IR 05000295/1987005
| ML20235N055 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 10/02/1987 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Oconnor J COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20235N058 | List: |
| References | |
| EA-87-105, NUDOCS 8710060377 | |
| Download: ML20235N055 (4) | |
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Docket Nos. 50-295; 50-304 License Nos. DPR-39; DPR-48 EA 87-105-Commonwealth Edison Company ATTN:
Mr.' James J. O'Connor President Post Office. Box 767 Chicago, Illinois 60690 Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY NRC INSPECTION REPORTS NO. 50-295/87005(DRSS); 50-304/87005(DRSS)
This refers to the NRC inspection conducted during the period March 2 through June 10, 1987, at the Zion Generating Station Units 1 and 2, Zion Illinois, of activities authorized by NRC Operating Licenses No. DPR-39 and No. DPR-43 and-to the circumstances associated with the failure of the control room makeup air charcoal adsorber system to meet design requirements. This matter, which was discovered _on September 15, 1986, and reported to NRC on October 10, 1986, involves a violation of NRC regulatory requirements. The details are presented in the subject inspection report which was sent to you by letter dated July 10, 1987. On July 15, 1987, we held an enforcement conference with members of your staff during which the violation, the root cause, and your corrective actions were discussed.
The violation, which is descritted in the enclosed Notice of Violation and Proposed. Imposition of Civil Penalty, resulted from a failure to install the control room emergency ventilation system as designed.
Further, you operated the Zion units without evaluating the as-built system configuration in accordance with 10 CFR 50.59. The unfiltered inleakage would have resulted in thyroid doses in excess of those previously calculated and stated in the Updated Final Safety Analysis Report (UFSAR), thereby increasing the consequences of an accident previously evaluated in UFSAR.
Consequently, the discrepancy between the as-built system configuration and the UFSAR description involved an unreviewed safety question as defined in 10 CFR 50.59.
We have reviewed your position presented at the enforcement conference that given the plant specific parameters of the Zion Station in the event of a design basis loss of coolant accident, the control room ventilation system would have been able to limit control room personnel thyroid doses to 30 rem.
We acknowledge the difference between the plant specific parameters and the assumptions made in the NRC standard review plan.
The differences in those criteria were taken into consideration when categorizing the severity level of this violation. Nevertheless, using either the assumptions employed in CERTIFIED MAIL RETURN RECEIPT REQUESTED B710060377 e71002 PDR ADOCK 05000295
PDR I
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MF Commonwealth Edison Company
your analysis or those ' sed by the NRC staff, the radiation doses to personnel u
in the control room would have been higher than previously calculated. The control room-ventilation system' therefore, could not perform as designed and this departure from the design was not properly evaluated.
The NRC staff recognizes that you have not made-a literal change to the control room ventilation system since receiving an operating license.
However, the cited NRC regulations make it clear that it is expected that facilities match the FSAR in the absence of reviews conducted pursuant to 10 CFR 50.59.
Your failure to assure that the Zion facility was in conformance with the FSAR is i
a violation of NRC regulations.
L The root causes of the. violation described in the Notice were:
(1) a failure
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to construct the control room ventilation system in accordance with design drawings; (2) an inadequate audit and quality assurance system which permitted i
L the control room ventilation system construction deficiency to go undisclosed, and (3) inadequate understanding by your operations and engineering personnel of the actual system configuration.
To emphasize the importance of verifying proper construction and maintaining i
accurate safety-related system design descriptions, I have been authorized, l
after consultation with the Director, Office of Enforcement, to. issue the
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enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Fif ty Thousand Dollars (550,000) for the violation described in the enclosed Notice. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement A:tiens," 10 CFR Part 2, Ap'pendix C (1987)
(Enforcement Policy), the violation described in the enclosed Notice has been categorized at Severity Level III.
The base value of a civil penalty for a Severity Level III violation is $50,000.
The escalation and mitigation factors in the Enforcement Policy were considered and no adjustment has been deemed appropriate.
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 document the specific actions taken and any additional actions you plan to prevent recurrence.
Your actions should include a review of the concerns outlined in Paragraphs 5(c) and (d) of NRC Inspection Report No. 50-295/87005 and No. 50-304/87005.
In addition, your response should provide the basis for having confidence that the control room ventilation system as well as other safety systems are in fact as described in the FSAR or properly evaluated pursuant to 10 CFR 50.59. 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.
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 placed in the NRC Public Document Room.
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Commonwealth Edison Company
007 2 1987 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 nignod by'
1. Bert Davia A. Bert Davis Regional Administrator Enclosures:
1.
Notice of Violation and Proposed Imposition of Civil Penalty 2.
Inspection Reports No. 50-295/87005(DRSS); and No. 50-304/87005(DRSS)
cc w/ enclosures:
Cordell Reed, Senior Vice President T. J. Maiman, Vice President, PWR Operations D. Butterfield, Nuclear
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Licensing Manager i
G. J. Plim1, Station Manager l
Jan Norris, Project Manager, NRR i
DCD/DCB'(RIDS)
i Licensing Fee Management Branch Resident Inspector, RIII Richard Hubbard J. W. McCaffrey, Chief, Public l
Utilities Division Mayor, City of Zion l
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Commonwealth Edison Company OCT 2 1937 Distribution PDR SECY CA JTaylor, DEDO ABDavis, RIII JLieberman, OE JLuehman, OE LChandler, 0GC Enforcement Coordinators RI, RII, RIII, RIV, RV EJordan, AE0D BHayes, 01 SConnelly, OIA FIngram, PA.
Jan Norris, Project Manager, NRR Licensing Fee Management Branch Resident Inspector, RIII Richard Hubbard J. W. McCaffrey, Chief, Public Utilities Division Mayor, City of Zion OE Files EDO Rdg File DCS l
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