ML17199U256
| ML17199U256 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 02/11/1988 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Oconnor J COMMONWEALTH EDISON CO. |
| References | |
| EA-87-204, NUDOCS 8802170258 | |
| Download: ML17199U256 (4) | |
See also: IR 05000237/1987005
Text
Docket No. 50-237
License No. DPR-19
EA 87-204
Commonwealth Edison Company
ATTN:
Mr. James J. O'Connor
President
Post Office Box 767
Chicago, IL 60690
Gentlemen:
FEB 1 1 1988
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY
NRC INSPECTION REPORT NO. 50-237/87005(DRP)
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This refers to the NRC inspection, conducted during the period December l, 1986
through January 8, 1987, at the Dresden Nuclear Power Station, Unit 2, of
activities authorized by NRC Operating License DPR-19, and to the circumstances
associated with the failure to follow Technical Specifications relating to
shutdown of Unit 2 following the deinerting of primary containment.
This
matter, which was discovered by the licensee on November 29, 1986, and was
- reported to the NRC on a timely basis, resulted in two violations of NRC
regulatory requirements.
The details are presented in the subject inspection
report.which was sent to you by letter dated January 16, 1987.
On January 19,
1988, we held an enforcement conference with members of your staff during which
the violations, the root causes, and your corrective actions were discussed.
The violations, which are discussed in the enclosed Notice of Violation and
Proposed Imposition of Civil Penalty, resulted from a failure to have an
effective system for keeping track of when a Limiting Condition for Operation
(LCO) is entered and its time limit expires.
As a resuJt, a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time limit
for deinerting primary containment prior to shutdown was exceeded.
When station
management became aware that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limit had been exceeded, it decided to
continue at power while a high pressure coolant injection pump (HPCI) fast start
test was conducted.
This resulted in the LCO time limit being exceeded by
almost five,ho.urs before the reactor was manually scrammed.
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On January 2~:;~:,,1987, a management meeting was held between Commonwealth Edi son
Company (CECo) personnel and the NRC Region III staff to discuss this event.
It
was CECo's position that when the Technical Specification LCO limit was exceeded
8802170258 880211
ADOCK 05000237
G
Commonwealth Edison Company
2
- FE.B 1 1 1988
the prov1s1ons of Technical Specification 3.0.A could be invoked, thereby,
making an additional 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> available for shutting down the reactor.
During
the January 23rd manag~ment meeting and again during the enforcement conference,
the NRC staff restated its position that Technical Specification 3.0.A can be
applied only when the circumstances are such that they are not specifically
provided for in Technical Specification LCOs and that it is not appropriate to
combine the shutdown time allocation of two Technical Specification limits.
As a result of this occurrence, an investigation was conducted (see attached
synopsis) by the NRC Region III Office of Investigations to determine if CECo
may have willfully violated Technical Specification LCOs.
This investigation
concluded that CECo personnel inadvertently exceeded the deinerting LCO, and
that CECo personnel or management did not willfully operate Dresden, Unit 2, in
violation of Technical Specifications.
To emphasize the importance of tracking the expiration of Technical LCO time
limits and ensuring the implementation of appropriate Technical Specifications,
I have been authorized, after consultation with the Director, Office of
Enforcement, and the Deputy Executive Director for Regional Operations, to
issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty
in the amount of Fifty Thousand Dollars ($50,000) for the violations described
in the enclosed Notice.
In accordance with the 11General Statement of Policy
and Procedure for NRC Enforcement Actions,
11 10 CFR, Part 2, Appendix C (1987)
(Enforcement Policy), the violations qescribed in the enclosed Notice have been
categorized in the aggregate as a Severity Level III problem.
The base value
of a civil penalty for a Severity Level III problem is $50,000.
The escalation
and mitigation factors in the Enforcement Policy were considered and no
adjustment has been deemed appropriate.
You are required to respond to this letter ~nd should follow the instructions
specified i~ the enclosed Notice when preparing your response.
In your
response, you should document the specific actions taken and any additional
actions you plan to prevent recurrence.
After reviewing your response to
this Notice, including your proposed corrective actions, the NRC will determine
-whether further enforcement action is necessary to ensure compliance with NRC
regulatory requirements.
In accordance_twith Section 2.790 of the NRC 1s 11 Rules of Practice,
11 Part 2,
Title 10, Cq~~*of Federal Regulations, a copy of this letter and its enclosures
wi 11 be pl aced:-i n the NRC Public Document Room.
Commonwealth Edison Company
3
FEB 1 1 1988
The responses directed by this letter and the enclosed Notice are not subject
to the clearance procedure of the Office of Management and Budget as r~quired
by the Paperwork Reduction Act of 1980, Pub. L., No.96-511.
Enclosures:
1.
Proposed Imposition of
C i v il Pe n a l ty
2.
Synopsis of Investigation
Report No. 3-87-002
3.
NRC Inspection Report
No. 50-237/87005(DRP).
cc w/enclosures:
Cordell Reed, Senior
Vice President
D. Butterfield, Nuclear
Licensing Manager
J. Eenigenburg, Plant Manager
DCD/DCB (RIDS)
Licensing Fee Management Branch
Resident Inspector, RIII
Richard Hubbard
J. W. McCaffrey, Chief, Public
Utilities Division
RII~_, ,\\.
Nor~J~~l
RIII
w~
Schultz
'Z.-~-t>'S
~incerely,
- .~riginal signed by
- L .Be.r..t Davis
A. Bert Davis
Regional Administrator
RI~I {J
PapJr!iello
- rl~~~
RIII
.&._
Davis
zj1rJ
Commonwealth Edison Company
Distribution
SECY
CA
JTaylor, DEDRO
ABDavis, RIII
Jlieberman, OE
Jluehman, OE
LChandler, OGC
Fingram, PA
- Enforcement Coordinators
RI, RII, RII I, RIV, RV
BHayes, OI
SConnel ly, DIA
EJordan, AEOD
TMurley, NRR
OE File
EA File