ML20234F044

Forwards Insp Repts 50-295/87-32 & 50-304/87-33 on 870921- 1026 & Notice of Violation & Proposed Imposition of Civil Penalty.Nrc Has Issued Several Documents Re Measures to Assure Isolation of Certain Pressure Isolation Check Valves

ML20234F044
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	01/04/1988
From:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Oconnor J COMMONWEALTH EDISON CO.
Shared Package
ML20234F048	List: ML20234F044 ML20234F143
References
EA-87-211, GL-87-06, GL-87-6, NUDOCS 8801110308
Download: ML20234F044 (4)

See also: IR 05000295/1987032

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Docket Nos. 50-295; 50-304

Licenses No. DPR-39; DPR-48

EA 87-211

Commonwealth Edison Company

ATTN: Mr. James J. O'Connor

President

Post Office Box 767

Chicago, IL 60690

Gentlemen:

SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY

NRC INSPECTION REPORTS NO. 50-295/87032(DRP);50-304/87033(DRP)

This refers to the NRC inspection conducted during the period September 21

through October 26, 1987, at the Zion Generating Station, Units 1 and 2, of

activities authorized by NRC Operating Licenses No. DPR-39 and No. DPR-48

relating to the testing of pressure isolation check valves (PIVs). This

inspection identified inadequacies in the Commonwealth Edison Company (CECO)

Quality Assurance (QA) Program and management controls to ensure adequate

testing of Zion Station's PIVs. The details were presented in the inspection

report sent to you by letter dated October 29, 1987. On October 30, 1987, an

enforcement conference was held with members of your staff in the Region III

office to discuss the violations, the root causes, and CECO's corrective actions.

The NRC has issued several documents related to measures to assure the pressure

isolation capability of certain PIVs (" Event V" check valves). In a 10 CFR

50.54(f) letter to CECO dated February 23, 1980 and a Generic Letter 87-06

dated March 13, 1987, the NRC requested information related to, among other

items, whether " Event V" configuration check valves existed in the facility

and whether surveillance or periodic tests were done on such valves with

specific emphat,is on individual valve surveillance or testing, and testing

each time the check valve is moved from the fully closed position. The letters

also requested a description of the periodic tests or measures to assure valve

integrity, leakage acceptance criteria, if any, and the testing frequency. The

licensee was required to do check valve testing pursuant to the Confirmatory

Order issued by the NRC to CECO on February 29, 1980.

The violations in the enclosed Notice of Violation and Proposed Imposition of

Civil Penalty (Notice) are considered significant because they identify

weaknesses in the leakage testing procedures for " Event V" check valves, in the

implementation of these procedures, and in the review of these procedures.

These weaknesses resulted in several Unit 2 valves not having valid leakage

test results and in the lack of assurance that these valves would perform

their isolation function. These testing weaknesses included: (1) testing, in

some instances, as many as 16 check valves at one time, many in series, rather

than individually; (2) testing confi

across the valves being tested; (3)procedures gurationsspecifying

which lacked pressure

inaccurate differential

visual 4

means of measuring flow or specifying incorrect instrument lineups; (4) procedures

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Comme.weaith Edison Co. -2- JAN 4 1968

specifying observation of a downstream pressure higher than that which was

applied upstream or personnel failing to obtain the proper test pressure;

(5) failing to have appropriate precautions to assure that proper pretest

conditions were established before the start of a new test procedure section;

and (6) failing to perform valid periodic testing during a refueling outage

which lasted from March through August 1987 .

The NRC has concluded that the violations resulted from multiple examples of

engineering deficiencies, invalid test methodology and inappropriate acceptance

I

criteria. In addition, there was an overall failure to apply the CECO approved

Quality Assurance Program and other management controls as they relate to the

Zion Station's PIV test program. We have concluded that the PIV testing program

would not have been able to detect individual PIV degradation or failure. We are

particularly concerned that CECO continued to maintain, until shortly before the

October 30, 1987 enforcement conference, that its PIV testing program was adequate

to test the pressure isolation function of the PIVs and that it did meet

regulatory requirements. Such a position was without merit and inconsistent

with acceptable testing and engineering practices.

To emphasize the importance of proper control of testing activities and the need

to effectively implement testing programs that will provide early identification

or equipment or component deficiencies, I .have been authorized, after consultation

with the Director, Office of Enforcement, and the Deputy Executive Director for

Regional Operations, to issue the enclosed Notice of Violation and Proposed

Imposition of Civil Penalty in the amount of One Hundred Thousand Dollars

($100,000) for the violations described in the enclosed Notice. In accordance

with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"

10 CFR Part 2, Appendix C (1987) (Enforcement Policy), the violations described

in the enclosed Notice have been categorized in the aggregate as a Severity

Level III problem. The base value of a civil penalty for a Severity Level III

violation or problem is $50,000. The escalation and mitigation factors in the

Enforcement Policy were considered and the base civil penalty amount has been

.

increased by 100% percent because: (1) the notice of the potential PIV problems

l

and of the importance of an effective valve testing program provided by the

February 23,1980 50.54(f) letter and Generic Letter 87-06 issued on March 13,

'

1987; (2) the numerous instances of deficiencies in the licensee's testing

l procedures and in the implementation of these procedures during the period

'

from 1980 - 1987; and (3) the extended duration for which these violations

existed, approximately seven years.

You are required to respond to this letter and should follow the instructions

specified in the enclosed Notice when preparing your response. In your

response, you should dccument the specific actions taken and any additional

actions you plan to prevent recurrence. After reviewing your response to this

Notice, including your proposed corrective actions and the results of future

inspections, the NRC will determine whether further NRC enforcement action is

necessary to ensure compliance with NRC regulatory requirements.

The NRC staff is currently reviewing the circumstances surrounding the CECO

submittals to the NRC regarding the repair of leaking PIVs. You will be

notified of any action after our review of this matter has been completed. No

response regarding this matter is required at this time.

..

_ _ _ _ _ _ _ _ _ _ - - _

.

.

Commonwealth Edison Co. -3- 'JAN 4 198

In accordance with Section 2.790 of the NRC's Rules of Practice," Part 2,

Title 10, Code of Federal Regulations, a copy of this letter and its

enclosures will be place in the NRC Public Document Room.

The responses directed by this letter and the enclosed Notice are not subject

to the clearance procedures of the Office of Management and Budget as required

by the Paperwork Reduction Act of 1980, PL 96-511.

Sincerely,

Original signed by

'A. Dert Davio

A. Bert Davis

Regional Administrator

Enclosures:

1. Notice of Violation

and Proposed Imposition

, of Civil Penalty

I 2. Inspection Reports

1

No. 50-295/87032(DRP);

No. 50-304/87033(DRP)

cc w/ enclosures:

Cordell Reed, Senior

Vice President

T. J. Maiman, Vice President

PWR Operations

D. Butterfield, Nuclear

! Licensing Manager

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G. J. Pliml, Station Manager

l Jan Norris, Project Manager,

NRR

DCD/DCB (RIDS)

Licensing Fee Management

Branch l

Resident Inspector, RIII

Richard Hubbard

J. W. McCaffrey, Chief,

Public Utilities

Division

Mayor, City of Zion

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RI I RIII RIII RIII i

c u tz d us

1/ y /88

Pa ello Da s

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Commonwealth Edison Company ,g . 4 jggs

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DISTRIBUTION:

PDR

SECY

CA i

JMTaylor, DEDO

TMartin, DEDR0 4

LChandler, OGC l

JLieberman, OE  !

9Wong 0E

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ABDavis, RIII

Enforcement Coordinators

RI, RII, RIII, RIV, RV

FMiraglia, NRR

BHayes, 01

SConnelly, 01A

EJordan, AE00

1 FIngram, PA -!

DCS

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