IR 05000254/1997023

Forwards Insp Repts 50-254/97-23 & 50-265/97-23 on 971014-980415 & Nov.Violation Re Personnel Not Properly Trained to Implement Manual Actions as Required to Mitigate Consequences of Postulated Fire in Listed Areas

ML20247P431
Person / Time
Site:	Quad Cities
Issue date:	05/15/1998
From:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Kingsley O COMMONWEALTH EDISON CO.
Shared Package
ML20247P436	List: IR 05000254/1997023 ML20247P455
References
50-254-97-23, 50-265-97-23, EA-98-175, EA-98-231, NUDOCS 9805280011
Download: ML20247P431 (4)

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May 15, 1998 EA Nos.98-175; 98-231 Mr. Oliver President, Nuclear Generation Group Commonwealth Edison Company ATTN: Regulatory Services ~

Executive Towers West til 1400 Opus Place, Suite 500 Downers Grove,IL 60515 SUBJECT: NRC INSPECTION REPORT 50-254/97023 (DRS); 50-265/97023(DRS) AND NOTICE OF VIOLATION

Dear Mr. Kingsley:

On April 15,1998, the NRC completed an inspection at your Quad Cities Nuclear Power Station. The purpose of this inspection was to review identified deficiencies conceming the safe shutdown analysis and implementing procedures which led to the shutdown of both units in late 1997. The units remain shutdown. The enclosed report represents the results of that inspection. Inspection and evaluation of your corrective action for those deficiencies is ongoing.

Areas examined within the post-fire safe shutdown program are identified in the report. Within i those areas, the inspection consisted of a selective examination of procedures and representative records, observation of performance, and interviews with staff. The objective of the inspection effort was to determine whether activities authorized by the license were conducted safely and in accordance with NRC requirements.

Based on the results of this inspection, the NRC has determined that a violation of NRC requirements occurred. The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in detail in the subject inspection report. The violation is of concern because personnel were not properly trained to implement manual actions as required to mitigate the consequences of a postulated fire in areas containing safe shutdown equipment.

The NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence is already adequately addressed in the subject inspection report. Therefore, you are not required to respond to this

' letter unless the description therein does not accurately reflect your corrective actions or your ;

position. In that case, or if you choose to provide additionalinformation, you should follow the l

! instructions specified in the enclosed Notice.

fi 9805280011 980515 ^ ^! j PDR ADOCK 05000254 I G PDR j

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in addition, two apparent violations were identified and are being considered for escalated i enforcement action in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions"(Enforcement Policy), NUREG-1600. The first apparent violation concemed the inadequacies in safe shutdown capabilities for certain fire areas containing safe l shutdown equipment. The second apparent violation concerned an untimely and inadequate l safety evaluation for the use of the station blackout diesels in lieu of the emergency diesel generators, which involved an unreviewed safety question requiring a license amendment. l Accordingly, no Notice of Violation is presently being issued for these inspection findings. In addition, please be advised that the number and characterization of apparent violations i described in the enclosed inspection report may change as a result of further NRC review.

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An open predecisional enforcement conference to discuss this apparent violation has been i scheduled for June 8,1998, at 2:00 pm (CDT). Please be advised that if the NRC identifies l significant deficiencies during the May 1998 onsite inspection to verify the corrective actions 1 you have taken in accordance with the confirmatory action letter (CAL) dated January 16,1998, the open predecisional enforcement conference may be rescheduled. The decision to hold a predecisional enforcement conference does not mean that the NRC has determined that a violation has occurred or that enforcement action will be taken. This conference is being held to obtain information to enable the NRC to make an enforcement decision, such as a common understanding of the facts, root causes, missed opportunities to identify the apparent violation sooner, corrective actions, significance of the issues and the need for lasting and effective corrective action. In addition, this is an opportunity for you to point out any errors in our inspec-tion report and for you to provide any information conceming your perspectives on: 1) the severity of the violation (s); 2) the application of the factors that the NRC considers when it determines the amount of a civil penalty that may be assessed in accordance with Section VI.B.2 of the Enforcement Policy; and 3) any other application of the Enforcement Policy to this case, including the exercise of discretion in accordance with Section Vll.

You will be advised by separate correspondence of the results of our deliberations on this matter. No response regarding the apparent violation is required at this time.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosure will be placed in the NRC Public Document Room.

Sincerely, Original /s/ J. A. Grobe John A. Grobe, Director Division of Reactor Safety Docket Nos.: 50-254;50-265 License Nos.: DPR-29; DPR-30 Enclosure: Inspection Reports 50-254/97023(DRS);

50-265/97023(DRS)

3See Attached Distribution l DOCUMENT NAME: G:DRS\QUA97023.DRS (SEE PREVIOUS CONCURRENCE)

r. c.~. . . ny oi es ooeo ni. iao c. . .. .w. 6..: c . cony soui .it. cam.nv.ocio.a,. e . cony in .ii.cnm.au.ocio.o,. w . so cony OFFICE Rlli l Rlli l Rlli l Rill ld Rll! _,

NAME Chyu:sd e Gardner p Ring + Clayton 8c. Gro@'

DATE 05/ /98 05/ /98 05/ /98 05/13/98 05/g98 OFFICIAL RECORD COPY

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O. Kingsl;y 2

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In addition, two apparent violations were identified and are being considered for escalated enforcement action in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions"(Enforcement Policy), NUREG-1600. The first apparent violation concerned the lack of safe shutdown capabilities for certain fire areas containing safe shutdown equipment. The second apparent violation concerned an untimely and inadequate safety evaluation for the use of the station blackout diesels in lieu of the emergency diesel generators, which involved an unreviewed safety question requiring a license amendment. Accordingly, no Notice of Violation is presently being issued for these inspection findings. In addition, please be advised that the number and characterization of apparent violations described in the enclosed inspection report may change as a result of further NRC review.

An open predecisional enforcement conference to discuss this apparent violation has been scheduled for June 8,1998, at 2:00 pm (CDT). Please be advised that if the NRC identifies significant deficiencies during the May 1998 onsite inspection to verify the corrective actions you have taken in accordance with the confirmatory action letter (CAL) dated January 16,1998, the open predecisional enforcement conference may be rescheduled. The decision to hold a predecisional enforcement conference does not mean that the NRC has determined that a violation has occurred or that enforcement action will be taken. This conference is being held to obtain information to enable the NRC to make an enforcement decision, such as a common understanding of the facts, root causes, missed opportunities to identify the apparent violation sooner, corrective actions, significance of the issues and the need for lasting and effective corrective action. In addition, this is an opportunity for you to point out any errors in our inspec-tion report and for you to provide any information concerning your perspectives on: 1) the severity of the violation (s); 2) the application of the factors that the NRC considers when it determines the amount of a civil penalty that may be assessed in accordance with Section VI.B.2 of the Enforcement Policy; and 3) any other application of the Enforcement Policy to this case, including the exercise of discretion in accordance with Section Vll.

You will be advised by separate correspondence of the results of our deliberations on this matter. No response regarding the apparent violation is required at this time.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosure will be placed in the NRC Public Document Room.

Sincerely,

>

John A. Grobe, Director Division of Reactor Safety Docket Nos.: 50-254;50-265 License Nos.: DPR-29; DPR-30 Enclosure: Inspection Reports 50-254/97023(DRS);

r0-265/97023(DRS)

See Attached Distribution DOCUMENT NAME: G:DRS\QUA97023.DRS ro ,.c.iv. . copy o, in ..com.ni. inoie. in en. 6..: e . con, inoui .ti.cnm.ni,.ncio.u,.v ce 3 in .et.cnm nironcio.ur. w . No cony OFFICE Rlli _

,lE Rlli E Rlli lF Rlli l Rlli l NAME Chyu:sd ViTn Gardner@M Ringel- Clayton 't Grobe .J(

DATE 05/7/98' / 4 05/7/98 /m 05/o /98 05/ /98 05/ /98 l OFFICIAL RECORD COPY

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(' O.' Kingsley 3 l

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! cc w/ encl: M. Wallace, Senior Vice President

! D. Helwig, Senior Vice President

! G. Stanley, PWR Vice President

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I- J. Perry, BWR Vice President  !

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D. Farrar, Regulatory l Services Manager j l. Johnson, Licensing Director DCD - Licensing )

l J. Dimmette, Jr., Site Vice President W. Pearce, Quad Cities Station Manager C. C. Peterson, Regulatory Affairs Manager i Richard 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 Distribution:

J. Goldberg, OGC w/enci J. Lieberman, OE w/enci B. Boger, NRR w/ encl SAR (E-Mail)

Project Mgr., NRR w/ enc!

A. Beach w/enci J. Caldwell w/enci B. Clayton w/enci SRI Quad Cities w/enct

~ DRP w/enci

.TSS w/ encl DRS w/enci -

Rlli PRR w/enci PUBLIC IE-01 w/enci Docket File w/enci l

GREENS LEO (E-Mail)- i DOCDESK (E-Mail)  !

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