ML20234F044
| 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: |
| 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
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
across the valves being tested; (3) gurations which lacked pressure differential
than individually; (2) testing confi
procedures specifying inaccurate visual
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means of measuring flow or specifying incorrect instrument lineups; (4) procedures
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Comme.weaith Edison Co.
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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
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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
.
and of the importance of an effective valve testing program provided by the
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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
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procedures and in the implementation of these procedures during the period
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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.
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Commonwealth Edison Co.
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'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.
and Proposed Imposition
of Civil Penalty
,
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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
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Jan Norris, Project Manager,
DCD/DCB (RIDS)
Licensing Fee Management
Branch
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Resident Inspector, RIII
Richard Hubbard
J. W. McCaffrey, Chief,
Public Utilities
Division
Mayor, City of Zion
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DISTRIBUTION:
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JMTaylor, DEDO
TMartin, DEDR0
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LChandler, OGC
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JLieberman, OE
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ABDavis, RIII
Enforcement Coordinators
RI, RII, RIII, RIV, RV
FMiraglia, NRR
BHayes, 01
SConnelly, 01A
EJordan, AE00
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FIngram, PA
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