IR 05000237/1996014
| ML17187A980 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 05/21/1997 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Jamila Perry COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML17187A981 | List: |
| References | |
| 50-237-96-14, 50-249-96-14, EA-96-532, NUDOCS 9705270293 | |
| Download: ML17187A980 (7) | |
Text
SUBJECT:
NOTICE OF VIOLATION May 21, 1997
. (NRC.RESIDENT INSPECTION REPORT 50-010/237/249/96014(DRP)) *
Dear Mr. Perry:
.
This refers to t.he inspection conducted from October 21 through December 6.
1996. at the Dresden.Station Unit 2 and 3 facilities.
The inspection included a review of the failure to adequately test the control room emergency
- ventilation system to ensure it conformed to its design basis.. The written results of this inspection*were provi.ded to you on February 4.~ 1997.
A predecisional enfor~ement conference was* conducted o~ February 28. -l997.
Based on the in~ormation developed during the inspection.and the inf6rm~ti~ri.
that you and your staff provided during the conference. the NRC has determined that a violation of NRC requirements occurred.
The violation is cited in the enclosed Notice of* Violation (Notice) and the circumstances surrounding it are described in detail in the subject inspection report.
The control room ventilation system had not been maintained or properly tested to ensure that the system operated within its'.design basis. and was declared inoperable on October S. 1996.
Several control room modifications. which ha.d not.*b.een completed. contributed to.the inability to pressurize the control room as
~tated in the Updated* Final Safety:Analysis Report (UFS~R). The modifications resulted in the inability to maintain the control room at a positive pressure during nor~al operations and at a.positive.pressure of 1/8-inch water-gauge (iwg) during emergency pressurization modes. with respect to adjacent areas.
Post modification testing.was not performed for a*1999 modification of the Unit 1 to Unit 2/3 control room fire-wall.
Following the. completion of this
- modification in May 1993. inadequate surveillance tests were performed on the emergency ventilation system.
Specifically. the surveillance procedure only required 118 iwg positive pressure. in the control room and did not ensure that.
pressure was greater than 1/8 iwg*for the surrounding areas.* In addition. * *.
instrumentation used to verify that the control room pressure was positive in the emergency mode had not been calibrated. and had not been installed in accordance with the piping and instrumentation diagram.
The instrumentation 9705270293 970521 PDR ADOCK 05000237 G
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J. used to verify the control room differential pressure also was not calibrated and was not verified to be appropriate for the parameters being measured.
Control room instrumentation was mislabeled with respect to the areas being sensed and. according*to the drawings. other sensing lines were nqt properly routed or were broken.
The safety significance of this issue was related to the potentially increased radiological consequences to control room operators-during a postulated design bas*is accident. Since the ventilation system was unable to maintain the required positive pressure during the emergency modes. an increased inleakage was *likely to occur during the design basis' accident.
Using this increased inleakage in conjunction with the dose calculation performed in the UFSAR. the dose limits established by 10 CFR 50. Appendix A. General* Design Criterion 19.
for control room operators potentially would have been exceeded.
The barriers i~ place to ensure these limits would not be exceeded failed. Specifically, post~modification testing was not performed. and surveillance testing was
_inadequate.
While this condition was identified on September 26. 1996. it is possible that the control room emergency ventilation system had not.met it~
design basis since the 1989 modification was comple_ted.
In addition. from January 16 to Maj 28. 1995. leakage from the Unit 3 main steam line drairi
- primary containment isolatfon va-lves would have exceeded accident analysis assumptions during a-postulated design basi~ accident..
During this period~ it ts quite likely~that the accident dose to control room o~erators would have exceeded regulatory requirements.
- *
"
. '
. '
The failure to perfor~ post~mod~fication te~ting of the co~trol room emergency-_
.ventilation system to ensure design requirements were maintained is of.concern because design modification testing controls ~ere inadequate to ensur~ that system operab.ility was maintained.* In* addition. engineering.backlog reviews conducted by your staff.in the spring of 1996 failed to*identify the potential fQr significant system degradati6n due to the open control room ffiodification patkages.
As a result. the control room was found not capable of maintaifiing the required positive pressure or in-le.akage limitations..
The as.:found degradation was significant in that the potential may have existed for control room radiological dos.es to be in excess* of regulatory limits following a design basis acci~ent. Therefore. this violation has b~en categorized in accordance with the '!General Statement of Policy and Procedure for NRC Enforcement Actions (Enforcement Policx). NUREG-1600 at Severity Level Ill..
In accordance with the Enforcemeni Policy. a base civil penalty in the amount of $50.000 is considered for a Severity Level III. violation, Because Dresden Station has been the subject of escalated enforcement actions within the last 2 years. the NRC considered whether credit wa~ warranted for Identification
J.. and Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy.
The NRC determined that credit for Identification was warranted because on September 26. 1996. while closing out the open 1989 modification. the cognizant system engineer noted that there was no differential pressure between the control room and the outside hallway.
This observation prompted the performance of~ test to determine the actual *
control room to outside air dif.ferential pressure.
On October 7. 1996. when the testing was performed. it was determined that the system was unable to maintain the required positive 1/8 iwg pressure in the control room with respect to all adjacent areas.
The system was declared inbperable on October 8. 1997.
The NRC determined that credit for Corrective Action was warranted based cin your staff's prompt and thorough corrective action.s.
I11imediate
corrective actions included sealing system duct work and control rqom emergency zone penetrations. removing wallboard and cabinets to allow access to walls for leak identification and sealing. and properly identifying*
i nsta 11 ed i n.strumentat ion.
Dresden personnel al so notified Quad Cities of potential problems with adequacy.of control room emergency ventilation system testing.
The ~antral room ventilation system was rest~red to full operability on January 21. 1997: after the repairs were completed. the pressurization requirements were verified. the control room differential pressure instruments were repaired. the original test engineer qualifications were revoked.
.
management oversight was improved. and the post modification testing program*
was imp roved.*
. Therefore. to \\:ncourage pr.ompf i dent if i cation and ccimprehens i ve correction.. of
- violations. I hav~ been authorized. after consultation with the Director.
. *
Office of Enforcement. not to propose a civil penalty in.this case.
Howev~r..
significant violations in the future could result in a ciVil penalty.
The NRC has concl~ded that information regarding the reason for the vio)ation.*. *
the corrective actions taken and planned to correct the violation and prevent *
recurrence and th~ date when full compliance was achieved is already adequateJy addressed.on the docket in LER 96-017: as supplemented. and the information you provided at the *predecisional enforcement conference which is
- attached to our letter to you dated March 26. 1997. Therefore. you arB not required to respond to thi~ letter unless the description therein does not accurately reflect your correcti~e actions or your position.
In that case. or if you choose to provide additional information~ you should follow the instructions specified in the enclosed notice.
Docket Nos.. 50-237: 50-249 License Nos.
DPR-19~ DPR-25 *
Enclosure:
Noti~e of Violation
Sincerely
.
Original signed by James l. Caldwell (fo.r)
. A. Bi 11 Beach Regional Administrator
. SEE PREVIOUS CONCURRENCE DOCUMENT NAME:
G~\\EICS\\96-532.WSl OF IC RII NAME e m Grant OAT
J. S.. Perry-3-and Corrective Action in accordance with the civil penalty assessment process in *section VI.B.2 of the Enforcement Policy.
The NRC determined that credit for Identification was warranted because on September 26. 1996. while closing out the open 1989 modification. the cognizant system engineer noted.that there was no differential pressure between the control room and the outside hallway.
This observation prompted the performance of a test to determine the actual control room to outside air differential pressure.
On October 7. 1996. when the testing was performed. it was determined that the sy~tem was unable to maintain the required.positive 1/8 iwg pressure in the control room with respect to all adjacent areas.
The system was declared inoperable on October 8. 1997.
The NRC determined that credit for Corrective Action was warranted based on your staff'.s prompt and thorough corrective actions.
Immediate corrective actions included sealing system duct work and control room emergency zone penetrations. remo~ing wallboard and cabinets to allow access to walls for leak identification and sealing. and properly *identifying installed i ristrumentati on.
Dresden personne 1 a 1 so.r:1oti fi ed Quad C.iti es of potential problems with adequacy of control room emergency ventilation system testing.
The control room vent.ilation system wa~ restored to full operability on January 21. 1997. after the repairs were completed. the pres-surization requirements were verified. the control room differential pressure instruments were repaired. the original test engineer qualifications were-.revoked.
management oversight was improved~ and the post modification testing program *
was imp roved.
- Therefore. *to encourage prompt j dent i fi cation and comprehensive corr.ect i ori. of violations. I have been authorized. after consultatiorl'with the Director.
. Office o_f Enforcement. not to propose a ci vi 1 pena 1 ty in this case.
However.
- **
- s.lgnificant Violations in the future coU*ld result in a civJl penalty.
.
.
.
-
. The NRC-has concluded that inform9tion regardjng the reason for the violat.ior:r.
the corrective actions taken and planned to correct the. violation and prevent-recurrence and the date when full comp 1 i ance was achieved is a 1 ready *:
~ *
adequately addressed on the docket in LER:96-017, as supplemented~ and th~.
information you provided at the. predec.isional enforcement conference which is
- attached to our letter to you dated March 26. 1997. Therefore. you are not.
required to respond to this 1 etter* un 1 ess the description therein doe*s not.
accurately reflect your corrective actions or your position.. In that case. or ff you choose to prcivi de addi ti ona 1 information. you shou 1 d foll ow the* *
instruction~ specified in the enclosed notice, *
- Docket Nos: 50-237: 50-249 License Nos. DIR-19: DIR-25 Enc 1 osure:
Notice of Vi o 1 at ion
Sincerely
.
A. Bill Beach*
Regional Administrator
- SEE PREVIOUS CONCURRENCE DOCUMENT NAME:
G:\\EICS\\96-532.WSl OFFICE NAME Grant *
DATE
J. S.. Perry-4-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).
Docket Nos.
50-237: 50-249 License'Nos.
DPR-1~: DPR-25 Endlosure: * Notice of Violation
Sincerely
.
A. Bill Beach Regional Administrator cc w/encl: T. J. Maiman. Senior Vice President
- Nuclear Operations Divi~ion*
'D. A. Sager. Vice President.. *_
Gen~ration Support H. W. Keiser: Chief Nuclear Operating Of.f i cer *
T. Nauman. Station Manager Unit 1 M, Heffley*: Station* M~nager Units 2 and 3 F. "Spangenb~rg.. Regulatory Assurance Manager
I. Johnson. Acting Nuclear
- Regulatory Services Manager
- Richard Hubbard
- Nathan Schloss. Economist Office of the Attorney General State Li~ison Offiter
.
- _.
Chairman. *I 11 i noi s. Commerce Cammi ss ion Document Control Desk-Licensing.
DOCUMENT NAME:
G:\\EICS\\96-532.WSl To receive a copy of this document, indicate in the box "C" = Copy w/o attach/encl."E" = Copy w/attach/encl "N" = No copy OFFICE RII I I
RI I I r.Cr I RII I I
I NAME Grobe/m 1.
Gra~t.\\. ~\\.;,I\\
Beach DATE
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1\\'h~.. v
\\ \\.k OF IC IAL RECORD COPY
J. cc w/encl:
T. J. Maiman. Senior Vice President Nuclear Operations Division
. \\.
D. A. Sager. Vice President.
Generation Support H: W. Keiser. Chief Nuclear Operating Officer T. Nauman. Station Manager Unit 1 M. Heffley. Station Manager Unfts 2 and 3 F. Spahgenberg. Regulatory Assurance
.Manager I. Johnson. Acting Nuclear Regulatory Services Manager-Richard Hubbard Nathan Schloss. Economist.
Office of the Attorney General
- State Liaison Officer Chairman. Illinois Commerce Commission-Document Control Desk.-Li~en5ing *
,
- I
'.
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Quad Cities,*
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