IR 05000237/1996005
| ML17187A470 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 06/13/1996 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Maiman T COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML17187A471 | List: |
| References | |
| EA-96-115, NUDOCS 9606180245 | |
| Download: ML17187A470 (7) | |
Text
June 13, 1996
SUBJECT:
DRESDEN STATION - UNITS 2 AND 3 NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY -
Dear Mr. Maiman:
This refers to the inspection conducted on February 14 through April 1, 1996, at the Dresden Station.
The purpose of the inspection was to review the circumstances surrounding the failure to ensure corrective actions to restore design margins to the structural steel for the low pressure coolant injection (LPCI) corner rooms.
Commonwealth Edison personnel were aware of the design deficiency for over five years without effective resolution.
The report documenting the inspection was sent by letter dated April 11, 1996, and a pre-deci si ona l enforcement conference was conducted on May 1, 1996.
Based on the information developed during the inspection and the information that was provided during the conference, the NRC has determined that violations of NRC requirements occurred.
The violations are cited in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice)
and the circumstances surrounding the violations are described in detail in the subject inspectio~ report.
Design organization interface weaknesses in the 1980s allowed modifications to corner room piping supports without evaluating the impact on structural steel loading. Structural steel stress design margins were not met for seismic loading conditions.
The affected steel performed an important safety function, namely to support low pressure emergency core cooling system (ECCS)
piping and heat exchangers.
We are concerned that the engineering decision process failed to ensure timely action to restore design margins.
Commonwealth Edison was aware of the design deficiency s i nee 1991.
Subsequent to a January 1994 operability evaluation of this issue for both units, the Dresden engineering organization missed several opportunities to ensure more timely resolution of the deficiency.
As a result, a refuel outage was conducted*on Unit 3 in 1994 without addressing the structural steel design deficiency.
In late 1994, corrective action was further postponed due to other emerging issues.
The proposed structural steel 9606180245 960613 PDR ADOCK 05000237 G
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- modifications were presented for review and approval in late 1995, but the engineering process and management oversight were insufficient to adequately identify the importance of returning the required design margin to the structural steel.
Consequently, the modifications were further deferred until after the in-process Unit 2 refuel outage.
The Unit 2 modifications were completed during the refuel outage subsequent to the NRC raising questions concerning the significance of the issue and timeliness of corrective actions.
Unit 3 will remain uncorrected until the next refuel outage.
There were a number of root causes for the violations.
Some of these included inadequate turnovers between the multiple cognizant engineers as engineering functions were decentralized, and ineffective interfaces with the multiple architect engineering firms on-site. Because the technical knowledge on-site was not sufficient to recognize complex problems, input from contractors was not always evaluated or challenged.
More significantly and recently, insufficient engineering and management emphasis on maintaining Final Safety Analysis Report (UFSAR) design margins resulted in a failure to recognize the full safety significance of the deficiency during the decision process and resulted in its untimely resolution.
The failure to promptly correct this design deficiency in the installed structural steel is a significant regulatory concern.
Therefore, the violation in Section I of the Notice has been categorized in accordance with the General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, at Severity Level III.
In accordance with the Enforcement Policy, a base civil penalty in the amount of $50,000 is considered for a Severity Level III violation.
Because your facility has been the subject of escalated enforcement actions within the last 2 years
, the NRC considered whether credit was warranted for Identification and Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy.
Credit was not warranted for identification because the NRC identified the violation.
Credit was warranted for your comprehensive corrective actions.
Your short term actions included reviewing deficiency backlogs for other UFSAR nonconformances and operability concerns, defining an effective engineering management process, and conducting nonconforming condition process awareness training for engineering managers.
Your long term actions will include performing modification design control assessments involving one or two systems, implementing engineering management performance meetings, and conducting nonconforming condition awareness training for all sites.
Therefore, to emphasize the need to identify significant deficiencies requiring prompt corrective actions, and thereafter, take such actions, I have been authorized, after consultation with the Director, Office of Enforcement, to 1 A Severity Level III violation (identified in February 1994) and $75,000 civil penalty was issued on May 17, 1994 (EA 94-048) involving failure to promptly correct problems with reactor level instrumentation; a Severity Level III problem (identified in January 1995) and $100,000 civil penalty was issued on April 5, 1995 (EA 95-030); and a Severity Level III violation (identified in August 1995) and $50,000 civil penalty was issued on December 5, 1995 (EA 95-214). issue the enclosed Notice in the base amount of $50,000 for the Severity Level III violation.
Section II of the enclosed Notice describes one violation not assessed a civil penalty involving the failure to report a condition outside the design basis of the plant.
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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 addition to responding to the specific violations, please address the design control deficiencies that resulted in the structural steel design deficiency. After reviewing your response to this Notice, including your proposed corrective 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 (PDR).
To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction.
Docket Nos. 50-237; 50-249 License No~. DPR-19; DPR-25 Enclosure:
Sincerely,
- ip~~M--.
Hubert J. Miller Regional Administrator Proposed Imposition of Civil Penalty Distribution:
See attached list