IR 05000254/1997017

Discusses Insp Repts 50-254/97-17 & 50-265/97-17 on 970821- 0912 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $55,000

ML20203L574
Person / Time
Site:	Quad Cities
Issue date:	03/03/1998
From:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Kingsley O COMMONWEALTH EDISON CO.
Shared Package
ML20203L576	List: IR 05000254/1997017 ML20203L583
References
50-254-97-17, 50-265-97-17, EA-97-466, NUDOCS 9803060125
Download: ML20203L574 (4)

Text

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(g4 k 9- .00NTa0 STAfst NUCLEAR REIULATORY COMMitslON

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MEGeoN 111 s01 WAMMENVILLE ROAD USLE,ILUNOis s0632-4361 March 3, 1998 EA 97 466 Mr. Oliver President, Nuclear Generation Group Commonwealth Edison Company ATTN: RegulatoryServices Executive Towers West lli 1400 Opus Place, Suite 500 Downers Grove, IL 60515 -

SUBJECT:

NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF civil PENALTY -

$55,000 (NRC inspection Reports No. 50 254(265)/97017)

Dear Mr. Kingsley:

This refers to the inspection conducted August 21 through September 12,1997, at the l

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Commonwealth Edison Company's (Comed) Quad Cities Nuclear Power Station (Quad Cities). The purpose of the inspection was to review Comed's implementation of 10 CFR 50,65, " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" (the Maintenance Rule) at Quad Cities. The exit meeting for this inspection was conducted on September 12,1997. Five apparent violations involving the failure to implement an adequate Maintenance Rule program were identified during this inspection. The inspection report was mailed to Quad Cities by letter dated October 24,1997. On November 26,1997, a prodocisional enforcement conference was held in the NRC Region lil office to discuss the apparent violations.

Based on the information developed during the inspection and the information provided by Comed representatives during the conference, the NRC has determined that violations of NRC requirements occurred. These violations are cited in the enclosed Notice of Violation and Proposed imposition of Civil Penalty (Notice), and the circumstances surrounding them are described in detail in the subject inspection report.

The violations in the Notice are directly related to the failure to meet the requirements of the Maintenance Rule, Violation A involves three examples of failure to establish goals and monitoring for structures, systems, and components (SSCs) as required by 10 CFR 50.65 a 1).

Violstion B includes seven examples of failures to demonstrate that the performance d or co(n)(ition of SSCs within the scope of 10 CFR 50.65 had been effectively controlled through the performance of appropriate preventive maintenance such that they would remain capable of -

performing their intended function. Violation C includes three examples of not monitoring the performance or condition of SSCs against established goals pursuant to the requirements of 10 CFR 50.65(a)(1), even though it was not demonstrated that the performance or condition of .

these SSCs was being effectively controlled through the performance of appropriate preventive maintenance as evidenced by maintenance preventable functional failures. Violation D includes two examples of incorrectly permitting SSCs to remain under 10 CFR 50.65(a)(2) following maintenanca preventable functional failures. Violation E involves the failure to include functions of the high pressure coolant injection, manual rod control, and intra plant communications systems the cope]f the station's Maintenance Rule program, g\ (

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l l These violations, collecDvely, represent a programmatic breakdown in the development and l Irnplementation of Comed's program to ensure compliance with the regulatory requirements of r j the Maintenance Rule. Escalated enforcement is warranted due to the significant regulatory  !

conoom with the common undertying causes of the violations. The root causes included: (1) i

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lack of understanding of the intent of performance criteria and goals; (2) inadequate system  !

engineer training; (3) lack of aggressive response to self assessment find 6ngs and other forms of  :

j Maintenance Rule information such as inspection reports; (4) lack of site management oversight;

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and (5) lack of corporate involvement and oversight. The NRC concludes that actions taken to  ;

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t implement the Maintenance Rule had not been fully integrated into the appropriate programs at l Quad Cities.  !

The NRC is concemed that Quad Cities did not have adequate measures in place to monitor the  !

! results of maintenance to assure plant 88Cs remain capable of performing their intended l 4 functions. Appropriate performance trending and effective maintenance preventable functional  ;

failure determinations were not property incorporated into maintes,anos monitoring activities to -  !

reasonably assure that plant equipment degradation or problems are identified and corrected l

before they result in significant failures. Therefore, the failure to implement key aspects of the  ;

Maintenance Rule are classified in the aggregate in accordance with NUREG 1600, " General  !

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Statement of Policy and Procedure for NRC Enforcement Actions,"(Enforcement Policy) as a i Severity Levellit problem.

I in accordance with tha Enforcement Policy, a base civil penalty in the amount of $55,000 is -  !

!: considered for a Severity Level ill problem. Because the Quad Cities facility has been the l

[ subject of escalated enforcement actions within the last 2 years', the NRC considered whether i r credit was warranted for identl#ceflon and Conectivo Action in accordance with the civil penalty

- assessment in Section VI.B.2 of the Enforcement Policy. The NRC has determined that

identifosfion Cmdit was not warranted. Although a corporate assessment did identify many of  !

! the issues in a June igg 7 effort, the Quad Cities staff failed to take appropriate action to

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understand the full extent of the issues and address tnem. It was only after NRC inspectors identified the extensiveness of the deficiencies, that aggressive, substantive actions were

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implemented. The NRC has determined that Conective Action Credit was warranted; Corrective actions for the Maintenance Rule violations, when finally taken, were Judged to be prompt and comprehensive. Several corrective actions implemented or proposed at the enforcement

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conference included: (1) contracting with an industry expert; (2) reviewing scoping standards i

, and performance criteria standards with an expert panel; (3) rescoping systems and revising -  ;

j performance ortterla; (4) training of system engineers; (5) per'orming a program independent *

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assessment; and (6) resetting goals of low and high safety significant systems. In addition, after i j the Maintenance Rule program issues were identified in September igg 7, Comed implemerited a t

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F program to re-examine, revetidate, and revise, as necessary, the Maintenance Rule program for

[ the Braidwood, LaSalle, and Zion facilities.

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r 1. :EA 96-114 leeued a Seversy Level til violation with a $50,000 eM peneRy on June 13,1996, for feEng to

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retum design margins to the low pressure irQoction comer rooms. EA 94 430 and EA 96 831 leeued a Severity j Level 111 vloisson with a $50,000 cMI penalty on June 24,1997, for ta inadequate engineering analysis h r*0erding damaged extemal panels for the secondary containment, p

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. Therefore, to emphasize the importance of full compliance with 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, I have been authorized, efter cor.sultation with the Director, Office of Enforcement, to issue the enclosed Notice in the base amount of $55,000 for the Severity Level 111 prob!em.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements, in accordance with 10 CFR 2.700 of the NRC's "Rutas of Practice," n copy of this letter, its enclosure, and your response will be placed in the NRC Public Document Room (PDR).

Sincerely, f

a sal U A. Bill Beach Regional Administrator Docket Nos. 50-254;50 265 License Nos. DPR 29; DPR-30 l Enclosure: Notice of Violation and Proposed l Imposition of Civil Penalty ec w/ encl: M. Wallace, Senior Vice President l D. Helwig, Senior Vice President G. Stanley, PWR Vice President J. Perry, BWR Vice President D. Farrar, Regulatory Services Manager 1. Johnson, Licensing Nrector DCD - Licensing E. Kraft, Jr., Site Vicesowident D. Cook, Quad Cities 'stion Manager

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C. C. Peterson, Regn :gry Affairs Manager Riched Hubbard Nathan Schloss, Economist Office of the Attomey General State Liaison Officer Chairman, Illinois Commerce Commission W. D. Leech, Manager of Nuclear MidAmerican Energy Company

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. DISTRIRVILQN:

PUBLIC IE-01 SECY CA JCallan, EDO AThadani, DEDE LChandler,000 JGeldberg, OGC SCollins, NRR BBoger, NRR -

Enforcement Coordinators Rl, Ril and RIV Resident inspector, Quad cities RCapra, NRR RPulsifar, NRR JGilliland, OPA HBell, OlG GCaputo, Ol LTromper, OC TMartin, AEOD OE:ES OE:EA (2)

RAO:RI:l SLO; Rill PAO: Rill OCFO/LFARB w/o encl.

DRP Docket File

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