (RSCS). Specifi-cally, a licensed operator withdrew a control rod from the reactor in the wrong sequence, and he continued to withdraw additional control rods without the assigned second licensed operator detecting the error. Further, when the RSCS subsequently prevented further rod withdrawal, the Shift Superintendent and Shift Supervisor bypassed the RSCS without assuring that the second licensed operator verified the correct position of the specific control rod.
l The two violations, which are more fully described in the enclosed proposal, are categorized in the aggregate at Severity Level III to focus on personnel errors by licensed individuals resulting from failure to follow procedures. As discussed in our proposed transmittal letter to the licensee, we believe that escalated enforcement action is appropriate because of company management's responsibilities i fostering good work practices and attitudes in the conduct y of operations. We80tbelievethattheselatestpersonnelerrorsareisolated cases but in fact e the result of an underlying management problem reflected by the attitude of the station staff toward procedural adherence. Although the base civil penalty amount for a Severity Level III violation is $50,000, we
! propose an increase in the civil penalty amount by 100% because (1) numerous
' licensed individuals had an opportunity to identify and correct the error, but the error went undetected until the Rod Worth Minimizer was subsequently made operable, and (2) other past enforcement actions at Peach Bottom have resulted from violations caused by personnel errors.
f Please note that this memo and Enclosure 1 are being sent on this date to you, the Director of Enforcement, and ELD via the 5520. Enclosure 2, the inspection I
0FFICIAL RECORD COPY CP PKG PEACH BOTTOM - 0001.0.0 03/28/86
James M. Taylor 2 report, was issued on March 25, 1986 and was previously sent to the Director of Enforcement, IE, and ELD via the Document Control Room as part of the standard distribution list for all inspection reports.
Thomas E. Murley Regional Administrator
Enclosures:
- 1. Proposed Letter and " Notice of Violation and Proposed Imposition of Civil Penalty"
- 2. Inspections Report No. 50-278/86-09 cc w/encls:
Enforcement Coordinators RII, RIII, RIV, RV J. Lieberman, ELD J. Axelrad, IE K. Abraham, PA0
. blind 2 2 RI:ES RI:DRP RI:RC RI:DRA RI:RA Holody/geb Starostecki Gutierrez Allan Murley 4/ /86
,end
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- f Docket No. 50-278 License No. DPR-56 EA 86-Philadelphia Electric Company ATTN: Mr. S. Daltroff Vice President Electric Production 2301 Market Street Philadelphia, Pennsylvania 19101 Gentlemen:
Subject:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC Inspection Report No'. 50-278/86-09)
On March 18-21, 1986, an NRC special safety inspection was conducted at the Peach Bottom Atomic Power Station, Unit 3, to review the circumstances associated with the withdrawal of a control rod during reactor startup in a sequence different from that specified in the control rod program. The inci-dent, which resulted in two violations of the station's technical specifica-l tions, was identified by members of your staff and promptly reported to the NRC. The details are provided in the inspection report sent to you on March 25,1986. On March 27, 1986, an enforcement conference was conducted with Mr. V. Boyer and you, and members of your staffs to discuss the incident, the related violations, their causes, and your corrective actions.
These violations resulted from numerous personnel errors by several licensed
! personnel, including the Shift Supervisor and Shift Superintendent, both of whom are senior licensed operators. The incident was initiated when the licensed operator in control of the startup made an error in withdrawing the wrong control rod from the core. The Rod Worth Minimizer, designed to detect such an occurrence, was inoperable at the time. Although a second licensed operator had been assigned to independently verify correct rod selection and withdrawal sequence, he did not identify this error. Further, when the Rod Sequence Control System (RSCS) subsequently prevented further rod withdrawals because the specific missed rod had not yet been withdrawn, the Shift Supervisor and Shift Superintendent, both of whom were supposed to be overseeing and managing the startup activities, apparently assumed the missed rod was in the " full out" position, and they physically performed the 1
manipulation to bypass the RSCS position for that rod to the " full out" posi tion. This was done without assuring that the second licensed operator had verified the rod's position. The printout from the plant process computer at this time also showed the affected rod to be out of position, but the printout apparently was not examined.
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Philadelphia Electric Company 2 These personnel errors by four licensed individuals demonstrate a continuation of a pattern of inattention to detail by plant staff at Peach Bottom in not adhering to procedural requirements, and also appear to represent a complacent attitude by the staff toward performance of their duties. For example, on June 21,1985, an enforcement conference was conducted with you and members of your staff to discuss the apparent inattentiveness of a licensed operator while at the controls of the reactor. Further, on June 18, 1984, a $30,000 civil penalty was issued for violations of the station's technical specifications, including violations that resulted from personnel errors, such as two instances when heatup rates were exceeded, and one instance when the reactor vessel was pressurized above limits. This latest incident demonstrates that the corrective actions taken to prevent such lapses have not oeen effective.
In addition to these personnel errors by licensed individuals, two civil penalties, in the respective amounts of $100,000 and $40,000 were issued in 1983 for four violations of containment integrity that resulted from the failure of nonlicensed individuals to follow procedures. The NRC is concerned that this history of personnel errors by both the licensed and nonlicensed staff at Peach Bottom indicates there is an apparent complacency that results in a poor attitude toward adherence to plant procedures, and there has developed poor work practices that result in lack of attention to detail in performing duties.
We view such problems as being indicative of a lack of management involvement and attention in station activities to assure that the station personnel respect, understand the need for, and adhere to your policies and procedures for the safe operation of the facility. It is for this reason that this proposed enforcement action is being taken against the Philadelphia Electric Company and not the individual licensed operators.
To emphasize the need for increased management involvement and attention in station activities to assure improved personnel performance, I have been authorized, after consultation with the Director, Office of Inspection and Enforcenent, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of $100,000 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 (1985), the violations have been categorized in the aggregate as a Severity Level III problem. The base civil penalty for a Severity Level III violation or problem is $50,000. However, the civil penalty has been increased by 100% because (1) several personnel had an opportunity to detect and correct the problem, but the error went undetected until the Rod Worth Minimizer was subsequently made operable, and (2) the enforcement history at Peach Bottom in the area of procedural adherence has not been good. Although each violation could be separately classified at Severity III, the violations have been categorized in the aggregate since they both involve the failure of licensed personnel to follow procedures.
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Philadelphia Electric Company 3 In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,
-Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
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 by the Paperwork Reduction Act of 1980, PL 96-511.
Sincerely, Thomas E. Murley Regional Administrator
Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty cc w/ encl:
R. S. Fleischmann, Manager (Receives All 2.790 Information)
John S. Kemper, Vice President, Engineering and Research Troy B. Conner, Jr. , Esquire W. H. Hirst, Director, Joint Generation Projects Department, Atlantic Electric Eugene J. Bradley, Esquire, Assistant General Counsel (Without Report)
Raymond L. Hovis, Esquire Thomas Magette, Power Plant Siting, Nuclear Evaluations (Without Report)
W. M. Alden, Engineer in Charge, Licensing Section Public Document Room (PDR) local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector Commonwealth of Pennsylvania
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- Philadelphia Electric Company 4
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bec w/ encl:
kegion I Docket Room (w/ concurrences)
SECY CA J. Taylor, IE J. Axelrad, IE T. E. Murley, RI J. Lieberman, ELD J. Sniezek, DED/ROGR Enforcement Coordinators RI, RII, RIII, RIV, RV F. Ingram, PA J. Crooks, AE0D B. Hayes, 01 S. Connely, OIA L. Cobb, IE V. Miller, NMSS D. Nussbaumer, OSP IE/ES File IE/EA File ED0 Rdg File DCS
,end
, blind 2 2 RT:ES RI:DRP RI:DRP RI:DRP RI:RC Holody/geb Gallo Collins Starostecki Gutierrez RI:DRA RI:RA ELD IE:ES IE:DD Allan IE:D Murley Lieberman Axelrad Vollmer Taylor 4/ /86
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NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Philadelphia Electric Company Docket No. 50-278 Peach Bottom, Unit 3 License No. DPR-56 EA 86-On March 18-21, 1986, an NRC inspection was conducted to review the circumstances associated with the withdrawal of a control rod from the reactor during reactor startup in a sequence different than that specified in the control rod program. This incident was identified by the licensee and promptly reported to NRC. During the review of this incident, two violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant I to section 234 of the Atomic Energy Act of 1984, as amended ("Act"), 42 U.S.C.
2282, PL 96-265, and 10 CFR 2.205. The particular violations and the associated civil penalty are set forth below.
A. Technical Specification Limiting Condition for Operation 3.3.B.3.b requires that whenever the reactor is in the startup or run mode below 25% rated power, the Rod Worth Minimizer shall be operable or a second licensed operator shall verify that the operator at the reactor console is following the control rod program.
Contrary to the above, at 1:28 a.m. on March 18, 1986, while the reactor was in the startup mode below 25% power and the Rod Worth Minimizer was inoperable, a licensed operator erroneously withdrew control rod 10-23 rather than control rod 02-23 as specified by the control rod program, and at the time, a second licensed operator did not properly verify rod i selection in that the wrong control rod was withdrawn.
B. Technical Specifications Limiting Condition for Operation 3.3.B.3.a and 3.3.A.2.d require that whenever the reactor is in the startup or run mode below 21% rated power, the Rod Sequence Control System shall be operable, and no position switches shall be bypassed unless the rods are moved in sequence to their correct position and the actual rod position is known.
Technical Specification Surveillance Requirement 4.3.A.2.d requires a second licensed operator to verify that a control rod is in its correct position before the RSCS function is bypassed.
Contrary to the above, between 2:30 and 2:55 a.m. on March 18, 1986, when a Group 3 rod withdrawal was attempted while the reactor was in the startup mode below 21% rated power, a rod block occurred because control
, rod 02-23 was " full-in" and out of sequence, and the RSCS position switch for this rod was bypassed to " full-out" position by the Shift Supervisor and Shift Superintendent without verification by a second licensed operator that control rod 02-23 was actually in that position.
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, 03/28/86
2 These violations a're categorized in the aggregate at Severity Level III (SupplementI)
Civil Penalty - $100,000 Pursuant to the provisions of 10 CFR 2.201, Philadelphia Electric Company is hereby required to submit to the Director, Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission, Washington,.D.C. 20555 with a copy to the Regional Administrator, USNRC Region I, 631 Park Avenue, King of Prussia, Pennsylvania 19406, within 30 days of the date of this Notice, a written statement of explanation in reply, including for each alleged violation, (1) admission or denial of the alleged violation, (2) the reasons for the violation, if admitted, (3) corrective steps that have been taken and the results achieved (4) the corrective steps that will be taken to avoid further violations, and (5) the date when full compliance will be achieved.
Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
Within the same time as provided for the response required above under 10 CFR 2.201, Philadelphia Electric Company may pay the civil penalty in the amount of One Hundred Thousand Dollars ($100,000) or may protest imposition of the civil penalty in whole or in part by a written answer. Should Philadelphia Electric Company fail to answer within the time specified, the Director, Office of Inspection and Enforcement, will issue an Order imposing the civil penalty in the amount proposed above. Should Philadelphia Electric Company elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, such answer may: (1) deny the violations listed in this Notice, in whole or in part, (2) demonstrate extenuating circumstances (3) show error in '
this Notice, or (4) show other reasons why the penalty should not be imposed.
In addition to protesting the civil penalty in whole or in part, such answer may request remission or mitigation of the penalty. In requesting mitigation of the proposed penalty, the five factors contained in Section V.8 of 10 CFR Part 2, Appendix C, should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. The attention of Philadelphia Electric Company is directed to the other provisions of 10 CFR 2.205 regarding the procedure for imposing a civil penalty.
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3 Upon failure to pay any civil penalty due, which has been subsequently
' determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282.
FOR THE NUCLEAR REGULATORY COMMISSION Thomas E. Murley Regional Administrator Dated at King of Prussia, Pennsylvania this day of April 1986
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