ML20197F492
| 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: |
| References | |
| 50-254-97-27, 50-265-97-27, EA-97-591, NUDOCS 9712300232 | |
| Download: ML20197F492 (3) | |
See also: IR 05000254/1997027
Text
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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
SUBJECT:
NRC INSPECTION OF CODE CLASS 1 AND 2 PRESSURE TESTING -
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INSPECTION REPORTS 50-254/97027 (DRS); 50-265/97027(DRS) AND
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
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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
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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:
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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