IR 05000295/1986032

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Discusses Safety Insp Repts 50-295/86-32 & 50-304/86-32 on 861210-870116 & Forwards Notice of Violation.Response Should List Corrective Actions & Address Controls to Preclude Instances of Mispositioned Containment Isolation Valves
ML20235L857
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 07/13/1987
From: Norelius C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Reed C
COMMONWEALTH EDISON CO.
Shared Package
ML20235L858 List:
References
NUDOCS 8707160850
Download: ML20235L857 (2)


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M JUL 131987 Docket No. 50-295 Docket No. 50-304 Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:

This refers to our letter dated February 9, 1987, which forwarded the results of a special safety inspection conducted to review the circumstances surrounding the mispositioned containment isolation valves (CIVs) in the Unit 2 demineralized water (DW) system which resulted in a violation of containment integrity (NRC Inspection Reports 295/86032(DRP) and 304/86032(DRP)). The letter also stated that we were evaluating enforcement action The evaluation has been completed and the NRC staff has determined that certain of your activities appear to be in violation of NRC requirements, as specified in the enclosed Notice. The inspection found that for approximately 314 days, Unit 2 containment integrity was violated with the reactor above cold shutdown because two DW CIVs had been left open. This violation of containment integrity was considered significant because under certain conditions (severe accident coincident with a seismic event) the contafr. ment would not be able to perform its intended function. This condition existed for over 10 months, and was not recognized until several days after the DW CIVs were found ope In addition, these two DW CIVs were not included in either section 4.9-3 of the facility Technical Specifications or in station operating procedure We have considered the additional information you provided at an Enforcement Conference held in the Region III office on March 2, 1987, between you and members of your staff and Mr. A. B. Davis and members of the Region III staf Your analysis of the potential offsite release which would result in the event that a design basis LOCA occurred coincident with shearing of the DW header inside the containment (assuming normal DW system leakage and no seismic event)

concluded that the resultant off-site doses would remain well below the limits of 10 CFR Part 100. We therefore categorize these two violations at 1 Severity Level IV. A written response is require l l

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The NRC is concerned that the control of CIVs at the Zion station was not l sufficiently rigorous to prevent two CIVs from being out of position (open)

for over three hundred days. In addition, we are concerned about other examples of valves being out of position at Zion in the past year. Therefore, in addition to describing your specific action to correct the noted violation, please describe your controls to preclude further instances of mispositioned valve ( PDR ADOCK 05000295

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Commonwealth Edison Company 2 dOb i 8 lbO7 Your reply to this letter and the results of future inspections in this area i will be considered in determining whether escalated enforcement actions may be appropriate if similar violations are identified during future inspection In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter, the enclosures, and your response to this letter will be placed in the NRC Public Document Roo The responses directed by this letter and the accompanying 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 96-51 We will gladly discuss any questions you have concerning this inspectio

Sincerely, CRIGINMEMirr C.Y.Mt)NTNi Charles E. Norelius, Director Division of Reactor Projects Enclosure: Notice of Violation

'cc w/ enclosure:

D. L. Farrar, Director of Nuclear Licensing G. J. Plim1, Station Manager Jan Norris, Project Manager, NRR DCS/RSB (RIDS)

Licensing Fee Management Branch Resident Inspector, RIII '

Richard Hubbard J. W. McCaffrey, Chief, Public Utilities Division Mayor, City of Zion J. Lieberman, OE

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