ML20141H005
| ML20141H005 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities, 05000365  |
| Issue date: | 06/24/1997 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Kraft E COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20141H009 | List: |
| References | |
| 50-254-96-17, 50-254-96-19, 50-365-96-17, 50-365-96-19, EA-96-530, EA-96-531, NUDOCS 9707140258 | |
| Download: ML20141H005 (6) | |
See also: IR 05000254/1996017
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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June 24, 1997
Commonwealth Edison Company
ATTN: Mr. E. Kraft
Site Vice President
Quad Cities Station
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22710 206th Avenue North
Cordova, Illinois 61242
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SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY
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- $50,000
(NRC Routine Inspection Report 50-254/365/96017(DRP) and NRC
Special Inspection Report 50-254/265/96019(DRP))
Dear Mr. Kraft:
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This refers to the two inspections conducted from October 27 through
December 6, 1996, at the Quad Cities Nuclear Power Station. One of the issues
reviewed during the routine resident inspection (Report 50-254/365/96017(DRP))
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was the potential inoperability of the control room emergency ventilation
system. Special inspection (Report 50-254/365/96019(DRP)) evaluated the
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reactor building interior and external damage caused by high winds. The
results of the inspections were discussed with your staff on November 26 and
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December 6, 1996.
The inspection reports were issued on February 4, 1997. A
predecisional enforcement conference to discuss the issues was held on
February 27, 1997.
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Based on the information developed during the inspection and the information
that your staff provided during the conference, the NRC has determined that
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violations of NRC requirements occurred. These violations are cited in the
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enclosed Notice of Violation and Proposed Imposition of Civil Penalty
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(Notice). The circumstances surrounding each violation are described in
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detail in the subject inspection report.
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On May 10, 1996, corrugated steel siding on the interior and exterior of the
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upper portion of the reactor building sustained wind damage.
Your staff's
initial evaluation concluded that the interior siding was required for the
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integrity of secondary containment, and the function of the exterior sidings
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was cosmetic.
Based on this evaluation, your staff repaired the interior
siding and elected to delay repairs to the exterior siding. The plant on-site /,Sp ,
review committee concurred with this course-of-action.
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An NRC inspection team concluded that the reactor building interior and exterior
siding are an integral part of the secondary containment and both are required to
contain radiological releases in the event of a design basis accident.
This
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conclusion was supported in several sections of the Quad Cities Updated
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Mr. E. Kraft
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Safety Analysis Report (USAR) and eventually acknowledged by your staff.
Each
section of the interior siding was attached with explosive bolts that fail at
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a predetermined differential pressure of 7 inches water-gauge across the
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panels. This design feature protects the reactor building superstructure
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during a design basis accident. During the inspection, the team determined
that many of the explosive bolts had been damaged at some time before the May
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10, 1996, storm.
The team reached this conclusion because the remains of
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damaged bolts had been painted over. As a result, the differential pressure
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that would cause the intact explosive bolts to fail was sufficiently below the
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design differential pressure specified for the structure.
In addition, the
team found two 1
inch air line pipes rigidly attached to the interior siding.
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Subsequent review determined that the piping was installed without a
modification package or an evaluation to analyze whether the installation
affected the interior siding.
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The findings discussed above indicated that your staff did not fully
understand the functional design of the interior and exterior reactor building
siding.
In addition, they failed to translate the desigri into surveillance
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tests to ensure the structure remained operable.
Part I of the Notice includes three violations pertaining to your staff's
failure to maintain the integrity of the reactor building interior and
exterior siding. The first violation involves the failure of your design
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engineering group to adequately translate the design of the reactor building
interior siding into procedures and instructions. Specifically, the
installttion of piping on the interior siding of the reactor building was done
without the benefit of a design modification and was never adequately analyzed
to determine if the modification affected the design function of the internal
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siding. The second violation involves the failure to develop appropriate
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surveillance procedures to periodically inspect reactor building interior
siding blow-out panels and associated " explosive" bolts.
The third violation
involves the failure to adequately evaluate and correct degraded exterior
reactor building siding.
These violations are significant because your staff did not fully understand
the functional design of the interior and exterior reactor building siding.
In addition, your staff failed to translate the design into surveillance tests
to ensure the structure remained operable. Therefore, these violations are
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classified in the aggregate in accordance with the " General Statements of
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Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy),
NUREG-1600, as a Severity Level III problem.
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Mr. E. Kraft
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In accordance with the Enforcement Policy, a base civil penalty in the amount
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of $50,000 is considered for the Severity Level III problem.
Because your
facility has been the subject of escalated enforcement actions within the last
2 years , the NRC considered whether credit was warranted for Identification
and Corrective Action in accordance with the civil penalty assessment process
in Section VI.B.2 of the Enforcement Policy.
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Identification credit was not warranted because site managers and the on-site
review committee reviewed and approved the inadequate safety evaluation that
permitted the delayed replacement of the external reactor building siding.
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The functional requirements of the internal and external reactor building
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siding were not realized until the NRC inspection team specifically questioned
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the USAR description of the reactor building siding.
In addition, it was the
team's inspection of the internal siding that identified the unauthorized and
unanalyzed installation of the air lines and the damaged explosive bolts.
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Corrective Action credit was warranted based on the corrective actions
implemented and discussed at the enforcement conference.
Several of the
corrective actions included:
(1) the repair of all damaged bolts,
(2) painting working labels on all blow-out panels to prevent unauthorized
modifications, (3) routine inspections of the bolts and blow-out panels,
(4) training to personnel on the importance of the blow-out panels and bolts,
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(5) training engineering supervisors on design basis requirements,
(6) communicating the lessons learned to other Commonwealth Edison stations,
(7) training the plant on-site review committee members on design basis
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requirements, and (8) revising operability determination . procedures clarifying
the process for evaluating reduced design margins.
Therefore, to emphasize the need to understand the functional design of a
safety-related system and the significance of your staff's limited questioning
attitude when high winds damaged the reactor building siding, I have been
authorized, after consultation with the Director, Office of Enforcement, to
issue the enclosed Notice of Violation and Proposed Imposition of Civil
Penalty (Notice) in the base amount of $50,000 for the Severity Level III
problem.
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Part II of the Notice includes two Severity Level IV violations pertaining to
the inoperability of the control room emergency ventilation system. The
inoperability was the result of your staff's failure to translate the control
room design specification into surveillance tests to ensure the continued
operability of the control room emergency ventilation system. The severity
level of each violation was based on your analysis (which was confirmed by the
A Severity Levet III violation and $50,000 civil penalty was issued on June 13, 1996,
for falture to implement corrective action to restore design margins to the
structural steel for the low pressure coolant injection corner rooms (EA 96-114).
A Severity Level III violation and $50,000 civit penalty was issued on January 2,
1996, for failure to promptly correct the potential for 480 VAC motor control centers
to trip on a current overtoed (EA 95-241).
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Mr. E. Kraft
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NRC) that the projected dose to the control room staff, during an accident and
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based on the "as found" configuration, would never have exceeded the
10 CFR 20 " Standards for Protection Against Radiation," allowable dose limit.
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These violations were identified as the result of discussions between the
Dresden and Quad Cities staffs when the Dresden staff identified testing
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problems with their control room ventilation. The comunication between the
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two sites and the reviews by the Dresden site staff is commendable. However,
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the Quad Cities staff should have identified the testing deficiencies during
their review of the system configurations before implementing restructured
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technical specifications.
It is the NRC's expectation that your staff will
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communicate the lessons learned from these violations to the other
Commonwealth Edison nuclear power plants so that similar, problems can be
avoided when implementing restructured technical specifications.
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You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response. The NRC will
use your response, in part, to determine whether further enforcement action is
necessary to ensure compliance with regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of
this letter, its enclosure (s), and your response will be placed in the NRC
Public Document Room (PDR).
Sincerely,
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4. Bill Beach
Regional Administrator
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Docket Numbers:
50-254; 50-265
License Numbers: DPR-29; DPR-30
Enclosure: Notice of Violation and Proposed
Imposition of Civil Penalty
See Attached Distribution:
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E. Kraft
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cc w/ enc 1:
T. J. Maiman, Senior Vice President
Nuclear Operations Division
D. A. Sager, Vice President,
Generat' ion Support
H. W. Keiser, Chief Nuclear
Operating Officer
L. W. Pearce, Station Manager
C. C. Peterson, Regulatory Affairs
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Manager
I. Johnson, Acting Nuclear
Regulatory Services Manager
Richard Hubbard
Nathan Schloss, Economist
Office of the Attorney General
State Liaison Officer
Chairman, Illinois Commerce
Commission
J. R. Bull, Vice President, General &
Transmission, MidAmerican Energy Company
Document Control Desk-Licensing
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Mr. E. Kraft
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DISTRIBUTdN:
PUBLIC C-01-
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SECY
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CA
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LCallan, EDO
EJordan, DEDO
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LChandler, OGC
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JGoldberg, OGC
SCollins, NRR
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RZimerman, NRR
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Enforcement Coordinators
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RI, RII and RIV
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Resident Inspectors,
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R. Capra, NRR
R. Pulsifer, NRR
JGilliland, OPA
HBell, OIG
GCaputo, 01
LTremper, OC
Dross, AE00
OE:ES.
-OE:EA (2)
GJohnson, OC/DAF
RAO:RIII
SLO:RIII
PAO:RIII
OC/LFDCB
Docket File
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