ML17187A658
| ML17187A658 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Quad Cities  |
| Issue date: | 11/14/1996 |
| From: | Grant G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Keiser H COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML17187A659 | List: |
| References | |
| EA-96-388, EA-96-389, EA-96-390, NUDOCS 9611220143 | |
| Download: ML17187A658 (5) | |
See also: IR 05000237/1996012
Text
EA 96-388
EA 96-389
EA 96-390
Mr. H. W. Keiser
Chief, Nuclear Operating Officer
Commonwealth Edison Company
Executive Towers West Ill
1400 Opus Place, Suite 300
Downers Grove, IL 6051 5
November 14, 1996
SUBJECT:
NRC INSPECTION REPORT NOS. 50-237/96012(DRS);50-249/96012(DRS);
50-254/96016(DRS);AND 50-265/96016(DRS)AND NOTICE OF
VIOLATION
Dear Mr. Keiser:
This refers to the inspection conducted on July 8 through October 17, 1996, at the
Dresden and Quad Cities nuclear facilities. The purpose of the inspection was to determine
whether activities authorized by the licenses were conducted safely and in accordance
with NRC requirements. The inspection scope included a review of Appendix R hot short
concerns (Dresden and Quad Cities); 4KV breaker hardened grease concerns (Dresden
only); and previously identified electrical distribution system functional inspection (EDSFI)
items (Dresden only). At the conclusion of the inspection, the findings were discussed
with those members of your staff identified in the encloseq report.
Areas examined during the inspection are identified in the report. Within these areas, the
inspection consisted of selective examinations of procedures and representative records,
interviews with personnel, and observation of activities in progress.
Based on the results of this inspection, one apparent violation was identified and is being
considered for escalated enforcement action in accordance with the "General Statement of
Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600.
Accordingly, no Notice of Violation is presently being issued for this inspection finding.
The apparent violation involved the failure to provide adequate protection to ensure that
motor-operated valves necessary to achieve and maintain hot shutdown conditions were
not susceptible to-fire induced hot shorts. Spurious valve operation with mechanical
damage to certain 10 CFR 50, Appendix R, designated valves could result in the loss of
\\//
safe shutdow.n capability during a control room fire (Section E1 .1.b(1 )). The circumstances
I
surrounding the apparent violation, the significance of the issue, and corrective actions
were discussed with members of your staff at the exit meeting on October 1 7, 1 996. As
a result, it may not be necessary to conduct a predecisional enforcement conference in
9611220143 961114
ADOCK 05000237
a
H. W. Keiser
-2-
order to enable the NRC to make an enforcement decision. However, a Notice of Violation
is not presently being issued for the inspection finding. Before the NRC makes its
enforcement decision, we are providing you an opportunity to either: ( 1 ) respond to the
apparent violation addressed in this inspection report within 30 days of the date of this
letter; or (2) request a predecisional enforcement conference. Please contact
Mr. Ronald Gardner at (630) 829-9751 within 7 days of the date of this letter to notify
the NRC of your intended response.
In addition, 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
concerns the use of an inadequate breaker maintenance procedure to maintain safety
related 4KV breakers. This procedure directed an inappropriate sequence of lubrication
steps, including the use of an incompatible degreaser. In addition, Dresden failed to
control the use of incompatible chemicals, such as penetrating oils, that were used during
breaker troubleshooting and maintenance. Also, a more rigorous review of 4KV
Magne-Blast circuit breaker service advisory letters (SALs) may have led to identification of
the hardened grease issue before the 3A low pressure coolant injection (LPCI) pump motor
breaker failure on June 11, 1996 (Section E1 .1.b(2)).
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 are
already adequately addressed on the docket in Commonwealth Edison Company letter
JSPL TR #96-0148, dated August 29, 1996, and this 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
additional information, you should follow the instructions specified in the enclosed Notice.
Your response to the apparent violation should be clearly marked as a "Response to An
Apparent Violation in Inspection Report Nos. 50-237/96012(DRS);50-249/96012(DRS);
50-254/96016(DRS); 50-265/96016(DRS)," and should include: (1) the reason for the
apparent violation, or, if contested, the basis for disputing the apparent violation; (2) the
corrective steps that have been taken and the results acl)ieved; (3) the corrective steps
that will be taken to avoid further violations; and (4) the date when full compliance will be
achieved. Include in your response details describing management's decision process
regarding the priorities and resource allocations that delayed correction of the hot short
issue prior to 1996. You should include a discussion of assurances that similar
nonconforming conditions do not exist at any of your other nuclear power plants and that
site and/or corporate engineers are providing conservative recommendations to station
management when addressing nonconforming conditions. In addition, Dresden did not
consider the susceptibility of the Units 2 and 3 isolation condenser 1301-3 valve to IN 92-18 hot shorts to be a credible event. Include in your response the rationale behind
Dresden's decision to not report this condition as outside the safe shutdown design basis
of the plant (10 CFR 50. 73(a)(2)(ii)(8)).
H. W. Keiser
-3-
Your response should be submitted under oath or affirmation and may reference or include
previous docketed correspondence, if the correspondence adequately addresses the
required response. If an adequate response is not received within the time specified or an
extension of time has not been granted by the NRC, the NRC will proceed with its
enforcement decision or schedule a predecisional enforcement conference.
In addition, please be advised that the characterization of the apparent violation described
in the enclosed inspection report may change as a result of further NRC review. You will
be advised by separate correspondence of the results of our deliberations on this matter.
Two unresolved items were identified involving old EDSFI items. The first item involves
the cable ampacity issue that was identified in 1991. About 350 cables require additional
analyses. Even though Dresden was to complete their evaluation by the end of 1996, we
consider your actions to be slow in resolving this issue. The second item involves the lack
of 125 and 250Vdc breaker to breaker coordination for several nonsafety loads connected
to the safety buses. If a nonsafety load faulted, the potential exists to lose the safety bus.
This item is being referred to the Office of Nuclear Reactor Regulation (NRR) for further
review.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter,
its enclosures, and your response (if you choose to provide one) will be placed in the NRC
Public Document Room (PDR). To the extent possible, your response should not include
any personal privacy, proprietary, or safeguards information so that it can be placed in the
PDR without redaction.
Sincerely,
Original signed by Brent Clayton for
Docket Nos. 50-237; 50-249
Docket Nos. 50-254; 50-265
Enclosures:
2. Inspection Report Nos.
50-237/96012(DRS);
50-249/96012(DRS);
50-254/96016(DRS);
50-265/96016(DRS)
See Attached Distribution
Geoffrey E. Grant, Director
Division of Reactor Safety
DOCUMENT NAME: G:\\DRS\\DRE96012.DRS .
To receive e copy of this document, indicate In the box *c* = Copy without attachment/enclosure *e* = Copy with attachment/enclosure
"N" = No copy
OFFICE
Riii
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HClayton/GGrant
10/30 /96
1<1196
H. W. Keiser
-4-
cc w/encls:
J. S. Perry, Site Vice President
E. Kraft, Site Vice President
D. A. Sager, Vice President,
Generation Support
T. Nauman, Station Manager, Unit 1
M. Heffley, Station Manager, Units 2 and 3
L. W. Pearce, Station Manager
F. Spangenberg, Regulatory Assurance
Supervisor
N. Chrissotimos, Regulatory Assurance
Supervisor
C. C. Peterson, Regulatory Assurance
Manager
I. Johnson, Acting Nuclear
Regulatory Services Manager
Document Control Desk - Licensing
Richard Hubbard
Nathan Schloss, Economist,
Office of the Attorney General
State Liaison Officer
Chairman, Illinois Commerce Commission
J. R. Bull, Vice President, General &
Transmission, MidAmerican Energy Company
Distribution:
Docket File w/encl
PUBLIC IE-01 w/encl
OC/LFDCB w/encl
DRP w/encl
DRS w/encl
J. Lieberman, OE
SRls, Dresden, LaSalle,
Quad Cities w/encl
C. Pederson, Rill w/encl
LPM, NRR w/encl
Riii PRR w/encl
J. Goldberg, OGC
Enf. Coordinator, Rill w/encl
RAC1 w/encl (E-mail)
CAA 1 w/encl (E-mail)
A. B. Beach, Rill w/encl
W. L. Axelson, Riii w/encl
R. Zimmerman, NRR
Commonwealth Edison Company
Dresden Station, Units 2 and 3
Docket Nos. 50-237; 50-249
- During an NRC inspection conducted on July 8 through October 17, 1996, a violation of
NRC requirements was identified. In accordance with the "General Statement of Policy
and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
1 O CFR 50, Appendix B, Criterion V, requires in part, that activities affecting quality be
prescribed by doc:.imented procedures of a type appropriate for the circumstances and
include appropriate qualitative acceptance criteria for determining that important activities
have been satisfactorily accomplished.
Contrary to the above, Maintenance Procedure DES 6700-03, Revision 7, dated April 1 8,
1996, "Inspection and Maintenance of General Electric 4KV Magne-Blast Circuit Breakers
Types AM-4. 76-250-0D (Horizontal Drawout)," an activity affecting quality, was not
appropriate for the circumstances in that it directed an inappropriate sequence of
lubrication steps including the use of an incompatible degreaser. In addition, the licensee
failed to control the use of incompatible chemicals, such as penetrating oils, that were
used during breaker troubleshooting and maintenance. This resulted in hardened grease
preventing the 3A Low Pressure Coolant Injection (LPCI) pump breaker from tripping open
for ten seconds on June 11, 1 996.
This is a Severity Level IV violation (Supplement I).
With regard to this violation, the NRC has concluded that the information regarding the
reason for the violation, the corrective actions taken and planned to correct the violation
and prevent recurrence and the date when full compliance was achieved is already
adequately addressed in the enclosed inspection report (Nos. 50-237/96012(DRS);
50-249/96012(DRS)). However, you are requi~ed to submit a written statement or
explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect
your corrective actions or your position. In that case, or if you choose to respond, clearly
mark your response as a "Reply to a Notice of Violation" and send it to the U.S. Nuclear
Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555, with a
copy to the Regional Administrator, Region Ill, and a copy to the NRC Resident Inspector at
the facility that is the subject of this Notice, within 30 days of the date of the letter
transmitting this Notice of Violation (Notice).
Dated at Lisle, Illinois
this 14th day of November 1996
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