ML20217P966
| ML20217P966 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 08/15/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20217P964 | List: |
| References | |
| 50-295-97-13, 50-304-97-13, EA-97-109, NUDOCS 9708290077 | |
| Download: ML20217P966 (4) | |
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NOTICE OF VIOLATION Commonwealth Edison Company Docket Nos. 50 295; 50-304 Zion Nuclear Generating Station Licerise Nos. DPR 39; DPR-48 EA No.97-109 During an NRC inspection conducted on April 4 through May 29,1997, three violations of NRC requirements word identified in accordance with the "Goneral Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violations are listed below:
1.
Technical Specification (TS) 6.2.1.1 requires that writton procedures be prepared, implemented, and mair 'ained for working hours of the Shift Enginoor, Shift Control Room Engineer, Shift i 9 man, and Nuclear Station Operator such that the heavy use of overtimo is not rs..inely required.
Zion Administrativo Procedure 200-01, " Station Organization," Revision 4, Table 1 A, clarifies the relationship of TS organization nomenclature to corresponding plant proceduro titles. Specifically, TS 6.2.1.i nomencl:ture refers to the following plant procedure position titlos: Shift Manager, Shif t Control Room Engincor, Shif t Technical Advisor, Unit Supervisor, Licensed Shif t Supervisor, and Nucioar Station Operator.
Zion Administrative Proceduto 200 04, " Overtime Guidelines," Ravision 2, Section F,4.b, requires that unless approval is granted per this procedure, an individual is not permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period, all excluding shif t turnover time.
Contrary to the above, the inspectors identified that from March 10 through May 18,1997, overtimo in excess of the guidolinos without approval was routinely used to accomplish operations department work activities. The inspectors reviewed gatehouse access records for four Shift Managers, three Unit Supervisors, and three Nuclear Station Operators and identified 83 examples of overtimo in excess of the guidelinos without approval including: one example of an individual working greater than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in a 24-hour period, three examples of individuals working greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7-day period, and 79 examples of individuals working greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48-hour period, all excluding shift turnover time.
This is a Severity LevelIV violation (Supplement 1).
(50 295/97013-02; 50-304/97013-02) 2.
10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings,"
requires that activities affecting quality be proscrit'ed by documented instructions, proceduros, or drawings of a type appropriate to the circumstances and that these activities be accomplished in accordance vcith these instructions, procedures, or drawings.
9708290077 970815 PDR ADOCK 05000295 O
s
- Notice of Violation 2-Zion Administrative Procedure 900 05, " Control, Use, and Storage of Flammable and Combustible Liquids and Aerosols," Revision 1, Section F.7, requires that adequate natural or mechanical ventilation is ensured in areas where flammable liquids or aerosols are to be used.
Zion Administrative Procedure 40014, " Equipment and Tool Storage in Safety Related Areas," Revision 0, Attachment B.5, requires that items which do not meet the height to width ratio (less than or equal to two) and are not stored in an approved location must be seismically restrained.
4 Zion Administrative Procedure 900 08," Station Fire Brigade," Revision 3, Section G.1, requires that any person discovering a fire is to immediately report it to the control room.
Contrary to the above, activities affecting quality were not accomplished in accordance with applicable procedures or instructions in the following instances:
a.
On May 24,1997, mechanical maintenance personnel did not ensure that adequate natural or mechanical ventilation was established whde applying a flammable lubricant to the Unit 1 reactor vessel stud holes: consequently, a flash fire resulted.
b.
On May 19,1997, the inspectors identified that a deconning machine and a storage cabinet were not stored in approvsd locations and did not meet the required height to width ratio, nor had the equipment been seismically I
restrained.
c.
On May 24,1997, upon observing a fire in the Unit 1 containment building, a Radiation Protection Technician failed to immediately report the fire to the control room.
This is a Severity Level IV violation (Supplement 1).
(50 295/97013-03; 50-304/97013 03) 3, 10 CFR 50.5(a)(1), " Deliberate Misconduct," requires, in part, that any employee of a licensee may not engage in deliberate misconduct that causes a licensee to be in violation of any license issued by the Commission.
License Nos. OPR-39 and DPR-48, Paragraph 2.C(5), states, in part, that the licensee is to implement and maintain in effect all provisions of the approved Fire Protection Program as described in the (Updated) Final Safety Analysis Report for the Zion Nuclear Power Station.
Updated Final Safety Analysis Report Section 9.5.1, " Fire Protection System,"
states,in part, that a detailed dracription of the plant's Fire Protection System (which License Nos. OPR-39 and DPR 48, Paragraph 2.C(5) requires to be implemented and maintained) is contained in the Fire Protection Report.
4
Notice of Violaticn.
The Zion Generating Station Fire Protection Report, Section 4.3, " Quality Assurance," states that tests of fire protection equipment and the fire protection system are included in regularly scheduled operating surveillance procedures.
Contrary to the above, from May 24,1994, to October 11,1995, two individuals falsified the data sheets for the Electrical Maintenance Surveillance Procedure (EMSP) 03, " Emergency Light Surveillance," Revision 1, which was a required surveillance for meeting the license condition. Specifically:
a.
On May 24,1994, an individual recorded 12 volts for 19 six volt emerQency light batteries on the data sheets.
b.
On St,ptember 12 and October 11,1995, the same individual recorded data for emergency light battery surveillances. However, the security computer access records showed that the individual had not entered the applicable plant areas to record the data.
On August 27 and 28,1995, another individual recorded 20 readings on the c.
data sheets exactly one minute apart. Based upon a walkdown of the applicable omorgency lights, the licensee concluded that recording each reading exactly one minute apart was extremely difficult to achieve.
This is a Severity Level IV violation (Supplement 1).
(50-295/97013-05; 50-304/97013-05)
With respect to the violation involving the deliberate falsification of data sheets, the NRC has concluded that information regarding the reason for the violation, the corrective actions taken to correct the violation and prevent recurrence, and the date when full compliance was achieved are already adequately addressed on the docket in your April 3, 1996, response to the Severity Levellli Notice of Violation and Civil Penalty dated March 22,1996, and in the enclosed inspection report (50-295/97013; 50-304/97013).
However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the discussion in these documents does not accurately leflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a " Reply to a Notice of Violation," and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region lil, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter
- transmitting this Notice of Violation (Notice).
With respect to the other violations, pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region 111, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice. This reply should be clearly marked as a " Reply to a Notice of Violat;on" and should include for each violation: (1) the reason
9 Notice of Violation 4-for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.
.Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response, if an adequate reply is not received within the time specified in the Notice, an order or a Demand for information may-be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction, if personal privacy or 4
proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information if you request withholding of such material, you mMit specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (o.g., explain why the disclosure of information will create an unwarranted invasion of p i ar v cy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financialinformation), if safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
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Dated at Lisle, Illinois, this 15th day of August 1997 i
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