ML20058N603
| ML20058N603 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 10/12/1993 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9310200041 | |
| Download: ML20058N603 (19) | |
Text
ft m
Commonwealth Edison
's. 1400 Opus Plac3
/ Downers Grove, IHinors 60515 October 12,1993 Director, Office of Enforcement U. S. Nuclear Regulatory Commission
' Washington, D. C. 20555 Attn: Document Control Desk
Subject:
. Zion Nuclear Power Station Units 1 and 2; NRC Docket-Numbers 50-295 and 50-304; NRC Inspection Report Numbers 50-295(304)/93014
Reference:
J. B. Martin letter to M. J. Wallace dated September 9,1993, transmitting Notice of Violation and Proposed Imposition of Civil Penalty - $50,000.
Enclosed is Commonwealth Edison's (CECO) response to the Nouce of Violation (NOV) transmitted in the referenced letter. The NOV cited five violations:
Violation I. (A and B) involve the violation of 10 CFR 50.59, in that a.
change to the facility made in August 1989 involved an unreviewed safety question without performing a safety evaluation, and the safety evaluation eventually performed in August 1992 was deficient.
Violation II. (A through D) describes four violations involving inadequate procedures, failure to report a condition that could prevent the fulfillment of a safety function, failure to promptly identify and correct conditions adverse to quality, and failure to calibrate required instrumentation.
' Violation I is a severity level III violation requiring a written response,
- and a civil penalty of $50,000. Violation II has been characterized as four level IV violations requiring a written response. CECO's response to the referenced letter is provided in attachment A. The civil penalty has been paid.
Notwithstanding CECO's payment of the proposed civil penalty, there are several remaining issues involving the Auxiliary Building Ventilation System and related design basis'which are viewed differently by CECO and the NRC.
Therefore, it is CECO's intent to initiate wor'.cing discussions with NRR to further clarify what constitutes an acceptable licensing basis. This effort is viewed as necessary to support CECO's effort to implement the Improved
' Technical Specifications at Zion Station. Any adjustments to the licensing basis will be docketed for NRR review.
, i f'd
-l 9310200041193'l012 OM 5'
/
N gpN n
J
~
E
,1 f
4 Director, OfIice of Enforcement-October 12,1993 If your staff has eny o.sestions or comments concerning this letter, plea'se refer them to Marcio Jrackson, Regulatory Performance Administrator
- at (708) 663-7287.
Very truly yours,
. - - v-l Dennis Farrar, Manager Regulatory Services MJ/gp
- Attachment cc:
J. Martin, Regional Administrator, RIII
. C. Shiraki, NRR Project Manager J. Smith, Senior Resident Inspector, Zion Station k-Il.'
e,J, _
b i
ATTACIBIENT A Notice of Violation And Proposed Imposition of Civil Penalty
' VIOLATION: 295(304)/93014-L A. and B.
10 CFR 50.59, " Changes, Tests and Experiments," allows a licensee to make changes to the facility as described in the safety analysis report (SAR), without prior Commission approval, unless the proposed change involves an unreviewed safety question or a change to the license technical specifications. A proposed
- change is deemed to involve an unreviewed safety question if, among other things, the consequences of an accident previously evaluated in the SAR may be
= increased.
. 10 CFR 50.59 also requires that the licensee maintain records of changes to the facility, including a written safety evaluation which provides the bases for determining that the proposed change does not involve an unreviewed safety question.
Final SAR Section 9.10.2, " Auxiliary Building Ventilation System Design and Operation, : and, subsequently, Updated Final Safety Analysis Report (UFSAR)
[
Section 9.4.3.2, " Auxiliary Building Ventilation System Description," state that the p
exhaust fans for the auxiliary building are controlled to maintain the auxiliary building at a nominal 1/4-inch of water of negative pressure with respect to the s
outdoors.
Contrary to the above:
- A.
In August 1989, without prior Commission approval, the licensee made a facility change that involved an unreviewed safety question, and a
~
written safety evaluation was not performed. ' Specifically, the licensee p
kept the auxiliary building missile door L-10 open for an extended period, 1
rendering the exhaust fans incapable of maintaining a nominal 1/4-inch I
of water of negative pressure with respect to the outdoors, and thereby
- increasing the potential cons.equences of a previously evaluated accident'
-(i.e., increasing the off-site doses that could result from dropping a spent L
fuel assembly onto the spent fuel floor).
p
)
l 1
=
,;g a-
ATTACHMENT A Notice of Violation And Proposed Imposition of Civil Penalty VIOLATION: 295(304)/93014-I. A. and B. (continued)
F B.
' On August 24,1992, the licensee completed a 10 CFR 50.59 safety evaluation of keeping the auxiliary building missile door L-10 open, and
' the evaluation failed to provide the bases for determining that this.
change did not involve an unreviewed safety question. Specifically, the y
evaluation incorrectly assumed that the auxiliary building exhaust fans could maintain a nominal 1/4-inch of water of negative pressure relative to the outside with door L-10 open, and failed to consider the effect of the open door on a previously evaluated accident (i.e., increasing the off-site i
doses that could result from dropping a spent fuel assembly onto the spent fuel pool floor).
This is a Severity Level III violation (Supplement I).
REASONS FOR THE VIOLATION:
CECO acknowledges the violation that a safety evaluation per the reqmrements of 10 CFR 50.59 was not performed and once performed was inadequate. The reason for this. violation has been identified as less than adequate training for personnel responsible for determining the need for and adequacy of a 10 CFR r
- 50.59 safe.ty evaluation. A contributing cause has been identified to be that comprehensive and well organized reference materials have not always been readily available to ensure that all' design basis assumptions are evaluated.
o While_ CECO acknowiedges the violation, the potential safety consequences of the scenarios of concern are minimal in light of the mitigating effects of. Zion's procedures for fuel handling evolutions and accidents, specific design features of the Zion fuel building ventilation systems, and the requirements of the Zion technical specifications.
g 1
2
[
t N
6-
m a
b 4
M i
ATTACHMENT A s
And Proposed Imposition of Civil Penalty CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED f-On December 9,1992 one of the two L-10_ doors was closed. Upon closure of one i
of the two doors, it was demonstrated that the auxiliary building ventilation system was capable of maintaining negative pressure in the auxiliary building general area.
On April 2,1993 both of the L-10 doors were returned to a normally closed status.
F CORRECTIVE STEPS TO BE TAKEN TO AVOID FURTHER VIOLATIONS Zion Station's corrective actions designed to address the root causes of this violation and prevent recurrence are divided into six distinct action areas. In an effort to ensure that the corrective actions for this violation are both comprehensive and provide for long term effectiveness, the scope of these corrective actions has been increased at the April 16,1993 enforcement conference. The six action areas are as follows:
1.
Training on identification of activities that require 10 CFR 50.59 Safety Evaluation performance.
Zion Station's Systems Engineering Staff (formerly Technical Staf0 has received training regarding this event with emphasis placed on considering the applicability of a 10 CFR 50.59 safety evaluation as the result of work requests, abnormal valve / barrier / electrical line-ups, or out-of-services that place a system or component in a condition that is not described in an approved procedure or technical specifications. In addition, this training also included emphasia on the importance of considering and documenting the analysis of all applicable UFSAR
(
' accidents. (Training on the specific details of these accidents and their assumptions is to be provided under action area 3 below). This training was completed on October 4,'1993.
L - (
s
TV- -
...5 '2 l
b i
+
1 w
k
)
. ATTACHMENT A j
r t
j Notice of Violation-And Proposed Imposition of Civil Penalty l
U l
g p
.Approximately eighty percent of site engineering personnel have also l
received this training as October 4,1993. The remainder of these
- personnel will receive this training no later than November 30,1993.
- Using feedback received from these training classes, an improved version -
7 of the syllabus will be developed and the training provided to licensed Shift Operating Management, and Maintenance Work Analysts. Training j
pJ
- for these groups.will be completed by March 31,1994.
y 2.
NSAC-125 Training / Source Document Training
~ All Zion Station engineering personnel preparing and approving safety l
evaluations will attend a seminar on the principles contained in NSAC-125 " Guidelines for 10 CFR 50.59 Safety Evaluations". - This seminar'will
~
- be developed under the direction of CECO's participant in the NSAC-125 l
~ industry effort. The intent of the seminar will be to reinforce clarifying R
concepts contained in NSAC-125 as they relate to our 10 CFR 50.59 4
. procedures. The ' seminar will also focus on increasing the engineers
['
awareness ofinformation needed to apply the concepts of NSAC-125 and L
where this information is located (ie. UFSAR, Fire Protection Report, j
NRC Operating License SER, and Amendment.SERs). Engineers e
currently qualified to prepare or approve 10 CFR 50.59 safety evaluations j
will attend this seminar by June 15,-1994, 1
- 3.
Zion Station 50.59. Resource Library i
- To provide comprehensive, well organized, and readily available reference l
< materials to the. individuals performing safety evaluations, a 50.59
~
3 4 reference center will be created. The reference center will have a l
e computer searchable copy of the UFSAR and the Zion Technical l
L Specifications.7 Hard copies of Zion's Fire Protection Report, ODCM,
. license amendments and SERs~will also be available. The center will be
.j fully functional by February 28,1994.
o H
2 4
r i- '
i "N
A
ATTACIDIENT A Notice of Violation And
. Proposed Imposition of Civil Penalty 4.
Accident Analysis Training Course A Zion UFSAR accident analysis training course has been developed to enhance the understanding of accident initiators, equipment credited for accident mitigation, key assumptions, and predicted consequences of accidents. This training has been provided to engineers performing safety-related design changes under CECO's modification program. The application of this training will be expanded to include engineers preparing safety evaluations for non-modification activities. This will be completed by June 15,1994.
5.
Continuing 10 CFR 50.59 Training Requirements To address the need identified for continuing 10 CFR 50.59 safety evaluation training, all Zion personnel qualified to prepare or approve these safety evaluations will be required to attend annual refresher training. This training will include, but not be limited to recent plant design changes and licensing bases change. In addition, the personnel authorized to perform 10 CFR 50.59 screening will receive annual training to reinforce the mindset that ' routine' activities such as work requests, out-of-services, or boundary alterations may directly or indirectly affect the system design bases described in the UFSAR. This training will focus on support systems and other changes that do not typically require a 10 CFR 50.59 safety evaluation. Both of these training courses will be aawmistered beginning after June 30,1994 and periodically thereafter.
6.
Offsite Review of 10 CFR 50.59 Evaluations As a result of CECO evaluations of the 10 CFR 50.59 review process, it was determined that this 50.59 evaluation was not subjected to offsite review. The reason for this oversight appears to be that a central focus is not established for transmitting safety evaluations to the off-site review group. CECO is currently reviewing corrective actions to ensure that all safety evaluations are reviewed by the off-site review organization in accordance with technical specifications.
5 l
m n.
- j i
- s,
- c...
ATTACHMENT A :
u' Notice of Violation 1
And 4 '
Proposed Imposition of Civil Penalty i
i t
e i
DATE WHEN FULL COMPLIANCE WAS ACHIEVED:.
t Full compliance was achieved on December 9,1992 when one of the two doors at '
- L-10.was closed.
+
[.c
'l y -
Ir j
s-'
t 'y
,v.
r fr, -
t s
- e..
f I
h P[
f',
c.
br :
t 6
t 4
i I
a E
.mj h
..z.
ip A g,S ' te y-
! ATTACHMENT'A.
U?'
=
f>
And'~
j
- Proposed Imposition of Civil Penalty
(:
l Fr p
- VIOLATION: 295(304)/93014-II.A_
, ;g 10 CFR 50, Appendix B, Criterion V States:
n LActivities affecting quality shall b'e prescribed by documented instructions, procedures, or drawings, of a type appropriate'to the circumstances and shall be L
accomplished in' accordance with these instructions, procedures, or drawings.
) Instructions, procedures, or drawings shall include appropriate quantitative or
/qu'alitative acceptance criteria for determining that important activities have
[
been satisfactorily accomplished.;
1
- Contrary to the'above:
i 1 ; LAs of March 23,1993, the licensee had failed to prescribe by procedure that 1
auxiliary building missile' door L-10 should.be normally closed, an activity
- affecting quality (in protecting safety-related equipment against loss of l function due to flooding, as prescribed by UFSAR Section 2.4.5.3).
0 L 2. ? As of March 23,1993',~ Procedure TSGP-35, Revision.1, dated May 18,1990,
.s.
' " Cubicle Differential Pressure Surveillanc'e," a procedure affecting quality, failed to use. appropriate quantitative or qualitative acceptance criteria (as
~
. prescribed by,UFSAR Section 9.4.3.1).
'3.
As of.Marcli23,1993, Procedure PT-0, Revision 6,' dated June 21,1992,
" Surveillance Checklist and Periodic Test,". a procedure affecting quality, failed to use' appropriate qua'ntitative or qualitative acceptance criteria to ensure that the auxiliary building would be maintained at a nominal negative K
pressure of 1/4-inch of water relative to the outdoors (as prescribed by
~
g, "UFSAR Section 9.4.3.2).
This is a Severity LeYel IV vielation (Supplement I).
r 2
L:
f,f I
r i
7 w,
2u L
V 3%
,~
~
~
1
~;.
y q ge 4.,
y/.M A'ITACHMENT A :
9J hC ' ' '
And y'
s Proposed Imposition of Civil Penalty 1
k ', LU ~
i a
~
~
e i*
- REASONS FOR THE VIOLATION:'
w
' CEC' 'acknowlsdges the violation.
o
- ~
VExample 1;
-J During the review.of this issue two procedures were identified which provide
' control over flood ' doors such as the auxiliary building doors L-10. One of.
l these is the Annunciator Response Manual under " Auxiliary Building Pressure High-Low" alarm response which directs operating personnel to -
f,'
. close auxiliary building ~ doors as a corrective action for high pressure in the j
auxiliary building. The other is AOP 8.4 " Severe Weather Conditions" which q
u
< was not in place when this issue was first identified. While both of these -
g<
, procedures identify actions to be-taken under abnormal conditions, they do
'i e(
j lnot address requirements for control of the door under normal ~ conditions; y
L' The violation' appears to have occurred due to inadvertent omission; As a i
ipermanent corrective action for this violation, Zion will develope an c administrative procedure thst will. provide controls for both flooding and for' a
Lventilation. boundary doors. ;In the interim, all auxiliary building 1 flood doors, q
. including the doors at L-10 have been appropriately labeled to ensure that' Ti
. they are identified ~as flood ' doors and remain'normally closed. It should be
(
noted that the table of floo'd doors currently in the Zion technical l
I' specifications shall remain until removed with implementation of the Zion m
improved.technicsl specifications.
(Example 2 ;
ii F
Upon review of the history of procedure TSGP-35 it was determined that the
- procedure was originally developed in 1985 in response to a recommendation
~
Jprovided in section 7.c~(4Xe) of draft NUREG-0761 " Radiation' Protection Plans for Nuclear Power Reactor' Licensee".- _' At the same time the procedure l
~
-was utilized to address a recommendation from IE Information Notice 84-45
" Reversed Differential Pressure Instrument Sensing Lines". The only eacceptance criteria provided by these documents was found in NUREG-0761.
r p &g That criteria simply. stated that pressure gradients should be such that air iflows are from areas oflow potential contamination to areas of higher y
f'A potential contamination ~.- This was accomplished in TSGP-35 bp requiring that cubicle d/p's be less than zero inches w.g.
p S
?
t
!I(
I IM V
8 Eyw NNa.
i
m.=
gf-3 y
,-l p
ATTACHMENT A i
E s0-i Notice of Violation
- And
-i y'
LProposed Imposition of Civil Penalty j
4 k...-
l C-
., y
--Based Ceco's~upon review of this. issue, CECO has concluded that a more
~
conservative acceptance criteria than that currently provided by TSGP-35 is warranted for those cubicles that have room coolers installed. These are l cubicles which contain ECCS pumps and are credited with directing potential
^
releases of radioactive iodine resulting from pump seal leak-off during design
. basis accidents.
F Example 31 LCECo agrees that th. original acceptance criteria for the general area auxiliary building'as found in procedure PT-0 was inadequate in that it
-i
.'specified that an auxiliary building pressure of between 0 and.65 inches w.g.
.was acceptable. ~AnLacceptance criteria of 0 inches w.g. does not afford a reasonable assurance that flow will be from clean areas to potentially
- contaminated areas.~
l CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED
! Procedure AOP-8.4,." Severe Weather Conditions" was a'pproved September 25, 1992 and ' enhanced on April 14,1993 to include the flooding concern and the_
L verification that the exterior Auxiliary building doors are closed, including door L-1 10.t I'
The Annunciator Response Manual has been enhanced for auxiliary building pr_ essure high alarm to include identification of specific doors to be checked closed,
~
s including.L-10.
Flood doo'rs have been labelled to delineate closure requirements.
Procedure PT-0 was revised April 13,'1993 to provide an appropriate acceptance -
criteria.
+
[
L.
L p
I p
q p
j 9^
3
- h. 7 s
3
q:
, a:
.a 1
ATTACHMENT A
.i i
'i
.And-Proposed Imposition of Civil Penalty
- CORRECTIVE STEPS TO BE TAKEN TO AVOID FURTHER VIOLATIONS I
~An Administrative procedure will be implemented to properly identify the flood doors as normally closed in'accordance with the Zion UFSAR. In addition, this-procedure will provide for administrative control of doors which serve as ventilation boundaries. This procedure will be completed by March 31,1994.
Procedure TSGP-35 will be revised to provide the appropriate acceptance criteria
- for those cubicles containing ECCS pumps as described above. This will be complete by January 31,1994.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Zion Station' will be in full compliance by March 31,1994.
i F
[
L
(-
-i t-10
p ;,7 n-DgJN ATTACHMENT A QjM Eo
~ Notice 'of Violation -
@E5
~
JAnd-j,'
. Proposed Imposition of Civil Penalty cn VIOLATIONi 295(304)/93014-II.B 3
Itj#
L10 CFR 50.73(a)(2)(v)(D) requires that'the licencee report within 30 days of
. discovery any event or condition that alone could have prevented the fulfillment F,'
of the safety function of structures or systems that are needed to mitigate the'
[d
- consequences of an accident.
B-k
- ContraryLto the above, as of June'24,1993, the licensee had failed to report that' l
missile door L-10 being in the full open position resulted in the auxiliary building
' L ventilation system test failure on December 9,' 1992, a condition which could increase the' actual off-site doses for the postulated accident involving dropping of
[
ta spent fuel assembly onto the spent fuel pool floor (UFSAR Section 15.7.4.1.5),
i
- and therefore could have alone prevented fulfillment of a safety function of a g
structure needed to mitigate the consequences of an accident.
[
This is a Severity Level IV violation (Supplement I).
p+
r
~
DISCUSSION:L L
E
,This violation'is a necessary consequence of the NRC's understanding of the o
-design basis for the auxiliary building / fuel handling building as 'of the time of the Lenforcement conference.. CECO's differing view of the design basis has been rejected by the NRC.L Moreover, since the enforcement conference, the Notice of
~
1 Violation has provided additionalinformation on the Staffs position. After reviewing the Notice of Violation for failure to submit a LER, comparing it to y
information utilized by plant personnel when the violation. occurred, and -
- considering the design basis foi the auxiliary and fuel handling buildings as
! presently understood by the NRC, CECO does not' contest the violation.
CORRECTIVE STEPS TAKEN'AND RESULTS ACHIEVED:
p
[In determining Ehether an LER should be submitted at^this time, CECO l reassessed the design basis for the auxiliary and fuel handling building. Based on this reassessment, CECO does not believe that an LER is required at this time.
Eus conclusion is based'on a ' design basis information known today, which supports CECO's conclusion that in~ hindsight, a condition did not exist which could -
~
. increase the actual off-site' doses for;the postulated accident involving dropping a -
?
spent fuel assembly onto the spent fuel pool floor'(UFSAR Section 15.7.4.5). The
~
g' as found condition, alone, could.not have prevented fulfillment _of a safety function-c of a structure n'eeded to' mitigate the' consequences of an' accident. Our e
L conclusions are based on the following additional information.
e 11 m
,.u.'
{~ w
>4
~ ~
E p
m, -
. ATTACHMENT A 4 y?.*
~
Notice of Violation-7 i
^
'And i *J:
a
- Proposed Imposition of Civil Penalty
. l
~
1 i
1 Prior to the start of fuel handling operations (whenever fuel irradiated within the
- (
- l previous 60' days is in the spent fuel pool), Zion procedures and technical
-specifications require that the fuel building ventilation exhaust be directed
~ '
7through the cha' coal filter banks and 'a charcoal booster fan be placed in r
3 p,
T operation. In addition, Zion' emergency procedures (AOP 6.1) require that in the.
i event of a fuel handling ' accident, the fuel handling supervisor is to. direct the l
k evacuation of the fuel building and to verify that all doors to the fuel building are l
Tclosedi p
W L'
Should a procedural violation take place and fuel handling operations commenced
- without proper alignment 'of the fuel building exhaust through the charcoal filters -
and in the event that a fuel handling accident were to occur, then upon detection
'of high radiation levels,'an automatic actuation signal from radiation monitor-l ORT-AR03 would cause damper repositioning to route fuel building exhaust throu~ h the charcoal filters and' automatically start a charcoal booster fan to g
ensure adequate exhaust flow. In addition, radiation monitor ORT-AR03 would l
send a signal to automatically close the main air supply' damper to the fuel i
building (OFCV-AV206).
1" By closing thel doors between the fuel building and the auxiliary building general K
area; and automatically shutting off the main air supply to the fuel building, radioactive gases r_re contained in the fuel building and routed through the HEPA filters' and charcoal filters prior to release to the atmosphere. Off-site ~ dose
~
4 i calculations take credit for this filtration.
L i
The off-site dose calculation is impacted only if radioactive gas migrates, via-
~ diffusion, to the auxiliary building general area where charcoal filtration is not
- available. JWith the isolation of supply air afforded by closing OFCV-AV206, the fuel building will be at a lower pressure than the auxiliary building general area
'and this migration cannot occur.1 Therefore, the off-site dose calculation is not caffected.
The operability of the fuel building ventilation system is verified on a monthly
- i
. basis in accordance with' the Zion Technical Specifications. The Zion periodic test
..(PT-19)-." Auxiliary Building / Fuel Building Ventilation Test".is performed to ensure s
1
. that the fuel building ventilation system is able to maintain the fuel building at a-
'E iii Edifferential" pressure equal to or greater than 1/4 inch negative with respect to the Loutside atmosphere. During the' period from February 1992 through December i
' 1992 when the Auxiliary building doors L-10 were open full time; the monthly test 1
~
u e
results for fuel building differential pressure ranged from a minimum of.25
' inches w.g. to a maximum differential pressure of.52 inches w.g.
j y
~
i 12 T.
J.
.. YL
s y.
y
- x p.
U
/n J j -a ATTACHMENT A
. - n
!/4,
E ~'
'And-O Proposed Imposition of Civil Penalty
.c.
u This additional information shows that to have a reportable event, in addition to -
d
- the postulated accident of dropping a fuel assembly, one must assume a failure of J
the. technical specification required automatic design features of the Fuel Building a
W ventilation system and a failure to follow procedures on the part of the Fuel U
' Handling Supervisor. Only if these events occur in conjunction, could radioactive gases.could be released into the A'uxiliary Building general area, where charcoal-
{
?
filtration is' not available.
M,
c
.Under these unlikely circumstances if door I 10 is in the open position during this j
+
postulated event, and there is a coincidental occurrence of some natural s phenomena which removes the temporary laundry facility, it would be possible for i
' radioactive gases to bypass the HEPA filters located in the exhaust plenuma for i the Auxiliary Building general area. It should be noted however that because
which is the principle contributor to the offsite dose, the Fuel Building is the
- structure which is relied upon to confme the gaseous activity released during the l
p
' postulated accident and not the Auxiliary Building.
T For these reasons,LCECo concludes that the combination of assumptions in the
' above scenarios are beyond what is assumed for the Design Basis Accident of a idropped spent fuel assembly in the fuel building, and that the placement of the laundry facility 'and opening of the doors at I 10 alone would not prevent
' fulfillment of a safety function of the fuel building ventilation system / fuel buildmg i
structure, j
,I L
N If the discussions between CECO and NRR on the auxiliary building / fuel handling sbuilding design _ basis results in a regulatory conclusion that is inconsistent with -
2 the above conclusions, CECO will reassess the need for submitting an LER as a p
corrective action to this violation.
1 j
b l
i j
13
hh ~ [
~
X 1 ATTACHMENT A -
dls '
l
@Q,<
Notice of Violation--
~And.
~
(
TProposed Imposition of Civil Penalty r
m 1;
G 7'-
VIOLATIONi 295(304)/93014-I'I.C j
F:
- e, y
10 CFR 50, Appendix B, Criterion XVI, states, in part, that measures shall be _
N>
- established to assure that conditions adverse to quality are promptly identified and correctsd.
,j V
fContr$ry to the above:
j
'1.
After becommg aware' of a condition adverse to quality in September 1992, 4
- when the inspector identified that the 10 CFR 50.59 safety evaluation dated l August.24,1992 used an invalid assumption (that the auxiliary building ventilation system could maintain a nominal 1/4-inch of water of negative c
pressure with respect to the outdoors with door L-10 open), the licensee failed to;promptly correct the condition adverse to quality (it was not corrected until December 9,L1992, when door L-10 was' partially closed to the half open E
iposition).
s
?2. As of April 29,1993, the licensee. had failed to promptly identify and correct a condition adverse to quality,in that nine auxiliary building cubicle differential pressure gauges (used in activities affecting quality) had been -
d
~~
linoperable.for' periods ranging from' 6 to 18 months'.
3This is a' Severity Level IV violation (Supplement I).
REASONS FOR THE VIOLATION:.
i (CECO acknowledges the violation, j
Example 1:
j During the time frame in question, CECO believed that prompt corrective actions were.being taken to address the concerns as they were communicated by the finspector. Repairs to the-door closing motor were expedited and a procedure to s
address door closure during severe weather conditions was created. The motor iwasl repaired on September 6,11992 and the procedure completed on September -
~
1 3
p
- 25,#1992. Through these actions, Zion believed that priorities were consistent.
l
- with safety significance and communications with the NRC were effective. _The s
assumption used in the 10 CFR '50.59 safety evaluation was not ' determined to be j
F, tinvalid until after the test was completed on December 9,1992. Upon completion
]
'of the test,1one of the'two Ir10 doors was immediately closed. In retrospect, it' i
/
1became clear; that'our communications with the NRC inspector were neither l effective or adequate'.
.i
)
14-1
- x
?%
- i
Na
. =-
e P
A ATTACHMENT A
' Notice of Violation And j
w Proposed Imposition of Civil Penalty j
n
' Example'2 -
. Regarding the failure to take prompt corrective actions to repair the inoperable differential pressure gauges, the reason for the violation has been identified as a weakn'ess in the procedures utilized for prioritizing work requests. ' Specifically,
- the procedure for determining work request priority did not provide for system engineer input. This weakness was identified and subsequently corrected to
- provide for significan.t system engineer input into work requeso prioritization, based on the engineer's assessment ofimportance with respect to system Joperation and function.
I
~ CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED
~
Auxiliary building door L-10 was partially closed on December 9,1992 and returned to normal fully closed position on April 2,1993.
LOf the nine gauges described as inoperable for greater than six months, it was
' determined that seven required repair or replacement and two were operable.
.For the two' cubicles with operable gauges,' ventilation systems repairs were necessary to increase flow into the cubicles. As of October 8,1993 all necessary -
repairs'and replacements had been completed.
i CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS 1
Zion Station management personnel responsible for coordinating NRC inspection activities'have been ~made aware of the proper. methods for handling of NRC inspector concerns and the need to ensure that the inspector is satisfied with
'l
. station responsiveness and~ timeliness of actions.
Zion Administrative Procedure 400-02, " Initiating and Processing a Work Request" was revised on July 13,1993 to provide for significant system engmeer input into work request prioritization.
I i
DATE WHEN FULL COMPLIANCE WAS ACHIEVED:
l e
UL -
. Full compliance was achieved'on October 8,' 1993.
I I
15 g
1
[ P %,,L,,
a
$v m
s W X dTTACHMENT A
yQg*
+
- Notice' of Violation?
4And'
~
L Proposed Imposition of Civil Penalty
[!l
'5 L
n VIOLATION: 295(304)/93014-ILD -
n L10 CFR 50,' Appendix B, Criterion XII, " Control of Measuring and Test
- Equipment," requires,'in part, that measures be estabhshed to assure that gauges g
E used in activities affecting quality are properly calibrated and adjusted at specified
- periods'to maintain accuracy within necessary limits.
e 1
Contrary to the above, as of June 24,1993, the licensee had not specified a calibration frequency for the_ auxiliary building individual cubicle differential a
_ pressure gauges', gauges used in activities affecting quality. Further, five gauges had.not been calibrated sin'ce 1978.
i g
. This is a Severity Level IV violation (Supplement I).
c REASONS FOR THE VIOLATION:
n CECO acknowledges the violation. CECO has reviewed this issue in an attempt to j
' determine whati bases were used to set the calibration frequency for the various
~
-auxiliary building cubicle differential pressure gauges. The review identified that only one differential pressure gauge / loop out of 88 is assigned a fixed calibration frequency. That is loop AV-93 which is used to measure / control the negative 1/4 L inch differential pressure requirement for fuel handling evolutions in accordance.
l N.
- with Zion technical specifications 3.13 and procedure' PT-19. The remaining cubicle differential' pressure instrumentation loops, are not assigned a calibration frequency. +
l As a result of CECO's review of the _ design basis for the Zion auxiliary building ventilation system, CECO has concluded that a 'specified calibration frequency is
. warranted for those instrument loops in cubicles which have room coolers
- installed (i.e. ECCS pump room cubicles).
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED
' Surveillance records have been reviewed for loo'p AV-93. Loop AV-93 was verified
'to Le within it's proper calibration frequency.
i 16
_A-
ATTACHMENT A a-l =
Notice of Violation And Proposed Imposition of Civil Penalty CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS An appropriate calibration frequency will be established for those cubicles which have room coolers installed (i.e., ECCS pump room cubicles). This frequency will be implemented and all affected cubicles brought within the established calibiation frequency by November 30,1993.
DATE WIIEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance will be achieved by November 30,1993.
17