ML20197F492

Forwards Insp Repts 50-254/97-27 & 50-265/97-27 on 971103-07 & 1204 & Notice of Violations.Three Apparent Violations Were Also Identified & Being Considered for Escalated Enforcement Action

ML20197F492
Person / Time
Site:	Quad Cities
Issue date:	12/23/1997
From:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Pearce L COMMONWEALTH EDISON CO.
Shared Package
ML20197F496	List: ML20197F492 ML20197F543 ML20197F574
References
50-254-97-27, 50-265-97-27, EA-97-591, NUDOCS 9712300232
Download: ML20197F492 (3)

See also: IR 05000254/1997027

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Docenter 23, 1997 .

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EA 97-591

Mr. L W, Pean's

Site Vice Presideni

Quad Cities Station

Commonwealth Edison Company

22710 206th Avenue North i

Cordova,IL 61242

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SUBJECT: NRC INSPECTION OF CODE CLASS 1 AND 2 PRESSURE TESTING -

INSPECTION REPORTS 50-254/97027 (DRS); 50-265/97027(DRS) AND

NOTICE OF VIOLATION

Dear Mr. Pearce:

On December 4,1997, the NRC completed an inspection at your Quad Cities Nuclear Power

Station. The purpose of the inspection was to review your activities related to the Unit 2

American Society of Mechanical Engineers (ASME) Code Class 1 pressure test performed at

power on June 22,1997. Further, this inspection included a review of ASME Code Class 1 and

2 pressure testing activities completed in pievious outages at your facility. The enclosed report

presents the results of this inspection.

Based on the results of this inspection, three apparent violations were identified and are being

considered for escalated enforcement action in accordance with the " General Statement of

Policy and Procedure for NRC Enforcement Actions"(Enforcement Policy), NUREG-1600. The

first apparent violation pe' tains to the failure to perform the Unit 2 ASME Code Section XI

Class 1 leakage test prior to taking the reactor critical. This issue is of significant concem to us,

because it demonstrated a lack of safety focus by your staff. In addition, your staff lack + me

fundamental knowledgeJnderstanding of the basis for this testing and the applicable rei 1ry

requirements. The failure to perform an adequate safety evaluation for this test was cora .ad

a second apparent violation, which led to the operation of Unit 2 without a fu,!y tested Class 1

syste m pressure boundary (an apparent unreviewed safety question).

The third apparent violation, involving five examples, pertains to missed or inadequate

comp!stion of ASME Code,Section XI, Class 1 and 2 pressure tests, which indicated a

programmatic breakdown in implementating of these requirements. This is of concern, as

failure to properly implement these requirements could result in an increased risk for pressure

boundary !sakage or failure at power, which would challenge operators and/or plant engineered

safety features.

No Notice of Violatbn is presently being issued for these apparent violations. In addition, be

advised that the numbc and characterization of the apparent violations described in the

. enclosed inspection report may change as a result of further NRC review.

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L. Pearce 2 December 23, 1997

An open predecisional enforcement conference to discuss these apparent violations has been

scheduled for January 8,1998. The decision to hold a predecisional enforcement conference

does not mean that the NRC has determined that violations occurred or that enforcement action

will be taken. This conference is being held to obtain information to enable the NRC to make

an enforcement decision, such as a common understanding of the facts, root causes, missed

opportunities to identify the apparent violations socner, corrective actions, significance of the

issues, and the need for las',ng and effective corrective action. In addition, this is an

opportunity for you to provide any 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 penalty that may be assessed la 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 Vll. You will be advised by

separate correspondence of the results of our deliberations on this matter. No response

regarding these apparent violations is required at this time During the pre-decisional

cnforcement conference, you should also address completeness and accuracy of test

documentation associated with the third apparent violation.

An unresolved item was identified herein pertaining to the methods used and short time taken

to complete the VT-2 examinations during the Unit 2 Class 1 leakage test on June 22,1997. At

the predecisional enforcement conference please provide information on this issue such that a

common understanding of the facts and significance of the issue can be established. This is an

opportunity for you to provide additional information concoming your perspectives on the

circumstances surrounding this unresolved item and to demonstrate that the applicable

regulatory requirements had been met. Further, we request that you , vide additional

information to demonstrate how VT-2 examination requirements have been implemented at

each of the Commonwealth Edison NRC licensed facilities.

In addition to the apparent violations being considered for escalated enforcement action, we

identified two violations of NRC requirements, which are being cited in the enclosed Notice of

Violation. The circumstances surrounding these 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 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

enclosures, and your response will be placed in the NRC Public Document Room.

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Pearce 3 Du e r 23, 1997

We will gladly discuss any questions you have conceming this inspection.

Sincerely,

/s/ J. Jacobson

John A. Grobe, Director -

Division of Reactor Safety

Dockets No. 50-254; 50-265

Licenses No. OPR-29; DPR 30

Enclosures: 1. Notice of Violation

2. Inspection Report 50-254/97027(DRS); 50-265/97027(DRS)

cc w/ encl: 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

1. Johnson, Licensing Operations Manager

Document Control Desk - Licensing

Quad Cities Station Manager

C.- C. Peterson, Regulatory Affairs Manager

Richard Hubbard

Nathan Schloss, Economist, Office of the Attomey General

State Liaison Officer

Chairman, Illinois Commela Commission

W. D. Leech, Manager of Nuclear, MidAmerican Energy Company

Distribution:

Docket File w/enci SRI, Quad Cities w/enci TSS w/enct

PUBLIC IE-01 w/enct LPM, NRR w/enci DOCDESK w/enci

OC/LFDCB w/enct A. B. Beach, Rill w/enci CAA1 w/enct

DRP w/enci J. L. Caldwell, Rill w/enct R. Zimmerman, NRR w/ encl

DRS w/enci Rill Enf, Coordinator w/ encl J. Goldberg, OGC w/enci

Rlli PRR w/enci R. A. Capra, NRR w/enci J. Lieberman, OE w/enci

DOCUMENT NAME: G:DRS\QUA97027.DRS

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OFFICE- Rlli l Rill , l- Rill lE Rllt lG Rill l J .

NAME MHolmberg:l# JGavulaMY MRing?V' '

BClayton 16(- J$49%d\

DATE 12/4/97 1_2/r,/97( 1249/97 12/u/97 124/W)

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- OFFICIAL RECORD COPY

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