ML20006C763
| ML20006C763 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 01/31/1990 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20006C760 | List: |
| References | |
| EA-89-218, NUDOCS 9002090107 | |
| Download: ML20006C763 (3) | |
Text
{{#Wiki_filter:. I w. e NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Commonwealth Edison Company Docket Nos. 50-295; 50-304 ' Zion Nuclear Generating Station License Nos. DPR-39; DPR-48 EA No. 89-218 During an NRC inspection conducted on October 18 through November 6,1989, t 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 (1989), the Nuclear Regulatory Consnission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205. The particular violations and associated civil penalty are set forth below: 1. 10 CFR 50.59(a)(1), in part, allows a_ licensee to make changes in the ( facility as described in the safety analysis report, without. prior Commission approval, unless the proposed change involves a change in the technical specifications incorporated in the license or an unreviewed safety question. 10CFR50.59(b)(1)furtherrequires,inpart,thatthelicenseemaintain l records of changes in the facility to the extent that the changes constitute changes in the facility as described in the safety analysis report. These records must include a written safety evaluation which provides the bases for the determination that the change does not involve L an unreviewed safety question. L Section 9.10.6.2.2 of the Updated Final Safety Analysis Report (UFSAR), l requires in part, that the diesel generator room ventilation system start ' automatically under all loss of off-site power conditions to limit the l ambient room temperature to 115'F'. Contrary to the above, the licensee changed the facility as described in L Section 9.10.6.2.2 of the UFSAR by placing the diesel generator room ventilation fan control switches in the pull-to-lock position so the L ventilation system could not operate automatically under loss of off-site i power conditions, without performin9 the required written safety evaluation to demonstrate that the change did not involve an unreviewed safety question. By placing the fan control switches in the pull-to-lock position, the diesel generator room ventilation systems could not operate for loss of off-site power conditions on the following dates: (1) The Unit 1, IA and IB diesel generator room ventilation systems could not automatically operate from March 15 to August 10, 1989. (2) The Unit 2, 2A and 2B diesel generator room ventilation systems could not automatically operate from March 20 to October 25, 1989, 9002090107 900131 {DR ADOCK0500g3
q c Notice of. Violation (3) The comon unit "0" diesel generator room ventilation system could not automatically operate from June 7 to July 7, 1989. This is a Severity Level 111 violation (Supplement I). j Civil Penalty - $100,000. II. 10 CFR Part 50, Appendix B, Criterion V Instructions, Procedures and Drawings, requires in part, that activities affecting quality be prescribed by and accomplished in accordance with documented instructions, procedures or drawings. ZionAdministrativeProcedure(ZAP),2-54-5, Revision 0,"SafetyReviewand Evaluation" requires in part, that a written safety evaluation providing the bases for the determination that the change, test, or experiment does not involve an unreviewed safety question, be performed for changes to the l station that will change the facility as described in the safety analysis report. Contrary to the above, on October 11, 1988, the licensee did-not perform an adequate safety evaluation to change the diesel generator ventilation ' intake air crash dampers from a fail open to a failed close mode. The safety evaluation for the proposed modification was inadequate in that-it did not consider that closure of the air crash dampers defeated the purpose of the diesel generator ventilation system as described in Section 9.10.6.2.2 of the Updated Final Safety Analysis Report. This is a Severity Level IV violation (Supplement I). Pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison Company (Licensee) q is hereby required to. submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within'30 days of the date of this Notice. This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each alleged violation: (1) admission or denial of the alleged violation; (2) the reasons for the violation if admitted;-(3) the 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. If an adequate reply is not received within the time specified in this Notice, an order may be-issued to show cause why the license should not be modified, L suspended, or revoked or why such other action as may be proper should not be taken. Consideration may be given to extending the response time for good L cause shown. Under the authority of Section 182 of the Act 42 U.S.C. 2232, l: this response shall be submitted under oath or affirmation. .Within the same time as provided for the response required under 10 CFR 2.201, h the Licensee may pay the civil penalty by letter to the Director, Office l of Enforcement U.S. Nuclear Regulatory Commission, with a check, draft, or L money order payable to the Treasurer of the United States in the amount l. $100,000 of the civil penalty proposed above, or may protest imposition l of the civil penalty in whole or in part by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission. i -e
H Notice of Violation i Should the Licensee fail to answer within the time specified, an order imposing the civil penalty will be issued. Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty in whole or in part, such answer should be clearly marked as an " Answer to a (1) deny the violation (s) listed in this Notice of Violation" and may(:2)demonstrateextenuatingcircumstances; Notice in whole or in part; (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 factors addressed in Section V.B 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 parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. -The attention of the licensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty. Upon failure to pay. any civil penalty due which subsequently has been determined in accordance with the applicable provision 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. 2282c. The responses to the Director, Office of Enforcement, noted above (Reply to a Notice of Violation, letter with payment of civil penalty, and Answer to a Notice of Violation) should be addressed to: Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, ATTH: Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Administrator, Region III.- U.S. Nuclear Regulatory Commission, 799 Roosevelt Road, Glen Ellyn, Illinois 60137. FOR'THE NUCLEAR REGULATORY COMMISSION a, p Ifh 't.' A. Bert Davis Regional Administrator l Dated.at Glen Ellyn, Illinois this 31st day of January, 1990 l f
~ r,[ j',[y ( h ~ - U.S. ' NUCLEAR REGULATORY COMMISSION l REGION !!! 'ReportLNos.'50-295/89036;50-304/89032(DRP)) Docket Nos. 50-295; 50-304 License Nos. DPR-39; DRP-48 Licensee: : Commonwealth Edison Company P. O. Box,767 Chicago, IL 60690 > Facility Name: Zion Nuclear Power Station, Unit 1 Inspection At: Zion, IL Inspection: Conducted: October 18 through November 6, 1989 1 Inspectors: R. J. Leemon W. J..-Kropp Approved By: 'J. M. Hinds, Chief NOV 81999 Rgact ct Section IA. Date (W.D.prfjro 3 .My % a I Inspection Summary =t Inspection:from October 18 - November 6,1989 -(Report Nos. 50-295/89036; 50-304/89032(DRPJ) Areas Inspected: Special, unannounced resident inspection of the failure 1 -- 1 . to declare the diesel generators inoperable when the diesel generator room ventiiation. systems were out;of service. 3 Results: In the area., inspected, one violation wasLidentified'(Technical-5pecification violation - operation with diesel generators inoperable for-a period in excess of the action requirements). The licensee failed to
- initiate a: Technical Specification: time clock when the diesel generator room ventilation systems were inoperable. The ventilation systems perform
'I a' safety; function as described in the Updated Final Safety Analysis Report; however,5this. function ~ is not specified in the Technical Specification. The licensee did not consider that a necessary. safety support system was. ? lost when ~the' diesel generator room ventilation systems were taken out of service and-that the diesel generators were therefore inoperable, g
g [( 4 [.[ { -{ DETAILS 1 1.. Persons Contacted T. Joyce, Station Manager W. Kurth, Superintendent, Production J P. LeBlond, Assistant Station Superintendent, Operations W. Stone, Regulatory Assurance Supervisor T. Saksefski, Regulatory Assurance Engineer T. Rieck, Technical Superintendent W. T'Niemi, Technical Staff Supervisor-E. Fuerst, Zion Project Manager, Nuclear Operations PWR Projects Department J. Smith, Senior Residint Inspector R. Leemon, Resident Inspector A. Bongiovanni. Resident Inspector
- Indicates persons present at the exit interview on November 6, 1989.
Discussions were also held with members of the Technical Staff. 2. Operation of Unit I and Unit 2 with the Diesel Generators' (DG) Ventilation Systems (71707) a.
Background
Each DG room has a -ventilation system that is described in the UpdatedFinalSafetyAnalysisReport(UFSAR),Section9.10.6. The-UFSAR states that each DG room ventilation system is designed to limit the maximum room ambient temperature to 115 degrees F.
- Also, the system is identified as part of engineered safeguards and is required to operate for all loss of off-site power conditions.
Each DG room ventilation system consist of a, ventilation fan, inlet damper, ductwork,-instrumentation and associated control circuits. The inlet dampers also perform a function as aircraft crash dampers as described in UFSAR, Sections 9.10.6, and 9.10.9, and USFAR question 2.28. The DG room ventilation systems are not specifically identified in the Technical Specification (TS); but, based on the g description in the UFSAR are considered a necessary support system for DG operability. The inlet dampers' function as a aircraft crash damper is addressed in TS surveillance requirement, 4.17.2.1.b. This surveillance required verification every six months that the dampers would close in two seconds. If_ the damper failed to close in two seconds the TS required the damper to be placed in the closed position. The. closure of the damper to comply with this TS requirement also resulted in the DG room ventilation system's inability to meet the engineered safeguard function described in the UFSAR. 2
h .,g' -{ -( - t + ge o r, Due to hardware problems with the inlet dampers, the TS surveillance. requirement for the-aircraft crash damper was not consistently met. The licensee initiated a modification to the inlet damper controls to increase the. reliability. The modification included a chan9e to the failure mode of the all DG room ventilation inlet dampers from fail
- open" to fail "close".
b.. Event Chronology 5/27/80 Special test on 2B DG performed for Sargent & Lundy to determine room temperature rise. '(To date, licensee has not-been able to turnish test procedure or results) 3/15/89 1A and IB DG vent dampers taken out-of-service (005) for modification No.1-86-5 to replace 3-way solenoid and - Miller valves with a 4-way solenoid,- 3/20/89.2A and 2B DG vent fan dampers taken 005 for modification No. 2-86-5 to replace 3-way solenoid and Miller valves with a 4-way solenoid. 5/24/89 TS change 89-10 to' remove aircraft. crash requirements mailed for Off-Site review. This change was initiated due to a TM1 DCRDR concern, s 6/16/89 2A and 2B DG vent fan dampers fail stroke time while ~ being tested in conjunction with modification 2-86-5. 6/19'/89 TS change 89-10 off-site review completed. 7/18/89 TS change 89-10 submitted to NRR. 8/10/89 1A and IB DG vent fan-dampe.rs returned to service after completion of modification 1-86-5. 9/08/89 Telephone conference call between licensee and NRR to discuss TS change 89-10. [ 10/19/89 Resident staff discussed with licensee the out of service of the 2A and 2B DG room ventilation systems. After discussions with the resident staff the licensee considered another test similar to the 1980 DG room temperature test. 10/20/89 ~ Resident inspectors witnessed monthly TS surveillance on 2B DG. DG room temperature exceeded the UFSAR temperature of 115'F. Room temperature approached 120*F with room doors open at the time of the surveillance. The 2B DG room temperature alarm function was inoperable and no compensatory action to monitor room temperature was initiated by the licensee. Room temperature was lost due to isolation of air to the inlet damper as part of the 005. 3 l
i ^[ 7,':. ( p. ~ ~ ~ ~ w ~: I 10/25/89 "0" DG aircraft crash damper failed TS closure time at-12:30 p.m. Damper was placed 00S and ventilation fan was pull-to-loc k (PTL). 10/25/89 Temporary Lift of 005 for 2A, 28, and "0" DG aircraf t crash dampers. Licensee requested Waiver of Compliance for closure time of dampers. The dampers were opened and the-systems were returned to service.
- c. -
Safety Significance 1 The design basis (UFSAR) states that the DG room ventilation systems were designed to limit the maximum ambient in the DG rooms to 115 degrees F. The resident staff observed, on October 20, 1989, 1 during the monthly TS surveillance on 28 DG, that the temperature in-the room was-118 degrees and the discharge of the air cooler for the 28 diesel generator,was 148 degrees-F. The diesel-generator had been . running for about I hour with the DG room doors opened to the turbine i building. The room temperature was-measured just inside the DG door. and may not have been a true indication of the overall room i temperature.. Elevated DG room temperatures could affect DG reliability to provide electrical power to the safeguard busses during a loss of off-site power. d. Concerns The licensee appears to have a restrictive application of Technical t Specifications requirements to support systems. When a safety function of a component's. support system described in the UFSAR was lost and the support system was not described in the TS, the affected l component was not declared inoperable.- A similar concern was L identified in inspection report 50-295/89017 and was discussed during-a l &n enforcement conference on May 31,1989. Also, a 50.59 review for a modification'to change the failure mode of the DG room ventilation l: inlet-dampers from fail "open" to fail "close" only discussed the function of the inlet dampers as aircraft crash dampers and did not address the' damper's engineered safeguard function as a supply to DG-l room cooling during. loss off-site power. e. Enforcement ecification (TS) 3.15.2.C required during power operation TechnicalSp(2)"A",1(2)"B"and"0"(common)'dieselgenerators(DG) i that the 1 L shall be operable. From and after the date that one of the DGs for a unit.is made or found inoperable, reactor' operation on that unit is permissible only during the succeeding 7 days provided that the other two DGs are available. Technical Specification 3.0.3 requires that l if a LCO and/or ACTION requirements cannot be satisfied, action shall be initiated within one hour to place the unit in at least HOT SHUTDOWN within the following 4 hours and in at least COLD SHUTDOWN within the following 48 hours. Technical Specification 1.27 (definitions) states that a system, subsystem, train, component or 1 device shall be operable or have operability when it is capable of l A
4 [ performing'itsspecifiedfunction(s)andwhenallnecessaryattendant instrumentation, controls, electric. power, cooling or seal water. . lubrication or other auxiliary equipment that are required for the function (s) ystem, train, component, or. device to perform its system, subsare also capable of performing their related support function (s). Also,theUpdatedFinalSafetyAnalysisReport(UTSAR), Section 9.10.6.2.2, states that each DG room ventilation system is designed to limit the maximum room ambient to 115 degrees F. It further states that this system is part of the engineered safeguards-The licensee had the IA,1B, 2A, 2B and. *0" (comon) power conditions. and is required to operate for all loss of off-site DG rooms ventilation systems out of service during the following periods: UNIT 1-1 1"A"----March 15 to August 10, 1989 i 1"8"----March 15 to August 10, 1989 L ' UNIT 2 2"A"----June 7 to October 25, 1989 2"B"----June 7 to October 25, 1989 UNIT 0(COMMON) "0"-----June 6 to July 7,1989 ' October 25, 1989 from 12:30 p.m. to 5:30 p.m. 'For the time frames-identified above, the licensee did not declare the DGs inoperable. Therefore, the licensee failed to enter TS 3.0.3 from . Marchil5 to August 10, 1989, for Unit 1 and June 7 to October.25, 1989, for Unit 2 when more than one DG were inoperable at the same time. Also, L on October 20, 1989, during the 2B 1)G TS monthly surveillance test the L temperature as measured inside the DG room reached 118 degrees F as - observed by the NRC residents. This is considered an apparent violation ~(295/89036-01; 304/89032-01). l. f. Corrective Actions The immediate corrective action consisted of.the licensee's request for a waiver of compliance to the TS requirement that pertained to the aircraft crash damper closure time. The waiver was granted by NRR on October 25, 1989. The dampers for the 2A and 2B DG that had been failed closed due to not meeting the TS requirement closure time were opened and the DG room ventilation systems were returned to service on October 25, 1989 at 5:40 p.m. The long term corrective action was discussed in the waiver of compliance document dated October 27, 1989 that required the licensee to install a modification to improve damper closure times. Also, further information concerning the TS change was requested. i 5 ll w w w T2u
.n: 4, ; l.
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-e. 7 g >, .] One apparent violation and no deviations were identified. 3.- Exit Interview (30703) -r The inspectors met with licensee representatives (denoted in Paragraph 1),. i throughout the inspection period and at the conclusion of the inspection on November 6, 1989, to summarize the scope and findings of the inspection activities. The licensee acknowledged the inspectors' conments. The inspectors also discussed the-likely informational content of the. inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not. identify any such documents or processes-as proprietary. f I r ~l 1 !L { i. .}}