ML20214M138
| ML20214M138 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs, Kewaunee, Cooper, Arkansas Nuclear, Summer, Columbia, North Anna, Vermont Yankee, San Onofre, Cook, Fort Calhoun, 05000000, Trojan |
| Issue date: | 05/26/1987 |
| From: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| To: | Davis A, Grace J, Martin J, Martin R, Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| TASK-083, TASK-83, TASK-OR EGM-87-04, EGM-87-4, NUDOCS 8706010188 | |
| Download: ML20214M138 (4) | |
Text
DU UNITED STATES
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MAY 26 1987 EGM 87-04 MEMORANDUM FOR:
W. Russell, Regional Administrator, RI J. Grace, Regional Administrator, RII A. Davis, Regional Administrator, RIII R. Martin, Regional Administrator, RIY J. Martin, Regional Administrator, RV FROM:
James Liebeman, Director j
Office of Enforcement
SUBJECT:
ENFORCEMENT FOR CONTROL ROOM HABITABILITY ISSUES The purpose of this memorandum is to provide enforcement guidance to the regions l
for issues related to control room habitability / control room emergency ventilation system deficiencies. As background to this issue, attention to the area of control room habitability became heightened because of a TMI Action Item in NUREG-0737 (Item III.D.3.4) and due to ACRS concerns in the area of control room habitability. A Generic Issue (83) was initiated to resolve the ACRS concerns.
Initially, the NRC surveyed three plants and the results were documented in NUREG/CR-4191, issued April 1985. These findings indicated deficiencies in the perfomance of the control room ventilation systems. For the resolution of Generic Issue 83, additional plants were visited. These plant visits revealed similar deficiencies as were found in the first three plants surveyed and were documented in plant visit sumary reports issued by the NRC contractor (Argonne National Laboratory) or inspection reports issued by the regional offices. Enclosure 1 sumarizes the plants reviewed and the document which describes the findings. While these reviews were perfomed by NRR, sometimes with a regional inspector, NRC attention was focused on the identification and resolution of problem areas and not on enforcement aspects.
We must now deal with the enforcement issues resulting from these reviews.
Furthermore, we understand that NRR is preparing a TI on this topic for all plants; additional NRR surveys are not planned.
The following guidance is provided concerning the determination of appropriate enforcement action.
1.
For the plants already visited, except Trojan for which enforcement action has already been taken, and for all other plants, the regions must detemine whether enforcement action (i.e., Notice of Violation and/or proposed civil penalty) should be taken for these facilities. Each case must be reviewed individually and evaluated to determine whether enforcement action is appropriate for deficiencies disclosed during these plant visits, even though the deficiencies may have been already corrected. Additional regional followup and discussions with the licensee may be necessary to understand the licensee's view of the findings and evaluate the significance of the findings.
8706010188 870526 PDR ADOCK 05000206 hh'*l P
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Regional Administrators Generally, enforcement action should be taken if it was reasonable to expect that the licensee should have identified the deficiency earlier; this includes items such 4: O) inadequacies in the licensee's QA/QC program (sG as inadequate deshn, improper construction, inadequate QC inspect!cn, improperly controlly nodification or maintenance, inadequate or improper preoperatiosi or p*>st-modification testing, or the failure to correct known deficiencies), (2) inadequate 50.59 or design / design change review or testing program, or (3) willful violations.
However, if it was not reasonable to expect the licensee to identify and correct these problems, then no enforcement action should be taken provided corrective action has been taken. As an example, for the case in which the licensee had taken reasonable actions in its preoperational testing program, no enforcement action should be taken if the NRC persuaded the licensee to make available additional flow monitoring locations and only through NRC experience in selecting the appropriate monitoring locations did the NRC identify system inadequacies. In such a case, the issue of instrument location should be addressed by the resolution of the Generic Issue.
In addition, for those cases in which it was not reasonable to expect the identification of the deficiency by the licensee, enforcement action should not be taken if:
(1)thelicenseehadimplementedtherequirementsofthe i
technical specifications and the NRC had approved implementation of the j
comitments regarding Item III.D.3.4 of NUREG-0737 and the licensee is meeting these commitments, or (2) the technical specifications are inadequate.
l 2.
As in any enforcement issue, the enforcement evaluation should include the safety significance of the deficiencies in terms of the radiation or hazardous material exposure to control room personnel or the safety significance of the root cause of the problem. While keeping in mind i
the analyses and assumptions of the FSAR and NUREG-0737 Item III.D.3.4, the evaluations for safety significance should also consider the actual hazard which the system deficiency represented to control room personnel.
NRR assistance may be required to establish the safety significance of the deficiencies. The Enforcement Policy of 10 CFR Part 2, Appendix C, and the examples of violations in Supplement I should be used to establish the severity level of any violation. Violations should be cited for the failure to meet technical specification requirements, NUREG-0737 comitments, or 10 CFR Part 50, Appendix B, and not for the failure to meet 10 CFR Part 50 Appendix A (General Design Criteria). Any resulting violation should be processed as any other violation would be, including escalated enforcement action if warranted.
If the only violation available appears to be Appendix A, please consult with OE.
In considering the appropriate enforcement action, the staff recognizes that the plants in Enclosure I agreed to participate in these visits and they assisted the NRC in being sources of infonnation for the resolution of Generic Issue 83. However, it appears that some of the deficiencies are significant enough to warrant consideration for enforcement action.
For example in Trojan EA 86-54 (NUREG-0940 Vol. 5 No. 2), a civil penalty has been already issued based on a Severity Level II violation for the i
system deficiencies. The action was based on:
(1)thesignificant l
deficiencies in system design, construction, and preoperational testing which led to the potential to subject control room personnel to radiation doses in excess of GDC 19 (2) the lack of action on the part of the
MAY 261987 Regional Administrators f licensee when deficiencies were identified, (3) the enforcement action served to highlight to the licensee previous NRC concerns, particularly in the engineering area, and (4) the enforcement action was intended to encourage other licensees, by example, to improve licensee performance in this area.
3.
This general guidance is intended to permit the initial review and evaluation of system and licensee deficiencies and may not be appli-cable in every case. Should the need for additional guidance be identified, contact me or Howard Wong of my staff.
James Lieberman, Director Office of Enforcement cc: Regional Enforcement Coordinators RI, RII, RIII, RIV, RV T. Martin, RI J. Stohr, RII J. Hind, RIII R. Bangart, RIV D. Kirsch, RV T. Murley, NRR J. Hayes, NRR J. Craig, NRP, J. Wermiel, NRR J. Taylor, DEDR0
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SUMARY OF PLANTS REVIEWED BY NRC l
Findings Plant Date of Site Visit Documented In 1.
Calvert Cliffs September 24-25, 1985 Plant Visit Sumary Report 2.
Cooper October 2-3, 1985 Plant Visit Sumary Report 3.
Vermont Yankee November 7-8, 1985 Plant Visit Sumary Report 4.
Arkansas Nuclear January 22-23, 1986 Plant Visit Sumary Report 5.
Trojan January 28-30 and Inspection Report February 24-28, 1986 No. 50-344/86-06 6.
WNP-2 April 7-10, 1986 Plant Visit Sumary Report 7.
San Onofre May 27-28, 1986 Inspection Report Nos.
Unit 1 50-206/86-25 and 50-206/86-38 8.
Kewaunee August 11-14, 1986 Plant Visit Sumary Report 9.
D.C. Cook September 15-19, 1986 Plant Visit Sumary Report
- 10. Ft. Calhoun October 27-31, 1986 Plant Visit Sumary Report
- 11. North Anna December 1-5, 1986 Plant Visit Sumary Report 12.
V. C. Sumer January 12-16, 1987 Plant Visit Sumary Report 1
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