ML20057B912

Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $125,000.Noncompliance Noted:As of 930609 Licensee Failed to Promptly Correct Identified Condition Adverse to Quality

ML20057B912
Person / Time
Site:	Quad Cities
Issue date:	09/21/1993
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20057B903	List: ML20057B902 ML20057B912
References
EA-93-210, NUDOCS 9309240138
Download: ML20057B912 (5)

Text

• *

?Q NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Commonwealth Edison Company Docket Nos. 50-254 and 50-265 Quad Cities Station License Nos. DPR-29 and DPR-30 Units 1 and 2 EA 93-210 During an NRC inspection conducted from June 9 through August 12, 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:

A. 10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action," requires, in part, that measures be established to assure that conditions adverse to quality are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action shall be documented and reported to the appropriate levels of management.

Contrary to the above:

1. As of June 9, 1993, recurring significant conditions adverse to quality existed with the High Pressure Coolant Injection (HPCI) turbine steam inlet drain level high alarm as documented in eight work requests dated between April 17, 1986, and September 18, 1992, and the cause of the condition was not determined and corrective action was not taken to preclude repetition.

2. As of June 9, 1993, the licensee failed to promptly correct an identified condition adverse to quality.

Specifically, the licensee received a General Electric Service Information Letter (SIL) No. 531, "HPCI and Reactor Core Isolation Cooling (RCIC) Magnetrol Level Switches," which was issued on February 7, 1991. The SIL recommended the installation of an improved level switch in high temperature applications. Although the SIL directly applied to the HPCI and RCIC system drain level switches, the licensee took no action regarding the recommendations.

3. As of June 9, 1993, the licensee failed to promptly correct an identified condition adverse to quality.

Specifically, the final report of the HPCI system 9309240138 930921 PDR ADDCK 05000254 G PDR 2...

7'T ~ .

I i

l Notica of Violation -2 -

1 l

reliability centered maintenance study dated December 31, 1991, recommended calibration and functional testing of the HPCI turbine inlet and exhaust drain pot high level switches at 18 month intervals. The licensee did not include this activity in its preventative maintenance program. Furthermore, Site Quality Verification Audit No. 04-93-01 dated March 10, 1993, identified that the torus high level i switches had not been tested as recommended by the  ;

reliability centered maintenance study, and concluded that the station did not adequately review the reliability centered maintenance report. l B. 10 CFR 50, Appendix B, Criterion V, " Instructions,

• Procedures, and Drawings," states that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with 1 these instructions, procedures, or drawings.

1. Procedure QCOS 2300-5, Revision 3, dated December 11, 1992, " Quarterly HPCI Pump Operability Test," Step F.4, requires ensuring that personnel near the HPCI turbine I are aware of the impending test and the potential for steam leaking around the turbine.

Contrary to the above, on June 9, 1993, personnel near the HPCI turbine were not made aware of the impending test and the potential for steam leaking around the turbine. '

i

2. Procedure QAP 300-2, Revision 36, dated May 1993,

" Conduct of Operations," Step C.13.j, " Responsibilities of all Operating Department personnel licensed by the Nuclear Regulatory Commission as Reactor Operators or  !

_ Senior Reactor Op_erators," requires that briefings be '

l conducted by cognizant personnel for individuals involved in an evolution that is to be performed. The detail of the briefing is dependent on the degree of ,

complexity, routineness, logistics, or number of people  !

involved. d l

Step C.14.1, " Responsibilities of all Operating Department personnel licensed by the Nuclear Regulatory Commission as Senior Reactor Operators," requires that l briefings be conducted by the Shift Engineer, or his '

designee, for individuals involved in an evolution that is to be performed. The detail of the briefing is dependent on the degree of complexity, routineness, i logistics, or .nber of people involved.

l 1

l

I I

i l

Notice of Violation l l

The individual who is to perform the activity is l responsible to adequately review the procedure, to l fully understand what he is doing, and to be cognizant  !

of all limitations, precautions, and requirements.

l Evolutions involving many individuals, especially from two or more departments or disciplines, may require large formal briefings or preplanning sessions. If the evolution is complex and involves close coordination, the briefing session shall be coordinated by the Operating Engineer or his designee and should include: l l

(1) a review of the appropriate section of the '

procedure by key parties; (2) examination of each individual's specific involvement and responsibility; (3) discussion of expected results or performance;

• review of limitations, hold points, emergency action to be taken if contingencies arise; and (4) assurance that everyone understands the interface  ;

and communications required.

Contrary to the above, on June 9, 1993, Operating Department personnel licensed by the NRC did not conduct a briefing prior to performance of the  !

Quarterly HPCI Pump Operability Test, an evolution involving many individuals drawn from two or more departments and requiring close coordination among the participants.

3. Procedure QCOS 2300-5, Revision 3, dated December.11, l 1992, " Quarterly HPCI Pump Operability Test," Step 1.22, for draining moisture from the HPCI inlet steam line specified a time limit of 10 seconds as the criterion for closing drain valves AO 1(2)-2301-64 and AO 1(2)-2301-65.

Contrary to the above, as of June 9, 1993, Procedure QCOS 23u0-5, Revision 3 was determined to be inappropriate for the circumstances because Step I.22 should have specified the observation of steam from the sump as the criterion for closing the drain valves in ,

order to ensure that all moisture had been properly drained.

This is a Severity Level III problem (Supplement 1). i Civil Penalty - $125,000. L

O .

]

i Notice of Violation -4 -

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  ;

Notice of Violation" and should include for each alleged  ;

violation: (1) admission or denial of the alleged violation, (2) '

the reasons for the violation if admitted, and if denied, the t reasons why, (3) the corrective steps that have been takeh'and the results achieved, (4) the corrective steps that will be taken to avoid further violations, and (5) the date when full compliance will be' achieved. If an adequate reply is not received within the time specified in this Notice, an order or a 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.

Within the same time as provided for the response required under  !

10 CFR 2.201, the Licensee may pay the civil penalty by letter l addressed to the Director, Office of Enforcement, U.S. Nuclear J Regulatory Commission, with a check, draft, money order, or l electronic transfer payable to the Treasurer of the United States '

in the amount of the civil penalty proposed above, or may protest 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 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 I in part, such answer may request remission or mitigation of the penalty.

r 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 i should be set forth separately from the statement or explanation l in reply pursuant to 10 CFR 2.201, but may incorporate parts of l the 10 CFR 2.201 reply by specific reference (e.g., citing page l 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.

1

{ . .. . . . -

r I-

-Notice of Violation. 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 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 with payment of civil penalty, and Answer to a Notice of Violation) should be addressed to: Director, Office of 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.

Dated at Glen Ellyn, Illinois this 21st day of September 1993

-