IR 05000237/1993006
| ML17179B003 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/15/1993 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Wallace M COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML17179B004 | List: |
| References | |
| EA-93-019, EA-93-19, NUDOCS 9307220026 | |
| Download: ML17179B003 (5) | |
Text
Docket Nos.
License Nos.
EA 93-019 UNITED STATES NUCLEAR REGULATORY COMMISSION REGION Ill 799 ROOSEVELT ROAD GLEN ELLYN. IWNOIS 60137-5927 July 15, 1993 50-237 and 50-249 DPR-19 and.DPR-25 commonwealth Edison Company ATTN:
Mr. Michael Vice President Chief Nuclear Officer Executive Towers West III, Suite 300 1400 Opus Place Downers Grove, Illinois 60515
Dear Mr. Wallace:
(
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL
. PE~ALTY -
~75,000
{INSPECTION REPORT NO. 50-457/93006)
This refers to the routine safety inspection conducted*during the period of December 14, 1992, to January 29, *1993, at the Dresden Nuclear Power Plant Units 2 and 3.
This inspection included a review of the circumstances surrounding the degraded containment cooling service water {CCSW) system flow identified on April 2, 1992.
The report documenting the inspection findings was mailed to you by letter dated February 12; 1993~
During the inspection, apparent violations of NRC requirements were identified.
An enforc~ment conference was held at the NRC's Region III office on February 22, 1993, to discuss the apparent violations.
Th~
enforcement conference report was sent to you by letter dated February 25, 1993.
.BY letter dated March 5, * 1993, you provided additional documentation to the NRC which supported your position.
The Off ice of Nuclear Reactor Regulation (NRR)
provided its response to that submittal in its July 12, 1993, letter from John Zwolinski.
on April 2, 1992, a test disclosed that the Dresden Unit 3 ccsw train flow (with two ccsw pumps running) was 5,600 gallons per minute (gpm) instead of the expected 7,000 gpm.
After determining that the system met the Technic~l Specification operability requirements.by demonstrating that each of the individual ccsw pumps would provide 3,500 gpm at 180 psig, the degraded flow issue was referred to your engineering staff for.
evaluation.
Your subsequent evaluations, culminating, with the 10 CFR 50.59 Safety Evaluation of December 1, 1992, concluded certified Mail Return Receipt Requested 9307220026 930715 *-
PDR ADOCK 05000237 G
PDR l:.*;*
., I
Commonwealth Edison Company
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that reductions in the ccsw heat removal capability were justified and that the design bases configuration of the ccsw system was one pump.
Two violations are described in Sectio*n I of the enclosed Notice of Violation and Proposed Imposition of civil Penalty (Notice)
which have collectively been categorized as a Severity Level III problem.
Both violation~ involve your failure to adequately evaluate changes made to the ccsw system described in the Final*
Safety Analysis Report (FSAR) in accordance with 10 CFR 50.59.
The first violation pertains to your failure to recognize the change as an unreviewed safety question.
The second violation pertains to inadequacies with your analyses which formed the bases for your conclusion that no unreviewed safety questions existed;
~he failure to perform adequate safety evaluations and to obtain Commission approval prior to accepting changes.to important systems such as the Dresden Station ultimate heat sink represents a significant safety and regulatory concern.
While changes to the ccsw system may have occurred without adequate evaluations several years ago, the focus. of this action is on the perf o~mance of your staff after identifying the degraded flow conditions in April 1992.
Specifically, we are concerned that your engineering staff put its effort toward explaining away the unexpected flow conditions, rather than fully and promptly exploring safety ramifications of the situation and*
taking corrective actions to restore the reduced flow.
Instead, from April to December 1992 you engaged in a series of partial or incomplete assessments to justify the as-found* condition of the ccsw system.
Each assessment ended when it appeared, at least on the surface, that there was no problem.
The assessments were inadequate in that they either (a) failed to address important factors which reduced the.margins of safety or (b) involved incorrect interpretation of licensing commitments.
More.
specifically, with regard to the latter concern,.your assessments were based on statements in the FSAR and other documents taken out of context.
Your handling of this issue reflects significant weaknesses in technical*support activities at Dresden. It underscores the importance of fully understanding the design of your facility.
We, therefore, *strongly encourage continued efforts to improve your knowledge of plant design including, among other things, the ongoing and planned initiatives.to reconstitute key design documents and parameters.
- The violations in Section I represent a significant failure to meet the requirements of 10 CFR 50.59.
Therefore, in accordance.
with the "General Statement of Policy and Pro.cedure for NRC Enforcement Actions," (Enforcement Policy) 10 CFR Part 2, App~ndix c, these violations have been categorized as a Severity
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- Commonwealth Edison Company
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Level III problem~
To emphasize the need to ensure that the facility as described in the FSAR is maintained or properly changed in accordance with the provisions of 10 CFR 50.59, I have been authorized, after consultation with the Director, Office of Enforcement and the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research to issue the enclosed Notice of Violation and Proposed Imposition of civii Penalty (Notice) in the amount of $75,000 for the violations set forth in Section I of the Notice.
The base value of a civil penalty for a Severity Level III problem is $50,000.
The adjustment factors in the Enforcement Policy were considered.
The civil penalty was increased 50%
($25,000) because the NRC identified the violation.
The other factors were considered and no other_ adjustment to the base was considered appropriate.
Section II of the Notice dontains a violation involving the failure to perform an adequate post-modification test on the Unit 2 CCSW when the system was modified to supply the backup control room ventilation system with cooling.
Finally, in light of the significant concerns raised above and in*
Mr. Zwolinski's letter concerning your submittal, I will be contacting you to arrange a meeting to discuss the quality of CECo submittals to the NRC.
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.
In light of y~:mr staff's statements at the enforcement*conference, your response should also address the specific actions you have taken or will take to ensure that the FSAR contains the necessary CCSW system design basis information and notes the presence of any FSAR information that should not be interpreted as system design basis information.
After reviewing your response*to this Notice~ including your proposed coirective 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.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice,"
a copy of this letter, its enclosure, and your response will be placed in the NRC Public Document Room.
_.,
Commonwealth Edison Company
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The response 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 t'Qe Pape.rwork Reduction Act
~ of 19 8 o, Pub 1 i c Law No. 9 6-511.
Enclosure:
John B. Martin Regional Administrator Notice of Violation and Proposed Imposition of Civil Penalty cc w/enclosure:
DCD/DCB (RIDS)
M. Lyster, Site Vice President L. DelGeorge, Vice President, Nuclear Oversight and Regulatory Services c. Schroeder, Station Manager
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J. Shields, Regulatory Assurance Supervisor D. Farrar, Nuclear Regulatory Services Manager OC/LFDCB
.Resident Inspectors LaSalle, Dresden, Quad Cities, Clinton Richard Hubbard J. W~ Mccaffrey, Chief, Public Counsel, State of Illinois Center
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_Commonwealth Edison Company DISTRIBUTION:
- -JPartlow, * NRR Enforcement Coordinators RI I RI I, RIV,. RV Fingram, GPA/PA DWilliams, OIG BHayes, OI EJordan, AEOD JLuehman, OE
_Day File EA File (2)
DCS State of Illinois J. Stang, Licensing Project Manager, NRR H.
Mil~er, Region III T. Martin, Region III J. Dyer, NRR c. Pederson, Region III M. Jordan, Region III s. Stasek, Region III E. Leeds, NRR RAO:RIII SLO:RIII PAO:RIII IMS:RIII.
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