ML20197E949
| ML20197E949 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 12/18/1997 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Pearce L COMMONWEALTH EDISON CO. |
| References | |
| EA-97-413, NUDOCS 9712300109 | |
| Download: ML20197E949 (46) | |
Text
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Dece ber 18,'1997 l
EA 97-413 Mr. L. W. Pearce Site Vice President Quad Cities Station Comrreonwealth Edison Company 22710 206th Avenue North' Cordova,IL 61242
SUBJECT:
NRC PREDECISIONAL ENFORCEMENT CONFERENCE
SUMMARY
Dear Mr. Pearce:
Thit refers to the Predecisicnal Enforcement Conference conducted by Mr. A. B. Beach, Regional Administrator, and other members of tho Region lil and Headquarters staff on
' November 5,1997. The subject of this conference was the apparent violations at Quad Cities Station identified in the NRC's letter to you dated September 17,1997, involving 10 CFR 50.9,
' Completeness and Accuracy of Information."
During the conference, your staff acknowledged the violations and presented information addressing the background, conclusions, significance, and lessons leamed for issues involving the operability determination, secondary containment, and coupon sample test. Also, actions taken by the site to prevent recurrence were presented. Copies of the NRC's and licensee's handouts, and the attendance list are enclosed with this summary.
You will be notified by separate correspondence of our decision regarding the enforcement action based on the information presented and discussed at the Predecisional Enforcement Conference. No response is required until you are nctified of the proposed Enforcement Action.
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.
Sincerely,
/s/ J. Jacobson for
' John A. Grobe, Director Divir n of Reactor Safety Docket Nos. 50-254150-265 License Nos. DPR-29; DPR-30
Enclosures:
As stated
- b. h.lh. l.l l.l-See Attached Distribution t-
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DOCUMENT NAME: G:\\DRS\\QUA12157 DRS d
To receive a copy of tNs document, Indicate in the box "C* a Copy wtmout attachmentrencbsure *E's Copy with attachment /encboure *N" = No copy OFFICE Rlll/DRS l(1 Rlll/DRPf l
Rlll/EICS '
l Rlil/DRhb NAME JGavula:s&M MRing@
HClayton /b JGrobeM6 DATE 12/lL/97 RV 12/4/97 12/18/97 12$9N
9712300109 971218
'clCIAL RECORD COPY
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PDR ADOCK 05000254 V "U[
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F L W. Pearce
' 2 Deceber 18,'1997 cc w/encis:
O. Kingsley, Nuclear Generation Group President & Chief Nuclear Officer.
M. Wallace, Senior Vice President, Corporate Services E. Kraft, Vice President, BWR Operations Liaison Officer, NOC-BOD D. A. Sager, Vice President, Generation Support D. Farrar, Nuclear Regulatory--
Services Manager I. Johnson, Licensing Operations Manager Document Control Desk - Licensing Quad Cities Station Manager C C. Paterson, Regulatory Affairs Manager 4
Richard Hubbard Nathan Schloss, Economist, Office of the Attomey General State Liaison Officer Chairman, Illinois Commerce Commission W. D. Leech, Mana. sr of Nuclear, MidAmerican Energy Company -
Distribution Docket File w/encls Rlli PRR w'encls Rlli Enf. Coordinator w/encls -
PUBLIC lE-01 w/encls SRI, Quad Cities w/encls TSS w/encls LPM, NRR w/encls
- J L. Caldwell, Rlli w/encls R. A. Capra, NRR w/encls DRP w/encls A. B. Beach, Rlli w/encls DOCDESK w/encIs DRS w/encls CAA1 w/encls R, Zimmerman, NRR J. Lieberman, OE J Goldberg, OGC f
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4 Attendance Sheet
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DATE: 11/5/9_7; REF. NO. EA 97-413
- LICENSEE: QUAD CITIES bleME TITLE COMPANY
- A. B. Beach Regional Administrator NRC R.- A. Capra Director, PDlli 2
_NRC
-J. M.- Jacobson Acting Deputy Director, DRS NRC M. Dapas -
Acting Deputy Director, DRP NRC R. M. Pulsifer Project Manager NRC R. Landsman
_ Project Engineer NRC J. A. Gavula
- Chief, Engineering Spec Branch 1 NRC C. G. Miller Senior Resident inspector NRC T. Reis Office of Enforcement NRC J. Heller --
Enforcement Coordinator NRC
. B. Berson =
Regional Counsel NRC H. Walker-Senior Specialist NRC E. S. Kraft, Jr.
BWR - Vice President Comed L. W. Pearce Site Vice President, Quad Cities Comed D.' B. Cock Plant Manager, Quad Cities Comed S. Eldridge Engineering Assurance Supervisor Comed R. Scoville Staff Engineer, Quad Cities Comed B.' Ryoak Senior Licensing Administrator iomEd R. Freeman Dreden Comed R. Gavankar Chief Engineer (Mech / Structural)
Comed J. Purkis System Engineer Supervisor Comed D. Stenger Attomey(Winston & Strawn)
Comed B. Helfrich Senior Counsel, Nuclear Comed D. Farrar Licensing Comed B. Fairbank Acting Site Engineer Manager Comed D.-Leech Manager, Nuclear Mid American Energy d
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ATTACHMENT B
NRC HANDOUT 1
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The appar:nt viol: tion discussed ct tha pred:cisi:nal cnicrc rn:nt confcrcnca is subj:ct to
- further r2vi:w cnd is subj ct to chInga prior to cny rzsulting enforc:m:nt action A.
10 CFR 50.9 (a) requires, in part, that information provided to the Commission by a licensee shall be complete and accurate in all material respects.
Contrary to the above, the August 25,1996, Operability Determination Checklist, which was attached to the PORC minutes stated, "The beams and connections checked had functionality interaction coefficients (FICs) less than 1.0," was inaccurate. Specifically, supporting calculations showed FICs to be in excess of 1.0. This information was material because the correct information would likely have resulted in substantial further inquiry by the NRC.
B.
10 CFR 50.9 (a) requires, in part, that information provided to the Commission by a licensee shall be complete and accurate in all material respects.
. Contrary to the above, during Quad Cities site visits on May 14 and 15,1996, the statements made by Commonwealth Edison personnel to NRC officials, that the metal siding panels blown off the Reactor Building during high winds on May 10,1996, had no effect on structJral integrity, was inaccurate and misleading.
Specifically, the panels were reQJired for structural integrity during design basis wind load or a line break in secondary containment. This information was material because the correct information would likely have resulted in substantial further inquiry by the NRC.
The apparent violation discussed at the predecisional enforcement conference is subject to further review and is sui;!ect to change prior to any resulting enforcement action
ATTACHMENT LICENSEE HANDOUT 1
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i Quad Cities Station Apparent Violations 1
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Operability Determination Secondary Containment Siding Coupon Sample Tests i
Actions Taken
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Quad Cities Station Operability Determination Issue t
Operability Determination Checklist, l
Attachment B of PIF 95-2256, stated:
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The beams and connections checked had functionality interaction coefficients less l
l than 1.0."
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i Quad Cities Station Operability Determination
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Factual Background l
i Corner Room Steel Issue Identified In
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August 1995 -- PIF 95-2256 Management Took Aggressive Action i
- Initiated 72-hour Operability Evaluation
- Preparations Made for Temporary Support of L
RHR Heat Exchangers I
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I Quad Cities Station lL Operability Determination i
Factual Background Operability Evaluation
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- Primarily Qualitative, Based on Previous Dresden Operational Evaluation and Engineering Judgment l
- Preliminary Evaluations Performed for Quad Cities i
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> Based on these, Operational Evaluation stated that l
Functionality Interaction Coefficients for i
Representative Beams and Connection.s Were < 1.0 i
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Quad Cities Station l
Operability Determination Factual Background t
PORC Did Not Accept as Final Determination at t
8/24/95 Meeting
- Allowed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for Further Evaluation
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- Wanted to Bound Problem - Knew More Calculations i
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4 Further Engineering Evaluation
- Corporate Engineering Support Provided j
- Additional Sample Evaluations Performed on Beams (Comed) and Connections (S&L) on 8/25 4
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Operability Determination Factual Background 1
l During 8/25 Meeting, PORC Accepted and j
Directed-I i
- Engineering to Continue Performing Formal l
Calculations
- Engineering to Initiate Design for 1
l Modifications to Restore Steel to Design Basis r
Limits i
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~"~~6perability Determination Factual Background
- Final Operability Calculations Completed 9/15/95
- Representative Beams Showed Acceptable Operability Functionality Interaction Coefficients
- In One Case (Beam B4) Engineering Judgment Used to Conclude Acceptable Interaction Coefficients
- Design Effort Continued 10
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Quad Cities Station '
Conclusions Operability Determination and Conclusion Were Valid:
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- Understand Source of Confusion r
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> Use of Term " Calculation"
> Lack of Explanation of Use of Engmeenng Judgment in the Operability Evaluation i
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.i Quad Cities Station Operability Determination l
Conclusions (Cont')
While the Terms could Cause Confusion, there was No Intent to Mislead i
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- Record of Second Set of Sample Calculations t
Performed
- PORC Understood Operability Determination Evaluation was not Formal Calculation
- Final Calculations Documented Engineering Judgment jt f
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l Quad Cities Station Operability Determination Significance i
i No Safety Consequences i
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- Did Not Affect Station's Actions
- PORC Review Not Affected
- Final Calculations Confirmed Operability Conclusion l
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w Quad Cities Station Operability Determination L
Lessons Learned i
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- LComEd Understands Potential for 4
Confusion
- Use of Term " Calculation"
- Need to Explain Bases for Judgments 14 1
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7 Quad Cities Station t
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Secondary Containment Siding i
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"~~~ Secondary Containment Issue l
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- Verbal Statements to NRC Regarding Function of Exterior Siding Panels on l
- Reflected Station's Understanding at Time Based on Inadequate Engineering Evaluation I
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~ ~~ Secondary Containment Factual Background c
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- Friday, May 10,1996 l
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- High Winds Hit -Station l
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> Damaged Exterior Siding Panels j
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> Other Damage to Site Facilities
- Secondary Containment Declared Inoperable
- Unit 2 Promptly Shut Down i
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- Unit 1 Already Shutdown, in Refueling i
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"~ ~~$econdary Containment Factual Background
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- Immediate Concerns Addressed by Engmeenng and Station Management 1
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- Personnel and Plant Safety
- Stabilization of Secondary Containment j
Envelope i
- System Restoration f
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~~~~ Secondary Containment Factual Background l
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- May 12,1996 4
- Operations Verified Standby Gas Treatment System Maintaining Negative 0.25 Inches l
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Water Pressure in Secondary Containment L
> Technical Specification Requirement l
- Secondary Containment Not Declared Operable 4
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~~~~5econdary Containment Factual Background i
- Engineering Reviewing Function of l
Exterior Siding -- Mistakenly Believed l
Siding Not Required forIntegrity
- Vendor Information Was Not Questioned l
-Inadequate Review ofDesign Bases
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~~~~5econdary Containment Factual Background
- May 10-15, Efforts t restore Plant & Site
- Secondary Containment Blowout Panel Repair
- Secondary Containment Siding Stabilization
- SBO Dieseis Out of Service due to Cable Damage
- Liquid Nitrogen Storage System Damage
- Meteorology Tower Damage
- Waste Oil Building Destroyed
- Mixed Waste Building Damage l
- Corner Room Steel & Other Issue Resolution l
- Unit 1 Outage In Progress 21
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~~"~5econdary Containment j
Factual Background j
- May 15,1996 t
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- Major Engineering Efforts Still Underway l
- Engineering Discussions with NRC j
> Indicated Siding Not Needed for Secondary l
Containment 1
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> Based on Belief of Vendor Input, Compliance with Technical Specification D/P Requirements, and Characteristics of Siding r
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~ ~~ Secondary Containment Factual Background l
- May 15,1996 (Cont')
NRC Senior Management Site Visit l
> Primary Focus on SBO Cables
> Comed Provided Understanding that Secondary
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Comed Personnel had Verified with Vendor
- As of May 15,1-inch Line Break Scenario Not Identified i
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~~~5econdary Containment j
Factual Background
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- May 18-24,1996
- Management Decision to Keep Both Units Shutdown to Resolve OtherIssues l
- May 19, Secondary Containment Declared Operable and FSAR Change Started
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- May 22, SRC Questioned Basis i
- May 29, Secondary Containment Declared Inoperable l
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~~~5econdary Containment Conclusions I
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- Statements Inaccurate Based on Information Later t
Developed, But Reflected Station's Understanding i
After Significant Event
- Incorrect Initial Assessment Due to Lack of l
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Questioning Attitude I
- Secondary Containment Met Technical Specification Surveillance Requirement
- Characteristics of Siding Suggested Only Needed for I
Weather Protection i
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~ ~~ Secondary Containment Conclusions (Cont')
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- NotIntentional j
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- Real Time Oral Communication to NRC of What Comed Believed Subsequent to Crisis l
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~~~~5econdary Containment t
Significance j
- No Safety Consequences 1
- Until Siding Repaired, Both Units Remained in j
Cold Shutdown i
- Seven Inch Internal Pressure from One Inch Instrument Line Break Is Not Possible During l
Cold Shutdown
- Other Repairs Prevented Startup l
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~ ~~ Secondary Containment Lessons Learned 1
- Comed Understands Potential Significance ofIncorrectInformation
- To Avoid Inadvertent Errors in Verbal 1
i Communications, Need Greater Effort to l
Clearly Convey Bases for Conclusions L
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Quad Cities Station i
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Coupon Sample Tests Issue I
- Failure to Inform XRC of Coupon Sample Test Results on Corner Room Steel at April 11,1996 Technical Meeting 30 l
Quad Cities Station Coupon Sample Tests Factual Background XRC Reviewing Dresden Operability Evaluation for Corner Room Steel March 28,1996 Phone Call with NRC Regarding Operability of Quad Cities Steel
- NRC Requested Information on Several Issues, Including 10 % Overstress Factor April 1,1996 Quad Cities Letter 1
- Responded to Staff Questions -- Provided Analytical Basis and Stated Commitment to Repair Steel 31
Quad Cities StationCoupon Sample Tests Factual Background l
March 29,1996 -- Station Management Decided to Obtain Test Samples of Existiw Structural Steel
- Only Existing Samples were from Dresden
- Small Group of Samples Taken at Quad Cities
- Purpose of Testing was to Confirm Same Batch of Material Type (A-36) as Dresden, Not to Justify 10% Overstress 32 L
', l Quad Cities StationCoupon Sample Tests Factual Background April 1 and 2,1996 - Test Results Received
- Confirmed A-36 Steel Test Results Not Considered Material
- Not Statistically Valid Sample
- Results In Line with Expe.:tations -- Not Considered to Contradict April 1 Letter
- Other Conservatisms Remained Valid to Justify 10% Overstress i
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l Quad Cities StationCoupon Sample Tests Factual Background l
April 11,1996 Technical Meeting
- Many Technical Issues Discussed, Including Operability Calculations, Basis for Calculations i
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Coupon Sample Tests Lessons Learned
- Greater Sensitivity to the Need to Provide Bases for Conclusions to NRC 35
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Quad Cities Station Actions Taken Vendor Information -- Documentation and
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Verification Third-party Review of 10 CFR 50.59 Evaluations Establishment of Engineering Assurance Group Formal Review of Written Correspondence with XRC 37 i
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'l Quad Cities Station Actions Taken (Cont')
Training Completed l
- Engineering - Secondary Containment EnforcementIssues
- Station Supervisors - Briefed on Need for
" Complete and Accurate"Information
- Regulatory Affairs - Regulatory Interface Training 38
' ' - - - - - - ' - - ' ' - - ~ ' - - - ' - - - '
e Quad Cities Station Future Actions Training on 10 CFR 50.9 for selected personnel who interact with the NRC.
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- o Quad Cities Station Concluding Remarks E. S. Kraft, Jr.
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