ML20215F503
| ML20215F503 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 12/19/1986 |
| From: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Oconnor J COMMONWEALTH EDISON CO. |
| References | |
| EA-86-049, EA-86-49, NUDOCS 8612230421 | |
| Download: ML20215F503 (5) | |
Text
{{#Wiki_filter:, hO 4 - -.m#o UNITED STATES NUCLEAR REGULATORY COMMISSION o B y WASHINGTON, D. C. 20066 \\...../ Docket No. 50-295 License No. DPR-39 EA 86-49 Comonwealth Edison Company ATTN: Mr. James J. O'Connor President Post Office Box 767 Chicago, IL 60690 Gentlemen: i
SUBJECT:
COMMONWEALTH EDISON COMPANY - ZION GENERATING STATION, UNIT 1 WITHDRAWAL OF PROPOSED CIVIL PENALTY This refers to your letter dated May 14, 1986 in response to the Notice of Violation and Proposed Imposition of Civil Penalty (Notice) sent to you by our letter dated April 15, 1986. The Notice describes a violation associated with the isolation of cooling water to an auxiliary feedwater pump oil cooler i and was reviewed by the NRC during an inspection conducted at your facility during the period January 27 - February 14, 1986. In your response you admitted the violation occurred but believed it should have been categorized as a Severity Level IV violation instead of a Severity Level III. In addition, you gave reasons why you believe the proposed civil penalty should be further mitigated. After careful consideration of your response, we ha've concluded, for the reasons set forth in the enclosed Appendix, that a sufficient basis was provided for changing the severity level of the violation. Accordingly, the violation set forth in the April 15, 1986 l Notice has been changed from Severity Level III to Severity Level IV and the i proposed $25,000 civil penalty has been withdrawn. No response to this letter is required since Commonwealth Edison Company responded to the Notice in its May 14, 1986 letter and described corrective actions that had been taken and will be taken. We will review the effective-ness of these corrective actions during future inspections. ~ Our records will be changed to reflect that the Severity Level of the violation set forth in the April 15, 1986 Notice has been modified as described above. CERTIFIED MAIL RETURN RECEIPT REQUESTED l $k b S O
DEC 1 - 1986 Comonwealth Edison Company In accordance with 10 CFR 2.790, of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosures will be placed in the NRC's Public Document Room. Sincerely, g wx J mes M. Tay1 . Director ffice of In ection and Enforcement
Enclosure:
Appendix t 9 1 ,-..._,--._.n ,g-
APPENDIX The licensee's May 14, 1986 response to the April 15, 1986 Notice of Violation and Proposed Imposition of Civil Penalty (Notice) for the Zion Nuclear Power Station admits the violation occurred as stated in the Notice; however, the licensee believes the severity level of the violation should be reduced from a Severity Level III to a Severity Level IV. In addition, the licensee's response stated that the NRC Enforcement Policy permits more extensive mitigation than was used in the Notice. The violation is restated below followed by a sumary of the licensee's response, the NRC's evaluation, and conclusion. Restatement of Violation 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 one steam turbine-driven auxiliary feedwater pump. With one motor-driven auxiliary feedwater pump inoperable, the pump must be restored to status within seven days, or the plant must be in Mode 4 within the next 12 hours. Contrary to the above, from December 21, 1985 until January 12, 1986 with the plant operating in Mcde 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 hours. This is a Severity Level III violation (Supplement I). (Civil Penalty - $25,000) Summary of the Licensee's Response The licensee reviewed the normal operating configurations for auxiliary feed-water (AFW) systems at a number of Pressurized Water Reactors throuohout the country and concluded that the configuration of the Zion auxiliary feedwater system with one AFW pump inoperable provided either equivalent or superior flow capacity and/or redundancy to that provided by the normal auxiliary feedwater configuration at a number of operating nuclear power plants. The licensee believes it is being penalized for constructing Zion Station with an auxiliary feedwater system design that exceeds minimum NRC requirements. In addition, the licensee reviewed past enforcement actions taken for violations concerning the auxiliary feedwater system. The licensee concluded that the proposed enforcement action for Zion was more severe than for comparable incidents. Based on these reviews, the licensee believes the isolation of service water to the IB auxiliary feedwater pump at the Zion Station for a period of 22 days is more properly characterized as a Severity Level IV violation. The licensee's response also stated the event was promptly identified, the corrective actions were both timely and extensive, and the enforcement policy allows for more extensive mitigation than was exercised in this case. The licensee further contends that Zion Station realized immediately the potential significance of this event. e ...... e
Appendix 2 NRC Evaluation of the Licensee's Response In reaching the decision to issue the April 15, 1986 Notice of Violation and 2 Proposed Imposition of Civil Penalty, the NRC staff considered a number of factors, including the importance of this system to assure adequate cooling of the reactor and the root cause of this event which involved personnel errors and a failure to consistently follow procedures. These personnel errors included: (1) the radwaste foreman apparently closed Valve 1SW 0656 and neither he nor the oncoming shift engineer initiated a non-routine valve lineup sheet to track this activity. (2) comunications between the radwaste foreman and the oncoming shift engineer were vague and unspecified, (3) some shift engineers were not aware of the normal lineup for the AFW lube oil coolers and this apparently contributed to the misconception that shutting a j " crosstie" would not affect the other unit, and (4) the procedure for non- - routine valve lineups has not been consistently applied. The NRC staff recognizes that the Zion Station auxiliary feedwater system continued to satisfy the single failure criterion even with one AFW pump inoperable. However, the licensee is required to operate and maintain the auxiliary feedwater system, a significant accident mitigation system, in I accordance with the regulatory requirements in the Zion Technical Specifications. i The NRC agrees that the safety significance of the Zion event was minimized because of the redundancy and capacity of the remaining AFW pumps. Two AFW pumps remained operable with a total capacity of 300 percent of the design flow required from the AFW system. The NRC evaluation of the Zion event shows, as was asserted by the licensee, that the Zion event was of less safety significance than of other AFW system violations for which escalated enforcement actions were taken. Further, the NRC considers the corrective actions taken by the licensee appropriate for the safety significance of the event. Therefore, after careful evaluation of these factors and the discussion presented in the licensee's letter, the NRC staff has concluded that, although the viola-tion did occur as stated, it was of less safety significance than originally considered. Although personnel errors were the cause of the violation, we note that the licensee has performed 58 hydrostatic tests during the last Unit 1 and 2 outages and this is the only example of a valve lineup error that i was not identified by the licensee during the review process. Accordingly, the violation has been more appropriately determined to be a Severity Level IV violation. Conclusion The NRC staff believes that a reduction of the Severity Level from III to IV is warranted and that the $25,000 civil penalty previously proposed be withdrawn. Since the proposed civil penalty has been withdrawn, there was no further consideration of the licensee's request for additional mitigation. 4 l m ms m-- r---- w----mee-w,,,-,_ m-
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