ML20046C715
| ML20046C715 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 08/06/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20046C714 | List: |
| References | |
| EA-93-162, NUDOCS 9308120002 | |
| Download: ML20046C715 (5) | |
Text
--
q v
AND PROPOSED IMPOSITION OF CIVIL PENALTY Commonwealth Edison Company Docket Nos.
50-254 and 50-265 Quad Cities Station License Nos.
Units.1 and.2 EA 93-162 l
l During an NRC inspection conducted from February 24-26, April 19-23 and May 27, 1993, violations of NRC requirements were identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205.
The particular violations and associated civil penalty are set forth below.
r I.
10 CFR 50, Appendix R, Section III, Paragraph G.3 states that alternative or dedicated shutdown capability and its associated circuits, independent of cables, systems or components in the area, room or zone under consideration, shall be provided where the protection of systems whose-i function is required for hot shutdown does not satisfy the requirement of Paragraph G.2 of this section; or where redundant trains of systems required for hot shutdown l
located in the same fire area may be subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems.
Quad Cities Technical Specification 6.2.A.7 requires written procedures be established, implemented, and maintained for Fire Protection Program implementation.
Quad Cities Fire Protection Report (FPR), Amendment 8 (December 1990), Table 4.16-1, " Opposite Unit Equipment Review," designates Unit 1 RHR service water system loop A as an oppoelle unit / shared replacement equipment for Unit 2.
t Quad Cities FPR, Paragraph 4.16.2, "Out of Service Equipment i
Administrative Technical Requirements," requires that if either the safe shutdown component or the opposite unit / shared replacement equipment has not been returned to service within 67 days, the unit must be shut down.
Contrary to the above, prior to May 27, 1993, procedures were not established to track opposite unit / shared unit safe shutdown components when equipment was taken out-of-service.
Consequently, from January 1, 1991 to March 14, 1991, Quad i
Cities Unit 2 was operated at power with the Unit 1, RHR service water system loop A inoperable, a period greater j
than 67 days, and Unit 2 was not shut down.
l 9308120002 930806 PDR ADOCK 05000254-O PDR
-2 II.
Quad Cities Tech'nical Specification 6.2.A.7 requires written procedures be established, implemented, and maintained for Fire Protection Program implementation.
Contrary to the above, written procedures were not
{
established or implemented as evidenced by the following examples:
A.
Quad Cities Procedure QAP 1170-19, Section C.3.a, requires that the fire detection instruments listed in Table QAP 1170-T5 be demonstrated operable at least j
once per six months by performing a functional test.
From February 28, 1991 until April 23, 1993 (November 9, 1992 for the MG Set Water Curtain), the fire detection instruments from Table QAP 1170-T5 listed below were not demonstrated operable at least once per six months by performing a functional test.
1 Specifically, no functional testing was performed during the specified periods.
i l
345 KV Relay House U1/U2 Main Transformers U1/U2 Aux Transformers U1/U2 Reserve Aux U1/U2 Turbine Oil Tanks Transformers U1/U2 Hydrogen' Seal Oil U1/U2 Turbine Bearings i
MG Set Water Curtain U1/U2 Exciter Housings
]
B.
QAP 1170-19, Section C.9.b, requires, for sprinkler I
systems, that at least once per operating cycle a l
system functional test be performed which includes l
simulated automatic actuation of the system to verify that any automatic valves in the flow path actuate to their correct position, inspection of the sprinkler l
system piping to verify its integrity, and inspection of each sprinkler head or nozzle to verify that the discharge spray pattern is not blocked or obstructed.
4 From February 28, 1991, until April 23, 1993 (November 9, 1992 for the MG Set Water Curtain), for the U1 & U2 Rotor Unstacking Transformer and the MG Set Water Curtain sprinkler systems, system functional tests and inspections of system piping, sprinkler heads and nozzles were not performed at least once per operating cycle.
C.
QAP 3170-19, Section C.1.g, states that changes may be made to the approved fire protection program without prior approval of the NRC only if those changes do not adversely affect the ability to achieve and maintain safe shutdown conditions in the event of a fire.
l I
{
As of May 27, 1993, an existing change to the approved i
fire protection program that could adversely affect the e
ability to achieve safe shutdown had not received prior NRC approval.
Specifically, a critical fire protection zone which contains a 13.8 kv transformer fire protection system located on the main turbine floor which must remain operable to protect safe shutdown l
cables or equipment, had been changed from'the system as-designed.
For example, the system as installed left i
open penetrations in the floor of the oil containment area which would allow liquid to flow to the floor below, failed to include certain control valves in the j
surveillance program, had inadequate curb heights in j
the oil containment area to handle the flow of both transformer oil and fire protection water, and failed l
tc have certain alarms connected to the station's central fire alarm system.
III. 10 CFR 50, Appendix B, Criterion XI, " Test Control,"
l requires that a test program be established to assure that e
all testing required to demonstrate that struct2res, c
systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures.
Contrary to the above, from June 1, 1990, until May 27, 1993, a written test program had not been established to demonstrate satisfactory performance of the safety related l
safe shutdown components identified in Attachment 2, Paragraphs B and C, of a licensee letter from B.
Rybak to all Commonwealth Edison Station Managers dated August 29, 1
1986.
i i
IV.
10 CFR 50, Appendix B, Criterion XVI, " Corrective Action,"
I requires that measures be established to assure that l
conditions adverse to quality are promptly identified and l
corrected.
i Contrary to the above, the licensee failed to promptly correct identified conditions adverse to quality.
j Specifically, an August 29, 1986, letter to all Commonwealth Edison Station Managers (B. Rybak Letter) stated, in part, that controls should be imposed on opposite unit / shared unit safe shutdown components not covered by technical i
specifications and that periodic testing should be l
implemented on safe shutdown components.
The failure to i
implement these recommendations was identified in a fire protection assessment report dated December 7, 1989, and in follow-up fire protection assessment report dated May 29, a
1990.
At Quad Cities Station, as of May 27, 1993, the controls had not been imposed for the equipment identified in Attachment 2, Paragraph A, of the B.
Rybak Letter and the testing had not been implemented for the equipment i
i d
,_m
b Notice Of Violation l identified in Attachment 2, Paragraphs B and C of that letter.
f This is a Severity Level III problem (Supplement I).
Civil Penalty - $50,000.
i i
Pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison Company (Licensee) is hereby required to submit a written statement of explanation to the Director, Office of Enforcement, U.S.
Nuclear Regulatory Commission, within 30 days of the date of this Notice of Violation and Proposed Imposition of Civil Penalty (Notice).
This reply should be clearly marked as a " Reply to a i
Notice of Violation" and should include for each alleged-violation:
(1) admission or denial of the allcged violation, (2) the reasons for the violation if admitted, and if denied,.the
{
reasons why, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps that will be taken to avoid further violations, and (5) the date when full i
compliance will be achieved.
If an adequate reply is not received within the time specified in this Notice, an order or a j
demand for information may be issued as to why the license should not be modified, suspended, or revoked or why such other actions as may be proper should not be taken.
Consideration may be given to extending the response time for good cause shown.
Under the authority of Section 182 of the Act, 42 U.S.C.
2232, this response shall be submitted under oath or affirmation.
J Within the same time as provided for the response required under I
10 CFR 2.201, the Licensee may pay the civil penalty by letter addressed to the Director, Office of Enforcement, U.S.
Nuclear i
Regulatory Commission, with a check,. draft, money order, or electronic transfer payable to the Treasurer of the United States i
in the amount of the civil penalty proposed above, or may' protest l
I imposition of the civil penalty in whole-or in part, by a written answer addressed to the Director, Office of Enforcement, U.
S.
Nuclear Regulatory Commission.
Should the Licensee fail to answer within the time specified, an order imposing the civil penalty will be issued.
Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, in whole or in part, such answer should be clearly I
marked as an " Answer to a Notice of Violation" and may:
(1) deny the violations listed in this Notice in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalty should not be imposed.
In addition to protesting the civil penalty in whole or in part, such answer may request remission or mitigation of the penalty.
In requesting mitigation of the proposed penalty, the factors addressed in Section V.B of 10 CFR Part 2, Appendix C, should be addressed.
Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of
I Notice Of Violation the 10 CFR 2.201 reply by specific reference (e.g.,
citing page and paragraph numbers) to avoid repetition.
The attention of the Licensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.
Upon failure to pay any civil penalty due which subsequently has been determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney j
General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C.
2282c.
The responses noted above (Reply to Notice of Violation, letter i
with payment of civil penalty, and Answer to a Notice of Violation) should be addressed to:
Director, Office of i
Enforcement, U.S.
Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C.
20555 with a copy to the Regional Administrator, U.S.
Nuclear Regulatory Commission, Region III, 799 Roosevelt Road, Glen Ellyn, Illinois 60137, and a copy to the NRC Resident Inspector at the Quad Cities Station.
s Dated at Glen Ellyn, Illinois this 6th day of August 1993 J
4 4
h I
i 1
-