ML20217R244
| ML20217R244 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 09/02/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20217R227 | List: |
| References | |
| EA-97-222, EA-97-223, NUDOCS 9709040365 | |
| Download: ML20217R244 (8) | |
Text
F_~
D f
4 y
AND PROPOSEC IMPOSITION OF civil PENALTIES Commonwealth Edison Company Docket Nos: 50-295 and 50-304 Zion Nuclear Generating Station License Nos: DPR-39 and DPR 48 EAs97-222 and 97-223 During NRC inspections conducted from February 6 through April 28,1997, several violations of NRC requirements were identified, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the NRC proposes to impose a civil penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as amanded (Act),
42 U.S.C. 2282, and 10 CFR 2.205. The particular violations and associated civil penalties are set forth below:
1, ylolations Assessed a Civil Penaltv A.1 Heactivitv Manaaement
]
Zion Technical Specification 6.2, Procedures and Proarams, requires, in part, that a
"(w]ritten procedures including applicable checkoff lists covering items listed below B
shall be prepared, implemented, and maintained: a.) The applicable procedures recommended in Appendix A, of Regulatory Guide 1.33, Revision 2, February 1978."
Appi;r, dix A of Regulsiory Guide 1.33, Revision 2 dated February 1978, recommends that written procedures should cover activities associated with " Authorities and Respons%.m t r Safe Operation," (paragraph 1.b) and " General Plant Operating Procedur& 4.tacaph 2) activities associated with all modes of operation, a.
General Operating Procedure (GOP) 4, " Plant Shutdown and Cooldown,"
Revision 13, partially implements paragraph 2 of Appendix A to Regulatory Guide 1.33, in Mode 2 with the reactor critical, step 5.21.f, states Hold "#363, ROD MOTION CONTROL" switch IN to minimize dumping steam and establish power at or less than the point of adding heat." (2.5 x 10E-2% intermediate range PR) or 0.025 percent power).
Contrary to the above, on February 21 1997, with the reactor critical in Mode 2, the primary Nuclear Station Operator (NSO) manipulated the control rods, but did not accomplish this activity in accordance with GOP-4, step 5.21.f.
Specifically, the primary NSO did not establish power at or less than the point of adding heat in accordance with GOP-4, step 5.21.f, but made the reactor sub-critical, i.e., entered Mode 3 (01013) b.
Zion Administrative Procedure (ZAP) 300-01B, " Reactivity Management Guidelines," Revision 1, partially implements paragraph 1.b of Appendix A to Regulatory Guide 1.33. Section G.2.c.1, states that strict reactivity controls are 9707040365 970902 PDR ADOCK 05000295 G
required to minimize the potential for core damage, and that all plant personnel, particularly operators, must stop and question unexpected situations involving reactivity, criticality, power level, or core anomalies.
Contrary to the above, on February 21,1997, the primary Nuclear Station Operator failed to implement strict reactivity controls when he did not stop and question unexpected changes in reactivity, criticality, and power level. The primary Nuclear Station Operator made the reactor substantially sub-critical (non-power) and, instead of stopping and evaluating the unexpected change in reactivity and criticality, he attempted to retum the reactor to the point of adding heat (0.025 percent po ver) by continuously withdrawing control rods, (01023)
ZAP 300-01B, " Reactivity Management Guidelines," Revision 1, partially c.
implements paragraph 1.b of Appendix A to Regulatory' Guide 1.33. Section G.I.1, states the Qualified Nucleer Engineer's (QNE) responsibility to implement the reactivity management policy by providing technical advice on reactivity related matters.
Contrary to the above, on February 21,1997, the ONE failed to provide technical advice on reactivity related matters to either the primary Nuclear Station Operator or the Shift Supervisor conceming the excessive control rod manipulations and resultant reactivity changes. Specifically, the ONE observed the Nuclear Station Operator (NSO) take the reactor subc.itical and then observed the NSO inappropriately add positive reactivity by withdrawing control rods in an unauthorized manner in an attempt to reachieve criticality.
Instead of promptly addressing the inappropriateness of the NSO's actions, the ONE, by his inaction, allowed the unauthorized control rod withdrawal to continue and left the control room to wiscuss the matter with the Lead Nuclear Engineer. (01033)
A.2 Command. Control. and Communication Zion Technical Specification 6.2, Procedures and Proarams. requires that "[w]ritten procedures including applicable checkoff lists covering items listed below shall be prepared, implemented, and maintained: a.) The applicable procedures recommended in Appendix A, of Regulatory Guide 1.33, Revision 2, February 1978."
Appendix A of Regulatory Guide 1.33, Revision 2 dated February 1978, states in paragraph 1.b, that written procedures should cover activities associated with
" Authorities and Responsibilities for Safe Operation."
a.
ZAP 300-01, " Conduct of Operations," Revision 3, partially implements paragraph 1.b of Appendix A to Regulatory Guide 1.33.Section VI.A, states, in part, that all operations personnel from the Operations Manager to the Nuclear Station Operator share the responsibility for the reactor core. The Nuclear
t!*
Station Operator, Unit Supervisor and station Reactor Engineer have a greater responsibility, and share this ownership on a continuous basis.Section VI.A further states, in part, that: (1) Operations personnel SHALL be attentive to the condition of the plant at all times and (4) the Unit Supervisor and Shift Engineer should NOT become so involved in any single operation that distracts them from the overall perspective of plant operations.
Contrary to the above, on February 21,1997, while the licensee was performing a Unit i shutdown, the Shift Engineer and the Unit Supervisor were so focused on containment spray pump restoration activities that they failed to be attentive to the fact that the Nuclear Station Operator had made the reactor substantially subcritical and was withdrawing control rods, in an attempt to return the reactor to criticality. (01043) b.
ZAP 300-01, " Conduct of Operations," Revision 3 partially implements paragraph 1.b of Appendix A to Regulatory Guide 1.33. Attachment A,Section VI.A.3, requires that a briefing be conducted prior to the conduct of an infrequently performed evolution.
ZAP 300-01, " Conduct of Operations," Revision 3,Section IV.G 2 defines infrequently performed evolutions as evolutions whereby the performance frequency is greater than annually MQ the evolution requires the coordination of two or more departments, QB three or more individuals, MQ has the potential to adversely affect reactivity control, OR core cooling.
Contrary to the above, on February 21,1997, the licensee failed to perform a briefing prior to conducting an activity to maintain the reactor at the point of adding heat (2.5 x 10E-2% IR), which was an infrequently perfumed evolution in that it had not been performed in more than a year, required the coordination of three individuals, and had the potential to adversely affect reactivity control.
(01053) c.
ZAP 300-01, " Conduct of Operations," Revision 3 partially implements paragraph 1.b of Appendix A to Regulatory Guide 1.33.Section IX.E.3, requires the individual who is to perform the activity to be responsible for adequately reviewing the procedure and fully understanding assigned responsibilities, and cegnbant of all the limitations, precautions, and requirements.
1 Contrary to the tabove, on February 21,1997, the primary Nuclear Station Operator and Unit Supervisor, failed to adequately review GOP-4, " Plant Shutdown and Cooldown," prior to performing the Unit 1 shutdown and failed to understand their assigned responsibilities as evidenced by the actions of the NSO in driving in control rods until the point of adding heat as measured on the intermediate range monitors. In doing so, the NSO failed to account for the time del y associated with the addition of substantial negative reactivity and as
a result inadvertently made the reactor subcritical. The inadequate review and failure to understand assigned responsibilities was fudher demonstrated by the Nuclear Station Operatods actions in subsequently withdrawing control rods once he recognized that he had made the reactor subcritical. (01063) d.
ZAP 300-01 A, " Control Room Access and Conduct," Revision 4 partially implements paragraph 1.b of Appendix A to Regulatory Guide 1.33. Section Vill.A.2, requires that Control Room business SHALL be conducted at a location and in such a manner that neither on-shift licensed personnel attentiveness nor the professional atmosphere is compromised.
Contrary to the abou, on February 21,1997, the presence of an excessive number of individuals in the control room - 39 people were in the control room envelope, with 15 people in the immediate vicinity of the primary Nuclear Station Operator and Unit Supervisor-caused a loud and disruptive environment. The high ambient noise level due to the large number of Individuals present made communications between operators and operations supervision difficult. This created a control room environment that was not conducive to conducting a controlled and oraerly shutdown. As a result, licensed personnel attentiveness and the professional atmosphere of the control room were compromised. (01073)
ZAP 300-09, " Station Operational Communications," Revision 3 partially e.
implements paragraph 1.b of Appendix A to Regulatory Guide 1.33. Section Vll.A.3., requires, in part, that if the receiver does not understand an operational communication, then the receiver shall promptly Infom, the sender and ask the sander to repeat or rephrase the message.
Contrary to the above, on February 21,1997, the primary Nuclear Station Operator (the receiver) failed to promptly inform the Unit Supervisor (the sender) that he did not understand the communication concerning establishing power at the point of adding heat and ask the Unit Supervisor (th.) r?. der) to repeat or rephrase his message. The Nuclear Station Operator did ask the Unit supervisor if he wanted him (the Nuclear Station Operator) to drive rods in, indicating he did not understand the instruction, and instead of explaining or
)
rephrasing, the Unit supervisor simply reread the step aloud. (01083)
These violations represent a Severity Level 111 problem (Supplement I) - $110,000 B.
Corrective Actions - Reactivity Management Event 10 CFR Part 50, Appendix B, Criterion XVI," Corrective Actions," requires, in part, that measures be established to assure that conditions adverse to quality are promptly corrected, and in the case of significant conditions adverse to quality, that measures t,e established to assure that the cause of the condition is determined and corrective actions taken to preclude recurrence.
l l
1.
Contrary to the above, as of February 21,1997, following the identification by the licensee of an adverse trend in reactivity management activities, which was documented in an internal Zion Station memorandum, "ZNG:96-002" dated February 12,1996, and which constituted a significant condition adverse to quality, corres.<e actions were not prompt and commensurate with the safety significance of the issue and failed to preclude recurrence of a reactivity management event on February 21,1997. (02013) 2.
Contrary to the above, as of February 21,1997, following issuance of a Notice of Violation (50-304/96005-03) on April 8,1996, that identified an inadvertent mode change - a significant condition adverse to quality that was caused by poor communications, weak command and control, and poor reactivity management -- corrective actions taken to preclude recurrence were not adequate as demonstmted by the February 21,1997, actions of the Unit 1 operating crew, where failures in communications, command and control, and reactivity management directly caused an unauthorized and uncontrolled positive reactivity addition.(02023) 3.
Contrary to the above. as of February 21,1997, following a command and control, communication and reactivity management problem during the Unit i startup on September 16,1996, which was a significant condition adverse to quality, corrective actions taken to preclude recurrence wore not effective as demonstrated by the February 21,1997, reactivity management event. The problem that occurred on September 16,1996 was the subject of a Notice of Violation (50-295/96014-02) issued on January 28,1997. (02033)
These violations represent a Severity Level ill problem (Supplement l} - $110,000 C.
Corrective Actions - Reactor Voldina Event 10 CFR Part 50, Appendix B, Criterion XVI," Corrective Actions," requires, in part, that measures be established to assure that conditions adverse to quality are promptly identified and corrected, and in the case of significant conditions adverse to quality, that measures be established to assure that the cause of the condition is determined and corrective actions taken to preclude recurrence.
Contrary to the above, from September 2,1996, through March 8,1997 the licensee failed to take prompt corrective actions commensurate with the undetected accumulation of gas in the reactor vessel head which displaced reactor coolant and threatened the ability to maintain decay heat removal Engineering and Operations personnel had determined the corrective actions necessary to preclude recurrence but failed to revise appropriate operations procedures prior to the recurrence of the event on March 8,1997, in both Units 1 and 2. (03013)
This is a Severity Level 111 Violation (Supplement 1) - $110,000
Notbo of Violation 6
ll.
Violations Not Assessed a Civil Penalty A.
Failure to Comolv With a Limitina Condition for Ooerat!on (LCOJ Technical Specification (TS) 3.1. " Reactor Protection Instrumentation and Logic," requires, that with the minimum number of operablo channels below the limits specified by Table 3.1 1, " Reactor Protection Systems - Limiting Operation Conditions and Setpoints," plant operation shall be as specified in Column 5 of Table 3.1 1. Table 3.1 1 specifies that if there are less than a minimum of two opera' le channels per loop of Low Primary Coolant Flow, o
maintain Hot Shutdown and, if the minimum conditions are not met within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the unit shall be in the Cold Shutdown condition within an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Contrary to the above, on February 24,1997, the licensee failed to comply with the Limiting Condition for Operation of TS 3.1 when Unit 1 was not placed in cold shutdown conditions within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of rendering all three-reactor coolant system loop "A" flow instrumentation channels inoperable. (04014)
This is a Severity Level IV Violation (Supplement 1)
B.
Undetected Disolacement of Reactor Coolant 10 CFR 50, Appendix B, Critorion V, " Instructions, Procedur3s, and Drawings,"
requires, in part, that activities affecting quality be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the above, as of March 8,1997, procedures for activities affecting quality, extended operation in cold shutdown, were not appropriate to the circumstances. Specifically, no operating procedures were prescribed which included measures to diagnose or prevent the displacement of reactor coolant from the reactor vessel caused by the undetected accumulation of nitrogen gas in the reactor coolant system. (05014)
This is a Severity Level IV Violation (Supplement 1)
C.
Failure to Reoort the Accumulation of Gas in the Reastor Coolant System 10 CFR Part 50.72(b)(2)(lii)(B) requires that the licensee shall notify the NRC as soon as practical, and in all cases within four hours, of any event or condition that alone could have prevented the fulfillment of the safety function of structures or systems that are needed to remove residual heat.
10 CFR Part 50.73(a)(2)(v)(B) requires that the licensee shall submit a i
____________A
Licensee Event Report within 30 days after the discovery of the event, for any event or condition that alone could have prevented the fulfillment of the safety function of structures or systems that are needed to remove residual heat.
Contrary to the above, the licensee did not notify the NRC within four-hours and did not submit to the NRC a Licensee Event Report within 30 days after discovery that nitrogen gas had accumulated in the reactor vessel head on both Unit 1 and Unit 2 on March 8,1997. This condition (nitrogen gas accumulation in the reactor coolant system) alone could have caused the loss of both trains of shutdown cooling prior to the nitrogen gas bubble reaching the size where pressurizer level would have provided direct indication of reactor vessel water level and, therefore, could have prevented the fulfillment of the safety function of a system needed to remove residual heat. Additionally, the nitrogen gas in the reactor coolant system could have accumulated in the steam generators which would have resulted in the obstruction of natural circulation cooling. This condition also could have prevented the fulfillment of the safety function of a system needeo to remove residual heat. (06014)
This is a Severity Level IV Violation (Supplement I)
Pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison Company (the Ucensee) is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regu!atory Commission, within 30 days of the date of this Notice of Violation and Proposed imposition of Civil Penalties (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each alleged violation:
(1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, and if denied, the reasons why, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps that will be taken to avoid further violations, and (5) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this 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. Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act,42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
Within the same time as provided for the response required above under 10 CFR 2.201, the Licensee may pey the civil penalties by letter addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, money order, or electronic transfer payable to the Treasurer of the United States in the amount of the civil penalties proposed above, or the cumulative amount of the civil penalties if more than one civil penalty is proposed, or may protest imposition of the civil penalties in whole or in part, by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission. Should the Licensee fail to answer within the time specified, an order imposing the civil penalties will be issued. Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, in whole or in part, such answer should be clearly marked as an " Answer to a Notice of Violation" and may: (1) deny the violation (s)
listed in this Notice, in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalties should not be imposed, in addition to protesting the civil penalties, in whole or in part, such answer may request remission or mitigation of the penalties, in requesting mitigation of the proposed penalties, the factors addressed in Section VI.B.2 of the Enforcement Policy should be addressed, Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of the 10 CFR 2,201 reply by specific reference (e.g.,
citing page and paragraph numbers) to avoid repetition. The attention of the Licensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalties.
Upon failure to pay any civil penaltlec due which subsequently has been determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attomey General, and the penalties unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act,42 U.S.C. 2282c.
The response noted above (Reply to Notice of Violation, letter with payment of civil pen l t ;s, and Answer to a Notice of Violation) should be addressed to: Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.
20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region 111 and a copy to the NRC Resident inspector at the Zion facility.
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 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 mus1 specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or pro-vide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
Dated at Lisle, Illinois this 2nd day of September 1997
---