ML20057B902
| ML20057B902 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 09/21/1993 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Wallace M COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20057B903 | List: |
| References | |
| NUDOCS 9309240130 | |
| Download: ML20057B902 (5) | |
Text
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UNITED STATES o
NUCLEAR REGULATORY COMMISSION
('go REGION iil e
I. Y.1 799 ROOSEVELT ROAD GLEN ELLYN, ILUNOIS 60137-5927 y4,
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September 21, 1993 Docket Nos.
50-254 and 50-265 License Nos.
DPR-29 and DPR-30 EA 93-210 Commonwealth Edison Company ATTN:
Mr. Michael J.
Wallace Vice President, Chief Nuclear Officer Executive Towers West III 1400 Opus Place, Suite 300 Downers Grove, Illinois 60515
Dear Mr. Wallace:
SUBJECT:
QUAD CITIES STATION - UNITS 1 AND 2 NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY - $125,000 (NRC INSPECTION REPORT NO. 50-254/265/93017(DRS))
This refers to the special safety inspection conducted during the period of June 9 through August 12, 1993, at Quad Cities Station, Units 1 and 2.
The purpose of the inspection was to review the circumstances surrounding the Unit 1 High Pressure Coolant Injection (HPCI) system rupture disc burst event on June 9, 1993.
The report documenting this inspection was sent to you by letter dated August 13, 1993.
You reported this event to the NRC Operations Center on June 9, 1993, and subsequently reported the reactor shutdown on June 18, 1993.
You submitted a Licensee Event Report on July 9, 1993, and a letter addressing your corrective actions on August 20, 1993.
On June 9, 1993, while performing the Unit 1 quarterly HPCI pump operability test, water was expelled from the HPCI turbine casing bursting the 20 year old rupture discs and releasing steam into the HPCI room.
The water had accumulated in the casing because of a faulty steam drain level switch.
The event damaged the HPCI turbine thrus* I aring, a set of fire doors, and both sets of secondary con.
Lument doors.
Five workers were contaminated and injured as a result of the steam release, one of whom required hospitalization for burns for several days.
The failed Unit 1 HPCI steam drain system was not an isolated case.
Inspections after the June 9, 1993, event identified that the steam drain systems on Unit 2 HPCI, and Unit 2 reactor core CERTIFIED MAIL RETURN RECEIPT REOUESTED n n e. -,.
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Commonwealth Edison Company 5 isolation cooling (RCIC) systems were also not functioning properly.
Four violations were identified as described in the enclosed Notice of Violation and-Proposed Imposition of Civil Penalty (Notice).
The violations involve: (1) failure to correct i
deficiencies with the HPCI turbine steam inlet-and exhaust level I
switches despite recurring work requests, industry notifications, a HPCI reliability centered maintenance (RCM) report recommendation, and a Site Quality Verification (SQV) audit; (2) i failure to make personnel near the HPCI turbine aware of an impending test and the potential for leaking steam; (3) failure to conduct a briefing prior to a test; and (4) an inadequate procedure for draining moisture from the HPCI turbine inlet steam
- line, i
The root cause of the event was Commonwealth Edison Company i
(CECO) management's failure to properly control activities associated with the safety related HPCI system.
The most significant failure was that engineering personnel did not fully understand the system's design and vulnerabilities, and did not insist that steam drain system problems were properly addressed.
l These failures existed even though there were long-standing, uncorrected problems with the steam drain system, and industry and Ceco documents, such as General Electric Service Information Letter No. 531 dated February 7, 1991, which were not acted on in a timely manner.
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Contributing to the problem were the facts that operations' l
personnel failed to control system tenting; maintenance personnel failed to evaluate recurring steam drain system failures; quality verification personne1' failed to follow up on identified issues; l
and an assessment of the potential HPCI vulnerabilities in November 1992 failed to consider relevant available docume W.s i
that-could have led to the earlier discovery of the probli u with l
the system.
While the issues discussed above specifically relate to the June 9, 1993 event, data indicates that your management effectiveness in maintaining safety system reliability has been poor at Quad Cities.
The number of safety system failures at Quad Cities in the last several years has been abnormally high.
For the HPCI system alone, LER data shows that there have been 2/
system failures since 1989.
I am particularly concerned that I
recent discussions with your supervisory and staff personnel revealed a general lack of knowledge of the poor performance of such safety systems, and little appreciation of the significance of the safety system failures.
i The violations represent a breakdown in the control of licensed activities and a significant lack of attention towards licensed i
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l Commonwealth Edison Company responsibilities.
Therefore, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"
(Enforcement Policy) 10 CFR Part 2, Appendix C, the violations are classified in the aggregate as a Severity Level III problem.
To emphasize the need for management involvement and oversight of activities affecting safety related systems, and appropriate prioritization and resolution of identified problems, I have been authorized after consultation with the Director, Office of i
Enforcement, and the Deputy Executive Director for Nuclear ~
Reactor Regulation, Regional Operations and Research to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) in the amount of $125,000 for the Severity Level III problem.
The base value of a civil penalty for a Severity Level III problem is $50,000.
The civil penalty adjustment factors in the Enforcement Policy were considered.
i The base civil penalty was escalated 50 percent because the NRC identified the program breakdown during the follow-up of the i
event.
We acknowledge your comprehensive corrective actions for the HPCI event itself, as identified in your letter dated August 20, 1993.
However, the corrective actions did not address the broader issues of engineering and management effectiveness.
This was underscored by a recent event in which the HPCI system engineer inappropriately directed valve manipulations which resulted in the HPCI drain float switch being isolated.
Therefore, no adjustment to the base civil penalty was made for corrective action.
The base civil penalty was escalated 100 percent for your poor past performance.
As previously discussed, the number of safety system failures at Quad Cities has been abnormally high.
Furthermore, two other escalated actions were recently issued (EA 93-127 and EA 93-162) for failure to implement fire protection and safe shutdown requirements; and inoperability of the diesel generators due to an original plant design error, and an incorrectly installed oiler.
The other adjustment factors in the Policy were considered and no further
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adjustment to the base civil penalty is considered appropriate.
Therefore, based on the above, the base civil penalty has been increased by 150 percent.
You are required to respond to this letter and should follow the instructions specified in the enclosed Motice 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, i
including your proposed corrective actions and the results of l
tuture inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
i In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice,"
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Commonwealth Edison Company
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a copy of this letter, its enclosure, and your responses will be placed in the NRC Public Document Room.
The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of
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Management and Budget as required by the Paperwork Reduction Act i
of 1980, Public Law No.96-511.
j sincer-y,
/
NAftOff John B.
Martin Regional Administrator I
Enclosure:
Notice of Violation and Proposed i
Imposition of Civil Penalty
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cc w/ enclosure:
L.
DelGeorge, Vice President, Nuclear Oversight and Regulatory l
Services R.
Pleniewicz, Site Vice President R.
Bax, Station Manager A.
Misak, Regulatory Assurance Supervisor D.
Farrar, Nuclear Regulatory Services Manager OC/LFDCB Resident Inspectors, Quad Cities, Dresden, LaSalle, Clinton Richard Hubbard J.
W.
McCaffrey, Chief, Public Counsel, State of Illinois Center Licensing Project Manager, NRR R.
Newmann,,0ffice of Public Counsel, State of Illinois Center State Liaison Officer H.
J.
Miller, Region III' h
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Commonwealth Edison Company p_ISTRIBUTION:
PDR SECY CA JTaylor. EDO JSniezek, DEDR JLieberman, OE JLuehman, OE LChandler, OGC JGoldberg, OGC TMurley, NRR JPartlow,-NRR Enforcement Coordinators RI, RII, RIV, RV FIngram, GPA/PA DWilliams, OIG BHayes, OI EJordan, AEOD OE:Chron OE:EA (2) 6DDSRsp State of Illinois RAO:RIII SLO:RIII PAO:RIII IMS:RIII
.