ML030300786
| ML030300786 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 01/30/2003 |
| From: | Pederson C NRC/RGN-III |
| To: | Skolds J Exelon Generation Co |
| References | |
| 3-2001-054, EA-02-265 | |
| Download: ML030300786 (7) | |
Text
January 30, 2003 EA-02-265 Mr. John L. Skolds, President Exelon Nuclear Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
PREDECISIONAL ENFORCEMENT CONFERENCE (NRC OFFICE OF INVESTIGATIONS CASE NO. 3-2001-054)
Dear Mr. Skolds:
This letter refers to the investigation conducted by the U. S. Nuclear Regulatory Commission (NRC) Office of Investigations (OI) into the completeness and accuracy of information provided by your staff to the NRC during a telephone conference call on September 27, 2001. That telephone call concerned the damaged pipe support discovery on July 19, 2001, in the Dresden Nuclear Power Station, Unit 3, High Pressure Coolant Injection (HPCI) system. On July 24, 2001, Dresden engineers completed an operability evaluation of the HPCI system. On August 24, 2001, Dresden engineers completed an Apparent Cause Evaluation (ACE) of the support damage and concluded it was caused by a water hammer on July 5, 2001. The NRC staff questioned the technical adequacy of the operability determination, and the September 27, 2001 telephone conference call was held to discuss the technical adequacy.
Based on our review of the OI report, apparent violations of 10 CFR 50.9, Completeness and Accuracy of Information, are being considered for escalated enforcement in accordance with the General Statement and Policy and Procedure for NRC Enforcement Actions (Enforcement Policy), NUREG-1600. The current enforcement policy is included at www.nrc.gov; select What We Do, Enforcement, then Enforcement Policy. In summary, on September 27, 2001, members of the NRC staff were told: (1) the maximum HPCI discharge pressure during the July 5, 2001 scram did not exceed 193 psi when Dresdens Transient Analysis Data System recorded a peak discharge pressure of approximately 1000 psi; (2) no other HPCI pipe supports showed damage from a water hammer, however a nearby trapeze pipe hanger had damage indicative of a water hammer; and (3) Exelon engineers contended that since the HPCI system had been continually pressurized, no voids would develop so there was no need to vent the system; other Exelon engineers present suspected there was air in the system and recognized the only method to eliminate an air void was to vent the system. Since the NRC has not made a final determination in this matter, no Notice of Violation is being issued at this time. In addition, please be advised that the number and characterization of the apparent violations may change as a result of further NRC review.
We have been in contact with Mr. B. Hovey of your staff to schedule a predecisional enforcement conference to discuss the apparent violations. The conference will be transcribed and closed to public observation. We will confirm the time and date of the conference after a mutually agreeable date has been scheduled.
J. Skolds We believe it is important for certain members of your staff, who were involved with these issues, to attend the conference. The requested individuals were specified during the above referenced call. The decision to hold a predecisional enforcement conference does not mean that the NRC has determined that violations have occurred or that enforcement action will be taken. The conference is being held to obtain information to enable the NRC to make an enforcement decision, such as whether violations have occurred, a common understanding of the facts, root causes, missed opportunities to identify any apparent violations sooner, corrective actions, significance of the issues, the need for lasting and effective corrective action, and any other information you believe the NRC should take into consideration in making an enforcement decision.
In addition, this is an opportunity for you to provide any information concerning your perspectives on: (1) the severity of violations; (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.C.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 VII.
Today, we are also issuing correspondence concerning a regulatory conference for the technical issues associated with the water hammer event on July 5, 2001.
If you have any questions, please contact Mr. David Hills at (630) 829-9733.
In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter with only will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/NRC/reading-rm/ADAMS.html (the Public Electronic Reading Room).
Sincerely
/RA by Roy Caniano Acting For/
Cynthia D. Pederson, Director Division of Reactor Safety Docket No. 50-249 License No. DPR-25
Enclosures:
- 1. Synopsis of Office of Investigations Report for Case No. 3-2001-054
- 2. Summary of Office of Investigations Report for Case No. 3-2001-054 (Not for Public Disclosure)
See Attached Distribution
J. Skolds cc w/encl 1:
Site Vice President - Dresden Nuclear Power Station Dresden Nuclear Power Station Plant Manager Regulatory Assurance Manager - Dresden Chief Operating Officer Senior Vice President - Nuclear Services Senior Vice President - Mid-West Regional Operating Group Vice President - Mid-West Operations Support Vice President - Licensing and Regulatory Affairs Director Licensing - Mid-West Regional Operating Group Manager Licensing - Dresden and Quad Cities Senior Counsel, Nuclear, Mid-West Regional Operating Group Document Control Desk - Licensing M. Aguilar, Assistant Attorney General Illinois Department of Nuclear Safety State Liaison Officer Chairman, Illinois Commerce Commission
J. Skolds We believe it is important for certain members of your staff, who were involved with these issues, to attend the conference. The requested individuals were specified during the above referenced call. The decision to hold a predecisional enforcement conference does not mean that the NRC has determined that violations have occurred or that enforcement action will be taken. The conference is being held to obtain information to enable the NRC to make an enforcement decision, such as whether violations have occurred, a common understanding of the facts, root causes, missed opportunities to identify any apparent violations sooner, corrective actions, significance of the issues, the need for lasting and effective corrective action, and any other information you believe the NRC should take into consideration in making an enforcement decision.
In addition, this is an opportunity for you to provide any information concerning your perspectives on: (1) the severity of violations; (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.C.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 VII.
Today, we are also issuing correspondence concerning a regulatory conference for the technical issues associated with the water hammer event on July 5, 2001.
If you have any questions, please contact Mr. David Hills at (630) 829-9733.
In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter with only will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/NRC/reading-rm/ADAMS.html (the Public Electronic Reading Room).
Sincerely
/RA by Roy Caniano Acting For/
Cynthia D. Pederson, Director Division of Reactor Safety Docket No. 50-249 License No. DPR-25
Enclosures:
- 1. Synopsis of Office of Investigations Report for Case No. 3-2001-054
- 2. Summary of Office of Investigations Report for Case No. 3-2001-054 (Not for Public Disclosure)
See Attached Distribution DOCUMENT NAME: G:DRS\\ML030300786.wpd To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE RIII RIII RIII OI NAME ADunlop for JNeurauter:sd DHills MRing RPaul DATE 1/28/03 1/28/03 1/28/03 1/29/03 OFFICE OE by telecon RIII RIII NAME JDixon-Herrity for FCongel C Weil for BClayton RCaniano for CPederson DATE 1/27/03 1/29/03 1/30/03 OFFICIAL RECORD COPY
J. Skolds cc w/encl 1:
Site Vice President - Dresden Nuclear Power Station Dresden Nuclear Power Station Plant Manager Regulatory Assurance Manager - Dresden Chief Operating Officer Senior Vice President - Nuclear Services Senior Vice President - Mid-West Regional Operating Group Vice President - Mid-West Operations Support Vice President - Licensing and Regulatory Affairs Director Licensing - Mid-West Regional Operating Group Manager Licensing - Dresden and Quad Cities Senior Counsel, Nuclear, Mid-West Regional Operating Group Document Control Desk - Licensing M. Aguilar, Assistant Attorney General Illinois Department of Nuclear Safety State Liaison Officer Chairman, Illinois Commerce Commission NRC Distribution Without Enclosure 2:
ADAMS (PARS) ENCLOSURE 2 IS NOT FOR PUBLIC DISCLOSURE WITHOUT THE APPROVAL OF DIRECTOR, OFFICE OF ENFORCEMENT NRC Distribution With Enclosure1 and 2:
W. Kane, DEDRP S. Collins, NRR J. Dyer, RIII J. Caldwell, RIII G. Grant, RIII J. Dixon-Herrity, OE D. Dambly, OGC G. Caputo, OI B. Clayton, RIII B. Berson, RIII C. Weil, RIII H. J. McGurren, OGC L. Dudes, NRR R. Paul, OI: RIII S. Kryk, OI: RIII D. Hills, DRS: RIII J. Luehman, OE D. Smith, RIII OEMAIL (e-mail)
OEWEB (e-mail)
PLB1 JRK1
ENCLOSURE 1 SYNOPSIS This investigation was initiated on November 14, 2001, by the U.S. Nuclear Regulatory Commission (NRC), Office of Investigations, Region III, to determine if deliberate false statements were provided to the NRC regarding a water hammer incident.
Based upon the evidence developed, this investigation substantiated that false statements were willfully provided to the NRC regarding a water hammer incident.
Case No. 3-2001-054