ML20134G107

Forwards Insp Repts 50-254/96-17 & 50-265/96-17 on 961027-1206 & Nov.Three Apparent Violations Were Identified & Being Considered for Escalated Enforcement Action

ML20134G107
Person / Time
Site:	Quad Cities
Issue date:	02/04/1997
From:	Caldwell J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Kraft E COMMONWEALTH EDISON CO.
Shared Package
ML20134G109	List: ML20134G107 ML20134G119 ML20134G123
References
NUDOCS 9702100278
Download: ML20134G107 (4)

See also: IR 05000254/1996017

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February 4, 1997

EA 96-531

Mr. E. Kraft, Site Vice President

Quad Cities Station ,

Commonwealth Edison Com)any 1

22710 206th Avenue Nortl l

Cordova, IL 61242  !

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SUBJECT: NRC INSPECTION REPORT 50-254/96017(DRP), 50-265/96017(DRP) AND l

NOTICE OF VIOLATION.  !

Dear Mr. Kraft-

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On December 6,1996, the NRC completed an inspection at your Quad Cities

Nuclear Power Station facilities. The enclosed report presents the results of

that inspection.

During the 6-week inspection period, your conduct of activities at the

Quad Cities facilities was acceptable. However, based on the results of the -

inspection, three apparent violations were identified and are being considered

for escalated enrorcement action in accordance with the " General Statement of

Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy),a

NUREG-1600. .

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The first apparent violation involves the control room emergency ventilation I

system (CREVS) being inoperable in excess of time limits in the Technical l

Specifications (TS). The CREVS was unable to maintain the required positive

pressure C i respect to all required adjacent areas. The second apparent

violation mvolves the failure of a 1985 modification test and subsequent  ;

surveillance tests to ensure the CREVS would perform as described in the

Updated Final Safety Analysis Report (UFSAR). The third apparent violation

involves the failure to perform a required safety evaluation.

An open pre-decisional enforcement conference to discuss these apparent

violations has been scheduled for February 19, 1997, at 9:30 a.m. (CST) in the i

Region III Office in Lisle. Illinois. The decision to hold a pre-decisional 1

. enforcement conference does ,uot mean that the NRC has determined that a

violation has occurred or that enforcement action will be taken. This

conference is being held to obtain information such as a common understanding

of the facts, root causes, missed opportunities to identify the apparent

' violation sooner, corrective actions, significance of the issues, and the need

for lasting and effective corrective action to enable the NRC to make an

l informed enforcement decision.

A

9702100278 970204

PDR ADOCK 05000254

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Mr. Kraft -2-

During the enforcement conference we expect you to address: (1) the

circumstances resulting in the apparent violations (2) your methods to en.sure

equi) ment testing incorporates design specifications such as those described

in t1e UFSAR, (3) an apparent reluctance to perform safety evaluations for

degraded equipment conditions, and (4) how degraded equipment is evaluated to

meet functional and license basis requirements. These discussions should not

be limited solely to the CREVS.

In addition, this is an opportunity for you to point out any errors in our

inspection report and for you to provide any additional information concerning

your perspectives on: (1) the severity of the violations. (2) the application

of the factors that the NRC considers when it determines the amount of a civil

Jenalty that may be assessed in accordance with Section VI.B.2 of the

Enforcement Policy, and (3) any other application of the Enforcement Policy

to this case, including the exercise of discretion in accordance with

Section VII.

In accordance with the Enforcement Policy, no Notices of Violation are

presently being issued for these ins)ection findings. Please be advised that

the number and characterization of tle apparent violations 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. No response regarding the apparent violations is required at

this time.

In addition to the concerns described above, three violations of NRC

requirements were identified this period. The first violation involves the

use of improper pump casing bolts in safety-related Jumps. Although the

condition was identified by station personnel and su) sequent actions to

correct the problem were commendable, this condition appeared to be similar to

other problems related to the control and issuance of safety-related parts.

While the short term corrective actions were aggressive, long term actions

which included both station and corporate actions, have not been demonstrated.

Based on this lack of comprehensive corrective action to prevent recurrence,

the NRC has chosen not to exercise the discretion outlined in Section VII.B.1

of the Enforcement Policy

The second violation, identified by the inspectors, involved the station's

failure to report that the plant was operating in a condition prohibited by TS

as required by 10 CFR 50.73. The third violation involved identification by

the inspectors that your surveillance and testing program did not incorporate

appropriate requirements to ensure TS requirements were being met.

In addition to the violations, the inspectors identified that your maintenance

practices did not always consider a)propriate considerations of risk to

reactor safety. This resulted in t le dual plant power operations for extended

periods with abnormal equipment lineups and without proper attention to the

importance of the maintenance activity or scheduling alternatives.

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Mr. Kraft -3-

These violations are cited in the enclosed Notice of Violation, and the

circumstances surrounding the violations are described in detail in the

enclosed report. Please note that you are required to respond to this letter

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and should follow the instructions specified in the enclosed Notice when

preparing your response. Your response should include a discussion of your

efforts to ensure that TS testing requirements are being addressed by plant

procedures, and methods to ensure that reports to the NRC are made in a timely

manner. You should also discuss the methods Comed is taking to ensure that

parts approved for installation into safety applications-are qualified for

their intended use. The NRC will use your response, in part, to determine

whether further enforcement action is necessary to ensure compliance with

l regulatory requirements.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of

this letter and its enclosures will be placed in the NRC Public Document Room

(PDR).

Sincerely.

/s/ J. A. Grobe for

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l James L. Caldwell, Director

Division of Reactor Projects

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Enclosures:

1. Notice of Violation

2. Inspection Report 50-254/96017(DRP), 50-265/96017(DRP)

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Docket Nos.: 50-254, 50-265

License Nos.: DPR-29, DPR-30

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DOCUMENT NAME: R:\INSPRPTS\ POWERS \0VAD\0UA96017.DRP

T receive a copy of this document, indicate in the box *C" = Copy withou", attach / enc 1 T = Copy with attach /enci "N* =

OFFICE RIII A/ RIII $ NRR M RIII _ _ , RIII a s 4

NAME Hilandfd Clayton b CaprafLh Grob b .. Cal M J

, DATE 1/.27/97 1/2 7/97 1/2 7/97

I 1/ [97 [1/M/97

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0FFICIAL RECORD COPY

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l Mr. Kraft -4-

l cc w/ encl: T. J. Maiman, Senior Vice President

Nuclear Operations Division

D. A. Sager, Vice President,

Generation Su) port

H. W. Keiser, C11ef Nuclear

Operating Officer

L. W. Pearce. Station Manager

C. C. Peterson, Regulatory Affairs

Manager

I. Johnson, Acting Nuclear

Regulatory Services Manager

l Richard Hubbard

Nathan Schloss, Economist

, Office of the Attorney General 1

State Liaison Officer i

Chairman, Illinois Commerce )

Commission I

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J. R. Bull, Vice President, General &

Transmission MidAmerican Energy Company

Document Control Desk-Licensing

i Distribution:

l Docket File w/ encl Project Manager NRR w/ enc 1

PUBLIC IE-01 w/ encl

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DRP w/ enc 1

OC/LFDCB w/ encl SRI Quad Cities Dresden,

, RAC1 (E-Mail) LaSalle w/ encl ,

A. E. Beach, w/ enc 1

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H. B. Clayton, w/ encl  !

CAA1 (E-Mail) W. L. Axelson, w/ encl i

RIII PRR w/ encl J. Goldberg, OGC w/ encl l

J. Lieberman, OE w/ encl R. Zinnerman, NRR w/ encl

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