IR 05000254/1993009
| ML20046C713 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 08/06/1993 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Wallace M COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20046C714 | List: |
| References | |
| EA-93-162, NUDOCS 9308120001 | |
| Download: ML20046C713 (6) | |
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/giog'o UNITED STATES NUCLEAR REGULATORY COMMISSION g
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GLEN ELLYN. ILLINOIS 60137-5927 E
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August 6, 1993 Docket Nos.
50-254 and 50-265 License Nos.
DPR-29 and DPR-30 EA 93-162 Commonwealth Edison Company ATTN:
Mr. Michael Vice President, Chief Nuclear Officer Executive Towers West III 1400 Opus Place, Suite 300 Downers Grove, Illinois 60515
Dear Mr. Wallace:
SUBJECT:
QUAD CITIES STATION - UNITS 1 AND 2 NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY - $50,000 (NRC INSPECTION REPORT NO. 50-254/265/93009(DRS))
This refers to the special safety inspection conducted during the periods of February 24-26, April 19-23, and May 27, 1993, at Quad Cities Station, Units 1 and 2.
The report documenting this inspection was sent to you by letter dated June 11, 1993.
An enforcement conference was held on June 21, 1993, and a report summarizing the conference was sent to you by letter dated June 23, 1993.
During an Octcber 1992 fire protection system enginecr turnover, the new system engineer identified that QAP 1176-19,
" Administrative Requirements for Fire Protection," was not being followed.
A deviation report was written which prompted your staff to further investigate the adequacy of the fire protection and safe shutdown programs.
This ultimately resulted in your submittal of voluntary Licensee Event Report (LER)92-032 dated January 7, 1993.
During the NRC inspection of the LER, four violations were identified as described in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice).
The violations involve: (1) operation of Unit 2 with the Unit 1 RHR servi'e water system loop A (opposite unit / shared safe shutdown component) inoperable for greater than 67 days; (2) failure to establish and implement certain fire protection procedures, and procedures to track opposite unit / shared unit safe shutdown components when equipment w&s taken out-of-service; (3) failure CERTIFIED MAIL RETURN RECEIPT REOUESTED
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to establish a test program to periodically demonstrate satisfactory performance of certain safe shutdown components; and (4) failure to correct deficiencies in safe shutdown equipment status tracking and equipment testing although the deficiencies were specifically identified in 1989 and 1990.
The root cause of the violations was management's failure to place a proper safety emphasis on fire protection and safe shutdown issues.
This resulted in failure to effect corrective actions for known fire protection and safe shutdown deficiencies and ineffective fire protection engineer performance.
Specifically, Quad Cities management had information, as early as 1986, that indicated deficiencies existed in the safe shutdown equipment control and testing and as early as 1989 for the fire protection deficiencies.
The deficiencies went uncorrected and were reconfirmed during audits in 1989 and 1990.
It was not until late 1992, when a new system engineer again identified the problems, that corrective actions were proposed.
However, it was not until NRC followup on the issues in 1993 that actions appropriate to the circumstances were implemented.
There were deficiencies in the system engineering program in that the fire protection system engineers were not thoroughly knowledgeable of their systems, a high turnover rate exacerbated knowledge deficiencies and resulted in a lack of continuity, and a heavy workload hampered the engineers' ability to properly analyze problems.
In general, weakness in engineering expertise at Quad Cities has been a continuing problem as evidenced by comments in the SALP 9 report, your response to the SALP 10 report, and most recently by the findings of a review conducted by NRC AEOD personnel in November 1992.
We acknowledge cour corrective actions for the violations in the Notice, which iceluded functional testing of detection systems, review of QAP 1170-19, qualification of the fire protection system engineer, review of sample of pre-1986 modifications to
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ensure that testing requirer.=nts have been incorporated into procedures, removal of the turbine rotor unstacking transformers, issuance of a policy on assigning priority ior resolutiori of code deviations, testing of opposite unit / chared unit safe shutdown systems and equipment, and implementation of administrative technical requirements.
However, your initial approach 1or testing sata shutdown components, following identif ication of problems in October 1992, was not proactive.
Your initial plans were to wait until procedures were implemented in December 1993, rather than prepare interin test proceduren.
You did not accelerate the testing of these components until prompted to do no during the NRC inspection.
From a plant eauipment standpoint, the potential satety consequences of the violationr was determined to be low ar your subsequent testing ot the 1 ire detection and sa1e shutdown i
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equipment found only a few problems.
The testing did identify deficiencies in three out of ten turbine bearing deluge systems, and the alternate feed to the 2B RHR room cooler fan, although the Unit 1 RHR service water system loop A was available to supply RHR service water to Unit 2 prior to expiration of the-67 day limiting condition for operation.
However, it should be noted that it had not been declared operable as defined by your Technical Specifications.
Finally, while you did determine that j
there was another means to achieve and maintain Unit 2 in a safe shutdown condition following a design basis fire without the Unit 1 RHR service water system loop A, that method was not reflected i
in the appropriate implementing procedures.
i Sufficient plant equipment, that would be relied on to achieve safe shutdown, was ultimately determined to be available.
Nevertheless, the violations in the Notico represent a breakdown in the control of licensed activities and a significant lack of attention towards licensed responsibilities.
Of particular concern is the violation that relates to programmatic deficiencies which were previously identified on a number of occasions.
Therefore, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"
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(Fnforcement Policy) 10 CFR Part 2, Appendix C, the violations are classified in the aggregate as a Severity Level III problem.
To emphasize the need for increased management attention to the fire protection and safe shutdown programs, including appropriate prioritization of known problems, and increased system engineer continuity for oversight of critical systems, I have been i
authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Fesearch, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) in the amount of $50,000 for the violations described in the Notice.
The base value of a civil penalty for a Severity Level III violation is $50,000.
The civil penalty
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adjustment factors in the Enforcement Policy were considered as l
discussed below.
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i The base civil penalty was mitigated 50 percent because your staff identified the violations.
In particular, the new fire protection engineer demonstrated the type of questioning attitude that you should expect from all your personnel.
The base civil penalty was not mitigated for your corrective actions because, as
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I discussed above, your corrective actions were not originally scheduled to be promptly implemented.
The civil penalty was l
escalated 50 percent because of the prior opportunities your i
staff had to respond to the programmatic concerns discussed in j-the Notice.
The other adjustment factors in the policy were
considered and no further adjustment to the base civil penalty is considered appropriate.
Therefore, based on the above, a civil
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penalty equal to the base civil penalty is proposed.
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.
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 10 CFR 2.790 of the NRC's " Rules of Practice,"
a copy of this letter, its enclosure, and your. responses will be placed 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, Public Law No.96-511.
Sincerely,
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f7AY k Jo n B. Martin Regional Administrator Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty cc w/ enclosure:
L.
DelGeorge, Vice President, Nuclear Oversight and Regulatory l
Services cc w/ enclosure:
See Next Page
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cc w/ enclosure:
(Con't)
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R.
Pleniewicz, Site Vice President R.
Bax, Station Manager A. Misak, Regulatory Assurance
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Supervisor D.
Farrar, Nuclear Regulatory I
Services Manager OC/LFDCB
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Resident Inspectors, Quad Cities, Dresden, LaSalle, Clinton i
Richard Hubbard l
J.
W. McCaffrey, Chief, Public Counsel, State of Illinois Center i
Licensing Project Manager, NRR
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R.
Newmann, Office of Public Counsel, l
State of Illinois Center
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State Liason Officer
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DISTRIBUTION PDR SECY CA JTaylor, EDO JSniezek, DEDR JLieberman, OE LChandler, OGC JGoldberg, OGC TMurley, NRR JPartlow, NRR Enforcement Coordinators RI, RII, RIV, RV FIngram, GPA/PA DWilliams, OIG BHayes, OI EJordan, AEOD JLuehman, OE Day File EA File DCS State of Illinois RAO:RIII SLO:RIII PAO:RIII IMS:RIII i
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