IR 05000295/1997003

Discusses Insp Repts 50-295/97-03 & 50-304/97-03 on 961207-970527 & Forwards Nov.Initial Plant Design Failed to Compensate for Unfiltered Ventilation Flow Path That Maint Personnel Routinely Created

ML20217A307
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	09/12/1997
From:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Brons J COMMONWEALTH EDISON CO.
Shared Package
ML20217A311	List: IR 05000295/1997003 ML20217A337
References
50-295-97-03, 50-295-97-3, 50-304-97-03, 50-304-97-3, EA-97-224, NUDOCS 9709190125
Download: ML20217A307 (4)

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1. "% UNITEo STATES

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\ NUCLEAR RE2ULATORY COMMISSION 3 9 REGloN lt!

O i[ 801 WARRENvlLLE ROAD lisle. ILUNols 60632-4351

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September 12, 1997 EA 97-224 Mr. Acting Site Vice President Zion Generating Station Commonwee'th Edison Company 101 Shiloh Buulevard Zion,11, 60099 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-295/304-97003 (DRS))

Dear Mr. Brons:

This refers to the inspection conducted at die Zion Nuclear Power Plant from December 7,1996 to May 27,1997, The inspector reviewed the circumstances surrounding your November 7, 1996, identification that removal of a block wall during the Unit 2 refueling outage bypassed the normal fuel building ventilation system. The inspector discussed the significance of the issues and the need for lasting and effective corrective action with members of your staff at the inspection exit meetirig on May 27,1997, The report documenting our inspection was sent to you by letter dated July 9,1997, Our July 9,1997 letter, offered you the option to request a predecisional enforcement conference or respond to the apparent violations. You elected to respond to the apparent violations and did not request a predecisional enforcement conference.

The NRC determined that violations of NRC requirements occurred. This determination was based on the information developed during the inspection; the infymation that your staff provided during the exit meeting; your Licensee Event Report Number 295/304-96T6 dated December 9,1996; and your August 8,1997, response to the apparent violation documented in ,

the inspection report. The violations are cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding theal are described in detail in the inspection report.

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The initial plant design failed to compensate for the unfiltered ventilation flow path that maintenance personnel routinely created when they removed a block shield wall during each Unit 1 and Unit 2 refueling outage. Additionally, previous reviews by your site maintenance and engineering staffs lacked sufficient rigor to identify that an unfiltered ventilation flow path was created whenever the block shield wall was removed. The block wall located between the containment hatch area and the fuel handling building (FHB) was routinely removed to facilitate movement of large equipment into/out of the containment during outage activities. Removal of the block wall created an unfiltered ventilation flow path from the FHB and/or containment to the environment during outage activities. Because of this practice, the potential dose at the site boundary during a fuel handling accident increased by a factor of two. Your staff identified this condition on November 7,1996, during a system walk down performed by a system engineer.

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, Auxiliary Building / Fuel Building Ventilation Test (Surveillance procedure PT-19) tested the ventilation system before each refueling outage and during fuel moves; however, it was always performed with the block shield wall removed. The test failed to alert engineers that approximately one-third of the air exhausting the FHB bypassed the filter ventilation system because your staff had not adequately analyzed the functhn of the block shield wall and the effect that its removal had on the ventilation system. Local radiation monitors could realign the exhaust path through the ventilation filters if high radiation was present in the ventilation flow path. However, the Technical Specifications do not require operability of these radiation monitors during a refueling outage. Therefore, there was no assurance that the monitors would have been anlable to realign pipe tunnel exhaust through the charcoal filters. The initial plant design assumed all exhaust would be filtered prior to release to the environmant. Your operating practice resulted in unfiltered exhaust to the environment. This violated two NRC requirements as described in the Notice. These violations are classified in the aggregate according to the " General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, as a Severity Level lli problem, in accordance with the Enforcement Policy, a base civil penalty in the amount of $50,000 is considered for Severity Level lil violations occurring before November 12,1996. Since the noncompliance period occurred before November 12,1996, a base civil penalty of $50,000 was considered for this case. Because your facility has been the subject of escalated enforcement action' within the last two years, the NRC considered whether credit was warranted for ,

Identification and Corrective Action by the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. You were given credit for both identifying this deficiency and for initiating prompt and effective corrective action. Your corrective actions included a modification to the ventilation ductwork to ensure that the ventilation exhausts via a filter path; a revision to the procedure for safety evaluations (SE) to include an expanded set of design issue workshest for consideration and use by SE preparers and reviewers; additional training for all SE preparers; and establishment of an engineering assurance group, consisting of experienced engineering personnel to verify that the SEs are complete, correct, and adequately justified.

Therefore, to encourage prompt identification and comprehensive correction of violations, I have been authorized, tter consultation with the Director, Office of Enforcement, not to propose a civil penalty in this case. However, significant violations in the future could result in a civil penalty.

The NRC has concluded that information regarding the reason for these violations, the corrective actions taken and planned to correct the violations and prevent recurrence and the cate when full compliance will be achieved is already adequately addressed on the docket in 1 EAs 97 222 and 97 223 issued two severity Level 111 Problems and a severity Level til Violation with a $330.000 civil penalty for a reactivity management problems and command / control problems that occurred during the February 21,1997, plant shutoown; the displacement of reactor coolant from the reactor vessel on March 8,1997; and the failure of the corrective action program to implement effective corrective actions for previous occurrences of these events These problems were identified during inspections conducted from February 1997 to April 1997.

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. Inspection Report No. 50-295/304-97003, Licensee Event Report 295/304 96026, and your letter dated August 8,1997. Therefore, you are not required to respond to this letter unicss the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, please follow the instructions specified in the enclosed Notice.

in accordance with 10 CFR 2.700 of the NRC's " Rules of Practice," a copy of this letter and the enclosures will be placed in the NRC Public Document Room.

Sincerely,

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A. Bill Beach Regional Administrator Enclosure: Notice of Violation Docket Nos.: 50-295,50-304 License Nos.: DPR-39, DPR-48 cc w/ encl: R. J. Manning, Executive Vice President, Generation l

M. Wailace, Senior Vice '

President, Corporate Services H. G. Stanley, Vice President PWR Operations Liaison Officer, NOC-BOD D. A. Sager, Vice President, Generation Support D. Farrar, Nuclear Regulatory Services Manager I. Johnson, Licensing Operations Manager Document Control Desk-Licensing R. Starkey, Plant General Manager R. Godley, Regulatory Assurance Supervisor Richard Hubbard Nathan Schloss, Economist Office of the Attomey General Mayor, City of Zion State Liaison Officer State Liaison Officer, Wisconsin Chairman, Illinois Commerce Commission

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