ML20154G401
| ML20154G401 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 09/11/1998 |
| From: | Caldwell J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Kingsley O COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20154G404 | List: |
| References | |
| 50-254-97-23, 50-254-98-11, 50-265-97-23, 50-265-98-11, EA-98-175, EA-98-231, NUDOCS 9810130162 | |
| Download: ML20154G401 (5) | |
See also: IR 05000254/1997023
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
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September 11, 1998
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Mr. Oliver D. Kingsley
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President, Nuclear Generation Group
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Commonwealth Edison Company
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ATTN: Regulatory Services
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Downers Grove, IL 60515
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SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY -
$88,000 (NRC inspection Report Numbers 50-254(265)/97023(DRS) and
50-254(265)/98011(DRS))
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Dear Mr. Kingsley:
This refers to two inspections conducted from October 14,1997 to May 22,1998, at the
Commonwealth Edison Company's (Comed) Quad Cities Nuclear Power Station (Quad Cities).
The inspections identified several apparent violations associated with Comed's (1)
implementing procedures for the post-fire safe shutdown analysis and, (2) changes to safe
shutdown procedures that involved an unreviewed safety question. The NRC discussed
significant inspection findings with members of the Comed staff at a public management
meeting conducted in the Region ll1 office on December 19,1997, The results of the
inspections were discussed at exit interviews conducted on April 15 and May 22,1998. On
June 18,1998, an open predecisional enforcement conference was held in the Region til office
to discuss the apparent violations.
Based on the information developed during the inspection and the informati' n provided by
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Comed representatives during the predecisional enforcement conference, the NRC has
determined that violations of NRC requirements occurred. These violations are cited in the
enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice), and the
circumstances surrounding them are described in detail in the subject inspection reports.
The violations in the Notice represent inadequacies in Comed's capability to shutdown the
Quad Cities facility following a postulated design basis fire. When it identified in
September 1997 that it may not be able to shutdown the Quad Cities facility following a
postulated design basis fire, Comed implemented compensatory measures including shutting
down Unit 2. However, during a December 19,1997, public meeting that occurred after several
months of NRC inspections, Comed acknowledged NRC inspection findings that concluded that
despite the compensatory measures, Comed had not demonstrated and could not demonstrate
that the Quad Cities design basis fire safe shutdown analysis and implementing procedures
were adequate. Subsequently, Comed shutdown Unit 1 and kept Unit 2 shut down while the
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analysis and procedures were revised and validated. These violations indicated a broad lack
of understanding on the part of the Quad Cities' staff for the importance of having analyzed,
proceduralized, and validated means for achieving and maintaining safe shutdown following a
design basis fire. During the enforcement conference, Comed acknowledged that inadequate
knowledge and ownership of the fire protection program, along with inadequate management
involvement and support for correcting identified deficiencies in the safe shutdown program
were several of the root causes for these violations. Comed stated that it expected that
operators would have been able to achieve and maintain safe shutdown based on their training
and various procedures including abnormal and emergency operating procedures (EOPs) and
equipment not described in the Quad Cities safe shutdown analysis. However, the NRC
concluded that some equipment necessary to achieve safe shutdown may not be available or
accessible and that reliance on unanalyzed impromptu measures such as combining sections
of EOPs during the fire would not provide reasonable assurance that operators could achieve
post-fire safe shutdown conditions.
Additionally, in response to the safe shutdown issue, Comed char. gad its safe shutdown
procedures to permit the use of the station blackout diesel generator in lieu of the emergency
diesel generators without first performing a safety evaluation to confirm that the departure from
the Updated Final Safety Analysis Report (UFSAR) did not constitute an unreviewed safety
question. The required safety evaluation was performed after substantialintervention by the
NRC staff. When performed, the NRC staff identified that the safety evaluation was deficient
because it did not consider all necessary manual actions required to operate the station
blackout diesel generator. These actions included manual unloading and reloading of electrical
buses and diesel engine refueling sooner than previously anticipated. Comed subsequently
determined that the additional manual actions needed to utilize the station blackout diesel
involved an unreviewed safety question that required Commission approval prior to
implementation of the change. The failure to perform a safety evaluation for a change to the
facility as described in the USFAR that was subsequently determined to be an unreviewed
safety question constitutes a violation of 10 CFR 50.59, " Changes, Tests, and Experiments."
These violations represent a very significant safety concern because they involve inadequacies
in Comed's capability to shutdown the Quad Cities facility following a postulated design basis
fire. Due to the design of the Quad Cities facility, the alternative shutdown capabilities relied
heavily on administrative controls to use opposite unit equipment and to implement a large
number of manual actions. If a design basis fire occurred in certain fire areas, the capability of
meeting shutdown performance goals, such as reactor coolant makeup, reactor heat removal,
process monitoring, and support functions, varied from area to area. Also of concern is
Comed's ability to evaluate fire protection issues as demonstrated by the weaknesses in its
preparation of the safety evaluation. In sum, because a postulated fire would so damage
equipment that reasonable assurance did not exist that safe shutdown could be achieved and
maintained using analyzed equipment and procedures, the violations were classified in the
aggregate, in accordance with NUREG-1600, " General Statement of Policy and Procedure for
NRC Enforcement Actions (Enforcement Policy)," as a Severity Level 11 problem.
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O. Kingsley
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In accordance with the Enforcement Policy, a base civil penalty in the amount of $88,000 is
considered for the Severity Level !! problem. Because the Quad Cities facility has been the
subject of escalated enforcement actions within the last two 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 c," the Enforcement Policy. Identification
credit was warranted because the Quad Cities engineering staff identified all of the technical
concems regarding the inadequacies in the Quad Cities alternative shutdown capabilities.2
Corrective Action credit was not warranted due to the extensive involvement by the NRC,
including involvement in identifying the 10 CFR 50.59 violation, to focus Comed resources to
obtain comprehensive corrective actions. The NRC's involvement culminated in the
December 19,1997 management meeting, during which the NRC pointed out significant
deficiencies in Comed's corrective acticas. This meeting resulted in Comed shutting down the
remaining operating unit and maintaining both units shutdown until these safe shutdown
violation: were corrected. Since Identification credit was warranted and no Corrective Action
credit was warranted, the civil penalty assessment for the violations is $88,000.
Therefore, to emphasize the importance of maintaining the post-fire safe shutdown capabilities
for all fire areas and the acknowledgment of Comed's recognition that the Quad Cities
10 CFR 50.59 program was in need of comprehensive corrective action, I have been authorized
after consultation with the Director, Office of Enforcement, and the Deputy Executive Director
for Regulatory Effectiveness, to issue the enclosed Notice of Violation and Proposed Imposition
of Civil Penalty in the amount of $88,000.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. Notwithstanding the apparent
comprehensiveness of your corrective actions associated with the 10 CFR 50.59 violation, and
in light of the prior similar violations, you should describe why you believe your actions will be
effective in preventing additional violations of 10 CFR 50.59. The NRC will use your response,
in part, to determine whether further enforcement action is necessary to en,sure compliance
with regulatory requirements.
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EA 97 591 issued two Severity Level til problems with a $330,000 civil penalty on March 12,1998, for
inadequate procedures for surveillance testing of the primary coolant system boundary and an inadequate
10 CFR 50.59 safety evaluation associated with changes to the surveillance procedures.
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While the NRC was involved in identifying the 10 CFR 50.59 issue, for purposes of assessment, this was
considered in determining Corrective Action credit.
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in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its
enclosure, and your response will be placed in the NRC Public Document Room.
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Sincerely,
James L. Caldwell
Acting Regional Administrator
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Docket Nos. 50-254; 50-265
Enclosure: Notice of Violation and Proposed
imposition of Civil Penalty
cc w/ encl:
M. Wallace, Senior Vice President
D. Helwig, Senior Vice President
G. Stanley, PWR Vice President
J. Perry, BWR Vice President
R. Krich, Regulatory
Services Vice President
1. Johnson, Licensing Director
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DCD - Licensing
J. Dimmette, Jr., Site Vice President
W. Pearce, Quad Cities Station Manager
C. Peterson, Regulatory Affairs Manager
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R. Hubbard
N. Schloss, Economist
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Office of the Attorney General
State Liaison Officer
Chairman, Illinois Commerce
Commission
W. Leech, Manager of Nuclear
MidAmerican Energy Company
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DISTRIBUTION /
PUBLIC IE,-Of
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CA
JCallan, EDO
WTravers, DEDE
= LChandler, OGC
'JGoldberg, OGC
SCollins, NRR
RZimmerman, NRR
PSoger, NRR
Enforcement Coordinators
RI, Ril and RIV-
Resident inspector, Quad Cities
SRichards, NRR
APulsifer, NRR
JGilliland, OPA .
HBell, OlG
GCaputo, Ol
LTremper, OC
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TMartin, AEOD
OE:ES
OE:EA (2)
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OCFO/LFARB w/o encl.
Docket File
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