ML20134G107
| 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: |
| 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
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Commonwealth Edison Com)any
22710 206th Avenue Nortl
Cordova, IL 61242
SUBJECT:
NRC INSPECTION REPORT 50-254/96017(DRP), 50-265/96017(DRP) AND
Dear Mr. Kraft-
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
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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
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The first apparent violation involves the control room emergency ventilation
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system (CREVS) being inoperable in excess of time limits in the Technical
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
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Region III Office in Lisle. Illinois. The decision to hold a pre-decisional
. 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
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informed enforcement decision.
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Mr. Kraft
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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
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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
and should follow the instructions specified in the enclosed Notice when
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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
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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.
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/s/ J. A. Grobe for
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James L. Caldwell, Director
Division of Reactor Projects
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Enclosures:
1.
2.
Inspection Report 50-254/96017(DRP), 50-265/96017(DRP)
Docket Nos.:
50-254, 50-265
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License Nos.:
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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
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DATE
1/.27/97
1/2 7/97
1/2 7/97
1/ [97
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0FFICIAL RECORD COPY
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Mr. Kraft
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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
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Richard Hubbard
Nathan Schloss, Economist
Office of the Attorney General
1
,
State Liaison Officer
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Chairman, Illinois Commerce
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Commission
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J. R. Bull, Vice President, General &
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Transmission MidAmerican Energy Company
Document Control Desk-Licensing
Distribution:
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Docket File w/ encl
Project Manager NRR w/ enc 1
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PUBLIC IE-01 w/ encl
DRP w/ enc 1
OC/LFDCB w/ encl
SRI Quad Cities Dresden,
RAC1 (E-Mail)
LaSalle w/ encl
,
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A. E. Beach, w/ enc 1
H. B. Clayton, w/ encl
CAA1 (E-Mail)
W. L. Axelson, w/ encl
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RIII PRR w/ encl
J. Goldberg, OGC w/ encl
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J. Lieberman, OE w/ encl
R. Zinnerman, NRR w/ encl
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