ML17179A722
| ML17179A722 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 02/12/1993 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Delgeorge L COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML17179A723 | List: |
| References | |
| EA-92-253, NUDOCS 9302220016 | |
| Download: ML17179A722 (5) | |
See also: IR 05000237/1992035
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UNITED STATES
NUq..EAR REGULATORY COMMISSION.
Docket No.
50-237
License No .. DPR~19
EA 92-253
REGION.Ill.
799 ROOSEVELT ROAD
GLEN EL.LYN, ILLINOIS 60137
February 12, 1993.
Commonwealth Edison Company
ATTN:
Mr.-L. o. DelGeorge, Vice President,
Nuclear Oversight and Regulatory
Services
Ex~cutive T6wers Wes~ III *
1400 Opus Place Suite 300
- Downers Grove, Illinois
60515
Dear Mr. DelGeorge:
SUBJECT:*
(NRC INSPECTION REPORT NO. 50-237/92035(DRP))
.This refers to the inspection conducted during the period of
October 19 thr6ugh December 15, 1992, ~t Dresden Statioh, Unit 2,
to.review the circumstinces surrounding your identification th~t
the reactor vessel pressure-temperature.curve .. in Technical
Specification Figure 3.6.1 w~s honconservative.
During this*
inspection a violation o~ NRC.requirements was identified.
The
report documenting the inspe6tion was ~ent to you by letter dated
December .24, 1992.
On January 22, 1993, **an enforce.ment
conference was held in the Region III off ice to discus~ the
~iolation~ .its cause and your corrective action~.
The re~ott
summarizing the conference ~as sent to you by letter dated
January 28, 1993.
On October 23, *1989, you submitted a Unit 2 Technical
specification amendment request to revise the pressure-
temperature curve to reflect the guidance in Regulatory
Guide 1.99, Revision 2.
Subsequently, on September 5, 1991,
Technical Specification Amendment No .. 114 was issued.
On
June 26, 1992, you identified that the Unit 2 reactor-pressure
temperature curve was nonconservative as a result of a review of
the data for the vessel beltline welds and made a one hour
telephone report.
During this revie~ you determined that the
material properties and the initial reference nil~ductility
temperature that were ~sed to develop the curve were based on
data ftom weld procedure qualification te~ting rather. than data
from the Unit 2 vessel materia~.
You subsequently submitted a
written licerisee event report pn July 16, 1992.
CERTIFIED -MAIL .
RETURN RECEIPT REQUESTED
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9302220016 930212
ADOCK 05000237
G
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190043
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Commonwealth Edison Company
_February 12, 1993
The violation,. which is described in the. enclosed Notice. of ..
- Viola~ion (Notice) , concerhs a failure to provid~ complete and
- accurate information in the Technical-Specification amendment
request.
The root cause of the violation was Cornrno'nwea1th Edison's
inadequate v~rification of contractor assumptions and erigineering
judgments which allowed an initial personnel.error to be
trarislated into* an inac~ur~te Technical Specification.
In
October 1988, a contractor employe~ incorrectly concluded that
the Unit 2 reactor vessel could be considered separately from
Unit 3 due to a personnel etror in his interpretation of a
summary table of-reacto~vessel material "and fabrication
information.
This conclusion was accepted by your ISI &
Materials Group Super~isor ind was subsequently used by General .
Electric in developing the new pressure-temperature curves.
In this particul~i case you have demonstrated tha~ reactor ~essel
in'tegrity was not* impacted and adequate margin against crack
. initiation existed at all times.
However, the sequence of events
which allowed you' to submit an inaccurate Technical Specitication
amendment request-is* a significant regulatory concern.
Further,
had the amendment request been.accurate at the time of submittal,
it would have resulted in a different NRC regulatory- position.
Theref_ore, in accordance: with the "General Statement of Policy * *
and Procedure for NRC Ehforce~ent Actions, (Enforcement Policy)
10 CFR Part 2, Appendix c, the violation has been categorized at
We acknowledge your immediate correctiv~ acti6ns which included
- directing Operations to use the Unit 3 curve for Unit 2
operations and temporary procedure changes.
Additionally, on
September 16, ,1992, an amendment request was submitted to the NRC
to correct Figure 3.6.1~
We also acknowledge your long-term corrective.actions which
included an architectural-engineering guidebook to provide
specific requirements for selecting.design inputs for
calculations and otner design products, an agreement with your
reactor vendor which calls fo~ vendor engineering output
documents to contain certain information, guidance to your
erigineering personnel to.clarify ~anagement expectations for the
review of calculations and other design products, and procedural
improvel'[lents in the processes for ensuring the.quality of*
engineering: documents prepared internally.
In accordance with the Erifbrcement Policy a civil penalty is
considered for a Severity Le~el III violation.
However, after
consul tati,Oh _with. the "Dire-C-tor I -Off ice of Enf orcernen~t ,** and. th,f
Deputy Execritive Director for Nuclear Reactor Regulation, .
Regional Ope.rations and Research, I have decided that a civil
Commonwealth Edison Company
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February 12, 1993
penalty will not be proposed in this case.
In reachin~ this
- decision, the st~ff considered the. adjust~ent ~actors in th~ NRC
We d~termined that full mitigation of the base civil penalty was
appropriate due to your identification of the nonconservative
pressure-temperatur~ curves, and your good corrective-actions.
The remaining factors in the Enforcement Policy were considered
and no further* adjustment to the base civil penalty was.
considered appropriate.
YoU are r~qrii~ed t6 respond to this letter and should foll6w the
instructions ~~ecified in th~ enclosed Notice when*pr~p~rin~ your
response.
In your respons~, you shbuld document the specific
actions taken and any additional actions you plan to prevent
recurrence.
After reviewing your re~pcinse to this Notice, *
- including your proposed corrective actions and the results of
future inspections, the NRC will d~termine whether further NRC
enforcement action is* nebessa~y to ensrire cbmpliance with NRC
regulatory requirements.
-
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice,"-
a copy of this letter ~nd its enclosur~ will be placed in.the:N~C
Public Document Room.
The response directed by this lett~r and the enclosed Notice are
n6t subject to t~e clearance procedures of the Off ice of
Management ?nd Budget as required by the Paperwork Reduction Act .
9f 1980, PL 96-511.
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Sincerely,
lfflt~--- /J~
-A. Bert Davis
Regional Administrator
Enclosure:
See Attached Distribution:
Commonwealth Edison Company
Distribution:
cc w/enclosure:
,iFocD/DCB (RIDS) .
M:
Ly~ter, Site Vice President
c. Schr6eder, Station
Manager
-
4* -
J. Shields, Regulatory Assurance
Supervisor
D. Farrar, Nuclear Regulato~y
Service~ Manager
OC/LFDCB
Resident Inspectors LaSalle,
Dreiden; Quad Cities, Clint6n
Richard Hubbard
J. W.
McC~ffrey, Chief, Public
Counsel, State of Illinois Center*
B. Siegel, Licensing Project Manager, NRR
T. Martin, Region III
J. Dyer, NRR
E. J. Leeds, NRR
M. t. Jor~an, RLII *
C. D. Pederson, RIII
S. Stasek, SRI, Davis Besse
. February 12, 1993
Commonwealth Edison Company
DISTRIBUTION:
.. SECY
CA
JTaylor, EDO
HThornpson, DEDS
.JSniezek, DEDR .
JLieberman, OE
WTros~oski, . OE *
LChandler, OGC
JGoldberg, OGC
TMurley, NRR
.JJ>artlow, NRR
Enforcement Coordinators
RI, RII, RIV, RV
Fingra:m, GPA/PA
DWilliams~ OIG
BHaye~, or
EJordan, AEOD
Day File
EA File
State of Illin~is
RAO:RIII
SLO:RIII
PAO:RIII
IMS:RIII
5
February 12, 1993