ML20197H155

Responds to NRC Re Violations Noted in Insp Repts 50-295/86-12 & 50-304/86-12 & Proposed Imposition of Civil Penalties in Amount of $25,000.Penalty Protested

ML20197H155
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	05/14/1986
From:	Reed C COMMONWEALTH EDISON CO.
To:	Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
1641K, NUDOCS 8605190074
Download: ML20197H155 (12)

Text

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Commonw 11th Edison One First National Plaza Chicago, liknois

( y{C__,/ '7 Chicago.

Address Reply lllinois to Post Office Box 767 60690 ,

May 14, 1986 ,

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Mr. James M. Taylor Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Zion Nuclear Power Station Units 1 and 2

{' Response to I&E Inspection Report Nos.

50-295/86-002 and 50-304/86-002 NRC Docket Nos. 50-295 and 50-304 References (a): March 17, 1986 letter from C. E. Norelius to Cordell Reed.

(b): April 15, 1986 letter from J. G. Keppler to J. J. O'Connor.

Dear Mr. Taylor:

This letter concerns the routine safety inspection of activities at Zion Station conducted on January 4 through February 14, 1986 by M. M. Holzmer, L. E. Kanter, and J. N. Kish. Reference (a) indicated that the isolation of service water to the IB auxiliary pump oil cooler for 22 days appeared to be in noncompliance with NRC requirements. This issue was discussed on March 31, 1986 during an Enforcement Conference held in the NRC Region III office.

Reference (b) provided Commonwealth Edison with a Notice of Violation and proposed imposition of Civil Penalty for this event. This event was characterized as a Severity Level III violation and a $25,000.00 Civil Penalty was proposed. Commonwealth Edison Company's response to the Notice of Violation is provided in Attachment 1 to this letter.

Reference (b) also expressed the NRC's concern regarding Zion Station's control of non-routine valve manipulations. The current system has been examined and found to be adequate for most situations. However, the system was being inconsistently applied and lacked an effective mechanism for identifying the alignment in the field. Thus, non-routine valve alignments at Zion Station will now be controlled by the positive methods contained in Commonwealth Edison's Out-of-Service Procedure.

Commonwealth Edison Company has carefully reviewed this event and is concerned about the overall availability of Zion's auxiliary feedwater system.

I This concern is reflected in the extensive and comprehensive corrective action described in Attachment 1. However, Conunonwealth Edison Company believes that this event has been improperly classified as a Severity Level III violation.

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Mr. J. M. Taylor May 14, 1986 i A review has been performed of the auxiliary feedwater system's normal operating configuration at a number of the industry's PWRs utilizing information from NURBGs 0611 and 0560. This review has demonstrated that the configuration of the Zion auxiliary feedwater system during the 22 day event provided either equivalent or superior flow capacity and/or redundancy than is provided by the norwal auxiliary feedwater configurations at a number of operating nuclear power plants across the nation. This fact is inconsistent with the characterization of this event as being a significant safety violation.

By virtue of these plant's continued operation, their auxiliary

, feedw<.ter systems must provide a sufficient level of redundancy, reliability,

! and capacity to satisfy the statutory requirement of adequate protection of the public health and safety. Thus, although a number of these plants are being reviewed by the NRC for the adequacy of their auxiliary feedwater systers, the fact of their current operation renders it inconsistent to fine Zion Station for operation for 22 days in a condition equivalent or superior i to these operating plants. The imposition of a civil penalty in this instance effectively penalizes Commonwealth Edison for constructing Zion Station with an auxiliary feedwater system design that exceeds the minimum requirements.

In addition to the review discussed above, a study was made of past enforcement actions taken in response to violations concerning auxiliary feedwater systems. This study demonstrated clearly that the proposed enforcement action for Zion is more severe than for comparable incidents across the nation. Thus, Commonwealth Edison believes that the enforcement

policy delineated in 10 CPR 2, Appendix C, has not been consistently applied e

in this instance.

The details of these two studies, and their relationship to the enforcement policy, are contained in Attachment 2. The conclusion of these assessments is that the isolation of service water to the IB auxiliary feedwater pump at Zion Station for a period of 22 days is more properly characterized as a Severity Level IV violation.

j Reference (b) also expressed the NRC's concern regarding the timeliness of Zion Station's actions following the discovery of this event.

Commonwealth Edison Company believes that Zion Station personnel pursued the

investigation of this event diligently. This was a complicated event, whose details required considerable effort to unravel. While it is recognized that the Resident Inspector could have been kept more informed as this investigation progressed, any such delay in communication does not have any bearing on the timeliness of Zion's corrective actions nor on the realization of the safety significance of this event.

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Mr. J. M. Taylor May 14, 1986 The enforcement policy allows for mitigation of a proposed civil penalty for both prompt identification and for extensive corrective action.

Reference (b) states that further mitigation of this penalty was not applied due to Zion Station's lack of timeliness in dealing with this issue.

Attachment 3 discusses these issues in detail and demonstrates that the event was promptly identified and that the corrective actions taken were both timely and extensive. Commonwealth Edison's conclusion regarding this matter is that the enforcement policy allows for more extensive mitigation than was exercised on this issue.

For the reasons discussed above, Commonwealth Edison Company believes that this event has been improperly categorized as a Severity Level III violation. In addition, notwithstanding our assertion that this event is a Severity Level IV violation, Commonwealth Edison Company also believes that the proposed civil penalty should be completely mitigated. Thus, in accord-ance with 10 CFR 2.205.b, we are protesting both the classification of the violation as Severity Level III and the limited mitigation of the proposed civil penalty.

Please direct any further questions to Commonwealth Edison's Department of Nuclear Licensing.

Very truly yours, on -

Cordell Reed Vice-president la Attachments cc: Zion Resident Inspector J. A. Norris - NRR J. G. Keppler - Region III SUBSCRIBED AND y N to befor Joe this / - day of' ' Idn. -

, 1986 i Yi (b1R

" Notary public 1641K

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ATTACHMENT 1 ZION NUCLEAR POWER STATION UNIT 1 RESPONSE TO NOTICE OF VIOLATION l

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ITEM OF NONCOMPLIANCE

! As a result of the inspection conducted on January 4 through February 14, 1986, and in accordance with the " General Policy and Procedures for NRC Enforcement Actions, "10 CFR Part 2, Appendix C (1985), the following violation was identified:

Technical Specification 3.7.2.A.(1) and (2) requires that during plant operation in Modes 1, 2, and 3, three Independent steam generator auxiliary feedwater pumps shall be operable with two motor driven and c

! one steam turbine-driven auxiliary feedwater pump. With one motor-driven auxiliary feedwater pump inoperable, the pump must be 1 restored to operable status within seven days, or the plant must be in Mode 4 within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Contrary to the above, from December 21, 1985 until January 12, 1986 with the plant operating in Mode 1, one motor-driven auxiliary feedwater pump was inoperable with the applicable action statement not satisfied, in that the pump was not restored to operable status within seven days and the plant was not in Mode 4 within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Corrective Action Taken and Results Achieved l

The immediate corrective action was to open 1SWO656 to provide a source of cooling water for the IB auxiliary feedwater pump oil cooler. In addition, the remainder of the service water supplies to the Unit 1 auxiliary feedwater pumps were verified to be lined up correctly.

3 Corrective Action Taken to Avoid Further Violation i

1. Changes to the Unit 1 and 2 SW hydro procedure valve lineups have been instituted to make permanent the valving alignment which ensures SW is provided for both AFW pumps on the opposite unit.

2. Personnel involved in hydro package review have been made aware of this event and cautioned to ensure attention to detail is given to the review

of these packages. However, it should be noted that of the 58 hydro packages reviewed and performed during this and the preceding refueling outage, there were literally thousands of valva positions examined by i these reviewers with only this one problem identified. All hydro i

packages have been re-reviewed since'the identification of this problem and no other problem has been found. In addition, these hydro tests are '

only performed once during each unit's ten-year inspection interval.

Therefore, this is considered an isolated event.

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3. A Zion Administrative procedure change has been initiated and training to reviewers has been provided to ensure procedure changes clearly state the reason for each change.

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} 4. The existing non-routine valve lineup procedure is being abolished. All

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valve manipulations will be controlled by the Out of Service procedure.

This procedure will provide more positive control over the plant's configuration.

5. A review of valve lineup procedures is being conducted to ensure that any l components normally supplied with Service Water from the opposite unit are 1

4 i never inadvertently isolated. Procedure changes will be made to correct j any deficiencies.

) 6. A memo has been provided to all shift supervisors alerting them to the cross connected condition which exists presently in the SW system and which may potentially exist in other " service systems" or common systems.

7. The fact that some components receive their cooling from the opposite unit presents a potentially confusing condition that could_ lend itself to 3

future errors. Thus, a review of the benefits obtained by allowing one

) unit's SW system to supply cooling to components on the opposite unit will j be conducted.

8. TraininghasbeenprovidedtoallRadWasteForemanonZionAbsinistrative

! procedures pertaining to operation. Adherence to procedures was emphasized j during this training.

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Date When Full Compliance Will Be Achieved Actions #4, 5, and 7 will be completed by June 30, 1986.

! All other actions have been completed.

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I ATTAQWENT 2

SUMMARY

i Commonwealth Edison Company has reviewed the auxiliary feedwater systems at many of the nation's operating PWR's and the nation's recent enforcement history concerning auxiliary feedwater. These reviews have concluded that the NRC's Enforcement Policy has not been properly applied in 2

this instance.

The NRC's Enforcement Policy authorizes the Region to issue a Severity Level III violation where a licensee's failure to satisfy an Action Statement in the time allotted by the Technical Specification results in a

significant violation of a limiting condition for operation (Lco) (10 CPR Part 50, App. C. Supplement I.C.1). However, the Enforcement Policy also l

distinguishes between Lco violations of varying significance. A less l significant violation of an Lco is characterized as a Severity Level IV i (Supplement I.D.1). Thus, the proper classification of a Technical Specification Lco violation depends heavily on the safety significance of  ;

the event.

f Edison has reviewed auxiliary feedwater operations at other plants 1 and civil penalties for similar incidents to establish a framework for evaluating the significance of this event. As summarized above, these comparisons show that:

1- operation of the Zion plant with one pump inoperable still left >

Zion with capacity and/or redundancy that was either equivalent or superior to the capacity and/or redundancy available during the  ;

] normal operation of several other plants; and l

! 2- the escalated civil penalty is significantly more severe than any j other penalty levied in comparable situations.

I i i Thus, the circumstances of this event and previous evaluations of the significance of similar events show that this event did not have a ,

safety significance warranting a Severity Level III violation. The  ;

appropriate classification for this violation is Severity Level IV.  ;

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DISCUSSION l

! The number of auxiliary feed water pumps at other Westinghouse  !

i plants and system capacities at those plants are enumerated in Table I. j i That Table shows that Zion's normal operating configuration, 3 auxiliary [

i feed water pumps having a total capacity of 400% of required flow, joins ,

several other Westinghouse plants at the high end of the spectrum of .

capabilities at all operating Westinghouse plants. More importantly, that  !

I Table also shows that the normal operating conditions for four Westinghouse plants provide less flow capacity or redundancy than was available at Zion during this incident. Five additional' plants have normal operating  :

i configurations that provide equivalent flow capacity and/or' redundancy. l

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During the Zion incident, 2 pumps capable of providing 300% of required auxiliary feedwater were available. By contrast, under normal operation, San Onofre-1, and Prairie Island have 2 pumps available, and are capable of providing only 200% of required flow. Turkey Point has available only 1 1/2 pumps capable of providing 300% of flow. Yankee Rowe has 1 pump with 100% capacity as its normal auxiliary feedwater system lineup. The continued operation of these four plants implies that the temporary operation of Zion with 2 pumps available and capable of providing 300% of flow was consistent with the adequate protection of public health and safety.

A review of Combustion-Engineering plants reinforces this conclusion. Table II enumerates the number and capacities of the auxiliary feed water pumps at those plants. Four of those plants operate with only two pumps with a range of pump capacities from 200% to 400%. Thus, the pump configuration at Zion during the incident was right in the middle of the operation of pump capacities for these Combustion-Engineering plants. Again, it follows that operation of Zion in this configuration was consistent with the adequate protection of public health and safety.

1 If 13 plants can run normally with equivalent or less system capability and/or redundancy than was available at Zion during the incident, then this incident cannot be considered a significant safety matter for the purposes of the Enforcement Policy. Therefore, the incident at Zion was improperly classified as severity Level III.

This conclusion is supported by comparing the civil penalty proposed for Zion with civil penalties previously imposed in other incidents involving auxiliary feedwater systems. A compendum of those civil penalties is provided in Table III. That Table shows that the proposed civil penalty for Zion is more severe than any other civil penalty for a comparable incident. In no other case was 300% capacity still available during the incident. This information is pertinent because the proper classification of a Technical specification LCO violation depends heavily on the safety significance of the event.

In addition, in every other case leading to escalated enforcement no more than one pump was available. Thus, in all other cases of escalated enforcement there was no redundancy in the available pumps. This critical factor distinguishes the Zion event for which two pumps were still available.

At Zion, pump redundancy was still available throughout the incident.

Clearly, this makes the Zion event fundamentally different from previous

, Severity Level III events involving loss of auxiliary feedwater. Therefore, classification of the Zion event with these previous events resulted in an inconsistent application of the Enforcement Policy. Accordingly, the Zion event should be reclassified as Severity Level IV.

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TABLE I WESTINGHOUSE PLANTS Approx.

Capacity # of Pumps Plant (%/ Unit) (#/ Unit)

Beaver Valley 1 400 3 D.C. Cook 1/2 300 2 Farley 1 400 3 Ginna 600 5 Haddam Neck 300 2 i

H.B. Robinson 400 3 Isidian FL. 2/3 400 3 Kewaunee 300 3 North Anna 1 400 3 i

Prairie Island 1/2 200 2 Point Beach 1/2 300 2 Salcm 1 400 3 San onofre 1 200+ 2 Surry 1/2 400 3 Trojan 400 2 Turkey Point 3/4 300 1 1/2 Yankee Rowe 100 1 Zion 1/2 400 3 Sources: NURBG 0611 NURBG 0560 1641K

TABLE II

, . - j. COMBUSTION - ENGINEERING PLANTS Approx.

Capacity # of Pumps Plant (%/ Unit) (#/ Unit)

ANO 400 2 Calvert Cliffs 1/2 400 2 Fort Calhoun 1 200 2 Maine Yankee 600 3 Millstone 2 400 3 Palisades 300 2 St. Lucie 1 400 3 Sources: NUREG 0611 NUREG 0560 j 1641K

i TABLE III NONCOMPLIANCE HISTORY Approx. Fine Plant Date Capacity # of Pumps Level /Amt.

Turkey Pt. 4/83 0 0 II/100,000 Turkey Pt. 12/83 200 1 III/60,000 Trojan 3/84 200 1 III/O 1 D.C. Cook 8/84 100 1 III/50,000 Turkey Pt. 12/84 200 1 IV i-i Zion

• 12/85 300 2 III/25,000

• Proposed 1641K

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, ATTACIBIENT 3 i

The NRC has stated in references (a) and (b) that it believes that '

i Zion station was slow to realize the full significance of this event.

. Specifically, the inspection report transmitted with reference (a) stated on page 6; The licensee was slow to realize the significance of this event, in that it was discovered on January 12, 1986, and was processed as a i routine deviation report (DVR) until approximately January 27, 1986, when the Operating Assistant Superintendent determined that this j event could have represented a significant reduction in the margin of safety, and informed the NRC resident inspector. The licensee

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usually informs the resident office immediately when significant events occur. The fact that the licensee informed the resident

inspector indicates that they were beginning to treat this as a more i serious matter.

In addition, reference (b) stated;

) However, NRC is concerned that af ter the valve misalignment was )

j diccovered and corrected two weeks passed before anyone realized the l full significance of this event. i 4

Reference (b) later stated; i

Further reduction was not applied because after the violation was j discovered, you failed to realize its safety significance for some i time.

The above statements indicate that the NRC is correlating the 15 day j time period between January 12 and January 27 with a perceived delay in the

recognition of the significance of this event. On the contrary, Commonwealth Edison believes that Zion Station realized immediately the potential l significance of this event. We acknowledge that the Resident Inspector could have been kept better informed of the investigation during this 15 day time j

period. However, this delay in communication does not have any bearing on the timeliness of Zion's corrective actions nor on the realization of the safety

! significance of this event.

4 The immediate corrective action upon discovering the event was both timely and comprehensive from a safety standpoint. The service water cooling flow was immediately restored to the la auxiliary feedwater pump and the service water supplies to the other auxiliary feedwater pumps were verified to

! be correct. When these actions were completed, the event's effect on reactor safety was terminated. The Unit 1 auxiliary feedwater system had been restored to a fully operable status. This occurred on January 12, 1986.

) The only information available to plant personnel on January 12, 1986 was the closed condition of valve 1sWO656. Since this valve had not been l associated with any maintenance or hydrotest activities, there was no indication as to the initiating mechanism of this event. Thus, there was no j, indication regarding the event's duration.

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However, station personnel immediately recognized the need to determine the total duration of the service water isolation. From the time of the initial reviews of the deviation report, the potential for this event to be a technical specification violation was clearly understood by station personnel.. Efforts were immediately initiated to determine the total time of isolation, so that the classification of this event could be accurately established. It should be noted that in order for this event to be reportable under 10CFR50.73.2.i.B. the total time of isolation would have to exceed the 7 days allowed by the technical specifications, o

As discussed at the Enforcement Conference held on March 31, 1986, the time period between January 13, 1986 and January 25, 1986, was spent engaging in extensive interviews, discussions, and research with numerous plant personnel. This investigation uncovered the root causes, personnel involved, initiating dates, and durations of the closure of both ISWO656 and ISWO660. In addition, the involvement of the service water system hydrotest valve line up was uncovered and thoroughly researched during this time period.

Commonwealth Edison acknowledges that the Resident Inspector could h.ve been informed of the progress of this extensive investis=Lluu duelus thlm time period. However, the NRC has incorrectly identified this lack of involvement of the Resident Inspector as a failure to realize the safety significance of this event. The perception of a logical tie between this lack of communication and Zion Station's perceived inability to recognize the significance of this event is incorrect.

As discussed above, Zion Station personnel immediately recognized the

/ potential of this event on January 12, 1986. The intervening two weeks was spent diligently investigating the details of this complicated event.

The immediate corrective action taken in response to this event was to restore the Unit 1 auxiliary feedwater system to a fully operable status.

This was the proper action to take and terminated this event. The additional.

corrective actions taken are discussed in Attachment 1. These 8 actions arc extensive and are specifically directed at the contributing causes of this event to preclude additional similar violations in the future. .

For the reasons discussed above, Commonwealth Edison Company believes that this event was identified promptly. The required reports were submitted within the mandatory 30-day time frame. In addition, the corrective action taken in response to this incident was both prompt and extensive. Thus, there is considerable opportunity for additional mitigation of the proposed civil penalty that has not been exercised on this issue.

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