ML20012B032

Responds to 900131 Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $100,000.Corrective Actions: Task Force Initiated & Nuclear Engineering Dept Developed Training Course for Preparation of Evaluations for Mods

ML20012B032
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	03/02/1990
From:	Kovach T COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF ENFORCEMENT (OE)
References
EA-89-210, NUDOCS 9003130319
Download: ML20012B032 (6)

Text

.t o

.A r

x-

[

) 1400 Opus Piece i

(

) Downers Grove, Illinois 60616 P

c a-

%d March 2, 1990 Director Office of Enforcement h

U.S.. Nuclear Regulatory Conunission Washington, DC 20555 1

L l

Subject:

Zion Station Units 1 & 2 i

H Response to Order Imposing Civil

)

Monetary Penalty - Enforcement j-Action 89-210 l

NRC Docket No. 50-295 and 50-304 J

References (a): A. B. Davis letter to Cordell Reed

)

dated January 31, 1990 j

Gentlement Reference (a) transmitted the Notice of Vloistion and proposed l

Imposition of Civil Penalty involving the failure to perform a safety l

evaluation required by 10CFR50.59 prior to operating Zion Station with the l

automatic start function of the diesel generator room ventilation systems inoperable.for an extended period of time. A civil penalty of one hundred thousand dollars ($100,000) was proposed.

Commonwealth Edison Company's response to the specific items in the l

Notice of Violation are contained in Attachment A.

The attachmeot describes

.j

-the steps that have been taken to enhance the Zion Station operability determination process. The response also describes the performance assessment

}

program including the prioritization, tracking and resolution of

+

self-identified improvement items. Conunonwealth Edision believes that the l

L actions taken at Zion Station will preclude the recurrence of this event.

Enclosed please find a check for $100,000 in payment of the fine.

Please address questions regarding this matter to this office.

Very truly yours, i

M'

/

t T. J

'ovach Nuclear Licensing Manager Enclosure cet A. B. Davis - Regional Administrator-RIII L. N. 01shan - Project Manager, NRR Byron Resident Inspector l

0748T/RACtwj

\\h 90031303I9 900302 PDR ADOCK 05000295

@. k 9

pnn

r-

-o

?

AIIACittiMI_A Violation I.

10CFR50 50.39(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.

100FR$0 50.59(b)(1) further requires, in part, that the licensee maintain records of change in the facility to the extent that the change constitute change in the facility as described in the safety analysis report. These reports must include a written safety evaluation which provides the basis for the determination that the change does not involve a unreviewed safety question.

Section 9.10.6.2.2 of the Updated Final Safety Analysis Report (UFSAR),

requires in part, that the diesel generator room ventilation system starts automatically, under all loss off-site power conditions, to limit the ambient room temperature to 1150F.

Contrary to the above, the licensee changed the facility as described in 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 ventilation system could not operate automatically under loss of off-site power conditions, without performing 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 i

diesel generator room ventilation systems could not operate for loss of off-site power conditions on the following dates (1) The Unit 1, 1A and 1B 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.

(3) The common unit "0" diesel generator room ventilation system could not automatically operate from June 7 to July 7,1989.

m m

L l

0

[

o o

l L

i

)

O Correclive lc11on Taken an L Resul.ts.lchieved The Operating Department issued a standing order on October 27, 1989, which specified that the diesel room ventilation system is a necessary support i

system to be considered when making diesel generator operability determina-tions. This standing order remained in effect until December 1, 1989, when

)

Zion Station revised its procedure titled " Inoperable Equipment Surveillance Tests" (PT-14) which incorporated the necessary philosophy to continue consi-dering diesel room ventilation as a necessary support system to the diesel generator.

Commonwealth Edison Company initiated a task force, subsequent to the May 31, 1989, operability enforcement conference concerning Containment Spray, that was chartered to review operability assessments throughout the Nuclear Operations Division. Applicable recommendations from this task force will be incorporated into the existing Nuclear Operations Directive (NOD) governing Conduct of Operations. This revision to the. NOD should be completed by April 15, 1990.

Zion Station has reviewed the task force recommendations and has implemented the appropriata sections into our operability decision making process.

As of November 17, 1989, senior Operating management had been per-forming a daily review of equipment variations to ensure the proper operability assessment had been made by the Operating shift personnel. This daily review was in ef fect until December 1,1989, when the revised PT-14 was formally implemented.

The revision to PT-14 and the standing order dated January 10, 1990, accomplished three major improvements to the operability assessment process at Zion Station.

1)

The procedure requires operators to assess the operability of all degraded safety related equipment for impact on the operability of Technical Specification requirements including the impact the degraded equipment has on the Update Final Safety l

Analysis Report.

2)

To provide the proper tool to allow the Licensed Shift Supervisor to assess the impact of the degraded equipment on the UFSAR, the operability matrix was created. The operability matrix lists all support equipment required to support the operability determination of Technical Specification requirements. The standing order requires the Licensed Shift Supervisor to utilize the operability matrix when assessing the operability of degraded equipment.

l 3)

To ensure that operators are properly utilizing the new guidance, the revised procedure requires that a licensed member of the Regulatory Assurance Department review the degraded safety related equipment logs to verify that all operability l

considerations have been properly evaluated.

l The Notice of Violation and Proposed Imposition of Civil Penality requested that this response address the actions Commonwealth Edison has taken or is planning to take to assure that performance assessment concerns are properly prioritized, tracked, and resolved.

The Performance Assessment 0746T/wj/2

Standard requires that areas of concern are identified and prioritized as Category I or Category II improvement items. A Category I improvement item is defined as an iten if left uncorrected could likely lead to an INPO finding or NRC noncompliance. Additionally, a Category I improvement item may also be a serious programmatic weakness, or a significant deviation from the requirements of company directives. A Category 11 improvement item is one which does not meet currently accepted performance standards.

The stations are required to respond to all Category I improvement items in writing, detailing the corrective actions and completion dates for resolution.

Zion Station has committed to provide responses to both Category I and Category II improvement items within 60 days from the receipt of the assessment report. The responses are reviewed by the Performance Assessment Manager, the Assessment Administrator, and the corporate functional manager to ensure that the proposed corrective actions are adequate to resolve the improvement items.

Zion Station will track the commitments made to resolve the Category I and Category II improvement items in the Commonwealth Edison Nuclear Tracking System. The station will periodically update the commitment status.

The Performance Assessment Department has access to the Nuclear Tracking System to allow status of the items.

The Station has the responsibility to assure that improvement items are satisfactorily resolved. The Performance Assessment Department has the responsibility for providing for the corporate follow-up of the Category I and II items. The Assessment Administrator ensures that follow-up activities are accomplished and in most cases an evaluation of the resolution to the items will be conducted during a subsequent assessment.

A quarterly status report of all Category I improvement items is i

prepared by the Performance Assessment Department for upper management review.

Co r r e c t iv elc.t i onloJe_Ia kenlo_hnid_.EuttherJ.iola tion To ensure consistency in operability determinations, the UFSAR matrix will be reviewed for accuracy by Corporate Engineering. The Corporate Engineering review will be completed by completed by April 1, 1990.

A list of discrepancies in various sections of the UFSAR was generated during the development of the UFSAR matrix. Corporate Engineering will resolve these discrepancies and include the necessary UFSAR revision into the 1990 and 1991 UFSAR updates for Zicn Station.

Zion Station will develop and implement administrative controls for updating the UFSAR matrix. These administrative controls will be in place by July 1, 1990.

Datc3 hen _Eull_C.ompliance.JilllJelchiered Commonwealth Edison believes that the actions taken and results achieved from implementation of those actions places Zion Station in full compliance at this time.

l

o Y1olation II. 10 CrR 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.

Zion Administrative Procedure (ZAP), 2-54-5, Revision 0, " Safety Review and Evaluation" requires in part, that a written safety evaluation providing the basis for the determination that the change, test, or experiment does not involve an unreviewed safety question, be performed for changes to the station that will change the facility as described in the safety analysis report.

Contrary to the above, on October 11, 1900, 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 closed 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 1).

Correctlyc_Ac11nn_Inken anLResulta_Achicleil The safety evaluation cited in the notice of violation was performed by the Nuclear Engineering Department in the October 1988, time frame as part of a Zion Station Modification.

In the spring of 1988, the Nuclear Engineering Department conducted an evaluation of their 50.59 program. During the summer and fall of 1988, a revision to the Engineering Procedure Q.6.1 was developed providing detailed instruction and checklists for safety evaluations for plant modifications. The revised procedure was issued in February 1989.

The Nuclear Engineering Department developed a training course for the preparation of safety evaluations for modifications. All PWR and BWR Systems Engineers were trained by September 1989.

These engineers are responsible to review safety evaluations for Safety Related Modifications.

Commonwealth Edison has recognized the need for more comprehensive safety evaluations and has been an active participant with NUMARC in the development of " Guidance for 10CFR50.59 Safety Evaluations" (NSAC 125).

An Assistant Technical Staff Supervisor from Zion Station has been an active participant in CECO's corporate task force to upgrade the safety evaluation process since the fall of 1989.

This task force is committed to utilizing guidance provided by NSAC 125 to develop safety evaluation criteria for use throughout Commonwealth Edison. Zion has implemented applicable section of NSAC 125 to upgrade their 50.59 safety evaluation process.

The safety evaluation criteria developed by this task force will result in issuance of a Nuclear Operations Directive (NOD). Upon receipt of the final NOD each station will be required to implement the applicable requirements within 60 days.

0746T/wj/4

e.

s 4

9; w

Cntrgetive Action To Ba_Iaken To Aynid Furthk d iklatiDn

(

Conoconwealth Edison believes that the corrective actions taken to I

improve our 50.59 safety evaluation process places us in full compliance at this time.

Dali_When Full Compliance Will be Achitys4 g

Commonwealth Edison is in full compliance.

i 1

l 0746T/wj/5 1